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Exhibit SHN-028 Commission Mandatory Hearing SHINE Construction Permit Application S f Safety Panel 2 P l 2 Accident Analysis December 15, 2015 , Accident Initiating Events and Scenarios Bases for identification of accidents:


  1. Exhibit SHN-028 Commission Mandatory Hearing SHINE Construction Permit Application S f Safety – Panel 2 P l 2 Accident Analysis December 15, 2015 ,

  2. Accident Initiating Events and Scenarios  Bases for identification of accidents:  Hazard and Operability Study (HAZOPS)  Preliminary Hazard Analysis (PHA)  List of events from NUREG-1537 and the Interim Staff Guidance (ISG) List of events from NUREG 1537 and the Interim Staff Guidance (ISG) augmenting NUREG-1537  Experience of the hazards analysis team  Current preliminary design information Current preliminary design information  Qualitative evaluations within categories  Quantitative evaluations to determine consequences  Postulated an irradiation facility (IF) and radioisotope production P t l t d i di ti f ilit (IF) d di i t d ti facility (RPF) Maximum Hypothetical Accident (MHA)  Establishes an outer limit consequence, bounds other accidents  Most limiting MHA was in the RPF (“Facility MHA”) 2

  3. IF Postulated Maximum Hypothetical Accident  Target solution vessel (TSV) and subcritical assembly support b iti l bl t structure (SASS) integrity lost, Subcritical Assembly target solution spills into Support Structure irradiation unit (IU) cell (SASS)  Maximum inventories assumed TSV in TSV (Internal to  Pool presence ignored SASS)  High radiation detected initiates High radiation detected, initiates alarms and confinement  High efficiency particulate air (HEPA) filters and charcoal adsorbers credited d b dit d  Dose consequences  Worker TEDE: 3.1 rem TSV Dump Tank  Public (site boundary) TEDE: Public (site boundary) TEDE: 0.017 rem 3

  4. RPF Maximum Hypothetical Accident (Facility MHA) (Facility MHA)  The five noble gas g TSV Off Gas storage tanks rupture Purge simultaneously NGRS Compressors  With the maximum inventory y  Contents are instantly released Noble Gas Storage Tanks RAD RAD RAD RAD RAD Al Al Al Al Al  High radiation levels initiate g alarm and cell isolation  Redundant isolation dampers close dampers close RAD Al Condensate  10% of the activity bypasses Knock Out Process Vessel Tank Vent System the isolation dampers  10% of the activity leaks 10% of the activity leaks Radioactive Radioactive through penetrations Liquid Waste 4

  5. RPF Maximum Hypothetical Accident (Facility MHA) (Facility MHA)  Dose consequences  Worker TEDE: 3.6 rem  Public (site boundary) TEDE: 0.082 rem  The MHA consequences are conservative  Simultaneous, instantaneous rupture  Entirety of noble gas is transferred and released  The five tanks are filled to capacity  Additional ventilation isolation dampers would close, but are not credited  Actual doses would be lower  Radiological consequences to workers and the public are within the limits of 10 CFR 20.1101, 20.1201, and 20.1301 , 5

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