ML20248F520

Safety Evaluation Supporting Amend 13 to License SNM-1107

ML20248F520
Person / Time
Site:	Westinghouse
Issue date:	06/02/1998
From:	Adams M NRC
To:
Shared Package
ML20248F493	List: ML20248F490 ML20248F510 ML20248F520
References
NUDOCS 9806040308
Download: ML20248F520 (2)

Text

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70-1151 LICENSEE:

Westinghouse Electric Corporation Commercial Nuclear Fuel Division Columbia, South Carolina

SUBJECT:

SAFEGUARDS EVALUATION REPORT: SUBMITTAL DATED DECEMBER 18,1997, REVISIONS TO FUNDAMENTAL NUCLEAR MATERIAL CONTROL PLAN BACKGROUND By cover letter dated December 18,1997, Westinghouse submitted three revised Chapters 2.0, 4.0, and 6.0 of the facility's Fundamental Nuclear Material Control (FNMC) Plan. The revision of the Plan was made to address modifications of measurement standards limits and proposed practices for the laundry measurement system. The revision was requested pursuant to the provisions of 10 CFR 70.34 since the proposed changes were dealing with modified practices.

By letter dated May 29,1998, Westinghouse submitted additionalinformation regarding the criticality safety basis of the laundry.

DISCUSSION Westinghouse submitted various changes to its FNMC Plan, which affected the text of three chapters. All revisions are made by section with a new designated date and revision number.

These Plan changes are summarized as follows:

Control limits of working calibration standards are revised and updated for

. nondestructive astay (NDA) methods (gamma spectrometer and SAM-II), resulting from routine statistical analysis of pooled measurement data points throughout the material balance period.

l The use of a nominal factor in grams U-235 per unit mass for contaminated laundry will replace the current measurement system in which each individual container of laundry is measured by NDA. The laundry measurement system is a non-key or non-accountability measurement system, which is classified as not contributing to the standard error of inventory difference. The use of a nominal factor is justified since documented evaluation studies showed consistent results agreed within the l

uncertainties, current controls are in place to prevent unintentional commingling of nuclear material with contaminated laundry, and the nominal factor is determined and updated on an annual basis with representative laundry containers. In addition, the use of a nominal factor is consistent with the acceptance criteria discussed in Section 2.5 of NUREG-1065 (Rev. 2, December 1995), " Acceptable Standard Format and Content for the Fundamental Nuclear Material Control (FNMC) Plan Required for Low-Enriched Uranium Facilities."

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All of the proposed changes have been previously discussed with the NRC MC&A licensing reviewer, and upon review of these submitted changes, they were found to be acceptable.

CRITICALITY SAFETY REVIEW The Criticality Safety Basis for Laundry submitted on May 29,1998, stated that: (1) there are no

. pockets in the protective clothing, which could collect SNM, (2) the dirty clothing is stored away from substantial quantities of SNM, (3) the historical NDA assay results show 0.36 g U-235 per laundry bag, but, the new FNMC plan will use a factor of 1.0 g per laundry bag, (4) normally there are no more than fifty bags in storage, for a total of 50 g U-235 using the new factor, and (5) based on the existing CSE for storing drums, the laundry could be piled / stored in an unlimited fashion and still not present any adverse condition for criticality.

The use of the NDA factor of 1.0 g U-235 per bag assumes a worst case of 2.7 times the amount of SNM expected. Also, assuming six times the number of bags that is normally present, there would be 300 g U-235, which is below the safety limit. It is unlikely that this situation would arise.

Because the NDA factor will be reevaluated annually using data collected from both historical and future readings and, based on the new factor, the criticality safety limit will not be exceeded, the staff have concluded that an accidental criticality in the laundry area is not credible.

l ENVIRONMENTAL REVIEW The staff have determined that the proposed activities involve safeguards plans and material accountability, which are categorically excluded from the requirements to prepare a site-specific environmental assessment. Therefore, in accordance with 10 CFR 51.22(c)(12), neither an environmental assessment nor an environmental impact statement is warranted for this action.

CONCLUSION l

The staff concludes that an accidental criticality in the laundry area is not credible. The staff concludes that the licensee's FNMC Plan revision is acceptable, and that the revised Plan contains L

appropriate and necessary commitments to satisfy applicable MC&A regulations specified in 10 l

CFR 74.31. Therefore, Safeguards License Condition SG-1.1 has been revised to incorporate the

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revised Plan.

b The Operations Branch (FCOB) inspection staff has no objection to this proposed action.

EHINGlP.ALCDfiTBlBUIQBS Thomas N. Pham Susan Chotoo ^

q Harry Felsher b

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