ML20149J044

SER Approving Application for Amend 3 to License SNM-1227

ML20149J044
Person / Time
Site:	Framatome ANP Richland
Issue date:	07/18/1997
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20149J013	List: ML20149J011 ML20149J028 ML20149J044
References
NUDOCS 9707280018
Download: ML20149J044 (4)

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1' UNITED STATES

r [ NUCLEAR REGULATORY COMMISSION

.W ASHINGTON, D.C.. 20565 0001

'%.4g July 18, 1997

[DOCKETi 70-1257 LICENSEE: SIEMENS POWER CORPORATION e 'RICHLAND WA

%BJECTi SAFETY EVALUATION REPORT: ' APPLICATION DATED FEBRUARY 2.1

" 1997. REQUEST FOR INCREASE IN HF BATCH SIZE FOR RELEASE,

!' DECREASE IN'THE FLOW-RATE FOR LABORATORY HOODS. AND 3 DECREASE IN THE CALIBRATION FREQUENCY FOR DIRECT-READING DDSIMETER b' .

PENCILS i [DACKGROUND

• By letter dated February 21. 1997, Siemens Power Corporation (SPC) submitted i

an amendment application to Special Nuclear Materials License SNM-1227. 'SPC requested an increase i' the authorized batch size of hydrofluoric acid (HF) .

. for release offsite, a decrease in the air. velocity through openings in

laboratory hoods, and a decrease in the calibration frequency for. direct- ,

' reading dosimeter pencils. In additionr SPC submitted revised pages to Part I of their license to correct errors and add clarification. By letter dated

. March:7; 1997, SPC submitted a supplement to the amendment,2pplication.to correct an oversight in the February 21 application.

A recuest for additional information (RAI) was transmitted to SPC by letter .

datec.May 13, 1997, identifying the staff's concerns regarding the requested

. decrease in the face-velocity for laboratory hoods. SPC responded to these  ;

concerns by letter' dated June 9, '997.

DISfMS.Sl0N l 1. HF Batch Size-

• < SPC is currently authorized to release hydrofluoric acid manufactured by the dry conversion process (OCP) for unrestricted commercial use, providing that a

representative sample of each batch is taken and analyzed for uranium,' the

,J specific activity of each batch is less than or equal to 3 pCi/L. and the batch size is no greater than 20,000 L.

, This batch size was adequate for 0CP pilot plant operation. However. SPC anticipates that, once the new DCP facility achieves steady state operation F' from its' three conversion lines. production'of HF will reach approximately 23,000. liters per week. SPC has installed two 45.420 L tanks to receive this

, HF prior to its being picked up by the customer in 19.000 L tank trucks. The ,

'A reason for having the two large tanks is to have enough lag storage.such that A anytinability of tank trucks to make scheduled weekly pickups would not result.

i'i Lin either neutralization and diversion to the lagoon system and then to che' tsewer or shutdown ofidry conversion.

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2 Therefore in the February 21. 1997 submittal. SPC requested an increase in the HF batch size to 46.000 L. SPC will continue to representatively sample the 46.000 liter lots to confirm that the specific activity is less than or 4 equal to.3 pCi/L prior to release.

Additional information concerning d Re size and emergency preparedness was emvided to the NRC by SPC staff via telephone on July 10. 1997. The HF tanks

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located in a common diked area capable of containing 123 percent of one of Lne 45.420 L tanks in accordance with Washington state regulations. In addition. HF Neutralization First Aid Kits are kept in the lobby of the DCP Facility and safety showers are located at the storage tanks. The NRC staff has determined that the HF is stored safely end an ir. crease in batch size is therefore acceptable, However. NRC regulations specified in 10 CFR 70.22 (I)(1)(ii) require SPC to have an emergency plan for responding to the radiological hazards of an accidental release of special nuclear material and any associated chemical hazards directly incident thereto. In review of this amendment request. the NRC staff notes that SPC's current Emergency Plan (Rev. 20. January 8. 1996) does not accurately reflect generation and storage of HF at the facility. For '

example, although SPC has requested that as much as 46.000 liters of HF to be stored onsite, the Plan lists the average inventory of HF as 10.000 pounds.

which is roughly 3.800 liters, assuming a concentration of 50 percent by

. weight HF. According to 10 CFR 70.33(I). SPC has six months to 3rovide the NRC a copy of changes to the emergency plan, when revisions to t1e plan do not decrease its effectiveness.

The NRC staff expects SPC to revise the Emergency Plan to accurately reflect current or expected plant conditions. In addition, the staff recommends the following license condition:

The licensee shall maintain and execute the response measures in the l Emergency Plan. Revision 20. dated January 8. 1996: or as further revised by the licensee consistent with 10 CFR 70.32(I).

NRC staff discussed this license condition with James Edgar. Staff Engineer.

Licensing Regulatory Compliance. SPC on June 26. 1996. Mr. Edgar did not express any objection to the license condition.

2. Laboratory Hoods

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In addition to the increase in the HF batch size, in the letter dated February 21, 1997. SPC proposed to decrease the minimum average air velocity .

through openings in laboratory hoods from 125 linear feet per minute (LFPM) to l 80 LFPM. SPC indicated that the change to the lower face velocity would help  !

i improve several facets of the laboratory exhaust system, including more 1 efficient hood ventilation, less hood leakage, hoods not having to operate at  :

or above their designed flows, and improved laboratory air balance. l l

Insupportofthisrequest.SPCprovidedacopyof"FundamentalsofLaboratory Venti,ation." dated February 11. 1990 and excerpts from Industrial Ventilation: A Mantel of Reconvended Practicg.1986, by the American j i

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Conference of Governmental Industrial Hygienists. Theie reference > aiscus I guidelines for ooen hood air velocities under varying conditions. SPC ,

indicated that t1eir laboratory hoods meet the regt.irements specified in .the -

Ventilation. Manual for an open hood face velocity of 80 liPM. The laboratory air supply vents are laminar and operate at less than 40 LFPM and the vents are located well away from the hx)d faces so that airfhw thrcagh the hood faces is not affected.

I In review of this request the NRC staff noted, however, that the Industrial i Hygienists' Ventilation Manual recommends a minimum face velocity of 100 LFPN

- for hoods where low activity radioactive laboratory werk is performed. In 3 addition. " Fundamentals cf Laboratory Venti'lation" recommends that in general.

laboratory hoods should have a face velocity of about 100 LFPM. The staff communicated these concerns to SPC by letter dated May 13. 1997. SPC respon ed d by letter dated June 9.195/. in which they revised their request. -

3PC committed to face velocities which tverage 100 LFPM for laboratorf hoods.

but due to the variable performance af kood ventilation. may range 15 percent. The average air velccity in other uranium handling hoods and in equipment containing readily dispersible uranium shall average 125 LFPM

i 15 percent. The staff has determined that this is con;istent with good industry practice and is, therefore, acceptsble.

3. Pencil Dosmeters SPC also reauested that the calioration frequency for direct-reading dcsimeter pencils be reduced from semi-annually to annually. The pencils are used only for emergency situations and are stored in cabinets. They are checked and

reset, if necessary. prior to use. The st.ff has reviewed this recuest and determined that annual calibration of direct reading dosimeter pencils is acceptable.

4. Corrections and Clarifications The February 21. 1997, submittal, included revised pages of Part I of SPC's license to correct typographical errors. Page 3-14 was revised to correct the

. urinalysis action levels in Table 1-3.3 from mgu/L (milligrams uranium per liter) to ugU/L (micrograms uranium per liter). and page 4-2 was revised to correct the reference in the second paragraph from 2.1.16 to 2.1.17 in two pnaCes.

By letter dated March 7, 1997. SPC resubmitted revised page 4-17 of the license, which includes Table I-4.1. This table lists the major system '

components used at SPC and the ty)e of criticality safety control for each

, component. In order to reflect tut the controls listed for the autoclaves in the DCP De the same as those listed for the DCP vaporization che.sts, the table waF revised to explicitly identify the autoclaves along with the vaporization chests. In addition, the table was revised to delete the words " pilot :lant" when referencing to the DCP vaporization chests and autoclaves. since tais is no longer applicable.

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ENVIRON $iENTA1PEVIEy The r,taff has determined that the following conditions have been met

.1, There is no significant change in the types or significant increase in I the amcunts of any effluents that may be released offsite. -

2. There is no significant increase in individual or cumulative occupational radiation exposure,

3. There is no significant construction impact. and  ;

4. There is no significant increase in the potential for or consequences from radiological accidents.

Accordingly, pursuant to 10 CFR 51.22(c)(11), neither an environmental

-assessment not an environmental impact statement is warranted for this action. )

COELELQti The NRC staff has reviewed the licensee's arcposed amendment and has determined that the proposed changes will uve no adverse ef fect on public  ;

health and safety or the environment. Therefore, approval of the amendment application is recommended.

~ihe Region IV inspection staff has no objections to this proposed amendment. i

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,,;n a PRLRClPAL CONTRIBUTOBS Q"g - ,

4 Susan D. Chotco Donald E. Stout 4

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t Kimberly J. Hardin p /

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