ML20239A188

Safety Evaluation Supporting Renewal of License SNM-1227

ML20239A188
Person / Time
Site:	Framatome ANP Richland
Issue date:	09/10/1987
From:	Bidinger G, Soong A, Swift J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20239A183	List: ML20239A180 ML20239A186 ML20239A188 ML20239A191 ML20239A205
References
NUDOCS 8709170153
Download: ML20239A188 (35)

Text

SEP '101987 i I

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SAFETY EVALUATION REPORT BY THE DIVISION OF INDUSTRIAL AND MED; CAL NUCLEAR SAFETY RELATED TO THE NRC MATERIALS LICENSE RENEWAL 4 i

FOR THE ADVANCED NUCLEAR FUELS CORPORATION RICHLAND, WASHINGTON DOCKET 70-1257 LICENSE N0. SNM-1227 SEPTEMBER 1987 l

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4 SEP 101987 TABLE OF CONTENTS Page I. INTRODUCTION ..................................................... 1 A. General ...................................................... 1 B. Location Description ......................................... 1 C. License History .............................................. 1 II. LICENSE APPLICATION............................................... 3 A. Review History ............................................... 3 B. Comp l i a n c e H i s to ry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 C. Current Application .......................................... 3 l

l III. POSSESSION LIMITS (PROPOSED) ..................................... 4 IV. AUTHORIZED ACTIVITIES (PROPOSED) ....... ........... ............. 4 A. General Summary ............................................. 4 B. Process Description ..................................... .... 5 V. FACILITIES ....................................................... 6 A. U0 Building ................................................. 6 2

B. SF Building .................................................. 6 C. ELO Building ................................................. 6 D. Warehouses ................................................... 6 E. Waste Process / Storage Facilities ............................. 8 VI. ORGANIZATION AND ADMINISTRATIVE PROCEDURES ....................... 8 A. Organization ................................................. 8 B. Administrative Practices ..................................... 13 C. Inspections and Audits ....................................... 14 D. Personnel Training ........................................... 15 VII. RADIATION PROTECTION .................................... ........ 16 A. Radiation Safety Administration .............................. 16 B. Systems of Exposure Controls and Exposure Levels ............. 17 C. Bioassay Program ............................................. 21

0. Control of Surface Contamination ..................,........... 21 E. Effluent Control .................................... ..... .. 22 F. Conclusion ................................................... 23 VIII. NUCLEAR CRITICALITY SAFETY ....................................... 24 A. Administrative Requirements .................................. 24 B. Technical Requirements ....................................... 24

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SEP 101987 TABLE OF CONTENTS (Continued)  !

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Page q

C. Review of Demonstration of Nuclear Criticality Safet Administration .....................................y.......... 26 D, Review of Demonstration of Process Nuclear Safet 27 E. Conclusion....................................y............

..... ........ 28 1

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1 IX. ENVIRONMENTAL MONITORING ......................................... 29 l 1

X. RADIOLOGICAL CONTINGENCY PLAN......................... ........... 29 l XI. FIRE SAFETY ...................................................... 29 XII. PLANT DECOMMISSIONING ............................................. 30 XIII. EXEMPTIONS AND SPECIAL AUTHORIZATIONS ................ ............ 30 XIV. CONCLUSION .. .................................................... 31 1

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SEP 101987 I. INTRODUCTION A. General The primary activities of Advanced Nuclear Fuels Corporation (ANF) at Richland, l Washington, are the conversion of uranium hexafluoride to uranium oxide, the processing of the uranium oxide, mad the fabrication of nuclear reactor fuel assemblies. Support functions include scrap recovery, development and pilot scale work, laboratory operations, waste treatment and disposal, and packaging l material for offsite transport.

1 The current authorized maximum possession limits are uranium containing 20,000 kilograms of U-235 and 500 grams of plutonium. The 20,000 kilograms includes not more than 35 grams U-235 at any errichment, 200 kilograms U-235 at not more than 19.99 w/o U-235, and the rest of the uranium contains not i more that 5 w/o U-235. Except for sealed sources and standards, most of the plutonium is in waste drums awaiting disposal.

B. Location Description The ANF site is located on 320 acres just inside the northern boundary of the City of Richland. The DOE site (Hanford Reservation) lies generally to the north of the ANF site. The ANF site lies between the Yakima and Columbia I Rivers. Figure 1 shows the geographical location of the site.

C. License History The license was first issued to Jersey Nuclear Company on December 14, 1970, primarily to authorize possession and storage only of UF at 6

maximum 5 percent U-235 enrichment. The license was subsequently revised on September 14, 1971, to authorize processing operations with low-enriched uranium, but was conditioned to expire within 4 months and to require the submittal of supplemental informa-tion to the Environmental Report. The license was extended and amended to per-mit limited operations with mixed oxide in the Mixed Oxide & Speciality Fuels I Building pending the environmental review. In March 1973, the name of the licensee was changed from Jersey Nuclear Company to Exxon Nuclear Company, Inc. t (ENC).

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SEP 101987 l

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"MMEEQhlkfff4?!?W" SEP 101987 On July 18, 1974, the license was revised and issued for a full 5 year term.

Following issuance of the Final Environmental Statements for the Uranium 0xide Plant and Mixed 0xide Fabrication Plants, an environmental impact appraisal was completed in August 1981, and the license was renewed again on October 26, 1981. The license, as renewed, authorized the possession, use, and storage of uranium and the possession and storage of plutonium.

On September 12, 1986, ENC submitted an application for a 5 year renewal of SNM-1227. In accordance with the provisions of 10 CFR 70.33, the license remains in effect until action is taken on the renewal application. In  ;

February 1987, the licensee's name was changed to Advanced Nuclear Fuels Corporation.

II. LICENSE APPLICATION j A. Review History The safety review of the ANF renewal application included an application dated September 1986 (submitted by letter dated September 12, 1986) and supplements i dated September 1986 (by letter dated May 18, 1987), May 1987 (by letter dated  !

May 12, 1987), May 1987 (by letter dated May 18, 1987), May 1987 (by letter dated May 21,1987), and July 1987 (by letter dated July 14, 1987). By letter I dated August 7, 1987, ANF revised the entire application.

i B. Compliance History l

l Nine (9) reports of inspection of health and safety activities by NRC Region V staff were reviewed. These reports cover a 4.5 year period. Nine (9) violations were reported; none of the violations were reported as Severity I, II, or III.

Severity levels are defined in 10 CFR 2.

i C. Current Application l

NRC staff reviewed the applicant's commitments concerning organization and administration of the nuclear safety program for radiation protection and nuclear i criticality safety. These proposed commitments and special authorizations are  !

in Part I, Chapters 1-8, of the renewal application.

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.l SEP 101987 NRC staff also reviewed the safety demonstration portion in Part II, l Chapters 9-16, of the renewal application. .{

i The following sections contain a description of the principal aspects of the l organization and safety programs.

III. PC.iSESSION LIMITS (PROPOSED) l The applicant has requested the following materials, forms, and quantities of special nuclear material:

1 Maximum  ;

Material Form Quantity 1

1 l A. Uranium enriched A. Any A. 100 g U-235 1

i in U-235 J lJ l B. Uranium enriched B. Uranium B. 200 kg U-235 I

, up to 19.99 w/o U-235 compounds l

l C. Uranium enriched C. Uranium C. 20,000 kg U-235 l up to 5 w/o U-235 compounds including U-235 l in A & B above D. Plutonium D. Sealed Sources D. 1 mg Pu 1

E. Plutonium E. Pu0 2

- 00 2 E. 500 g Pu stored waste IV. AUTHORIZED ACTIVITIES (PROPOSED)

A. General Summary The general activities being assessed in this safety review include:

1. The conversion of uranium hexafluoride to uranium oxide by the ADV process and the dry conversion process.

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SEP 101987

2. The fabrication of light-water-reactor fuel from the uranium oxide.

3. The processing of ANF scrap, including incineration.

4. Support activities which include process technology, laboratory, waste L treatment, and disposal.

5. Storage and packaging of plutonium contaminated waste.

l l- B. Process Description The proposed process activities being assessed in the safety review include:

1. Conversion'of UF6 to UO2 by the wet ADV process.

2. Conversion of UF 6 to U0p by the dry conversion process.

3. Fabrication of sintered UO 2 Pellets.

4. Cladding of UO2 pellets and assembly of fuel rods into fuel assemblies.

5. Processing of scrap uranium compounds, including incineration, for l recovery and recycle of uranium.

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6. Laboratory operations.

7. Development of process technology for above activities.

8. Treatment cf solid, liquid, and airborne waste streams for uranium recovery and waste disposal.

9. Storage of Pu waste in drums, pending disposal.

l l To authorize these activities, the staff proposes the following license condif. ion:

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SEP 101987 Authorized Use: For use in accordance with the statements, representations, and conditions of Part I of the licensee's application dated July 1987 (submitted by letter dated August 7, 1987).

V. FACILITIES The location of facilities on the ANF site is shown in Figure 2. The primary I facilities under license are:

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A. UO 2 Building

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Fuel manufacturing operations for converting uranium hexafluoride into U0p encapsulated fuel assemblies and scrap recovery operations are conducted in this building.

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B. SF Building i

Operations for manufacturing fuel assemblies from U02 p wder are performed in

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the SF Building. Incineration of combustibles contaminated with uranium enriched j up to 5 w/o U-235 will be a new operation under this license.

1 Waste contaminated with plutonium is stored in drums in one room. When disposal l

is available, the material may be repackaged for shipment and disposal.

C. ELO Building i

This building is used for process development and pilot plant operations. All phases of fuel assembly manufacturing can be performed in the laboratory.

D. Warehouses The warehouses are used to store uranium compounds in various stages of production or scrap recovery. -

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SEP 101987 E. Waste Process / Storage Facilities These facilities consist of the lagoons for storage of waste liquids and solids, '

pads for storage of combustible materials, and waste liquid processing equipment. 1 i

I To authorize these, and only these facilities, the staff proposes the following I license condition:

Authorized Place of Use: The licensee's existing facilities at Richland, Washington.

I VI. ORGANIZATION AND ADMINISTRATIVE PROCEDURES i

A. Organization ANF is a Delaware corporation with its corporate office in Bellevue, Washington.

ANF is a wholly-owned subsidiary of Siemans Capital Corporation, a Delaware corporation. The ANF corporate organization is shown in Figure 3.

1. Nuclear Safety Responsibilities The ANF President has ultimate responsibility for ensuring that all company activities are conducted safely. The Vice President, Engineering and Production, is the responsible site representative for overall safety during fabrication of nuclear fuel. The site organization is shown in Figure 4.

1 Operation of the facilities is directed by the Manager, Operations-Richland. 1 Within the constraints of nuclear safety, the Manager, Operations, is responsible for the fabrication of nuclear fuel.

The Manager, Plant Operations, and the Manager, Safety and Security Operations, j report to the Manager, Operations. The Plant Operations Manager directs opera-tion of fuel manufacturing facilities and is responsible for safe operations and protection of the environs. The Safety and Security.0perations Manager is  ;

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SEP 101987 responsible for providing support to all operations involving radiological and criticality safety. The Safety and Security Operations Manager has the authority to request shutdown of any operation which he judges to be unsafe.

The Supervisor, Radiological and Industrial Safety, reports to the Safety and Security Operations Manager and provides the radiological safety and criticality safety support. The Radiological Industrial Safety Supervisor establishes the radiological safety program in accordance with criteria provided by Corporate Licensing. The Supervisor is also responsible for administering the program, directing the Health Physics Technician's activities, evaluating the program's l effectiveness, auditing the program's implementation, and preparing Radiation Work Permits. The Supervisor has the authority to request management to shutdown any operation judged to be unsafe.

The Plant Criticality Safety Engineer reports to the Supervisor, Radiological and Industrial Safety, and provides criticality safety engineering assistance to all groups using special nuclear material. The Engineer is responsible for preparing criticality safety specifications and limits based upon criteria and I analyses provided by Corporate Licensing and for auditing shop operations.

The Manager, Materials Research, directs operation of the Engineering Laboratory Operations facility. The Manager is responsible for safe operation and control of facility activities and for the safety of the environs.

l The Manager, Process and Equipment Engineering, directs all licensing and process and facilities engineering activities. The Manager is responsible for the ade-quacy of health physics, criticality safety, environmental safety, and auditing programs. The Manager has the authority to assure that new or modified facilities are designed to operate within regulatory limits.

The Manager, Corporate Licensing, reports to the Manager, Process and Equipment Engineering, and is responsible for licensing and regulatory activities for nuclear fuel production. In this line organization, the Manager has access to Company Management and is independent of fuel handling activities. The Manager has the authority to request shutdown of any activity judged to be unsafe.

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SEP 10.1987 The Health Physics Component of Corporate Licensing.is responsible for providing technical bases, criteria, and methods related to health physics; preparing Radiation Protection Standards; providing outside special services for health physics and emergencies; performing compliance inspections; and reviewing Radia-tion Work Procedures. The Criticality Safety Component of Corporate Licensing i is responsible for providing technical bases, criteria, and methods relating to criticality safety; preparing the Nuclear Criticality Physics Methodology docu-ment and Criticality Safety Standards; performing compliance inspections; and approving criticality safety specifications. l The licensee has a Health and Safety Council which meets monthly to review aspects of the safety program. The review includes radiological and criticality  ;

practices and trends, adequacy of emergency planning and procedures, and unusual occurrences or accident investigations and corrective actions.

Members of the Council include the Manager, Operations-Richland; Manager, Safety and Security Operations; Vice President, Engineering and Production (and his staff); Manager, Corporate Licensing; Supervisor, Radiological and Industrial Safety; and Plant Criticality Safety Engineer. Designated members of the Council make monthly inspections. Findings are assigned to individuals for resolution.

An ALARA Committee meets semi-annually and issues an annual report to the Health and Safety Council. The Committee report reviews trends in personnel exposures and effluents, potential for reductions in exposures and effluents, and proper design, use, and maintenance of equipment designed for exposure and effluent control.

Members of the Committee include the Manager, Corporate Licensing; Health Physics Specialist; Supervisor, Radiological and Industrial Safety; Manager, Facilities and Equipment Engineering; Manager, Safety and Security Operations; Manager, Plant Maintenance; Manager, Plant Operations; and Manager, Process Support Engineering.

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i SEP 101987 I

2. Minimum Technical Qualifications The licensee has proposed minimum qualifications for the Radiological and Industrial Safety Supervisor and his staff positions. The Supervisor will have I a B.S. degree and 5 years of radiation safety experience or 10 years of experience in radiation safety. The Plant Criticality Safety Engineer will have a B.S. l degree and 3 years of nuclear experience or 6 years of nuclear experience.

In either case, at least 1 year of experience will be in criticality safety 1 application. Health Physics Technicians will have a high school diploma and 3 years of experience or 6 years of experience. The Technicians will have )

completed the ANF formal training program or its equivalent. The option of experience in lieu of formal education is acceptable to the staff because of the interaction with the Corporate Licensing function. f 1

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The applicant has proposed minimum qualifications for the Manager, Corporate l Licensing, and his staff positions. The Manager will have a B.S. degree and 10 years of nuclear experience, 4 of which have been in nuclear safety. The Health Physics Specialist will have a B.S. degree in science or engineering and j 5 years of radiation protection, including 2 years of experience in fuel fabri-cation. The Criticality Safety Specialist will have a degree in science or ,

engineering and at least 2 years of experience in nuclear criticality safety i i

analysis. These qualifications are acceptable to the staff.

1 In the revised application, the applicant proposed minimum qualifications for.

the Manager-0perations and the managers of Technical Services Functions and Engineering. The managers shall possess a degree in science or engineering and shall have a minimum of 2 years' experience in the nuclear industry. Other managers, such as the Manager, Maintenance, are not required to possecs degrees. Special training and technical support will be provided for these managers. i B. Administrative Practices The applicant is committed to conducting business in accordance with approved written standard operating procedures. ANF also has a system of Company 13

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Standards and Policy Guides. Plant and facility managers are responsible for assuring compliance with all radiation protection and criticality safety pro-cedures within their respective facilities. The applicant has provided an extensive Approval and Responsibility Matrix for the development, approval, modification, and implementation of the above-mentioned documents. The Matrix will be incorporated by reference into the license.

The Supervisor, Radiological and Industrial Safety, is responsible for assuring j that Health Physics Technicians perform their assigned activities in a;cordance {

with approved procedures. l l

I C. Inspections and Audits i

1. Radiation Protection -l l

1 While conducting other routine duties, the Health Physics Technicians make periodic inspections of all radioactive mai,erial processing areas. Minor infractions.of procedures are corrected when detected. Serious infractions or violations of the license are documented and reported to facility management and the Manager, Corporate Licensing.

l The Health Physics Component of Corporate Licensing conducts monthly audits of radiation protection practices. The audit is conducted using a written plan, j and documented results are provided to. facility management and the Manager, Corporate Licensing. The Health Physics Component tracks deficiencies until corrective actions are taken.

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2. Criticality Safety During routine duties, the Health Physics Technicians perform inspections for criticality safety. Findings are reported to the Plant Criticality Safety Engineer.

The Plant Criticality Safety Engineer conducts monthly inspections of areas containing special nuclear material. The inspections are conducted in accordance 14

l SEP 101987 with a written plan. Findings are documented and reported to facility manage-ment and the Manager, Corporate Licensing. The Engineer tracks infractions until corrective actions are completed.

The Criticality Safety Component of Corporate Licensing performs bi-monthly audits of criticality safety control systems. The Component also audits modi-fications of existing systems and new systems prior to startup. All audits follow a written plan; findings are reported in writing to facility management and the Manager, Corporate Licensing. Open items are tracked until corrective actions are completed.

i 3. Environmental Protection 1

s The Health Physics Technicians collect environmental samples under the guidance  ;

of the Industrial Hygiene Specialist, who monitors the environmental releases.  !

The Health Physics Component of Corporate Licensing conducts monthly inspections of environmental protection practices and exposure controls. Results of inspec-tions, which are conducted per a written plan, are reported to facility manage-ment and the Manager, Corporate Licensing. Open items and recommendations are tracked by the Component until resolution is received.

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4. Other 1 1

The applicant has also committed to fire safety inspections by the Safety l Council and to chemical safety inspections by the' Supervisor, Radiological and Industrial Safety, and the Industrial Hygiene Specialist. I D. Personnel Training l

l For all company employees, the applicant has training programs which are commensurate with the employees' responsibilities and the extent of the l employees' contact with radioactive material.

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., SEP 101987 l s

1. Initial Instructions )

l 1 Befare on-the-job training is provided, each employee is given initial instructions in radiation protection, criticality safety, and emergency requirements. Independent operation assignments must be preceded by the instructions.

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2. Refresher Training l Refresher training is provided on a yearly basis. The effectiveness of the l training is measured by written tests. During monthly safety meetings, refresher training on selected safety topics is also given. I

3. Health Physics Technician Training The applicant provides special training for technicians and requires that the l technicians pass a certification examination within 6 months after employment.

l VII. RADIATION PROTECTION l

A. Radiation Safety Administration The Supervisor, Radiological and Industrial Safety, reports to the Safety and Security Operations Manager and is responsible for administering a radiological safety program which is established in accordance with criteria and standards provided by the Health Physics Component of the Corporate Licensing organization.

The Supervisor is responsible for implementing the radiological safety program, collecting data relative to the radiation exposure of employees, and providing other components wi'h radiation protection services. He is authorized to l recommend suspension of any operation which he believes uns'afe.

l The overall objective of the program is to ensure adequate containment of radioactive material and reduce the levels of radiation to meet'the As Low As Reasonably Achievable (ALARA) goal.

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SEP 101987 Radiation Work Procedures (RWP)

For any operation or maintenance work involving radiation and/or radioactive material, a RWP containing all safety requirements for the proposed work is .

prepared by the Radiological and Industrial Safety function. The licensee j

requires RWPs to be approved by the Corporate Health Physics Component and the ]

Manager (s) of the affected operation.

ALARA Commitment The licensee has made a commitment to maintain the radiation exposure to employees and the general public to an ALARA level. To do this, the licensee has established two safety review committees. The first one is the ALARA Committee which consists of seven senior members of the ANF technical staff j and a Health Physics Specialist. The Committee meets at least twice a year j and is responsible for reviewing the ALARA activities of the plant. '

The second committee, Health and Safety Council, has responsibility for I continued review and improvement of various aspects of the safety program, I I

conducting monthly inspections of safety and housekeeping practices, and assuring that occupational radiation exposures are kept as low as practicable.

The Council meets monthly and consists of ANF's management members and technical staff. )

1 The ALARA Committee, which makes an annual report, reviews employee exposures and effluent data to determine (a) trends in personnel exposures and effluents, l

(b) if personnel exposures or radioactive effluent might be lowered under the ALARA concept, and (c) if equipment for effluent and exposure control is properly designed, used, maintained, and inspected. The report will also include the review of required audits and inspections during the past year. )

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l B. Systems of Exposure Controls and Exposure Levels l

External Exposure External exposures of ANF personnel are controlled and evaluated using personnel ,

dosimeters as required by 10 CFR 20. The dosimeters are read and analyzed at  !

least quarterly. Should an individual's exposure exceed 40 percent of the permissible limit, an investigation will be conducted by the licensee.  !

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y SEP 101987 )

External exposure of' personnel has generally not been a problem in uranium fuel fabrication plants, and the ANF is fairly typical. The exter.al exposure data reported by the licensee for the period 1985 through 1986, at epresented by j the following table, shows that more than 99 percent of individuals' annual exposures are typically less than 10 percent of the regulatory limit, with no '

i exposure near the 5 rem per year limit. l

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External Exposure yExpressedasPercentof

> ' Individuals in Each Range Annual Exposure Ranges (Rem) 1985 1986 l 1

l No measura:.ie- 43 59.1 Measurable less than 0.1 41.8 29.4 0.1-0.25 10.7 8.9 '

O.25-0.50 3. 4 2.1  ;

0.50-0.75 0.3 0.4 0.75-2.5 0.6 0. 0

>2.5 0.0 0. 0 l

1 Internal Exposure i

Radioactive material may enter the body by breathing contaminated air, by ingestion as a consequence of poor hygiene or failure to self monitor. At l]

l ANF, protection of the operating personnel from excessive internal exposure is 3' i

provided by the use of:

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1. Ventilation systems designed to limit the concentration of radioactive j material in the breathing air and the confinement of uranium within process '

I equipment.

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2. An air sampling and analysis program for evaluating the airborne l

concentration of radioactivity in working areas.

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SEp 10 i987

3. A bioassay program to evaluate any significant deposition of radionuclides in the body.

4. Protective clothing to minimize direct contact with the radioactive material.

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5. Respiratory protective equipment to limit the inhalation of airborne.

,ra icactive material. The use of respiratory protective devices will be in acc'rdance with 10 CFR 20.103.

6. Surveys to detect the presence and extent of radioactive surface

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contamination.

. 7k Procedures, including action levels for investigation, control, and decontamination of contaminated surfaces.

Description of Equipment Ventilation Systems The ventilation system at ANF provides an air pressure gradient so that airflow is directed from the working area into exhaust systems. All exhaust systems frwthe uranium processing areas are filtered by HEPA filters and continuously monitored for radioactivity before being discharged through the stacks. The ventilation system maintains the face velocity of the uranium handling hoods in the facility above 125 LFPM and the ventilation exhaust rate in contaminated areas to at least seven air changes per hour. The performance capabilities are checked on a monthly basis.

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i After passing through HEPA filters, room air may be discharged back into work '

areas. The recirculated air is continuously monitored for airborne concentra-tion of radioactivity. If the recirculated air exceeds the 8 MPC-Hr exposure level, it is diverted to the facility exhaust air system.

19

SEp 101987 Monitoring of Air Concentration of Radioactivity and Controlling of Internal _j Exposure i

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The ANF ventilation system was designed and is operated to move air from areas of ";ow potential concentration to higher potential concentration. In the wo*

areas, the airborne concentration of radioactivity in the worker's breathing q air will be sampled using fixed sampling heads mounted at the work stations. l The frequency of the air sample change is based upon historical records within )

i each sampling area and varies from once per shift to once per week. The repre-l tentativeness of the sampling heads is evaluated by the licensee at least every 1 1

12 months or when changes to the process or equipment are made. If the worker's j weekly average internal exposure exceeds 10 mpc-br, the case will be investigated I and necessary corrective action will be taken.

4 In-Plant Airborne Activity Levels Data on the concentrations of airborne radioactivity in major work areas for 1983 thiough 1985 are summarized in the following table:

ANNUAL AVERAGE AIRBORNE CONCENTRATION LEVELS (Expressed as percent of maximum permissible concentration in 10 CFR 20)

Area 1983 1984 1985 UF6 -UO2 Conversion 10.0 5.8 5.0 Pellet Press 7. 2 7. 2 6.5 l Grinder 10.0 11.0 7.1 l Lube Blend 8.6 6.3 7.3  !

Scrap Recovery 4.3 1.4 2.1 Powder Storage 4.8 4.8 2.8 i NAF Facility 9.1 5.9 4.8 The table indicates the average airborne concentration of radioactivity in the work area is less than 12 percent of the maximum permissible concentration levels l specified in 10 CFR 20. i 20

1 1

l SEP 101987 1

l C. Bioassay Program l At ANF, the bioassay program is used to verify the adequacy of contamination control in work areas and to evaluate and control worker's internal exposures. j The program is conducted in accordance with provisions similar to those in I Regulatory Guide 8.11, " Application of Bioassay for Uranium." The program provides for routine collection and analysis of. urine samples on a monthly basis and for routine in-vivo lung counts at least annually from individuals who are routinely exposed to uranium compounds. The bioassay frequency will also 1 1

increase according to the most recent quarterly average airborne uranium ]

concentration as specified in Table 3 of Regulatory Guide 8.11. The program also provides action levcls and action to be taken when the levels are exceeded.

Data provided by ANF indicated that for the past 3 years (1983-1985), all urinary analysis results, except one sample, were below the action level of 25 pg/1. A resample from the individual whose first urinary analysis result exceeded the action level showed his urine to be below the detection level.

For the same period, in-vivo lung count results indicated the average lung burden of the worker to be below the action level of 125 pgm U-235 which is about one-third of maximum permissible lung burden for ANF workers.

D. Control of Surface Contamination l

The restricted areas of the ANF plant are zoned as contaminated, intermediate, and clean areas. In the contaminated area, protective clothing must be worn, '

and the individual must monitor himself for possible contamination upon exiting the area. Using an instrument which is calibrated twice a year, each defined area is surveyed routinely for contamination. The frequency of this survey is determined based on the extent to which the area is occupied and the potential hazard presented by the presence of surface contamination.

Specifications used by ANF for control of surface contamination are within the levels useJ at other fuel fabrication facilities with similar types of material and potential for contamination. They are summarized as follows:

21 4 .

SEP 101987 ;

Action limits for surface contamin'a tion control Action levels Survey Action to Area Removable dpm /100 cm2 frequency be taken Contaminated area 10,000 Weekly Clean up immediately Intermediate area. 500 Daily End of shift Clean area Any level above Monthly End of shift background l

Personnel clothing 200 Before leaving

• worn contaminated area I

Skin 200 (lower detection Same as above

• l level of detecting ]

instrument)  !

• Immediately clean up. If decontamination attempts are not successful, the j Radiation Protection function will be informed. I t

The release of contaminated equipment or material to clean areas will be in accordance with NRC " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct,  ;

Source, or Special Nuclear Materials," May 1987.

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E. Effluent Control I Air Effluent Air from the processing areas is passed through HEPA filters prior to release through stacks to the unrestricted area. The stacks are continuously and isokinetically sampled for radioactivity and analyzed weekly. If exhaust air concentration exceeds 12.5 percent of the limits for U-234 as specified in Appendix B, Table II, Column I, of 10 CFR 20, the licensee will investigate-and take corrective action. Data reported by the licensee shows the airborne effluents from.1983 through 1986 were less than 12 percent of the release limit allowed by the license condition implementing the requirements of 40 CFR 190.

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-j SEP 101987 Liquid Effluent All process radioactive liquid wastes are discharged to the onsite lagoon system )

'for storage and for further treatment to remove radioactivity as necessary. I Liquid and sanitary wastes are combined and discharged to the ANF-City Lift Station where the effluent is continuously sampled and pumped to the Richland Municipal Sewer System. Any radioactive material above the' detection level of 0.1 pg/ml uranium is cause to take corrective action. Data reported by the q licensee show that liquid effluent released from the plant from 1981 through l 1985 remained below 10 percent of the total annual release limit as specified 'f in 10 CFR 20.303.

Effluent releases from ANF are and have been within all license conditions and regulatory requirements including EPA's Environmental Standards, 40 CFR 190, for discharge of radioactivity to unrestricted areas. Detailed descriptions of the effluent releases and impacts resultirg from the overall plant operation are in the Environmental Assessment related to the license renewal.

Solid Waste l

l Noncombustible low-level radioactive solid wastes are packaged in accordance with all applicable regulations and transported to a . licensed disposal site.

F. Conclusion Upon completion of the radiation safety review of the licensee's renewal application, the staff has concluded that ANF has the necessary technical staff l at the site to administer an effective radiological safety program. Conformance by ANF to their proposed conditions should ensure a safe operation and the quick detection of unfavorable trends for corrective action.

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I SEP 101987 )

0 VIII. NUCLEAR CRITICALITY SAFETY A. Administrative Requirements i

Criticality Safety Specifications are prepared for each operation by.the Plant Criticality Safety Engineer. The Specifications contain information on work  ;

location, equipment, uranium enrichment and form, operation, criticality

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controls and limits, date, and approvals.

A specification is based on limits established in criticality safety analysis provided by the Criticality Safety Component of Corporate Licensing. ,Each $

criticality safety analysis is performed and independently reviewed by f individuals who, as a minimum, possess qualifications as specified in Section i 2.2.6 of the application. Each analysis must comply with Criticality Safety Standards which are prepared by Corporate Licensing. j Both the Specifications and the Standards are reviewed annually and updated as appropriate. The approvals for both documents are as described in Section 2.5 of the application. Criticality Safety Specifications and Process Specifica-tions are the basis for the Operating Procedures. Prior to initiation of a f

new process, the Criticality Safety Component will conduct a preoperational inspection to confirm that assumed controls are 'in place.

Fissile material locations will be posted with a sign showing limits from the l Criticality Safety Specification. The Specification will be available in the work / storage area. .

1 1

B. Technical Requirements l

The licensee has modified the Double Contingency Principle in ANSI /ANS-8.1-1983 l in establishing its Double Contingency Policy. The Double Contingency Principle  !

states that process designs should incorporate sufficient factors of safety to q minimize the possibility of nuclear criticality. ANF's policy states that '

l design and procedures will incorporate sufficient factors of safety. ANF also j l

commits to using favorable geometry whenever practicable. This is acceptable'to

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the staff.

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i 24 l

_-- _ -----_ - -_-- - --- - 1

SEP 101987 Where minimum critical mass, volume, or geometry data is available, ANF has proposed safety factors for establishing safe individual units. The safety factors range from 0.45 for a safe mass unit to 0.85.for a safe diameter infinite cylinder. When critical data is.not available, validated analytical methods may be used. In Section 4.2.2 of the application dated July 1987, ANF has proposed a safety factor of 0.05 for k-eff calculations of normal conditions.

A factor as low as 0.03 may be used for abnormal conditions if justified by sensitivity analyses.

When favorable geometry is not practicable, ANF proposes to use either fixed

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neutron absorbers or concentration control. Concentration control would be for  !

the uranium solution or the hydrogenous moderator of the oxide powder or-pellets. When fixed neutron absorbers are used, the absorbers will be i fabricated as an integral part of the equipment. Inspections of the equipment will be performed to verify the continuing integrity of the neutron absorber structure.

When solution concentration control is used, the concentration will be limited to not more than 50 percent of the minimum critical concentration in the vessel.

In addition, the concentration will be limited so that k-eff does not exceed ,

the limits in Section 4.2.2 for specified conditions. When moderator concen- I q

tration control is used for oxide powders or pellets,'the moderator concentra-l tion be limited to 50 percent of the critical concentration for the system.

l In addition, the licensee had proposed that "where practicable, the material 1

shall be contained within a fireproof barrier or in a process area containing l

limited sources of hydrogenous material." To satisfy the double contingency I principle, the words "where practicable" were deleted from the supplement to the application. This satisfies the double contingency criterion.

For all safety analyses, the licensee will use experimental results or calcula-tions using methods which have been validated. In revised Section 4.2.7.1 of the application dated July 1987, the licensee made a commitment to validate calculations in accordance with ANSI /ANS-8.1-1983 which is endorsed by Regulatory Guide 3.4. The analyses will be based on optimum moderation and full reflection except in certain specified cases.

25

1 i

l SEP 101937 C. Review of Demonstration of Nuclear Criticality Safety Administration l

In Chapter 11, the licensee described the Engineering Change Notice (ECN) j j

procedure. The ECN is for a variety of conditions, including changes involving I criticality or radiological safety. Prior to formal preparation of an ECN,  !

i safety, operations, and maintenance representatives review and revise the scope  !

package with the. responsible engineer. After this initial review, an ECN is prepared and controlled by the Design and Drafting Clerk. The ECN is concurred in by several managers and approved by'the user manager. When fissile material  ;

is involved, criticality safety personnel conduct a physical review. For larger projects, both a Startup Council overview and acceptance tests may be required.

The Manager, Corporate Licensing, may provide input to the Council. The ECNs and criticality analyses records are maintained by the licensee.

)

In Chapter 14, the licensee described the administrative practices for ensuring ]

criticality safety. The practices include the development and use of validated )

i methods for criticality safety analyses, the ECN method described above, per- J formance of a Criticality Safety Analysis (CSA) for each process or piece of equipment, establishment of specifications and procedures to ensure assumptions in the CSA and limits derived from the CSA, preoperational inspections of equipment and procedures, training, and audits of operations.

Each CSA includes consideration of off-normal conditions which are postulated and, if credible, are controlled by equipment design or administrative controls.

The licensee also discussed use of calculational codes and cross-sections, validation of the codes and cross-sections for both homogeneous and hetero- j geneous systems, and modelling of homogeneous and heterogeneous _ systems for

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CSAs. I The licensee is committed to sensitivity analyses when moderation controls are employed. In the revised application, the-licensee is not committed to sensitivity analyses for the safety factors for k-effective calculations. This assessment will assure that the safety factors are sufficient.

26

SEP 101907 D. Review of Demonstration of Process Nuclear Safety In Chapter 15 of the application, the licensee has provided a very general description of the process starting with the receipt of UFs to the fabrication of UO2 fuel assemblies and the recycle of uranium scrap. Each major process step description makes reference to the basis for nuclear criticality safety, e.g. , favorable geometry or moderation control, and to confinement of materials, e.g., process off gas systems, emergency scrubbers, etc.

i The safety demonstration for the incinerator, the SWUR facility, was provided in the May 18, 1987, supplement. The incinerator is a commercial controlled air unit which has been modified for minimum ash holdup and system cleanout.

The unit consists of primary and secondary combustion chambers. Both chambers have propane-fueled burners and combustion air ports.

The first chamber is controlled for quiescent burning to minimize particulate entrainment in combustion products passing to the second chamber. In the second chamber, excess air and high temperature are combined with sufficient residence time to burn all combustible gases, including dioxins which may have i formed in the first chamber.

Combustibles for incineration will come from two sources - current onsite generation and drums of stored onsite generated material. The current genera-tion material will be sorted at the place of origin and packaged in cardboard l boxes for incineration. Drums of stored material will be dumped into a hood in SWUR and sorted. Combustibles will be packaged in cardboard boxes for incineration; noncombustibles will be drummed for offsite disposal. The incinerator also has l the capability to burn contaminated liquids.

The ash from the incinerator will be transferred into 55 gallon drums in the loadout hood. The ash will be assayed and sent to uranium recovery or scheduled  !

l for disposal. l 1

Offgases from the second chamber will oe cooled and washed in a quench column, venturic scrubber, and packed column before passing through a mist eliminator, reheater, HEPA filters, and exhaust stack. Room air is also double-filtered i

i 27

i SEP 10 i987-i and exhausted through a separate stack. Makeup air is supplied by a SWUR makeup system, infiltration from the rest of the SF faciP ty, and by an outside untested supply to the incinerator. I 1

The uranium inventory for the incinerator will be limited to a safe batch of U-235. A running inventory will be maintained and adjusted for each container  !

charged to the incinerator and for each drum of ash removed. The charge material and the ash will be nondestructively asseyed, using methods which are l an existing part of the accountability system.

The facility is designed to be operated .c. thout the need for respiratory protection during normal operation. Air samples will be taken from the working areas. 'As part of the ALARA program, exposures to operators working in SWUR 1

will be tracked separately to assure that there are no significant radiological  !

l safety problems with SWUR.

l The incinerator is designed for continuous operation, subject to manual shutdown for cleanout to maintain safe batch control for nuclear criticality safety. The incinerator is alarmed for some 60 potential abnormal situations. In over 50 of I these alarm situations, the feed cycle is completed but further feeding is auto-matically prevented. In 13 of these alarm situations, the automatic response is l

an emergency shutdown. In the emergency shutdown sequence, the feeding 1

l mechanisms (liquid injection or RAM feeder) are shutdown, chamber burners are  !

shutdown, the combustion air blower is stopped and dampers are closed, a N2 purge of the primary container is initiated, the main offgas exhauster is shutoff and the shutdown exhauster is started to maintain negative pressure on the primary chamber, and any air cooling is maintained until system restart.

E. Conclusion l

The staff has concluded that the licensee's proposed criteria, as modified by license conditions above, are adequate. This conclusion is based on:

1. The history of safe operations with respect to nuclear criticality safety.

2. The demonstrated qualific c .ons of the nuclear criticality safety staff.

28

i i

SEP 101987 l l

3. The proposed license conditions which are not significantly changed from l current conditions.

1

4. The safety analyses which demonstrates sufficient, valid applications of the proposed administrative and technical requirements.

IX. ENVIRONMENTAL MONITORING I The licensee has proposed an environmental monitoring program which starts with conduit monitoring of liquid and airborne effluents. The program also includes i ambient air, soil, vegetation, and groundwater sampling. Groundwater sampling 1

is done onsite; other environmental sampling is done both onsite and offsite.

The adequacy of this program is being evaluated and will be reported in the  !

" Environmental Assessment for Renewal of Materials License No. SNM-1227 for the Advanced Nuclear Fuels Corport.; ion, Richland, WA."

i X. RADIOLOGICAL CONTINGENCY PLAN The licensee has incorporated, by reference, the revised Radiological Contingency Plan submitted by letter dated August 27, 1985, and committed to maintain implementing procedures, i

Changes which decrease the' effectiveness of the Plan will not be made without NRC approval. The NRC will be notified of other changes within 6 months of the l changes.

XI. FIRE SAFETY Permanent onsite buildings were constructed in accordance with local, state, and national building codes. The two main process buildings are precast concrete slabs attached to concrete reinforced columns. The rcofs are steel decks with builtup asphalt over a vapor barrier. Other facilities are preengineered metal buildings. The facility is self-insured. Fire protection audits are scheduled at approximate 3 year intervals. The last audit was conducted in April 1983 29 i

SEP 101987 by M&M Protection Consultants, Cedar Knolls, NJ. Copies of the Property Loss Prevention (AUDIT) Report and the ANF response were included in the application and reviewed by the staff.

XII. PLANT DECOMMISSIONING The licensee included the Decommissioning Plan in Chapter 7 of the application.

The plan contains criteria and general procedures. Detailed procedures would be developed at the time of decommissioning. By letter dated April 28, 1987, Hans W. Decker, President, Siemans Capital Corporation, provided assurance that ANF will have funds available for decommissioning.

XIII. EXEMPTIONS AND SPECIAL AUTHORIZATIONS In Section 1.6 of the application, the licensee requested several exemptions and special authorizations as follows:

1.6.1 The licensee regt.ests an exemption from 10 CFR 70.24(a) with respect to alarm system design and performance for all process areas except the lagoon area which will not be covered by the alarm system. The alarm system uses neu-tron detectors. The trip point for each neutron detector is 1-5 seconds at 80 mrem /hr (fast neutrons). The NRC staff finds this exemption request to be acceptable.

1. 6. 2 Uranium enriched to more than 5 but less than 19.99 w/o U-235 may be received, stored, and processed in existing equipment provided that not more than 45 percemt of a minimum critical mass is in process or storage; or safety analyses show the equipment is adequately subcritical; or equipment is modified to conform to criticality limits in the license. These controls or W its are acceptable to the staff.

1.6.3 The licensee proposes to continue storage and surveillance of Pu0 2 in sealed containers in the SF Building until packaged for disposal. This is acceptaDie to the staff.

30

SEP 101997

, 1.6.4 The licensee requests an exemption from 10 CFR 20.203(f). In lieu of 1

the labeling requirement, the licensee will post entrances to each building -

with an appropriate specified warning. The staff recommends approval of this exemption request.

• l 1.6.5 The licensee, pursuant to 10 CFR 20.302, requests authorization to dispose of solid waste material at other than a licensed disposal site provided I that the waste contains not more than 30 pCi of low-enriched uranium per gram 1

of dry solids. This is in accordance with the Draft Branch Technical Position.

1.6.6 This section on Safeguards requirements is not affected by this action and will be approved.

1.6.7 This section requests authorization to possess fuel assemblies and rods at reactor sites for loading or delivery to a carrier. The staff recommends approval.

The staff recommends the following license condition:

The licensee is hereby granted the exemptions and special authorizations in Sections 1.6.1 through 1.6.7, Chapter 1, of the application.

XIV. CONCLUSION Upon completion of the safety review of the licensee's application and com-pliance history, the staff has concluded that the activities to be authorized '

by the issuance of a renewal license to ANF will not constitute an undue risk to the health and safety of the public. Furthermore, the staff has determined that the application fulfills the requirements of 10 CFR 70.23(a).

The staff has discussed the renewal and the proposed license conditions with the Region V Project Inspector. On August 24, 1987, the Project Inspector's Supervisor stated he had no objection to the issuance of the renewal.

d 31

SEP 101987 The staff, therefore, recommends that the ANF license be renewed in its entirety, in accordance with the statements, representations, and conditions in ANF's application dated September 1986 and supplements, subject to the above identified conditions.

Original Si6noa by Originni Signed by l

An-Liang Soong George H. Bidinger Uranium fuel Section Uranium Fuel Section Fuel Cycle Safety Branch Fuel Cycle Safety Dranch, Division of Industrial and Division of Industrial and Medical Nuclear Safety Medical Nuclear Safety l

Original signea by Approved by:

s'erry J. Swif t, ,,ection Lead" Uranium Fuel Section l

l 1

- 1 EY.N . b.)]h...... E .k!b..

NAME:GHBidinger: ht :VLTharpe :SSoong :J wift  :

bATEb8 hbh b8k)bh bb h 8h Oh)hbh 0FFICIAL RECORD COPY l

32 L