ML20212M269

Forwards Draft Guide for Preparation of Renewal Applications for SNM Licenses for Univs & R&D Facilities, Per Telcon

ML20212M269
Person / Time
Site:	07000600
Issue date:	03/09/1987
From:	Cool D NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Guy R SEATTLE UNIV., SEATTLE, WA
References
NUDOCS 8703110338
Download: ML20212M269 (34)

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-Seattle > University ATTN: Dr. Reed A. Guy

,; Chairman, Physics Department School of Science' and Engineering ~

Seattle', Wa'shington 98122

.: Gentiemen': .

s As a followup to our telephone conversation, enclosed is a copy of draft' guidance for.the preparation of renewal applications for special nuclear. material. licenses for universities and research and developement facilities. I hope that-this information proves useful to you.

If you have _any. questions regarding the preparation of.the Seattle University license renewal 1for SNM 589, please feel free-to call me at-_(301). 427-4510.

Sincerely orictn,7 Stenaa.w-r Donald A. Cool, Ph.D. a 7 - Uranium Process Licensing Section-fg] -

ADocg o7 Uranium. Fuel' Licensing Branch c {3120338 po ED,8o8[po Division of Fuel Cycle and -

Material Safety, NMSS-

Enclosure:

As stated ,

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OFFICIAL RECORD COPY

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.O-4 GUIDE FOR THE PREPARATION OF RENEWAL APPLICATIONS FOR SPECIAL NUCLEAR MATERIAL LICENSES FOR UNIVERSITIES AND RESEARCH AND DEVELOPMENT FACILITIES s-4

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r 4 INTRODUCTION i

Section 70.33, " Renewal of licenses" of 10 CFR Part 70, " Domestic Licens-ing of Special Nuclear Material," specifies that applications ~for renewal of licenses to' possess and use Special Nuclear Material should be filed in accord-ance with 5 70.22,'which identifies the general information required. The

" Standard Format and Content for the Health and Safety Sections of Renewal Applications for Universities and Research and Development Plants" (hereinafter-referred to as Standard Format) was prepared to provide more specific guidance for the preparation of the health and safety sections of renewal applications.

The NRC staff suggests the use of this Standard Format for renewal applications 4

to facilitate their preparation by ifcensees and their timely and uniform

- review by the NRC staff.

Information-contained in previous submittals, statements, or reports filed with the Commission under the license may be incorporated by reference, provided such references are clear and specific. The information called for in this regulatory guide that is incorporated by reference to a previous application should be summarized.

A timely renewal application must be filed in proper form not less than 30 days prior to expiration of the exist'ing license (see 10 CFR Part 70

$ 70.33). However, the NRC suggests that earlier filing is preferable. .The renewal application for the health and safety section of the license consists ,

of two major parts. The first part contains the proposed license conditions that state what performance requirements the applicant proposes to be committed.

. The second part contains detailed safety information and descriptive informa-tion on how the applicant will demonstrate adherence to the conditions of the first part. This format is designed to separate the requirements in Part I (Jicense conditions) from the descriptive information in Part II (demonstration and performance record).

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The information in Part I is of major importance to the NRC inspection'and

-enforcement staff and should be_ written so as to be inspectable and verifiable.

The information in Part -II, on_ the other hand, is of major importance to the NRC licensing' staff during the review of the license renewal application and should be written to provide the basis for licensing decisions. This Standard Format'is acceptable to the NRC staff, but conformance is not required. Renewal applications with different formats will be acceptable to the staff, if they provide an adequate basis for the findings required for the issuance of a

-license. 't The Commission's requirements for information needed in its review of applications for licenses to process and use special nuclear in material may change. The contents of this Standard Format will be revised to reflect rule changes. Revisions of the Commission's needs for the information in connection with licensing will be conveyed to the industry and the public in the following principal ways: (1) by revisions to this Standard Format, (2) by the issuance of new or revised regulatory guides, (3) by public announcements, and (4) by direct communications to the applicant from the NRC staff as needed.

Purpose and Applicability This Standard Format has been prepared to identify the type and quality of'information needed in an application for license renewal. It is recognized

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! that the magnitude of operation has a bearing on the complexity and level of

license application detail. Therefore, this regulatory guide is written to cover a general situation and the actual submittal may be more or less detailed.

If additional _ guidance is required, the applicant is invited to confer with the NRC staff prior to or during the preparation of the application.

s The renewal application should demonstrate the degree of skill, care, and a effort used by the applicant in operating the licensed facility. To this end, the applicant may provide in-depth analyses as supplemental reports incorporated l in the application by clear and specific references. Common literature or references that are readily available need not be supplied with the application.

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Proprietary Information Proprietary information must be submitted separately. When submitted, it should be clearly identified and accompanied with the applicant's justifications for requesting its being withheld from public disclosure, as specified by 52.790,"Public. Inspections,$xemptions,RequestsforWithholding,"of10CFR Part 2, " Rules of Practice for Domestic Licensing Proceedings." NRC's staff review of the safety analysis should depend as much as possible on nonproprie-tary information. ..

Style and Composition The applicant should strive for clear, concise presentation of the information provided in the application.

Where numerical values are stated, the number of significant figures given should reflect the accuracy or precision to which the number is known.

Where appropriate, estimated limits of errors or uncertainty should be given.

Abbreviations should be consistent throughout the application and should be consistent with generally accepted usage. Any abbreviations, symbols, or special terms not in general usage or unique to the licensed facility should be defined when they first appear in the application or presented in a separate

" Glossary" of terms and definitions.

Graphic Presentations Graphic presentations such as drawings, maps, diagrams, sketches, and tables should be employed where the information may be presented more adequately or conveniently by such means. Due concern should be taken to ensure that all information so presented is legible, that symbols are defined, and that scales are not reduced to the extent that visual aids are necessary to interpret pertinent items of information. These graphic presentations should be located in the section where they are primarily referenced.

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References used should appear either as footnotes to the page where referenced or at the end of each chapter.

Physical Specifications Paper size Text pages: 8-1/2 x 11 inches

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Drawings and graphics: 8-1/2 x 11 inches; however, a larger size is acceptable provided the finished copy when folded does not exceed 8-1/2 x 11 inches.

Paper stock and ink. Suitable quality in substance, paper color, and ink density for handling and reproduction by microfilming or image-copying equipment.

Page margins. A margin of no less than 1 inch should be maintained on the top, bottom, and binding side of all pages submitted.

Printing' Composition: text pages should be single spaced.

Type face and style: should be suitable for microfilming or image-copying equipment.

Reproduction: may be mechanically or photographically reproduced.

All pages of text should be printed on both sides and the image printed head-to-head.

Binding. Pages should be punched for standard 3-hole loose-leaf binders.

Page numbering. Pages should be numbered with the digits corresponding to the chapter followed by a hyphen and a sequential number, e.g., the third page of Chapter 4 should be numbered 4-3. Do not number the entire report sequentially.

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Table of Contents. A table of contents and an index of key items should be included in each volume of the renewal application.

Procedures for Updating or Revising Pages Data and text should be updated or revised by replacing pages. The changed or revised portion on each page should be highlighted by a " change indicator" mark consisting of a bold vertical line drawn in the margin opposite the binding margine,. The line should be the same length as the portion actually changed. All pages submitted to update, revise, or add pages to the report should show the date of change and a change or amendment number. A guide page listing the pages to be inserted and the pages to be removed should accompany the revised pages. Where major changes or additions are made, a revised Table of Contents should be provided.

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l TABLE OF CONTENTS' Introduction Part 1 - License Conditions Chapter 1 Standard Conditions and Special Authorizations ,

1.1- Name and Address

1. 2 Site Location-1.3 License Number and Period of License 1.4 Possession-Limits ,,

1. 5 Authorized Ac.tivities

1. 6 Exemptions and Special Authorizations Chapter 2 General Organization and Administrative Requirements 2.1. Organizational Responsibilities and Authority 2.2 Personnel Education and Experience Requirements

2. 3 ALARA policy 2.4 Safety Review Committee 4

2. 5 Training

2. 6 Procedures 2.6.1 Radiation Work Permit 2.7 Audits and Inspections 2.8 Records Chapter 3 Radiation Protection 3.1 General Technical Requirements 3.1.1 Restricted Areas - Access Control 3.1.2 Radioactivity Measurement Instrumentation 3.1.3 Leaktesting 3.1.4 Personnel Exposure

, 3.1.4.1 External

! 3.1.4.2 Internal l

3.2 Work With Other Than Sealed SNM 3.2.1 Ventilation

' 3.2.2 Work Area Air Sampling j 3.2.3 Surface Surveys xi

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TABLE OF CONTENTS (Continued) l Chapter 4 Nuclear Criticality Safety

. 4.1 Special Administrative Requirements 4.2 Technical Requirements Chapter 5 Environmental Protection 5.1 Effluent Control Systems 5.2 Environmental Monitoring Chapter 6 Special Proce,sses 6.1 Waste Management Chapter 7 Decomissioning Plan Chapter 8 Radiological Contingency Plan Part II - Demonstration Appendix

1. License History

2. Education and Experience of Key Personnel

3. Radiation Protection Analysis

4. Nuclear Criticality Safety

5. Process Description and Safety Analysis k

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-The application should contain the proposed license conditions which describe the licensees level of performance. The conditions should be con-cisely stated,*and written to permit inspection and verification cf the stated performance requirements. When necessary to demonstrate or expand a point, and to present data to support past performance, a sdparate appendix should b9 provided and that portion of the application will not be a condition of the l license.

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CHAPTER 1. STANDARD CONDITIONS AND SPECIAL AUTHORIZATIONS-1,1 Name and Address The applicant should furnish the full name and address of the institution or research and development (R&D) facility. The State or charter, organization, or incorporation, if different from the address, should be indicated. Include

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a listing of the principal officers, with name, title, address and citizenship.

1. 2 Site Location The location (including building name and number)-of any facility where the licensed material is to be used or stored should be described. Include a map of the institution clearly indicating areas of use and storage. If SNM may be used in a dispersible form, the location of the nearest residence, school and population center should be identified.

1.3- License Number and Period of License The licensee should state the applicable license number and the period of time for which the license is requested.

1.4 Possession Limits The maximum quantity of special nuclear material (SNM) to be possessed and used under the license should be identified by isotope, enrichment, chemical and physical form, and mass in grams. Possession limits requested should cover the total anticipated inventory including stored materials.

1. 5 Authorized Activities A summarized description of all activities for which the licensed material will be used should be provided. For each activity described, the location of use should be identified.

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1.6 Exemption and Special Authorization Any specific exemptions from the requirements specified in the regulations, l or special authorizations such as a request for disposal of radioactive waste l by incineration in accordance with 10 CFR 20.305, should be listed in this l section. Justification should'be provided for exemptions. l l

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CHAPTER 2. GENERAL ORGANIZATIONAL AND ADMINISTRATIVE REQUIREMENTS 2.1- Organizational Responsibilities and Authority Key positions with safety related responsibilities should be identified and those responsibilities should be fully described. The lines of authority-from radiation safety to top mar.4gement should be indicated on an organizational t

chart, and the position responsible for personnel selection for safety-related positions should be stated..,. ,

4 The authority for the Radiation Safety Officer to halt any operation which

• he believes threatens the health or safety of personnel or public should be explicitly expressed.

2.2 Personnel Education and Experience Requirements The minimum educational, training and experience requirements for radia-tion and nuclear criticality safety related positions and for membership on the safety review committees should be specified in this section.

2.3 ALARA Policy In this section the licensee should state its commitment to ensuring that exposures to radiation will be maintained "as low as reasonably achievable" (ALARA). A description of how this policy will be implemented should be included.

2.4 Safety Review Committees

, The application should contain a list of all safety committees, including the one functioning as an ALARA committee. The function and responsibility of each should be described. The description should include the purpose, charter of responsibilities, frequency of meeting, membership (by position), and report-ing and recordkeeping requirements.

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2.5 Training ,

The a'p plication should contain a oescription of. the program used to-train users of_the licensed material and the eddiaticn safety personnel. In addition to-content and methodology the program should includs evaluation to assess understanding,- recordkeeping to be assured all new pr.sonnel are trained, and there should be a retraining program to provide refresher or upgrade trainin2-at a stated interval.

2.6 Procedures The licensee should provide practices for esoablishing, modifying and implementing procedures which would be adhered to for all work with SNM.

Included should be the provision tuat all peccedures involving licensed mate- .

rial would be evaluated and approved by the Radiation Safety Officer and the appropriate' Safety Review Committee, where applicable. The range of procedures

, should encompass operations, radiation safety and maintenance.

2.6.1 Radiation Work Permit (RWP)

There should be a provision for unusual or unplanned activities w:lich are not covered by established procedures. The criteria and procedure for initiat- '

ing, evaluating, approving and terminating a RWP should be described.

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, 2.7 Audits and Inspections l

The licensee should state requirements for and frequency of internal audits and inspections to determine if SNM operations are conducted in accordance witn written procedures that satisfy applicable regulations, license conditions and licensee's policies. Include distribution of auait results and decumentation l

of corrective actions.

I i 2.8 Records l

The application should include a description of the system for maintaining records related to health and safety. Retention time of these records should i

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be specified. Areas of interest include principal maintenance, alterations or additions made, abnormal occurrences and events associated with radioactivity releases, nuclear criticality safety analyses, audits and inspections, instru-ment calibration, ALARA documentation, employee training and retraining, personnel exposure, routine and special radiation surveys, and environmental 4 surveys.

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. CHAPTER 3. RADIATION PROTECTION 3.1 General Technical Requirements 3.1.1 Restricted _ Areas - Access Control The application should identify the restricted areas and the means used to control entry and exit. The description should include:

1. Posting and labeling.

2. Identification of physical limits (e.g., step-off pads) and means of access control.

3. Protective clothing. Describe the policy on use of protective clothing and a description of protective clothing (coats, coveralls, shoe covers, headcovers, etc.) available for use.

4. Personnel exit survey and decontamination policy. Describe the provisions for personnel decontamination.

3.1.2 _ Radioactivity Measurement Instrumentation The application should identify the types (not manufacturers names) of instrumentation used for measuring radioactivity. The purpose (e.g., radiation surveys, personnel monitoring), number, range, seasitivity, alarm set point (s),

calibration method and frequency, and testing should be described.

3.1.3 Leak Testing The poli;y and program for leak testing of sealed sources should be provided. Frequency and methodology should be included.

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D 3.1.4 Personnel Exposure 3.1.4.1 External-The application should contain a description of the program for determin-ing, validating and controllin' occupational g exposures. The description'should include the type (s) of equipment used, the frequency'of-data collection and evaluation, and the administrative action level for individual exposure. When personal dosimeters are-usedi.the type, range, sensitivity, and accuracy should be specified. Also describe how dosimeter readers are tested for accuracy if

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dosimeters are read by the licensee.

3.1.4.2 Internal If dispersihie SNM is used, a description of the bioassay program to detect and monitor any significant deposition of radioactive ~ material in the body I should be described. Included should be criteria for initiation, selection

-(in vivo and/or urinalysis), frequency and interpretation of results. Dose level limits selected for a commitment of action, and actions to be taken, should also be presented.

3.2 Work with Other than Sealed SNM 3.2.1 Ventilation The application should contain a description of containment ventilation systems. The description should include:

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' 1. Minimum flow velocity, maximum differential pressure measurement across filters, and frequency of system (s) checks.

I l 2. Operation of vacuum systems including criteria for filter replacement.

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ing airborne radioactivity. When' fixed samplers are used, the descriptica bj d

~s should include how placement of the samplers .is determined to beI rapresentative ' V, ~

of the workers breathing area as wel.1 as the frequency of sample.; collection and.

analysis.. Action _ levels-( S PC and'2 PC-hrs) and actions to be taken if these levels are exceeded should 'oe specified, including any action level at whi d an oneration will be shut down ; , ,

3.2.3 Surface Surveys The application should contain a descriptiots of tne program for surface contamination control. The description should include the frequency of surface surveys, action levels and actions for removable and fixed contamination, and the time interval' allowed before commencing decontamination.

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I CHAPTER 4. NUCLEAR CRITICALITY SAFETY

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4.1 _Special Administrative Requirements

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- The licenser should state tha't the double contingency policy is followed

' ins establishing nuclear criticality safety practices and procedures. The r double contingency policy. states that procedures incorporate sufficient factors j 'of safety to require at least two unlikely, independent, and concurrent changes ins; process conditions before,.a criticality accident is possible. The licensee should refer to Regulatory Guide 3.4, " Nuclear Criticality Safety in Operations with Fissionable Materials Outside Reactors."

. The administrative guidelines should be specified for determining whether

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a nuclear safety analysis needs to be performed. The position responsible for initiating the pequest and authorizing the analysis should be consistent with the license req'uirements.

f The procedures.should be stated for " Posting of Limits" at each location

, where fissile material is handled, processed, transported, or stored. They should include the information required for labeling fissile material containers.

l The general administrative requirements should be included in Chapter 2.

4.2 Technical Requirements The licensee should state the technical requirements for nuclear critical-ity-safety in the design and design changes for the building, equipment or components, and processes in which fissile materials are used. Guides used, in

j. s,upport of the requirements, should be referenced (e.g., Regulatory Guides 3.4 i and 3.41, " Nuclear Criticality Safety in Operations with Fissionable Materials Outside Reactors" and " Validation of Calculational Methods for Nuclear Critical-lty Safety," respectively). Tables used, specifying safe masses and container geometries, should be provided. Similarly, criteria (interaction criteria) for safe spacing between individual safe units should be specified.

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'This section should also specify the basic assumptions and design condi--

tions that are of-papticular importance in the safety analysis. The following are examples of such assumptions and design conditions: ,

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1. Minimizing,the possibility of the accumulation of fissile materials in  ;,

locations other than those specifically designed for accumuistion.

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2. Nuclear safety dependence on the degree'of moderation within the process j ,

unitanddependenceon4hedegreeofmoderationbetweenunits.

3. Nuclear safety dependence on neutron reflector of interest (if more effec-tive than an infinite water reflector) or based on an infinite water reflector.

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4. Nuclear safety dependence on enrichment, concentration, and diluents.

5. 0ptimum conditions (limiting case) of water moderation and heterogeneity credible for the system.

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• 6. The analytical methods used for criticality safety analysis and the valida- ,

gy tion of the methods unless published criticality data or nuclear critical-ity safety guides are.used. In the latter case the applicability of the data to the fuel handling activities of interest must be demonstrated. -

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7. , Safety margins for selected individual units and the justification of these safety margins based on normal and acciAcJ conditions such as flooding, multiple batching, and fire.

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8. Safe geometry parameters applicable to the licensee's activities.

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9. Method of deriving applicable multiplication factors.

10. Criteria used in spacing of pipes, process vessels, transport and process equipment, storage containers, etc.

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Criteria for the application of fixed poisons (e.g. , borosilicate raschig 11.~

rings).

12. Design basis to ensure structural integrity of safety-related structures, systems, and components.

13. Criteria for preoperation testing of equipment.

14. Criteria used in the choice of fire protection methods.

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CHAPTER 5. ENVIRONMENTAL PROTECTION 5.1 Effluent Control Systems Radioactivity levels in gaseous and liquid effluents' that require a commit-ment to action should be specified. The action levels should be selected to

. meet regulatory limits, including ALARA commitments.~ The application should contain a description of. proposed corrective actions to be taken when these limits are exceeded. Levels .at which' an operation will be shutdown should be specified.

The application should also contain a description of sampling frequency, analysis, lower limit of detection, instrumentation, calibration and testing, method of reporting, and responsibility (by position) for control of all c

effluents at their point of discharge. Limits selected for a commitment of I action, and action (s) to be taken, should be described.

5.2 Environmental Monitoring The environmental (radiological and nonradiological) monitoring program should be described. When applicable, the description should include revisions for sampling and analyses of air, soil, vegetation, surface-water, and ground-l water-to evaluate radioactivity and/or other effluents released from the facility. Also, the application should show the location of sampling stations, including any background stations, and should include evaluation and reporting comm tments of the monitoring program.

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CHAPTER 6. SPECIAL PROCESSES 6.1 Waste Management The application should contain a description of. processes and systems used for handling, storing, and disposing of radioactive wastes. The areas where radioactive waste is generated should be identified. If radioactive wastes are stored onsite, methods of containment and monitoring of containment should be described. ,.

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CHAPTER 7. DECOM4ISSIONING PLAN The licensee should affirm the commitment to decommission the facility and the site at the end of its operation in a manner that will protect the health and safety of the public. Plans for decontaminating the facility and site so

- the facility and grounds can be released for unrestricted use should.be provided.

The application should include an updated estimate of the costs involved and a description of the financial arrangements made to ensure that adequate funds will be available to cover these costs at the time of decommissioning.

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.c i CHAPTER 8. RADIOLOGICAL CONTINGENCY PLAN f

When the requested possession limits exceed the limiting quantities dis-cussed in NUREG-0767 " Criteria for Selection of Fuel Cycle and Major Material Licenses Needing Radiological Contingency Plans, the application should contain a radiological contingency plan.in accordance with NUREG-0762, "Shandard Format and Content for Radiological Contingency Plan for Fuel Cycle and Material Facilities," dated July 1981.

If the existing license contains an approved plan, it should be incorporated by reference into'the application.

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PART Ir

.1. LICENSE HISTORY-The original license-issue date and subsequent renewal dates should be-provided.

• 1 2.- EDUCATION AND EXPERIENCE OF KEY PERSONNEL The resumes of personne'l assigned to safety related positions should be presented. Identify individuals by position and title.

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3. RADIATION PROTECTION t

Provide an analysis of exposures (internal and external) covering at least the past 2 years of operations for each area and type of activity performed.

.The analysis should identify the' sources and locations where most exposures L occurred as related to job categories and work activities. Any trends'in expo-sure that can be identified should be discussed. Abnormal occurrences should be reviewed and categorized by such aspects as frequency, operations being performed and the magnitude of the resulting exposure. The analysis of internal exposure should consider air sampling data, as well as bioassay data (including '

l in vivo counting). The analysis should conclude with a description of any steps or measures taken to reduce exposure), the effectiveness of these measures, and any additional actions planned.

4. NUCLEAR CRITICALITY SAFETY v 4.1 Administrative and Technical Procedures

'- Administrative and technical procedures to ensure nuclear criticality safety in the fabrication, storage and movement of SNM should be described in detail. Describe administrative practices such as establishing the responsi-bilities for nuclear criticality safety; providing qualified personnel; and j establishing written criteria and procedures, process analysis, materials and DRAFT 02/20/87 16 UNIV STD FMT RENEWAL APPLIC i

9 operational controls, operational reviews, emergency procedures, audits and inspections, reports, acceptable data sources, and validation techniques.

4.2 Preferred Approach to Design The preferred approach to' design should be specified in this section. If the approach is other than the use of equipment of safe geometry, provide infor-mation that justifies its use. The design approach should include designs that minimize the possibility of, accumulating fissile materials in inaccessible loca-tions, make nuclear safety independent of the degree of moderation within a unit and the degree of interspersed water moderation between units, and make nuclear safety independent of neutron reflector thickness.

4.3 Basic Assumptions The basic nuclear criticality safety analysis assumptions should be stated in the application. Some examples are maximum credible fissile material density, the optimum (limiting case) conditions of water moderation and heterogeneity credible for the system, the enrichment, and unit limits based on full water i

l reflection. If a more effective reflector than water is present (e.g. , concrete) it should be considered in the analysis.

Safety margins for the individual units should be specified (e.g., safety factors for large units, dimensions for small units). Safe unit geometry and safe unit spacing will differ from facility to facility, process to process, and SNM content of materials in process. For this reason, the applicant should provide tables of the maximum safe parameters for individual units of the plant and the criteria for spacing between units in an array.

For the convenience of the applicant, criticality safety design methods acceptable to the NRC staff are provided in Appendix A to this guide.

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. .4.4 Analytical Methods and Validation References Describe and demonstrate the use of the validation of the analytical methods-used and their applicability to the systems being analyzed. If published criti-cality data or nuclear safety guides are to be used, state the basis for their accuracy and for their applica6flity to the facility activities.

4.5 Data Sources Thesourcesorreferenbsfortheapplicabledatashouldbespecified.

4.6 Fixed Poisons In the event that borosilicate glass raschig rings are used as a primary or secondary means of criticality control, describe how they are used and maintained. (In this connection, guidance is provided in Regulatory Guide 3.1, "Use of Borosilicate-Glass Raschig Rings as a Neutron Absorber in Solutions of Fissile Materials.") Alternative poison material may be used if safety justiff-cation is provided. Justification includes the determination of the initial and continuing presence and effectiveness of the poison material.

4 4.7 Structural Integrity Policy and Review Requirements

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j- Show that the structural integrity for single units and arrays is ensured i by providing adequate margins of safety for all credible accident conditions and that the engineering design is reviewed by a qualified person to ensure an l

L adequate margin of safety under all normal and abnormal conditions.

l 4.8 Special Controls Any other special controls used to ensure nuclear safety such as zoning l for fire protection should also be described.

d i DRAFT 02/12/87 18 UNIV STD FMT RENEWAL APPLIC l

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5. PROCESS DESCRIPTION AND SAFETY ANALYSES

' (For facilities fabricating or processing SNM) 5.1 Process Steps and Flowsheet Describe in detail the pr6 cess equipment and associated controls. Include in this description ancillary activities if pertinent to the main process, i.e., preparation of reactants, offgas handling, volume reduction of wastes, decontamination, and scrap re, cycling.

In support of the description, supply flowsheets showing the process, materials, and instrumentation. Provide identification of the process and effluent streams in sufficient detail to permit an independent review to . ensure a safe operation. That should include activities, compositions, properties, sample points, and identification of primary control points. Justify the conclusions relevant to safety and environmental effects.

I 5.2 Safety Analysis of Each Step Provide a safety analysis of each step of the process. .The applicability of all methods of analysis specified in Part I should be demonstrated.

5.3 Safety Features of Each Step i .

Describe all safety-related features, systems, or special handling tech-I niques included in the system for the safety of the operation under both normal and abnormal conditions. Include the limit (s) selected for a commitment of action. Provide a summary description of the principal design guidance, proce-dures, and special techniques used to preclude criticality in all steps of the process. Describe the location of criticality detectors. Provide a summary

. dInscriptionoftheprincipalchemicalandfirehazardsandtheapproachesused to preclude accidents.

DRAFT 02/12/87 19 UNIV STD FMT RENEWAL APPLIC

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APPENDIX A SAFETY MARGINS AND INTERACTION CRITERIA For the convenience of the applicant, criticality safety design methods

~

. acceptable to the-NRC staff,. including maximum safe parameters for. individual units and crite-ia for spacing between units in an array, are provided in this appendix.

~:

• I~ 1. SAFETY MARGINS ,

The following are acceptable margins of safety for individual units: when double-batching is'possible, mass limits should be held to no more than 0.45 of the minimum critical mass based on spherical geometry; when double-batching is not possible, the mass should be limited to no more than 0.75 of the critical mass, provided no more SNM can physically be placed in the container. ~ Mass

. limits should be based on experimental data or on calculations performed by a

~ method that has been validated for the type of system being analyzed. Accept-

able geometry margins of safety for large single units are 90 percent of the minimum critical cylinder diameter, 85 percent of the minimum critical slab thickness, and 75 percent of the minimum critical sphere volume. Maximum safe dimensions must be specified for small units.

Safe cylinder diameters, slab thicknesses, unit masses, and volumes may l be tabulated in the application as a function of moderation, enrichment, reflec-

_ tion, etc. The specific values tabulated should meet the above criteria or may correspond to a unit k,ff that provides an adequate margin of safety under specified normal and credible abnormal conditions.

For most universities, research and development, and other facilities in which fuel fabrication and/or processing is limited, safe parameters based on l' . nuclear criticality safety guides, handbooks, or other documented criticality data are adequate for establishing a satisfactory nuclear criticality safety program. However, the reviewer must confirm the limits of error applied to the data, remove any uncertainties in the " critical" parameters, and the

! DRAFT 02/12/87 20 UNIV STD FMT RENEWAL APPLIC

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licensee must demonstrate their appropriate application. Use of the " single parameter limits" specified in ANSI /ANS-8.1-1983, " Nuclear Criticality Safety in Operations and Fissionable Materials Outside Reactors," is acceptable as

" minimum critical parameters" in establishing the " maximum safe parameters."

The published " safe" data in DP-1014, " Critical and Safe Masses and Dimensions of Lattices of U and U02 Rods in Water," are acceptable when used as " critical" data in establishing maximum safe parameters for uranium fuels containing 15%

23su enriched uranium. The " safe" parameters tabulated in DP-1014 have the uncertainties removed from the calculated " critical" parameters tabulated in the same document. ,

The following method of analysis should be used by licensees basing nuclear criticality safety on a k,ff that provides an adequate margin of safety.

The evaluated multiplication factor under normal and credible abnormal conditions must be equal to or less than an established maximum safe allowable multiplication factor (k,), i.e. , ,

ks i k, where k = the evaluated multiplication factor, including any necessary s

allowance for statistical uncertainties.

The maximum allowable multiplication factor should be calculate from the expression:

k, = kc - Aku - Ak, where kc= the value of k,77 that results from the calculation of benchmark

' experiments using a particular calculational method. The value represents a combination of theoretical techniques and numerical data.

the uncertainty in the benchmark experiments, including random Ak"= and systematic errors (bias) within the range of parameters encountered in the equipment design.

DRAFT 02/13/87 21 UNIV STD FMT RENEWAL APPLIC

' Ak, =~the value required to ensure an acceptable margin of subcriti-r cality. In the~ absence of information that justifies a smaller margin of safety, value-of 0.05 should be assumed for Ak,in equipment design.

2. INTERACTION CRITERIA Desirable spacing criteria ~ include:

a. The closest approach of one individually subcritical unit-to another should be limited by mechanical means or by clearly delineated criticality zones.

b. The array analysis should allow for double-batching of a single position in the most limiting array position (or positions) credible.

c. The array analysis should account for interunit moderation unless it can be shown that moderation is not credible.

d. The array analysis should include a conservative allowance for spatial tolerance in unit positions,

e. Mixed array criteria should be used where applicable (e.g.,

solutions and solids).

The licensee should identify the criteria to be used in spacing. Acceptable criteria for the spacing of process equipment and stored units include the following:

a. Validated KENO calculations should yield a maximum k,ff or 0.95 at

, the 95 percent confidence level,

b. The maximum safe surface density should be limited to 25 percent of the critical surface density of a fully water-reflected uniform slab of the appropriate composition when each unit in the array has a maximum quantity of fuel that is no more than 30 percent of critical DRAFT 02/20/87 22 UNIV STD FMT RENEWAL APPLIC

for a bare assembly, based on container geometry, fuel composition,.

and the degree of water moderation of interest.

c. .The nuclear criticality safety criteria for arrays may be based on

-the application of the solid angle method. The method of analysis should be demonstrat6d applicable to the system being analyzed.

d. In the application of the density analog method, safety factors of 2 should be used fot,.the maximum allowable number of units. Factors for reflection and moderation must also be supplied.

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1 DRAFT 02/12/87 23 UNIV STD FMT RENEWAL APPLIC

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