ML19341A136

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Safety Evaluation Supporting Licensee 801121 Application to Amend License SNM-1227 to Authorize Change in Filter Tests & Company Organization
ML19341A136
Person / Time
Site: Framatome ANP Richland
Issue date: 01/06/1981
From: Crow W, Stevenson R
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML19341A134 List:
References
NUDOCS 8101220197
Download: ML19341A136 (2)


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UNITED STATES

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g NUCLEAR REGULATORY COMMISSION

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DOCKET NO.:

70-1257 APPLICANT:

Exxon Nuclear Company (Exxon)

FACILITY:

Fuel Fabrication Plant Richland, Washington

SUBJECT:

REVIEW 0F APPLICATION TO AMEND LICENSE CONDITIONS CONCERNING HEPA FILTER TESTING AND THE EXXON ORGANIZATION, NOVEMBER 21, 1980, 07001257A05S

Background

Exxon's current license (SNM-1227) for the fuel fabrication plant in Richland calls for D0P testing of the HEPA filters used in the gaseous discharge system. Because of D0P's suspected carcinogenic properties, as reported in the draft report " Carcinogenesis Bioassay of Di (2-Ethylhexyl)

Phthalate" dated October 15,1980, D0P testing of HEPA filters has been discontinued by Exxon's supplier and testing is conducted using a replace-ment for the 00P.

Exxon is therefore proposing to delete references in the license to D0P testing of the final HEPA filters.

The subject amendrent application also includes a proposed alternative procedure for testing the final HEPA filter installations, revised wording concerning the differential pressure value at which the HEPA filters will be changed, and some changes in company organization and personnel.

Discussion The main change proposed by Exxon concerning the HEPA filters is deletion of references to DOP testing; the requirements for HEPA filter efficiencies and effluent releases would not be altered and the supplier of the HEPA filters may use some material other than D0P to conduct efficiency tests. Furthermore, Exxon is proposing an alternative to the use of intentionally added suspended material for testing filters after installation. The alternative procedure will be to sample and monitor the effluent continuously downstream of the filters using alarms on the monitor set at radioactivity levels twice back-ground. Such monitors will actuate remote alarms at locations under the routine surveillance of the Health Physics technicians.

The alternative procedure should be adequate to ensure that either the filters are effective following installation or corrective actions are taken.

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The current license states that HEPA filters are replaced when the differential pressure exceeds three inches of water. The licensee proposes to revise the wording so that the differential pressure does not exceed four inches of water, with the expectation that the filters will be replaced after the differential exceeds three inches.

Since most licensees (LWR fuel fabricators and others) allow the differential to attain four inches, this change will simply allow the Exxon practice to approach that commonly used.

The proposed changes in the organizational structure and personnel should have no effect on the safety of the operations. A major change is elimination of the position of Vice President, Projects, and transfer of the Corporate Licensing & Compliance Department from Projects to Engineering.

& Technology. The Vice President, Engineering & Technology, also receives responsibility for engineering design and development of nuclear fuels from the Vice President, Manufacturing. The individual to be assigned the position of Vice President, Engineering & Technology, is well qualified.

Similarly, the individuals to be assigned to other positions (including the President, the Manager of the U02 Plant, and the Licensing Engineer, Criticality Safety) meet applicable requirements for their respective positions.

The entire amendment application was discussed with Mr. William Cooley, principal inspector of the Exxon plant from Region V Office of Inspection and Enforcement, in a telecon on December 19, 1980. Mr. Cooley saw no objection to issuance of the authorizing license amendment.

Conclusion The proposed changes in filter testing procedures and change criteria involve no changes in efficiency or environmental release requirements and hence should cause no changes in the environmental effects of the plant operation. The personnel replacements and the changes in organization meet existing criteria for personnel qualifications and independence of the safety organization.

Further, the issuance of this license amendment is not deemed to be a major federal action significantly affecting the quality of the human environment; and thus, pursuant to Section 10 CFR 51, Section 51.5(d)(4), an environmental impact statement, negative declaration, or an environmental appraisal need not be prepared.

Approval of the amendment application is recommended.

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W4cw Robert L. Stevenson Uranium Process Licensing Section Uranium Fuel Licensing Branch Division of Fuel Cycle and Material Safety Approved by:

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.lh W. T.' Crow, Section Leader

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