ML20236H615
| ML20236H615 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 07/14/1987 |
| From: | Malody C SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER |
| To: | Bidinger G NRC |
| References | |
| 28421, NUDOCS 8708050265 | |
| Download: ML20236H615 (12) | |
Text
JUL 16 '87 10:03 ANF RICHLAND WA P.2 RETURN TU 3915-ss "2b-5267 ADVANCEDNUCLEARFUELS CORPORATION
?$$$$eN!?$$?s.*ieN"
of, %Rg July 14,1987 r-RECEIVED \\g3 Q
JUL211987 lPt-U.S. Nuclear Regulatory Commission 9 u,$, NUCLEAR REGULATORY!)
~
Attention: Mr. George Bidinger
+ cow.ussion
/-
gjll$n
?
7915 Eastern Avenue g
((g#
/
Dear Mr. Bidinger:
l l
Attached are copies of revised pages to our license appilcation and a copy of a safety analysis of two credible events with the incinerator operation.
It is my understanding that once we have reached agreement on the contents of this package, all licensing issues associated with this renewal will have been resolved.
Sincerely, I
bY/
C. W. Malody, Manager Corporate Licensing CWM:jrs Attachment l
As Stated f,%
~Y ~ *,
~
f j
l g]y 4
a DOCKETE7 gg
'x r
y I
- N Q
.[/
]
JUL2119872) ;12 y
a
((Eli N
4 s,
=
Q v
- fa "
s Qgy#E m
a Q
UNN N
- AGE' OF ATTN k
(\\
I B7080g265hO{257 b
%aA,.
ocx ena eoa c
AN AF91LlA?R 05 MAA996tM LtN.ON cawu
\\
N&
l
Jut is 'e7 10:03 ANF RICHLAND WA P.3 ADwUtCSDNUCLEARFUELSCORPORATION ANF-2 SPECIAL NUCLEAR MATERIAL LICENSE No. SNM-1227, NRC DOCKET NO. 70-1287 PART I - LICENSE CONDITIONS gg The' responsibilities of the Criticality Safety Component include the following:
1.
Providing technical boses, criteria, and methods related to nuclear criticality safety.
2.
Preparing the Nuclear Criticality Physics Methodology document and the Criticality Safety Standarus.
1
)
3.
Providing criticality safety determinations for designs and procedures.
4.
Providing professional cdvice and counsel concerning matters within his cognizance.
S.
Membership in the Emergency Codro.
6.
Performing compliance inspections.
7.
Approving Criticality Safety Speelfications.
All determinations concerning nuclear criticality safety shall b'e reviewed by a second-party reviewer who shall be knowledgeable in the technical dato and quollfled in the techniques of criticality physics.
Second-party reviews shall be arranged for by the Criticality Sofety component and may be either from within the component or by on outside reviewer.
safety calculations and reviews shall be documented and documents shall beAll nuc held in permanent Company records.
Calculational detalls, work sheets, etc.,
shall be held for o minimum period of six months following termination of the process or operation reviewed.
2.2 Personnel Educotton and Experience Requirements Responsibilities and authorities of all line managers /shall be provided in writing.
Hiring of managers and key professlorals in plant operations, health physics and ' nuclear criticality safety shall be subject to approval by the Vice President, Engineering and Production.
1 The Monoger-Operottons and'monagers in engineering and technical
' 'GHM I
services functions, which have responsibilities for the processing, storing or handling of special nuclear materials shall have a minimum of two years of experience in the nuclear Industry and a degree in Science or Engineering.
There are certain other positions where a technical degree is not required such es the Manager, Maintenance.
In those ecses; the incumbent will have adequate job trotning, and technical support and overview will be ovalloble Specific requirements for those key safety professionals whose major respon.
sibility is In a safety field are listed below.
AMENDMENT APPUCATION DATE:
PAGE NO.:
/,.
RAPfFAX NO, 11,Q XN NF F01422 ' (s/87)
PAme xor k\\
/
j LTTN
\\
JUL 16 '87 10:04 ANF RICHLAND WA P.4
~.
ADVANCEDNUCLEARFUELS CORPORATION ANF-2 SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM-1227, NRC DOCKET NO. 70-1257 l
PART l - LICENSE CONDITIONS I
R EV.
3.
Contaminated Redlocetive Materialt Areas. Visible contamination in these areas and/or smecrable coritamination in excess of 10,000 dpm (alpha) per 100 cm2 will be cleaned up immediately. These limits are not opplicable to nonroutine tasks being conducted under special controls.
4.
Plutonium Contaminctlan. Plutonium contamination is limited to:
i 100 ppm /100 cm2 average fixed 300 dpm/100 cmj removable mexlmum fb;ed l
20 dam /100 cm 3.2.6.2 Release of Personnelt Materiots, Equipment, Facilities and Shioments l
Contamination surveys are performed en allrpersonnel leaving contaml-l l
noted arecs, on all materials, equipment and facilitles to be released from l
radiation protection requirements, and on all 'ncoming and outgoing shipments of radioactive materials. Release of equipment and packages from the plant site or to clean areas on-site shall be in accordance with NRC Guidelines dated May 1987 (see Appendix A).
l 1.
Personnel.
Personnel contamination, surveys are conducted accord-i ing to the following schedule:
l All persons leaving contaminated creas are reqsired to survey l
a.
themselves for contamination with survey Instruments located at respective step-off creas after removing protective clothing and prior to leaving the step-off.orea.
b.
Personnel are not released to eat or leave the respective facility, except with the approval of the Radiological and Industrial Safety Supervisor and the respective f acility of 200ll)f their personal cloth g is contaminated in excess manager i dpm per 100 e (alpha) direct or skin is contaminated in excess of 200q dpm per 100 cm2 (cipha).
9 c.
Cloth protective clothing is not reused If the contamination exceeds 1000 dpm/l00 cmZ alpha. Rubber shoe covers shall not be reuse dpm/100 cmj cipha.If after cleaning contamination exceeds 5000 During the work day, protective clothing l
In a contaminated crea will be chcnged If contamination is visible / exceeds 10,000 dpm/100 crn2 alpha.
I 200 dpm per 100 cm2 (olpha) representa the practical lower detection
!cvel for most direct-reading contamination survey instruments.
AMENDMENT APPLICATION DATE:
P AGE NO.:
g 3,9
/*
RAPiW M]3'g XN NF.F01622 (6/87)
[
PAGE OF ATTN.
U
JUL 16 '87 10:05 ANF RICHLAND WA P.5 ADVANCEDNUCLEARFUELSCORPORATIGN ANF-2 SPECIAL NUCLEAR MATERIAL LICENSE NO. $NM-1227, NRC DOCKET NO. 70-1257 PART I - LICENSE CONDITIONS PI E V.
okm=
A safety margin to assure suberificality. A value of 0.05 is used for normal conditions. A value as low as 0.02 may be used for abnormal conditiors if justifled b'y a sensitivity analysis.
4.2.3 _ Geometry Whereve'r practicable, reliance is placed on equipment designs which physically Ilm1t the dimenstens of units containing special nuclear material.
Sofe dimensions may be established by utilizing the following safety factors:
1.
The' kpff of the unit mcy be established by using the guidelines given in Section 4.2.2.
2.
Critical dimensions multiplied by the cpplicable safety factors given in Tables 1-4.1 and I-4.2.
Where appilcoble, dimensional limitations include an cllowance for fabrication tolerance and/or potentloi dimensloral changes from corrosion or mechenical distortion.
i 4.2.4 Neutron Absorbers l
Criticality safety ma obsorbers, such as ccdmium, y be assured thrcugh the use of fixed neutron boron, etc., provided that:
1.
Neutron obsorbers are designed and fabricated as an integral port of the equipment.
2.
Inspections to verify the cont neutron absorber structure a,inued integrity of the equipment and re performed on established time frequencies suf ficient to insure their ef festiveness. Results of these inspections, and the basis for the inspection frequencies are recorded and audited.
fd'
-3.
Vlable alternatives to the use of fixed neutron obsorbers to assure
]f,,
criticality safety do not exist.
4.2.5 Concentration Control eggp Rellonce for primary criticality control may be placed on concentration controls in creos where geometry control is not practicable, and where the noture of the process and operations make violation of the concentration limit AMENDMENT APPLIC AtloN DATE:
PAGE NO.
RAPlFM m TQQ XN NF.Fo1422 (8/67)
PAGE L( OP
/
/
vrTN.
l\\
/
I fut 10:05 ANF RICHLAND WA P.6
.. su.0km>eIED NUGLEAR FUELS CORPORATION
~
s ANF-3
- j SPECIAL NUCLEAR MATERIAL LICENSE No. SNM-1227, NRC DCCKET No. 70-1207 f
PART I - LICENSE CONDITIONS REV.
.i unlikely even af ter failure of cny single control.
Concentration control may be applied to both overmoderated and undermoderated accumulations of material as described below.
F 4.2.5.1 Concentration Controf - Solutions The concentration of fissile material dispersed or dissolved in another medium may be limited to prevent criticality, provided that:
1.
The concentration limit shall not exceed 50 percent of the minimum critical concentration in the system being evaluated.
2.
l The concentration ilmit shall assure that the keff meets the limits In Section 4.2.2 at normal and credible abnormel conditions.
The abnormal condition evaluation will include:
I Precipitation of solid fisslie material to the most reactive a.
t credible extent.
b.
Increasing the concentration of the fissile material to the maximum credible extent due to effects such as evaporation.
For arrays of units on concentration control, additional-c.
abnormal conditions to be evcluated (as applicable) include
/
crray size, unit spacing, and interspersed moderation effects.
4.2.5.2 Concentration Control - Powders and Pellets The concentration of hydrogenous material within the fissile material may be limited to a small percentage by weight of the fissile material (moderation control) to prevent criticality, provided that:
1.
The permitted concentration of hydrogenous material shall be equalt to or less than fif ty percent of the critical concentration for the system in questioni 2.
The maximum reactivity of the system full of the material in question, under the worst credible accident conditions, shall be Ifmited by the guidelines glven in Section 4.2.2; and 3.
The material shall' be contained within a fireproof barrier or in o process area contolning limited soure:as of hydrogenous material, in M 4,.
the obsence of a fireproof barrier, special' controls shall be used to prevent fires and to control the use of moderators in fire fighting In such process creas.
I l
AMENDMENT APPLICATION DATE:
P AGE NO.:
y p; XN.NF,F01422 (6/87)
PAGE A.T7n 5... cp ~.\\\\...,.................
e,...
...,. p
,.....u._...
g
JUL 16 '87 10:06 ANF RICHLAND WA P7
~d ADVANCEDNUCLEARFUELSCORPORATION ANF-2
$PECIAL NUCLEAR MATERIAL LICENSE NO. 8NM-1227, NRC DOCKET NO. 70-1257 PART I - LICENSE CONDITIONS R E V.
been established which are odequate to casure that the effluent treatment systems function properly and that immediate steps are taken to rectify any observed deficiencies as soon as practicable.
Lift Station where the total combined liquid effluent from the pla
(
pumped to the Richland Municipal Sewsrage System.
effluent is continuously sampled and the flow is measured prior to the liftThe combine station.
The composited samples are analyzed for urenlum and regulated chemicals. Any increase in the chemical or uranium content of the composited samples statistically above those limits described in 10 CFR 20.303 or the State of Washington Liquid Waste Discharge Permit shall be cause for on immedicte Investigation of the problem and o;;propriate corrective action.
5.l.2.1 Sanitory Wastes other liquid wastes prior to being discharged to the ANF-City Lift S l
S.I.2.2 Process Cooling Weste Wcter Process cooling waters are isolated from the octual process atmospheres by double phystr ol barriers.
Process cooling water is discharged from various facilities (with the exception of the ELO -Bullding) vic building sewer systems separate from both sani' tory and process chemical waste sewers.
waters may be disposed of by any one of the following methods:The process cooling w 1.
Discharged to the municipal sewerage system; 2.
Discharged to o seepage pondl 3.
Used to' Irrigate Advanced Nuclear Fuels propertyi or 4.
Olscharged to the Advanced Nuclear Fuels Process Chemical Weste Storage Lagoon System.
5.l.2.3 Process Chemical Westes All process rodtooctive liquid woutes ore routed to lagoon storage. Some logoon solutions require further trectrnent prior to discord to the sewer. These gf solutions moy be trected as necessary for cher,1 col /rodlocettvlty removal prior to release to the sanitary sewer system.
AMENDMENT APPUCATION nATE:
- g PAGE NO, 5-3 RAPIFAX NO. 7 3 Q XN.NF Foi 422 (5/87)
/
/
PAGE OF
/
...g m..
q.?
((
.;.,,......w.. w. c.s.k w. a... ~..
JUL 1687 10:06 ANF RICHLAND WA P.8 i4DMSNGED NUCLEAR FUELS CORPORATION ANP-2 SPECIAL NUCLEAR MATERIAL LICENSE NO. UNM-1227, NRC DOCKET NO. 70-1267 PART I - LICENSE CONDlTIONS PIEV.
The release of chemical wastes to the sanitary sewer system is con-trolled by local authorities vio o permit system.
The licensee will notify i
NRC, for Informational purposes of any occurrences which, by permit, require reporting to the authorities.
5.l.3 Process Chemical Weste Storage Lagoon System The lagoons are sealed on the bottom and all sides with an impervious liner to prevent teckage of the lagoon contents to the groundwater. The liner consists of a double layer of impervious material separated by c Icyer of sand. A system of sampling tubes is installed in the Intermediate sand layer to provide sompling copobility between the liner layers to permit detection of leaks in the first barrier.
Routine monitoring of the integrity of the upper liners will be cecom-allshed by drawing a vacuum on each group of the "between-liners" sampling leads at least monthly.
In the event that a significant amount of liquid is pumped from ony sampling heod(s), the liquid will be cnolyzed for fluoride end uronium content. If urenlum and fluoride are present, on investigation will be Initiated which will include:
1.
Additional between-liner sampling; 2.
Lagoon solution sampling:
3.
Checking the Integrity of the bottom Hypolon liner offected logoons; for lagoons numbers I and 3 by cetivating son.pling !!nes located between the bottom Hypclon liners and the originct Petromot liners of these two lagoons; or 4.
Checking the Integrity of the bottom Hypolon liner of lagoon number 4 by sampling the three dry wells associated with the three
" French Drains" located under the bottom liner of this logoon; and 5.
Making maximum use of the lagoon test well system.
The between-ilner sampling system is the first line of defense for detect-Ing liner lecks and sampling is scheduled monthly.
The beneath the bottom liner leck detection system is cetivated at any time the first liner is deter-mined to be leaking to confirm the Integrity of the bottom liner, Test wells are provided around the Lagoon System os a backup to provide the copobility to detect lecks penetrating both liner layers and to follow the movement of any groundwater contamination, in addition, these test wells are sampled periodically as a part of our environmental monitoring progrom to maintcln o general overview of concentrations in the g oundwoter of those chemicals which are representative of lagoon solutions as well as urenlum.
AMENoMENT APPLICATION DATE:
PAGE NO.:
RAPlFAX NO, 7 M Aj XN.NF.Fo1822 (8/87)
PAGE OF
.. w.
ATTN.,.
O,
r 61 Ll
n - - - -
JUL 16 '87.10:07 AtF RICHLAND WA P.9-
+
5 l
ADifANCED NUCLEAR MIELS CORPORATION ANF-2 8PECIAL NUCLEAR MATERIAL LICENSE NO. SNM-1227, NRC DOCKET NO. 70-1257 PART I - LICENSE CONDITIONS R E V.'
periodleclly as a part of our environmental monitoring progrom to maintcIn a general overview of concentrations -In the groundwater of those chemicals which ore representative of lagoon solutions es well as uronium.
In the event that a lack in on. upper liner is detected, 'repolr of the liner will be scheduled and completed. A report of the leak Including results of the investigation and corrective actions taken will be forwarded in writing to the Director, Region V within 90 days of detection of the leck.
5.2 Environmental Monitoring Advanced Nuclear Fuels conducts a routine environmental surveillance program in relation to the operation of the Richland Plant.
Surface and j
groundwater somptes are collected from strategic locations in the environment h
and onelyzed for pertinent chemicals and uranium.
1 5.2.l Surface Sampling m
Sampling stations have been established both on-slte and off-site near points of expected maximum concentrations.
The schedule for the various
/
sampling stations are identified in the following tcble. See Figure I-5.1 for the location.
l Somple Sample Sarnpling Station Type Frequency Analysis i
Soil Quarterly Urenlum 2
Soll Quarterly Uranium 1
3 Air Monthly Fluoride 4
Air Monthly Fluoride 5
Forage Monthly!
Fluoride L
6 Forage Monthly Fluorlde 1
5.2.2" Groundwater Scmp!!no i'
Potential releases to the groundwater from the liquid waste storage
'i logoons are monitored by sampling the "between liners." leak detection system.
l l
If liquid la found en investigation is initiated. Test wells around the periphery of t e lagoon system are monitored to indicate whether leaks have penetroted i
Curing the growing secson only (April-Octcber).
I i
e b
e g p,p g g gg XN NF pot 822 ' (6/Br)
PAGE g OF q
[
Am r
m JUL 16 '87 10:08 ANF RICHLAND WA P.10
~ ~~~-- -
ADVANCEDNUCLEARFUELSCORPORATION M -2
-_SPECIAL NUCLEAR MATERIAL LICl!NSE NO..-SNM-1227. NRC DOCKET NO. 70-1257 PART I - LICENSE CONDITIONS REV.
ococentrations and movement of chemicals in the groundwater. The ground-water sampling progrom is provided by the following table.
See Figure I-5.2 for the locations of the sample stations.
l Presence of liquid Monthly Lagoon interliner Grob l
sampling system l
Cross Alpha / Beta 2 Quarterly Well Group I Grob Gross Alpha / Beta 2 Semi-ennually Well Group 2 Grab 1
Monitoring Well Group l is Wells I-7, i1,12,13 and 19-21.
Monitoring Well Group 2 is Well 9, 14, 15, 16, 5.2.3 Sanitory Sewer Sludge Sampilno j
The release of radiacetive material to the sanitary sewer system is controlled and monitored as described in preceeding Section 5.l.2 of this
)
l application. At the Richland sewage treatment facility, the sludge is continu-
{
ously removed from the process, dewatered.to a semi-dry solid and trucked to c sanitary landfill on a dally basis. Samples of sludge are taken monthly by j
the licensee and analyzed for uranium. The analyses are converted to pico curles of urenlum per gram of sludge as transferred to the landflll, if a i
running overage of the analyses over a six month period exceeds 25 pico j
curles per ' gram or any single confirmed results equal or exceeds 30 pico curies on immediate investigation will be recuired and a plan of action instituted.
The action plan as o minimum will require o reduction or even elimination of discards to the sewer system until the sewer sludges contain less than 25 pice curies uranium per grcm.. A report of the results of the Investigation including permanent corrective action will be forwarded to the Director, Region V within 60 days of the dete: tion of limit violation.
l
\\
, y,.-
j i
i I
nuh6 l
2 The analytical method shall be capable of detecting 5 pleo curies per liter olpha and 15 plco curies per liter beta.
i AMENDMENT APPLICATION DATE:
jg P AGE NO.:
/
nmmx na, n x
PAGE q OF
/
Ami 0l
JUL 16 '87 10:08 ANF RICHLAND WA P.11 INCINERATOR OPERATION. SAFETY ANALYSIS The incinerator and controls have been engineered to detect and correct or shutdown whenever events occur which have strong safety implications. In addition we have onalysed two unlikely but credible events end the results of that onalysis is summarized below. The two events are a fire in the sorting hood and pressuri-zotion of the Incinerator by including an aerosol spray paint can in a box of feed.
Sorting Hood Fire In the unlikely event that a fire occurs In the waste sorting hood the release to the environs would be minimal. The fire would damcge the sorting hood resulting in loss of confinement to the operating area and the fire could spread to the overhead feed conveyor thus contributing to equipment damage and spread of contamination to the opercting area. The estimated maximum quantity of cantam-Inated combustible waste material which could be involved in the fire is 900 pounds containing about 6 kg of low-enriched uranium.
The fire would be detected by operating personnel and/or the building fire detection system.
The City of Richland fire department would automatleclly be notified to combat the fire.
Since the system is under safe batch control assuming full moderation and reflection, water could be used to extinguish the fire without crificellty concerns.
The fire would result in high surface and airborne contamination levels limited primarily to the incinerator operating area. The exhaust ventilation system pre-filters and two-stage HEPA filters would confine the contamination to the produc-tion oreo. A fog deluge system is Installed immediately upstream of the final HEPA filter bank to protect the filters from burning debris and heated air should a fire occur in the exhaust duet containment system.
Assuming 10 percent of the uranium is picked up by the exhaust ventilation system, the overall release of uranium to the atmosphere via the building exhaust stack would be less than 0.lS milligrams of uranium or less than I.Sx104 uCl. If this release were to occur over a 30 minute period the uronlem concentration at the fence line would be below those limits in 10 CFR 20, A?pendix B, Table 11.
Incineration of an Aerosol Spray Prfnt Can All waste feed to the incinerator is manually sorted to remove hazardous and noncombustible. ltems.
The combustibles are packaged in cardboard boxes for incinerator feed.
if during the manual sorting operoflon, an aerosol can of spray palnt is inadvertently packaged with the combustible waste, the can would rupture in the primary chamber releasing the contents.
A typical con of s contains 13 ounces of material consisting of obout 30 wt% toluene, pray point 25 wt%
methylene chloride, 6 wt% resin, and 30 wt% propellant.
Depending upon the operating conditions.at the time of release, a portion of the combustible gases would be oxidized in the primary chamber with the remainder being burnt in the secondcry chamber.
wm na, - D PAGE op
(
et 1O g
g
.a
. a. ~ - - ~ w L
. a..... ~.....
JUL 16 '87 10:09 ANF RICHLAND WA P.12 The release would momentarily pressurize the incinerator (estimated at less then 0.5 psi) which would result in release of uranium contaminated ash to the operating This surge in pressure would shutdown the incinerator which would close a area.
block valve in the air supply line.
The process off-gos system would continue to function normally.
The momentary pressurization would result in a small backflow of combustion gases conta!ning ash into the combustion air supply piping ahead of combustion air dampers but would not release contamination to the atmosphere via the combustion air Intake due to the high (approximately 2 psi) upstream combus-tlon air blower pressure.
No equipment damage is expected except for the remote possibility that the ruptured can could damage the primary chamber temperature arobe or oxygen analyzer. The exhaust ventilation system prefilters and two-stoge
-lEPA filters would confine the contamination to the production area.
Assuming a 9 kg incinerator inventory with 5 percent release to the operating crea,10 percent of which is picked up by the building exhaust ventilation system, the overall release of uranium to the atmosphere via the building exhaust stock would be less than 0.011 milligrams of uranium.
1 e
RAPlFAX NO, PAGE OF srm u
q
N 4
g an O
(
y L
j
\\
t'
,/
I s
4:
}
\\ - /.
,[
4
\\
\\
a
\\,
y s'*
g
\\
f
.. % N v
N 3,,
s r
m.:^
,%f V-sJ,,
s x
1
?I N0. _.
[__
. f
(,
,, I
[
-- -.._...__/
b.
j n y/,
a
- g. - /
""***M.-n,,.
! '. i f
(. j,.
... ~.
t o-io n
.