ML20212L152

SER Supporting Renewal of License SNM-7

ML20212L152
Person / Time
Site:	07000008
Issue date:	03/31/1983
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20212L140	List: ML20212L134 ML20212L141 ML20212L147 ML20212L152
References
NUDOCS 8703100259
Download: ML20212L152 (50)

Text

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SAFETY EVALUATION REPORT BY THE DIVISION OF FUEL CYCLE AND MATERIAL SAFETY RELATED TO THE LICENSE RENEWAL OF THE BATTELLE COLUMBUS LABORATORIES COLUMBUS, OH CCCKET NO. 70-8 LICENSE NO. SNM-7 MARCH 1983 8703100259 870303 gDR 8 ADOCK 0700000s pon

, 44, TABLE OF CONTENTS Page

1.0 INTRODUCTION

. . . . . . . . . . . . . . . . . . . . . . . . . 1 1.1 Background . . . . . . . . . . . . . . . . . . . . . . . . I 1.2 Authorized Activities. . . . . . . . . . . . . . . . . . . 2 1.3 Possession Limits and Places of Use. . . . . . . . . . . 3 1.4 Scope of Review. . . . . . . . . . . . . . . . . . . . . 4 1.5 Modifications as a Result of Staff Review. . . . . . . . . 4 1.6 Compliance History . . . . . . . . . . . . . . . . . . . . 4 2.0 CONOUCT OF OPERATIONS . . . . . . . . . . . . . . . . . . . . . 6 2.1 Management Organization. . . . . . . . . . . . . . . . . . 6 2.2 Administrative Controls and Procedures . . . . . . . . . . 8 2.3 Audits and Reviews . . . . . . . . . . . . . . . . . . . . 10 2.4 Personnel Training Program . . . . . . . . . . . . . . . . 10 2.4.1 General Safety. . . ................

2.4.2 Radiological, Nuclear and Industrial Safet 2.4.3 Health Physics Personnel. . . . . . . . .. y. .. .. .. .

2.4.4 Emergency Response Trainin 2.4.5 0,ffsite Personnel . . .. .. g. .. .. .. .. .. ..... .. .. .. .

2.5 Emergency Plans. . . . . . . . . . . . . . 12 2.6 Quality Assurance. . . . . . . . . . . . . . . .. ..... .. .. .. 13 2.7 Decommissioning Plan . .................. 13 2.8 Staff Evaluation - Conduct of Operations . . . . . . . . . 14 3.0 SITE AND FACILITY CONSIDERATIONS. . . . . . . . . . . . . . . . 15 3.1 King Avenue Facility . .............. . . . 15 3.1.1 Site Description. .................

3.1.2 Facility Description. . . . . . . . . . . . . . .

3.2 Nuclea r Sciences Area. . . . . . . . . . . . . . . . . . . 20 3.2.1 Site Description. . ............ . . .

3.2.2 Nuclear Sciences Area Facilities Description. . . .

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. TABLE OF CONTENTS (Cont'd)

Page 4.0 RADIATION SAFETY. . . . . . . . . . . . . . . . . . . 25 4.1 Radiation. Safety Administration. . . . . . . . . . . . . . 25 4.1.1 Organization and Authority. . . . . . '. . . . . . .

4.1.2 Radiation Work Permit . . . . . . . . . . . . . . .

4.1.3 Radioactive Materials Application . . . . . . . . .

4.1.4 ALARA Commitment. . . . . . . . . . . . . . . . . .

4.2 Radiation Safety Controls. . . . . . . . . . . . . . . . . 29 4.2.1 External Radiation Exposure Control . . . . . . . .

4.2.2 Control of Internal Exposure s . . . . . . . . . . .

4.2.3 Contamination Control . . . . . . . . . . . . . . .

4.3 Radiation Protection Evaluation . . . . . . . . . . . . . 31 5.0 NUCLEAR CRITICALITY SAFETY. . . . . . . . . . . . . . . . . . . 32 6.0 RADIOACTIVE WASTE EFFLUENTS . . . . . . . . . . . . . . . . . . 34 6.1 Liquid Effluents . . . . . . . . . . . . . . . . . . . . . 34 6.2 Gaseous Effluents. . . . . . . . . . . . . . . . . . . . . 34 6.3 Solids . . . . . . . . . . . . . . . . . . . . . . . . . . 35 6.4 Staff Evaluation - Radioactive Waste Effluents . . . . . . 35 7.0 ACCIDENT ANALYSES . . . . . . . . . . . . . . . . . . . . . . 37 8.0

SUMMARY

EVALUATION / CONCLUSIONS. . . . . . . . . . . . . . . . . 39 11

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1. INTRODUCTION

1.1 Background

The initial License No. SNM-7 was issued in 1960 with renewal in February 1969 to Battelle Columbus Laboratories to conduct activities in facilities located near West Jefferson, Ohio and in Columbus, Ohio. The license was scheduled to expire in February 1974. However, since that time, the license has remained in effect in accordance with the timely renewal provisions, pursuant to sub-section 70.22(b) of 10 CFR 70. A revised renewal application dated October, 1981, which combines the Special Nuclear Materials License and Byproduct License No. 30-6854-5 contains a description of the activities to be licensed l and proposes license conditions for conduct of these activities.

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• Battelle Columbus Laboratories (BCL) is a research center of Battelle Memorial Institute, a nonprofit organization devoted to scientific research and develop-ment. Among the research activities, BCL conducts NRC-licensed nuclear research at the West Jefferson Nuclear Facility, located about fifteen miles west of Columbus, Ohio and at 505 King Avenue, Columbus, Ohio, where the corporate headquarters are located.

At the King Avenue location, small quantities of byproduct materials are used in bioscience laboratories and some research work involving enriched uranium is conducted. The West Jefferson Nuclear facility consists of four separate buildings located within a fenced, protected area. The four buildings are a Hot Cell Laboratory, a former Plutonium Laboratory, a building for administra-tive offices, and a building containing the remnants of a retired research reactor plus a waste storage area.

The Hot Call Laboratory is where the majority of BCL's radiological activities are conducted. It contains a large cell designed to accommodate as much as an entire fuel assembly. An adjacent fuel pool stores fuel as assemolies or individual rods. There are two additional cells for nandling fuel and irrac-f ated nonfuel items, a meenanical test cell, and ten small cells for work on 1

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, . . l irradiated specimens. The laboratory performs a wide range of research and development work, primarily related to the physical properties of irradiated fuel and other irradiated materials.

The Plutonium Laboratory has been decontaminated and decommissioned and is now used for non-radiological purposes.

Sponsors of the nuclear projects undertaken by BCL are private industry and the government primarily through the Department of Energy (00E). BCL's nuclear activities meet both Nuclear Regulatory Commission (NRC) and 00E requirements and are audited by both agencies.

The license under which BCL is currently operating is bread in nature and relies heavily on the licensee's capability and competency to provide adequate administrative controls to assure continued margins of safety for all aspects of the licensed activities. Similar Special Nuclear Materials (SNM) licenses are issued by the NRC when the staff has determined that the qualifications of the licensee's safety-related functions and administrative controls are adequate to protect the health and safety of the personnel, the public, and the environment.

1.2 Authorized Activities The renewed license combining the former SNM and Materials License will authorize BCL to acquire, store, process, and dispose of radioactive materials and to continue research and development work at the King Avenue facility and at the West Jefferson Nuclear Sciences facility near West Jefferson, Ohio. At the King Avenue site, the research and development activities are defined in 10 CFR 30.4(1) and include use of small quantities of mixed-fission products in support of life science projects. Additionally, provision is made for handling and processing small quantities of unirradiated U-235.

As the West Jefferson Nuclear Services area, a Hot Laboratory (JN-1) has been used for postirraciation examination of reactor materials, components and fuel and radiation source encapsulation. A general laboratory has been used for storage of SNM, a nuclear instrumentation laboratory, and support services.

A research reactor was formerly located in Building JN-3 and is now a retired 2

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facility. The Plutonium Laboratory, JN-4, has been devoted to research and development associated with plutonium materials. This latter. facility has been decontaminated, and therefore, continuance of that type development work-is not within the scope of the renewal request and this licensing action. The renewed license authorizes the continuing research and development activities at the King Avenue location and the West Jefferson Nuclear facility as described in the October, 1981 request.

1.3 Possession Limits and Places of Use 1.3.1 Special Nuclear Material Limitations King Avenue Facility Uranium enriched to greater than 5 percent w/o U-235 500 grams West Jefferson Facility Uranium-235, as contained in .

irradiated nuclear fuel 250 kgs Plutonium as contained in irradiated nuclear fuel 50 kgs Plutonium 500 grams 1.3.2 Byproduct Material Limitations King Avenue Facility Byproduct isotopes, total 500 cur'ies Byproduct, any one isotope 30 curies West Jefferson Facility Byproduct isotopes, total 22 million curies t

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1.4 Scone of Review The safety review of BCL's license renewal application included an evaluation of the revised application dated October, 1981 and BCL's decommissiening and financial plans, and various quality assurance documents.

Also included was a review of the compliance history, certain in plant records, the BCL organization, administrative controls and radiation protection, nuclear safety, and fire safety capability.

Comparative assessments were made against the requirements of 10 CFR 20, 10 CFR 30,10 CFR 70, the guidelines of applicable regulatory guides, and industrial standards and practices. Those used are identified in the appro-priate sections of the evaluation.

1.5 Modifications as a Result of Staff Review The review of the BCL facilities and operations did not identify the need for modifications to facilities and equipment or to management practices, including

' procedures developed to protect health and minimize danger to life and property.

1.6 Comoliance History The staff reviewed Inspection and Enforcement (I&E) reports of BCL's License SNM-7 and supplemented this analysis by discussion with I&E and BCL personnel. The review covered the period commencing July 1975. The following areas were examined:

frequency of exposure incidents a

location of incidents a

causes of incidences I&E citations issued to BCL Corrective actions taken by BCL 4

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Identified items of concern were:

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overexposures of individuals working in the JN-1 building in 1981 health physics coverage associated with the above problems Corrective actions by BCL on the above two items are discussed in Chapter 4,

" Radiation Safety."

In the review, the staff did not identify a pattern of chronic or repetitious problems with respect to regulations and license c.onditions. This, in part, provides justification for renewal of License No. SNM-7.

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2. CONOUCT OF OPERATIONS Battelle Columbus Laboratories, a division of Battelle Memorial Institute, has management staff located at Columbus, Ohio and at West Jefferson, Ohio. For the most part, nuclear activities are conducted under contract with the Depart-ment of Energy (DOE) and are, thus, exempt from NRC licensing. BCL's manage-ment and administrative controls are established to meet both DOE and NRC requirements.

The staff in its review compared BCL's organization and controls with draft ANSI N299, Draft 6, "American National Standard Administrative and Managerial Controls for Operations of Nuclear Fuel Reprocessing Plants," dated April 19, 1976.

This document is concerned with Nuclear Fuel Reprocessing Plants, but items concerning organization, audit and review, and policies and procedures are generally applicable to all nuclear facilities. In its reference to organization, ANSI-N299 generally states that the facility organi:ation should be clearly described, the positions and responsibilities of the position should be defined, the authority for discharging the responsibilities should be delegated 1n writing, the generic competence criteria for persons who are assigned to the position shall be established, the individuals assigned as replacements on a temporary or continuing basis shall have the minimum training and experience required for the position, and the support functions shall report to management independently of the operating organi:ation.

A description of the current management organization and administrative proce-dures is provided in this safety evaluation.

2.1 Management Organi:ation The following discussion provides a brief descrf ption of the organizational responsibilities pertinent to the conduct of radiological programs.

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Manager, Nuclear Technology and Physical Sciences Department Conduct studies in nuclear materials R&D, expecially those involving hot cells and decontamination and decommissioning and nuclear analysis.

Section Manager. Nuclear Materials Technology The Section Manager, Nuclear Materials Technology, is responsible for all aspects of safety with respect to hazard control in the activities of the section.- These activities are generally conducted in the hot cells. He is responsible for consultation and making appropriate arrangements with support services, committees or other personnel having expertise or responsibilities in areas involving operational safety. He assures that adequate procedures, training and retraining programs and equipment are in place.

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Section Manager, Nuclear Services The Section Manager, Nuclear Services, as does the Section Manager above, reports to the Manager, Nuclear Technology and Physical Sciences Department.

He is responsible for providing BCL nuclear services in the areas of opera-tional and env.ironmental health physics; packaging and transporting, waste management; materials accountability and safeguards; and quality assurance.

l Radiation Safety Officer The Radiation Safety Officer is a health physicist appointed by the Laboratory Director as his direct link to all radiological activities. As discussed later in Chapter 4, Madiation Safety," the Radiation Safety Officer reports directly to the Laboratory Of rector. He is cognizant of all BCL activities involving radiation and his acproval is required for all new and continuing work. He is responsible for periodic audits and evaluations of ongoing activ-ities to: (1) assure that adequate procedures, equipment, and monitoring and surveillance techniques are being used, (2) evaluate routine health anysics data and (3) investigate unusual occurrences to determine that safe and nealthful working conditions are maintained.

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Senior Research leader, Nuclear Safety The Senior Research Leader, Nuclear Safety, reports directly to the Manager, Nuclear Technology and Physical Sciences Department. He is responsible for criticality, shielding, and dosimetry analyses for nuclear systems and irrad-1ation experiments.

2.2 Administrative Controls and procedures BCL has developed an internal review system to ensure that activities are conducted in a safe and efficient manner. Procedures have been developed for initiation and review of all changes in existing and new equipment, design or location, storage areas, emergency procedures, limits, or operating procedures '

requiring change in nuclear criticality or radiation protection controls.

These may be administered by BCL without specific review and approval of the NRC.

• As part of the procedures, a written safety evaluation for a new activity is prepared by the Section Manager and approved by the Radiation Safety Committee (RSC). BCL relies strongly on the expertise of individuals available in the RSC or its delegated subcommittees to assess the adequacy of the proposed activities to protect personnel, the public, and the environment, and that ALARA considerations have been taken into account. Implementation of activ-ities is accompanied by written procedures and/or quality assurance olans which are approved by cogni: ant individuals.

The following additional acministrative procedures and manuals have been developed and adopted by BCL as part of its internal review and control system:

Ocerating Guide - The Operating Guide provides general guidance for the conduct of all coerations at BCL. Included is a section discussing radiological safety matters.

Radiological Safety Committee (RSC) Charter - The basic information on the assignment of responsibilities for radiological safety in BCL operations is 8

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contained in the RSC charter. In particular, it defines the role of the RSC, its membership and its relation to the overall radiological safety program.

In the staff's review of BCL's renewal app 1tcation "Part I, License Conditions" several aspects of the RSC's scope of responsibilities were briefly discussed.

Several, such as appraisal of operations and investigation of incidents, are more clearly presented in the Appendix A, Radiation Safety Committee Charter to the application. Therefore it was determined preferable *to incorporate the Charter as License Condition 13 as stated in Chapter 8 of this SER.

In addition to the RSC functions discussed in Appendix A, Section 5.1.1,

" Annual Review and Appraisal of Facilities" and to assure implementation of 10 CFR 20, Section 20.1(c) License Condition 14 is added to the license renewal; which assures a "as low as reasonably achievable" approach to occupational radiation exposures and releases of radioactive material, s Additionally Section 4.3.1, " Mandatory Review" provides nuclear criticality criteria to be used. The staff's review has resulted in several revisions as License Conditions 15,16 and 17 which are discussed Chapter 5.0, " Nuclear Criticality Safety" of this Safety Evaluation Report.

Quality Assurance Occument HL-A-1, Hot Laboratory Operational Safety - This quality assurance document provides the staff safety procedures and informa-tion on safety-related features for the Hot Laboratory located in Building JN-1.

It defines the:

responsibilities for each position in the operating organization.

laboratory safety rules and information for routine operations, alarm systems and required personnel response to alarms.

emergency equipment, facility security, the procedures and schedules for performing safety checks of equipment and systems anc the safety training program for new emoloyees, and 9

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the interactions between _ this safety program and the other SCL

, components.

Operating Procedures All operations at BCL are performed in accordance with written operating proce-dures available in the associated operating area. These operating instructions are available prior to the implementation of any new or modified activities or procedures involving radioactive material. All such operating procedures and any changes to these procedures are approved in writing by the appropriate personne1.

Radiation Work permit (RWp)

A RWP is prepared for all work on or involving entry into an area or system

.containing radioactive material not covered by an effective operating procedure, where a potential for release of contamination exists or exposure ~of employees to radiation'from the proposed operation or work is likely to exist. All RWPs are approved by a representative of the health physics support group.

The staff's review of BCL administrative controls and means for implementing them has determined them adequate for assuring safety of the operations.

2.3 _ Audits and Review Written review and audit programs have been prepared by BCL. They define the scope of the programs, designate the personnel and their area of competence, l the frequency of audits, required audit documentation, and define the areas to be audited. The specific areas audited include the operations and controls for: personnel and environmental radiation protection; nuclear criticality safety; industrial health and safety; and the overall safety program.

2.4 personnel Training programs BCL has established training programs for those personnel resconsible for handling radioactive material and those providing support to the various 10

activities. The training programs are designed to assure an adequate understanding by the employees of the hazards and complexities of handling radioactive materials both from the standpoint of radiological and nuclear criticality safety.

The initial and continuing training program is designed to _ develop an understanding of rules and procedures and to promote safety consciousness and sound safety practices.

BCL provides annual reinstruction and instruction when changes are made in radiation protection procedures, nuclear criticality safety controls, or emergency procedures.

These programs are described in Part II, Descriptive Supplements of BCL's renewal application. It is the staff's judgment that the programs are adequate.

However to assure continuation of this program License Condition 20 is included in the renewed license.

2.4.1 General Safety All employees receive basic instructions that instill an awareness and an understanding of the potential hazards associated with the BCL operations.

Various levels of first aid training are provided to ensure that sufficient personnel have knowledge to cope with situations that may occur in personal and industrial accidents.

2.4.2 Radiological, Nuclear and Industrial Safety All personnel associated with the handling of radioactive materials are instructed in the basic aspects of nuclear and industrial safety, radiation protection (health physics) procedures, together with standard operating procedures and approved emergency responses. After training, each individual is certified in writing for his ability to understand the information provided.

A periodic retraining program reemphasizes previous training and identifies any changes in safety policies or procedures. These training programs are documented.

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2.4.3 Health Physics Personnel Personnel assigned responsibility for the health physics program receive supplemental training. Each is given individualized training to complement his background and experience. As desirable, provision 1s made for attendance at offsite training schools. Successful completion of the training results in documented certification of the employee.

Recertification is scheduled at two year intervals.

2.4.4 Emergency Response Training All staff personnel are provided training with respect toEfire reporting and fire control by fire extinguishers. Red Cross First Aid courses are offered to personnel on a volunteer basis.

It is line management responsibility to identify operations requiring special emergency procedures. These procedures are incorporated in the normal job training program. Training sessions and drills are scheduled at frequency determined by the Emergency Coordinator (s) assigned responsibility for the specific type of accident event. A written evaluation of drills is prepared to provide guidance for improvement when indicated.

2.4.5 Offsite Personnel Provisions is made for exchange of information with various outside support groups. These groups are periodically provided information such as identiff-cation of substances handled in facilities, ha:ards associated with these substances, emergency procedures, maps of facilities, call lists and methods of notification.

2.5 Emeroency Plans At the time SCL was involved in activities using plutonium, it was required that they have emergency plans that meet the requirements of 10 CFR 50, Appendix E.

" Emergency Planning and Prepareeness for Production and Utili:ation Facilities."

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s However, on ' February 'll,1981, the Nuclear Regulatery Commission issued an -

order to BCL to prepare and submit specific radiological contingency planning information for its review.

The basis for this. order is found in NUREG-0767, "Critera for Selection of Fuel Cycle and Major Materials Licensees Needing Raciological Contingency Plans" datsd July 1981 and 10 CFR 70.22(1). BCL submitted its Radiological Contingency Plans to NRC on March 1982. Review of the plan determined it adequate and resulted in a License Condition to be incorporated in the license.

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This condition will be License Condition 22 in the renewed license.

~ 2.6 Quality Assurance Ouring the time of plutonium operations BCL implemented a quality assurance program that was required to meet 10 CFR 50, Appendix B, " Quality Assurance i Criteria -for Nuclear Power Plants and Fuel Reprocessing Plants." Although no longer required by regulation for their proposed activities, BCL has continued-this program. BCL considers this a necessary program to provide an adequately documented system" for policies, procedures, instructions, control of special proc' esses or activities, assuring corrective action is taken, records retention and an audit system.

Based upon our review and evaluation of tne BCL quality assurance program for their activities, we conclude the quality assurance personnel have sufficient authority, access to work areas, and organizational freedom to (1) initiate, recommend, and provide solutions to quality programs; (2) verify implementa-tion of solutions of quality problems; and (3) assure that activities are conducted in an approved manner.

2.7 Decommissioning Plan BCL has provided decontamination /decommd ssioning plans in correspondence dated November 22 and December 15, 1978; April 25, 1979; and October 1 and December 15, 1980. Accordingly, the staff amended tne BCL licenses June 19, 1981. The resulting amendment is incorporated in Part I, Section 5 of BCL's license renewal request. Therefore to affirm NRC's previous approval License Condition 23 is incorporated in the renewed license.

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Additionally it has become NRC's Fuel Cycle Division practice to require the licensee to provide NRC a report describing the decontamination activities leading to decommissioning. License Condition 24 is included to assure the information will be provided.

s During decontamination of JN-4, formerly the Plutonium building BCL also removed contaminated soil and' subsequently requested NRC authorization to backfill an excavation of a retired filterbed area. Authorization for back-filling is provided in License Condition 25.

2.8 Staff Evaluation - Conduct of Operations Review of past and current performance has shown BCL's conduct of operations to be satisfactory and capable of safe operation. The license application commitments and the demonstration portion of their license application presents the details the staff considers necessary for safe operation. We conclude on '

the basis of our review and consideration of the proposed guidelines in the draft ANSI-N299 standard that the management organization and administrative controls are adequate to protect health and minimize danger to life and property per 10 CFR 70.23(a)(2) and 10 CFR 70.23(a)(4).

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3. SITE AND FACILITY. CONSIDERATIONS Licensed activities are conducted by BCL at two locations in Ohio. These are known as the King Avenue Facility located in Columbus, Ohio and the Nuclear Sciences Area near West Jefferson, Ohio. This section discusses the types of

( facilities, their uses and engineered safety-related features. A portion of the safety evaluation review for the license renewal includes the staff assess-ment of the capability of certain facilities located at the Nuclear Science '

area to withstand the adverse effects of natural phenomena, i.e., earthquakes, severe weather and flooding. This work is presently underway, but not completed.

The natural phenomena review will include a detailed description of the Nuclear Science area's seismic, hydrological, and normal and severe meterological characteristics; the structure capability of the selected facilities; dispersion patterns for releases, if any; demography; radiological dose; and an overall risk assessment. This information will be presented in a supplement to this report.

3.1 King Avenue Facility 3.1.1 Site Description The BCL King Avenue facility is located in the west-central portion of the city of Columbus, Ohio. The ten-acre plot, accommodating twenty-one buildings, is bounded on the north by King Avenue, Perry Street to the east, Fifth Avenue on the south and the Olentang/ River on the west (Figure 3.1). Figure 3.2 is an expanded view of the King Avenue facility. Buildings 6 and 7 house the Biosciitnce Laboratories. Building 3 houses the uranium processing activities at the King Avenue facility.

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3.1.2 Facility Description 3.1.2.1 Uranium Laboratory The U-235 Processing facility is located in Building 3 of the King Avenue site. Building 3 was constructed in the mid-50s. It served until the late 60s as an exclusion area specifically designed for the processing and storing of unirradiated enriched uranium utilized on various government and. industrial R&D programs. Presently Building 3 is used for several activities, but access to the U-235 processing area is limited and entry doors to the area are alarmed.

A vault is used for the temporary storage of limited quantities of unirradiated enriched uranium. The area is also used for the receiving, storing, waste

, processing and packaging for shipment of source materials.

The major piece of processing equipment located in the area is an electric calcine furnace which is used for the reduction of scrap or waste to an oxide residue suitable for shipping to either a waste disposal site or scrap reprocessor. The furnace consists of a closed system muffle and glove-box combination. The exhaust system for the furnace is arranged so that room temperature air is drawn into and mixed with the hot exhaust gases within a blending box. The semicooled exhaust gases are then drawn through a water scrubber system which is equipoed with a re-circulating water system. After passing through the scrubber, the washed exhaust gases flow through a bank of absolute filters and are then exnausted to the outside atmosphere through a blower and duct opening on the roof.

The reduced residues and ash, after being burned and cooled are dumped into plastic bags within a glove-box. This glove-box is an exhausted, closed system and therefore the system operating pressure is negative to the room pressure.

This prevents any problem of contamination in the surrounding area exterior to the system.

The area is also the central gathering and packaging location for low-level radioactive contaminated waste. The area also served as a receiot anc snipping, sampling, and measurement area for shioments of botn source materials and 13

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a small quantities of unirradiated uranium which are utilized on programs being performed at the King Avenue site.

3.1.2.2 Bioscience Laboratories The Life Sciences Radioisotope Laboratories are designed for the preparation, utilization, and analysis of tracer quantities of radioisotopes in biological research. Such applications of low-level radioactivity will vary from use in live animals to isolated tissues and cells and for biochemical reactions in vitro. Only levels of radioactivity will be used, which after dilution in the system under analysis, will provide a sufficient quantity of radioactivity by sampling for valid quantitative identification.

The work performed is primarly tracer work with small quantities of individual radionuclides. Individual batches are normally on the order of 1 microcurie or less. Stock quantities are normally 10 militcuries or less. Annually the working inventory is a small number of isotopes, for example, the inventory for January 1980 consisted of a few isotopes with the maximum activity of any isotope being a few millicuries. Thus, the 500 curie possession limit notwith-standing the accidental release of the total working inventory is inconsequen-tial (see Chapter 7, " Accident Analysis").

Almost all the activity is of a wet chemistry nature using tagged compounds purchased from the supplier. Experiments using substances of low toxicity or otherwise low hazard are performed in standard fume hoods with no filtration in the exhaust system. Experiments utili:ing substances of increased toxicity or otherwise increased ha:ard are handled in especially designed hoods with filtered exhaust systems. Some substances may be handled in glove boxes. When tagging operations are done using byproduct material (e.g., such as iodinations) they are performed in hoods which have enarcoal filtration. The particulate filters are high efficiency; hoods are designed for face velocities of 100 to 150 linear feet per minute and are periodically tested. Exhaust stacisdischarge above the coof of a four-story building housing most of the laboratory facili-ties of this department. This stack disenarge level is about 55 feet aeove l ground level.

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3.2 Nuclear Sciences Area 3.2.1 Site Description The Nuclear Sciences area is located near West Jefferson, Ohio, approximately 17 miles west of Columbus, Ohio as shown in Figure 3.3. The. Nuclear Sciences Area is located on a 1,000 acre site as shown in Figure 3.4. Th.e JN-1 Hot Cell Laboratory houses hot cells and support facilities for postirradiation examination of reactor fuels, materials and components. The majority of the licensed activities are conducted in this facility. The JN-2 Critical Assembly Laboratory now houses the Special Nuclear Materials (SNM) vault, offices and laboratory space for supporting services. JN-3 is a dismantled research reactor which houses environmental monitoring services, plutonium contaminated waste storage area, and general office space. The former JN-4 Plutonium Laboratory was equipped for research and development work related to plutonium bearing materials but has now been converted for use on nonnuclear activities.

3.2.2 Nuclear Sciences Area Facilities Description As previously shown in Figure 3.4, there are four principal buildings at the West Jefferson Nuclear Sciences , area: JN-1; the Hot Laboratory; JN-2, the Critical Assembly Laboratory; JN-3, a retired Research Reactor; JN-4 Each of these facilities, except JN-4, which will not be covered in the renewed license, is described in the following paragraphs.

3.2.2.1 Hot Laboratory, JN-1 This building houses facilities to provide research and development capability and technical assistance in the area of examining the effects of radiation on (1) nuclear fuels and (2) the physical and mechanical properties of fuel assembly hardware and reactor components. For the most part these are obtained from nuclear power reactors. Additionally, there is capability to encapsulate sources. To accommodate the wide variety of activities, the hot cells and their support facilities were designed and constructed for specific purposes.

The most important design features selected were (1) providing adeouate 20

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. radiation shielding for the radiation' levels to be experienced, (2) confinement design, especially as it relates.to ventilation, (3) materials handling, (4) storage of~ irradiated materials to mimimize personnel exposure, and (5) provisions for fire protection. Detailed descriptions are presented in-the ' renewal application and, in part, the staff's Environmental Assessment t

. dated February 1981.

j These details have been reviewed by the staff, and the review has been supple-mented by site visits to determine the adequacy of the facility and its l equipment to protect health and minimize danger to life and property. The staff has determined that:

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• From a review of occupational exposure information the amount of

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shielding provided has been generally adequate.

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The shielding design and construction has met the guidance of Regu-latory Guide 3.9, " Concrete Radiation Shields."

Where applicable, ventilation air flow patterns and operating proce-du'res have been established to assure that the air flow for rooms and -the support and operating areas (including cells) meet the guidarce provided in Regulatory Guide 3.12, " General Design Guide a for Ventilation Systems of plutonium Processing and Fuel Fabrication Plants."

Designed equipment for cask handling, irradiated material dry and wet storage, solid and liquid waste disposal, and equipment decon-tamination are comparable with the state of the art used in uther i

licen. sed facilities.

Adequate automatic fire protection is proviced for the High Energy Cell (which generally contains tne highest inventory of radioactive material) and manual fire protection for the other cells. A more detailed description is proviced in Acpencix A to this Safety Eval-

,. uation Report.

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It, therefore, _is the staff's conclusion that the Hot Cell Laboratory, its

, equipment and safety features are adequate to protect health and minimize danger to life and property [10 CFR 70.23(a)(3)].

3.2.2.2 Administrative Building, JN-2 (Formerly the Critical Assembly

~ Laboratory)

This building was designed and constructed for use as a critical assembly laboratory. It was used for critical experiments from 1957 through 1963.

Since the cessation of critical experiments, the facility has been used for several nuclear related projects including direct conversion concepts, irra-diation experiment assembly, and special nuclear materials handling. The operating license was terminated in 1970. Offices and small laboratories are used by nuclear supporting services staff including Section Administration, Health Physics Services, Nuclear Materials Accountability, Quality Assurance, and Instrument Maintenance. These activities are the major building activ-ities at this time. The building also currently houses the vault, used for storage of special~ nuclear materials, and a nuclear instrumentation laboratory.

3.2.2.3 Battelle Research Reactor, JN-3 The Battelle Re arch Reactor began operations on October 29, 1956, but tnose operations were terminated on December 31, 1974, and dismantling initiated.

The dismantling was completed without incident during 1975, and the license changed to a possession only status. Storage of waste awaiting shipment for burial is the only licensed activity conducted in JN-3 at this time.

74

L. - s. .

4

4. RADIATION SAFETY

.4.1- Radiation Safety Administration 4.1.1' Organization and Authority Primary responsibility for radiation safety rests with the line Section Managers in the BCL organization. It is the Section Manager's responsibility to assess his operations to assure they are conducted in a safe manner, identify remedial action alternatives and request support assistance as needed. Support assistance

.to the section managers at.BCL is provided in several-ways: -

Safety Deoartment - A BCL wide Safety Department has responsibility for safe operations (radiological and otherwise) throughout the organization by providing consultation, surveillance and training in safety programs. It provides a periodic audit and inspection of hazard control in all BCL facilities. Audits and inspections include training programs, practice of good hazard control principles; compliance with applicable regulations; and use, care, and maintenance of safety equipment; and supplies. The Safety Department has the responsibility and authority to order cessation or modification of activities considered to be a hazard.

4 Radiolacical Safety Officer (RS0) - The RSO is a health physicist appointed by the Laboratory Ofrector to represent him in a direct line of responsibility and authority to assure that all aspects of radiological activities are maintained and conducted in a safe manner. The RSO has the responsibility for the initial review of the proposed new uses of radioactive materials, with the exception of those activities covered by a Radiation Work permit. When the i use is essentially covered by an existing Approved Standard Procedure the RSO may approve the activity. In other cases the proposec use l

25

u es and accompanying safety analysis (prepared by the Section Manager or >

a member of his staff) is referred to a committee system for review ,

and approvalEas described below.

f

'The RSO is also responsible for surveillance and auditing of all BCL

' operations for radiological safety practices, compliance with appli-

, cable regulations and BCL safety policy. He has the responsibility and authority to interdict any activities deemed to constitute an unacceptable radiological risk.

Radiological Safety Committee - BCL relys heavily on a committee system to assure safe conduct of radiological' activities. Specific written guidance in the form of a Radiological Safety Committee (RSC) charter provides the details of responsibilities and authori-ties and the procedures for. implementing the charter. The RCS shares with the Safety Department the responsibility for control of potenti~al radiological hazards. The RSC, as do the Safety' Office and RSO, has the responsibility and authority to interdict operation of a facility or experiment believed to constitute an unacceptable potential for radiological hazard. Other responsibilities of the RSC. include:

Advice to the Laboratory Director in matters of operational philosophy, policy and procedure with respect to radiological hazards.

Determination of the types of work requiring review and approval, d

Evaluation of experimenter's hazard analysis of proposed work s

to assure adequate safety precautions will be taken.

Audit of operations to assure activities are being concucted to maintain hazards to the lowest practical level.

t N

, 26

To facilitate these responsibilities several subcommittees are established to

, provide specific expertise for the reviews and audits. The RSO is a member of the RSC and all subcommittees. No meetings are held without his or his designated alternate being present.

Health Physics Services - Within the Nuclear Services Section is the Health Physics Services group that conducts the comprehensive radio-logical safety program for all BCL research and development activities.

associated with radioactive materials. The group conducts training-programs, provides facility monitoring for contamination control, effluent control, and occupational exposure control. Additional responsibilities include evaluation of preoperational plans; approval of Radiation Work Permits; quality assurance documents and operating procedures; observation of operations to assure that proper controls are used; and evaluation of the various activities; and maintenance of pertinent records. As with the other support to the Section Manager, they have the responsibility and authority to require suspension or modification of any operation which is judged to involve an unacceptable radiological hazard, or is being conducted contrary to approved procedures.

4.1.2 Radiation Work Permit In addition to the review procedures discussed in Chapter 2, " Organization and Administrative Procedures," BCL uses a Radiation Work Permit (RWP) system. As a result of two overexposures that occurred in 1980, the implementation and information required for the RWP approval was revised. The permit requests authorization to undertake a specific operation which will require special consideration for radiological safety. This includes access control to con-taminated or potentially contaminated areas. Prior to commencing the work, the permit request must be completed and a preccerational briefing be held involving the requestor, the person (s) to perform the work, the observer, and health physics personnel. The information proviced in the request includes:

Cescription of the work to be cone.

Time, date and location.

27

Description of anticipated radiological hazards.

Safety equipment required.

Estimated time for completion.

Estimated exposure.

Determination whether ALARA.

Name of participants.

~

Authorizations (Operations Supervisor, Health Physics Representative).

Exposure (s) received.

All work covered by the Radiation Work Permit requires health physics personnel coverage. This formalized preplanning and health physics coverage enhances the ability of management to control the spread of contamination and limit personnel ex'posure.

4.1.3 Radioactive Materials Application For control of all radioisotopes at the King Avenue location, a Radioactive Materials Application (RMA) is required. This RMA is used for procurement of the radioisotopes and is required for movement of them from one location to another. It requires a brief description of a proposed new use, or proposed modification of a new one. The RSO may approve the RMA or it, in his judgment, may be referred to the RC for review and approval.

4.1.4 ALARA Commitment The BCL management subscribes to the philosophy of maintaining occupational radiation exposures as low as reasonably achievable (ALARA). This philosophy is, in part, implemented through the Radiological Safety Committee whose charter is documented in the " Radiological Safety Committee (RSC) Charter,"

Appendix C, dated October 18, 1979. An annual report of actions taken and their results is prepared by the RSC for the Laboratory Director. All new projects are preceded by a hazards analysis that identifies potential for occupational exposure and release from confinement. A part of this analysis assesses that procecures anc equipment will be ALARA. As discussed earlier the Radiation Work Permit reauest acdresses consideration of ALARA.

28

~4;2 Radiation Safety Controls ~

4.2.1 External Radiation Exposure Control Whole body dose from external radiation is minimized by limiting the exposure rate at each work station and by administratively limiting the quarterly accumulative dose of each individual. BCL's activities represent a wide variety, thus emphasis is given in the preoperational planning to potential to both whole body and extremity exposures. This planning includes identification of the safety equipment required. - When indicated, the actual work is preceded by a dry. run to identify possible time and handling problems.

BCL provides additional personnel exposure protection in three specific areas.

Instrumentation to monitor gamma radiation is provided at the storage and transfer pool, a waste water holdup tank and at the air inlet duct to the High Energy Cell. Each instrument has a variable alarm set point which is set at a *

predetermined level. The instrument at the pool is~to provide assurance that there is sufficient water shielding. If the level of the pool should drop or

-the radioactive material be located too near the surface, the alarm sounds requiring corrective action to be taken. In the event of low water level in the pool, water level sensors automa,tically activate a pump to add water.

The holdup tank monitor provides an indication of the degree of contamination being generated in waste water. The HEC inlet duct air monitor provides information on the condition of the general laboratory air.

The staff has reviewed the implementation of SCL's radiation exposure control program, and based on accepted practice and the pertinent portions of Regulatory Guides 8.8, "Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations Will Be as low as is Reasonably Achievable,"

and 8.10, " Operating philosophy for Maintaining Occupational Radiation Exposures as low as is Reasonably Achievable (Nuclear power Reactors)," finds the BCL program satisfactory.

29

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A.2.2 Control of-Internal Exposures BCL uses a total confinement approach, when possible, to minimize the possi-bility of bodily intake. To monitor the effectiveness of the confinement techniques alpha and beta gamma continuous air monitors (CAMS) are located in areas _where there is a possibility for the existence of airborne radioactive material. All CAMS are equipped with audible alarms, and personnel are instructed to evacuate the facility when an alarm sounds. Followup action is taken by a health physicist following written procedures. All exhaust ventilation systems at the Nuclear Services Center where the release of radioactive material is possible are continuously monitored for alpha, beta gamma and/or gaseous radioactive materials. Alarm conditions shut down blower systems and/or divert air flow through appropriate media such as a charcoal bed for iodine retention.

J In the conduct of the research and development program, occasions arise requiring personnel entry to areas with airborne contamination in excess of the concentra-tions listed in 10 CFR 20, Appendix B, Table 1. For those occasions, through the Radiation Work Permit system, provision for respirators, protective cloth-

- ing and lapel air samplers is made. The BCL respiratory program is conducted in accordance with 10 CFR 20.103(c).

BCL also has a in-vivo counting program that has been designed to monitor all personnel who work in areas where there is potential for internal radiation exposure. Personnel are monitored at six-month intervals for mixed-fission

! products and whenever a suspected exposure may have occurred.

4.2.3 Contamination Control BCL conducts weekly contamination surveys in all areas. The results of surveys are forwarded to the facility supervisor for immediate decontamination areas that exceed laboratory guidelines. Cleanuo in contamination :enes is initiated whenever the removable (smearable) level is found to be 200 cpm /100 cm2 alpha or 10,000 com/100 cm2 beta gamma. All cecontamination activities take priority 30

over project work in the area of concern. Additional smear surveys are taken at other times when activities present the possibility for contamination. All surveys and corrective actions are documented.

.The staff has added Condition 12 requiring that release of equipment, packages or formerly contaminated areas for urrestricted use is in accordance with Annex C, " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of License for Byproduct, Source, or Special Nuclear Materials."

4.3 Radiation Protection Evaluation Upon completion of the radiation safety review of the licensee's application and compliance history, the staff has concluded that BCL has the necessary technical staff, administrative and technical procedures and equipment to provide an effective and safe radiation program. Conformance by BCL to their proposed conditions as well as those developed by the NRC staff should ensure a safe operation and ensure that unfavorable trends or effects can be detected quickly by BCL or NRC's Inspection and Enforcement personnel for corrective action.

l 31

C 4

5. NUCLEAR CRITICALITY SAFETY The nuclear criticality system at BCL is based on:

a qualified nuclear criticality safety staff with specified responsibility and authority; technical criteria using establi hed policies, analytical. methods, data, safety margins; and a

administrative requirements for written operating procedures, posting of limits, and training.

The BCL discussions on the administrative requirements for nuclear safety did not clearly provide for an independent review of the hazards analysis by a second qualified individual to determine that the methods used in the analysis are appropriate and that the results are correct, nor is there provision for a physical inspection by qualified personnel of the approved system after instal-lation to assure that the parameters in the analysis are met. To assure that BCL administrative procedures provide for these items, License Condition 15 to the renewed license shall be included.

In BCL's technical criteria, provision is made to use the KENO code as a method of analysis. While this method is generally acceptable, it is the staff's judgment that this approach must be demonstrated formally in a supplement to BCL's renewal application, part II, " Descriptive Supplements," prior to use in future nuclear safety evaluations. As such, License Condition 16 is recommended by the staff for inclusion in the renewed license.

In Section 4.3.1 of the RSC charter (Aopendix A of the application), an equation is provided for calculating safe masses of mixtures of pu and U-235. The use of this equation appears to be non-conservative because a second equation to 32

determine the effective enrichment of the mixture assumes Pu is no more reactive

, than U-235. A comparison of the safe mass values for the two isotopes shows this is not the case. The equation should be revised to eliminate this non-conservatism. As a substitute, the unity rule may be used with single unit mixtures. License Condition.17 to the license will be added.

W 33

c- .

6. RADI0 ACTIVE WASTE' EFFLUENTS 6.1' Liquid Effluents It is the BCL's policy that no liquids containing radioactivity greater than their action level be discharged to the environment. Contaminated or poten-tially contaminated liquids are mixed with cement for solidification. The cement is contained in steel drums which are shipped offsite for burial. To reduce the volume of liquid generated at the Nuclear Services Center, a holdup tank-evaporator system is located in a JN-1 hot cell. The contents of the holdup tank are monitored for radioactivity. The evaporator bottoms are mixed -

with cement as above.

6.2' Gaseous Effluents As discussed and referenced in Chapter 3, " Site and Facility Considerations,"

potential radioactive release's as gaseous effluents from the Hot Laboratory, JN-1, are controlled, by features designed into the various ventilation systems, i.e., flow and differential cressuro control, high efficiency particulate filters and absorbers. To provide additional assurance that releases will be minimized, BCL monitors the effluents for alpha, beta, and gamma particulate matter and radioactive gases. The systems for both JN-1A and JN-1B were designed to the guidance criteria found in Regulatory Guide 3.12, " General Design Guide for Ventilation Systems of Plutonium Processing and Fuel Fabrica-tion Plant." The JN-1A system was revised to these criteria in 1977; however there are six individual stacks compared to one stack servicing JN-18 (High Energy Cell).

Each of the stacks from JN-1A has its own continuous air monitor (CAM), and each CAM has three channels with the capability to monitor alpha particulates, beta gamma particulates, and radioactive gas (Kr-85) concentrations. The measurements are recorded and each CAM is set to alarm when a preselected level is exceeded. Also when this level is reached an electrical interlock turns off tne respective blower.

34

~ .

Effluent from the JN-18 High Energy Cell is discharged from a single stack in which four separate CAMS are installed to measure alpha particulate, beta gamma ,

particulate, radioactive gas (Kr-85) and I-131. Any of the four instruments will activate an alarm, shut down the exhaust fans and close butterfly valves so no more air can be drawn from the cell. Additionally the I-131 monitor will start an exhaust fan and open division dampers causing exhaust air to flow through a charcoal tray.

6.3 Solids Solid radiological wastes from operations at the King Avenue location are collected, compacted if necessary, and packaged for shipment to a licensed disposal site. Animal carcasses are incinerated and disposed of in accordance with 10 CFR 20.306, " Disposal of Specific Wastes."

Solid waste from the Nuclear Services area is from many sources. Examples of solid waste are HEPA filters, cartridge water filters, spent ion-exchange resins, disposable clothing and other supplies. These are compacted, as necessary, and packaged according to NRC, 00E, and Department of Transportation regulations for shipment offsite. Contaminated equipment is decantaminated to the extent possible and packaged in accordance with applicable regulations.

6.4 Staff Evaluation - Radioactive Waste Effluents In our evaluation of the radioactive waste effluent control systems we have considered:

The historical measured and reported BCL performance records.

The capability of the effluent control systems to maintain the levels of radioactive materials in plant effluents to within acceptable limits.

The caoacity of the systems to handle the waste volume demands anticipated over the period of the license.

35

V The adequacy of the system components and equipment to minimize the radioactive waste generated in the plant operation.

The BCL administrative control procedures and controls for the management.of radioactive waste.

Based on the requirements of 10 CFR 20, 30, and 70 and en our engineering judgment and experience, we find the radioactive waste effluent control systems provided by BCL to be acceptable.

36 t

i I

t . . -

7. ACCIDENT ANALYSIS Accident scenarios for the King Avenue and Nuclear Services facilities have been postulated and analyzed in the Environmental Imoact Assessment, Battelle Memorial Idstitute Laboratory, Columbus, Ohio, Chapter 5, " Accident Analysis" dated February 1981. The scenarios selected and the assumptions ~ used to deter-mine dose are discussed in this reference. A brief summary of the results are-presented in Table 7.1 and Table 7.2.

Table 7.1 Estimated doses at 400 meters for airborne releases due to postulated accidents (King Avenue site)

Dose (rem)*

Organ Case 1 Case 2 Case 3 Total body 9.7E-03 9.7E-06 1.4E-03 Kidneys 9.7E-03 9.7E-06 1.4E-03 Liver 9.7E-03 9.7E-06 1.3E-03 Sone 5.2E-02 5.2E-05 1.8E-03 Thyroid 9.7E-03 9.7E-06 3.5E-02 GI Tract 9.7E-03 9.7E-03 1.1E-03 Lungs 9.7E-03 9.7E-06 1.4E-03

' Dose includes exposure to plume and ground during plume passage and 50 year

,' dose commitments resulting from inhalation of activity during plume passage.

2 Cases:

1 - Release of 30 C1 of C-14 as gas.

2 - Release of 0.03 Ci of C-14 as powder.

3 - Release of 0.03 Ci of I-131.

37 l

Table 7.2 Estimated doses (REM) from airborne releases' due.to postulated bounding' accidents (West Jefferson site)

~ Assembly Orop in Criticality in.

High Energy Cell High Energy Cell

• Fenceline Nearest Res. Fenceline Nearest Res.

Organ (400 meters) (760 meters)

Total body 1.5E-1 6.8E-3 6.3E O 2.8E-1 Kidneys 1.4E-1 6.3E-3 5.0E 0- 2.2E-1 Liver 1.4E-1 6.1E-3 5.4E O 2.4E-1 Bone 1.7E-1 7.0E-3 7.2E O 3.2E-1 Thyroid 2.3E-1 1.0E-2 2.0E+1 9.0E-1

• GI Tract 1.4E-1 6.0E-3 6.4E O 2.8E-1 l

l l

38 l

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1

8.

SUMMARY

EVALUATION / CONCLUSIONS Based on a review of the BCL application for renewal of License SNM-7, 'other pertinent documents, and the licensee's compliance history the staff concludes that:

1. The issuance of a revised license, subject to certain conditions, would not be inimical to the common defense and security or to the health and safety of the public,

2. The lic'ensee meets the requirements of the Atomic Energy Act of 1954, as amended, and the regulations of the Commission in that, in accordance with the provisions of 10 CFR 70.23, " Requirements for'the approval of applications":

a. The proposed use of special nuclear material is to be used for the conduct of research and development activities of a type specified in Section 31 of the Act.

b. The licensee is qualified by reason of training and exoerience to use the source, byproduct and special nuclear materials for the purpose requested in such manner as to protect health and minimize danger to life or property; and

c. The licensee's equipment, facilities and procedures are adequate to protect health and minimize danger to life and property.

3. By virtue of having operated the facility from 1960 to the present in such a manner as to result in controlled effluent releases at acceptably low levels and low occupational radiation exposure, the licensee is I

considered to have demonstrated the aci'ity to conduct the operation in substantially complete compliance with Commission regulations and license specifications and conditions.

i 39

4. An emergency plan and procedures have been prepared which provide

,. adequate provisions to meet 10 CFR 70, for coping with emergency conditions. e

5. The licensee has submitted an adequate p'an for the physical protection and security of special nuclear material.

6. ' The licensec appears to be financially qualified to engage in the proposed activities.

The staff recommends that the Battelle-Columbus Laboratory License No. SNM-7 be renewed in its entirety to incorporate reference to the statements, repre-sentations, procedures and conditions contained in the application dated October 5, 1981 subject to the following conditions:

14 . The licensee shall comply with the provisions of Annex 8 (attached),-

" License Condition for Leak Testing Sealed Byproduct Material Sources,"

for byproduct sealed sources in its possession. These leak test pro-cedures shall also be used for the PU-238 sealed source (Item 6.C above) at such time as it is removed from its storage package in the JN-2 Vault for use or transfer.

12. -Notwithstanding Table III and Table IV presented in Part I, Sections 3.4 and 3.5, for the release of materials, equipment and facilities for unrestricted use the licensee shall adhere to the provisions of Annex C attached to this license, " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use" dated July 1982.

13. Item 9 above incorporates Appendix A (Radiological Safety Committee Charter) of the licensee's renewal application (BCL-1081) as a condition of th.) license to clarify and define more fully administrative procedures for review, approval and audit of activities covered by the license, as described in Section 1.3 and Section 2.0 of Part I. The licensee may make revisions to the provisions of Appendix A, based upon written evaluation of the changes, without NRC approval if it is cetermined that such changes 40 l-

a .

> 4 will not decrease the~ effectiveness of the Committee in carrying out its functions. Revisions to the Charter and supporting evaluations shall be submitted to the Director, Division of Fuel Cycle and Material Safety, NRC, with a copy to the Administrator, Region' III Office, NRC, within 60 days following such changes.

14. In addition to the subjects identified in Section 5.1.1, Appendix A, the annual review and appraisal of facilities shall include an assessment of occupational radiation exposures and releases of radioactive material over the past year with regard to maintaining such exposures and.. releases as low as is reasonably achievable, as stated in Section 20.1(c), 10 CFR Part 20.

15. Part I, Section 2.1 of the licensee's application specifies when mandatory criticality reviews for new operations are required by the Nuclear Safety Subcommittee. The reviews by the Nuclear Safety Subccmmittee shall include (1) an initial analysis by an indiv'idual qualified in accordance with provisions of Section 1.2.2 and Section 2.2, Part I; (2) an indepen-dent review by a second qualified individual to determine that the methods used in the analysis are appropriate and that the results are correct,-and (3) as appropriate, physical inspection by the individual performing the original analysis to assure that the physical environment and parameters assumed in the analysis are valid.

16. Part I, Section 2.4 of the application for renewal provides for use of KENO as an acceptable criticality analysis method. Prior to use of this analytical method for nuclear safety evaluations under this renewed license, the licensee shall submit a demonstration (as an addition to Part II or a new Appendix) of its use to NRC for approval.

17. Notwithstanding the formula in Section 4.3.1(1)(c) of the Radiation Safety Committee Charter (Appendix A of the application for renewal), the licensee shall use the formula:

41 .

Grams U-235 . Grams PU 1 g

L 220 grams -

235 where L235.is the mass limit from Table 1, Appendix A of the application, for.the appropriate U-235 enrichment.

18.

The licensee is hereby exempted from the provisions of Section 70.24, 10 CFR Part 70, insofar as this section applies to special nuclear material authorized under this license for possession and use at the licensee's King Avenue Laboratories.

19. The licensee shall provide three copies each year of its annual environ-mental report to the Director, Division of Fuel Cycle and Material Safety, NRC, and a copy to the Administrator, Region III Office, NRC.

20.

Section 2.1 and 3.10, Part I refer to provisions for training and periodic retraining of employees, as appropriate and related to employee work assignments with radioactive and fissionable materials. Such training shall be conducted, as appropriate, for new employees and prior to initiating new operations approved by the Radiological Safety Committee and retraining shall be conducted on topics appropriate to employee work assignments at least annually. Documentation of such training and retraining shall be maintained.

21. Section 4.0, Part I of the licensee's renewal application incorporates the text of previous amendments issued by the NRC to Special Nuclear Material License No. SNM-7 and Byproduct Material License No. 34-6854-5.

For clarification, the licensee's authority to permit increases in the radioactivity in the Hot Cell Laboratory pool water to levels above the limits for routine operations, as specified in Section 4.0 is hereby affirmed, subject to the following provisions:

a.

The period that non-routine levels of radioactivity exist in the pool shall not exceed 45 days before they are reduced to routine levels or below;

b. Work requests, as approved by the Laboratory Operations Manager and the resident Health-Physicist, shall be utilized during the non-routine 42

9' .

" operations to assure that personnel are. aware of the specific radiological safety considerations for the operation;

c. The-pool lid cover shall be in place during down time and after hours;

d. Radiation monitoring will be performed at least twice weekly around the perimeter.of the pool and radiation levels with the cover in place and the cover removed will be posted;

e. Pool water samples will be collected and analyzed at least weekly; and

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f. The resin bags of fon columns will be replaced when readings of 300 mR/ hour at one foot are reached.

The above provisions, extracted from the licensee's letter to the NRC of October 31, 1980 eliminate the need for reference in this license to this letter, which requested the non-routine operational levels to accommodate such activities as pool cleaning and maintenance, examination and maintenance of storage racks, and the handling of additional ~ fuel assemblies.

22. The licensee shall implement, maintain, and execute the response measures of his Radiological Contingency Plan submitted to the Commission on March 5, 1982. The licensee shall also maintain implementing procedures for his Radiological Contingency Plan as necessary to implement the Plan.

This Radiological Contingency Plan and associated implementing procedures incorporate the emergency planning requirements of 10 CFR 70.22(i) as they refer to onsite planning and notification procedures. The licensee shall make no change in his Radiological Contingency Plan that would decrease the response effectiveness of the Plan without prior Commission approval as e'videnced by a license amendment. The licensee may make changes to his Radiological Contingency Plan without prior Commission approval if the changes do not decrease the response effectiveness of the Plan. The licensee snall maintain records of changes that are made to the Plan without prior approval for a period of two years from the date of the change and shall furnish the Chief, Acvanced Fuel and Spent Fuel 43

Licensing Branch, Division of Fuel Cycle and Material Safety, NMSS, U.S.

Nuclear Regulatory Commission, Washington DC 20555, and the Region III NRC Regional Office at the address specified in Appendix 0 of 10 CFR Part 20, a report containing a description of each change within six months after the changes is made.

23. Section 5.0, Part I, of the licensee's renewal application incorporates the text of p~revious amendments issued by NRC to Special Nuclear Material License No. SNM-7 and Byproduct' Material License No. 34-6854-5 covering decontamination and decommissioning plans applicable to the Battelle Hot Cell Laboratory. It is hereby affirmed that the provisions of these decontamination and decommissioning plans, including financial arrangements, continue in effect under this renewed license.

24. At such time that facilities covered by this license are decantaminated for proposed unrestricted release (in accordance with Annex C), the licensee shall submit a report that identifies the facilities where radioactive materials were used and stored, or disposed on the site. The report shall briefly describe operations conducted and radioactive materials

'used in the facilities and shall assess the results of the decontamination activi ties. The report shall provide the basis for unrestricted release of the facilities and the site, including a description of samoling and survey methods and instrumentation used, and shall include final contamination survey data for the facilities and grounds. The licensee may segment the report to obtain release of certain areas of facilities or individual structures if it is demonstrated that ongoing activities in other areas will not lead to recontamination of the area or structure proposed for release.

25. The licensee is authorized to backfill the retired filter bed area on the West Jefferson site where contaminated soil was removed as described in the licensee's letter of May 13, 1981. The homogenized bed containing low levels of residual contamination shall be covered with approximately three feet of soil as stated in the letter of May 13, 1981.

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L APPENDIX A 1 HOT CELL u80RATORY, JN-1, FIRE PROTECTION

, Room Area Fire protection In-Cell Fire protection l All cells except the High Energy Cell are equipped for manual fire fighting protection. Two large portable CO2 extinguishers are available for combating in-cell fires. In addition to the CO extinguishers, G-1 powder is available 2

for fighting uranium fires, and soda ash is on hand for NaK or butyl alcohol

~

fires. A fire hose is located in the operating area, and at other locations throughout the laboratory.

t j In the event of an in-cell fire which requires the use of C03 , a large portable unit located in the operating area is used to inject CO2the ugh one of the l entry ports in the face of the cell. In cases where particularly flammable operations are being performed, such as reacting NaK alloy with butyl alcohol, an entry port is selected for introduction of the CO2 during set up of the

operation, and this port is plainly labelled on the exterior of the cell wall.

The portable CO 2 bottle is then moved to a location where it is readily avail-able for the particular operation. Containers of soda ash and G-1 powder are placed in strategic locations in the cells where they are readily available.

The cell exhaust blowers can be manually controlled if it becomes necessary to shut them off during an emergency. The radiation monitor installed in the cell exhaust system is designed to shut off the blowers in the event particulate or gaseous radioactive matter penetrates the filters.

For the High Energy Cell fire protection is provided by a Firecycle System manufactured by and installed under the suoervision of the Viking Fire protec-tion Company.

l 45 l

1 +

The system is an on-and-off cycling.preaction sprinkler system. The system-is

, activated by heat detectors, set at 190*F, with an electrical control panel.

The system has the capability of a continued on-and-off cycling while extin-guishing a fire, and of shutting off the flow of water when the fire is extin-guished. The Firecycle System minimizes the amount of water used .to extinguish a fire. Water is not supplied to the sprinkler until the heat detector is energized, in this respect it is a dry pipe system and damage to the sprinkler heads or the piping will not result in water damage stemming from accidents.

The following is a description of the Firecycle System; a Firecycle flow control valve is controlled by water under pressure. Two pilot solenoid valves are used to control pressure in the flow control valve chamber, and is in turn controlled by the heat-sensitive. detectors. (Using two solenoid valves in parallel increases the reliability by 400 percent.) The detectors are connected to the solenoid valves through an electrical control panel. When a detector senses a rise in temperature above the set point (190*F), the solenoid valves open and water from the upper flow control valve enamber is vented, reducing pressure above the valve diaphragm, opening the valve, and supplying water to the sprinkler heads. At the same time, audible alarms are sounded at the elec-trical control panel and flow control valve. The system is now a wet pipe system. An increase in temperature to 212*F would melt a fusible link on a sprinkler or sprinklers and water would be applied to the fire. When the temperature of the fire is reduced below the set point (190*F) of the detector a signal is sent to a safety timer, delaying closing of the solenoid valves and flow control valve for a pre-set period (2 minutes). At the end of this period water to the sprinklers is shut off. Should any detector at any time again sense a temperature rise over the set point, the system recycles and applies water through the already open sprinklers. The sprinkler system func-tions like a conventional wet pipe system in case of damage to the detector circuit and the electrical control panel has standby'24 volt cada. 2m batteries on a trickle charge to supply full power for 4 to 5 days in case of power failure. The water supply to the flow control valve need not be turned off following a fire or for sprinkler maintenance, thereoy eliminating danger of naving an unprotected area at these times.

46

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• The Firecycle System is approved by. Factory Mutual and listed by Underwriters'

, Laboratories.

Simultaneous with the activation of the sprinkler system the cell will be made static with respect to air flow as described in the section describing the call exhaust system.

, This type of sprinkler system should provide an effective fire suppression system while causing a minimum of water damage. Excess water in the cell could cause some contaminated water to run out of the cell and into the operat-ing and service aisles bringing with it radioactive contamination. The major part of the contaminated water would, however, go into either the cask wash-down area and then into the floor drain and into the 5,000 gallon holdup tank, or into the transfer canal and then into the storage pool. Radioactive con-tamination would be contained within the building thus protecting the surround-ing areas.

The loss of filters.due to a fire in the cell either by burning or water damage is minimized by running the cell atmosphere static. Should the primary in-cell HEPA filters be damaged, the secondary HEPA filters on the mezzanine would still be effective when the exhaust system is reactivated.

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