ML20209G346
| ML20209G346 | |
| Person / Time | |
|---|---|
| Site: | 07000824 |
| Issue date: | 08/20/1985 |
| From: | Olsen A BABCOCK & WILCOX CO. |
| To: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 25672, NUDOCS 8509190236 | |
| Download: ML20209G346 (25) | |
Text
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RETURN TO 396-SS 84 gg Researcn & Development Division Babcock & Wilcox tynenburg n.s..rca conier P. O. Box 1116s E ' 22 All :27 (24) 522ew'S'"'a 24 sos.
'Y"'"b"'S V' August 20, 1985 Uranium Process Licensing Section Uranium Fuel Licensing Branch NMSS m M 23 P2:26 U. S. Nuclear Regulatory Commission
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Washington DC 20555
SUBJECT:
Amendment No. 9
REFERENCE:
License SNM-778, Docket 70-824 I request that.the referenced-license.be amended to reflect changes in the organization at the Lynchburg Research Center.
Attached are replacement pages for. Sections 2 and Appendix A for the license application manual, BAW-381,." Demonstration and Conditions for License SNM-778." An attachment entitled " Instruction Sheet" describes the manner for entering the. changed,pages and an attachment entitled
" Description of Changes" describes the changes'that were made. Changes on the replacement pages'to' the manual are denoted by vertical lines in the right margin opposite _the. line where a change appears.
The organization was changed by adding the position of Manager, Safety and Licensing. The Health and Safety Group," consisting of Health Physics and Industrial Safety, previously reported to the Manager, Facilities Department. This Group now reports to the Manager, Safety and Licensing.
The Accountability Specialist and License Administrator previously re-ported to the Manager, Accounting and Administrative Services. These two positions now rAport'to'-the Manager, Safety and Licensing. The intent of these changes..is.to consolidate the positions that have license related responsibilities unde'r~one manager who reports to the Director.
Amendment No. 5 to the license reduceithe possession limits for SNM to below one effective kilogramc This change eliminated the need for a Nuclear Materials Manager and this amendment reflects that change.
A check in the amount of $150.00 is attachtd to cover the fee for an administrative amendment.
Very truly yours, 9
N BABC0CK & WILC0X oocmm Research and Development Divisic, 6
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BAW-381 DEMONSTRATION AND CONDITIONS FOR LICENSE SNM-778 REVISION 19,' AMENDMENT N0. 9 DESCRIPTION OF CHANGES Page Section Change 2-1 2.1 Change reflects one Facility Supervisor.
2-2 2.2.2 Change reflects one Facility Supervisor.
Changed "shall" to "may."
2.2.3 The position of Manager, Safety and Licensing is added.
2-3 2.2.4 Sentence #1 was reworded for clarity.
Paragraph #2 was changed to reflect the new reporting chain.
2-4 2.2.6 Subitem 3 was changed to reflect one Facility Supervisor.
2-5 2.2.7 Change reflects one Facility Supervisor 2-6 2.2.7 Changed " month" to " quarter" in two places.
Subitem 4, changed " month" to " quarter."
2.2.3 (Old) Deleted the position of Nuclear Materials Manager.
2.2.8 (New) Changed to reflect the new reporting chain.
2.2.9 Deletes the coordination of the Facility Supervisors and changes the reporting chain.
2-7 2.3 New description of the Facilities Department.
2-8 Figure 2-1 reflects the present organization.
2-9 Figure 2-2 reflects the present organization.
A-5 No change.
A-6 No change.
A-7 Line 1, Change reflects one Facility Supervisor.
Line 2, Deleted "These supervisors, appointed by LRC management, are. responsible for the safe operation and control of activities and for the safe handling of licensed materials within the areas'of their supervision."
A.5.2.3 Line 4, Change reflects one Facility Supervisor.
A.5.2.4 Adds the new position of Manager, Safety and Licensing.
A-8 A.5.2.7 Deleted. the position of Nuclear Materials Manager and replaces it with the Accountability Specialist.
BAW-381 DEMONSTRATION AND CONDITIONS FOR LICENSE SNM-778 REVISION 19. AMENDMENT NO. 9 DESCRIPTION OF CHANGES 4
i Page
~ Section Change 4
A-8 A.S.2.8 The experience requirement was reduced from 12 years to 5 years. The 5-year requirement is consistent with the experience requirements for other positions.
A.5.2.9 The position responsibilities were deleted. These are described in Section 2.
. 5.2.10 Deleted descriptive material.
A-9
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A-10 No change.
A-45 No change.
A-46 New organization chart.
A-47 New organization chart.
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INSTRUCTION SHEET' i
BAW-381 DEMONSTRATIONS AND CONDITIONS FOR LICENSE SNM-778 REVISION 19, AMENDMENT NO. 9 TAKE OUT PAGE REPLACEMENT PAGE Page Rev Date-Page Rev Date.
2-1 1
9/79 2-1 19 8/85 2-2 1
9/79 2-2 19 8/85 l
.2-3 1
9/79 2-3 19 8/85 1
2-4 2
10/79 2-4 19 8/85 2-5 1
9/79 2-5 19
-8/85 2-6 1
9/79 2-6 19 8/85 2-7 1
9/79 2-7 19 8/85 2-8 14 7/81 2-8 19 8/85 O
2-9 14 7/81 2-9.
19
~8/85 I
I A-5 16 6/83 A-5 16 6/83 A-6
.1 9/79 A-6 19
'8/85 A-7 3
11/79 A-7 19 8/85 A-8 2
10/79 A-8 19 8/85 A-9 3
11/79 A-9 19 8/85 A-10 3
11/79
.,-10 3
11/79 A-45 1
9/79 A-45 1
9/79 l
-A-46 2
10/79
~A-46 19
'8/85 A-47 14 7/81 A-47 19 8/85 i
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ORGANIZATION AND SUPPORT SERVICES 2.1 ORGANIZATION The Director is responsible for all LRC operations. Two Laboratory Managers report to him.
The Laboratory Managers are responsible for opera-tions that fall within the areas of expertise encompassed by the sections under their control.
Section Managers report to the Laboratory Managers and are responsible for the safe performance of projects under their purview.
Research and development performed at the Lynchburg Research Center may result in projects being performed by sections of different laboratories in the same building.
For this reason, the Director has established the position of Facility Supervisor. He advises the Laboratory and Section l
Managers in the safety aspects and the control of licensed material, ard coordinates the safety program within their areas.
The Facility Supervisor utilizes the expertise of the Supervisor, Health and Safety, the Accounta-bility Specialist, Nuclear lafety Officer, and the Industrial Safety Officer (n.
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to insure the safety of operations performed at the LRC.
2.2 POSITION REQUIREMENTS The minimum requirements for key positions in the organization are as follows.
2.2.1 Laboratory Manager They shall be appointed in accordance with Company policy.
2.2.2 Facility Supervisor The Facility Supervisor must demonstrate to Company management, proficiency in the application of good principles of radiation protection, License No SNM 778 Docket No.70-824 Date August, 1985 m
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Amendment No.
9 Revision No. 19 Page 2-1
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Babcock & Wilcox a McDermott company
industrial safety, and nuclear criticality safety as related to the activities expected in his area of responsibility.
He must have a minimum of three years of related experience and either hold a degree in related work or have five years of experience in the use and handling of licensed material.
The Facility Supervisor is appointed by the Director. He shall be i
responsible to the Director for the safe conduct of all operations at the LRC and for ensuring that these operations are conducted in accordance with all license conditions.
The Facility Supervisor shall become familiar with all license con-ditions and procedures concerned with radiation safety, nuclear safety, industrial safety, and nuclear materials safeguards. He may consult with the l
following personnel to ensure compliance with all safety regulations and principles:
Supervisor, Health and Safety Nuclear Safety Officer Industrial Safety Officer Accountability Specialist In addition to the general responsibilities stated above, the Facility Supervisor shall be responsible for:
1.
Reviewing and approving all Area Operating Procedures.
2.
Terminating any operation he deems contrary to license conditions, area operating procedures, or general safety conditions.
3.
Designating an alternate to assume his responsibilities in the event of his absence.
2.2.3 Manager, Safety and Licensing The Manager, Safety and Licensing shall have a BS degree in a techni-cal field and five years experience in the nuclear field. The Supervisor, Health and Safety, License Administrator, and the Accountability Specialist report to him.
License No SNM-778 Docket No.70-824 Date August, 1985 Amendment No.
9 Revision No. 19 Page 2-2 Babcock &Wilcox a McDermott company
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2.2.4 Supervisor, Health and Safety x-The Supersisor, Health and Safety shall have a BS degree in a techni-cal field and professional experience in supervising a radiation protection l
program. He shall have at least five years experience and demonstrate pro-ficiency in the application of radiacion safety principles and be knowledge-able in fields related to radiation protection.
The Supervisor, Health and Safety reports to the Manager, Safety and Licensing. He has direct access to the LRC Director in matters concerning Health and Safety.
The Health Physics Group and the Industrial Safety Officer report to the Supervisor, Health and Safety.
2.2.5 Health Physics Engineer The Health Physics Engineer shall have a BS degree, with course work in health physics. He shall report to the Supervisor, Health and Safety and is responsible for the activities of the health physics staff at the LRC, which include:
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1.
Performing area surveys 2.
Administering the air survey program 3.
Administering the respiratory protection program 4.
Administering the bioassay program 5.
Leak testing radioactive sources 6.
Supervising shipping and receiving of radioactive material 7.
Supervising and coordinating the waste disposal program 8.
Assisting in personnel, equipment, and facility decontamination 9.
Conducting radiation safety training 10.
Providing expertise in all aspects of radiation protection License No SNM-778 Docket No.70-824 Date August, 1985 n
Amendment No.
9 Revision No. 19 Page 2-3 is_-)
Babcock &WHcox a McDermott company
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Generating, maintaining, and distributing records and reports required by regulations or procedures within the Health Physics Group 12.
Distributing and processing personnel monitoring equipment, notifying supervisors of exposures that exceed permissible limits, and recommending appropriate restrictions.
2.2.6 Industrial Safety Officer The Industrial Safety Officer shall have at least one year's experi-ence in radiation and industrial safety.
He shall be familiar with the codes and requirements of the Occupational Safety and Health Act of 1970 and the National fire Protection Association. The Industrial Safety Officer reports to the Supervisor, Health and Safety.
The responsibilities of this position are:
1.
Administering the industrial safety program 2.
Reviewing proposed facility changes to insure fire safaty 3.
Providing extertise in fire prevention to the Facility Supervisor and the Safety Review Committee 4.
Performing tests. maintenance, and inspection of fire protection, control, and extinguishing equipment 5.
Providing training for the LRC fire and rescue team and all site support agencies 6.
Inspecting all areas of the LRC periodically to ensure:
a.
Proper storage and use of flammable solvents b.
Proper placement of fire extinguishing equipment c.
Elimination of fire hazards d.
Reduction, to the minimum practicable levels, of flammable materials Proper use and maintenance of electrical equipment.
e.
License No SNM-778 Docket No.70-824 Date August, 1985 Amendment No.
9 Revision No.
19 Page 2-4 Babcock &Wilcox a McDermott company 1
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Work with supervisors to formulate safety rules and eliminate hazards 8.
Investigate all accidents 9.
Keep management informed concerning safety activities 10.
Arrange for safety films, lectures, and other training in industrial safety, as required.
2.2.7 Nuclear Safety Officer The Nuclear Safety Officer must be technically trained and have a BS degree in science or engineering with experience as a responsible reactor engineer or nuclear physicist. He must have been engaged for one year in an activity that would develop an understanding of the nuclear criticality problems as they relate to the LRC.
It shall be this Officer's responsibility to ensure that no operation at the LRC can lead to the inadvertent assembly of a critical nass. To help assure this, he will review all new Area Operating Procedures as well as f-^)
changes to these procedures, observe operations, institute educational t(_)
' programs if and when he deems them necessary, and carry our confirming nuclear criticality safety calculations.
The Nuclear Safety Officer does not in any way relieve the Facility Supervisor of his responsibility for ensuring safe operations at the LRC, l
nor will it eliminate the necessity for the reviews by the Safety Review Committee.
Once a month, the Nuclear Safety Officer will inspect all LRC opera-tions where special nuclear material is being processed. Other areas shall be inspected less frequently; however, all areas shall be inspected at least twice a year.
He shall consider area operations when scheduling these in-spections and shall, if necessary, schedule his inspection at more frequent intervals. His consideration should include inspection of new operations, an audit of nuclear safety records, a check for area posting and a review of current practices.
i License No SNM-778 Docket No.70-824 Date August, 1985
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Amendment No.
9 Revision No. 19 Page 2-5 Babcock &Wilcox a McDermott company
A written report is to be filed with the Director quarterly with a copy to the License Administrator. Prior to submission of the report, he shall discuss its contents with the Facility Supervisor.
The report shall be brief, concerning itself with inspections made during the quarter, and with the nuclear sr.fety activity of the quarter.
The follouing information is to be included:
1.
Areas visited 2.
Operations observed 3.
Unsafe practices or situations noted 4.
Nuclear safety activity of the quarter 5.
Recommendations.
2.2.8 Accountability Specialist The Accountability Specialist shall have at least a high school education or equivalent snd at least one year's experience in the nuclear fuel business. He is responsible for the maintenance and retention of SNM accountability records, preparing and transmitting required reports generated from these records. The Accountability Specialist reports to the Manager, j
Safety and Licensing.
I 2.2.9 License Administrator The License Administrator shall have a BS degree in science or engineering and three year's experience in nuclear technology or an AS degree in scienca or nuclear technology with five year's experience in nuclear technology. He is responsible for administering the license.
He is the primary liaison with the U. S. Nuclear Regulatory Commission and other federal, state, and local agencies regarding nuclear matters.
He is the coordinator of the Safety Review Committee and the Safety Audit Subcommittee and represents LRC management on both.
The License Administrator reports to the Manager, Safety and Licensing.
License No SNM-778 Docket No.70-824 Date Augus t,1985 Amendment No.
9 Revision No. 19 Page 2-6 Babcock &Wilcox a McDermott company
2.3 FACILITIES DEPARTMENT Design and drafting services, machine shop services, equipment mainte-nance, modification and installation services are provided by the Facilities Department.
Facilities Department personnel assist the Health Physics Group in assembling radioactive waste shipments.
They provide all groups at the LRC with material handling support.
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I License No SNM-778 Docket No.70-824 Date August, 1985 Amendment No.
9 Revision No. 19 Page 2-7 Babcock &Wilcox a McDermott company 1
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Any byproduct Irradiated 50,000 Ci material structural material &
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Byproduct Any 3000 Ci each; total material with not to exceed atomic nos.
1,000,000 Ci 3 thru 83 14.
Trans-uranium Any 20 millircuries each elements 15.
Cf252 Sealed 4 milligrams sources 16.
Am241 Sealed 30 Ci sources 17.
H3 Sealed 100 Ci sources 18.
H3 Oxide 3 Ci i
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H3 Ni plated Sc 3 Ci Tritide foil i
License N o.
SNM-778 Docket N o.70-824 Date June, 1983 Amendment N o.
5 Revision N o.
16 Page _ A-5 L
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O A.4 RESTRICTIONS A.4.1 Unirradiated Plutonium Research and development activities utilizing unirradiated plutonium shall be limited to the following operations:
1.
Research and development of analytical chemistry techniques and procedures.
2.
Preparation of irradiation and test samples.
3.
Scrap recovery.
4.
Research and development of sintering process techniques.
5.
Fuel characterization.
6.
Performance of studies of the conversion of plutonium nitrate of plutonium oxide.
A.4.2 Pyrophoric SNM Research and development or processing of special nuclear material in pyrophic form is limited to quantities not exceeding 200 grams of U-235, U-233, or plutonium. Pyrophoric SNM is finely divided U-233, U-235, or Pu metal powders no greater than 0.044 mm in diameter.
A.4.3 Plutonium-238 Research and development or processing of plutonium containing greater than 12% Pu-238 shall be performed in the hot cells.
A.4.4 Uranium Hexafluoride The LRC is restricted from processing or conducting research and development utilizing uranium hexafluoride.
A.5 ORGANIZATION AND POSITION REQUIREMENTS A.5.1 Organization The Director of the LRC has the ultimate responsibility for the safety of operations and the control of activities at the LRC.
He directs License No SNM-778 Docket No.70-824 Date August, 1985 Amendment No.
9 Revision No.
19 Pags A-6 Babcock & Wilcox a McDermott company
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t the safety of these activities through the Facility Supervisor. The Facility Supervisor is assisted by the Supervisor, Health and Safety, the l
l Nuclear Safety Officer, and the Accountability Specialist in fulfilling j
his responsibilities.
A.5.2 Position Requirements The minimum requirements for the key positions are'given below:
A.5.2.1 Laboratory Manager - Laboratory Managers shall be appointed in accordance with Company policy.
A.S.2.2 Section Manager - Section Managers shall have a BS degree and three years post graduate or equivalent training in the pertinent technical field. They are responsible for the safe performance of projects under their purview. Section Managers shall have demonstrated knowledge in the appl'. cation of radiation and nuclear criticality safety associated with their rrojects.
A.5.2.3 Facility Supervisor - The Facility Supervisor must demon-
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strate to Company management proficiency in the application of good principles of radiation protection, industrial safety, and nuclear safety, as related to the activities at the Lynchburg Research Center. He must l
have a ninimum of three years of related experience and either hold a degree in his related work or five years' additional experience in the use and handling of licensed material. The Facility Supervisor shall be re-sponsible for reviewing and approving Area Operating Pr3cedures to ensure that among other things that the concerns of the Industrial Safety Officer are incorporated. He shall have the authority to terminate any operation that he feels is contrary to license conditions, Area Operating Procedures, or general safety conditions.
A.S.2.4 Manager, Safety and Licensing - The Manager, Safety and Licensing shall have a BS degree in science or engineering and five years' License No SNM-778 Docket No.70-824 Date August, 1985 (A)
Amendment No.
9 Revision No.
19 Page A-7 Babcock &Wilcox a McDermott company
experience in the handling and use of licensed material.
A.5.2.5 Supervisor, Health and Safety - The Supervisor, Health and Safety shall have a BS degree in a technical field and professional experi-ence in assignments involving radiation protection at a supervisory level.
He must have five years' experience and demonstrate proficiency in the application of radiation safety principles and be knowledgeable in fields related to radiation protection.
A.5.2.6 Nuclear Safety Officer - The Nuclear Safety Officer shall be technically trained and have a BS degree in science or engineering.
He must have either two years' experience with nuclear criticality safety calculations similar to those associated with LRC activities, or he must have one years's experience in nuclear reactor physics calculations.
All nuclear criticality safety calculations that require a second party reviewer shall be reviewed by an individual whose qualifications are the same as those required above for the Nuclear Safety Officer.
A.5.2.7 Accountability Specialist - The Accountability Specialist j
shall have at least a high school education and three years' experience in the use of license. mate rial.
He must demonstrate to Company management j
his knowledge of tua principles necessary for the accountability and safe-guarding of special nuclear material.
A.5.2.8 License Administrator - The License Administrator shall have a BS degree in science or engineering and three years' experience in nuclear technology or an AS degree in science or nuclear technology and five years' experience in nuclear technology.
A.S.2.9 Health Physics Engineer - The Health Physics Engineer shall have a BS degree which shall include at least 20 quarter hours of health physics related course work or the equivalent in work experience.
License No SNM-778 Docket No.70-824 Date August, 1985 Amendment No.
9 Revision No.
19 A-8 Page Babcock &Wilcox a McDermott company
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\\d A.S.2.10 Industrial Safety Officer - The Industrial Safety Officer shall have at least one year's experience in radiation and industrial safety.
He shall be familiar with the codes and requirements of the Occupational Health and Safety Act of 1970 and the National Fire Protection Association.
A.6 ADMINISTRATIVE CONTROL Procedures control and provide the necessary direction to coordinate and ensure the safe operation of activities at the LRC.
In addition to formal procedures, numerous routine activities are conducted in accordance with established practices developed through years of operational experience.
Many of these have never been produced in written form since the basis for ensuring safe operation rests with the experienced scientist, engineer, and technician. Work involving the use of licensed material that is not covered by an approved written procedure shall be performed pursuant to a Radiation Work Permit (RWP).
RWP's shall be reviewed and updated quarterly.
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Amendment No.
9 Revision No.
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The LRC procedures are defined as follows:
A.6.1 Demonstration and Conditions for License SNM-778 This document presents the procedures necessary to show compliance with the license conditions.
l.
Additions or changes to the procedures in the demonstration sections of
" Demonstration and Conditions for License SNM-778" are submitted to the LRC license administrator, who, with the concurrence of the Director, laboratory managers and facility supervisor, may implement these changes or additions. Prior to implementation, all changes or additions are referred to the Safety Review Committee.
A.6.2 Area Operating Procedures Area operating procedures are facility procedures for the safe handling of licensed material.
1.
Additions or changes to area operating procedures are sub-mitted to the representative facility supervisor. The facility supervisor forwards the submittal to the supervisor, health and safety, and nuclear safety officer for review and approval. The health physicist and nuclear safety officer shall be independent of the operation under review.
Subsequent to these approvals he shall review and approve the addition or change. The Facility Superv shall consider the recommendations of the Industrial Safety Officer.
2.
All area operating procedures and revisions thereto shall be approved by the Safety Review Committee except:
a.
Revisions correcting spelling or typographical errars.
b.
Revisions in the procedure form or format.
c.
Procedures and revisions that govern the use of equipment that does not have an effect on the use or handling of licensed material.
3.
Area operating procedures shall be followed and sitall be available in each operations area.
License No.
SNM-778 Docket No.70-824 Date November 1979 Page A-10 Amendment No.
Revision No.
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