ML20247L437
| ML20247L437 | |
| Person / Time | |
|---|---|
| Site: | 07000824 |
| Issue date: | 07/17/1989 |
| From: | Christopher Boyd BABCOCK & WILCOX CO. |
| To: | Rouse L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 25769, NUDOCS 8908010247 | |
| Download: ML20247L437 (8) | |
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ATTN: Leland C.
uiFCch Fuel Cycle ' Safety.Branc Division of. Industrial & Medical Nuclear Safety
. Washington, DC 20555
Reference:
- 1) Letter from C. :C. Boyd to L. C. Rouse dated May 19, 1989
- 2) Telecon between C. C. Boyd and S. Soong on July 6 and 13, 1989 concerning Reference 1.
Gentlemen:
The Babcock & Wilcox Company. Naval Nuclear Fuel Division Research Laboratory (NNFD-RL), is providing revisions to our Reference 1 submit-tal as discussed in Reference 2.
An explanation of the revisions is attached along with the actual proposed page changes _ to the specification section of our license.
Changes from the currently approved license application are marked by a vertical line in the right hand margin.
Please replace the corresponding pages in the Reference 1 submittal with the attached pages.
If you should ' have any further questions, please contact me at (804) 522-5753.
Very truly yours, BABC0CK & WILC0X NNFD Research Laboratory f.
Charlie C. Boyd, Jr.
License Administrator
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- Attachments 3ff5 8908010247 890717 25769 PDR ADOCK 07000824 4
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SNM-778 ORGANIZATIONAL AMENDMENT REVISIONS The revisions to our original May 19, 1989 license amendment submittal, as discussed with Mr. Sean Soong of your office on Any G and 13, 1989, are listed below.
Paragraph No. 2.5.8 The qualifications of the Industrial Safety Officer. have been upgraded to include a choice between educational requirements (which were not present before) or experience requirements.
Paragraph No. 2.8.3.1 The industrial safety aspects of the audit.have been added back.
Paragraph No. 2.10 Responsibility for industrial safety records has been added back in a separate subparagraph (No. 2.10.5) on page number 2-12.
Paragraph No. 3.1.1.2 The Industrial Safety Officer has been added to the review process for RWP's.
LIST OF ATTACHED PAGES Page Rev.
Da te 2-6 11 5/89 2-9 11 5/89 2-10 11 5/89 2-12 11 5/89 3-1 11 5/89
[i 2.5.8-Industrial Safety Officer - The Industrial Safety Officer shall have a BS or advanced degree with course work in industrial safety or at least one year's experience in industrial safety.
He shall be familiar with the codes and requirements of. the Occupational Health and Safety Act of 1970 and the National Fire Protection Association.
2.6.9 Nuclear Criticality Safety Officer - The Nuclear Criticality Safety Officer shall have a BS degree in science or engineering.
He must have either two years experience with nuclear criticality safety calculations similar to those associated with site activities or he must have one year's experience with nuclear criticality safety calculations similar to those associated with site activities if he has at least an additional two years' experience in nuclear reactor physics calculations.
2.5.10 Accountability Specialist - The Accountability Specialist shall have at least a high school education and three years' experience in the use of licensed material.
He must demonstrate to Company management his knowledge of the principles necessary for the accountability and safeguarding of special nuclear materials.
2.5.11 Safety Review Committee - The SRC membership, as a body, shall have expertise in chemistry, nuclear physics, health physics, and the safe handling of radioactive material.
The SRC membership shall have a general understanding of nuclear criticality safety as it pertains to site operation.
2.6 TRAINING 2.6.1 Program 1 - This course is presented to site workers and non-site workers who will be granted access to the restricted area but who will not be granted unescorted access to the controlled areas. The course provides an introduction to radiation and radioactivity (understandable to a non-technical person) and a thorough coverage of safety rules and procedures, including the site emergency pro-cedures. The Supervisor, Health Physics may modify the course l
content for those individ8als knowledgeable in the basics of radi-ation and radioactivity.
However, safety rules, procedures, and emergency procedures that apply at the site shall be covered.
2.6.2 Program 2 - This course is presented to site workers and non-site workers who will be granted unescorted access to the restricted area and controlled areas but who will not be permitted to work with radioactive materials without supervision. The Supervisor, Health Physics may modify the course content for those individuals J
License No SNM 778 Docket No.70-824 Date "Y'
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II 2-6 Amendment No.
Revision No.
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r al ternate. The designated alternate for a Health Physicist must I
meet the minimum qualifications'specified in Sections 2.5.7.
The designated alternate for the Nuclear Criticality Safety Officer must meet the same minimum qualifications specified in Section 2.5.9.
Approval signatures shall appear on the procedure.
I 2.8 INTERNAL AUDITS AND INSPECTIONS 2.8.1 Nuclear Criticality Safety 2.8.1.1 The Nuclear Criticality Safety Officer or his designated alternate shall conduct internal audits for the purpose of evaluating the nuclear criticality safety aspects of operations. This audit shall be conducted in accordance with written audit guidance.
This audit shall be conducted once each calendar quarter. A report of his findings shall be made to the Manager, SS within two l
l weeks of completing the audit. The audit reports shall be forwarded to the Licensing & Compliance Officer. The Licensing &
Compliance Officer shall be responsible for assuring that the appropriate corrective actions are taken to address the audit findings.
2.8.1.2 The Licensing & Compliance Officer shall perform an inspection I
weekly for compliance with the nuclear criticality safety aspects of the operations. Findings resulting from these inspections shall be reported to the Nuclear ~ Criticality Safety Officer.
2.8.2 Health Physics 2.8.2.1 The Supervisor, Health Physics or his designated alternate shall l
conduct internal audits for the purpose of evaluating the health physics aspects of operations.
This audit shall be conducted in accordance with written audit guidance. This audit shall be conducted once each month. A report of his findings shall be made to the Manager, SS within two weeks of completing the audit. The audit reports shall be forwarded to the Manager, SS and the Licensing & Compliance Officer. The Licensing & Compliance Officer shall be responsible for assuring the appropriate corrective actions are taken to address the audit findings.
2.8.3 General Safety and Compliance 2.8.3.1 The SAS performs audits of general safety and compliance. These I
audits shall be conducted three times annually. The audits shall
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be distributed over a 12-month period. The SAS shall include an audit of the Health Physics and Industrial Safety functions at l
May, 1989 License No SNM-778 Docket No.70-824 Date S
II 2-9 Amendment No.
Revision No.
Page Babcock &Wilcox a McDermott company
least once annually. This annual audit shall be performed by a qualified individual who is independent of the Health Physics Group. Other areas shall be audited for compliance with written requirements and the exercise of acceptable safety practices.
Audits shall be made in axordance with written guidance to assure all aspects of Section 2.3.3.2 are audited. The Chairman, SAS shall file a report of the audit findings with the Chairman, SRC, with a copy to the Licensing & Compliance Officer and members of j'
the SRC. The Chairman, SRC shall forward the report to the Manager, SS with comments, as he deems appropriate. The Licensing
& Compliance Officer shall be responsible for assuring that the appropriate corrective actions are taken to address the audit findings.
2.9 INVESTIGATIONS AND REPORTING OF 0FF-NORMAL OCCURRENCES 2.9.1 Licensing & Compliance Officer l
The Licensing & Compliance Officer shall investigate and report, j
when required, the following types of off-normal occurrences:
2.9.1.1 Excessive levels of radiation from or contamination on packages upon receipt.
2.9.1.2 Thef ts, attempted thefts, or losses of licensed material, other than normal operating losses.
2.9.1.3 Incidents as specified in 10 CFR 20.403 2.9.1.4 Overexposure of individuals and excessive levels and concentra-tions of radioactivity.
2.9.1.5 Failures to comply and defects pursuant to 10 CFR 21.
2.9.1.6 Changes to security, safeguards, or emergency plans made without prior NRC approval, when prior approval is required.
2.9.1.7 Failures to comply with license requirements.
2.9.1.8 Unapproved storage or use of licensed material.
2.9.1.9 Any violation of nuclear criticality safety criteria.
2.9.1.10 Any violation of Area Operating Procedures or RWP's.
I May, 1989 License No SNM-778 Docket No.70-824 Data I
5 II 2-10 l
Amendment No.
Revision No.
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2.10.2 Nuclear Criticality Safety Officer Nuclear criticality safety 6 months af ter evaluations and calculations termination of the approved process.
Nutlear Criticality Safety Officer 2 years Audit Reports.
2.10.3 Licensing & Compliance Officer l
Safety Review Committee Minutes
(*)
Safety Audit Subcommittee Audit Reports 2 years Investigation reports of off-normal occurrences 2 years
-2.10.4 Emergency Records Records pertaining to emergency response and preparedness shall be retained in accordance with Radiological Contingency Plan, Section 8.0.
2.10.5 Industrial Safety Officer Training Recordt.
(*)
Industrial Safety Audits
(*)
Industrial Safety Inspections
(*)
Pay, 1989 License No SNM 778 Docket No. 70 824 Dets Amendment No.
Revision No.
p,2-12 5
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3.0 RADIATION PROTECTION 3,1 SPECIAL ADMINISTRATE!YE REQUIREMENTS 3.1.1 Radiation Work Permits (RWP) 3.1.1.1 RWP's shall be issued whenever the activity is not covered by an Area Operating Procedure and workers are likely to be exposed to levels of radiation or concentrations of radioactive material in excess of.those specified in 10 CFR 20.101 & 20.103, 3.1.1.2 RWP's shall be approved by the Area Supcrvisor, Supervisor, Health Physics, Industrial Safety Officer, and the Licensing & Compliance Officer.
In the absence of any of the above persons, a designated and qualified alternate may approve RWP's.
3.1.1.3 The RWP shall specify the radiological protection requirements for the operation and specify levels of worker exposure above which a documented ALARA evaluation shall be performed. RWP's that re-quire a documented ALARA evaluation must, in addition to 3.1,,1.2, be approved by the Manager, SS.
I 3.1.1.4 RWP's shall be approved at a meeting of all the signators of the form.
3.1.1.5 The RWP form shall provide space for entering the estimated exposures to the whole body, extremities, and for the job. These are used to identify the areas of exposure concern and do not constitute an exposure goal or limit.
3.1.1.6 The RWP form shall provide space for the Area Supervisor to sign or initial, attesting that the workers have been instructed in the requirements of the RWP.
3.1.1.7 The term of a RWP shall not exceed 30-days, except that Standing RWP's shall have a term not to exceed 6-months, 3.1.2 ALARA Policy The management of the site is committed to a policy of maintaining exposures as low as is reasonably achievable.
3.1.2.1 Site workers shall be introduced to this policy during their initial training and shall be reinforced during the annual re-training of Authorized Users.
May, 1989 Lloonee No SNM 778 Docket No.70-824 Date l
5 II 3-1 Amendment No.
Revision No.
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