ML20202D942
| ML20202D942 | |
| Person / Time | |
|---|---|
| Issue date: | 04/03/1986 |
| From: | Parr O Office of Nuclear Reactor Regulation |
| To: | Shingleton R NUCLEAR PACKAGING, INC. |
| References | |
| NUDOCS 8604110629 | |
| Download: ML20202D942 (8) | |
Text
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April 3,1986 Mr. Roger L. Shingleton, Vice President Nuclear Packaging, Inc.
1010 South 336th Street Federal Way, Washington 98003
Dear Mr. Shingleton:
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION ON TP-03, REVISION 0 We are currently reviewing the Nuclear Packaging, Inc. Topical Report TP-03, Revision 0 dated February 25, 1985 covering Nuclear Packaging's Oil Solidifi-cation System. Our initial review reveals the need for the additional infor-mation indicated in the Enclosure.
In order to complete our review within the currently scheduled time, responses to these questions should be received by the NRC by May 1, 1986.
Please advise Charles Nichols at 301-492-7694 f f you cannot meet this date..
l The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511.
Sincerely, Orfsinal signed y otaa Nr.
Olan D. Parr, Chief Plant, Electrical, Instrumentation and Control Systems Branch Division of PWR Licensing-B
Enclosure:
As Stated Distribution Central Fil NRC PDR PEICSB Rdg. File F. Miraglia T..Speis G. Lainas C. E. Rossi
.H. Berkow D. Crutchfield R. Emch J. Wermiel J. Minns b.
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- LICENSING REVIEW QUESTIONS ON NUCLEAR PACKAGING, INC. TOPICAL REPORT TP-03, REVISION 0, DIL SOLIDIFICATION SYSTEM Provide a revised version (Revision 1) of the subject topical report which includes all the desired changes identified with vertical lines in the margin. Revision 1 should incorporate all of the responses to 4
the following review questions on the Revision 0 report:
1.
Th'e following standards potentially apply to the licensing acceptability of this portable solidification system.
Identify, where appropriate, how j
.the portable solidification system meets these standards, or explain why i
the standards do not apply:
NbREG-08'00,StandardReviewPlan,Section.11.4,SolidWasteManagement
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a.
Systems, including Branch Technical Position ETSB'11-3, Design Guidance i-for Solid Radioactive Waste Management Systems.
- b.
NUREG-0800, Standard Review Plan, Section 11.5, Process and Effluent i
l Radialogical Monitoring Instrumentation and Sampling Sy::tems.
c.
10 CFR 20, Standards for Protection Against Radiation.
t' d.
10 CFR 50, Appendix A, General Design Criteria for Nuclear Power j
. Plants.
e.
10 CFR 61, Section 61.55, Waste Classification.
l f.
10 CFR 61, Section 61.56, Waste Characteristics.
i g.
10 CFR 71, Packaging of Radioactive Material for Transport and Trans-q portation of Radioactive Materials Under Certain Conditions. h.
49 CFR 173, D0T regulations for packaging.
- i. Regulatory Guide 1.140, Design Testing and Maintenance Criteria for Normal Ventilation Exhaust System Air Filtration and Adsorption-Units of Light-Water-Cooled Nuclear Power Plants.
- j. Regulatory Guide 1.143, Design Guidance for Radioactive Waste i
Management Systems, Structures and Components in Light-Water-Cooled Nuclear Power Plants.
k.
Regulatory Guide 8.8, Information Relevant to Ensuring That Occupa-tional Radiation Exposures at Nuclear Power Plants Will Be As Low As Is Reasonably Achievable.
2.
Provide the design volumes, activities, hhysical and chemical characteris-
{
tics of the types of waste oil to be processed.
Provide the range and limitations on the types,-compositions and physical properties of waste oil j
l.
. that can be processed and the bases therefor; the design volume and radio-nuclide contents of solidified wastes based on the types and quantities of the waste oil processed; the capacity or throughout of the system in relation to the expected waste oil solidification requirements of a 1200-MWe PWR and BWR; and the radioactive source terms used in the system design for shielding analyses and calculations of normal effluents and effects of postulated accidents.
3.
Describe the type and size of solid waste containers which can be used and potential means for monitoring for removable contamination and for decontamination.
4.
Provide the quality group classification of piping and equipment and the bases governing the classification; provisions incorporated in the system design to minimize leakage and facilitate operations and maintenance; provisions in the design or which should be made by users for containing and cleanup of overflows and spills of radioactive materials; and the design and initial and periodic testing of interfaces between the system waste return line) in accordance with Regulatory Guide 1.143.
5.
Describe the estimated maximum radiation exposures to operating and maintenance personnel (and the basis for these estimates) and the measures taken in the design and in the operating, testing, and maintenance pro-cedures to keep radiation exposures ALARA, including the uncoupling of the mixing equipment from the solidifying waste and the capping operation.
6.
A description should be provided of the potential radiation hazards and accidents and the procedures that may be used in abnormal situations, e.g. spills of radioactive materials, mixer motor or blade failure during solidification, and failure of a batch to meet solidification criteria.
7.
Provide a detailed drawing of the overall system and a detailed piping and instrumentation diagram.
8.
Describe the system for storage, metering, and transfer of the cement and other additives.
9.
Describe the design, location, testing and maintenance of. Iner level monitors, radiation monitors (in accordance with NUREG-0800, SRP 11.5),
and offgas system filters (in accordance with Regulatory Guide 1.140).
- 10. Describe the information to be used and the criteria to be employed by the operator to determine that a homogeneous mix has been established, that accelerator or retardant should be added, that there is no free-standing liquid, and to select steps (describe steps) to be taken when it cannot be determined that a homogenous mix has been established or that there is no free-standing liquid.
- 11. Describe the means for determining the isotopic composition and total activity of the waste product.
. 12. Describe Pacific Nuclear's conclusions regarding the long-tenn stability attributes (in addition to solidification and absence of free-standing liquid) of the solidified product, including the effects of radiation and decay.
- 13. Describe the means for assuring that the plant's waste oil storage tank has been adequately mixed and that the waste sample is an adequate repre-sentation of the waste; and that the plant's waste oil storage tank is completed isolated after the waste sample has been taken?
14.
In Appendix B, clarify whether the tenn " batch" refers to the contents of the waste batch tank or the waste product container; the size of the
. sample to be taken; that the test solidifications should be repeated until a satisfactory end product is obtained; and the source of the Sample Proportion values to be used in the Sample Verification Worksheet.
- 15. Describe the quality assurance program for the design, construction and testing of the system in accordance with Regulatory Guide 1.143.
- 16. The report should state whether the NuPac 011 Solidification System is intended to be operated as a mobile service by NuPac, or whether it is to be leased or sold to a utility as a more-or-less permanent installa-tion.
17.
In Section 2.0, why are References 2.3, 2.4, 2.6 and 2.7 listed? Where are they used in this topical report? What is the complete title of Reference 2.8, and what organization authored it?
18.
In Section 3-1 on page 3-1, where is the mixer speed control unit located?
In the last paragraph, where is the loading hopper shown in the drawing?
How much does it hold? What sort of mechanism is used to control and measure cement additions? How does the loading hopper " monitor" mixing operations?
- 19. This topical report should include all of the requirements for installing the NuPac System on a cement pad with dikes and drains in order to con-tain any spill or overflow of radioactive liquids.
(See Reg. Guide 1.143.) Are there any requirements for installing the system indoors?
- 20. The following questions and comments pertain to Section 4.0 Equipment Operation:
(a) Presumably, the entire operation is conducted inside a radioactive control zone and the operator is dressed in anti-C clothing. This should be addressed in the report.
(b)
In order for the operator to observe the changes in consistency and coloration descrined.in Section 4.0, he would have to be right next to the waste drum and peering inside. He would seem to be very vulnerable to direct radiation and contamination from the drum con-tents. What is done to keep such exposures ALARA? Are there any radiation monitors mounted nearby? What are the maximum expected levels of radioactivity.
J
- 4 (c)
In the last two paragraphs on page 4-1, a description is given of the appearance of the " emulsion."
If the mixing head is sealed to the drum (as described in Section 3.0), how can the operator observe the emulsion during mixing?
(d) How is the isotopic composition and total activity of the waste product determined? Who is responsible for this? Who is respon-sible for classifying and labeling the waste product per 10 CFR 61 requirements?
(e) What amount of airborne radioactivity occurs during the mixing process? How is this controlled? How is it monitored?
(f) How is the waste oil transferred from the oil storage tank to the drum? How is the water transferred, and where does it come from?
What assurance does the operator have that no oil is added to the oil storage tank after it has been sampled? Is there a requirement that the oil storage tank should be isolated and well mixed during sampling as well as during the transfer of oil to the waste drum?
What kind of control does the operator have on these transfers?
(g) How are the emulsifier or any of the additives placed in the drum?
Where are they stored?
(h) The types of interconnections between the plant and the NuPac System should be described, especially hoses or piping between the plant's radwaste tanks and the NuPac System. What types of initial and periodic hydrostatic testing are conducted on these interconnection lines?
(i) In similar operations, dust from the cement tends to obscure the waste product from the operator.
How is this controlled?
(j) In the second paragraph of Section 4.0, it is stated that the interior of the drum is marked. Who does this? Are the marks made as a result of the sampling analysis and determination of volume proportions in the PCP?
(k) When the mixing head is moved back and forth between the waste product drum and rinse drum, there is bound to be some dripping of radioactive material on the floor. How is this contained and controlled?
- 21. Section 6.0, Qualification Testing in conjunction with Appendix C gives a chronological account of the problems encountered by NuPac in learning how to mix oil and cement. The really significant information is in the last two paragraphs which describe (briefly) some successful testing.
It would be beneficiel to expand on the description and conclusions of this successful' testing. Were various viscosity oils used? Is the PH of the waste a factor? Was the testing performed on actual or siinulated radwaste? What is the effect of radioactivity on the solidification 1
process and on the solidified product?
,y
. 22.
In the first paragraph of Section 6.0, it is stated that qualification tests were conducted to establish that the solidified product was "in accordance with U.S. Gypsum's topical report." What does that mean?
The only product attributes addressed in Section 6.0 are solidification and absence of free liquid. What are NuPac's conclusions regarding their tests for long-term stability attributes such as U.S. Gypsum tested for in their topical report?
Section 6.0 should include a description of the test program showing how the solidified product meets the stability criteria of 10 CFR 61.
NuPac should consider using the U.S. Gypsum Envirostone Cement topical report (or summary) as an appendix to NuPac's topical report.
It con-tains significant information on the stability testing of the cement /
waste samples.
23.
In Section 7.0, third paragraph, the reader is directed to Appendix B for a copy of the Quality Discrepancy Report. This is obviously in error; Appendix B contains the Process Control Program.
- 24. The following questions and comments pertain to the Process Control Program (PCP) in Appendix B:
(a) On page 1 of the PCP in Section 1.2, it is stated that the purpose of the PCP is to provide reasonable assurance of complete solidifi-cation of the waste oil.
If the NuPac System is to be used to process both Class A and B wastes, the PCP must also provide reasonable assurance that the solidified product will meet the stability criteria of 10 CFR 61.
(b) On page 2 under Section 5.2.1, who are "the facility personnel" and how do they " confirm that the contents of the waste oil storage tank have been adequately mixed"? This point could be very crucial to the ability of the PCP to provide any assurance of a satisfactory waste product.
(c) Where is the sample test area relative to the NuPac 011 Solidifica-tion System? Is it considered to be part of the system provided by NuPac. What precautions are taken in the sample test area to control radioactive contamination.?
(d) The Sample Verification Form lists a retardant. Why isn't this shown in the materials listed under Section 5.2.2 of the PCP?
(e)
In Section 5.2.3, what constitutes a batch? The contents of the oil storage tank? The contents of a waste drum?
Is a trial solidification done on each of the samples? Is it done prior to solidification in the drums?
(f)
In Section 5.3.1, what is the sample size?
(g)
In Section 5.3.2, it would seem advisable to provide conversion tables to relate sample volumes to production volumes that would be used in the Operating Procedure.
f
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, (h)
In Section 5.3I, what is the portable mixer? What assurance is there that the same mixing is accomplished with the drum mixer?
In view of the difficulties described in the qualification testing in Appendix C in obtaining a uniform product ('it seems apparent that, for any given set of characteristics,of the oil, it may be
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possible to obtain a satisfactory tect specimen and/ still-have a large part of the product in the drum not solidified.
(i) What.is direction provided on the additio'n:0f. accelerator and retardant?
(j) What are the record-keeping requirements for sample solidifica-tions?
l 25.
In Appendix C, there is no indication that the testing was done with more than one type of oil. What is the effect on solidifcation of various viscosities, contaminants, pH, etc.? Are there any tempera-ture limitations on the process?
- 26. On page 3 of Appendix C in the fifth paragraph, how does rotating the mixer 180 degrees have any effect on the mixing efficiency?
- 27. The QA Program described in Appendix D seems tp be limited to the shipping packages. The QA Program in this topical report should address the entire NuPac 011 Solidification System.
- 20. The following questions ar.d comments pertai!pto the Operating Procedure
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in Appendix E:
(a) The drawing number in Section 2.4 should probably be X 303-001.
(b) In Step 7.2, how were these volumes determined?
It would seem that the specific volumes of water, oil, cement (and whatever else) should be prescribed as a result of the PCP test solidification.
(c) In Step 7.5, how is the ' amount of" cement in the hopper determined?
4 How is it transferred to the hopper? How is the addition rate con-trolled? The note advises the operator to " carefully monitor drum level during binder addition." How does the operator monitor drum level, especially if the mixing head is sealed to the drum?
1 (d) Beginning with Step 7.5, the term " binder" is used, apparently meaning cement. What is the significance of using this term at this point whereas it is not used at all in the rest of the report? In the U.S. Gypsum topical report,.the binder is a constituent of the Envirostone cement.
(e) Where in the procedures is the direction for adding accelerator or retardant? How is the addition related to the PCP7 (f) In Section 7.9, what action is taken by the operator if the contents' of the drum do not solidify in 20 minutes? Whet if it does not solidify at all? How is the reach rod inserted through the mixing head? How is free-standing liquid detected? What action is taken by the operator if liquid _is present?
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- (g) What guidance or procedures are provided to the operator in case of emergencies (e.g., inadvertently overturning a drum of radwaste, failure of a mixer motor, breaking a mixer blade)?
(h) The procedure should include direction regarding the monitoring of the outside surfaces of the drum for radioactivity, and the subsequent decontamination process-before it is removed from the solidification area.
(i) The instruction in Section 7.10 is extremely terse.
Is the lid secured with a crimping device?
(j) In Section 7.11, how is the drum of solidified waste moved to the storage area? What ALARA measures are taken during this transfer?
(k). In Section 8.0, how do these " recommended" volume and weight ratios relate to the ratios determined in the PCP for each batch of waste oil?
(1) Section 8.1. implies that aqueous waste may be used instead of plain water. Neither the report nor the PCP discuss this. How would such waste be transferred from the plant's liquid radwaste system to the
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drum? How is the radioactivity and chemistry of this waste accounted for in the solidification process?
.