ML19325E012
| ML19325E012 | |
| Person / Time | |
|---|---|
| Site: | 07000036 |
| Issue date: | 10/20/1989 |
| From: | Bauser M ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY, NEWMAN & HOLTZINGER |
| To: | Bechhoefer C Atomic Safety and Licensing Board Panel |
| References | |
| CON-#489-9343 89-593-01-MLA, 89-593-1-MLA, MLA, NUDOCS 8910310193 | |
| Download: ML19325E012 (8) | |
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Charles Bechhoefer, Presiding Officer Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.-
20355 Re s. In the Matter of Combustion Engineering, Ince.
(Hematite Fuel Fabrication Facility, Special Nuclear Material License No. SNM-33)
Docket No. 70-36 MT.A. ART.nD JIo. 99-593-01-MT.A l
7 Dear Judge Bechhoefer
. Enclosed are answers to the three questions posed to
. Combustion' Engineering, Inc. (C-E) in your Memorandum and Order of September 25, 1989.
Each question has been repeated, essentially as presented, and is followedby C-E's response.
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October 20, 1989 i
. RESPONSES TO QUESTIONS POSED TO COMBUSTION ENGINEERING, INC.
IN MEMORANDUM AND ORDER DATED EEPTRMRRR 25, 1999 As part of its May 1, 1989, application for a license amendment, and again-in the further information-filed on August 18, 1989, the Applicant has set forth certain criticality considerat. ions as part of its description of the process of filling of bulk storage hoppers.
It states that "the K.fr 18 0.9744 0.0032."
It is my understanding, however, that the K.fr normally found' acceptable by the NRC Staff is 0.95.
See ANSI /ANS-8.1-1983, as incorporated in NRC Regulatory Guide 3.4,
" Nuclear. Criticality Safety in Operations With Fissionable i
Materials at Fuels and Materials Facilities" (Rev. 2, March, 1986).
In addition, the current license includes a provision limiting the K.fr to not in excess of 0.95 unless specifically authorize:1 (license SNM-33, Amendment 13, at 1 31).
Therefore, I have the following questions:
[
(1)
What justification are you providing for using a K.g, greater (i.e., less conservative) than 0.95?
Response
NRC Regulatory Guide 3.4, Revision 2, " Nuclear Critically Safety in Operations with Fissionable Materials at j
Fuels and Materials' Facilities," sets forth a method acceptable to the NRC for complying with the requirements of 10 C.F.R.,70 that applications for specific licenses contain proposed procedures to avoid accidental criticality.
As stated in its o
L Introduction, Regulatory Guide 3.4 describes procedures acceptable to the NRC staff for preventing accidental criticality in i.
operations with fissionable materials at tuels and materials facilitias.
. and for validating calculational methods used in assessing nuclear criticality safety.
Enclosure
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I Regulatory; Guide 3.4 endorses the methods of ANSI /ANS-8.1-1 1983, " Nuclear Criticality Safety in Operations with Fissionable Naterials outside Reactors," a stendard of the American National Standards Institute (" ANSI") and thE American Nuclear Society
("ANS").
The Applicant's application meets or exceeds all of the requirements of ANSI /ANS-8.1-1983, and conforms to the requirements of Regulatory Guide 3.4.
As noted in Part B of. Regulatory Guide 3.4, ANSI /ANS-0.1-1983 does not address the margin of safety to be used with the method.
So long as K,gg remains less than 1, accidental criticality does not occur.
Illustrative of the degree of safety provided by the design of C-E's system, under normal operation the value of K,gg for the UIq-UO2 Plant analyzed in Paragraph 8.3.4.1 of the application is calculated to be 0.2835 0.0050.
ANSI /ANS-8.1-1983 applies a " Double Contingency Principle" 5
to nuclear criticality safety analyses.
Under this principle, as stated in section 4.2.2 of ANSI /ANS-8.1-1983, Process designe should, in general, incorporate sufficient factors of safety to require at least two unlikely, independent, and concurrent changes in process conditions before a critically accident is possib3e.
In order to provide a more meani..gful and limiting analysis, Combustion Engineering evaluated conditions which required many f
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l 3-s Lehanges in process conditions or failures to act (rather than the two requirsd by ANSI /ANS-8.1-1983) before reaching the physical limits which result in the K.tr of 0.9744 d 0.0032.
These include:
1.
Failure of all heating elements (change in process conditions).
r 2.
Fai.'ure of low temperature alarm.
3.
Failt.re of operator to respond to R-3 temperature I,
indicator.
i 4.
Failure of pressure control system to close steam control valve (change in process conditions).
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Failure of high pressure alarm.
6.
Failure of high pressure switch to close steam inlet valve (change in process conditions).
.1 7.
Failure of operator to respond to R-3 pressure indicator.
8.
Failure of rupture disc to rupture (,hante in process conditions).
9.
Failure of operator to follow procettures which require unloading R.' reactor every 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> (change in prccess conditions).
(It takes at least three such failures (8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />) to fill R-3).
10.
In spite of #9, above, operator continues to open valve from R-2 to R-3 (chenge in process conditions).
The analysis also included the conservative assumptions: (a) that certain process vessels are surrounded by water, and (b) that a water mist of 0.001 g/cc axists in the oxide conversion room.
1 Even under these incredibly extreme conditions C-E's application
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' calculated K,n equal to 0.9744 1 0.0032.
li It should be noted that no special significance attaches to
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While that value of K rt represents a condition further removed from o
criticality than a higher value, the regulatory requirement is sir ply to remain'suberitical, a condition achieved so long as Keft it, in fact, less than one.
C-E did not rw-analyze the p' ant using " credible abnormal" conditions, i e, the two unlikely changes situation, because the conditic; actually analyzed is sore conservative and more limiting.
Moreover, since no specific value of suberitical F u is required by applicable standards and regulations, it was felt that the analysis in,the application promoted greater understanding of ths inherent safety margins in L
the process.
The NRC Staff previously considered the use of similar conservative assumptions by the Applicant, and found them acceptable.
(See NRC Safety Evaluation Report for Amendment 8 to License SNM-33, dated June 16, 1988, pp. 3 and 4.)
1 l
(2)
What changes in your application, if any, would result if you were to be limited to a K,gt of 0.95 or less?
Rasoonse: If a limit on K.it of 0.95 were imposed on the UFe-L UO2 Plant, the Applicant would be required to expend additional time and incur additional expense to perform nucleer criticality n
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. rat er t an t e more conservat ve cont ngenc er current y utilized.
Such an nalysis w3uld result,in lowe.e values of K,gg, but.would not provide any better' demonstration of'the criticality safety of the array.
Or,the contrary, since the Applicant would not be expected to perform two analyses, the more limiting 1
demonstration of margins'and the better understanding it provides 4:
would be lost in future applications for amendme
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a (3)
What would be the effect on your operations if I were p
to include a provision in your amended licenne i
comparable to 1 31 of your current license, covering the information submitted at i 8.3.4'.1'of your amendment application?
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Ragganaat So long as the values of K.tr reported for the
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3 amendment application are specifically authorized by.the license,
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l, a continuation of the condition of Paragraph 31 of the license L
would not affect operations.
It should be noted that comparable values of K,gr are currently so authorized.
This does not mean, 1
O however, that modification or deletion of Paragraph.31 may not be j
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appropriate at some future time.
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g UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'89 DCT 23 P4 :35 t
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'a ATONIC SAFETY AHD LICENSING BOARD PANEL,.,
Before Administre.tive Judge: CharlesBechheeYEbTNko
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In.the Matter of
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- COMBUSTION ENGINEERING, INC.
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Docket No. 70-36-MLA
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(Hematito' Fuel Fabricas. ion
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Facility, Special'Etclear
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ASLPB No. 89-593-10-MLA l
Materials License No. SNM-33)
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. CERTIFICATE DJ. SERVICE I hereby certify that copies.of the Letter to Charles Bechhoefer, Presiding Officer, from Michael A.'dauser, dated October 20, 1989, and the Enclosure thereto, have been served upon the
,hg; following persons by United States, mail, postage prepaid and i
property ' addressed, on tha date shown balows sa.
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Charles Bechhoefer*
Presiding Officer it g
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Atomic Safety and Licensing Board 1s' U.S. Nuclear Regulatory Commiscion i
i Washington, D.C-20555 s
Administrative Jurige*
Dr. Jerry R. Kline i
Atomic Safety and Licensing Board
,b.,L U.S. Nucleer Regulatory Comatin.vlon Washington, D.C.
20555 t
Adjudicatory File Atemic Safety and Licensing Board
(
U.S. Nuclear Regulatory Commission Washington, D.C.
20555 i
(Two copies)
.i s
Secretary
- I U.S. Nuclear Regulatory Commission j
b Washington, D.C.
20555 Attn:
Chief, Docketing & Service Section (Original plus to copies)
- Also served via messenger.
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Colleen P. Woodhead, Esq.*
Office of~the General Counsel U.S. Nuclear Regulatory Coi. mission washington,.D.C.
2055b i
Atomic Safety and Licensing App al Board Panel U.S. Nuclear Regulato ? Commission Washington, D.C.
20555 (Three copies)
Missouri State Senator **
L, Jeremiah W.
(Jay) Nixon 22nd District u
Room 42, State Capitol Jefferson City,~MO 63502 Karen Sisk**
1123 Wolf Hollow Road Imperial, MO 63052 l
Martha Dodson**
Crystal City, MO 63019 i
T Arlene Sandler**
President Coalition for the Environment St. Louis Chapter 6267 Delmar Boulavard l
St. Louis, MO 63130 i
l Dated this 20th day of October, 1999.
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.Tichael A.'.Bauser Newman and Holtzinger, P.C.
,d 1615 L Street, N.W.
Suite 1000 l
j Washington, D.C.
20036 t.7y Telephone:
202/955-6600
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