ML20059F910
| ML20059F910 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 10/27/1993 |
| From: | Edgar J SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER |
| To: | Pierson R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| TAC-L30591, NUDOCS 9311050157 | |
| Download: ML20059F910 (8) | |
Text
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s30-136.7 ;
f S.IEMENS i
i October 27,1993 i
.i i
U.S. Nuclear Regulatory Commission
.l Attn: Mr. Robert C. Pierson, Chief l
Ucensing Branch
'j Division of Fuel Cycle Safety and Safeguards, NMSS
-)
Washington, DC 20555
{
Ucense No. SNM-1227 l
Docket No. 70-1257
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Dear Mr. Pierson:
Re:
- 1. Letter, JB Edgar to EG Adensam, dated March 8,1993..
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- 2. Letter, M Tokar to 1.J Maas,
- Relocation and Upgrade of UF Cylinder Storage s
and Handling Facility (TAC No. L30591)," dated August 16,1993.
In Reference 1 Siemens Power Corporation (SPC) informed the NRC of its plans to relocate its UF, cylinder handling and storage area. This relocation serves two purposes - one, to 1
alleviate the congestion inherent with the existing location and two, to make room for the '
t future dry conversion facility. The new UF facility represents neither a new emission source j
s nor an unreviewed safety question.. The same processes, methods of operating, safety --
requirements, and organizational responsibilities will be used at the new UF handling rand
- j 6
storage facility as are currently authorized in SPC's license. SPC disagrees, therefore, with the NRC's contention in Reference 2 that license conditions need to be added to Part i of its NRC license regarding this project.
Per my recent telephone conversations with Mary Adams of your staff, the September 8, l
1993, meeting among members of your organization and personnel from SPC, and my.-
meeting on September 30 with Mary Adams and Mike Lamastra, in which it was stated that the NRC's primary purpose is to obtain more information about SPC's processes and l
facilities, enclosed are SPC's replies to the requests for additional information in Reference 2. -
If you need further information, please call me at 500-375-8663.
Very truly yours, 0.
7 James B. Edgar ID Staff Engineer, Ucensing JBE:jb for pm Siemens Power Corporation g
Nuclear Division Engineenng and Manufactanng Facihty g
Tet (509) 375 8100 Fa)c (509) 375NA02 '
2101 Horn Rapds Roag. k$ (934] RcNand, WA 993520130 i
4 LICENSE - PART I As stated in the cover letter SPC disagrees that the information provided below in response to NRC's requests should be included in Part I as license conditicas. The content of SPC's replies, however, does provide pertinent additional information about the new UF cylinder s
handling and storage facility to aid in your review.
NRC Recuests 1.
The maximum number, size, and capacity of UF cylinders that will be stored and 6
handled in the area; 2.
A brief description of the UF cylinder facility and its operation, including operating g
equipment layout, safety-related equipment, and mechanical operations; SPC Reply The UF cylinder storage and handling facility will be located east of the Ammonia Recovery 3
Facility with paved access to the UO Building and the future dry conversion facility. The new 2
location will facilitate the servicing of these two buildings. A direct access road to Horn Rapids Road will be provided along with a truck staging area. This new road and staging area will alleviate the traffic congestion problems inherent with the current arrangement.
The operations occurring at the new facility will be identical to those at the existing facility; i.e., loading and unloading cylinders /overpacks on to and off of trailers; weighing and i
assaying cylinders; moving the cylinders to and from the UO Building and, in the future, the 2
Dry Conversion Facility; storing cylinders and overpacks; and pressure testing washed cylinders for recertification. Vaporization of the UF in the cylinders, heel removal, and 6
cylinder washing all take place in the UO Building. In the future vaporization, at least, will 2
also take place in the Dry Conversion Facility.
The facility will include an asphalt pad for single tier storage of 315 full UF cylinders and g
stacked (up to three high) storage of 105 empty cylinders. As discussed in the reply to NRC request 5 in this part, an infinite array of such cylinders is subcritical. The cylinders handled in the UF area are DOT specification 30 B cylinders (30 inches in diameter). A coverod area 6
will be provided, as part of the cylinder storage pad, for loading and unloading trucks, removing cylinders from overpacks, and transferring cylinders to the scale house. Two 5 ton motorized bridge cranes will be provided to service the ent;re cylinder storage area.
An 18 ft. x 40 ft. metal fabricated scale house will be provided to house equipment for weighing and assaying cylinders and to provide personnel comfort during inclement weather.
The scale house will provide for weighing and assaying two cylinders at a time with two rail trolleys. Each trolley will have access to either scale and will be able to be loaded from either side of the scale house.
An area on the asphalt pad, but separate from the cylinder storage area, will be provided for stacked storage of 125 UF cylinder overpacks. This area will be serviced by fork truck.
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Safety-related equipment includes guardrails to protect the facility from a vehicular crash and fire extinguishers and a nearby hydrant. In addition the pad will be slightly sloped to allow runoff to avoid standing liquids. The duplicate cranes and cylinder weighing facilities will allow for more orderly cylinder handling thus reducing the likelihood of an accident. The equipment for recertifying cylinders, i.e., the hydrostatic and pneumatic test hookups, have
-i been increased from one each to ten each which will allow for more controlled hooking up j
and unhooking cylinders for testing, thus reducing the likelihood of an accidental j
contamination accident. The nuclear criticality detector (NCD) system provides criticality detection coverage of the new UF facility.
g NRC Reauest i
3.
A brief summary of the management control system to be used at the new UF6 cylinder facility:
SPC Reply The operations at the UF facility are conducted by members of the Traffic component of the g
Traffic and Warehousing section which is part of the Materials and Scheduling Department.
Chapters 2 and 11 of our NRC license describe the company-wide management control system at SPC. This system will also be applied to the new UF facility.
s NRC Reauest 4.
A description of the processes that could pose a risk to the employees' or the public's health and safety or to the environment and safe operating parameters for those processes; t
SPC Reply The main danger to employees handling UF cylinders is from handling large, heavy objects; s
e.g., injury to hands and feet from getting pinched or crushed. Cylinders and overpacks, 4
both loaded and empty are handled using a crane or forklift. Cylinders stored outside of overpacks are stored on wooden chocks which prevent the cylinder from rolling. The precautions to be taken in handling the cylinders are described in the operating procedures for the facility. Because the UF is enclosed within cylinders with 1/2 inch steel walls which S
have been shown to contain the UF under hypothetical accident conditions, there should be 3
no risk to the public or the environment in transporting and storing the cylinders.
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NRC Reauest 5.
A description as to how nuclear criticality safety will be provided and the double contingency principle implemented at the UF cylinder storage and handling facility; s
SPC Repiv The criticality safety analysis for the existing UF facility is applicable as well to the new facility s
since there are no new unreviewed safety questions. Notwithstanding that the cylinders must meet enrichment (s 5% U-235) and purity (> 99.5% UF ) limits for shipping, the cylinders are 3
checked upon receipt at SPC to ensure these limits are met before they can be stored out of the overpack next to other cylinders or released for conversion. SPC currently only receives 30 inch cylinders and SPC limits require full cylinders to be stored in a single tier array only.
As mentioned earlier, the cylinders are constructed and periodically tested and recertified in accordance with DOT specifications and regulations. The storage area is surrounded by a traffic barrier guardrails.
K-infinity for an array of cylinders at optimum interstitial moderation is less than 0.9 for 30 inch cylinders. At the enrichments the 30 inch cylinders are licensed to contain, no physical arrangement of these cylinders can cause a criticality accident.
No single credible accident can rupture a cylinder and force enough water inside a cylinder to be a concern.
NRC Reauest 6.
A description of changes, if any, to the environmental monitoring program resulting fiom the UF cylinder facility relocation and upgrade; 6
SPC Reply No changes to the environmental monitoring program described in SPC's current license will be required by the new UF facility.
s NRC Reauest j
7.
A description of the processes and systems for handing, storing. and disposing of radioactive wastes; SPC Repiv No changes from the waste handling, storing and disposal program currently in place will be necessitated by the new UF facility. A description of the types cf wastes generated and the g
storage / disposal methods is provided in SPC's response to NRC request 5 in Part !!.
NRC Reovest 8.
A description of changes to the decommissioning plan resulting from the relocation and upgrade of the UF cylinder facility. Any changes to the cost estimate and g
decommissioning funding plan should be incorporated into the plan.
SPC Reply SPC has submitted (in 1990) and twice updated a Decommissioning Funding Plan (DFP) which the NRC is currently reviewing. We expect to update the financial assurance instruments for the plan annually and the plan itself every five years. We do not expect the activities carried out at this facility to result in environmental releases or contaminations relevant to future decommissioning efforts. We do, however, plan to take soil samples from the area where the new facility will be located, analyze them for U and U-235 content, and maintain records of such analyses in a decommissioning file.
LICENSE - PART 11 As stated in prelude to NRC's requests under Part I, SPC considers that the information requested hereunder should be used for information purposes to facilitate your review, not for inclusion into the license.
NRC Reouest 1.
Revisions to the figures in Chapter 10, Facility Description, showing the location of the new UF storage area and its buildings and structures; s
SPC ReoIV Once the new UF facility is in place, SPC will update the applicable drawings in Chapter 10 6
in both the existing license and the renewal application.
NRC Reouest 2.
An estimate of potential exposures of plant employees and the local population to any radioactive materials or radiation resulting from routine UF cylinder storage and 6
handling facility operations and from postulated plant accidents caused by credible events both internal and external to the plant; SPC Reply There is minimal exposure to employees from loaded cylinders reading a few mr/hr at the container surface and no exposure to the public from normal operation. At ambient temperatures UF is solid, so if a valve were broken off, there would be only a minimal 6
release.
SPC's emergency plan describes a fire at the present UF site which is near and at a lower s
elevation than diesel fuel storage tanks for emergency generators. The postulated fire, caused by a spark during an overflow accident during tank filling, would burn for approximately 20 minutes before the cylinder's valves or drain plugs blow out or the cylinder ruptures to release UF -
6 The new UF area is not near the diesel fuel storage tanks. The only fuel for a fire, therefore, 6
would come from the tank of a transport vehicle,300 gallons maximum, and the postulated fire at the new UF facility would be mL;h sma!!er. Such a fire would most likely be 6
extinguished quickly by the use of the fire extinguishers, described in the response to NRC request 4 in this part. In addition the response time for the Richland Fire Department to SPC is approximately 10 minutes. Due to the limited amount of fuel, the minimization of flammable material accumulations, the on-site fire fighting capability, and the response time of the off-site fire fighting department, the likelihood of a UF release caused by a fire is highly unlikely at g
the new UF facility. The on-and off-site consequences of such a fire and UF release are 6
g described in SPC's NRC-approved emergency plan.
NRC Recuest 3.
A listing of the building codes and standards used in the design and construction of the UF cylinder handling facility and the process equipment (e.g., bridge cranes, 3
scales, rail trolleys, storage racks), including any safety-class equipment and the basis for selection of that equipment; SPC Reply Codes and standards from t !c e ' awing organizations will be used in the construction of the UF pad and the structures eu,,f ;quipment therein: American Concrete institute (ACl), ASTM, s
American Welding Society (AWS), American Institute of Steel Construction (AISC), Federal Specifications (FS), American Iron and Steel Institute (AISI), industrial Fasteners Institute (II),
Sheet Metal and Air Conditioning Contractors National Association (SMACNA), National Fire Protection Association (NFPA), American National Standards Institute (ANSI), Uniform Building Code (UBC), Flat Glass Marketing Association, Commercial Standards (CS), Architectural Aluminum Manufacturer's Association (NAAMA), United States of America Standards institute (USASI), Bridge Crane Manufacturer's Association Specification, Hoist Manufacturer's Association, Crane Manufacturer's Association of America (CMAA), National Electrical Code (NEC), American Society of Mechanical Engineers (ASME), Underwriters Laboratory (UL), Air Conditioning and Refrigeration institute (ARI), Factory Mutual Engineering Corporation (FMEC), National Electrical Manufacturer's Association (NEMA), institute of Electrical and Electronic Engineers (IEEE), Richland Municipal Fire Code, and applicable Siemens Power Corporation criteria and standards.
The individual specifications, standards and criteria used hre listed in the Project Specification document for the UF facility project which is available for NRC perusal.
g NRC Recuest 4.
A discussion of the principal protection systems used at the UF cylinder storage and s
handling facility, including systems for fire and explosion protection, radiological protection, criticality safety, industrial and chemical safety, engineered confinement barriers, and engineered features to assist in decontamination of the UF cylinder 6
storage and handling facility; SPC Reply As described earlier there is a hydrant available to deliver water to fight a fire; there are also portable ABC fire extinguishers available; a 350 lb wheeled extinguisher on plant for fighting B/C fires; and the Richland Fire Department is available on 10 minutes' notice. Radiological protection is provided by surveying containers for dose rates and contamination and a system of Radiation Work Procedures (RWP's) describing radiation protection practices.
Industrial safety is provided by SOP's for handling the large, heavy cylinders and overpacks, by the cafety codes required on the handling equipment and structures, by the wood storage i
l chocks which prevent rolling, and by the crash guardrails. Criticality safety is assured by l
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moderation control and by limits on enrichment and purity of the UF. Other than as a result g
of the fire described in the reply to 2, above, an overfilled cylinder could rupture during vaporization in the UO Building, but not at the UF facility. During the receipt process 2
g cylinders are weighed both to confirm shipper's weights for accountability and to detect an overfilled condition. Any cylinder found to be overfilled above cylinder limits will not be released for conversion.
NRC Reauest 5.
An estimate of the types and volumes of radioactive waste that will be generated from the new UF facility and a description of treatment processes for gaseous, s
liquid, and solid wastes.
SPC Reply The types of radioactive wastes generated by the UF handling process consist of small 6
amounts of low level solid waste (rags, parar, etc.) and low level (a few ppm of uranium) liquid waste generated from hydrostatier' f testing washed cylinders for recertification. The 3
solid waste,40 - 50 ft /yr, is eits.., wi. to burial or incinerated. The liquid waste,20,000 -
30,000 gal /yr, is pumped to a lagoon as a prelude to future treatment. There are no gaseous wastes generated at this facility.
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