ML20217B728
| ML20217B728 | |
| Person / Time | |
|---|---|
| Issue date: | 03/23/1998 |
| From: | Cool D NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Paperiello C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9803260153 | |
| Download: ML20217B728 (12) | |
Text
March 23, 1998 MEMORANDUM TO: Carl J. Paperiello, Director Office of Nuclear Material Safety and Safeguards FROM: Donald A. Cool, Director originalSta::1by Division of Industrial and Medical Nuclear Safety, NMSS
SUBJECT:
SUBMITTAL OF ADDITIONAL ISSUES FOR TRACKING IN THE GENERIC ISSUE MANAGEMENT AND CONTROL SYSTEM (GIMCS)
After your recent meeting with the Chairman, you provided us with a list of potential additions to the agency-wide generic issues tracking system maintained by RES. We have coordinated ,
your suggestions with the other divisions, and obtained input on additional issues we believe j should be submitted to GIMCS for tracking. Our summary of the issues is attached for your j review.
Attachment:
Potential New issues
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cc: E. Ten Eyck J. Greeves C. Haughney CONTACT: Kevin M. Ramsey, NMSS/IMNS (301) 415-7887 DISTRIBUTION ENRC Central File? "
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Carl J. Paperiello 2 l
l l Wo do not consider all of the issues on the attached list to be safety enhancement issues. If the policy for submitted NMSS generic issues has changed, we believe PPL 1-57 should be revised to establish new criteria for submitting issues to RES for tracking in GIMCS. j'
Attachment:
Potential New issues I
cc: E. Ten Eyck J. Greeves C. Haughney DISTRIBUTION: '
NRC Central File RJohnson IMNS r/f SRosenburg <
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PDR: YES NO LCamper i
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NUCLEAR REGULATORY COMMISSION f i
WASHINGTON, D.C. 20666-4001 1 4
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/f MEMORANDUM TO: Carl J. Paperiello, Director '
JJ Office of Nuclear Material Safety g h and Safeguards [ l FROM: Donald A. Cool, Director Division of Industrial and -
Medical Nuclear Safety, NMSS
SUBJECT:
SUBMITTAL OF ADDITIONAL ISSUESf0R TRACKING IN THE GENERIC ISSUE MANAGEMENT AND CONTROL SYSTEM (GIMCS)
After your recent meeting with the Chairman, you prov us with a list of potential additions to the agency-wide generic issues tracking system mairitained by RES. We have coordinated your suggestions with the other divisions, and obtaIned input on additional issues we believe should be submitted to GIMCS for tracking. Ou dummary of the issues is attached for your review.
In general, our current procedures limit the ypes of generic issues we submit for tracking in GIMCS. These procedures are as follows,-
/
Management Directive 8.5, O rational Safety Data Review, establishes the requirements for NRC gener' issues programs MD 8.5 states that events should be assessed to determine wh enhancements, or ofmatte e/her compliance withresponse actions existing regulations. should Generic issuesbethattreated as have the potential to'r ire safety enhancements (i.e., licensee safety improvements, and/or new or revise gulations or guidance), are submitted to RES for tracking.
Generic issues th involve compliance with existing regulations generally are not submitted to RE for tracking. MD 8.5 states that NRR, NMSS, and OE shall utilize (other) appropr' te mechanisms for consideration of compliance activities.
. Policy and ocedures Letter 1-57, NMSS Generic issues Program, states that typically, only gene c safety issues are forwarded to RES for tracking (not licensing issues, environ ntal issues, regulatory impact issues, nor generic compliance issues).
Howev r, other generic issues involving significant staff effort may be submitted to RES for tr cking,if desired.
I CONTACT: Kevin M. Ramsey, NMSS/IMNS (301)415-7887
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" 2 WASHINGTON, D.C. 2056!H)o01
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March 23, 1998 l
l MEMORANDUM TO: Cari J. Paperiello, Director Office of Nuclear Material Safety and Safeguards ,
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- FROM: Donald A. Cool, Director .
Division of Industrial and Medical Nuclear Safety, NMSS gyl
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SUBJECT:
SUBMITTAL OF ADDITIONAL ISSUES FOR TRACKING IN THE GENERIC ISSUE MANAGEMENT AND CONTROL SYSTEM (GIMCS)
After your recent meeting with the Chairman, you provided us with a list of potential additions to the agency-wide generic issues tracking system maintained by RES. We have coordinated your suggettions with the other divisions, and obtained input on additional issues we believe j should be submitted to GIMCS for tracking. Our summary of the iscues is attached for your review.
Attachment:
Potential New issues cc: E. Ten Eyck J. Greeves
' C. Haughney CONTACT: Kevin M. Ramsey, NMSS/IMNS (301) 415-7887 s
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I l Potential New NMSS Generic issues:
IMNS i
IM-1 Year 2000 issue - The Year 2000 computer problem has the potential to pose a threat to public health, site safety & safeguards, and worker safety. Many computer systems may potentially fail to recognize the change to a new century. These systems may misread the year 2000 and thus may cause the systems to fail or generate faulty data.
Resolution: NMSS has taken a number of actions to ensure that the Year 2000 computer problem will be either eliminated or minimized for its materials licensees.
These actions include issuing information notices on the Year 2000 issue, coordinating with FDA regarding medical devices, establishing a Year 2000 team to address Year 2000 impacts on materials and fuel cycle licensees, conducting interviews with the management of materials and fuel cycle licensees to identify Year 2000 issues, ,
publishing articles in industry publications, and following up on all activities through !
personal contact by materials and fuel cycle inspectors. NMSS will issue a Generic Letter to fuel cycle licensees addressing the Year 2000 problem. NMSS will continue to produce Newsletter articles or Information Notices to emphasize the Year 2000 problem.
Although viewed primarily as a compliance issue, it involves significant staff effort. We will submit this to RES for tracking as a generic issue.
IM-2 Amersham Cable Issygg - During November and December 1997, NRC received 3 !
reports of radiography source disegnnects involving drive cable failures (see EN 33351, PN-1-97-75, and PN-3-97-93). Each of these incidents involved Amersham equipment.
Information Notice 97-91 was issued on 12/31/97 to alert all radiography licensees to ;
I the problem: Amersham is analyzing the cable functions.
Resolution: Special team inspections have been conducted at Amersham facilities in Massachusetts and Louisiana. Additional followup actions will be considered after the investigation report is issued.
Submitting this issue to RES for tracking as a generic issue will be considered at the next Operational Events Briefing. The issues resulting from the staff's evaluation could prove to be generic safety issues or could only result in modified surveillance.
IM-3 Low-Level Radiation Risks - it is unclear what issue this refers to, but we believe it refers to the debate over whether the Linear-No Threshold (LNT) model should continue to be used as the basis for the dose limits in NRC regulations. We are not aware that the staff has been tasked with any specific action to address this issue. We believe that the ongoing debate in professional societies and other forums may lead to a petition to use a different model as the basis for NRC dose limits.
We do not intend to submit this for tracking as a generic issue.
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IM-4 ICRP-60 Internal Dose Models - Internal dose calculations require the use of mathematical models to estimate the organ doses resulting from intakes of radioactive ;
materials. Assessment of intakes, on the other hand, can often be made without the ]
use of models, especially when the available data is in the form of measured air concentrations or whole body counting data. The major revision of Part 20 changed internal exposure control from regulation of intake to regulation of committed dose equivalents. This change makes internal dose models critical to demonstrating 1 compliance with Part 20. It is generally believed that the newer models provide more accurate estimates of the doses resulting from exposure to radioactive materials. There are no explicit references to models in Part 20, however the All's and DAC's in Appendix B of Part 20 imply that the models used to calculate them (ICRP 26 and 30) are the models that must be used to demonstrate compliance.
Resolution: On 11/4/97, GAP tasked IMOB with preparing information and recommendations concerning the use of newer dose models to demonstrate compliance with NRC regulations. On 11/14/97, IMOB recommended that licensees should be permitted to use the most recent, generally-accepted models in calculating doses to show compliance. Licensees should be permitted to est blish new All's and DAC's.for use in their facilities based on these models. IMOB proposed changes to Part 20 and regulatory guides. On 12/17/97, GAP requested the input of the IMNS Senior Level Health Physicist. IMNS plans to prepare a generic letter to all NRC licensees discussing the stati position on dose models acceptable to NRC for demonstrating compliance with the regulations. This letter will be coordinated with NRR and submitted to the Commission for review before it is issued.
We will submit this to RES for tracking as a generic issue.
IM-5 Troxler Weld Failure issues - On 6/25/97, the source from a Troxler moisture density gauge broke off the source rod and was left at a temporary job site (see PN-1-97-42).
On 7/17/97, NMSS and North Carolina staff met with Troxler to discuss the ongoing problem with cracked and broken source rods. Information Notice 96-52 previously recommended that users inspect source rods for cracks. There have been 6 known disconnects and 57 additional devices with cracked welds.
Resolution: In August 1997, North Carolina planned to issue a " consent decree" to Troxler confirming that they will issue a customer bulletin, conduct accelerated device inspections, revise procedures, and perform additional tests. At the September 1997 Operational Events Briefing, this issue was approved for submittal to RES as a medium-priority generic safety issue. The North Carolina consent decree has received extensive review and comment by State legal staff. As of January 1998, it had not been issued yet.
Referral of this issue to RES has been delayed by higher priority work. The referral memo is currently in concurrence, i
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IM-6 Acaee-Berthold Gauce Failures - On 9/14/97, a cobalt source fell out of a density gauge at a steel plant. A bolted plate fell off the device. It is unclear from the device registry whether the plate should be welded or bolted. Several Apgee customers have reported loose bolts.
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l Resolution: A CAL was issued confirming that Apgee would stop distributing bolted l devices. Response to CAL claims that users are loosening bolts, but we disagree. The l evaluation of the root cause assessment is ongoing. We may recommend that the vendor replace the bolted design with a welded design.
l l This did not appear to be a significant issue warranting refenal to RES, however on 2/5/98, the source housing of a gauge at another facility shifted several inches (see EN 33659). Although the source remained shielded, it appears that the gauge l
experienced complete weld failure. This new information is being reviewed. ~ We do not intend to submit this to RES for tracking as a generic issue.
DWM WM-1 Kev Technical Issues (KTis)- The high-level repository program 10 KTis should not be j i
submitted to RES for tracking as generic issues because they are unique to the geologic repository at the Yucca Mountain site. They have no applicability to other waste programs or sites. However, the proposed generic issue listed below for radionuclide transport has some applicability to KTis that involve flow, radionuclide transport, and the nearfield environment. Submittal of the radionuclide transport issue to the generic
! issues tracking system is preferred.
WM-2 Underaround Criticality - This issue involves the potential for special nuclear material (SNM) to mobilize and reconcentrate to form a critical mass after it has been buried at a low-level waste site. Studies of the burial sites at Envirocare, UT and Barnwell, SC concluded that criticality is unlikely when the moderators silicon dioxide and water are present. However, a study of the moderators carbon and beryllium in waste drums concluded that the presence of these moderators in excess of 5 times the mass of U-235 serves to reduce the areal density of the fissile material required for criticality.
Resolution: On 7/27/97, a user-need memo was issued to RES requesting a study of the role of unusual moderators such as carbon and beryllium in LLW disposal systems to determine their effect on the potential to develop a critical mass. On 8/5/97, this issue was submitted to RES for tracking as a medium priority, generic safety issue.
On 9/19/97, a supplemental user-need memo was issued to expand the scope to l include development of a methodology to quantitatively evaluate the risk of post-disposal criticality.
WM-3 Consistent Modelina Parameters - This issue involves defining an appropriate set of parameters which are consistent with empirical information for use in modeling dose for decommissioning.
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Resolution: DWM plans to identify a research user need and request research to be conducted.
We will submit this for tracking as a generic issue when the user need memo is issued.
WM-4 Radionuclide Transoort and Behavior in the Environment - This involves a variety of issues related to radionuclide transport including -- (1) developing a methodology for selecting and testing groundwater flow and transport models, (2) demonstrating surface complexation modeling in per'ormance assessment, (3) field studies and analysis of soil property data, and (4) develop'ng and testing infiltration evaluation methodology. This issue has broad applicability to decommissioning of contaminated sites, radioactive waste disposal, and uranium remvery activities.
Resolution: Continue ongoing generic research project.
We will submit this for tracking as a generic issue.
WM-5 Predictino Post-Restoration Groundwater Quality Monitorino and Restoration Pumoino Volumes at Uranium in Situ Extraction Facilities - This issue involves developing an approach to determine an appropriate period of post-restoration groundwater quality monitoring at uranium in situ leach extraction facilities. It also involves developing a methodology to calculate the groundwater pumping volumes needed for restoration of the mine zone in aquifers associated with ucanium in situ extraction facilities. This issue has applicability to assessments of all uranium in situ extraction restorations.
Resolution: Continue research defined in user need memos dated 4/1/97 and 4/8/97, We will submit this for tracking as a generic issue.
WM-6 Maouacy of Part 150 Criticality - As a related matter to WM-2, the Envirocare review and the transfer special nuclear material (SNM) licenses to Agreernent States for the Richland and Barnwell low-level waste disposal facilities surfaced an issue regarding the criticality safety of low-level waste as it is placed for deposal. Although individual shipments of waste may remain below critical mass limRs in Part 150, placement of multiple shipment in close proximity could possibly result in a criticality accident. NRC staff's initial assessment concluded that the likelihood of such a criticality was very low under present operating procedures at the waste disposal facilities. However, changes in these procedures could substantially reduce, if not eliminate, this safety margin. The
! State of Washington retains a satisfactory license condition on the areal density of SNM I for the Richland low-level waste disposal facility. In contrast, the State of South l
Carolina did not impose an areal density limit on SNM emplacement in the disposal trenches; this condition was deleted upon transfer of regulatory authority from NRC to the State. It is not clear whether the Agreement States recognize the potential need for l restrictions on the emplacement of SNM waste. They may assume that a criticality is 4
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precludad by adherence to the critical mass limits in Part 150. This could affect existing low-level waste disposal facilities, as well as planned disposal facilities.
Resolution: DWM has proposed to develop guidance on acceptable methods to assess and prevent an inadvartent criticality during the emplacement of low-level waste for disposal. DWM also plans to coordinate this guidance with the Agreement States.
These plans are described in SECY-98-010, which is presently being reviewed by the Commission. Over the longer term, the Commission may wish to require Agreement States to evaluate emplacement criticality safety under 10 CFR 61.16(b)(2).
We will submit this issue to RES for tracking as a generic issue.
WM 7 Adeouacy of 0.05 weiaht oercent limit in Part 40 - Recent assessments of potential recycle / reuse scenarios have raised questions about the unconditional release of chemical mixtures, compounds, solutions, or alloys that contain less than 0.05 weight percent source material (exempted under 40.13). Some assessments indicate that members of the public could receive doses exceeding 100 millirem per year.
Resolution: RES is coordinating a contractor report entitled " Systematic Radiological Assessment of Exemptions for Source and Byproduct Materials." The report addresses a number of exemptions including 40.13. It is currently undergoing peer review. In addition, it is our understanding that two rulemakings related to this issue are currently on hold. One rulemaking would revise the definition of source material, and the other rulemaking would require NRC approval before exempt quantities could be transferred to unlicensed persons. l i
We will submit this item to RES for tracking as a generic issue.
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FCSS FC-1 Criticality Benchmarks >5% Enrichment - The availability of experimental data to support nuclear criticality safety (NCS) evaluations does not provide sufficient information to validate NCS calculations for all required configurations at U-235 enrichments in the range of 5-20%. This issue potentially affects uranium enrichment, commercial fuel fabrication, transportation, use in reactors, and both fresh fuel an spent fuel storage.
Currently, the commercial fuel facilities are not authorized to produce fuel in excess of 5% ent;fned uranium. However, more licensees are showing interest in increasing
, enrichment levels for their processes. One fuel fabricator has indicated intent to submit a license amendment request for processing >5% enriched uranium in July or August l 1998.
Resolution: In the short term for some configurations, NCS calculational methods may be extended beyond the range of experimental conditions. However, various calculational methods should be used to provide a better estimate of the bias, uncertainties, and sensitivities in the extended area. NRC reviewers should ensure that 5
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licensees who wish to operate in this range have made correlations in the expected compositions ano affected variables, and have applied sufficient conservatisms in the calculations and margins to ensure safe operations.
In the long term, NMSS has requested the cognizant ANSI committee to assess the need for a new industry standard or revisions to existing standards to ensure safety in processing and using uranium enriched to greater than 5% in addition, NRC needs to obtain additional criticality benchmark experimental data for representative systems with uranium enrichments between 5-20% Recent research performed for NRC by Oak Ridge National Laboratory shcws promise in allowing the extrapolation of existing criticality codes to cover the lower end of this range for certain systems. Los Alamos National Laboratory has done some experiments in this area and is still working on the l study. The International Criticality Safety Benchmark Evaluation Project is also I compiling experimental data from various countries which may be applicable. We plan to continue monitoring such activities for applicability to licensed activities.
We will submit this for tracking as a generic issue.
FC-2 Exoandino the definition of SNM to include other fissile material- The definition of special nuclear material (SNM) means plutonium, U-233, U-235, or any other material '
the Commission determines to be SNM. Questions have been raised about the need to expand the definition of SNM to include other fissile materials (i.e., americium, californium, etc.). This will not be an issue for NRC unless we assume greater responsibility for independent oversight of DOE's nuclear complex. DOE facilities ;
possess and process substantially greater quantities of these additional fissile materials i than current NRC licensees.
Resolution: No action for NRC until long term responsibility for external regulation of DOE nuclear facilities is clarified. In the interim, NRC simulated regulation of the Oak Ridge Radioisotope Engineering Development Center in DOE External Regulation Pilot 11 will provide insights into criticality safety, safeguards, and other aspects that are unioue to these additional fissile materials. NRC will be able to use these insights in determining the need for, and issues associated with, potential rule changes that would be appropriate to address safety and safeguards concerns.
We do not intend to submit this for tracking as a generic issue.
SFPO SF-1 Burnuo Credit - DOE is seeking approval of a methodology for taking credit for fuel burnup in the criticality safety analyses of spent fuel containers (storage, transport, and disposal). Current criticality analyses assume spent fuelis fresh and unirradiated.
Under burnup credit, these analyses will include the reduction in reactivity that occurs when the fuel is burned in a reactor. A topical report on the methodology was submitted for NRC review on May 31,1995.
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Resolution: In response to NRC's request for additional information (RAI), a revised topical report was submitted on May 15,1997. A second RAI is has been drafted and is presently in the concurrence process. Burnup credit can save costs by allowing more spent fuel to be placed in a container which reduces the number of containers and shipments needed. j SFPO is handling and tracking this issue which contains a number of sub-issues. We do not believe this is a safety issue, and do not intend to submit it to RES for tracking as j a generic issue. However, assistance from RES may be requested in the future for specific technical expertise to help evaluate some of the more complex sub-issues.
Otherwise, all future reviews will be in-house.
SF-2 Drv Cask Weldino Cracks - During nondestructive testing (PT/MT and helium leak test) of the VSC-24 dry fuel storage container closure welds, cracks have been discovered on four containers. Each of these weld cracks was repaired before being placed into service. The function of the closure welds is twofold -- to maintain a confinement boundary to preclude leakage of radioactive material and to maintain an inert gas environment within the container to preclude long term cladding and fuel degradation from oxidation. These welds are to remain intact for normal, off-normal, and accident ,
(drop) conditions. 1 Resolution: In May 1997, NRC issued CALs to SNC and each VSC-24 user to determine the root causes of the weld problems and develop corrective actions to j preclude recurrence. SNC has determ!ned that the root causes for each occurrence were different and proposed several corrective actions to preclude recurrence of the identified weld cracking problems. Of concern is the potential for delayed cracking or introduction of subsurface defects (via a weld process malfunction) that would not be l detectable via current nondestructive test requirements. In response to a staff RAI, SNC and users of the VSC-24 system have committed to assessing the feasibility of a volumetric examination technique (UT) for the structural-lid closure weld to provide added assurance that this weld does not contain any unacceptable subsurface flaws.
This method would be used to inspect structural-lid closure welds on future containers and for re-examination of previously loaded containers (19 totalloaded to date).
The potential for the introduction of flaws during welding processes is applicable to the l final closure welds on any dry cask storage or disposal system design. In the past, a double welded closure for the final seal welds has been accepted because of the perceived difficulties involved in performing a volumetric examination of these welds.
However, current UT technology may provide a means to perform a volumetric examination of these welds. Volumetric examination of the closure welds would ensure consistency with requirements to volumetrically inspect other confinement system welds and consistency with the ASME Code.
We will submit this issue to RES for tracking as a generic issue.
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SF-3 Package Testing - In 1997, an inspection of Amersham Corporation identified problems with the adequacy of Amersham's package testing program. Specifically, the puncture test was performed using a bar that was not mounted as specified in 10 CFR 71.73(c)(3). An inspection of Source Production and Equipment Company (SPEC) found the same problem.
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( Resolution: On June 10,1997, a confirmatory action letter (CAL) was issued to confirm i
that Amersham would retest their Type B packages. On June 24,1997, a CAL was issued to confirm that SPEC would conduct retesting also. On September 23,1997, t Bulletin 97-02 was issued to all holders of NRC Certificates of Compliance for transportation packages. The responses to the bulletin identified packages that were not puncture tested in accordance with 10 CFR 71.73(c)(3). In addition, there were a few packages for which the Certificate holder was unable to determine whether the puncture test was performed correctly. The followup of the bulletin responses is ongoing.
t We will submit this ise"e to RES for tracking as a generic issue.
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