ML19257D270
| ML19257D270 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 12/10/1979 |
| From: | Crow W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Estey H SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER |
| References | |
| NUDOCS 8002040004 | |
| Download: ML19257D270 (9) | |
Text
,e p k e REGog UNITED STATES n
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WASHINGTON, D. C. 20555
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J DEC 101979 FCUP:RLS 70-1257 Exxon Nuclear Company, Inc.
ATTN: Mr. H. Paul Estey, Manager Licensing and Compliance, Operating Facilities 2101 Horn Rapids Road Richland, Washington 99352 Gentlemen:
Draft questions and comments on your application for renewal of Special Nuclear Material License No. SNM-1227 were discussed with Exxon Company staff daring the site visit of Messrs. A. L. Soong and R. L. Stevenson of my staff and Mr. W. Cooley of Region V Office of Inspection and Enforce-ment, on November 27, 1979. As promised during those discussions, we are sending you a written set of the questions in final form (enclosed).
To maintain our schedule for the rev'ew of your application, it is desirable that we receive your responses by January 7, 1980.
Sincerely,
.'t l
NQ.r!
W. T. Crow, Section Leader Uranium Process Licensing Section Uranium Fuel Licensing Branch Division of Fuel Cycle and Mater al Safety
Enclosure:
Questions and Comments on License Renewal Application, Exxon Nuclear Company (Transmittal letter Dated May 31,1979) 1864 081 8002040 Cb
Questions and Comments on License Renewal Application, Exxon Nuclear Company, (Transmittal Letter Dated May 31,1979)
Docket 70-1257 Concern,ing Part I and Appendices, proposed license conditions:
It should be noted that the following comments and questions do not include thc,sc relevant to the environmental monitoring program', which has yet to be reviewed in connection with the license renewal.
1.
Pace 1.1, paracraoh 1.1 - It is planned that the information in the renewal license for " authorized place of use" will identify the buildings in which the specified activities are to be carried out.
Please relate the activities to be authorized with the buildings in which they will be conducted.
2.
Paae 1.2, caragraoh 1.3 -
a.
Please confinn that the buildings onsite in which SNM is processed or stored meet an identified building code or provide other information to justify their acceptance as regards resistance to damage by fire.
b.
Please provide a copy of the latest insurance (or other independent agency) insoection report for the Exxon Nuclear Richland facilities in which the provisions for fire protection were evaluated.
3.
Pace 2.3, caracraoh 2.2.1, ALARA Committee -
a.
Please state the minimum frequency for meetings of the 'ALARA Comittee.
The minimum frequency should be consistent with the revised report frequency indicated in b, following.
1864 082
2 b.
To be consistent with the ALARA review reporting requirements in other similar licenses recently renewed, the ALARA Committee review reports should be issued at a minimum 6-month frequency.
4.
Page 2.15, middle paragraoh - What is the intent of " certified" in describing the required qualifications of the health physics technicians ?
5.
Paces 2.16 and 2.22 -
a.
Ti;e minimum qualifications of the second-party reviewer should includt a minimum of two years of criticality safety analysis experience, b.
(Page 2.22, last paragraph) - Since not all members of the Criticality Safety Component of Licensing and Compliance are required to have the stated qualificatior.s, references to the Criticality Safety Component elsewhere in the Conditions of License need further clarification.
6.
Figure 2.3.2 on oage 2.25, and pages 3.2, 3.3 -
a.
It should be confirmed that long-standing procedures such as safety manuals, criticality safety specifications and radiation work procedures will be kept current by an annual review and update.
b.
How is it assured (e.g., by approval review of health and safety staff) that operating procedures incorporate necessary safety precauti ons ?
1864 083
3 c.
(also relates to page 3.54) The temporary process deviation should be included in the Approval and Responsibility Matrix
.on page 2.25.
7.
The following commitments relevant to radiation safety practices should be confinned or deviations from the indicated action should be justified:
a.
Page 3.11 - Each glove box should be equipped with a device to measure the relative pressure in the enclosure, and a minimum negative pressure specified for operation, b.
Page 3.12 - Surface contamination surveys in the exclusion area where food is allowed should have a minimum daily 'requency.
c.
Page 3.13 - (upper item 2)
Cleanup operations should be conducted when smearable contamination on exposed or non-hooded surfaces 2
in uranit e process areas exceeds 5000 dpm (alpha) per 100 cm,
d.
f age 3.13 - (item 1)
If surfaces of equipment are painted wnere contamination levels exceed the limit specified in Annex C (attached), there...ould be a permanent record of the painting that. includes :
(1) date the painting was done, (2) identity of the potential contaminating radionuclides, (3) identification of the items painted, And (4) contamination level of each radio-nuclide on the surface.
e.
Page 3.15 - For routine release, personnel skin surface contamination levels should not exceed background.
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4 f.
Pace 3.16 - Permanently mounted air sampling equipment used to detennine the workers' breathing zone concentrations should be evaluated for representativeriess at least every twelve months and following process or equipment changes.
g.
Page 3.17 - The requirements of Regulatory Guide 8.11. " Application of Bioassay for Uranium," June 1974, should be followed, or an alternative program justified.
8.
Pace 3.12
" Radioactive Material Area" will be assumed to have the meaning given on page B-2.3 of Attachment B.
Also, why are the definitions of Attachment B not considered to be extensions of the license conditions?
9.
Page 3.21, caragraph 3.2.1.1 - The license conditions need to be supplemented with a clearer definition of inspection responsibilities for new equipment or process changes that require a criticality safety analysis.
This concerns confirmation that the conditions assumeri ano derived in the analysis are met in practice and installation.
10.
Page 3.26, caragraph 3.2.2.2 - There should be additional text (or a cross reference) to make clear that the 0.95 maximum multiplication factor will include allowances for calculational and experimental un ce rtain ti es.
11.
Page 3.27, caragraph 3.2.2.3 b - It is not clear that the monthly ins pectier.
.which appear to have an arbitrary frequency higher than 1864 085
5 usual) of neutron absorber structure are adequate to ensure continued absorber effectiveness.
Please explain the basis and intent of this r qu'irement.
12.
Pages 3.'27 and 3.28, paragraph 3.2.2.4 -
a.
The interaction criteria need further clarification and justifi-cation, particularly paragraph b cn page 3.28.
b.
The paragraph on structural integrity should include provision for a review of the integrity by a competent (civil, structural or otherwise qualified) engineer.
13.
Page 3.30, paragraoh 3.2.2.5 e -
a.
The solid angle method should be' subject to the constraints in TID-7016, Revision 2.
b.
Exxon Nuclear should incorporate specific exceptions (if the use of exceptions is planned) to the criteria for use of the solid angle method and provide justification.
c.
The second sentence of 'the paragraph, which refers to the use of empirical methods or theoretical models, should include a comitment to validated methods, referencing Pegulatory Guide 3.41,
" Validation of Calculational Methods for Nuclear Criticality S a fe ty. "
(This comment also applies to page 3.28, paragraph 3.2.2.5 A(3).)
14 Pages 3.30 and 3.31, caragraph 3.2.2.6 - Reference c should be replaced by TID-7016, Revision 2 and Reference f by LA-3366 (Rev.) dated November 1972.
1864 086
6 15.
Pace 3.37, paragraph 3.3.3 - Please identify the radionuclides to be analyzed in the stack samples, the action levels and the actions to be taken.
16.
Page 3.38, paragraoh 3.4 - This par'agraph should also include a commitment to compliance with all of the requirements of 10 CFR 20.303.
17.
Page 3.4,8_ - Please identify where retention tanks of 120,000 gallon capacity are described in the safety demonstration.
- 18. Pace 3.52 - The commitment to operator training should include the method (e.g., written tests signed by the employee) used to evaluate training effectiveness.
- 19. Page 3.54, paragraph 3.11 - Please confim that unless operation or maintenance work is covered by an effective Radiation Work Procedure, a Radiation Work Pemit (RWP) will 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 ccacentration 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 spe:ial local ventilation.
1864 087
7 All RWP's shall be signed by the manager of the affected facility, and the Super 11sor, Radiation Safety, or their designees prior to the start of operations except that during off-shift hours approval of the Super-visor, Radiation Safety, may be obtain via telephone.
- 20. Pace 3.56, paragraph 3.12.7 - Please explain the intent of this para-graph and give an example of application.
- 21. Page 3.57, paragraph 3.13.1 -
a.
Please confirm that the monthly radiation protection inspections will be made in accordance with a written plan.
b.
Please incorporate the required follow-up on the results of the monthly inspections by the Health Physics Component of Licensing and Compliance.
- 22. Page 3.58, caragraoh 3.13.2 -
a.
Please incorporate the required follow-up on the results of the monthly inspections of criticality safety practices at the plant.
b.
The Plant Criticality Safety Engineer has very limited responsibility for criticality problem analysis and different professional quali-fications from those of the qualified personnel in the Criticality Safety Component of Licensing and Compliance.
The commitment to inspection should, therefore, be augmented to ensure that the criticality specialist from Licensing and Compliance inspects the plant at least quarterly. Also, the inspections should be conducted in accordance with a plan.
1864 088
8 23.
Page 3.63, Table 3.2.1 -
a.
Please justify use of a mass of 0.8 minimum critical instead of the customary 0.75.
b.
Please justify use of a safe slab of 0.90 minimum critical instead of the customary <0.85 minimum critical.
- 24. Aopendix I, oage I-2.1 - The term "MUF" should be replaced with the term " inventory difference."
- 25. Paragraph 20.l(c) of 10 CFR Part 20 states in part that licensees should make every reasonable effort to maintain radiation exposures as far below the limit specified in that regulation as reasonably achievable (ALARA).
In order to permit us to evaluate your commitment to the ALARA principle, please provide an analysis of quarterly average occupational exposures (internal and external) covering at least the last two years of operations for each working area in each building in which licensed materials are or may be handled, stored or processed.
The analysis should identify the sources and locations where most exposures occurred as related to job categories and work activities.
The analysis of internal exposures should consider the air sampling data as well as the bioassay data (including in-vivo lung counting data).
The analysis should conclude with a description of any actions (taken -
or planned) to reduce employee exposures.
1864 089
.