ML20214K451
| ML20214K451 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/21/1987 |
| From: | Standerfer F GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 0189P, 189P, 4410-87-L-0072, 4410-87-L-72, NUDOCS 8705280445 | |
| Download: ML20214K451 (3) | |
Text
GPU Nuclear Corporation Nuclear
- =,ome: 48o s
Middletown, Pennsylvania 17057 0191 717 944 7621 TELEX 84-2386 Writer's Direct Dial Number:
(717) 948-8461 4410-87-L-0072 Document ID Ol89P May 21,1987 US Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
Dear Sirs:
Three Mile Island Nuclear Station, Unit 2 (TMI-2)
Operating License No. DPR-73 Docket No. 50-320 Request for Exemption from 10 CFR 70.24 In conjunction with the defueling of the TMI-2 reactor vesscl, dampics of Special Nuclear Material (SNM) are being obtained for analysis prior to disposition. Due to physical limitations, it is not feasible to store these SNM samples in areas where criticality monitors exist pursuant to 10 CFR 70.24,
" Criticality Monitoring Requirements." However, GPU Nuclear has imposed certain administrative and physical controls, as described in the attachment, for each SNM sample storage area. Based on the attached justification, GPU Nuclear requests an exemption, pursuant to 10 CFR 70.24(d), from the criticality monitoring requirements of 10 CFR 70.24 for SNM sample storage areas.
Per the requirements of 10 CFR 170, an application fee of $150.00 is enclosed.
8703280445 870521 PDR ADOCK 05000320
[.
P PDR.
. Standerf Director, TMI-2 00l h
FRS/RDW/eml
\\
Jh pd Attachment g
g
(
ggc,,3 wjeggcg { jfg
Enclosure:
GPU Nuclear Corp. Check No. 004706 cc: Regional Administrator, Region 1 - W. T. Russell gooWob Director, TMI-2 Cleanup Project Directorate - Dr. W. D. Travers GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation
ATTACHMENT 4410-87-L-0072 10 CFR 70.24, " Criticality Accident Requirements," states, in part:
"(a) Each licensee authorized to possess special nuclear material in a quantity exceeding 700 grams of contained uranium-235, 520 grams of uranium-233, 450 grams of plutonium, 1,500 grams of contained uranium-235 if no uranium enriched to more than 4 percent by weight of uranium-235 is present, 450 grams of any combination thereof, or one-half such quantities if massive moderators or reflectors made of graphite, heavy water or beryllium may be present, shall maintain in each area in which such licensed special nuclear material is handled, used, or stored, a monitoring system meeting the requirements of either paragraph (a)(1) or (a)(2), as appropriate, and using gamma-or neutron-sensitive radiation detectors which will energize clearly audible alarm signals if accidental criticality occurs."
TMI-2 is authorized to possess in excess of 1500 grams of U-235 enriched to less than 4%; thus, the above requirement applies. Presently, the TMI-2 reactor vessel is being defueled. As part of the defueling evaluation, samples of special nuclear material (SNM) are being taken for analysis. These samples are currently being stored on-site in vital areas, prior to disposition (e.g., Spent Fuel Cooler Cubicle at the 305' elevation of the Auxiliary Building). Based on the following justification, GPU Nuclear believes that criticality monitors, as specified in 10 CFR 70.24, should not be required for TMI-2 SNM sample storage areas since adequate administrative and physical controls will be implemented to ensure subcriticality, o
Administrative and physical controls shall be implemented to ensure that the amount of SNM in each sample storage area does not exceed 70 kg.
The limitation of 70 kg is an administrative limit established by GPU Nuclear to ensure subcriticality for a single volume. For purposes of conservatism, this limit is 75% of the minimum critical mass for TMI-2 fuel (i.e., 93 kg). The minimum critical mass is based on the following conservative assumptions:
3% enriched UO2 (whole fuel pellets)
Optimum moderation using unborated water The spherical fuel configuration Full water reflection No assumed credit for effects of poisons or structural materials o
Each SNM sample will be placed in a container which is critically safe by design. Specifically, each SNM sample container has a volumetric design limit of 6400 cm3 This volumetric limit ensures that a full receptacle cannot exceed 70 kg of SNM based upon the maximum theoretical density of UO2 (10.9 g/cc).
o The total SNM mass in each storage area will be procedurally limited to 70 kg.
This limit will be ascertained and controlled by the mass measurement of each SNM sample. Each SNM sample container will be weighed prior to and after loading in order to ascertain the weight of the sample.
ATTACHMENT 4410-87-L-0072 o
Each SNM sample storage area will be separated, as a minimum, from any other SNM storage area by 12 feet of air or 12 inches of concrete.
o All SNM sample storage areas are maintained locked. The keys for the locks are under control of TMI-2 Security and all storage or any movement of SNM must be authorized by the SNM Coordinator. prior to transfer into a storage area.
Based on the above justification, GPU Nuclear believes that the subcriticality of the SW sample storage is assured by implementation of.the above controls and thet the requirements for criticality monitors should not be. imposed.
Therefore, pursuant to 10 CFR 70.24(d), GPU Nuclear requests an exemption from the criticality monitoring requirements of 10 CFR 70.24 for the SNM sample storage area (s).
Y l
j._-
.