ML19305B659
| ML19305B659 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 02/22/1980 |
| From: | Estey H SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER |
| To: | Crow W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML19305B652 | List: |
| References | |
| 15618, NUDOCS 8003200043 | |
| Download: ML19305B659 (32) | |
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'EDRON NUCLEAR COMPANY,Inc.
. J-2101 Horn Rapids Road P. O. Box 179. Richland. Washington 99352 Phone: (SC9) 375-8100 Telex: 15-2878 February 22, 1980 Mr. W. T. Crow, Section Leader Uranium Process Licensing Section Uranium Fuel Licensing Branch Division of Fuel Cycle & Material Safety U.S. Nuclear Regulatory Commission Washington, D. C. 20555 License No. SNM-1227 Docket No. 70-1257
Dear Mr. Crow:
SUBJECT:
NRC Questions on License Renewal Application
Reference:
Letter, W. T. Crow (NRC) to H. Paul Estey (ENC), dated December 10, 1979 Exxon Nuclear Ccmpany, Inc. hereby submits its. response to the questions raised by your staff on the subject license renewal application, as transmitted by your letter of December 10, 1979.
Respective pages of the licerse renewal application have been appro-priately amended in accordance with this repsonse, and seven copies of the amended pages are enclosed. Also, one copy.has been sent to Region V IE, and the Richland, WA, public library copy of the applica-tion has been updated accordingly by Exxon Nuclear.
Since the time that the license renewal application was submitted, there has been several changes made in the Exxon Nuclear organization; these changes have been incorporated into the Application as reflected in the enclosures.
Also, pertinent material (except Amendment No. 21, which will not be applicable at the time of renewal) submitted and received since the renewal application was made has been factored into the enclosures.
Sincerely, H. Paul Es ey, Manager Licensing and Compliance Operating Facilities Enclosurt.s CC: Mr. W. J. Cooley (USNRC Region V IE)
AN AFFILIATE OF EXXCN CORPOR AT10N s o oa 2o owe
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Response To Questions and Comments on License Renewal Application, Exxon Nuclear Company, (Transmittal Letter Dated May 31,1979)
Docket 70-1257 Concerning Part I and Appendices, proposed license conditions:
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Comesst Page 1.1, patagtacit 1.1 - Lt is planned 6ta.t 6te 1.nform.ti.on in 6te rencwal License for "au.thori:cd place of use" tci.it identify Bte bu.itdings in ukich Bte speelfied activities a,te.to be carried ou.t.
Please reia.te nte activities to be aubtori:ed Witit ste bu.iidings in which Bie) will be conduc.ted.
Response
Section 1.3 of the Application has been modified to reference a table of specific locations of authorizs i activities.
Table 1.3-1, " Specific Locatiens of Authorized Activities," has been added to Section 1 of the Application.
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Page 1.2, pa.tagraph 1.3 j
Coment fal I
Please confien Btat nie buildings ons.l.te in sdtic]t SMf is ptocessed or sto.ted meet an. identified bediding code or puvide outer infornttion to justify Ztsi.t acceptance as regastds resistance to damee bi fLte.
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Response
l Copies of letters from designers / builders of the subject buildings which certify the codes and standards complied with in the design /
construction of these buildings have been added to Attachment A (Section 7) of the Application. '
Commen.t fQ
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Please ptovide a copy of he la.tes.t ir.suitance (c.t cue,t independent agency) inspection.tepo>t.t fa.t be Euon Nite?rmt Richiand facilities in which he ptovisions fo.1 fL1e ptotection wc<te evaluated.
Response
A copy of the latest report, at the time the license renewal Application was submitted, was included in the Application, in the form of the July 19, 1978 letter f?om Edward K. Reitler (American Nucleir Insurers) to Robert Purcell (ENC). This letter is located
~ in Section 5 of Attachment A.
Although there is no "e/aluation" of fire protection provisions contained in this letter, the introductory paragraph of the letter mentions that fire protection was one of the items on which attention was focused during the June 27, 1978 inspection by fir. Reitler.
Further, an inspection of the fire protection features and practices of the plant was conducted by the Richland City Fire Department on February 13, 1980. A copy of the subsequent report has been added to Attachment A (Section 6) of the Application.
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Page 2.3, pauguph 2.2.1, ALARA ComnLttee Comen.t (a)
Please state de mininum frequency for meetings of de ALARA CoMee. The minimum frequency should be consistent win be revised repo,tt frequency indicated in b, fattaaing.
Response
The ALARA Comittee shall convene at least semi-annually. Section 2.2.1 of the Application has been modified to incorporate this requirement.
Comen.t (b)
To be consisten.t wi.th de ALARA revico reporting requirements in other siritar Licenses recently renaced, de ALARA Ccmittee revico reports should be issued at a. minimum 6-modh frequency.
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Response
The final result of each meeting of the ALARA Comittee shall be a formal report to the Industrial Health and Safety Council. Section 2.2.1, of the Application has been modified to incorporate this requireisent.
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Question Page 2.15, middle patagraph - O! hat is ne in. tent of "e'
- fied"in desstibing he.tequ.Lted qua.lifications of he healdt physics technicians?
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Response
Exxon Nuclear conducts its own internal Health physics Technician certification program.
In order for Health physics Technicians to be certified to be independently competent, they must meet the specified minimum qualifications and pass a formal examination approved by the Health Physics Component of Licensing & Compliance, Operating Facilities and administered by the Radiological Safety Supervisor.
(Also, see Section 3.10.2 of the Application.)
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Paaes 2.16 and 2.22 i
coment (c)
The minimum quafj. fica.tions of the second-pa.tbj reviceer should include a.uirimum of sco years of cititicality safety analysis expeit.icnce.
Resconse It is not clear how this comment applies to anything on page no.
2.16; the Plant Criticality Safety Engineer (Section 2.3.12) does not perfom either criticality safety analyses nor second-party revie.4s. For clarification, the word " application" has been addeu as the last word of the last sentence of Section 2.3.12.of the Application.
j The last sentence of Section 2.3.18 (previously Section 2.3.20) of the Application has been modified to require at least two years of experience in nuclear criticality safety analysis of at least one l
member cf the Criticality Safety Component and of each second-party reviewer.
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.5 Comment (b)
(Page 2.22, las.t paitahnaph! - Since not all membe.ts of tJte critientity Safeb) Component of.. atting and Compliance a.te requLted.to have
.the stated qualifica.tio-, references.to the C.titientitj Safety Componen.t eiscuiv>"". in.the conditions of License need furdter ztat.ificatics.
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Resoonse It is Exxon Nuclear's policy that initial criticality safety determinations may be perfomed by any member of the Criticality Safety Component, or by outside contractor personnel, as deemed appn griate by Manager, Corporate Licensing & Compliance.
- However, as.pecified in the second paragraph of Section 3.2.1.1 of the Application, each criticality safety determination shall be reviewed and approved by a second-party reviewer, and all second-party reviewers are required to have the stated qualifications.
6.
Fig ur~e 2. 3. 2 on pag e 2. 25, and pag es 3. 2, 3. 3 Comment (a)
Tt shcaid be confirmed that Long-standing p.tocedu.tes sudt as safet1]
^ manuals, criticalit;f safeb) specifications and radiation work procedures will be kept curtent by an annual review and upda,te.
Response
Appropriate wo-ds have been added to Sections 3.1.1, 3.2.1.1 (seventh paragraph), 3.2.1.2 and 3.9 of the Application to require annual review and appropriate updating of these manuals, specifica-tions and procedures.
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1 questian ib1 Hcw is it assured (e.g., by approvat review of healtit and safety staff) tha.t openating ptocedwtes incorpo.11te necessaty safety precautionst
Response
t Radiation Work Procedures and Criticality Safety Specifications are written for each operation, as stated in Section 3.1.1.3 and 3.2.1.1 of the Application. These Procedures and Specifications are reviewed and approved by respective health and safety personnel located in the Auxiliary Operations and the Licensing & Compliance, Operating Facilities components.
Operating Procedures are also written for each operation. These Procedures reference respective Radiation Work Procedures and Criticality Safety Specifications, and, as such, RWPs and CSSs become part of the Operating Procedures.
Copies of respective RWPs and CSSs are maintained in the opera-tional areas where they apply, along with copies of applicable Operating Procedures.
Coment (c)
(also relates to page 3.54) - The.. tempo.taty ptocess deviation i
shout.d be included in tlte Apptoval and Responsibility Mattix on page 2.25.
Response
The term " temporary process deviation" was mis-used by Exxon Nuclear in the Application; this tem has been replaced by the term ' Process Test Authorization".
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Responsibil,ities for the preparation, review and approval of Process j
Test Authorization have been included in the Approval and Responsi-bility Matrix (Figure 2.3-2) of the Application.
Also, the corresponding definition has been changed in Attachment B (now Appendix IV) of the Application.
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The following comlbnents relevant.to pndintion safettj practices should be confitmed or deviations from the indienhd action shouid be justified:
Connent (c)
Page 3.11 - Each glove box should be equipped with a device to measure. tite relative ptcssure in.t}te enciosure, and a ntininum negative ptessu.te specified fo.t opetation.
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Response
In discussions during the site visit by NRC staff members, it was determined that this comment applied to the pu-gloveboxes in the MO&SF building. These gloveboxes are equipped with ap gauges to measure and indicate the differential pressure between interior of the gloveboxes and room atmosphere. The gloveboxes are maintained nominally at a negative pressure of one (1) inch water gauge with respect to a room atmosphere.
Section 3.1.4.1 of the Application has been modified to incorporate these requirements.
Coment (6)
Page 3.12 - Surface cont:Mn su,tvetjs in tJte exclusion area where food.is aitcwed should have a minimum dcittj f.tequency.
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Response
Section 3.1.4.3(A) of the Application has been modified to include s
the requirement for daily contamination surveys of all lunch rooms located within the exclusion area of the plant.
Coment (c)
Page 3.13 - (upper item 2) Cleanup opera.tiona should be conducted when smearabt.e containation on exposed or non-hooded surfaces in E
uranium process areas exceeds 5000 dpm (alpha) per 100 cm.
Response
Exxon Nuclear established, and desires to continue use of the 2
smearable contamination limit value of 10,000 dpa per 100 cm on exposed ~or non-hooded surfaces in uranium process areas as an acceptable, safe, reasonable and workable personnel radiation
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protection control, in that:
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, o;..There is no evidence in Exxon Nuclear's facilities that Jf airborne concentrations of uranium are adversely affected by surface contamination at this level; o
-There is no evidence in Exxon Nuclear's facilities that personnel external radiation exposures are adversely affected by surface contamination at this level; In theory and in practice, the general contamination o
level will be considerably lower than the level at which cleanup is required; G
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o 10,000 dpm per 100 cm represents a level of contamination that is visible (5000 is not, in most instances), and thus, operators can clean up " excessive" contamination without there first being a survey performed by a Health physics Technician; o.
Health physic Technicians are not tied up on continuous surface contamination surveys of the intire process area, in order to be in compliance with this license condition, and can be more effective in other aspects of the radiation protection program.
Therefore, Exxon Nuclear proposes to retain the 10,000 dpm per 100 2
cm smearable contamination control value for uranium process areas.
Coraent (d)
Page 3.13 - (Lcem 1)
If su.tfaces of equ,ipmertt are pairled wheAe contanb= tion Levels exceed de Linlc spesified.in Annex C (attached),
nete shouil be a permnert.tecc.td of de painting tita.t inciudes:
(11 date the paintb1g was done, (2) identit.] of t.he poteuttia.l earttaninatb19,tadionueLides, (3) identifica. tion af tite Lter.s pa.irled, and (4) earttanina. tion level of each.tadionuclide on flie surface.
Response
Agreed. This section of the Application has been modified to include this requirement.
Cor:mertt (e)
Page 3.15 - Fat.toatine telease, petsartnet skin su.tface contanb:otion Levels should not exceed baekg.tound.
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Response
Agreed. A new section (3.1.4.3 (B)(1)(d) has been added to the Application to incorporate this requirement.
Comed (f)
Paae 3.16 - Penmanentbj mauded ait sampling equipment used to det.ennine the workers' breathing zone concentAa.tions shou.id be evaluated fa.1 reptesentativeness at least evetuj. twelve mondts and following ptocess n equipment changes.
Response
Agreed. Section 3.1.4.4(a) of the Application has been modified to incorporate this requirement.
Coment (g)
Page 3.17 - The requitements of Reguidoty Gtzide 8.11, " Application of Sloassay for Uranium," June 1974, sitould be fol. lowed, or an alterna.tive ptogram justified.
Response
In accordance with agreements reached in discussions during the NRC staff members' visit to the ENC plant, and later by telephone communi-cations with NRC staff members, Exxon Nuclear has modified Section 3.1.4.5 of the Application to the following:
" Bioassay Program The bioassay program established by Exxon Nuclear is normally conducted to confirm the results of radioactive material contami-nation control and room air monitoring programs and to detect I
.1 unsuspected intakes of radioactive materials.
However, it is also used to estimate internal exposures due to internally deposited radioactive material.
s The frequency and type of measurement is established on the. basis of the exposure potential of the individual's work assignment and the physical and biological properties of the radioactive material with which he works.
The following aspects of the bioassay program shall apply:
a)
An in-vivo examination is performed on all new employees who have previously handled special nuclear material prior to allowing them to work in Contamination Control Areas.
b)
A urine specimen from each employee scheduled for routine work in Contamination Control Areas is obtained and analyzed for uranium and/or plutonium, as appropriate, prior to allowing
.them to work in these Areas.
c)
Employees working in uranium-Contamination Control Areas submit monthly urine specimens for routine uranium analysis.
d)
Employees working in plutonium-Contamination Control Areas submit quarterly urine specimens for routine plutonium analysis, e)
Employees routinely working in areas where the airborne con-centration of radioactive material exceeds 10 percent of the respective Derived Air' Concentration (DAC) shall receive in-vivo examinations at least annually.
f)
If the most recent quarterly average of the at.rborne uranium concentration for any work area exceeds 25% of the respective e
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3 DAC the frequency of sampling and the type of bioassay measure-I ments for workers in that work area shall be modified to that given in Table 3 of Regulatory Guide 8.11. " Application of Bioassay for Uranium," June 1974.
Unusual occurrences with documented evaluation will not be included in calculating the quarterly average. However, diagnostic evaluations, as defined in Section C.2.b(4)'of Regulatory Guide 8.11, shall be perfonned in accordance with criteria set forth in Figure 2 of the same Guide.
g)
If an employee may have been exposed to greater than 40 DAC-hours of plutonium in air in any consecutive 7-day period, or if routine urinalysis exhibits > 0.2 dpm of Pu per 24-hour specimen, additional urinalyis shall be required within one working day follcwing detection. If confirming urinalysis exhibits > 0.2 dpm of pu, then an in-vivo examination shall
'be performed within one week.
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The following action guides and actions shall apply:
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For transoortable uranium ccmoounds, an individual whose urine specimen exhibits a concentration in excess of 25 ug U/1 is required to submit another urine specimen on his first work day following the Company's receipt of the result, and at least weekly thereafter until a concentration of less than 25 ug U/t is reached.
2.
For nontransoortable uranium and plutonium, should the future dose commitment to an individual's lung (based on in-vivo examinations) exceed 7.5 rem for the following 12 months, that individual will receive in-vivo examinations at least bi-monthly as long as
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he continues to work in Contamination Control Areas, and until that time when the future dose commitment to the lung for a subsequent 12-month period is less than 5 rem.
Any time that a dose evaluation is necessary, an investigation as to the possible source and cause shall be jointly conducted. by the Radiological Safety Su'pervisor and the Health Physics Component of the Licensing & Compliance, Operating Facilities Section.
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Individuals shall be restricted from work in Contamination Control Areas according to the following:
1.
For transcortable uranium compounds, any individual
- whose urine specimen exhibits a concentration in excess of 100 ug U/t; such individuals shall not be
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1 allowed to work in Contaminatio~n Control Areas until subsequent urine specimens exhibit a concentration of less than 25 ug U/t.
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For nontransoortable uranium and plutonium, any individual whose future dose commitment to the individual's lung (based on in-vivo examinations) exceeds 12 rem for a subsequent 12-month period; such individuals shall not be allowed to work in Contamination Control Areas until that time when his future dose commitment to the lung for a subsequent 12-month period is less than 7.5 rem."
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Comment G Question Page 3.12
" Radioactive Sfa.terial Area" will be assumed.to have 6te mean.ing given on page B-2.3 of Attaclunent_B. Also, sdty are 6te definitions of Attachment B not considered.to be ex. tensions of ble License conditions 2 i
Response
Agree.with meaning of the term " Radioactive Material Area".
The definitions contained in Attachment B of the Application have been moved to a new Appendix IV.
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Coment Page 3.21, pa.taauph 3.2.1.1 - The License conditions need to be supplemented scint a clearst definition of inspection.tesponsi-bilities for new equ.ipment o.t ptocess citanges 6ta.t require a criticality safety analysis. This concerns confirmation Btat Die
. conditions assumed and detived in Bte analysis are met in practice and ins'talia. tion.
Response.
A new section (3.2.1.7, " Confirmation of Analysis. Assumptions") has been added to the " Administrative Practices" section (3.2.1) of the Application to incorporate this requirement.
- 10. Coment Page 3.26, pa.taguph 3.2.2.2 - There should be additional tex.t for a stoss reference) to make clear Btat 0.95 max.imum multiplication factor will include altaatnce.s fa.1 cnfmtrational and experimen.ta.l uncertainties.
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Response
Sections 3.2.2.2and3.2.2.4(nowsection3.2.2.5)oftheApplica-tion have been rewritten to better define the maximum allowable reactivity and the restraints on it.
- 11. Comment Page 3.27, patagraph 3.2.2.3 b - it is not cicar Btet Bte mandsbj inspections (wh.ich appeat to have an stbittaraf frequency higher than usual) of neutton absorber situctu.te ste adequate tc ensure continaed absorber effectiveness.
Please exphtin ste basis and intent af Stis requitement.
Response
Section 3.2.2.3 (b) of the Application was written specifically for 4
the autoclave bas 6.ets, which have a central poison column. The B C 4
pois~on column is divided into thirteen equal sections, with the top section and one other section being x-rayed monthly so that the total column will be x-rayed during a twelve conth period to detect any voids or compaction.
Other applications of neutron at,sorbers may be in different forms or structures requiring inspections of different types or on different schedules to assure that the integrity of the neutron absorbers is verified on a periodic schedule compatable with its use. Section 3.2.2.3(b) of the Application has been modified to clarify the intent and basis of neutron aborber inspection fre-quencies.
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- 12. Pages 3.27 and 3.28, pangucit 3.2.2.4 Comment (a)
The inteuction critetia need furtiter cinti'ication and justifica. tion, partir"% tty paragrapit b on page 3.28.
Response
Reference the Response to Comment No.10. Sections 3.2.2.4(a) and (b) (now Section 3.2.2.5) of the Application have been modified to more percisely define the limits on maximum rcactivity for close packed multi-unit arrays. This criteria applys to arrays calcu-lated by M0!iTI CARLO techniques as opposed to arrays calculated by emperical methods such as Solid Angle as defined in Section 3.2.2.5(E)
(now Section 3.2.2.6) of the Application.
Comment (b)
The paragrapit on sttueturalinteg.tity sitould include provision for a review of bte in.tegrlty by a compe, tent (civii, sttuetural o.t obterwise qualified) engineet.
Response
Section 3.2.2.2 (last paragraph) (now Section 3.2.2.5) of the Appli-cation has been modified to include the requirement for review by a competent engineer in the field of designs where changes in geometry of the array could result in the loss of a contingency.
- 13. Comments Pag e 3. 30, pauguch 3. 2. 2. 5 e 1.
Tite solid angle metitod should be subjected.to.dte etnsttaints in T10-7016, Revision 2.
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.e b.
Exxon Nuclear should. incorporate specific exceptions (if de use of exceptions is planned).to the criteria for use of de solid angle method m1d ptovide justifica. tion.
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c.
The second sentence of de paragraph, schich refers to de use of empitical menods or neo.tetica.t. models, should include a comLonent.to valida.ted methods,.tefetencing Regata. tory Gaide l
3.41, " Val &' ion of Calculational Methods fa.t Nuclear Ctitical-ity Safety."
(This comment also applies to page 3.28, paAA~
graph 3. 2. 2. 5 A (3). )
Response
Exxon Nuclear's use of the solid angle method is subject to the constraints in TID-7016, Revision 2 except for the use of only the fully reflected solid angle criteria.
Section 3.2.2.5(E) (now Section 3.2.2.6) of the Application has been modified to include reference to TID-7016, Rev. 2, specific exceptions and justification for t' heir use, and a reference to Regulatcry Guide 3.41 " Validation of Calculational Methods for Nuclear Criticality Safety."
Section 3.2.2.5(A)(3) (now Section 3.2.2.6) of the Application has also been modified to incorporate reference to Regulatory Guide 3.14. _.
- 14. Commen.t Paaes 3.30 and 3.31, pa.tagraph 3.2.2.6 - Reference c. should be replaced by T10-7016, Revision 2 and Reference f by EA-3366 (Rev.)
dated Novembe.t 1972.
Resoonse j
Agreed. The subject References have been mcdified accordingly in the Application (Section 3.2.2.7).
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- 15. Coment Page 3.37, paragraph 3.3.3 - Please identi.fy tite radionuctides to be anaty:ed in klte stack samples, 211e action Levels and the actions to be taken.
Response
Samples of gaseous effluents potentially containing uranium are analyzed for gross alpha activity in the range of 4.1 to 4.8 Mev.
Samples of gaseous effluents potentially containing plutonium are analyzed for gross alpha activity in the range of 5.1 to 5.8 fiev, and th? results adjusted to the total activity by applying a correction factor calculated from isotopic analysis of the material being processed.
Action levels and associated actions to be taken are itemized in the attached table.
Section 3.3.3 of the Application has been modified to incorporate the information submitted in this Response.
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.1 Table (Comment No.15)
GASE0US EFFLUENT ACTION LEVELS AND ACTIONS I.
Concentrations (Individual Stacks)
Action Levels Seven-Day Sample Results (uC1/ml-Alphal U-Op.III M0-Op.I2)
Selection Criteria Required Actions (4) 6x10-16 Twice the lower detection level Recount sample (s); check for 7 day sampling time and 20 operations for possible j
minute counting time.
source.
5x10-15 Minimum concentration that can Increase sampling frequency be' detected for h minute to daily; check pressure drop counting time and 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> across all exhaust HEPA filters; sampling time.
re-evp.luate all relative exhaust sampler results; check for proper seating of related HEPA filters.
N lx10-13 Represents Exxon Nuclear's Shutdown associated intake fans annual Control Value (at and reduce exhaust flow rate;
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prepare to shut down associated process; inspect all related HEPA filters and replace all that exhibit any indication of inad-
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equacy; if final HEPA filters exhibit any deficiencies, replace them and DOP (in-place) test the final filter bank; perform particle size analyses of sampler filter papers; notify sensitive radiological laboratories within one mile radius.
Update summation of quantity of radioactive material released via gaseous effluents on a weekly basis until a discharge concentration below this Action Level is sustained for a full calendar quarter.
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' " A Table (Comment No.15) (continued)
L GASEOUS EFFLUENT ACTION LEVELS AND ACTIONS I.
Concentrations (Individual Stacks) (continued)
Action Levels Seven-Day Sample Results (uCi/ml-Alpha)
U-Op.III MO-Op.(2)
Selection Criteria Required Actions (4) 5x10-13 Represents Exxon Nuclear's Recount sample (s); check opera-design objective, tions for possible source, if activity is confirmed.
Increase sampling frequency to daily; check pressure drop across all exhaust HEPA filters; re-evalt ta i
all relative exhaust sampler results; check for proper seating of related HEPA filters.
Update summation of quantity of radioactive material released via gaseous effluents on a weekly basis until a discharge concentration below this Action Level is sustained for a full r..
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calendar quarter.
5x10-12 Represents Exxon Nuclear's Shutdown associated intake fans annual Control Value (at and reduce exhaust flow rate; stack).
prepare to shut down associated process; inspect all related HEPA filters and replace all that exhibit any indication of inad-equacy; if final HEPA filters exhibit any deficiencies, replace them and 00P (in-place) test the final filter bank; perfona particle size analyses of samlpler filter papers; notify sensitive radiological laboratories within one mile radius.
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Table (Connent No.15) (continued)
- !j GASEOUS EFFLUENT ACTION LEVELS AND ACTIONS I.
Concentrations (Individual Stacks) (continued)
Action Levels Sample Seven-Day (uCi/ml-Alpha)
Results
. U-Op. U )
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Selection Criteria Required Actions (4) 5x10-10 5x10-10 Preliminary corrective action Initiate orderly shutdown of not adequate. This value (at associated process for repair stack) would yield approxi-or correction of substandard mately the 10 CFR 20 Limiting conditions.
Initiate environ-Values (annual) at the nearest mental air sampling in down-unrestricted area, windsector(s).
2.5x10-7 2.5x10-7 This value (at stack) would Shutdown associated processes yield approximately 500 x the and HVAC systems imediately; 10 CFR 20 Limiting Values at notify NRC Region V I&E Office the nearest unrestricted area. within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> if this concen-If this value is sustained tration is sustained for a for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, 24-hour notifi-24-hour period.
cation is required.
2.5x10-6 2.5x10 This value would yield approx-Shutdown associated process &
imately 5000 x the 10 CFR 20 HVAC systems imediately; notify Limiting Values at the nearest NRC Region V I&E Office immed-unrestricted area.
If sus-iately if this concentration is tained for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, immedi-sustained for a 24-hour period, ate notification is required.
(1) Uranium-only operations.
(2) MixedOxide(Pu0-UO) operations.
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(3) Mixed 0xide Acti0n Levels represent the associated alpha activity only.
It is to be noted that the 10 CFR 20 limiting value (total alpha activity) for actual uranium-l plutonium mixtures is approximately two times higher than that for reactor grade l
plutonium alone; however, for simiplicity13 Exxon Nuclear's Control Value is f
conservatively taken as the latter (1x10 uC1/ml).
(4) Actions required at any one Action Level includes all action that would have been undertaken at lower Action Levels.
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.1 Taole (Coment No.15) (continued)
GASEOUS EFFLUENT ACTION LEVELS AND ACTIONS II. Quantities (Total Gaseous Effluent)
I4)
Action Levels (uci)
Selection Criteria Required Actions 25 per calendar quarter 1/2 of license condition Evaluate all gaseous effluent Report Value.
sampling data for the previous quarter to identify potential problems; investigate identified sources of elevated concentra-tions of radioactive material in gaseous effluents as described in Section I (for Action Levels less than ENC Annual Control Values) of this Table.
40 per calendar quarter Approaching license con-Take actions specified for dition Report Value.
Action Levels representing ENC
' Annual Centrol Values in Section I of this Table.
Update summation of quantity of radioactive material released via, gaseous effluents on a weekly basis until a weekly discharge rate of <1 uCi has been sustained for a full calendar quarter.
>50 per calendar quarter License condition Report Submit report to NRC within i-__
Value.
30 days identifying cause, along with corrective actions taken to reduce release rates; prepare to petition the NRC for a variance in accordance
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with the conditions of 40 CFR 190.11.
In the event that the calcu-lated dose to any member of the public in any consecutive 12-month period is about to exceed the limits specified in 40 CFR 190.10, shutdown all operations involving unencapsulated radioactive mat-erial and all HVAC systems imediately, and notify NRC Region V I&E Office imediately.
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- 16. Comen.t Page 3.38, paugraph 3.4 - This pa. tag.taph should also include a ec:. d. bent to compliance scith all of 4te.tequirements of 10 CFR 20.303.
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Response
Section 3.4 of the Application has been modified to incorporate this requirement.
17.. Comment Page 3.48 - Please identify schete.teten. tion t1nks of 120,000 gation capacity a.1e described in the safety demonstta. tion.
Response
The combined capacity of these two retention tanks is 60,000 gallons instead of tne 120,000 gallons stated in the Application. The Application has been corrected.
- 18. Comment
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Page '3.Si - The cormtibe>1t.to opeu.to.1 staining should include.the method (e.g., sctitten tests signed by the employee) used to eva.iuate ttaidng effec.tiveness.
Response
I l
Section 3.10 of the Application has been modified to incorporate the I
following:
Prior to assignment to independent operation, each employee is required, by signiture, to indicate that he has been instructed in radiation protection, criticality safety and emergency requirements and procedures.
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Employee awareness of and conformity to safety requirements and procedures, as well as the effectiveness of safety training programs, shall be evaluated at least monthly by the Radiological Safety Supervisor fu radiation protection, and by the Plant Criticality Safety Engineer for criticality safety. These ENC staff members have the authority to require retraining of employees.
The'se evaluations shall be documented, along with actions required by l
them.
- 19. Comment Page 3.54, panagraph 3.11 - Please confitm Btat unless operation or ma.intenance wod is covered by an effective Radiation Wod Procedure, a Fadiation Wod Fe,tmit (RWP) utiLL be prepared for aZL wod involving entty irtto a system containing S"'A o.1 where. a potential for,telease of containation exists such 6ta.t bte airbo.tne radioactivity concat-
.ttation to which employees are exposed f. tom Bie ptoposed opeM. tion or wad is Likely to exceed Bte concenttation in Appv1 dix B, Table 1, of 10 CFR 20 or B1e potettial exterral radiation exposu.te to which espiogees are exposed frcm 6te proposed operation or wod is Likely to exceed 6 mremlivt. The RWP's shall specify nte necessaraj radiation safety cortttels including but not Limited to repitatory prot.ection, special alt sampling, and special Local ventilation.
1 AlL RWP's shall be signed by tjte marager of Bte affec.ted facility, and Bte Supervisor, Radiation Safety, or titeir designees prior to tite statt of operations except titat during off-shift hou,ts approvat of tite Supervisor, Radiation Safety, may be obtained via telephone.
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Response
l Section 3.11 of the Application has been modified to incorporated t
this requirement.
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- 20. Commertt i
Page 3.56, mutagaaph 3.12.7 - Please explain tJte isttentt of this paragraph and give an example of application.
Response
Primary protection against an accidental criticality is assured by control of process variables at a minimum of locations in the Uranium Oxide Fuel Fabrication Building. At any location where control of the process provides primary (loss of one contingency) or secondary criticality control the variable and/or the method employed to control the variable will be monitored with an alarm in the control room or other conspicous location.
Locations within the process where this method of criticality control is used include the steam injection system for the calciners.
The Criticality Safety analysis assumes that the operation of the calciners are limited to dry 002 p wder or ADU at a maximum density 3
of 0.85 gm U/cm. Steam is produced in a heat exchanger and injected into the calciners to enhance the conversion process.
If water was allowed to enter the calciner at this point it would constitute the loss of a primary control. The steam lines to the calciners are monitored and flow to the calciners is stopped if the f
temperature drops below a preset point. The shutoff in the steam line is also alarmed to alert operators.
l Other locattas where process variables are used to assure criticality safety include the propczed ion exchange system, and the UF6 eductors in the vaporization process.
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- 21. Page 3.57, pa. agraph 3.13.1 Comment (a)
Plea.se confion Btat die mandsty radiation prot.ection inspec.tions will be made in acco.tdance wint a written plan.
Response _
Section 3.13.1 of the Application has been modified to incorporate this requirement.
Comment (b)
Please incorpo. tate tJte reqdted fattcto-up 'on tite result.s of B1e montitLj inspections by tite Health Phtjsics Componen.t of Licensing and Compliance.
Respons'e
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Section 3.13.1 of the Application has been modified to incorporate this requirement.
- 22. Page 3.58, paraarach 3.13.2 Comment (a)
Please incorporate tite requited folloco-up on ble results of Bte mondtlJ inspec.tions of criticality safet:] p.tactices at Bte plant.
Response
Section 3.13.2 of the Application has been modified to incorporate this requirement.
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Commed (b)
The Piad Criticalib) Safe.bj Engineer has veluj Lini.ted.tesponsi-bifibj for c.titicalib) ptobiem anabjsis and diffetent ptofcssional qualifications f. tam.those of de qualified personnelin de Cri.tlen11ty Safeb) Component of Licensing and Cor pliance. The comnibnent.to inspection shodd, ne,tefo,te, be augmented to ensure dat be criflentity specialist f tom Licensing and Compliance inspec.th de plant at ieast quarterbj.
Aiso, de inspec. tion should be cordncted in acco.tdance with a pian.
Response
The criticality safety inspection program is being revised to include monthly audits by the Plant Criticality Safety Engineer, and at.least bi-monthly audits by a member of the Criticality i
Safety Component of Licensing & Ccmpliance, Operating Facilities.
The Plant Criticality Safety Engineer will audit all areas containing special nuclear material for compliance to Criticality Safety Specifications, and with safe practices. The findings of these audits will be reported to appropriate managers. Most of the findings of this audit should be corrected during the audit.
The Criticality Safety Component of Licensing & Compliance, Operating Facilities will conduct bi-monthly audits. These audits will be detailed audits of the vario0s criticality safety programs, such as moderation control or enrichment control.
In additicn to the two types of audits mentioned above, the Criticality Safety Component will inspect new installation or modifications to equipment and processes prior to their operation with special nuclear material.
Section 3.13.2 of the Application has been modified to incorporate these changes.
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- 23. Comments i t Page 3.63, Table 3.2-2 a.
Ptcase justify use of a mass of 0.8 ninimum c,titicalinstead af Bte customam) 0.75.
b.
Please justify use of a safe slab of 0.90 minimum crit.ical
.instead of tJte cust.omatuj <_0.85 minimum critical.
Response
Tables 3.2-1 and 3.2-2 of the Application have been modified in the following cases:
a.
The safety factor for the safe mass limit has been changed to 0.75; b.
. The safety factor for a safe slab has been changed to 0.85
.of the minimum critical; c._
The safety factor for the safe rvlinder diameter has been
. set at 0.85 of the minicum crit diameter for all
-diameters; d.
The safe degree of enrichment has been eliminated; and e.
.The safety factor for the safe infinite slab for hetrogenous units has been changed to 0.85 of the critical infinite slab.
In addition to the limits given in Tables 3.2-1 and 3.2-2, the maximum reactivity for any accumulation of special nuclear material is subject to the constraints given in Section 3.2.2.2 (1) and (2); the maximum reactivity for any single unit will not exceed 0.95 at a 95 percent confidence level.
- 24. Comment Appendix 1, paae T-2.1 - Tite te,tm "ifUF" sitould be,tcplaced wint die te1m "invento,ty diffetence."
Response
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L Section 2 of Appendix I of the Application has been modified in accordance with above comment.
- 25. Comment Parag.tapit 20.1(c) of 10 CFR Patt 20 states in part fl11t licensees sitould make every reasonable effort to mabttain radiation expostutes as far betao tite limit specified in titet regulation as.tcasonabbj achievable (ALARA). In ordst.to permit us 2.0 evaluate. gour commit-ment.to tite ALARA principle, please p<tovide an anstysis of qusstetty average occupational exposwtes (inte,tnat and ex,ternat) coveting at least tite last too yea.ts of ope?Mians for eacit working atea. in each building.bt edticit Licensed materials a<te or may be Itandled, stored or processed. The analysis sitould identify tite soutecs and Locations where most exposures occured as related to job categories and work activities. The analysis of internal exposure should consider the alt sa=pling data as well as 11te bicassay data (inclu-I ding in-vivo lung counting data). The analysis should conclude with a description of ant) actions (takest of piam1ed) to reduce employee exposures.
Resconse A major portion of this information has previously submitted by letter of May 29, 1979 to W. T. Crow (fiRC) from H. P. Estoy (Etic) for the calender years of 1977 and 1978. However, that information has been expanded to include similar 1979 data, as well as additional 1
information required by the above Comment, and is presented below.
The information presented is for all employees, as appropriate, working with or around radioactive materials. However since employees are not always assigned to single locations but rather to functions, which cover several areas and/or buildings in many cases, the information is presented by function.
Presentation of the information in this-manner still represents all exposure incurred by employees at the plant.
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, J-5 The attached Sumary (Tables I through XII) presents employee j
external radiation exposures, facility room air sampling results, employee urine uranium concentrations, and employee in-vivo exam-ination results for the years of 1977,1978 and 1979.
The external radiation exposures (Tables I, II and III) for' employees are consistently low, with the average being approximately 100 mrem per year. Dosimeter results for office area workers, visitors, etc., are not included in these data. The employees working in the Pellet UF -UO Conversion & Scrap Recovery Operations and the UO2 6
2 Production areas receive higher external radiation exposures than do employees involved in other operations.
The room air concentrations of radioactive materials summarized in Tables IV, V and VI include data from air samplers used to monitor the effectiveness of contair. ment provided by equipment enclosures (sampling devices located at points of maximum potential, irrespective of representativeness for personnel exposure), as well as data from air samplers used to monitor personnel exposure to airborne radio-active materials. However, data frca air samplers used tn determine background values are not included in these Tables. Also, authorized protection factors for respiratory protection equipment used have not been applied to any of the air sampling data presented in these Tables.
Conversion & Scrap Recovery Areas and the Except for the UF - 02 6
UO Pellet Production areas, the average room air concentrations of 2
radioactive materials are consistently less than 10 percent of i respective DAC values, as would those for the two excepted areas be if equipment monitoring data were deleted from the attached Sumary and/or if protection factors for respiratory protection equipment used were applied to respective results. This statement is sup-l ported by data presented in Table VII through XII of the attached Sumary.
The occasional elevated room air concentrations of uranium in the l
Pellet UF -UO Conversion & Scrap Recovery areas and the UO2 6
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] ] ".1 Production areas reflected in Tables IV, V and VI of the attached Summary are directly attributable to increased throughput rates and startup of new systems and equipment, as well as to frequent clean-outs between campaigns of different enrichments.
However, Exxon Nuclear has not accepted the level of room air contamination as represented in Tables IV, V and VI for routine operations,.and during 1978-1979 made the equipment and facility j
modification listed in Table XIII in attempts to reduce airborne uranium contamination in the UO building.- In conjunction with 2
these physical improvements, additional administrative controls, as identified in Table XIV, have been implemented, and continue to be applied. Additionally, the facility modifications identified in Table XV are budgeted for 1980 to further improve room air con-tamination control.
The urinary uranium concentrations (Tables VII, VIII and IX) for employees are routinely low. The elevated values (maximums) shown for the.UF -U0 2 Conversion & Scrap Recovery Operations are attri-6 buted to_ unsuspected UF6 gas leaks; several of the physical modifi-
_ cations listed in Table XIII were made in order to prevent the release of such leaks to room air, and thus, reduce associated personnel exposures.
Since plutonium was not processed during this time frame (1977-1979), there is no urinary plutonium data presented in the attached l
Summary.
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The results of employee in-vivo examinations (Tables X, XI and XII) are routinely low, with the indicated positive results being in the
" questionably positive" range; this observation is supported by the fact that in no case does any one employee exhibit continueous positive results in subsequent in-vivo examinations.
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