ML20057E080

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Summary of 930908 Revised Meeting W/Licensee to Discuss Criticality Safety Analysis Update Program & Dry Conversion Expansion Plans.Agenda & Attendance List Encl
ML20057E080
Person / Time
Site: Framatome ANP Richland
Issue date: 10/06/1993
From: Adams M
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Pierson R
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
NUDOCS 9310070249
Download: ML20057E080 (23)


Text

Docket: 70-1257 OCT 6 1993 MEMORANDUM FOR:

Robert C. Pierson, Chief Licensing Branch Division of Fuel Cycle Safety ano Safeguards, NMSS THRU:

Michael Tokar, Section Leader Licensing Section 2 Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS FROM:

Mary Adams Licensing Section 2 Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS

SUBJECT:

REVISED

SUMMARY

OF MEETING WITH SIEMENS POWER CORPORATION, SEPTEMBER 8, 1993 Enclosed is a copy of the agenda, attendance list, revised summary, and handouts of a meeting with Siemens Power Corporation (SPC) on September 8, 1993, to discuss the Criticality Safety Analysis Update Program and dry conversion expansion plans.

This meeting summary has been revised in accordance with SPC's request to eliminate information claimed to be t

proprietary.

Also discussed were issues related to SPC's license renewal and NRC's plans to revise 10 CFR Part 70 and the development of Standard Review P1ans.

[gg g g Mary Adams Licensing Section 2 Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS

Enclosures:

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Agenda 2.

Summary of meeting 3.

Attendance list 4.

Handouts i

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Siemens Power Corporation Distribution: w/encls.

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-Docket-70-1257

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AGENDA FOR SIEMENS POWER CORP MEETING SEPTEMBER 8, 1993 DWFN, Conference Room 4-B-11 INTRODUCTIONS - Mary Adams, Licensing Project Manager 8:00 i

CRITICALITY SAFETY ANALYSES UPDATE PROGRAM 8:15 Report from SPC - R. Vaughan, Manager, Sa'ety, Security, and i

Prog am Plan Summary Prog ess to date Findings i

Obsta lehlan Changes Progr.:

Schedule for future program efforts 10:15-10:30 - BREAK Discussion < Region V; R. Pierson, FCLB; C. Smith, FCOB I

11:45 - 12:45 LUNCH t

12:45 DRY CONVERSION EXPANSION PLANS Report from SPC - M. Valentine, Manager, Manufacturing Engineerin

- I.J. Urza, Manager, Manufacturing Technology f

Description of dry conversion process i

Experience at Richland and Lingon Plantsradiation, fire, criticality,

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I Safety provisions:

environmental protection, emergency response 2:15-2:30 - BREAK Design and construction schedule Anticipated start-up date License amendment application schedule NRC discussion - R. Pierson, M. Tokar, M. Adams, FCLB 4:00 - ADJOURN

1 MEETING WITH SIEMENS POWER CORPORATION AT NRC HEADQUARTERS I

September 8, 1993

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r 'ticality Safety Analysis Update Procram Ray. _ghan reported on the criticality safety analyses update program. They l

have two staff members, Cal Manning and Richard Coen, and two contractors, Mohr & Associates and Meier & Associates, as well as Lonnie Gerrald, Siemens'

.j former criticality safety specialist.

l Mr. Vaughan briefly described the three-phase program, as it is ' escribed in l

d Siemens' letter of December 30, 1992. The expected duration of the program is 2 years, with a 12-14 person-year effort. Mr. Ed Hough is the Project j

Manager. He reports to Vaughan.

e The consultants reviewed the 290 existing CSAs and checked to see if the basic j

assumptions for each CSA were still valid. About 80 of them were not used anymore, because the equipment was obsolete and no longer in use, and the CSAs were then archived. The CSA safety review team arranged the 216 remaining CSAs into 59 plant system groups. They also~ reviewed the CSAs for license compliance and 91-01 reportability and made three 91-01 reports.

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The CSA systems were then sorted into one of three ca'tegories. Category I indicated that the CSAs for the system need major urgent upgrading to

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demonstrate safe operation.

Category II-indicated that the CSAs for the l

l system.needed addenda or modification to strengthen the criticality safety controls. Category III indicated that the CSAs for the system are adequate i

i and need reformatting only.

Seven criteria on a categorization checklist were used to categorize the CSA systems.

j Four systems were identified as Category I, and three of them were reanalyzed l

or fixed immediately. The fourth is the SWUR incinerator, which is still shut L

down.

Phase 3 of the program reanalyzes Category II CSAs, to determine.what addenda are needed to strengthen the controls pending final upgrade. Also as part of i

Phase 3, tse engineering group is checking plant system drawings against the l

plant syste.n: "as-built." The team for the walkdown of the first system -

l (powder prep) discovered that the drawings were usually present but not well l

tracked. That is, new drawings were filed, but revisions to.

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l process and instrumentation diagrams, equipment arrangements, and other

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drawings were not consistently recorded.

SPC has contracted with Meier &

l Associates for mechanical engineering and drafting assistance to update the

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drawings. They are also setting up a system to maintain the as-builts of i

these drawings.

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i After this first walkdown is completed, SPC will train additional teams to i

j perform walkdowns of the other Category II systems. The plant engineer l

responsible for each system will lead each walk-down.

l After each CSA is updated, the Plant Manager indicates.by signature that the safety margin and residual risk are appropriate. NRC asked what criteria the 1

Plant Manager uses to make this determination, and SPC. stated that; it is more than

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simply an appropriate K and number of barriers, but that there is a fair. amount l

of judgement required.,#,An example is that moderator-controlled areas cannot have I

fire-suppression sprinkler systems; this necessary trade-off requires technical and management judgement.

Dry Conversion Expansion M. Valentine and I.J. Urza reported on the dry conversion expansion plans. Mr.

Valentine said SPC is experienced with the dry conversion process. They expect to i

be' operational by the end of 1906 and to be able to close the lagoons. Mr. Urza i

discussed the dry conversion plant at Siemens' plant at Lingen, Germany. This plant is the same as the one to be built at Richland, and has been in operation since the beginning of August.

l The hydrofluoric acid from the Richland plant will probably be sold to a chemical l

broker.

Siemens will construct two dry conversion lines with room in the building for a third line.

There are three systems for Criticality Safety Analyses - the reactor, calciner, and powder prep system. The entire reactor /calciner/ powder prep area will be moderator controlled. Mr. Urza presented a list of postulated accidents and the calculated exposures in case the accidents occur. Autoclaves will be explosion-resistant to contain a ruptured cylinder. The vaporized UF will flow through a 6

hot box, and a vacuum system will pull the heels down to about 1 kg.

Lines will be purged with nitrogen at startup and between cylinders.

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t With respect to the schedule, Siemens expects to submit the license amendment l

l application in the summer of 1994 and anticipates the amendment in early 1995.

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They will start construction in late 1994 and complete in early 1996, with start-l up'in mid-1996.

1 L'icense Renewal Mr. Pierson described NRC's plans for developing Standard Review Plans and '

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revising 10 CFR Part 70, as discussed during the August 17, 1993, licensees meeting. NRC expects to work together with industry in developing the SRPs. The l

new Part 70 will be proposed ~ in August 1994 and finalized in August 1995. New Part i

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70 will probably require new information and new parts of licenses, including l

integrated safety assessments, criticality safety analyses, and quality assurance.

i If Siemens' license is renewed before the new rule is promulgated..it will be necessary for them to update the license to comply with the new rule. The goal l

for renewal of Siemens' license is January 1995. This does not mean that the renewed license will be effective for only 8 months; but that it will need to be l

updated beginning with the effective date of the new rule.

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.g SPC-ND SIEMENS POWER CORPORATION CRITICALITY SAFETY ANALYSES UPDATE PROGRAM 4

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k SPC-ND Siemens Power Corporation Criticality Safety Analyses Update Program Description Three phase program Phase 1:

Review, validate and categorize CSAs, ECD: June 30,1993 Phase 2:

Prioritize and reanalyze Category l CSAs, ECD: January 31,1994 Phase 3:

Prioritize and reanalyze Category 11 CSAs, ECD: January 31,1995 Expected duration:

Two years - completion scheduled for January 31,1995 Program resource analysis: Expected 12 to 14 man-year effort Multi-disciplinary effort:

Operations, Manufacturing Engineering, Criticality Safety

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SPC-ND SIEMENS POWER CORPORATION CRITICALITY SAFETY ANALYSES UPDATE PROGRAM l

TASK OUTLINE i

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I Phase 1 Review, Validate, Categorize CSAs Consultant Reviews Existing '

Criticality Safety Review CSAs and Provide Team Defines Ust of Assumptions Process Systems to Project Manager i

l Project Manager Arranges Groups of CSAs into Systems Packages I

Project Manager t

Prepares Summary of Assumptions, Accident Condition for CSAs i

Engineering and Operations Validation of Current Assumptions

_and Accident Conditions Criticality Safety Review for Ucense Compliance and 91-01 Reoortability i

Sort CSAs into 3

Safety Imoact Categories l

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Category i Category 11 Category til CSAs for the System CSAs for the System Need CSAs for the System are Needs Major / Urgent Addenda to Strengthen Adequate as is and will be Upgrading to Demonstrate Controls Pending Fina! Upgrade Reformatted as Part of Periodic Review Safe Ooeration Phase 1 Comp!ete 5/93

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1 Phaso 2 Prioritize and Reanalyze i

l Category i CSAs 1

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Each Process System l

I Engineering & Criticality Safety Review i

As-Builts & Validated Assumptions &

Establish Credible Accident Conditions 4

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Engineering to Mark Complete New System CSAs

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l Matrixfor Future Review ]

Pertinent Drawings as j

Requiring C.S. Approval i

Before Changing System C.S. Review Team Validates Dimensions, Assumptions, Accident Conditions etc.

Plant Manager Indicates by Signature That Safety Margin and Residual Risk are Appropriate Place all Criticality Safety l Technical Basis g

Requirements in Criticality LDocument l

Safety Specifications i

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Procedures l

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l Analysis Document Establish Periodic Review of Assumptions Used in CSAs Phase 2 Complete 5/93

1 Phaso 3 Prioritize and Reanalyze l

Ccegory 11 CSAs i

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Each Process System 3

I Engineering & Criticality Safety Review As-Builts & Validated Assumptions &

Establish Credible Accident Conditions i

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I Engineering to Mark Complete Addenda

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to CSAs

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Matrix for Future Review l Pertinent Drawings as Requiring C.S. Approval Before Changing System L

Place all Criticality Safety JTechnical Basis

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d Requirements in Criticality 1 Document l

Safety Soecifications t

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Analysis Document i

Establish Periodic Review of Assumptions Used in CSAs Phase 3 Complete 5/93 6

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Phaso 3(Revised)

Prioritize and Reanalyze Category 11 CSAs

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.I Engineering & Critic ality Safety Review As-Builts & Validate 1 Assumptions &

Establish Credible Accident Conditions I

1 Engineering to Mark Complete New System CSAs

'g Add Assumptions to a l

_ Matrix for Future Review Pertinent Drawings as Requiring C.S. Approval Before Changing System C.S. Review Team Validates Dimensions, Assumptions,

_ Accident Conditions etc.

Plant Manager Indicates by Signature That Safety Margin and Residual Risk are Approcriate Place all Criticality Safety lTechnical Basis

'g Requirements in Criticality LDocument l

Safety Soecifications t

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I Phase 3 Complete

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SPC-ND Siemens Power Corporation Criticality Safety Analyses Update Program Progress Summary DATE ACCOMPLISHMENT December 11,1992 Draft plan of CSA update program issued December 29,1992 Resource requirements analysis completed 1

December 30,1992 Plan approved by SPC management January 6,1993 Draft task outline for CSA update plan issued January 8,1993 CSA program Steering Committee established / Project Manager appointed Criticality safety review teams (CSRT) assigned with written charter -

Phase IA begins January 29,1993 Criticality safety review teams establish 53 systems envelopes to encompass 216 existing CSAs February 4,1993 CSA assumption validation teams (Plant Engineering / Operations) assigned 09/93

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1 SPC-ND Siemens Power Corporation Criticality Safety Analyses Update Program Progress Summary (Continued)~

DATE ACCOMPLISHMENT February 10,1993 CSA systems packages prepared February 16,1993 All CSA systems packages issued to review teams by Project Manager March 29,1993 Implemented weekly status reporting and review at Safety, Security, and Ucensing (SS&L) Weekly Planning Meeting April 27,1993 NRC Bulletin 91-01 reportable condition on inadequate SWUR incineration criticality safety controls May 13,1993 Phase-1 A complete - initial CSRT review of all CSA systems packages completed May 17,1993 Presentation on CSA update program to NRC HQ and Region V representatives in Walnut Creek June 9,1993 SPC makesBulletin 91-01 Report on Une 1 Process Offgas (POG)

Scrubber Separator configuration. NRC Report Number 25632 and SPC letter dated July 9,-1993 refer.

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SPC-ND Siemens Power Corporation Criticality Safety Analyses Update Program Progress Summary (Continued)

ACCOMPLISHMENT DATE SPC makesBulletin 91-01 Report on UO Pellet Grinder Water Centrifuge 2

June 17,1993 Reservoir Configuration. NRC Report Number 25662 and SPC letters dated June 17,1993, and July 15,1993 refer.

NRC routine inspection review of program status. (NRC Inspection June 14-18,1993 Report No. 93-07).

Phase 1B complete - review and categorization by Criticality Safety June 29,1993 Component.

1 Oversight Committee program status review. System review priorities July 15,1993 established for first four systems. Team members for walkdown (as-built) of first system selected.

July 23,1993 As-built walkdown pilot team trained.

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Criticality Safety Analyses Update Program Progress Summary (Continued)

L DATE ACCOMPLISHMENT i

July 26-30,1993 NRC routine inspection review of program status. (NRC Inspection Report Number 93-09).

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August 11,1993 As-built pilot team debriefing to Oversight Committee. - Additional i

walkdown required.

August 23,1993 Oversight Committee meeting to review as-built task resources and refine 4

instructions for task.

August 24,1993 Quarterly Progress Report submitted to NRC.

initial contract engineering team (Meier and Associates) on-site for "as-August 30,1993 i

built" task team augmentation.

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4 SPC-N.D Siemens Power Corporation Criticality Safety Analyses Update Program Phase I Completion Summary Total Number of CSAs.................................................

216 Total Number of original systems 53 Total Number of current systems

..........................................59 Number of category 1 systems identified......................................

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Number of category 2 systems identified.....................................

28 Number of category 3 systems identified.....................................

27 Of the 4 packages originally identified as category 1 during this review, only SWUR remains a.

category 1. One category 2 system, MOP powder dissolution, will remain out of service pending implementation of stronger criticality safety controls on the process.. Immediate actions taken for each of the systems initially identified as category 1 shown on following slide.

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SPC-ND Siemens Power Corporation Criticality Safety Analyses Update Program Category I Determination Action Taken System Package 1.4 The checklist for this package shows this as a category 1 system. However, Line 1 Uranium the GEN 2.0 analysis adequately provides a safety basis for this operation.

Recovery Therefore the system will be handled as a category 2.

1.6 An additional overflow line was added to the Une 1 POG Offgas scrubber Process Offgas, system and an addendum to CSA U-1.29 was completed and this system was Line 1 changed to category.2.

2.6 The centrifuge clean water tank was equipped with an overflow line with a Pellet Grind &

maximum overflow depth of 8 inches. An elbow was found to be turned Inspection upward and the overflow depth was approximately 10 inches. The elbow was immediately turned down which returned the system to compliance.

Engineering did further modifications to provide a more positive means of overflow. After these changes the system was changed to category 2.

4.10 The system was shut down for repairs prior to this review. This system will SWUR remain down until a new analysis is complete and a startup council gives permission for the system to restart.

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SPC-ND Siemens Power Corporation CSA Update Program Phase l Categorization Checklist Are all obvious accident conditions with serious consequences documented?

a.

b.

Is the existing CSA adequately consistent with plant configuration to assure safety?

Are all major assumptions that have a primary impact on safety valid?

c.

d.

Are stronger controls needed to implement existing limits?

Does the system description need to be updated to include key items?

e.

f.

Are all major / minor assumptions that have a small impact on safety valid?

g.

Does the existing analysis meet license conditions for FWR & Optimum Moderation?

A "no" for any items a-c is a criterion for a Category 1 unless / until an addenda and / or modifications are complete so these questions could be answered affirmative.

A "yes" for items d and e or a "no" for items f and g are criteria for a Category 2 A "yes" for all items except d and e is a criterion for a Category 3 e.

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Siemens Power Corporation CSA Update Program Phase I Categorization Matrix Comments System #

a b

c d

e f

g Category _

1.2 y

y y

y n

y y

2 Interaction analysis should be more detailed and include a model of specific equipment Line 1 rather than use solid angle.

Vaporization CSA prohibits the use of water during heel reduction operations. It is noted that cylinder washing after the cylinders are weighed and-verified to contain less than 15.8 kg, up to 5-gallons of water is used to wash the interior of the UF cylinders. This is consistent with ANSI s

N14.1.

Vaporization scrubber assumptions in U-1.2.1 regarding interlocks / alarms need to be added to the CSS where the requirement is more visible.

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Siemens Power Corporation CSA Update Program Phase i Categorization Matrix System #

a b

c d

e f

g Category Comments 1.2 y

y y

y n.

y y

2 U-1.2 requires 2 independent, positive controls Line 1 to prevent moisture from process streams from Vaporization entering UF cylinders-the presence of these s

(Continued) two positive controls was evaluated and found to be in place. However, desired improvements were identified and will be specifically listed in the CSS when the new system CSA is complete.

i The frequency for periodic checks of these systems should be documented in the CSS where they are more visible.

1.3

-y y

y n

n

-y-y 2

The interaction analyses should be updated to

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ADU y

y y

n n

y y

reflect current equipment arrangements.

Process y

y

,y n

y y

y y

y y

n y

y y

The dryer analysis does not include the y

y

.y n

n y

y consequences of spilling uranium. liquids on the insulation. However, the insulation was y

y y

n n

y y

-y y

y n

n y

y recently changed and the consequences are not major. This condition will be specifically.

addressed when the analysis is redone.

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SPC-ND Siemens Power Corporation Criticality Safety Analyses Update Program Observations Exoected Benefits:

Improved safety analyses document packages to meet evolving standards Multi-disciplinary review - greater involvement of, and understanding by Operations and Manufacturing Engineering personnel System drawings and diagrams brought up to "as built" condition Improved logic in establishing systems and interfaces Reduced number.of CSAs to administer Expanded and clear statement of accident / upset condition scenarios evaluated and barriers / defenses to preclude criticality 09/93 m.m m

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