ML20150D278

Requests Addl Info in Support of 880120 Application to Amend License SNM-1067 to Permit Processing of U,Enriched to 5%,in U-235 Isotope

ML20150D278
Person / Time
Site:	07001100
Issue date:	07/07/1988
From:	Bidinger G NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Mcgill P ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY
References
NUDOCS 8807130398
Download: ML20150D278 (5)

Text

4 4 IMUF:GHB 70-1100

.-SNM-1067 Combustion Engineering, Inc.

ATTN: Dr. P. L. McGill, Vice President Nuclear Fuel 1000 Prospect Hill Road.

Windsor, Connecticut 06095-0500 Gentlemen:

' We have reviewed your application dated January 20, 1988, and will need additional infonnation in support of the amendment application to process uranium enriched to 5,/o in the U-235 isotope. The additional infonnation, identified in the enclosure, was discussed with your representatives on

' Wednesday, June 29, 1988.

We will continue our review upon receipt of the information. If you have any questions, feel free to call me.

Sincerely, Original $ipg Geor'g'd H. B dWger Fuel Cycle Safety Branch Division of Industrial and Medical Nuclear Safety, NMSS

Enclosure:

As stated cc w/ enc 1:

Mr. A. E. Scherer, Director Nuclear Licensing Mr. C. B. Brinkman, Manager Washington Nuclear Operations Mr. C. Waterman, Plant Manager, Windsor Fuel Manufacturing Mr. R. E. Sheeran, Manager 80 Licensing, Safety, Accountability < '0%

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Request for Additional Information Amendment Application Dated January 20, 1988 Part I of the Application (Numbers refer to Subsection) 1.6, These subsections provide subcritical mass limits for some buildings, 4.1.7.1 safe masses and subcritical slabs for others, and SIV's (Table 4.2.5 and in Part I) for other buildings. Since Section 4.1.7.1 is concerned 4.2.2 with "Audits," this is not the logical place for mass limits. Safe unit limits should be established in Part I, Section 4.2. The bases for all such units should be provided in Part II, Section 7.0.

The "double contingency principle" should be derronstrated.

4.1.7 These subsections serve no useful purpose since they refer to and requirements in Section 2.6 and 2.8.

4.1.8 4.2.2 The proposed limit of 6.0-inches for slabs for Building 5 does not assure nuclear criticality safety. See 4.2.2 above.

4.2.4 The proposed deletion of a requirement for the consideration of unit and array reflectors has not been justified and cannot be justified.

A clear statement requiring the consideration of reflection effects is needed.

The basic assumption concerning optimum conditions (limiting case) of water moderation and heterogeneity credible for the system is confusing. We suggest that, as a minimum, the parenthetical wcrds be deleted.

4.2.4.A The proposed changes are not justified. The existing criteria including limits and controls on mist density in areas where sealec fuel rods are processed and stored must be maintained. The proposed change would allcw use of the existing criteria in areas containing unsealed powder and pellet containers. Additional criteria would be needed for these areas to assure that moderated units and arrays of units would remain subcritical or that the moderation would be excluded i from the units.

l l The other proposed change would allow the Manager of Nuclear

! Licensing to approve changes to the fire sprinkler system. The qualifications for this position and the resume of the incumbent should be in the license, i 4.2.5 The units in Table 4.2.5 do not satisfy the Surface Density criteria I nor the safety factors for individual units as set forth in Section 4.2.4. The spacing requirement for cach unit in Table 4.2.5 should be provided in Table 4.2.6.

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4.2.6 This section limits array analysis to the Surface Density method.

This is quite restrictive and hos been violated repeatedly in Part II of the application.

The spacing criteria for slabs is nonconservative. Interaction with other units, and slabs in particular, must be controlled.

4.2.9 Proposed revisions to this page were made to a superseded page. The curreretly approved page should be revised and submitted.

4.3.2 The fire door would close upon alarm and loss of power. The door should close upon alarm or loss of power. The door as a safety system should be required to be closed except when attended and in use.

4.3.3 The location and contents of the four containers in the referenced figure can not be determined. Figure 8.2 must show the location of the containers.

4.3.4 This "one" pail limit is in conflict with the "two" pail limit in 4.3.3. Please clarify.

4.3.5 Does the 35 kg limit include material in the transfer pipes? If not, the safety analysis is incomplete.

4.3.6 What is the moximum potential depth of powder on and under the drying belt? Justify use of the "average" depth.

4.3.8 Provide the basis for 4-inch slab limit."

ano 4.3.9 4.3.10 Provide tne basis for the 6-inch slab limit.

4.3.12 4.3.13 4.3.16 Provide the bases for the drum mass limit and for the 2-high drum limit.

4.3.18 Provide the basis for storage of pellet containers on pallets.

4.3.18 These two subsections are contradictory on required spacing of 4.4.19 containers. Please clarify.

Part II of Application 8.1.2 Justify the fire door normally being in the open position.

8.1.3 The text described dimensions for steel containers whereas Figure 8.2 describes polybuckets with different dimensions.

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The cone change process should be described.

If moderator is considered to be excluded from the batch makeup process, the features of the hoods and the process to assure moderation exclusinn should be described. Appropriate license conditions in Part I should be established.

8.1.4.1 How much powder can accumulate under the belt. The assumption of 1/2-inch of powder must be justified.

8.1.4.2 How is the dryness of the powder verified?

Figure 8.4 is not sufficiently legible, but it appears to permit hopper sizes only for uranium enriched to less than 4.1 weight percent U-235. Provide hopper dimensions and a legible Figure.

8.1.5 Specify the hopper size for 5 */o enrichment material. If multiple hoppers are to be used, so specify and demonstrate the safety of each hopper.

8.1.6 Please describe the prccess and provide a safety analysis.

8.1.7 Provide a safety analysis for the press operation.

8.1.8 Provide the basis for the 4-inch slab.

8.1.9 Describe the slab storage rack and, if the trays are stored on more than one level, provide a safety analysis. Provide a safety analysis for the sump to ensure that a critical mass does not accumulate in the unfavorable volume sump. The 4-inch slab shculd be treated as in 8.1.8 above.

8.2 Provide process des:riptions and provide a safety analysis. Provide license conditions as appropriate.

8.3.1 It is not clear that fully reflected columns of buckets were analyzed. Since reflector controls were not provided, this situation must be evaluated.

8.3.2 Provide the basis for the VO, density measurements and justify use of homogeneous UO -H 0 mixtures. License conditions for pellet size anddensityshoulbbbestablishedinPartI.

Because less than optimum moderation was used, describe controls to ensure that moderation does not accumulate between trays and effectively increase moderation of the pellet slabs, t

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4 8.3.3 See comments above fu less than optimum moderation.

8'. 4 This unit is not cocootible with Table 4.2.5, Part I. Criteria duthoriring concentration con.rol should be provided.

8.5.1 See comments in 8.3.2 above for less than optimum moderation.

8.5.4 Was the rubber pad tre6ted as interspersed moderator? How will the rod height be controlled? (The box height is 5.25-inches where as the fuel is 6.5-inches.) The smallest diameter rod is 0.382-inches.

What is the largest pellet and rod diameter. Appropriate license conditions should be proposed in Part I.

How is moderation control assured so that interspersed moderation is not considered credible?

8.5.6 Figure 8.10 should come before Figure 8.11. License cor.ditions for pellet and rod parameters should be in Part I.

8.5.7 (Page 11.8-28) Where are Figures 8.24 and 8.25?

The assumeo film thickness was 0.025 nrn and the calculated thickness was 0.094 nrn. Reactivity increases with film thickness as shown on page II. 8-28A. The assumed film appears to be noncenservative.

C.5.9 Please provide a detailed process description.

8.5.10 An unlimited number of containers may be stored anywhere while an dTray of Containers is limited to 80 T.I. and 20-foot separation.

These two statements are contradictory.

8.5.11 A k-effective value was provided for a bucket containing 35 kg UO2 (at theoretical density) and water. A parametric study is needed to verify that the reported value is the maximum k effective, i.e., that optimum moderation conditiens for a reficcted bucket do not occur with less UO 2.

The pagination should be changed to alir.inate multiple page numbers and blank pages.

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