ML20199B688
| ML20199B688 | |
| Person / Time | |
|---|---|
| Issue date: | 01/11/1999 |
| From: | Ten Eyck E NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Parks C AMERICAN NUCLEAR SOCIETY |
| References | |
| NUDOCS 9901140045 | |
| Download: ML20199B688 (4) | |
Text
d Dr. Cecil Pzrks, Chrir January 11, 1999
. Nucirr Criticality Sif:ty Division ;
l American Nuclear Society Post Office Box 2008 l Building 6011, Mail Stop 6730 l Oak Ridge, Tennessee 37831-6730 1
Dear Dr. Parks:
SUBJECT:
DRAFT PROPOSED 10 CFR PART 70 AND ASSOCIATED STANDARD l REVIEW PLAN Thank you for providing comments on the U.S. Nuclear Regulatory Commission (NRC) staff's draft revisions to 10 CFR Part 70 and the associated standard review plan (SRP). Since '
issuance of the draft revisions, the Commission has directed the NRC staff to discuss all relevant documents with stakeholders and to submit a revised proposed rulemaking package in May 1999. (Once the Commission approves a rule for publication as a proposed rule, the stakeholders and public will again have an opportunity for formal comment.) Since September 1998, we have held two public meetings and have established a Part 70 website.
The website contains a library of documents related to the rulemaking and allows comments to be submitted online (http://techconf.llnl.aov/cai-bin /messaaes? dom lic). Your December 1, 1998 letter has been posted on the website.
NRC will be holding a public meeting on January 13 - 14,1999, that specifically deals with the nuclear criticality safety aspects of the draft rule and SRP, including the issues raised in your letter. We have already begun the process of revising the rule language and have posted some of the revised sections on the website. NRC plans to post updated revisions of the l proposed rate and the SRP for nuclear criticality safety on the website. To facilitate completion of the proposed rulemaking package by May 1999, we intend to resolve the specific issues, including those raised in your letter, as part of the overall, interactive effort. I hope you are able to attend the January public meeting and would greatly appreciate your views on the material posted on the website.
Should you have any questions, please contact Mr. Andrew Persinko on (301) 415-6522.
Sincerely, M
Elizabeth Q. Ten Eyck, Director Division of Fuel O de Safety \\
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i DISTRIBUTION: (FCSS-1998-065)
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- !i 4 NUCLEAR REGULATORY COMMISSION-E WASHINGTON, D.C. 205eH001 Q..o. f Jancary 11, 1999 Dr. Cecil Parks, Chair 1
. Nuclear Criticality Safety Divisiom ;
1 American Nuclear Society Post Office Box 2008
- Building 6011, Mail Stop 6730 Oak Ridge, Tennessee 37831-6730 v
Dear Dr. Parks:
SUBJECT:
DRAFT PROPOSED 10 CFR PART 70 AND ASSOCIATED STANDARD ,
REVIEW PLAN j Thank you for providing comments on the U.S. Nuclear Regulatory Commission (NRC) staff's draft revisions to 10 CFR Part 70 and the associated standard review plan (SRP). Since ,
1 issuance of the draft revisions, the Commission has directed the NRC staff to discuss all l' relevant documents with stakeholders and to submit a revised proposed rulemaking package in May'1999. '(Once the Commission approves a rule for publication as a proposed rule, the i' stakeholders and pubiic will again have an opportunity for formal comment.) Since September 1998, we have held two public meetings and have established a Part 70website. The website contains' a library of documents related to the rulemaking and allows comments tu be Lsubmitted online (http://techeonf.lini.aov/coi-bin /messaaes? dom lick Your December 1,1998
- leiter has been posted on the website.
NRC will be holding a public meeting on ' January 13 - 14,1999, that specifically deals with the .
nuclear enticality safety aspects of the draft rule and SRP,' including the issues raised in your letter. We have already begun the process of revising the rule language and have posted some of the revised sections on the website. NRC plans to post updated revir!:ns of the proposed rule and the SRP;for nuclear criticality safety on the website. To facNhte completion of the proposed rulemaking package by May 1999, we intend to resolve the specific issues, including those raised in your letter, as part of the overall, interactive effort. I hope you are able to attend the January public meeting and would greatly appreciate your views on the material posted on the website.
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I Should you have any questions, please contact Mr. Andrew Persinko on (301) 41S6522.
Sincerely,
~
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M' Eliz th Q. T yck, Directo Division of Fue Cycle Safety j and Safeguards E .j Office of Nudsar Material Safety t and Safeguards ' l
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TICKET NUMBER: FCSS-1998-065 1
4 ACTION: FRIB DUE DATE: 1/08/99
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SUBJECT:
DRAFT PROPOSED 10 CFR 70 AND l ASSOCIATED STANDARD REVIEW PLAN Prepare short acknowledgement letter for EQT signature.
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CORRESPONDENCE CONTROL TIb1(" j PAPER NUMBER: CRC-98-1111' LOGGING DATE: Dec 7 98 I
- ACTION OFFICE: EDO c-q5:
' AUTHOR:- DR. CECIL PARKS % lk l AFFIL3ATION:. COLORADO ADDRESSEE: CARL PAPERIELLO, NMSS LETTER DATE: Dec 1 98 FILE CODE: ID&R 14 PT. 70 ;
SUBJECT:
DRAFT PROPOSED 10 CFR.70 AND ASSOCIATED STANDARD- i REVIEW PLAN l ACTION: Appropriate i
DISTRIBUTION: CHAIRMAN, COMRS, SECY/ RAS, OGC
-SPECIAL'. HANDLING: NONE',; -
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C. 1 AMERICAN NUCLEAR SOCIETY l l
i NUCLEAR CRITICALITY SAFETY DIVISION i
1 December 1,1998 Dr. Carl A. Paperiello, Director Office of Nuchar Material Safety and Safeguards )
U.S. Nuclear Regulatory Commission l
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Dear Dr. Paperiello:
Subject:
Draft Proposed 10 CFR 70 and Associated Standard Review Plan As the current Chair of the Nuclear Criticality Safety Division (NCSD) of the American Nuclear Society (ANS), I am wnting to provide comments that will hopefully benefit the NRC as they proceed in their considerations related to the subject material.
The NCSD is composed of approximately 575 criticality safety professionals who are dedicated to the understanding of the physics of nuclear criticality and the associated practices for safe operation during the handling of fissile material.
The members of NCSD span the full realm of job categories: research and development, commercial and government operations, regulatory development and oversight, educators, and consultants. As one of its major activities, the NCSD supports the development of consensus technical safety standard; through its sponsorship of Subcommittee ANS-8, Fissionable Materials Outside Reactors, of the Standards Committee of the ANS. With minor exception, the NRC has endorsed all 15 of the ANS 8 standards in Regulatory Guide 3.71.
During the recent ANS Winter Meeting, the Chair for our Government / industrial Relations Committee provided our Executive Committee with a copy of the draft proposed 10 CFR Part 70 and draft Standa d Review Plan (SRP) At my request several senior technical members of NCSD have reviewed the draft to assess its consistency with the promulgation of safe practices endorsed by NCSD. In general, the review provided support for the objective of the proposed rule. However, NCSD is concerned with some underlying issues in the rule, particularly as these issues are expressed in the associated SRP. Our concerns and comments are expressed below.
- Proposed 10 CFR 70.60(b) defines a nuclear enticality as a "high consequence" event. We note that most criticality accidents in the U.S. and elsewhere have not exposed personnel to greater than 100 rem (the other *high consequersce* cnteria). Criticality accidents in fuel processing plants in the United States have resulted in two deaths (one at an NRC licensee site and one at a DOE contractor site). Experience, while limited, indicates that lethal consequences occur only when the nuclear worker is vcithin a few meters of the critical excursion and with little intervening shielding. The category of "high consequence" for a criticality accident should be consistent with the other events in this category and be limited to those accidents for which an expr e of over 100 rem is likely. An objecNve assessment of nuclear criticality accident history indicetes that continued attention to enticai. . afety is necessary, but that nuclear criticality safety differs in no intrinsic way from industrial safety.
e The direction and bases provided in the SRP Section 5.4.5.2 for establishing nuclear enticality safety limits for controlled parameters and their respective controls is overly prescriptive, onerous, and confusing. Even using a simple example, no common interpretation of the terminology and direction provided within Subpart 5 b of Section 5.4.5.2 could be found among the enticality specialists that I queried. But, of primary concern is the fact that the section is inconsistent with concepts of assuring equivalent safety and risk control regardless of the basis (expenmental cntical data or validated analytical methods) for a subentical limit. As properly validated and applied, the subcrit: cal value of k,,,(kw,'should have no less certainty for defining a suberitical condition than an actual enticai experiment. This is to say, that the selection of operational controls should beindependent of the methods (i e , experimental data versus validated analytical methods) used to estabush parameter limit Thus, we conclude that the Controlled Parameters and Controls methodologies in Subpart 5.b are inappropnate
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I determine if the double contingency principle is affirmed. Although PRA can be profitably used in some applications, it is substantial overkillin most instances and frequently goes far beyond that required or intended in ANSilANS-8.1, Nuclear Criticality Safetyin Operations with Fissionable l Materials Outside Reactors. In fact, if this becomes a requirement, we are concerned that more l offort will be expended in calculating the probabilities than in demonstrating that the entire l process is in fact subentical as requ; red by Section 4.1.2 of ANSI /ANS-8.1. Data bases simply do not exist to support PRA for equipment failures in fuel cycle facihties and we feel that this i course of action could divert attention from operational safety. The statement of considerations l notes the industry's objection to PRA as a requirement, but this objection is ignored in the SRP.
1 e in principle, we support the integrated safety assessment (ISA) process proposed by the 10 CFR l Part 70 rule change. However, we feel that the ISA methodology and reporting requirements must not be made so complex that safety engineers of al. disciplines do not have time to spend observing operations and talking to operators. The reporting requirements appear to be quite burdensome. For example, DOE requires contractors to have enticality safety evaluations for all operations, but reporting is not required if the operations remain within the operating bases authorization. The NRC should consider this model.
The opinions expressed in this letter are tnose formulated by several senior professionals representing a cross cut of experience and responsibilities related to enticality safety. Due to the short time that NCSD has had to review the subject material, our review has been limited. However, we have sought to identify concerns that we feel are detrimental to established safe practice for fiss"e material operations at nuclear facilities We are hopeful that your staff will be able to consider our comments and concerns as they continue to review and modify the material. To the degree possible, NCSD would like to support the resolution of these issues. I can be reached at 423-574-5280.
Sincerely,
-i 4
, [. -
Dr. Cecil Parks, Chair Nuclear Criticality Safety Division American Nuclear Society Post Office Box 2008 Building 6011, Mail Stop 6370
! Oak Ridge, Tennessee 37831-6370 I cc: The Honorable Shirley A. Jackson, Chairman, NRC l
The Honorable Greta J. Dieus, Commissioner, NRC f The Honorable Nils J. Diaz, Commissioner, NRC The Honorable Edward McGaffigan. Jr. Commissioner, NRC l
l The Honorable Jeffery S. Memfield, Commissioner, NRC Dr. William D. Travers, Executive Director for Operations. NRC l
,