ML19305B651
| ML19305B651 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 02/21/1980 |
| From: | Estey H SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER |
| To: | Crow W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML19305B652 | List: |
| References | |
| 15618, NUDOCS 8003200032 | |
| Download: ML19305B651 (12) | |
Text
3 espw wuct. mas c.cnwauv.inc.
- f. YDS 70- /M7 i
A 2101 Hom Rapids Road
~
P. O. Box 130. Richland Washington 99352 Phone: (SC9) 37S-81C0 Telex: 15-2878 February 21, 1980 Mr. W. T. Crow, Section Leader Uranium Process Licensing Branch Division of Fuel Cycle & Material Safety U.S. Nuclear Regulatory Cornmission Washington, D. C. 20555 License No. SNM-1227 Docket No. 70-1257
Dear Mr. Crow:
SUBJECT:
NRC Comments & Questions on License Amendment Application No.18
Reference:
Letter, Robert L. Stevenson (NRC) to H. Paul Estey (ENC),
dated January 24, 1980 Exxon Nuclear Company, Inc. hereby submits its response to the corrr.ents and questions raised by your staff on the subject license amendment application, as transmitted by your letter of January 24, 1980.
' Respective pages of the License Amendment Application have been appro-priately amended in accordance with this response, and seven copies of the amended pages are enclosed. Also, one copy has been sent to Region V IE.
The License Renewal Application has also been appropriately amended to incorporate the commitments reflected in the attached response.
Sincerely, H
aul E ey,!!anager Licensing and Compliance Operating Facilities Enclosures cc: Mr. W. J. Cooley (USNRC Region V IEi b
Ih AN AFFil. LATE OF EXXON CORPORATION 80032000 R
f 0
Response To Coments and Questions on License Amendment Application No.18 (Application Dated November 19,1979)
Exxon Nuclear Company, Inc.; License No. SNM-1227; Docket No. 70-1257 f.
Comment Page 1-5.30, pata. 5.2.2.4.2 - It sitould be confL1med Bia.t (a), (b) and (c) a,te additive,tequitements.
Pa,1a. (c) sitould add Btat, in Bte absence of a fLteptoof ba,trist, special conttots mitt be used to ptevent fLtes and.to conttol use of moderators in fitefigitting in such ptocess arcas. Fu,ttitetmore, (c) appcats to aLicw use of concenttet,lon conttet based sately on adminissta.tive ptocedates.
It sitould be made etext B:1t sucit applications will be Lintitcd to situations wftere Bte nata,te of die process and ope,11tions ma.ke violation of tite concenttation Lir:Lt wtLikety even aftet faifate of any singic conttot.
Response
It is agreed that Sections 5.2.2.4.2(a), (b) and (c) constitute additive requirements, and Section 5.2.2.4.2 of the Application has been modified to show this.
Section 5.2.2.4.2.(c) of the fspplication has been expanded to include the statement, "In the absence of a fireproof barrier, special control shall be used to prevent fires and to control the use of moderators in firefighting in such process areas".
Section 5.2.2.4 of the Application has been expanded to include the statement, "... where the nature of the process and operations made violation of the concentration limit unlikely even after failure of any single contol."
Sections 5.2.2.4, 5.2.2.4.1 ard 5.2.2.4.2 (as modified above) of this Amendment Application have been incorporated into the License l
j Renewal Application as Sections 3.2.2.4, 3.2.2.4.1 and 3.2.2.4.2, respectively.
2.
Question Page II - 2.16b - What is de justification for not employing de usual.ttmpeitature conttats on ne ion exchange column feed stteams and the column itselft
Response
The nomal operating tempersture range for tFe conversion process waste stream is between ambient temperature and 100*F. The ion exchange columns and a significant amount of the associated piping is plastic (PVC, polypropylene and fiberglass) which is used for corrosion resistance where operating temperatures-do not exceed 140*F. The fiberglass ion exchange columns would fail at around 220*F. All of the above temperature points are less than the 275 F (135 C) at which accelerated nitration of the resin could pres-surize the column. In addition to the above process limits on the temperature, the ion exchange column effluent-temperature will be monitored.
a.,'
3.
Comment Page IT - 2.26 - Since, as st:.ted on page 2 of de t~snsnittal letter, it is desited tJta.t the d.ty end af the WR be ticensed at this time, ndditionalinfo,tnttion sitcald be p.tovided iden.tifying the basis for nuclea.t criticality safety ist hat past.t af tJte M1R.
Response
The Waste Uranium Recovery Facility dry end will receive 55 gallon barrels of uranium-contaminated waste and used HEPA filters which will be assayed for uranium content prior to processing.
If chese items contain greater than 150 gU/ item, they will be moved to the second floor of the facility for separate processing. The O
O e.%
w.
w-
kk.
3-M i
is m.g.
2-
- ~i
.J barrels will be dumped and the contents will be sorted, shredded, and separated into low and high uranium content waste. HEPA filters will be shredded and the material separated into low and high uranium content waste. The high uranium content material will be repacked and stored for subsequent leaching.
The low uranium-s contaminated waste will be repacked for burial.
Criticality safety for the dry end of the Waste Uranium Recovery Facility will be assured on a safe batch control basis. The uranium content-of the barrels and filters being dumped will be recorded, and when the accumulated uranium equals one safe batch the equipment will be shut down and cleaned out. The equipment included in the batch limit area will include the barrel dumper, shredder, separator and the barrel filling station. All of the equipment included in the safe batch control area is designed for convenient inspection and cleanout. Any storage areas associated with the dry end of the Waste Uranium Recovery Facility will also be limited to one safe batch.
The use of safe batch control as a method of assuring criticality safety is used in several locations throughout the fuel manufac-turing building and is demonstrated in Part II of Document No. JN-2.
4.
Comment s
Page 11 - 2.27, second and third Lines - Picase state specificdly whd codes will be met by Die building design.
Response
A copy of a letter from the building designer, which specifies the l
codes and standards followed in the design, is attached. A copy of this letter has also been included in Attachment A, Section 7, of the License Renewal Application.
l
ARCHITECTS
. > ENGINEERS CONSTRUOTCRS FACILITIES SYSTEMS ENGINEERING CORPORATION 2305 UTArt AVENUE EL SEGUNDO. CALIFCRNLA 9024S (213) TTO-FAO 9170/ TBS
.m tws maat e.o. ur. nicwuso. w^sninoTow ms2 pen so-am 22 January 1980
'M Exxon Nuclear Company rh[g/g-ov 2955 George Washington Way Richland, Wa 99352 0 0*/t fg8EJC Attn:
Jack Fastabend Ge_tlemen:
The Waste Uranium Recovery Building, to be constructed at Exxon Nuclear Company's Horn Rapids Site, will be used to store and handle special nuclear materials.
This building was designed to the following codes and standards:
Washington State Highway Standard Specification for e
Road and Bridge Construction - Roadway & Parking e
U.B.C. Uniform Building Code, 1979 Edition e
Nctional Electrical Code ANSI-Cl, 1978 Edition
~
e Uniform Fire Code, 1976 Edition e
Uniform Plurbing Code, 1976 Edition Uniform Mechanical Code,.1976 Edition e
e ASHRAE Standards, 1979 Edition City of Richland Ordinance Numbered:
3777 (Adopt. Building Code) e 3877 (Adopt. Plumbing Code) 3977 (Adopt. Mechanical Code)
Very truly yours, s
W g Thomas B. Swearingen, Resident Manager Facilities Systems Engineering Corporation TBS:sjf D
4 me e 4.e.-
., U 1
5.
Commerl Page 11 - 4.76 - Titere appear t.o be exponents omitted in some of
.tlte descriptions of maximum resin loading (e.g., 3rd Lbte up on page 4.76). Please reviac Btis page and 11-4.77 and correst if necessary.
Re_sponse 7
Paragraph 4.6.T3.2(a) and paragraph 4.6.13.3(a) of the application have been corrected with the proper exponents.
In addition, the minimum critical concentration for a twenty inch diameter cylinder 3
is stated both in kgs U/ft. of column length and kgs U/ft. This data is from ARH-600, Table III.B.7-6.
6.
Comment Page 11 - 4.77 - Please reta.te die maximum resin Lcadbtg values quoted by tJte manufacturer.to tite values given based on Bie Exxon experl=ents, and siteto titat Bte tatter are consistent scLth Bte manafaeturer's yalues.
Resconse The maximum resin loading values based on Exxon experiments are
~
lower than the resin loading values quoted by the manufacturer because the manufacturer loading factors represent total ion exchange or equilibrium capacity where as the Exxon numbers repre-sent a breakthrough capacity. Since the chelating resins were developed specifically for copper, nickel, zinc and iron recovery, and the uranyl ions are ccmpeting with metal cations for resin sites, it would be difficult to reach the manufacturers quoted m
9 e
a ee w
.1 resin loading values. The total exchange capacity for the resins quoted by the manufacturer is equivalent to s 45 gU/t, or 1.27 3
kgU/ft, as shown below.
A (1) grams / liter = equivalent / liter x a r (2) Q vol. = (1-s) p Qweight(2)
N Where Q vol = volume capacity of packed bed in equiv./ liter; Q weight = theoretical weight capacity in meg /g(dry); 6 = fractional void volume; w'= water content and; p = density (Sp.G.) of swollen Resin.
Equation (1) yields a larger exchange capacity as follows:
IRC-718 Chelating Resin Total chelating / cation exchange capacity: 5.3 =eg/g (dry)
Moisture Content: 68 percent (nominal)
. Shipping Weight (sodium form): 42 lbs/ft3 = 0.67 kg/t Resin dry weight basis: 0.67 kg/l x 0.32 = 214 g/L 5.3 meg /g x 214 g/1 = 1134.2 meg /1 or 1.134 eg/t 1.134 eg/t x 238 = 45 g/t 3
Paragraph 4.6.13.3(a) of the Application has been rewritten using the manufacturer's maximum resin loading values (instead of the values based on experiments), since these can be calculated. The
~
use of the manufacturers maximum res.in loading values instead of the experimental values has no significant effect on the basic assumptions for the analysis.
(1) Water Suoply and Tretment_, National time Association (2) Ion Exchange, McGraw-Hill, Helfferich, 1962.
I 1
e f;
~
Y eee e.
w
UY raffQa-.a mq;;
,j.'
.- [.I 7.
Coments S Question Paae II - 4.78, para. 4.6.13.3(b) - Tite calc"Idion for noextL conditions of etution is based on dissolution of amonium diuatanate (ADU). t:lltat is de expetimental basis for concluding titat de etution reaction is ahuys cortectly reptesented by be HNO -ADU 3
reaction? It is necessaty for a. valid safety conchaion t.o be able to confinn iltat ne elation ope 11 tion cannot resatt in a. deep plug af sotation above de ninimum critieni concentration in be bed.
Response
Since the IX feed is alkaline (pH>9.0) from the upstream precipitaion of ADU, it is assumed that the form of uranium loading on the resin is ADU of extremely small particle size that has not been removed by the upstream centrifuges and filters. Since the exact resin loading mechanism and form of uranium loading is unknown, it was decided to experimentally deternine the maximum concentrations of uranium in and U 0 2N nitric acid, by dissolving excess amounts of ADU, U02 38 to saturate the 2N nitric acid.
These uranium concentrations are compared to the concentrations derived theoretically, from the following generally accepted equlibrium dissolution reactions.
U02 7 + 6NH03 + 2U02 (NO )2 + 2NH NO3 + 3H O (NH)2 ADU:
3 4
2 4
2N nitric yields 0.67 Mole of UNH or 159 gm U/t 2 (NO )2 + 2N02 + 2H O UO : UO2 + 4HNO3 + U0 3
2 2
2N nitric yields 0.5 Mole of UNH or 119 gm U/t 2 (NO )2 + 2NO + 4H O 3UO2 + 8HNO3 + 3UO 3
2 2N nitric yields 0.75 mole of UNH or 178.5 gm U/t
1 2 (NO )2 + 2N02 + 4N 0 U03 8 + 8 HNO3 + 3U0 U0 3
2 38 2N nitric yields 0.75 mole of UNH 3U 0 20 HNO + 9002 (NO )2 2N0 + 10 H O 38 3
3 2
2N nitric yields 0.9 mole of UNH or 214 gm U/t As can be seen, the latter equation gives the h'ighest uranium concentration.,This compares with cxperimental uranium saturated 2N nitric acid concentrations of 97 gm U/t for ADU, 53 gm U/t for U0, and 124.6 gm U/t for U 0.
It should be noted that in 2N 2
38 s1 wer but nitric acid, ADU dissolves quickly and completely, U 038 complete, and UO2 probably does not reach saturation in 2N nitric.
It is very doubtful that U 0 w uld load on the column. The only 38 source of U 0 w uld come from a scrap uranium UNH stream.
UNH is 38 prefiltered, precipitated, centrifuged (3 centrifuges in series) andfiileredagainpriortoentrytotheIXcolumns.
3.
Page it f.78, pata. (c)
Question (a)
What.is de basis for assur:ing a ::ero resin Leading schen de interstices were assumed filled tein AQU for de ceten9dion reported heret
Response
Ian exchange is typically a surface phenomenon where the resin contains bound groups carrying an ionic charge in conjunction with free ions of an opposite charge that can be displaced or " exchanged."
l O
J.
~
~
'D ~
..s The total surface area is comprised of the external surface of the resin particles plus the areal surface of macropores, therefore, resin loading and bed packing occur in the same space.
Question (b)
The vdues quoted for normd resin unloading appett to be smart compared to de uncerta.inty in, and possible impact af, resin bed void volume. Are bere no me.asurements af resin bed void volume dat would be dbteetig appW"Me to be sinrntion analyzed?
Respo.n Three alternate methods are available for determining the resin bed void volume:
- 1) Manufacturers report void volumes of 30-40 percent;
- 2) Manufacturers give a bulk censity and particle density with the
~
relatio'nship, ob = pp(1-c) where ob = bulk density, pp = particle density"a'nd c = void fraction; For the resins to be utilized, the bulk density is 42 lbs/ft3(0.67 kg/1),'_ and the particle density (or Sp. G.) is approximately 1.09,
^
representing a 38 percent voi tolume.
- 3) Volumetric Measurement Laboratory measurements yield an average of 39.3 percent void volume. There appears to be good correlation for a void volume of 40 parcent. The situation analyzed assumes a 50 percent void volume.
Question (c_1_
Why was it assumed tlat AQU would nat fili ne unpacked section? -
e v*
+m.
?
-g
^
10 -
3
. 1
Response
If a surge of ADU in a concentration considerably greater than the 300 ppm U limit were to enter the column the ADU would not accumu-late on top of the resin bed, but would pack into the void spaces, s
as analyzed, c;/asing the column to blind. Differential pressure measurements and controls preclude packing of the bed to a point where the upper section of the column would accumulate ADU.
D w
O F
=%em p
-:J[:( _=
~,.
4Sh e
~
b
-9me 9
t t
4 o
O 9
t' b
~
~
ATTACHMENT
SUMMARY
OF CHANGES IN DOCUMENT NO. JN-2 Page No. Section No.
Change I-5.29 I-5.2.2.4 Added statement to the effect that concentration control may be used where the nature of the process and operations make iolation of the concentration limit unlikely even after failure of any single control.
1-5.30 I-9. 2. 2. 4.'2 Confirmed that (a), (b) & (c) are additive require-ments by adding the word "and" after (a) & (b).
Added the statement, "In the absence of a fireproof barrier, special controls shall be used to prevent fires and to control the use of moderators in firefighting in such process areas".
3 II-4.76 II-4.6.13.2(a) Changed"kgs/ft."to"kgs/ft." (oneplace).
II-4.77 II-4.6.13.3(a) Modified the first paragraph at this section to use resin manufactures data rather than ENC's experimental data.
II-4.77a II'~4.6.13.3(a) Added new page; corrected' exponent; clarified units of minimum critical concentration; added reference.
e "f