ML20134Q289
| ML20134Q289 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 02/18/1997 |
| From: | Lamastra M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Weber M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9702260374 | |
| Download: ML20134Q289 (2) | |
Text
_ -
February 18, 1997 MEMORANDUM T0:
Michael F. Weber, Chief Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS THRU:
George C. Pangburn, Section Chief Original signed by:
Licensing Section 2 Licensing Branch Division of Fuel Cycle Safety and Safeguards, NHSS
]
l FROM:
Michael Lamastra Original signed by.
Licensing Section 2 Licensing Branch Division of Fuel Cycle Safety 4
1 and Safeguards, NMSS
SUBJECT:
SUMMARY
OF FEBRUARY 5, 1997, MEETING WITH B&W FUEL (FRAMATOME COGEMA FUEL) i On February 5, 1997, representatives from the Licensing Branch, Division of Waste Management and B&W Fuel (Framatome Cogema Fuel) met to discuss the additional information requested in our letter dated November 5,1996, (Attachment 1), regarding the licensee request to free release the area of the site known as the wet-weather stream. The meeting was requested by the NRC to ensure that the licensee understood all the issues raised by our November 5, 1996, letter. Attachment 2 is a copy of the attendees list. All issues were discussed with additional clarification given on the recommendation of i
NUREG/CR-5849; which describes the hot spot and scan survey criteria. The licensee representative indicated that she understood what additional information was required to respond to our letter. During the meeting, it was agreed that the licensee would respond to our November 5, 1996, letter by April 7, 1997.
Docket 70-1201 License SNM-1168 Attachments:
1.
Ltr dtd 11/5/96 gY 2.
Attendee List cc: Ms. Gayle F. Elliott, Manager 4
Safety and Licensing 7
B&W Fuel Company r
Commercial Nuclear Fuel Plant
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P.O. Box 11646 g\\
Lynchburg, Virginia 24506-1646 Distribution i
Docket 70-1201 PUBLIC NRC File Center s
NMSS r/f FCSS r/f FCLB r/f Region II KHardin GTroup, RII G:\\b&wltr4.ml]
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FCLB A,y NAME MLadastra PShea /)d b DMoser k GPangtN DATE 2/k/97 2/N/h7 2/JY/97 2/ /[/97 C = COVER E = COVER & ENCLOSURE N = NO COPY 0FFICIAL RECORD COPY 9702260374 970218 PDR ADOCK 07001201 C
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION o
f WASHINGTON, D.C. 205554X)01 February 18, 1997 MEMORANDUM T0:
Michael F. '.::ber, Chief Licensing Branch Division of Fuel Cycle Safety and Safeguards, NHSS THRU:
George C. Pangburn, Section Chief
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Licensing Section 2 Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS 4
FROM:
Michael Lamastra f
Licensing Section 2 b'r Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS l
SUBJECT:
SUMMARY
OF FEBRUARY 5, 1997, MEETING WITH B&W FUEL (FRAMATOME C0GEMA FUEL)
On February 5, 1997, representatives from the Licensing Branch, Division of Waste Management and B&W Fuel (Framatome Cogema Fuel) met to discuss the additional information requested in our letter dated November 5,1996, (Attachment 1), regarding the licensee request to free release the area of the site known as the wet-weather stream.
The meeting was requested by the NRC to ensure that the licensee understood all the issues raised by our November 5, 1996, letter. Attachment 2 is a copy of the attendees list. All issues were discussed with additional clarification given on the recommendation of NUREG/CR-5849; which describes the hot spot and scan survey criteria.
The licensee representative indicated that she understood what additional information was required to respond to our letter.
During the meeting, it was agreed that the licensee would respond to our November 5, 1996, letter by April 7, 1997.
Docket 70-1201 License SNM-1168 Attachments:
1.
Ltr dtd 11/5/96 2.
Attendee List cc: Ms. Gayle F. Elliott, Manager Safety and Licensing B&W Fuel Company Commercial Nuclear Fuel Plant P.O. Box 11646 Lynchburg, Virginia-24506-1646
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S NUCLEAR REGULATORY COMMISSION WASHINGTON. D.C. 20666-0001
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November 5, 1996 Ms. Gayle F. Elliott, Manager Safety and Licensing B&W Fuel Company Commercial Nuclear Fuel Plant i
P.O. Box 11646 Lynchburg, Virginia 24506-1646
SUBJECT:
FREE RELEASE OF WET-WEATHER STREAM AREA (TAC NO. L30746)
Dear Ms. Elliott:
This refers to your application dated December 1, 1994, requesting free release of the wet-weather stream, our request for additional information dateu September 27, 1995, and your response dated May 15, 1996.
Our review of I
your response dated September 27, 1995, has identified additional information i
that is needed before final action can be taken on your request.
The additional information, specified in the enclosure, should be provided within 60 days of the date of this letter.
Please reference the above TAC No. in future correspondence related to this request.
As we discussed on October 18, 1996, I recommend that we have a conference call or a public meeting to discuss the additional information being requested. After you have reviewed our comments to your May 15, 1996, letter, please contact me on (301) 415-8139, to arrange either the conference call or the meeting.
Sincerely, 4MT N
Michael Lamastra Licensing Section 2 Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS Docket 70-1201 License SNM-1168
Enclosure:
Additional Information kl l!SDl $l
[h-ATTACHMENT 1
t U.S. NUCLEAR REGULATORY C0iMISSION'S COMMENTS ON THE ADDITIONAL INFORMAi10N REGARDING THE FREE RELEASE Of 'HE B&W FUEL COMPANY (FRAMATOME COGEMA FUELS) WET-WEATHER STREAM AREA i
Re_scnse to W :7 ment <
As recuested. :ne Jata spr'ary yr :e sa:' "es *ce # est of Te 3 Conditions recommended in NbREi CR-5549 t ie tre 3serace concentrat 0n of the entire wet weather stream is less than 30 pC1<g at a'95t confidence level).
The staff 15 also satisfied with the approach taken by the licensee to demonstrate that the survey data successfully meets the second condition recommended in NUREG/CR-5849 (1.e.
that the average concentration in each z
contiguous 100 m area is less than 30 pC1/g).
However. two of the contiguous areas averaged 30 pC1/g and one contiguous area averaged 31 pC1/g.
NRC staff understands that the background was not subtracted from the original measurements and that the net values may De lower than the data reported.
Please provide the results of background soll measurements and describe now background measurements were obtained In response to thc third recommendation of '.UREG/CR-5849. the licensee's response does not adequately satisfy the staff concerns that the concentration of enrich,ed uranium in any elevated area aDove 30 pCi/g 1s less than (100/ A) - times 30 pC1/g.
The NRC finds the action limit of 2.24 times 30 2
pCi/g. based on 16.8 m per data point. an acceptable approach for demonstrating compliance with the hot spot crite 1a.
However. one problem with the licensee's approach is that the (100/A){
formula used to derive a 2
release limit based on an area of 16.8 m was compared to the average concentration of the entire grid, this is not an appropriate application of this formula.
The derived limit using (100/A)05 should be compared to the average concentration over area 'A' For all data points with concentrations above 67 pCi/g (i.e.
2.24 x 30 pCi/g) the licensee should obtain additional measurements to determine the areal extent of elevated activity or used previous data, if i ailable. to evaluate compliance with the hot spot criteria.
It is still not evident from the data summary as to which data points are from the 1991 characterization survey and which are from the 1994 post-remediation survey.
A comparison of the data summary provided June 7. 1996, with the original report dated December 1. 1994, indicates that the 1994 post remediation activity levels are higher than the 1991 characterization data.
This is illustrated by the data points listed in the table below.
Please explain why 6ctivity at certain data points increased after remediation.
Data Point 1991 Characterization 1994 Post-remediation Survey Survey I
C3-5 3.24 pCi/g 89 pCi/g 07-5 32.2 pCi/g 43 pCi/g S6-5 20.0 pCi/g 46 pCi/g T6-5 2.67 pCi/g 64 pCi/g T8-5 9.51 pCi/g 70 pCi/g l
T10-2 67.2 pCi/g 90 pCi/g 1
Attachr
Response to NRC Comment 42 i
Page 2 and 30 of the survey report does not state that tne Reuter Stokes instrument was used to scan the surface of tne netmeather stream. The repert states 'Nt 'A Reuter Stokes mstrument was used to obtain radiation levels the samo e point location.
As mentioned the previous NRC staff comment.
scan surveys are an important part of a final survey.
NUREGsCR-5849 recommenas that af fected outcoor areas receive a surface scan of 100 percent of tne af fected area using mstrumentation with appropriate detection sensitivity.
A Reuter Stokes instrument (the staff assumes tne licensee is referring to a pressurized lon chamber-PIC) 1s appropriate for exposure rate measurements, which are also recommended as part of a final survey.
However.
PICS are not the most appropriate instruments to conduct surface scans.
Surface scans are conducted prior to direct measurements to identify areas of elevated activity and direct measurements 3re then performed at these elevated areas to define the extent and activity.
In the absence of sufficient surface scans. the staff 15 concerned that the licensee has not adequately identified dreas of elevated activity.
Response to NRC Comment #3 The licensee na g not demonstrated the wet-weather stream area is suitable for unrestricted release.
As indicated in the original comment. NRC staff 1s concerned that conducting a confirmatory survey at this time will identify additional elevated areas of contamination in excess of release criteria that may require additional remediation.
The issues listed below need to be addressed before a confirmatory survey of the area should be conducted.
(1)
In the absence of adequate surface scans. NRC' staff is not confident that the licensee has sufficiently identified all elevated areas of activity (see comment #2).
(2)
The licensee has not appropriately evaluated hot spots (see comment #1 and #8).
(3)
The survey does not include exposure r6te measurements as recommended in NUREG/CR-5849.
(4)
The highest points on the data summary appear to be taken from the 1994 post remediation survey (1.e.
C3-5 @ 89 pCi/g. T6-5 @ 64 pCi/g.
T8-5 @
70 pCi/g. T10-5 @ 90 pCi/g).
This indicates that contamination may still be present in excess of NRC release criteria (see comment #1).
Response to NRC Comment #6:
The licensee's response only addresses the second part of this comment.
Please address the first part of this comment.
In response to the second part of this comment, the licensee states. "
extensive surveys were conducted which concluded that the contamination was limited to the 0-6" depth."
Please provide the information or data to illustrate and validate this statement.
2 Attachment
1 Respon'se to NRC Comment #3:
As with comment al. NRC comment aB reite-ated that tne curvey data presented in the original '90er: does no: ceTC<nstrate 10mDl'arce wit" "o! 500: ; 'ifr'd
( 1.. e.
(100/A) 3s Tne 1,censee rescence; to :nis c;mment sta: eg -^a:
add 1;lonal samDies ColleC ec in 199J 3r;ur' '+ 3r :a:3 ;o'r:c sspoor: *re'<
i assumpt'cr trat :crtam,-a:' r c : :: screa: Devcrc : e.6 6 ~# area
'FC
~
sta " r i act -ea:- tre sate :09ci st:r a're 3.sc: c e 'ew :' :^e licensee's or'g:nal report.
- cr e(amp'e page 34 of
- -e :r g a' repcrt l
Illustrate the samples collected o!tnin Gr'c 5-6 Ine nignest sample oo'nt 's S-6-6 (102 pC1;g) wnich is in tne upper most ' eft correr of the grid block Without additional information. the extent of elevated activity above and to i
the left of data point 5-6-6 is not clear.
If fact. all grid blocks presented on pages 34-40 of the original report contain exterior data point with elevated activity.
This does not indicata that contamination is confined 2
within the assumed 16.8 m area.
As stated in comment #1. the licensee should obtain additional measurements to determine the areal extent of elevated activity around those data points that exceed 67 pCi/g (the derived hot spot z
limit for 16.8 m contaminated areas) or used previous data. If available. to evaluate compliance with the hot spot criteria.
)
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3 Attachm l
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I t
I i
l ATTENDANCE LIST j
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NAME ORGANIZATION Mike Lamastra U.S. NRC/FCLB Donna Moser NMSS/DWM Gayle Elliott Framatome Cogema Fuel i
George Pangburn NRC/NMSS/FCLB i
I 1
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ATTACHMENT 2