ML20138N972
| ML20138N972 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 10/08/1985 |
| From: | Malody C SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER |
| To: | Crow W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 25921, NUDOCS 8511060228 | |
| Download: ML20138N972 (13) | |
Text
c RETURN TO 396-SS 74 4 @
POX ERON NUCLEAR COMPANY INC.
acetivta 2101 HORN RAPOS ROAD, PO BOX 130. HICHLAND.WA 99352
- ' (*g" ",,,,',[9""8 (509) 375 8100 TELEX 152878
'85 0CT 28 Pi0:44 y
t C. F E October 8, 1985 b
s Mr. W. T. Crow, Acting Chief Uranium Fuel Licensing Branch l'
Division of Fuel Cycle and Material Safety, NMSS U.S. Nuclear Regulatory Commission j
Washington, D. C.
20555 13 Cs
. License No. SNM-1227 Docket No. 70-1257
Dear Mr. Crow:
,f' Exxon Nuclear Company, Ine. manufactured plutonium-uranium mixed oxide fuels in Room 173 of it's Mixed Oxide facility from 1971 into 1975. Manufac-turing of these fuels was hal'ted in 1975 and the facility has essentially been held in standby since that..date...During 1985, all mixed oxide equipment including hoods and of f gas treatment systems were decontaminated and packaged either for disposal or -long-term storage.
Room 173 is now consid-ered free of plutonium.
It is our plan to change the use of Room 173 from mixed oxide processing to uranium processing. We will be submitting to your office our final survey of that facility using the guidelines contained in Annex C to our license.
The final-survey will be submitted on or before October 25, 1985.
At the request of Mr. George Bidinger of your staf f we are, at this time, submitting a cogiy of'60Ffinal survey plan (enclosed).
The purpose of this decontaminati$n And final survey activity is to
~'
provide a basis for agreement between the-USNRC -and Exxon Nuclear that Room 173 has been cleansed of plutonium suf ficiently that it no longer will be considered a f actor in establishing licensing requirereents for future uranium operations planned for that facility.
We possess a small quantity of plutonium waste resulting from our decontamination e f forts, which is not acceptable for disposal to a low level disposal site under existing regula-tions. This material is currently stored in a vault separate from Room 173 but within the Speciality Fuels facility. Following our mutual agreement
. Room 173 is released from plutonium status we intend to submit a request t,
to appropriately amend the license eliminating requirements based upon I
onium except those necessary for storage.
~
4 p
DOCKETED
\\
rk4 y 'T"g{
G f ;;%a ff78 l
e usnm:
aw 3
OCT 311985 > ~2
~
g-Nur M AIL SECnCN 8
AN MFlUATE OF EXXON ConPORAf 0N g
DOCKET CLDs 8511060228 851000 PDR ADOCK 07001257
' m; C
m. _.
l
=
4' i,
l jl' i.
Mr. W. T. Crow-l October'8, 1985 Page 2 We will.also request a license amendment in the near future to allow the
~
incineration of combustible uranium wastes in Room.173. This latter request for amendment will be submitted in two parts.
The first part will be preliminary in nature but sufficient to allow construction to proceed.
The
[
f second part, which will cover the safety features in more detail, will be submitted at a later date.
Sincerely,
/
C. W. Mal'ody Corporate Licensing i
f CWM:jrs cc: R; D. Thomas, Region V
[
j i
I i
i 1
Y t
i d
i h
i 5
5 i
2 h
f F
I i
Ie i
r-
DECOMMISSIONING SURVEY PLAN ROOM 173 SPECIALTY FUELS FACILITY INTRODUCTION From October 1971 to November 1975, Room 173 was used for the fabrication of mixed oxide fuels containing up to 5.5 wt% plutonium oxide blended with natural uranium oxide.
See Figure 1 for typical arrangement during opera-tions. The gloveboxes and associated ventilation system which composed the 1
primary containment have been decontaminated to low level waste disposal limits, packaged and removed from the room. The majerity of the electrical, piping and duct work which supported the gloveboxes has also been removed.
See Figure 2 for typical arrangement after decontamination and equpment removal.
It is planned to utilize Room 173 for uranium only operations in the near future. It is necessary therefore to determine that any remaining plutonium contamination is insignificant to the point that it will not be a factor in future uranium operations. The acceptable surface contamination levels and procedural guidelines for such a release survey are in Annex C of License SNM-1227. Uranium was also processed in this room, therefore during the survey whenever alpha contamination is found with a portable survey instrument, a lab counter, surface barrier detector will also be used. This i
type of detector can differentiate between uranium and plutonium alpha particle energies.
BACKGROUND I
l l
The plutonium operations were conducted in gloveboxes operated at a negative pressure.
The operations consisted of blending plutonium-uranium oxide, coverting the powder to pellets and loading the pellets into fuel rods. The room air is rectrculated through two HEPA filters banks.
The glovebox
' exhaust was filtered through three HEPA filters banks prior to discharge out j
the stack. During deconsnissioning the glovebox exhaust lines and filters t
i
. were removed up to and including the second HEPA filter.
No plutonium contamination has ever been found on the inside of the duct work past the second HEPA filter.
The operations with the radioactive material were dry.
The only water in the room was non-contact cooling water for the furnace, which was discharged down the floor drain.
The liquid discharge from the floor drains and the HPT shower was held in the retention tanks for sampling prior to discharge.
Contamination has never been found in process cooling water.
During the early 1970's, several plutonium contaminated personnel were washed in the HPT shower after first being decontaminated by the Health Physics technicians.
It is possible that additional plutonium was removed in the shower but no plutonium was detected in the shower or retention tank at that time.
Plutonium was detected in the retention tank during 1975 when a few samples indicated 1.0 dpc/ liter with a detection limit of.5 dpm/ liter. The tank has been continually used and has had multiple cleanings since 1975. All sam-l i
plings since 1975 have shown the tank to be free o? detectable plutonium.
Minor amounts of contamination were released from the gloveboxes to the room (via glove rupture) from time to time during operation; all releases were readily cleaned.
During the operating life of the facility one significant contamination release occurred.
This resulted in contamination (5000 dpm direct maxieum) of a small portion (approximately 10 f t2) of floor and was subsequently identified, cleaned to non smearable and painted over. During decommissioning this area was cleaned by removal of the paint and no pluto-nium could be detected on followup surveys.
The vacuum system, which was used to draw air samples from room air and exhaust ducting, was the only service piping that was not under positive pressure.
All of the sample air was drawn through air sample filter paper which has an efficiency of greater than 90% for micron size particles.
Due to the minimal plutonium contamination in the room air there was an extremely small source term for contamination of the piping.
The legs of the vacuum O
. system have been removed. This vacuum system also services uranium contamin-ated process areas of the building which provide a much larger source term for uranium contamination of the vacuum system.
Uranium contamination has been seen in the final vacuum system filters which are in the system just prior to the vacuum pumps.
There is no indication of plutonium contamination in the system and it is intended to leave the system in service.
The lifetime cleanliness of the operation is indicated by surveys that show there to be no contamination in accumulated dust on the light fixtures and ceiling support members.
The procedural guidelines provided by Annex C 1.
Residual contamination will be reduced to levels as low as reasonably achievable.
2.
The contamination under or covered by paint must be documented by survey as meeting the release limits.
3.
The radioactivity on interior surface of pipe drain lines and duct work may be determined by survey at traps an other locations that provide a representative sample, 4.
Prior to release
- t. comprehensive survey report must be written and filed with the NRC.
This report must 1.
Identify the premises.
2.
Show that a reasonable effort has been made to eliminate residual contamination.
3.
Describe the scope of the survey and the general procedures followed.
4.
State the findings of the survey.
_._ e m
The actual release limits for plutonium are:
Average fixed 100 dpm/100 cm2 2
Maximum fixed 300 dpm/100 cm 2
Average removable 20 dpm/100 cm FINAL SURVEY PLAN l
The following is a summary list of surfaces that require a documented survey in support of the report to the NRC.
l 1.
Floor, walls, ceiling surfaces, (including under painted surfaces) the lights and roof supports.
2.
The outside of the service piping remaining in the room.
3.
The room floor drain and HPT shower drain system.
I 4.
The exhaust system.
5.
The vacuum system.
The standard procedures used for performing these surveys are summarized as
~
follows:
s SURVEYING FLAT SURFACES 2
j Smearable contamination:
Over 75% of the surfaces will be wiped down with j
dry soft paper / cloth. At regular intervals the wipe will be surveyed by a l
lab counter for detectable contamination.
If detectable contamination is found additional smears will be taken to locate the source. The source will i
subsequently be cleaned to below release levels.
Special ef fort will be made to wipe out and/or scrape out corners,. crevices and piping that may be j
contaminated.
f A
l l
l
...... _.. ~.,. _ _ _._.
1 l
}
Fixed contamination:
Survey will be-performed with a portable alpha survey i
instrument over 100% of the floor, 25% of the walls up to eight feet high and 5% to 10% of the upper wall and ceiling.
Special care shall be taken to survey the tops of duct work, corners, crevices, and piping remaining in the room.
If any count rate above limits is observed the source shall be investigated and cleaned to below release levels.
1 SURVEYING PAINTED SURFACES j
The original coat of paint covered non-contaminated surfaces; however j
surfaces that have received additional coats of paint will be surveyed for contamination following selective paint removal.
The floor and the wall i
below the 8 foot level are the largest surfaces that fall into this category.
Wall siirfaces eight feet above the floor and the ceiling will be investi-j gated but appear to have only the original coat of paint.
In order to verify that contamination does n;t exist beneath the coat of paint, the paint will be rcEeved from 100 cm2 areas selected at random and measured for plutonium.
i SURVEYING INSIDE DUCT WORK (EXHAUST-SYSTEM) i The _inside of the duct work will be surveyed by smearing and direct survey of 1
the inside' of the duct-at all accessible openings. Particular. care will be 1
taken to survey filter boxes and fans for detectable plutonium, i
SURVEYING THE DRAIN SYSTEM i
Srear surveys will be performed on the traps at the beginning of each inlet to the drain system. The HPT shower system has received multiple flushing during.the years *since the last plutonium processing.
These flushing j
combined with the negative results from the retention tank sample will i
provide adequate documentation of the cleanliness of the piping downstream of j
the traps.
i i
.4
,-.....,._,,_.--.y.
,.,__.,-4...%.
,,r
, SURVEY OF THE VACUUM SYSTEM The main vacuum header will be opened where each sample line connected to it, and a smear and if possible direct survey will be performed.
The vacuum system filters and their associated housing will be surveyed for plutonium T
contamination.
C0!JCLUSION Upon completion of the surveys the data will be collated and presented in report form as documentation that the facility is not contaminated with plutonium above Annex C limits and that the a reasonable effort has been made to remove any residual plutonium contamination to levels as low as reasonably s
achie'vable.
i I
1
.f I
}
\\
1 i
$I 9
{ i..
e 4
ep 4
1 e
$CN
/
T.
,/,s/
r
'l
/
,(/
/
l
/. _ s* *
,a"
- r. ~,as q
s*%4.-)
~
\\/
3 &E$?h&
W
+
L
=
L b$j
/,dc::
%^ 4
/v/ '('x' j j ty'.s e s'
/
/
d f;/
1 t
q 4
(
- %e '3ty=c(g O
\\/.
s.~_......~,.
v.
, m.
' 'l s
~~.
~'
,1
,1,...
~...
.K, ~s,.,.o ). '
,. s.p.
~
~. '.
U u a.;.
~..
~..
,'^,
l'_.
,,e',
e, N,._~. ', 2
'N',$ 'y< W'Q t
N ~, v, y
\\,.
I 1
l
i a:
i-i-i 1
N
.N
-f s x
/
j L
-. /-
N N
s
.. N N
-;D
\\
3 A>x x
/
p '-
N,.
[
I
%j
,k f
TI
- i S:
y' f' N bW.
APERTURE 1
No J
i CARD s 'N t niN. s.
_. - - J 3,
. - $d j Q'
)-
s
' ?*
, j % :
d,, b '.d).. 7 Also Available on I
A erture Car,f
-jfy 6' i
P
',fr ~ //
u'- 0 i
,-u..,~
./
I i
jf,',;, +% ?'s 6-
%Q
._N l
s 4
,a
..,u en
- c.. s
,f.g>3-
",l7~ -
C'd M Ws. bs )
,/
,/
~
y : ' _~l/3~
1,w..:?:/;
b6.,'.
' a j< :rge
~ -- w
% :'_, 2'.
l; f. -
j
, f' 5
Room 173 Typical
/,s
~.>
'/
,Y Glovebox Arrangement q-QN.a.,
^
j j
!m w>
. M,, t *.
~
agou was aw. u...w
,s/4 ~,
.,;_. f.
,....u
~,
.can u.a
- I. %, J >
FIGURE 1
.i I y N/
N/
i-~"
~~
((f 96J04O %Q m(
N
\\
i/'
~
f/
,./
1
.l,'
/
e n.csJ
)
/
% poei.m*.p # M P ME l
/
64/*TWO C
/
e 1;[ 'W' V
/
.f
..i.
i, h004 MvM farSTA & MeCi2 N
w.
t. (:
,', p NA ass %
L.,
",/, ', ',,
,e o _
l g
,o', * *
..,-~;.'~,.,.
N y",,',.
. 'g
%.',.=,' "
s l
'*'a' r 4, l,$',* N ', L:
%.. '.;,,;., ~
i
'~..>
~ ;.-
a,
a
~~,
~ ~,,. -
~.
'., y -:....,.- '..;..-,.-
% a y'
' *;l
~. c. y,.
y.,
~
,y
- 1 sa '
,a/
s, 's l
~'h
7 l
~_
/
V x-s a
3
)
)/ l i
1
?
i E
l l
e
.,/
~
/
M
=
o 1
q e
1
,s
?
TI
-% r*,",c-.," " " ',.
APERTURE y//"
CARD
--~~
' i. ',.-,'
ceans
/E
& Avanable on,
.[
~ ~.
tre M MusaC)
P
' Aperture Card h
', ',~,
.i.
' T.2 *]. '.
,o
,c' s s
,. S '
'/
.,/
4' '
sj' v-
-~
,ev mapa uctuacomma.ac
,/
FIGURE 2
~
ROOM 173 DECONTAMINATED r- "
a,-
r.....
__.JTF SSi O(o o 2R2-61
~
l