ML20149L730
| ML20149L730 | |
| Person / Time | |
|---|---|
| Issue date: | 11/05/1996 |
| From: | Gary Comfort NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Rowland T ENERGY, DEPT. OF |
| References | |
| REF-PROJ-M-32 NUDOCS 9611140284 | |
| Download: ML20149L730 (5) | |
Text
November 5, 1996 Mr. Thomas J. Rowland, Director West Valley Demonstration Project U.S. Department of Energy P.O. Box 191 West Valley, New York 14171 4
SUBJECT:
COMMENTS ON THE SAFETY ANALYSIS REPORT (SAR) FOR FUEL RECEIVING AND STORAGE FACILITY, WVNS-SAR-012, REVISION 0, DRAFT C
Dear Mr. Rowland:
Enclosed are comments and questions dweloped during our review of the Safety Analysis Report (SAR) for Fuel Receit ing and Storage Facility, WVNS-SAR-012, Revision 0, Draft C, submitted as an att whment to a letter from you to me dated October 8, 1996.
If you or your staff require further clarification of these comments, please call me at 301-415-8106.
Sincerely, Original signed by:
Gary C. Comfort, Jr.
Licensing Section 2 Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS Project M-32
Enclosure:
WVNS-SAR-012 Comments Distribution Project'M-32 PUBLIC ~
NRC' File Center FCSS R/F m.
NMSS R/F FCLB R/F Region I
- G:\\wv110196.gcc]
0FC FCMk.-
E FCLB h
FCLB
. 6 NAME domfort PShe n ()b MTokar/[h g
DATE 11/ f /96 11/I/h6 11/I/96
/d i
9611140284 961105 g
k EB52 em 13013.1 NRC FILE CENTER W
~
p arco 4
UNITED STATES ee
+
2 E
NUCLEAR REGULATORY COMMISSION f
WASHINGTON, D.C. 20565 0001 November 5, 1996 Mr. Thomas J. Rowland, Director West Valley Demonstration Project U.S. Department of Energy P.O. Box 191 l
West Valley, New York 14171
SUBJECT:
COMMENTS ON THE SAFETY ANALYSIS REPORT (SAR) FOR FUEL RECEIVING AND STORAGE FACILITY, WVNS-SAR-012, REVISION 0, DRAFT C
Dear Mr. Rowland:
Enclosed are comments and questions developed during our review of the Safety Analysis Report (SAR) for Fuel Receiving and Storage Facility, WVNS-SAR-012, Revision 0, Draft C, submitted as an attachment to a letter from you to me i
dated October 8, 1996.
If you or your staff require further clarification of these comments, please call me at 301-415-8106.
Sincerely, Gary C. Comfort, Jr.
j l
Licensing Section 2 Licensing Branch Division of Fuel Cycle Safety i
j and Safeguards, NMSS 1
Project M-32 l
Enclosure:
WVNS-SAR-012 Comments i
1 COMMENTS OR QUESTIONS ON WVNS-SAR-012, REVISION 0, DRAFT C i
Comment #1 lection 2. Paae 2-4 (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 (mrem). This is inconsistent with the value given in Table 2.5-1 which indicates a dose of i
967 mrem.
It appears that the offsite and onsite doses have been reversed in I
this table.
Please review this table to ensure its correctness.
i t
l Comment #2 Sections 4.0 and 5.0. Paaes 4-1 and 5-3 l
The text states that although the Fuel Receiving and Storage (FRS) facility does not meet all of the current design criteria, they are nonetheless judged to meet the West Valley Project's current needs.
Please provide a copy of the i
Bixby (1989) reference that supports this assertion.
Comment #3 e
l Section 5.2.3. Paaes 5-4 to 5-5 The text states that masonry blocks from the 8-inch masonry block interface wall between the FRS building and the Main Plant building may become dislodged
)
l during certain seismic conditions.
Please provide a copy of the Dames & Moore l
(1995) reference evaluating this issue.
l Comment #4 l
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 properties such as pH, conductivity, etc.
It appears that the measurement of B activity or '37Cs 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.
Comment #5 Table 7.2-1 Some of the information presented in this table does not appear to be internally consistent.
Examples include:
(1) the total Pu in HIC "C" is less than the sum of the Pu isotopes in the same HIC, and (2) the total Pu-238 inventory assuming the indicated sludge mass for all HICs is 0.0116 rather than 0.0193 Ci.
Please review these tables to ensure their correctness.
4 ENCLOSURE
2 Comment #6 Tables 8.2-3 and 8.2-4 on Paaes 8-28 and 8-29. respectively 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 is expected to increase with time (for short times).
This discrepancy may be a result of the initial inventories being calculated with an old version of ORIGEN and then calculating the 21-year inventories without accounting for ingrowth resulting from the decay chain. 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 i
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-year inventories by correcting for only the decay of the nuclide. This process is incorrect for nuclides that appear in a decay chain, such as Am-241.
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 i
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 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 /MTV. 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 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 in the inventory may affect subsequent calculations, especially any criticality calculations, that use Tables 8.2-3 and 8.2-4 as a basis for the radionuclide content of the fuel.
Comment #7 Tables 8.7-1 and 8.7-2 on Paaes 8-30 and 8-31. respectively The text nor the subject tables state whether burnup credit was considered when calculating the listed values of kinventories shown in Tables 8.2-1 and 83.
If the uranium and plutonium 2 were used for the criticality calculations, that should also be stated.
3 Comment #8 Section 9. Paae 9-3. Line 25 and Section 9.1.2.3.2 The text states that "... gravitational potential energy represents the most significant source of energy..." Have the consequence 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 non-radiological impacts.
Comment #9 Section 9. Paae 9-24. Table 9.2-1 Due to discrepancies found in the inventory calculations, the on-site dose calculation for Am-241 for a class D atmosphere wag checked. The listed Chi /Q value were 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.
Comment #10 Section 9. Paae 9-13. Lines 30 and 31 1
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 incorrect).
j
.