ML17135A104
| ML17135A104 | |
| Person / Time | |
|---|---|
| Site: | 07000270 |
| Issue date: | 09/25/2018 |
| From: | Merritt Baker Fuel Manufacturing Branch |
| To: | Terry C BWXT |
| References | |
| CAC L33497 | |
| Download: ML17135A104 (3) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 25, 2018 Mr. Chris Terry, Manager Licensing and Safety Analysis BWXT Nuclear Operations Group, Inc.
P.O. Box 785 Lynchburg, VA 24505-0785
SUBJECT:
CONFIRMATION OF DESIGNATION OF NEW PICKLING FACILITY (COST ACTIVITY CODE L33437)
Dear Mr. Terry:
This refers to letter 17-008, dated February 17, 2017, which submitted a request for concurrence that the new pickling facility should be considered an extension of the current operation, the acid used in pickling operations is not comingled with licensed materials, and a license amendment is not required.
The U.S. Nuclear Regulatory Commission (NRC) staff appreciate the early notification of BWXTs intent to expand the existing pickling facility. Following receipt of the request, staff have reviewed the available data and have inspected the facility during its construction.
During a site visit on May 8-10, 2017, the NRC staff interviewed BWXT staff and reviewed safety and operating documents for existing pickling operations. In addition, the staff reviewed the process descriptions in the site Integrated Safety Analysis, Safety Analysis Reports 5.27 and 5.37, which provided details of controls used in the pickling operation. Among the controls are measurements and engineered controls that are not Items Relied on For Safety but are industrial safety or quality assurance measures. The staff also examined the procedure for pickle operations, which includes all the existing safety features, their operation, testing, and acceptance criteria.
The staff examined the request for confirmation of the designation of the new pickling facility with respect to the regulations in Title 10 of the Code of Federal Regulations 10 CFR Section 70.72(b), which require that a licensee evaluate any change to site processes, systems, or components prior to implementing a change, and determine if a license amendment is required.
An amendment is required for any change that:
creates a new type of accident sequence that exceeds the performance requirements of 10 CFR Section 70.61 and has not been described in the ISA (10 CFR Section 70.72(c)(1)(i)),
uses a new process, technology, or control system for which the licensee has no prior experience (10 CFR Section 70.72(c)(1)(ii)),
removes, without at least an equivalent replacement of the safety function, an item relied on for safety (IROFS) listed in the integrated safety analysis (ISA) summary and is necessary for compliance with the performance requirements of 10 CFR Section 70.61 (10 CFR Section 70.72(c)(2)),
alters any IROFS, listed in ISA summary, that is the sole item preventing or mitigating an accident sequence that exceeds the performance requirements of 10 CFR Section 70.61 (10 CFR Section 70.72(c)(3)); or
C. Terry 2
is otherwise prohibited by 10 CFR Section 70.72, license condition, or order (10 CFR Section 70.72(c)(4)).
Chapter 11 of the License Application provides the commitments for control, evaluation, review, and approval of modifications and additions to the facilities, processes, and equipment used for handling licensed material. During site visits, the staff interviewed safety and licensing staff regarding this proposed change and other changes in progress and examined Quality Work Instruction QWI 2.1.3, the internal procedure for executing the site ISA methodology. It includes the method for conducting the Process Hazards Analyses (PHAs), risk assessments, and identifying controls and IROFS.
Staff also held a closed meeting with BWXT on April 24, 2018, to discuss the new pickling facility and other topics. During the meeting, the NRC expressed appreciation for the advance notification of intent and explained that the NRC could not make a finding based on preliminary information. The final change package was not available at that time.
The NRC staff typically reviews final documentation (e.g., amendment requests, 10 CFR 70.72 evaluations) and issues its findings on compliance with regulations and license commitments.
In this case, BWXT requested NRC to provide concurrence on preliminary information. The NRC staff is unable to concur or make a final determination as to whether a license amendment is required for the new pickling facility. Note that the requirements in Section 70.72(a) and the commitments in section 11.1.3 of the License Application continue to apply for evaluation, approval, and documentation of this proposed change. While BWXT appears to be approaching the modification in a conservative manner, final review of the modification will not occur until the design is complete and facility change reviews in accordance with 10 CFR 70.72 analyses/screening are completed. NRC licensing staff will continue monitoring progress and NRC inspectors will continue to inspecting the construction of the new facility while it is under construction. NRC inspectors will also inspect the final 70.72 screening, when completed.
The NRC staff also examined the request regarding comingling of acid and licensed material, as well as the attachments furnished with the request, and determined that the acid used in the pickling process is not a hazardous chemical produced from licensed materials, as defined in 10 CFR Section 70.4, definitions. Such chemicals, as stipulated in the regulations, physically or chemically interact with licensed materials, or are comingled with licensed materials. The staff reviewed the attachments, which included an assessment of hydrogen generation from the pickling process. Based on the lack of hydrogen generation and nominal measurements of equipment before and after pickling, the staff concluded that pickling acid is not comingled with licensed materials. The staff concluded that as long as the revised pickling process is consistent with the existing process, and as such, the staff position outlined in inspection report 1R 70-27/2014-204 remains unchanged.
Enterprise Project Identifier (EPID) L-2017-LLA-0024 (former Cost Activity Code number L33437) is CLOSED.
If you have any questions, please contact me at by Telephone at (301) 415-7119, or via e-mail to Merritt.Baker@nrc.gov.
C. Terry 3
In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room, or from the ADAMS. ADAMS is accessible from the NRC Web site at:
http://www.nrc.gov/reading-rm/adams.html.
Sincerely,
\\RA\\
Merritt N. Baker, Senior Project Manager Fuel Manufacturing Branch Division of Fuel Cycle Safety, Safeguards, and Environmental Review Office of Nuclear Material Safety and Safeguards Docket No. 70-27 License No. SNM-42
ML17135A104 OFFICE FCSE/FMB FCSE/FMB FCSE/FMB FCSE/FMB NAME MBaker TBrockington RJohnson MBaker DATE 07/17/ 2017 09/25/2018 09/07/2018 09/ 25/2018