ML20044H158
| ML20044H158 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 06/04/1993 |
| From: | Emeigh C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Maas L SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER |
| References | |
| TAC-L30547, NUDOCS 9306080011 | |
| Download: ML20044H158 (2) | |
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JUN 4 1993 Docket 70-1257 License SNM-1227 Mr. L. J. Maas, Manager Regulatory Compliance Siemens Power Corporation 2101 Horn Rapids Road Richland, Washington 99352-0130
Dear Mr. Haas:
SUBJECT:
NEW DRY CONVERSION CONSTRUCTION AND HF ACID RELEASE LIMITS (TAC NO. L30547)
This refers to your application dated April 28, 1993, regarding the proposed construction of a new facility to house the expanded dry conversion process and the sale of hydrofluoric acid.
Your application also discusses future licensing actions resulting from the dry conversion expansion.
We agree, based on the size of the building and its location on Siemens-controlled industrial property, that the construction will not significantly affect the human environment, and therefore, we have no objection to your i
initiating construction. However, as you recognized, License SNM-1227 must be amended prior to the introduction of radioactive material into the new area.
The amendment application should include a complete safety analysis that-addresses the building structure, radiation safety, nuclear criticality safety, chemical safety, process safety, fire protection, utilities, ventilation, and other considerations that may affect the health and safety of plant operators or members of the public.
The NRC will perform technical reviews of this plant design and operations information.
Based on this review, modifications to the building may be required..Therefore, you are proceeding with the proposed construction at your own risk.
Also, pursuant to 10 CFR Part 51, an environmental assessment of the potential impact of the proposed plant operations is required.
Because of the time necessary to perform the environmental assessment, as well as the possibility that the staff's technical review of the safety analysis might require modifications to the plant, you should submit your application and environmental report as soon as possible and well before planned installation of equipment.
Due to the significance and complexity of this facility expansion and the associated license amendment, we suggest that Siemens management staff directly responsible for the dry conversion expansion attend a meeting at NRC headquarters to discuss the expansion.
For this meeting, Siemens should prepare a presentation of the proposed expansion activities. The presentation should include a description of the dry conversion process, a summary of 1
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Siemens' experience with the existing test line, and detailed schedules for implemehting the expansion and submitting the license amendment application.
This meeting should be held as soon as possible to enable NRC to schedule staff resources for the license amendment and to coordinate this amendment with the renewal application.
NRC will make every effort to accommodate Siemens' project schedules; however, it must be recognized that this amendment activity will be prioritized in coordination with other NRC resource commitments and schedules.
With respect to your amendment application to authorize radioactivity limits for the unrestricted release of hydrofluoric acid from the currently licensed dry conversion line, and ultimately from the expanded dry conversion facility, you proposed limits on uranium content in the HF acid of 3 pCi/ml, as a running average of 10 batches, with no single batch exceeding 15 pCi/ml. This value was selected based upon the 3 pCi/ml limit for uranium released to the sewer, stated in 10 CFR Part 20 Appendix B.
The assumptions underlying the Part 20 sewer disposal criteria do not apply to industrial reuse of hydrofluoric acid.
A revised amendment application should include an environmental report containing a pathways analysis that considers potential uses of the HF acid, especially uses that may result in dilution or concentration of the uranium, such as in still bottoms or precipitates, and that follows these uses through final disposition. The pathways analysis should evaluate the radiological impacts resulting from both planned and accidental exposures and events. The evaluation results should be reported as committed effective dose equivalent per year for the maximally exposed individual, the critical groups, and the exposed general population and should provide sufficient assumptions, data, and results to allow NRC to perform an independent review. The collective dose for the exposed general population is exclusive of the critical group exposures and need not include individual dose contributions received at a rate of less than 0.1 mrem / year.
To arrange the meeting discussed above or if you have other questions, please contact Mary Adams, Project Manager, at 301-504-2505 or me at 301-504-2396.
Sincerely $igned Br W@igi Charles W. Emeigh, Acting Chief Licensing Branch '
Division of Fuel Cycle Safety and Safeguards, NMSS
- DISTRIBUTION (Control No. 6805)
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