ML20212N186
| ML20212N186 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 08/14/1986 |
| From: | Watters J BABCOCK & WILCOX CO. |
| To: | Crow W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 27307, NUDOCS 8608280119 | |
| Download: ML20212N186 (6) | |
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RETURN TO 396-SS
/3 g grzC,3F E"*bbM Babcock & Wilcox a McDermott company P.O. Box 11646 Lynchburg. VA 24506 1646 (804) 522 6000 August 14, 1986 N
United States Nuclear Regulatory Commission Attn:
Mr. W. T. Crow, Acting Chief Uranium Fuel Licensing Branch Co Division of Fuel Cycle & Material Safety a
Washington, D. C.
20555 7,
rd
References:
(1)
SNM-ll68, Docket 70-1201 (2)
Letter to Mr. R. G. Page from J.
P. Watters dated 5/28/85 Gentlemen The Babcock & Wilcox Company, commercial Nuclear fuel Plant is requesting amendment of SNM-1168 allcwing natural U 0 drums to 2 8 be stored outside of the freight containers presently authorized (Reference 2).
We would like to upgrade our storage area to include areas that are more suitable for long-term storage of 55 gallon drums that provide more protection from the elements.
Attachment I gives background information on the uranium storage area and justification for the proposed change.
This amendment request consists of revised Page 40 of Section V of SNM-1168, dated 8-14-86 and is included as Attachment II to this letter.
8608280119 860814 PDR ADOCK 07001201 C
pon We are requesting timely approval on this amendment request as we are faced with meeting contractual obligations and timing constraints involving storage logistics and the transfer of drums from freight containers to a more suitablu storage area.
Enclosed is a check for $150 to cover the initial, licensing application fee.
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United States Nuclear Regulatory Commission Page 2 August 14, 1986 If we can assist you in the timely approval of this request, please feel free to call me at (804) 522-6202.
Sincerely, BABCOCK & WILCOX COMPANY COMMERCIAL NUCLEAR FUEL PLANT I
J. P. Watters License & Control Administrator JPW:cmr Attachments cc:
J.C. Prost R. A. Alto B. W.
Pugh W. T. Engelke K. E. Shy D. W.
Zeff
ATTACHMENT I Natural U 0 SD #^9J 38 Originally, the amendment request for the natural U 0 storage 3g (Reference 2) indicated that 20' freight containers w6uld be exclusively used as a means of 55 gallon drum storage.
We had concluded that the use of the freight containers would serve the purpose of a secondary barrier for both potential spills and personnel access.
Since that time, we have received a number of the freicht containers and have maint,ained them in storage in accord with the conditions as presently stated on Page 40 of Section V of SNM-ll68.
The monitoring program for the U 0 drums is clearly 3 8 indicating that long-term drum storage inside the freight containers causes accelerated deterioration of the 55 gallon drums.
This is due to the fact that these freight containers are not suitable as long-term storage against the elements.
The tops of these containers are essentially flat and can tend to trap rainwater and not permit adequate drainage.
Additionally, these freight containers have no ventilation capability and the heat and humidity in the storage area causes extreme amounts of condensation to form and collect on the tops and sides of the drums.
This permits accelerated rusting of the drums and will in the long term damage the drum such that a potential spill is more probable.
As a result, we are planning to upgrade the storage area and store the U 0 drums outside of the freight containers but protected 3 n from th5 elements.
The license as written will not permit anything but freight container storage which we have seen to be detrimental, to the life of the U,0 drums.
Storage of the U,0 drums 8
g outside of the freight containers will permit th5 Iollowing:
1.
The drums will be more adequately protected from detrimental effect of the elements.
2.
By allowing proper ventilation, condensation collection will be inhibited and will keep the drum in a better condition in the long term.
ATTACHMENT I Natural U 0 Storage 38 e
3.
Monitoring of the drums will be enhanced because visibility and access to the drums will be easier.
The storage configuration at present has the drums tightly packed in each freight container which has complicated the monitoring of the drums.
4.
The U,g8 material in the drums is considered as " Low Specific Activity" (LSA) material as indicated in 49 CFR 173.403 (n) (2).
The packaging requirement for LSA material is simply a " strong tight package".
The " strong tight package" requirement as stated in 49 CFR 173.425 (b) (1) is still maintained because each individual 55' gallon drum meets this criteria without the freight container outer containment.
To go along with the U 0 storage outside of the freight 2 8 containers (Part 7.16 6f Section V of SNM-ll68), we are requesting approval of amended Parts 7.16a, c, e,
and g to accommodato the request.
Part 7.16a was revised to eliminate the restriction to the 20' freight containers.
Part 7.16c was changed to add
" pallets" along with timbers and to change freight containers to uranium oxide drums.
Part 7.16e was revised to clarify that only enriched UF or uranium oxides be limited to a single planar 6
array.
NatQral and depleted UF or uranium oxides do not require g
geometric controls for criticality safety.
Finally, Part 7.16g was modified to include the uranium oxide storage area in the monitoring program.
These changes to the controls imposed on our uranium storage facilities will enhance the health and safety of the employees and public and will provide a more suitable and appropriate means of drum storage and monitoring by helping to eliminate potential I
long-term damage to the drums.
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BABQ0( & WILQX C&PMY, CGIERCIAL NUCLEAR FLEL PLAff USNRC LICCNSE SNM-ll68 DOCKET 70-1201 SECTICN V CONDITIONS 7. 0' Nuclear Safety - Technical Specifications (continued) 7.15 Transport of fuel rods from storage to the assembly area shall be in maximum of 4.00" slabs.
7.16 UraniumStorage(UF and Uranium 0xide) 6 The uranium storagearea may consist of both UF in cylin-6 ders and uranium oxides packaged in drums. The uranium oxide drums will be stored within the perimeter fence and protected from the elements. The uranium storage area is exempt
- w from the criticality monitoring requirements of 10 CFR 70.24.
The following specific conditions apply:
^
The UF area will be kept segregated from the area containing a.
6 the uranium oxide storage area for ease of handling.
l b.
The UF storage area is enclosed by a barrier when cylinders are 6
not being loaded or unloaded.
c.
No combustibles shall be sto' red in the uranium storage area (other than timbers / pallets used to cradle the UF6 cylinders or to support the uranium oxide drums).
d.
UF cylinders shall be equipped with valve protectors during 6
movement and stcrage, single plan $r array.iched uranium oxides will be stored in a Enriched UF and enr e.
Natural or depleted uranium does not require geometric controls for criticality safety.
f.
The entire uranium storage area shall be prepared and maintained under weed control with near edge at least 100 feet from the paved driveway which circles the main CNFP building.
9 The UF cylinder and uranium oxide storage areas shall be moni- ***
6 tored quarterly to detect leakage and monthly to assure adequacy of storage conditions.
l DATE 8-14-86 REVISICH NO.
3 PAGE 40 CLNRENT REVISICN:***
SUPERSEDES: PAGE 40 USNRC APPROVAL REFERENCE DATE 5-28-85 REVISIQ; 2
._.