ML20041A356
| ML20041A356 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 02/02/1982 |
| From: | Bidinger G NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Vaughan C GENERAL ELECTRIC CO. |
| References | |
| NUDOCS 8202220021 | |
| Download: ML20041A356 (4) | |
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General Electric Company
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'lECEiVliD ATTN: Mr. Charles Vauqhan, Acting Manager
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Licensing and Compliance Audits 41_
, EB 4 1982% 18 P.O. Box 780 d""^meme Castle Hayne Road
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Gentlemen:
We have reviewed the December 4,1981 supplement to your December 27, 1979 application to construct and operate a new incinerator. Our review has identified additional information which is needed to demonstrate the safety of your proposed operation of the incinerator. The additional information is identified in the enclosure to this letter.
Seven referenced drawings were not enclosed with your supplement. Non-proprietary flow diagrams for the process and for facility ventilation should be provided as soon as possible.
In addition, a valid State of North Carolina discharge pennit should be provided.
Sincerely.
Oricinci signed by George H. Bidinger George H. Bidinger Uranium Process Licensing Section Uranium Fuel Licensing Branch Division of Fuel Cycle and Material Safety, NMSS
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Questions Concerning December 4,1981 Supplement To December 27, 1979 Application Appendix A I
1.
Your proposed incinerator limit of 250 g U-235 per box would require repackaging all boxes containing more U-235.
Because the average U-235 content of each box is about 240 grams, it would appear that a significant number of boxes will exceed the limit and will have to be repacked.
This may lead to unnecessary personnel or environmental exposures es well as operating problems in the repackaging area.
You are requested to reexamine this operating limit, taking into account ALARA, the safe mass limit for enriched uranium, and the uncertainty of measurements, to ensure that a reasonable balance is maintained between nuclear criticality safety and ALARA.
2.
The safety evaluatien for the incinerator process is based on uranium enriched to not more than 4% in the U-235 isotope.
Authorized WMD activities include powder blending with 4.5% enriched material and process development with 15% enriched material.
Please describe your controls to ensure that such enrichments do not contaminate combustibles which are designated for incineration.
3.
Module 1 and Figure M1 show an array separation distance of 12 feet for the waste box pad.
This distance does not satisfy the spacing criterion in the safety analysis attached to Module 1.
The array separation distance should be justified.
In addition, please verify that the U-?35 contents of all waste containers from onsite and offsite operations will be measured before they are stored on the pad.
4.
The safety analysis for safe mass control in the incinerator provides for the ICAMS computer lockout of the incinerator feed mechanism when the computer calculates that the U-235 in the next box plus U-235 holdup in the incinerator equals a safe mass of U-235. The incinerator is then to be shutdown and cleaned out.
The process and equipment description (Section 3 of Appendix A) indicates that after the safe mass limit is. reached, but prior to cleanout, internal waste boxes -
will be incinerated.
Since some of the internal waste, such as filters, may be generated during incineration of several batches, describe your controls to assure that the safe mass limit will not be exceeded by incineration of internal waste.
5.
The proposed batch limit on the incinerator, viz., a safe mass based on measurement plus a safe mass based on a 3 sigma uncertainty on the measurement, does not satisfy the double contingency policy in your license.
The safe mass limit should include the measurement and its asso'ciated uncertainty (although not necessarily at the 3 sigma level).
The operational limit for the incinerator should be revised accordingly.
In' addition, your program to determine the uncertainty of measurements
- ,n additions of U-235 to, and remoral from, the incinerator should be described.
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% 6.
The incinerator loading ram will be subjected to a water spray during the retraction stage.
Please describe the disposition of this water and evaluate the potential for moderating the U-235 in the incincator ash box.
7.
Describe your controls to assure that liquids, especially explosive liquids such as solvents, will not be in the waste boxes.
What are the design features to mitigate an explosion in the incinerator?
8.
Describe how the U-235 contents of drums of oil will be entered into the inventory in the incinerator.
Describe how the inventory of the incinerator will be adjusted after a cleanout'.
We note that only unsafe geometry portions will be observed or measured for holdup.
Please explain why only unsafe geometry sections of the incinerator will be observed and measured for holdup during cleanout.
9.
You propose to store containers of UO2 and ash on Pads 1, 2 or 11.
Describe the array and the physical barriers to maintain containers in the array.
You propose to demonstrate nuclear criticality safety by a general reference to a safety analysis for several powder storage areas.
Identify the particular area analysis which you are using and show that the environmental factors (array reflectors, air space between array and reflectors, steel conveyors, etc.) used in the safety analysis are valid for the pad storage.
10.
i~er all powder storage arrays, as well as the pad storage areas, show
- t. hat the calculated array reactivities (keff) satisfy reactivity limits in the license.
11.
Table 1 and Figure 2 of the Attachment to Module 1 contain errors in presentation of data.
The data presentation should be revised and reviewed to assure valid safety analysis.
Failure to detect and correct errors such as these raise serious questions about the effectiveness of the GE review and verification process.
12.
Please provide a description of your progam covering contamination control of the ash containers being moved to the storage pads, a description of your program to protect the stored containers from the t
I weather, and a description of your surveillance program for contami-nation control and weather protection for stored containers.
13.
Please identify the radionuclides to be incinerated.
14.
Please describe how the contaminated ash residue will be disposed of once j
the U-235 content is determined.
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. 15.
Please confirm that the following radiation safety practices will be followed in the incinerator facility or justify any deviations from these practices:
a.
The permanently mounted air sampling station normally used to determine concentration in'a worker's breathing zone shall be evaluated for representativeness during the first week of operation, and after this, the air sampling station shall be checked for its representative-ness at least once every 12 months.
b.
Airborne concentration of radioactivity in the incinerator facility will be evaluated every eight hours or more often when'the incinerator is in operation.
Furthermore, whenever any single air sample exceeds the applicable concentration in Appendix B, Table I of 10 CFR 20, the radiation safety officer shall make an investigation.
c.
(i) The survey for surface contamination in the incinerator facility shall be made daily for the first 30. days of operation.
If the 30-day average is less than 5000 dpm2/100 cm2 (removable),
the survey frequency may be changed to weekly.
(ii)
Cleanup operations shall be conducted within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> anytime the removable 2
contamination level exceeds 5000 dpma/100 cm.
16.
Confirm that the existing radiation protection program will be extended to incinerator operators.
In this regard, the proposed bioassay action level of 30 mg/ liter (Table 12-2 of Appendix B) appears to be in error.
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