ML20214W992
| ML20214W992 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 05/18/1987 |
| From: | Malody C SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER |
| To: | Rouse L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20214W995 | List: |
| References | |
| 28231, NUDOCS 8706160288 | |
| Download: ML20214W992 (12) | |
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RETURN El 39A-55 7dMP57 ADVANCED NUCLEAR FUELS CORPORATION 2101 HORN RAPIDS ROAD. PO Box 130 R!CHLAND, WA 99352 4 130 CORPORATELICENSING (509) 375-8100 TELEX ^ 15-2878 May 18,1987
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RECENED 6 MAY261987 )
U.S. Nuclear Regulatory Commission
( E U.S.Nucun tcum* '
Attention: Mr. L. C. Rouse, Chief 1
cot.wesu NM3 Fuel Cycle Safety Branch i
x Division of Fuel Cycle, Medical, Academic
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and Commercial Use Safety Washington, D.C.
20555 License No. SNM-1227 Docket No. 70-1257
Dear Mr. Rouse:
Advanced Nuclear Fuels Corpora + ion (ANF) submitted an application for renewal of License No. SNM-1227 by letter < fated September 12, 1986. During your staf f s' review of that application, certain questions and comments were generated and were delivered to me during my visit to Silver Springs on March 3,1987.
Our response to those questions and comments are enclosed.
In most cases, our response required modification to certain pages in our application for renewal and in those cases, replacement pages (six copies) are also enclosed. Vertical lines in the margin of those replacement pages indicate where wording changes have been made.
The application was submitted prior to the change in Company name on January I,1987. To rectify possible confusion the name change may cause in the future, it is our plan when all questions and comments have been resolved to issue a total final draft of that application with the name of the licensee corrected throughout.
ANF is currently constructing on incinerator for volume reduction of low-level radioactive waste including the option of recovering uranium values from those wastes.
The current schedule predicts startup of that incinerator in August 1987.
We would appreciate your assistance in meeting that startup date by either approval of the current application with the incinerator included, or by a separate amendment to the existing license. I have discussed this matter with Mr. George Bidinger of you staff who indicated that interruption from recent NRC reorganiza-d
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Mr. L. C. Rouse May 18,1987 Page 2 tion might interfere with that schedule. We will keep you informed of our incin-erator schedule in case there is some slippage and we will appreciate your efforts in assisting us to meet our startup date.
Sincerely, C. W. Mglody, anager Corporafe Licensing CWM:jrs Enclosure As Stated
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RESPONSE TO NRC COMMENTS FOR LICENSE RENEWAL SNM-1227 Comment-l Provide a report indicating the personnel occupational external exposure data for the past two years including the number of individuals whose total whole body _
exposures fall in each specified exposure range.
Response-l The requested exposure data is enclosed.
Comment-2 Page 1-2, Sections 1.3.2 and 1.3.3 The activities described in these two sections are not regulated by the NRC.
Therefore, they should be in Part 11 of the application.
Response-2 Section 1.3.2 has been removed from the application, and Section 1.3.3 has been moved to Section 13.3.
Comment-3 Page 2-1, Section 2.1 This section should be expanded to include the responsibilities and authorities of the Health Physicist Specialist.
Response-3 The responsibilities of the Health Physicist Specialist are listed in Section 2.1.19 on page 2-10.
Comment-4 Page 2-15, Section 2.4.3 This section should include on annual refresher training course for the Health Physicist Technician.
Response-4 The comment is accepted. 'Perio. dig training of HPT's is a part of our training program but was omitted from the original application.
A
r Comment-5 Page 2-16, Section 2.6.1 This section should be expanded to specify that o' radiation protection inspection shall be conducted on a daily basis and in accordance with an approved written plan.
Response-5 The comment is accepted and is incorporated in Section 2.6.l.
Comment-6 Page 3-3, Section 3.2.2 Confirm that the direction of the air flow in the contaminated areas shall be tested monthly.
Response-6 This comment is accepted and is already incorporated in our existing procedures.
Comment-7 Page 3-4, Section 3.2.3 This section should contain the following specifications regarding the air sampling program for the work areas (any deviations should be justifiedh I.
The air in all areas where unclad licensed material is processed or where the operation could result in worker exposure to radioactive material exceeding those concentrations specified in 10 CFR 20.103 shall be regularly sampled and analysed for airborne concentration of radioactivity.
The survey fre-quency for the continuous air sampling of the workers' breathing zone shall be in accordance, where applicable, with Table I of Regulatory Guide 8.24,
" Health Physics Survey During Enriched Uranium-235 Processing and Fuel Fabrication," dated October 1979 (enclosed).
2.
If a single air sample for the workers' breathing zone indicates the airborne concentrations of radioactivity exceed the MPC specified in Table I, Column I of 10 CFR Part 20, Appendix B, or the weekly overage airborne concentration levels exceed 25 percent of the above MPC air limit, the licensee shall investigate the cause and take action to prevent its reoccurrence.
3.
The air flow rotometer shall be calibrated at least every six months.
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'1 Response-7 Item 1.
Our air sampling programs dif fers to some extent from Table I in Regulatory Guide 8.24 and is outlined below.
Air samples are not taken at shipping, receiving or storage areas that are not a.
contamination control areas. In most of these areas, the licensed material is packaged, clad or sealed.
b.'
Air.somples are taken at least daily in contamination control areas while selected samples representing the work environment are pulled each shift when operating.
The uranium concentration in all sample areas consistently falls below lx10-Il uCi/ml. The samples pulled each shift are used to confirm the low air concentrations.
Analytical laboratory air samples are changed weekly.
The laboratory-c.
conducts analyses on licensed material in ventilated hoods which has main-toined excellent contamination control through the years. The areas outside the hoods themselves are maintained clean and uranium concentration in air are routinely below lx10-12 uCi/ml.
d.
Fuel assembly and inspection' areas air samples are changed weekly as all licensed material is clad and surveyed before entry into the area.
Item 2.
Comment is accepted and is already incorporated in our existing plan. -
Item 3.
Our air flow rotometers are calibrated annually which'our experience has shown to be adequate.
Comment-8 Page 3-5, Section 3.2.4.1 Confirm that the calibration of the survey instruments shall meet the specifications described in Section 1.1 I of Regulatory Guide 8.24.
Justification should be provided for any deviation.
Response-8 We do follow the guidance given in Regulatory Guide 8.24 and this is indicated in Section 3.2.4.l(l).
Comment-9 Page 3-7, Section 3.2.5.2 The following specifications relevant to personnel dosimetry should be established:
1.
The film badges are used for personnel radiation dosimeter, they shall be processed monthly for determination of radiation exposure.
2.
The action level established which is less than the regulatory limits that prevent overexposure.
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s Response-9 1.
We will accept the comment although we do not currently use film dosime-ters.
2.
Investigation levels have been added to Section 3.2.5.2.
Comment-10 Page 3-8, Section 3.2.6.1 Provide justification for the action levels established for the outside areas.
c.
b.
Action levels for releasing personnel and material should be deleted, they are addressed in Section 3.2.6.2.
c.
Establish the contamination limits for the plutonium activities described in Section 1.6.3.
Response-10 a.
Outside areas has been removed from Section 3.2.6.1 and release ' limits have been added to Section 3.2.6.2(2).
b.
Comment accepted, c.
Plutonium limits are presented in Section 3.2.6.l(4).
Comment-i l Page 3-8, Section 3.2.6.2 This section should be expanded to include the following:
1.
Confirm that on individual whose skin is found contaminated above background shall not be allowed to exit a contaminated area without prior opproval of the radiation protection staff.
2.
The licensee shall establish the contamination levels for protective clothing that may be reused in the contamination areas. (Toble 2 of enclosed Regu-latory Coide 8.24 can be used for reference.)
Response-11 1.
See 3.2.6.2.1.b.
2.
See 3.2.6.2.1.c.
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Comment-12 Page 3-9, Section 3.2.7 The bioassay program described in this section is not complete and should be-expanded to include the following:
1.
Criteria for-determining who~ is required to participate in the specified bioassay program.
2.
Specify the frequencies for bioassay, action levels,.and action to be taken for each measurement technique (bioassay frequency should vary according to the elevation of airborne concentration of radioactivity in the work area and dust classification).
3.
Criteria for determining that. a diagnostic bioassay measurement shall be initiated.
Response-12 Section 3.2.7 has been expanded to include additional facets of our bioassay program which address the comments above.
Comment-13 In order to meet the above requirements, we suggest that the bioassay program in Part 11 of the application (Section 12.12) be moved to Part 1.
In addition, the following additional specifications should be included in the program:
1.
If the workers' urinalysis results are confirmed (25 micrograms / liter), the licensee shall conduct on investigation to determine the probable cause, and consider ' work restrictions for affected workers.
2.
If the workers have received an uptake of 1.30 mg or greater of uranium via the bloodstream, the licensee shall consider imposing work restrictions for-affected workers.
3.
If the workers' in-vivo lung count results are confirmed (7.5 rem), the licensee shall take action to identify the probable cause and initiate additional control measures.
4.
Express the action levels for in-vivo lung count results in units of ugm U-235.
5.
Provide justification which is based on the one year organ dose rather than the 50 years committed dose concept for the action taken with respect to in-vivo measurement results.
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Response-13 l&2 It is our plan to use 25 ugm/l as on action level. One option based upon the results of the investigation will be to consider work restriction for offected workers, see 3.2.7.4.o.
3.
We agree.
The first action level has been changed to 5 rem (125 micro-grams).
4.
We have added micrograms U-235 in parenthesis.
5.
Footnote l on page 3-11 has been added.
Comment-14 Page 6-2, Section 6.4.2 This section should specify a maximum. residence time that a radioactive waste package will be allowed to be stored outdoors.
Response-14 There is no merit to specifying an outdoor storage time limit in that there is no safety basis fer identifying a time. It could become argumentative during on audit as to whether an item were waste, scrap, or contaminated equipment to be reclaimed or reused. A short paragraph addressing this subject has been added to Section 6.4.2 which is really a policy once our incinerator has come on-line. We feel that this is responsive to the intent of your comment.
Comment-15 The managers who are on the Health and Safety Council and on the ALAR A Committee, as specified in Sections 2.3.1 and 2.3.2 of chapter of the application, and the Manager, Materials Research, shall possess a B.S. degree in Science or Engineering, and except for the Manager, Operations-Richland, shall have a minimum two years experience in nuclear fuels processing. The Manager, Opera-tions-Richland, shall have ten years of experience in nuclear fuel processing.
Response-15 The Health and Safety Council is concerned with normal industrial safety as well as nuclear and radiological safety thus many of the members do not have science degrees. There are also some areas with some nuclear involvement where a degree is not necessary in that some experience and specialized training along with technical backup is quite adequate to insure safety. We have attempted to address your concerns in Section 2.2 on page 2-11.
Comment-! 6 in lieu of the first sentence of subparagraph 3 of Section 4.2.5.2, the material shall be contained in a fireproof barrier or in a process crea containing specified limited quantities of hydrogenous material.
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Response-16 This comment is accepted.
Comment-17 in lieu of paragraph 3 of Section 4.2.7.1 of the application, calculational methods shall be validated in accordance with all requirements in Section 4.3 of ANSI /ANS-8.l-1983.
Resoonse-17 This comment is accepted.
Comment-18 in lieu of Section 4.2.7.3 of the license application, critical parameters derived l
from nuclear criticality safety analyses shall be based on optimum moderation unless the requirements of Section 4.2.5 of the license application, as modified above, obtain.
Response-18 This comment is accepted.
Comment-19 I
in lieu of Section 4.2.7.4 of the license application, critical parameters of individual units and arrays of units shall be based on full water reflection unless other reflectors in the immediate vicinity could result in higher reactivity.
Response-19 This comment is accepted.
Comment-20 In lieu of proposed item 7, Section 14.3.3.1, fuel pellets shall be modeled as a heterogeneous mixture.
Response-20 4
This comment is accepted and item 7 has been deleted.
Comment-21 Operation of the SWUR facility described in Section 1.5 and Table I-l.1, Part I, 2
and Section 10.4.5, Part ll is not authorized.
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d Response-21 This Solid Waste Uranium Recovery (SWUR) facility.is currently under construction and is on a schedule which predicts startup 'in August of 1987. Discussions on the incinerator, including a tour, were held with members of Headquarters staff during
. their plant visit on March 17-18.
A set of.-13 questions and ' comments' were received.on the incinerator following their visit. We are targeting for a response to those questions by May l.
It is called to your attention that the SWUR HVAC system is discussed in Section 10.3.2.1 beginning on page 10-18.
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Comment-22 In' lieu of the Radiological Contingency Plan referenced in Chapter 8 of the
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application, the licensee shall use the Plan submitted on August 27, 1985.
Response-22 This comment is accepted.
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WHOLE BODY EXPOSURES FOR CALEllDAR YEAR 1985 Estimated Annual Whole Body. Exposure Number of Individuals Rances * (Rems) in Each Rance No fleasurable Exposure 369 fleasurable Exposure less than 0.1 358 0.1 --0.25 92..
0.25 -0.50 29 0.50 -0.75 3(.52,.54,.65) 0.75 -1.0 2(.82,.98) 1 1.0 - 2.0 2 (1.12, 1.49) 2.0 - 3.0 2 (2.06,2.32) 3.0 - 4.0 0
4.0 - 5.0 0
5.0 - 6.0 0
6.0 - 7.0 0
7.0 - 8.0 0
1 8.0 - 9.0 0
9.0 -10.0 0
10.0-11.0 0
11.0-12.0 0
12.0 +
0 Total Number of Individuals 857
- Individual values exactly equal to the values separating exposure ranges shall be reported in the higher range.
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RECORDED PERSONNEL-WHOLE BODY EXPOSURES FOR CALENDAR YEAR 1986 '
LICENSEE:
LICENSE NO(s).:
Advanced Nuclear Fuels Corporation SNM-1227 2l01 Horn Rapids Road -
WN-1062-1 P. O. Box 130 Richland, WA - 99352-0130 Annual Whole Body Dose Number of Individuals Ranges (l)-(Rems) in Each Range No. Measurable Exposure 498 Measurable Exposure Less Than 0.100 248 0.100 - 0.250 75 0.250 - 0.500
'l8 0.500 - 0.750 3(2) 0.750 - 1.000 0
1.000 - 2.000 0
2.000 - 3.000 0
3.000 - 4.000 0
4.000 - 5.000 0
5.000 - 6.000 0
6.000 - 7.000 0
7.000 - 8.000 0
i 8.000 - 9.000 0
f 9.000 - 10.000 0
10.000 - l 1.000 0
I l.000 - l2.000 0
Measurable Exposure Greater Than 12.000 0
Total Number of Individuals Reported
-842 The above information is submitted for the total number of Advanced Nuclear Fuels Corporation employees for whom personnel monitoring was provided per 10 CFR e
20.407(a)(2) during the calendar year.
(1)
Dose values exactly to values separating exposure ranges were reported at next higher range.
(2)
Three doses received were 0.620 Rem for person in Fuel Performance, 0.580 i
Rem for person in UF Conversion, and 0.570 Rem for person in Ceramics.
6 Report Prepared By: h/
(509) 375-8537 Nome Q
Telephone
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