ML19323G222
| ML19323G222 | |
| Person / Time | |
|---|---|
| Site: | 07000033 |
| Issue date: | 05/12/1980 |
| From: | Ketzlach N NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Sherman F TEXAS INSTRUMENTS, INC. |
| References | |
| NUDOCS 8005300583 | |
| Download: ML19323G222 (19) | |
Text
. _ _ _ _
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,y } g((,g NUCLEAR REGULATORY COMMISSION e E WASHINGTON, D. C. 20555 3
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o MAY 121980 FCUF:NK 70-33 S!!it-23 Texas Instruments, Inc.
ATTN: Mr. F. L. Sherman Manager, HFIR Project Metal Systems Division Attleboro, Massachusetts 20703 Gentlemen:
We have completed the initial review of the Texas. Instruments, Inc. revised renewal application for License No. SNM-23 dated August 29, 1979, and find that additional information is needed to complete our evaluation. The enclosure to this letter lists our comments and questions relating to your renewal appl.ication, all of which were discussed with your staff during my visit on April 21-25, 1980.
Prior to submitting fonnal responses to our questions and comments, you may find it prudent to arrange a meeting to discuss a draft of your responses.
Formal responses are due no later than August 22, 1980.
If there are any questions concerning this matter, please call me.
Since rely,
/
f Norman Ketzlach Uranium Fuel Licensing Branch Division of Fuel Cycle and Material Safety
Enclosure:
Request for additional information 8005800 563
ENCLOSURE TEXAS INSTRUMENTS, INC. LICENSE RENEWAL APPLICATION INITIAL SAFETY REVIEW COMMENTS 1.
Page I.l.1 (a) Confirm the renewal application is in the name of Texas Instruments, Incorporated Material and Electrical Products Group.
(b) Define the Criticality Index (C.I.)
(c) Confirm no source material will be in the facility.
2.
Page 1.1.2 (a) Confirm the definition of " monitoring" is any measurement or observation related to the assessment or control of the following:
1.
Exposure to radiation and radioactive material and 2.
Nuclear criticality safety (b) Confirm a HFIR Project Employee is a TI employee who supervises or performs operations on and/or moves U 0s and U 0s fuel related components.
3 3
3.
Page I.2.1 (a) Confirm the license condition specifications reflect the license condition criteria as they shall be followed not just as they exist at the present time (e.g., the following minimum administrative practices shall be observed).
Confirm this clarification wherever inc'orrectly used in the license condition section.
(b) Confirm the approved written procedures are p'rovided and available in the work area and are followed.
4.
Page I.2.2 (a) Provide an organization chart in the license conditions section that shows the independence of the safety functions from the operations they review and approve.
(b) Update the responsibilities and authorities of key personnel in the organization.
(c) Clarify the statement the authority of the HFIR Project Manager is " derived from the TI Corporate Structure."
(d)
Indicate on Attachment II.3.1 the Manager, HFIR Quality Assurance reports to the Manager, Quality Assurance.
2 (e)
Identify those with authority to terminate operations which threaten the health and safety of the public or employees.
Confirm the Manager, Nuclear Safety also has this authority.
(f) Confirm that once terminated, the operation can restart only after remedial actions are taken to the satisfaction of the official who terminated the operation and written permission to restart is documented to the next higher level of management.
(g)
Include a safety Committee, composed of senior management personnel (and outside consultants, if needed), charged in the broadest sense with assuring management attention is devoted to the health and safety of the employees and the public and that adequate environmental protection is provided.
Provide the Committee functions which should include a review of abnormal events, approval of procedures and performance of audits.
Include senior management personnel on the Committee who are independent of the operations they review.
Also include the Committee's composition, responsibilities, minimum frequency of meetings, and reporting requirements.
(h)
Include the responsibilities of the nuclear criticality safety specialist consultant.
(i) Define exempt employees.
Identify the positions essential to safety considerations.
(j)
Identify the position responsible for the review and approval of changes in procedures and/or equipment that are related to industrial safety and fire protection.
(k) Confirm the Manager, Nuclear Safety reviews and approves all procedures tt.at relate to the handling and storage of licensed materials.
Include his other principal functions.
5.
Page I.2.3 (a) Confirm the two years' experience of the Manager, Nuclear Safety and the nuclear criticality safety specialist consultant shall include fissile material systems, operations and the methods of analysis 2
demonstrated in the renewal application.
3 (b) Confirm the Manager, Nuclear Safety has demonstrated experience in implementing a nuclear safety program.
(c)
Include the functions of the Attleboro Site Safety Director that are related to the HFIR Project.
6.
Page I.2.4 (a) Confirm the Nuclear Criticality Safety Speciali-st Consultant has at least three years' experience in evaluating nuclear safety programs.
(b) Confirm the training and retraining program includes, but is not limited to, the subject categories specified.
Confirm the training programs include industrial safety and the emergency procedures.
(c) Confirm the Manager, Nuclear Safety is responsible for the training program.
(d) Include the title, responsibilities and minimum qualifications of members of the Nuclear Safety Group who perform radiation or nuclear criticality safety functions.
7.
Page I.2.6 (a) Clarify the identification of the enrichment of the SNM.
(b) Specify the administrative control to maintain enrichment identity that can not result in erroneous identification of enrichment.
(c) Confirm the evaluation of the effectiveness of the training and retraining program is by test and the documentation of the programs includes the subject matter covered, the attendees, the date given, the name of the instructor, and the evaluation of its effectiveness.
(d) Include the work limitations on new support personnel in the HFIR project before training is received.
8.
Page I.2.7 (a) Confirn all approved procedures shall be followed.
(b) Clarify the location of operating procedures "near the work area".
(c) Confirm the Manager, Nuclear Safety reviews and approves both production operation procedures related to the handling and storage'of licensed materials and procedures related to the operation of the nuclear safety program.
4 (d) Confirm all procedures for the handling and storage of licensed material shall be reviewed annually and updated, promptly if out of date.
Identify the one responsible for the review, update and distribution of approved procedures.
(e) Confirm all procedures for conducting the nuclear safety program (radiation and nuclear criticality safety) are documented, approved by the. Manager, Nuclear Safety, reviewed annually and updated
~
promptly if out of date.
9.
Page I.2.9 Confirm criticality safety analyses and second party reviews are retained for at least two years or for at least six months after termination of the arsociated operations, whichever is longer.
10.
Page I.2.10 ' (a) Identify the minimum qualifications of the Manager, HFIR Project (see page I.2.3) that qualify him to review and approve the nuclear criticality safety analyses and to review nuclear safety operating procedures.
i (b)
Identify the criteria for changes that do not require an independent review beyond that made by the Manager, HFIRProject.
(c) Confirm that when a change is not within the limits of Tables 4.2.6.1 and 4.2.6.2 an NRC amendment is required.
(d) Confirm the reviews and analyses made by the qualified independent reviewer (e.g., Nuclear Criticality Safety Specialist Consultant) are documented.
11.
Pages I.3.1, I.3.2 Confirm a radiation safety specialist consultant performs an audit of the radiation safety program once every 12 months.
Specify the minimum qualifications of the radiation safety specialist.
. 12.
Pages I.3.2, I.3.3 Confirm that a formal annual report by the Manager, Nuclear Safety (health physics) shall be made to the ALARA Committee reviewing employee exposures and effluent release data to determine (1) if there are any upward trends developing in personnel exposure for identifiable categories of workers or types of operations or effluent releases,
5 (2) if exposures and releases might be lowered ih accordance with the concept of as low as reasonably achievabin, and (3) if equipment for effluent and exposure control is being properly used, maintained and inspected.
This report shall include review of other required audits and inspections performed during the past 12 months and review of the data from the following areas:
employee exposures; bioassay results; in plant airborne radioactivity and environmental monitoring.
13.
Page I.3.4 (a) Confirm that an alpha meter shall be available immediately upon exit from the FMA so that personal surveys of hands, shoes, clothing, etc. can be made.
(b) Confirm the unfiltered air within the FMA being released directly through the roof shall be sampled continuously and analyzed weekly or monitored by a continuous air monitor which alarms when the released airborne concentration reaches MPCa levels. The maximum quantity of weekly release from the facility (from the stack and through the roof) shall not exceed 1.0 pCi/wk by gross alpha counting.
14.
Page I.3.5 (a) Confirm that each high efficiency filter (HEPA) shall be equipped with a device to measure continuously the pressure difference across the filter and the filter shall be replaced when the pressure drop across the filter exceeds 4 inches of water.
The annual efficiency testing of the filter shall be~
conducted in accordance with Regulatory Guide 3.2 dated January 8, 1973.
(b) Confirm each glove box shall be equipped with a device to measure the negative pressure in the enc 1csure and a minimum negative pressure is specified for each operation.
15.
Page I.3.6 (a) Justify the absence of a beta / gamma survey meter to measure radiation exposure rates greater than 20 mr/hr.
j (b) Please also provide the information on the minimum number of radiation detecting instruments that is available for use for each type of instrumentation.
16.
Page I.3.6 Confirm the range of capabilities for detecting radioactive material in urinalysis samples, in vivo counting and film badges are beyond the stated ranges in the application.
6 17.
Page I.3.7 Clarify the frequency of monitoring occurs " prior to each continued use on an individual basis."
18.
Page ! 3.8 Confirm the room air in all areas where unclad uranium is handled, processed or where operations could result in worker exposure to the intake of quantities of uranium exceeding those specified in 10 CFR 20.103, shall be iagularly sampled and analyzed for uranium.
Air sampling shall be accomplished using fixed-location samplers and/or personnel samplers for basic evaluation of the exposure of workers.
The survey frequencies for the continuous air sampling shall be in accordance with TPS 1 of Regulatory Guide 8.24 dated October 1979, where applicable.
In addition, specify the minimum flow rate used in the air sampling.
The permanently mounted air sampling equipment normally used to determine concentrations in a worker's
(
breathing zone shall be evaluated for representativeness 1
at least once every 12 months and whenever any licensed process or equipment changes are made.
In addition, the location of air samplers shall be checked out at the commencement of operations in an area that has been shut down for more than six months to verify the representa-tiveness of the air sampling.
19.
Pages I.3.8, I.3.10, I.3.15 Confirm the evaluation of internal exposure to concentrations of radioactive material in air in restricted areas shall apply to all workers in the areas.
~
20.
Page I.3.10 Notwithstanding the statement that the records of the breathing zone monitoring results shall be kept for at least two years, the records of airborne concentrations in the working areas shall be kept in accordance with 10 CFR 20.401.
21.
Page I.3.11 Confirm the reporting of incidents or overexposures shall be in accordance with 10 CFR 20.403 and 10 CFR 20.405.
22.
Pages I.3.ll, I.3.14, I.3.15 Confirm the requirements of Regulatory Guide 8.11,
" Application of Bioassay for Uranium" dated June 1974, shall be followed, or justify an alternate program.
1 23.
Page I.3.14 Describe in the demonstration section the quality assurance program to check the accuracy and precision of the outside vendor's analytical services (e.g., urinalyses).
i
7 24.
Page I.3.17 Confirm the stack sampler (s) shall be operated continuously to insure a representative sample and the maximum quantity of weekly release from the facility shall not exceed 1.0 pCi/wk by gross alpha counting.
25.
Page I.3.21 (a)
Specify the protection factors applied when respiratory devices are used.
(b) Correct reference (a) to 49 CFR 172.403 on Attachment I.3.
26.
Page I.4.1 (a) Confirm the double contingency principle agrees with that in N16.1-1975.
(b) Specify the minimum qualifications of the members of the project staff, independent of Nuclear Safety, who make a " periodic" review of the effectiveness of the nuclear criticality safety program.
Specify the minimum frequency of the review.
(c)
Include the responsibility of the HFIR Project Manager for assuring an independent second party review.
27.
Page I.4.2 (a) Confirm all procedures involving licensed material include nuclear criticality safety controls.
Requests for review of changes to MSQ's are not adequate.
(b)
Identify the position to whom investigation of incidents shall be reported.
Include the Metal Systems Division Manufacturing Manager.
28.
Pace I.4.3 Confirm the manufacturirig foreman provides assurance that personnel under his supervision observe nuclear criticality safety limitations.
29.
Page I.4.4 (a) Justify the review of the nuclear safety analysis and approval by the Manager, HFIR Project.
He does not function independent of the operation he reviews.
He has manufacturing responsibilities.
(b)
Identify the minimum qualifications of the HFIR project manager to determine the Nuclear Safety Analysis and Approval (NSA&A) is consistent with the limit for single units, for interaction criteria, the thoroughness of the reviews by HFIR Nuclear Safety and the adequacy of the review by the Nuclear Safety Specialist Consultant.
L_
8 30.
Page I.4.5 Confirm the labeling of SNM is attached to or on the container to control the identity of the SNM.
31.
Page 1.4.6 (a) Confirm a member of Nuclear Safety partit.: pates in the " informal random monitoring".
Although the monitoring by the Manufacturing Foreman is a good practice, it can not be considered an independent monitoring of the nuclear safety of the operation.
The informal random monitoring should be included in
~
the demonstration rather than in the license condition section.
(b) Confirm the minimum frequency of the more formal monitoring (auditing) by a member of Nuclear Safety is monthly whenever SNM fuel handling activities are conducted curing the month.
32.
Page I.4.7 (a) Confirm the Manager, Nuclear Safety classifies the severity of the unauthorized activities found during the monthly monitoring and audit.
Include the classification criteria in a demonstration section.
(b) Confirm the monthly audit is performed by the Manager, Nuclear Safety or other equally qualified personnel for both nuclear criticality and radiation safety in accordance with a written review and audit plan and documented.
The audit report shall identify what was inspected, address each item in the audit plan, and corrective action to be taken.
Include corrective actions taken on previous recommendations.
Please provide in the demonstration section (Part II) of the application a description of the preconceived audit program.
(c) Confirm all audit reports are submitted to the Manager, HFIR Project and to the Metal Systems Division Manufacturing manager.
If desirable to submit less frequent reports to the latter, confirm the audit reports are submitted quarterly to the Metal Systems Division Manufacturing manager and include a summary of the monthly audits made during the quarter.
33.
Page I.4.8 Confirm the Manager, Nuclear Safety performs the monitoring of approved changes and documents his approval.
34.
Page I.4.9 (a) Provide clarification of "the criteria for monitoring is the approval".
9 (b)
Confirm the audits by the Nuclear Criticality Safety Specialist Consultant include an evaluation of the application of the nuclear criticality safety criteria to fuel fabrication operations.
(c) Confirm the Nuclear Criticality Safety Specialist Consultant prepares his own audit report and submits it to the Metal Systems Division Manufacturing Manager and to the Manager, HFIR Project.
(d) Confirm the audit report includes the areas audited, the audit findings and the recommendations for the improvement of the nuclear criticality safety program.
(e) Confirm that audit recommendations are reviewed and appropriate action is taken.
Document the reviews and actions taken.
35.
Pace I.4.10 (a) Add < before'468 g 23s0 (two places).
(b) Confirm water moderation (third paragraph) is interspersed moderation.
(c) Confirm moderation within an MSQ is assumed in an open container and/or when neutron moderatcr material is associated with the MSQ.
(d)
Include criteria that establish the conservatism of the assumption that full water reflection provides greater reactivity tc an MSQ or to an array than do the actual walls, ceiling and floor in the facility.
(e) Clarify the last part of the fifth paragraph beginning with "for circumstances which are physically limited" and ending with "cannot b'e attained".
The sentence is not complete.
(f) Confirm no inter-unit shielding is considered for facility interaction analyses (e.g., container walls, structural supports).
(g) Clarify the statement that replacing 2ssU by lH or 27Al will cause the system to be less reactive.
Under certain conditions the system may be more reactive.
10 36.
Page 1.4.11 (a)
If less than full water reflection is to be considered for the evaluation of MSQ's, include criteria for its application.
Otherwise always assume full water reflection.
This comment applies to both the first and last paragraphs on page I.4.11.
(b)
Explain mass measurement " decade errors."
(c) Clarify the last sentence in section 4.2.3.
It is incomplete.
~
(d) Confirm that the industry standards used are endorsed by the NRC.
(e) Confirm the mass limit applies only when double batching is possible.
The mass limit has not been justified for geometry controlled volumes.
Confirm that when double batching is not possible, the mass will be limited to no more than 75% of the minimum critical mass or include another criterion supported by adequate justification.
27.
Page I.4.12 (a)
Confirm the limits in Table 4.2.6.1 are not process limits but are limits which do not meet the double contingency principle.
Reference to the values in the Table as " limit values" is misleading and can possibly lead to a hazardous condition.
The limits given in the Table are a mixture of 90% of minimum critical, 90% of maximum subtritical, and between minimum critical and maximum subcritical.
Prepare tables for the license conditions section that clearly identify operating limits under normal conditions and are subtritical under accident conditions for moderated units, units that are unmoderated (H/2ssU = 0) and for units that have limited moderation (0 < H/23sU < 3),.
if needed.
Revise Appendix A to justify the operating
~
limits stated in Table 4.2.6.1.
Include the contingent condition of flooded units at work stations.
In establishing tables with truly limiting values, consideration should be given to the following:
(1) Reduce the number of significant figures in the Table to those warranted by the accuracy of the data.
(2) Correct the '*1imiting values." Maximum subcritical masses are not safe mass limits for the unmoderated units.
?
11 (3) Our evaluation of the spherical volume data referenced in Appendix A indicates the following changes are necessary for spherical volumes:
VOLUME (LITERS)
Presently in Table 4.2.6.1 Indicated by Referenced Data 3.99 3.94
~
8.37 7.4 7.22 7.2 16.10 13.0 34.70 33.1 396.80 407.
133.81 133.
305.52 302.
38.
Paae I.4.13 (a) Establish the maximum H/U'for each unit type in Table 4.2.6.2 and verify the demonstration of the C.I. assignment.
Include the container volume and container dimensions if safety related.
(b) Confirm the C.I. assignments are consistent with the most optimum array shape possible with the given number of units within the physical limits of the plant.
(c)
Identify the items in Tables 4.2.6.1 and 4.2.6.2 that are related to moderated operations (e.g., pickling and degreasing).
(d) Verify the nuclear criticality safety analyses of the C.I. indices reflect the indicated container volume, 23sU mass content, degree of internal moderation, unit spacing, array shape and size.
Consideration should be given to optimum intersper*.ed water moderation in " wet" areas.
(e) Confirm the values in Tables 4.2.6.1 and 4.2.6.2 are total uranium content or specify the criteria and.
provide justification for use of the uranium content as contained 23su to fuels of <93.Zg 23sU.
(f) Verify nuclear criticality safety is not compromised by accidentally double batching a single position in the array.
12 39.
Paae I.4.14 (a) Provide justification for the C.I.'s for the 6M containers (see related comments on Appendix B).
(b) Provide justification to allow the altering of center-to-center spacing between units by <25% of the stated values with no change to the C.I.
40.
Page I.4.15 (a) Confirm the k of 0.95 at the 95% confidence level correctsfor8herimentalaswellascalculational bias (see Appendix B).
Reconcile the k of 0.95 withthelimitingvalueof0.90asspecTNedin Appendix B.
(b) Confirm only C.I. 's in Table 4.2.6.2 will be used without NRC approval.
(c) Justify the application of "twice the maximum number of permitted packages in a Fissile Class III Shipment" in establishing'the C.I. of a unit when interspersed. water moderation is possible.
41.
Pace I.4.16 (a) Remove section 4.2.8.
The absence of criteria for neutron poisons is not a license condition.
(b) Confirm evaluations of the structural integrity are made for the single unit processes as well as for storage racks.
(c)
Identify "special controls," if required.
(d) Confirm distances shorter than 120 feet from a criticality alarm detector may be required when intervening shielding or other pertinent factors are present and 120 feet of equivalent air will not be exceeded.
42.
Paae I.S.1 Confirm there are no radioactive liquid releases from the HFIR facility.
It was noted that potential contamination from hands and/or body is removed by washing hands prior to monitoring, upon exit from the FMA, appears to be a TI requirement.
Provide assurance that waste discharged to the sewerage system meets the criteria of 10 CFR 20, Appendix B, Table II, Column 2.
43.
Chapter II.2 (a) Provide assurance Building 10 is constructed and operations performed therein are consistent with the requirements of the local fire safety codes.
This assurance may be by certification from appropriate local or state officials.
i
13 (b) Provide a copy of the latest fire safety inspection report made by the independent organization that establishes the insura!>ility of the facility.
44.
Page I1.1.3 Provide a brief history of the license (e.g., when first issued, incorporation of earlier licenses, names of companies in whose name earlier licenses were issued, when renewed).
45T Page II.2.2 Iaentify the functions of areas A through F.
45 Attachment II.3.4 Please attach the resume of current manager of nuclear safety and all others in the Nuclear Safety Group who perform radiation or nuclear criticality safety functions.
47.
Page II.7.1 Include the requirement. for approvals of process changes as well as MSQ's.
48.
Page II.8.1-(a) Demonstrate the safety of each unit type in 11.8.4 Table 4.2.6.2.
Include spacing between units at work stations having more than 1 MSQ.
(b) Specify container size (where significant to nuclear criticality safety), the mass limits per container and at a work or storage station, the number of plates, compacts, containers, etc., at a work or storage station.
This is necessary to demonstrate the application of Section I, license conditions and the analyses of " control failures".
49.
Attachment II.8.4 (a) Provide clarification between controls and process conditions.
The double contingency principle is based on two unlikely independent and concurrent changes in process conditions.
The safety demonstration is based on the failure of "no less than three independent and concurrent controls."
(b) Revise Table 4.2.6.1 to reflect the process limit values (see comments on Table 4.2.6.1).
(c) Analysis No. 1 - 4, 8, 9, 17, etc.
Confirm the safety of the 17 kg depends on the total volume 53.9 liters.
(d) Analysis No. 6.
Reconcile the subcriticality of moderated systems in 5.6 liter cans each containing 3.2 kg 23su with Appendix A, section 1.2 indicating the mass limit be in a 1 3.9 liter volume.
Identify
14 the criterion in Table 4 :.6.1 used to establish the nuclear criticality safety of the operation.
(e) Analysis No. 11, 12, 13.
Reconcile the moderated criticality limits with those given in Appendix A, section 2.2.
(f) Analysis No. 16.
Reconcile the moderated criticality limits with those given in Appendix A, section 3.2.
(g) Analysis No. 17.
Correct all analyses of credible control failures to reflect changes in Appendix A (see comments on Appendix A).
(h) Analysis No. 21.
IdentifythedataORNi./CSD/TM-55 that indicate 25 MSQ's of 3.2 kg 23su each are subcritical.
(i) Analysis No. 22, 3'1, 36.
Demonstrate moderation is not possible in the vacuum chamber or furnace when in the open position.
(j) Analysis No. 23.
Correct the 75% reduction in man to 25% reduction in mass.
The reduced limit is applicable with the concrete thickness <8 inches.
The mass limit should be reduced by 40% witli the concrete thickness >8 inches.
(k) Analysis No. 29.
Specify the basis for safety of the two degreasing racks with 49 plates (975 g 233U) or confirm each rack holds a maximum of 12 plates.
(1) Analysis No. 32, 33, 35.
Demonstrate the safety of two moderated fuel trays independent of spacing between trays or base the safety on controlled spacing between trays.
The latter case meets the double contingency criterion.
(m) Analysis No. 36, 37, 38.
Consideration should be given to moderated trays or boxes that are not touching (greater moderation and volumes possible).
(n) Analysis No. 39, 40, 42.
Justify the application of overmoderated U-H O criticality data (based on 2
g U/ml) to U-Al-H 0 systems.
2 l
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15 (o) Analysis No. 47, 48, 49.
Correct the reference to a report by N. Ketzlach.
It is a safety evaluation report associated with the review of a TI amendment application.
Include the basis for safety of the
" moderated" carts (e.g., cart design for 10 HFBR elements in an annular ring with a cover that precludes flooding between elements on a cart).
(p) Analysis No. 53.
Confirm vacuuming of large quantities of U 0s powder will not be approved.
3 Although the safety of the specified MSQ is not in question, the safety demonstration of 3.2 kg 2ssU has not been justified.
50.
Appendix A (a) Section 1.1 (1) Review and correct the data in the first paragraph.
3
[a]
The U 0s density should be 4.49 g U 0s/cm 3
3
[b] The increase factor for mass of U for reduced density is 2.9 corresponding to 126.1 kg U.
[c] The corresponding maximum subcritical U 0s 3
mass and volume are 148.8 kg and 33.1 liters, respectively.
[d] Consideration should be given to the lack of general experimental verification cf the core-density exponents.
The 1.46 exponent may be non-conservative.
[e]
Identify the compound in Table 3.1, TID-7016, Rev. 2 for which the density is 8.86.
(b) Section 1.2 (1)~ Correct the volume associated with 17.7 kg U 0s.
3 It should be 3.9 liters.
(2)
Reconcile the critical mass of 34.835 kg U02 with that stated in Y-DR-120.
(c) Section 2.1 Correct the volume associated with 178.1 kg U 0s.
It 3
should be 407 liters.
16 (d) Section 2.2 (1) Reconcile the subcritical mass and volume limits with the accuracy of reading Figure 2.1 in TID-7016 Rev. 2.
(2) The same comment applies to Figure 8 in TID-7028.
(e) Section 3.1 Reconcile the 158 liters of U 0s with the subcritical 3
U content of 150.8 kg.
(f) Section 3.2 (1)
Reconcile the minimum U density of 0.58 g/cm3 with the 0.27 g 23sU/cn3 in Table 4.2.6.1.
(2)
Correct'the 8.6 liter U 0, volume to 7.2 liters.
3 (g) Section 4.2 (1) Reconcile the 16.1 liter volume for the minimum subcritical mass with that shown in Figure 2.2 of TID-7016, Rev. 2.
(2) Reconcile the minimum critical mass of 807 g 235U with the maximum subcritical mass of 760 g
- 23sy, 51.
Attachment (a)
Page 1.
Reconcile the k of 1.00000 with the exp II.8.5 reported k f 1.0167 and 1.0054 for experiment exp numbers 1 and 19, respectively.
(b) Page 2.
Confirm ORNL/CSD/TM-58 is dated June 1978.
(c) Appendix B.
(1) Specify the storage " unit" dimensions on the demonstration pages of the C.I. assignments.
(2) Confirm the 15 x 15 x 1 and the 100 x 100 x 1 unit array are of the HFIR units and they are more reactive than the corresponding arrays of box type fuel elements.
(3) Borated Phenolic Foam Container.
Identify the engineering drawings related to the fuel element ccafiguration, re.ference the ORNL study for the
-, ~.,
17 nuclear criticality safety of the shipping container and demonstrate applicability of the study to the final container design.
(4) Justify the storage of twice the number of 6 M containers allowed in a Class III shipment.
Interspersed water moderation should be considered.
Confirm the U 0s powder has an H/23su greater (5) 3 than 0 but less than 3.
The corresponding C.I.'s for containers with 6.867 kg U and 10.3 kg U would be 0.08 and 0.4, respectively, if twice the number of undamaged containers aTiowed per Class-III shipment were permitted in storage.
(6) Justify the assignment of a C.I. = 0.01 to containers with Certificate of Compliance No. 5274.
(7) Reconcile the use of 0.05 g water /cm3 to establish the k for optimum interspersed moderatiawith'bfl25gwater/cm3 indicated by the demonstration included with your submittal dated September 6, 1979.
(8) Conclusions.
[a] Confirm that when mass limits are based on data for cubic cells and applied to noncubic cells the largest dimension does not exceed the smallest by more than a factor of 2.5.
[b] Demor. 9 ate the conservatism of applying the criterion for changing dimensions of evaluated cubic cells to non cubic cells with the changing of dimensions of evaluated non-cubic cells to non cubic cells having different dimensions.
52.
Attachment Identify the items in Tables 4.2.6.1 and 4.2.6.2 used 11.8.6 as criticality safety justification.
" 53.
Attachment Correct the C.I. Loading at TI for consistency with 11.8.7 comments on Table 4.2.6.2.
18 54.
General Comments (a) License application organization (1) Clarify the difference between attachments and appendices.
Identify their locations in the Table of Contents by title and section number (e.g., Appendix A follows Attachment I' 4.4, another Appendix A is part of Attachmen. II.8.5 and Appendix B is at the end of
. 1.8.5).
(2) Paginate all sections, attachments and appendices.
(b) Floor Plan - Relate the work station numbers on the floor plan with the corresponding nuclear criticality safety analysis.
4 e
l l
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