ML20245J079
| ML20245J079 | |
| Person / Time | |
|---|---|
| Site: | 07000824 |
| Issue date: | 05/19/1989 |
| From: | Christopher Boyd BABCOCK & WILCOX CO. |
| To: | Rouse L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 25624, NUDOCS 8906300175 | |
| Download: ML20245J079 (41) | |
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. BibCOCk & WilC X NNFDREsEARCHLABoRAToRY -
L Yd P.O. Box 11165 a McDermott company g
g Lynchburg, VA 24506 1165 (804) 522-6000 s
{ U s t. c 000h COMMISfgyGUMTORY,
DOWETru og NMs3
~Q USNRC i
MallSection U.S. Nuclear Regulator)h,CissM6M t
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Attn: Leland C. Rouse, Nuss g,p$y/CL'88 CNN f
Fuel Cycle Safety Branch
,4 ' g @ 'j Division of Industrial & Med' cal d
Nuclear. Safety Washington D.C.
20555 Gentlemen:
The Babcock & Wilcox Company, Naval Nuclear Fuel Division Research Laboratory (NNFD-RL), is requesting an amendment to our license, SNM-778, to reflect recent proposed changes in our organization.
An explanation of the changes is attached along with the actual proposed page changes to the specification section of our license.
Changes are marked by a vertical line in the right hand margin. Page changes for the demonstration section of our license will be submitted under a separate cover letter.
NNFD-RL believes these changes to be an improvement to our current organization and administrative in na ture.
This request does not affect nor modify any. operations which are currently approved nor affect the health and safety of any personnel on or off-site nor have any adverse effect on the environment. There-fore, granting this request should not require an environmental impact
. statement as specified in 10 CFR 51.22 (c) (11).
Also, attached is a check for $150 to cover the initial application fee.
If you should have any further questions, please contact me at (804) 522-5753.
Sincerely,
-C Charlie C. Boyd, Jr.
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SNM-778 ORGANIZATIONAL CHANGES The. Manager Regulatory Relations' (Ma.aager,. RR)- is now called the-Manager, Safety & Safeguards.(Manager, SS).
The Supervisor, Health & Safety is now called the Supervisor, Health Physics.
- The Industrial. Safety Officer now reports to the NNFD Health &
Safety Manager.
His responsibilities ~at and for the NNFD-RL remain.
'the same.-
However, the~ Manager, Safety and Licensing and the Supervisor, Health Physics are no longer directly responsible' for.
this function.
- The Facility Supervisor and License Administrator positions are now combined into ' one position (with the same functions, responsibilities, and. requirements) called the Licensing Compliance Officer.
- National Bureau of Standards (NBS) has been changed to National.
Institute of Standards and Technology (NIST).
- The titles and responsibilities of Senior Health Physics-Engineer and Health Physics Engineer - are now consolidated -into one title, that of Health Physicist.
There are no. changes to the duties.
. responsibilities, and requirements.
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Attachment REVISIONS BY'PAGE'AND PARAGRAPH Pa ge ~'l-4 Paragraph 1.6.7 Manager,' Regulatory Relations (Manager, RR) changed to Manager, Safety
& Safeguards-(Manager, SS).
Paragraph 1.6.9 and 1.6.10' National Bureau of Standards (NBS) has been changed to National Institute of Standards and Technology (NIST).
Page 2-1 Paragraph 2.2.2 Manager, RR changed to Manager, SS.
Paragraph 2.2.3
.01d paragraph 2.2.5 is now the new paragraph. 2.2.3.
Industrial hygiene and industrial safety have been renvoved from the responsibilities of. the Manager,- Safety and Licen' sing since the Industria1' Safety Officer reports to the Manager, Health and Safety at NNFD.
Paragraph 2.2.4 Facility Supervisor changed to Licensing & Compliance Officer.
The position is now responsible to the Manager, Safety and Licensing.
The ' responsibilities of the License Administra tor from the old paragraph 2.2.10 has been added as the second paragraph.
Page 2-2 Paragraph 2.2.5 1
Health Physics Superv'sor changed to Supervisor, Health Physics.
Facility Supervisor changed to Licensing & Compliance Officer.
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i, Paragraph 2.2.6.
L Supervisor, Health and. Safety changed ~ to Supervisor Health Physics.
The Health Physics supervisor is no longer: responsible for' industrial safety programs and will "be responsible for" rather than " conducting"'
training.
Paragraph 2.2.7
' Senior Health Physics. Engineer changed to Health Physicist and Health-Physics Staff, changed to Health Physics Group, i
Supervisor, Health and Safety changed to-Supervisor, Health Physics.
Paragraph 2.2.8 8
The: Industrial Safety. 0fficer now reports to the Manager, Health and f
Safety at NNFD.:
Page 2-3 Old paragraph 2.2.10 was combined with paragraph 2.2.3.
Old paragraph 2.2.11 was renumbered to 2.2.10.
Paragraph 2.3.1.3 Supervisor, Health and Safety changed to Supervisor, Health Physics.
t Manager, RR changed to Manager, SS.
' Paragraph 2.3.1.6 The SRC Coordinator is changed to the Licensing & Compliance Officer.
Page 2-4 Paragraphs 2.3.3.4, 2.3.4.1, and 2.3.5.2 Manager, RR changed to Manager, SS.
Paragraph 2.3.5.3 SRC Coordinator changed to Licensing & Compliance Officer.
Paragraph 2.3.5.6 Manager, RR changed to Manager, SS.
Page 2-5 Paragraph 2.4.1 and 2.5.2 Manager, RR changed to Manager, SS.
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'Paragrap'h 2.5.3 Facility Supervisor changed to Licensing & Compliance Officer.
Paragraph 2.5.6 Supervisor -Health and Safety changed to Supervisor, Health Physics.
Paragraph 2.5.7
' Senior' Health ' Physics Engineer changed to Health Physicists.
Page 2-6 Paragraph 2.5.8 "Or equivalent" added af ter "one year's experience."
Old paragraph 2.5.10 was deleted since there is no longer a separate position of License Administrator.
Paragraph 2.6.1 and 2.6.2 Supervisor, Health and Scfety changed to Supervisor, Health Physics.-
Page 2-7 Paragraph 2.6.3 and 2.6.7 Supervisor, Health and Safety changed to Supervisor, Health Physics.
Paragraph 2.6.8 Reference (2.5.8) changed to.(2.5.9) l p
Page 2-8 Paragraph 2.7.1.2 and 2.7.1.3 Supervisor, Health and Safety changed to Supervisor, Health Physics, i
Facility Supervisor changed to Licensing & Compliance Officer.
Industrial Safety Officer added to the review process.
Paragraph 2.7.1.6 Facility Supervisor changed to Licensing & Compliance Officer.
Paragraph 2.7.2.1 i
Senior Health Physics Engineer changed to Health Physicist.
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'Page 2-9 4
. Paragraph 2.7.2.1-Senior' Health Physics Engineer changed to Health Physicist' Referenced paragraph numbers changed from 2.5.6 to.2.5.7 and 2.5.8 to i
2.5.9.
Paragraph 2.8.1.1 Manager, RR changed to Manager,-SS.
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Facility Supervisor and License' Administrator changed to Licensing 8 Compliance Officer.
Paragraph 2.8.1.21 j
Facility Supervisor changed to' Licensing & Compliance Officer.
Paragraph 2.8.2.1 Supervisor, Health and Safety changed to Supervisor, Health Physics.
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-Manager, RR changed to Manager, SS..
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" License Administrator changed to Licensing & Compliance Officer. -
d Paragraph 2.8.3.1 Health and-Safety. Group changed to Health Physics Group.
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Page 2-10' 4
Paragraph 2.8.3.1 Health and Safety Group changed to Health Physics Group.
Manager. RR changed to Manager, SS.
License Administrator and Facility Supervisor changed to Licensing &
j Ccmpliance Officer.
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' Paragraph 2.9.1
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License Administrator changed to Licensing & Compliance Officer.
Paragraphs 2.9.1.9 and 2.9.1.10 have been added. These paragraphs use 4
to be old paragraphs 2.9.3.1 and 2.9.3.2.
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Supervisor, Health and Safety changed to Supervisor, Health Physics.
- Paragraph 2.9.2.4 Health and Safety changed to Health' Physics.
Old paragraph"2.9.3 moved ' to new paragraph 2.9.1 under Licensing &
Compliance Officer.
Paragraph 2.10.1 Health and Safety Group changed to Health Physics Group.
Page 2-12 Paragraph 2.10.3 License Administrator changed to Licensing & Compliance Officer.
Page 2 New organization diagram.
Page 3-1 Paragraph 3.1.1.2 Health Physics Supervisor changed to Supervisor, Health. Physics.
Facility Supervisor changed to Licensing & Compliance Officer.
Paragraph 3.1.1.3 Manager, RR changed to Manager, SS.
Page'3-2 Paragraph 3.1.2.3 Facility Supervisor changed to Licensing & Compliance Officer.
Supervisor, Health and Safety changed to Supervisor, Health Physics.
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Paragraph 3.1.2.4 Supervisor, Health and Safety changed to Supervisor, Health Physics.
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Paragraph 3.2.1.2 Health and Safety Group changed to Health Physics Group.
Supervisor, Health and Safety changed to Supervisor, Haalth Physics.
Page 3-3 Paragraph 3.2.2.5 Health and Safety Group changed to Health Physics Group.
Page 3-7 Paragraph 3.2.4.2.1 Supervisor, Health and Safety changed to Supervisor, Health Physics.
Paragraph 3.2.4.2.5 Senior Health Physics Engineer changed to Health Physicist.
Paragraph 3.2.4.2.6 Supervisor, Health and Safety changed to Supervisor, Health Physics.
Page 3-9 Paragraph 3.2.4.3.1 Supervisor, Health and Safety changed to Supervisor, Health Physics.
Page 3-10 Paragraph 3.2.4.3.2 Supervisor, Health and Safety changed to Supervisor, Health Physics.
Page 3-11 Paragraph 3.2.4.3.2 Supervisor, Health and Safety changed to Supervisor, Health Physics.
Paragraph 3.2.4.3.3 Supervisor, Health and Safety changed to Supervisor, Health Physics.
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Page 3 Paragraph-3.2.4.3.3 Supervisor, Health and Safety changed a Supervisor, Health: Physics.
Page 3-13 Paragraphs ~ 3.2.4.4.2,'3.2.4.5.1, and 3.2.4.6.1' Health and Safe'ty Group changed to Health Physics Group.
Page 3-14 Paragraph 3.2.4.7.1 Health and Safety Group changed to Health Physics Group.
Paragraph 3.2.4.7.3 and 3.2.4.7.4 Supervisor, Health and Safety changed to Supervisor, Health Physics.
Page 4-1.
Paragraph 4.1.3 and 4.1.4 Facility Supervisor changed to Licensing & Compliance Officer.
Paragraph 4.1.6 Facility Supervisor changed to Licensing & Compliance.0fficer.
Page 4-2 Paragraph 4.1.6 Supervisor, Health and Safety changed to Supervisor, Health Physics.
Manager, RR changed to Manager, SS.
Page 4-3 Paragraph 4.2.2.2.2 Facility Supervisor changed to Licensing & Compliance Officer.
Page 5-1 l
Paragraph 5.1.1 j
Supervisor, Health and Safety changed to Supervisor, iiealth Physics.
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9/87 2-13 11 5/89 3-1 7
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4/87 3-2 11 5/89 3-3 4
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________________.________._____J
1.6.2 SRC means Safety Review Committee.
1.6.3 SNM means Special Nuclear Material.
1.6.4 Licensed Material means source, byproduct, or SNM received, possessed, used or transferred under a general or specific license issued by the Nuclear Regulatory Commission.
1.6.5 Research and Development (R&D) means (1) theoretical analysis, exploration, or experimentation; or (2) the extension of investigative findings and theories of a scientific or technical nature into practical application for experimental and demon-stration purposes, including the experimental production and testing of models, devices, equipment, materials and processes. The administration of licensed material, internally or externally, to human beings is not included in this definition.
1.6.6 Safety Audit Subcommittee (SAS) means the subcommittee established under the SRC to perform audit functions.
1.6.7 Manager, Safety & Safeguards (Manager, SS) means the position with l
primary responsibility for the safety of operations at the site.
1.6.8 Authorized User means a person who may work with licensed material unsupervised and may supervise others, not so designated, in the handling of licensed material.
1.6.9 Calibration means a comparison of a measurement standard of known accuracy that is traceable to the NIST with another standard or
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l instrument to detect, correlate or adjust any variation in the accuracy of the item being compared, within the specified range and accuracy of the item.
Calibration also includes standardization.
1.6.10 Standardization means, the act of using standards which are traceable to the NIST, a nationally accepted measurement system, l
or natural phenomena to set up an instrument. Standardization must be performed before and after use.
l 1.6.11 Unit means (1) a separate laboratory, room, or work area; (2) a transfer cart where SNM is separated from adjacent units by at least 8-inches edge-to-edge and 24-inches center-to-center. More than one unit may be on a cart provided the preceding edge-to-edge l
l May, 1989 License No SNM 778 Docket No.70-824 Date 5
11 p, 1-4 Amendment No.
Revision No.
l Babcock &Wilcox a McDermott company
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TABLE OF CONTENTS 1
Section Page 2.0 GENERAL ORGANIZATIONAL AND ADMINISTRATIVE REQUIREMENTS 2-1 2.1 POLICY 2-1 l
2.2 ORGANIZATION RESPONSIBILITIES AND AUTHORITIES 2-1 2.3 SAFETY REVIEW COMMITTEE 2-3 2.4 APPROVAL AUTHORITY FOR PERSONNEL SELECTION 2-5 2.5 PERSONNEL EDUCATION AND EXPERIENCE REQUIREMENTS 2-5 2.6 TRAINING 2-6 2.7 OPERATING PROCEDURES 2-8 2.8 INTERNAL AUDITS AND INSPECTIONS 2-9 2.8.1 Nuclear Criticality Safety 2-9 2.8.2 Health Physics 2-9 2.8.3 General Safety and Compliance 2-9 2.9 INVESTIGATIONS AND REPORTING 0F 0FF-NORMAL OCCURRENCES 2-10 2.9.1 Licensing & Compliance Officer.
2-10 l
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2.9.2 Supervisor, Healtit Physics 2-11 l
i 2.10 RECORDS 2-11 l
2.10.1 Health Physics Group 2-11 l
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2.10.2 Nuclear Criticality Safety Officer 2-12 2.10.3 Licensing & Compliance Officer.
2-12 l
2.10.4 Emergency Records 2-12 i
May, M89 License Wo SNM 778 Docket No.70-824 Date 5
11 2-1 Amendment No.
Revision No.
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TABLE OF CONTENTS (Continued).
h List of Figures Figure Page 2-1 SITE ORGANIZATION 2-13
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License No ONM 778 Docket No.70-824 Data May, 1989 5
11 2-11 i
Amendment No.
Revision No.
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1 2.0 GENERAL ORGANIZATIONAL AND ADMINISTRATIVE REQUIREMENTS i
1 2.1 POLICY It shall be the policy of the site to maintain radiation exposures to employees and the general public as low as is reasonably achievable.
j The. facility procedures to ensure the safe handling of licensed material are the Area Operating Procedures.
I 2.2 ORGANIZATION RESPONSIBILITIES AND AUTHORITIES 1
2.2.1 Vice President, NNFD is ultimately responsible for ensuring that all operations at the site are conducted safely and in full com-pliance with NRC requirements.
2.2.2 Manager, SS - The Manager, SS is responsible for safety of oper-l ations at the site.
2.2.3 Manager, Safety and Licensing - The Manager, Safety and Licensing directs technical and administrative activities and establishes policies related to facility decommissioning, accountability and safeguards of special nuclear material, radiation protection, nuclear criticality safety, and licensing. He coordinates l
retources to perform operations in compliance with Federal and State regulations.
l 2.2.4 Licensing & Compliance Officer - The Licensing & Compliance Officer is responsible to the Manager, Safety and Licensing for the safe conduct of operations at the site and for ensuring that applicable operations are conducted in compliance with the license and appli-cable regulations. To fulfill these responsibilities the Licensing
& Compliance Officer shall have the authority to stop any operation that he feels is unsafe or in violation of license. The Licensing l
8 Compliance Officer shall review new Area Operating Procedures and RWP's, and changes thereto, for license and regulatory compliance i
and for facility. safety; and he shall have approval authority for them. He shall submit items for review to the SRC. He shall have approval authority for Area Supervisors.
The Licensing & Compliance Officer shall also be responsible for administering the license. He is the primary liaison with the NRC and other federal, state, and local agencies in matters that May, 1989
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License No SNM-778 Docket No. 70 824 Date 5
II 2"I Amendment No.
Revision No.
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pertain to nuclear activities. He shall be the coordinator of the SRC and the Safety Audit Subcommittee and shall represent manage-ment on both. He shall maintain the permanent records of the SRC and shall be responsible for assuring that appropriate action is taken to correct SAS audit findings that are approved by the Manager, SS.
2.2.5 Area Supervisors - Area Supervisors are recommended by their division management end their appointment shall be jointly approved by the Supervisor, Health Physics, and the Licensing & Compliance Officer. They shall functionally report to the Licensing & Com-pliance Officer. They shall be responsible for the safety and compliance of operations in their assigned areas. They shall be responsible for maintaining the exposures of personnel assigned to their area below 300 millirem / week; 1250 millfrems/ quarter. They shall have approval authority for Radiation Work Permits that apply to their assigned areas. They shall keep the Licensing & Compliance Officer advised of plans for projects and work to be carried out in their areas.
2.2.6 Supervisor, Health Physics - The Supervisor, Health Physics is l
responsible for providing adequate facilities, procedures, and properly trained personnel to implement the Health Physics Program.
He is responsible for health physics activities. The Supervisor, Health Physics reports to the Manager, Safety and Licensing. The Supervisor, Health Physics has the authority to stop any operation that he believes is contrary to accepted safety practices or license requirements. He shall review new Area Operating Procedures, Radi-ation Work Permits and changes thereto, for the radiation safety aspects of the procedure, RWP, or change, and he shall have approval authority for them. He shall be responsible for training programs l
for new employees and Authorized Users of Radioactive Material. He shall be responsible for the shipment of licensed material. The Supervisor, Health Physics shall be a member of the Safety Review l
Committee but shall not be a member of the Safety Audit Subcommittee.
He shall have approval authcrity for Area Supervisors.
2.2.7 Health Physicists - The Health Physicists shall administer activi-ties of the Health Physics Group. They shall report to the Super-i visor, Health Physics.
2.2.8 Industrial Safety Officer - The Industrial Safety Officer shall administer the industrial safety program.
He shall report to the NNFD Manager, Health and Safety.
l May, 1989 License No SNM 778 Docket No. 70824 Data 5
II 2-2 Amendment No.
Revision No.
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4 2.2.9 Nuclear Criticality Safety Officer - The Nuclear Criticality Safety Officer shall be responsible for ensuring that no operation at the '
site results in the inadvertent assembly of a critical mass. He shall review all new Area Operating Procedures and changes thereto, for nuclear criticality safety and shall have approval authority for them. He shall conduct training programs in criticality safety and perform criticality safety calculations. He shall report to the Manager, Safety and Licensing.
2.2.10 Accountability Specialist - The Accountability Specialist shall be responsible for the maintenance and retention of SNM accountability records. The Accountability Specialist shall report to the Manager, Safety and Licensing.
2.3 SAFETY REVIEW C0lHITTEE 2.3.1 Function 2.3.1.1 The SRC shall review and approve new Area Operating Procedures, and shall concur with changes made to them in the time interval since their last regular meeting.
2.3.1.2 The SRC shall review and approve new projects and major changes to existing projects that utilize licensed materials.
2.3.1.3 The SRC shall review the annual report prepared by the Supervisor, Health Physics. The report of the SRC's review shall be sent to the Manager, SS, with a copy to the Vice President, NNFD.
2.3.1.4 The SRC shall provide general consulting services in the field of radiation protection and the safe handling of licensed material.
2.3.1.5 The SRC shall review SAS audit findings, overexposure and unusual occurrences which must be reported to the NRC. These reviews shall be conducted during the next regularly scheduled meeting following the event and the results of the review shall be documented in the minutes.
2.3.1.6 The Licensing & Compliance Officer shall be responsible for l
resolving comments and recommendations made by the SRC.
2.3.2 Frequency of Meetings 2.3.2.1 The SRC shall meet at least four times annually for the purposes of conducting its business as specified in Section 2.3.1.
May, i m License No SNM-778 Docket No.70-824 Date 5
II 2-3 Amendment No.
Revision No.
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1 4-2.3.3 Safety Audit Subcommittee
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2.3.3.1 The SAS shall perform audits for the Safety Review Committee.
2.3.3.2 The SAS shall audit facilities, procedures, records, and opera-i tions for compliance with written requirements and the exercise of I
acceptable safety practices.
1 2.3.3.3 The SAS shall perform at least three audits annually, distributed i
over a 12-month period. Audits shall be made in accordance with 1
written guidance to assure all aspects of 2.3.3.2 are audited.
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2.3.3.4 SAS membership shall be appointed by the Manager, SS.
l 2.3.4 Reporting 2.3.4.1 The SRC shall report to the Manager, SS.
l 2.3.4.2 The SAS shall report to the Chairman, SPC.
2.3.5 R_ecordkeeping 2.3.5.1 Minutes of the SRC proceedings shall be prepared by the Chairman, SRC.
2.3.5.2 SRC Minutes shall be forwarded to the Manager, SS, with a copy to l
the Vice President, NNFD, by the Chairman, SRC.
2.3.5.3 The permanent records of the SRC shall be kept by the Licensing &
Compliance Officer.
2.3.5.4 SAS audit reports shall be prepared by the Chairman, SAS.
2.3.5.5 SAS audit reports shall be forwarded to the Chairman, SRC by the Chairman, SAS.
2.3.5.6 SAS audit reports shall be forwarded to the Manager, SS with a l
copy to the Vice President, NNFD by the Chairman, SRC with comments, as he deems appropriate.
May, 1989 License No SNM-778 Docket No. 74824 Date 5
II 2-4 Amendment No.
Revision No.
Page Babcock &Wilcox a McDermott company
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a 2.4 APPROVAL AUTHORITY FOR PERSONNEL SELECTION 2.4.1 The Manager, SS shall approve the personnel selected for safety-l related positions specified in Section 2.2 of this Part and shall appoint the members of the Safety Review Committee in writing. The NNFD shall appoint the Manager, SS.
l 2.5 PERSONNEL EDUCATION AND EXPERIENCE REQUIREMENTS 2.5.1 Vice President, NNFD - The Vice President, NNFD shall be appointed i
in accordance with Company policy.
2.5.2 Manager, SS - The Manager, SS shall, as a minimum have a Bachelor's l
degree or equivalent and three years experience in the nuclear field. He shall have demonstrated sufficient judgement and experi-i ence to manage the functions under his direction.
2.5.3 Licensing & Compliance Officer - The Licensing & Compliance Officer l
shall have a BS degree in science or engineering and three years experience in the use and handling of licensed material, or an AS degree in science or nuclear technology with five years experience in the use and handling of licensed material.
i 2.5.4 Area Supervisors - Area Supervisors shall have at least a high school education and two years of experience in the handling and use of licensed material. They shall have demonstrated sufficient knowledge and experience in the equipment and techniques employed in projects performed in their assigned areas to ensure that all operations are conducted safely and in full compliance with appli-cable license conditions and area operating procedures.
l 2.5.5 Manager, Safety and Licensing - The Manager, Safety and Licensing shall have a BS degree in a technical field and five years j
experience in the nuclear field.
i 2.5.6 Supervisor, Health Physics - The Supervisor, Health Physics shall l
have a BS degree in a technical field and professional experience in assignments involving radiation protection at the supervisory i
level.
He must have four years experience and demonstrate proficiency in the application of radiation safety principles and be knowledgeable in fields related to radiation protection.
2.5.7 Health Physicists - The Health Physicists shall have a BS degree l
which shall include at least 20 quarter hours health physics related course work, and two years of radiation control related experience or an MS degree and one year of radiation protection experience.
License No SNM-778 Docket No. 70 824 Date May, 1989 l
Amendment No.
Revision No.
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11 2-5 Babcock &WHcox a McDermott company
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2.5.8 Industrial Safety Officer - The Industrial Safety Officer shall-
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have at least one year's experience or equivalent in radiation and l
i industrial safety.
He shall be familiar with the codes and
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requirements of the Occupational Health and Safety Act of 1970 and the National Fire Protection Association.
2.5.9 Nuclear Criticality Safety Officer - The Nuclear Criticality Safety Officer shall have a BS degree in science or engineering.
He must have either two years experience with nuclear criticality safety calculations similar to those associated with site activities or he must have one year's experience with nuclear criticality safety calculations similar to those associated with site activities if he has at least an additional two years' experience in nuclear. reactor physics calculations.
2.5.10 Accountability Specialist - The Accountability Specialist shall have at least a high school education and three years' experience in the use of licensed material. He must demonstrate to Company management his knowledge of the principles necessary for the accountability and safeguarding of special nuclear materials.
2.5.11 Safety Review Committee - The SRC membership, as a body, shall have expertise in chemistry, nuclear physics, health physics, and the safe handling of radioactive material. The SRC mcw" ship shall have a general understanding of nuclear criticality safety as it pertains to site operation.
2.6 TRAINING 2.6.1 Program 1 - This course is presented to site workers and non-site workers who will be granted access to the restricted area' but who will not be granted unescorted access to the controlled areas. The course provides an introduction to radiation and radioactivity (understandable to a non-technical person) and a thorough coverage 1
of safety rules and procedures, including the site emergency pro-cedures. The. Supervisor, Health Physics may modify the course l
content for those individuals knowledgeable in the basics of radi-ation and radioactivity. However, safety rules, procedures, and emergency procedures that apply at the site shall be covered.
i 2.6.2 Program 2 - This course is presenteo to site workers and non-site
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workers who will be granted unescorted access to the restricted q
area and controlled areas but who will not be permitted to work j
with radioactive materials without supervision. The Supervisor, Health Physics may modify the course content for those individuals l
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i knowledgeable in the basics of radiation and radioactivity.
However, safety rules, procedures, and emergency procedures that apply at the site shall be covered. The effectiveness of the training shall be determined by a written examination.
2.6,3 Program 3 - This course shall be presented to site workers and non-site workers who will be granted unescorted access to the restricted area and controlled areas and will be permitted to work with radio-active materials and supervise such work. This course shall meet the requirements for designating a worker as an Authorized User.
The Supervisor, Health Physics may modify the course content for l
those individuals knowledgeable in the basics of radiation and radioactivity. However, safety rules, procedures and emergency procedures that apply at the site shall be covered. The effective-ness of the training shall be determioned by a written examination.
2.6.4 Retraining - Persons who are designated as Authorized Users shall q
be retrained annually. Satisfactory completion of the retraining shall be determined by passing a written examination.
2.6.5 Respiratory Protection Training - Training in respiratory pro-tection techniques and equipment shall be required of all workers before the use of such equipment will be permitted. Satisfactory completion of this training shall be determined by passing a written examination.
2.6.6 Respiratory Protection Retraining - Retraining in respiratory pro-tection shall be performed at two year intervals. Satisfactory completion of this retraining shall be determined by passing a written examination.
2.6,7 The training specified in Section 2.6 shall be administered by the Supervisor, Health Physics, or his designated and qualified l
al terna te.
1 2.6.8 Nuclear Criticality Safety Training - Nuclear Criticality Safety trair.ing provided as a part of the programs specified in Sections 2.6.2. 2.6.3 and 2.6.4, shall be performed by the Nuclear Criti-cality Safety Officer or his designated alternate. The designated alternate must meet the same minimum qualifications as those spect-fied for the Nuclear Criticality Safety Officer (2.5.9).
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l 2.7 OPERATING PROCEDURES l
2.7.1 Area Operating Procedures 2.7.1.1 All operations with licensed material shall be conducted in accordance with. Area Operating Procedures or Radiation Work Permits (see 3.1.1).
2.7.1.2 Area Operating Procedures (A0P) - Area Operating Procedures shall be established for all routine operations in which SNM, source and byproduct materials are stored or handled. A0P's shall include those nuclear criticality and radiation safety controls and limits that apply to the operation.
Each A0P shall be approved by the Nuclear Criticality Safety Officer or his designated alternate, the Supervisor, Health Physics or his designated alternate, the Licensing & Compliance Officer or his designated alternate, the Industrial Safety Officer or his designated alternate and the Safety Review Committee.
2.7.1.3 A0P's may be revised with the approval of the Nuclear Criticality Safety Officer or his designated alternate, the Supervisor, Health Physics or his designated alternate, the Industrial Safety Officer or his designated alternate and the Licensing & Compliance Officer or his designated alternate.
The revised procedure may be used with these approvals until the next scheduled regular meeting of the Safety Review Committee when the revision must be approved by the SRC.
2.7.1.4 A0P's shall be available in each operations area where they apply and shall be followed by site personnel.
2.7.1.5 Distribution of new and revised procedures shall be made in accordance with a document control system which assures that the procedure manuals contain only the most current revision of the procedures.
2.7.1.6 A0P manuals shall be reviewed annually by the Licensing & Com-j pliance Officer to assure that the manuals contain the most current revision of the procedures.
2.7.2 Technical Procedures 2.7.2.1 Technical procedures shall be established, reviewed, approved, and followed for Health and Safety or Nuclear Criticality Safety. They shall be reviewed and approved by a Health Physicist or the Nuclear l
Criticality Safety Officer, respectively, or their designated May, 1989 License No SNM 778 Docket No.70-824 Date 5
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al terna te. The designated alternate for a Health Physicist must meet the minimum qualifications specified in Sections 2.5.7.
The designated alternate for the Nuclear Criticality Safety Officer must meet the same minimum qualifications specified in Section 2.5.9.
Approval signatures shall appear on the procedure.
l 2.8 INTERNAL AUDITS AND INSPECTIONS 2.8.1 Nuclear Criticality Safety 2.8.1.1 The Nuclear Criticality Safety Officer or his designated alternate shall conduct internal audits for the purpose of evaluating the nuclear criticality safety aspects of operations. This audit shall be conducted in accordance with written audit guidance.
This audit shall be conducted once each calendar quarter. A report of his findings shall be made to the Manager, SS within two l
weeks of completing the audit. The audit reports shall be forwarded to the Licensing & Compliance Officer. The Licensing &
Compliance Officer shall be responsible for assuring that the appropriate corrective actions are taken to address the audit findings.
2.8.1.2 The Licensing & Compliance Officer shall perform an inspection I
weekly for compliance with the nuclear criticality safety aspects of the operations. Findings resulting from these inspections shall be reported to the Nuclear Criticality Safety Officer.
2.8.2 Health Physics 2.8.2.1 The Supervisor, Health Physics or his designated alternate shall I
conduct internal audits for the purpose of evaluating the health physics aspects of operations. This audit shall be conducted in accordance with written audit guidance. This audit shall be conducted once each month. A report of his findings shall be made to the Manager, SS within two weeks of completing the audit. The audit reports shall be forwarded to the Manager, SS and the Licensing & Compliance Officer. The Licensing & Compliance l
Officer shall be responsible for assuring the appropriate corrective actions are taken to address the audit findings.
2.8.3 General Safety and Compliance 2.8.3.1 The SAS performs audits of general safety and compliance. These audits shall be conducted three times annually. The audits shall be distributed over a 12-month period. The SAS shall include an audit of the Health Physics Group at least once annually. This l
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annual audit shall be performed by a qualified individual who is independent of the Health Physics Group. Other areas shall be I
audited for compliance with written requirements and the exercise of acceptable safety practices. Audits shall be made in accordance with written guidance to assure all aspects of Section 2.3.3.2 are audited. The Chairman, SAS shall file a report of the audit findings with the Chairman, SRC, with a copy to the Licensing & Compliance Officer and members of the SRC. The Chair-man, SRC shall forward the report to the Manager, SS with comments, as he deems appropriate. The Licen.;ing & Compliance Officer shall be responsible for assuring that the appropriate corrective actions are taken to address the audit findings.
2.9 INVESTIGATIONS AND REPORTING OF 0FF-NORMAL OCCURRENCES 2.9.1 Licensing & Compliance Officer l
The Licensing & Compliance Officer shall investigate and report.
l when required, the following types of off-normal occurrences:
2.9.1.1 Excessive levels of radiation from or contamination on packages upon receipt.
2.9.1.2 Thef ts, attempted thef ts, or losses of licensed material, other than normal operating losses.
2.9.1.3 Incidents as specified in 10 CFR 20.403 2.9.1.4 Overexposure of individuals and excessive levels and concentra-tions of radioactivity.
2.9.1.5 Failures to comply and defects pursuant to 10 CFR 21.
2.9.1.6 Changes to security, safeguards, or emergency plans made without prior NRC approval, when prior approval is required.
2.9.1.7 Failures to comply with license requirements.
2.9.1.8 Unapproved storage or use of licensed material.
2.9.1.9 Any violation of nuclear criticality safety criteria.
2.9.1.10 Any violation of Area Operating Procedures or RWP's.
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t 2.9.2 Supervisor, Health Physics s
The Supervisor, Health Physics shall perform investigations and issue reports of the following:
2.9.2.1 Higher than expected personnel exposures.
2.9.2.2 Higher than expected concentration of airborne activity in the facili ty.
2.9.2.3 Unauthorized entry into a High Radiation or Airborne Radioactive Material area.
2.9.2.4 Failure of equipment or instrumentation to meet Health Physics l
requirements.
2.10 RECORDS The following positions or organizations shall be responsible for maintaining the indicated records, for the period specified.
Records may be kept in original form, microfilm or in computer storage. The symbol (*) indicates that the record will be retained until the NRC authorizes its disposition.
2.10.1 Health Physics Group Health Physics Supervisor audits 2 years Shipping and receiving RM forms 5 years Waste disposal records
(*)
Personnel dosimetry records
(*)
Results of Bioassays and Whole Body Counting
(*)
Releases to the environment
(*)
Radiation survey data 2 years Contamination survey data 2 years Radiation Work Permits (coutpleted) 5 years Radiation detection instrument calibration 2 years Leak tests of sealed sources 2 years Personnel training
(*)
l Personnel retraining
(*)
j Airborne radioactivity sampling data
(*)
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NRC-4 forms
(*)
NRC-5 forms
(*)
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L 2.10.2 Nuclear Criticality Safety Officer Nuclear criticality safety 6 months after evaluations and calculations termination of the approved process.
Nuclear Criticality Safety Officer 2 years Audit Reports.
2.10.3 Licensing & Compliance Officer l
Safety Review Committee Minutes
(*)
Safety Audit Subcommittee Audit Reports 2 years Investigation reports of off-normal occurrences 2 years 2.10.4 Emergency Records Records pertaining to emergency response and preparedness shall be retained in accordance with Radiological Contingency Plan, Section 8.0.
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FIGURE 2-1 l
SITE ORGANIZATION NNFD RESEARCH LABORATORY i
ORGANIZATION NAVAL-NUCLEAR FUEL DIVISION VICE PRESIDENT SAFETY & SAFEGUARDS MANAGER SAFETY SAFETY SAFETY & LICENSING REVIEW MANAGER COMMITTEE MANAGER HEALTH &
LICENSING &
NUCLEAR HEALTH ACCOUNTABILITY SAFETY COMPLIANCE SAFETY PHYSICS SPECIALIST OFFICER OFFICER SUPERVISOR MANAGER INDUSTRIAL AREA HEALTH PHYSICIST SAFETY SUPERVISORS OFFICER HEALTH PHYSICS GROUP License No SNM 778 Docket No.70-824 Date May, 1989 5
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3.0 RADIATION PROTECTION l
3.1 SPECIAL ADMINISTRATIVE REQUIREMENTS 3.1.1 Radiation Work Permits (RWP) 3.1.1.1 RWP's shall be issued whenever the activity is not covered by an Area Operating Procedure and workers are likely to be exposed to levels of radiation or concentrations of radioactive material in excess of those specified in 10 CFR 20.101 & 20.103.
3.1.1.2 RWP's shall be approved by the Area Supervisor, Supervisor, Health Physics, and the Licensing & Compliance Officer.
In the absence of any of the above persons, a designated and qualified alternate may approve RWP's.
3.1.1.3 The RWP shall specify the radiological protection requirements for the operation and specify levels of worker exposure above which a documented ALARA evaluation shall be performed. RWP's that re-quire a documented ALARA evaluation must, in addition to 3.1.1.2, be approved by the Manager, SS.
l 3.1.1.4 RWP's shall be approved at a meeting of all the signators of the form.
3.1.1.5 The RWP form shall provide space for entering the estimated exposures to the whole body, extremities, and for the job. These are used to identify the areas of exposure concern and do not constitute an exposure-goal or lim
- t.
3.1.1.6 The RWP form shall provide space for the Area Supervisor to sign or initial, attesting that the workers have been 1.1structed in the requirements of the RWP.
3.1.1.7 The term of a RWP shall not exceed 30-days, except that Standing RWP's shall have a term not to exceed 6-months.
3.1.2 ALARA Policy The management of the site is committed to a policy of maintaining exposures as low as is reasonably achievable.
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3.1.2.1 Site workers shall be introduced to this policy during their initial training and shall be reinforced during the annual re-I training of Authorized Users.
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3.1.2.2 The ALARA policy shall be implemented through the Area Operating Procedures and Radiation Work Permits.
3.1.2.3 The ALARA policy shall be enforced by the Licensing & Compliance j
Officer and the Supervisor, Health Physics in the exercise of their review and approval authority, their authority to terminate operations, and audits.
3.1.2.4 The SRC shall evaluate ALARA performance in exercising their review authority over procedures and proposed new projects and their review of the annual report from the Supervisor, Health Physics.
3.1.3 Off-Site Possession Off-site possession and use of licensed material shall be the re-i sponsibility of and under the control of site workers specifically approved by the Safety Review Committee.
3.2 TECHNICAL REQUIREMENTS j
3.2.1 Access Control 3.2.1.1 High Radiation Areas - Entry into a High Radiation Area or an Airborne Radioactivity Area shall be controlled by an RWP.
j 3.2.1.2 Contamination Areas - Areas which are determined by the Health Physics Group to present a risk of spreading radioactive l
contamination into non-contaminated areas shall be clearly marked at each entrance.
Step-off pads shall be provided.
Personnel survey instrumentation shall be provided at the step-off pad. The minimum protective clothing required in Contamination Areas shall be shoe covers and lab coats. Exiting such areas shall require personnel to remove their protective clothing and survey thent-selves with the instrumentation provided. Persons found to be contaminated above background levels must receive the approval of the Supervisor, Health Physics prior t0 leaving tile contaminated l
- area, l
3.2.2
,yntilation Requirements 3.2.2.1 Air flows within Building B shall be in the direction of highest 1
potential for airborne radioactive material. Air flow directions j
shall be checked monthly.
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3.2.2.2 Potenticily contaminated exhaust air from hood, hot cells, and glove boxes shall be discharged through the fifty meter high stack, except c: r.cted in 3.2.2.7.
3.2.2.3 The exhaust stack shall be sampled isokinetically.
3.2.2.4 The stack sampling and monitoring system shall operate continu-ously except for periods when repair or calibration is required.
3.2.2.5 The following" table presents the release limits and action levels associated with the exhaust stack. The Health Physics Group shall l
be responsible for responding to releases in excess of these action levels. An operation that results in action levels being exceeded for 4-consecutive time periods, shall be shutdown until the cause is corrected.
STACK RELEASE LIMITS AND ACTION LEVELS Release Product Release Limit Action Level Beta Particulate 2 mC1/yr 200 uCi/ week Alpha Particulate (long lived) 20 uCi/yr 1 uCi/2 weeks Kr-85 2500 Cf/yr 70 C1/ week H-3 130 Ci/yr 3 Ci/ week I-131 6 mci /yr or 300 uC1/ week 200 uC1/ week 3.2.2.6 Exhaust systems that cannot be practicably discharged through the 50-meter stack, and where there exists a reasonable probability that the discharges to the atmosphere could exceed 10% of the applicable MPC for an unrestricted area, shall be monitored for gaseous and particulate activity in the effluent.
3.2.2.7 Exhaust air from areas in which there is no airborne radioactive material may be exhausted directly to the roof either with or without continuous sampling, if approved by the Safety Review Commi ttee.
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3.2.4.2 Air Sampling and Analysis 3.2.4.2.1 Continuous air sampling shall be performed in all areas where, in the judgment of the Supervisor, Health Physics there exists l
the potential for exposing personnel to concentrations of airborne radioactive materials in excess of 10% of the app 11-cable MPC.
3.2.4.2.2 Air sampling filters shall be changed. daily in areas where sample evaluations indicate concentrations of airborne radio-active materials in excess of 10% of the applicable MPC.
3.2.4.2.3 Air sampling filters shall be changed weekly in areas where sample evaluations indicate concentrations of airborne radio-active materials less than or equal to 10% of the applicable MPC.
3.2.4.2.4 Preliminary evaluation of air sample filters shall be performed within the next working day following their removal. Final evaluation of air sampling filters shall be performed within 7 working days following their removal.
3.2.4.2.5 An investigation by a Health Physicist shall be performed into l
the cause of unexpected air sampling results that indicate air-borne activity at levels between 10% and 25% of the applicable MPC. The Health Physicist shall assign responsibility for l
completion of any actions that may be indicated by the investi-gation.
3.2.4.2.6 An investigation by the Supervisor, Health Physics shall be l
performed into the cause of unexpected air sampling results that indicate airborne activity at levels exceeding 25% of the appli-cable MPC. The Supervisor, Health Physics shall be responsible j
for specifying corrective actions and assuring that the specified actions are taken.
3.2.4.2.7 If fixed air samplers are used to determine concentrations of airborne radioactivity in the worker's breathing zone, the representativeness of the samplers shall be determined at least once every 12-months.
3.2.4.3 Bioassay 3.2.4.3.1 Uranium Bioassay Program May, 1989 License No SNM-778 Docket No.70-824 Date 5
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dose, the worker shall be restricted from further exposure until the Super-visor, Health Physics l
authorizes the lifting of the restriction.
- d. In vivo
< 30 ug None U-235
- e. In vivo 30-120 ug
- 1. Determine if area surveys U-235 support the analysis results.
- 2. If #1 is positive, investi-gate and correct as needed.
- f. In vivo
> 120 ug
- 1. Resample the individual U-235 within 10 working days.
- 2. Determine if area surveys support the analysis results.
- 3. If #2 is positive, investi-gate the cause and correct as needed.
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- 4. If exposure is confirmed by
- 1, investigate to determine how exposure was incurred and correct it.
If the ex-posure exceeds 120 ug, the worker shall be restricted from further exposure until the Supervisor, Health Physics authorizes the l
lifting of this restriction.
3.2.4.3.2 Plutonium Bioassay Program
- 1. All workers who routinely work in Plutonium handling areas shall be subject to the Plutonium bioassay program. The minimum frequency for urine sampling shall be six months. The minimum frequency for in vivo counting shall be annual.
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ditional bioas::ays shall be performed when, in the judgment of the Supervisor, Health Physics conditions during a job l
and/or other data (air samples, floor smears or clothing con-tamination) indicate an internal exposure may have occurred.
- 2. The following are the action criteria for the routine Plu-tonium bioassay program:
Action Analysis Level Action to be Taken
- a. Urinalysis
< 0.2 dpm/L None
- b. Urinalysis
> 0.2 dpm/L
- 1. Resample the individual within 5 working days.
- 2. The Supervisor, Health Physics shall consider the I
need for worker restriction to prevent further exposure until the diagnostic evalu-ation is complete. Only the Supervisor, Health Physics l
may lift any work restriction once it is imposed.
i
- 3. Determine if area surveys support the analysis results.
- 4. If #3 is positive, investi-gate the cause and correct.
- 5. If the exposure is confirmed by _ #1 investigate to de-termine how exposure was incurred and correct it.
If the exposure exceeds 50% of the maximum permissible annual dose, the worker shall be restricted from further exposure until the Supervisor, Health Physics l
authorizes the lifting of this restriction.
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- c. In vivo.
< 1.6E-8 Ci None Pu-239 2
- d. In vivo
> 1.6E-8 C1
- 1. Restrict the worker from Fu-239 further exposure.
- 2. Resample the individual within 10 working days.
l
- 3. Determine if area surveys support the analysis results.
- 4. If #3 is positive, investi-gate the cause and correct as needed.
5.-If exposure is confirmed by
- 2, the Supervisor, Health Physics shall determine the l
organ dose.
If the confirmed exposure exceeds 50% of the maximum per-missible annual - dose, the worker shall be restricted from further. exposures until the Supervisor, Health Physics authorizes the l
lifting of this restriction.
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- 6. The restriction in #1 may be lif ted by the Supervisor, Health Physics if the l
results of the analysis per-formed under #2 fails to confirm the analysis.
3.2.4.3.3 Fission Product Bioassay Program
- 1. The fission product bioassay program sampling frequency shall comply with Regulatory Guide 8.26, September,1980.
- 2. Additional bioassays shall be performed when in the opinion of the Supervisor, Health Physics, conditions during the job l
were such that significant internal exposure may have May, 1989 i
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i occurred. The following are action criteria for additional bioassays.
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1 Action f
Analysis Level Action to be Taken i
In vivo
>10% MP0B Remeasure subject to determine effective half life of the contami-nant and plot decay curves.
Follow-up. program will continue until the contamination present is l
<5% MP0B or the effective half life has been determined.
Estimation >10% MP08 Submit in vitro sample for analysis from nasal within 5 working days.
i smears or air sample In vitro
>5% MP08 Resample excreta to confirm presence of contamination and to establish rate of elimination.
Perform isotopic analysis if >10%
of MP08 is a possibility.
In vitro
>10% MP08 In vivo measurement to be made as soon as practicable.
- 3. The Supervisor, Health Physics shall be responsible for l
evaluations to determine the location and amount of depo-sition; to provide data necessary for estimating internal dose rates, retention functions, and dose commitments; and to determine if work restrictions or referrals for therapeutic treatment are required for any case where a result indicating a greater than 10%/MP08 deposition of a radionuclides is verified.
3.2.4.4 Protective Clothing 3.2.4.4.1 The use of protective clothing shall be specified in Area Operating Procedures and Radiation Work Permits.
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3.2.4.4.2 Protective clothing may also be specified by the Health Physics Group.
In the event of conflicts between the Area Operating
)
Procedure, Radiation Work Permit, and the Health Physics Group.
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the decision of the latter shall prevail.
3.2.4.5 Respiratory Protection 3.2.4.5.1 The Respiratory Protection Program shall be conducted in ac-cordance with 10 CFR 20.103, and shall be a responsibility of the Health Physics Group.
I 3.2.4.5.2 The Respiratory Protection Program shall be implemented through j
written and approved procedures.
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'3.2.4.6 Surface Contamination Monitoring 3.2.4.6.1 The Health Physics Group shall perform smear surveys in the l
below listed areas at the indicated minimum frequencies:
Action Level Area Frequenc.y (dpm/100cm2)_
<---------------------------ALPHA------------------------->
i Unirradiated, unencapsulated Weekly 5000 fuel handling areas Building B Counting Lab.
Monthly 200 Hot Cell Oper. Area Monthly 200 Scanning Electron Monthly 200 Microscopy Lab.
Exit portals from Biweekly 200 controlled areas i
<-----------------------BETA + GAMMA---------------------->
Building B Counting Lab.
Monthly 2000 Scanning Electron Monthly 2000 Microscopy Lab.
Hot Cell Operations Area Bimonthly 2000 License No SNM-778 Docket No. 70424 Date May, 1989 5
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- Cask Handling Area Bimonthly 22000 Radiochemistry Lab.
Bimonthly 22000 Exit portals from Biweekly 2000 controlled areas 3.2.4.6.2 Large area smears are used to survey many square meters of surface area. To determine if these smears indicate that an action level has been exceeded, the assumed area covered shall not exceed 1-square meter.
3.2.4.6.3 Daily surveys shall be performed in snack bars and vending machine areas located within the restricted area and in the cafe teria.
Weekly surveys shall be performed in snack bars and vending machine areas in the unrestricted areas on site.
If contamination is detected in any of these areas, corrective action shall be taken at once.
3.2.4.7 Decontamination 3.2.4.7.1 The Health Physics Group shell determine and direct the action j
to be taken to protect personnel and reduce the levels of contamination below those specified in Section 3.2.4.6.
3.2.4.7.2 Decontamination to reduce levels of contamination shall begin within 24-hours of the discovering survey..If the survey is made just prior to the beginning of a holiday or weekend, the contamination shall be marked and labeled, and decontamination shall commence during the first regular workday after the survey.
3.2.4.7.3 Fixed contamination that, in the opinion of the Supervisor, Health Physics does not substantially contribute to a worker's l
exposure, shall be posted and its location and radiation level recorded and its removal shall be scheduled as soon as practicable.
3.2.4.7.4 Fixed contamination that, in the opinion of the Supervisor, Health Physics may substantially contribute to workers' exposure l
shall be posted and removed as soon as practicable.
3.2.4.8 Emergency Evacuation 3.2.4.8.1 Refer to Radiological Contingency Plan, required by Order dated February 11, 1981, as amended.
3.2.4.9 Personnel Monitoring l
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4.0 NUCLEAR CRITICALITY SAFETY l
4.1 SPECIAL ADMINISTRATIVE REQUIREMENTS 4.1.1 Double Contingency Policy - The Double Contingency Policy as de-l 1
fined in the American National Standard ANSI /ANS-8.1-1983 shall be i
followed in establishing the basis for nuclear criticality safety j
L of all operations.
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4.1.2 Structural Integrity - Where structural integrity.is necessary to provide assurance for nuclear criticality safety, the design and construction of those structures will be evaluated with due regard to load capacity and foreseeable abnormal loads, accidents, and j
deterioration. The Manager, Facilities shall be responsible for determining the structural integrity of equipment when it is necessary to provide assurance of nuclear criticality safety.
4.1.3 Nuclear Criticality Safety Evaluation - All modifications or additions or both to any operation, system or equipment must be approved by the Licensing & Compliance Officer.
It is the responsi-4 bility of the Licensing & Compliance Officer, in consultation with the Nuclear Criticality Safety Officer, to determine whether or not a nuclear criticality safety evaluation is required for.the proposed modification or addition. The Nuclear Criticality Safety Officer or a person designated by him shall provide any required evaluations, including calculational support. Nuclear criticality safety evaluations shall be reviewed by a second individual, either the Nuclear Criticality Safety Officer or by a person with the same minimum qualifications required for the Nuclear Criticality Safety Officer.
4.1.4 Posting - Each unit shall be posted with the limits of SNM per-mitted in the unit. The Licensing & Compliance Officer shall be l
responsible for approving the posting of nuclear criticality' safety limits.
4.1.5 Labeling - Each container containing greater than 0.5 grams of SNM shall be labeled to show the amount of element, the percent enrichment, when applicable, and the amount of fissile isotope.
This condition does not apply to irradiated SNM.
1 4.1.6 Compliance ~ Compliance with the nuclear criticality safety require-ments shall be in accordance with written area operating procedures, reviewed and approved by the Licensing & Compliance Officer, the l
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l-Supervisor, Health Physics, the Nuclear Criticality Safety Officer, l
and the SRC. Area operating procedures shall include all the-controls and limits significant to the nuclear criticality safety I
of the operation. In addition, the Nuclear Criticality Safety j
Officer shall perform a quarterly audit for compliance with nuclear criticality safety requirements and verifies that process conditions have not been altered that may affect nuclear criticality safety.
J The results of the audit shall be documented and submitted to the j
Manager, SS.
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4.2 TECHNICAL REQUIREMENTS i
4.2.1 Nuclear Isolation - When nuclear isolation is required (the potential neutronic interaction between units is negitgtble) the unit or units isolated shall be separated from all other SNM by one of the following or equivalent conditions:
1.
Twelve inches of water.
3 i
2.
Twelve inches of concrete with density of at least 140 lb/ft when the unit (s) being nuclearly isolated are one of the units permitted by this license. (i.e., a mass limit specified in Section 4.2.2.2 or an authorized PWR or BWR fuel assembly or portion thereof, pursuant to Section 4.2.2.7.1) provided that the unit or units cannot be representable as a slab which interacts with other SNM primarily through its major face.
3.
The edge-to-edge separation of 12-feet, or the greatest distance across an orthographic projection of either accumulation on a plane perpendicular to a line joining their centers, whichever is larger.
4.2.2 Building B 4.2.2.1 General - Buf1 ding B shall be limited to 40 units, excluding the hot cells, underwater storage, and the examination of power reactor fuel assemblies. Each unit shall be separated from adjacent units by at least 8-inches edge-to-edge and 24-inches center-to-center.
4.2.2.2 Unit Limits - Each unit shall be limited to one of the following:
4.2.2.2.1 Mass limits for mixtures of plutonium and U-235 License No SNM-778 Docket No.70-824 Date May, 1989 i
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Amendment No.
Revision No.
Babcock &Wilcox a McDermott company l
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i Pu (wt%)
Limit (total grams fissile)
{
l 0
350 l
I to 20 313 20 to 40 283 40 to 60 258 60 to 80 237 80
'.o 100 220 4.2.2.2.2 Mass Limits for Low Enriched Uranium - 850 grams of U-235 as f
contained in uranium enriched in the isotope U-235 to and including 4 wt%.
1.
Whenever uranium enriched to 4 wt% U-235 is being processed under the 850 gram limit, no unit shall be permitted to have fissile material at an enrichment greater than 4 wt% within that laboratory, room, or work area.
- 2. Whenever an 850 gram, enriched controlled unit is in use in the building, the Licensing & Compliance Officer must l
approve all transfers involving materials with enrichments greater than 4 wt% within the building.
4.2.2.3 Unit Limits - Each unit shall be limited to the values specified in Section 4.2.2.2 of this Part.
4.2.2.4 Hot Cell - The hot cells, except for examination of power reactor fuel assemblies, shall be limited to the following units:
1.
Three units in hot cell no.1, separated by at least 12-inches edge-to-edge.
2.
One unit in each of the other hot cells.
4.2.2.5 Underwater Storage (Transfer Canal & Storage Pool) - SNM in storage under water in the Transfer Canal & Storage Pool shall be in racks or containers limited to the values specified in 4.2.2.2, excluding power reactor fuel assemblies, and separated by 12-inches edge-to-edge.
4.2.2.6 Storage Tubes - SNM in storage tubes shall be limited to the values specified in 4.2.2.2 for each tube.
Storage tubes shall be spaced a minimum of 17-inches center-to-center, are approximately 5-inches in diameter, and totally immersed in concrete.
License No SNM 778 Docket No.70-824 Date May, 1989 1
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II 4-3 Amendment No.
Revision No.
Pm Babcock &Wilcox a McDermott company
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5.0 ENVIRONMENTAL PROTECTION 5.1 EFFLUENT CONTROL SYSTEM l
5.1.1 Responsibility - The Supervisor, Health Physics is responsible for l
the Effluent Control System.
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l 5.1.2 Solid Waste - Solid radioactive waste, including solidified liquid 1
wastes, shall be sent off site to a licensed disposal facility.
L 5.1.3 Liquid Waste - Low-level, liquid radioactive waste is discharged i
from process areas to the Liquid Waste Disposal Facility. This facility is comprised of several tanks where the waste is accumu-lated for eventual transfer to the B & W Naval Nuclear Fuel Division (NNFD) for ultimate release to the James River.
5.1.3.1 Prior to release to NNFD the contents of a tank shall be mixed and sampled.
5.1.3.2. The contents of liquid waste tanks shall not be released to the i
NNFD unless the concentration of radioactivity is less than 25% of the MPC values of Table I, Col. 2, of 10 CFR 20, Appendix B.
The limiting values 'n water shall be determined in accordance with the note at the end of Appendix B,10 CFR 20.
5.1.3.3 Process liquid wastes may be collected and stored indoors. These wastes may be solidified and handled as dry waste.
5.1.3.4 Storage tanks in the Liquid Waste Disposal Facility shall be inspected visually upon each tank voiding or annually, whichever is sooner, to assure that there is no unsafe accumulation of Special Nuclear Material.
Storage tanks that have not been used during a year will not be inspected.
5.1.3. 5 Samples of liquid waste are grab sampled. A small portion of the sample is pipetted into a planchet and brought to dryness. This planchet is counted on a low background counter, either low Beta or Wide Beta, and the waste activity concentration is calculated.
The samples are counted for gross alpha and beta. Waste tanks that may receive Sr-90 waste will have their samples analyzed for Sr-90.
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License No SNM 778 Docket No.70-824 Date May, 1989 5
11 5-1 Amendment No.
Revision No.
Pap Babcock &Wilcox a McDermott company
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