ML22271A964
| ML22271A964 | |
| Person / Time | |
|---|---|
| Site: | SHINE Medical Technologies |
| Issue date: | 09/28/2022 |
| From: | SHINE Technologies |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML22271A962 | List: |
| References | |
| 2022-SMT-0101 | |
| Download: ML22271A964 (9) | |
Text
ENCLOSURE 1 SHINE TECHNOLOGIES, LLC SHINE TECHNOLOGIES, LLC APPLICATION FOR AN OPERATING LICENSE SUPPLEMENT NO. 31 REVISION TO THE PHASED STARTUP OPERATIONS APPLICATION SUPPLEMENT PHASED STARTUP OPERATIONS APPLICATION SUPPLEMENT CHANGE
SUMMARY
Summary Description of Changes Phased Startup Operations Application Supplement Impacts Update to include additional criticality safety controls and Chapter 6b, Chapter 13a2, accident sequences relating to backflow of target solution Chapter 13b into the iodine and xenon purification (IXP) system and enhance the description of accident sequences for heavy load drops.
A markup of the Phased Startup Operations Application Supplement changes is provided as Attachment 1. Phased Startup Operations Application Supplement markups are incorporated into the Phased Startup Operations Application Supplement revision provided in Enclosure 2 (non-public version) and Enclosure 3 (public version).
ENCLOSURE 1 ATTACHMENT 1 SHINE TECHNOLOGIES, LLC SHINE TECHNOLOGIES, LLC APPLICATION FOR AN OPERATING LICENSE SUPPLEMENT NO. 31 REVISION TO THE PHASED STARTUP OPERATIONS APPLICATION SUPPLEMENT PHASED STARTUP OPERATIONS APPLICATION SUPPLEMENT CHANGE
SUMMARY
PHASED STARTUP OPERATIONS APPLICATION SUPPLEMENT MARKUP
Chapter 6b - Radioisotope Production Facility Engineered Safety Features Figure 6b.2-1 provides a block diagram of the supercell confinement boundary applicable to Phase 1, 2, and 3 operations.
6b.2.1.2 Below Grade Confinement The below grade confinement is installed in full, as described in Subsection 6b.2.1.2 of the FSAR, to support initial operations of the SHINE facility.
The below grade confinement functional block diagram, as described in Figure 6b.2-2 of the FSAR, is not affected by phased startup operations.
6b.2.2 PROCESS VESSEL VENT ISOLATION The process vessel vent isolation SSCs are installed in full, as described in Subsection 6b.2.2 of the FSAR, to support initial operations of the SHINE facility.
6b.2.3 COMBUSTIBLE GAS MANAGEMENT The combustible gas management system is installed in full, as described in Subsection 6b.2.3 of the FSAR, to support initial operations of the SHINE facility.
The RPF combustible gas management functional block diagram, as described in Figure 6b.2-3 of the FSAR, is not affected by phased startup operations.
6b.2.4 CHEMICAL PROTECTION The description provided in Subsection 6b.2.4 of the FSAR is not affected by phased startup operations.
6b.3 NUCLEAR CRITICALITY SAFETY IN THE RADIOISOTOPE PRODUCTION FACILITY 6b.3.1 NUCLEAR CRITICALITY SAFETY PROGRAM The description of the criticality safety program provided in Subsection 6b.3.1 of the FSAR is not affected by phased startup operations 6b.3.2 CRITICALITY SAFETY CONTROLS The criticality safety controls described in Subsection 6b.3.2 of the FSAR are not affected by phased startup operations with the exception of the iodine and xenon purification and packaging (IXP) system.
The iodine and xenon purification and packaging (IXP) system is not installed as part of Phase 1, 2, or 3 operations. The criticality safety controls which support the criticality safety basis of the IXP system described in Subsection 6b.3.2.12 of the FSAR are installed to support Phase 4 operation.The evaluation of the uninstalled IXP cell shows that the system will remain subcritical under normal and credible abnormal conditions.
The inadvertent transfer of target solution to the IXP cell requires application of the double contingency principle to prevent criticality accidents. Lines entering the IXP cell from other cells that could credibly contain target solution are equipped with a locked closed isolation valve SHINE Technologies 6b-2 Rev. 12
Chapter 6b - Radioisotope Production Facility Engineered Safety Features inside the IXP cell that prevents target solution flow into the IXP cell. Additionally, prior to performing operations involving target solution in molybdenum extraction and purification system (MEPS) extraction cells B or C, operators confirm the position of the valves in MEPS that prevent flow to the IXP and the target solution staging system (TSSS) tank isolation valve.
To reflect installation of the IXP system to support Phase 4 operation, Figures 6b.3-1, 6b.3-2, and 6b.3-3 provide system overviews of the radioactive liquid waste storage (RLWS) system, the molybdenum extraction and purification system (MEPS), and the radioactive drain system (RDS), respectively, in Phases 1, 2, and 3. The Phase 1, 2, and 3 system overviews provided in Figures 6b.3-1, 6b.3-2, and 6b.3-3 provide configuration updates to the system overviews provided in Figures 6b.3-2, 6b.3-3, and 6b.3-7 of the FSAR, respectively. The system overviews provided in Figures 6b.3-1, 6b.3-4, 6b.3-5, 6b.3-6, and 6b.3-8 of the FSAR are not affected by phased startup operations.
6b.3.3 CRITICALITY ACCIDENT ALARM SYSTEM The criticality accident alarm system is installed prior to Phase 1 operation; therefore, the description provided in Subsection 6b.3.3 of the FSAR is not affected by phased startup operations.
6b.3.4 TECHNICAL SPECIFICATIONS The description provided in Subsection 6b.3.4 of the FSAR is not affected by phased startup operations.
6b.4 REFERENCES None SHINE Technologies 6b-3 Rev. 12
Chapter 13a2 - Irradiation Facility Accident Analysis CHAPTER 13a2 - IRRADIATION FACILITY ACCIDENT ANALYSIS The SHINE Safety Analysis (SSA) methodology, as described in Chapter 13a2 of the FSAR, was used to evaluate the impacts of phased startup operations on the SSA and the accident analysis provided as Chapter 13 of the FSAR. A hazard evaluation was performed along with a review of the current process hazard analysis for the facility to identify new or different accident scenarios, including changes to likelihood or consequences of existing accident scenarios.
The likelihood and consequences for these new or different accident scenarios were then evaluated and compared to the risk matrix, as described in Chapter 13a2 of the FSAR. Where the uncontrolled scenario resulted in unacceptable risk, safety-related controls were applied to prevent or mitigate the accident scenario. These controls were applied in a method consistent with that described in Chapter 13a2 of the FSAR.
The results of accident analysis specific to phased startup operations is summarized in the remainder of this chapter. Phased startup operations do not result in new accident categories, but the following new accident sequences within the irradiation facility (IF) were identified:
Improper target solution routing to an uninstalled irradiation unit (IU) cell Damage to an installed tritium purification system (TPS) train during the installation of another TPS train Damage to a process vessel vent system (PVVS) to target solution vessel (TSV) off-gas system (TOGS) interface line during installation of the subcritical assembly system (SCAS)
Accident sequences within the IF modified based on increased likelihood include:
Heavy load drop on the TPS Heavy load drop on an open IU cell Heavy load drop onto an in-service IU or TOGS cell Fire in the IF general area Heavy load drop on an open IU cell that has been in operation was determined to not be impacted by phased startup operations because the number of lifts over the IU cell during the short duration of maintenance evolutions in early operations are not being sufficient to increase the likelihood index for the initiating event. Heavy load drop on an open IU cell was evaluated for an IU cell not in operation and determined to be of low consequence due to the lack of source term to drive radiological dose.
Additionally, several accident sequences have reduced likelihoods or consequences during phased startup operations due to reduced frequency of operations and a reduced material at risk. These accident sequences were not reevaluated because they are bounded by the accident analysis as currently documented in Chapter 13 of the FSAR.
Two new credited engineered controls are required to prevent phased startup operation accident sequences in the IF. ThreeTwo new credited specific administrative controls are required to prevent phased startup operation accident sequences in the IF.
The following subsections provide additional detail on the scenarios listed above and the credited controls used for prevention.
SHINE Technologies 13a2-1 Rev. 12
Chapter 13a2 - Irradiation Facility Accident Analysis 13a2.1.8 LARGE UNDAMPED POWER OSCILLATIONS The information provided in Subsection 13a2.1.8 of the FSAR is not affected by phased startup operations.
13a2.1.9 DETONATION AND DEFLAGRATION IN THE PRIMARY SYSTEM BOUNDARY The information provided in Subsection 13a2.1.9 of the FSAR is not affected by phased startup operations.
13a2.1.10 UNINTENDED EXOTHERMIC CHEMICAL REACTIONS OTHER THAN DETONATION The information provided in Subsection 13a2.1.10 of the FSAR is not affected by phased startup operations.
13a2.1.11 SYSTEM INTERACTION EVENTS The information provided in Subsection 13a2.1.11 of the FSAR remains valid for phased startup operations. Additionally, a system interaction event of damage to a PVVS to TOGS interface line during installation of the SCAS was identified and evaluated. The accident scenario of fire in the IF general area leading to damage of cooling room equipment was also modified and evaluated for increased initiating event likelihood during phased startup operations.
Errors during installation of SCAS equipment in an IU cell during Phase 1 or Phase 2 operations may result in damage to the PVVS to TOGS interface line that extends into the IU cell. Damage to this line could create a preferred flow path for PVVS gas to bypass process tanks, leading to deflagration and radiological dose. This scenario is prevented through the application of a new passive engineered control of a physical barrier installed over vulnerable portions of the PVVS to TOGS interface line and a specific administrative control to limit crane hoist speed during SCAS installation.
The accident sequence of a fire in the IF general area leading to damage of cooling room equipment resulting in a complete loss of primary closed loop cooling system (PCLS) cooling in one or more IU cells or TOGS cells is modified during phased startup operations to account for an increased likelihood of the initiating event as a result of on-going installation activities.
Radiological release due to this scenario is prevented by the credited controls currently in place, as described in Subsection 13a2.2.3 of the FSAR.
Because these events have preventative measures in place, there are no radiological consequences.
13a2.1.12 FACILITY-SPECIFIC EVENTS The information provided in Subsection 13a2.1.12 of the FSAR remains valid for phased startup operations. Additionally, a facility-specific event of damage to an operating TPS train during the installation of another TPS train was identified and evaluated. The accident scenarios of a heavy load drop into an open IU cellheavy load drop onto an in-service IU cell or TOGS cell and a heavy load drop onto TPS equipment were also modified and evaluated for increased initiating event likelihood during phased startup operations.
SHINE Technologies 13a2-3 Rev. 12
Chapter 13a2 - Irradiation Facility Accident Analysis Errors during installation of TPS trains B or C during Phase 1 or Phase 2 operations, respectively, may result in damage to an operating TPS train. In the uncontrolled scenario, mechanical damage to an installed TPS train leads to release of tritium and radiological dose to workers and the public. The physical distance separating the TPS train installation locations reduces the likelihood of the initiating event. The scenario is prevented through the application of a new specific administrative control for operators to install physical barriers (e.g., roping or stanchions) around installed TPS trains to limit access to areas where mechanical damage to an installed TPS train is possible.
The accident sequences of a heavy load drop onto an in-service IU cell or TOGS cell and a heavy load drop onto TPS equipment isare modified during phased startup operations for increased likelihood of the initiating event as a result of on-going installation activities. Thisese scenarios isare prevented by athe credited control currently in place (i.e., single failure proof crane in the IF) and through the application of a new specific administrative control which requires that operators use safe load paths that avoid lifting over the TPS room.
Because these events have preventative measures in place, there are no radiological consequences.
13a2.2 ACCIDENT ANALYSIS AND DETERMINATION OF CONSEQUENCES The information provided in Section 13a2.2 of the FSAR is not affected by phased startup operations. No new accident scenarios resulting in radiological or chemical release were identified as a result of phased startup operations. The material at risk for certain existing scenarios may be reduced by phased startup operations due to fewer units being in operation; however, the scenarios as described in Section 13a2.2 of the FSAR remain bounding and no credit is taken for the reduction in consequence that would result.
13a3
SUMMARY
AND CONCLUSIONS The information provided in Section 13a3 of the FSAR is not affected by phased startup operations. The IF accident dose consequences provided in Table 13a3-1 of the FSAR bound the IF accident dose consequences during any of the initial phases of operation.
13a4 REFERENCES None SHINE Technologies 13a2-4 Rev. 12
Chapter 13b - Radioisotope Production Facility Accident Analysis CHAPTER 13b - RADIOISOTOPE PRODUCTION FACILITY ACCIDENT ANALYSIS 13b.1 RADIOISOTOPE PRODUCTION FACILITY ACCIDENT ANALYSIS METHODOLOGY The information provided in Section 13b.1 of the FSAR remains valid for phased startup operations. The methodology used to evaluate the impacts of phased startup operations is described in Chapter 13a2 of this supplement.
13b.1.1 PROCESSES CONDUCTED OUTSIDE THE IRRADIATION FACILITY The process descriptions provided in Subsection 13b.1.1 of the FSAR remain valid for phased startup operations with the exception that the iodine and xenon purification and packaging (IXP) system is not installed as part of Phase 1, 2, or 3 operations.
13b.1.2 ACCIDENT INITIATING EVENTS The information provided in Subsection 13b.1.2 of the FSAR remains valid for phased startup operations.
Phased startup operations do not result in new accident categories, but the following new accident sequences within the radioisotope production facility (RPF) waswere identified:
Improper target solution routing to the IXP cell, prior to Phase 4 operations Backflow of target solution to the IXP cell prior to Phase 4 operations Accident sequences within the RPF modified based on increased likelihood include:
Heavy load drop onto the radioactive liquid waste immobilization (RLWI) shielded enclosure or supercell Fire in the RPF general area Accident sequences that may have reduced likelihood or consequences due to the phased startup operations were not reevaluated because they are bounded by the accident analysis as currently documented in Chapter 13 of the FSAR.
OneTwo new credited engineered controls isare required to prevent phased startup operation accident sequences in the RPF. One new credited specific administrative control is required to prevent phased startup operation accident sequences in the RPF.
The following subsections provide additional detail on the scenarios listed above and the credited controls used for prevention.
13b.1.2.1 Maximum Hypothetical Accident The information provided in Subsection 13b.1.2.1 of the FSAR is not affected by phased startup operations.
SHINE Technologies 13b-1 Rev. 12
Chapter 13b - Radioisotope Production Facility Accident Analysis 13b.1.2.2 External Events The information provided in Subsection 13b.1.2.2 of the FSAR is not affected by phased startup operations.
13b.1.2.3 RPF Critical Equipment Malfunction The information provided in Subsection 13b.1.2.3 of the FSAR remains valid for phased startup operations with the exception that the IXP system is not installed as part of Phase 1, 2, or 3 operations. The accident sequences that result from process upsets in the IXP are, therefore, not applicable during Phases 1, 2, or 3.
AnTwo additional RPF critical equipment malfunction scenarios of a target solution leak into the IXP cell waswere identified and evaluated. The initiating event in the firstis RPF critical equipment malfunction scenario is the failure of a locked closed valve between the molybdenum extraction and purification system (MEPS) and IXP, located in the MEPS cell. In the uncontrolled sequence, failure of the valve causes leakage of target solution into the IXP cell, resulting in dose consequences to the worker and the public. This scenario is prevented by a second locked closed manual valve between MEPS and IXP, located in the IXP cell.
The initiating event in the second RPF critical equipment malfunction scenario is the backflow of solution from the target solution staging system (TSSS) to the IXP due to failure of a TSSS tank isolation valve. In the uncontrolled sequence, failure of the TSSS tank isolation valve during molybdenum extraction causes a backflow of target solution into the IXP cell through the MEPS drain line, resulting in dose consequences to the worker and the public. This scenario is prevented by the locked closed isolation valve between MEPS and IXP, located inside the IXP cell, as well as the cap on the pipe entering the IXP cell.
The accident sequence of a heavy load drop onto the RLWI shielded enclosure or supercell is modified during phased startup operations to account for an increased likelihood of the initiating event as a result of on-going installation activities. This increase was small in comparison to the total planned lifts during normal operations and did not result in an increase in the likelihood index for the initiating event. This scenario is prevented by the credited controls currently in place, including the application of applicable guidance from NUREG-0612, Control of Heavy Loads at Nuclear Power Plants (USNRC, 1980), for control of heavy loads in the SHINE facility.
Because these scenarios have preventative measures in place, there are no radiological consequences.
13b.1.2.4 RPF Inadvertent Nuclear Criticality The information provided in Subsection 13b.1.2.4 of the FSAR is not affected by phased startup operations.
13b.1.2.5 RPF Fire The information provided in Subsection 13b.1.2.5 of the FSAR remains valid for phased startup operations. An increase in the initiating event likelihood for a fire in the RPF general area was reevaluated for phased startup operations, resulting in an increase in the likelihood index for the initiating event. A new specific administrative control of suspension of radiological material SHINE Technologies 13b-2 Rev. 12