ML20195B770

Requests Addl Info on 980331 Application for Amend to License SNM-1107 for Changes to Chapters 3.0 & 6.0 Re Criticality Safety.Addl Info Needed Specified in Encl

ML20195B770
Person / Time
Site:	Westinghouse
Issue date:	10/29/1998
From:	Gaskin C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Robert Williams WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
References
TAC-L31067, NUDOCS 9811160270
Download: ML20195B770 (7)

Text

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October 29, 1998 Mr. R bert A. Willitms

'Sif; guards Coordinator Westinghouse Electric Corporation Commercial Nuclear Fuel Division Drawer:R Columbia, South Carolina 29250

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE REVISION 10.0 - CRITICALITY SAFETY (TAC NO. L31067)

Dear Mr. Williams:

This refers to your application dated March 31,1998, requesting an amendment to Materials License SNM-1107 for char ges to Chapters 3.0 and 6.0 regarding Criticality Safety.

Our review of your applicaf on has identified additional information that is needed before final action can be taken on yo'. r request. The additional information, specified in the enclosure, should be provided within 60 days of the date of this letter. Please reference the above TAC No. in future correspondence related to this request.

If you have questions regarding this matter, please contact me at (301) 415-8116.

Sincerely, Original signed by:

Charles E Gaskin Licensing Section 1 Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS Docket 70-1151 License SNM-1107

Enclosure:

As stated l cc: Mr. Wilbur Goodwin, Regulatory Affairs l Westinghouse Electric Company I

Commercial Nuclear Fuel Division Drawer R I Columbia, SC 29250 Distribution: (Control No. 810S)[ PARTIAL]

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%,,, October 29, 1998 Mr. Robert A. Williams '

Safeguards Coordinator Westinghouse Electric Corporation Commercial Nuclear Fuel Division Drawer R Calumbia, South Carolina 29250 {

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE ,

REVISION 10.0 - CRITICALITY SAFETY (TAC NO. L31067)

Dear Mr. Williams:

i This refers to your application dated March 31,1998, requesting an amendment to Materials License SNM-1107 for changes to Chapters 3.0 and 6.0 regarding Criticality Safety.

Our review of your application has identified additionalinformation that is needed before final action can be taken on your request. The additional information, specified in the enclosure, should be provided within 60 days of the date of this letter. Please reference the above TAC l

_ No. in future correspondence related to this request.

l If you have questions regarding this matter, please contact me at (301) 415-8116. l Sincerely,

artes E. Gaskin i Licensing Section 1 Licensing Branch Division of Fuel Cycle Safety

[ and Safeguards, NMSS Docket 70-1151 License SNM-1107 l

)

Enclosure:

As stated cc: Mr. Wilbur Goodwin, Regulatory Affairs )

Westinghouse Electric Comoany )

Commercial Nuclear Fuel Csision  ;

4 Drawer R  ;

Columbia, SC 29250 i

. Requ:ct far Additisn:1 Infarm!.tlan Application Dated March 31,1998 Westinghouse Electric Corporation l

, Docket 70-1151 Please provide the following information: l

1. In the license application, you reference ANSI /ANS-8.1. You should include in the  !

license application the revision number and date of any material or document that CFFF commits to (e.g., Subsection 6.1.3 (c), (g), (1), (k.2-three instances), 6.2.3 (c) and 6.5.1). Otherwise, if the standard or document changes, you would not be in compliance with your license until you changed your systems to correspond to the changes in the standard or document. In addition, when describing specific records requirements in the license application, as in Subsection 6.1.3 (b), refer to the section in the license application that describes the general records requirements.

2. Subsection 6.1.1, clarify that the definition of Double Contingency used by CFFF is different from the National Standard ANSI /ANS-8.1 (1983). Justify changing the Standard words from "As such, process designs.. " to."Where practicable, all process designs..." and " .. margin of safety.. " to " .. factors of safety.. ." Also, in the license application, define the term "significant process" as in "significant process within the system." l

3. In Subsection 6.1.1, correct the reference to the program for routine testing and l maintenance from Subsections 3.2.2 and 3.2.3 to Subsections 3.2.1 and 3.2.2. l t

4. In Subsection 6.1.2, state that assurance of passive engineered controls is maintained I through specific periodic inspections or verification measurement (s) as appropriate.

State that assurance of active engineered controls (AECs)is maintained through '

specific periodic functional testing as appropriate, and that AECs are fail-safe in that the ,

l failure of the control results in a safe condition. State that assurance of administrative controls (ADMCs) is maintained through training, experience, and audit. You should maintain onsite for NRC review a complete list of the types of controls and where the controls are at CFFF that are used as " Passive Engineered," " Active Engineered," and

" Administrative" controls.

5. Subsection 6.1.3 (a), explain CFFF's methodology regarding " Geometry" control,

" Favorable geometry" control, " Safe geometry" control, and " Geometry control systems."

6. In Subsection 6.1.3 (a), incorporate into Subsections 6.1.3 (a.1) and (a.2) the same requirements for analyzing, evaluating, and periodic inspection that Subsection 6.1.3 (a.3) cf.ntains.

7. Subsection 6.1.3 (a.2), justify why and how, " Favorable geometry may also be achieved through other means, including level control." Favorab!e (or safe) geometry is normally a passive control. Trying to achieve favorable geometry through the use of level control is an active control that would have a different set of requirements associated with its functional testing and other uses. Thus, with the proposed subsection, equipment like the moisture drop-out pots can still be characterized as favorable geometry, and would be so for liquids (as long as the level controls worked), but would not necessarily be favorable for solids buildup. Remove from Subsection 6.1.3 (a.2) the use of level controls as " Favorable Geometry if its use cannot be justified."

Enclosure

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l 8. Subsection 6.1.3 (a.3) mentions provisions for periodic inspection, but does not state

.from where these provisions will come, nor does it mention frequency. Better wording can be found in Subsection 6.1.3 (g) which says, "The presence of the absorber...will be verified on a frequency determined in the CSA, CSE, or ISA." incorporate into Subsection 6.1.3 (a.3) the requirement that the CSA, CSE, or ISA shall identify the frequency of the periodic testing for all the kinds of geometry control systems.

9. In Subsecticn 6.1.3 (b), state that the establishment of mass limits includes the given considerations of all fissile material bearing units in the individual room or groups of rooms and include the last sentence from the current license provisior,6.2.4 (b): "When only administrative controls are used for mass controlled systems, double batching is assumed to be the worst credible upset condition." Also, clarify what is meant by "...the definition of subsequent controls."

10. In Subsections 6.1.3 (c.1) and 6.1.3 (e.1), define " independent results of sampling used by CFFF" and explain why this description of independent sampling and independent controls / measurements are included in these subsections, but are not included in an overall discussion of independence used for any of the controls.

11. In Subsection 6.1.3 (c.2), state that moderator controls will be used to prevent uncontrolled moderator from entering the system after each loading (e.g., initial and subsequent) has occurred and state a frequency of testing for leakage of outermost barriers after each installation (e.g., not just initial installation). Also, define what is meant by "promptly self-disclosing."

12. In Subsection 6.1.3 (d), state that when Enrichment control is not utilized, the maximum licensed enrichment is assumed rather than the maximum credible enrichment.

13. Subsection 6.1.3 (e.2), the concentration of what will be prevented by the establishment of controls? State that this prevention will be done after ea:n loading (e.g., not just the initial loading). State that each system will have, in place and operating, controls to detect and/or mitigate the ef' ,s of intemal concentration within the system.

14. Revise Subsection 6.1.3 (f) to include the industry standard terminology for the use of Reflection in ari analysis of the criticality safety of a system (e.g., use of ANSI standards, the use of the term "close-fitting", and definition of the term "near"). Also, define what is meant by " credible praess environment" and clarify that the system analysis will be used in determining whether partial reflection can be used in the system.

15. Revise Subsection 6.1.3 (g) to include in the first bullet a lower limit for the pH in addition to the upper limit. Although this bullet is an exception for neutron absorbers in basic solutions, the term Abasic solutions can have more than one meaning. Thus, to clarify that the exceptions are for non-acidic solutions, a limit for the pH of no less than 7

@ould also be e stablished.

16. In Subsection 6.1.3 (1), state that the effects of heterogeneity will not only be considered, but assessed and documented with the appropriate CSA, CSE, or ISA.

Also, justify the definitions of homogeneity and heterogeneity used that are based on particle size.

17. In Subsection 6.1.3 (j.2), state that the basis for Process Characteristics control will be documented in the appropriate CSA, CSE, or ISA.

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, 3

18. In Subsection 6.1.3 (k.3), reconcile the K , limit shown here with the K , limits in 6.2.3 (a). Modify the license application so that the credible process upset K., limit will ,

be less than 1.00. One alternative is to have the K., limit of 0.95 be applicable in all conditions. Also, reference the other applicable section(s) in the license application when discussing validating Monte Carlo computer codes.

19. In Subsection 6.1.4, state who will perform the comprehensive analysis, how will the analysis be performed, what analysis result allows the use of a container, and who reviews and signs off on the ux of the container. Also, include in this subsection the above information conceming Non-Favorable Geometry (NFG) containers.

20. Section 6.2, justify why only the complexity of the system is used in determining whether l to perform a CSA, CSE, or ISA on a system. Why should not other factors, such as risk l and consequence of accidents, also be used?

21. In Subsection 6.2.1, include a complete listing and description of what sections will be included in a CSA.

22. In Subsection 6.2.1 (a), state that you will consider, assess, and document (1) the ,

reliability of each control, (2) the potential common mode failures of each control, and (3) the margin of safety of each control. l

23. In Subsection 6.2.1(b), restate to clarify the second sentence (e.g., Section 6.0 of the ISA as described in Chapter 4.0 of this License Application includes.. ").

24. In Subsection 6.2.3 (a) through (d), state that validation and verification will occur and be documented, independently reviewed, and signed-off before the (1) use of specific l hardware and software systems using specific cross section libraries, (2) use of analytical codes, (3) use of the methodology, and (4) qualification and re-qualification of the codes.

25. Subsection 6.2.3 (d), confirm that a document exists and will be maintained at CFFF that describes the procedure and results used to select the calculations used to determine code operability.

26. In Subsection 6.2.4, state the qualifications of the independent qualified reviewer (or place these qualifications elsewhere in the licensa application) and state that the independent review will be documented. In addition, the 2nd paragraph states, "The i

technical reviewer will verify." The reviewer can only verify something if it is found to be i

correct. If the reviewer finds a problem with the original analysis and can not verify it, i then he/she violates this license requirement by NOT verifying it. The intent is clear, but this whole subsection needs to be worded such that it does not imply that verification is automatic. Instead of saying that "The technical reviewer will verify," revise to state that, "The technical reviewer will perform a verification process.. " or something similar.

27. In Section 6.3, Table of Plant Systems and Parametric Controls:

! Clarify how CFFF intends to use Table 6.3.

Confirm that the determination of separation distances will be used in all situations which require unit separation distances for criticality safety.

C

. 4 Commit to (1) notifying the NRC within 30 days of changing the table in the case of no decrease in the health and safety of the workers and public and (2) applying for amendment of the license when changing the table in the case of a decrease in the health and safety of the workers or public.

Explain how a system can have double contingency protection using a single parameter.

Quantify the entries for " Optimum H,0 Moderation."

Explain what " Full Concrete Reflection" is and describe which sides have Partial Reflection.

Explain why there appears to be a disconnect between the text using level control as Favorable Gaometry and the table using level centrol as Geometry. Modify in relationship with Question 7.

Quantify the entries for " Full Interstitial Moderation."

Explain what is meant Oy "5 wt. % U" as an evaluation bounding assumption in the table.

On page 6.16, the evaluation bounding assumptions for compaction and granulation both assume homogeneous UO2 . However, according to the new definitions for homogeneous and heterogeneous systems (Subsection 6.1.3 (1)), the compacts made and then broken up in these two steps seem to fall under the heterogeneous category.

Thus, the assumption of homogeneity needs to be reconsidered.

Explain the use of two identical processes and equipments with different controlled parameters (e.g., there are two Miscellaneous: Ventilation Systems).

Specifically, explain the reasons for the deletions, changes, and additions in the table.

28. In the License application, define the following terms used in Subsection 6.4.2:

" assessments,"" conduct of operations," and " triennially."

29. Subsection 6.4.2, confirm that a complete list of nuclear criticality safety processes used at CFFF is available onsite for NRC review.

30. In Subsection 6.4.2, state the agreed upon end date for when the development of the ISAs and upgrading of the CSAs and CSEs will be complete.

31. Subsection 6.4.2, explain the process of controlling the lower level documents listed so that they do not conflict with the CSA, CSE, or ISA at a later date.

32. In Subiection 6.5.1, provide a description of how CFFF achieves compliance with the ANSI standard and NRC Regulations when they are not the same.

33. Explain why Revision 10 has the current license provision of Subsection 6.1.1 (c) as Subsection 6.4.1 with "or" changed to "and" in the first sentence.

34. Justify why you removed the current license provisions of Subsections 6.1.1 (a),

6.1.1 (b), 6.1.2, 6.1.3, the latter parts of 6.2.1 (e.g., verification, maintenance, and functional testing of controls), and 6.3.3. If Revision 10 is approved, where would this information be in the license Application?