L-93-042, Application for Amend to License SNM-1067,requesting That Bldgs 6,17 & 21 Be Additionally Exempt from Requirements of 10CFR70.24(a).Informs That It Is Licensee Intent to Deactivate Alarm Sys in Subj Bldgs Upon Approval of Amend

Application for Amend to License SNM-1067,requesting That Bldgs 6,17 & 21 Be Additionally Exempt from Requirements of 10CFR70.24(a).Informs That It Is Licensee Intent to Deactivate Alarm Sys in Subj Bldgs Upon Approval of Amend

ML20059G535
Person / Time
Site:	07001100
Issue date:	10/21/1993
From:	Conant J ABB ATOM, INC. (FORMERLY ASEA ATOM, INC.), ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY
To:	Pierson R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
ML-93-042, ML-93-42, NUDOCS 9311080186
Download: ML20059G535 (12)

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1. %BBBB ASEA BROWN BOVERI October 21,1993 AIL-93-042 Docket No. 70-1100 License No. SNM-1067 Mr. Robert C. Pierson, Chief Licensing Branch Division of Fuel Cycle Safety and Safeguards Office of Nuclear Materials Safety and Safeguards U.S. Nuclear Regulatory Commission Attention: Document Control Desk i

Washington D.C. 20555

Subject:

Removal of the Criticality Alarm System

Reference:

Letter, J. F. Conant (CE) to R. C. Pierson (NRC), ML-93-038, dated September 23,1993.

Dear Mr. Pierson:

In the reference letter, Combustion Engineering submitted to the Nuclear Regulatory Commission a license amendment application to change the total special nuclear material limit for possession and use in the laboratory facilities to <350 gms U-235. In addition, the l

application limits the possession of residual special nuclear material in Buildings 17 and 21 to t

a total of 700 gms U-235 for decontamination and decommissioning activities. Combustion Engineering will thus no longer have significant quantities of special nuclear material in l

. Buildings 6,17, and 21. By maintaining the requested limits in each criticality control area, the criticality monitoring system will no longer be needed. It is requested, in accordance with 10CFR 70.24(d), that Buildings 6,17, and 21 be additionally exempt in SNM-1067 from the requirements of 10CFR 70.24(a). It is our intent to deactivate the alarm systems in j

Buildings 6,17, and 21 upon approval of this amendment.

Enclosure I provides the justification for the removal of the criticality alarm system.

Enclosure II provides a tabulation of the affected pages and their respective revision numbers 04008R I

Adts Uoniuuwun uy...eenng Nuclear Power j

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hNJSilon Engneering. inc.

_000 Proge HS Road M,. ephone (203) (1881911 a

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Mr. Robert C. Pierson ML-93-042 October 21,1993 Page 2 l

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and page dates. Enclosure III provides the affected pages; changes are indicated by a bar in j

the right hand margin. Six (6) copies of the enclosures are provided herewith for your use, j

If I can be of any further assistance, please feel free to call me or Mr. Reid Wolf of my staff

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at (203) 2854839.

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Very truly yours, COMBUSTION ENGINEERING, INC.

t hn F. Conant j

fanager Nuclear Materials Licensing JFC:ct

Enclosures:

As Stated -

j cc:

J. Roth (NRC - Region I)

S. Soong (NRC) j l

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Enclosure I to ML-93-042 l

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i COMBUSTION ENGINEERING, INC.

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WINDSOR NUCLEAR FUEL MANUFACTURING FACILITY-JUSTIFICATION OF REMOVAL

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OF CRITICALITY ALARM SYSTEM FROM BUILDINGS 6,17, AND 21 i

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OCTOBER 1993 l

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COMBUSTION ENGINEERING, INC.

WINDSOR NUCLEAR FUEL MANUFACTURING FACILITY JUSTIFICATION FOR REMOVAL OF CRITICALITY ALARM SYSTEM FROM BUILDINGS 6,17 AND 21 t

The following discussion assumes that the total material limit for possession and use in the laboratory facilities (includes Building 6) is <350 gms U-235, and that the total possession limit for residual special nuclear material in Buildings 17 and 21 during decontamination and decommissioning is 700 gms U-235.

i To control the amount of uranium-235, a log will be maintained of the uranium-235 entering and leaving each building. The only activities in Buildings 17 and 21 following termination of fuel manufacturing will be those associated with decontamination and decommissioning.

Only Buildings 5 and 17 discharge water into Building 6.

Building 17 has several potential sources of uranium contaminated water: the centrifuge, the change room Bradley sink, two floor drains on the FA-3 mezzanine and the FA-3 mezzanine industrial sink. The controls for each source are described below.

i Bradley sinks - The change room has one large hand washing sink. SNM is not allowed in the change room other than slightly contaminated protective clothing. The l

door to the change room is posted "NO SNM ALLOWED BEYOND THIS POINT".

j The combination of personal protective equipment and contamination control prevents f

personnel from becoming contaminated. Therefore the Bradley sink is not a

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significant source of unmeasured SNM to Building 6.

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l Centrifuge - The centrifuge has recently undergone rigorous review both internally i

and by the NRC as part of the centrifuge relocation amendment and NRC Safety 7

Evaluation Report (SER). Discharge from the centrifuge to Building 6 is i

accomplished only after isolating and double sampling the centrifuged water. Water

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is only released when the concentration of uranium is less than 3E-5pCi/ml 235 (MPC,m). Conservatively assuming 5%

U by weight and a specific activity of I

235 2.4 Ci/g, the activity concentration reduces to 6.3E-7 grams U/ml. During the j

235 year 1992, the centrifuge was discharged 150 times. The total amount of U

235 i

released during the year, conservatively assuming 5%

U by weight, was j

approximately I gram. Thus, at this rate of discharge, the yearly release to Building 235 i

6 is about 1 gram U/ year. Considering the double sampling of the centrifuge

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water, the small amount of SNM released and dispersed in 10 retention tanks, this is

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not a significant source of SNM to Building 6.

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FA-3 mezzaning - The FA-3 mezzanine located in the northeast side of the pellet shop has two air conditioner condensate drains and one industrial sink. Access to the mezzanine from the pellet shop is via a covered safety ladder. There is also a closed and locked door from the mezzanine to the cold side of the shop. The Air Handling Units (AHU) may contribute a small amount of SNM to Building 6, as well as the respirator washer. The FA-3 mezzanine is not considered a significant source of unmeasured SNM to Building 6. The controls for the AHUs are as follows:

Air handling units (AHU) - The following table provides brief analysis of the amount of uranium passing through each AHU. Using the extremely conservative assumption that all of the air passing through the AHUs is filtered of 235U and that all of the air originates in the pellet shop, then 22 grams of i

235U would be collected in a year. Radiological measurements of the condensate drip pan suggest that the amount of uranium removed from the air and discharged in the condensate is much lower. Therefore, condensate from i

the AHU's are not be considered a significant source of unmeasured SNM.

Maximum Unmeasured Discharge via Air Handline Units IInil Capacity Grams 235 U/ year AHU1 22,000 CFM 7

AHU2 8,000 CFM 2

8,000 CFM 2

j AHU3 AC-7 34,0004 M

11 Total = 22 235 Concentration (air; grams U / ml) =

235 (IE-12 pCi / ml) x (1 gram U / 2.4 Ci) x (.05 g U / gU) =

235 2.1E-14 grams U/ml

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Building 5 has several discharge points into Building 6. - The control of discharges from Building 5 will be based on limiting the quantity of SNM in Building 5. Building 5 is limited to a total of <350 gms U-235. The limit will be controlled by a log. Discrepancies in the log that cannot be accounted for will be assumed to have been discharged to Building 6.

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t Enclosure II to ML-93-042 i

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COMBUSTION ENGINEERING, INC.

3 WINDSOR NUCLEAR FUEL MANUFACTURING FACILITY LIST OF AFFECTED PAGES

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OCTOBER 1993 1

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4 COMBUSTION ENGINEERING, INC.

WINDSOR NUCLEAR FUEL MANUFACTURING FACILITY LIST OF AFFECTED PAGES Combustion Engineering, Inc. is updating Part I, Licensing Conditions license application information regarding its Windsor Nuclear Fuel Manufacturing Facility (License No. SNM-3 1067) due to the fact that criticality alarms are no longer required in Buildings 6,17 and 21 i

following shutdown of the fuel manufacturing operation and the limitation oflaboratory facilities to <350 gms of uranium-235. The affected pages are provided in Enclosure II.

The license application pages affected are as follows:

List of Affected Pages Delete Page Add Page Page No.

Em DAte Page No.

Em Date i

4 I.1-4 5

5/27/92 1.1-4 6

10/21/93

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I.3-8 4

6/23/89 I.3-4 5

10/21/93 1.4-11 3

10/22/86 I.4-11 4

10/21/93 I.4-12 6

5/27/92 I.4-12 7

10/21/93 11.8-7 5 1

5/27/92 II.8-75 2

10/21/93 l

Enclosure III to ML-93442 COMBUSTION ENGINEERING, INC.

WINDSOR NUCLEAR FUEL MANUFACTURING FACILFn' AFFECTED PAGES OCTOBER 1993

be of a product development nature and the material may ultimately be returned I

to the Nuclear Fuel Manufacturing facility. These transfers shall not require I

the issuance of applicable NRC transfer documents, but shall be transferred in j

accordance with the provisions of this license, and shall be handled as a 1

departmental transfer and shall be controlled by the Fundamental Nuclear Material Control Plan (FNMC) referenced in Section 9.0 of this application.

Buildings 1, I A, 2, 2A, 3, 3A, 5, 6,16,17,18 and 21 shall be exempt from l.

I the requirement of a criticality monitoring system as specified in j

10CFR70.24(a)(1). The above buildings are not required to have a criticality monitoring system because of the exemptions allowed in 10CFR70.24(d).

In each area where labelling of all containers is not in accordance with l

10CFR20.203(f), all personnel ingress locations shall be posted with a sign stating that "Every container or vessel in this area, unless otherwise i

identified, may contain radioactive material."

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License No. SNM-1057 Rev. 6 Date:

10/21/93 Docket No. 70-1100 Page:

I.1-4 t

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

material.

Face velocities will be checked monthly in Product Development.

f The filters in these stacks shall be tested either by 1) counting samples immediately after 1/2 hour of operation or 2) DOP testing the filters in accordance with ANSI standards.

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

The results of thesE tests shall be documented.

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

3.2.4 Instrumentation i

Capabilities of radiation detection and measurement instrumentation i

shall be as follows:

Alpha counting System 10 - 10,000 dpm Alpha Survey meters 0 - 50,000 counts per minute t

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

.5 - 5,000 mrem /hr A sufficient number of the instruments, meters and systems listed l

above shall be maintained operational to adequately conduct our i

Radiological Protection and Industrial Safety program. Additional instrumentation is maintained for emergency use as outlined in Part I, Section 8.

Instruments are calibrated semi-annually and

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following any repair that affects the accuracy of the measurements.

The ca'4ibration of the survey instruments shall meet the l

specifications described in Section 1.11 of i

i Docket No. 70-1100 Rev. 05 Date:

10/21/93 License No. SNM-1067 Page I.3-8 i

shall be indicated with a colored line. The line may be crossed by carts only to permit an operator to transfer that SIU to an available storage position.

1 4.2.7 Structural Intearity Policy - All storage racks, furnaces, containment, and processing equipment which provide nuclear safety limiting parameters shall be designed to assure against failure under normal and reasonable overload conditions and j

under conditions of shock or collision foreseeable in the plant area. All equipment designed shall incorporate a j

minimum safety factor of 3.0.

All equipment design shall conform to standard design practices, thereby assuring I

adequate structural integrity. Materials of construction shall be selected to assure, as far as possible, resistance to l

1 fire and corrosion.

The individual engineer responsible for the purchasing or design of the new equipment shall assure i

that the minimum safety factor of 3 has been incorporated into the design of the equipment.

The minimum qualifications for engineers shall be a bachelors degree in engineering or related fields.

4.2.8 Zonina for Fire Protection - An overhead sprinkler system as f

well as portable extinguishes are located throughout the fuel manufacturing facilities and Product Development. Onsite and t

Offsite fire protection service personnel have been instructed to use only portable dry chemical extinguishers in the Bldg.

1. 17, to maintain the highest possible margin of nuclear criticality safety.

Fere hoses shall not be permitted in Bldg. #17.

4.2.9 (SECTION DELETED) k License 16. SNM-1067, Docket 70-1100 Rev. 4 Date:

10/21/93 Page:

1.4-11

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

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i License No. SNM-1067 Rev. 7 Date:

10/21/93 Docket No. 70-1100 Page:

I.4-12 i

,z (THIS PAGE REPLACES PAGE II.8-75 AND IS INTENTIONALLY BLANK) t i

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License No. SNM-1067 W.

2 Date:

10/21/93 Docket No. 70-1100 Page:

11.8-75