ML20155C516
| ML20155C516 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 10/07/1998 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20155C486 | List: |
| References | |
| NUDOCS 9811020255 | |
| Download: ML20155C516 (5) | |
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- Mou yr .-k UNITED STATES lg )W j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 f,
%, . . . . . f, DOCKET: 70 1151 LICENSEE: Westinghouse Electric Company, a Division of CBS Corporation, Columbia, SC
SUBJECT:
SAFETY EVALUATION REPORT: LICENSE REVISIONS 12,13 (REVISION OF SAFETY CONDITION S-2), AND 14 BACKGROUND Westinghouse Electric Company (WEC) submitted amendment applications listed as Revision 12 dated June 30,1998, (Chapters 1 and 4), Revision 13 dated July 13,1998, (Safety Condition S-2), and Revision 14 dated July 23,1998, (Chapters 1,2,3,5, and 8) of Materials License SNM-1107. Revision 12 included changes regarding an Integrated Safety Assessment l (ISA). Revision 13 included a suggested replacement for Safety Condition S-2 to provide a
- schedule for the completion of updated Criticality Safety Evaluations / Criticality Safety Analyses
! (CSEs/CSAs) and submittal of summaries (in the form of License Annexes) for review by the Nuclear Regulatory Commission (NRC). The schedule submitted in Revision 13 will replace the previous schedule for the CSE/CSA submittals and the CSEs/CSAs would be part of the ISA review process. The WEC commitment to submit the CSE/CSA summaries and to begin the development of the ISAs was part of an agreement made with the NRC at the time of the renewal of Materials License SNM-1107. Revision 14 included minor administrative changes and new health physics practices.
In order to meet the current License Condition S-2 CSE/CSA summary submittal schedule, WEC submitted summaries of CSEs and CSAs by letters dated October 4, November 30, and December 22,1995; February 15, March 29, April 30, June 28, and September 30,1996; April 30,1997; and March 27,1998. By letter dated November 25,1997, the NRC sent a request for additional information (RAI) to WEC related to NRC's review of the CSEs for the ADU Conversion Process and Uranyl Nitrate (UN) Bulk Storage Tanks. On January 28,1998, following discussions at a meeting between the NRC and WEC on January 9,1998, NRC withdrew the RAI pending site visits to determine the adequacy of documentation and whether substantive reviews could be conducted onsite. NRC staff visited the site in January and March 1998. Following the visits, the NRC determined that additionalinformation needed to be submitted and sent a second RAI on June 26,1998; this RAI requested specifically more detailed process descriptions and fault tree narratives for the ADU and UN Tanks systems.
, WEC submitted an insufCcient RAI response in a letter dated July 24,1998, and after further t
discussions with NRC, submitted the requested information in a letter dated August 24,1998.
i NRC staff performed technical and programmatic reviews of CSAs, summaries of CSAs, CSEs,
- and summaries of CSEs to determine if WEC had met the safety performance expectations of
) the NRC with the WEC submittais made in accordance with the schedule requirements of i Safety Cond! tion S-2.
I i Based on these reviews, the NRC was ready to issue a Safety Evaluation Report (SER).
However, the commitment made by WEC in a letter to the NRC dated April 17,1998, regarding submitting updated CSE/CSA summaries in the form of License Annexes precluded the need to e
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issue the SER. The information in the response to the RAI will be used to write a future SER associated with the License Annex submittals.
Parallel to the development of the system CSEs/CSAs, WEC began the development of system ;
ISAs. An ISA is more comprehensive than a CSE/CSA and includes the CSE/CSA as well as ,
other important safety (i.e., radiation protection, chemical safety, fire safety, and environmental safety) and operational features (e.g., controls, physical layouts, and process descriptions) for i the systems in use at the Columbia Fuel Fabrication Facility (CFFF). l l
As a result of the ongoing development of the safety program at CFFF and the development of i the system 'SAs, WEC has continued to make changes to the license. These changes are !
reflected in Revisions 12,13, ana 14, which will be discussed below. Note that some revisions include changes that may have been previously changed (e.g., Revisions 12 and 14 both include changes to Chapter 1,0). This SER will discuss each revision alone and on its merits rather that attempt to tie each change through subsequent revisions.
1 Revisions 10 and 11 are not included in this amendment package because both are still under l technical review and will be addressed in future licensing actions. The changes to Chapter 3.0, )
" Conduct of Operatione" in Revision 10.0 (i.e., pages 3-3, 3-4, and 3-8) are minor administratise changes and are approved as part of the changes in Revision 14 and are part of this amendment. However, the changes to Chapter 3.0 in Revision 11.0 (i.e., pages 3-18 to 3-23) )
are not approved by this SER and are not part of this amendment.
DISCUSSION l
- In Revision 12, WEC submitted a new Chapter 1.0, " General Information" to add definitions for l
" Safety Margin improvement Controls,"" Safety-Related Controls," and " Safety-Significant l
Controls." " Safety-related controls" are def;ned as preventive and mitigative controls relied upon for environmental protection, radiation safety, nuc! ear criticality safety and safeguards, chemical safety, and fire safety. These controls, which include both " safety significant" and
" safety margin improvement
- controls as subsets, will be identified in the integrated safety analyses. " Safety significant controls" are controls crucial or important to, or deemed desirable for, the safe and effective operation of a process, and an adequate safety margin for the process. " Safety margin improvement controls" are controls that provide cost-effective enhancements to the safe and effective operation of a process; these controls enhance an existing and adequate margin of safety. Identified safety controls will be placed under
- appropriate levels of Quality Assurance and Maintenance to ensure their reliability and j availability. Staff have determined that these definitions are appropriate for use within the
, context of integrated Safety Analyses as described in Revision 12 to Chapter 4.0 of the license, and are acceptable. WEC also submitted a new Chapter 4.0, " Integrated Safety Assessment,"
to update and enhance the ISA commitments. These changes in Chapter 4.0 include ,
1 commitments to develop and maintain an ISA for the site and to submit License Annexes to the NRC. These Chapter 4.0 changes incorporate commitments contained in a supplemental response, dated April 17,1998, to a Notice of Violation dated Felsruary 5,1998. These changes are improvements in the development of CFFF's ISA 9
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! In Revision 13, WEC proposed a revision of Safety Condition S-2 to replace the CSE/CSA i commitments with License Annex commitments. The suggested replacement was modified to describe in more detail the changes in the revised schedule. As discussed in the " Background" section of this SER, the current Safety Condition S-2 provided a schedule for the submittal of CSE/CSA summaries. Each of the required CSE/CSA summaries have been submitted. The i final summary (Plant Ventilation System) was submitted in the form of an ISA License Annex.
As part of the revised Safety Condition S 2, all CSEs/CSAs will be part of ISAs, and the system License Annexes will be submitted by WEC for review by the NRC.
l License Annexes are non-proprietary. In order for NRC to properly review the License Annexes for UN Tanks, ADU Conversion, URRS Dissolver, and Powder Blending (ADU), proprietary versions of those submittats that include Sections 1 and 5 of the respective CSE/CSA are required to be submitted as well. The staff recommends the following revised Safety Condition l S-2' l l
S2 Criticality Safety Evaluations (CSEs) and Criticality Safety Analyses (CSAs) will define the interim I cuticality safety bases utilized throughout the CFFF. All CSEs/ CSAs will be upgraded and/or l completed in accordance with all applicable commitments in Chapter 6.0 of the License Application ;
and all other regulatory requirements. Summaries of the CSEs/CSAs (in the format of License Annexes) will be submitted to NRC for review and approval. Proprietary versions containing Sections 1 and 5 of the CSEs/CSAs for UN Tanks, ADU Conversion, URRS Dissolver, and Powder Blending (ADU) will also be provided at the same time as the License Annexes for those systems.
All completed CSEs/CSAs will be independently peer reviewed in accordance with all applicable
. regulatory requirements and related procedures. Configuration control data packages for ongoing I
changes to facility structures. systems and components, and controls will be filed with their respective CSEs/CSAs to provide a substantially complete 'living" framework for system Integrated Safety Assessments (ISAs) that will ultimately become the Final CFFF Design Safety Basis described in Chapter 4.0 of the License Application. CFFF will provide the License Annexes to the NRC using the following schedule:
COMPLETION DATE (Calender Year) PROCESS SYSTEM 2003 UN Tanks
- 309i ADU Conversion
- Rods (ADU & IFBA)
UF6 Cylinder Washing l I
4098 ADU Pelleting ,
4 URRS Dissolver*
1 Powder Blending (ADU)* l l
1Q99 Low Level Waste Processing Hoods & Containment l 2099 URRS Scrap Processing i Solvent Extraction URRS Waste Treatment Final Assembly I 3099 Storage IFBA (Excluding Rods)
Laboratories
- Will be done as ISAs (" Final Design Safety Basis *)
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Five License Annexes have been submitted by Westinghouse to date; these are Ventilation Systems, UN Bulk Storage Tanks, ADU Conversion Process, ADU Fuel Rod Manufacturing, and Integrated Fuel Burnable Absorber Rod Manufacturing. NRC performed preliminary reviews of the UN Tanks and the ADU Conversion Process Annexes, and determined that more detailed process and accident sequence descriptions were needed for NRC to determine the adequacy of the safety analyses for those systems. Westinghouse submitted proprietary process descriptions and accident sequence descriptions for these two processes on August 24,1998. NRC staff will perform technical reviews of these two higher-risk systems and of the URRS and ADU powder blending systems; based upon the results of these reviews, NRC will determine whether detailed reviews of additional systems are necessary, in Revision 14, WEC submitted another new Chapter 1.0, " General information," a new Chapter 2.0, " Management Organization," a new Chapter 3.0, " Conduct of Operations," a new Chapter 5.0, " Radiation Safety," and a new Chapter 8.0, " Fire Safety." The changes in Chapters 1.0, 2.0, and 3.0 are administrative changes (e.g., changing " Westinghouse Electric Co* to
" Westinghouse Electric Company," updating the names of current corporate officers, and changing " safety" to " integrated safety").
The other two changes in Chapter 3.0 add a commitment to conduct the monthly formal audits, in accordance with a written procedure and delete Pellet Carts from the list of safety-related systems. The commitment to perform monthly audits in accordance with a written procedure is i consistent with good industry practice and is acceptable. The Pellet Carts were removed from the list of components to receive programmed maintenance. This change is possible because passive engineered controls have been implemented to preclude the need for programmed maintenance of the cart wheels. Measures have been established to assure that any new carts will be fitted with the passive control. Experience and testing has shown that the passive controls functioned properly when there was a cart wheel failure (two occasions), which prevented a cart upset. The staff have determined that this preventive controlis more robust than the administrative control requiring maintenance and is acceptable.
Chapter 5.0, " Radiation Safety," was changed to include a commitment to perform invivo lung counting annually for individuals required to be monitored for internal radiation exposures.
3 valuations of air sample data, operator stay-time, routine invitro (fecal and urine) sampling, or any combination of these methods will be used for individuals unable to be invivo counted (i.e.,
claustrophobic individuals). The licensee also added a commitment to provide a determination by a physician prior to the initial fitting of respirators, and periodically at a frequency determined by a physician, that the individual is medically fit to use respiratory protection equipment. NRC '
staff has determined that these commitments are in accordance with 10 CFR Part 20 and standard industry practice and are, therefore, acceptable.
The changes in Chapter 8.0, " Fire Safety," specifically identify the function responsible for preparation and revisions to pre-fire plans and commit the licensee to provide copies of the plans to the off-site fire department. NRC staff has determined that these commitments are acceptable.
NRC staff have reviewed the changes in Revision 14 and have determined that they improve licensee safety programs and are acceptable.
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ENVIRONMENTAL REVIEW These changes are considered administrative in nature. The staff has determined that the proposed changes do not adversely affect public health and safety or the environment and are categorically excluded from the requirement to prepare a site-specific environmental assessment. Therefore, in accordance with 10 CFR 51.22(c)(11), neither an environmental assessment nor an environmental impact statement is warranted for this action.
CONCLUSION The staff has reviewed Revisions 12,13, and 14 and determined that the proposed changes (except for pages 3-18 to 3-23 in Revision 14, which will be reviewed under Revision 11 at a later date) are satisfactory and meet regulatory requirements. In addition, the changes in Chapter 3.0 in Revision 10 (i.e., pages 3-3,3-4, and 3-8) are also approved as part of Revision 14. The changes in Chapter 6.0 in Revision 10 will be reviewed at a later date. There is reasonable assurance that the proposed action will not adversely impact upon the health and safety of the public or the environment. Accordingly, the staff recommends approval of these actions.
The current Safety Condition S-2 required WEC to provide submittals to the NRC providing the safety basis of plant operations. On the basis of technical and programmatic reviews, staff has determined that the terms of the current Safety Condition S-2 have been met, and there is no danger to the health and safety of the public. The revised Safety Condition S-2 provides an updated schedula with additional opportunity for technical and programmatic review.
Accordingly, the staff recommends approval of the revised Safety Condition S-2.
The Region 11 inspection staff has no objection to this proposed amendment.
Princioal Contributors Harry Felsher Ed Flack l Charles Gaskin Paul Lain 4
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