ML20195F809

Application for Amend to License SNM-1227,allowing Licensee to Process Uranium for DOE Project,Which Contains Up to 50 Bq/Gu of Alpha Activity from Pu & Neptunium (Transuranics)

ML20195F809
Person / Time
Site:	Framatome ANP Richland
Issue date:	11/13/1998
From:	Edgar J SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER
To:	Lain P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
JBE:98:099, JBE:98:99, NUDOCS 9811200091
Download: ML20195F809 (8)

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Lr EgIEMENS l

November.13,1998 JBE:98:099 '

U.S. Nuclear Regulatory Commission Attn: Paul W. Lain

Licensing Branch (T8D14)

Division of Fuel Cycle Safety & Safeguards, NMSS One White Flint North 11555 Rockville Pike Rockville, MD 20852

Subject:

- Request to Amend Limit for Transuranic-related Activity in Foodstock: SNM 1227, Docket 70-1257'

. Siemens Power Corporation (SPC) has entered into a contract to produce low enriched UO fuel 2

.pel!ets and possibly fuel rods from uranium that has been down-blended from Department of

. Energy high enriched, reprocessed uranium. The work is in support of a lead test assembly program for the Tennessee Valley Authority (TVA).

Two issues require resolution with regard to the processing of this material:

1) The plutonium and neptunium (Pu/Np) alpha activity of the uranium feedstock SPC will

- receive for processing exceeds the 3.3 Bq/gmU limit specified in SPC's NRC license; and

2);it must be confirmed that the Pu content and the fission product activity of the uranium feedstock are not greater than the 10 CFR 50.2 " Production Facility" criteria of 1 ug/gm23sU l and 0.25 mci /g2asU, respectively.

With' regard to the first issue, above, Attachment I demonstrates that the contribution to the Eannual dose of an individual working full time with Class Y material would be minimally

increased by the additional presence of Pu/Np at 50 Bq/gU. SPC, therefore, requests an

. amendment to its license to allow it to process uranium for this project which contains up to 50 Bq/gU of alpha activity from plutonium and neptunium ("transuranics").

With regard to the second issue, Attachment 2 demonstrates that, if the transuranic limit is q

increased to 50 Bq/gU, the 1 pg PulgassU is not exceeded as long as the enrichment is at least

'2.18% In' fact, the enrichment is approximately 4.35% With respect to fission product-activity, analyses of representative samples of the three lots of material to be used in producing L

Lthe pellets show a maximum of <7x10~5. mci of fission product activity per g23sU.

ADOCK 070012577["

9811200091 981113 L

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- Siemens Power Corporation Nuclear Division -

2101 Horn Rapids Road Tel:

(509) 375-8100

' Engineering & Manufacturing'

. Richland, WA 99352-0130 P.o. Box 130.

Fax:

(509) 375-8402 s

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Mr. Paul W. Lein JBE:98:099 November 13,1998 Page 2 The processes SPC will employ to produce UO pellets, and possibly fuel rods, from this 2

material will not result in concentrating either Pu or fission products.

Process Descriotion SPC expects to receive approximately 2250 kg U 0 enriched at approximately 4.35%

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from which it will produce pellets and possibly fuel rods. The process will include dissolving the materialir nitric acid to produce uranyl nitrate (UNH); processing the UNH through SPC's existing Line 2 ADU (ammonium diuranate) process in the UO Building to 2

produce UO powder; pressing the powder into UO pellets; and possibly loading the 2

2 pellets into fuel rods. The processes are further described in Chapter 15 of SPC's license application in sections 15.1.6.5 (Line 2 ADU Piocess),15.1.7.2 (Line 2 Powder Production System),15.1.8.2 (Line 2 and 3 Powder Preparation); 15.1.9 (Pelletizing);

and 15.1.10 (Rod Fabrication).

UNH is added to the ADU process at the precipitation tank where ammonium hydroxide is added to cause the uraniurn to precipitate as ammonium diuranate. The ADU is centrifuged and dried and then ca!cined to produce UO powder. The UO pouvder then 2

2 goes through various oreparation processes (e.g., blending, milling, compacting and granulating) to prepare it to be pressed into UO pellets. Processing of the pellets 2

through a sintering furnace produces ceramic-grade pellets which are then packaged and shipped to the fuel fabricator where they are loaded into rods which are assembled into fuel assemblies. If SPC fabricates rods, they will be loaded and examined as described in SPC's license application section 15.1.10 and shipped to the fuel fabricator where they will be assembled into fuel assemblies.

Safety This material will be handled under SPC's radiation protection, criticality safety, and environmerital protection programs described in chapters 3,4, and 5, respectively, in its license application. With regard to radiation protection, the impact on dose will be quite small because the processing time for this materialis expected to be less than one week for pellets or two weeks if rods are f abricated.

Enclosed are six copies of revised license pages 1-3 through 1-6. In order that we can receive the down-blended UaO. by mid-January 1999, we need to receive the amendment by January 1, 1999. We appreciate your willingnen to review this request on an expedited basis. If you neei additional information, please call me at 509-375-8663.

Very truly yours, l

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J. B. Edgar, Staff Engineer Licensing i

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1 Potential Health Consequences of 50 BolgU Limit l

Assumptions:

- 50 Ja (Po/Np)/gu limit = 1.35x10' Ci/gU

- Airbo:ne U activity concentration = 2x10-" pCi/ml (this is DAC for class Y uranium compounds) -

- Specific activity for U = 6 Ci/g i

As seen below, if the airborne uranium activity is at DAC, the concentration of uranium j

mass would be 3.3x10"2 gU/ml.

1 2x10~" CiU IgU 33x10- gU -

x

=

ml 6pCiU ml If the airborne activity is at DAC, then would be an airbome concentration of U of this amount.

From this the concentration of transuranics can be calculated.

5,3x10~" gU 135xl0~'pCi(PuI Np)

J x

1 mi gU i

4.5x10*"pCl(PuI Np) ml If the airborne activity is at DAC for U, there would be 4.5x10 Ci (Pu/Np)/mi of Pu/Np airborne concentration.

Conservatively, assume all the transuranics are 227Np. The occupational DAC for Np =

237 j

2x104 Ci/ml

. 4.5x10-" Ci / ml J

Therefore,

= 0.00225or 0.225%

1 r

2x10"* pCiIml

. The' calculations above demonstrate that if the airborne contamination is at DAC for uranium, the dose contributed by the increased limit on transuranics (Pu and Np) of 50 Bq/gU would be less than 0.23% of that from the uranium. This dose relationship holds j

true regardless of the percent of DAC represented by airborne uranium. Hence, increasing -

the transuranic (Pu/Np) limit to 50 Bq/gU results in a very minor increase in dose.

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50 Bq/gU Limit Compared to 1 pg PulgassU Limit I

Assumptions:

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-. U enrichment = 4.35 wt% asU 2

- Pu t

>- -F

'a it = 1 r Pulg2asy A..

aese"v:s 23sPu 2

23 23 l gPu 4.35g ' 6.13x10"Ci 'Pu 3.7x10' Bq2 99Bq

. g "U

• 100gU

• pgPu

. Ci* Pu gU The calculation above demonstrates that for the limit of 1 pg Pu/grasU to be exceeded with 4.35% enriched maximum, at least 99 Bq (Pu/Np)/gU is required. At 50 Bq (Pu/Np)/gU, conservatively assuming all the transuranics (Pu/Np) are 23sPu, the limit of 1 gPu/g u 23s would not be exceeded as long as the enrichment of uranium is at least 2.18 w/o 23s U.

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SiemenS Power Corporation.- Nuclear Division eup.2 SPE,CIAL NUCLEAR MATERIAL LICENSE NO. SNM-1227, NRC DOCKET NO. 701257 PART I-LICENSE CONDITIONS asy.

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1.6.2 ' Plutonium Possession and Storaae

! Trace-quantities of plutonium may enter the plant ar contamination in uranium 4

. !..feedstock (UF., scrap pellets / powder, etc.) that contains reprocessed uranium in any j

j amount.

In addition, SPC currently stores a small amount of plutonium as a l j

contaminant in drummed solid waste generated during the past decommissioning of i i

an onsite mixed oxide facility.

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i 1.6.2.1 Plutonium Contaminated Feedstock l

1 SPC may receive, process, store, and ship reprocessed uranium containing plutonium l and other transuranic isotopes.

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1.

a.

The concentration of transuranic isotopes in such uranium shall be I

limited to that specified in ASTM specification C996-90 for

" Enriched Reprocessed UF ": i.e., the alpha activity for plutonium and neptunium (transuranics) shall be less than 3.3 Bq/gU.

b.

The alpha activity of plutonium and r.eptunium in the uranium for the TVA lead assemblies described in SPC's amendment application i dated November 13,1998 shall be no greater than 50 Bq/gU.

2.

SPC shall,- when it expects to receive such uranium, obtain from the !

I shipper cer+.ification that the uranium is within the limits for transuranics as specified in either 1.a or 1.b, as applicable.

1.6.2.2 Plutonium Contaminated Waste Storaae-SPC is presently in possession of plutonium as PuO and PuO -UO left over from past 4

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decommissioning of an onsite mixed oxide facility. This material is in the form of 2

contaminated solid waste stored in drums.

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These containers shall be stored'in the SF Building, Room 162 autoclave pit in accordance with the following controls:

1.

These stored containers shall be sealed with gaskets.

2.

The SF Building storage pit shall be exhausted by the building HVAC system. Two stages of HEPA filtration shall be provided prior to exiting the exhaust stack.

3.

.The air exiting the SF Building storage pit shall be continuously monitored and sampled, and the samples analyzed weekly for

- radioactive material content.

Assurance of containment shall be-verified at least once every six months by visual inspection and smear survey of the stored waste drums. The inspection and surveys shall be documented. All indications of drum leakage shall be investigated and appropriate action taken.

_ auecutNr AMCATON DATE.

PAGE No; November 13,1998 1

1-3 SPC No 3330 947 tR 007 921

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- SiemenS Power Corporation - Nuclear Division EM F-2 SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM-1227, NRC DOCKET NO. 70-1257 PART I-LICENSE CONDITIONS nev.

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In order to provide continued containment, SPC may find it necessary to repackage the containers. These activities shall be performed using a special Radiation Work Procedure (RWP).

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5.

All alpha contamination discovered by smear surveys or air sampling !

i within the pit area shall be considered as plutonium alpha unless proven j otherwise.

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1.6.3 Labelina Exemption i

I Pursuant to 10 CFR 20.1904(a) requirements,' a sign bearing the legend, "Every container or vessel in this area, unless otherwise identified, may contain radioactive ;

material," may be posted at entrances to each bui', ding in which radioactive materials

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are used, stored or handled, in lieu of the requirement to have s " Caution, Radioactive !

l Material" or "Dmiger, Radioactive Material" label affixed to each container of licensed material.

1 1.6.4 Waste Disposal Pursuant to 10 CFR 20.2002, disposal of solid waste material containing 30 pCi/ gram 1

or less to other than a licensed waste disposal facility is authorized. The low enriched I

uranium shall not exceed 30 pCi/ gram of dry solid waste material, The uranium shall l be essentially uniformly distributed throughout the waste material.

l 1.6.5 Special Nuclear Material Safeauards I

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' Specific safeguards requirements for special nuclear material are given in Safegua dc Amendment SG-2 issued pursuant to 10 CFR Parts 70, 73, 74 and 75. These conditions are not affected by this licensing action.

1.6.5.1 Physical Security SPC shall follow the special safeguards conditions given in the Safeguards Amendment SG-2 and the NRC-approved security plan submitted in accordance with the provisions of 10 CFR Part 73.67(c)(1). The NRC-approved security plan is:

ANF-538(P), " Physical Protection Plan for Material of Low Strategic Significance." This document shall be maintained in a current and approved status and shall be properly implemented.

1.6.E.2 Material Control and Accountine SPC shall follow the special safeguards conditions given in the Safeguards Amendment SG-2 and the NRC approved Fundamental Nuclear Material Control Plan (FNMC) submitted in accordance with 10 CFR Part 74.31(b). The NRC approved FNMC Plan is:

AuCNDMENr APPUCATON DATE; j PAGE NO.;

November 13.1998 1-4 SPC-No 3330 947 A 007%

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3 i.e SiemenS Power Corporation - Nuclear Division eup.2 SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM-1227, NRC DOCKET NO. 70-1257 PART I-LICENSE CONDITIONS lREV.

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l EMF-12(P), " Nuclear Material Safeguards Procedures Description for the Fuels i

Fabrication Plants."

This document shall be maintained in a current and approved status and shall be properly implemented.

.1.6.6 Authorization at Reactor Sites SPC is authorized to possess fuel assemblies or fuel rods at reactor sites for the purpose of loading them into shipping containers and delivering them to a carrier for transport.

1.6.7 Authorized Release Guidelines SPC is authorized to release equipment, scrap or facilities for unrestricted use, or for termination of license according to the " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material" as published by the U.S. Nuclear Regulatory Commission dated April 1993.

1.6.8 Authorized Criticality Alarm System Outaae SPC is granted an. exemption from 10 CFR 70.24(a) for the purpose of performing maintenance on the criticality alarm system. Sections of the criticality alarm system may be taken out-of-service provided that all movement or processing of fissile ',

material in affected areas is halted for the duration of the outage. Health and Safety

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hnicians shall conduct continuous surveys of the areas during the criticality alarm sys. tem outage.

1.6.9 Notification Notifications to the NRC shall be made as required by regulations with the exception of 10 CFR 20.2202(a)(2) and (b)(2) as they apply to restricted areas. Reports to the i

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NRC shall be made as required by regulations with the exception of those paragraphs

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in 10 CFR 20.2203 which refer to 10 CFR 20.2202(a)(2 and (b)(2) as they apply to restricted areas.

1.6.10 Authorized Workplace Air Samplina Adiustments 1 SPC is authorized to adjust Derived Air Concentration (DAC) limits and Annual Limit i

of Intake (All) values in process areas to reflect actual physical characteristics of the airborne uranium.

-1.6.11 Authorized hetease Guidelines for Hydrofluoric Acid SPC is authorized to release hydrofluoric acid manufactured by the dry conversion process for unrestricted commercial use providing the following conditions are met:

1.

'A representative sample of each batch of hydrofluoric acid product shall be obtained and analyzed for uranium;

{ PAGE NO.

AMENDMENT APPLCATION DATE.

November 13,1998 1-5 SNo 3330 947 R- 007.E i

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'Siemens Power Corporation Nuclear Division sw.2 SPECIAL NUCLEAR MATERIAL LICENSE NO, SNM 1227, NRC DOCKET NO,70-1257

- PART I - LICENSE CONDITIONS gev.

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A batch shall be no larger than 46,000 liters;

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The specific activity of any batch released for unrestricted use shall be s 3 pCi/ml.

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.- AMENDuENT APPUCATON DATE.

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November 13,1998 1-6 SPC-f10 3330 947 (R 147 92)

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