ML20195B476
| ML20195B476 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 09/30/1988 |
| From: | Nardi A WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | Rouse L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 24803, LA-88-43, NUDOCS 8811020034 | |
| Download: ML20195B476 (14) | |
Text
- _ __-____--__-__-_
RETURN TO ^hd$)
'/d-//8/
^6 ~
h g
/y LA 88-43
/
?
'%tito vsr.g 9
Westinghouse Water Reactor b
OcTor1988)
?
EsS'epennsywama is23a 0355 Electric Corporation Divisions 4
Af4/{ /,II
- %d'c?lll 8, f,
~ ' ' Q' fi
,4
'u p
s
~
h Septem 0, 19 g
O
-. U S.,gSjl. ? l GEE 9\\
c I
U. 5. Nuclear Regulatory Commission g
g AT'11:
Mr. Leland C. Rouse, Chief 4 % g" %
Fuel Cycle Safety Branch Gf f
Division of Industrial & Medical Nuclear Safety as W
HMSS M/S WF16113 Washington, DC 20555 Gentlemen:
REFERENCE:
SNM-1107, Docket 70-1151 Westinghouse Electric. Corporation submits the following information in support of a license amendment to SNM-1107:
1.
Changed pages 2.1-2 and 2.1-3, adding definitions for frequencies defined in the license.
The definition assures that tasks will be performed in accordance with the frequencies (e.g.,
monthly) but incorporates some flexibility to avoid inspection and enforement problems.
The spans included in this definition represent an approximate latitude of 25 percent which is generally acceptable in the nuclear industry.
2.
Changed pages 2.2-9 and 2.2-10, r'.odi f ylus the criteria for side shields on bulk containern shen they are removed from moderation controlled areas.
This was implemented because of industrial safety problems encountered with the side shields and is supported by Attachments 1 through 3.
If you have any questions on the attached, please write or telephone me at (803) 776-2610, Extension 3247.
Included is a check for $150.00 to cover the cost of a minor amendment.-
-, rq, c3,3,, -,,
5C if Very truly yours, 4
e
- 4 r
,n l
Wf A. J. Hardi, Manager
}, ~ f 9,,
yf NES License Administration N[i
'g
.s im p' i' WP2799E 3p.1 Q
cc:
G. D. Bidinger c)
,,i' M
h'W' Enclosures G811020034 880?30 g\\
--v1 ADOCK 0700 1
gDR
SCHEDULE OF REVISIONS Page Revision Page Revision Number Number Number Number i
15 1.5-2 2
11 10 1.5-3 2
iii 20 1.5-4 2
iv 3
1.5-5 2
y 15 1.5-6 2
vi 20 1.6 1 2
vii 14 1.7-1 2
viii 12 1.7-2 2
ix 20 1.8-3 2
1.0-1 2
1.8-2 2
1.0-2 15 1.8-3 2
1.1-1 2
1.8-4 2
1.1-2 2
1.8-5 2
1.2-1 2
1.8-6 2
1.3-1 2
1.8-7 2
1.3-2 11 1.8-8 2
1.3-3 2
1.8-9 2
4 1.3-4 2
1.8-10 2
1.3-5 2
1.8-11 2
1.3-6 2
1.8-12 2
1.3-7 2
1.8-13 2
1.41 2
1.8-14 2
1.4-2 2
1.8-15 2
1.4-3 2
1.8-16 2
1.4-4 2
1.8-17 2
1.4-5 2
1.8-18 2
1.4-6 2
1.8-19 2
1.4-7 2
1.8-20 2
1.4-8 2
1.8-21 2
1.5-1 2
1.8-22 2
Docket No. 70-1151 Initial Submittal Date:
4/30/83 Page No.
iii License No. SNM-1107 Revision Submittal Date: 9/30/88 Revision No.
20
SCHEDULE OF REVISIONS Page Revision Page Revision Number Number Number Number 2.0-1 15 2.3-11 2
2.1-1 2
2.3-12 2
2.1-2 20 2.3-13 2
2.1-3 20 2.3-14 2
2.1-4 2
2.3-15 3
2.1-5 2
2,3-16 deleted 2.2-1 2
2.3-17 2
2.2-2 2
2.3-18 2
2.2-3 16 2.3-19 2
2.2-4 3
2.3-20 2
2.2-5 3
2.4-1 3
2.2-6 2
2.5-1 19 2.2-7 2
2.6-1 5
2.2-8 2
2.7-1 3
2.2-9 20 2.7-2 3
2.2-10 20 2.7-3 2
2.2-11 2
2.7-4 2
2.2-12 4
2.7-5 2
2.2-13 4
2.7-6 2
2.?-14 15 3.0-1 2
2.3-1 4
3.1-1 2
2.?-2 4
3.1-2 2
2.3-3 3
3.1-3 2
2.3-4 2
3.1-4 2
2.3-5 2
3.1-5 2
2.3-6 2
3.1-6 2
2.3-7 2
3.1-7 2
2.3-8 2
3.1-8 2
2.3-9 2
3.1-9 2
2.3-10 3
Docket No. 70-1151 Initial Submittal Date:
4/30/83 Page No.
vi License No. SNM-1107 Revision Submittal Date: 9/30/ 88 Revision No. 20
4; REVISION RECORD Revision Date of Number Revision Pages Revised Revision Reason 13 7/23/87 New pages 1.11-6 Added authorization for through 1.11-8.
off-site drying of calcium fluoride.
14 8/14/87 Revised page 4.5-1.
Added drying of calcium
. fluoride to scope ~ of operations.
Revised pages 4.8-1 Delete. Western Zirconium and 4.8-2.
as' an authorized recipient of HF.
Revised page 4.1-1.
Update document date.
Revised pages 1.11-2, Added encapsulated 1.11-4, 1.11-5, and materials to briquetting 1.11-6.
description.
.15 8/18/87 New pages 1.14-1 thru Added criteria to 1.14-5 and 2.2-14.
preclude foreign contaminants from UFs cylinders.
16 1/25/88 Revised page 2.2-3.
Add interlock pressure requirement positive pressure gloveboxes.
17 2/8/88 Revised page 2.5-1.
Update of Emergency Plan Section.
18 5/25/68 Revised page 2.5-1.
Update of Emergency Plan Section.
19 8/12/88 Revised page 2.5-1.
Update of Emergency Plan Section.
20 9/30/88 Revised pages 2.1-2, Add frequency criteria 2.1-3, 2.2-9 and to the definitions 2.2-10.
Section.
Revised criteria for bulk containers.
Docket No. 70-1151 Initial Submittal Date:
7/23/87 Page No.
ix License No. SNM-1107 Revision Submittal Date: 9/30/88 Revision No.
20
2.1.1.7 Equivalent Diameter wnen evaluating the
- adequacy, for purposes of nuclear criticality safety, of the geometry control of a subcrit unit having a noncircular cross section, the diameter of that circle that has the same area as the area of the section of the suberit unit.
Dequiv.
2
( Area /pi) gross'/2 where Area is the cross sectional area of the
=
subcrit unit under review.
2.1.1.8 Equivalent Experience - when used to equate experience with education, then years of applicable experience 15 equivalent to a bachelor's degree.
2.1.1.9 Engineered Controls Equipment which physically constrains the SNM or redundant instrumentation controls which assure that a safety factor of 1.3 is not exceeded, using double contingency criteria.
2.1.1.10 Fraction Critical the ratio of the equivalent spherical volume of a subcrit, determined from geometric buckling conversions (for example, see Subparagrph 1.8.1.4),
to tne unreflected critical volume of a sphe.re of the same fissile material.
2.1.1.11 Frequency Definitions Where measurement / surveillance Trequencies are described in the
- license, the following criteria shall apply:
FREQUENCY CRITERIA Daily Once per day, j
Weekly Once per calendar week.
Monthly Twelve per year; no measurement or task to exceed a span of 40 days.
Quarterly Four per year; no measurement or task to exceed a span of 115 days.
Semi-Annual Twice per year; no measurement or task to exceed a span of 225 days.
Annual Once per year; no measurement to exceed 4
a span of fifteen months.
Biennial Every two years; no measurement or task to exceed 30 months.
2.1.1.12 Functlan,. when used administrative 1y, an individual (usually the compoaerit manager), acting in coordination with the other personnel, of a component, having the capability and authority to make and implement decisions required to carry out the component's assigned responsibilities.
2.1.1.13 Licensed Activity - that combination of personnel, plant and equipment established by the Corporation to carry out the processing of radioactive material authorized by this license.
2.1.1.14 Limited Area - An area where small quantities of uncontained radioactive materials are processed such that th0 probability of contamination on floors and accessible surfaces is low.
(e.g.,
Analytical Chemistry
- Lab, Healtn Physics
- Lab, Manufacturing Development Lab, Metallurgical
- Lab, Step-Off Pads,etc.).
2.1.1.15 Maximium Permissible Value (MPV) - that value or combination of values of a selected nuclear criticality safety control parameter (s) which:
Docket No. 70-1151 Initial Submittal Date:
4/30/83 Page No.
2.1-2 License No. SNM-1107 Revision Submittal Date:
9/30/88 Revision No.
20 4
I, 2,l.1
- (Continued)
(1) has been established.to ' assure nuclear criticality
. safety for the subcrit' under all foreseeable f
conditions, ' including interaction and the' maximum credible accident.
l (2) is the value connunicated to the operator (s) as the f
value that must be observed.
i 2.1.1.16 Nuclear Equivalence - A reduction in neutron flux equivalent j
to eight inches of high density concrete (greater than 140
~
pounds per cubic foot).
2.1.1.17 Nuclearly Isolated - A subcrit or array of subcrits located with respect to any other subcrit such that an edge-to-edge separation exists between them which is not less than one of the following or its nuclear equivalent:
(1) Eight inches of water.
f (2) A distance through air which is the larger of 12
- feet, or the greatest distance across an orthographic projection of either subcrit or array of subcrits on a plane perpendicular to a line joining their centers.
l 2.1.1.18 Rettricted Area - An area to which access is controlled by
{
physical or administrative moans and routinely monitored by f
site security personnei.
2.1.1.19 Subcrit - An accumulation of fissionable material which is t
treated as a whole and within which one or more physical limitation (s) is incorporated to assure nuclear criticality safety.
2.1.2
_ Sum.ary Descri_ption l
2.1.2.1 The objective of the licensed activity is the ADU or IDR
}
process conversion of uranium hexafluoride to uranium dioxide l
and the manufacture of fuel-bearing components for nuclear i
reactor cores.
The licensed material is composed of unirradiated special nuclear materials received principally as j
uranium hexafluoride containing uranium enriched up to 5.0 w/o in the isotope U-235.
I I
i Docket No. 70-1151 Initial Submittal Date:
4/30/83 Page No.
2.1-3 I
r License No. SNM-Il07 Re?ision Submittal Date: 9/30/88 Revision No.
20 l
i I
ATTACHMENT 1 JUSTIFICATION FOR TRANSPORT OF BULK URANIUM CONTAINERS WITHOUT PROTECTIVE SIDE SHIELDS Transport of bulk containers from blending, storage and processing areas will be accomplished via a hand operated lif t vehicle.
The routes include pellet and conversion aisleways in addition to a portion of the UF6 Bay.
The integrity of the bulk containers in Subparagraph 2.2.13.9 of License SNM-1107 focuses on the use of speed limiting devices on transport equi pment, container cesign to portable tank specification 49CFR 178.251 and protective devices for containers during transport. For this review, impact features along designated transport routes will be imolemented in lieu of container sideshields.
A hypothetical bulk container rupture could occur via three modes; collisions involving bulk containers and other transportable equipment, overhead equipment failures dropping debris on bulk containers and a container accidental drop causing failure.
Container ruptures are precluded through the use of speed limiting devices on transport vehicles.
In addition, maintaining containers in accordance i
with the portable tank specification 49CFR 178.251 will ensure, coupled with the speed limiting device, that no container ruptures can result due to collisions.
As an added precaution, impact devices such as railings (as opposed to container sideshields) will be employed so tnat the integrity of moderating systems can be assured.
Overhe:.d equipment failures can result in container ruptures.
This can be d
wevented by minimizing overhead equipment to that which is essential to area operations and by ensuring the integrity of this equipment.
Currently, there is no overhead equipment in the proposed storage area.
A container rupture or breach due to an decidental drop is not credible since the containers are generally lifted only two inches.
lhese containers are designed to withstand a two (2) foot drop as described in 49CFR 178.252-3(2).
Thus, container ruptures can be prevented through transport speed limiting devices, container design, and impact features along designated transport routes to prevent interactions with rmderating systems.
Based on a review of the storage and transport area accident scenarios, involving a breached bulk container and ingress of moderators, the double contingency principle can be assured for the following conditions:
a.
Bulk container design to 49CFR 178.251.
b.
Speed limiting devices on transport equipment.
c.
Continuous operator surveillance of bulk container during transport.
d.
Protective impact features for moderating (H 0) systems.
2 e.
Ensure integrity of the sprinkler system and steam lines through routine maintenance.
f.
Adherence to procedures regarding transport routes, minimization of combustible and moderating material, is strictly enforced.
contingency)grity of area construction (required to satisfy the double Ensure inte g.
through routine maintenance. summarizes the list of required administrative and physical controls for the transport of bulk uranium containers in conjunction with postulated "events" or failures. An adequate safety margin will exist, for the proposed design and requirements, to minimize the probability of a criticality in the unlikely event that the containers are breach to allow water ingress. list the "contributing causes" described in Subparagraph 2.3.1.10 of License SNM-1107 that would apply to storage and transport of bulk containers, i
1 l
r WP2799E:3 l
a
EVENTS / CONTINGENCIES EVENT CONTINGENCY 1.0 Breach of structure (wall 1.1 Facility designed to roof) in Southeast Expansion prevent water ingress.
and entrance of water.
1.2 Integrity of facility maintained.
1.3 Limited use of water in adjacent areas.
2.0 Breach of bulk container in 2.1 Containers designed and blending, storage and maintained in acccrdance with processing areas.
49CFR 178.251.
2.2 Integrity of facility maintained to prevent ingress of water.
2.3 Protective impact features used in storage.
2.4 Speed limiting and braking devices used en transport equi pment.
2.5 Minimize overhead load bearing devices.
2.6 Written procedures dictate required moderation controls in the Soutneast Expansi7n.
3.0 Breach of bulk container 3.1 Containers designed and during transport between maintained in accordance blending, storage and witn 49CFR 178.251.
processing areas.
r 1
P
EVENTS / CONTINGENCIES (cont'd)
EVENT CONTINGENCY 3.2 Protective features used along designated container transport routes.
3.3 Speed limiting and braking devices used on transport equipment.
3.4 Written procedures define transport routes.
3.5 Continuous operator surveillance during transport.
4.0 Entrance of water to breached 4.1 Written procedures concerning bulk container during transport.
sealing (gaskets) cf bulk containers.
4.2 Protective impact features used for steam lines in the UF6 Bay.
4.3 Sprinkler system designed and maintained to prevent false activation.
4.4 fianual shut-off capabilities for sprinkler system, c
4.5 Written procedures concerning minimization of combustible material storage in the UF6 Bay.
4.6 UF6 trench maintained in a dry state to prevent water ingress in the event that a bulk container is dropped in the trench.
4.7 Written procedures define transport routes.
WP2799E:3
ATTACHMENT 3 CONTRIBUTING CAUSES/ CONTINGENCIES CONTRIBUTING CAUSE CONTINGENCIES a.
No detailed written procedures a.1 Written procedures are for new process.
required for all process operations.
2 All procedures for operations b.
P must be reviewed and approved by Regulatory Affairs.
b2 Written and approved procedures are required for all operations.
b.3 Operations personnel are trained in the proper responses to process and area
- upsets, c.
Inadequate identification of col Transfers of uranium-bearing materials.
materials are controlled by procedures, c.2 Supervisor or Chief Operators are required to verify the proper identification of materials prior to the transfers, d.
Failure to audit program.
d.1 The audit program is a
condition of the SNM-Il07 license.
d.2 Audits o/
programs and operations include assessments of personnel performance.
WP2799E:3
CONTRIBUTING CAUSES/ CONTINGENCIES CONTRIBUTING CAUSE CONTINGENCIES e.
Failure to follow procedures, e.1 Supervisor overcnecks of operators.
e.2 Regulatory Affairs audits.
f.
Changes improperly authorized by f.1 Supervision is responsible shift supervisors, for the safety aspects of all operations.
f.2 Changes to existing procedures and new operations involving special nuclear materials must be reviewed and approved by Regulatory Affairs prior to implementation, f.3 Routine audits are performed by Regulatory Affairs to confirm compliance.
f.4 Supervision is supported by process engineering for technical aspects of the processes.
g.
Poor connunications between j.1 Operations performed in personnel, accordance with
- written, approved procedures.
J.2 Process steps documented via checklists provided as part of procedares.
J.3 Procedures 3nd checklists subject to Regulatory Affairs inspections.
WP2799E:3
2.2.13.4 ' (Continued)
Radiation Protection Component may be introduced to the area.
Individual containers of moderator (e.g.,
water) shall be j
limited to 5-gallon capacity.
2.2.13.5 Moderator additions to moderation-controlled processes (e.g.,
IDR operations) shall be made batchwise so that accidental addition of large quantities of moderator has a
low probability.
2.2.13.6 Controls associated with transfers of enriched uranium from geometry-controlled containers to moderation-controlled containers (e.g.,
completion of moisture determinations, container
- sealing, verifying that moderation-controlled containers are free of hydrogenous materials) shall be documented.
This documentation shall be overchecked for completeness and accuracy by an individual other than the one performing the original determination prior to further processing of the material.
Moisture determinations shall be completed before the material is transferred into moderation-controlled areas.
2.2.13,7 Monthly audits shall be conducted by the Radiation Protection Component to verify continued proper functioning of moderation-control systems and controls.
2.2.13.8 Nuclear criticality safety analysis of moderation-controlled operations shall include consideration of the effect of accidental moderator double batching (e.g., IDR operations).
2.2.13.9 The following controls shall apply when bulk container s conta in ing fissile
- material, are removed from the Moderation Controlled Area:
(1) During transport, moderating systems (water lines, etc) shall be physically protected (impact features, etc.)
against conditions incident to transport of bulk containers.
(2)
Bulk containers shall be transported through designated areas.
Docket No. 70-1151 Initial Submittal Date:
4/30/83 Page No.
2.2-9 License No. SNM-1107 Revision Submittal Date:
9/30/88 Revision No.
20
l*,
2.2.13.9 ' (Continued)
(3) During transport, storage and powder off-loading, the bulk containers shall be oriented with the discharge feeder in the "down" position (4) During powder off-loading and container breaches at th e unloading station, controls shall be established to assure that a closed system is maintained, providing positive containment of powder and precluding accidental introduction of moderating materials.
This containment shall consist of a ventilated confinement surrounding the bulk powder container and discharge equipment and designed to exclude maderator material.
(5) Bulk containers snall be designed, constructed, and tested in accordance witn applicable specifications in Title 49, Code of Federal Regula+1ons, Part 178.251 and 178.252, for Specification 56 portable tanks.
~
(6) Container closure devices (gaskets, flanges, etc.) shall be inspected for integrity prior to eacn closure.
l (7) Bulk container hoists shall be designed and operated to provide a margin of safety for both routine and accident conditions, including excess speed brak ing provision, brake-motor interlocks,. semiannual load testing of hoists and chains or cables.
2.2.14 10R Conversion Process Equipaent 2.2.14.1 The followIng shall be provided as part of the 10R conversion i
system:
i (1)* Disentratnment chamber steam temperatiire detectors (2) Disentrainm^nt chanter steam trace heater circuit t
detectors l
(3)* Disentrainment chamber temperature detectors (4) Disentrainment chancer heater circuit detectors (5)* Disentrainment chancer pressure detectors (6)* Kiln barrel steam temperature detectors 1
Docket No. 70-1151 Initial Submitt61 Date:
4/30/83 Page No.
P.2-10 l
License No. SNM-Il07 Revision Submittal Date: 9/30/83 Revision No.
20 1
t l
l