ML19348A069
| ML19348A069 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 10/21/1981 |
| From: | Ketzlach N NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Zeff D BABCOCK & WILCOX CO. |
| References | |
| NUDOCS 8111030122 | |
| Download: ML19348A069 (13) | |
Text
'To DES tol fri Distribution:
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4 NMSS rf DCT 211981 FCUP rf NKetzlach (2)
LTyson FCUP:NK WTCrow 70-1201 RGPage RECunningham JBlaylock BBrooks ACabell RErickson 54\\ M f I / 4,/
Babcock & Wilcox Company JRobertson Nuclear Materials and Manufacturing Commercial Nuclear Fuel Plant
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Division BMKosla GPCoryell, R:II ATTN: Mr. D. W. Zeff, Manager y OCT2 71981* }
Health-Safety & Licensing ic.
P.O. Box 800 M U A bu m," g ^
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Lynchburg, Virginia 24505 (fi Gentlemen:
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We have completed the initial review of the renewal application for License No. SNM-ll68, dated February 27, if H, and find additional information is needed to complete our evalcation.
The enclosure to this letter lists our comments and questions relating to your renewal application, all of which were discussed with your staff dur their visit to our office on tetober 6-7, 1981.
Prior to submitting formal responses to our comments ano q"estions, you may find it prudent to arrange a meeting to discuss a draft of your responses.
Formal responses are due no later than December 11, 1981.
If there are any questions concerning this m. tr, please call me.
~
Sincerely, Original Signed by N. Ket::lach Nonnan Ketzlach Uranium Process Licensing Section j
Uranium Fuel Licensing Branch Division of Fuel Cycle and Haterial Safety l
E7 closure: As stated l
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Comments on Babcock & Wilcox Company Nuclear Materials and Manufacturing Division Commercial Nuclear Fuel Plant License Renewal Application License No. SNM-ll68, Docket No. 70-1201 I.
License Conditions A.
Section V 1.
Page 2 Idcrfify tha facility location of all authorized activities (e.g.,io01 fabrication, storage, laboratory operations, process development).
2.
Page 3, Sections 3.2 and 3.4 Provide in the demonstration section the precautions used in the storage of UF6 cylinders to show they are. adequate to protect the hr.ith and safety of thefoperating personnel, the public and the S rironment.
Include the information supplied to secure amendme.nt No.14 to your SNM-ll68 license. The storage area locations should be identified.
In addition, the nuclear criti-cality safety criteria for the storage of the erriched UF6 should be added to your license conditions section with the demonstration of their application added to the demonstration-section.
3.
Page 3, Section 3.6 Clarify the request for "c antamination quantities" on returned, unirradiated fuel componer.ts.
4.
Page 6, Section 5.0 t
Provide an organization chart showing all key positions of personnel having safet,-related responsibilities that shows separate lines of authority for production and safety functions.
The lines of responsibility leading to top management should be indicated.
Include the Safety Review Board on tne chart.
Describe the lines of authority that show the independence of the safety review and approval functions. -There does not appear to be an independent management review of the operations of the Health-Safety and Licensing Section. The 'ianager, Health-Safety and Licensing is chainnan of the Safety Review Board. He decides when Board action is needed and designates the " independent auditors."
5.
Page 6, Section 5.1 1
Include' the ALARA commitment as-part of the policy of all organizational components.
Describe the activities of the ALARA committee, the required audits and inspections for radiation, and the administrative I
o
. procedures for review of all new activities or changes in existing activities. State the committee's membership by position titles, the frequency of meetings, and the re-sponsibility for conducting periodic audits of occupational radiation exposures (external and internal), in-plant radioactivity and bicassay results, radioactive material i
releases to unrestrie.ted areas, and abnormal events or emergencies.
A formal annual report should be made by.the ALARA committee to senior management reviewing employee exposures and effluent release data to determine (1) if there are any upward trends developing in personnel exposures for identifiatle categories of workers, types of opr 'stions, or effluent releases, (2) if exposures and releaset might be lowered in accordance with the A'(RA concept, and (3) if equipment for effluent and exposuie control is being properly used, maintained, and inspected.
This report should include review of other required audits and inspections performed during the past 12 months.
In order to permit us to evaluate your commitment to the ALARA principle, please provide in a demonstration section an analysis of the annual' average of occupational exposures.
(internal and external) covering at-least the last 2 years of operation in each working area of the building in which the licensed materials are handled, stored or processed.
Include the maximum MPC - hours per quarter for the last two years. The analysis should identify the sources and locations where most exposures occurred relative to job categories and work activities. The analysis of internal exposure should con-sider the air sampling data as'Well as the bioassay data. The analysis should conclude with a,, description of any action (taken and planned) to reduce enployee exposure.
6.
Page 7, Section 5.3 Include in Section I the resume of at least one person satisfy-ing the minimum qualifications of Section 5.3.1.
7.
Page 9, Section 5.4.2 Confirm the independent auditors are the responsibility of the CNFP plant manager and are independent of the activities under review.
8.
Page 12, Section 6.1 a.
Specify the minimum frequency for inspection, by Health-Safety personnel, of ventilation, containment and air i
cleaning equipment.
. b.
Spacify-the minimum frequency for review of the air sampling and survey records by the' Health-Safety supervisor (s) and the fianager, Health-Safety and Licensing.
c.
Specify the minimum qualifications of the " qualified" designee who shall be responsible for conducting the air sampling and contamination survey-program.
d.
Specify the minimum qualifications represented by members on the Safety Review Board, by those attending a specific meeting, and the minimum number of members constituting a quorum, e.
Corfim the Manager, Health, Safety and Licensing and He.,.ith-Safety Supervisor have authority to suspend operation if radiation safety is jeopardized.
9.
Page 13, Section 6.1.1 a.
Specify the operations the Safety Review Board is required to review.
Include the Board's review of the ALARA commitment.
b.
Clarify a " minor" change.
c.
Specify w. o appoints members of the Safety Review Board and. to whom it is responsible.
d.
Confirm the Board ascertaing an independent red ew of nuclear criticality safety analysis has been made, where -
required, before authorizing an operation for handling or storing fissile material.
e.
Confirm all reviews made by the fianager, Health-Safety and Licensing, by-the Safety Review Board, and by the Supervisor, Health Safety,are documented, f.
Clarify who is required to review the documented nuclear safety evaluation or license amendment request.
- 10. Page 14, Section 6.1.2 a.
Describe the system for maintaining records relating to health and safety and their retention times. Such records include plant alterations or additions, abnormal and off-norn.al occurrences and events associated with radioactive
-releases, criticality analyses, audits and inspections, instrument calibrations, ALARA findings, employee training and retraining, personnel exposures, routine radiation surveys, and environmental surveys.
Confirm the records are kept for a minimum of two years or longer when required.
by regulatio.ns or other license conditions.
. b.- Confirm all suployees, whether they are newly hired or not, receive the initial training before they are, authorized to handle licensed material, c.
Confirm the documentation includes-the form 61 retraining.
as well as training.
.11.
Page 15, Section 6.2 a.
Describe the steps taken to assure management that operational personnel understand the radiation protection considerations of their work assignments.
b.
Describe the method uced to evaluate the effectiveness l ___
of the training and retraining programs.
12.
Page 16, Section 6.2 Confirm Health-Safety monitoring personnel receive their formal training prior to performing independent monitoring operations.
13.
Page 18, Section 6.5 a.
Describe the administrative controls that will ensure, tb.c prior to the start of L'y now or changed activity
.c any new or changed equipmenc or facility involving licensed material, an independent safety review is made and documented.
b.
Confirm all procedures shall. be available to the user in the working area and sha}l.be followed.
- 14. ~ Pages 19-21 a.
Confirm the audits include fire protection and environmental-quality.
b.
Specify the minimum frequency of audit reviews by the Manager, Health-Safety and Licensing.
c.
Confirm all audit reports are documented and include the recommendations for corrective actions and the renedial action taken on recommendations made during the previous audit.
d.
Confirm all primary audits (i.e., formal quarterly _ nuclear criticality safety and health physics) shall be conducted in accordance with a written plan.
~
. e.
Specify the minimum frequency for review and evaluation-of contamination survey data.
f.
Confirm records of all audits are maintained for at least two. years.
- 15. Page 21, Section 6.6 Confirm the licensee shall investigate and report to the Plant Manager any unusual events that could lead to radiation health and safety problems. The NRC shall be notified of such occurrences.
- 16. Page 23, Section 7.1.2 Confirm all units in an array will be considered (neglecting-shadowing) in calculating the total solid angle between units in an array (see NUREG/CR-1615, " Solid Angle and Surface Density as Critical Parameters," by J. T. Thomas dated October 1980).
Correct the demonstration in Section III, 7.4.2.13 to be consistent with this license condition.
17.
Page 31, Part E Specify the maximum safe volume in a demonstration section.
- 18. Page 32, Section 7.4.3.1 Cor firm. the fire-proof containers used to collect flammable wastes are covered.
- 19. Page 39, Section 7.4.4.1 c
Identify the criteria in "this section" for the maximum allowable moisture content in the powder.
20.
Page 49, Part F Confirm-there is a minimum spacing of 28 inches between individual stacked accumulations in the array (see existing license).
- 21. Page 52, Section 7.6 Clarify in the demonstration section.(see page 152 of Section III),-
that all fissile material is confined within a 6-foot slab.
- 6'-
22.
Page 52. Section 7.6C and Page 53, Section 7.7C
. Provide the limitations on the.use of the 2.3-inch smeared thickness for establishing safe interaction criteria. Specify the limits on'the maximum geometry or mass of a unit in the array. Justify the limits in Section III.
23.
Page 63, Section 8.1.1 Confirm the commitment to the 40 CFR 190 requirement as specified.
in Amendment No.12 (dated January 28,1980) in the existing license.
24.
Page 66, Section 8.1.4 Describe your environmental monitoring program and relate it to the map and table on page 67.
Include the location of your background station and the procedures for evaluating and re-porting results of the monitoring program.
25.
Page 68, Section 8.2.2 Change ALAP to ALARA.
26.
Page 70, Section 8.2.2 Confirm that the minimum hood face velscity shall be 100 LFM, whenever hood work involving dispersibio licensed material is being performed. Any alternative flow rate requested must be technically justified.
t
- 27. Page 71, Section 8.2.3 a.
Confirm the air samples shall be collected and analyzed after each shift or provide justification for a less frequent sampling program (also see Page 62, Section 8.1.lb).
b.
Confirm tha' if any. one sample meastres 1 MPC, the location and occurrence shall be investigated and corrective measures taken to prevent its reoccurrence, c.
Provide the method used to determine placement of fixed air samplers.
Specify the minimum frequency for testing the appropriateness of their placement.
28.
Page 73, Section 8.2.4 Confirm the use of respiratory protective equipment shall be governed by Regulatory Guide 8.15, " Acceptable Programs for Respiratory Protection," as required by 10 CFR 20.103(c).
,7-
- 29. Page 76, Section 8.3.3 Confirm the criticality monitoring system is designed to produce the desired signal within one-half second of activation by each initiating event.
(See Regulatory Guide 8.5, " Criticality and Other Interior Evacuation Signals," dated March 1981 and ANSI /ANS-N2.3-1979, "Immediate Evacuation Signals for Use in Industrial Installations.")
- 30. Page 79, Section 8.4.4 Confirm the licensee saall not allow an individual, whose skin or his clothing is found to be contaminated above background levels, +o axit a restricted area without 1
prior approval of Health-Safety.
- 31. Page 70, Section 8.4.5 Specify the maximum time period allowed before cleanup is initiated.
- 32. General Change all the criteria -in the license conditions section(s) to specific requirements (e.g., use "shall" instead of "are" or "will" - see Pages 5, 6, 7 and 8).
B.
Safety Conditions Not Addressed 1.
State the policy with regard to safety of the work place and the obligation at all times to cpmply with the license requirements.
It should be the policy of all drganizational components to keep-radiation exposures to employees and the general public as low as is reasonably achievable (ALARA).
2.
Clarify the requirements and conditions which govern the issuance l
of RWP's.
II. Demonstration Sections A.
Section I 1.
Page 2 a.
Identify and discuss Figure 1 (doesn't appear. to be in the application).
b.
Figure 2 should also be included.
2.
Page 5 a.
Confirm the " uranium other than oxide" form is UF.
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, b.
Specify, in a license conditions section, the minimum requirements for the safety related equipment for the protection of health and to minimize the danger to life or property (see Sections 3.2.2 and 3.2.3 of the draft Regulatory Guide, " Standard Format and Content for the Health and Safety Sections of Renewal Applications for Uranium Fuel Fabrication Plants," Task FP 716-4, dated October 1980).
c, Specify in a license conditions section the minimum re-quirements for procedures writing review and approval for both criticality and radiological safety control.
Section (a)(8) of 10 CFR 70.22 specifies more.than just criticality control procedures.
3.
Page 6 a.
Identify the document "provided in Section II."
b.
Identify the document "provided in Section VI."
c.
Identify the document "provided in Section VII."
4.
Appendix A Include the resumes of all personnel with safety related responsibilities, including the manufacturing personnel.
B.
Section III 1.
Page 2, Section 7.1.2 e
a.
Complete the identification of the referenced ANS Transactions report (include the author, pages and date of the report).
Identify the section of the report indicating the specified conclusions.
b.
Complete the equation for the interaction fraction, p.
c.
Identify interaction items a, b, and c.
2.
Page 4 Replace the graph by one that is legible.
3.
Page 5 Identify items "d" and "e".
4.
Page 13, Section 7.4.1 a.
Provide a flowsheet of the process operations and describe the process.
o
. b.
Include a facility description so that the safety of the-operations can be confirmed (e.g., work station and fuel storage area locations as identified in the nuclear safety analysisoftheoperations). Replace the " facility layout" of Page 1 of Appendix B by one that is legible.
If large drawings are required to make them legible, their size should meet the criteria sp'ecified in the draft standard format, Task FP 716-4.
5.
Page 41 a.
Correct the reference to ARH-600.
It should be.III.B.10(4) -
1 and 2.
The refergnce indicates the migration' area to be 28.5 rather 29.8 cm6.
b.
Correct the radial term in the buckling equation. The extrapolation length should be in the denominator.
c.
Demonstrate the applicability of the solid angle method for low enriched UO2 - water mixtures, d.
Justify the allowance for shadowing in the determination of the total solid angle for the central unit in an array (see NUREG/CR-1615, " Solid Angle and Surface Density as Criticality Parameters," by J. T. Thomas, dated October 1980).
6.
Page 66 Specify' the reference used for the SANGLE code.
~~
7.
Page 67 c
Identify the unit in the array from which the solid angle was measured.
8.
Page 83 The reference on sprinkler spray density has been used incorrectly and should be corrected:
a.
The discharge densities given for the particular sprinkler design is an average, not a maximum, and is based on a discharge rate of 20 gpm/ sprinkler.
b.
Your discharge density of 0.02 gpm/ft2 should be corrected 2
to 0.20 gpm/f t,
c.
.The 13.3 ft/sec used is not the minimum velocity but the velocity of droplets having a particular diameter. The droplet size distribution is a function of sprinkler type, size, and operating pressure. For a one-half inch
" Reliable" upright sprinkler (see YA0 reference) operating at 28 psi
- (30 gpm) 50% of'the droplets have a diameter smaller than 1 mm.
Droplets this size have a velocity of 13.3 f t/sec. The smaller' droplets have smaller velocities.
d..
The saturated steam data is not applicable because the water temperature becomes room temperature after the fire is out.
9.
Page 105 a.
Confirm the referenced Figure 2 is in'Part 7.4.2.3 (Page 51 of Section III).
1 b.
Identify. the section for the referenced Figure 1 (referencedonPages 105-106).
- 10. Page 106 Correct the weight percent of "Sterotex" to.0.3.
- 11. Page 111, Section 7.4.4.6 Clarify the sentence "The total hydrogen measurement - - - - -
to determine total H ntent."
2
- 12. Page 114, fourth to last line
~
Correct it to read "well qualified as the one performing the initial evaluation."
- 13. Page 129, Section 7.4.5.1.3 Clarify the first sentence.
14.
Page 138, Section 7.5.1 Confirm the clad thickness on each side of the core is 0.041 inches.
15.
Page 147 Demonstrate that an 8-inch thickness of concrete is adequate for isolation.
16.
Page 150, Section 7.6.2 Clarify the title of the last column in the table.
- 17. Page 153, Section 7.7.2.b Correct the fraction of critical and slab thickness ratios. They are a factor of 10 low.
4
. 18. Page 156 Identify Reference 4 (Reference 1 is on Page 162).
- 19. Page 158 Clarify the title to the "0.3f curve" (see comment No.16 above).
- 20. Page 177 a.
Identify the reference for the equivalent output of a 1-inch fog nozzle.
b.
Provide a conservative demonstration of the maximum water spray density from your sprinkler system (see comments made relative to Page 83 of the demonstration section).
- 21. Appendix A, Page 17 Summarize the verification of the KEN 0 code used.
Include the calculations made comparing the results with experimental data and the application of the limits of error to the evaluation of the nuclear criticality safety of plant operations.
22.
Fire Protection
-a.
Provide assurance the facilities are constructed and operated consistent with requirements of the applicable
~
safety codes.
b.
Provide evidence for the adpquacy of the fire protection program for the facility through nuclear liability and property insurance coverage.
C.
Section IV 1.
Page 1 Your " policy" statement should be incorporated in a license conditions section.
Include the authority of the Health-Safety component to stop hazardous or potentially hazardous operations until correction or resolution by plant management is obtained.
.