ML20063N364

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Application to Amend OL, Reducing Possession Limits for Unirradiated Snm,Permitting Matl Licensed by State of CA to Be Neutrographed at Test Reactor & Providing Specific Relief from Provisions of 10CFR70.24
ML20063N364
Person / Time
Site: Vallecitos Nuclear Center
Issue date: 09/14/1982
From: Cunningham G
GENERAL ELECTRIC CO.
To:
Shared Package
ML20063N363 List:
References
NUDOCS 8209200306
Download: ML20063N364 (4)


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! AFFIRMATION 4

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,' PROPOSED AMENDMENTS TO LICENSE R-33 1

The General Electric Company hereby submits three proposed changes to License R-33.

1 i To the best of my knowledge and Delief, the information contained

! herein is accurate.

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! R. E. Butler, Acting Manager i l

Irradiation Processing Operation 1

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! Submitted and sworn before me this [4shM day of Mp4 , 1982.

Alo /kkd@nw, Notary Pu lic, in and for the County of Alameda,

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! State of California. ,

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i 8209200306 820910 PDR ADOCK 05000073 P PDR

September 10, 1982 PROPOSED AMENDMENTS TO LICENSE R-33 T. Proposed Amendments A. Paragraph 2.B.(2)a. of License R-33 should be amended to read:

4 a. 4 kilograms of contained U-235 as fuel for operation of the reactor; i

B. Paragraph 2.B.(3) should be amended to read:

(3) Pursuant to the Act and Title 10, Chapter I, Part 30, " Rules of General Applicability to Licensing of Byproduct Material",

(1) to receive, possess, and use 100 Curies of activated solids as contained in items such as encapsulating materials, structural materials, and components irradiated elsewhere, or any quantity of such materials authorized by State of California License 0017-59, as amended; (2) 10 Curies of tritium for pulsed neutron sources; and (3) to possess, but not to separate, such byproduct j material as may be produced by the operation of the reactor.

C. A new paragraph 2.C.(3) should be added to read:

(3) Exemption from the requirements of Section 70.24 of 10CFR70 I is granted for each area in which there is not more than:

(a) one shipment of packages containing special nuclear

materials licensed pursuant to 10CFR Part 71 for transport outside the confines of the Vallecitos Nuclear Center; packages in any shipment which depend on special arrangement for nuclear safety shall be retained in that same arrangement during such storage; (b) one safe batch of finished reactor i fuel rods or assemblies, providing no activities could cause rearrangement of fuel-bearing portions into more reactive configurations; or (c) 500 grams of U-235, 300 ' grams of U-233, or 300 grams of plutonium or a prorated combination of such materials provided the area is separated from other areas by a minimum of twelve inches of concrete or twelve feet of air and provided that no two such areas are located in the same room.

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September 10, 1982 PROPOSED AMENDMENTS TO LICENSE R-33 (Continued)

II. Safety Analyses A. The original possession limit for fuel at the NTR was four kilograms.

This was raised to eight kilograms by Amendment 10 to License R-33 (April 5,1976) in order to accommodate a proposed reload core.

Plans for this core have been cancelled, and there is no need for the higher limit.

B. Amendment 8 to License R-33 (August 20,1968) amended paragraph 2.B. of the license to permit the possession and use of material authorized by License SNM-960 in the NTR South Cell. Amendment 9 (April 5,1976) was a general revision of License R-33 which extended the authorization for SNM-960 material into the reactor cell and the control room. Amendment 10 further modified paragraph 2.B. to include the possession and use of material authorized under License TR-1 and added the North Room.

The proposed amendment to allow possession and use of materials authorized by State of California License 0017-59 is a logical extension of the previous licensing actions. It will permit materials such as irradiated reactor hardware possessed under License 0017-59 to be sent to the NTR for neutrography without having to officially transfer the material from License 0017-59 to License R-33 and back again. This can eliminate considerable superfluous paperwork.

As noted in our application (May 8,1968) for Amendment 8 and in the Commission's safety analysis for Amendment 8, the presence of these materials in areas peripheral to the reactor will not affect reactor operation.

C. As SNM possessed under Licenses SNM-960 and TR-1 are handled in NTR facilities, it could be interpreted that the provisions of 10CFR70.24 apply. However, the alarm levels required by that regulation are incompatible with neutrography operations or, in the case of the reactor cell, with reactor operation. It is recognized that certain assemblies and accumulations of fissile material are so inherently subcritical that a number of improbable events must occur simul-taneously for there to be even the possibility of a criticality event, and these assemblies and/or accumulations should be exempt from the requirements of 10CFR70.24. The NRC has, in fact, amended License SNM-960 (Amendment No. 21; October 28,1981) to exempt certain accumulations and assemblies from those regulatory requirements.

General Electric wishes to extend these exemptions into License R-33.

In support of this request, Amendment No. 21 to License SNM-960 and the NRC Safety Analyses for the amendment are enclosed as Attachment A to this Safety Analysis.

September 10, 1982 ATTACHMENT A Amendment No. 21 to License SNM-960, Docket 70-754 NRC Safety Analyses for Amendment No. 21

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! SNM-960,, Amendment No. 21 i

$ Gc neral Electric Ccmpany ATTri: G. C. Cunningha, j Senior Licensing Engineer Vallecitos Nuclear Center

,j P. O. Box 460

Pleasanton, California 94566 .

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3 Gentiemen:

Pursuant to T r tie 10, Code of Fet'eral ?egulatt ons, l'i " " , Caec f al Nuclear Ma terial License No. St.'M-960 i s l er&y a~a: d u ts . .ise ce Min nuclear criticility conditions in accordance with your application dated Aupst 14,1981 and its supplenent dat d September 25, 1981. Accordingly.

Appendix A of the current license is e ended to in:orporate a nes Section j 6.12 and a revised Section 3.8, and It..m 8 of the current licer.se is amended to add the dates of August 14, 1981 and September 24, 1981.

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Tha new and revised sections of >ppendix A shall reaa as folic. .

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'h "3.8 'Subcritical Area' means a hysicaily identifled are1 or location involving special uclev materials in no intities

,; of less than 500 grams of U- 235, Au gems of U-2; , or 300 grans of plutonium or a prora ted co4 f nation c: such

! materials under the directicn of a single area .'ai pr and which is unrelated to any other area where special asclear

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naterial is handled. A subtritical area is consic tred unrelated when it meets the isolation requirenent: of

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Section 6.11(c) of the Appendix and is r,t locater in the same room."

! "6.12 Monitor Alarm Exemption

" Exemption from the requireN ats of Section 70.24 ' .

, 10 CFR 70 is granted for eac h area in which there > et

'l more than: (a) one shipment of packages containiny specici nuclear miterials licensei tursuant to 10 CFR Par: li -

transport outside the confires of the Vallecitos dear Center; package; in any ship lent which depend on - Nial arranget ent for nuclear sa fety shall be retained M same arrangcment during such storage; (b) one saf. *1

of finished rea'
tor fuel rods or assenblies, prov irG no activities could cause ri arrangeneat of fuel-bF ing portions into mre reactive configurations; (c) nr , more than 600 grams of plutoniun as Pu-Be sources; (d)

(7 which meets the requirements of scacritical area aa j V defined in Section 3.8 of this Appendix."

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, The changes incorporated in Tppendix A are reflected in the attached a

replacer: tent, pages 5-A and 23.

All other conditions of this license shall rema h the same.

'f These changes will be incorporated into 1 pending application for renewal

, of License No. SNM-960.

a FOR T4E ;,JCLF',R REGULATORY CC:,:iU5 ION 3

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.- l Lelar.d C. Rouse, Chief a Advanced Fuel and Spent Fuel Licensing Branch j Division of Fuel Cycle and

, Material Safety

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Enclosure:

! Ar: ended Appendix A

? " License Conditions,"

pages 5-A and 23 4

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/, C h NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 2ZZ

' i ;,i f j' OCT 2 8 f41 Docket fio.70-754 Stil4-960 MEMORANDUM FOR: Leland C. Rouse, Chief

Advanccd Fuel anc Spent Fuel Licent  ; Branch i Division of Fuel Cycie and Material Safety FROM
Robert T. Kratzke

. Advanced Fuel and. Spent Fuel Licensing Branch I Division of fuel C3 c'e and Material Safety

SUBJECT:

GEf;ERAL ELECTR!C COMPANY, VALLECIT05 fluCLEAR CENTER, AME!;DMENT APPLIC/TI0f; DATED AL J i 14, 1981 4 :TS

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SUPPLEMENT DATED SEPTEMBER 25,1El PERTAILfL .0

~l CRITICALITY SAFETY REQUIREMENTS, LICEf!SE fl0. SiiM-960, DOCKET NO.70-754, AMEllCMENT NO. 21 i

-l Discussion i

f GE has applied for a license amendent which would, if aporoved, exernt

M GE from the requiremonts of 10 CFC 70.24(a). 10 CFP 70.24(a) requires t t' the use of criticality alams in areas where SNM is handled, used, or

, stored. It also adds a definition for a "subcritical area" to the definitions in its license conditions section, Appendi> A.

i We requested assistance from the Uranium fuel Licensing Branch to review and evaluate criticality safety criteria and other related elements of 1 this amendment request. This request for assistance was made through a i memorandum fron L. C. Rouse, Chief, Advanced Fuel and apent fuel Licensing Branch to R. G. Page, Chief, Uranium fuel Licensin: R a,ch, da_ J Septen -

! 2, 1931. In an October 21, 1931 nemorandum frc:a . C. Page to L. .. .su ;,

' the Uranium Fuel Licensing Branch provided a nuclear criticality safety review of the license anendment application. Their conclusion was that

- the nuclear criticality safety controls as presented in the amendment were I

adequate. This evaluation is attached for your convenience.

Evaluation The amendment application was reviewed and evaluated. The review of the proposed revised license amendmer: and supportive documents has shown that:

. The isolation criteria betw en ubc-itical areas are adequate to preve:.t the accumulation of potentially critical quantities j of fissile material in a single subcritical area.

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]1 Leland C. Rouse OCT 2 8 081 i h The nuclear criticality safety controls provide an adequate

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.; margi.i nf safety for the protection of the health and safety j of the operating personnel, the public, and the environment.

There should be no adverse effect as a result of approving the l

amendment on the process safety, radiolngical safety or environ-

. mental affects of the VliC operations.

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. The proposed amendment more accurately reflects the activities of VttC and the quantities of Stim that may be included in those

'j activities. .

f . tio elements associated with the proposed amendment could be con-

.1 strued as adversely affecting the health and safety of the general j public.

Recommendations i

The proposed amendment has no detrimental impact on nuclear criticality

] safety, radiological safety and environmental aspects of the VNC operation.

tj The changes proposed in the amendment have been reviewed and the nuclear j criticality safety aspects of the amendment are adequate. The exemption of 10 CFR 70.24(a) for the current Vtic operations is appropriate. There-jl ft fore, approval of the proposed amendment is recomended.

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Robert T. Kratzke i Advanced Fuel and Spent Fuel Licensing Branch

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. Division of Fuel Cycle and

') Material 5he a

Enclosure:

Memo to L. C. Rouse from R. G. page dated

))1 October 21 1981 C. Gh(

l Approved by L. C. Rouse, Chief  :

4 Advanced fuel and Spent Fuel  !

Licensing Branch i e Division of Fuel Cycle and Material Safety O

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OCT 3 1 1C*31 MEMORAfiDUM FOR: L. C. Rouse, Chief Advanced Fuel and Spent Fuel i Licensing Branch 1

Divisicn of Fuel Cycle and j Material Safety FROM: R. G. Page, Chief .

Uranium Fuel Licensing branch Division of Fue: Cycle d Material Safety

SUBJECT:

REVIEW 0F LICEtiSE APPLICATI0!i DAT.D E~PTEMBER 2, li;s g Afi0 ITS SUPPLEMEt4T DATED SEPTEMBER E5, 1981, DOCKET fi0.70-754 i

3 I. Background

} The General Electric Company (GE), by application dated September 2,1981,

' and its supplement dated September 25, 1981, requested authorizaticn for 4

h the following at its Vallecitos ticclear Center:

1. Add a definition for a "subcritical area" to the definitions in its license conditions section, Appendix A.

( 2. Exemption from the criticality alarn requirements of 10 CFR 70.24(a) in "subcritical areas."

l1 At your request, we have made a nuclear criticality safety review of the license amendment application.

l 1 II. Discussion 1;

ii GE has defined a "subcritical area" as a physically identified area or i;

gation invpiving special nuclear materials in quantities less than 500 g 33 , 300 g Pu, or a prorated combination of such materials l U, 300 g U

'. under the directic n of a single area ranager and which is unrelated to any

j other area where ;, ecial nuclear r.aterials are handled. A subcritical area is considered unrtiated wher; it moets the isolation requirements of Section 6.ll(c) of the Appendix and is not in the same room.

! Since a subcritical area is under the direction of a sinale area manager, I

the manager can administratively control the maximum cuantity of fissile material in the area. At the request of the t!RC, GE has further defined an

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unrelated subcritical area as one that meets the isolation requirements of Section 6.ll(c) of the Appendix and is not in the same room. This

]j , added restriction precludes the manager from subdividing a large room

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, into mnre than one subcritical area. .

j' Pst 10 CFt' 70.24(a) exempts the licensee from the criticalty alarm re-

guirements when the possession limit is no more than 700 g Z350 , 520 ;

q 2330 , 450 g Pu, or 450 g of any combination thereof. Although ti e licensee's

q. possession limit for single fissile isctopes in a subtritical area is p less than that specified in Part 70.24(a), the combination of fissile 1 isotopes n.ay be more than allowed (500 g vs. 450 g). However, the prorated .

k combinaticn of fissile isotopes requested in a subcritical area is farther j from critical than the allowable 450 g of any combination of fissile 4 isotopes. The isolation criteria between subcritical areas are adequate to prevent the accumulation of potentially critical quantities of fissile

)M material in a single subcritical area. Therefore, the nuclear criticality 4 safety controls provide an adequate margin of safety for the protection ci the health and safety of the operating personnel, the public, and the environment.

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1 R. G. Pa ef Uranium Fuel Licensing Branch A , Division of Fuel Cycle and j Material Safety

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