ML20209E305
| ML20209E305 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 08/19/1986 |
| From: | Watters J BABCOCK & WILCOX CO. |
| To: | Crow W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 27336, NUDOCS 8609100210 | |
| Download: ML20209E305 (102) | |
Text
_
RETURN TO '396-5S k
Babcock & Wilcox E".*'*,",,10-a McDermott company P.O. Box 11646 Lynchburg, VA 24506 1646 (f44) 522-6000 August 19, 1986 M
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~3 United States Nuclear Regulatory Commission cn Attn:
Mr. W.
T. Crow, Acting Chief tn Uranium Fuel Licensing Branch Division of Fuel Cycle and Material Safety Washington, D.C.
20555
References:
(1) SNM-ll68, Docket 70-1201 (2) Letter from J.
P. Watters to W. T. Crow, dated 2-10-86 (3) Letter from N. Ketzlach to J.
P. Watters, dated 5-16-86 Gentlemen:
The Babcock & Wilcox Company, Commercial Nuclear Fuel Plant has requested amendment of SNM-ll68 as described in Reference 2.
This letter is written to address the questions on that amendment request as listed in Reference 3.
Attachment I to this letter lists the questions from Reference 3 along with our response.
All revised pages from SNM-ll68 originally submitted as Reference 2 are completely resubmitted for your approval and are included in Attachment II.
All revised pages keep the original 2-10-86 submittal date for consistency and they replace the existing approved pages of SNM-ll68 as follows:
SECTION I - Pages 3, 5,
7, 9, Appendix A - Pages 3, 4, 5, 9,
10, 11, 12 (Pages 11 and 12 are new pages).
SECTION III - Pages 44, 110, 112, 115, 119, 12G, 124, 129, 131, 190.
SECTION IV - Pages 1, 3, 4,
5, 6,
7, 10, 11, 12, 14, 21, 22, 23, 24, 25, 26, 27, 28, 29, 30, 31, 33, 34, 35, 36, 39, 40, 43, Appendix 1, Page 10.
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United States Nuclear Regulatory Commission Page 2 August 19, 1986 SECTION V - Pages 6, 7, 8,
11, 12, 13,;14, 15, 16, 18, 19, -
20, 21, 23, 28, 31, 42, 43, 49, 50, 51, 52, 53,-54, 55, 56,-57, 58, 59, 67, 68, 69, 70, 71, 72, 73, 74,. 75.
If there are any questions, please feel free to call me at (804) 522-6202.
Sincerely, BABCOCK & WILCOX COMPANY COMMERCIAL NUCLEAR FUEL PLANT
.b b J.
P. Watters License & Control Administrator JPW:cmr Attachments s
i ATTACHMENT I The following is a listing of each of the NRC questions as written in Reference 3, followed by the CNFP's response.
The same numbering system used in Reference 3 is maintained in Attachment I.
I.
1.
Provide an organization chart that clearly outlines the reporting chain for all safety-and production-related functions (e.g., production control, health-safety, quality assurance (QA), licensing, Safety Review Board, etc.).
See comment II 1.a below for additional details required.
An expanded organization chart is provided on Page 9 of Section I which gives individual names for the managerial positions and outlines the reporting chain for all safety and production related functions.
A similar chart is provided on Page 6 of Section V which highlights those positions relative to plant sat'ety including the Safety Review Board.
2.
Provide a resume for the Manager, Quality Assurance, that demonstrates his radiation and nuclear criticality experience.
An updated resume for the Manager, Quality Assurance is given on Pages 10-11 of Section I which expands on his experience and how it relates to radiation and nuclear criticality safety.
3.
Demonstrate that the new Chairman of the Safety Review Board (also Manager, Operations Support) is as aware of potential facility radiation safety problems as the former Chairman (also Manager, Materials and Facilities) who had radiation and nuclear criticality safety functions under his surveillance.
CNFP controls safety of operations under the following program:
i r
1 I.
3.
Continued The Safety Review Board is chartered to:
Review and determine acceptability of new or revised facilities, consider nuclear criticality, radiation, and occupational safety for both specific operations and general plant areas.
Assess the continuing effectiveness of established safety system controls, considering airborne concentrations, external radiation, surface contamination, and effluents, and considering any safety control discrepancies or audit findings, regardless of source.
Provide a forum for identification and discussion of safety related issues.
By design, the Safety Review Board formally establishes the safety controls for new or revised facilities, and monitors overall plant conformance to those controls through routine reports.
CNFP through the Quality Assurance organization then issues procedures, posts individual unit or local area safety rules, and trains personnel in the operational controls necessary for assuring compliance with controls established by the Safety Review Board.
Detailed operating procedures may be modified without convening the Safety Review' Board provided no previously established safety controls are changed a
(i.e., same nuclear safety and radiation safety controls apply).
Whenever a change is contemplated a
that will change the established nuclear safety cur radiation safety controls, the Safety Review Board must first approve the operation.
Thus, by routinely reviewing conformance to existing safety controls and by limiting the nature of procedural changes that can be made, the Safety Review Board continues to function with full knowledge necessary to effectively discharge its duties.
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I.
3.
Continued Further, having the Safety Review Board chaired by someone other than the Manager of Health-Safety, provides greater independence in establishing controls and in considering the effectiveness of the Health-Safety program.
II.
la.
Expand the organization chart to include the operating functions (e.g., health safety (including the technicians), nuclear safety, production control, nuclear materials control, accountability representative).
The chart, without individual names should be in the appropriate license conditions sections; that in a demonstration section with individual names.
This question is answered via the response given for j
Question I.1.
lb.
Remove the resumes of those whose positions no longer are a part of your organization (e.g., Health-Safety Foreman, Regulatory Control Manager).
The page replacement scheme as outlined on the cover letter should yield the proper page sequence for SNM-ll68.
For further clarification, the following is a listing of the resumes in Section I, Appendix A:
Page Resume Page Date Name 1
Richard A. Alto 5-04-84 2
Richard A. Alto 5-04-84 l
3 David W.
Zeff 2-10-86 i
4 David W.
Zeff 2-10-86 5
Donald V. Ferree 2-10-86
~
6 James P. Watters 5-04-84 7
Kenneth E.
Shy 5-04-84 8
Kenneth E. Shy 5-04-84 9
Bobby W.
Pugh 2-10-86 10 Wilfred T.
Engelke 2-10-86 11 Wilfred T.
Engelke 2-10-86 12 Gerald B.
Lindsey 2-10-86
)
9 O
II.
2.
a.
(Page 9) Identify the new position of James T.
Ford whose resume now appears on Pages 9 and 10.
If he still occupies a key role in a safety-related function, his resume should still be included.
Mr. J. T. Ford's position is the Fuel Manufacturing Manager and reports directly to the Manufacturing Manager, Mr. D. V. Ferree.
Mr.
Ford no longer occupies a key role in a safety-related function, therefore his resume was deleted from the 2-10-86 submittal.
Question II.lb outlines the resumes to be included in Section I, Appendix A of SNM-1168.
2.
b.
(Page 10) Identify the experience of the Manager, Quality Assurance, (QA) that qualifies him to approve health physics procedures and to.
authorize exposures that are greater than those allowed by 10 CFR Part 20 limits, etc.
See Question I.2 which describes the updated resume on Pages 10-11 of Appendix A of Section I for the Manager, Quality Assurance.
III.
1.
Provide justification for an apparent decrease in safety controls by replacing some of the functions of the former Regulatory Control Manager to the Health-Safety or the Health Physicist, and some of his functions to the Manager of QA.
Some of the functions performed by the former Manager, Materials and Facilities, are also assumed by the Manager of QA.
The functions of the former Health-Safety Foreman are also assumed by the Health Physicist.
Provide the support the Health Physicist has to perform all the indicated duties.
The safety controls in place with the new organization have not decreased from the previously approved organizational alignment.
In fact, the visibility or authority of the Health Physicist has been enhanced because he is now one organizational level closer to the Plant Manager which therefore provides a quicker.
avenue for resolution of potential safety concerns.
o III.
1.
Continued Additionally, the CNFP has added a Health-Safety Leader position which assumes the duties of the Health-Safety Foreman which provides support for the Health Physicist to adequately carry out the Health-Safety functions at the CNFP.
III.Section IV, Pages 12 and 25 2.
Identify who performs the specified services previously performed by the Health Physicist or the Health-Safety Foreman in the absence of the Health Physicist.
The CNFP has added the position of the Health-Safety Leader which assumes the duties of the Health-Safety Foreman.
The Health-Safety Leader will be the backup to the Health Physicist, as was the Health-Safety Foreman.
The position description for the Health-Safety Leader is included on Page 8 as Section 5.3.2.
The resume for the Health-Safety Leader is given'on Page 12 of Appendix A of Section 1.
IV.
Section V, Page 8, Section 5.3 la.
Clarify the references to the "section".
On Page 7, it is referred to as a " Group".
All references to "section" on Page 8 were changed to Health-Safety section.
Likewise the references to group were changed to Health-Safety section.
Ib.
Identify the experience of the Manager, QA, that meets the requirements of Section 5.3.2.
The updated resume for the Manager, Quality Assurance identifies the experience that demonstrates to the Plant Manager sufficient judgement and capability to establish and maintain an effective nuclear criticality and radiation safety program for the activities authorized by license.
Ic.
Correct the Revision Number of this page (Section V, Page 8).
It should be Revision Number 2.
IV.
Ic.
Continued Based on our records, the currently approved versions of Section V, Pages 7 and 8 are:
Section V Page 7 Revision 1 dated 5-04-84 Section V Page 8 Revision 0 dated 12-6-82 Therefore, the 2-10-86 submittal should indicate Revisions 2 and 1 for Pages 7 and 8 respectively.
2.
Page 12, Section 6.1 a.
Identify the position within Health-Safety that performs the periodic review of the recorded inspections.
i b.
If the position in 2.a above is the Health Physicist, clarify to whose attention he brings them.
Obviously, they should be brought to the attention of responsible supervision at a higher
- level, c.
Clarify the quarterly review of the air sample program records by the Health Physicist.
He evaluates the daily sample results.
The review should be made by a qualified person independent of the one who performs the evaluation of the daily results, d.
Identify the qualifications of the Manager, QA, to evaluate the adequacy of the contamination control, effluent levels, nuclear and radiation safety, and the license parameters.
e.
Explain how the Health Physicist can evaluate the inadequacy of contamination control or air effluent levels when he's the one responsible for their control.
Section V, Page 12, Paragraph 6.1 was revised to reflect the original organizational structure which utilized a Health-Safety Foreman, a Health Physicist, and a managerial function except that the Health-Safety Foreman is now known as the Health-Safety Leader.
The
IV.
2.
Continued original review chain as specified in Revision 2 of Page 12 (the current revision) is now reinstated in requested Revision 3 dated 2-10-86.
This should adequately address the concerns expressed in Question 2a, b, c, and e listed above.
The revised resume of the Manager, Quality Assurance (Page 10 of Section V) illustrates the qualifications necessary to carry out the functions as listed in Question 2d.
Additionally, the organizational structure which includes the Health-Safety Leader and a Health Physicist gives added strength to the Health-Safety Section at the CNFP.
3.
Page 13, Section 6.1.1 a.
Identify the position responsible for requesting Safety Review Board changes to existing procedures or new procedures, equipment, and facilities.
The Safety Review Board Chairman (Manager, Operations Support) no longer has the direct line of communications (as did the Manager, Materials & Facilities) with the surveillance performed by Health-Safety personnel.
The response given for Question I.3 gives detail on the Safety Review Board structure and responsibilities which demonstrates that the proper attention to plant safety will be maintained.
b.
Identify the permanent " technical management" membership on the Safety Review Board who is qualified to review the radiological safety of the proposed operation under review by the Board.
The Health Physicist is qualified to access the radiological safety implications of new or modified operations.
The Health Physicist can express these assessments in operational terms to the Manager, Quality Assurance and to the other Safety Review Board members.
The Safety Review Board can then appropriately review the proposed operation and make any necessary changes that will assure the operation will maintain the radiological safety consistent with the Health Physicist's assessment.
1
IV.
3.
Continued c.
Identify the qualifications of the Manager, Quality Assurance to act as Board Chairman.
These qualifications are ncted in the revised resume for the Manager, Quality Assurance (Page 10 of Section I).
4.
Page 18, Section 6.5 Provide justification for the replacement of-both the Manager, Materials & Facilities, and the Manager, Regulatory Control, by the Manager, QA, for the approval of Health-Safety Procedures.
i Originally, the Manager, Materials & Facilities and the Regulatory Control Manager (who reported directly to the Manager, Materials & Facilities) had control of both the NMC and Health-Safety responsibilities. 'The new organization eliminates the Regulatory Control Manager and splits the NMC and Health-Safety duties to the Manager, Production & Materials Control and i
Manager, Quality Assurance respectively.
This organization permits a more independent and direct managerial control over both functions.
For further justification, see the response given for Question III.1.
5.
Page 43, Section 8.1.2 Identify the qualifications of the Manager, QA, to authorize individual releases in the 21 percent to 75 percent MPC range.
These qualifications are noted in the revised resume for the Manager, Quality Assurance (Page 10 of Section-I).
i 6.
Page 47, Section 10.2.4 1
Confirm that access to the RCZ area requires both i
notification and approval of Health-Safety.
Originally, Section 10.2.4 indicated that notification and approval was required prior to entry to the RCZ.
We are requesting that this indicate "be controlled by
IV.
6.
Continued Health-Safety".
The intent is to control access to the RCZ area so as to not spread contamination to other plant areas and to prevent unauthorized personnel from entering the RCZ.
The revised Section 10.2.4 still provides a means to control RCZ access and to deny access to the RCZ if necessary.
Additionally, a statement was added that requires visitors to the RCZ be accompanied by authorized personnel.
Control of RCZ access in this fashion will maintain the personnel and plant safety required for the ECHO-330 operations.
7.
Page 68, Section 10.2.5 Confirm that Radiological surveys shall be performed as contaminated ECHO-330 equipment is unloaded and prior to transport to the RCZ area.
This change is requested simply out of practicality and will in effect enhance the radiation and contamination-safety surrounding the ECHO-330 equipment.
As written, we have to perform receipt surveys before the equipment is taken to the RCZ area which yields a higher potential for contamination spread outside of the RCZ and to the environment because the equipment is exposed to the environment during the surveys.
If the surveys are performed after the ECHO-330 equipment is placed in the RCZ and before any handling or maintenance operations, any potential contamination or radiation hazard would therefore be limited to the RCZ area which is equipped to handle the potential Health-Safety Concerns.
8.
Page 68, Section 10.2.6 i
Confirm that contaminated equipment that exceeds radiation control zone limits shall be immediately l.
decontaminated or transported to a facility that can I
receive such contamination.
l As with Question #7, this change is requested out of practicality and enhances the Health-Safety program for.
the ECHO-330.
We requested that "or transported to a facility that can receive such contamination" be deleted because if the ECHO-330 equipruent contamination exceeds the limits, there would be a greater potential for contamination spread due to the increased handling from repackaging and transport to an authorized facility.
The CNFP has the capability to properly perform the decontamination of the equipment if necessary, therefore the transport option is not needed.
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9.
Page 68, Section 10.2.8 r
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Confirm the radiological surveys of the RCZ shall be performed at least daily on the contaminated equipment-during periods of maintenance and as necessary throughout the maintenance activity, i
This change is requested to provide a more realistic-means to identify potential contamination spreads in i
the RCZ.
As written, Section 10.2.8 states that the l
surveys shall be performed daily on the contaminated i
equipment which will not identify a potential contamination spread within the RCZ.
A survey of the.
RCZ area will however show if a contamination spread has occurred from the contaminated ECHO-330. equipment within the RCZ which will enhance the Health and Safety of the personnel working within the RCZ.
10.
Page 68, Section 10.2.9 This section should be included in your replacement page.
It appears to have been inadvertently left out.
Renumber the remaining sections in Section 10 as needed.
4 Section 10.2.9 is replaced'on Page 68 but was modified to indicate that the weekly surveys are' performed on the RCZ rather than the contaminated equipment.
The-same justification for Question 9 concerning surveys on the RCZ as opposed to surveys'on the contaminated equipment applies to Question 10.
Also, the sections-following 10.2;9 were appropriately renumbered.
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ATTACHMENT _II
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BABC0(X & WIL(DX C0FPANY, C0ftERCIAL NUCEAR REL PLAff USNRC LICENSE SNM-ll68 DOCKET 70-1201 SECTICN I - GENEPsAL INFORMATION Tt. Connercial Nuclear Fuel Plant has been established for the purpose of fabricating fuel assemblies for commercial utility reactor cores.
- 1) Name of Applicant 1
Babcock & Wilcox Company Commercial Nuclear Fuel Plant
- 2) State of Incorporation Babcock & Wilcox is a segment of McDermott, Incorpcrated, and is organized and exists under the laws of the State of Delaware.
- 3) Addresses of Principal Offices Babcock & Wilcox Op'erating Unit, McDermott Incorporated 1010 Common Street P. 0. Box 60035 New Orleans, Louisiana 70160 Babcock & Wilcox Commercial Nuclear Fue1 P1 ant P. O. Box 11646 Lynchburg, Virginia 24506-1646 DATE 2.-10-86 REVISION NO, 1
PAGE 3
CURRENT REVISION:
2 1 0
DATE REVISION
BABC00( & WILCDX C0f##, ONERCIAL NUCLEAR REL PLAT USNRC LICENSE SNM-ll68 DOCKET E.1201 I - GENERAL INFORMATION SECTICN 10 CFR 70.22 (a)(4)
Name Low (4.05%) enriched uranium oxide Uranium as low enriched UF6 Uranium as natural UF6 Depleted or natural uranium oxide By-product material SNM as Pu and Cf sealed sources Amount This application rer,uests authorization for:
235
- 25,000 Kg 0 in powder or pellet form 235
- 5,000 Kg U as enriched UF f r storage only 6
- 3,000,000 lbs. uranium as natural UF f r storage only 6
- 20,000 Kg depleted or natural uranium oxide as powder or pellets 235
- Up to'100 grams U in any form Specifications
- Up to 51 ci by-product material as sealed sources
- By-product material in contamination quantities on returned, unirradiated fuel assemblies
- Up to! 6' grams encapsulated plutonium
- Up to 3.0 mg Californium - 252 as sealed sources
- Up to 0.1 curies of by-product material as contamination ***
n equipment or as waste 10 CFR 70.22 (a)(6)
Technical qualifications, training, and experience are shown in Appendix A of this section.
Description of equipment and facilities to protect health and ' property is provided in Section III and IV.
Procedures to provide for protection of health and property due to accidental criticality are provided 1
5 DATE 2-10-86 REVISION NO.
PAGE ClRRENT REVISION:
5 P
WERS E S 29,g 0
DATE REVISION i
BABC00( & WIL(DX C&PW, QMERCIAL NlX1 EAR REL Pl#T USNRC LICENSE Stet-ll68 DOCKET F1201 I - GENERAL INFORMATION FIGURE 1 SEGIm
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PAGE 7
CLERENT REVISION:
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SUPERSEDES: PAGE 7
USNRC NE EN I
DATE 5-04-84 REVISION
BAB0XX & WILCDX CGPANY, C0WERCIAL NUQER REL PLAff 1
USNRC LICENSE SNft-ll68 DOCKET h l201 SECTICN I - GENERAL INFORMATION FIGURE 3 l
l l
i COMMERCIAL NUCLEAR FUEL PLANT R. A. Alto Plant Manager
~
l OPERATIONS MANUFACTURING SPECIALTY QUALITY PRODUCTION AND i
SUPPORT MANUFACTURING ASSURANCE MATERIALS CONTROL D. V. Ferree D. W. Zeff Manager C. A. Moore W. T. Engelke B. W. Pugh Manager Manager Manager Manager Tafn matica tarvices Health Product 1on nysicist '
control SAFETY REVIEW BOARD Heal th-Sa fety Nxlear leader Meterials controt' Mealth-$4fety Monitors
- The Safety Review Board Chairman is the Manager of.0perations Support.
The permanent membership of the Board shall consist of representatives of CUFP operational and technical management.
DATE 2.10-86 REVISION NO.
3 PAGE 9
CtRRENT REVISION:
SUPERSEDES: PAGE 9
2 N N E REFE m 2-04-85 MTE REVISIm
B/EC00( & WILODX C0FP#lY, C0ffERCIAL,1UCLEAR REL PLAIT USNRC LICENSE SNM-ll68 DOCKET 70-1201 I - GENERAL INFORMATION SECTICN NAME:
David W. Zeff TITLE:
Manager, Operations Support, CITIZEN OF UNITED STATES EDUCATION:
1972 University of Wisconsin - B.S. Physics 1973 Purdue University - M.S. Industrial Administra-tion EXPERIENCE:
1973-1974 Planning analyst, Babcock & Wilcox Company, Lynchburg, Virginia.
Responsible for capital appropriation requests, market analysis, acquisition analysis, advanced planning, P & L anaiysis, cash flow analysis, etc.
1974-1978 License Administrator, Babcock & Wilcox Company, Commercial Nuclear Fuel Plant, Lynchburg, Virginia.
Responsible for licens-ing activities associated with nuclear fuel assembly plant, interpretation and applications of NRC regulations, measurement control pro-grams, and statistical methods application in Nuclear Materials Control.
1978-1982 Manager, Health-Safety and Licensing, Babcock and Wilcox Company, Commercial Nuclear Fuel Plant, Lynchburg, Virginia.
Responsible for all safety and licensing activities associated with nuclear fuel assembly plant.
1982-1983 Manager, Materials Management, Bab' cock and 1
Wilcox Company, Commercial Nuclear Fuel l
Plant, Lynchburg, Virginia.
Responsible for
'i license administration, Safety Review Board, safeguards, and production control activities.
l 1983-1985 Manager, Materials & Facilities, Babcock and
- l Wilcox Co., CNFP, Lynchburg, Va. Responsible for all Regulatory Control activities includ-ing safety, licensing, compliance, safeguards, and nuclear materials control, plus production planning & control, and facility engineering functions.
I DATE 2-10-86 REVISION NO.
2 PAGE 3 CURRENT REVISION:
SUPERSEDES: PAGE Appendix A, Page 3 USNRC APPROVAL REFERENCE 1
DATE 5-04-84 REVISICf1
BABCDO( & WILCDX C&P#f/, CGTERCIAL NUCLEAR REL PLATT USNRC LICENSE SNM-ll68 DOCKET 70-1201 l
SECTICN I - GENERAL INFORMATION EXPERIENCE:
1985-Present Present Manager, Operations Support at B&W's CNFP.. Responsible for Safety e
Review Board, NRC licensing, automation, and computer support.
Professional Organizations - Institute of Nuclear Materials* '
- Management 2
DATE 2-10-86' REVISION NO.
2 PAGE4 CtRRENT REVISION:
SUPERSEDE 5: PAGE Append ~ix'A, Page 4'
~
DATE 5-04-84 1
REVISIQ1
PAC 0C< & WILCOX CCFPAf/, C0ftERCIAL NUCEAR FLEL PLAIT USNRC LICENSE SNM-1168 DOCKET 70-]201 I - GENERAL INFORMATION SECTION NAME:
Donald V. Ferree TITLE:
Manager, Manufacturing CITIZEN OF UNITED STATES EDUCATION:
1967 Ohio State University - B.S. Physics 1972 University of Tennessee - M.S. Physics EXPERIENCE:
1967-1972 Associate Physicist, Union Carbide Corp.,
f Nuclear Division, Y-12 Plant.
Responsible for R&D in NDE methods of UT, RT, and other i
radiation techniques.
1972-1974 Senior Research Engineer, B&W, LRC.
Respon-sible for R&D in NDE methods of UT and ET.
1974-1979 NDE Manager, QC Manager, QA Manager, B&W, Mt. Vernon Works.
Responsible for produc-tion NDE, dimensional inspection and all QA.
1979-1981 QC Manager, Pullman Std., Bessimer, Alabana, and Butler, Pennsylvania.
Responsible for all QC/QA in rail freight car plants.
J 1981-1982
' Supervisory Engineer, B&W, NPD-SPIS.
Responsible for NDE at nuclear sites.
1982-1983 Nuclear QA Manager, B&W, UPGD.
Responsible for all nuclear QA for division.
1984-1985 Manager of Special Projects, B&W, CNFP.
Responsible for ASME Code QA Manuals and l
j ECH0-330 development.
1985-Present Manager of Manufacturing, B&W, CF7P.
Responsible for all fuel and specialty manufacturing and manufacturing engineer-ing at the CNFP.
Professional Organization - ASME 1
ppCil IA DATE 2-10-86 REVISION NO.
2 PAGE 5
CURRE?fr REVISION:
SUPERSETEs: PAGE Appendix A, Page 5 p
5-04-84 1
DATE pggggy
BABCDCK & WIL(DX C&PM, C@tERCIAL NUCLEAR REL PLM USNRC LICENSE SNM-ll68 DOCKET M-1201 SECTIm I - GENERAL INFORMATION
,i NAME:
Bob W. Pugh TITLE:
11anage~r, Production & Materials Control CITIZEN OF UNITED STATES EDUCATION:
1963 Phillips Business College - Cata Processing EXPERIENCE:
1969-1970 Production Sponsor Jr., Babcock & Wilcox Company, Commercial Nuclear Fuel Plant, Lynchburg, Virginia.
Responsible for requisiting and monitoring Contract Materials.
1970-1975 Production Sponsor, Babcock & Wilcox Company, Lynchburg, Virginia.
Responsible for Materials Control Function.
1976-1983 Supervisor, Materials Control, Babcock & Wilcox Company, Lynchburg, Virginia.
Responsible for f:1aterials Control, Stores, and Shipping and Receiving Functions.
1983-1985 Man &ger, Special Projects, Babcock & Wilcox Company, Lynchburg, Virginia. Responsible for all special project activities.
1985-Present Manager, Production & Materials Control, Babcock &
Wilcox, Lynchburg, Virginia.
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Appendix A DATE 2-10-86 REVISI m NO.
2 PAGE 9 CURREtNREVISION:
r
>t SUPERSEDES: PAGE Appendix A, Page 9 USNRC APPROVAL REFERENCE i
DATE 5-04-84 ggygg gg.
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BABC00( & WILODX C&PA#, CatERCIAL NUCLEAR REL PLK1T USNRC LICENSE SNM-ll68 DOCKET 70-3201 I-GENERAL INFORMATION SECTICN NAME:
Wilfred T. Engelke TITLE:
Manager, Quality Assurance CITIZEN OF UNITED STATES EDUCATION:
1959 University. of Maryland - BSME '
EXPERIENCE:
1959-1960 Engineer, Reaction Motors Division, Denville, New Jersey, in design and test of solid and liquid rocket engines.
i 1960-1962 Engineer, Chrysler Missile Division, Huntsville, Alabama, involved in design and fabrication in heat transfer instrumentation for the saturn missile.
1962-1974 Research Engineer, Southern Research Institute, Birmingham, Alabama, performing heat transfer research and thermal characterization of materials.
Promoted to Head of Applied Thermal Section.
1974-1977 Engineering and Plant Manager, Tech Air Corporation, Atlanta, Georgia.
Involved in the development, design, installation, and operation of a pyrolysis waste neutralization process, supervised operational crew in development work and around the clock opera-tion of the unit.
1977-1985 Manager, Manufacturing Engineering, Babcock & Wilcox, Lynchburg, Virginia, managed the Manufacturing Engineering Section.
Responsible for process engi-neering, technical documentation issuance, qualifi-cation and development of manufacturing operations in the fabrication of nuclear fuel elements. Also managed Information Services Section, responsible for the computer data processing and information systems. Also served as a member of the Safety Review Board.
1985-Present Manager, Quality Assurance, Babcock & llilcox, Lynchburg, Virginia. Manage Quality Assurance and Health and Safety-Departments.
Responsible for functions.of inspection, data evaluation, radiation and industrial safety. Continued to serve as a member of the Safety Review Board.
Appendix A DATE 2-10-86 REVISIQ4 NO. 2 PAGE 10 CURRENT REVISION:
SUPERSEDES: PAGE Appendix A, Page 10 DATE 5-04-84 1
REVISIQi
BABC0CK & WILGE COWAi#, C0ffERCIAL NUCLEAR PEi PLM USNRC LICENSE SNM-ll68 DOCKET 70-1201 SECTim I - GENERAL INFORliATION 1
GENERAL:
Experience'at B&W since 1977 has been in the management and direction of a variety of manufacturing and quality ' processes, operations, and procedures.
This has required a basic under-standing of nuclear criticality and radiation safety since the safety program at the CNFP impacts the entire plant operations. This has qualified him to manage the health safety organization at the CNFP which has within it a Health Physicist and a Health-Safety Leader that can provide indepth technical assessment as needed.
J l
(
J I
O DATE 2-10-86 REVISION NO.
PAGE j
CURRENT REVISION:
SUPERSEDE 5: PAGE USNRC APPROVAL REFERENCE DATE REVISICtl
t BABC00( & WILOR C0FPM/, C0fTERCIAL NUCLEAR FUEL PLAff USNRC LICENSE SNM-ll68 DOCKET 70-1201 SECTICN I - GENERAL INFORMATION NAME:
Gerald B. Lindsey TITLE:
Health-Safety Leader CITIZEN OF THE UNITED STATES EDUCATION:
1975 Graduate of Virginia Polytechnic Institute and State University, Blacksburg, Virginia - B.S. in Biology CVCC Emergency Medical Technician,110 hours0.00127 days <br />0.0306 hours <br />1.818783e-4 weeks <br />4.1855e-5 months <br /> (coordinated through Blue Ridge Emergency Medical Service)
EXPERIENCE:
1969-1976 Lynchburg General Hospital Emergency Room.
Duties include vital signs, emergency aid, patient care.
1976-1983 Babcock & Wilcox Company, Commercial Nuclear Fuel Plant.
Employed as a QA lab technician - 5 years; Health-Safety Monitor - 2 years.
1983-1985 Babcock & Wilcox Company, Lynchburg Research Center.
Employed as a H.P. Surveyor for the Building C. Decommissioning Project.
'Oct. 1985-Babcock & Wilcox Company, Commercial Nuclear Fuel April 1986 Plant. Employed as a Senior Health-Safety Monitor.
April 1986 -
Present Babcock & Wilcox Company, Commercial Nuclear Fuel Plant.
Employed as Health-Safety Leader.
Duties include standard review and implementation, safety training program, plant safety audi'ts, procedure writing, accident investigations.
w l
Appendix A DATE 2-10-86 REVISICN NO.
O PAGE 12 CURRENT REVISION:
SUPERSEDES: PAGE USNRC APPROVAL REFERENCE DATE REVISICN
BABOXX & WIL(DX C&PANY, COMECIAL NinEAR REL PLAT USNRC LICENSE SNM-ll68 DOCKET M.1201 III NUCLEAR SAFETY ANALYSIS SECTIO 4 7.4 Pelletizing 7.4.2.i.U_0 powder Receipt (continued) 2
~
ttst.
i z
i 2
1 4
s c
Contents of pc. uter tontatact: 3 g/cc t:3 da do 40 to en g
larlshmnt v/o L.0 40 43 to do do E/U-0.6 0.6 0.6 7.24 7.24 7.24 Interspersed roderatica (:)
0 7,
100
'O 7
100 Itif
.222 1.004
.G7G 1 0.012 0.5 % 1 0.010 0.9 2 0.011 1.C18
- 0.011 0.925 1 0.01 The above results indicate that, except in the case where all available space in all the powder containers is filled with moderator and 7% interspersed moderation is present (Case 5), K-effectives are acceptable. The situation calculated in Case 5 is not credible due to powder pack-aging techniques and moderation controls established for the pelletizing area.
The limitation on the number of vertical containers in the sampling' area is assured by physical sampling and conveying equipment li.mitations as well as by operator work area requirements.
Powder containers are visually inspected upon receipt.
Containers exhibiting damage that could have resulted in violation of internal packaging are set aside on the loading dock for Health-Safety inspe~ctio'n'." Upon~
~
Health-Safety determination that the container has not been breached so as to allow internal moderation the coa-lPAGE DATE 2-10-36 REVISICH NO.
2 i
44 CLRRENT REVISION:
44 SUPERSEDES: PAGE memgem 5-04-84 1
DATE REVISION l
A 4
6 BAB(DO( & WIL(DX CTPANY, COWERCIAL NUCLEAR REL PLM WNRC LICENSE Snit-ll68 DOCKET 70-1201 III NUCLEAR SAFETY ANALYSIS SECTICN 7.4 Pelletizing 0 ransfers Between Moderation Controlled Units (cont'd) 7.4.4.4 T
ports, etc. Additionally, blind flanges, screw type caps, or other equally effective measures are utilized to provide secondary protection of penetrations into the blender and transport container at all times when such penetrations are not in use.
When empty, process equipment normally operated under moderation control limitations is maintained in a closed and sealed condition and is inspected prior to returning to use.
Gloveboxes or other effective enclosures are utilized as necessary to preclude external moderation of SNM where the unit itself does not provide the necessary protection (slug press) or where;, such as in blender loading, the use of positive connections is not feasible. Where practicable, such e1 closures shall
. be of metal. When visibility or other operating requirements dictate their use, plastics or other hood. materials are of fire resistant construction
(. chlorinated PVC or equivalent).
7.4.4.5 Admininistrative Controls and procedures Approved ' Health-Safety and process procedures ~~
~
DATE 2-10-86 REVISION No.
2 PAGE 110 CURRENT REVISION:
SUPERSEDESi PAGE 110 WNRC APPROVAL REFERENCE 5-04-84 I
MTE REVISION
BABUXX & WILODX C0WANY, CutERCIAL NlnEAR REL PIM USNRC LICENSE SNM-ll68 DOCKET 70-]201 III NUCLEAR SAFETY ANALYSIS SECTICH 7.4 Pelletizing 7.4.4.6hModeration Control Measurements (continued)
OPERATOR QUALIFICATION Personnel responsible for measuring moisture content of UO will be trained in equipment operation and 2
result interpretation. Such training will include practical use of the instrumentation and satisfactory analysis of unknown samples. Operation of moisture analysis units will be limited to authorized personnel. Authorized operators will be determined by the area supervisor.
PROCEDURES AND CHECK LISTS Specific procedures covering the u'se of moisture analysis equipment, approved by Health-Safety, will be maintained at the work station. Additionally, the actual process is conducted in accord with a
" check-list" indicating the operational sequence,
. development of analytical data, and the operator performing the analysis.
Points where " standard samples" are analyzed and the action to be taken in the event of an unsatisfactory standard result are indicated.
2-10-86 112 DATE REVISION NO.
2 PAGE CURRENT REVISION:
SUPERSEDES: PAGE 112 USNRC APPROVAL REFERENCE 5-04-84 I
DATE REVISION
BABC00( & WIL(DX CTPANY, COMMIAL NtX1 EAR REL PLAVf USNRC LI NSE Snit-ll68 DOCKET &l201 III NUCLEAR SAFETY ANALYSIS SECTICN 73 Pelletizing l
7.4.4.7 ' Administrative Controls (continued) 1.
those in the process which require dual signature:
- Initial moisture analysis of as-received powder
-- Prior to addition of powder lubricant to blender or transport container
- Prior to addition of re-cycle material to a moderation controlled unit, if the ma-terial has been exposed to an uncontrolled environment.
Adherence to the above procedure will be audited by Health-Safety at least monthly.
2.
The addition of powder lubricants to the blender or transport codtainer has been shown to be safe under credible accident conditions.
However, in order to further preclude the potential for double batching of lubricant, or of adding lubricant to a system where the existing H/U is such that the additional moderator would cause the system to exceed the 0.45 H/U license specification, administrative controls are established for the receipt, storage, and DATE 2-1U-86 2
REVISION NO.
PAGE 115 ClRRENT REVISION:
SUPERSEDES: PAGE 115 USNRC APPROVAL REFERENCE 1
DATE 5-04-84 REVISIm L
BAB000( & WILG)X OFANY, C0WERCIAL NlX1 EAR REL PLM USNRC LICENSE SNM-3168 DOCKET &l201 III NUCLEAR SAFETY ANALYSIS SECTIQ4 7.4 Pelletizing
.7.4.4.8 General Area Moderation Control Criteria (continued)
In the event it becomes necessary to utilize " wet" decontamination techniques on a moderation controlled units, Health-Safety shall inspect and certify that visible moisture is not present before the unit is returned to service.
FIRE FIGHTING Specific procedures relative to fire fighting will be instituted and will include, as a minimum, the following considerations:
A.
Fire fighting capability will be based on the use of CO, "Halon" or other non-hydrogeneous-2 agents.
B.
TheCNFPFirhBrigadewillbeinformedofarea restrictions and will receive training in the techniques to be utilized.
C.
All fire fighting efforts will be conducted under the direction of qualified members of the plant management.
D.
Accumulation of flamables will be limited to i
the greatest practical extent.
2-10-86 DATE REVISION NO.
2 PAGE 119 CURRENT REVISION:
SUPERSEDES: PAGE 119 m mg gm 5-04-84 I
DATE REVISION
BABC00( & WILG)X COW #A', 00ftERCIAL NUCLEAR REL PLAYT USNRC LICENSE SNM-1168 DOCKET 70-1201 SECTICN III NUCLEAR SAFETY ANALYSIS
~
7.4 Pelletizing 7.4.4.86 General Area Moderation Control (continued)
FIRE FIGHTING E.
The area contains no source of generalized mo-deration such as sprinkler systems, or steam lines.
Flammable wastes will be stored only in metal containers approved by Health-Safety.
WATER LINES Figure 1 shows the placement of water lines in the pelletizing area relative to moderation-controlled and other major equipment positions. Water lines are, except where necessary to service equipment, located against (e.g., s 1 foot) the outer building walls approximately 20 feet above the floor and are l
secured.in place by means of steel brackets.
1 For purposes of industrial safety, and to limit the potential for accidental damage, the water lines
'necessary for furnace and grinder operation are po-sitioned above head height until the unit to be serviced is reached.
The typical baffling technique for service lines positioned along the plant walls is represented DATE 2-10-86 REVISION NO.
2 PAGE 120 CtRRENT REVISION:
SUPERSEmS: PAGE 120 USNRC APPROVAL REFERENCE DATE 5-04-84 REVISION -
1
l l
BABC0CK & WILCOX QPP#ff, CafERCIAL NUCLEAR REL PLM l
USNRC LICENSE SNM-ll68 DOCKER F 1201 III NUCLEAR SAFETY ANALYSIS SECTIO 4 7.4 Pelletizing 7.4.4.8;' Unit Area Moderation Control (continued)
WATER LINES directly over moderation controlled units or arrays, the overhead shielding essentially serves as a tech-nique for providing "second order" protection. The i
shielding is not required to protect the array from accidental moderation due to pipe rupture since that contingency has been provided for through baffling and double containment.
PERIODIC EVALUATION OF MODERATION CONTROL EQUIPMENT The routine calibration and standards analysis pro-gram for moderation control instrumentation has been described previously. While safety within an orierational area is the responsibility of the area supervisor, Health-Safety conducts routine system audits to verify that all activities are conducted
' safely and in accord with license conditions.
Additional nuclear safety and health physics audits are conducted by qualified B&W personnel, from outside the CNFP, at least quarterly.
At least monthly, a detailed inspection will be con-ducted by Health-Safety, DATE 2-10-86 REVISION NO.
2 PAGE 124 ClRRENT REVISION:
SUPERSEDES: PAGE 124 WNRC NE EFEENCE 1
DATE 5-04-84 REVISION
BABC00( & WIL(DX CTPANY, CutERCIAL NUCLEAR REL PLAT USNRC LICENSE SNM-ll68 DOCKET D-1201 III NUCLEAR SAFETY ANALYSIS SECTICN 7.4 Pelletizing
?
7.4.5.1 FIRE. The following measures are applied to minimize the fire potential and to assure localized containment in the event a fire does occur.
1.
Hoods, gloveboxes, and other containment devices are constructed of fire resistant materials ("Self-extinguishing " Plexiglas" conforming to ASTMD 635,"
or equivalent) with metal supporting members.
2.
Pre-filters and HEPA units are the fire resistant metal case type. Additionally, supporting units and manifolds are of flame resistant construction.
Breaching of the ventilation system is not credible due to the limited flammable material available.
3.
Accumulations of flamable wastes and scrap are removed from the area promptly when containers are filled.
Only covered fire-safe containers approved by Health-Safety are utilized tor' the accumulatio~n of flammable wastes in the pelletizing area.
4.
Limited quantities of flammable solvents may be required for operation. These materials are
~
DATE 2-10-86 REVISION NO.
2 PAGE 129 CLERENT REVISION:
SUPERSEDES: PAGE 129 USNRC APPROVAL REFERENCE DATE 5-04-84 REVISION 1
BABC00( & WIL(DX CTPANY, C0WERCIAL NUClfAR REL PLM USNRC LICENSE SNWll68 DOCKET 70-1201 III NUCLEAR SAFETY ANALYSIS SECTIO 4 7.4 Pelletizing 7.4.5.1., FIRE.
6.
While Brigade members are cognizant of the radiological and nuclear safety limitations that may be imposed, any major fire fighting activity would be conducted under the direction of responsi-ble plant management (e.g., except 1st aid measures).
Brigade members receive semi-annual training by representatives of Health-Safety as appropriate to the subject matter.
7.
Formal weekly inspections are conducted by Heal th- ***
Safety to monitor the effectiveness of, and ad-herence to, the fire prevention ; Jgram.
8.
Response arrangements have been made with the Con-cord Volunteer Fire Department. The Lynchburg Fire Department and the Concord Volunteer Fire Department have toured the CNFP facilities and have been made aware of special hazards that may be encountered.
Retraining is conducted on an annual basis.
Based on the above considerations, as well as the limited potential for fire within the process itself, it is felt that fires represent only a limited accident potential.
The most likely hazard will consist of DATE 2-10-E6 REVISION NO.
2 PAGE 131 ClRRENT REVISION:
SUPERSEDES: PAsE 131 uSNRC NE REFERENCE I
DATE 5-04-84 REVISION
q BABC00( & WILCDX CTPANY, C0WERCIAL NUCLEAR REL PIAT USNRC LICENSE SNM-ll68 DOCKER E-1201 III NUCLEAR SAFETY ANALYSIS
~
SECTICH 7.14 Waste Storage 7.14.2 Nuclear Safety Parameters The safety of both 850 grams of U-235, and the 4.0" slab has been demonstrated elsewhere.
7.15 Self-Explanatory.
i 7.16 Transport 7.16.1 Such transport occurs only during the course of manufacturing activities, at which times abnormal levels of moderation are not present, interaction with other materials need not be considered.
7.17 UF Storage 6
7.17.1 Storage Parameters - Source and Special Nuclear Material The UF, as received for storage only, will be in solid form 6
and stored in cylinders that are approved for shipment.
The cylinders will be stored outside, in an area designated for
.UF storage within the CNFP security fence. The cylinders will 6
be stored on timbers designed to cradle and give support, in an area prepared and maintained under weed control, and located a minimum of 100 ft. from the paved driveway which circles the' CNFP.
The cylinders will be equipped with valve protectors, and will be routinely monitored by. Health-Safety personnel to detect leakage and to assure the continued adequacy of storage conditions.
Outside storage of enriched UF cylinders has been 6
previously determined to have no adverse environmental impact (Reference 1).
Reference 1: BAW-1412, Annex 1; UF to 00 Conversion Facility.
6 2
DATE 2-10-86 REVISION NO, 2
PAGE 190 CLEREFE REVISION:
SUPERSEDESi PAGE 190 LENRC APPROVAL REFERENCE 5-04-84 1
DATE REVISION
BAB000( & WILCDX C&PANY, COMERCIAL NUQIAR REL PLM USNRC LICENSE SNM-ll68 DOCKET hl201 IV HEALTH PHYSICS SECTICN 1'
INTRODUCTION This section pres ~ents the health physics program which is adminstered at the Commercial Nuclear Fuel Plant of the Babcock & Wilcox Company to assure safe operating conditions.
The information provided in this section is intended to demonstrate typical methods utilized in the i
health physics and, to some extent, in the industrial safety programs and, as such, is subject to change in detail, or in the application of alternate methods.
Program effectiveness will not be reduced as a result of changes instituted by plant management. Technical specifica-i tions defining the parameters which the health physics program must meet are contained in Section V.
2.
POLICY Operations involving exposure, or potential exposure, to radioactive materials will be performed in a manner which will assure the radiation safety iof employees and the general public.
This policy is implemented by maintaining a staff of qualified personnel and appropriate equip-ment, procedures, and records.
Operations will be conducted in accordance with applicable Federal, State, and Local requirements.
Exposures to radioactive materials, or other hazards, will be maintained as low as reasonably achievable.
Health-Safety has the authority to stop hazardous or potentially hazardous operations until correction or resolution by plant management is obtained.
i l
DATE 2-10-86 REVISION NO.
2 PAGE 1 CURREfR REVISION:
SUPERSEDES: PAGE l
USNRC APPROVAL REFERENCE 5-04-84 1
MTE REVISION
BAB000( & WILODX C0W#h', CutERCIAL N(JClfAR REL PIM USNRC LICENSE SNPt-ll68 DOCKET 70-1201 IV HEALTH PHYSICS SECTION Detailed operating procedures are developed by Health-Safety to 3.3 assure standardization, accuracy, and effectiveness of activities Heal th-Safety.
performed y _
Procedures are reviewed periodically and revised as required.
As a minimum, Health-Safety procedures shall be approved in writing i* "
by the Manager, Quality Assurance as well as approval by affected members of plant management.
- r 4.
RESPONSIBILITIES The Health-Safety.Section reports directly to the Manager. Quality Assurance who reports directly to the Plant Manager of the Commerchl Nuclear Fuel Plant.
4.1 Health-Safety Section Health-Safety personnel are responsible for the general surveil-lance of all activities involving radioactive materials, distributing and processing personnel monitoring equipment, maintaining in-dividual exposure records, notifying supervisors of significant exposure levels, and recommending appropria,te restrictions.
Other responsibilities are represented by, but not limited to, the following:
a.
Maintaining appropriate radiological and regulatory control of radioactive material, shipments, and receipts.
b.
Supervising and coordinating the contaminated waste disposal program.
c.
Assisting in personnel and equipment decontamination.
~2 3
MTE 2-10-86 REVISION NO.
PAGE ClRRENT REVISION:
SUPERSEDES: PAGE3 USNRC APPROVAL. REFERENCE 5-04-84 l
MTE REVISIW
_,.._-_,.~n,
- -., -. -. - - -,,., _.n
BABC00( & WIL(DX C0WANY, COMBCIAL NlX1 EAR REL PIKT USNRC LICENSE SNtt-1168 DOCKET 70.1201 IV HEALTH PHYSICS SECTICN 4.1 d.
Orienting and training CNFP parsonnel in radiological and n,uclear safety.
e.
Furnishing consulting services and advice on radiation protection to plant supervision and management.
f.
Generating or acquiring, maintaining, and appropriately distributing all records and reports required by appli-a cable regulations or procedures.
g.
Leak testing on sealed radioactive sources.
h.
Developing and disseminating procedures related to radiation safety and reviewing procedures prepared by other operating sections for regulatory compliance and the adequacy of safety considerations.
4.2 Employees Since every unnecessary exposure to radiation violates sound Health Physics practice, each CNFP employee is responsible for the following:
a.
Folleving all established Health-Safety procedures.
b.
Seeing that any visitor in his company or custody observes all established Health-Safety procedures.
c.
Reporting any radiation hazard or potential hazard to his super-Visor or to a Health-Safety representative.
d.
Minimizing radiation exposure, and assisting in the evaluation of exposure of himself and others to the DATE 2-10-8G 4
REVISION NO.
2 PAGE CURRENT REVISION:
SUPERSEDES: PAGE 4
LENRC APPROVAL REFERENCE 5-04-84 DATE REVISION
BABCDCK & WIL(DX C0WANY, C0ltERCIAL NUCLEAR REL PLM USNRC LICENSE SNM-ll68 DOCKET 70-1201 IV HEALTH PHYSICS SECTICN 4.2 d.
extent possible by:
- Wearing prescribed monitoring and protective equipment.
- Surveying hands, shoes, and body for radioactivity and removing loose contamination to prescribed tolerance levels to comply with approved decontamination procedures.
- Wearing appropriate protective clothing whenever contami-nation of clothing is possible, and not wearing such clothing outside prescribed areas.
- Using recommended safety equipment; using proper techniques and facil... s in operations.
- Observing regulations governing eating and smoking in contaminated areas..
- Promptly reporting injuries and suspected or known in-gestion or inhalation incidents to Heal th-Safety.
- Cooperating in all attempts to evaluate exposures.
- Roping off hazardous areas, controlling potential hazards, and reporting contamination to his supervisor.
- Cleaning up contamination for which he is responsible.
- Properly storing and labeling radioactive materials for which he is responsible.
- Being familiar with the evacuation plan and evacuation route.
4.3 Supervisors Each supervisor is responsible for ensuring that the individual DATE 2U0-86 REVISION NO.
PAGE
~'
5 CURRENT REVISION:
5 SUPERSEDES: PAGE USNRC APPROVAL REFERENCE 5-04-84 l
DATE REVISION
BABC00( & WIL(DX COPANY, C0ltERCIAL NLUEAR REL PLM USNRC LICENSE SNM-ll68 DOCKET 70-1201 IV HEALTH PHYSICS SECTICN 4.3 responsibilities listed previously are discharged by persons under his control;.and is also responsible for the following:
1.
Acting in conjunction with Health-Safety to keep his em- _
ployees' exposure below 300 mrem in 1 week and keeping the average weekly exposure below 1.25 Rem /13 weeks (See 10 CFR, Part 20).
2.
Furnishing information to Hee.lth-Safety on individuals and
- i activities in his area, particularly additions to or deletions from, his personnel roster.
3.
Contacting Health-Safety whenever major changes in operational procedures, new techniques, or new operations are anticipated.
5.
OPERATIONAL EVALUATION Radiation safety evaluations will be made for new operations, or those operations undergoing significant revisions or redesign.
These evalua-tions will also consider industrial and nuclear safety as appropriate.
Pre-operational evaluation may consider, but is not limited to, such items as ventilation control, external exposure potential, license compliance, contaminated waste generation and control, and special protective measures that may be required.
Results of the evaluation will be reviewed with cognizant area supervision and any necessary changes will be made prior to approval for operational startup.
In addition, the evaluation results will be documented and maintained on file at the CNFP for at least six months after termination of the operation.
DATE 2-10-86 REVISION NO.
2 PAGE 6
CLRRENT REVISION:
SUPERSEDES: PAGE 6
DATE 5-04-84 REVISION 1
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BABC00( & WILG)X QWANY, CutERCIAL NUCLEAR REL PLAW USNRC LICENSE SNM.U68 DOCKET D E l t
SECTICN IV HEALTH PHYSICS 6.
RADIATION SAFETY EQUIPMENT Instrumentation, appropriate to the detection, monitoring, and measure-ment of industrial and radiological safety hazards potentially encountered in a nuclear fuel plant, wil) be maintained by Heal th-Safety.
6.1 A list of radiation detection and miscellaneous instrumentation is given below. These instruments are typical of those which are available for use at the CNFP.
Equivalent substitutes, or additions, will be acquired as necessary.
a.
Alpha survey and monitoring 1
- PAC-4G (0 - 500K CPM 2w) 4 j
- Alarming Hand Monitor (50 CPM 2n) b.
Low Range S/y survey - Eberline E-120 (0 - 50 mR/hr.)
~
- Eberline E-530 (0 - 200 mR/hr.)
4 c.
Intermediate Range y survey - Eberline " Red Owl" R0-2A (0-50R/hr.)
d.
High Range y - Victoreen Radector II (0 - 1000 R/hr.)
e.
Laboratory =/s/y Measurement - NMC Proportional systera, DSIT/
PC11T
- Ludlum scintallation system, Model 20-A
't
- Multi-channel analysis capabilities, alpha spectrometers, etc., are available at other B&W facilities.
l f.
Miscellaneous
- Positive displacement, low flow rate sampling pumps
- HG-70 and " Glass fiber" filter papers
- Sound level meter, Pulsar, Model 85 1
DATE 2-10-86 REVISION NO.
PAGE 7 i
CURRENT REVISION:
StPERSEDES:. PAGE 7
USNRC APPROVE EN DATE 5-04-84 I
REVISION
i BABC00< & WIUDX C0WANY, CutERCIAL NUCLEAR REL PLAVf USNRC LICENSE SNtt-ll68 DOCKET h.1201 IV HEALTH PHYSICS SECTICN 7.1 CNFP procedures require that Health Safety be notified before maintenance or other non-routine operations are undertaken if significant airborne activity may result.
Data collected by work station or other fixed samples is supported, and modified if necessary, based on lapel sample results.
Lapel sample collection frequency is determined by Health-Safety based on verification requirements and the nature of the operation being conducted.
7.2 Smear surveys to evaluate surface contamination levels are con-ducted throughout the plant on a regular schedule.
Routine survey frequency varies from daily to monthly depending on contamination potential or potential hazar'd category.
Portable instruments used concurrently with smear surveys provide a means of assessing total surface contamination.
In addition, special smear programs are instituted as consi.dered necessary by Health-Safety to provide in-depth coverage of special or unusual activities and to evaluate the effectiveness of decontamination.
Material being transferred from a " contaminated" to a " clean" erea is routinely monitored for surface contamination.
7.3 External {_" penetrating") radiation levels throughout the plant are monitored using a combination of portable instruments and TLD area dosimeters.
l DATE 2-10-86 REVISION NO.
2 PAGE 10 CURRENT REVISION:
SUPERSEDES: PAGE 10 USNRC APPROVAL REFERENCE 5-04-84 MTE REVISION 1
BABC00( & WILWX CCWANY, C0ltERCIAL NUClfAR REL PINT USNRC LICENSE SNM-ll68 DOCKET 70-1201 SECTION IV HEALTH PHYSICS 8.
PERSONNEL DOSIMETRY AND EXPOSURE CONTROL 8.1 Personnel monitoring devices are selected by Health-Safety on the basis of radiation type and sensitivity requirements, and' may include film, TLD, or pocket chambers.
Rapid dosimetric evalua-tion of neutron exposure in the event of accidental criticality is provided by indium foil issued to personnel as part of their standard dosimetric package.
Dosimeters are issued to all plant employees and selected visitors based on the requirements of 10 CFR 20, with routine monthly or quarterly exchanges.
Use of special dosimeters may be required by Health-Safety where unusual exposure levels may be encountered, as in source manipulation. An indica-tion of 100 mR/or more on a pocket chamber requires the expeditious evaluation of the employee's TLD or film.
Extremity exposure is monitored using TLD's as determined necessary by the Health Physicist,***
or Healt'h-Safety Leader. TLD and film dosimeters are pro-cessed by a vendor with monthly or quarterly printout forwarded to CNFP.
More rapid notification is available by telephone if 1
needed.
Personnel involved in activities where exposure to airborne activity is possible participate in a bio-assay program con-ducted in accord with Regulatory Guide 8.11 (" Applications of Bioassay for Uranium").
Operating philosophy is that the air sampling program, supported by the smear surveys, provides 2-10-86 2
DATE REVISION NO.
PAGE 11 ClRRENT REVISION:
ll SUPERSEDES: PAsE USNRC APPROVAL REFERENCE 5-04-84 MTE REVISION
BAB000( & WIL(DX CGPANY, C0ftERCIAL NUCLEAR REL PLET USNRC LICENSE SNM-ll68 DOCKET M-1201 IV HEALTH PHYSICS SECTION 8.1 definitive indications of personnel exposure. Bioassay techniques, including urinalysis and in-vivo counting serve to validate the effectiveness of existing exposure controls. A " Base-Line" bioassay (urine) sample is collected from all new hires and from terminating personnel with an exposure history.
In addition, newly hired employees whose job assignments involve handling of significant i
quantities of unclad SNM are scheduled for in-vivo analysis as required.
In-vivo and urinalysis services are provided by a vendor.
Fecal sampling may be employeed, as considered necessary by the Health Physicist or Health-Safety Leader to evaluate j
the magnitude of suspected accidental or elevated exposure.
8.2 Radiation exposure and absorbed dose to employees are derived based on dosimetric results and in accord with 10 CFR 20.
Normal operational doses accrued by CNFP employees are limited to the following (10 CFR 20.101)
- Whole Body, trunk and head, active blood forming organs, lens of eyes, and gonads 1.25. Rem / cal qtr.
- Hands and forearms, feet and ankles 18.75 Rem / cal qtr.
- Skin of whole body 7.50 Rem / cal, qtr.
However, NRC Form 4 documentation is provided for each permanent employee and in specific cases the Manager, Quality Assurance, Health Pny'sicist, and the. Plant Manager may autnor1Ze ex-posures greater than the above provided 10 CFR 20.101 (b) and 20.102 requirements are satisfied. In these cases, the " maximum permissible exposure" 2
DATE 2-10-R6 REVISION NO.
PAGE 12 CURRENT REVISION:
SUPERSEDES: PAGE 12 USNRC APPROVAL REFERENCE DATE 5-04-84 I
REVISION
BAB000( & WIL(DX OWANY, C0ftERCIAL NUCLEAR REL PlNT USNRC LICENSE SNM-ll68 DOCKER 70-1201 SECTION IV HEALTH PHYSICS 8.6 Eating and smoking are prohibited in controlled areas. Smoking may be per itted in change rooms if assurance of adequate radiological hygiene practices are maintained. At the discre-I tion of the Health Physicist drinking fountains may be located within controlled areas where non-transportable materials are being processed.
Drinking facilities are provided in change areas.
8.7 Exposure histories at CNFP for the period 1977-1980 are shown in Figure 1 below.
Data show normal fluctuations from period to period, without significant discernable trends.
FIGURE 1
$NsN7'EsSEEIm"A"iLie
"" ' " "C " "" / 0 ' * " '"d "' d"* 1 5
r h
dy exposure. except 520MPCHours/Qtr.)
1977 1978 1979 1980 Year 1979 1980 t
and 4.9%
3.75 4.7%
42%
1st Qtr.
17.25 20.3%
n maximum 2080 4.9%
3.2%
4.3%
4.41 2nd Qtr.
18.61 17.6%
MPC hrs./yr.
Rod Processing 3rd Qtr.
14.01 15.8%
Assembly Fabri.
2.6%
2.3%
4,21 4.45 4th Qtr.
17.25 11.25
["t'"*"(. Grid.
0.5%
0.31 1.1%
1.21 p
Office 0.11
<0.15 0.15 0.15 1
DATE 2-10-06 REVISION NO.
2 PAGE 14 i
CURRENT REVISION:
SUPERSEDES: PAGE I4 USNRC N E E m DATE 5-04-84 I
REVISION l
. - _ =
BAB000( a WILEX C0fANY, COPPERCIAL NUCifAR REL PLM USNRC LICENSE SNM-3168 DOCKET &]201 SECTION IV HEALTH PHYSICS
~
9.1 filters (in series) before re-entering the area. Air recirculated to the pell,etizing area is representative 1y sampled on a continuous basis to verify filter effectiveness.
Existing procedures require notification of Health-Safety prior to servicing or maintenance on those portions of the fans or HEPA l
systems that may be contaminated.
Flow sensing elements are installed within ductwork at appropriate 1
locations to provide an audible and visual alarm if flow is
]
interrupted.
If flow loss is other than a momentary disrup' tion, j
l operations may be terminated until proper ventilation is restored.
Additionally, pressure sensing devices are routinely monitored to assure that the controlled area remains negative with respect to the remainder of the plant.
- 10. LIQUID EFFLUENT CONTROL i
Potentially contaminated liquids generated at the CNFP are controlled by means of a dedicated drain and retention tank system.
Sanitary wastes, and waste originating in areas where there is no potential for radiological or chemical contamination, are routed to a sewage treat-ment plant through separate piping.
Liquids originating in the con-trolled area, analytical labs, de-ionizer area and " cleaning room" i
are part of the retention tank system.
Liquids accumulated in the retention tanks are sampled, radiometrically DATE 2-10-E6 21 i
REVISION NO.
2 PAGE i
CLRRENT REVISION:
SUPERSEDES: PAGE 21 USNRC APPRO M M FEE NCE MTE 5-04-84 REVISICH I
BAB000( & WILCDX C&PMY, C0ftERCIAL NUCLEAR REL PIM USNRC LICENSE SNM-ll68 DOCKET h.1201 SECTIO 4
~
~
10.
LIQUID EFFLUENT CONTROL analyzed, and treated as necessary, prior to release.
The retention tank system incorporates capacity alarms, and air agitation capability.
Analytical sensitivity is 1% of the applicable 10 CFR 20, Appendix B.
Table II limit.
The sampling program is under the control of Health-Safety and no releases are made without the prior approval of that component.**
The retention tanks are housed in the Rad Waste Retention Building.
11.
SOLID WASTE DISPOSAL Non-contaminated solid wastes are disposed of through a contract hauler.
Contaminated solid wastes are sent to another licensed facility for processing or to a licensed burial facility.
Uncontrolled disposal of solid wastes or equipment is authorized when 2
contamination levels do not exceed an average of 2500 dpm/50 cm and a 2
2 maximum of 7500 dpm/50 cm for total alpha; 1000 dpm/100 cm maximum for removable alpha; or an average of 0.2 mradAr. and a m4ximum of 1 mr/hr.
(6/y) at 1 cm.
Establishment of the above contamination limits to permit disposal in accord with routine industrial practice does not present a hazard to the general public and the limits are generally accepted, within the nuclear industry, as not presenting any significant radiolo-gical or nuclear safety hazard.
49 CFR 173.397(a) cites removable 2
contamination levels below 2,200 DPM/100 cm as being insignificant when applied to natural or depleted uranium.
Although uranium enriched 235 up to 4.05% will be the contaminant of interest, the low 0 content DATE 2-10-86 REVIS!Q1 No.
2 PAGE 22 CURRENT REVISIOJ:
SUPERSEDES: PAGE 22 WNRC APPROVAL REFERENCE DATE 5-04-84 I
REVISIO) _
BAB000( & WILG)X ONANY, CufERCIAL NUClfAR REL PIM 4
USNRC LICENSE SNM-ll68 DOCKET /0-1201 SECTIO 4 IV HEALTH PHYSICS
- 11. SOLID WASTE DISPOSAL 1
is not significant in the present case for radiological safety purposes and is treated as natural uranium.
Additionally, 49 CFR 173.391(a)
)
notes that the allowable s/y exposure rate is 0.5 mrem / hour for exempt
{
shipments.
Solid waste material, when the radioactive component is 4
distributed throughout the non-radioactive matrix, is not considered radioactive when the specific activity does not exceed 0.002 microcuries j
per gram (49 CFR 173.389).
3 Routine sampling and monitoring programs are conducted by Heal th-Safety to assure that material, contaminated in excess of specification limits, is not released for uncontrolled disposal and to detect and alleviate
~
increasing contamination trends.
4 11.2 Contaminated solid wastes consist primarily of low specific
}
activity material and are disposed of a by a licensed contractor
)
by land burial on an NRC or state licensed site.
LSA wastes are packaged in containers designed to retain loose contamination.
SNM content for each package is estimated using gama scan or i
sampling technique.
I 12.
RESPIRATORY PROTECTION f
A supply of respirators, equipped with high efficiency filters, is I
maintained for use in unusual conditions where airborne concentrations l
l are such that personnel may receive exposures in excess of acceptable l
DATE 2-10-pr, REVISION NO.
2 PAGE 23 l
cuRREur REviSImi 23 SUPERSEDES: PAGE mune mg na IMTE 5-04-84 I
REVISim
l BABC00( a WIUDX CGPANY, COPPERCIAL NllCLEAR REL PLAU i
l USNRC LICENSE SNft-ll68 DOCKET E-1201 IV HEALTH PHYSICS SECTICH 4
12.
RESPIRATORY PROTECTION limits. All respiratory devices for protection against radioactive materials are approved by the NIOSH or other authorized governmental authority.
Respiratory devices giving effective protection against acid gases, chlorine, ammonia, and other toxic substances as well as
]
particulate are available, based on the specific requirements imposed by plant activities. Self-contained breathing units of the "back pack",
j pressure demand type, are provided for emergen::y use.
Examples of operations for which respiratory protection may be determined to be necessary by Health-Safety include certain mainte-nance activities such as filter changes and to provide an additional safety factor during the initial start-up of operations where the extent of airborne contamination cannot be evaluated accurately j
during the pre-operational check.
Respirators are not used as a i
routine protective measure or as a substitute.for engineered controls.
i 12.1 All respiratory devices, used for protection against toxic substances, as opposed to those used for " nuisance control" j
(paint spraying, etc.) are maintained, issued, and use-monitored l
by Heal th-Safety. Health-Satety also determines the type of l
respirator to be used in a particular situation.
I f
Each individual who is required to wear a respirator, for toxic l
substance protection, is ' trained by Health-Safety iniroper use and fitting including:
}
DATE 2-10-86 REVISION NO.
2 PAGE 24 CLRRENT REVISION:
SUPERSEDES: PAGE 24 USNRC APPROVAL REFERENCE l
DATE 5-04-84 REVISION 1
0 BAB000( & WIUDX C00NY, QMERCIAL N(nEAR REL PIM USNRC LICENSE SNPt-ll68 DOCKET 70-1201 SECTICN IV HEALTH PHYSICS 12.1 a.
Advise that the user may leave the area in case of malfunction and psychological or significant physical discomfort.
b.
Proper method of fitting and use (wearing) of the respirator.
The initial fitting of a respirator on an individual will be conducted by Health-Safety during the training program and the fit checked by sr.oke or an equivalent method.
Procedures relating to respirator use, training, and maintenance are in effect.
Respirator maintenance is performed by Health-Safaty based on manufacturer's recommendations.
Routine inspections are conducted by Health-Safety tio evaluate operability, check for deteriora-tion, and to remove outdated components from stock.
Outdated can-nisters, etc., may be used for training purposes; however, they will be identified so as to prevent use in a situation where protection is required.
Air sample coverage is provided during all activities where the use of respirators is required. Special bioassay evaluations are undertaken if justified in the opinion of the Health Physicist or Health-Safety Leader in order to define the respirator effectiveness.
12.2 Protection factors for respirators currently available at the DATE 2-10-86 REVISION NO.
2 PAGE 25 CLRRENT REVISION:
SUPERSEDESi PAGE 25 USNRC NE REN 1-DATE 5-04-84 REVISION
_x j
e B/BUXX & WIL(DX COWANY, CutERCIAL NUCLEAR REL PLM USNRC LICENSE Snit-1168 DOCKET 70-1201 IV HEALTH PHYSICS SECTICN ChFP, are defined below:
12.2 a.
Half-mask facepiece, negative pressure - 10 b.
Full f ce piece, negative pressure 50 c.
Full face powered air purifier - 1000 Self-contained breathing apparatus full face (pressure demand) -
d.
1000
- 13. ANTICONTAMINATION PROGRAM Means for the limitation of personnel contamination in controlled areas and the spread, by personnel, of contamination from controlled areas are defined by Health-Safety procedures and plant design criteria.
All persons entering contaminated areas are required to wear pro-tective clothing. Minimum protective clothing consists of shoe covers and lab coats.
Additional protection in the form of coveralls, hair covers, etc., is required, where necessary, (e.g., pelletizing area).
Anti-contamination clothing is identified to assure that is not worn in " clean" areas without., Heal th-Safe.ty approval.
Change room facilities are provided at all entrances to controlled areas, the sole exception being emergency exits, and controlled access points, not used on a routine basis. The change rooms contain facilities for protective and personal clothing storage and decontamination.
" Controlled" showers are available for whole body decontamination.
Fixed alpha monitors are installed in all change
~
rooms.
Instructions for the use of these monitors and the decontami-nation procedures to be followed are posted with the instrument.
l DATE 2-10 d REVISION NO.
2 PAGE 26 Cf.RRENT REVISION:
SUPERSEDES: PAGE 26 5-04-84 I
DATE REVISION b
BAB000( & WILWX C0FPANY, C0WERCIAL NUCLEAR REL PIM USNRC LICENSE SNft-3168 DOCKET h.1201 SECTICN
~
13.
ANTICONTAMINATION PROGRAM In the event an employee cannot reach satisfactorily low contamination levels after two attempts he is instructed to contact Health-Safety for further evaluation. A personnel decontamination kit is maintained in the First Aid Room.
Section V, Part 8.4 specifies action levels for surface alpha contamina-tion on personnel and equipment.
Entrance to the controlled area is demarcated by means of easily visible stepoff lines.
Instructions for proper use of the change room facility are posted by Health-Safety as appropriate. Normal access to the con-trolled area is limited to the change room, and the layout of the change room itself is such that individuals exiting the contaminated area must pass the decontamination and monitoring points.
Tools and other equipment routinely used within the controlled area are i
conspicuously marked and'are not normally removed from the area. If removal is necessary, decontamination to the levels specified _in Section V, Part 8.4 is undertaken.
If decontamination attempts are not successful, specific Health-Safety appr' oval must be obtained prior to removal, and additional controls instituted as necessary.
Where tools or equipment have been exposed to high contamination levels such as may be found inside process units, the items will be decontami-nated as soon as practicable, or will be packaged and labeled if prompt i
cleanup is not feasible. All such equipment will be decontaminated prior MTE 2-10-86 REVISION NO.
2 PAGE 27 CLERENT REVISION:
SUPERSEDES: PAGE 27 USNRC APPROVAL REFERENCE 5-04-84 MTE REVISION
BABQXX & WILCDX COPANY, COWERCIAL NUClfAR REL PLM USNRC LICENSE SNtt-ll68 DOCKET 70-1201 SECTICN IV HEALTH PHYSICS
- 13. ANTICONTAMINATION PROGRAM to removal from the controlled area unless the item is intended for disposal as radioactive waste and is properly packaged to prevent contamination spread.
14.
MEDICAL AND FIRST AID PROGRAM Medical examinations of employees are performed as consistent with good industrial practice.
All employees receive a thorough pre-employment physical including kidney function, hematological evaluation, and chest x-ray.
Examinations upon termination of employment will be made when considered appropriate by plant management.
Babcock & Wilcox has retained the services of a number of area physicians to assure adequate representation of various medical specialties as appropriate.
The CNFP maintains a fully equipped First Aid Room staffed by personnel qualified in first aid.
Additional plant personnel receive Red Cro'ss (or equivalent) training to assure that first aid capability is always available. Registered nurse and ambulance services are available on site from another B&W facility.
15.
PERSONNEL TRAINING All personnel receive basic training in radiological, industrial, and nuclear safety upon being hired. ~ This initial training is a coopera-tive effort involving Personnel, Health-Safety, and the employee's supervisor and is designed to satisfy the requirements of 10 CFR 19.12.
DATE 2-10-86 REVISION NO.
2 PAGE 28 ClRRENT REVISION:
SUPERSEDES: PAGE 28 USNRC APPROVAL REFERENCE 5-04-84 1
DATE REVISION i
l i
BABC00( a WILWX C&PANY, C0ftERCIAL NUCLEAR REL PLAW j
USNRC LICENSE SNft-3168 DOCKET 70.1201 IV HEALTH PHYSICS SECTICN 15.
PERSONNEL TRAINING Particular emphasis is placed on the nature of the materials handled, plant safety program and rules,10 CFR 19 requirements, and the emergency evacuation system. The training is documented in Health-Safety records. Additional training sessions, of a general or specialized
"
nature, are conducted by Health-Safety as requirea.
Postings are mace as required by 10 CFR 19 and 20 specifications.
Radiation workers are re-trained annually.
15.1 Employees are referred to Health-Safety by the Personnel Department for initial training in safety.
At this time, the entire plant safety program is reviewed in some detail with par-ticular emphasis being placed on specific areas according to the employee's job assignment.
A'brief discussion of, and familiari-zation with, the genr.ral principles of health physics and nuclear safety is included.
The employee is informed of his rights and responsibilities under CFR 19, and OSHA. Training sessions are documented and filed as part of the employee's Healtih-Safety record.
Following the initial indoctrination, the employee receives additional safety training from his immediate supervisor. The employee's immediate supervisor shall complete a new employee training verifica-tion form (App. 3, Exhibit A) prior to allowing the employee to operate independently.
15.2 Continuing training of a general nature is provided as necessary
~~
by Health-Safety and supervision. This training' niay~be formalized (i.e., " classes") or informal and conducted as a part of routine 2-10-66 DATE REVISION NO.
2 PAGE 29 CURRENT REVISION:
SUPERSEDESi PAGE LENRC APPROVAL REFERENCE DATE 5-04-84 REVISICN 1
BAB000( & WILCDX CTPANY, OMERCIAL NUCLEAR REL PIM USNRC LICENSE SNM-ll68 DOCKET &l201 IV HEALTH PHYSICS SECTICN 15.2 Health-Safety audits.
Formalized retraining may be utilized to explain ope, rational changes affecting safety, control of special problems such as increased airborne activity, or changes in license specifications.
The responsibility for determining the necessity for retraining or special training rests with Health-Safety based on plant conditions or the request of supervision.
15.3 Training and retraining in the use of respiratory protection devices is provided by Health-Satety as required.
Points relating to proper use are covered as the unit is issued and fitted by Health-Safety. This approach provices continuing review of respiratory protection requirements. Should situations arise where frequent use of a respirator is necessary, frequent Heal th-Satety surveillance will assure conti'nued proper application.
15.4 Specialized training for special and emergency r'esponse units such as the Fire Brigade, Radiation Monitoring Team and First Aid personnel is coordinated by dealtn-Safety.
Fire t5rigace training is conducted by representatives of Health-Sa' et) and/or f
local Fire Departnents and covers the use of equipment and agents available at CNFP including high pressure water, C0, dry chemical, 2
and Met'L-X.
Radiation Monitoring Team members receive periodic training from Health-Safsty 1n emergency respunse techniques'
~
~
(emergency plan), instrument use and maintenance, health physics and nuclear safety fundamentals, respiratory protection and 2
DATE 2-10-86 REVISION NO.
PAGE 30 CLERENT REVISION:
SUPERSEDES: PAGE 30 USNRC APPROVAL REFERENCE DATE 5-04-84 REVISIQ4
BABC00( & WIL(DX CCPPANY, C0WERCIAL NUCLEAR REL PIM USNRC LICENSE SNM-ll68 DOCKET 20-1201 IV HEALTH PHYSICS SECT!m 15.4 contamination control. Annual evacuation drills are utilized as a training period for the emergency teams.
First aid training is given by a qualified instructor and is the standard Red Cross program or equivalent.
Efforts are made to recruit individuals who have had previous training such as military damage control or Civil Defense radiation monitoring.
16.
RECORDS AND REPORTS Records and reports pertaining to Health-Safety activities requiring formal documentation are maintained and stored in accord with Regulatory Guide 8.7, Occupational Radiation Exposure Records Systems.
Supporting documentation and material not appropriately part of Regulatory Guide 8.7 is prepared and stored in a manner, and for a period of time, consistent with good industrial pra' tice. The provisions for records c
retention and report submittal are governed by 10 CFR 19, 20, 70, and 71 specifications.
All documentation directly relating to Health-Safety activities is pre-pared by, or is under the administrative control of, the Health-Safety Section.
Vendor generated and supplied data (bioassay,.TLD) is incor-
^
parated as part of the Health-Safety ' record system based on contractual
=='
assurance of quality, precision, and adequacy of supporting information.
Information generated by other plant or company components is utilized as appropriate in the Health-Safety doc 0 mentation program. This~t pe~ ~ ~ ~
of material may be characterized as " supportive" and may include selected DATE 2-10-S6 REVISION NO.
2 PAGE 31 CLRREt6 REVISION:
SUPERSEDES: PAGE 31 USNRC N E REFERENCE DATE 5-04-84 REVISI(N 1
BABC00( & WILQX QNANY, C0fERCIAL NUCifAR REL PLM USNRC LICENSE SNM-ll68 DOCKET 70-1201 SECTICN 16.3 reviewed periodically by the Manager, Quality Assurance and in the course of routine audits provided by other B&W com-
?.
ponents.
flecord retention requirements are in accord with 10 CFR 20.
16.4 Where applicable, all records are maintained using terminology equivalent to 10 CFR 20. Where because of type of sample or the analytical technique employed, other units are more descrip-tive or useful, Health-Safety may maintain records in the units rcost appropriate. Typically, unit terminology will be as noted below:
- All air samples - pCi/ml 2
- Removable surface contamination - DPM/100' cm 2
- Fixed surface contami:1ation - DPM/50 cm
- Effluent water samples - pCi/ml
- Environmental water samples - pCi/ml
- Soil / vegetation samples - pCi/g
- Bioassay samples in-vivo counting - pgU-235 urinalysis - DPM/t pgU/t fecal - pgU/ sample nasal smears - DPM/ sample
- Exposure records
. Rem, mrem, MPCh
- Penetrating radiation surveys - R, mR, mrem
- Source leak test - pCi 235
- Solid waste disposal - gU, g 0
2-10 MTE REVISION NO. 2 PAGE 33 CLRRENT REVISION:
SUPERSEDES: PAGE 33 USNRC APPROVAL REFERENCE 5-04-84 MTE -
REVISION
=.. -. -
PA(DO( & WIL(DX C&PANY, CTPERCIAL NUCLEAR REL PLANT l
USNRC LICENSE SNWll68 DOCKET M - E l l
IV HEALTH PHYSICS SECTICN 17'.
CAUTION SIGNS, LABELS, AND AREA CONTROL A continued exemption is requested from the labeling and posting require-l ments of'10 CFR,20,203(e)(1) and 20.203(f)(1) because of the nature of our operation.
The intent of these section is met by posting plant entrances with signs incorporating the radiation symbol and the following warning:
CAUTION RADI0 ACTIVE MATERIALS ANY AREA OR CONTAINER WITHIN THIS PLANT MAY CONTAIN RADI0 ACTIVE MATERIAL.
This system has been applied effectively at the CNFP for the past ten years.
l 17.1 Personnel access to the plant and supporting buildings is con-trolled through a ~ guard station which is constantly manned.
The plant area is surrounded by a' chainlink fence, and all access-points, other than the main gate, are locked when..no_t in use.
Key control and other security measures utilized at the CNFP is.. u * {.
the responsibility of Facilities and Seryices.
For purposes of plant and personnel protection and access control, the CNFP " restricted area" is considered to consist of all areas within the perimeter fence.
In specific instances, CNFP management may modify the restricted area as defined above in order to accom-modate unusual or temporary conditions.
17.2 " Controlled areas" within the CNFP are established as necessary to assist in the protection of personnel or in the control of contamination spread.
Criteria specified in 10 CFR 20.202
~~
DATE 2-10-86 REVISION NO.
2 PAGE 34 CLRRENT REVISION:
SIFERSEDES: PAGE 34 USNRC N A REFERENCE DATE 5-04-84 1
REVISION l
BABCDO( & WILWX COPANY, C0ltERCIAL NUCEAR REL PIM USNRC LICENSE SNtt-ll68 DOCKET 20-1201 SECTICN IV HEALTH PHYSICS 17.2 and 20.203 are applied to the determination for the necessity of establishing: controlled areas.
)
Portions of the plant falling within one of the above categories are identified and controlled in accord with 10 CFR 20 requirements, l
P.ostings utilized in accord with the above are placed so as to be visible from all access points.
Additionally, Heal th-Safety.
may require the use of barriers, tapes, etc., to further control access or delentate the extent of the involved area.
J Change areas, stepoff lines and appropriate-monitoring equipment are used to control the spread of contamination to uncontrolled l
areas.
Boundaries'between' controlled and uncontrolled areas are clearly identified and special requirements for access to
~
the area are posted.
A radiation work permit program (RWP) may be instituted by Heal th-Saf'etf at any time in order to assure adequate protection, con.
trol, and health physics coverage of personnel working 'under high, or potentially high, radiation exposure conditions.
Due to the routine nature of plant operations, the imposition of RWP controls is infrequent and generally relates to special mainte-nance or process development programs.
Safety rules (industrial, radiological, and nuclear) are pro-minently posted throughout the plant.
These postings are main-DATE 2-10-86 F 2
REVISION NO.
PAGE.
35 CLRRENT REVISION:
SUPERSEDESr PAGE 35
~
USNRC APPROVAL REFERENCE MTE 5-04-84 1
REVISION i
BABQXX & WIL(DX CGPANY, C&fERCIAL NU0fAR REL PINT USNRC LICENSE SNM-ll68 DOCKET 70-1201 SECTION IV HEALTH PHYSICS 17.2 tained by_ Health-Safety based on license requirements and spec 1 tic plant operating criteria.
18.
EMERGENCY RESP 0NSE AND CONTROL PROGRAMS 18.1 Criticality Monitoring System A criticality monitoring system based on a series of GM detectors units and a central control panel located in the Health-Safety Office is installed at the CNFP. GM detector spacing meets, or exceeds, the specifications of 10 CFR 70.
Integral with the detector system is an immediate evacuation alarm system composed of a modulated frequency generator and speakers or horns positioned thro.ughout the plant. Alarm sound levels in all areas requiring immediate evacuation are distinctively audible above maximum ainbient noise levels. Selection.of the alarm system was based on noise levels,. frequencies, and modulation characteristics under plant operating conditions.
The system currently in use has'been demonstrated in the course of drills to result in immediate personnel response. Sound characteristics of the evacuation alarm are totally distinct from other audible alarms or signals in use at the plant (fire siren, time bells).
At the.present. time the monitoring system consists of six master detector. units covering the plant in a manner consistent with the requirements iri 10 CFR 70.24(a)(1) or (a)(2).
These detectors are located at appropriate distances where necessary to allow for
-10;8F DATE REVISION NO.
2 PAGE 36 CIRRENT REVISION:
SUPERSETS PAGE 36
^
USNRC APPROVAL REFERENCE DATE 5-04-84 REVISI(N 1
BABC00( a WILG)X QWANY, C0ftERCIAL NUCLEAR REL PIAVf USNRC LICENSE SNft-ll68 DOCKET E1201 IV HEALTH PHYSICS
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SECTION
- 19. BY-PRODUCT MATERIAL AND SEALED SOURCES 19.1 Encapsulate *d by-product material and neutron sources may be 3
possessed at CNFP for use in instrument calibration, monitor training, and product evaluation devices such as scanners. Signi-ficant quantities of material are required in order to provide exposure or neutron flux rates of sufficient intensity to calibrate "high range" survey instruments and to penetrate high density materials for gauging purposes.
CNFP Health-Safety personnel have adequate training and experience in health physics and source handling to insure utilization of such sources (reference SNM-1168,Section V, minimum qualifications).
The following controls are in effect to insure adequate radiological safety:
a.
Authorized users of sources intended for training and instru-ment calibration are limited to qualified jealth; Safety and plant instrument technicians.
In cases where other personnel may be involved in use of these sources, as in training exercises, the operation is directly supervised by a qualified representative of ~ Health! Safety b.
Sources' intended for use in manufacturing / quality control devices will be operated only by personnel designated by plant supervision and instructed in safe operating proce-dures by Health-Safety personnel.
-~
DATE 2-10-86 ~
~
REVISION NO.
2 PAGE 39 ClRRENT REVISION:
SUPERSEDESi PAsE 39
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USNRC APPROVAL REFERENCE
'1 DATE 5-0.4-84 REVISION
_ = =
i BABC00( & WIL(DX CDFANY, C(MERCIAL NUCLEAR REL PLATE USNRC LICENSE SNM-ll68 DOCKET 70-1201 SECTICN IV HEALTH PHYSICS
~
19.1 c.
When not in use, sources will be stored in approved, labeled and locked shields in a designated area. Source container shielding shall be sufficient to minimize the exposure, rate to personnel working in the vicinity of the container to less 1
than 2 mrem /hr.
In general, storage requirements will be l
l guided by the conditions outlined in " Safe Handling of Radio-isotopes" (IAEA Safety Series, No. 1 Section 4, 1962) and NBS Handbook 73 (1960).
d.
Adequate portable survey instrumentation ~is presently available on site.
All employees of CNFP routinely wear personnel monitoring.
e.
devices.
In addition, self-reading dosimeters, neutron dosimeters, and extremity' dosimetry are required as deemed necessary by Health-Safety.
Routine use of remote handling devices minimizes extremity exposure. Wherever practicable, automated handling and process equipment is utilized.
f.
Leak tests are conducted on all sources imediately 'upon receipt and at least semi-annually thereafter and are performed in accord with the guides outlined in NBS Handbook 73 (1960, Section 7.6, " Radioactive Source Leakage & Contami-nation") or by an equally effective method.
In the event that a'. leaking source is. discovered it shall be packaged so as to prevent further contamination spread and arrangements DATE
~2-10-86'
~~
REVISION NO.
2 PAGE 40 CLRRENT REVISION:
SUPERSEDES: PAGE 40 USNRC APPROVAL REFERENCE DATE 5-04-84 REVISION 1
3
l l...
l BAB000( & WILUM CafANY, C0tfERCIAL NUCLEAR REL PLM USNRC LICENSE-SNft.ll68 DOCKET &l201 SECrim IV HEALTH PHYSICS 20.1 d.
Sampling media available at selected site.
Chemicql and physical characteristics of potential con-e.
taminants (insoluble uranium oxides, etc.).
f.
Potential impact from neighboring nuclear facilities.
The sample results are maintained on file by Health-Safety.
Figure 4 shows results of the environmental sampling program for the period 1977-1980.
Normal data fluctuations are noted with no discernable trends identified.
h DATE 2-10 86~'
2 REVISION NO.
2 PAGE 43 ClRRENT REVISION:
x SUPERSEDES:: PAGE 43 USNRC APPROVAL REFERENCE
~
DATE 5-04-84 1
REVISION
BAB000( & WIL(DX COPANY, OMERCIAL NUCLEAR REL PLAVT USNRC LICENSE SNht-ll68 DOCKET &l201 SECTIO 4 IV HEALTH PHYSICS APPENDIX 1, PAGE 10 NEUTRON EMITTING SEALED SOURCES It is believed that neutron activation of scanned rods will resuit in an insignificant increase in the penetrating radiation levels normally encountered with unexposed fuel rods.
During the initial phase of scanning, however, a confirming measurement program will be undertaken. Sources are 4
leak tested upon receipt at CNFP and at~least every six months thereafter (unless the source is in storage).
Leak tests will be conducted by Health-Safety using remote handling techniques and will be compatible with NBS Handbook 73, Section 7,6, or by an equally effective method. Measurement techniques are capable of detecting 0.005 microcurie on the test sample.
When practicable, leak tests will be conducted without removing the source from its shielding unit.
Neutron survey instrumentation is available on-site.
Personnel dosimetric devices, such as film and self-reading chambers, appro-priate for evaluating neutron exposure are utilized as determined to be necessary by Health-Safety._
Operating personnel are trained in safe practices and health physics requirements prior to operating the scanner.
Documentation of'sucti training is maintained.in the Health-Safety Office.
In-plant operating proce'dures require that ilealth-SafetV~be notifiedjFior to undertaking any~
~~
~-
~
~
~~
maintenance or other activities that may involve access to, or modification of the source shield.
In addition, all source handling is under the supervision of qualified Health'-Safety personnel. Written procedures provide guidance for normal use of the sources and define the controls to be applied in the event of leakage or other non-routine condition.
appenoix i DATE 2-10-86 REVISION NO.
2 PAGE 10 CLRRENT REVISION:
SUPERSEDESr PAsE Appendix 1, Page 10 MTE 5-04-84 1
REVI_Sim
=...
.. ~.
.1 BAB000( & WIL(DX C(NANY, C0ltERCIAL NUCLEAR FLEi. PIM USNRC LICENSE SNM-ll68 DOCKET D E l SECTICN V CONDITIONS 5.0 Administrative The following feature of administration provide control to assure nuclear and radiation safety.
5.1 Management shall be responsible to assure the safety of the operation and compliance with license conditions.
Control shall be established by designation of responsibilities to qualified individuals, review and approval of Health-Safety procedures designed'to assure continuing safety and compliance, review of program effective-ness and assuring correction of non-conforming conditions.
ORGANIZATION CllART_-
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ne y respons 'bl. for redvetion MAL TT 5.2 Operational Area Supervision
~
Operational area supervision is that supervision directly responsible for the control of materials, personnel, equipment, and activities in specific areas.
Those responsibilities include assuring that approved control procedures developed with Health-Safety shall be available in writing to operators and other concerned personnel and shall be adhered to.
5.2.1 Minimum qualifications of operational area supervision shall include:
(a) A high school education or equivalent and a minimum of 6 months experience in the nuclear industry.
Experience shal.1 include the practical 4
DATE 2-10-06 REVISION NO.
2 PAGE 6
CtRRENT REVISION:
6 SUPERSEDES: PAGE 5-04-84 1
DATE REVISION
BABC00( & WIL(DX CDP ##, C0&ERCIAL NUCLEAR REL PLAVT USNRC LICENSE SNM-ll68 DOCKET &l201 V CONDITIONS SECTICN 5.0 Administrative (continued)
~
5.2.1 (a') application of criticality control techniques and a familiarity with the applicable specific limitations imposed on CNFP operations.
(b) Sufficient experience of industrial supervisory nature for recognition of the responsibilities of the position and achievement of the required control.
~
'~
5.3 The llealth-Safety Section' ~shall De respons1 ole to in-
~
terpret the license conditions, provide monitoring facilities, develop safe operation guidelines, maintain training programs, and review and approve operating procedures to assure safe opera-tion and license compliance.
These responsibilities include nuclear safety and radiation safety
~
with the approval authority limited to authorized specific or general license conditions.
The Hialth-Safety Section shall be resid6sibliii to pro '
r vide, management with assurance of the effectiveness of the safety program by maintaining an audit program that includes periodic inspection of controls and operations, reports to management, follow-up of non-conforming conditions and necessary documentation.
(_See Audits, Part 6,6,Section V),.
~ ~ ~ ~
7 DATE 2-10-86 REVISION NO.
-2 PAGE CLRRENT REVISION:
SUPERSEDES! PAGE 7
5-04-84 I
DATE REVISICN
BABC00( & WILCDX C0FPAin' f C0ftERCIAL NUCLEAR REL PLAK USNRC LICENSE SNM-ll68 DOCKET 70-]201 SECTICN Y
CONDITIONS 5.0 ' Administrative (continued) 5.3 The Health-Safety section shall not be directly responsible for the performance o'f manufacturing operations.
5.5.1 The Health-Safety section shall include a person trained in health physics with a Bachelor's Degree in Science or Engineer-ing, or equivalent, and a minimum of three years experience shall be of a nature that would provide an under-standing of the health physics and nuclear safety hazards involved, and the ability to evaluate the potential for exceeding authorized control limits.
5.3.2 The Health-Safety Leader shall have a high school education or equivalent, and a minimum of one year experience in responsible positions or three years experience in radiation safety which would develop an understanding of nuclear and radiation safety.
5.3.3 The manager to whom the section reports shall have a bachelor's degree, or equivalent, and a minimum of five years experience in responsible positions which would develop an understanding of nuclear and radiation safety. Such experience shall be of a nature which demonstrates to the Plant fianager sufficient judgement and capability to establish and maintain an effective nuclear criticality and radiation safety program for the activities authorized by license.
5.4 Independent Auditors shall be responsible to ascertain the over-
~
all performance of the' plant functions in providing adequate con-trols, surveillance, and followup to assure safety and license ll compliance. This shall be accomplished by periodic inspection of the facilities and records resulting in a written report to the Plant Manager.
5.4.1 Oualifications of the ind.ependerlt auditors shall include i
DATE 2-10-86 REVISION NO.
1 PAGE 8
CURRENT REVISION:
SUPERSEDES: PAGE 8
USNRC APPROVAL REFERENCE DATE 12-6-82 REVISION __ 0
f BABC0CK & WILC0X C0f1PA% C0itERCIAL NUCLEAR FlEL PlM USNRC LICENSE SNM-ll68' DOCKET 70-1201 SECTION V CONDITIONS 6.0 G_eneral Specifications - Implementation of the technical specifications will be accomplighed through application of the following general specifications.-
6.1 Control Program Specifications and design criteria for purchased or locally fabricated equipment where nuclear and radiological safety considerations are involved shall be approved by a knowledgeable representative of Health-Safety. Before being released for production operation, new equipment shall be tested to assure that safety specifications are satisfied. Safe geometry equipment shall be measured by a knowledgea,ble person to.
ascertain that it is of. proper dimensions before it is put into service. Where operational safety is based wholly or in part on the use of electrical or mechanical interlocks, the proper functioning of interlocks shall be verified upon installation and on an annual basis thereafter. Routine plant inspections place added emphasis on new operations. No equipment is used after being removed from service until an equipment checkout for continued effectiveness of safety related para-meters is perfonned.
Radiation instruments shall be calibrated at the frequency indicated in Section V, Part 8.3.4.
Calibration shall be performed by Health-Safety personnel or other rikC licensed -
~ ***
facilities. -
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DATE 2-10-86 REVISION NO.
3 PAGE 11 CURRENT REVISION:
SUPERSEDES:: PAGE 11 USNRC APPROVAL REFERENCE
~
DATE 2'-04-85 REVISION 2
~-
BAB000( & WIL(DX C&P#ff, COMERCIAL NUCLEAR REL PLAVT USNRC LICENSE SNft-ll68 DOCKET F1201 V CONDITIONS SECTICN 6.0 General Specifications (continued) 6.1 Ventilation, containment, and air cleaning equipment shall be _
routinely inspected by Health-Safety personnel to assure continued
~
effectiveness and.cpmpliance with. license specifications.
~
These inspections shall be recorded and a periodic. review shall.be per-forried by the Health-Safety Leader. Any unusual circumstances
.M
~~
I shall be br'ought to the attention of the~ Health Phy5icist '
l and/or the 'O.uality Assurance Manaaer. - - - [-
-._ J ;
The Heal thlSffely~ Leader.o[ qual ifi e[jes i gnee_as appoi n ted_by_ Z***_
'*y' Manager, Quality Assurance shall be responsible for the control}
of the air, sampling and contamination survey program, and sval'ates u
e daily sample results.
Quarterly air sample program records shall be t
reviewed by the Health Physicist. and/or the Manaaer, Quality Assurance.
~
i***-
Instances of inadequate cont'rol of contamination or air effluent levels, and of equipment operation not in accordance with established nuclear and radiation safety and license parameters shal'1 be reviewed 'by either thilleallh Physicist, and/or the ~
-~
~
Manager, Qualityys'surance wno may orcer the operation suspended t
if timely compliance cannot be assured. Disciplinary action can be recommended if warranted.
6.1.1 Safety Review Board
~
1 A Safety Review Board shall be established to review the folloEing as a minimum on a quarterly basis; j
DATE S1E~86 3
I REVISION NO.
PAGE CtRRENT REVISION:
SUPERSEDES; PAGE 12
~
USNRC APPROVAL REFERENCE 2-04-85 DATE REVISION t
b.
I BAB0XX & WIL(DX CDPM, C0ftERCIAL NUCLEAR REL PLAY USNRC LICENSE SNM-ll68 DOCKET h.1201 SECTION V CONDITIONS 6.0 General Specifications (continued) 6.1.1 Safety Review Board
'new or revised facilities
' analysis of equipment and processes involving radioactive materials
'the continuing effectiveness of established controls 'and safeguards
' maintenance of ALARA criteria (review of quarterly air sample averages, review of surface contamination surveys)
' safety-related audit findings
'other items (such as abnormal occurrences) that Saf ty Review Board members wish to discuss The Safety Review Board Chairman or his qualified designee shall be directly responsible to the Plant Manager for the pro-per conduct of the Safety Review Board. The. Plant Manager shall_
be kept informed in writing of Safety Review Board action.
The Board shall be chaired by the Manager, 0perations Support, tand the permanent membership of the Board shall consist of representativesof CNFP operational and technical management, specified by procedure, which is approved by Plant Management personnel. Technical representatives of f
. consulting organizations shal.1 be included as 'necessary (LRC, Nuclear _ Criticality Safety,Grouo).
Board meetings may be convened at the discretion of the Safety Review Board Chairman or his qualified designee,
~
but shall be held at least quarterly. The Safety Review Board Chairman or his qualified designee shall decide whether or not the necessary disciplines are present' during a board meeting to evaluate the item (s) under consideration. There shall be a minimum of 4 Safety Review Board members present during a board meeting.
~ 4076
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PAGE. 13 2
REVISION NO.
3-DATE CURRENT REVISION:
l-SUPERSEDES: PAGE 13 USNRC APPROVAL REFERENCE 2-04-85 2
DATE RMSM.
s.
s.
g
BABC00( & WILGX C&PA#, CatERCIAL NUCLEAR FLEL PLA1T USNRC LICENSE SNM-ll68 DOCKET 70-1201 V CONDITIONS SECTIO 4 6.0 General Specifications (continued) 6.1.1 Safety Review Board TiieSafetyReviewBoardChairmanorhisqualifieddesignec reviews all requests for changes in process and equipment which involve radioactive material.and determines if Board review is necessary.
In the case of minor change where existing safety practice remains the same, the Safety Review Board Chairman or his qualified designee may determine that Board review is not necessary.
Safety Review Board members shall be kept appraised of actions taken by the Safety Review Board Chairman or his qualified designee on such minor changes.
Where other than minor changes are involved, the Safety Review Board review and approval process shall be con-ducted in accord with Part. 7.1.4 of this section.
1 1
Records of Safety Review Board proceedings, including supporting calculations' and approvals, shall be retained for at least six months after the completion or termina-tion of the subject activity.
t l
l l
6.1.2 Records Plant alterations or additions, abnormal occurrences, events associated with radioactive releases, criticalit'y analyses, audits, inspections, instrument calibration, ALARA findings,
{
employee training.and retraining, personnel exposures,
{
routine radiation surveys, and environmental surveys shall l
be maintained on file for a minimum of 2 years or as other-wise required by federal regulation or other license con-dition, for review by B&W management and regulatory agencies.
6.2 Personnel Training Initial indoctrination of employees into nuclear and radiological safety shall be the responsibility of Health-Safety and shall l
l
~~~10-86
~
2-REVISION NO.
2 PAGE 14 DATE CURRENT REVISIQ4:
SUPERSEDES: PAGE 14 USNRC APPROVAL REFERENCE 5-04-84 DATE REVISIQ1
- s. '..
BABC00( & WIL(DX C&PNN., CGfERCIAL NUClfAR REL PIRT USNRC LICENSE SNM-ll68 DOCKET E1201 SECTIO 4 V CONDITIONS 6.'0 General Specifications (continued) 6.2 Personnel Training l
conformwith10CFR19.
Initial indoctrination training shall, as a minimum, include the following topics:
' license conditions
' federal regulations loperatingprocedures I
radiation safety lnuclearsafety emergency procedure i
The extent and depth of the training, relative to the detailed aspects of the health physics and nuclear safety programs, is dependent on the employee's job assignment and potential exposure to radioactive 3
materials as determined by Health-Safety.
],
]
The initial indoctrination training shall be reinforced (as appro-priate to the individual's job assignment) by tha employee's ime-diate supervisor or his designee with respect to individual unit,
}_
safety requirements, location of-emergency exits, contamination
^
' ~
control techniques, specific local controls, and operating proce-
[
dures, prior to the employee being released to operate independently.
The employee's immediate supervisor shall complete a new employee j
l training verification form prior to allowing tne employee to operate -
l independently.
j j
A continuing safety training program shall be conducted by i
Health-Safe ~ tf~to iihTe~xteht he~cessaiy~to assure'the'miintenance~ ~
~ - ~
~
~
w,*
j of acce'ptable safety practices. Such training may be conducted I
on an individual or group _ basis. The-content of retraining.
, programs may be varied by Health-Safety but will include radiolo ~ *** ;
l gical and nuclear safety as a minimum.
Emphasis is placed on new I
i or revised safety criteria or areas in need of reinforcement. A l
formal retraining of radiation workers shall be conducted at least
' annually.
Documentation of formal training and retraining shall _
~
j be maintained-by Health-Safety.
1
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/
REVISION NO.
-2k PAGE 15 l
DATE 2-10-86 CLRRENT REVISION:
f.
SUPERSEDES: PAGE 15-USNRC APPROVAL REFERENCE i-DATE 5-04-84 iREVISION~_._
71
. (
_3 __. _.,._.._ -.__ _-
4
. - ~ -...
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BAB000( & WIL(DX C@PANY, C(NERCIAL NUCifAR FLEL PLAVf USNRC LICENSE SNM-3168 DOCKET &l201 SECTICN 6.0 General Specifications (continued) 6.2 The Manage'r, Quality Assurance shall be responsible to assure that. personnel assigned _to_ Health-Safety are properly __
~
trained. The extent and depth of the training is based on the specific job assignment involved.
Health-Safety monitoring personnel shall receive a combination of formal and "on-the-job" training such that they can successfully demonstrate their proficiency in basic nuclear and radiation physics monitoring and control techniques and regulatory requirements before being allowed to function with-out direct oversight.
Members of the CNFP emergency monitoring team:shall be trained by Health-Safety in the proper technique of accident control.
6.3 Postings Nuclear safety postings approved by Health-Safetyfshall be maintained specifying nuclear safety parameters that are subject to procedural controls.
Area postings may be used for those-parts of the process where nuclear safety is maintained by means of " area-wide" require.
ments.
Operations for which specific (dedicated) controls are applicableshali}beindividuallyposted.
Local safety. rules approved by HeWth;Sifety providinTpeEsonnel
- r and supervision with specific direc'tions esse'ntial to assuring DATE 2-10-86 REVISION No.
2 PAGE 16 CLRRENT REVISION:
SLPERSEDES: PAGE 16 USNRC APPROVAL REFERENCE DATE 5-04-84 REVISION 1
1
BABC00( & WIL(DX C&PM, COMERCIAL NlLLEAR REL PLMT USNRC UCENSE SNtt-ll68 DOCKET h.1201 V CONDITIONS SECTI(N 6.0 General Specifications (continued) 6.5 consideration involves SNM or radioactive materials, specific written approval by the Manager, Quality Assurance '
s or his designee shall be required prior to implementation of the procedure. Applicable procedures shall be available in the work
~
i area and adherence to procedure shall be required of all personnel.
Procedures for operations where nuclear and radiological safety are involved shall include specific reference to applicable safety re-quirements. Procedure and format shall be such that operations are clearly detailed and specific directions are provided for operaticn under both normal and abnormal conditions Deviation from written procedures for the handling of SHM shall be approved'by the Manager, Quality Assurance', or his iualified designee ~.
Procedural
~
l control of activities at the CNFP are catacorized as follows:
- Procedures developed by Health ~-Safety fpecifying the
~ ~ ~ ~
~
j method by which safety related functions are to be accom-plished. Such procedures may be for internal Health-Safety. ~ ~ ~ ~
~
use er may be intended for general distribution to affected indivi-duals within other components. As a minimum,~ Health-Safety Proce-dures shall be approved in. writing by the Manager, Quality
~*v*
~
Asturhnc~e as well as approved by affectiid members of plant management.
M..-
~.
i c,i
~l DATE ~ 2IOkk
~
i REVISION NO. J:3, PAGE 18 CURREf6 REVISION:
18 SUPERSEDES l PAGE USNRC NE REN DATE 2-04-85 REVISICN '
.2
BAB000( & Wl(DX COPANY, C0WERCIAL NUCLEAR REL PLM USNRC LICENSE StM-ll68 DOCKET D.1201 V CONDITIONS
~
SECTICN 6.0 General Specifications (continued) 6.5 Nuclear Materials Control procedures provide techn_iques_for the accountability and measurement of SNM. As a minimum, sucn pro -
cedures shall be approved in writing by the Manager, suality Assurance and the Manager, Production & Materials Control.
- Procedures from other plant groups where nuclear or radio-logical safety, license conditions, or regulatory require-ments are involved require prior approval by the Manager, Quality Assurance as well as approval by affected members of plant management.
Revised procedures shall be subject to approval in the same manner as'new procedures. Health-Safety
procedures shall be reviewed at least annually for technical correctness and applicability.
Procedure distribution and control shall be the responsibilit.y of plant supervision.
6.6 Audits An internal audit program shall be maintained to provide assurance that_ plant activities are conducted safely and in accord with license specifications.
The Manager, Qu'ality Assurance shall be responsible to
- di"=
~
assure that.the audit program is conducted effectively.
DATE 2-1036~
REVISION NO., 3 -
PAGE 19 CLRRENT REVISION:
SUPERSEDES: PAGE 19 mmgam MTE 2-04-85
'2' REVISION
BAB000( & WILG)X CDPANY, C0WERCIAL NUCLEAR REL PIM USNRC LICENSE SNPt-ll68 DOCKET 70-1201 SECTION V
CONDITIONS 6.0 General Specifications (continued) 6.6 Health-Safe'ty_ personnel shafl conduct, at least weekly, a formal audit of plant status relative to nuclear and radiolo-gical safety, except during plant shutdown of a week or longer.
At the discretion of Health-Safety, the audit may consist of an indepth evaluation of a specific area or may be of a generalized nature providing an over-i view of total plant activities. Audit results shall be documented, reported to plant management and supervision as appropriate, and will be maintained on file by Health-Safety for at least 2 years. ***))
Health-Safety audits shall be conducted by personnel technically
_ j** ~
~
qualified in operational nuclear and radiological safety and in the application of license specifications.
Health-Safety personnel shall, as p. art of their routine duties, c'onduct informal daily audits of plant activities.
Independent auditors shall conduct inspections as follows
- nuclear safety
- quarterly
- health physics
- quarterly All formal (quarterly) nuclear safety and health physics audits shall be. conducted in accordance with written instructions or procedures.
The audit program shall include physical inspections and records reviews for the industrial, nuclear,. and radiological safety elements of plant activities including:
- Effectiveness of procedural controls impacting on operational safety parameters.
MTE '
2 10-86 ~~~
REVISION NO.
Y' PAGE 20 ClRRENT REVISION:
SUPERSEDES:, PAGE 20 USNRC NE REFEM
- 2 '-
MTE 2-04-85 REVISION
BAB000( & WILCDX C&PANY, COWERCIAL NUClfAR REL PINT USNRC LICENSE SNft-ll68 DOCKET D E l
~
i SECTICH V
CONDITIONS 6.0 General Specifications (continued)
~
6.6
- Audit of operating records, where such re' cords provide a means of verifying procedural compliance with safety specifications.
- Periodic review and evaluation of contamination survey data.
An annual ALARA report shall be submitted to the Safety Review Board on employee exposures and effluent release data.
A copy of the report shall be sent to the Plant Manager.
Independent auditors' reports shall be submitted to the Plant Manager.
The' Manager, Quality Assurance shall review the audit reports as they *"
are submitted. The audit report shall include any audit findings or recommendations. Actions taken as.a result of audit findings shall be documented.
Safety-related audit findings are reviewed by the Safety Review Board.
6.7 Reporting Unusual events requiring reporting under 10 CFR shall be investi-gated, with results reported to plant management'and NRC.
Events not otherwise requiring a report may be reported to NRC based on potential public or media involvement, etc., in order to keep NRC appraised of the situation.
f l
IMTE
'2-10-86 '
2 REVISION No.
PAGE 21 ClRRENT REVISION:
SUPERSEDES: PAGE 21 WNRC APPROVAL REFERENCE
~
5'-04-84:
1 MTE REVISION i
BABC00( & WILG)X C&PANY, C0WERCIAL NUCLEAR FLEL PLAVf USNRC LICENSE SNM-ll68 DOCKET &l201 V CONDITIONS 7.D Nuclear Safety - Technical Specificatior.s (continued) 7.1.2 e
The solid angle criteria applied in accord with p
TID-7016 (Rev. 2) for accumulations having k-eff
< 0.8.
7.1.2.1 The Safety Review Board Chairman or his qualified designee, with the concurrence of the LRC Nuclear Criticality Safety Group, shall determine which arrays are more reactive than those used as a basis for a, b, and c or are best represented as slabs for nuclear interaction purposes.
In these cases, the interaction acceptance cri-teria shall be evaluated on an individual basis by the LRC Nuclear Criticality Safety Group or itshall be the equivalent of eight inches (20.3 cm) of water or as defined in.
7.1.2(d) or (e).
7.1.3 Isotopic enrichment of SNMshall be verified by shipper's i
documents with added assurance by Quality Assurance overchecks.
l 7.1.4 Modification of rec 6 at process involving SNM may be made without license amendment provided such changes are controlled as described in this section and where the license conditions specified in this part are not violat# t DATE 2-10M6 REVISION NO.
2 PAGE 23 CLRRENT REVISION:
SUPERSEDES: PAGE 23 (ENRC APPROVAL REFERENCE DATE 2-04-85 I
REVISION
.~.
BAB000( & WILCDX C0WANY, C0ttERCIAL NLX1 EAR PIL PLM USNRC LICENSE SNM-ll68 DOCKET 70-1201 V CONDITIONS SECTICN 7.0 Nuclear Safety - Technical Specifications (continued) 7.2 discussed,in Section III and may be considered typical of material pr'ocessed.
7.2.1 Fuel Pellets Composition: Uranium 0xide Size:
.300" to.600" diameter inclusive 235 Enrichment: Maximum 4.05%
U NOTE: An increase from 4.00 to 4.05 w/o does not significantly affect nuclear safety calculations based on 4 w/o material.
7.3 Fuel Pellet Receiving and Temporary Storage A single shipment of pellets may be stored in the shipping containers in an array no more reactive'than as received pending transfer to planned storage facilities.
Nuclear interaction between the shipment and other.SNM will be as specified in 7.1.2.
7.3.1 The containers shall be examined for transit damage, and
~
Health-Safety notified if damage is found.
Heal th-Safety shall examine the damaged containers for evidence of water entrainment and other conditions that might constitute a hazard.
Damaged containers shall be opened one at a time and as the material is removed, itshall be immediately placed into storage within safe geometry slabs or 850 grams U235 accumulations in accord with appropriate license con-ditions for storage.
DATE 2-10-86 REVISION NO.
2 PAGE 28 CtRRENT REVISION:
SUPERSEDES: PAGE 28 USNRC APPROVAL REFERENCE DATE 5-04-84 REVISI(N 1
BABC00( & WIL(DX COPANY, CatERCIAL NUCLEAR REL PLAT USNRC LICENSE SNft-ll68 DOCKET 70-1201 SECTION V CONDITIONS 7.0 Nuclear Safety - Technical Specifications (continued) 7.5.2 Only a single slab thickness will be permitted on any one shelf.
7.5.3 The vault is separated from other SNM storage and pro-cessing areas by eight inch thick concrete walls.
7.5.4 Storage and handling of materials in the vault shall be controlled based on. criteria specified by Health-Safety per ***
sonnel. Enrichment determination and selection of proper slab **'
thickness shall be made utilizing appropriate records or test data.
7.6 Fuel Pellet Handling and Storage Fuel pellet handling (following release from the pellet handling areal may involve such operations as fuel rod loading, and storage of packaged but unclad fuel pellets in areas other than the vault.
Fuel pelleth shall be handled in accumulations limited to thickness by enrichment as follows:
235U Enrichment Maximum Thickness (5)
(i n. )
< 2.5 5.4
> 2.5 1 3.0 4.8
> 3.0 1 3.5 4.4
> 3.5 1 4.05 4.0 MTE 2-10-86 REVISION NO.
2 PAGE 31 ClRRENT REVISION:
SUPERSEDES: PAGE 51 USNRC APPROVAL REFERENCE MTE 2-04-85 1
REVISION
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BABC00( & WILCDX C& PAN, CatERCIAL NUCLEAR REL PLAff USNRC LICENSE SNtt-ll68 DOCKET &l201 V CONDITIONS SECTION 8.0 Technical Specifications - Radiation Safety (continued) 8.1.1 c.
The following program shall be instituted _to assure that airborne releases to uncontrolled areas are maintained as low as, reasonably achievable.
AIR EFFLUENTS Quarterly Average - % of 10 CFR 20-Appendix B, Table 2 LIMIT ACTION
< 10% of "MPC" None' required.
11 - 20%
Conduct investigation of system and -
correct if possible.*
21 - 75%
Visually inspect. system. As soon as practicable, conduct efficiency test.
Determine and correct cause.**
> 75%
Conduct immediate investigation
-to determine and' correct problem in ventilation system. Maintain addi-tional Health-Safety surveill'an'ce of system to monitor contamination levels until problem is corrected.
- end weld ope. ration area. none, required
,,end weld ope' ration area - none required at < 50% MPC ~
end cap removal area
.none. required at < SD% MPC Health-Safety shall maintain records of investiga-tions and actions resulting therefrom.
d.
its daughters) pha radioactivity (excluding radon and If the gross al in planned gaseous effluents discharges exceeds 10 uCi/ cal, qtr., a written report shall be submitted to NMSS and the Regional 0ffice of the Com-mission within 30 days, identifying the cause for exceed-ing the limit, and corrective actions to reduce release rates.
If the parameters important to a dose-assessment change such that the parameters no longer represent boundary conditions, report shall be submitted within 30 days which describes the changes in parameters and includes an estimate of the resultant change in dose commitment.
(Ref: Order to Modify License, Jan. 28, 1980).
DATE 7-10-R6 REVISION NO.
3 -
PAGE 42 CURREffT REVISION:
SUPERSEDES:.PAGE 42 USNRC APPROVAL REFERENCE 2
DATE 2-04-85 REVISIm
BABC00( & WIL(DX COPANY, CutERCIAL NUCifAR REL PIAE USNRC LICENSE SNM-ll68 DOCKET 70-1201 SECTICN V CONDITIONS 8.0 Technical Specifications - Radiation Safety (continued) 8.1.2 Po.tentially contaminated liquid effluents shall be controlled through a retention tank system with dilution and mixing capabilities and shall be evaluated for compliance with 10 CFR 20, Appendix B limits prior to release to unrestricted areas. The following actions, at the contamination levels indicated, shall be undertaken in order to maintain contaminated liquid effluent re-leases as low as practicable:
LIQUID EFFLUENTS
% 10 CFR 20 App. B. "MPC" Action
< 20%
No action required.
21 - 75%
Individual releases authorized by Manager, Quality Assurance or his alternate.
> 75%
Discharge prohibited.
Effluent routed for further treatment or disposal.
Sealth-Safety shall maintain records of investiaation.s and actions resulting therefrom.
a.
Retention tanks shall be inspected monthly for sludge accumulation.
8.1.3 The following parameters are established for determining if waste or excess materials and equipment may be disposed of in routine industrial fashion.
Item (d)
DATE M0-86 '
3 43 REVISION NO.
PAGE CtRRENT REVISION:
SUPERSEDESL:1PAGE 64 DATE 2-04-85 2
REVISION
l BABC00( a WIL(DX C&PANY, QMERCIAL NUCLEAR REL PIM USNRC LICENSE SNPt-ll68 DOCKET 70- 2 1 V CONDITIONS SECTIO 4 8.0 Technical Specifications - Radiation Safety (continued) 8.2.2 Pressure differential shall be monitored by manometers or eg'uivalent devices. Minimum face velocities for hoods and similar enclosures shall be 100 LFM whenever hood work in-volving dispersible licensed material is being performed.
Air velocity surveys shall be conducted.using heated thermocouple anemometers or equivalent. Higher velocities may be required, based on Health-Safety survey data.
1.
Glovebox negat.ive pressures shall be monitored weekly, except during plant shutdown of a week.or longer.
- 2. Face velocities shall be measured weekly, except during plant shutdown of a week or longer.
f as.
" Elephant trunk" drops shall be used as required for maintenance or non-routine activities requiring ex-haust ventiilation and where other, more permanent types of containment are not practicable.
Exhept as noted above, elephant trunks shall not be used as a routine control measure without the specific approval of Health-Safety. flinimum velocity at the point of entrance to " elephant tr'unk" drops in the pelletizing area shall be 1300 LFM.
\\
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i 4
i DATE 2-10-86 REVISIO4 NO.
3 PAGE 49 CURRENT REVISION:
SUPERSEDES: PAGE 70 USNRC APPROVAL REFERENCE
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2 DATE 2-04.-85 REVISIQ1 L
J
BAB000( & WIL(DX CTPANY, C0ltERCIAL NUCLEAR REL PLAT USNRC LICENSE SNM-3168 DOCKET hl201 SECTIm V CONDTTTON9 8.0 Technical Specifications - Radiation Safety (continued) 8.2.2 andshall be measured weekly when the area is in operation.
8.2.3 Air Sampling In order to verify the adequacy of the ventilation and containment systems, air sampling technique (s) shall be employed. Air samplers shall be positioned at work stations based on evaluation of smoke tests, special air samples, and operator working position. Based on operational status and/or exposure potential, air samples shall be collected after each shift. The air samples shall be analyzed to evaluate airborne s
levels and assign worker exposures.
General area air samples shall be collected and analyzed as stated in the preceding paragraph.
Upon initiation of new operations, non-repetitive opera-tions, or operations modified such that previous airborne contamination levels may be effected, ~ Health-Safety sha'11 verify that satisfactory control is being maintained by means of the air sampling techniques stated above. The scope and duration of such special programs shall be determined by Health-Safety based on good health physics pr'actice. ~
DATE 2-10-86 REVISION NO.
3 PAGE 50 CLRRENT REVISIQ4:
SUPERSEDES: PAGE 71 IENRC APPROVAL NEFERENCE DATE 2-04-85 REVISION 2
BAB000( & WIL(DX C&PMY, COMERCIAL NUClfAR REL PLAE USNRC LICENSE SNM-ll68 DOCKET L 1201 V CONDITIONS SECTICN 8.0 Technical Specifications - Radiation Safety 8.2.3 The following action points shall apply to the routine work station air sampling program:
PERSONNEL EXPOSURE Quarterly % MPC-Average Action
< 25%
No action required.
> 25%, < 50%
Report to Manager, Quality Assurance ***
or designee.
Evaluate operation and containment.
Increase air sample frequency if indicated.
> 50%, < 75%
Report to Manager, Quality Assurance. Take steps necessary to lower airborne activity to acceptable range.
> 75%
Notify Manager, Quality Assurance." ***
Terminate operation if > 100 MPC. fedify or install air capture devices. Increase air sample freauency.
l If any one sample measures 100% MPC, the location and occurrence shall be investicated.
i Health-Safety shall maintain records of investigations and corrective actions taken.
The action levels do not apply to non-routine operations con-
~
ducted with the cognizance of Health-Safety, and in accord
.M**
with specific contamination control measures (for example, certain maintenance activities).
DATE REVISION No.
4 2-10-86 PAGE 51 CLERENT REVISION:
SUPERSEDES: PAGE 72 WNRC NE REN 3
DATE 2-04-85 REVISION
-a..
.ay, u,
..~.~.n BAB000( & WILOM C&PANY, CORERCIAL NUCLEAR REL PLM USNR: LICENSE SNM-3168 DOCKET 70-1201 V CONDITIONS SECTION 8.0 Technical Specifications - Radiation Safety (continued) 8.2.4 Re.spirators may be used in unusual conditions where air-borne concentrations of radioactive material may.cause personnel to receive exposures in excess of permissible levels. Typical emusual conditions may be certain maintenance operations, startup periods, short-term operations, etc.
Procedures for maintenance of the respirators and training of personnel using respirators shall be under the cognizance of Heal th-Safety.
Respira-tors shall not be applied as a routine control measure in situations where engineered or procedural controls are feasible.
SCBA is available at the plant.
Respiratory protection equipment shall be governed by 10 CFR 20.103(c).
8.3 Instrumentation 8.3.1 Portable instrumentation used to evaluate general area activity shall be capable of detecting contamination levels at or below license limits or action levels.
MTE 2-10-86 REVISION NO.
PAGE 52 3
CURRENT REVISION:
SUPERSEDES: PAGE 73 g
2-04-85 2
MTE REVISION l
BAB000( & WIL(DX CDPANY, CGtERCIAL NUCifAR REL PLM USNRC UCENSE SNPt-1168 DOCKET &l201 SECTICN V CONDITIONS 8.0 Technical Specifications - Radiation Safety (continued) 8.3.2 Analytical capability for evaluation of effluent samples shall be such that instrument sensitivity and sample preparation techniques allow:
a.
1% of the appropriate MPC for liquid effluents b.
10.0% of the' appropriate MPC for airborne effluents.
8.3.3 A criticality monitoring system shall De maintained in com-pliance with the appropriate sections of 10 CFR 70. Response time for the system shall be in accord with Regulatory Guide 8.5, " Criticality and Other Interior Evacuation Signals" dated March, 1981.
The criticality alarm system shall be function-tested at least quarterly, and detector units calibrated annually.
Nuclear accident dosimeters incorpo-rating neutron activation foils shall be positioned in the plant at locations, selected by Health-Safety to provide exposure estimating capability in the event of a nuclear incident.
8.3.4 All instrumentation shall be calibrated upon initial installation, following major maintenance, and at other times as deemed necessary.
In any case, I
~
~
DATE 2-10-86 REVISICN NO.
3' PAGE 53 CLRRENT REVISION:
SUPERSEDES: PAGE 74 USNRC N E REFERENCE
~~
2 DATE _ 2-04-85 REVISICN
. ~
BABOXX & WIL(DX C&PANY, C0WERCIAL NUCLEAR REL PLAW USNRC LICENSE SNft-ll68 DOCKET 70-1201 SECTION V CONDITIONS 8.0 Technical Specifications - Radiation Safety (continued) 8.3.4 calibration shall be performed at least semi-annually. Labora-to'ry counting instruments shall be calibration-checked daily when in use. Calibration records shall be maintained for a minimum of two years.
i 8.3.5 Field check sourcesshall be available for assuring functional response of instrumentation prior to use.
8.4 Personnel Monitoring and Contamination Control 8.4.1 Personnel monitoring equipment - film badges, thermo-luminescent dosimeters, detectors, etc., -shall be used by persons having access to restricted or radi-ation areas, as deemed necessary by Heal th-Safdty,
~
i and in accord with 10 CFR 20.
The dosimeters shall be processed routinely 'to determine radiation dose. Heal th- ***
i Safety shall review and maintain the dose records and prepare such reports as are required by regulatio.ns.
Neutron dosimeters shall be used by operators and other
~
persons as deemed necessary by Health-Safety when a potential for measurable neutron exposure exists.
8.4.2 An indium foil stripshall be worn by plant personnel to provide for identification of persons receiving high exposures in the event of an accidental criticality.
8.4.3 Persons who work routinely in areas where there is a potential for bodily intake of radioactive materials DATE 2-10-36 ~
3 REVISION No.
PAGE 54 CURRENT REVISION:
f j
SUPERSEDES: PAGE 75 REVISION
.2 DATE 2-04-85 e
r
.e BABC00( & WILG)X GWANY, COREICIAL NUCLEAR REL PLM USNRC LI NSE SNM-ll68 DOCKET E-1201 SECTIO 4 V CONDITIONS 8.0 Technical Specifications - Radiation Safety (continued) 8.4.3 shall be subject to determination of the extent of in-take and retention by analysis of excreta or body counting. The bioassay program shall be conducted in accord with Regulatory Guide 8.11, " Application of Bioassay for Uranium".
Periodic " blank" or " spike" samples shall be included in the bioassay program.
8.4.4 Personnel Contamination
" Change room" facilities shall be provided for the control of contamination spread from areas where sig-nificant quantities of unclad SNM are handled.
Normal exit from controlled areas shall be through change room facilities.
The change room shall include personnel decontamination and monitoring capability.
External contamination of personnel entering; controlled areas shall be limited by means of protective clothing.
The degree and type of protection required is determined by-Health-Safety, depending on tile contamination potential ***
in the area under consideration.
Required protection may range from a minimum of lab coats and shoe covers over street clothes to coveralls, haircaps, gloves, and special shoe for areas of higher contamination j
potential.
The use of anti-contamination clothing l
DATE 2-10-86~~
REVISION NO.
3 PAGE 55 CtRRENT REVISION:
SUPERSEDES: PAGE 76 USNRC APPROVAL REFERENCE 2-04-85 2'
MTE REVISIm l
BABC00( & WIL(DX C&PANY, C0ffERCIAL NUCLEAR REL PIM USNRC LICENSE SNft-ll68 DOCKET 70-3201 V CONDITIONS SECTI(N 8.0 Technical Specifications - Radiation Safety (continued) 8.4.4 within the plant is limited to the controlled area, except as specifically authorized and monitored by lieal th-Safety.
Radiation monitors, incorporating audible and/or visual alarms, shall be located at routine exit points from controlled areas.
The monitor alarm point shall be set as low as practicable taking into account the necessity for reducing spurious alarms induced by background fluctuations. Health-Safety shall be noti-fied when initial decontamination attempts fail to reduce skin contamination below the monitor alarm point. Health-Safety shall assist during further decontamination, as nec,essary, to levels as low as reasonably achievable, consistent with good health physics practice before releasing the employee.-
8.4.5 Surface Contamination Control The following criteria shall be applied to monitoring and control of surface contamination.
The levels shown represent contamination levels which, when ex-ceeded, shall cause prompt c'ean-up activities of the affected area to be initiated.
I DATE 2-10-06 REVISION NO.
3 PAGE 56 CLERENT REVISION:
SUPERSEDES: PAGE 77 WNRC NR EFEM DATE 2-04-05 REVISION 2
7 BABC00( & WILQX CO*PMY, C0ftERCIAL NUQfAR REL PIRT USNRC LICENSE SNM.ll68 DOCKET 70.1201 SECTICN V CONDITIONS 8.0 Technical Specifications - Radiation Safety (continued) 8.4.5 Area Ac+. ion Level Survey Frequency 2
1.
Controlled pellet Removable:
5,000 DPM/100 cm Weekly processing / rod Total 50,000 CPM / 50 cm loading, change room (hot area) 2 2.
Change Room Removable:
-500 DPM/100 cm Daily *
(Intermediate)
Total 2,000 DPM/ 50 cm 3.
Clean (Rema:ader of Removable:
200 DPM/100 Monthly plant and office Total 500 DPM/ 50 cm area)
- When pellet processing operations are being conducted.
In no case shall there be more than one week between surveys.
The levels establishe'd for Item "1" abcve are defined for the general area including floors and other exposed surfaces. The contamination levels in hoods and on equipment that directly contacts SNM cannot be effectively speci fled.
Control shall be maintained through frequent cleanup and limitation of powder accumulation.
Tools and equipment removed from controlled areas for uncontrolled use elsewhere in the plant shall not exceed that.specified for clean areas unless specified by Health-Safety.
In such cases, Health-Safety may impose
~
limitations on use or require other controls to preclude con-tamination spread.
DATE 2-10-86 REVISIG1 NO, 3
PAGE 57 CURRENT REVISION:
SUPERSEDES: PAGE 78 USNRC APPROVAL REFERENCE DATE 2-04-85 REVISIQ1
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BABC0CK & WILCDX CGPAf(, COMBCIAL NUCIIAR REL PLAW -
l
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USNRC LICENSE SNtt-ll68 DOCKET h.1201 V CONDITIONS SECTIO 4 8.D Technical Specifications - Radiation Safety (. continued) 8.4.6 Health-Safety may approve the performance of non-routine or. temporary operations in the manufacturing area outside the l
controlled area when the operation may result in contamination provided the following controls are established and documented:
- The area involved is identified and access controlled.
f.
- Necessary area and personnel contamination control i
and monitoring programs are implemented including J,
l use of anti-contpmination clothing if needed and j
air sampling as required.
- During the course of the operation, decontamination j
shall be initiated when general contamination levels i
in excess of 1000 DPM/100 cm (removable) or 2,500 DPM/50 cm2 (total) are noted.
Following completion of i
l the operation, decontamination to clean area levels i
specified in Paragraph 8.4.5 shall be accomplished.
8.4.7 Operations which are not covered by an operating procedure and are judgad by cognizant supervision as being likely to
, exceed the concentration limits specified in Table I of Appendix B to 10 CFR Part 20, shall be covered by a Radiation l
Work Permit (RWP).
l The RWP shall be issued by the Health-Safety group.
It' ***
i shall specify the safety requirements, protective clothing l
and equipment, and monitoring requirements necessary to l
assure the operation is conducted in a safe' manner.
l1 1
8.5 Receiving Inspection j
8.5.1 SNM receipts'shall be inspected for damage, and surveys j
conducted to ascertain if the level of contamination is j
acceptable for CNFP handling and storage.
Results in excess of contamination limits specified by the Department of j
Transportation shall be reported to Health-Safety for i
DATE 2-10-86 REVISION NO.
3 PAGE 58 l
CURRENT REVISION:
SUPERSEDES: PAGE 79 m mg mm.
2-04-85 2
DATE REWSM
BABQXX & WIL(DX CTPANY, C0ftERCIAL NUCEAR REL PIM USNRC LICENSE SNM-ll68 DOCKET 20-1201 V CONDITIONS
~
SECTICH 8.0 Technical Specifications - Radiation Safety (continued) 8.5.1 n tification of the shipper and evaluation of the need for decontamination.
8.6 Non-Exempt Sealed Source Control 8.6.1 Use of non-exempt sources for training and instrument calibration shall be Ifmited to, or under the direct control of, qualified Health-Safety personnel.
8.6.2 Sources utilized as a functional component of devices designated for manufacturing and quality control purposes shall be operated only by approved personnel who have been instructed in safe practice by Health-Satety.
Health-Safety shall provide appropriate monitoring support """
during maintenance o'r other operations that may entail 4
increased exposure levels. A register of approved operators.shall be maintained in the Health-Safety Office.
8.6.3 Maximum whole body exposure rates in any constantly occupied area in the vicinity of operating manufacturing or quality control units utilizing by-product material sources shall be less than 2 mrem /hr.
8.6.4 In addition to dosimetric devices routinely worn by all CNFP employees, appropriate self-reading dosimeters shall be utilized by personnel involved in source MTE
~ 2-10-E6 REVISION NO.
3 PAGE 59 i
CURRENT REVISION:
SUPERSEDES: PAGE 59 USNRC APPROVE REN MTE 2-04-85 REVISION 2
BABC0CK a WILCOX COWA% C0itERCIAL NUCLEAR FLEL PLM USNRC LICENSE Sitt-ll68 DOCKET 70-3201 SECTION
.V CONDITIONS 10.
Failed Fuel Rod Detection System c
10.1 Description of Activities A Radiation Control Zone (RCZ) will be established for activities with the ECH0-330 when it is out of the storage configuration.
Typical activities performed on the ECH0-330 equipment in the RCZ include decontamination, repair, testing, and packaging.
The ECH0-330 will be appropriately packaged and labeled to prevent contamination spread when in the storage configuration.
10.2 Radiation Control Zone (RCZ)
The following conditions apply to the establishment and maintenance of the RCZ.
10.2.1 The RCZ will be physically defined (rope and/or changeline tape) at the CNFP plant site.
10.2.2 All maintenance of contaminated ECH0-330 equipment shall be performed within the RCZ.
10.2.3 The action levels used for radiological control within the RCZ are given in Table 1 of this part.
10.2.4 Access to the RCZ area shall be controlled by Health-Safety ***
Visitors to the RCZ must be accompanied by authorized personnel.
l DATE 2-10-86
' REVISION No.
' 1 PAGE ' 67 CURRENT REVISION:
SUPERSEDESi PAGE 67 USNRC APPROVAL REFERENCE 5-07-85 DATE REVISION 0
BABC0CK c, WILC0X C0ffA'4Yi C0(ERCIAL NUCLEAR FUEL PLM USNRC LICENSE SNtt-ll68 DOCKET 70-1201 SECTION
.V CONDITIONS 10.
Failed Fuel Rod Detection System 10.2.5 Upon return to the CNFP, radiological surveys shall be performed prior to any initial maintenance or handling of the ECH0-330 equipment.
10.2.6 Contaminated equipment that exceeds the Radiation Control Zone limits in Table I shall be decontaminated.
10.2.7 Radiological surveys shall be documented and maintained by Health-Safety personnel for a minimum of 2 years or longer if required by Federal Regulations.
10.2.8 During periods of maintenance on the contaminated equip-ment, radiological surveys of the RCZ shall be performed at ***
least daily.
10.2.9 During periods of long term storage, weekly surveys of the RCZ for external radiation and removable contamination ***
shall be performed, except during CNFP plant shutdown of a week or longer, but not to exceed 3 weeks.
DATE 2-10-86 REVIS101 No.
1 PAGE 68 CURREffT REVISlal:
SUPERSEDES: PAGE 68 USNRC APPROVAL REFERE!4CE DATE 5-07-85 REVISla; O
~
BABC0CK & WILCOX C0WANY, C0ffERCIAL NUCLEAR FUEL PLM USNRC LICENSE SNtt-ll68 DOCKET 70-1201 SECTION
.V CONDITIONS i
10.
Failed Fuel Rod Detection System 10.2.10 Removai of RCZ designation (including physical markings like ropes and changelines) shall require a documented survey that the RCZ area meets the Unrestricted Area Release Limits in Table 2 of this part.
10.2.11 All personnel entering the RCZ shall wear as a minimum pro-tective lab coats and shoe covers. All personnel handling contaminated equipment shall also wear protective gloves.
Upon exiting the RCZ, personnel shall survey to assure they
]
meet unrestricted area release limits given in Table 2 of l
this~part.
i 10.2.12 Radiation workers shall receive initial indoctrination a
training before they are allowed to work in the RCZ.
This training is as described in Paragraph 6.2 of Section V of
)
i l
)
i DATE 2-10-86
~ REVISION No.
1
~PAGE-69 CURRENT REVISION:
SUPERSEDES: PAGE 69 USNRC APPROVAL REFERENCE DATE 5-07-85 REVISION 0
. =
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4 PABC0CK & WILC0X COW.n C0tN_RCIAL NUCIFA FUEL PLM i
USNRC LICENSE SNtt-ll68 DOCKET 70.1201 i
SECTION
. V CONDITIONS 3
10.
Failed Fuel Rod Detection System 10.2.13 Instrumentation shall be calibrated as indicated in Section 8.3.4.
10.2.14 Respirators may be used in unusual conditions where air-borne concentrations of radioactive material may cause personnel to receive exposures in excess of permissible levels. Typical unusual conditions may be certain maintenance operations, short-term operations, etc. Pro-
}
cedures for maintenance of the respirators and training i
)
of personnel using respirators shall be under the I
cognizance of Health-Safety.
1 i
i DATE 2-10-86
' REVISION NO.
I
~PAGE-
-70 CURRENT REVISION:
i SUPERSEDES: PAGE 70 USNRC APPROVAL REFERENCE DATE 5-07-85 REVISION 0
-....-.~. -
- .--~.~......~--
a I
BABC0CK a WILC0X COWANYj C0(1TRCIAL NUCLEAR FLEL PLM USNRC LICENSE SNM-ll68 DOCKET 70-1201 SECTION
- y. CONDITIONS 10.
Failed Fuel Rod Detection System 10.2.14 The Respiratory Protection Program shall be conducted in accord with 10 CFR 20.103.
10.2.15 Personnel and/or fixed air samplers shall be used to deter-mine exposure to airborne radioactivity during maintenance operations.
Health-Safety shall specify frequency of per-sonnel sampling based on operational experience and Health Physics judgement to keep exposures within 10 CFR 20.103(a) i limits.
Gaseous effluents from the RCZ shall be used to determine compliance with 10 CFR 20.106(a).
Fixed i
boundary and RCZ air samples shall be run daily during maintenance operations.
HEPA filtered containment facili-ties such as disposable tents or enclosures, shall be i
used in accord with good Health Physics practice as required by Health-Safety to control airborne radioac-I tivity. HEPA filters shall be changed when the differential pressure exceeds 4" of water.
Differential pressure l
shall be recorded weekly when containment facilities are in use.
l l
2-10-86 DATE
' REVISION No.
1
'PAGE 71
~
CURRENT REV1S10N:
SUPERSEDES: PAGe_
71 USNRC APPROVAL REFERENCE
.0 DATE 5-07-85 REVISION
BABC0CK & WILCOX COWA% C0fiERCIAL NUCLEAR FUEL PlM USNRC LICENSE SNti-ll68 DOCKET 70-1201 SECTION
.V CONDITIONS.
10.
Failed Fuel Rod Detection System 10.2.16 Personnel working directly in the RCZ shall be included in the bioassay program of at least one in vivo measurement per year, if they work in an area which is designated as an airborne radioactivity area as defined in 10 CFR 20.203(d).
Additional bioassays shall be performed when, in the judgement of Health-Safety that conditions during work were such that significant internal exposure may have occurred. Such conditions include but are not limited to:
1.
Nasal smear results indicating facial contamination in excess of 10,000 DPM.
2.
An internal exposure in excess of 40 MPC. Hr. in any seven consecutive days.
3.
Any accidental internal exposure, whether real or suspected.
Immediate followup bioassay (excreta) measurements shall be performed if any of the 3 conditions noted above exist. If the followup measurements confirm the presence of greater than 10% of the maximum permissible organ burden, the worker will be restricted from work in a contaminated airborne environment until the maximum permissible organ burden is under 10%.
DATE 2-10-86 REVISION NO.
1 PAGE' 72^
CURRENT REVISION:
SUPERSEDES: PAGE 72 USNRC APPROVAL REFERENCE DATE 5-07-85 REVISION 0
.... ~
o FRC0CK a WILCOX COPPN1YJ C001ERCIAL NUCLEAR FUEL PLMT USNRC LICENSE SNft-ll68 DOCKET 70.1201 SECTION V CONDITIONS 1
10.
Failed Fuel Rod Detection System 10.2.16 Prior [o Health-Safety approval of an individual to work in the RCZ, the individual's occupational radiation exposure 1
history (both internal and external) shall be reviewed.
10.2.17 The reactor inspection equipment contain only l
contamination quantities of by-product material and there-j fore does not require special handling with regard to nuclear criticality safety.
10.2.18 Contaminated wastes that cannot be disposed of under the current conditions in Section V will, be transferred to a licensed facility for subsequent disposition.
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1 I
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i DATE 2-10-86 REVISION f0.
1 PAGE' 73 CURRENT REVISION:
~
SUPERSEDES: PAGE 73 USNRC APPROVAL REFERENCE
i DATE 5-07-85 REVISION 0
_. ~. _
.o BABC0CK & WILC0X M1%1Y, COI1T.RCIAL NUCLEAR FLEL PLM USNRC LICENSE Snit-ll68 DOCKET 70.1201 SECTION V
CONDITIONS E
TABLE 1:
RADIATION CONTROL ZONE (RCZ) LIMITS
- l Beta-Gamma e
Total (Fixed & Removable)
Item External Radiation Removable Contamination i
i 2',,
- 1. Protective Clothing
.5 mR/hr. at I cm 5,000 DPM/100 cm
- 2. Equipment Maintenance 2
and Storage 50 mR/hr. at I ft.
500,000 DPM/100 cm l
- 3. Floors, Walls, and 2
other Surfaces 1.0 mR/hr. at 1 ft.
5,000 DPM/100 cm k
- Alpha contamination will be controlled as indicated in i
Part 8.4.5 of Section V.
- As measured by direct survey.
- l 1
l i
DATE 2-10-86 REVISION No.
1 PAGE' 74 l
~
~
{
CURRENT REVISION:
f SUPERSEDES: PAGE 74 USNRC APPROVAL REFERENCE i
DATE REVISim 5-07-85 0
l
BABC0CK & VILC0X C0ff.E COMRCIAL NUCLEAR FLEL PLM USNRC LICENSE SNti-ll68 DOCKET 70-1201 SECTION V. CONDITIONS.
O r
L TABLE 2:
UNRESTRICTED AREA RELFASE LIMITS
- Beta-Gamma Item External Radiation Removable Contamination
- 1. Skin, Hair, and Personal Clothing Min. Detectable Level Min Detectable Level **
2
- 2. Equipment 0.2 mR/hr. at I cm 1,000 DPM/100 cm
- 3. Floors, Walls, and 2
Other Surfaces 0.2 mR/hr. at I cm 1,000 DPM/100 cm
- Alpha contamination will be controlled as indicated in Part 8.4.5 of Section V.
- As measured by direct survey.
i I%TE 2-10-86 REVISION No.
l'
~PAGE' 75-CURRENT REVISION:
~,
SUPERSEDES: PAGE 75 USNRC APPROVAL REFERENCE-5-07-85 0
DATE REVISION
.