ML20133H886
| ML20133H886 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 08/05/1985 |
| From: | Crow W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Malody C SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER |
| References | |
| NUDOCS 8508090558 | |
| Download: ML20133H886 (3) | |
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AUG 5 1985 FCUP:GHB 70-1257 Exxon Nuclear Company, Inc.
ATTN: Mr. C. W. Malody, Licensing Specialist Corporate Licensing 2101 Horn Rapids Road Richland, WA 99352 Gentlemen:
We have reviewed Parts I and II of your June 12, 1985, application.concerning the dry conversion process and equipment. Additional infonnation, identified in the enclosure, is needed for us to continue our review.
We will continue our review upon receipt of the additional information.
Sincerely.
Original Signed By:
W. T. Crow W. T. Crow, Acting Chief Uranium Fuel Licensing Branch Division of Fuel Cycle and Haterial Safety, NMSS
Enclosure:
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AUG 5 1985 REQUEST FOR ADDITIONAL INFORMATION EXXON NUCLEAR COMPANY, INC.
APPLICATION DATED JUNE 12, 1985 1.
Nuclear criticality and radiation safety depend, in part, on the proper b
pressure, temperature, and flow rates of different gases or vapors.
It would appear appropriate to have low-flow alarms, high-and low-pressure alams, and high-and low-temperature alarms which would automatically activate shutoff valves for all process and purge lines. Please describe the instrumentation and/or demonstrate that loss of flow would not affect safety.
4 2.
Because criticality safety depends on proper action of valves, the
" double contingency principle" should be demonstrated for inline valves.
In addition, how will the valves be clo::ed if primary power is lost? If moderation control is assured by operation of the steam trap during both operating and 4
I shutdown periods, please describe actions to assure effective operation at all times including loss of power situations.
3.
Where practicable, reliance should be placed on equipment design in which i
dimensions are limited rather than on administrative controls for nuclear criti-cality safety (Ref. ANSI /ANS-8.1-1983). When favorable geometry control is not i
us.ed, Exxon Nuclear must justify the proposed use of nonfavorable geometry and establish appropriate administrative controls. After justifying the need for nonfavorable geometry equipment, the analysis must:
(a) take into consideration identified contributing causes of criticality accidents, (b) demonstrate that such causes will be subject to administrative controls, and (c) demonstrate compliance with the double contingency principle (Ref. ANSI /ANS-8.1-1983).
Contributing causes to be addressed are:
l a.
No detailed written procedures for new process (Ref. 1).
b.
Processupsets(Ref.1).
c.
Inadequate identification of material (Ref.1).
d.
Failure of audit program (Ref.1).
e.
Failure to follow procedures (Refs. 1, 3).
f.
Changes improperly authorized by Shift Supervisors (Ref.1).
g.
Inadvertent mixtures of solvents, aqueous liquors, and raffinates (Ref. 2).
h.
Failure to completely drain system (Ref. 2).
l i.
Failure of instruments (Ref. 3).
l j.
Poor communications between personnel (Ref. 3).
l k.
Failure to investigate and correct "out of spec" signals (Ref. 3).
1.
Failure to record transfer (Ref. 3).
l m.
Irregularities in function and operation-of valves (Refs. 4, 5).
i n.
Temporary transfer lines (Refs. 4, 5).
o.
Other potential causes for specific installation.
4.
Provide the following infomation to clarify the needs of the proposed action:
a.
Will the dry conversion process eventually be used to replace the wet process?
b.
What is the maximum through-put of the proposed dry process line? What will be the total through-put capacity with the dry and wet lines?
AUG 5 1985 c
5.
Describe the treatment of process liquid waste from the dry conversion process prior to discharge to the sewer.
i 6.
What would be the projected releases of uranium and total fluoride in air effluents from the dry process line? Will Tc-99 be measured in air effluents and at the lift station? If not, explain why.
7.
Please provide a map identifying the location of the new process line l
in relation to the existing process lines.
i 8.
Describe the potential accident scenarios for the dry process that are different from the wet process. What would be the environmental impact associated with those accident scenarios?
1 l
References 1.
Regiort of the AEC Technical Review ' ommittee, November 6,1964,
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(Wood River Junction), Rhode Island).
2.
Criticality Incident-August 24, 1980, Windscale Works, ANS Transactions, Vol. 14, pp. 35-36.
3.
Investigation of the 10/17/78 Criticality Incident in the Uranium Extraction Process Scrub Column at the Idaho Chemical Processing Plant, USD0E-100, November 1978.
4.
A Review of Criticality Accidents, LA-3Sil, pp.17-18, September 26, 1957.
5.
Ibid. pp. 25-27.
Please note that in addition to responding to Item 3 above, Section 3.2 of the license application should be revised to include a comitment to follow Item 3 for all future uses of nonfavorable geometry equipment.
.