ML20027C056
| ML20027C056 | |
| Person / Time | |
|---|---|
| Issue date: | 09/29/1982 |
| From: | Rouse L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Jesse Rollins GESELLSCHAFT FUER NUKLEAR SERVICE, MBH |
| References | |
| REF-PROJ-M-34 NUDOCS 8210120360 | |
| Download: ML20027C056 (47) | |
Text
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j [L. @.A.N d SEP.,1982 N Ydhd5 ^g Project M-34 Gesellschaft fuer Nuklear Service, nbH ATTH: Jack D. Rollins, U.S. Representative 340 Six Branches Court Roswell, Georgia 30076 Gentlemen:
In response to your submittal, docketed June 1982 under Project No. M-34, we have evaluated for completeness and technical adequacy your submitted Topical Report entitled, " Topical Safety Analysis Report for a Castor Cask Type Independent Spent Fuel Storage Installation (Dry Storage)." Our detailed comments are enclosed separately. I want, however, to draw your attention to and to emphasize certain points raised in our comments so that you nay consider them in revising your Topical Report.
The purpose of a Topical Report (TR) is to stand as a referenceable document in site-specific license applications. It should be in the format of a Safety Analysis Report (SAR). While a TR itself is nonsite specific, it should envelope site parameters sufficiently well to encompass an adequate-range of sites within the United States. Otherwise the scope of the standardized design approach used in a TR is of limited utility to po-tential applicants. The submitted GNS report does not accomplish this objective. It simply cites transportation cask tests or analyses without adequate development to denonstrate that or how the results of these tests and analyses address site parameters with respect to normal storage operations and credible accident conditions. From the information that has been presented thus far we find no reason to believe that the GMS Castor Ic cask design cannot be shown to be acceptable. However, the GHS report must f
be revised to do so.
To be useful this TR nust establish that the cask design itself is acceptable and in doing so it cust be formatted so that sections of it can be readily referenced in a license application SAR. Thus, we have suggested in our coments that a revised GNS-TR focus on the single cask itself providing najor descriptive information and data in the main body of the TR. Infor-mation about specific facilities, such as Gorleben, should be eliminated.
Such descriptions are not ger)eric design information applicable for ir;clusion for a license SAR. For purposes of demonstrating how an array of casks should be addressed in an SAR, we,have suggested that a line array and a representative
- square array of casks be included. While array configurations at specific -
sites will vary, the methods developed in the TR in addressing such topics as occupational exposure and tenperature ranges in the vicinity of an array can have a general utility.
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PDR DATE)
- N,C F1RM 318 (1040) NRCM O240 OFFICIAL RECORD COPY
G2sellschaft fuer Nuklear Service, mbH SB g
We also suggest in line with the objective of focusing on the cask design itself that the TR address only an at-reactor site ISFSI scenario. If this is done, the interfaces between the cask design and services and operations outside the cask can be clearly delineated and described. For a cask type ISFSI located at an operating reactor there are major operations and structures which are eliminated from direct consideration in a Part 72 license review because they occur within the reactor, such as cask loading, unloading and handling in the reactor pool area, cask decontamination, and cask maintenance and repair.
Obviously, in the site-specific license application for ISFSI storage it must be shown that these requirements of Part 72 are met under the reactor operating license. Thus the site-specific SAR must reference that they are but the TR need not and indeed cannot generally do so. Thus, material describing Hurgassen ISFSI storage should be generally eliminated since it serves no useful purpose.
In summary, a TR should be a single coherent document capable of being referenced in an SAR format according to Regulatory Guide 3.48.
It shonid address the cask design including all necessary information and test data to establish the acceptability of the cask design in the NRC staff safety review.
Where the requirements of Part 72 and other regulations are met in the TR specific citation of the regulations by section should be made. Particular attention should be made in delineating in the TR what is and is not included for safety review and in establishing interfaces between the cask ISFSI and the reactor and site-specific topics.
Your application and affidavit for review of the Topical Report requested that Appendices 1, 3 and 6 through 24 of the Topical Report be withheld from public disclosure pursuant to 10 CFR 2.790. In our letter to you of August 13, 1982 we noted that your affidavit had been reviewed and that it was not in con-formity with Section 2.790(b) of the Comission's regulations. We requested that you supplerent the record with additional factual information. Since we have not concluded, as yet, whether the information referenced in your affidavit is proprietary, we will withhold the following portions of our enclosed comments from public disclosure until a determination is made on your requests:
- 1) paragraph 3 of page 16,
- 2) all of page 17, 3
all of page 18 except Section 4.1, 4
paragraphs 4 and 5 of page 25.
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Gesellschaft fuer Itklcar S::rvica, nbH SEF G82 These pages vaay contain corrents on specific information and data whkh you have requested to be withheld from public disclosure.
If I can provide further help, please contact me.
1 naOt Orisi" ko;go/
Ic1;Li Leland C. Rouse, Chief Advanced Fuel and Spent Fuel Licensing Branch Division of Fuel Cycle and Material Safety, HitSS Enclosure (s): As stated Distribution:* w/o proprietary portion Project M-34 file
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Topical Safety Analysis Report for a Castor Cask Type Independent Spent Fuel Storage Installation (Dry Storage)
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~ General Comments
~The Safety Analysis Report for a Castor-type Independent Spent Fuel Storage Installation submitted by GNS does follow the format of Nuclear Regulatory Guide 3.48.
However its content is not sufficiently substantive to facilitate an orderly ' review. Much of the relevant material is distributed throughout appendices in a variety of contexts so -that it is difficult to extract a coherent descr_iption of its technical contents.
Consequently we find it necessary to recommend that the report be so edited that it -stands alone as a safety analysis report with the appendices providing details related specific-ally-to the items for which they are referenced.
To assist GNS in restructur-ing their report the following detailed comments-have been organized in accordance with the. format of Regulatory Guide 3.48.
Comments' associated with a particular section address the adequacy of its content and request further information where it appears to be lacking.
All mechanical design details and analysis should be placed in main report body.. Final text should be entirely in English including tables and figur~es.
For_the report.to be useful to site specific license applicants and' reference-able in site-specific safety analysis reports (SARs) we recommend that GNS address the Castor. Ic cask specifically as a storage cask.
The report should
~ consider only the situation-of an at reactor (AR) site independent spent fuel
-storage installation (ISFSI). While the report shall focus in detail on a single' cask, consideration _ should be given to a generic treatment of casks -in 1
multiple arrays such as in-line, square etc. Sufficient-information should.be
- provided to enable the site-specific license applicant to evaluate a'particular array with regard to thermal and radiological conditions within the array, at; the boundary of the-array,: and at a number of distances from the array that might be applicable to a typical site.
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CASTOR CASK TSAR COMMENTS s
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While the report itself is not site specific, it should envelope site parameters sufficiently well in its presentation to encompass an adequate range of sites within the United States so that the Castor Ic cask ISFSI design may be
" qualified for such sitos.
Reference to other cask types for the purpose of qualifying the Castor Ic cask is acceptable provided the relationships are clearly set forth.
It would be i
helpful if the test parameters relating to other cask types were presented in
.t an orderly fashion so that their significance would be more readily apparent.
We would also suggest that a list and description of the computer programs I
referred to in the report be provided in a separate appendix.
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CASTOR CASK TSAR COMMENTS l
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INTRODUCTION AND CENERAL DESCRIPTION OF INSTALLATION i
1.1 Introduction l
1.1.1 General 1.1.2. Principal Design Features of Installation 1.1.2.1 Type of Dry Storage Mode Generally, the dry storage mode consists of storing spent fuel in a sealed cask I
constructed principally of nodular cast iron.
The reference to a "Casta-type cask" is not definitive at this point of the report.
The use of the " Castor" designation should be limited to identifying unique cask configurations when it is necessary to refer to them.
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1.1.2.2 Description of Installation i
Recognizing that thel safety analysis report is not site specific, it should I
nevertheless be possible to describe characteristics of the installation that are site independant.
For example, the fact that the cask is vertically free standing is an important installation characteristic.
In addition, the fact that the casks can be installed in appropriately spaced modular arrays is also I
a key characteristic.
The content in this section relating to cask capacities would be more appropriate in Section 1.1.2.4.
Describe basic heat trar.3fer phenomena involved in everyday operation, i.e.,
passive system, heat transfer fins keep fuel rod temperature "alow certain limits to preclude damage, touchable surface temperature.
Dn the effect of multiple casks in arrays on heat transfer.
1.1.2.3 Location of Installation Not applicable.
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CASTOR CASK TSAR COMMENTS
1.1.2.4 Capacity of the Installation
~ Provide the number and type of fuel assemblies to be stored it in the Castor Ic.
Identify each of these fuel types in this section, preferably in tabular form.
1.1.2.5 Spent Fuel Identification The nature of the spent fuel is a principal design feature of the installation and should be described in this section with reference to appendices only for l
detailed data.
Since the primary emphasis is on the Castor Ic cask, it would be sufficient to consider only those spent fuels that are associated with this cask.
In particular, it should be plainly stated whether Castor Ic is for BWR fuel only or for either BWR or PWR fuel.
1.1.2.6 Waste Products The statement that ".no measurable activity is released from the cask storage unit" needs to be documented in the body of the report.
Results appear in Appendices 1 and 3 for gaseous fission product releases into the cask from cladding-tube rupture - 0.16 to 0.18 Ci of 3H, 2.4 Ci of ssKr, and 6.1 to 7.6 pCi of 129I per fuel (PWR and BWR) rod.
If these inventories were released from the cask quickly, as with a catastrophic failure, they would seem to be measurable.
If on the other hand, catastrophic failure can be ruled out, then what about a slow and steady leak? GNS provides some leakrate calculations in the appendices that may well be included.
GNS must clear up the contradiction on the acceptance of casks.
At first they state only that "only clean casks are accepted for storage." Then they state that the " possibility of waste generation is limited to the case when the acceptance of a contaminated cask cannot be refused on the basis of ALARA principles." What are the recommended maximum levels of surface contamination for storage casks?
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CASTOR CASK TSAR COMMENTS
1.1.2.7. Corporate Entities
, Provide description of Gesellschaft fur Nuklear Service, mbH.
1.1.2.8 Time Schedules for Construction and Operation
~Not applicable.
.1.2 General Description of the Installation 3.2.1 Principal Characteristics of the Site A summary description of the principal site characteristics is not relevant to this report and should be so stated.
However, an explanation that a range of^
parameters has been chosen to envelope a variety of sites should be provided.
In accordance with Section 1.2 of Regulatory Guide 3.48 items 1.2.3 to 1.2.7 should be addressed.c 1.2.2 Principal Design Criteria The principal design criteria are outlined in Subpart F of 10 CFR Part 72.
These design criteria establish the design, fabrication, construction,. testing
.and performance. requirements for structures, systems and components important to safety as defined in Par. 72.3w.
A brief discussion of the design criteria that are applicable should be included in this sect'on.
These need not be as detailed.as-required in Chapter 3 but should address those criteria that are applicable to the structures, systems and components covered in this safety-analysis report.
t1.2.3 Operating Systems-Applicable to cask only.
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CASTOR CASK TSAR COM1ENTS
h 1.2.4. Structural features Refer to Figures 1.2-1 to 1.2-8.
Figure 1.2-1 shows the cask with shock
" absorberinsthlled.
Does this shock absorber remain on the cask.when it is installed as a storage' cask?
1.2.5 Passive Decay Heat Dissipation System Provide summary description.
1.2.6 Fuel Handling Not applicable to AR ISFSI.
1.2.7 Special Features That Are Safety Related Response should refer to cask features.
Much of this is contained in Appendix 6.
l 1.3 General Systems Description The' general systems description should deal with AR storage only.
Although the report should focus on the characteristics of a single cask (loaded) with no enclosing structures, Figure 1.3-1 could be included as a generic representa-tion of an AR storage site. All other figures and information pertinent to AFR storage should be deleted.
1.4 Identification of Agents and Contractors Identify sources-of data such as consultants, testing labs, etc.
This would include BAM when they are a data-source.
09/09/82-6 CASTOR CASK. TSAR COMMENTS-
1.5 Material Incorporated by Reference List and supply the documented sources for supporting data applicable to the
' Castor Ic design.
If the data is not easily available or referenceable it should be included in the report.
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SITE CHARACTERISTICS Provide ranges of site-specific parameters which envelope credible. conditions
'under which the ISFSI will operate.
This would include meteorological condi-tions, floods, wind, seismic, etc.
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3.
PRINCIPAL DESIGN CRITERIA 3.1 Purposes of Installation z
.This section does not appear to adequately address the requirements of Regula-tory Guide 3.48.
i 3.1.1 Material to be Stored Detailed descriptions of the " physical, thermal, and radiological character-istics 'of the spent fuels to be stor-1" are required here.
To be included in.
this description are " specific power, burnup, decay time, and heat generation rates." All information should apply to U.S. BWR and PWR fuel assemblies and should be presented in a clear and concise form to be useful to U.S. license al.. 'icants.
3.1.2 General Operating Functions 3.1.2.1 Waste Processing GNS states that "in principle no radioactive waste is generated in a dry cask storage installation." They then cite the exception of decontamination of a i
' cask under ALARA principles.
For AR ISFSI storage conditions the cask would be decontaminated in the reactor service area prior to transfer to the storage area.
Any other decontamination activities required should be described.
GNS i-must substantiate all claims and clarify any contradictions. Waste processing for AR storage is the issue here.
i 3.1.2.2 Transportation As a storage container'the cask indeed needs to be transported within the confines of the storage site. That it can perform this function safely needs to be~ demonstrated, quite aside from its capability as a shipping container.
The
. fact that the storage cask can' survive testing conditions appropriate.for
-transport casks under accident conditions is important'but it must be demon-
.strated that the accident loadings applied ~to a storage configuration. do not-09/09/82-9 CASTOR CASK TSAR COMMENTS.
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result in a compromise of safety.
A condition affecting this analysis is that
.the transport cask has a shock absorber while the storage cask may not.
'3.1.2.3 Utilities Not applicable.
3.2 Structural and Mechanical Safety Criteria This safety analysis report invoke. the performance criteria of transport casks as evidence that the design of the storage cask has a sufficient margin of safety with regard to unacceptable levels of shielding loss, leakage of radio-active materials or increase in criticality.
Howe er, no such criteria are indicated in the body of tne report other than a reference to a 30-foot drop test.
No safety analysis report for a nodular cast iron-transport cask has as yet been submitted for review, nor has it been demonstrated that the performance criteria for transport casks does indeed envelope the most severe design criteria associated with a storage cask.
While specific site specific design criteria for tornados, seismic distrubances etc. may not be available, it should be possible to postulate extreme levels of these environmental conditions or credible accident conditions to show that they do not result in greater damage than would occur under transport conditions.
3.2.1 Tornado and Wind Loadings Postulate crefible extremes for the cask.
L 3.2.2 Water Level (Flood) Design Postulate credible extremes for the cask.
f 3.2.3 Seismic Design Postulate credible extremes for the cask.
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i 3.2.4 Snow and Ice Loading Postulate credible extremes for the cask.
r 3.2.5 Combined Load Criteria Describe criteria selected for the cask.
i 3.2.6 Thermal Loading Describe criteria selected including consideration of factors cited in Subsec-tions 3.2.6.1 - 3.2.6.3.
3.2.6.1 Ambient Air Temperature Range 3.2.6.2 Solar Insolation Range I
3.2.6.3 Temperature Transients 3.3 Safety Protection Systems i
3.3.1 General j
t 3.3.2 Protection by Multiple Confinement 3.3.2.1 Confinement Barriers and System This section must address the design criteria assoc'iated with the confinement barriers-(primary, secondary, and when necessary, insert covers).
The detailed descriptions of the cover and seal systems in the appendices should be consoli-dated and brought forward.
GNS should explicitly define what "no measurabl.e release of radioactive material" means.
Further discussion of the tightness surveillance system is in order here.
Addition of the insert cover or replace-ment of the secondary cover in the event of seal failure must be addressed.'
Any figures'that are presented should be for the Castor Ic.
09/09/82 11-CASTOR CASK TSAR COMMENTS
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3.3.2.2 Ventilation - Offgas J
We have a problem with the GNS statement of "zero-release" from the Castor cask.
"This statement does not acknowledge that any release is possible, yet in the t
previous section (3.3.2.1), it is stated that there is "no measurable release."
Is-this a. contradiction or are they one in the same? Even though ventilation and off gas design criteria are unnecessary here (no structures with the cask exposed to the elements), GNS should make it clear what "zero-release" means.
3.3.3.1 Equipment 1
3.3.3.2 Instrumentation
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The design criteria for the tightness surveillance system given in Appendices 11 and 15 should be consolidated and brought forward.
Emphasis is to be placed "on features to provide testability and contingency for safety purposes."
3.3.3 Protection by Equipment and Instrumentation Selection 3.3.4 Nuclear' Criticality Safety Basis for criticality should be defined that apply to " design basis" U.S. fuels (BWR and PWR).
3.3.4.1~ Control Methods for Prevention of Criticality 3.3.4.2 -Error Contingency Criteria 5
.3.3.4.3 Verification Analysis 1
3.3.5 Radiological Protection
.3.3.5.1 -Access Control 4
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12 CASTOR CASK TSAR COMMENTS
i 3.3.5.2 Shielding i
.Since the report should focus on a single loaded cask and address representative arrays with no enclosing storage structures, and only repair and. maintenance are considered as nonsite-specific operations, the scope of this section is somewhat limited.
Citing Gorleben, Ahaus, or Wurgassen is not appropriate.
They are site specific in the arrangement of casks, all use concrete-walled storage structures to increase the radiation attenuation, and the dose points external to the facilities are not representative, but site specific.
It is stated that "the shielding criteria of the cask are those applied for transport";
i they should be documented.
In addition to the shielding criteria, detailed descriptions of the repair and maintenance operations, to include the times required for the various operations and their bases and the procedures used to compute collective and maximum individual dose, are in order.
Only radiation from the casks should be considered.
Scattering from structures enclosing the cask array should not be considered.
Information concerning the-source field
. at the surface of the cask is particularly required.
Of the reference informa-l tion cited (Appendices 16, 17, 18, and 19) none seems relevant here.
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As noted above, for generic use, the focus of this report should be on the characteristics of a single loaded casks.
However, detailed calculations for representative line and square arrays of casks showing radiation exposure for occupational personnel and skyshine calculations of exposure at various distances i
from these arrays are also recommended.
They will provide e'xpected values.and methods useful to future license applicants desiring to use this report.
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.3.3.5.3 Radiological Alarm System Not. applicable.
3.3.5.3.1 Area Monitoring
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Not applicable.
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l 3.3.5.3.2 Personnel Monitoring L
f Not applicable.
t 3.3.5.3.3 Cask Monitoring All detailed information on the tightness surveillance system should be-consoli-dated and brought forward:
in particular, the information on the pressure measuring system. Discussions of the reliability of the system parts would seem appropriate, the possibility of false alarms due to a pressure drop asso-ciated with assembly cool-down / aging), and a general description of the alarm-thresholds and actions in the event of seal failure.
3.3.5.3.4 Monitoring in the Vicinity 3.3.6 Fire and Explosion Protection
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If the 10 CFR Part 71 criteria for fire and explosion are to be used, they should be specified in this section.
Later on the ability of the storage cask to meet those criteria should be addressed.
f 3.3.7 Materials Handling and Storage GNS should define and discuss their "zero-release design cencept." The surface contamination level criterion being specified by transport regulations should be specified and the U.S. regulations referenced.
Expand and give details of design criteria used to arrive at maximum cladding temperature.
Ambient temperatures and solar insolation conditions should be chosen to envelope. site conditions in establishing design criteria.
Also address design criteria with respect to possible accident conditions (e.g., fire, tipping of cask, etc.).
3.3.7.2 Radioactive Waste Treatment This section should address AR storage only.
For the most part, the GNS comments in the initial paragraph seem adequate for this section.
There should be i
09/09/82 14 CASTOR CASK TSAR COMMENTS
substantiation for their claims that the " casks remain permanently sealed" and that the containment" securely prevents the escape of radioactive materials."
3.3.7.3 Waste Storage Facilities The comments in the report appear to address offsite storage.
Waste storage facilities associated with AR storage are site specific and the responsibility of the power plant.
3.3.8 Industrial and Chemical Safety 3.4 Classification of Structures, Components Provide for cask only.
3.5 Decommissioning Considerations 3.5.1 Storace Casks More information on the neutron activation of the casks is required.
The activation products, activities, and radiation standards mentioned should be stated.
The information in the reference should be included in this section.
The following may be said of the reference:
Appendix 12 - More information is required, e.g., for the reference fuel, a justification of assumptions; the source and method of the neutron flux calcula-tion; the method of ORIGEN activation calculations; and activation calculations at 20, 30, and 40 year intervals as well.
3.5.2 Building and Facilities Under the installation conditions with no enclosing structures, building and
. facilities discussions are not relevant.
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4.
INSTALLATION DESIGN The principal feature of the site boundary, controlled area, EPZ etc., are all I
site specif'ic and need not be dealt with in 4.1, the Summary Description.
How-ever, for structures such as sealed surface storage casks there is a need to provide design bases including, at least, (1) analysis and design procedures for external phenomena, fire a',nd explosion effects, (2) analysis and design t
procedures for normal and accidental loadings, (3) allowable deflections and deformation stresses for structures and (4) consideration given to combination stress loadings.
Furthermore, applicable codes and standards should be cited, f
especially with regard to materials of construction, fabrication and inspection.
i Apparently, a considerable amount of analysis has been performed for the cask l
structural elements in Appendix 6.
However, the partial translation makes it difficult to follow.
While the appendix is the proper place for computational details, the body of the report should provide a summary of the analysis of the structural elements important to safety.
This summary would include such things as a description of the component or structure, the magnitude and directions of j
the applied forces, the method of analysis, the maximum stresses and deflections (if significant), the applicable material properties and the safety margins.
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's 4.1 Summary Description Site-specific details are not applicable and references to typical installations are not generally applicable to this type of report.
This, however, is not intended to discourage consideration of layouts of the storage installation in various generic arrays.
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T-4.1.1 Location and Layout of Installation See Section'4.1.
4.1.2 Principal Features See Section 4.1.
4.1.2.2 Controlled Area Not applicable.
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- 4.1.2.3 Emergency Planning Zone (EPZ)
Not applicable.
l 4.'1.2.4 Site Utility Supplies and Systems Not applicable.
I 4.1.2.5 Storage Facilities Only applicable to single cask and representative arrays-on storage pads (no enclosing structures).
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' 4.1.2.6. Stack-Not applicable.
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4.2 Storage Structures q
Provide design bases for~ cask.
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Y 4.2.1-Structural Specifications l
i Describe the bases and engineering design specifications for cask.
f 4.2.2 Installation Layout Site specific except for generic cask arrays.
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4.2.3 Individual Unit Description r
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Site-specific requirements do not apply to single cask analysis.
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h 4.2.3.1 Function 4
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Limit to single cask.
4.2.3.2 Components.
t Limit to single cask.
4.2.3.3 Design Bases and Safety Assurance i
Limit to single cask.
4.3 Auxil'iary Systems i
I Not applicable.
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4.3.1 Ventilation and Offgas Systems I
Not applicable to single cask' analysis.
4.3.2 Electrical Systems
- Not' applicable to single cask analysis.
09/09/82 20 CASTOR CASK. TSAR COMMENTS w
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4.3.3 Air Supply Systems I
Not applicable.to single cask analysis.
4.3.4 Stream Supply and Distribution System Not applicable to single cask analysis.
4.3.5 Water Supply System Not applicable to single cask analysis.
4.3.6 Sewage Treatment System Not applicable to single cask analysis.
4.3.7 Communications and Alarm Systems The communications and alarms systems referenced in this section are site i
specific and do not apply.
For the installation conditions chosen, it would appear that a discussion of the functioning of the alarms associated with the tightness surveillance system in response to normal, abnormal, and accident conditions is all that is required.
4.3.8 Fire Protection System Regulatory Guide 3.48 requires for this section an identification of fires that could indirectly or directly affect structures, systems and components that are
.important to safety.
This is relevant for assessing the suitability of the storage cask and provides a basis'for the design of the fire protection system.
However, the fire protection system is more closely related to the site charac-teristics than to the cask itself and need not be addressed.
09/09/82 21-CASTOR CASK TSAR COMMENTS
4.3.9 Maintenance Systems For the installation conditions chosen, the GNS comments appear adequate.
'However, the title of the referenced section (Shipping Cask Repair and Mainte-nance) should be included.
4.3.10 Cold Chemical Systems Not applicable.
4.3.11 Air Sampling Systems Not applicable.
4.4 Decontamination Systems As stated earlier, we have a problem with the GNS allusion to their "zero-release design." In any event, discussion of decontaminat' ion systems are not relevant.
For AR storage, decontamination, whether cask or personnel, is the responsibility of the power plant.
4.5 Shipping Cask Repair and Maintenance Regulatory Guide 3.48 requires an indication of the location of the shipping cask repair and maintenance facility which is obviously site specific.
Recog-nizing that we are dealing here with a storage cask, it might be appropriate to discuss those repair or maintenance activities that would affect contamination and occupational exposure reduction.
4.6 Cathodic Protection Address the possibility of corrosion as a damage mechanism.
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4.7 Fuel Handling Operating Systems While the fuel handling facilities are site specific, it would be helpful if the characteristics of the storage cask could be described relating to pre-paration of the cask to receive spent fuel, transfer of the cask, the actual placement of the spent fuel in the container, container sealing and testing, decontamination, preparation for storage and transfer to storage.
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5.
OPERATION SYSTEMS 5.1 Operation Description 5.1.1 Narrative Description 5.1.2 Flow Sheets Only AR storage of a single cask (loaded) with no structures should be con-sidered in this section. Material specific to offsite storage is not relevant.
Radiation source terms required in this section should apply to U.S. BWR and PWR fuel assemblies and should be presented in a clear and concise form.
Information on the tightness surveillance systems seems appropriate here, as well as any other information in the referenced appendices that are pertinent to the installation conditions chosen.
5.1. 3 Identification of Subjects for_ Safety Analysis i
5.1.3.1 Criticality Prevention
.c To insure applicability for U. S. license applicants, we suggest that criticality calculations should be based on the most reactive U.S. design basis fuel.and not on German 2-8T enrichment fuel.
5.1.3.2 Chemical Safety If applicable to single cask.
5.1.3.3 Operation Shutdown Modes Not applicable.
I 5.1.3.4 Instrumentation I
The information in Appendix 15 which addresses instrumentation used to detect j
operating conditions should be summarized.in this section.
The description should include. testability, redundancy and failure conditions.
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'09/09/82 24 CASTOR CASK-TSAR COMMENTS
5.1.3.5 Maintenance Techniques Maintenance tasks associated with the storage cask project should be extracted from the ap'pendix and placed in this section.
l 5.1.3.6 Heat Transfer Design, In this new section summarize results of calculations and/or experiments that show the design criteria in Section 3.3.7.1 have been met for normal operating conditions for a single cask.
Also include heat transfer calculations for a representative in-line or' square array of casks.
Incorporate appropriate Appendix 6, 22, and 24 material in this section with enough detail to judge the adequacy of the calculations and/or experiments.
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5.2 Fuel Handling Systems I
Not applicable.
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5.2.1 Spent Fuel Receipt, Handling and Transfer Not applicable.
5.2.1.1 Functional Description Not applicable.
5.2.2 Spent Fuel Storage As applicable for AR ISFSI.
5.2.2.1 Safety Features Provide description and limits selected for a commitment-to action.
5.3 Other Operating Systems As applicable to single cask.
5.3.1 Operating System As applicable to single cask and representative arrays.
5.3.1.1 Functional Description Include for cask only.
5.3.1.2 Major Components Relating only to cask.
5.3.1.3 Design Description As applicable to single cask.
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09/09/82 26 CASTOR CASK TSAR COMMENTS
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- 5. 3.1. 4 Safety Criteria and Assurance
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As. applicable'to single. cask.
L 5.'3.1.5' Operating Limits l
Provide requested information as appropriate and feasible, focusing on a single i
cask but considering representative arrays.
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5.3.2 Component / Equipment Spares j
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-More detail is rquired in this section.
There should be a discussion of 1
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replacement of the secondary cover in the event that it fails, as well as addi-
- tion of the insert cover in the event that the primary cover fails.
Reliability l
of the tightness surveillance system is also of interest-here.- Design provi-sions to minimize exposure to radi+. tion during maintenance operations should also be addressed..The refererce cited (Appendix 17) says nothing of the.
design features associated wita addition of the insert cover:
it deals only 4
R with the' exposure of personnrI to the wipeable surface activity that might be i
vaporized during welding of the cover.
5.4 Operation Support Syste,s.
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'5.4.1 Instrumentation and Control: Systems l
Provide information requested as applicable to a cask only.
5.4.2 System and Component Spares Provide information requested as applicable.to a cask only.
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5.5.'. Control Room and/or Control Areas No.t applicable.
-5.6 Analytical Sampling Provide information requested as applicable to a single cask.
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6.
WASTE CONFINEMENT AND MANAGEMENT 6.1 Waste Sources Comments here are directed to decontamination of a cask that must be accepted under ALARA principles.
For AR storage, the GNS comments do not seem relevant.
Clarification is needed here.
There is no mention of the wipeable surface activity that might be vaporized during welding rif the insert cover (Appendix 17) or any contamination associated with an accidental release.
6.2 Offgas Treatment and Ventilation For the installation conditions chosen, offgas treatment and ventilation systems discussions are not required.
If the GNS comment is to remain, it must be substantiated.
6.3 Liquid Waste Treatment and Retention Comments here appear to be directed to decontamination at an AFR storage site.
For AR storage, liquid waste treatment and retention is the responsibility of the power plant.
6.4 Solid Wastes Comments here also appear to be directed to decontamination at an offsite storage installation.
For AR storage, solid wastes are also the. responsibility of the power plant.
6.5 Radiological Impact of Normal Operations-This section requires a sunimary of the gaseous and liquid effluents and solid wastes.
Liquid effluents and solid wastes are eliminated because of AR storage considerations; for gaseous effluents, none is provided.
For gaseous effluents from accidental release, the requirements for the amount generated per MT of fuel stored per unit time, quantity and concentration of each radionuclide 09/09/82 29 CASTOR CASK TSAR COMMENTS
released, radiation dose at the perimeter of a generic controlled area, sample collections, and system constraints should be fulfilled.
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7.
RADIATION PROTECTION 7.1 Ensuring that Occupational Radiation Exposures Are As Low As Is Reasonably Achieveable (ALARA) 7.1.1 Policy Considerations The-requirements of this section are, for the most part, site (utility) specific.
In addition, Regulatory Guides 8.8 and 8.10 center on management po)icies, administrative procedures, and design features associated with an installation.
Jio the extent that the guides may be used, the GNS comments seem appropriate.
However, each statement made by GNS in this section should be documented, where necessary, and should cite the specific guide and recommendation it responds to. More detail on the policies during maintenance and optical inspection of
~ he casks is definitely in order.
Comments concerning cast receipt and posi-t tioning for the most part are site specific.
7.1.2 Design Considerations Design considerations of a generic nature should be presented here.
Discussion of the maintenance procedures and time periods required to perform the various functions that lead to occupational exposure is needed.
It should be clear that the design is directed toward reducing the occupational exposure to a minimum.
How the guidance in (or alternatives to) regulatory position 2 of Regulatory Guide-8.8 will be followed is not indicated.
7.1.3 Operational Considerations This section should contair a description of the methods used to develop the detailed plans and-procedures for ensuring that exposure-is ALARA and the criteria and conditions under which various procedures and techniques are implemented for ensuring that exposure is ALARA.
References to regulatory
-position 4 of Regulatory Guide 8.8 and Regulatory Guide 8.10 are definitely site specific and as such, not relevant.
09/09/82 31 CASTOR CASK-TSAR COMMENTS
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- 7. 2 Radiation Sources 7.2.1 Characterization of Sources
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The discussion in this section is inadequate.
All material pertinent to the i
characterization of the radiation sources should be consolidated and brought l
forward from the appendices.
The guide states that "the description should include'a tabulation of all sources by isotopic composition, x and gamma-ray energy groups, strength (curie content), and geometry and should provide the basis for the values." This information should be presented for the various decay times and the burnups relating to U.S. PWR'and BWR assemblies.
7.2.2 Airborne Radioactive Material Sources This section should explain and justify the bases for assuming no releases during normal operations and anticipated occurrences.
(-See previous comments related to this for Sections 3.3.7 and 6.5.)
- 7. 3 Radiation Protection Design Features 7.3.1 Installation Design Features More information is required in this section.
Citing Gorleben (Appendix 3) as a typical laycat is not appropriate.
A single cask and representative arrays should be considered.
The pertinent material in Appendix 6 should be consoli-dated and brought forward.
Since the storage is AR and there are no other structures, many requirements are negated.
However, all potential sources of exposure should be identified and described.
Other requirements appear to be the design radiation dose rate for the storage area and the maintenance and repair activity, and estimates of the radioactive materials that might be discharged, if any, during storage.
7.3.2 shielding More information is required.than is presented in this section.
For the cask, the pertinent material referenced in Section 2.3 of Appendix 6 should be consolidated and brought forward.
All radiation sources under Section 7.2.1 09/09/82-32 CASTOR CASK TSAR COMMENTS
and 7.2.2 are to be addressed. Of Section 2.3 of Appendix 6, the following may be said:
Section 2.3, Appendix 6 - More information is required, e.g., how the mean spectrum was determined for ORIGEN; detail on the effective polyethylene layer thickness calculation; precise descriptions of the source terms for the cask and end piece calculations; more detail on the ORIGEN, ANISN, and DOT codes, with specific input / output; calcu-lations for reference fuel assemblies; full documention of assumptions and computational results.
7.3.3 Ventilation For the installation conditions chosen (no structures), ventilation system discussicns are not required.
7.3.4 Area Radiation and Airborne and Radioactivity Monitoring Instrumentation For a generic installation, referencing the comments under Section 3.3.5.3 of this report may be adequate once the deficiencies noted earlier in that section are corrected.
The information that the guide requests is site specific and, therefore. not relevant to this topical report.
7.4 Estimated Onsite Collective Dose Assessment The discussions in this section are not adequate.
The reference (Appendix 38) only covers the estimated dose during loading of a Castor cask, which is not directly related to cask storage.
What about maintenance operaticns, optical inspection, etc,? What is 10% of the admissible annual dose? The bases, models, and assumptions must be supplied for each dose assessment.
'7.5 Health Physics Program Not applicable; site specific.
09/09/82 33 CASTOR CASK TSAR COMMENTS
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7.6 Estimated Offsite Collective Dose Agreement
.While.it is'true that the offsite collective dose is site specific, GNS should acknowledge accidental release of radioactive gases as a possible source term.
.Any effluent and environmental monitoring program associated with this source term'would remain a site-specific issue.
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CASTOR CASK' TSAR COMMENTS
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ACCIDENT ANALYSIS 8.1 Off-Normal Operations 8.1.1 Event More information seems appropriate here.
For the acceptance of a contaminated cask, only AR storage should be considered.
The specifics of the acceptance control procedures should be stated.
There is no mention of the radiological consequences of accepting the cask and what corrective measures could be taken.
Failure of auxiliary systems should address the problem of a masked accidental release coincident with the failure of a tightness surveillance system component.
Failure of one of the sealing systems does not consider the effects or radio-logical consequences of an accidental release or give any specific indication of how long it would take to begin and complete the necessary repairs.
8.1. 2 Radiological Impact from Off-Normal Operations More information is required here.
Surface dose rates for the Castor Ic should be presented in clear and concise form applicable to U.S. BWR and PWR fuel assemblies at cooling times expected for present reactor inventories.
The exposures quoted by GNS should be fully documented, to include the bases, models, and assumptions.
8.2 Accidents GNS states that there is no accident that will result in a dose of 25 mrem beyond the controlled area.
Regulation Guide 3.48 requires that this statement be shown to be true. The accident analyses cited in the references should be consolidated, made generic in nature, and brought forward from the appendices.
So too should the safety evaluations that are pertinent to the Castor Ic.
8.2.1 External Hazards This section should be entitled " Accidents Analyzed" to conform with require-ments of Regulatory Guide 3.18.
The applicant must prolide a rigorous analysis 09/09/82 35 CASTOR CASK ISAR COMMENTS
of the accident potential for the proposed ISFSI.
This requires an identifica-tion'of the accident followed by its cause and an analysis of its effects particularly with respect to radiological consequences.
Also recovery from the
' consequences of an accident and steps to mitigate the accident must be described.
This must be done for all identifiable accidents.
Relevant material from the appendices should appear in this section.
For each of the external hazards discussed, sufficient documentation should be provided in the body of the report to substantiate claims of no activity release cr increase of radiation.
Insufficient support of this claim requires an accident analysis with emphasis on radiological consequences and accidental dose calculations such as the potential integrated whole-body population dose and 50 year dose commitment.
Describe in detail how fire tests were conducted and how-the design criteria were met.
Give sufficient detail to verify the adequacy of the experiments.
No justification is given for the statement that actual fires will cause temperatures lower than these observed in full scale fire tests.
An experiment described in Appendix 6, Section 2.2.2.1 is the most applicable fire test documented but it applies to an Ia cask.
It does not investigate temperatures the fuel rods will experience nor does it address how the given information can be applied to the Ic cask.
8.2.2 Internal Hazards There is no Section 8.2.2 in Regulatory Guide 3.48.
The discussion relating to operator errors and equipment failure belongs more properly in Section 8.2.1 which deals with specific accident scenarios such as cask drop or other impacts.
That the resulting shock effects or energy inputs do not result in loss of cask integrity must be demonstrated.
09/09/82 36 CASTOR CASK TSAR COMMENTS
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8.2.3 Secondary Effects Describe in detail calculations and experiments verifying that covering the cask, with resultant reduction in heat dissipation, will meet the design criteria.
Appendix 6, Section 2.information is for an la model cask simulating covering the cask.
No information as to the extrapolation to a Ic task is given.
Justify the statement that an insulated cask has a temperature rise of 35 C in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and also that appropriate countermeasures (digging out of the casks) can be completed in an adequate time period.
For example, if it is assumed that cask tip over can occur for the seismic g values postulated, recovery from the tip over must include the ability to right all the casks in a timely manner.
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CONDUCT OF OPERATIONS
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The.information required here refers to that whicn is to be supplied by the license applicant.
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I-10.
OPERATING CONTROLS AND LIMITS We.will expect each applicant for site-specific use of the cask to specify oper-
ional controls and limits that apply to the individual case.
However, GNS aould identify and provide in this section the bases for any generic controls and limits for use of the cask that they determine are applicable for any proposed use.
10.1 Proposed Operating Controls and Limits 10.1.1 Contents of Operating Controls and Limits What about operating controls and limits on cask leak rates? Should they not be considered here?
Describe in more detail the controls on cask surface temperatures limit and give details such as location of temperatures sensors.
10.1.2 Bases for Operating Controls and Limits For any new areas identified under Section 10.1.1, a description of the bases should be provided.
10.1.2.1 Fuel Characteristic Limits Provide the specific power from the reference fuel assembly.
Provide the maximum fuel clad temperature reached by fuel in storage (this value should have been obtained from analysis in Chapter 5, Section 5.1.3.6, for fuel assembly specific power and external phenomena extremes, i.e., maximum ambient temperature, maximum solar insolation, etc.).
1 10.1.2.2 Site Paramter Limits j
l Provide site parameter limits used in the cask design analysis including maximum and minimum ambient temperature and, if relevant, their periods of duration, 1
09/09/82 39 CASTOR CASK TSAR COMMENTS
maximum solar insulation, temperature transient information on maximum expected i
[
site temperature decreases or increases over minimum periods of time, i.e.,
minutes, hours or a day.
While site data should be discussed in detail in
~ Chapter 2, operating limits should be summarized in this section.
(These should I
be related to the analysis performed in Section 5.1.3.6 as to their use in establishing a maximum fuel clad temperature.)
10.1.2.3 Cask Surface Temperature Limit 1
Provide the maximum cask surface temperature limit.
(Fuel specific power and applicable site parameter limits should be used in the analysis performed for Section 5.1.3.6 to determine this limit.)
i 10.1.2.4 Cask Surface /0ff-Surface Dose Rate Limit The limits of 10 CFR Part 72.67 must be met, and this section should be refer-enced.
(The analysis performed for Section 3.3.5.2 should be referenced here.)
I 10.1.2.5 Cast Tightness Control i
t The 10 CFR Parts 72.72 and 72.74 requirements referenced here should be so stated, where applicable.
10.2 Development of Operating Controls and Limits For any new areas identified under Section 10.1.1, a description should be pro-vided under Equipment (Section 10.2.2.1), Technical Conditions and Characteris-tics (Section 10.2.2.2), and any other subsections of 10.2 that are pertinent.
I 10.2.1 Functional and Operating Limits, Monitoring Instruments,and Limiting Control Settings i
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09/09/82 40 CASTOR' CASK TSAR COMMENTS t
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10.2.2 Limiting Conditions for Operations
- 10.2.2.1 1 Equipment The pertinent material referenced in this section should be consolidated and brought forward from the appendices.
10.2.2.2.1 Fuel Characteristics The initial enrichment, weight of uranium, maximum burnup, and minimum decay time since removal from the reactor core shall be given for spent fuel asseinblies stored.
10.2.2.2.2 Site Parameter Limits List site parameter limits applicable.
While limits are site specific, listing them will provide any. potential applicant with a means to compare this informa-tion with a potential site and to determine if the site is enveloped by these limits or if modifications are needed before the cask design and fuel specified can be used.
10.2.2.2.3 Cask Surface Temperature Cescribe conditions for the Castor It cask only.
Give the time to thermal equilibrium for the cask after the fuel is loaded.
The measured surface cask temperature should not exceed the predicted cask surface temperature for the conditions under which actual measurement is made.
Provide in tabular form predicted cask surface temperatures for the reference fuel and ambient tempera-tures, solar insolation values, etc., for comparison with measured values.
10.2.2.2.4 Cask Surface /0ff-Surface Dose Rate Limits 1
Provide in tabular form cask surface and off-surface dose rates at various dis-tance from a single cask and from representative cask arrays.
These predicted values should not be exceeded by measured values under the same conditions.
'09/09/82 41 CASTOR CASK TSAR COMMENTS
i 10.2.3 Surveillance Requirements Generally, GNS comments seem adequate.
However, further information about the
^
maintenance operations may be appropriate.
10.2.4 Design Features 10.2.5 Administrative Controls Little can be said here because of the site-specific nature of the r<quirements.
All material presented should be generic.
Using any information that is specific to Gorleben is not appropriate here.
10.2.6 Operating Controls and Limits In this section GNS need only address the installation conditions chosen. The Regulatory Guide suggests a format for specifying the controls and limits; GNS' identifies some operating control areas and then claims there is no problem.
At the minimum, their "no problem" claim should be documented in more detail.
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09/09/82 42 CASTOR CASK TSAR COMMENTS
11.
QUALITY ASSURANCE i
_This section does not satisfy the requirements of Regulatory Guide 3.48 for the body of the report.
The relevant information appears to be contained in Appen-dix 23 a summary for which should be brought up front to satisfy Section 11.
.The use of American National Standard N46.2-1978 referred to in Appendix 23 deviates from the requirement to use the more recent ANSI /ASME NQA-1-1979 as I
specified in Regulatory Guide 3.48.
However, their tables of contents are identical suggesting that Appendix 23 may meet Section 11 requirements.
Never-theless the review of Section 11 and Appendix 23 will be governed by the requirements of ANSI /ASME NQA-1-1979.
The qual,ity assurance requirements define what is to be contained in a quality assurance program plan.
The quality assurance program plan, in turn, must describe how the requirements will be satisfied.
Thus words like "must be" and "shall be" which appear in Appendix 23 do not belong in a QA program plan; what "is" or "are" should.
11.1 Organization The basic requirements with regard to organization are that the organization structure, functional responsibilities, levels of authority and lines of communication for activities affecting quality shall be documented.
A diagram of the entire organization may be of interest but it-does not, by itself, meet the basic requirements.
Section 1.2.5 in Appendix 23 mixes functional require-ments and lines of communications.
These should be separated and the lines of communication illustrated graphically for clarity.
While Quality Assurance is shown in Figure 1-1 of Appendix 23 as reporting directly to management, it does not indicate at what level.
It would be help-ful if the QA organizational structure were shown, the level of the QA manager in the. organizational structure and the officer or director to whom the QA manager is responsible.
Sufficient information should be supplied to assess s
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~the degree of authority of persons and organizations responsible for estab-lishing quality assurance programs, gaining access to work areas,. identifying quality problems, etc.
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