ML19207B853
| ML19207B853 | |
| Person / Time | |
|---|---|
| Site: | 07002219 |
| Issue date: | 07/02/1979 |
| From: | Stevenson R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Nilson R SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER |
| References | |
| NUDOCS 7909050427 | |
| Download: ML19207B853 (5) | |
Text
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Distribution:
FCPF r/f NMSS r/f Docket File 70-2219 PDR 9
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FCPF:RLS
/IE E Q 70-2219 WTCrow R
M, 2N EYShum lj ALSoong i
RLStevenson (2)
HKForsen, Exxon 3
Exxon Nuclear Cenpany, Inc.
WCooley, R:V L
ATTN: Dr. Roy Nilson,Pfanager Licensing 2955 George Washington May Richland, Washington 99352 Gen tlece'n:
With the exception of the fire safety review, we have conpleted our initial review of your February 26, 1979, application for a special nuclear material license for the Experimental Test Facility. Our review has revealed a need for additional infomation, which is identified in the attachment.
Other infomation needs will be transmitted to you if indicated as an outcome of the fire safety review or follcwing our inspection of the plant prior to operation.
Your request for proprietary withholding of certain infomation is under consideration.
We would appreciate receipt of the requested additional infomation within sixty (60) days, to pemit tinely continued effort on your application.
Sincerely, Robert L. Stevenson Uranium Fuel Fabrication Section Fuel Processing a Fabrication Branch Division of Fuel Cycle and Material Srfety
Enclosure:
Coments and Questions on Experimental 3
Test Facility Application, February 26, 1979 Dccket No. 70-2219
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ENCLOSURE COMMENTS AND QUESTIONS ON APPLICATION FOR EXPERIf1 ENTAL TEST FACILITY, FEBRUARY 26, 1979 DOCKET NO. 70-2219 Part I - Conditions of License 1.
_Page I - 1.3, para. 1.6 Further clarification is needed concerning the requested exemption from the requirenents of 10 CFR 70.24.
The criticality alarm system and coverage are acceptable as doscribed.
2.
_Page 1 - 2.2, para. 2.2 (a) Please state the required frequencies for meetings of the Safety Committee, their reviews of data relative to ALARA, and their inspections of housekeeping and safety practices.
Justifi-cation should be provided if the intervals between ALARA reviews, meetings, or inspections exceed six months.
(b)
It should be confirmed that operating procedures will be reviewed and updated at least annually.
3.
Page I - 2.17, para. 2.3.13 The paragraph immediately preceding para. 2.3.14 reads, "The minimum qualifications af at least one member of the Health Physics Component shall be a Bachelor degree in Science or Engineering with five years' experience in radiation protection, including at least two years of radiation protection experience".
Please explain.
4.
Page I - 2.19 (a) The experience requirements for each second party nuclear criticality reviewer should include at least two years of criticality analysis.
(b) (para. 2.4) The decommissioning plan and financial commitment will be required prior to the introduction of source or special nuclear material into the plant.
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- 5.
Page I - 3.3 Please confirm that unless operation or maintenance work is covered by an effective Radiation Work Procedure, a Radiation Work Permit (RWP) shall be prepared for all work involving entry into a system containing SNM or where a potential for release of contamination exists such that the airborne radioactivity concentration to which employees are exposed from the proposed operation or work is likely to exceed the concentration in Appendix B, Table 1 of 10 CFR 20 or the potential external radiation exposure to which employees are exposed from the proposed operation or work is likely to exceed 6 mrem /hr.
The RWP's shall specify the necessary radiation safety controls including but not limited to respiratory protection, special air sampling, and special local ventilation.
All RWP's shall be signed by the Manager, ETF Operations, and the Radiation Safety Officer or their designees prior to the start of operations except that during off-shift hours approval of the Radiation Safety Officer may be obtained via telephone.
6.
The following commitments relative to radiation safety practices should be confirmed or deviation from the indicated action should be justified:
(a) Page I - 3.11 Each glove box shall be equippad with a device to measure the negative pressure in the enclosure and a minimum negative pressure specified 'w operation.
(b) Page I - 3.13 Surface contamination surveys in general areas where food is allowed shall have a minimum daily frequency.
(c) Page I - 3.13 Cleanup operatior,s shall be conducted when smearable con-tamination on exposed or non-hooded surfaces in uranium containing areas exceeds 5000 dpm (alpha) per 100 sq. cm.
(d) Page I - 3.15 For routine release, personnel skin surface contamination levels shall not exceed background.
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' (e) Page I - 3.17 Permanently mounted air sampling equipment used to determine the workers' breathing zone concentrations shall be evaluated for representativeness at least every twelve months and following process or equipment changes.
7.
Page I - 3.19, para. 3.1.4.5 The wording of this paragraph will be interpreted as committing Exxon to all applicable requirements of RG 8.11.
8.
Page I - 3.36 Certain of the criticality safety criteria and references should be updated as follows:
(a) Ine use of the solid angle method should be subject to the constraints in TID-7016, Rev. 2.
(b) The reference to a 30 cm thickness of concrete as isolator should be deleted or additional justified constraints on its use should be added.
(c) Reference c (Revision 1 of TID-7016) should be replaced by Revision 2.
(d) Reference f (LA-3366) should be replaced by LA-3366 (Rev. )
9.
Table 3.2 - 2 What is the meaning of "In regular fissionable material matrix"?
10.
Page I - 3.43, para. 3.3.3 Please identify the radionuclides to be analyzed in the stack samples, the action levels, and actions to be taken.
11.
Page I - 3.49, paras. 3.7.1 and 3.7.2 Please confirm that the monthly inspections will be made in accordance with a written plan.
12.
Page I - 3.51, para. 3.8 The emergency plan should be submitted as a separate entity for review and approval by NRC prior to issuance of the operating license.
Please refer to Regulatory Guide 3.42, " Emergency Planning for Fuel Cycle Facilities and Plants Licensed Under 10 CFR Parts 50 and 70", August 1977.
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13.
Page I - 3.58, para. 3.10 (a) How will the effectiveness of operator training be measured?
(b)
It should be confirmed that there will be at least an annual frequency for refresher training.
Part II - Supporting Descriptive Information
- 14. General Additional supporting details for the plant demonstrating the application of Part I criteria, may be requested prior to authorization of plant operation.
15.
Lagoon Please describe the lagoon location, capacity, design, discharge rate, method of monitoring including location and depth of wells (if any) chemical or radiological parameters to be analyzed, frequency of sampling and action levels.
The sampling system, parameters and action levels should be incorporated as a commitmer.t in Part I.
16.
Section 2.2, Building Description It is requested that a single combined layout drawing be provided to show the relationship of the flodule and Laser and Dye Facilities.
17.
Page II - 2.27, para. 2.8.3 There appears to be an inversion of the intent concerning the count rate in the audit circuitry.
18.
Page II - 4.14, para. 4.3.3.2 How does the introduction of water or steam into the module cause termination of the power input?
19.
Page II - 4.23, para. 4.3.10 It should be noted that the critical mass values quoted apply to oxide systems.
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