ML20246B546

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Revised Windsor Fuel Fabrication Facility Request for Amend to License SNM-1067,changing Facility Organization
ML20246B546
Person / Time
Site: 07001100
Issue date: 06/30/1989
From:
ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY
To:
Shared Package
ML20246B539 List:
References
NUDOCS 8907100006
Download: ML20246B546 (81)


Text

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Dockst No.'

70-1100

~6 Liconne No.-SNM-1067-e-

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. ENCLOSURE II COMBUSTION ENGINEERING, INC.

WINDSOR FUEL FABRICATION FACILITY REQUEST FOR LICENSE AMENDMENT PROPOSED LICENSE APPLICATION PAGES

'l JUNE,- 1989 1

'8907100006 890623

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PDR ADOCK 07001100 C

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.i TABLE OF CONTENTS PART I LICENSE CONDITIONS SECTION~

1.0 Standard conditions and Special Authorizations 1.1' Name 1.2 Location 1.3-License Number 1.4

-Possession Limits and Location 1.5 Section Deleted 1.6 Authorized Activities 1.7 Exemptions and Special Authorizations 2.0 Organization and Administration 1

2.1 Organization Responsibilities and Authority for Key.

Positions Important to Safety 2.2 Personnel Education and Experience Requirements for Key Positions Important to Safety 2.3 Facility Review Group 2.4 Approval-Authority for Personnel Selection 2.5 Training 2.6 Operating Procedures 2.7 Internal Inspections and Audits

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. Investigations and Reporting of Off-Normal Occurrences 2.9 Records 3.0 Radiation Protection 1.1 Special Administrative Requirements 3.2-fechnical Requirements 4.0 Nuclear Criticality Safety t

L 4.1 Administrative Requirements 4.2 Technical Requirements 4.3 Specific Criticality Safety Criteria 5.0 Environment Protection 5.1 Effluent Control Monitoring System Commitments 5.2 Environmental Monitoring Program 6.0 industrial Safety 7.0 Decommissioning 8.0 Radiological Contingency Plan 9.0 Fundamental' Nuclear Material Control Plan (FNMC)

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Docket No. 70-1100 Rev. 04 Date: 06/23/89 License No. SNM-1067 Page 1 i

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TABLE OF CONTENTS (continued)

PART II

. SAFETY DEMONSTRATION SECTION l' 0 Overview of Operations 1.1 Corporate Information and Financial Qualifications 1.2 Operating Objectives and Process-Summary 1.3 Site Description 1.4 Locations.of Buildings On-Site 1.5 History. of License 2.0 Facility' Description

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2.1

' Plant Layout 2.2 Utilities 2.3 Heating, Ventilation, and Air Conditioning (HVAC) 2.4 Waste Disposal 2.5 Chemical Storage -

2.6 Security i

2.7 Fire Protection 3.0 Organization and Personnel 3.1 Functions of Key Personnel Important to Safety 3.2 Resumes of Key. Personnel Important to Safety 4.0 Radiation. Protection Procedures and Equipment 4.1 Procedures 4.2 Written Procedures 4.3 Posting and Labeling l

4,4' Personnel. Monitoring 4.5 Surveys 4.6 Reports and Records 4.7 Instruments

-4.8 Protective Clothing 4.9 Dosimetry 5.0 Occupational Radiation Exoosures 5.1 External Radiation Exposures 5.2 Internal Radiation Exposures 5.3 General _ Air Sampling Results 6.0 Environmental Safety 6.1 Liquid Effluent Discharges 6.2 Airborne Radioactivity Discharge Docket No. 70-1100 Rev. 03 Date: 06/23/89 License No. SNM-1067 Page 2 i

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'2.0. Organization'and~ Administration The President,. Nuclear. Power Businesses has.the ultimate responsibility.for ensuring that' corporate operations related to the Nuclear Power Businesses' Division are conducted safely and in full compliance with applicable Federal, State and local regulations, licenses and certificates of compliance.

The President has delegated the L

responsibility for nuclear fuel ~ manufacturing and product' I

development activities to the Vice President, Nuclear. Fuel.

2.1 Organization Responsibilities and Authority for Key L

Positions Important to Safety 2.1.1 Vice President and General Manaaer The Vice President and General Manager, Nuclear Fuel Manufacturing reports to the Vice President, Nuclear Fuel.

He or she has the overal1' responsibility for the safe operation of. Combustion Engineering's nuclear fuel manufacturing facilities located in Hematite,. Missouri (SNM-33) and Windsor, Connecticut (SNM-1067).

His or her responsibilities encompass the following functions:

operations, accountability, security, training, criticality, -

radiological and industrial safety, environmental protection, transportation, materials handling and storage, licensing, process and equipment engineering and maintenance.

These responsibilities are administered through the professional staff of both fuel manufacturing facilities and the technical staff of Combustion Engineering's Nuclear Power Businesses Division.

The Vice President and General Manager also acts in the capacity of 4

the~ Plant Manager for the Windsor Nuclear Fuel Manufacturing (SNM-1067) activities described in this application.

2.1.2 Director. Product Develcoment The Director, Product Development reports to the Vice President, Nuclear Fuel and is responsible for the f

management of nuclear fuel product development laboratory 1

activities (SNM-1067).

This responsibility encompasses the 1

following_ functions: operations, accountability, security,

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training, criticality, radiological and industrial safety, l

environmental protection, materials handling and storage, 1

and licensing.

The Director is supported in executing these i

responsibilities by a professional staff reporting directly to him, by members of the Windsor Nuclear Fuel Manufacturing facility staff and by other professionals within the Nuclear Power Businesses Division, as.necessary.

Docket No. 70-1100 Rev. 04 Date: 06/23/89 License No. SNM-1067 Page: I.2-1

l 2.1.3 Procram Manaaer. Radiological and Industrial Safety l

The Program Manager, Radiological and Industrial Safety reports tx) the Vice President and General Manager and is

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responsible for defining programs and standards related to

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radiological, criticality and industrial safety, i,

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environmental protection and emergency planning for both the fuel manufacturing facility and the product development laboratories.

The programs and standards address safety i

criteria, monitoring, procedures and training materials.

necessary to ensure the protection of employees, the'public and the environment.

The Program Manager, Radiological and Industrial Safety has no production responsibility.

He or she has the authority to halt any operation in the fuel manufacturing facility or product development laboratories that he or she believes presents a safety hazard to employees, the public or the environment.

If an operation is halted for a safety reason (s) it shall not be restarted without the concurrence of the Program Manager or his/her designee.

2.1.4 Senior Criticality specialist i

The Senior Criticality Specialist may be a member of the technical staff of the Nuclear Fuel organization or an outside consultant who reports in a functional, manner to the Program Manager, Radiological and Industrial Safety.

He or she provides assistance to the Program Manager in executing those aspects of the Program Manager's function which relate to criticality safety.

The Senior Criticality Specialist also serves as the second reviewer for criticality evaluations performed by the Nuclear Criticality Specialist (first reviewer).

The Senior criticality Specialist has no production responsibilities.

The Senior criticality Specialist has the authority to halt any operation in the fuel manufacturing facility or product development laboratories that he or she believes to represent an unsafe criticality condition.

If an operation is halted for a criticality safety reason (s) it shall not be restarted without the concurrence of the Program Manager, Radiological and Industrial Safety or his/her designee.

2.1.5 Manpaer, Radiological Protection and Industrial Safety The Manager, Radiological Protection and Industrial Safety

' reports.to:the Vice President and' General Manager.

The function of the Manager is to provide information, advice, and assistance to the operating and engineering Line l

Managers to ensure personnel and environmental protection Docket No. 70-1100 Rev. 04 Date: 06/23/89 License No. SNM-1067 Page: I.2-2

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measures are' adequate and to keep records documenting safety related facility operations.

He or she has the Responsibility to implement the programs defined by the

. Program Manager, Radiological and Industrial Safety in the areas of radiological, criticality and industrial safety, environmental protection and emergency planning.

As tJart of L

this responsibility, he or she assures that ALARA is.

considered in the implementation process.

The Manager reviews and approves safety related operating procedures.

These responsibilities are executed for both the fuel' manufacturing' facility and the product development laboratories'by working with the cognizant Line Managvrs to ensure safety limits and operating procedures are acceptable.

The Manager, Radiological Protection and Industrial Safety has no production responsibility.

If the Manager believes any operation in the fuel manufacturing facility or product development laboratories to be unsafe,.he or she has the authority to halt that operation.

If an operation is halted for a safety reason (s) it shall not be restarted without the concurrence of-the Program Manager, Radiological and Industrial Safety or his/her designee.

2.3.6 Nuclear Criticality Soecialist The Nuclear Criticality Specialist is a member of the technical staff of the Nuclear Fuel organization and reports in a functional manner to the Manager, Radiological i

Protection and Industrial Safety.

The Nuclear Criticality Specialist works with the cognizant Line Managers to ensure that nuclear fuel manufacturing facility or product development laboratory operations (processes, procedures and equipment) or changes thereto are acceptable with regard to l

nuclear criticality safety.

He or she executes'this responsibility by advising the cognizant Line Managers regarding criticality safety practices, arranges for analyses or reviews and approves changes to processes,

. procedures or equipment related to criticality safety.

The Nuclear Criticality Specialist has no production responsibilities.

The Nuclear Criticality Specialist has the authority to halt any operation in the fuel manufacturing facility or product development laboratories that he or she believes to represent an unsafe criticality condition.

If an operation is halted for a criticality safety reason (s) it shall not be restarted without the concurrence of the Program Manager, Radiological and

, Industrial Safety or his/her designee.

J Docket No. 70-1100 Rev. 06 Date: 06/23/89 License No. SNM-1067 Page: I.2-3

1 2.1.7 Nuclear Criticality Analyst

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The Nuclear Criticality Analyst performs the detailed numerical criticality calculations as prescribed by the Nuclear Criticality Specialist to verify the acceptability of fuel manufacturing facility or product development laboratory processes or equipment.

2.1.8 Sunervisor, Radigloaical Protection and Industrial Safety The Supervisor, Radiological Protection and Industrial Safety reports to the Manager, Radiological Protection and Industrial Safety.

He or she assists the Manager in carrying out his/her duties and is responsible for surveillance of nuclear fuel manufacturing and product development activities related to radiological, criticality and industrial safety, environmental protection and emergency planning.

This surveillance ensures that operations are being conducted in accordance with Federal, State and local regulations, the conditions set down in this application and certificates of compliance, as applicable.

The Supervisor also issues Radiation Work Permits for activities that fall outside the scope of safety related operating procedures or which require enhanced radiological protection measures.

The Supervisor, Radiological Protection and Industrial Safety has no production responsibility.

If the Supervisor believes any operation in the fuel manufacturing facility or product development laboratories to be outside specified limits or unsafe, he or she has the authority to halt that operation.

.f an operation is halted for a safety reason (s) it shall not be restarted without the concurrence of the Program Manager, Radiological and Industrial Safety or his/her designee.

2.1.9 Industrial Safety Specialist The Industrial Safety Specialist reports to the Manager of Radiolo'gical Protection and Industrial Safety.

He or she acts as a. consultant to the Manager on matters relating to industrial safety and environmental protection at the fuel manufacturing facility and product development laboratories.

He or she also advises the Radiation Protection and Industrial Safety Technicians in the proper methods of monitoring industrial safety and environmental protection compliance..The Industrial Safety Specialist has no production responsibility.

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t 2.1.10 Radiological Protection and Industrial Safety Technicians 1

The Radiological Protection and Industrial Safety I

Technicians report to the Supervisor, Radiological i

Protection and Industrial Safety.

The Technicians are responsible'for the day-to-day monitoring of operations at the fuel manufacturing facility and the product development laboratories.

Monitoring is accomplished through the collection of data which allows the effectiveness of j

radiological, criticality and industrial safety,

'j environmental protection and emergency planning programs to be assessed.

Technicians also monitor the proper implementation of Radiation Work Permits issued by the Supervisor of Radiological Protection and Industrial Safety.

The Radiological Protection and Industrial Safety Technicians have no production responsibilities.

i 2.1.11 Manaaer. Production The Manager of Production reports to the Vice President and General Manager.

He or she is responsible for the planning,"

4 scheduling and control of the production process for the fabrication of fuel assemblies and their subsequent shipment to meet customer needs.

Facility process / equipment operators are under the cognizance of the Production Manager.

He or she is responsible for ensuring the proper training of personnel and that procedures and safety limits are followed.

The Production Manager also oversees material and equipment purchasing, receiving, warehousing and inventory control.

2.1.12 Manacer. Manufacturing EncipierinQ The Manager of Manufacturing Engireerlag reports to the Vice President and General Manager.

Engineering activities related to facility equipment, pcocess, methods and constru,ction, whether new or a nodific6 tion are directed by the Manager of Manufacturing Engineering.

As part of this responsibility he or she assures that ALARA is considered as part of the design process.

The Mar,ager is also responsible for equipment maintenance at the fual manufacturing facility.

Through the appropriate engineering design, he or she ensures that radiological, criticality and industrial safety as well as environmental protection requirements are satisfied.

He or she is also respons!.ble for the

. preparation of procedures and training materials concerning facility equipment and the manufacturing process.

I Docket No. 70-1100

'Rev. 04 Date: 06/23/89 License No. SNM-1067 Page: ** 2-5

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2.1.13 Emercency Director

.i The Emergency Director reports to the Vice President and General Manager.

In this capacity he or she coordinates the l

actions of the emergency response team members (for both on-and off-site support).

The Emergency Director shall remain in control of emergency operations until the situation is stabilized or terminated depending on the severity of.the incident.

The Emergency Director has authority to direct recovery operations for any emergency condition.which may I

arise in the Nuclear Fuel Manufacturing facility or Product Development laboratories.

The Emergency Director may designate qualified. alternates.

2.2 Personnel Education and Exoerience Requirements for Key Positions Imoortant to Safety J

2.2.1 Vice President and General Manager l

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The minimum qualifications for 6his position ~are a bachelor's degree in one of the sciences or engineering, with ten (10) years experience, including at least five (5) years in management positions in the nuclear industry.

2.2.2-Director, Product Development The minimum qualifications for this position are a bachelor's degree in one of the sciences or engineering, with ten (10) years experience, including at least five (5) years in management positions relating to product development activities in the nuclear industry.

2.2.3 Procram Manacer. Radiological and Industrial Safety The minimum qualifications for this position are a bachelor's degree in one of the sciences or engineering, with five (5) years experience in the nuclear industry.

Three (3) of the five (5) years shall be in at least one of safety related areas within his or her cognizance.

2.2.4. Senior criticality Scecialist The m!.nimum qualifications for this position shall be a bachelor's degree in one of the sciences or engineering, with two (2) years experience performing criticality evaluations.

Docket No. 70-1100 Rev. 06 Date: 06/23/89 License No. SNM-1067 Page: I.2-6

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i 2.2.5 Manacer. Radiological Protection 1and Industrial Safety The minimum qualifications for this position are a

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bachelor's degree in one of the sciences or engineering, i

with five. (5) years experience in the nuclear industry.

Two (2) of the five (5) years shall be in at least one of the safety related areas within his or her cognizance.

In the absence of a technical degree, the alternate qualifications are a high school diploma and ten (10) years experience in the nuclear industry.

Two (2) of the ten (10) years shall have been in management positions with another four (4) of I

the ten (10) years experience in at least one of the safety related areas within his or her cognizance.

Two (2) of the four (4) years of safety related experience shall have been in'a senior position.

2.2.6 Nuclear Criticality Soecialist The minimum qualifications for this position shall be a bachelor's degree in one of the sciences or engineering, with two (2) years experience performing criticality evaluations.

2.2.7 Nuclear Criticality Analyst The minimum qualifications for this position shall be a bachelor's degree in one of the sciences or engineering, with one (1) year of experience performing criticality analyses.

An analyst without the one year experience may perform analyses under the supervision of a qualified Nuclear Criticality Analyst as a means of obtaining the necessary experience.

2.2.8 Suoervisor. Radiological Protection and Industrial E3fety The minimum qualifications for this position are a high school diploma with five (5) years direct experience in at lesst ope of the safety related areas within his or her cognizance.

'Three (3) of the five (5) years of safety related experience shall have been in a senior position.

2.2.9 Industrial Safety Specialist The minimum qualifications for this position shall be an associate's degree in industrial safety, with two (2) years of related experience in. industrial safety and/or environmental protection, f

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l Docket No. 70-1100 Rev. 06 Date: 06/23/89 i

License No. SNM-1067 l

Page: I.2-7

I 2.2.10 Radiological Protection and Industrial Safety l

Technicians The. minimum qualifications for this position are a high school diploma with one'(1) year of experience in at least one of the safety related areas within his or her cognizance.

Technicians shall also complete a facility specific training program (s) in safety related areas within their area (s) of cognizance.

2.2.11 Manacer. Production The minimum qualifications for this position are a high school diploma with five (5) years experience in the nuclear industry.

At least three (3) years of experience shall be in production coordination positions.

2.2.12 Manacer Manufacturing Encineerina The minimum qualifications for this position 'are a bachelor's degree in one of the sciences or engineering, with three (3) years experience in the nuclear industry.

2.2.13 Emeraency Director The. Emergency Director shall be a member of the Nuclear Fuel management team and shall be familar with the Nuclear Fuel Manufacturing and Product Development processes and facilities.

He or she shall be familar with the emergency plan and the implementing procedures for the Nuclear Fuel Manufacturing facility and Product Development laboratories.

Alternate Emergency Director designees shall be selected from the Nuclear Fuel Manufacturing or Product Development supervisory levels or above.

Alternates shall also be familar with the emergency plan and the implementing procedures for the Nuclear Fuel Manufacturing facility and Product Development laboratories.

I 2.3 Facility Review Groun l

The Nuclear Fuel Manufacturing facility and Product d

Development laboratory operations are monitored by a

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Facility Review Group.

The Facility Review Group reports to the Vice President and General Manager, Nuclear Fuel Manufacturing and is responsible for oversight of safety j

related operations.

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l Docket No. 70-1100 Rev. 06 Date: 06/23/8.9 License No. SNM-1067 Page: Ie2-8

o Tne Facility Review Group is composed of senior personnel from the technical staff of Combustion Engineering's Nuclear Power Businesses organization that have at least five (5) years experience in the nuclear industry.

The overall function of the Facility Review Group is to review operations on a regular basis.

In order to execute this responsibility, the Group will meet at least quarterly to review operations and more often if deemed necessary by the Chairperson.

As a minimum, the Group shall perform the following specific functions:

- Review environmental protection practices and trends.

- Review radiological safety practices and trends.

- Review criticality safety practices and trends.

- Review industrial safety practicos and trends.

- Review the adequacy of emergency planning tests and drills.

- Review effectiveness of-the ALARA program.

- Review internal inspection and audit reports.

- Review abnormal occurrences and accidents, including -

recommendations to prevent recurrence.

- Review physical facility changes in the Pellet Shop and changes to operations involving radiation and/or nuclear criticality safety.

The Chairperson of the Facility Review Group or the Vice President and General Manager may request the Group to examine other areas deemed appropriate.

The Group may establish subcommittees and/or use consultants, as necessary, to carry out its various responsibilities.

Findings, however, shall be those of the Group ar4 not just that of the subcommittees or consultants.

If the*.e are dissenting opinions, they shall be incorporated in the Group report.

It is the responsibility of the Line Managers in the fuel manufacturing facility and the Director of Product Development to ensure that deficiencies identified by the Group, in their area of cognizance, are addressed.

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As a minimum, the Group shall also prepare a quarterly report summarizing the facility operations with emphasis on j

compliance with the various safety programs and standards 1

which form the basis for the detailed facility operating procedures and safety limits.

The reports shall also address the effectiveness of the ALARA program.

Findings and recommendations (if any) of the Group shall be reported to the Vice President and General Manager and the Docket No. 70-1100 Rev. 05 Date: 06/23/89 License No. SNM-1067 Page: I.2-9

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Direcfor of Product Development with copies to Line l

Managers, the Vice President, Nuclear Fuel and the President of Nuclear Power Businesses.

Records of the Groups findings shall be retained for a period of three (3) years from the date of issue or until closure of issues is obtained, whichever is later.

1 2.4 Approval Authority for Personnel Selection The Vice President and General Manager, Nuclear Fuel Manufacturing and each of his direct reports, which are in key positions important to safety, shall be approved by the next two (2) levels of management above the-position to be filled.

Other staff positions are filled following the normal administrative practices of Combustion Engineering, Inc.

The Director, Product Development and each of his direct reports, which are in key positions important to safety and are involved in activities within the scope of this application, shall be approved by the next two (2) levels of management above the position to be filled.

Other staff positions are filled following the normal administrative practices of Combustion Engineering, Inc.

Chairmanship of, and membership on, the Facility Review Group shall be by appointment of the Vice President and General Manager, Nuclear Fuel Manufacturing.

2.5 Trainina In addition to on-the-job training and training in special operational skills, employees and visitors to the Windsor Nuclear Fuel Manufacturing facility or the Product Development laboratories participate in formal (classroom) training programs to ensure a basic understanding of facility operations and safety requirements.

The degree of training an individual receives is commensurate with the extent to which he or she will require unescorted access to these facilities or will come into contact with nuclear materials.or other hazardous materials or operations that are a part of the manufacturing process or product development activities.

Escorted visitors do not require any training.

Guidelines shall be established which denote the various types of training conducted and classifications for employees and visitors with respect to what training / refresher training is required.

All safety related training shall'be conducted by an individual well versed with the specific training subject matter.

Docket No. 70-1100

'Rev. 05 Date: 06/23/89 License No. SNM-1067 Page: I.2-10

i 2.5.1 Initial Trainina Employees and visitors (as necessary) working in the Windsor Nuclear Fuel Manufacturing facility or the Product Development laboratories shall participate in a General Employee Training program.

This program shall include information necessary for each individual to understand the nature of the work done at these facilities and to perform his or her duties in a safe manner.

As a minimum, the General Employee Training program shall cover the following subject areas; 1) Organization and Administration, 2)

Facility Description, 3) Quality Control, 4) Security, 5)

Industrial Safety, 6) Radiation Safety, 7) Criticality Safety, and 8) Emergency Preparedness.

The General Employee Training program for Nuclear Fuel Manufacturing and Product Development shall be appropriate to the activities conducted in those respective facilities.

Employees and visitors (as necessary), working in the Nuclear Fuel Manufacturing facility Pellet Shop or whose job involves working with unclad nuclear material shall also participate in a Radiation Worker Training Program.

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program shall include information necessary for each individual to understand the nature of the work performed in the Pellet Shop and to perform his or her duties in a safe manner, especially as relates to the handling of unclad nuclear materials.

As a minimum, the Radiation Worker Training program shall provide a higher level of detail concerning radiological and criticality safety than the GET program which is appropriate to facility operations.

Employees and visitors (as necessary) working in any of the Product Development laboratories shall also participate in a Radiation Worker Training Program.

This program shall include information necessary for each individual to understand the nature of the work performed in the Product Development Laboratories and to perform his or her duties in a safe manner, especially as it relates to the handling of unclad nuclear materials.

The training program may be combined with the Pellet Shop Radiation Training Program.

2.5.2 Refresher Trainina Employees and visitors (as necessary) working in the Nuclear Fuel Manufacturing facility Pellet Shop or whose job involves working with unclad nuclear material shall participate in an annual Radiation Worker refresher training program.

The refresher trainint program shall emphasize the key -safety aspects ' of their jobs' and.sha'll include, as a minimum: 1) a module covering significant abnormal occurrences and operational deficiencies identified at the Docket No. 70-1100 Rev. 04 Date: 06/23/89

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License No. SNM-1067 Page: I.2-11

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facility and the corrective actions taken to preclude recurrence, 2) Radiation Safety, and 3) Criticality Safety.

2.5.3 Trainina Records Formal. training sessions shall be documented and competency demonstrated by passing a test to verify training effectiveness.

When changes are made in radiation protection or criticality safety limits, affected individuals shall be informed and instructed in the new material. ~At the discretion of the Manager, Radiological Protection and Industrial Safety and based on the complexity of the new material, formal testing to assess an individuals understanding may be waived.

Training records shall be retained for the duration of an individuals employment at Combustion Engineering or a minimum of two years, whichever is greater.

2.6'Oceratina Procedures Routine Nuclear Fuel Manufacturing facility and Product Development laboratory operations which involve licensed materials shall be conducted in accordance with written procedures.

The preparation of written safety related procedures are the responsibility of the cognizant Line

' Manager and shall be approved by the cognizant Manager, the Manager of Radiological Protection and Industrial Safety and the Nuclear Criticality Specialist.

Written procedures that affect radiation and/or nuclear criticality safety shall include limits and controls which are required for nuclear safety of the subject activity.

Safety related work in the Product Development area is done'under a Radiation Work Permit issued by the' Manager or Supervisor, Radiological Protection and Industrial Safety.

The preparation, review, revision, approval and implementation of safety related operating procedures shall be accc5plished through a document control system.

Safety related' operating procedures shall be reviewed every two years, as.a minimum, by the cognizant Line Manager and the Radiological Protection and Industrial Safety group to assure continued acceptability.

Safety related operating procedures, and changes thereto, shall be retained for a period of six (6) months following procedure revision or termination of the operation involved, whichever.is longer.

Docket No. 70-1100 Rev. 06 Date: 06/23/89 License No. SNM-1067 Page: I.2-12

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l 2.7 Internal Inspections and Audits Inspections are routine reviews to check that operations are being conducted according to approved procedures.

Audits are independent formal examinations made to verify that operations are being conducted according to established criteria.

Audits are more formal and less frequent than inspections.

2.7.1 Inspections The inspection function (assuring that operations are being conducted in compliance with regulatory requirements, license conditions, posted safety limits and safety related written operating procedures) is a normal part of the Radiological Protection and Industrial Safety Technician's job.

Technicians are assigned to all operating shifts.

As such, the inspection function is informally satisfied on an ongoing basis.

On a monthly basis, Technicians shall perform a documented inspection using a prepared checklist to review the conduct of facility operations.

Any time the Technicians find discrepancies, the cognizant Line Manager is informed of the remedial actions to be taken and a written deficiency report is turned over to the Manager, Radiological Protection and Industrial Safety.

The Manager or his/her designee, assures that any necessary corrective actions specified are adequate and that they will be initiated in a timely manner.

The Manager, Radiological Protection and Industrial Safety shall also ensure that quarterly fire safety, hazardous material safety (non-radioactive) and environmental protection inspections are performed by members of his/her staff.

These inspections are also to be conducted with the aid of a prepared checklist.

The Manager shall assure that any necessary corrective actions are initiated in a timely manner.

J Completed inspection checklists shall be signed by the i

Technician performing the inspection and turned over to the Manager', Radiological Protection and Industrial Safety for review.

A copy of the checklist is also provided to the Chairperson of the Facility Review Group.

1 Records of all deficiency reports and inspection checklists shall be retained for a period of at least three (3) years from the date of issue or until closure of all findings is obtained, whichever is later.

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9 2.7.2 Audits Audits are performed by individuals. independent of day-to-day operating' activities at the Nuclear Fuel Manufacturing facility or Product Development laboratories to verify that operations are being conducted according to established criteria.

Audits are conducted in accordance with a written plan.

A report documenting audit results is prepared and distributed to the Vice President and General Manager and the Director Product Development, with copies to Nuclear-Fuel Manufacturing facility Line Managers and the Chairperson of the Facility Review Group.

The Program Manager, Radiological and Industrial Safety shall ensure the conduct of quarterly audits of the Radiation Protection, Criticality Safety, Fire Safety, Hazardous Material (non-radioactive) Safety, and Environmental Protection Programs in use at the Nuclear Fuel Manufacturing facility and Product Development laboratories.

These audits shall be conducted by the Program Manager, members of his/her staff or consultants.

The purpose of the audit is to verify the adequacy of program implementation and that designated limits and controls are being properly followed.

Individual (s) conducting audits in either the areas of radiological or criticality safety shall meet the qualification requirements of the Program Manager, Radiological and Industrial Safety or the Senior Criticality Specialist, respectively.

Records of audit reports shall be retained for a period of three (3) years from the date of issue or until closure of findings is obtained, whichever is later.

2.8 Investigations and Reportina Of Abnormal Occurrences Abnormal occurrences are investigated in accordance with written procedures and are reported to the Vice President l

and General Manager, Nuclear Fuel Manufacturing or the Director, Product Development, as appropriate.

Reports to the Nuclear Regulatory Commission are made in accordance with specific conditions of this application and/or the applicable Federal Regulations.

Regulatory Guide 10.1, Compilation of Reporting Requirements for Persons Subject to NRC Regulations, is used as a guide in identifying applicable reporting requirements.

The level of investigation and the need for corrective action are determined based on the severity of the incident.

The severity of an incident is based on the levels of uranium released and/or the degree of potential for exposure to workers or the public. The Facility Review Group is charged Docket No. 70-1100 Rev. 06 Date: 06/23/89 License No. SNM-1067 Page: I.2-14

with the. responsibility for investigating abnormal occurrences and recommending corrective action (s),

as appropriate.

Records of Facility Review Group investigations of abnormal occurrences are retained for a period of three (3) years after closure of the investigation.

2.9 Records Records pertaining to health and safety, facility modifications, abnormal occurrences, criticality analyses, inspections, audits, instrument calibrations, ALARA findings, employee training and refresher training, personnel exposures, routine radiation and contamination surveys and environmental surveys are retained to demonstrate compliance with the conditions of this application and the applicable Federal, State and-local regulations.

Records are retained for the periods specified in the applicable application sections or the governing regulations, whichever is longer.

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License No. SNM-1067 Page: I.2-15

I 3.0 Radiation Protection 3.1 Special Administrative Requirements 3.1.1 ALARA Commitment It is the policy of Combustion Engineering to conduct its business in a manner which assures that its Nuclear Fuel Manufacturing Facilities and Product Development Laboratories are in compliance with' radiation protection and other applicable regulations, and that the operation of these facilities will not be detrimental to the environment.

In implementing this policy, Combustion Engineering shall assure that radiation exposure to personnel (both in-plant and off-site) is maintained As low As Reasonably Achievable (ALARA).

In providing this assurance, conditions of applicable NRC and state licenses and other regulatory permits or licenses shall be complied with and regard shall be given to applicable NRC regulatory guides and industry standards.

For activities carried out within the scope of this application, responsibility for establishing and ensuring adherence to this policy shall rest with the Vice President and General Manager, Nuclear Fuels Manufacturing and the Director, Product Development.

This policy shall be implemented through appropriate delegations to th'e Program Manager, Radiological and Industrial Safety, the applicable Line Managers, and the Facility Review Group.

3.1.2 Radiation Work Permit Procedures All work with radioactive materials in the Product Development 1:

Laboratories and, all non-routine maintenance or repair operations on equipment involved with handling radioactive material within Docket No. 70-1100 Rev. 06 Date: 06/23/89 License No. SNM-1067 Page 1.3-1 L__________________.-

E',_

9 Nuclear. Fuel Manufacturing including those non-routine maintenance operations in which ventilated containment systems are breached shall be covered by a Radiation Work Permit (RWP).

The RWP shall be requested by the cognizant engineer or supervisor _.

The Manager or Supervisor of Radiological Protection and Industrial Safety,' utilizing historical data and input from the Radiological Protection and Industrial Safety Technicians, shall establish the t

. radiological safety requirements and set individual exposure limits.

The Manager or Supervisor of Radiological Protection and Industrial Safety shall approve all RWP's. The Radiological Protection and Industrial Safety Technicians are responsible for monitoring proper implementation of the RWP's.

RWP's shall be reviewed for their need every 30 days as a minimum.

The Manager or Supervisor of Radiological Protection and Industrial Safety acting on input from the Radiological Protection and Industrial' safety Technicians shall close out all RWP's to assure that the specific worh was completed in a satisfactory manner prior to permitting restart of the related operation.

3.2 Technical Requirements 3.2 1 Access Controls

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All personnel entering the unclad fuel handling areas must do so through the change areas provided for this purpose. As a minimum, the following protective clothing shall be worn:

Coverall or Lab Coat Special shoes or shoe cove.rs Safety glasses Docket No. 70-1100 Rev. 07 Date: 06/23/89 License No. SNM-1067 Page I.3-2

Additional protective clothing which may be required for non-routine operations shall be prescribed'by the applicable RWP both in the Product Development Laboratories and the Nuclear Fuel Manufacturing

. facility.

3.2.2 Personnel Monitorino Requirements All personnel must wash their hands before exiting the contaminated area and, as a minimum, shall monitor their hands, exposed areas of the body and personal clothing with the alpha personnel monitor located at the change line.

The frequency and control levels of monitoring personal clothing and body surfaces shall be as follows:

PERSONAL CLOTHING AND BODY SURFACE ALPHA ACTIVITY CONTROL LEVELS Surface Aloha dom /100cm2 Min. Survey Frecuency Personal Indistinguishable Before leaving contaminated

Clothing, from background area and when contamination Body Surfaces is observed on body (Hair, Face, surfaces.

Hands)

If indicated levels are greater than the control level, the individual shall promptly notify a member of the Radiological Protection and Industrial Safety staff and shall not leave the

-contaminated area until they respond and the situation is resolved.

3.2.3 Ventilation Requirements Nuclear Fuel Manufacturing i

Ventilation in the Nuclear. Fuel Manufacturing facility (Buildirig

  1. 17) is'provided by four separate exhaus't systems as follows:

j Docket No. 70-1100 Rev. 05 Date: 06/23/89 License No. SNM-1067 Page 1.3-3 b

FA-1 Powder Preparation and Pressina - This system has a capacity of 12,100 CFM and incorporates prefilters and a double bank of 12 i

absolute filters, each 99.97% efficient at 0.3 microns.

The air exhaust from this system'which is either returned to the inclad fuel area or released from the plant is sampled 100% of the time and analyzed each day.

FA-2 Furnace H2 Burnoff - This system has a capacity of 1340 CFM and incorporates prefilters and a single bank of 4 absolute filters, each 99.97% efficient at 0.3 microns. The air exhaust from this system is released from the plant and sampled 100% of the time and analyzed each day.

FA-3 Pellet Grindino and Rod Loadina - This system has a capacity of 17,500 CFM and incorporates prefilters and a double bank of 16 absolute filters, each 99.97% efficient at 0.3 microns.

The air exhaust from this system is released from the plant and sampled 100% of the time and analyzed each day.

FA-4 Recycle Powder Are_a - This system has a capacity of 6000 CFM and incorporates prefilters and a double bank of 6 absolute filters, each 99.97% efficient at 0.3 microns. The air exhaust from this system is released from the plant and sampled 100% of the time and analyzed each day.

The capacity of the ventilation systems have been matched to provide a negative pressure differential between the Pellet Processing Facility and all surrounding work areas.

The direction of air flow shall be checked monthly and documented.

If airborne activity res'ults, averaged over a two week period, exceed 25% of the applicable concentration listed in Table II, Column I of 10 CFR 20 Docket No. 70-1100 Rev. 04 Date: 06/23/89 License No. SNM-1067 Page 1.3-4

j "g-o Appendix B for air being discharged-to an unrestricted area (from

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manufacturing or Product Development Operations), an investigation will be conducted and corrective actions taken.

In addition, to assure our releases remain as low as reasonably achievable, a quarterly limit of 18 uti in gross alpha activity of total uranium in plant gaseous effluents shall be maintained.

If the i

radioactivity in plant gaseous effluents exceeds 18 uCi, a report

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which identifies the cause for exceeding the limit and the corrective actions to be taken to reduce. release rates shall be submitted to the NRC within 30 days. Also, if the parameters important to a dose assessment change, a report shall be submitted within 30-days which describes the changes in parameters and includes an estimate of the resultant change in dose commitment.

1 The 18 uCi/qtr limit would result in a lung dose to an individual at the nearest residence of (conservatively) less than 0.10% of the 25 mrem / year standard as specified in 40 CFR 190.

Ventilation system filters and/or prefilters will be changed, l

rotated, or knocked down whenever a pressure drop of 4 inches of water is measured across the combination of the prefilter and first bank of absolute filters. The pressure drop for all 4 systems shall be checked weekly and documented. When the face velocity at a

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ventilated hood drops below 100 fpm, the hood filters or ventilation system filter will be changed, brushed, or knocked down to increase the air flow to 100 fpm minimum or the hood shall not be used to handle radioactive material.

Face velocities will be checked. weekly in the Manufacturing facility and monthly in Product Development.

Docket No. 70-1100 Rev. 05 Date: 06/23/89 License No. SNM-1067 Page 1.3-5

F b

.ii l

.3 4

Any work on filter change involving any of the four fixed air systems in manufacturing shall be performed under an RWP.

Following all filter changes or other movement of filters, both.the Supervisor and a Technician from the Radiological Protection and Industrial Safety group shall inspect the placement of the absolute filters for l

proper sealing.

In addition, air samples will. be taken and counted immediately after 1/2, 2, and 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> of operation to assure the absolute filters are adequately filtering the exhaust air. The adequacy of the sawpling techniquec to obtain representative samples will be verified quarterly in the Manufacturing facility and annually in Product Development.

Product Development Airborne wastes are released from Product Development as a result of airborne activity during handling and transfer of U02 powder for chemical analysis purposes, production of special R&D test fuel, and metallographic examination of production fuel and special test fuel.

All airborne waste is exhausted from Product Development (Building

  1. 5) via seven individual stacks.

The exhaust is continuously monitored whenever operations involving dusting or release of radioactive material are in progress. All stacks used for the exhausting of radioactive effluents are equipped with sampling l

connections. All but one of the stacks has absolute filters.

The one exception is the environmental test laboratory stack (Stack #7).

l Docket No. 70-1100 Rev. 04 Date: 06/23/89 License No. SNM-1067 Page 1.3-6

--___-__-___a

Product Development (Building #5) exhaust stacks typically have the following flows:

Stack No.

Area Monitored Flow (ft3/ min.)

1 Chemistry (No longer in use) 6200 2-Hot Chemistry Lab 3100 3

Emission Spectroscopy Lab 2000 5

Radiochemistry Lab, Environmental 2610 Labs & Vault 6

Ceramics Lab (Rm 222),

2125 Metallographic Lab 7

Environmental Test labs (No 2000 longer in use) 8 Ceramics Lab (Rms. 224 A & B) 4500 Air from system Nos. 1,2,3,4,5,6 and 8 pass through single banks of absolute filters (99.97 percent efficient for >0.3 micron particles), and are vented to the atmosphere.

Continuous sampling is provided immediately upstream from the discharge point.

The environmental test lab is connected to System No. 7, however, the system is not presently being used.

Ventilation system filters and/or prefilters will be changed, rotated, or knocked down whenever a presstire drop of 4 inches of water. is measured across the combination of the prefilter and first bank of absolute filters.

The pressure drop for all systems shall be checked monthly and documented. When the face velocity at a ventilated hood drops below h

100 fpm,'the hood filters or ventilation system fil~ters will be changed, brushed, or knocked down to increase the air flow to Docket No. 70-1100 Rev. 05 Date: 06/23/89 License No. SNM-1067 Page 1.3-7

l 100 fpm minimum or the hood will not be used to handle radioactive l

material. Face velocities will be checked monthly in Product Development.

The filters in these stacks shall be tested either by 1) counting samples immediately after 1/2 hour of operation or 2) DOP testing l

the filters in accordance with ANSI standards.

Such testing shall be done after all filter changes or movement of the filters to assure they are adequately filtering the exhaust air. The results of these tests shall be documented.

Each ventilating filter system described in Section 3.2.3 shall be equipped with an instrument that measures the pressure drop continuously.

3.2.4 Instrumentation Capabilities of radiation detection and measurement instrumentation shall be as follows.

Alpha counting System 10 - 10,000 dpm Alpha Survey Meters 0 - 50,000 counts per minute i

Beta Gamma Survey Instruments.05 mR/hr - 200 mR/hr Neutron Survey Instruments

.5 - 5,000 mrem /hr A sufficient number of the instruments, meters and systems listed above shall be maintained operational to adequately conduct our Radiological Protection and Industrial Safety program. Additional

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instrumentation is maintained for emergency use as outlined in Part I, Section 8.

The detectors for the criticality alarm system are calibrated semi-annually and following any repair that affects the accuracy of the measurements.

All other instruments are calibrated semi-annually and following any repair that affects the accuracy of j

the measurements.

The calibration of the survey instruments shall meet the specifications described in Section 1.11 of i

l Docket No. 70-1100 Rev. 04 Date: 06/23/89 License No. SNM-1067 Page 1.3-8 i

l Regulatory Guide. 8.24, " Health Physics Survey During Enriched Uranium-235 Processing and Fuel Fabrication".

The alpha counting 1

equipment is checked daily to verify background and efficiency.

3.2.5 Internal Exposure (Fixed Location Breathina Zone Air Samplina and Fixed location General Air Samolina Nuclear Fuel Manufacturing The room air in all areas where unclad licensed material is handled, processed, or where operations could result in worker exposure to f

the intake of quantities of uranium exceeding those specified in 10 CFR 20.103, shall be continuously sampled and analyzed on every

'i shift for radioactivity. Air. sampling.shall be accomplished using fixed-location general air sampling stations and fixed location breathing zone air sampling stations. The sampling results from the

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fixed location breathing zone air sampling stations shall be used i

l for the basic evaluation of.the internal exposure of workers.

During the normal operating period, if a single breathing zone or general air sampling station indicates the airborne concentration of

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radioactivity for that area exceeds the MPC specified in Table I Column I of 10 CFR 20, Appendix B, an investigation as to the cause i

I shall be conducted. Any necessary corrective actions to prevent its l

l recutrence shall be taken and documented.

Both fixed location i

i breathing zone and general air samplers shall have a minimum flow of 10 1pm.

The fixed locations breathing zone air sampling stations shall be the' primary means of determining radioactive airborne concentrations of. particulate in'the workers' breathing zone.

The fixed location breathing zone air sampling stations shall be strategically located i

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Docket No. 70-1100 Rev. 08 Date: 06/23/89 License No. SNM-1067 Page 1.3-9 i

e throughout the shop and run continuously during operations.

The fixed location general air sampling stations provide air sample which are' representative of working areas in order to verify adequate ventilation and contamination control. All samples from both fixed location breathing zone and general air sampling stations shall be analyzed after each working shift.

The representativeness of the fixed location breathing zone air

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sampling stations shall be evaluated at lease once every 12 months and whenever any licensed process or equipment change is made.

It is recognized ~that' the behavior of individual operators can be a significant contributing factor to an individual's exposure, and that this may not be amenable to the desired degree of improvement Where the individual operator is found to contribute significantly to higher exposures, closer personnel surveillance shall be maintained. An individual whose 40 hr. exposure exceeds 2.5 MPC days shall be closely monitored with a portable BZ sampler.

The sampler will have a minimum flow rate of 1400cc/ min.

If the person's 40 hr. exposure exceeds 4 MPC days, the person shall be removed from exposure to airborne contamination.

It is the responsibility of the Supervisor, Radiological Protection and Industrial Safety to evaluate these situations to determine the

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relative contributions of individuals and equipment.

The pellet shop is the only place in the manufacturing facility that handles unciad 002. This portion of the facility is kept at a negative pressure as described in Section 3.2.3.

therefore, continuous air sampling'shall be conducted in this area only.

b Docket No. 70-1100 Rev. 04 Date: 06/23/89 License No. SNM-1067 Page 1.3-10 l

Product Development All operations in Product Developments which involve U02 powder or the potential for worker exposure to airborne uranium exceeding the limits specified in 10 CFR 20.103, shall be sampled with breathing zone samplers 100% of the time.

Samples shall be analyzed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after each operating shift. A one MPC action level and a minimum flow rate of 1400 cc/ min. shall be used for Froduct Development operations.

l 3.2.6 ht, pat _ Exposure (Dosimetry Requirements)

Each individual who enters a restricted area under such circumstances that he is likely to receive a. dose in any calendar quarter of 25 percent of the applicable value specified in 10 CFR 20.101(a) shall be supplied with a TLD badge and indium foil for purposes of personnel dosimetry. Badges will be processed monthl.y.

When a high exposure is suspected, the individual's badge will be sent out for immediate processing.

All visitors will be supplied with indium foil badges. Area TLD badges and neutron foils are also strategically placed throughout the facility for the purpose of recording background radiation levels as well as radiation resulting from a criticality accident.

The TLD badges will also be processed monthly during normal operations and immediately following a criticality accident.

Procedures to determine high radiation doses immediately following a criticality accident are described in the Emergency Procedures Manual.

Docket No. 70-1100 Rev. 04 Date: 06/23/89 License No. SNM-1067 Page 1.3-11

3.2.7 Bioassay Proaram Urinalysis and in-vivo lung counting shall be conducted annually.

l i

Urine samples for any workers who routinely work with soluble compounds of uranium shall be collected and analyzed monthly.

If the most recent quarterly average of the airborne uranium concentration for any work area exceeds 25% of the respective DAC, the frequency of sampling and the type of bioassay measurements for workers in that work area shall be modified to that given in Table 3 of Regulatory Guide 8.11, " Application of Bioassay for Uranium".

The following tables outline the action levels which will be utilized for both urinalysis and in-vivo' counting:

URINALYSIS ACTION LEVELS Urinalysis Result Action

1) Sample >25 ugU/ liter
1) Confirm result (if unexpected)
2) If result is confirmed:

- Impose work restrictions

- Collect and evaluate diagnostic urine samples

- Conduct investigation to identify probable cause

- Perform In-Vivo count Docket No. 70-1100 Rev. 05 Date: 06/23/89 License No. SNM-1067 Page I.3-12

3 l

IN-VIVO ACTION LEVELS l

In-Vivo Result Action-

1) Lung Burden >175 ug U235
1) Confirm result (if unexpected)
2) If result is confirmed:

- Impose (or continue) work limitations.

- Conduct job investigation to identify probable cause, determine if others were exposed, and evaluate adequacy of air sampling.

- Initiate corrective actions.

3.2.8 Contamination Surveys 3.2.8.1 Contaminated Areas (Pellet Shoo Buildina #17 & Contaminated Areas of Product Development)

Removable Aloha Contamination Action to be Taken 10,000-dpm/100 cm2 Immediate Clean-Up 5,000 dpm/100 cm2

' Clean-Up within 24-hours Contaminated areas shall be surveyed on a weekly basis. Material l-fixed on processing equipment or on surfaces shall be limited as required.to control airborne radioactivity and external radiation l

l-exposures.

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Docket No. 70-1100 Rev. 03 Date: 06/23/89 License No. SNM-1067 Page I.3-13 I

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'O, O '

G 3.2.8.2 Clean Areas (Other olant areas. office areas. lunch areas)

Removable Aloha Contamination Action'to be Taken Aloha-Level 100 dpm/100 cm2 Immediate Clean-Up 50 dpm/100 cm2 24-hour Clean-Up 10 dpm/100 dm2 (lunch rooms only)

Immediate Clean-Up Other manufacturing areas, office areas, and the warehouse (Bldg.

21) shall be surveyed on a monthly basis. The lunch rooms shall be surveyed once a day, as a minimum.

Fixed Aloha Contamination Monthly fixed alpha contamination levels in the non-contaminated areas (and for release of equipment from contaminated areas) shall be less than 500 dpm/100 cm2 average.

3.2.8.3 Materials & Eouioment Released for Unrestricted Use-(does not include the abandonment of Buildinos)

The release of materials and equipment for unrestricted use shall be in accordance with " Guidelines for Decontamination of facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for By-Product, Source, or Special Nuclear Material",

USNRC, Annex B. July 1982.

3.2.9 Resotratory Protection Thi Respiratory Protection Program shall be conducted in accordance with the USNRC Regulatory Guide 8.15.

Docket No. 70-1100 Rev. 04 Date: 06/23/89 L'icense No. SNM-1067 Page 1.3-14

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4.0 Nuclear criticality Safety 4.1 Administrative Requirements 4.1.1 Double Contingency Policy - Process designs shall, in general, incorporate sufficient factors of safety to require at least two unlikely, independent, and concurrent changes in process condi.tions l

l before a criticality accident is possible.

i 4.1.2 Written Procedures and Anoroval Authority - All process operations involving SNM shall be covered by a shop traveler and/or an operation sheet which shall be followed.

Precautions and limits regarding criticality and radiological safety shall be included in these procedures.

In addition, all procedures shall provide for the labeling of mass limited containers to indicate the enrichment and the uranium content. All process equipment and operating areas shall be labeled to indicate the enrichment. Geometry limited containers will be handled as though they are full unless J

specifically labeled empty.

Labeling shall be carried out under the l

direction of the cognizant supervisor.

I These procedures shall be approved by the Manager, Radiological Protection and Industrial Safety.

However, procedures involving a i

change in the criticality safety controls used for that particular

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process in the past shall also be reviewed and approved by the Nuclear-Criticality Specialist.

It is the responsibility of the Manager, Production to ensure that personnel are trained in operations and the corresponding safety limits.

i Docket No. 70-1100 Rev. 04 Date: 06/23/89 License No. SNM-1067 Page 1.4-1 1

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-It shall be the responsibility of the Supervisor, Radiological Protection and Industrial Safety to assure that each work station is i

properly posted, and that operations are performed in. compliance with posted limits and written instructions.

4.1.3 Recuest for Chances and Criticality Analysis All proposed changes in process, equipment, and/or facilities that could affect nuclear criticality, radiological or industrial safety shall be approved in accordance with the responsibilities and authorities set forth in.Section 2.1 of this part. The necessary analysis and resultant safety limits shall be established by a person having the minimum qualifications of a Nuclear Criticality Specialist.

Procedures have been established for requesting changes and all request forms, approval forms, and associated documentation shall be maintained under the direction of the Manager, Radiological Protection and Industrial Safety.

4.1.4 Postino of Limits All special nuclear material work stations and storage areas shall be posted with a nuclear criticality safety limit approved by the Manager of Radiological Protection and Industrial Safety and the i

Nuclear Criticality Specialist. The Supervisor, Radiological Protection and Industrial Safety, maintains records of the review and approval of each posted nuclear criticality safety limit.

4.1.5 Internal Review Requirements All process / equipment / facility changes which affect nuclear criticality safety shall be reviewed and approved in writing by the 1

Nuclear Criticality Specialist andithe Manager, Radiological Protection and Industrial Safety. An independent review shall be i

performed by the Senior Nuclear Criticality Specialist.

Docket No. 70-1100 Rev. 05 Date: 06/23/89 l

License No. SNM-1067 Page I.4-2 1

l

9 As stated in Section 4.1.3, all such approvals shall be recorded in a log maintair ed under the direction of the Supervisor, Radiological Protection and industrial Safety.

4.1.6 Harkina and Labelina of $_NM - All mass-limited containers shall be labeled as to enrichment and content.

All geometry limited containers and processes are safe up to the maximum allowable enrichment of 5.0wt% U235.

4.1.7 Section Deleted l

1 1

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Docket No. 70-1100 Rev. 07 Date: 06/23/89 License No. SNM-1067 Page 1.4-3 I

I l

l 8.12, " Criticality Accident _ Alarm system" shall be maint> ined in l

Product Development areas and the manufacturing facility. The

[

detectors operate in the range of 1-10,000 mR/hr.

The locations of 4

the detectors within the manufacturing facility are shown on Page 11.8-75 and within the Product Development on Page 11.8-76.

The radiation intensity ;s shown on a central panel located in the Building 17 Radiological Protection and Industrial Safety office for Building 6,17 and 21, and in the main hallway in Bldg. #5 of Product Development. There is an alarm which serves as a local and general audible radiation evacuation alarm. When the alarm is sounded, the Emergency Plan is immediately put into effect.

The monitors are connected to the emergency power system, which is supplied to all emergency lights and alarms in the event of a general power failure within the facility. This electrical system renders the alarm system operative at all tines.

Operation is further enhanced by visual observation by Radiological Protection and Industrial Safety personnel.

Alarm operational tests of the radiation monitors are performed monthly by Radiological Protection and Industrial Safety personnel.

A radioactive source is used to perform these test. The entire system is calibrated semiannually and following any repair that affects the accuracy of

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the measurement.

4.3 Specific Criticality Safety Criteria Specific criticality safety criteria in addition to the general criteria described in.Section 4.2 are necessary to assure nuclear safety'for several process operations, as described below:

Docket No. 70-1100 Rev. 05 Date: 06/23/89 License No. SNM-1067 Page I.4-12 1

_____.__m_

l which time contamination levels will be evaluated, and the adequate condition of the packages will be verified.

5.1.4-Liouid Wastes All liquid wastes, in-process, and clean-up rinse water solutions are sampled to verify that MPC is not exceeded, and are then introduced to the liquid waste system as described below.

Release of liquid waste will be authorized by a member'of the Radiological Protection and Industrial Safety staff.

Sinks and showers in the laboratories and the manufacturing facility are drained to any one of ten (10) 2000-gallon retention tanks.

The tanks fill automatically in sequence. When eight tanks become filled to capacity, a blinking warning light located in the outside wall of the building is activated'to warn that two retention tanks remain in reserve to receive radioactive liquid waste before overflow might be expected.

a sampling station is provided at the base of each retention tank. A 500-m1 sample is withdrawn and forwarded to the Radiochemistry Laboratory for gross alpha and beta analyses.

Water is discharged to the Windsor site creek which flows into the Farmington River at, or below 0.000003 uti/ml (this is ten percent of MPC for insoluble natural uranium). The discharge level for unidentified mixtures of radionuclides is 0.000000003 uCi/ml.

(This if ten percent of MPC for unidentified mixed radionuclides).

Where levels of activity exceed these limits the water is diluted before being discharged.

The instruments measuring the liquid-waste level in each dilution tank shall be calibrated on an annual. basis.

Docket No. 70-1100 Rev. 04 Date: 06/23/89 L'icense No. SNM-1067 Page I.5-3

6.0 INDUSTRIAL SAFETY The Program Manager, Radiological and Industrial Safety shall be responsible for defining all programs and standards related to Industrial Safety, including OSHA regulations, for all activities in the Nuclear fuel Manufacturing Facility. The Industrial Safety Specialist, acting as a consultant to the Manager, Radiological Protection and Industrial Safety, is responsible for implementing those programs and standards. The Radiological. Protection and Industrial Safety Technicians monitor the day-to-day compliance.

The Director, Product Development shall be responsible for assuring compliance with all applicable industrial safety (OSHA) regulations for all activities conducted in the Product Development Laboratories under License SNM-1067. This function is satisfied by the same personnel described above for the Nuclear Fuel Manufacturing facility. These individuals provide like services in a support role to the Product Development area.

7.0 DECOMMISSIONING PLAN Combustion Engineering's Decommissioning Plan dated 1/15/79 was submitted previously and is included as Appendix A to this License.

8.0 RADIOLOGICAL CONTINGENCY PLAN Combustion Engineering's Radiological Contingency Plan, approved as Amendment No. 35 to SNM-1067 on March 26, 1982, is considered to be part of this license.

9.0 FUNDAMENTAL NUCLEAR MATERIAL CONTROL PLAN (FNMC)

Combustion Engineering's FNMC dated February 1980 was submitted June-11,.1980.and should'be considered part of this License.

Docket No. 70-1100 Rev. 04 Date: 06/23/89 License No. SNM-1067 Page 1.6-1 I

I i

)

m PART 11.

SAFETY DEMONSTRATION L

1.0 OVERVIEW OF OPERATIONS-1.1 Coroorate Information and Financial Qualifications

]

1.1.1 Name and Address of Licensee:

COMBUSTION ENGINEERING, INC.

1000 PROSPECT HILL ROAD f

l WINDS 0R, CT 06095 Combustion Engineering is incorporated in the State of Delaware.

The principal office location is in Windsor, Connecticut.

1.1.2 Name. Addresses and Citizenship of Principal Officers N_gg Position Address Citizenship HUGEL, Charles E.

Chairman and 900 Long. Ridge Road U.S.

Chief Executive Stamford, CT Officer KIMMEL, George S.

President and 900 Long Ridge Road U.S.

Chief Operating Stamford, CT Officer FORTNEY, Ray A.

Vice President 900 Long Ridge Road U.S.

Power Services Stamford, CT Businesses i

BARNETT, Charles E.

Vice President &

900 Long Ridge Road U.S.

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General Counsel Stamford, CT RUBIN, Jeffrey S.

Vice President 900 Long Ridge Road U.S.

of Finance Stamford, CT SMITH, Dale E.

Vice President 900 Long Ridge Road U.S.

Human Resources Stamford, CT l

& Operations l

Docket No. 70-1100 Rev. 05 Date: 06/23/89 License No. SNft 1067 Page II.1-1

1-.l.3 Company Backaround Combustion Engineering is a diversified company serving electric utility companies, oil and gas producers, chemical companies and general industry throughout the world. The major portion of C-E':

business has long been steam generation equipment for electric utilities, and it is one of the largest manufacturers of such equipment in the world.

In recent years the company has diversified into related fields while continuing to apply its basic skills and technology.

0-E,was first-organized as a corpora' tion in 1912.

When considering the companies which have. merged into._the, corporate structure, however, C-E's history dates back to the.1880's, Thus, the organization, as it exists today, has' mo N than 90 years of

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experience in the design, development and fabrication of steam generation equipment.

C E has been active in the development of nuclear power for more than 30 years, The Company's decision to extend its systems to large nuclear utility power plants represents a logical development of its previous activities as a supplier of thermal steam generating plants. All nuclear activities are carried out by the Nuclear Power Businesses Division.

The capabilities of the entire C-E organization are available to the Nuclear Power Businesses Division and will be utilized by it, as necessary, to fulfill its responsibilities.

Docket No. 70-1100 Rev. 03 Date: 06/23/89 License No. SNM-1067 Page 11.1-2

E Nuclear Power Businesses employs more than 1500 people of whom approximately 70% are scientists and engineers. A majority of the professional staff have at least five years experience in the nuclear field and have continued their education beyond the Bachelors Degree level. This staffing provides competence in the field of nuclear science and technology and extensive experience in the following specific areas:

theoretical and experimental physics, mathematics, reactor analysis, chemistry, metallurgy, instrumentation controls, mechanical design, thermal sciences and nuclear.and radiological safety.

The, Nuclear Poweru8usinesses Division.is divided..i,nto three principal business segments; Nuclear Systems, Nuclear Services and Nuclear Fuel.

Each of these business segments is headed by a Vice President responsible for the activities of the unit and who reports to the President, Nuclear Power Businesses.

The Nuclear Fuel Manufacturing and Nuclear Fuel Product Development activities within the scope of this license application are conducted under the auspices of the Vice President, Nuclear Fuel.

Nuclear Fuel Manufacturing Nuclear Fuel Manufacturing (NFM) is equipped to provide a variety of

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services necessary to the development and manufacture of precision reactor components such as fuel rods and assemblies containing low enriched UO2 and control rods.

Product Development Product-Development maintains complete facilities for.the development, design, analysis and testing of nuclear components and systems.

Equipment is maintained for mechanical testing, X-ray Docket No. 70-1100 Rev. 04 Date: 06/23/89 License No. SNM-1067 Page 11.1-3

j l

diffraction, vacuum and inert atmosphere heat treating, radiography, l

UO2 powder processing, U02 pellet fabrication development, ceramics-materials processing, analytical chemistry and radiochemistry. The

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Product Development staff is comprised of metallurgists, chemists, engineers, and technicians. Product Development consists of two i

functional sections:

New Product Development - Establishes experimental basis for new l

fuel products; specifies materials for prototype fuel fabrication; reviews drawings, specifications and other documents for prototype fuel; performs dynamic and structural testing of reactor components; evaluates test data, and test results.

Core Materials Development - Prepares material specifications;

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analyzes material problems, recommends materials for specific applications _and environments; reviews fabrication and test procedures; performs manufacturing process development; develops and maintains chemistry specifications; performs metallurgical and chemical testing; analyzes chemistry related problems; predicts the effects of irradiation on material properties; performs irradiated materials testing, provides in-service fuel performance evaluations and performs and interprets field inspection data.

Docket No. 70-1100 Rev. 04 Date: 06/23/89 License No. SNM-1067 Page 11.1 4

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i Docket No. 70-1100 Rev. 04 Date: 06/23/89 License No. SNM-1067 Page 11.1-5

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Information Known to ' Apolicant Recardino Foreian Control There is no information known to combustion Engineering, Inc. of any control exercised over it by any alien, foreign corporation, or foreign government. The stock of Combustion Engineering is traded on the New York Stock Exchange. According to the stock records of Combustion Engineering maintained by its Transfer Agent, the Chase j

Manhattan Bank,.as of December 31, 1979 there were approximately 26,74'2' stockholders;of record, holding 16,337,119~ shares of Combustion. capital stock issued and outstanding. Of this number less than.1 percent of all' stockholders gave foreign addresses.

1.1.5 Financial Qualifications Combustion Engineering's 10-K which details its financial position is attached as Appendix B.

1.2 Operatino Ob.iective and Process - Summary The process at the nuclear fuel manufacturing facility begins with receipt of UO2 powder or fuel pellets enriched to a maximum of 5.0wt% U235. The primary source of this material is Combustion Engineering's.

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Docket No. 70-1100 Rev. 05

'Date: 06/23/89 License No. SNM-1067 Page 11.1-6 l

,3.0 Organization and Personnel Functions of key positions important to safety, specifics on education and experience required for key positions important to safety, operating procedures, and training are described in Part I, Chapter 2.0 - Organization and Administration.

The Windsor Nuclear Fuel Manufacturing facility and Product Development organization structure is depicted in Figure 3.1.1.

3.1 Functions of Kev Personnel The function, responsibilities and authorities, of key personnel important to safety are decribed in Part I, Section

-2.1 of.this application." This section provides similar information for the remaining personnel holding key line management positions.

3.1.1 Manacer, Nuclear Materials Licensina The Manager, Nuclear Materials Licensing reports functionally to the Vice President and General Manager and has responsibility _for licensing of Combustion Engineering's Nuclear Fuel Manufacturing and Product Development activities.

This responsibility is executed by identifying applicable NRC regulations and ensuring that they are appropriately addressed in applicable licenses and certificates of compliance, as necessary.

3.1.2 Manaaer. Nuclear Materials The Manager of Nuclear Materials reports to the Vice President and General Manager.

Nuclear materials control relating to the receipt, storage, use and transfer of special nuclear material (SNM); the accounting and locating of SNM; preparation / revision / submittal of the Fundamental Nuclear Material Control Plan; quantity accountability and maintenance of records relating to the operating, receipt and storage of SNM are directed by the Nuclear Materials Manager.

In order to execute these functions, he defines the Materials Control and Accountability Program used by the Windsor Nuclear Fuel Manufacturing facility.

The Manager of Nuclear Materials has no production responsibility and he has no hands on responsibility for nuclear materials.

He or she also provides an audit function for Combustion Engineering's nuclear fuel manufacturing facilities to ensure compliance of operations personnel with the requirem~ents of the Materials Contro.1 and Accountability

' Program.

Docket No. 70-1100 Rev. 04 Date: 06/23/89 License No. SNM-1067 Page: II.3-1

1 I

3.1.3 Manaaer. Ouality Assurance The Manager of Quality Assurance reports to the Vice President and General Manager.

Quality control and quality assurance functions are_under the direction of the Quality Assurance Manager.

He or she is responsible for establishing quality control inspection procedures to ensure that manufacturing operations produce a product that meets or exceeds customer

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specifications.

He or she also prepares and implements the Quality Assurance Manual for the Windsor Nuclear Fuel Manufacturing facility.

The Manager, Quality Assurance has no production I

responsibility.

He has the authority to shutdown operations which inspection reveals are not producing a product consistent.with-customer specifications.

3.1.4 Manacer. Accountability and Security The Manager of Accountability and Security reports to the Vice President and General Manager.

The implementation of the Fundamental Nuclear Material Control Plan, maintaining custodial control of nuclear materials, warehousing when not under the control of the Production Manager and management of radioactive waste are the responsibility of the Manager of Accountabi'ity and Security.

He or she maintains nuclear materials measurement control systems and records of nuclear materials in the production process.

He or she is-also responsible for the preparation and implementation of the Physical Security Plan and oversight of the security force for the Windsor Nuclear Fuel Manufacturing facility.

3.1.5 Manacer. Operations The Manager of Operations reports to the Vice President and General Manager. He or she is responsible for the coordination of activities amongst Line Managers to ensure that the facility production goals are satisfied within the limits imposed by Federal, State and local regulations, this license applicatio'n, certificates of compliance and other permits, as applicable. -

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Docket No. 70-1100 Rev. 04 Date: 06/23/89 License No. SNM-1067 Page: II.3-2

3.2; Resumes of Kev Personne1'Imoortant to Safety i

1 Resumes of key personnel important_to safety are. provide.d on-Pages II.3-5 through II.3-30.

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- Docket No. 70-1100 Rev. 06 Date: 06/23/89 License No. SNM-1067 Page: II.3-3

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CHARLES R. WATERMAN - Vice. President and leneral Manager, Nuclear Fuel Manufacturing EDUCATION B.

S. Electrical Engineering, Tri-State College, 1957 EXPERIENCE' COMBUSTION ENGINEERING, INC.

Windsor, Connecticut Vice President and-General Manaaer, Jan.-1989 to Present Nuclear Fuel Manufacturing Overall responsibility for the safe operation of Combustion Engineering's-nuclear fuel manufacturing facilities located in Hematite, Missouri and in Windsor, Connecticut.

Continuing responsibility as the Plant Manager for the Windsor Nuclear Fuel Manufacturing. facility.

Plant Manaaer.

1988 to:Jan. 1989 Windsor Nuclear Fuel Manufacturing Responsible for day-to-day manufacturing operations, accountability, security, nuclear criticality safety and radiological safety related to all special nuclear and source material received by Windsor Nuclear Fuel Manufacturing and used in any manufacturing process.

Assured compliance with Federal and State and local regulations and the requirements and limitations set forth in facility license SNM-1067.

Director. Outace Services 1986 to 1988 Responsible for management of outage services, for development test and application of maintenance and inspection services provided to nuclear utilities.

These services included integrated refueling and maintenance outages, fuel services, major plant retrofits, full steam generator services using i

advanced remote controlled devices designed and built by outage services.

Responsible for all aspects of compliance with Windsor' facility NRC by-product license.

Responsible for the operation of Amdata, Inc., a wholly owned subsidiary of CE.

Amdata designs and manufactures advanced ultrasonic imaging equipment and inspection services for the Nuclear, Oil and Gas and Acrospace industries.

President / General Manaaer 1985 to 1986 l

CE/Delas Weir. Inc.

Responsible for strategic direction'of this joint venture company as well as day-to-day operations.

CE/Delas Weir 4

Docket No. 70-1100 Rev. 04 Date: 06/23/89 License No. SNM-1067 Page: II.3-5

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CHARLES R. WATERMAN l

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provided new and replacement heat exchanger equipment to Electric Utilities.

4 ENGINEERING PLANNING AND MANAGEMENT CO.

1984 to 1985 President and CEO 1

Responsible for strategic direction and day-to-day operations.

EPM supplied engineering services to the Nuclear Utility Industry and Maintenance Management Software Programs to the Food and Pharmaceutical Industries.

SENSOR ENGINEERING COMPANY 1981 to 1984 DIVISION OF ECHLJN, INC.

President Responsible for strategic direction and day-to-day operations for a high-tech manufacturing company of magnetic devices for use in security, automotive and industrial control systems.

ELECTRO-MECHANICS, INC.

1977 to 1981 President and Chairman of the Board Responsible for strategic direction and day-to-day operations for a manufacturer of custom electronic control systems for the Electric Utility and Commercial Industries.

COMBUSTION ENGINEERING, INC.

1965 to 1977 1

Director. Plant Accaratus 1975 to 1977 Responsible for technical specification and procurement of all NSSS mechanical hardware.

Established the organization and QA Manual for CE's Engineering "N"

stamp.

Proiect Manaaer. Boston Edison 1972 to 1975 Nuclear Reactor Proiect 1

Responsible for representing Combustion Engineering with l

Boston Edison and all governmental agencies in matters i

relating to contracts, licensing, design, fabrication schedules, erection, startup and acceptance of the nuclear steam supply systems and associated fuel.

Authorized all work to be done on the project.

Reviewed, evaluated, and approved all technical work on-the project, including purchase orders,

' purchase order supplements, drawings, an'd specifications.

Docket No. 70-1100 Rev. 04 Date: 06/23/89 License No. SNM-1067 Page: II.3-6

a CHARLES R. WATERMAN Assistant Proiect Manaaer, 1970 to 1972 Malpe Yankee Nuclear Reactor Proiect Assisted the Project Manager in the direction of technical and administrative activities.

General Manacer. Naval Reactor Division 1968 to 1970 overall responsibility for the operations of the SIC land-based submarine prototype facility under contract between CE and the U.S. Atomic Energy Commission.

Operations Manaaer, 1967 to 1968 Naval Reactors Division m

Responsible for operation and maintenance of the SIC prototype and support facilities.

Responsibilities included the approval and implementation-of schedules for operation testing, training, maintenance, plant modifications and for the control and forecast of department budgets.

Assistant Operations Manaaer.

1965 to 1967 Trainina Manaaer. Naval Reactor Division Responsible for training SIC prototype operating personnel including coordination of Naval and Division personnel.

CONNECTICUT YANKEE ATOMIC POWER COMPANY 1964 to 1965 j

Nuclear Enaineer In training as Assistant Plant Superintendent.

COMBUSTION ENGINEERING, INC.

1959 to 1964 Senior Shift Supervisor. Naval Reactors Division Responsibl'e for the safe and efficient operation of the SIC prototype.

Electrical design engineer responsible for the evaluation of electrical and electronic systems and equipment.

ELECTRIC BOAT DIVISION, 1959 GENERAL DYNAMICS CORPORATION Test Director Test Director!on the Nucl' ear Submarine USS (BN) George Washington for preoperational and operational tests.

Docket No. 70-1100 Rev. 04 Date: 06/23/89 License No. SNM-1067 Page: II.3-7

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CHARLES.R.. WATERMAN

-COMBUSTION ENGINEERING, INC.

1957 to 1959

~ Electrical Control ~Encineer, Reactor Development Division

il-Reactor analysis for the SIC /S2C reactor plants.
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.s Docket.No. 70-1100 Rev. 04 Date: 06/23/89, License No, SNM-1067 Page: II.3-8

ROBERT NORMAN DUNCAN - Director, Product Development EDUCATION B.S. Metallurgy, Massachusetts Institute of Technology, 1955.

Additional Study, Stanford University, Graduate Materials Science Courses, 1964-1968.

Registered Professional Engineer (California) #MT-1047.

EXPERIENCE COMBUSTION ENGINEERING, INC.

t Director. Product Development 1985 to Present Responsible for the management of all nuclear fuel product development laboratory activities.

This responsibility includes operations, material accountability, security, radiological, criticality and industrial safety, environmental protection,;and licensing.

Director. Fuel Development Department.

1974 to 1985 Responsible for direction of core materials development including programs to develop and test fuel, cladding and control materials.

Functional responsibility included j

Materials Technology, Fuel Performance Testing and Analysis and Analytical Chemistry.

Responsible for planning and. executing experimental programs to improve C-E fuel performance, evaluating and monitoring of I

fuel performance in C-E supplied plants and technical integration of development activities with KWU.

Manaaer Core Materials 1972 to 1974 Responsible for line management of the Core Materials Development organization including planning and execution of PED projects related to fuel testing, examination and performanc6 analysis.

Initiated several major fuel irradiation test programs in both test and power reactors.

Responsible for project field support, on-site fuel 4

examinations and plant licensing activities related to fuel l

performance.

Responsible for the integration of fuel j

i performance related R & D with the appropriate KWU programs.

Staff Assianment Reportina to Director.

May, 1972 to Dec. 1972

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t Nuclear Laboratories In a staff function, reviewed C-E positions on l'icensing, prepared and reviewed PED programs, participated.in early KWU/C-E inform'ation exchanges on fuel performance and planned

. Docket No. 70-1100 Rev. 04 Date: 06/23/89 License No. SNM-1067 Page: II.3-9 i

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e ROBERT NORMAN DUNCAN integrated C-E/KWU irradiation test programs.

Planned and initiated an experimental irradiation test program on fuel densification and negotiated agreements for joint programs in this area with EEI and'others.

Evaluated the impact of C-E participation in the Halden Reactor Project and assisted in the negotiations of the agreements.

GENERAL ELECTRIC COMPANY 1963 to 1972 Breeder Reactor Development Ooeration and Nuclear Fuels Development Managed Fast Reactor-Ceramic Fuels and Cladding Metallurgy Units..

Directed research and development effort on stainless steel clad uranium-plutonium oxide fuels for fast breeder reactor application,- including basic physical property measurements:and an extensive irradiation test program conducted in EBR-II.

Responsible for zirconium fuel cladding developiaent program coordination and irradiation testing in the Big Rock Point reactor.

Project Engineer of the AEC-Euratom Specific Zirconium Alloy Design Program.

Project Engineer of the AEC-Euratom Stainless Steel Failure Investigation Program involving stress-assisted intergranular corrosion of austenitic stainless steels in water reactors.

AEC High Power Density Fuels Development Program, including post-irradiation examinations of VBWR fuel assemblies.

WESTINGHOUSE ELECTRIC CORPORATION 1958 to 1963 ATOMIC POWER DEPARTMENT Senior Engineer Designed-irradiation test program on Zircaloy clad UO2 fuel i

rods.

GENERAL ELECTRIC COMPANY 1956 to 1958 ATOMIC POWER EQUIPMENT DEPARTMENT Worked on. development of process and fabrication techniques on l

reactor core materials WESTINGHOUSE ELECTRIC CORPORATION 1955 to 1956 Worked on fabrication. techniques fo'r uranium-aluminum fuel.

I Docket No. 70-1100 Rev. 04 Date: 06/23/89 License No. SNM-1067 Page: II.3-10

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PHILIP R. ROSENTHAL - Program Manager, Radiological and Industrial Safety EDUCATION B.S. Mechanical Engineering, University of Maryland, 1959 Graduate Study, Nuclear Engineering, Drexel Institute of Technology, Philadelphia, Pennsylvania, 1962 - 1963 EXPERIENCE COMBUSTION ENGINEERING, INC.

1970 to Present Procram Manaaer, Jan. 1989 to Present Radiological and Industrial Safety Responsible for definition of radiological, criticality, and industrial safety and environmental protection programs and standards for Combustion Engineering's Windsor'and Hematite Nuclear Fuel Manufacturing facilities.

Also responsible for emergency planning at the Windsor facility.

Through an audit function, assure compliance and proper implementation of safety related programs and standards.

Manaaer, Radiological and Industrial June, 1988 to Jan. 1989 Safety Responsible for the radiological protection, health physics, and industrial safety programs at Combustion Engineering's Windsor Nuclear Fuel Manufacturing facility.

Ensured that the necessary engineering and administrative controls were in place for radiological protection, criticality safety, and industrial safety.

Reviewed and approved all proposed alterations, modifications, and additions were the use of radioactive materials where involved.

Manaaer, Radiological Protection Services 1974 to June, 1988 Responsible for all radiologic 61 protection and health physics activities for Combustion Engineering, Inc.

Administered NRC licenses for by-product, source, and special nuclear i'

materials.

Reviewed and approved all proposed alterations, modifications, and additions to facilities where the use of radioactive material was involved.

Responsible for all C-E operations involving radioactive waste disposal, decommissioning, environmental control and the transportation of radioactive materials.

Responsible for providing health physics and radioactive material control services for all C-E field service activities.

Provided consultation services to utilities in the area of' radiological protection, waste disposal, and radioactive material transportation.

Docket No. 70-1100 Rev. 04 Date: 06/23/89 License No. SNM-1067 Page: II.3-11

PHILIP R. ROSENTHAL Program manager for development of a computerized dose tracking and evaluation system for power plant maintenance activities.

Responsible for the design, construction, and licensing of a facility for contaminated and irradiated equipment.

Program manager for three decommissioning projects including the decontamination and decommissioning of a uranium fuel fabrication facility to unconditional release criteria.

Supervisor of Mechanical Development 1970 to 1974 Responsible for mechanical development and testsfacilities for pressurized water reactor systems and components.

GENERAL-DYNAMICS CORPORATION-ELECTRIC BOAT DIVISION Senior Proiect Encineer 1964 to 1970 Responsible for the design, procurement, test and evaluation of submarine reactor plant components.

Refuelina Director Developed refueling procedures, tools and equipment for refueling submarine reactors.

Supervised the refueling of six naval reactor plants.

l UNITED SATES NAVY (Civilian Employee)

Mechanical Encineer 1962 to 1964 Responsible for nuclear engineering research and development programs. _

MARTIN-MARIETTA CORPORATION Reactor Systems Engineer 1958 to 1962 Responsible for design and fabrication of a liquid radioactive waste disposal system.

Docket No. 70-1100 Rev. 04 Date: 06/23/89 License No. SNM-1067 Page: II.3-12 1

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4 DAVID G.

STUMP - Manager, Radiological Protection and Industrial Safety EDUCATION B. S,, Candidate, Business Administration, Eastern Connecticut State College, Willimantic, Connecticut Certified NRRPT, Feb. 1983 Associate in Science, Arts & Sciences, Mohegan Community

College, Norwich, Connecticut, 1977 College Preparatory Graduate, Alpena High School, Alpena, Michigan, 1963 EXPERIENCE COMBUSTION ENGINEERING, INC.

Nov. 1983 to Present Windsor, Connecticut r

Manacer. Radiological Protection and Jan. 1989 to Present Industrial Safety Provided information, advice and assistance to operating and engineering line managers on personnel safety and environmental protection requirements.

Implements programs for radiological, criticality and industrial safety, environmental protection and emergency planning at the Windsor Nuclear Fuel Manufacturing facility and the Product Development laboratories.

Radiation Protection Lecture /Traininc Nov. 1983 to Jan. 1989 Instructor Development specialist for certification and requalification training programs pertaining to Radiation Protection.

Developed programs in fundamental engineering radiation safety for industrial radiographer and performance based training for Nuclear Fuels Manufacturing.

INSTITUTE OF NUCLEAR POWER OPERATIONS Atlanta, Georgia Erg-lect Manaaer 1986 to 1988 On loan from Combustion Engineering to INPO Training and Education Division.

Evaluation of training programs in Chemistry, Radiation Protection, and Technical Staff and Manager disciplines for compliance with INPO. Accreditation Criteria.

INPO Accreditation. Coordinator for three nuclear power stations.

Docket No. 70-1100 Rev. 04 Date: 06/23/89 License No. SNM-1067 Page: II.3-13

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1 DAVID G. STUMP j

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NORTHEAST NUCLEAR ENERGY COMPANY 1972 to 1983 j

Millstone Station, Unit 1 & 2 l

Waterford, Connecticut ESL12r Instructor.

March, 1981 to Nov. 1983 Health Physics. Chemistry Developed health physics, radiation protection safety and j

chemistry training programs for a commercial nuclear power station.

Responsible for the radiological aspects of emergency plan training and the health physics aspects of

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operator licensing training and health physics department j

technician training courses.

j Senior Health Physics Technician 1972 to 1981 Indoctrinated personnel on radiation protection requirements.

Serviced-and calibrated nuclear instruments.

Responsible for proper packaging, labeling, surveying and permit application of radioactive materials and radioactive waste for shipment.

Set up a maintenance and record keeping system for Health Physics instrumentation calibration facility.

Supervised Health Physics technical staff during unit outages.

THE HARTFORD ELECTRIC LIGHT COMPANY Waterford, Connecticut Customer Service Representative 1969 to 1972 Repaired, calibrated and installed gas and electric metering equipment and appliances.

THE CHARLES PFIZER CHEMICAL COMPANY Groton, Connecticut Chemical Operator 1966 to 1969 Operated and maintained instrumentation console for chemical production.

U.

S.

NAVY Hospital Corosman 1963 to 1966 Combat hospital corps duties with the 3rd Marine Division, FMF, Vietnam.

Shipboard duties with USS Fulton,.Groton, l

Connecticut.

l Docket No. 70-1100 Rev. 03 Date: 06/23/89 License No. SNM-1067 Page: II.3-14

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ROBERT J.

KIDTZ - Nuclear Criticality Specialist

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EDUCATION Graduate, Oak Ridge School of Reactor Technology, 1957 M.S. Physics, Kansas State College, 1954 A.B. Physics and Mathematics, Kansas State Teachers College of Emporia, 1952 l

Graduate Studies, Texas Christian University 1,.

l EXPERIENCE COMBUSTION ENGINEERING, INC.

1965 to Present Windsor, Connecticut Senior Consultino Physicist 1977 to Present Responsible for the physics design of new and spent fuel racks, fuel transfer machines, and other equipment involved in moving, testing or storing fuel.

Nuclear Criticality Specialist provide technical support and criticality audit function at both the Windsor Manufacturing and Hematite Fuel Manufacturing facilities.

Involved in solving special physics -

problems.

Section Manacer. Radiation and 1965 to 1977 Criticality Physics Responsible for radiation shielding, the ex-core criticality, and determination of source terms for Nuclear Steam Supply Systems.

Also for providing nuclear heat generation rates for structures in the NSSS, and radiation dose rates for assessing physical changes in NSSS materials and equipment in the radiation environment.

GENERAL NUCLEAR ENGINEERING CORPORATION Physicist 1959 to 1965 Responsibl,e for the shield design of the heavy water research reactor at the Georgia Institute of Technology and the thermal and biological shield design analysis for the Boiling Nuclear Superheat Rehetor (BONUS) located in Rincon, Puerto Rico.

Reviewed all the literature on radiation shielding for the publication Power Reactor Technoloav.

CONVAIR DIVISION OF GENERAL DYNAMICS Physicist 1954 to 1959 Responsible for the design of a shield for a mobile reactor of the Army Compact Core Design and fo,r a Nuclear Ramjet Missile.

Performed analysis of aircraft nuclear shielding experiments, developed shielding programs for computers, and contributed to the' Aircraft Shield Design Manual.

Docket No. 70-1100 Rev. 03 Date: 06/23/89 License No. SNM-1067 Page: II.3-15

h JOSEPH J. VOLLARO - Supervisor, Radiological Protection and Industry Safety EDUCATION Hazardous Waste Management Course, satisfies EPA RCRA mandate per 40CFR265.16, October, 1988.

Certified Radiation Safety Officer, January, 1988.

Respiratory Protection at Nuclear Power Plants, by Radiation Safety Associates, 1987.

Nuclear Criticality Short Course, University of New Mexico, May, 1985.

Certified NRRPT, Fall, 1985.

Four. year training course as a Dosimeter / Health Physics Technician.per NAVSHIPS.,0288, General,, Dynamics Electric Boat Division, 1973.- 1977

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Two semesters Physics / Physical Science, Eastern Connecticut 3 tate College, 1972 - 1973.

Training Course in " Radiation Protection Technology",

Combustion Engineering College Preparatory, Plainfield High School, 1972 EXPERIENCE COMBUSTION ENGINEERING, INC.

Nov. 1980 to Present Windsor, Connecticut Supervisor Radiological Production and Nov. 1985 to Present Industrial Safety Provide surveillance of nuclear fuel manufacturing and product development activities for radiological, criticality and industrial ~ safety, environmental protection and emergency planning.

Issues Radiation Work Permits for activities outside scope of routine operating procedures or which require enhanced radiological protection.

Docket No. 70-1100 Rev. 04 Date: 06/23/89 License No. SNM-1067 Page: II.3-16

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JOSEPH J. VOLLARO k

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Senior Health Physics Technician 1980 to Nov. 1985 I

Responsible for implementing and monitoring industrial safety,

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. radiation, contamination and. criticality control program.

j Also responsible for packaging / transportation of radioactive 1

waste / hazardous waste program, ALARA and implementing

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respiratory protection program.

I GENERAL DYNAMICS ELECTRIC BOAT DIVISION Groton, Connecticut-I Egnipr RadCon Monitor 1973 to 1980 Responsible for training of Electric Boat employees in usage of TLD's, radiation, control, contamination control, usage of TID rerader/ computer. interface equipment.

Also performed.

routine /non-routine.whole body counting of facility personnel, operated TLD readers and,whole body counters, maintained personnel and. environmental TLD program, directed.

monthly / quarterly radiation drills, performed audits of, facilities, performed high/ low range surveys of reactor shielding duringsinitial start-up.

9 Docket No. 70-1100 Rev. 04 Date: 06/23/89 License No. SNM-1067 Page: II.3-17

L 0 o-

. GARY C.;KERSTEEN

< Manager, Production 1'.

EDUCATION B.S. Mechanical Engineering, Trinity College, 1968 EXPERIENCE L

COMBUSTION ENGINEERING, INC.

1974 to Present L

Windsor, Connecticut Manaaer, Production 1979 to-Present Responsible for all aspects of. planning, scheduling, material control, and production control at the Windsor Nuclear Fuel Manufacturing facility.

This includes inventory accounting for non-nuclear commodities and the operation of warehousing, receiving and shipping functions.

Also responsible for training of facility operations personnel in proper use of operating procedures and adherence to safety. limits.,o.,,.-

-n Supervisor, 1974 to 1979:

Nuclear Material Accountability Responsible for all aspects of nuclear material control, measurement control, and statistics.

Included in the responsibilities of the' position was the development and operation of computer system for nuclear material accountanting, item control and measurement control.

MILITARY SERVICE:

U. S. ARMY 1969 to 1974 Commander, 575th Ordnance Co. Germany 1972 to 1974 Responsible for 150 men assigned to the 575th Ordnance Co. in electronics, mechanical ~ repair, depot supply and support sections.

Responsible for general electronic and mechanical repair support to the Sergeant guided missile systems for the Eurr, pean Theatre.

Sunolv Officer, E75th Ordnance Comoany 1970 to 1972 Responsible for 30 men and 8000 line items at a depot level supply warehouse furnishing repair parts to missile units in Europe.

i Docket No. 70-1100 Rev. 04 Date: 06/23/89 License No. SNM-1067 Page: II.3-18

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i PAUL W. HUBERT - Manager, Manufacturing Engineering l

j EDUCATION B.S. Materials Science Engineering, San Jose State College, 1966 EXPERIENCE COMBUSTION ENGINEFr.dG, INC.

Jan. 1970 to Present Windsor, Con?.ecticut Manaaer. Manufacturing Engineering 1974 to Present Direct engineering of the Windsor Nuclear Fuel Manufacturing facility equipment, process, methods and construction for new i

facilities and-for modifications.

Prepare procedures, perform training and maintenance'for facility processes and equipment.

Verify that facility engineering satisfies requirements on criticality, radiological and. industrial safety and environmental protection.

c Encineerina Sunervisor, Fuel Pellet 1970 to 1974 Fabrication Facility Responsible for all engineering activities associated with the Windsor Fuel Manufacturing Facility.

Responsible for plant layout, equipment specification, process development, plant startup, manufacturing procedures, material specification, and production engineering.

l UNITED NUCLEAR CORPORATION Proiect Encineer. Semi-works Oxide and 1966 to 1970 Pellet Plant Supervised the activities of an engineering group engaged in designing, building, starting up,-and operation of two UO2 pellet production lines.

Responsibilities included plant layout, equipment and materials specification, process development, and plant start-up.

GENERAL ELECTRIC COMPANY Manufacturing Enaineer. Fuel Production 1958 to 1966 Enaineerina Responsible for equipment and materials specification, manufacturing procedures, and process specification for production of UO2 fuel pellets, fuel rods, and other nuclear fuel components.

Prior to this assignment, held various technical positions in Fuel Development Engineering, Fuel Design Engineering, and Quality Control.

Docket No. 70-1100 Rev. 04 Date: 06/23/89 License No. SNM-1067 Page: II.3-19 1

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ROBERT S. HARDING.- Senior Criticality Specialist EDUCATION B.S., Physics, Trinity College, 1951 Ph.D., Physics, University of Rochester, 1958 EXPERIENCE COMBUSTION ENGINEERING, INC.

Principal Consultant, Nuclear Engineering 1989 to Present Currently assisting Nuclear Fuel Manufacturing in updating and implementing applicable SNM licenses.

Serve as second party

' independent reviewer ~for facility criticality evaluations.

Also act as criticality consultant to the Nuclear Safety Committee..

Senior Nuclear Scientist, Nuclear Engineering 1985 Acted as R&D Manager in the Nuclear Fuels area.

In addition, had technical cognizance for the criticality, shielding, and vessel fluence activities in Nuclear Engineering.

Also served as criticality consultant to the Nuclear Safety Committee.

Manacer, Nuclear Desian, Nuclear Engineering 1972 to 1985 Responsible for the administrative and technical management of the-Nuclear Design Department for design activities on PWR Nuclear Steam Supply Systems - fuel management, reactivity control, power distribution monitoring, generation of core nuclear safety parameters, radiation physics, criticality evaluations for excore fuel handling operations, nuclear design data for NSSS proposals, and support of other functional groups for plant design.

Also served as criticality consultant to the Nuclear Safety Committee in 1983 and 1984.

Manaaer. PWR Physics Methods Development, 1968 to 1972 Physics and Computer Analysis Department Responsible for developing and testing of design methods and computer codes employed in the nuclear design of PWR reactor cores.

Manacer. HWOCR Reactor Physics Section, 1965 to 1968 Physics Department Responsib1'e for the nuclear design and methods development activities on the Heavy Water Organic Cooled Reactor project and served as principal liason between the Physics Department and the HWOCR Project Office.

Also' responsible for the Docket No. 70-1100 Rev. 04 Date: 06/23/89 License No SNM-1067 Page: II.3-20

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-ROBERT S. HARDING nuclear design analyses relating to the conversion of a Savannah River Reactor to a D 0 moderated power reactor.

2 Staff Physicist. General Nuclear Encineerina, 1962 to 1965 (C-E Subsidiary)

Participated in the. State-of-the-Art Physics Program, a study of reactivity control methods for the NASA reference reactor design, and the review of literature on critical experiments for the Technical Progress Review, Power Reactor Technology.

Suoervisor. Advanced Critical Exoeriment Facility, 1961 to 1962 Nuclear Power Department

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Responsible for the technical programs and safe operation of both reactor; cells.

Staff Physicist. Advanced Critical Exoeriment 1958 to 1961

' Facility, Nuclear Power Department-Participated in the~ SIC Flux Measurement,' Nuclear Superheat,

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BONUS Critical, and Army Boiling Water' Reactor (PL-2) Critical Programs.

On BONUS Program was the Project Principal Experimental Physicist.

Also served as a member of the Critical Facilities Safeguards Committee and in 1961 was designated as the Alternate Supervisor of the critical Facilities for' purposes of assuring safe operation of the facilities.

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PAUL F. O'DONNELL - Nuclear Criticality Analyst EDUCATION Professional Engineer Degree, Nuclear Engineering,

~1978 North Carolina State University B.S., Nuclear Engineering, University of Lowell 1977 EXPERIENCE COMBUSTION ENGINEERING, INC.

Consultina Nu,glear Encineer 1988 to Present Responsible for performing criticality analyses for both the Hematite and Windsor fuel manufacturing facilities. These analyses include the criticality evaluations in support of the design of the new pelletizing-operation at the Hematite facility.

Developed KENO-IV models for evaluation of process, storage.and transportation systems.

Employed both the 16 group Hanson and Roach library and the NITAWL and XSDRNPM

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generated cross section libraries for these analyses.

Also has evaluates and reviewes equipment and process changes at both facilities.

Additionally, responsible for the criticality evaluation of spent PWR fuel assembly storage facilities. In these analyses, employed the two dimensional transport theory code DOT.

Princinal Nuclear Enaineer 1985 to 1988 Directly responsible for the development, testing and verification of core physics models for nuclear power reactors. In addition, directly involved in the analyses of advanced fuel management strategies for pressurized water reactors. In these capacities, employed the Discrete Integral Transport theory code DIT for the generation of neutron cross sections in HARMONY format, the three dimensional diffusion theory cods ROCS for the calculation of core power

$1striention-and reactivity, the two dimensional tranpsort li theory code. DOT for the calculation of radial boundary conditions, the one-dimensional transport theory code ANISN for axial flux and boundary conditions calculations, and PDQ J

for pin power distribution calculations.

Participated in a project which evaluated core power I

distribution and reactivity'following,a steam line break.

l accident. In this analysis, developed-three dimensional thermal-hydraulic and neutronic models for the HERMITE code.

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PAUL F..O'DONNELL Senior Nuclear Enaineer

'1982 to 1985 Directly= involved in a DOE sponsored program for the development of gadolinia shims in pressurized water reactors.

This included the definition of assembly designs with gadolina shimmed pins, generation of neutron cross sections with the.

DIT code, and the development of an 18 month fuel management strategy.

Also developed a computer code for the automated generation of assembly neutron cross sections in HARMONY format. In addition, employed and modified the point kernel code SHADRAC for neutron attenuation calculations.

Nuclear Encineer II' 1980 to 1982 Principal investigator for the development of fuel management strategies that would transition the CANDU-600 heavy water reactor from the natural uranium fuel cycle to higher enrichment and burnup fuel cycles. This program was sponsored by the U.S. Arms Control and Disarmament Agency. In this capcity, responsible for the development of cross sections

'using the DIT code and the definition of acceptable refueling strategies using the three dimensioani diffusion theory code FC.

GENERAL ATOMIC COMPANY, HTGR Core Performance and Analysis Department Physicist 1978 to 1980 Involved in High Temperature Gas Ccoled reactor (HTGR) conceptual design.

In this capacity, responsible for:

prismatic and pebble bed reactor core design and safety analyses, estimations of heavy metal mass requirements, cross section generation for hexagonal graphite fuel assemblies and the spherical shaped graphite lattice used in the Pebble Bed concept. In these analyses, employed the tranport theory code MICROBURN for.the generation of neutron cross sections, the one dimensional tranport theory code DTF for control rod modeling, and the two dimensional diffusion theory code 2DB for core power distribution and reactivity calculations.

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.KEVIN'R. HAYES - Industrial Safety Specialist EDUCATION B.S., Industri'al Technology, Central Connecticut State University, 1988 Special: Curricula: Manufacturing; also completed several

- requirements for occupational Safety and Health

.A.S., Manufacturing Engineering, Hartford State Technical College, 1986 n

EXPERIENCE COMBUSTION ENGINEERING, INC.

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-Industrial Safety Soecialist. Windsor Nuclear 1989 to Present-Fuel Manufacturing Facility Consultant on industrial safety and environmental protection.

Responsible for implementation of programs and standards inL the industrial safety and' environmental / protection area.

Also advise the Radiation Protection and Industrial Safety Technicians in the proper methods of' monitoring industrial-safety and environmental. protection compliance.

Safety Soecialist. Power Systems Enerav 1987 to 1989 Services-Responsible for coordinating Combustion Engineering Site environmental programs for' compliance with local, state, and i

federal regulations.

Assisted in revising C-E Nuclear' Fuel t

Manufacturing facility emergency plans and procedures.

Also served as security guard and ambulance technician. In this capacity was responsible for site security, responding to emergencies-and writing / maintaining incident records.

j SIMSBURY,'CT FIRE DISTRICT Fire Department Discatcher 1986 to 1987 Dispatched assistance for all fire calls, interfaced with public and wrote / maintained records.

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METAL IMPROVEMENT COMPANY 1982 to 1986 Employed in several shop manufacturing positions including 4

Leadman, Tool Grinder, Maintenance Technician, and Machine

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Operator.

Docket No. 70-1100 Rev. 03 Date: 06/23/89 License No. SNM-1067 Page: II.3-24 l

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'KEVIN R., HAYES 4

Sunnlemental Experience Volunteer firefighter'for 10Lyears; Connecticut certified Emergency Medical Technician (certified ' EMT-D) ; Senior. Rescue Instructor, Hartford-_ County? Fire / Emergency Plan.

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RAYMOND E. VAUGHAN - Manager,-Operations & Emergency Director EDUCATION M.

S., Systems Management, University of Southern California, 1975 B.

S., Marine Engineering, U.S. Naval Academy, 1963 Supplemental Education:

Naval Submarine Prospective Commanding Officer School, 1978 Naval Submarine and Nuclear Power School, 1965 EXPERIENCE COMBUSTION ENGINEERING, INC.

Manaaer. Operation - Windsor Nuclear Fuel 1989 to Present E

Manufacturing Facility Responsible for overall coordination of activities amongst all Line Managers to ensure that the facility production goals are satisfied within the limits imposed by Federal, State and local regulations.

Also serve as Emergency Director for nuclear fuel manufacturing facility and product development laboratories emergency response team.

Nuclear Fuels Independent Task Force Aug 1988 to 1989 j

Assigned to an eleven-member Independent Task Force established to conduct an audit of C-E's Windsor Nuclear Fuel Manufacturing Facility.

Audit results determined the status i

of compliance with applicable license conditions and regulatory requirements.

Areas of review included; manufacturing operations, nuclear criticality safety, radiological controls, health physics, industrial and environmental safety, maintenance, licensing, training, emergency preparedness, and organizational and management effectiveness.

Manaaer. NQclear Startup 1983 to 1988

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Responsible for the organization and direction of a multi-disciplinary engineering staff providing a wide range of engineering services at nuclear power plants.

Directed the establishment and administration of the C-E Site Startup offices at projects in which the Nuclear Steam Supply System was provided by C-E.

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RAYMOND E. VAUGHAN Proiect Manaaer. Technoloav Transfer.

Sept 1986 to Mar 1987 Korea 1.ssigned, on loan, to the NSSS Projects Department throughout the contract negotiation phase for Korea Nuclear Units 11 and 12.

Responsible for preparing, resolving and coordinating all technical, commercial and legal terms leading to award of two Technology Transfer Agreements to provide techology to Korea Heavy Industries and Construction, Inc. for NSSS Component Design and Manufacturing; and Korea Advanced Energy Research Institute with NSSS System Design and Fuel / Core Design.

UNITED STATES NAVY Anti-submarine Warfare and Submarine Liason Officer, 1983 Staff, Cruiser-Destroyer Group Five Deputy, Training and Readiness, Staff, 19u2 Submarine Squadron Three Commanding Officer, USS GUARDFISH (SSN-612) 1979 to 1982 -

Executive Officer, USS SEADRAGON (SSN-584) 1975 to 1979 Director, Tactical Training Department, 1973 to 1975 Naval Submarine Training Center, Pacific Engineer Officer, USS FLASHER (SSN-613) 1969 to 1973 Weapons Officer and Main Propulsion Officer, 1966 to 1969 USS HADDOCK (SSN-621)

Assistant Engineer and Sonar / Communication /

1965 to 1966 Electronics Material Officer, USS CHOPPER (SS-342)

Technical Naval Experience Power Plant Maintenance and ODeration Extensive experience in new construction, overhaul, refueling, testing, maintenance, inspection, training and operation of naval nuclear propulsion power plants, including pre-commissioning and overhaul crews in private and naval shipyards.

Qualified as an Engineering Officer of the Watch on four different reactor plant designs.

Certified by Naval Reactors as an Engineer Officer qualified for supervision of.

maintenance and operation'of naval nuclear power plants.

Weapons and Intearated Loaistics Systems Manacement In-depth experience in theory, operational and maintenance of nuclear power plants, complex electronics systems, weapons, Docket No. 70-1100 Rev. 04 Date: 06/23/89 License No. SNM-1067 Page: II.3-27

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RAYMOND E. VAUGHAN sensor and communications systems.

Proiect Manaaement overall manager for development and installation of advanced submarine (SSN-688) update to Integrated Submarine Tactical Team Training Device 21A38; and for Advanced Submarine ASW.

Training Device 21A41 Proposed Military Characteristics design l

and procurement specifications.

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I MAURICE E. HATCHER - Radiological Protection and i

i Industrial Safety Technician d

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EDUCATION Jonathan Law High School, Milford, CT, 1981 EXPERIENCE 1

l COMBUSTION ENGINEERING, INC.

1988 to Present Windsor Nuclear Fuel Manufacturing l

Radiological Protection and Industrial Safety Technician l

Power Systems Energy Services, Inc.

Sept. 1987 to 1988 Senior Health Physics Technician Senior Health Physics Technician assigned to support various utilities on a contract basis.

Responsibilities have included identifying radioactive waste, controlling high level waste, performing routine radiation, contamination and airborne surveys and releasing equipment.

' Bartlett Nuclear, Inc.

Feb. 1987 to Sept. 1987 Health Physics Technician Health Physics Technician assigned to support various utilities on a contract basis.

Responsibilities have included performing routine radiation, contamination and airborne surveys.

Worked in the ALARA unit responsible for pre-and post-job survey data; installation of numerous contamination control devices; installation of various HEPA ventilation units to control the spread of loose surface contamination.

Performed surveys of tools and equipment to allow for free release.

Performed decontamination of articles above established limits.

Issued respiratory protection equipment.

USS HUNLEY (Submarine Tender)

May 1983 to Oct. 1986 Article 108 Qualified Radiological Controls Monitor Duties included: ensuring proper radiological controls were enforced during all radioactive work, including supervision of Control Point Watches; ensuring numerous radioactive material transfers were properly executed; maintaining nuclear grade "A" cleanliness of primary systems; monitoring personnel exiting highly contaminated work areas; monitoring personnel l

Docket No. 70-1100 Rev. 04 Date: 06/23/89 License No. SNM-1067 Page: II.3-29

MAURICE E. HATCHER exposure; ensuring that all personnel received exposure within established limits.

Performed job coverage of two Steam Generator primary side inspections.and various Radioactive Liquid Waste tank dives.

Assigned primary collateral duties

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as Radioactive Materials Control Petty Officer and Primary Radiological Controls Monitor for the Northern Europe l.

. Radiological Casualty Assistance Fly-Away Team.

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4.0 RADIATION PROTECTION' PROCEDURES AND EQUIPMENT

'4.1 PROCEDURES A manual entitled " Nuclear Licensing & Safety Procedures" which contains procedures necessary to implement the radiation protection program described in Part I of the license application is maintained under the direction of the Manager, Radiological Protection and Industrial Safety.

4.2 Written Procedures All ' routine operations involving nuclear fuel handling are covered by i shop traveler and/or various operation sheets (0.S.) which are issued by Manufacturing Engineering or Quality Assurance.

These procedures include the necessary precautions which must be observed to assure that the operation is conducted.in a safe manner. '

The Manager, Radiological Protection and Industrial Safety will r.eview these precautions regarding all aspects of safety and indicate his approval in writing. However, procedures involving a change in the criticality safety controls used for a particular process in the past shall be approved by Manager, Radiological Protection and Industrial Safety, and the Nuclear Criticality Specialist.

Each Line Supervisor shall instruct his people to assure their understanding of the operations and their particular safety -limits and restrictions.

It is the responsibility of the Supervisor, Radiological Protection and Industrial Safety to assure that each work station is properly posted, and that operations are performed in compliance with posted limits and written instructions.

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14.3 Postina and labelina

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All. work stations involving handling of special nuclear material are posted with a Nuclear Criticality Safety Limits in accordance with m

Section 4.0 of Part I of this application. All mass limited' containers are labeled as to U235 contents and enrichment.

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Radiological posting of areas is in accordance with 10 CFR 20.203.

4.4' Personnel Monitorina.

J All personnel wash their hands before exiting the Pellet Shop and monitor their hands, exposed areas of the body and personal clothing with the alpha personnel monitor located at the change line. Any person having suspected contamination on his body must thoroughly wash the area and recheck for contamination.

If contamination persists, a member of the Radiological Protection and Industrial Safety staff assists in further. decontamination.

4.5 Syrveys Removable contamination levels in plant areas and on items to be released to an unrestricted area are established by smearing an area of 100 cm2 (4" x 4") with two inch diameter smear paper.

Pellet Shop floor smears are taken on a weekly basis.

Cold Shop floor smears are taken on a monthly basis. Contamination action thresholds are provided in Section 3.2.8 of Part I of this application.

Direct radiation surveys of plant environs, sealed sources,- and Docket No. 70-1100 Rev. 04 Date: 06/23/89 License No. SNM-1067 Page 11.4-2

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- offsite shipments of radioactive materials are made as necessary to comply with the regulations in 10 CFR 20.201. All survey results are documented.

4.6.

ReDorts and Records Radiological Protection records for the current calendar _ year, including training, and reports required by the regulations of the U.S. Nuclear Regulatory Commission and this license are retained under the direction of the Manager, Radiological Protection.and Industrial Safety.

Reports and records for previous years are made available to inspectors upon request.

~4.7 Instruments-Types:of radiation detection instruments, their capabilities, and frequency of calibration are described in Section 3.2.4 of Part I of this renewal -application.

4.8 Protective Clothina Protective Clothing requirements far personnel entering the Pellet Shop are described in Section 3.1.1 of Part I of this application.

4.9 Dosimetry 4.9.1 TLD Badaes Each individual who enters a restricted area under such circumstances that he is likely to receive a dose in any calendar

- quirter in excess of 25 percent of the applicable value specified in P

Docket No. 70-1100 Rev. 03 Date: 06/23/89 License No. SNM-1067 Page 11.4-3

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l 10 CFR 20.101 (a) shall be supplied with a TLD badge and indium foil for purposes of personnel dosimetry.

Badges are processed monthly.

j When a high exposure is suspected, the individual's badge is sent out for immediate processing. All visitors are supplied with indium foil badges. Area TLD badges and neutron foils are also strategically placed throughout the facility for. the purpose of recording background radiation levels as well as radiation resulting from a criticality. accident. These badges are processed monthly for normal operations and immediately following a criticality accident.

Procedures to determine high' radiation' doses immediately following a criticality accident are described in the Emergency Procedures Manual.

4.9.2 Breathina Zone Monitorin.g Breathing zone monitoring of personnel is conducted in accordance with Section 3.2.5 of Part I of this application.

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1 5.0 OCCUPATIONAL RADIATION EXPOSURES l

Due to the extremely low levels of penetrating radiation which exist at: Combustion Engineering's fuel fabrication facility (<5 mr/hr),

the greatest emphasis in exposure control is directed towards minimizing ingestion of airborne uranium particulate. To this end, 1

C-E strives to maintain internal exposures as low as reasonably

-achievable through the use of ventilated hoods and process j

. containment and an extensive air sampling program. General air samplers are strategically placed throughout the facility to provide indications of airborne activity levels and are analyzed three times each working' day. A bioassay program which includes periodic urinalysis and in-vivo counting also provides information regarding internal deposition of radioactive materials and confirms Combustion Engineering's long standing commitment to the ALARA concept.

5.1 External Radiation Exposures There has not been a single instance throughout the history of license SNM-1067 which has resulted in any individual exceeding the 10 CFR 20 quarterly limit of 1.25 Rem. A statistical summary has been provided herein as Figure 5.1 which indicates more individuals have _been falling into the lower exposure categories over the past 3 years. -The slight increase in the higher categories can be attributed to the higher throughput of uranium in the past 3 years (112 MTU in 1977 to 157 MTU in 1979) and the higher enrichments being processed as utility demand for extended-life cores increases.

(License SNM-1067 was amended in 1988 to allow an increase in the Docket No. 70-1100 Rev. 04 Date: 06/23/89 License No. SNM-1067 Page 11.5-1

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maximum allowable enrichment to 5.0wt% U235).

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5.2-Internal Radiation Exposures The most: accurate results concerning actual internal deposition of radionuclides are found in bioassay results.

The accuracy of these results far exceeds the accuracy obtained from personnel breathing zone air samples (BZ's), since BZ samples serve only as an immediate aid in assessing internal exposure potential and do not conclusively indicate that the material was actually ingested.

During the past 3 years, all urinalysis results were less than 1 microgram U/ liter (the lower limit of detection for our fluorometric method of analysis) with 3 exceptions in 1978 where individuals' results were 2, 3, and 4 micrograms U/ liter respectively.

In-vivo lung counting results over the past 10 years clearly indicate that no individual has ever received a maximum permissible lung burden (MPLB), which is about 200 ugm U235 for low enriched uranium.

Due to the extreme sensitivity required to detect such low amounts of U235, most results are reported as zero with a statistical accuracy associated with them.

Figure 5.2 is a summary of lung counting for the past 5 years and clearly indicates that the ALARA concept practiced at C-E has paid off.

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5.3.

General Air Samplina Results.

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Results in graphic form are shown for all air sampling stations in Figure 5.3 thru 5.8.

All results are below 15% of MPCa for q

restricted areas (0.0000000001 uC1/cc) and most results are well below 10% of MPC. The only results which were slightly over 15% of MPC are explained below:

2) tiarch 1980 - Powder Prep Station #1 and Presses 1 and 2 (Figures 5.3 and 5.4). The pellet shop had been undergoing'a complete cleanup prior to an enrichment change at this time.

Our license action limit was exceeded four (4) times.

an investigation ' revealed that the sample heads were colliding with'a nearby vacuuming hose which was highly contaminated.

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June 1978 - Powder Prep Station #1 (Figure 5.3).

Several powder-lot cleanups caused rapid plugging of hood filters and reduced ventilation at the time.

Problems were also encountered with the granulator screen and the belt dryer.

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