ML20246N958
| ML20246N958 | |
| Person / Time | |
|---|---|
| Site: | 07000754 |
| Issue date: | 04/21/1989 |
| From: | Cunningham G GENERAL ELECTRIC CO. |
| To: | Rouse L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20246N964 | List: |
| References | |
| 25448, NUDOCS 8905220042 | |
| Download: ML20246N958 (34) | |
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Attention:
L. C. Rouse, Chief f0 w
Fuel Cycle Safety Branch Referr.nce: License SNM-960, Docket 70-754
Dear Mr. Rouse:
0 The General Electric Company, Vallecitos Nuclear Center (VNC) requests the renewal of License SNM-960, including the Materials and Plant Protection Amendment issued pursuant to Parts 70 and 73.
In support of this request, VNC submits the enclosed application consisting of a set of proposed license
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conditions (Appendix A) and a description of the site facilities and activities.
Both parts of the application are updates of the documents submitted in 1984 for the previous renewal of the license.
The revisions reflect the reduced activities at VNC.
Because large organizations such as the General Electric Nuclear Energy group are subject to frequent changes, it did not seem appropriate to include detailed organization charts as license conditions. Accordingly, Section 4.7 has been deleted from Appendix A.
This deletion does not modify the license requirement that the nuclear safety function be independent of operations.
Also deleted from Appendix A is Table 1.
This table was originally intended as a set of design criteria or guidelines for facilities.
Because of the reduced activities at VNC (particularly the discontinuance of operations with mixed oxides) and the fact that no new major facilities are planned for VNC, this table has become obsolete.
VNC also requests the following modifications to License SNM-960:
I.
Modify Table 1 of Annex C to the license to move Pu-241 to the release category containing Th-232, Sr-90, and I-131.
As Pu-241 is basically a
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beta emitter (alpha accounts for only 0.00245%. of all decays), it should i
not be included with the more hazardous alpha-emitting transuranic.
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.USNRC April 21, 1989 The difference in the relative hazard between Pu-241 and other transuranic is already recognized in Table A-1 of Appendix A to 10CFR71. The A and A values for Pu-241 are 100 to 500 times higher y
2 than for alpha-emitting transuranic.
Pu-241 does decay to alpha-emitting Am-241.
However, this does not present a problem.
Should a person ingest sufficient Pu-241 to result in a maximum permissible body burden of 0.9 Ci (Report of Committee II on Permissible Dose for Internal Radiation, 1959), after 50 years (ignoring any natural biological eliminations) the total quantity of Am-241 present would be 0,023 pC1, less than one-half the maximum permissible body burden of 0.05 pCi.
A decay / generation chart for Pu-241 and Am 241 is included as Attachment B to this letter.
II.
License Condition 12 to SNM-960 requires VNC to follow the provisions of the Radiological Contingency Plan submitted to the NRC in October, 1982, and subsequent revisions. The recently pub dshed emergency preparedness regulations for fuel cycle facilities (54FR14051) offer an option to demonstrate that a plan is not needed. VNC has evaluated potential accidents and their effects on the surroundings and has concluded that a radiological contingency plan is not necessary. VNC requests that Condition 12 be deleted. The basis for the request is contained in Attachment C to this letter.
A check for $150.00 for the renewal application fee is enclosed.
If you or your staff have any questions concerning this application, please contact me at (415) 862-4330. Thank you.
Sincerely, h
G. E. Cunningham Senior Licensing Engineer
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~ Attachment A Ano11 cation For Renewal of License SNM-960
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.Includina Provosed License Conditions i
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LICENSE CONDITIONS FOR THE VALLECITOS NUCLEAR CENTER APPENDIX A LICENSE SNM-960 DOCKET 70-754 i
i GENERAL ELECTRIC COMPANY VALLECITOS NUCLEAR CENTER P.O. BOX 460 PLEASANTON, CA 94566
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CONTENTS W
Section Zagg I
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1.0 AUTHORIZED ACTIVITIES A-1-1
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1.1 Product Processing Operations................................... A-1-1 1.2 Laboratory operations........................................... A-1-1 1.3 Ceneral Services Operations..................................... A-1-2 1.4 Waste Treatment................................................. A-1-3 1
2.0 POSSESSION LIMITS A-2-1 3.0 DEFINITIONS-A-3-1 3.1 Area Manager.................................................... A-3-1 Array......................................................... A-3-l' 3.2 3.3 Criticality Area................................................ A-3-1 3.4 Criticality Contro1............................................. A-3-1 3.5 Criticality Limit Area.......................................... A-3-1 3.6 Fissile Material Accumulation................................... A-3-1 3.7 Full Reflection................................................. A-3-1 3.8 Homogeneous System............................................... A-3-1 3.9-Heterogeneous System............................................ A-3-2 3.10 Normally Suberitical Va1uos..................................... A-3-2 3.11 Nuclear Energy operations....................................... A-3-2 3.12 Nuclear Safety.................................................. A-3-2 3.13 Safe Batch...................................................... A-3-2 3.14 Special Nuclear Materia1...........................,............ A-3-2 3.15 Suberitical Area................................................ A-3-2 4.0 GENERAL ADMINISTRATIVE REQUIREMENTS A-4-1 4.1 Area Managers................................................... A 4-1 4.2 Criticality Safety Component.................................... A-4-1 4.3 Radiation Safety Component...................................... A 4-2 4.4 Vallecitos Technological Safety Counci1......................... A 4-3 4.5 Compliance Policy............................................... A 4-4 4.6 Change Procedures............................................... A-4-4 5.0 CRITICALITY CONTROL ADMINISTRATIVE REQUIREMENTS A-5-1 5.1 Procedures...................................................... A 5-1 5.2 Analysis Request................................................ A-5-1 5.3 Criticality control Analysis.................................... A-5-1 5.4 Neutron Physics Advice.......................................... A 5-2 5.5 Verification of Criticality Safety Analysis Results............. A 5-2 5.6 Records......................................................... A-5-2 5.7 Criticality Control Inspections................................. A-5-2 5.8 Training Program................................................ A 5-3 5.9 Monitor Alarm System............................................ A-5-4 Uernse No. SNM-960 DodetNo.70-754 Sect. No.
Contents pg i APPENDIX A pets 3/27/89 A,n.ng s es.(o
Section Eagg 6.0 CRITICALITY CONTROL CONDITIONS -
TECHNICAL AND ANALYTICAL REQUIREMENTS A-6-1 6.1 Ceneral Requirements............................................ A-6-1 6.2 Calculative Methods............................................. A-6-1 6.3 Normally Suberitical Values - Individual Accumulations.......... A 6-2 6.4 Normally Suberitical Values - Interacting Accumulations......... A-6-3 6.5 Inte gri ty o f S truc ture s......................................... A-6 -4 6.6 Optimum Conditions of Moderation and Reflection................. A-6-4 6.7 Conditions of Moderation Other Than 0ptimum..................... A-6-5 6.8 Conditions of Reflection Other Than Full Reflection............. A 6-5 6.9 Moderators...................................................... A-6-6 6.10 Nuclear Isolation............................................... A-6-6 7.0 RADIATION CONTROL ADMINISTRATIVE REQUIREMENTS A-7-1 7.1 Radiation Standards............................................. A-7-1 7.2 Radiation Control Inspection.................................... A-7-1 7.3 Radiation Safety Training....................................... A-7-1 8.0 RADIATION CONTROL CONDITIONS -
TECHNICAL AND OPERATING REQUIREMENTS A-8-1 8.1 Air Contamination Contro1....................................... A-8-1 8.2 Instrument Capability........................................... A-8-2 8.3 Contamination Detection......................................... A-8-2 8.4 Sample Detection................................................ A-8-2 8.5 Exposure Detection.............................................. A-8-3 8.6 Instrument Calibration.......................................... A-8-3 8.7 Laboratory Counting Instruments................................. A-8-3
- 8. 8 '
Instrument Check Sources........................................ A-8-3 8.9 Liquid Waste Disposa1........................................... A-8-3 8.10 Airborne Effluent Contro1....................................... A-8-4 8.11 Contamination-Free Articles..................................... A-8-4 8.12 Bioassay........................................................ A-8-5 8.13 High Radiation Alarm Exemption.................................. A-8-5 9.0 ON-SITE TRANSFERS A-9-1 9.1 Type A and Unirradiated SNM..................................... A-9-1 9.2 Type B.......................................................... A-9-1 l
License No. SNM-960 Dodet No.70-754 Sect. No. Contents Page 11 APPENDIX A Dets 3/27/89 Amends Sect.(s) f
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. LICENSE COFDITIONS FOR'THE VALLECITOS NUCLEAR CENTER i
Set forth herein are the technical and administrative requirements' proposed for' governing the receipt, possession and use of the special nuclear material.
l and associated by-product material (as defined in Section 2.0 of this
'l'
- Appendix), subject'.to licensing and regulation byl the Nuclear Regulatory Commission, in activities other than reactors at General Electric's Vallecitos Nuclear. Center near Pleasanton, California.
1.0 AUTHORIZED ACTIVITIES The following types of activities are authorized.
3 1.1 PRODUCT PROCESSING OPERATIONS Assembly,' modification, cleaning and repair of unirradiated encapsulated experimental assemblies.
1.2-LABORATORY OPERATIONS 1.2.1 Chemical Analysis of the chemical and isotopic composition, concentration and behavior of special nuclear materials by wet chemistry and physical measurement techniques.
1.2.2; Meta 11urrig31 Physical analyses and testing of physical and metallurgical properties of special nuclear materials.
i Lammes No. SNM-960 Docket No.70-754 Sect. No.
1.0 Page APPENDIX A Date 3/27/89 Amends sect.(s)
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1.2.3 Physics and Health Physics i
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' Measurements of radiation and its effects on instruments and on the structure and composition of materials.
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1.2.4' Hot Laboratories a
Post-irradiation examination, testing, and analysis of fuel elements and materials in shielded enclosures by remote manipulative techniques; research and development and/or pilot plant activities.
1.2.5 Research and Development Including but not limited to the above.
1.3 CENERAL SERVICES OPERATIONS 1.3.1 Eauiement Maintenance and Engineering Design, fabrication, and testing of equipment containing special nuclear materials and maintenance of such equipment.
1.3.2 Storare Storage of special nuclear materials other than wastes in shielded containers and/or at locat. ions as applicable and in designated general purpose storage areas.
1.3.3 Transportation and Transfer Inspection of packaging and preparation for shipment and/or transfer of special nuclear materials.
- L,icense No. SIM-960 Dodet No.70-754 Sect. No.
1.0 Page APPENDIX A pote 3/27/89 Amends Sect.(s)
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a 1.3.4 Decontamination l
Decontamination of' equipment and facilities.
Y 1.4 WASTE TREATMENT 1.4.1 Linuids Concentration of the' radioactive constituents of liquid wastes by
. evaporation, chemical treatment, sedimentation, filtration, and ion exchange; solidification and packaging of concentrates for disposal.
l 1.4.2-Solids Packaging' cnd storage of wastes contaminated with or containing nonreclaimable special nuclear materials, excluding direct burial in soil.
. License No. SNM-960 Docket No.70-754 Sect. No 1.O pop
' APPENDlX A Dets 3/27/89 Amends sect.(s)
A-1-3
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2.0 POSSESSION LIMITS The following quantities'of special nuclear materials are authorized at the Vallecitos Nuclear Center.
2.1 U-235
50 kg enriched to less than or equal to lot for authorized activities. The material may be in the form of irradiated special nuclear material with its attendant by-product material and l
l reactor-produced transuranic.
2.2 IL-211
4 kg enriched to more than 10% for authorized activities. The material may be in the form of irradiated special nuclear material with its attendant by product and reactor-produced transuranic.
2.3 Plutonium
100 grams in any form in addition to the irradiated l
quantities as referenced in Subsections 2.1 and 2.2 above.
2.4 U-233
100 grams in any form.
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I 2.0 70-754 Sect. h.
Pee Osense No. SNM 960 Docket No.
A-2-1 APPENDIX A Dets 3/27/89 m sect.M
3.0 DEFINITIONS As used in the proposed license conditions set forth herein:
3.1 Area Manarer means the lowest supervisory position fully responsible for the specific activity or function with which the term is l
associated. The generic term " Area Manager" does not necessarily refer to the title of any specific position in General Electric's system of organization and position nomenclature.
3.2 Array means two or more interacting fissile material accumulations.
3.3 Criticality Area means any physically identified area or location within which fissile materials are handled under the direction of a single area manager. A criticality area may include more than one criticality limit area.
3.4 Criticality contr21 means the administrative and technical requirements established to minimize the possibility of achieving inadvertent criticality in the environment analyzed.
3.5 criticality Limit Area means a designated and physically identifiable locality within which a specific set of criticality control limits governs the use of fissile materials.
3.6 Fissile Material Accumulation means any single accumulation of fissile material; for example, one can of UO2 p wder, one can of fuel pellets, or one fuel element.
3.7 Full Reflection means that degree of reflection equivalent to a tight-fitting shell of greater than 12 inches of water.
3.8 Honoreneous System means a system containing compounds of fissile materials in the form of uniformly distributed particles and fissile compounds in solution.
Ucense No. SNM-960 Dodet No.70-754 sect. h.
3.0 p,
APPENDIX A Dets 3/27/89 Aanends Sect.(s)
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Heterogeneous System means a system containing compounds of fissile 3.9 7
materials in the form of clumped fissile. compounds (e.g., fuel rods in water).
L 3.10. Normally Suberitical Values means those maximum values which provide safety under normal conditions of operation. Further adjustment of such values may be necessary to incorporate safety margins for the activity as it is' conducted in the plant allowing for' credible mishaps
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that could occur in the actual plant situation.
3.11 Nuclear Enerry Doerations means those components of the Genersi l
Electric Company engaged in the various aspects of nuclear energy and p
does not refer to a specific component by title.
3.12 Nuclear Safety means that field of safety comprised of criticality safety and radiation safety.
3;13 Kaft..Bal;sh means an accumulation of fissile material which is 45% of l
the critica1' accumulation considering enrichment, full reflection, and optimum water moderation consistent with the form of the material.
3.14 Soecial Nuclear Material means plutonium, Uranium-233, Uranium-235, or any material artificially enriched by any of the foregoing.
3.15 Suberitical Area means a physically identified area or location l
involving special nuclear materials in quantities of less than 500 grams of U-235, 300 grams of U-233, or 300 grams of plutonium or a prorated combination of such materials under the direction of a single area manager and which is unrelated to any other area where special nuclear materials are handled. A suberitical area is considered unrelated when it meets the isolation requirements of Section 6.10 of this Appendix and is not located in the same room.
3.0 psy Usenn No.
A-3-2 APPENDIX A pses 3/27/89 Anunds Seeds)_
'4.0 GENERAL ADMINISTRATIVE REQUIREMENTS 1
i 4.1 AREA MANAGERS Orerations and activities'in a specific criticality area or radiation area l
shall be directed by the 'esignated area manager.
The responsibility for d
safe operation and control of activities in the area and for.the safety of the environs as influenced by the activities conducted therein shall be
. vested in this position. An area manager shall be proficient in the application of the VNC radiation protection program as it relates to limitations and radiological controls on work activities in his assigned radiation or radioactive materials area. Additionally, each area manager of a criticality area shall be proficient in the application of criticality control procedures and be knowledgeable in the procedures applicable to the criticality area under his management.
4.2 CRITICALITY SAFETY COMPONENT The Criticality Safety component is defined as that component with designated l
responsibility to provide authoritative professional advice and counsel to area managers on matters of control against accidental criticality and to measure the effectiveness of the criticality control program.
4.2.1 JThe functions of the Criticality Safety component shall exclude direct responsibility for operations involving the use of fissile materials, and the Criticality Safety component shall not report to an area manager responsible for an area where fissile material is handled other than a suberitical area.
4.2.2 The Criticality Safety component shall include at least one technically trained person with a bachelor's degree in science or engineering and three years experience in the nuclear field, including one year of directly relevant criticality safety 4.0
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70 754 g,,,, g,,
SNM-960 Dodet No.
Usenes No.
A-4-1 APPENDtX A.
Osas 3/27/89 a,,wne Sect.(s)
experience. Should the Criticality Safaty component lack the one year of experience, all analyses for the interim period until the experience is achieved shall be verified by two of the individuals described in 5.5 or by the physics advice function in 5.4 of this Appendix.
4.2.3 The manager of the Criticality Safety component shall hold a
' bachelor's degree in science or engineering and have at least five years experience in a responsible position in a nuclear field such as engineering, physics, or chemistry.
4.3 RADIATION SAFETY COMPONENT The Radiation Safety component is defined as that couponent with designated responsibility to provide authoritative professional advice and counsel to area managers at the Vallecitos Nuclear Center on matters of radiation protection and A1 ARA and to measure the effectiveness of the radiation protection program.
4.3.1 The functions of the Radiation Safety component shall exclude direct responsibility for operationn involving the manufacture of nuclear products or processing of nuclear materials. The Radiation Safety component shall be responsible to establish and maintain the l
radiation safety program to ensure the protection of employees at the l
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Vallecitos Nuclear Center and of the community. The radiation safety l
l-program shall include as a minimum: the evaluation of release of I
radioactive effluents and materials from the site, establishment of procedures and training programs to control contamination and exposure to individuals, the review of calibration and maintenance activities for radiation detection instruments, maintenance of appropriate records and reports, review of radioactive material handling practices, and review of change procedures (see Section 4.6), including ALARA considerations.
usene No. SNM-960 Docket No.70-754 et. No.
4.0 Pep l
APPENDIX A Date 3/27/89 Amends Sect.(s)
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<4.3.2 Theminimumqualificationsokpersonnelassignedfunctional responsibilities in the Radiation Safety component shall be as:
follows:-
4 Manager: LB.S. degree:in science or engineering with five years
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experience in' assignments involving radiation protection, b.
Specialists:
B.S. degree in science or engineering with two, years experience in assignments involving radiation protection
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- or eight years of experience in health physics or radiation
-protection, c.
Monitors: High school with two years experience in handling.
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radioactivematerialsortwoyearsofcollege-an[fourmonths experience;'also,' successful completion of a General Electric k
certification program which includes written and oral examinations covering radiation protection procedures and/or n
criticality procedures.
4.4 VALLECITOS TECHNOIDGICAL SAFETY COUNCIL The functions of the Vallecitos Technological Safety Council (VTSC) shall
' include responsibility-for review of reportable incidents, new facilities or major changes to facilities, and for contributing professional advice and counsel on criticality'and radiation safety policy. The VTSC shall review annually the site safety and compliance program performance to include I
effluent releases and occupational exposures in terms of ALARA and focus on trends for corrective action as necessary.
l Its deliberations in any calendar quarter shall be reported in writing to the l
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Manager. Irradiation Processing, and retained two years.
Should the VTSC l
4 choose not.to meet in any calendar quarter, the Manager, Irradiation Processing, shall be notified in writing. The Vallecitos Technological l
. Safety Council shall consist of at least five senior members of General
. Electric's technical and/or management personnel appointed by the Manager, Irradiation Processing, and shall include competence in the physics, chemistry, and engineering disciplines.
WasnesNo. SNM-960 Dodot No.70-754 Sect.Ne, 4.0 Page APPENDIX A gen 3/27/89 Amends Sect.(s)
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.4.5 COMPLIANCE POLICY s',
I General Electric shall establish and maintain a policy statement in writing expressing requirements for compliance with the terms and conditions.of
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l special nuclear materials licenses and applicable NRC regulations. Each area-manager shall know and understand the provisions of this policy.
4.6 CHANGE PROCEDURES Activities which do'not involve a change in license conditions but which require procedures, facilities, or equipment substantially different from 1
those.previously used shall not be initiated until the Radiation Safety
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component has completed a' review and technical evaluation to assure adequacy of health.and safety features and compliance with license conditions and
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AIARA policy where applicable.
In a criticality limit area, such activities shall not be initiated until the Criticality Safety component has completed a criticality analysis or a review of the existing criticality analysis for the proposed activity.
Such changed activities shall be initiated in accordance with written procedures issued by the area manager.
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l SNM-960 Doaket No.70-754 Sect. No.
4.0 Page m g.,
AMENDIX A Osts 3/27/89 Amends Sect.(s)
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'5.0
' CRITICALITY CONTROL ADMINISTRATIVE' REQUIREMENTS
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5.1f.PROCEDCRES Area' managers shall develop and maintain written criticality control
. procedures incorporating limitations established by the Criticality Safety.
component and'shall assure that these procedures are made readily available
. to concerned personnel through posting of limits or other appropriate-
. notifications.
5. 2'
- ANALYSIS REQUEST
'A request for criticality. analysis or. review of existing analyses'shall be~-
.l prepared in writing by, or under the direction of, an area manager'for any activity-or change in activity; requiring a change in criticality controls or changes in environment of possible consequence to criticality safety. The activity or change shall not be initiated until receipt of an approved-criticality analysis or documentation of a review.
l 5.3-CRITICALITY CONTROL ANALYSIS-Qualified individuals of the Criticality Safety component shall be
. responsible for the establishment of safe batches, safe geometries, safe l
concentrations, safe spacing of special nuclear materials, and limitations of I
other nuclear parameters utilizing information set forth in the request for criticality analysis and verification and assessment of normal and potential environmental conditions of significance to criticality control.
5.0 Page SNM-960 70-754 Sect. No.
Usense No.
Doeket No.
APPENDIX A
> 3/27/89 A,nens Sect.4)
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m 5.4 NEUTRON PHYSICS ADVICE An organizational component competent in neutron physics and the technical methods for criticality computations shall verify the use of any new J
computational methods for criticality control. This component also shall provide technical review and verification of criticality safety analyses as q
I requested by the manager of the Criticality Safety component pursuant to 5.5.
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5.5 VERIFICATION OF CRITICALITY SAFETY ANALYSIS RESULTS
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The manager of the Criticality Safety component shall assure that the results of criticality analyses are reviewed. This review may be performed by the manager of the Criticality Safety component provided he has acquired a minimum of two years experience in the methods used or by a member of the Criticality Safety component other than the individual who performed the analysis or an independent reviewer of equivalent education and experience.
The neutron physics advice function (5.4) may provide technical review of computation methods. The review need not involve a recalculation of the results.
5.6 RECORDS Records of criticality control analyses shall be maintained in sufficient detail and form to permit independent review of the method of calculation and results.
Such records shall be retained for a period of at least six months following the cessation of activities to which they apply.
5.7 CRITICALITY CONTROL INSPECTIONS 5.7.1 The Radiation Safety component shall be responsible for inspecting each criticality area on an ongoing basis to assure compliance with criticality control procedures.
Items to be inspected shall include, but not be limited to, the posting of criticality control limits, the Usense No. SNM-960 Docket No.70-754 Sect. No.
5.O p,
APPENDIX A pets 3/27/89 Amends Sect.(s)
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hI It labeling of:SNK containers with information needed for criticality
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o lb control purposes, the movement of SNM, and general criticality safety l:
. work' practices.-
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L 45.7, 2 A" program of inspection shall be performed by the Criticality Safety i
component to determine that actual operations conform to the physical l
situations on which the calculations of criticality limits have;been j
based.
Inspection reports shall be furnished to area managers.
Where situations are identified.which requir's corrective action, such reports shall so indicate.- Corrective or follow-up action shall be taken in accordance with VNC Safety Standards and/or site Nuclear Safety Procedures.
" Operations which handle routinely in process more than-one; safe batch (as defined in Section 3.13) of fissile material shall be inspected.
l' on a quarterly basis. All operations shall be inspected on an annual' basis.
3.8 ' 2 TRAINING PROGRAM
'F Area managers shall assure that new employees receive instruction in
~ criticality safety and plant operating and emergency procedures prior to their working with special nuclear materials. A criticality control training program, approved by the Criticality Safety component, shall be maintained to emphasize.the need for following criticality control procedures and to aid personnel in understanding the various parameters which are essential to the maintenance of suberitical conditions. The program may be conducted by the Criticality Safety component, some other portion of the Nuclear Safety component, or combined with training performed by operating components. It may be combined with radiation safety training. A written test shall be completed by each employee taking the course. The test shall be evaluated and the'results forwarded to the appropriate area manager.
1 Lisense No, - SNM-960 Doaket No,_
70-754 Sect. No.
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- 5.9 MONITOR ALARM SYSTEM 1
. 5.9.1 No transfers of fissile materials between criticality limit areas shall be permitted in criticality areas required to have a monitor
-alarm system unless the system is operable. Transfers may resume.
following repair and verification of the monitoring system's operability.
5.9.2-
. Exemption from the' monitor alarm requirement of Section 70.24(a)(2) of 10CFR70 is granted for the Remote Handling Operation (RHO) pool l
and hot cells.,At the high-level solid waste storage facility and th9 storage pit in the RHO pool area, for the purpose of compliance l
with 70.24(a)(2) of 10CFR70, the source of a possible accidental
- condition of criticality may be considered as the accessible surface of the' earth or concrete shielding.
5.9.3 Specific exemption from the prescribed prese't alarm points (5 to 20 mrem /h) is~ granted for those monitoring devices where the routine movement of by-product materials could result in gamma fields at the monitoring devices in excess of those that would result in a dose
- 3 rate of 20 mR/h. Further, the alarm setting for these monitoring de' vices under the above conditions ~shall not exceed 500 mrem /h.
5.9.4 Exemption'from the. requirements of Section 70.24 of 10CFR70 is granted for each area in which there is not more than one shipment of packages containing special nuclear materials licensed pursuant to 10 CFR Part 71 for transport outside the confines of the Vallecitos Nuclear Center (packages in any shipment which depend on special arrangement for nuclear safety shall be retained in that same arrangement during such storage); or one safe batch of finished l
reactor fuel rods or assemblies, providing no activities could cause rearrangement of fuel-bearing portions into more reactive configurations; or which meets the requirements of a suberitical area as defined in Section 3.15 of this Appendix.
l h No.'SNM 960 m No.70-754 Gen.No.
5.0 Pep APPENDIX A
> 3/27/89 A,,wnds Sea.gg A-5-4
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6.0 CRITICALITY CONTROL CONDITIONS TECHNICAL AND ANALYTICAL REQUIREMENTS h
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6.1l CENERAL REQUIREMENTS _
Criticality controls;shall be based on the normal environmental conditions in the criticality area and also on all credible abnormal conditions that could affect the criticality safety.in that area. These factors shall include but not necessarily be limited to moderation, reflection,-neutronic interaction,
. fissile material accumulation size, physical form, chemical and isotopic composition, nuclear poisons, density, concentration, reliability of equipment, type of operation, and training and supervision of operating personnel.
In evaluating the suberiticality of individual accumulations,' process v
configurations, or arrays of fissile material, the two-contingency criterion shall be applied; that is, two unlikely, independent'and concurrent accidents
.or changes in process conditions must occur before criticality is credible, 6.2 CALCULATIVE METHODS Criticality analyses shall utilize calculative methods that have been validated by the calculation of models of critical experiments of similar
. geometrical configuration and material content; the maximum negative bias in the multiplication factor, defined as (-Akbias) - calculation experiment' determined in the validation shall be applied to the analysis as given in the l.
' relationship below. The effective multiplication factor of the accumulation l
or array of accumulations shall satisfy the relationship:
+ (-Akbias} S *"
k,,3 + Akuncertainty where:
k,,1 is the calculated effective multiplication factor by the l
calculative method, and Ak is the statistical uncertainty (2a) in uncertainty the mean value of the calculated effective multiplication factor, and l
6.0 70-754 sen. No.
SNM-960 Dodet No.
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A-6-1 APPENOtX A pse 3/27/89 A,vene fen.W
(-Akb bs) is the maximum negative bias determined from the validation of the calculative method. Ifthebiasispositive,the(-Agg,,)termshallnotbe used, so that overstatements in the effective multiplication factor shall not l
be corrected.
Calculative methods shall be subject to independent review and verification by persons with demonstrated competence in neutron physics computations before use.
6.3 NORMA 11Y SUBCRITICAL VALUES - INDIVIDUAL ACCUMULATIONS Facilities and processes involving the accumulations listed below shall adhere to the two-contingency principle (Section 6.1).
The twr-contingency principle may be achieved through physical constraints and inventory controls or a combination thereof.
Normally suberitical values of nuclear parameters for individual accumulations under normal operating conditions shall be as shown below except that the effective multiplication factor shall not exceed 0.95 in any l
case.
6.3.1 For accumulations limited by mass, the normally suberitical mass shall not exceed 74% of the critical mass.
6.3.2 Not more than 45% of the critical mass shall be contained in any accumulation in a criticality limit area in which double batching is credible.
6.3.3 For accumulations limited by volume, the normally suberitical volume shall not exceed 76% of the critical volume.
6.3.4 For accumulations limited by dimension, the normally suberitical cylinder diameter or slab thickness shall not exceed 90% or 88%,
respectively, of the critical dimension where U-235 is the fissile constituent, nor 85% in all other cases.
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APPENDIX A Osw 3/27/89 m s.es.(s)
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6.3.5 For accumulations limited by concentration, the normally suberitical concentration shall be less than that concentration which is equivalent to the following atomic ratios of hydrogen to fissile material: H/U-235, 5200; H/U-233, 7600; and H/Pu (fissile), 7600.
6.3.6 Accumulations limited by the effective multiplication factor shall be l
limited by Section 6.2.
6.4 NORMALLY SUBCRITICAL VALUES - INTERACTING ACCUMU1ATIONS Facilities and processes involving arrays of fissile materials shall adhere to the two-contingency principle (Section 6.1).
The two-contingency principle may be achieved through physical constraints and inventory controls or a combination thereof.
Normally suberitical (as defined in Section 3.10) numbers of interacting accumulations shall be as listed below except that the effective l
multiplication factor for the array shall not exceed 0.95.
6.4.1 Not more than 69% of the critical number of accumulations whenever the critical number has been determined by experine nt; or 6.4.2 Not more than 50% of the critical number of accumulations in any array calculated by the density analog method (Ref: ARH-600); or 6.4.3 The number of accumulations determined by the solid angle method as l
described in TID-7016, Rev. 2, Paragraphs 4.29 through 4.34.
The method may be applied only to accumulations that are well moderated (e.g., aqueous solutions) at the point of the maximum multiplication factor, and array reflection must be no more effective than a thick water reflector spaced at distances from the accumulations comparable to the spacing between accumulations.
1 6.4.4 Interacting accumulations limited by the multiplication factor shall be limited by Section 6.2.
SNM-960 Dodet No.70-754 Sect. No.
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q 6.5 INTEGRITY OF STRUCTURES f
6.5.1 ? Whenever criticality control is directly dependent on the integrity i
of a structure used to retain a special nuclear material storage l
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' array, the structure will be designed with an adequate strength i
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' factor to assure against failure under foreseeable loads or accident L ~
conditions. Materials of construction will be selected to resist fire, and the degree to which any corrosive environment might affect nuclear safety will be considered and corrosion-resistant materials or coatings applied as necessary. The design shall be reviewed by a qualified engineer.
6.5.2
. Whenever criticality control is directly dependent on the integrity of a neutron isolating structure, the structure will be designed to assure against loss of integrity through foreseeable accident conditions such as fire, impact, melting, corrosion or leakage of
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- materials. The design shall be reviewed by a qualified engineer.
6.6 OPTIMUM CONDITIONS OF MODERATION AND REFLECTION Unless. moderation or reflection is controlled by physical and administrative means.in accordance with Sections 6.7 or 6.8 below, calculations of i
criticality control limits shall be made assuming that optimum light-water moderation and full reflection by light water exist, consistent with the form of the fissile material and its container. When mass limitation is to be employed for criticality control of an accumulation of fissile material, optimum moderation is that degree of moderation which minimizes the mass of material that is required to achieve criticality. When a geometric limitation is to be employed for criticality control of an accumulation of fissile material, optimum moderation is that degree of moderation which
. maximizes the material buckling.
Usense No. SNM-960 Dodet No.70-754 Sect. No.
6.O Page APPENDlX A Oste 3/27/89 Amens Sect.(s)
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6.7 CONDITIONS OF WODERATION OTHER THAN OPTIMUM.
Notwithstanding Section 6.6 above, criticality control limits may be based on conditions of moderation other.than optimum when all of the applicable l,
following conditions exist:
- 6. 7.1 - The fissile material specifications require the~ state of moderation be greater or less than optimum.
6.7.2 No single credible mishap will result in a more' effective degree of moderation than assumed in the specific criticality analysis.
6.7.3 The undermoderated matoris', accumulation is either contained within a noncombustible water barrier, or of such physical form and natural arrangement that the application of water cannot in any credible -
' mishap result in a more effective degree of moderation than that assumed.in the specific criticality analysis.
'6.7.4' The overmoderated. fissile material accumulation is assayed and periodically inspected or sampled to assure the proper chemical concentration and' composition are maintained.
6.8' CONDITIONS OF REFLECTION OTHER THAN FULL REFLECTION Notwithstanding Section 6.6 above, criticality control limits may be based on less than full reflection when all of the following conditions are satisfied:
16.8.1 The fissile material environment provides the unreflected condition or a specific degree less than fully reflected.
6.8.2 The environment of the fissile material is such that more effective reflection cannot occur through a single credible mishap.
Wasnes No. SNM-960 Dodet No.,70-754 Sect. No.
6.0 pop APPENDIX A Does_ 3/27/89 Amenei Sect.(s)
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=6.8.3 The ' fissile material accumulation.is within a structure that will preclude more effective reflection by yersonnel or other objects in the environment.
6.9 MODERATORS-y If special nuclear materials are to be stored, handled or used in the
- presence of heavy water, beryllium or graphite, possible moderating and reflecting effects of those materials shall be considered.
6.10 NUCLEAR IS01ATION '
Two accumulations or arrays of accumulations may be considered as being nuclearly isolated from each other only if an edge-to-edge separation exists
'which is not less than one of the following or its nuclear equivalent:
6.10.1 Twelve' inches of water.
6.10.2. The larger of 12 feet.or the greatest distance across an orthographic projection of either accumulation or array on a plane perpendicular to a line joining their centers.
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h Uame No. SNM-960 Doaket No.70-754 gect. No.
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w 7.0 RADIATION CONTROL ADMINISTRATIVE REQUIREMENTS
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7.1. RADIATION STANDARDS General Electric shall establish and maintain a comprehensive set of
. standards for operational health and safety, including ALARA considerations.
Such standards shallLbe. reviewed by the Radiation Safety. component and the.
. appropriate, area managers prior to issuance. The Radiation Safety component-
- shall review the standards biennially thereafter.
7.2' RADIATION CONTROL 7NSPECTION~
Activities involving special nuclear material shall be' inspected by the Radiation Safety component on a continuing basis. Conditions of an unusual or uncertain nature that could lead to radiological health and. safety problems shall_be referred to the area manager immediately for correction.
7.3 RADIATION' SAFETY TRAINING A training program in radiation protection shall be in effect and shall include training in the requirements of 10CFR19 and 10CFR20, methods of
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- controlling radiation exposure, license requirements, protective methods, and basics of radiation effects. All personnel working in radioactive materials areas or in radiation areas shell receive an indoctrination lecture prior to starting work followed by additional training, including periodic re-training, cosusensurate with the work environment as determined by the area manager.
Lassnes No. SNM-960 Doaket No.
70 754 Emet.No.
7.0 Pap
. APPENDIX A Dets 3/27/89 Amends Sect.(d A+7-1
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8.0 RADIATION CONTROL CONDITIONS -
TECHNICAL AND OPERATING REQUIREMENTS n
1 8.1 AIR CONTAMINATION CONTROL F.
The following design criteria for ventilation systems shall be used to i
N provide air. contamination control.
i 8.1.1 Airflow shall be from areas of lesser contamination to areas of higher contamination. Potential accident conditions shall be considered.
8.1.2 Duct flow velocities and design shall be such to minimize possible accumulation of contamination.
8.1.3 Air shall be sampled routinely in work areas with potential airborne contamination.
8.1.4 In general, potential airborne radioactivity-producing operations shall utilize close-capture ventilation devices, e.g., hoods, glove boxes, and high-velocity local exhaust.
8.1.5 All.HEPA filters shall be fire resistant.
8.1.6 All ventilation exhaust systems for facilities that routinely handle dispersible radioactive materials in quantities in excess of the lhaits specified in Appendix C of 10CFR20 shall be sampled continuously as proof of filter performance.
l 8.1.7 At least one filter in each such stream (8.1.6) shall be equipped with a device for measuring differential pressure that shall be read monthly. Filters shall be changed when readings deviate from
' specification values or following evidence of damage.
^ Wnes No. SNM-960 Doeket No.70-754 Sect. No.
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l' ii 8.2 INSTRUMENT CAPABILITY' l'
-Dose rate range capabilities of portable instrumentation shall include the
- following:
o 1 to 50,000 mR/h gamma c
~ 4 to 200,000 mrad /h beta L
neutrons 1 to 5,000 mrem /h i
8.3 CONTAMINATION DETECTION l
8.3.1 contamination detection capabilities of portable instrumentation l
g shall be:
200 to 300,000 disintegrations per minute alpha twice background to 80,000 counts per minute on a l
beta-gamma Geiger-Mueller counter 8.3.2.
Contamination detection capabilities of portable instrumentation when used.in the smear survey technique shall be 200 disintegrations per minute for alpha and 500 disintegrations per minute beta-gamma.
8.3.3 Detection equipment shall be maintained on site to meet the requirements of Section 8.11 of this Appendix for contamination-free items.
8.4 SAMPLE DETECTION Sample detection capabilities for laboratory analysis of effluents and other samples shall be $ 0.1 times the concentrations specified in 10CFR20, j
Appendix B, Tables I and II.
l Liesme No. SNM-960 Dodet No.70-754 Sect. No.
8.0 Pate APPENDIX A
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8.5i EXPOSURE DETECTION
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' Personnel dosimeters shall be capable of detecting gamma, beta :and x-ray radiation. Additional neutron detection capability shall be available as
. appropriate; In areas of possible accidental _ criticality normally occupied by personnel, equipment shall include detectors-such as indium foil, gold foil, and sulphur to assist in post-accident dose determinations.
t 8.6 INSTRUMENT CALIBRATION l
Portable monitoring' instruments shall be calibrated upon initial acquisition, l-after major maintenance, and at' least annually.
8.7 IABORATORY COUNTING INSTRUMENTS l
Control charts indicating background and efficiency utsing standard sources shall be maintained on'all laboratory instruments used for~ counting health physics samples.
8.8 INSTRUMENT CHECK SOURCES l
q Field check sources shall be available for use in functional response checks of portable radiation-measuring instrumentation.
8.9 LIQUID WASTE DISPOSAL l
Potentially contaminated liquid wastes shall be retained in quarantine, l
sampled and analyzed before relemae to unrestricted areas.
yo,ne No, SNM-960 Doaket No.70-754 Sect. No.
8.0 Pap APPENDIX A Cass 3/27/89 Amends Sect.(s)
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' AIRBORNE EFFLUENT CONTROL 1
r Potentially contaminated airborne effluents shall be released through HEPA filter systems which shall be at least 99.954 efficient for 0.3-micrometer.'
l
' particles..Such effluents shall be limited at the point of release to the
- atmosphere lso that the annual average concentration at the' site boundary does not exce'ed the concentrations specified in 10CFR20, Appendix B,'. Table II, F
Column 1.
The limits at the points of release shall be based on s'X/Q
.' calculation, reconcentration-factors, and the effects of other' site stacks.
If'the environmental sampling program indicates a reconcentration of these materials, the release levels shall be lowered such that the reconcentration trend is reversed.
8.11 CONTAMINATION-FREE ARTICLES j'
Articles,which have been handled, used or stored in areas with a potential for contamination with radioactive materials may be disposed of or transferred to persons not licensed to possess radioactive materials when all-of the following conditions are satisfied:
8.11.1 Either all surfaces are accessible for survey or it is reasonable to l
assume from the design and usage that no radioactive materials could have' contaminated inaccessible surfaces-without having contaminated-the accessible surfaces as well.
8.11.2. Articles are considered contamination free which meet the requirements of Annex C to this license with the exception of the exemption granted in Section 8.11.3.
'8.11.3 An exemption is granted from the provisions of Annex C to this license to include beta-emitting Pu-241 in the same radionuclides group as Sr-90 (i.e., an average unconditional release level of 2
1,000 dpm/100 cm ).
SNM-960 Doaket No.70-754 Sect. No.
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APPENDIX A Dec. 3/27/89 A,nene Sect.(d A-8-4
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8.12 BIGASSAY-
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Persons who work routinely in areas where there is potential for internal deposition of radioactive materials shall be subject to determination of the extent of radioactive materials _ intake by techniques such as analysis of excretia or whole body counting.
8.13 HIGH RADIATION AIARM EXEMPTION Exemption'from the provisions of 20.203(c)(2) of the Commission's regulations is granted for an area or location which is located within the 94-acre inner fenced exclusion area of the Vallecitos site provided such area or location is bounded by a distinctly colored rope or chain providing a barrier where dose rate values are not higher than 100 mR/h and is posted as a High Radiation Area in accordance with 10CFR20.203(c) and is:
8.13 1 used for the temporary storage of strong, weatherproof. containers not exceeding 1,000 mR/h at any point of readily accessible surface; or 8.13.2 an area established for any continuous period of 30 days or less in l
whicle there are contained radioactive materials, the readily accessible surfaces of which do not exceed 1,000.mR/h at any time and which do not exceed 100 mR/h at the barrier.
8.0 p,p 70-754 Sect. No.
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9.0 ON-SITE TRANSFERS 9.1
, TYPE A AND UNIRRADIATED SNM Transfers. of Type A quantities of radioactive materials or transfers of 1
unirradiated SNM between buildings on the VNC site shall be made in such a manner as to limit the probability of any release of radioactive material to i
the environs of the VNC site.
9.2
. TYPE B Transfers of Type B irradiated special nuclear materials with associated by-product materials may be made in containers approved by the NRC pursuant to 10CFR71 but without the crash / fire overpacks or in containers for which
' written and approved procedures have been generated in accordance with Section 4.6 of this Appendix.
Leone No. SNM-960 Doaket No.70-754 Sect. No.
9.0 page APPEND'X A Oste 3/27/89 Amends sect.(s)
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