ML20198R079
| ML20198R079 | |
| Person / Time | |
|---|---|
| Site: | 07000036 |
| Issue date: | 11/03/1997 |
| From: | Soong S NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Sharkey R ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY |
| References | |
| TAC-L30975, NUDOCS 9711130150 | |
| Download: ML20198R079 (6) | |
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_ Mr. Robert W. Shrrk;y, Manag:r Regulatory Compliance Combustion Engineering, Inc.
3.300 State Road P Hematite, MO 63047
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION, CHAPTER 4 CRITICALITY SAFETY (TAC NO. L30975)
Dear Mr. Sharkey:
This refers to your application dated April 17,1997, requesting the revision of Chapter 4,
- Nuclear Criticality Safety," of License SNM-33. Our review of the rev sion has identified i
additional information that is needed before final action can be taken on your amendment request. This information consists of both technical and clar'.fication/ consistency questions and is described in the enclosure to this letter.
The additional information should be provided in the form of responses to the individual comments within 30 days of the date of this letter. Please reference the above TAC number in future correspondence related to this request.
If you have any questions, please call me at 301-415 8155 or Harry Felsher at 301-415-5521.
Sincerely, Sean Soong Licensing Section 2 Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS Docket 70-36 License SNM 33
Enclosure:
Request for AdditionalInformation pistribution: w/ encl. (Control No. 650S) [PARTIAll Docket 70-36 PUBLIC NRC File Center FCSS R/F Region lil FCLB R/F PHiland, Rlli NMSS R/F
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Docket 70 36 Technical Questions:
1.
In Chapter 4, provide a list of all criticality safety controls used at the site and their definitions (e.g., f avorable geometry (which should always be used in conjunction with another control), geometry control, volume control, fixed neutron absorber, neutron absorbing additives, concentration control of uranium, concentration control of moderators, mass control of uraniun, mass control of moderators, process parameter control, control of array size, control of spacing from other fissile units, neutron interaction, reflectk.., etc.i.
2.
Define and explain the following types of conditions during processing operations: operating, normal, credible abnormal, accident, normal operat:n0, and credible abnormal operating.
3.
Three times you mention that the "... highest effective multiplication f actor for normal or credible abnormal operating conditions shall be less than or equal to 0.05 including applicable biases and calculational uncertainties."
(a)
Explain why this is repeated in different places.
(b)
What is the justification for both the normal and credible abnormal condition limits to be the same?
(c)
Why is there no multiplication f actor limit for accident conditions?
(d)
What is the multiplication f actor limit for accident conditions?
(e)
How were the limits for normal, credible abnormal, and accident conditions determined?
4.
In Section 4.1.1 (b),
(a)
The purpose of controls is to conduct safe operations. Change " achieve process throughput" to " achieve safe operations."
(b)
All three methods of communication (postings, operating procedi.res, and training) should be used to communicate information to workers.
Change " procedures, or training" to " procedures, and training."
5.
In Section 4.1.1 (c)
Credible abnormal conditions are likely to be encountered in a process. Thus, add
" credible abnormal" conditions to the list of conditions under which the entire process will be subcritical.
ENCLOSURE
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6.
In Section 4.1.3, Criticality safety evaluations should include all the relevant conditions in a process.
Thus, add " normal and abnormal conditions" to the scenarios considered in the evaluation of nuclear criticality safety.
7.
In Section 4.1.6, (a)
Explain why you removed the restriction against intermixing empty and loaded containers.
(b)
Explain why empty containers should be allowed to be unsigned in non
" empty container" areas.
(c)
Explain why unsigned empty containers should be allowed to be uncovered.
8.
Section 4.1.7 does not include the dnscription of how "Preoperational Testing" will be performed. Modify the section to include it.
9.
In Section 4.2.1.2,
.(a)
Provide a list and description of all multiparameter controls that are used at the site.
(b)
Explain ivhat is meant by "or defined configurations of individual SNM units in a given process layout."
(c)
Confirm that the term " nuclear safety analysis" includes both " criticality safety" and " radiation protection".
(d)
Define and explain the term " safe unit."
10.
In Section 4.2.1.3 (e),
Justify why you removed the statement identifying that a program to periodically verify the presence of the parasitic isotopes would be maintained or reinstate this statement.
11.
In Section 4.2.1.3 (f),
(a)
Explain how maintaining the structural integrity of the structure is included in the criticality safety evaluation.
(b)
How will the confirmation of the structural integrity be performed over time?
12.
In Section 4.2.1.3 (1),
Explain which " geometry" control for criticality safety is being used.
s 3
13.
In Section 4.2.1.3 (m),
Explain how "less than full neutron reflection" could be considered a control for criticality saiety.
14.
In Section 4.2.2.1 (g),
Revise to include that the criticality safety evaluation should show that the transit is safe before the transit is begun.
15.
In Section 4.2.2.1 (i),
Explain the sources and validation for the numerical values in this subpart.
16.
In Section 4.2.2.1 (j),
Define and explain the phrase " include the double batch allowance."
17.
In Section 4.2.2.1 (k),
Justify why you removed the restriction on the use of 927 containers in the Transportation Index of 100 or reinstatement this statement.
18.
In Section 4.2.4 (b),
Change "can be continued" to "may be continued."
19.
In Section 4.2.4 (j),
Define " fraction" in the phrase " fraction of the calculated critical mass." Provide the basis for this value.
20.
In Section 4.2.4 (o),
Confirm that a specific criticality safety evaluation is more limiting than the criticality safety evaluation performed for Table 41, Part A.
21.
In Section 4.2.4 (u),
Confirm that the respective barrier completely surrounds each Receiver.
22.
In Section 4.2.4 (v),
(a)
Confirm that the system involved is the " reactor gas filtration" system.
(b)
Confirm that the barrier completely surrounds the system.
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4 23.
In Table 4-4, (a).
Please explain why all processes do not have two criticality safety controls in order to meet the double contingency principle. Provide the names of the two controls for each process.
(b)
Explain which " geometry" control for criticality safety is being used.
Clarification / Consistency Questions:
- 24. - The " Table of Contents" for License SNM 33 should reflect the changes made in Chapter 4.
25.
" Enclosure 1 to RA565" dated April 17,1997, should reflect the correct the information in the " Delete Page" Section.
26.
In Table 41, Part B, Confirm that Note 3 should be changed to refer to a definition in part (i) in Section 4.2.2.1.
27.
It appears that the order and content of the sections in Chapter 4 should be reorganized (e.g., Section 4.2.1.3 includes items in no apparent order; Section 4.2.2.1 includes items that are unrelated to spacing; and Section 4.2.2 includes general and specific items intermixed in no apparent order).
28.
It appears that introductory paragraphs to describe the purpose of new sections are missing from certain sections (e.g., Section 4.2.1,4.2.3, 4.2.3.1, 4.2.3.2, and 4.2.4).
29.
Be consistent in your reference to other sections of the license (i.e., Chapter 2, Section 2.1 or Chapter 4. Section 4.2.3.2).
30.
Be consistent in your use of position titles in the license. Tdny should be capitalized (e.g., " Nuclear Criticality Specialist" and " Health Physics Technicians").
31.
In Section 4.1.1 (c), you should change " technical criteria" to " criteria."
32.
In Section 4.1.7, you should remove the reference to Chapter 2, Section 2.7 because it does not contain a description of "Preoperational Testing".
- 33. -
In Section 4.1.8, you should change " Internal" to "?!ritten."
34.
In Section 4.2.1.1, you should change "When based on experimental data," to "For SIUs based on experimental data,."
f
-S 3 5. --
In Section 4.2.1.3 (I and m), you should change " evaluation" to " criticality -
- safety evaluation."
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In Section 4.2.2.1 (c) (second sentence), you should change " maximum mist t
36..
density" to:" credible maximum mist density."
37.
In Section 4.2.2;1 (d), you should add at the end of the sentence, "etc."
38.
In Section 4.2.4 (j), you should change'" unsafe vessels" to " unfavorable
-vessels."
39.
Modify Section 4.2.5, Table 4-4, and Table 4 5, so that it is c!-r that the tables do not contain all of the' major processes.
' 40.
Provide a title for Table 41.
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