ML20215L407
| ML20215L407 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 03/31/1987 |
| From: | Malody C SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER |
| To: | Rouse L NRC |
| References | |
| 28071, NUDOCS 8705120232 | |
| Download: ML20215L407 (9) | |
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RETURN IO: 396-55 ADVANCEDNUCLEARFUELSCORPORATION 2101 HORN RAPIDS ROAD. Po Box 130. RICHLAND, WA 993524130 CORPORATELICENSING (509) 3758100 TELEX: 15 2078 March 31,1987 I.q/
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Attention: Mr. L. E. Rouse, Chief 9_
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Dear Mr. Rouse:
This is in reply to W.T. Crow's letter dated M. orch 2,1987 concerning the prevention of the introduction of hydrocarbons into UF6 cylinders and process systems.
An assessment of the controls which prevent the introduction of hydrocarbons into UF6 cylinders or processing equipment at our Richland facility has been completed and the controls found adequate.
A summary assessment is outlined below for your review.
Advanced Nuclear Fuels Corporation uses 30B cylinders for the transport of UF.
Any cylinders purchased in the future will be manufactured according to :
6 ANSI NI4.I. That standard, among other things, requires a thorough cleaning of the finished cylinder including the manufacturers certification to that effect.
Flushing and cleaning procedures prior to maintenance, inspection and testing specifically exclude the introduction of hydrocarbons and follow the recommen-dations in ANSI 14.1.
The design of the UF6 process system for emptying cylinders specifically excludes hydrocarbons. For example, the vacuum pump used for heel draw-down is a diaphragm pump' rather than an oil-filled pump.
Any equipment or system modifications, other than replacement in kind, require authorization by on Equipment Change Notice (ECN).
The ECN is signed by appropriate Licensing, Safety, Engineering and Operating personnel which will preclude inappropriate equipment pieces from being substituted.
Full cylinders are found sealed _upon receipt and cylinders with heels are sealed prior to shipment.
The synopsis above covers the specific points in Mr. Crow's request. The controls described above are not all included'in-our license; therefore, oppropriate amended _ pages are enclosed. We have recently_ subnp,11ed a license application for j
renewal which is under review.
As part of the revrew process, we will submit j
revised pages for that application.
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March 31,1987 Page 2 A check for $150 is enclosed as the amendment fee.
Sincerely, C. W. Malody, Manager Corporate Licensing CWM:jrs Enclosures As Stated
ADwU@CEDNUCLEARFUELSCORPORATION XN-2 SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM-1227, NRC DOCKET NO. 70-1257 Attachment Q - Safety Features and Accident Analyses REv.
ATTACHMENT Q SAFETY FEATURES AND ACCIDENT ANALYSES CONTENTS Section No.
Section Title i
REFERENCES TO DOCUMENT NO. JN-2 2
REFERENCES TO DOCUMENT NO. JN-2 ADD-l 3
DISCUSSION l 14 i
i AMENDMENT APPLICATION DATE:
PAGE NO.:
April 1987 Q-0 XN-NF-FO1-822 (2/s7)
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ADWU9CED NUCLEAR FLJELS CORPORATION XN-2 SPECIAL NUCLEAR MATERIALllCENSE NO. SNM-1227, NRC DOCKET NO. 70-1257 Attachment O - Safety Features and Accident Analyses REv.
3.
Discussion The reactions of hydrocarbons with UF, even in smali quantities, con be 6
vigorous to the point of serious explosions. Therefore, ANF has assessed
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its controls to prevent the introduction of hydrocarbons into cylinders or UF6 systems and find them adequate.
These various controls are outlined below.
The purchase specification of new 300 cylinders require conformance to ANSI N14.1 which includes certification by the vendor that cleanliness requirements specified therein have been met.
Recertification and maintenance on cylinders is also performed within the requirements of 14 ANSI N 14.1.
The procedures for cylinder heel removal and washing prior to maintenance or recertification specifically exclude the use of hydrocarbons.
The equipment used for processing UF6 is designed to exclude the need for hydrocarbons (oil). For example, the vacuum pump used to reduce cylinder heels is a diaphragm vacuum pump rather than an oil filled pump.
An Equipment Change Notice (ECN) must be authorized to modify equipment which requires review and approval in accordance with Figure 2.3-2 and would therefore protect against hydrocarbons being utilized in the future.
AMENDMENT APPLICATION DATE:
PAGE NO.:
April 1987 Q-3.1 XNM-F01-c22 (2/s7)
ADVANCEDNUCLEARRJELSCORPORATION XN-2 SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM-1227, NRC DOCKET NO. 70-1257 Application - License Conditions
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The exterior surfaces of each package surveyed to be within the release limits specified in Section 3.l.4.3(B)(2) prior to being removed from the process building.
g)
Radioactive material storage areas are not sprinklered.
h)
The occumulation of combustible materials in building used for the storage of radioactive materials is maintained at a minimum.
Solvents, oils, and flammable liquids are not allowed in such buildings unless they are separated from containers of uranium and uranium-contaminated materials by fire walls of at least one-hour rating.
All outside enriched uranium storage areas are identified, posted and controlled as Radioactive Materials Areas, and all such areas are established within the fenced exclusion area.
3.7.2.1 UFx Cylinders New UF6 cylinders purchased by ANF shall conform to ANSI N14.1 which includes certification by the vendor that the cylinders comply with all fabrication, test and cleanliness requirements specified 14 therein. Periodic inspection and testing of cylinders is performed following heel removal.
The heel removal procedures specifically exclude the use of hydrocarbons.
Cylinders of UF6 are received, unloaded and stored on a barricaded pad. As needed for processing, cylinders of UF6 are transferred to either an elevated dock or a barricaded pad adjacent to the UO2 Building.
UF6 cylinders are stored bare in cradles providing AMENDMENT APPLICATION DATE:
PAGE NO.:
April 1987 3.52 XN-NF-F01-822 (2/87)
ADERNCEDNUCLEARFUELSCORPORATION XN-2 SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM-1227, NRC DOCKET NO. 70-1257 Application - License Conditions
- ggy, spacing and stability. The cylinder volve seals which were installed by the shipper are left intact until the cylinder is moved into the 14 plant for emptying.
Evacuated UF6 cylinders (containing heels) are also stored in these locations.
Elevated or barricaded storage of bare UF6 cylinders is designed to guard the cylinders against vehicular damage.
Prior to shipping bare cylinders containing heels, the valves are covered and sealed. When the cylinders are shipped in overpocks, 14 the valves are not covered and sealed but the overpack is sealed.
AMENDMENT APPLICATION DATE:
PAGE NO.:
April 1987 3.52a XN-NF-F01-822 (2/87)
o' ADWU0CEDNUCLEARFUELSCORPORATION XN-2 SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM-1227, NRC DOCKET NO. 70-1257 Application - License Conditions REv.
procedures, each employee affected is promptly informed and properly instructed.
Safety topics are routinely discussed in monthly safety meetings.
Additionally, each employee routinely working with special nuclear material receives annual refresher instruction as part of Advanced Nuclear Fuel's continuing program in radiation protection and criticality safety awareness.
3.10.2 Health Physics Technician Training Health Physics Technicians are given special training related to their radiation protection assignment.. Previous training is accepted if considered equivalent to the Advanced Nuclear Fuel training program. Despite previous acceptable training, the Health Physics Technicians are required to become proficient in Advanced Nuclear Fuel radiation protection and criticality safety programs, criteria, specifications, procedures, and routines, as demonstrated by successfully passing an Advanced Nuclear Fuels certification examination within six months cf ter employment as a Health Physics Technician.
3.11 Process and Equipment Modifications Operations involving radioactive and fissionable materials are conducted in accordance with written Radiation Work Procedures (Section 3.1.1.3) and Criticality Safety Specifications (Section 3.2.1.1 ).
When process, equipment or storage modifications are to be made, a review of the radiation, criticality and industrial safety aspects are made.
Such modifications are only made following authorization of an Equipment Change Notice (ECN) which requires -
AMENDMENT APPLICATION DATE:
PAGE NO.:
April 1987 3.58 XN-NF-F01822 (2/87)
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ADwU9CEDNUCLEARFUELSCORPORATION XN-2 SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM-1227, NRC DOCKET NO. 70-1257 Application - License Conditions
- ggy, approvals in accordance with Figure 2.3-2.
The ECN system assures review of all modifications by appropriate engineering and safety personnel. Where modifications are substantial or significant safety issues are involved, a Startup Review Board may conduct a final review prior to equipment startup.
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14 When process or equipment modifications are made, new or appro-priately revised written procedures and specifications are issued for the modified operation.
When temporary or special operations, which. ore not covered by existing operating procedures and which can affect radiation and/or criticality safety, are needed and warranted, written Process Test Authorizations ore-issued.
Process Test" Authorizations are reviewed by the Radiological Safety Supervis'orond the plant Criticality Safety Engineer of Safety and Security" Operations, and by the Health Criticality Safety Components of Corporate Licensing. Process Test Authorizations involving special nuclear material specify special control limits and procedures under which the nonroutine work must be cone, and specify the authorized duration of the test. Process Test Authorizations are approved in accordance with Figure 2.3-2.
AMENDMENT APPLICATION DATE:
PAGE NO.:
April 1987 3.59 XN-NF-F01-822 (2/87)
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