ML20133N502

SER Supporting 841009 License Application & 850208,0506 & 0605 Suppls

ML20133N502
Person / Time
Site:	07002947
Issue date:	07/29/1985
From:	Crow W, Ketzlach N NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20133N479	List: ML20133N475 ML20133N482 ML20133N488 ML20133N495 ML20133N502
References
NUDOCS 8508130505
Download: ML20133N502 (12)

Text

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AUG 7 1985 Docket No.: 70-2947 Applicant: Illinois Power Company (IPC)

Facility: Clinton Power Station, Unit 1

Subject:

SAFETY EVALUATION REPORT - REVIEW OF REVISED LICENSE APPLICATION DATED OCTOBER 9, 1984 AND SUPPLEMENTS DATED FEBRUARY 8, MAY 6, AND JUNE 5, 1985 FOR A MATERIALS LICENSE.

I. INTRODUCTION A. General By application received July 1981, and supplements dated January 15, March,31, May 17, June 8 and 28, July 19, and November 17, 1982, and April 25, and July 8, 1983, IPC requested authorization to receive, possess, and use 2,036 kg U-235 in the form of unirradiated fuel assemblies, 30,000 curies of Antimony-124 in the form of sealed neutron sources, and 20 Ci of Pu-238 in neutron calibration sources.

On September 30, 1981, the Nuclear Regulatory Commission issued Materials License No. SNM-1886 to IPC. The license authorized IPC to receive, possess, and use up to one gram of U-235 in any form and 15 microcuries of plutonium.

The license was amended August 31, 1983, to authorize the possession and use of up to 20 Ci of Pu-238 in neutron calibration standards and extended the license expiration date to August 31, 1986.

By letters dated October 9, 1984, and its supplements dated February 8, May 6, and June 5, 1985, IPC submitted a revised application incorporating (with modifications) the information from all previous submittals.

The finished fuel assemblies will be supplied by the General Electric Company.

Each fuel assembly contains 62 fuel rods and 2 Zircaloy-2 tubes called water rods. The rods are spaced and suppor.ted in an 8-by-8 array by seven spacers and a lower and upper tie plate. Table 1 gives general fuel rod parameters that describe the fuel which will eventually be used in Clinton Power Station, Unit 1, a boiling water reactor (BWR). The materials license is being issued to allow early receipt of the fuel for the purpose of inspection and preparation of the fuel for reactor loading and will automatically terminate upon issuance of the Part 50 operating license.

B. Location Description The Clinton Power Station, Unit 1, is located about 6 miles east of the city of Clinton in DeWitt County, Illinois. The construction permit application was docketed on October 30, 1973, AEC Docket No. 50-461, and Construction Permit No. CPPR-137 was issued in February 1976.

8508130505 050807 PDR ADOCK 07002947 C PDR y

AUG 7 1905 Table 1 Clinton Power Station Fuel Assembly Parameters Parameter Initial Core Rod Array 8 by 8 Number of Fuel Rods per Assembly 62 Fuel Rod Material UO 2

Pellet Diameter 0.410-inch Pellet Length 0.410-inch Pellet Immersion Density (% theoretical) 95.0 Clad Material Zircaloy-2 Clad I.D. 0.419-inch Clad 0.D. 0.483-inch Clad Thickness (nominal) 0.032-inch Pellet Clad Gap 0.0045-inch Active Fuel Length 150.0-inch Fuel Rod Pitch 0.636-inch Number of Water Rods per Assembly 2 Water Rod 0.D. 0.591-inch Water Rod I.D. 0.531-inch II. AUTHORIZED ACTIVITIES A. Enriched Uranium Fuel Assemblies The licensee requests authorization to receive, possess, and store 636 fuel assemblies containing up to 2100 kg of U-235 with a maximum enrichment of 3.00 w/o U-235. The licensee also requests authorization to repackage any assembly, if necessary, for delivery to a carrier. It should be noted that the license does not authorize insertion of a fuel assembly into the reactor vessel.

B. Other Materials Authorization is also requested to receive, possess, and store antimony-beryllium sources containing a maximum of 30,000 curies, in-core neutron detectors contain-i ing 1 g U-235, alpha calibration standards and check sources containing 15p curies of Pu-239, and neutron calibration standards containing 20 curies of Pu-238.

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AUG 7 885 III. SCOPE OF REVIEW The safety review of the Illinois Power Company's request for a Materials License included an evaluation of the original application and its supplements and the revised application and its supplements. A detailed review was made of the Illinois Power Company's organization, administration, nuclear criticality safety, radiation protection, and fire protection.

During the course of the reviews, discussions were held with the NRR project managers, the resident inspectors, the NRC regional office, and with staff mem-bers of the licensee. The evaluation of the physical security plan was made by the Physical Security Licensing Branch, Division of Safeguards, Office of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Commission.

IV. POSSESSION LIMITS Conditions 6, 7, and 8 of the license will specify the type, form, and quantity of material the licensee may possess under this license and shall be revised to read as follows:

6. Material 7. Form 8. Quantity A. Uranium enriched in A. In unirradiated A. 2,100 kg of the U-235 isotope reactor fuel U-235 in ura-assemblies nium enriched to no more than 3.00 % in U-235 B. Antimony-124 B. In Sb-Be neutron B. 30,000 Ci of sources Sb-124 total C. Uranium enriched in C. Contained in-core C. One (1) gram U-235 isotope neutron detectors of U-235 at any enrichment D. Pu-239 D. Alpha calibration D. Fifteen (15) standards and check microcuries of sources Pu-239 E. Pu-238 E. Neutron calibration E. 20 Ci of standards Pu-238 V. ORGANIZATION A. Nuclear Criticality Safety and Radiation Protection Responsibilities The Power Plant Manager has overall responsibility for the administrative con-trols to ensure the safety of all fuel handling and storage operations and is Chairman of the ALARA Committee.

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AUG 7 1985 The Radiation Protection Supervisor has direct responsibility to ensure safety during all fuel handling and storage operations. He has functional control of and is responsible for establishing and implementing the Radiological Control Program. He has the responsibility for ensuring that the ALARA policy is implemented, serves as the Radiation Protection Manager, and reports directly to the Power Plant Manager.

The Senior Reactor Operator or Nuclear Engineer, in charge of fuel handling, directly supervises all fuel transfers and verifies the moves are to the proper locations. Fuel handling procedures and changes to them are reviewed and approved by the Station's ALARA Committee. The Plant Manager has the overall responsibility of the ALARA Program. )

8. Minimum Qualifications The qualifications of the aforementioned safety-related personnel have been reviewed and the staff finds they meet the minimu'm qualifications specified in Regulatory Guide 1.8, " Personnel Selection and Training" and/or ANSI /

ANS-3.1-1978, "American National Standard for Selection and Training of Nuclear Power Plant Personnel." However, the position, Nuclear Engineer, is not specified in the ANSI /ANS Standard. The minimum qualifications for the latter position, as specified by IPC, are adequate for the responsibilities of the position related to the license. Those, as well as the minimum qualifications for the other safety-related positions, are specified in Conditions 11-14 as follows:

Condition 11: The minimum technical qualifications for the Clinton Power Station (CPS) Power Plant Manager shall be in accordance with Section 4.2.1, " Plant Manager," of ANSI /ANS-3.1-1978.

Condition 12: The minimum technical qualifications for the Radiation Protection Supervisor shall be in accordance with that for the " Radiation Protection Manager" specified in Regulatory Guide 1.8, September 1975.

Condition 13: The minimum technical qualifications for the Senior Reactor Operators shall be in accordance with Section 4.3.1,

" Supervisors Requiring NRC Licenses," of ANSI /ANS-3.1-1978.

Condition 14: The minimum technical qualifications for the Nuclear Engineer shall be a bachelor.of science degree in engineer-ing or a physical science, 1 year nuclear power plant experience, and shall have completed the General Electric Station Nuclear Engineer Training Course.

C. Tpining t IP has committed to the radiological control training of all individuals prior to entering either a protected or a radiological control area commensurate with the working conditions and the individuals' responsibilities and duties. In addition, " radiological worker" training and annual retraining is given to all personnel working with radioactive materials. Radiation protection technicians and supervisors also receive theoretical and practical training, including periodic drills. Personnel involved in fuel handling activities also receive training prior to fuel receipt.

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AUG 7 1985 VI. NUCLEAR. CRITICALITY SAFETY A. General 4

The fuel assemblies may be stored in the following areas: (1) in the unloading area-in their inner and outer shipping containers, (2) in their inner containers in the Fuel Building, (3) New Fuel Storage Vault, (4) Spent Fuel Storage Pool, and (5) Containment Storage Pool. The fuel assemblies will be stored dry in all locations, except location (4) where it will be stored flooded or dry.

B. Shipping Container Storage Fuel assemblies may be temporarily stored in their inner and outer shipping con-tainers or only in their inner containers. The shipping containers will not be stacked more than 3 layers high with no more than 24 containers in a single array. The licensee has committed to maintain a minimum of 25-feet spacing be-tween groups of 24 shipping containers. Nuclear criticality safety is assured since the safety of fuel stored in their inner shipping containers in an infi-nite array stacked four high has been established (Amendment No. 5 to Materials License No. SNM-1097, dated June 6, 1978, Docket No. 70-1113). The 25 feet of separation between arrays is adequate for isolation between arrays.

C. Fuel Handling The licensee has stated he plans to have no more than three fuel assemblies out-side their shipping containers or storage racks at one time. However, the licensee did not specify the minimum distance between this grouping of assem-blies and all other fuel. The NRC staff has shown that three isolated fuel assemblies cannot be made critical independent of the spacing between them and of the degree of water moderation and/or reflection. The staff has also deter-mined that a separation of at least 12 inches between the grouping of three fuel assemblies, and all other fuel assemblies in their shipping containers or stor-age rack locations, is required to assure the nuclear criticality safety of the arrays, under all degrees of water moderation and/or reflection. The staff recommends Condition Nos. 15 and 16 be added to identify these requirements.

Condition 15: No more than three fuel assemblies shall be outside their shipping containers and storage racks at any one time.

Condition 16: The minimum edge-to-edge distance between the group of three fuel assemblies and all other fuel assemblies shall be 12 inches.

D. New Fuel Storage Vault The new fuel racks in the New Fuel Storage Vault are designed to store up to 240 fuel assemblies. There are 24 rows and 10 fuel assemblies per row. The center-to-center spacing between assemblies is 7 inches within a row and 12.25 inches between rows. The licensee's and the NRC staff's criticality calculations were for infinite arrays at all moderator densities. Calculations of k for the array were independently performed by the NRC staff. Thestaffca18ufated the array to be supercritical when enveloped in mist with a density between 0.01 g/cm3 and 0.15 g/cm3 (approximate densities). If the entire array were flooded with full density water, k eff f the array would be approximately 0.82.

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IP has provided four aluminum plate covers over the vault to prevent the entry of mist. Further, no more than two of the covers would ever be off the vault and expose no more than 12 rows (120 assemblies) of fuel assemblies. The licensee has stated in the FSAR that covers will normally be in place over the vault except when new fuel is to be inserted or removed from the rack. Since it has been estimated by the staff that an array of as few as five rows of assemblies fully flooded with water mist at optimum density for maximum k may become critical, IP has installed firehose protection stations equipp$df with solid stream nozzles to fight fires that may, but are unlikely to, occur in the vault. The licensee has committed to establish station administrative pro-cedures specifying actions to be taken for control of combustibles, control of ignition sources, and to control action to be taken in the event of a fire. It is recommended Conditions 17 and 18 be added to emphasize the water mist control in fighting fires.

Condition 17: Fuel assemblies, when stored in the New Fuel Storage Vault, shall be stored under the following conditions:

a. No more than 12 rows of fuel assemblies shall remain uncovered during the loading or unloading of fuel assemblies.

b. Metal covers shall cover all other rows containing fuel assemblies during loading and unloading of fuel assemblies.

c. When loading or unloading of fuel assemblies is not in progress, metal covers shall cover all rows of fuel assemblies.

Condition 18: All firehoses servicing the New Fuel Storage Vault area shall be equipped with solid stream nozzles.

Conditions 17 and 18 preclude the possibility of moderating an entire open sec-tion of the fuel array and from generating mist over the entire exposed array to assure nuclear criticality safety. The NRC staff concludes that, with the above controis, the licensee's actions are adequate to ensure nuclear critical-ity safety during fuel handling operations in the New Fuel Storage Vault.

The licensee plans to wrap the fuel assemblies in polyethylene sheeting to pro-tect them from the environment while in storage. The fuel assemblies may become internally moderated with water while the spaces between assemblies would be occupied only with air. This could occur if the storage area flooded, the area then drained, and the water was retained in the plastic bags. Under these con-ditions, the array may become critical. The licensee plans to have the poly-ethylene sheets open at both ends to enable water to drain freely from the fuel assemblies. Under these conditions, there is no nuclear criticality hazard from full density flooding (water) and subsequent draining. The NRC staff emphasizes the licensee's action to prevent such a situation in License Condition 19.

Condition 19: Fuel assemblies shall be stored in such a manner that water would drain freely from the assemblies in the event of flooding and subsequent draining of the fuel storage area.

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AUG 71985 It is the staff's' opinion that with this condition, the licensee has established reasonable and satisfactory precautions to avoid accidental criticality in the New Fuel Storage Vault.

E. Upper Containment Fuel Storage Pool The Upper Containment Fuel Storage Pool has the same design as the New Fuel Storage Vault. Therefore, k of fresh fuel stored in this pool is the same at allwatermistdensitiesasThisintheNewFuelStorageVault(assuming infinite arrays). Since the k of the array is only 0.82 when flooded with full density water, IP presentTyfplans to store fresh fuel assemblies in this pool only under water. This requirement will be emphasized as Condition 20.

Condition 20: Fresh fuel assemblies shall be stored in the Containment Fuel Storage Pool only under water.

F. FuelBuildin$SpentFu'elStoragePool The racks in the Spent Fuel Storage Pool form a square array of storage cells spaced on 6.4375-inch centers. The walls that separate storage locations are composed of two steel sheets with a nominal thickness of 0.060 inches, welded to each other to form a pocket 0.150-inches wide in which a 4.25-inch wide by 0.11 inch thick Boral poison sheet is placed for criticality control. The Boral plates contain baron with an areal deasity of 0.030 g B-10/cm2 The inner diameters of the storage cells are 6.1675 inches. The layers of steel and Boral provide a margin of safety to prevent an inadvertent criticality.

The staff determined the maximum k for an infinite array of fuel assemblies intheSpentFuelStoragePoolto8b0.840t0.004attheoptimumdegreeof water moderation (full density water) within and between assemblies. Therefore, any size array of fuel assemblies in the Spent Fuel Storage Pool is safe from inadvertent criticality under all degrees of water moderation. The licensee has a quality assurance program starting with the certification of the analysis of the Boral plates, continuing with the manufacturing of the plates, their installation in the spent fuel racks, and the surveillance program to assure their continued presence in the racks. The Resident Inspectors, T. P. Gwynn and P. L. Hiland, have confirmed the Boral meets the above specifications and has been fabricated into plates which were installed in the storage racks in their design positions.

IP has stated it has no intention "at this time" to store fuel assemblies in the control rod racks. Since the staff was not supplied with sufficient infor-mation to evaluate the nuclear criticality safety of these racks if loaded with fuel assemblies, it recommends Condition 21 be added to the license.

Condition 21: No fuel assemblies shall be stored in the control rod racks.

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AUG 7 1985 VII. RADIATION SAFETY The Radiological Control Program at CPS has been established and managed to pro-tect the public, workers, and the environment and to monitor and control radia-tion exposure and radioactive materials. The objectives of the program are to control radiation exposures and releases of radioactive materials in effluents to unrestricted areas, not only within regulatory limits, but as low as reasonably achievable (ALARA). Each incoming and outgoing shipment of radioactive material is handled in compliance with radiological control procedures and limit surface contamination to either 1000 dpm beta / gamma per 100 cm2 of surface area or 100 dpm as measured by a pancake GM detector. Alpha emitting loose surface contamination is limited to 100 dpm alpha per 100 cm2 The antimony-124 neutron startup sources, separated from their beryllium sleeves, are stored in their shipping containers prior to installation in the reactor core vessel. The shipping containers are lead-filled drums, meeting 00T package specifications, and are General Electric Model 1500 Shielded Containers licensed under S.P. No. 5939. The containers are stored under lock and key security with access controlled by Radiati.on Protection Personnel. Radiation surveys are made upon receipt of the radioactive materials and at subsequent specified intervals.

The neutron startup source,s may be loaded into the source holders and installed in the core vessel prior to receipt of the operating license. Removal of the source pins from the cask, loading them into the holders, and transfer to the reactor vessel are all done under water and at ao time, will any radioactive source component outside a shipping container (cask) be allowed to come within 5 feet of the surface. The procedures are covered by a Radiation Work Permit, and a Radiation Protection representative shall be present during manipulations of the loaded cask and all source handling operations to monitor the operations.

Although the licensee has committed to leak testing the sources within 31 days prior to installation in the core ano following repair or maintenance, it is recommended Condition 22 be added to c'arify that the test will be performed prior to installation in the core vessel.

Condition 22: The antimony-124 startup sources shall be leak tested within 31 days prior to installation in the reactor core vessel and following repair or maintenance.

The licensee also requested the receipt, possession, and installation of incore fission detectors containing small quantities of U-235. An acceptable leak test was specified by the licensee for the fission detectors. The detectors are stored in a permanent warehouse in their shipping containers. The warehouse is locked and access controlled.

Alpha-calibration standards and check sources were also requested by the licen-see. They will be stored in a locked cabinet in the Radiation Protection In-strument Calibration Facility. The storage cabinet is locked and access controlled.

When not in use, the neutron calibration standards are locked in the shielded storage position of a neutron irradiator. The irradiator is also within the Instrument Calibration Facility. The storage area is locked and access controlled.

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AUG 7 1985 The staff has concluded that the CPS Radiation Protection Program, together with the proposed license conditions, is adequate for the protection of the public, CPS personnel, and the environment.

VIII. ENVIRONMENTAL PROTECTION The Final Environmental Statement related to the operation of the Clinton Power Station, Unit 1, dated May 31, 1982, has been prepared and issued by the NRC as NUREG-0854. An Environmental Assessment has also been prepared for the 10 CFR Part 70 fuel storage license in accordance with 10 CFR 51.21. This Assessment supports a Finding of No Significant Impact which was published in the Federal Register on June 3, 1985.

IX. FIRE SAFETY The areas in the Fuel Building and in the Containment Building, where fuel storage and handling are conduc;ed, have very little combustible material.

Administrative controls are implemented to control the quantity of combustible materials, ignition sources, and action to be taken in the event of a fire.

Fire protection is provided by charged firehose stations having solid stream nozzles and by portable halon extinguishers in the vicinity of each storage and handling area. The staff feels the fire protection system for the facility is adequate.

X. PHYSICAL PROTECTION The Clinton Power Station physical secur'ity plan was reviewed and it was the staff's opinion that the program described was adequate and met the requirements of 10 CFR 73.67. The licensee was notified by NRC letter dated May 31, 1983, that his " Feel Storage Physical Security Plan" was approved. By letter dated May 14, 1985, IP requested authorization to modify the CPS security plan. The NRC, by letter dated June 11, 1985, notified the licensee the modification was approved. The staff recommends Condition 23 be added approving the modified plan.

Condition 23: The approved "Clinton Power Station, Unit 1, Physical Protection Plan for Special Nuclear Material (SNM)," sub-mitted by letter dated May 18, 1982, and as revised by letters dated November 17, 1982, and May 14, 1985, for the fixed site and in-transit protection of special nuclear material of low strategic significance shall be fully implemented by the date of fuel receipt and shall be in effect whenever fresh fuel is stored onsite.

XI. CONCLUSIONS

1. After reviewing the application and its supplements, the NRC staff finds that:

( a. The application teets the requirements of the Atomic Energy Act, as amended, and the regulations of the Commission.

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b. Issuance'of the license would not be inimical to the common defense and security.

c. Issuance of the license would not constitute an unreasonable risk to the health and safety of the public.

2. With the recommended license conditions, the NRC staff finds that;

a. The applicant is qualified by reason of training and experience to use the material for the purpose requested in accordance with the regulations in 10 CFR 70.23.

b. The applicant's proposed equipment and facilities are adequate to pro-tect health and minimize danger to life or property.

c. The applicant's proposed procedures to protect health and to minimize danger to life or property are adequate.

XII. RECOMMENDATIONS The staff recommends approval of the application and its supplements subject to the following conditions which the staff finds are appropriate to protect health or to minimize danger to life or property:

11. The minimum technical qualifications for the Clinton Power Station (CPS) Power Plant Manager shall be in accordance with Section 4.2.1,

" Plant Manager," of ANSI /ANS-3.1-1978.

12. The minimum technical qualifications for the Radiation Protection Supervisor shall be in accordance with that for the " Radiation Protec-tion Manager" specified in Regulatory Guide 1.8, September 1975.

13. The minimum technical qualifications for the Senior Reactor Operators shall be in accordance with Section 4.3.1, " Supervisors Requiring NRC Licenses," of ANSI /ANS-3.1-1978.

14. The minimum technical qualifications for the Nuclear Engineer shall l

be a bachelor of science degree in engineering or a physical science, 1 year nuclear power plant experience, and shall have completed the General Electric Station Nuclear Engineer Training Course.

15. No more than three fuel assemblies shall be outside their shipping containers and storage racks at any one time.

16. The minimum edge-to edge distance between the group of three fuel i assemblies and all other fuel assemblies shall be 12 inches.

17. Fuel assemblies, when stored in the New Fuel Storage Vault, shall be stored under the following conditions:

a. No more than 12 rows of fuel assemblies shall remain uncovered during the loading or unloading of fuel assemblies.

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b. Metal covers shall cover all other rows containing fuel assem-blies during loading and unloading of fuel assemblies,

c. When loading or unloading of fuel assemblies is not in progress, metal covers shall cover all rows of fuel assemblies.

18. All firehoses servicing the New Fuel Storage Vault area shall be equipped with solid stream nozzles.

19. Fuel assemblies shall be stored in such a manner that water would drain freely from the assemblies in the event of flooding and subse-quent draining of the fuel storage area.

20. Fresh fuel assemblies shall be stored in the Containment Fuel Storage Pool only under water.

21. No fuel assemblies shall be stored in the control rod racks.

22. The antimony-124 startup sources shall be leak tested within 31 days prior to installation in the reactor core vessel and following repair or maintenance.

23. The approved "Clinton Power Station, Unit 1, Physical Protection Plan for Special Nuclear Material (SNM)," submitted by letter dated May 18, 1982, and as revised by letters dated November 17, 1982, and May 14, 1985, for the fixed site and in-transit protection of special nuclear material of low strategic significance shall be fully implemented by the date of fuel receipt and shall be in effect whenever fresh fuel is stored onsite.

Origenni Signed by N.Kott. loch Norman Ketzlach Uranium Process Licensing Section Uranium Fuel Licensing Branch Division of Fuel Cycle and Original Signea by Material Safety, NMSS Approved by:

ggW.T. Crow,SectionLeader OFC: FCUP :FCUF l

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DATE:07/L685 :07/#/85  : 07/2[./85 0FFICIAL RECORD COPY 12 1 1

TABLE 1 gb CHANGED REQUIREMENTS FOR SHUTDOWN FACILITIES Spec. 7 l$33 Vol. New Sybject ites Sec. Exi st ino Reaui rement R*auirement Comment or Condi t ion Inte rna l _. I rLspec t i ons Health Physics 3.6.1 Quarterly Annual HIGR & Ifot Cell Pa rt icu la te ,

exposures essentially eliminated by nothing in storage Nuclea r Safety Qua rte rl y Annual Where mtl is vault s to red in stable forms, e.g., oxide or encapsulated Personnel Mo n i_t o r e n3 u-235 bioassay 4.1.3 Includes gua rds Eliminate guards During shutdown of fuel fab Suryey3 Wipes 4.1.4.1 Daily Monthly In shutdown fuel fab a reas in QC Weekly Lab & other Type II workplaces

" No Survey when hoods Air Velocity Quarterly Enclosure cleaned to minimize poten-a re unused tial for a i rborne re lea se of materia l Glove Box Ai r Samgles work place 4.1.4.2 Shift Monthly in shutdown fuel fab a reas Weekly Weekly in QC Lab & other Type i t work places Analysis interval Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> I week Stack Weekly Monthly in shutdown processing a rea s Water Sampl ing Sewage 4.1.4.3 Collected daily ollected weekly Samples evaluated Samples evaluated daily monthly plus sample and evaluate on days of di scha rge Alarm checks &

Ca lib ra tion

• Ca l i b ra t i on 4.2.1 & Semiannual recali- Eliminate CWAS from Functionally test monthly with bra tion to NBS requirement of 4.2.1 builtin check or portable sources 4.2.1.4 Traceable Sources or other system features Work Place Ai r changes 4.1.2.1 All work places Eliminate requirement 4 air changes /hr in areas when all mate-rial is stored and equip-ment is cleaned out.

hcl Monitoring 6.6.1 Qua rte r l y O No planned itC1 furnace opera tions Environmental Air Sampling 6.1 Weekly Monthly Suspended Particulate 6.6.1 Semiannual No change lap Wa ter Sampling 4.1.4.3 Daily Evaluation Weekly Evaluation Sewage Sampling 6.2 Daily Sampled daily Analyzed weekly

• Requested change under a l l levels of operation

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