ML20235U563

Safety Evaluation Concluding That Stated 10CFR70 License Conditions Should Be Incorporated Into 10CFR50 License

ML20235U563
Person / Time
Site:	Comanche Peak
Issue date:	02/24/1989
From:	Mccaughey D NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20235U500	List: ML20235U497 ML20235U563
References
NUDOCS 8903090262
Download: ML20235U563 (2)

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SAFETY EVALUATION, TEXAS UTILITIES. ELECTRIC C'OMPANY (TUEC), COMANCHE PEAK STEAM ELECTRIC STATION, UNIT 1

Background

On February 14, 1983, NMSS staff issued Materials License No. SNM-1912 which authorized the receipt, possession, inspection, and storage of enriched uranium in the form of fuel assemblies at Comanche Peak Steam Electric Station, Unit 1.

When the Part 50 Operating License is issued, the Part 70 license will be terminated. The purpose of this evaluation is to assess the appropriate Part 70 license conditions which should be incorporated into the Part 50 license.

Discussion Conditions 1-10 of the Part 70 license are essentially administrative in nature

-and will be replaced by appropriate conditions in the Part 50 license.

Conditions 11 and 12 specify minimum qualifications for the Manager, Technical Support, and the Radiation Protection Manager or his alternate to provide assurance that TUEC has the technical capability to perform safe fuel handling operations.- Personnel qualifications for the Part 50 license should replace these conditions.

Condition 13 requires that fuel assemblies be stored in such a manner as to permit water to drain freely from the assemblies in the event of flooding and subsequent draining of the fuel storage area. If the storage array were to become flooded, and the dust wrappers around individual fuel assemblies filled with water, and then the vault drained, the fuel assemblies could be well-moderated and effectively coupled to other well-moderated fuel assemblies as the isolating water between the fuel assemblies drained away. The staff evaluated the condition of full-density water within the fuel assembly and low-density water between fuel assemblies. There is not erough steel in the storage racks to assure that such an array remains subcritical under this condition. Thus, the plastic dust wrapper on each fuel assembly in the vault must be removed from the fuel assembly or must be open at the bottom so that water will not collect in the wrapper. The TUEC FSAR contains a commitment to remove the dust wrappers from the assemblies prior to storage. As long as this commitment remains in effect, Condition 13 is not necessary.

Condition 14 applies to the use of administrative controls to control the spacing between fuel assemblies in the spent fuel storage racks. This was necessary at the time of issuance of the Part 70 license because TUEC had committed to a checkerboard loading pattern in the spent fuel pool. This condition should be revised to allow storage conditions justified for the operating license.

Condition 15 requires TUEC to have not more than 40 loaded shipping containers in an array. At the time the Part 70 license was issued, the shipping container in use was designated as a Fissile Class II package and had a minimum transport index of 1.2. With this transport index, an array of 40 shipping containers is s903090262 890224 5 FDR ADOCK 0500

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• Texas Utilities Electric Company 2 safe. This container has been upgraded to a Fissile Class I design which would allow TUEC to have 250 containers in a single shipment or array. By spacing the arrays in accordance with DOT requirements, an unlimited number of containers can be safely brought onsite. Accordingly, Condition 15 is no longer necessary.

Conditions 16, 17, and 18 provide spacing criteria for nuclear criticality safety for both arrays and individual assemblies out of storage. Based on a more realistic reassessment, the staff recommends that Conditions 16, 17, and 18 be replaced with the following two conditions:

No more than two fuel assemblies shall be out of storage racks or shipping containers at any one time.

The licensee shall maintain a minimum 12-inch edge-to-edge distance between fuel assemblies which are out of storage racks or shipping containers.

Condition 19 exempts TUEC from the monitoring requirements of 10 CFR 70.24 as provided for in 70.24(d). TUEC's reasons for requesting the exemption are that storage facilities and procedures provide assurance that criticality cannot occur during receipt, inspection, and storage of new fuel. TUEC's reasons for the exemption are valid and good cause exists for the exemption. The shipping containers and storage racks provide physical protection to ensure subcriticality. The procedural controls provide reasonable assurance that nuclear criticality will not occur during fuel handling, and monitoring is not needed. Even if the procedural controls were violated, optimum conditions of neutron moderation, physical spacing, and neutron reflection would be required for assemblies to be in a critical situation. The procedural controls, considering the limited activities and material handling methods, are deemed '

adequate to grant the exemption. This exemption is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest. If the basis for the exemption is still valid, the exemption should be transferred to the Part 50 license.

Condition 20 requires TUEC to calibrate portable alpha survey instruments at least quarterly. This condition was added to highlight a commitment made by TUEC, and accordingly, is not necessary.

Condition 21 commits TUEC to an interim Physical Security Plan. Because the Plan was not designed for an operating facility, the condition should not be transferred to the Part 50 license. 4 MMk David A. McCaughey Uranium Fuel Section Fuel Cycle Safety Branch =

Division of Industrial and Medical Nuclear Safety, NMSS l

Approved by: l George H. Bidinger, Section Leader l OFC:IMUF: g IMUFj

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DATE:2/$/89 :2 A\ /89 :2/f//89 0FFICIAL RECORD COPY

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