ML20133E225
| ML20133E225 | |
| Person / Time | |
|---|---|
| Issue date: | 01/07/1997 |
| From: | Gary Comfort NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Rowland T ENERGY, DEPT. OF |
| References | |
| REF-PROJ-M-32 NUDOCS 9701100249 | |
| Download: ML20133E225 (5) | |
Text
.
December 7, 1997 s,g s
, Mr.'Tho2as J. Rowland, Director West Valley Demonstration Project U.S. Department of Energy P.O. Box 191 West Valley, New York 14171
SUBJECT:
REVIEW 0F WVNS-SAR-012, REVISION 0, DRAFT C
Dear Mr. Rowland:
By letter dated December 5,1996, you responded to our request for additional i
information dated November 5,1996, regarding your submittal, " Safety Analysis Report for Fuel Receiving and Storage Facility, WVNS-SAR-012, Revision 0, 1
Draft C," dated October 8, 1996.
Our review of your December 5,1996, response has led to three issues which i
require further addressing. These issues include:
(1)
Comment #2: Additional justification should be provided for the conclusion that the Fuel Receiving and Storage (FRS) building meets design criteria.
(2)
Comment #6: Justification for the selection of key radionuclides listed in Tables 8.2-3 and 8.2-4 should be provided.
(3)
Comment #10: The dose calculations in revised Table 9.3-3 should consider the presence of daughter products (e.g., Am-241) in the initial inventory in order to be conservative.
If you have any questions, please call me at (301) 415-8106.
Sincerely Original signed by:
GPangburn for Gary C. Comfort, Jr.
Licensing Section 2 Licensing Branch 9701100249 970107 Division of Fuel Cycle Safety
@$2 PROJ and Safeguards, NMSS PDR Project M-32
Enclosure:
As stated cc: Mr. Nrassi Sridhar WSS Program Element Manager Center for Nuclear Waste Regulatory Waste Analysis 120 M CEE.m COPY P.O. Drawer 28510 h(0 )
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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20655-0001 January 7,1997 Mr. Thomas J. Rowland, Director West Valley Demonstration Project U.S. Department of Energy P.O. Box 191 West Valley, New York 14171
SUBJECT:
REVIEW 0F WVNS-SAR-012, REVISION 0, DRAFT C
Dear Mr. Rowland:
By letter dated December 5,1996, you responded to our request for additional l
information dated November 5,1996, regarding your submittal, " Safety Analysis Report for Fuel Receiving and Storage Facility, WVNS-SAR-012, Revision 0, Draft C," dated October 8, 1996.
Our review of your December 5,1996, response has led to three issues which require further addressing.
These issues include:
(1)
Comment #2: Additional justification should be provided for the conclusion that the Fuel Receiving and Storage (FRS) building meets design criteria.
(2)
Comment #6: Justification for the selection of key radionuclides listed in Tables 8.2-3 and 8.2-4 should be provided.
(3)
Comment #10: The dose calculations in revised Table 9.3-3 should consider the presence of daughter products (e.g., Am-241) in the initial inventory in order to be conservative.
If you have any questions, please call me at (301) 415-8106.
Sincerely,
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hv 4 Gary C. Co rt, Jr Licensing ction 2 Licensing Branch Division of fuel Cycle Safety and Safeguards, NMSS Project M-32
Enclosure:
As stated cc: Mr. Nrassi Sridhar WSS Program Element Manager Center for Nuclear Waste i
Regulatory Waste Analysis P.O. Drawer 28510 6220 Culebra Road San Antonio, Texas 78228-0510
Comment #2 6 4.0 and 5.0. Daaes 4-1 and 5-3 The text states that although the FRS facility does not meet all of the current design criteria,.it is nonetheless judged to meet the current needs ~of the West Valley Project.
Please provide a copy of the Bixby (1989) reference that supports this assertion.
WVDP Response:
A copy of Bixby (1989) has been provided to the reviewer.
NRC Evaluation of WVDP Response and Resolution:
The Bixby (1989) reference does not provide technical information relevant to this comment; however, the Dames & Moore (1995) report does.
A three-dimensional (3D) finite element dynamic analysis of the FRS and process buildings, including soil-structure interaction modeling, conducted by Dames & Moore, shows that the lateral load-resisting bracing of the FRS steel frame yields or buckles at a peak ground acceleration (PGA) of 0.05 g [0.5x Evaluation Basis Earthquake (EBE)] in the east-west direction and at a PGA of 0.075 g (0.75xEBE) in the north-south direction. However, despite yielding or buckling of the lateral load-resisting bracing of the FRS steel frame at 50 percent to 75 percent of EBE, Dames & Moore concluded, without any quantitative justification, that significantly higher levels 'of ground motion would be required to induce failures leading to collapse of the building.
While the entire FRS building may' not collapse, a large section of it might and could pose a threat to the spent nuclear fuel assemblies stored in the FRS pool. The WVDP should provide quantitative justification to support its conclusion regarding the stability of this building.
l Comment #6 Tables 8.2-3 and 8.2-4 on Daaes 8-28 and 8-29. resoectivelv The 21 yr PWR and BWR fuel inventories for Am-241 are less than their respective initial inventories.
Due to ingrowth from the decay of Pu-241, the inventory of Am-241 increases with time (for short times).
Also, the basis for choosing the presented radionuclides as the " key radionuclides" for this exercise has not been referenced nor explained.
An independent analysis using ORIGEN Version 2.1 found that for the PWR fuel with the listed characteristics, the initial inventory for Am-241 was 133 Ci/MTU (a 50% increase from the 86 Ci/MTU listed in Table 8.2-4).
The 21-yr inventory of Am-241 was found to be 2,673 Ci/MTV (a factor of 32 increase from the 83 Ci/MTU listed in the table).
For all other nuclides, independent analysis using ORIGEN Version 2.1 roughly agreed with the results listed in the table.
It appears that the ENCLOSURE
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2 authors of the report are relying on ORIGEN runs that were performed for i
the initial fuel. inventories and then are calculating the 21-yr i
inventories by correcting for only the decay of the nuclide. This process is incorrect for nuclides that appear in a decay chain, such as Am-241.
For the BWR fuel, the transuranics listed in Table 8.3-3, with the exception of Pu-238, were a factor of 3 to 5 lower than predicted by the i
l independent analysis. Specifically for Am-241, the initial inventory was found to be 25 Ci/MTU (a factor of 5 increase from the 5 Ci/MTV listed in Table 8.2-3) for a fuel with an initial enrichment of 2.75%
U-235 exposed to a specific power of 25.9 kw/kg with a burnup of f
12,423 Mwd /MTU.
The initial enrichment was assumed since none was listed in the table. The 21-yr inventory of Am-241 was found to be 85 Ci/MTU (a factor of 18 increase from the 4.83 Ci/MTU value listed in the table). Again, it appears that the authors of the report are relying on ORIGEN runs that were performed for the initial fuel
,.entories and then are calculating the 21-y. inventories by correcting for only the decay of the nuclide.
The differences in the inventory may affect subsequent calculations, especially any criticality calculations, that use Tables 8.2-3 and 8.2-4
-as a basis for the radionuclide content of the fuel.
WVDP Response:
The values for Am-241 activity in Tables 8.2-3 and 8.2-4 of SAR-012, Draft C, were incorrectly calculated.
Correct values have been calculated for both BWR and PWR fuel using ORIGEN2, and these values are included in the appropriate tables in SAR-012. The revised Am-241 activities to be included in the SAR are based on the more realistic decal times of 22 and 24 years for the BWR and PWR fuel, respectively.
NRC Evaluation of WVDP Response and Resolution:
.The recalculated values of radionuclide inventory shown in revised Tables 8.2-3 and 8.2-4 (Attachment 2) appear reasonable for all radionuclides (including Am-241). Therefore. this portion of the response is accepted. However, the authors have not justified the selection of the radionuclides shown in Tables 8.2-3 and 8.2-4 as the "important" radionuclides for this analysis.
For example, the initial inventories of An-243 and Cm-243 may be about equal, and they liave approximately equal dose conversion-factors. However, one nuclide is tracked (Am-241) and the other is not (Cm-243) in the analysis presented in SAR-012. Other actinides, such as Am-242m, may also be important.
Comment #10 6 9. oaoe 9-13. lines 30 and 31 Due to possible errors in the radionuclide inventories listed in Tables 8.2-3 and 8.2-4, these analyses should be redone with correct inventories (if the original inventories are determined to be in error).
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3 WVDP Response:
A reanalysis of the consequences of an inadvertent criticality in the FRS has been performed using the activities presented in Table 8.2-4.
Results of this analysis are documented in Table 9.2-3 of SAR-012, Draft D.
The dose to the maximally exposed off-site individual from this event is calculated as 3.53E-01 rem.
NRC Evaluation of WVDP Response and Resolution:
In revised Table 9.2-3 of SAR-012, Draft D (Attachment 2), the authors have used the initial inventory for all radionuclides in the dose calculations.
For nuclides that do not appear in a decay chain, assuming the initial isotopic content of the fuel yields conservative dose calculations.
For nuclides appearing in a decay chain (such as Am-241), this assumption can be nonconservative.
It is recommended that the authors assume the 24-yr inventory for Am-241 when calculating the doses shown in Table 9.2-3.
Using the 24-yr inventory for Am-241 will increase its importance by approximately a factor of 26, placing.it fourth in Table 9.2-3.
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