ML20134P580
| ML20134P580 | |
| Person / Time | |
|---|---|
| Issue date: | 02/20/1997 |
| From: | Gary Comfort NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Rowland T ENERGY, DEPT. OF |
| References | |
| REF-PROJ-M-32 TAC-L30924, NUDOCS 9702260033 | |
| Download: ML20134P580 (10) | |
Text
1 February 20, 1997 Mr. Thomas J. Rowland, Director W5st Valley Demonstration Project U.S. Department of Energy l P.O. Box 191 l West Valley, New York 14171 l
SUBJECT:
LETTER REPORT DOCUMENTING NRC'S REVIEW 0F WVNS-SAR-012, REVISION 0, DRAFT C (TAC NO. L30924)
Dear Mr. Rowland:
l l
This letter documents the Nuclear Regulatory Commission staff's review of and resolution of comments from your submitted Safety Analysis Report (SAR),
" Safety Analysis Report for Fuel Receiving and Storage Facility, WVNS-SAR-012, ;
Revision 0, Draft C," dated October 8, 1996. By letter dated December 5, l 1996, you responded to our request for additional information dated j November 5, 1996. By letter dated January 23, 1997, you updated your submittal in response to NRC's further comments sent to you in a letter dated '
1 January 7, 1997.
The staff's review of WVNS-SAR-012 focused primarily on the evaluation of facility design criteria, source-term development, accident analysis, and the evaluation of potential off-site impacts. My primary comments to you in my ,
November 5,1996, letter dealt with the calculation of source terms. In your J December 5,1996, response, you submitted recalculated source terms for the i spent fuel stored on-site in response to our concerns regarding the validity of the original calculations. The new evaluations appear to be more in line with our expectations. l l
NRC's overall conclusion is that the activities presented in WVNS-SAR-012 will not significantly impact the health and safety of the public and the environ-ment. Enclosed is a summary of my original comments and their resolution.
If you have any questions, please call me at (301) 415-8106.
Sincerely, Original signed by:
Gary C. Comfort gg g @ N Y Licensing Section 2 Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS Project M-32
Enclosure:
As stated Distribution (Control No. 1305) %
Project M-32 PUBLIC NRC File Center FCSS R/F FCLB R/F PMDA NMSS R/F Region I TJackson, RI h(O \
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NAME GCon[ fort PShea [ALN GPadrn DATE 2/ 10/97 2/ 90 /97 2/ 76 /97 9702260033 970220 PDR PROJ M-32 PDR
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j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20566-0001
% # February 20, 1997 j Mr. Thomas J. Rowland, Director I West Valley Demonstration Project U.S. Department of Energy ,
P.O. Box 191 l West Valley, New York 14171 i
SUBJECT:
LETTER REPORT DOCUMENTING NRC'S REVIEW 0F WVNS-SAR-012, REVISION 0, l DRAFT C (TAC NO. L30924)
Dear Mr. Rowland:
This letter documents the Nuclear Regulatory Commission staff's review of and resolution of coments from your submitted Safety Analysis Report (SAR),
" Safety Analysis Report for Fuel Receiving and Storage Facility, WVNS-SAR-012, Revision 0, Draft C," dated October 8, 1996. By letter dated December 5, 1996, you responded to our request for additional information dated November 5, 1996. By letter dated January 23, 1997, you updated your submittal in response to NRC's further comments sent to you in a letter dated January 7, 1997.
The staff's review of WVNS-SAR-012 focused primarily on the evaluation of facility design criteria, source-term development, accident analysis, and the evaluation of potential off-site impacts. My primary comments to you in my November 5,1996, letter dealt with the calculation of source terms. In your December 5, 1996, response, you submitted recalculated source terms for the spent fuel stored on-site in response to our concerns regarding the validity of the original calculations. The new evaluations appear to be more in line with our expectations.
NRC's overall conclusion is that the activities presented in WVNS-SAR-012 will ;
not significantly impact the health and safety of the public and the environ- j ment. Enclosed is a summary of my original comments and their resolution. !
If you have any questions, please call me at (301) 415-8106.
Sincerely, O P Gary C. Comfort Licensing Section 2 Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS Project M-32
Enclosure:
As stated j
^
REVIEW OF THE SAFETY ANALYSIS REPORT (SAR) FOR THE FUEL RECEIVING AND STORAGE FACILITY, WVNS-SAR-012, REVISION 0, DRAFT C, AND RESOLUTION OF WEST VALLEY DEMONSTRATION FROJECT RESPONSES The U.S. Nuclear Regulatory Commission staff and its contractor performed a review of the West Valley Nuclear Services, Inc. (WVNS) Safety Analysis Report (SAR) for Fuel Receiving and Storage (FRS) Facility, WVNS-SAR-012, Revision 0, Draft C (WVNS-SAR-012). NRC provided comments on the subject document to the Department of Energy (DOE) by letter dated November 5, 1996. DOE replied to these comments by letter dated December 5, 1996. After review of the responses, NRC provided follow-up comments hv letter dated January 7,1997.
DOE provided responses to the follow-up comments in a letter dated January 23, 1997.
The following is a synopsis of the comments and associated responses:
Comment #1 6 2. Daaes 2-4 and 2-6. lines 18-20 and Table 2.5-1 The text mentions that the dose to the maximally exposed individual off-site following a criticality event would be 399 millirem (nirem). This is inconsis-tent with the value given in Table 2.5-1 which indicates a dose of 967 mrem.
It appears that the off-site and on-site doses have been reversed in this table. Please review this table to ensure correctness.
DOE Response:
The values corresponding to the on-site and off-site doses due to a critical-ity in the FRS were transposed in both Table 2.5-1 and Table 9.2-4. This accident was reevaluated in response to concerns raised in Comment #10. The ;
corrected values have been incorporated into Tables 2.5-1 and 9.2-4 and into l the text discussions of the accident in Chapters 2 and 9 of WVNS-SAR-012, j Draft D.
Evaluation of Response:
The new Tables 2.5-1 and 9.2-4 (Attachment 2) supplied by Dames & Moore i
indicate that the maximum off-site doses are less than the maximum on-site i doses, which is internally consistent. However, the new dose values in these l tables are significantly different from those mentioned in the original text J of WVNS-SAR-012, Revision 0, Draft C. This is because the radionuclide ;
inventory values were changed as a result of response to Comment #6. Hence, j assuming that the new dose values are correct, the text in Sections 2 and 9 l needs to be revised to match the new dose values provided in these tables.
This item is considered to be resolved assuming that the text in Chapters 2 and 9 is appropriately revised.
ENCLOSURE
1 ,
~
2 Comment #2 4 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 Demonstration Project (WVDP). Please provide a copy of the
.Bixby (1989) reference that supports this assertion.
DOE Response:
A copy of Bixby (1989) has been provided to the reviewer.
Evaluation of Response:
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 f
pool. DOE should provide quantitative justification to support its conclusion j regarding the stability of this building.
Final Evaluation of Comment:
Further discussion with Dames & Moore staff indicated that the dose calculations for accident scenarios assumed complete collapse of the FRS.
Although partial collapse of the FRS structural members may occur under 50 to i 75 percent of EBE, the calculated on-site and off-site doses were indicated to be within the guideline limits. Hence the structural instability of the FRS building is not considered to be a safety concern. Based on the clarification provided by Dames & Moore staff, this comment is considered to be resolved.
Comment #3 4 5.2.3. Daaes 5-4 and 5-5 ,
The text states that masonry blocks from the 8-inch masonry block interface i wall between the FRS building and the Main Plant building may become dislodged I during certain seismic conditions. Please provide a copy of the Dames & Moore I (1995) reference evaluating this issue. i l
3 DOE Response:
A copy of the Dames & Moore (1995) report has been provided to the reviewer.
Evaluation of Response:
The Dames & Moore (1995) r'eport evaluated ts risk of potential collapse of the 8-inch masonry block wall adjacent to the FRS spent fuel pool under extreme natural hazard seismic conditions. The Dames & Moore activities included a review of the findings of previous independent seismic integrity studies by Blaw-Knox (1972), Dravo (1976), Lawrence Livermore National Laboratory (LLNL) (1978), and Los Alamos National Laboratory (LANL) (1978), as well as a 3D finite element dynamic analysis of the FRS and process buildings, including soil-structure interaction modeling.
The Dames & Moore review of the previous independent seismic integrity studies indicated that the estimate of the load-bearing capacity of the 8-inch masonry block wall adjacent to the pool was based on inconsistent data. To correct this deficiency, Dames & Moore performed a 3D finite element dynamic analysis to more accurately assess the wall's performance under various levels of earthquake loading. The assumptions made by Dames & Moore in conducting this ,
dynamic analysis are consistent with standard engineering practice. Based on i the dynamic analysis, the 8-inch masonry block wall does not pose a threat to !
the spent nuclear fuel assemblies stored in the FRS pool for an EBE of 0.1 g i PGA. The issue of the risk of potential collapse of this masonry block wall ,
under extreme natural hazard seismic conditions is considered to be resolved. l Comment #4
)
Paae 6.8. line 19 The meaning of water quality in this section is unclear. It may refer to the decontamination factor of the demineralizer system or to different water propertiessuch7as pH, conductivity, etc. It appears that the measurement of B activity or Cs y activity is the method used for detection of fuel failures, but this is not clear from the text. Please describe the water quality requirements that are evaluated and clarify the method (s) of fuel failure detection.
DOE Response:
The text will be modified to indicate that water samples from the gel storage pool or CUP will be collected weekly to measure pH, conductivity, Cs y activity, and gross B activity. These parameters will also be measured quarterly as well as chlorides, nitrates, nitrites, sulfates, and gross a activity. It is stated that the purpose of this sampling and analysis is to verify the performance of the fuel pool Submerged Water Filtration System in maintaining water quality parameters within desired ranges and to detect possible fuel failures.
l I
4 Evaluation of Response:
Based on the WVDP response, this comment is considered to be resolved.
However, the maximum acceptable values for the various parameters in the form of a table, and the recommended corrective actions for upset conditions should be provided.
l Comment #5 Table 7.2.1 Some of the information presented in this table does not appear to be internally consistent. Examples include: is less than the sum of the Pu isotopes in the same(1) theand HIC, total(2)
Puthe in' total HIC "g"Pu 2
inventory assuming the indicated sludge mass for all HICs is 0.0116 rather than 0.0193 C1. Values in the table should be riviewed to ensure correctness.
DOE Response:
The value for Pu-239/240 activity concentration for HIC "C" will be corrected.
An additional correction to the table will be the elimination of total activity values for Co-60, Pu-238 and Pu-239/240 because activity concentrations for these isotopes were not measured for all HICs.
Evaluation of Response:
Based on the WVDP response, this comment is considered to be resolved.
Comment #6 i Tables 8.2-3 and 8.2-4 on paaes 8-28 and 8-29. respectivelv :
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/MTU (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 authors of the report are relying on ORIGEN runs that were performed for the initial fuel inventories and then are calculating the 21-yr inventories by correcting for only the decay of the nuclide. This process is incorrect for nuclides that appear in a decay chain, j such as Am-241.
. . . = ._ -_ - - -_ . .-
5 l 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 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/MTU listed in Table 8.2-3) for l 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 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/MTV value j 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 inventories and then are calculating the 21-yr inventories by correcting for only the decay of the nuclide.
The differences ia the inventory may affect subsequent calculations, I especially any criticality calculations, that use Tables 8.2-3 and 8.2-4 as a l basis for the radionuclide content of the fuel. J l
. DOE Response:
l The values for Am-241 activity in Tables 8.2-3 and 8.2-4 of WVNS-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 WVNS-SAR-012. The revised Am-241 activities to be J included in the SAR are based on the more realistic decay times of 22 and 24 ;
years for the BWR and PWR fuel, respectively.
Evaluation of Response:
The recalculated values of radionuclide inventory shown in revised Tables i 8.2-3 and 8.2-4 (Attachment 2) appear reasonable for all radionuclides I (including Am-241). Therefore, this portion of the response is resolved.
However, DOE has 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 Am-243 and Cm-243 may be about equal, 4
and they have approximately equal dose conversion factors. However, one nuclide is tracked (Am-243) and the other is not (Cm-243) in the analysis presented in WVNS-SAR-012. Other actinides, such as Am-242m (m-metastable),
may also be important.
Final Evaluation of Comment:
Discussion with DOE and Dames & Moore staff indicated that the selection of key radionuclides was based on the results documented in WVDP-065, Revision 2, entitled Radiological Parameters for Assessment of WVDP Activities (Faillace '
et al . , 1990) . The radionuclides selection in WVDP-065, Revision 2, was based on the criterion that these radionuclides contribute greater than 0.1 percent ,
to the total dose. The staff reviewed WVDP-065, Revision 2, and found the '
explanation for seTection of radionuclides acceptable. Hence, this comment is l considered to be resolved. l 1
i l 1
i
6 Comunent #7 ,
-Tables 8.7-1 and 8.7-2 on oaaes 8-30 and 8-31. respectivelv ;
Neither the text nor the subject tables state whether burnup credit was considered when. calculating the listed values of k If the uranium and plutonium inventories shown in Tables 8.2-1 and 8.f#.2 were used for the '
. criticality calculations, that should also be stated.
-DOE Response: ,
1 All criticality analyses referenced in the WVNS-SAR-012 have assumed )
unirradiated fuel, unless explicitly stated otherwise. 4 The following text has been added after the sentence ending on Line 1 of page 8-12: "All calculations were performed assuming unirradiated fuel."
i The sentence beginning in Line 10 on page 8-12 has been ceworded as follows: i "This analysis evaluated the reactivity of unirradiated PWR and BWR l assemblies ..."
Evaluation of Response:
Since the " fresh fuel" assumption was used in performing the criticality ;
calculations, changes in the radionuclide inventory due to irradiation and decay would not affect the calculated criticality calculations. For fresh .
fuel, the calculated values of k ,,gshown in Tables 8.7-1 and 8.7-2 appear '
reasonable. On the basis of DOE s response, this comment is considered to be resolved.
Comment #8 6 9. Daae 9-3. line 25 and 6 9.1.2.3.2 The text states that "... gravitational potential energy represents the most significant source of energy ..." Have the consequences of combustion (i.e.,
fire hazards) been considered in making this evaluation? It would seem that fire would have the potential for significant radiological and nonradiological ,
impacts. ;
1 DOE Response:
The consequences of a fire in the FRS were evaluated in the process hazards analysis and have been documented in Table 9.1-1. A fire in the FRS is not considered to pose a significant risk because the FRS contains only minor amounts of flammable materials. Furthermore, hazards located in the FRS (i.e., spent nuclear fuel, pool water filtration cartridges, and loaded ion exchange resin) are' stored either underwater or in large concrete shield containers, which would provide protection for the hazards from a fire, should one occur. j l
l i . \
l Evaluation of Response:
Based on DOE's response, this comment is considered to be resolved.
Cosament #9
]
6 9. Daae 9-24. Table 9.2-1 l l
Due to discrepancies found in the inventory calculations, the on-site dose l l
calculation for Am-241 for a Class D atmosphere wps checked. The listed Chi /Q value was reasonably well reproduced (1.5E-06 s/m versus 1.6E-06 listed in the SAR) but because of the difference in the calculated inventory of Am-241 used in the SAR, the on-site dose value in the table was calculated to be 5.8E-05 rem (the same factor of 32 increase found in Comment #6). These results make Am-241 the top-ranking nuclide in terms of dose in the list.
DOE Response:
A reanalysis of the consequences of the failure of the fuel assemblies in the FRS has been performed using the corrected values of Am-241. Results of this analysis are documented in Table 9.2-1 of WVNS-SAR-012, Draft D. The dose to the maximally exposed off-site individual from the drop of a single fuel assembly is 6.14E-03 rem while the dose due to the failure of all 125 fuel l assemblies has been calculated to be 7.68E-01 rem. l I
Evaluation of Response: !
Table 9.2-1 of WVNS-SAR-012, Draft D (Attachment 2), was reviewed. In this revised table, DOE used corrected inventory values for all nuclides ;
(calculated using the most recent version of ORIGEN2) as well as for Am-241. '
This strategy is appropriate. The new values appear to be reasonable.
Therefore, this comment is considered to be resolved.
Comment #10 6 9. Dace 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).
DOE 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 WVNS-SAR-012, Draft D. The dose to the maximally exposed off-site individual from this event is calculated as 3.53E-01 rem.
r 8
Evaluation of Response:
In revised Table 9.2-3 of WVNS-SAR-012, Draft D (Attachment. 2), DOE 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 DOE 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 i 26, placing it fourth in Table 9.2-3.
Final Evaluation of Comment:
DOE agreed to modify the text in WVNS-SAR-012 to delete the reference in the text in Section 9.2.2.3.2 to a conservative initial inventory. DOE stated that while not including in-growth of Am-241 may lead to a nonconservative initial inventory in Table 9.2-3, the total dose calculations are sufficiently '
conservative such that small differences in Am-241 initial inventory will not lead to total dose above the evaluation guideline levels. The staff agrees with this statement and the modification indicated by the WVDP in the text.
This comment is considered to be resolved. ,
REFERENCES Bixby, Willis W. 1989. DOE Order 6430. lA. Letter dated July 17, 1989, to R.A..
Thomas. CBL:010:89-0902:89:01 (DW:89:0365).
Blaw-Knox. 1972. Evaluation of the Fuel Receiving and Storage Structure for Tornado and Earthquake Forces.
Dames & Noore.1995. Seismic Integrity Review Report-Fuel Receiving and Storage facility. West Valley, NY: Dames & Moore. 1 Dravo. 1976. Seismic Competence of the Existing Reprocessing Building at the West Valley Reprocessing Plant. Chemica1 Plants Division. Report No. 0476.015. West Valley, NY. j Faillace, E.R., J.J. Prowse, Y. Yuan. 1990. Radiological Parameters for Assessment of West Valley Demonstration Project Activities. WVDP-065.
West Valley, NY: West Valley Nuclear Services Co., Inc.
Lawrence Livermore National Laboratory.1978. Structural Analyses of the fuel Receiving Station Pool at the Nuclear Fuel Service Reprocessing Plant.
UCRL-52572. Livermore, CA: Lawrence Livermore National Laboratory.
Los Alamos National Laboratory.1978. Seismic Investigation of the Nuclear '
Fuel Services', Inc. Reprocessing Plant at West Valley, NY. LA-7087-MS.
Los Alamos, NM: Los Alamos National Laboratory. i t
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