ML20126E188
| ML20126E188 | |
| Person / Time | |
|---|---|
| Site: | Claiborne |
| Issue date: | 12/23/1992 |
| From: | Bidinger G NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Roche L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9212290046 | |
| Download: ML20126E188 (4) | |
Text
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. DEC 2 31992 MEMORANDUF FOR: L;dia Roche Fuel Cycle Sa^ety Branch Division of Industrial and Hedical Nuclear Safety, NMSS FROM: George H. Bidinger Uranium fuel Section Fuel Cycle Safety Branch Division of Industrial and Medical Nucitar Safety, NM55
SUBJECT:
REQUEST FOR-ADDITIONAL INFORMATION, LOUISIANA ENERGY SERVICES, DOCKET 70-3070 Enclosed is a request for additional information which has been developed by a review of the LES SAR, Section 4.5 and the referenced Criticality Safety Engineering Report, and Sections 11.1 to 11.4.
It may be appropriate to discuss these issues with the applicant. I am quite willing to do so.
0;ypini SSid W George H. Bidinger Uranium Fuel Section Fuel Cycle Safety Branch Division of Industrial and Medical Nuclear Safety, NMSS
Enclosure:
As stated Distribution:
Docket 70-3070 NRC File Center- IMUF R/F PDR/LPDR.
IMSB R/F NhSS R/F - CBidinger(;D FBrown JGre)ves MTokar :
OFC IMUF: SE IMUF W /$1UF: E NAME 4$kidinger: -VTbpe: [No'kar':
DATE 12/ss/92 12/KV92 12/2S/92 C = COVER E = COVER & ENCLOSURE N = NO COPY
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. . , _ _ _ . 1 9212290046 921223 PDR ADOCK 07003070 D)/ l-l C PDR
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In the review of the Safety Analysis Report (SAR) and the Criticality Safety !
Engineering Report (CSER), we have identified several problems with the safety j analysis. The SAR/CSER should be revised to describe an adequate administrative and technical nuclear criticality safety program. The problem areas which need revision or supporting justification are:
- 1. In Section 11.1.4.1 of the SAR, education and experience qualifications are provided (paragraph 1) for a Projects !
Individual. The adequacy of these qualifications cannot be l assessed because the responsibilities and authority-for this ;
individual were not specified in Section 11.1.2. i If an applicant proposes to make changes in the- facility which l would require new nuclear safety analyses, the staff requires that a trained individual perform the analysis and that a second trained individual with at least 2 years of experience in analyses and safety program implementation independently review and approve the analysis.
- 2. In Sections 11.2 and 11.4 of the SAR, the application states that plant procedures will specify limits on control parameters and corrective measures to return a parameter to its control band, as appropriate. Limits and corrective measures must be specified for all operations. Exceptions, if any, must be explicitly identified in the application.
- 3. In addition to the operating procedures discussed in Section 11, written procedures must be established and implemented for activities of the nuclear criticality safety function.
- 4. In Section 4.5 of the SAR, safety factors are provided for reducing critical mass or dimensions for process equipment.
Safaty factors or practices must be provided also to ensure that specified geometric configurations are maintained.
- 5. In Gctions 4.2 and 2.1 of the CSER, the proposed limits for UF, product cylinders, i.e., 2 kg of hydrogen or H/V < 1, do not assure nuclear criticality safety. In particular, a large array of cylinders, filled with UF6 moderated such that H//U.- 1, would not be subcritical. - As shown by your evaluation in the CSER, 570 g of hydrogen corresponds to H/U - 0.088. Accordingly, for 2000 g of nydrogen, the corresponding H/U-is 0.3 'This H/U can be shown to provide a greater margin for nuclear criticality safety.
- 6. In Section 2,1 of the CSER, the-feed cylinders have been assumed to contain only natural UF6. However, the feed cylinders can be used for enriched as well as natural UF . Provisions must be established and implemented to ensure tht. enriched UF 6 is not introduced as feed material.
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- 7. In Section 4.3 of the CSER, criticality safety of the desublimers requires control room monitoring of instruments m?asuring pressure and aressure changes. The monitoring and control system must be cali arated and functionally tested periodically.
- 8. In Section 4.4 of the CSER, the neutron interaction analyses from the chemical traps on mobile pumps and for mobile vacuum pumps must be provided.
- 9. In Section 4.7 of the CSER, criteria for process pipe bends and joints must be provided.
- 10. in Section 4.8 of the CSER, the Fomblin oil recovery equipment should be described. A nuclear criticality safety analysis must be provided for the array of equipment in the hood,
- 11. In Section 4.10 of the CSER, certain waste treatment processes ,
will be undertaken by a licensed contractor. However, if such -
processes are to be taken on the CEC site, the activities must be authorized by the CEC license. The appropriate waste treatment process descriptions and nuclear safety analyses must be provided for such activities.
- 12. In Section-4.11 of the CSER, positive controls to limit the uranium accumulative in the effluent collection tanks has not been demonstrated. If enriched uranium can collect in these tanks, positive controls, e.g., multiple inline monitors or inline ,
favorable geometry collection and sampling tanks, must be provided.
- 13. In Section 4.11 of the CSER, the basis for nuclear safety of the effluent pits must be provided. For example, floor leakage into a pit and multiple tank spills into a pit must be evaluated.
- 14. In Section 4.11 of the CSER, positive controls to limit the-uranium accumulation for each citric acid bath has not been demonstrated. The daily sampling does not provide high assurance that a critical mass accumulation will not' occur. Therefore, the limit for each bath must be reduced significantly below a safe mass to allow for the poor quality of controls our the uranium accumulation in the baths.
- 15. An array analysis for all waste liquid process and collection tanks must be provided.
- 16. In Section 4.12 of the CSER, the potential deposition of uranium in the ductwork prior to the filter system must be cor, trolled by either favorable geometry ducts, frequent inspections, or other safety features.
- 17. A description of processing and waste handling for all areas such as the chemistry area should be provided. The basis for nuclear -
criticality safety of all areas must be provided in the application.
- 18. In Section 6.0 of the CSER, the requested exemption-from the criticality monitoring system requirements of 10 CFR 70.24-has not been justified for the TSA. The lack of positive controls in the .'
waste handling area do not support the request. On the otherhand, !
the combination of process and safety controls does provide justification for an exemption for the enrichment halls. .
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