ML20127L681
| ML20127L681 | |
| Person / Time | |
|---|---|
| Issue date: | 11/23/1992 |
| From: | Haughney C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Roberts J ENERGY, DEPT. OF |
| References | |
| REF-PROJ-M-38 NUDOCS 9211250166 | |
| Download: ML20127L681 (8) | |
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Project No. M-38 3E l Mr.' John P. Roberts Acting Associate Director-for Systems and Compliance 4 Office of Civilian Radioactive l Waste Management U.S. Department of Energy j
, Washington, DC_ 20585 i l Dear Mr. Roberts-I In response to your September 10, 1992, letter, which transmitted the Department of Energy (DOE) Monitored Retrievable Storage (MRS) Facility i Annotitad Outline Skeleton Text for the Preparation of a License Application, we are enclosing some comments for your consideration in future revisions to the Annotated Outline. The scope of this a:tivity is limited to the review of the Annotated Outlines to determine if the material presented: (i) conforms with Nuclear Regulatory Commission Regulatory Guide 3.48, and Regulatory Guide 3.50, and (ii) is sufficient to make determinations against the requirements in the Commission's regulations. The scope of this review does not include technical analysis of the information provided.
Please note that the NRC's comments September 28, 1992, on the March 31, 1992, version of the MRS Annotated Outline are applicabb La the August 31, 1992, Annotated Outlines and have not been duplicated in this document. There are no new comments on the License Applicaiton Annotated Outline.
We will be glad to meet with you to discuss our comments. Should you have any questions, please call Steve Ruffin, MRS Program Element Manager, at (301) 504-2696.
Sincerely.
original signed by S. Baggett for Charles J. Haughney, Chief Source Containment and Devices Branch Division of Industrial and Medical Nuclear Safety, NMSS
Enclosure:
Comments on the MRS Annotated
, Outline, dated August 31, 1992 cc: Asadul H. Chowdhury, CNWRA DISTRIBUTION: Project M-38 PDR NRC File Center RCunningham AGarcia IMIF r/f JHolonich FBrown IMNS Central Files JGreeves SCDB r/f KWinsberg 0FC nJMIF 8 INIF. b _ JMIF h 5 D,,, M NAME M N fin /tk Cfkhbwn hSturz 6 M$h DATE 11/ 2 3 /92 1k/$0 /92 11/ @ /92 It/ 2<t/d C = COVER E = C0VER & ENCLOSURE N = NO COPY 0$ l G: Roberts 9211250166 921123 PDR PROJ f f I M-38 PDR
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- NRC COMMENTS ON DOE REPORT
" MONITORED RETRIEVABLE STORAGE (MRS) FACILITY ANNOTATED OUTLINE SKELETON TEXT FOR THE PREPARATION OF A LICENSE APPLICATION,"
AUGUST 31, 1992 I.
GENERAL COMMENT
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- 1. Some sections of Regulatory Guide 3.48 (NRC, 1989a) are not addressed (e.g., Sections 2,6.5.1 through 2.6.5.4, 4.1.2.5, and 4.3.4). No t --
including these sections, without explanation, may cause delays with the
!- review of the SAR. To the extent practicable, the SAR sections should be made consistent with the format of Regulatory Guide ).48 (NRC, 1989a)
- or the rationale for exclusion should be given. Including the title of i
i a section, that is not applicable, with a sentence stating the section does not apply would preserve the suggested format for the SAR.
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Some sections (e.g., 2.1.2.1, 4.3.1.1, and 4.3.1.2) of W SAR Annotated-
! Outline (DOE,1992b) do not have a parallel section in C iatory Guide -
3.48 (NRC, 1989a) and were placed within the middle of a series of sections listed in Regulatory Guide 3.48 (NRC, 1989a). As the size and i complexity of the SAR expands,- this' method of insertion may make the SAR-
- more time consuming to review. It is suggested that the DOE follow the
! numbering sequence of Regulatory Guide 3.48 (NRC, 1989a), to the extent i practicable, perhaps by placing additional sections at the end of a j series.
! 2. The following suggestions are provided to help expedite the review process for the LA and SAR:
(i) Prepare a comprehensive index for the LA and SAR Annotated Outlines (00E, 1992a and 1992b). This index would_. list specific or key terms used in the documents. This would help to ensure that the same-
- terminology is used consistently and would help to facilitate the l review. An example of such an index-is Volume IX of the DOE Site l Characterization Plan: Yucca Mountain Site (DOE, 1988).
(ii) Prepare a list of approved acronyms for the LA and SAR Annotated Outline and ensure that-all acronyms are applied consistently.
! (iii) Prepare a listing of all the different systems and areas j currently named and ensure that they are consistent. This would also
} facilitate integration and review.
- 3. Clarify whether the appropriate sections of the SAR Annotated Outline i
' (00E,1992b) which deal:with fire protection (refer to Sections 3.3.6,-
4.1.2.3.1, 4.3.7, 7.7, and 9.4.3.10) will address provisions to protect against_ adverse effects of either the operation.or failure of the fire 4
suppression system, per 10 CFR~ 72.122(c), in relation to' criticality -
safety.
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II. SPECIFIC COMMENTS l Chapter 1.0 - Introduction and General Descriotion of Installation
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Section 1.1.3.2 - Descriotion of an MRS i 4. Discussions on the transfer facili_ty should consider the possibility of 1
using a dual or multipurpose cask design (e.g., those with transportttion and storage capabilities), where removal of the SNF from 4
l shipping casks is not required.
- Section 1.2.4 - General Arranaements I 5. Clarify whether there will be one " Protected Area" or several " Protected Areas." This could be done in the text and/or by providing the referenced Figure 1.2-8.
- Section 1.2.4.2 - Main Structurn j 6. This section lists the major structures, however, it does not suggest providing information on the " arrangement" of these structures.
Regulatory Guide 3.48 (NRC,1989a) Section 1.2 " General Description of Installation," requests a description of the " arrangement of major structures and equipment." Clarify whether this -information will be-provided by means of appropriate text and/or figures.
Chapter 3.0 - Principal Desian Criteria i
Section 3.2.3 - Seismic Desian
- 7. 10 CFR 72.102(f) refers to 10 CFR Part 100, Appendix A, for establishing the design earthquake for an MRS sited in the western United States:
"The design earthquake (DE) for use in the design of structures must be determined as follows:- (1) For sites that have been evaluated under the criteria of appendix A of 10 CFR part 100, the DE must be equivalent to the safe shutdown earthquake (SSE) for a nuclear power plant." It is
, notable that 10 CFR Part 100 is currently being considered for r:! vision.
Consequently, its prescription for the Safe Shutdown Earthquake (SSE) for nuclear power plants may change significantly. The potential for rev_isions to 10 CFR Part'100.should be anticipated.
Chapter 4.0 - Installation Desian Section 4.1.2.1 - Site Boundary
- 8. Clarify whether the site boundary is intended to be the same as the controlled area-boundary.
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.53ction 4.3 - Auxiliary Systems
- 9. Clarify the apparent contradiction between the first and fourth paragraphs, regarding utility and support systems being bportant to safety.
Section 4.3.1 - Ventilation and Off-aas
- 10. Clarify where the major components and operating characteristics will be described. Refer to Section 4.3.1.1 of Regulatory Guide 3.48 (NRC, 1989a).
Section 4.3.3 - Air Supolv System
- 11. Clarify whether breathing quality air is only supplied through the use of individual self-containeu breathing apparatuses.
$ 12. Clarify the meaning of " critical components" and " IRS."
Section 4.3.3.2 - Instrument Air
- 13. Clarify tt.e safety class or category of the Instrument Air System in the text anQor Table 4.3-H.
Section 4.3.4.3 - Component Coolina Water System
- 14. Clarify whether component cooling water will be required to cool the
- emergency power generators. .
4 Section 4.5 - Shinoina Cask Repair and Maintenance
- 15. Clarify whether this section will address contamination control and I occupational exposure reduction, as requested by Regulatory Guide 3.48 (NRC, 1989a).
Section 4.7.1 - Structural Soecifications i
- 16. Clarify the intent of the second paragraph and its relation to other methods of grouping the MRS structures, systems, and components (1.e.,
important to safety).
Section 4.7.1.3.1 - Transfer Facility l
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- 17. Clarify whether keeping _ exposures as low as is reasonably achievable (ALARA) has been considered for the MRS in the location of the change
- room, next to the transfer cell. Refer to Figure 4.7-C, page 5 of 5, of the SAR Annotated Outline (00E, 1992b).
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e Chapter 5.0 - Ooeration Sysigmi Section 5.6.1 - Facilities
- 18. Clarify whether laboratory facilities are part of the Auxiliary Systems discussed in Section 4.3 of the SAR Annotated Outline (DOE,1992b).
I Chapter 6.0 - Site-Generated Waste Confinement Manaaement Section 6.1.1.3 - Solid Waste Systems Wastqi
- 19. Consider whether the discussion in the last paragraph would be more l appropriate in Section 6.1.3 "Non-Radiological Waste."
Section 6.2 - Offaas Treatment and Ventilation i
- 20. Clarify whether there is one Offgas Treatment System ar.a one Ventilation System, multiples of these twc systems, or just ona combined-function Offgas Treatment and Ventils'.lon Systam. Sevscal different terms are used throughout this section, its subsections, end other related sections. For example, refer to SAR Sections: 4.3.1.1 "Ventil ation Systems," 4.3.1.2 "Offgas Systems," and 6.2.1 " System Description and Performance."
- Section 6.2.1.1 - Ventilation Systems
- 21. The Zone IV System Description refers to accident analyses. Clari fy whether other SAR sections should be referenced (e.g., Chapter 8 -
" Accident Analysis").
- 22. Clarify how Zones I -- IV are consistent with Zones I -- VII of Section 7.3.1 " Installation Design Features."
Section 6.2.1.2 - Offaas Systems I 23. Clarify whether the waste storage casks will require offgas suction, j such as provided for the liquid waste treatment and monitor tanks.
I Section 6.3.2 - Eouioment and Systems Descriation i 24. Clarify whether the sources of mixed wastes will be identified.
- 25. Clarify whether there is one liquid radwaste treatment system or are there several systems.(refer to page 6.3-1).
- 26. The Clean Water Act is referenced in the text but is not included in the list of references.
- 27. Consider whether the Safe Drinking Water Act should be referenced.
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Section 6.5.3 Solid Wastes
- 28. Clarify the bases for b " compaction ratio of 10 to 1," given on page 6.5-3.
Chapter 7.0 - Radiation Protection Section 7.1 - Ensurina that Occupational Radiation Exoosures are ALARA In addition to the previous Comments 40 through 47 (NRC, 1992) the following are added.
- 29. Clarify which manual is referred to at the top of page 7.1-3.
- 30. On page 7.1-5, clacify what the term " company" refers to.
- 31. Clarify where in Chapter 6 the " discussions on ... the application of the ALARA philosophy" are located; give the specific section number /s.
- 32. Clarify whether the MRS will be designed to include means to prevent the i
accumulation of radioactive material in those systems requiring access and designed to include means to decontaminate those systems to which access is required, per'10 CFR 72.126(a)(1) and (2).
- 33. Section 7.3.4.1 " Area Radiation Monitoring System" discusses monitoring for ALARA. Clarify if Section 7.1.3 " Operational Considerations" will discuss monitoring for ALARA as well.
Section 7.2.2 - Airborne Radioactive Material Sources
- 34. Verify the units of the conversion factor (2.833 x 10' ,l/ft / 3min) on page 7.2-4, then verify the equation given on page 7.2-3.
l Section 7.3.1 - Installation Desian Features l
l 35. For Zone V, clarify how 10 CFR 20.1902 provides a limit of 15 mrem /hr.
- 36. Clarify how Zones I -- VII are consistent with Zones I -- IV, identified in Section 6.2.1.2 " Ventilation Systems" and Section 4.3.1.1 -
- " Ventilation Systems."
t Section 7.3.4.1.1 - Description
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- 37. Clarify the basis for " twenty detectors."
Section 7.5.2.1.2 - Portable Radiation Monitorina Instruments and Ecujoment
-38. Clarify how " Respiratory protection equipment" (item D) is associated
- with portable radiation monitorina instrument-and' equipment.
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l l Section 7.5.2.2 - Inolant Radiation Monitorina
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- 39. Clarify whether Table 7.5-C will include a column for off-normal operating conditions.
Section 7.5.2.3.4 - Control Points for Entrance to and Exit from the RCA I 1
- 40. Clarify whethe "whole body detectors" are portal monitors or body l burden analyzers.
I Section 7.5.3.2 - Dosimetry and Exposure Records
- 41. Clarify what value will be used for the " quarterly allowable dose" l (refer to 10 CFR 20.1201).
- 42. Clarify the meaning of the term " maximum permissitle organ burden (mpob)." fwfer to page 7.5-16.
Section 7.7.3 - Criticality Evaluation
- 43. Clarify whether the analyses will demonstrate criticality safety under conditions other than " normal conditions," as specified in 10 CFR 72.124(a).
Chaoter 8.0 - Accident Analysis Section 8.2 - Accidents
! 44. Within Section 8.2 " Accidents," it is stated, "These events' include any accident which could result in a dose of ;t 25 mrem beyond the controlled area." It is assumed that the term "these events" includes both the third and fourth types of events (Design Events III and IV) given in American Nuclear Society (ANS) Standard - ANSI /ANS-57.9 (ANS, l 1984). The basis for this statement is requested.
Section 8.2.1 - Fuel Droo in Transfer Cell
, 45. It appears that the worst-case design basis accident has been determined l to be a single fuel assembly drop accident. This section should provide the basis for this determination.
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Section 8.2.1.2 - Accident Analysis l
- 46. Clarify whether the " site boundary dose" is the same as the dose at the boundary of the controlled area.
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- 47. Consider whether the reference to ICRP 30 should be replaced with ICRP 48, and add the appropriate one to the list of refereaces.
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[hapter 9.0 - Conduct of 00eration Section 9.1.1.3 - Interrelationships With Contractors and Supolies t
- 48. As requosted in Section 9.1.1.3 of Regulatory Guide 3.48 (NRC,-1989a), .
this section is entitled " Interrelationships with Contractors and <
4 Suppliers." The SAR Annotated Outline (DOE, 1992b) references an information request (RGE-85) to provide the information on interrelations. The referenced information request (RGE-85) only calls for organization charts and responsibilities for all-contractors, but does not mention interrelationships and organizational interfaces between contractors. Clarify whether the interfaces between contractors will be addressed.
Section 9.1.1.4 - Acolicant's Technical Staff
- 49. This section relies on information request (RGE-85) to supply the information. Regulatory Guide 3.48 (NRC,1989a) requests the qualifications, background, and experience of technical staff. Again, the information request (RGE-85) only calls for organization charts and i responsibilities of staff. Clarify whether the requested information will be addressed. Note: qualification of technical staff may be covered by information request (RGE-87) which is not referenced by this section.
Section 9.1.2.2 - Personnel Functions. Responsibilities, and Authorities
- 50. Clarify if the succession of responsibility, as requested by Section 9.1.2.2 of Regulatory Guide 3.48 (NRC,1989a), will be addressed.
Although it may be implied through the identification of the deputy site l manager, this would still require further clarification.
Section 9.2.2 - Test Proaram Descriotion
- 51. The parallel section of Regulatory Guide 3.48 (NRC,1989a) requests a description of the acceptance criteria which will be used to evaluate test results, however, there is no mention of such criteria in this section. Clarify whether this information will be provided.
Section 9.d.4 - Records
- 52. Regulatory Guide 3.48 (NRC,1989a), Section 9.4.2 " Records," specifies the types of records to be described, which include quality assurance (QA) records. The SAR Annotated Outline (00E, 1992b), Section 9.4.4 -
" Records," has subsections which cover most of the record types requested, but does not discuss, or have a subsection for, QA records.
Clarify whether this information will be provided.
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6 III. REFERENCES ANS.1984. Design Criteria for an Independent Spent Fuel Storage Installation (Dry Storage Type). ANSI /ANS-57.9-1984. ANS. La Grange Lark, IL.
D0E. 1988. Site Characterization Plan: Yucca Mountain Site, Nevada Research and Development Area, Nevada. Vol. IX. DOE. Oak Ridge, TN.
DOE.1992a. Monitored Retrievable Storage (MRS) Facility Annotated Outline for the Prepara* .on of a License Application. Vol. I. Dated August 31, 1992.
D0E. Washiagton, DC.
00E.1992b. Monitored Retrievable Storage (MRS) Facility Annotated Outline for the Preparation of a License Application, Safety Analysis Report. Vol.
II. Books I and II. Dated August 31, 1992. 00E. Washington, DC, D0E.1992c. Monitored Retrievable Storage (MRS) Facility Annotated Ot:tline Skeleton Text for the Preparation of a License Application. Vol. I and II. Dated March 31, 1992. 00E. Washington, DC.
NRC.1989a. Standard Format and Content for the Safety Analysis Report for an Independent Spent Fuel Storage Installation or Monitored Retrievable Storage Installation (Dry Storage). Regulatory Guide 3.48. Rev.1. NRC.
Washington, DC.
NRC. 1989b Standard Format and Content For a License Application to Store '
Spent Fuel and High-level Radioactive Waste. Regulatory Guide 3.50. Rev.
- 1. NRC. Washington, DC.
NRC. 1992. NRC Comments on DOE Report " Monitored Retrievable Storage .(MRS)
Facility Ar. notated Outline Skeletal Text for the Preparation of a license Application." Letter. Dated September 28, 1992. NRC.
Washington, DC.
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