ML20206S026
| ML20206S026 | |
| Person / Time | |
|---|---|
| Site: | 07003091 |
| Issue date: | 01/22/1999 |
| From: | Pierson R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Gibbs D ENERGY, DEPT. OF |
| References | |
| NUDOCS 9901270187 | |
| Download: ML20206S026 (2) | |
Text
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! Dr. D. Clark Gibbs U. S. Department of Energy
( Richland Operations Office P.O. Box 550 Rich!and, Washington 99352 '
I
SUBJECT:
F4EVIEW OF COMMENTS ON BNFL INC. CRITICALIT'r SAFETY PROGRAM !
Dear Dr. Gibbs:
In your letter to me dated December 16,1998, multiple concerns that the U. S. Nuclear l Regulatory Commission (NRC) previously raised concerning the most recent revision to the i British Nuclear Fuels Limited Criticality Safety Program, Tank Waste Remediation Project were l addressed by the U. S. Department of Energy, Richland Operations Office, Regulatory Unit (RU). With minor exceptions noted, the RU believes provisions in the Safety Requirements Document or Quality Assurance Plan adequately address NRC concerns.
However, after careful review by NRC technical staff, it is NRC's position that several of the provisions do not adequately or fully resolve the issues raised. In summary, responses to General comment 3 and section Specific comments 10,11, and 12 appear unresolved with respect to NRC concerns. Also, for General comments 1 and 4, and Specific comment 3, !
NRC disagrees, in part, with the explanations given. For General comments 5 and Specific comment 7, NRC technical staff has not reviewed the referenced documents in relation to i criticality; upon completion of the review, NRC will close out these comments as appropriate. !
The specific details are provided in the enclosure. Finally, in regard to specific comments on the recommended consideration of Keff sensitivity calculations, we would like to emphasize that it was never our intent that an appropriate consideration for calculational uncertainty and administrative margin be replaced by sensitivity calculations. Rather, the sensitivity calculations support a determination of appropriate subcritical margin.
NRC would like to thank the RU for the continued opportunity to provide comments and believes such interactions are beneficial to the achievement of necessary and sufficient safety and to the efficient preparation for transfer of regulatory jurisdiction, should such occur. If you have any questions or would like a more detailed explanation, please contact Michael Tokar of my staff at (301) 415-7251.
Sincerely, O'igina! M OY Robert C. Pierson, Chief Special Projects Branch Division of Fuel Cycle Safety and Safeguards, NMSS MGgb' 7
Docket 70-3091
Enclosure:
As stated DISTRIBUTION:
Docket 70-3091 !NRC File Center ~ 7 FCSS r/f NMSS r/f Public 270027
- see previous concurrence oComron. SPB SPB r/r
- SPB *SPB *SPB SPB
{ SP/
JDavis:ij JMuszkiewicz MGalloway jMh 1 IFierson 1/13 /99 1/20/99 1/20/99 / /1.# /99 I /D98 C= Cover E= Cover & Enclosun N= No Copy
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9901270187 990122 PDR ADOCK 07003091 C
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l I Dr. D. Clark Gibbs
. U. S. D:partm:nt of En rgy
( Richland Operations Office j P.O. Box 550 1 ichland, Washington 99352 S BJECT: REVIEW OF COMMENTS ON BNFL INC. CRITICALITY SAFETY PROGRAM
Dear r. Gibbs:
In your le er to me dated December 16,1998, multiple concerns that the U. S. Nuclear Regulatory ommission (NRC) previously raised concerning the most recent revision to the ,
British Nuclea {uels Limited Criticality Safety Program, Tank Waste Remediation Project were '
addressed by thb U. S. Department of Energy, Richland Operations Office, Regulatory Unit (RU). With minor c ceptions noted, the RU believes provisions in the Safety Requirements Document or Quality surance Plan adequately address NRC concerns.
J However, after careful revie by NRC technical staff, it is NRC's position that several of the provisions do not adequately o lly resolve the issues raised. In summary, responses to General comments 3 and 5 and s ion Specific comments 7,10,11, and 12 appear unresolved with respect to NRC conc. s. Also, for General comments 1 and 4, and Specific comment 3, NRC disagrees, in part, with e explanations given. The specific details are I provided in the enciosure. Finally,in regar specific comments on the recommended consideration of Keff sensitivity calculations, w ould like to emphasize that it was never our intent that an appropriate consideration for calcula ' nal uncertainty and administrative margin be replaced by sensitivity calculations. Rather, the se itivity calculations support a determination of appropriate subcritical margin.
NRC would like to thank the RU for the continued opportunity ovide comments and believes such interactions are beneficial to the achievement of nec sary and sufficient safety and to the efficient preparation for transfer of regulatoryjurisdiction, s uld such occur. If you have any questions or would like a more detailed explanation, please con et Michael Tokar of my staff at (301) 415-7251.
Sincerely, Robert C. Pierson, Chief Special Projects Branch Division of Fuel Cycle Safety and Safeguards, NMSS Docket 70-3091
Enclosure:
As stated DISTRIBUTION:
Docket 70-3091 NRC File Center FCSS r/f NMSS r/f Public GComfort. SPB SPB r/f
- see previous concurrence
- SPB PPB ( SPB b SPB SPB JDavis:ij hbzkiewicz kkvh MTokar RPierson 1/13 /99 / /24/99 ) /20/99 / /99 / /98 I C= Cover E= Cover & Enclosure N= No Copy g$cspl.res OITICIAL RECORD COPY
g Dr. D. Clark Gibbs i
. x U. S. Department of Energy !
Richland Operations Office :
i 9 i P.O. Box 550 1 Ric' d, Washington 99352 SUBJE : REVIEW OF COMMENTS ON BNFL INC. CRITICALITY SAFETY PROGRAM Dear Dr. Gib .
In your letter to m dated December 16,1998, multiple concerns that the U. S. Nuclear Regulatory Commis 'on (NRC) previously raised concerning the most recent revision to the British Nuclear Fuels ited Criticality Safety Program, Tank Waste Remediation Project were addressed by the U. S. partment of Energy, Richland Operations Office, Regulatory Unit (RU). With minor exceptio s noted, the RU believes provisions in the Safety Requirements Document or Quality Assura e Plan adequately address NRC concerns.
However, after careful review by RC technical staff, it is NRC's position that several of the provisions do not adequately or full esolve the issues raised. In summary, responses to General comments 3 and 5 and secti Specific comments 7,10,11, and 12 appear unresolved with respect to NRC concer Also, for General comments 1 and 4, and Specific comment 3, NRC disagrees, in part, with t explanations given. The specific details are provided in the enclosure. Finally,in regard specific comments on the recommended consideration of Keff sensitivity calculations, N C would like to emphasize that it was never our intent that an appropriate consideration for calcu ional uncertainty and administrative margin be replaced by sensitivity calculations. Rather, the nsitivity calculations support a determination of appropriate subcritical margin.
NRC would like to thank the RU for the continued opportuni to provide review and believes such interactions are beneficial to the achievement of necessa and sufficient safety and to the efficient preparation for transfer of regulatory jurisdiction, should ch occur. If you have any questions or would like a more detailed explanation, please contact 'chael Tokar of my staff at (301) 415-7251.
Sincerely, Robert C. Pierson, Chief Special Projects Branch Division of Fuel Cycle Safety and Safeguards, NMSS Docket 70-3091
Enclosure:
As stated DISTRIBUTION:
Docket 70-3091 NRC File Center FCSS r/f Public GComfort, SPB SPB r/f NMSS r/f \
SPB [ SPB SPB SPB SPB hDavis:ij JMuszkiewicz MGalloway MTokar RPierson
/ / /3/99 / /99 / /99 / /99 / /98 l C= Cover E= Cover & Enclosure N= No Copy g:\cspl.res OfTICIAL RECORD COPY
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