ML19345G996
| ML19345G996 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 11/17/1980 |
| From: | Kaplan A GENERAL ELECTRIC CO. |
| To: | Shum E NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 8104221004 | |
| Download: ML19345G996 (52) | |
Text
_
'l hb /70 / //3
['
GEN ER AL h ELECTRIC NUCLEAR ENERGY Is d
' I / o, PRODUCTS DIVISION COCKirgo N g WILMINGTcN MANUFACTURI.'JG a CEPARTM ENT CASTLE HAYN E ROAO + P. O. BOX 730. WILMINGTON. N, 8401. (9 323 5000 w
1 DEC 0
- 650 >
' November 17, 4
1980 4
.}-
MAIL SECTICM D
./. CCKET CLERX, I?
Director O
Office of Nuclear 11aterial Safety & Salg;WrdM'f y
'<o U.
S. Nuclear Regulatory Commission Washington, D. C.
20555
\\
2 5-Attention:
Dr.
E. Y. Shum U
[.ECEWED Uranium Process Licensing Section t
5 DEC 02 ESO >, 7
]d v.3 7.ym '[
11/S 396-SS Gentlemen:
T.
aL o
Reference:
NRC License SN11-1097, Docket #70-1113 c/
o Subj ects:
- 1) 5!ODIFICATION 1 TO APPLICATION A11ENDt!ENT N-2, EXPANSION OF PLANT CONVERSION CAPACITY
- 2) h!ODIFICATION 1 TO APPLICATION A11END21ENT N-4/S-15, REPLACE 11ENT INCINERATOR FACILITY With reference to activities authorized by SN'.!-1097, General Electric Company hereby encloses the additional information requested in your recent letter related to our requests for amendments to SN11-1097, concerning a planned replacement incinerator facility and a planned addition to UF -to-UO2 conversion 6
capacity, at the GE fuel fabrication plant in Wilmington, N. C.
The following attachments are enclosed, which contain the specific information requested: - Conversion Plant Expa1sion - Incinerator Replacement - Environmental Report (NEDO-20197, January 1974) l General Electric Company personnel would be pleased to discuss this matter with you and members of your staff as you deem necessary.
,k Very truly yours, S
g III ENDI@~{jY GENERAL ELECTRIC COi!PANY f' n;mm ud *_k
/
gq l
- '..,,m. - n.
h y
a.
c.
h,N,% %
Okh ^
4 *>
Ik5 A3 Arthur L. Kaplan, 3Ianagerf, 2
Licensing & Compliance Audigs.
!!/C J26 ALK:bmw NSD/Sco-L
^ $it, !!i THIS DOCUMENT CONTAINS N
31 : !:!$a 6.10423400%.
P00R QUAUTY PAGES
a GENERAL h ELECTRIC Dr. E. Y. Shum November 17, 1930 ATTACm!ENT 1 QUESTIONS ON CONVERSION PLANT EXPANSION 1.0 Question e
Page 1 - Amendmed Lettet - Tite lettet states hat de addition "wouid inc< tease de conve.tsion capacity by 40%."
In NEDC-20197 (page 4-42),
it is s.txted hat de "Wilmington piad can supply de annual f eed 1equitements fo.t mcre uan a hand.1ed 1000/MWe Light-untet.teacto.ts."
Can an additional statement be ptovided tint cle11ty demonsttates tite ptesent need for de plant expansion?
Please ptovide detailed discussion on the altstnatives on siting of tite proposed plant expansion and also tite altetnatives on UF,
t convetsian opetational ptocess. Fot botit discussions, plcase quantify tile impact, advantage and disadvantage as mucit as possible.
1.1 Referenced Paragraph in Amendment Letter There are at present five process lines for conversion of in the manufacture of nuclear fuel at the Wilmington UF6 to UO2 plant.
General Electric proposes to add two additional process lines which would increase the conversion capacity by about 40"o.
1.2 Ref erenced Statement in NEDO-20197 (page 4-42)
The uranium dioxide fuel produced in 1 year at the Wilmington plant can supply the annual fuel requirements for more than a hundred 1000-MWe light-water reactors.
The electrical l
energy output from these nuclear reactors is the same as that which would be produced if 250 million tons of coal were consumed in coal-fueled plants.
l l
1.3 GE Response to Question l
l The major thrust behind the addition of UF -to-UO2 conversion 6
capacity is to implement use of the GECO process, a dry conversion process which produces a greatly reduced environ-mental impact from that already extremely small impact from present ADU conversion operations; as well as to take advantage of the improved economics associated with GECO conversion as compared to the presently used ADU conversion.
l l
l l
~
r. E. Y.
S'. S.c.
ovember 17, 1980 A t tac hmen t 1 - page 2 Also, our intention is to maintain the present ADU conversion capacity intact for use when the additional conversion capacity might be requ. ired to meet business needs.
A statement of present need as requested is summarized below:
Imple-Alternatives mented?
Reason e
o Add GECO Yes To take advantage of environmental conversion and economic superiority of GECO over ADU conversion.
o Add ADU No Increase in conversion capacity conversion is not needed at this time.
o No addition No Business decision was made to take (neither advantage of environmental and GECO nor economic superiority of GECO over ADU)
ADU conversion.
2.0 Question Pages f and 3 - l'Ecase ptovide a demogtaphy up to a 50-mile ?adius frcm site and.teflecting the most catteat paptia.ticn d.Lsttibation. Also, if possible, ptaject the fakte poptlation 9.toteth in the area at the eid af the plant's Life.
2.1 Ref erenced Information in Attachment 1, Pages 2 and 3 The five county area surrounding the plant site is essentially rural with a low population density.
The population characteristics of the five county area are below.
Population
- Density, 1970 Percent Persons per County Population Urban Square Mile Bladen 26,477 0
30.0 Brunswick 24,223 0
28.3 Columbus 46,937 8.9 49.7 New Hanover 82,996 69.5 448.6 Pender 18,149 0
20.0 The closest metropolitan area is the city of Wilmington with a 1970 population of 46,169.
Wilmington is the central city of the Wilmington Standard Metropolitan Statistical Area (SMSA), defined as New Hanover and Brunswick counties.
l l
l
Dr. E. Y. Shum Sovember 17,-
1980 o
A t tac hmen t 1 - Page 3 Wilmington SMSA characteristics are shown below:
City of Wilmington 46,169 Other Urban 11,476 Total Urban 57,645 Places of 1000-2500 Population, Total 5,584 Places of <1000 Population, Total 2,434 Other Rural 41,556 Total Rural 49,574 Total SMSA Population 107,219 Castle Hayne, the nearest community (3 miles north) has a population of 700.
Other than Wilmington, only three centers within 20 miles of the site have populations larger than 1000.
Population centers within a 2 ile radius of the plant are as follows:
1970 Popu-Location from Population Center lation Plant Site Burgaw 1744 16 miles north Wrightsville Beach 1701 11 miles southeast Carolina Beach 1663 20 miles south Located 45 miles to the northeast are Jacksonville, N. 'C.,
with a 1970 population of approximately 16,000, and the nearby Camp LeJeune (U. S. ' Marine Corps) which had a 1970 population of 34,549.
During the 1960-70 period, population growth in the five county area has been significant only in the Wilmington SMSA, principally in suburban areas.
Though New Hanover County's l
growth was 15.7 percent over 10 years (11,254 persons),
l Wilmington's growth was only 5 percent.
Projected growth for the area indicatds continuation of these trends.
l 2.2 GE Response to Questions l
The population within a 50-mile radius has been obtained.
We will utilize this ir. formation to perform an analysis of l
potential radiation exposure to the public, considering the total dose commitment to the population within a 50-mile radi?s of the plant.
l
Dr.
E. Y. Shum Novembtr 17, 1980
. - Page 4 3.0 Question Attacinent 1, Page 12 - It is merttioned that a cooling.toteer nd 200-ton tattet chit.Ler teill be installed. Will.the.se attits occuptj any of the ptevicus open Land on the site or teill they be toca.ted in a. teas in schich const'utc4 ion ha.s a.Eteady occa,tred?
3.1 Referenced Information in Attachment 1, Page 12 (4) Add'the services required to support GECO process installa "
tion in FMOX.
o Install unste treatment filtration capacity (inertial filter).to remove uranium solids from defluorinator scrubber solutionc.
o Install additional GECO offgas vacuum system capacity of 170 SCFM.
o Install a cooling tower (fully automatic of 8.2 million Btu /hr capacity) and a 200-ton water chiller to provide cooling water and chilled water for FMOX facilities.
3.2 GE Response to Question The cooling tower and the 350-ton
- water chiller both will occupy areas in which construction has already occurred.
The chiller will be located inside the fuel manufacturing building at the west side of the building.
The cooling tower will be located outside the building near the northwest corner.
4.0 Question Attaciment 1, Page 13 - Kijitogen for the convetsian reactor and the defluo.~ha. tor is supplied f tom a dissocia.ted amonL1 (CA) ststem. Whe.te j
is thi.s unit loca.ted and scha.t ptovisions are made to avoid styd.togen fLte.s or explosiorts in the. ptoduction unit and Jte. hyd.togen disttibaten systen?
4.1 Referenced Information in Attachment 1, Page 12 2.2 Process Description - The GECO process for converting uranium hexafluoride (UF ) to uranium dioxide (UO ) is a 6
2 direct dry process.
This process, developed by the General Electric Company, has been through numerous development steps at Wilmington since 1972.
The GECO
- Changed since the original submittal.
Dr. E. Y. Shum Sovcmb:r 17, 1980 a
A t tachmen t 1 - Page 5 process to be implemented in the planned expansion, is the same as that currently in use for the two GECO lines presently operating in FMO.
This process is described below:
(1) Vaporization - Uranium hexafluoride (UF ) 15 6
received in steel cylinders containing 4800 pounds of solid material.
The cylinder is placed in an autoclave and heated by the condensing steam.
The UF6 melts at 1500 F and the liquid is heated to about 1800 F developing a gas pressure of 50-psia.
The hot UF6 gas is fed to the reactor.
(2) Reactions - The reactor is a vertical, cylindrical chmnber.
Gaseous UF'6, hydrogen from dissociated ammonia (DA), and oxygen from dry air, are introduced through a. nozzle assembly into the top of the reactor.
The critical flow rate of each component is measured and controlled within i 2% of the component parameter.
4.2 GE Response to Questions The system supplying dissociated ammonia for the chemical conversion reactor is in a structure located about 100 feet west of the fuel manufacturing building.
There are no special precautions taken to avoid hydrogen fires or explosions in the production unit or in the hydrogen distribution system because of the safeguards inherently built into these systems as described below:
o Dissociated _ ammonia production unit
- Dissociated gases are cooled in the unit and pressure regulated to 7-psig (0.5 kg/cm2 gauge).
- Pure hydrogen will not explode unless there is oxygen or air present and the hydrogen content of the mixture has to be less than 75%.
Air is excluded from the system by design.
o Hydrogen distribution system
- The piping used for the hydrogen distribution system consists of all-welded lines.
Air is excluded from the lines by design.
2
- Pressure in the line is limited to 15-psig (1.1 kg/cm )
gauge by a pressure reducing valve.
- Lines are. purged with nitrogen and pressure-tested at 100-psig prior to each use of the, system.
E Dr. E. Y. Shum dovember 17, 1980 A t tac hmen t 1 - Page 6 5.0 Question Pte.ue cLttify Sectan 2.1 on Page 11 venus the table on Page 13.
5.1 Information Referenced'in Section 2.1 on Page 11 2.1 - Plans for Expansion - At the present t ime, there are three ADU production lines and two GECO production lines for UO2 powder.
The sixth existing line (UPS) is used for scrap recycle.
These production lin'es are located in the older part (FMO) of the fuel manufacturing building.
Present project plans call. for the addition of two GECO production-lines for UO2 powder in the newer part (FMOX) of the fuel manufacturing building.
In addition, one existing ADU line in~FMO has been converted to the GECO process design.
Two of the existing ADU powder production lines will be retained for short term ' fuel market growth and for capacity to produce JNF powder and B&W contracted fuel pellets.
A third ADU line will serve as a dual ADU/UPS production line.
Powder preparation systems, material handling equipment, services, and support equipment for the additional GECO lines will also be installed.
5.2 Table on Page 13
~
Conversion Lines Before & Af ter Project:
Before -
After -
FMO 3 ADU
- 2. 5 ADU*
2 GECO 2.0 GECO 1 UPS 1.5 UPS*
FMOX 0
2.0 GECO UPS 1
1.5 Plant Capacity 5
6.5
(# lines producing virgin UO )
2 Total Lines 6
8.0
- One ADU line will be utilized 50% to supplement UPS output.
5.3 GE Response to Question At present, there are.six conversion lines in the fuel manufacturing building.
Three of these lines convert UF6 to i
UO2 using the ADU process.
Two of these lines convert UF6 i
l to UO2 using the GECO process.
l l
t
Dr. E. Y. Shum November 17, 1980 A t tachmen t 1 - Page 7 Also, one existing production line is the so-called " uranium purification system (UPS)," used for recycling most. uranium scrap materials.
These lines are all presently in the older part (BIO) of the fuel manufacturing building.
Thus, the present configuration for UO2 is as follows (five UFG + UO2 conversion lines and one scrap + UO2 conversion line):
3 ADU lines (UF6 + UO2) r 2 GECO lines (UF6 + UO )
1 UPS line (Scrap + UO )
Present plans call for the addition of two GECO conversion lines in the newer part (DIOX) of the fuel manufacturing building.
Two of the three existing ADU lines will be kept in reserve to accommodate short-term fuel market growth (if it occurs) and for capacity to produce powder for Japan Nuclear Fuels (JNF) or Babcock & Wilcox under a contract for supply of PWR fuel pellets.
Also, the third of the three existing ADU lines will be utilized about half of the time for UF6 to UO2 conversion and the rest of the time for conversion of scrap to UO2 (UPS).
Thus, the final configuration for production of UO2 is as follows (6.5 UF6 + UO2 conversion lines and 1.5 scrap + UO2 conversion lines):
UO ) - in n!O building 2.5 ADU lines (UF 6 + UO ) - 2 in M10, 2
2 in DIOX 4.0 GECO lines (UF6+
2 1.5 UPS lines (Scrap +UO ) - in D10 building 2
Effectively, we will end up with eight conversion lines in the fuel manufacturing building, as described above, an increase of two over the present total.
6.0 Question Attacitmertt 1, Page 16 - Wlutt ptovisions ate made.to enou,te.that lupitagen cannot pass utcugit 6te convetto.t.teactat, pa.tticula.tig undet upset conditions? Wlutt is die fa.te of die smali amourtt ~(0.001%) of Bte U C3g and UOgFg posade.ts tha.t pass utougit Die primary fit.tet?
6.1 Referenced 11aterial tin Attachment 1, Pages 13, 16 & 17 9
i 2.2 - Process Description - The GECO prccess for converting uranium hexafluoride (UF ) to uranium dioxide (UO ) is a 6
2 direct dry process.
This process, developed by the General Electric Company, has been through numerous development steps
~
'Dr. E. Y. Shum
'Novemb r 17, 1980 A t tac hmen t 1 - Page 8 at Wilmington since 1972.
The GECO process to be. implemented in the planned expansion, is the same as that currently in use for the two GECO lines presently operating in FMO.
This process is described below:
(1) Vaporization - Uranium hexafluoride (UF ) is received in 6
steel cylinders containing-4800 pounds of solid material.
The cylinder is placed in an autoclave and heated by the condensing steam.
The UF6 melts at 1500 F and the liquid is heated to about 1800 F developing a gas pressure of 50-psia.
The hot UF6 gas is fed to the reactor.
(2) Reactions - The reactor is a vertical, c ylindrical chamber.
Gaseous UF6, hydrogen from dissociated ammonia (DA), and oxygen -from dry air, are introduced through a nozzle assembly into the top of the reactor.
The critical flow rate of each component is measured and controlled within i 2% of the component parameter.
~
The chemical reactions for this process are:
o Primary reaction -
- 1/3 U 03 8 + 6EF + 3H O + 0.3702 UFg + 6H2 + 3.202 2
o Secondary reaction -
UF6 + 2H2+O2 + UO F2 2 + 4HF About 80% of the UF6 is converted to U 03 8 and the remaining to UO F These reactions take place as a flame in which 9 2 the UF6 burns in the presence of hydrogen and oxygen.
Excess air is provided to ensure complete consumption of the hydrogen.
Interlocks such as flow, temperature, and flame sensors ensure safe operation of the reactor.
The reactor pressure is controlled to a sub-atmospheric pressure.
A special high-volume vacuum scrubber system pulls the gases from the reactor through the filters and HF recovery system.
U03 8 and UO Fg 2 powder, water The hot reaction products, vapor (H O), hydrogen fluoride (HF), nitrogen (N ),
and 2
2 oxygen (02) are discharged from the bottom of the chamber to the primary filter.
(3) Solids separation - The reactor product contains U 038 and UO F2 2 powder which must be removed from the gaseous phase.
This separation takes place in the primary filter, containing hollow, porous monel filter tubes.
The powder is collected on the external surface of the filters and I
the gas is pulled through the porous metal by a high volume vacuum system.
The efficiency of these filters is 99.999%.
[.
Dr. E. Y. Shem
'Novemb:r 17, 1930 A t tac hmen t 1 - Pw:e 9 (4) Defluorination - The defluorinator is a rotating, gas-fired kiln, similar to the ADU defluorinator.
Dry powder f rom the primary filter is f ed into the defluorinator and dissociated ammonia and steam are' introduced into the discharge end flowing countercurrent to the powder.
In the defluorinator, the fluoride is removed from the UO F2 2 and the U 03 8 powder is reduced to.UO2 at temperatures
~
up to 7000 C.
The UO2 powder discharged from the defluorinator is collected in 5-gallon cans, weighed, and sent to the powder preparation operation.
The gas stream removed from the front of the defluorinator is cooled and scrubbed with deionized water and discharged to the process ventilation system.
Ammonium hydroxide is added to the scrub water to neutrlize the hydrogen fluoride, and the water is sent to waste treatment.
This is the only systematic loss of uranium from the GECO process.
(5) HF Recovery - The gas stream from solids separation contains hydrogen fluoride (HF), water vapor (H O),
2 nitrogen (N2), and oxygen (02).
This gas passes through an absorption system to recover the HF as an acid solution.
This is a standard absorption system commonly used in the chemical industry for recovery of acid gases.
The acid solution contains about 30% HF.
It is purified by distillation and stored for sale or disposal.
The gas from the absorption system contains mostly nitrogen and oxygen with trace concentrations of HF and water vapor.
This gas goes to the vacuum system where it is scrubbed with ammoniated water to remove any HF and discharged to the process ventilation system.
(6) Waste Treatment - The waste water from the GECO process originates in the defluorinator scrubber and the vacuum system.
Both contain ammonium hydroxide and a small amount of fluoride.
The water from the defluorinator scrubber is pumped to a high ef ficiency filtration system (inertial filtration) for recovery of uranium solids.
The waste water is sent to waste treatment where the solution is treated with lime to precipitate the fluorides, and the ammonia is recovered.
The ammonia as ammonium hydroxide is returned to the process.
The residual solution is ' pumped to a lagoon where the calcium fluoride precipitant is settled.
.. _. e
=..
.___=._. _ _ :._ w.,
u.
~
Dr. E. Y. Shum November 17, 1980 A t tac hment 1 - Page 10 6.2 GE Responses to Questions (1) There are provisions to assure that hydrogen wiil not pass through the reactor even under upset conditions.
These are:
o-The reactor gases are always maintained in an oxidative environment (i.e., ratio of H2 to 02 is always
<1.9; minimum H /02 ratio of 2.1 required for detonation),
2
~
o Gas inlets are automatically shut off and the reactor shut down under " upset conditions" such as:
Loss of vacuum inside the reactor High hydrogeri~ ~ flow"
~
No hydrogen flame o
After reactor shutdown, a five minute post-operation purge of the system with nitrogen occurs.
(2) The small amount (<0.0001%) of U Og and CO F2 2 powder 3
that passes through the primary filter is carried into the HF recovery system with the of f-gas from the primary filter.
There this powder is captured by the exhaust gases that go to the roof scrubber and HEPA filter in the chemical area exhaust stack.
This stack is monitored daily for compliance with requirements for uranium and fluoride contents in gaseous effluents to the atmosphere.
7.0 Questions Pages 16 and 17 -
(1) Ts the UFf int,toduced to the convetsion teacto.t ccmpletelt) tcacted undet apset condi.ticns? Ls u,taninm ca,ttled cn occasinn irtto the vacuum system sc,tabbet?
(2) L'htt picvisicrts a,te made to ensu,te -tha.t unteacted hud,togen f.tcm dissociated amcrtia is not discha,tged to the offgas f tcm the i
l defLuc. tina ta.t?
7.1 Referenced Material on Pages 16 and 17 Please see Section 6.1 on Page 7 of~this attachment.
7.2 GE Reply to Questions (1) There are cases where UF6 could be carried through the reactor under upset conditions.
For example, if both
.e-Dr. E. Y. Shum
.Novemb r 17, 1980 A t tachment 1 - Page 11 the H2 and 02 (air) systems failed at the smne time (double f ailure), some unreacted UF6 could pass through the system before the inlet valves automatically closed.
(They close within a few minutes if such upset conditions occur.)
Under.such conditions, most of the UF6 will condense out into the pipes as UO F2 2 and travel into the primary filter, and then be caught in the hydrogen fluoride recovery system.
The small remainder will be caught in the off gas system and be exhausted to the roof scrubber where it would be converted to UO F22 in liquid form.
Thu s all such UF6 would be trapped before reaching the roof exhaust stack.
(2) Please see the answer to question #1 above.
No significant quantities of. unreacted hydrogen can reach the defluorinator because of the provisions described in the above answer to ensure that no unreacted UF6 passes through the conversion reactor.
S.O Question Page 17 - Ate die gas st'tcams f tom Bte defluoMnatc.t, Ble ptima.tij filtet and 6te vacuum stfstem combined istto single sitcam?
8.1 Referenced Material on Pages 16 and 17 Please see Section 6.1 on Page 7 of this attachment.
8.2 GE Response to Question The gas from the primary filter, which contains HF, water vapor, nitrogen and oxygen, as well as the very small quantities of U 03 8 and UO F2 2 (0.00017e of the powder in the gaseous phase before passing through the primary filter),
all goes to the HF recovery system.
This is a standard absorption system commonly used in the chemical industry for recovery of acid gases.
The gas from the absorption system goes to a vacuum system where it is scrubbed with ammoniated water to remove any HF and then discharged to the process ventilation system.
The gas stream removed from the front of the defluorinator is cooled and scrubbed with ammoniated deionized water and discharged to the process ventilation system.
Thus, eventually, the gas stream from the primary filter as well as those from the vacuum system and from the defluorinator, are all discharged into the sane process ventilation system.
Dr. E. Y. Shum Novembcr 17, 1980 A t tac hmen t 1 - Page 12 9.0 Question Pages 13,16 astd 11 - Please ptovide a block ficw diagtam siwtcing tite flow of autium and ottu cincmical. reac. tads to cLttif t) tite rcuting of ptocess siteams.
9.1 Ref erenced h!aterial on Pages 13, 16 an'd 17 Please see Section 6.1 on Page 7 of this attachment.
9.2 GE Response to Question The following is the requested diagram.
BLOCK FLOV DIAGRAM SHOVING FLOW OF URANIUM & OTHER CFEMICAL REACTANTS UF6 Cylinders Solid UF5 Vaporl:ation Chambers H2 Gas UF6 Gas 2 Gas GECO Reaction Vessel N Gas 2
U033 & UO F22 Powder in Casecus Phase F,
Vater vapor, Primary Filter HF Recovery System e
N2 &02 in Gaseous
=
HF Liquid Off gas U Og &
22 Powder F
U Storage While Vacuum System Awa i t i ng Gas from -
D ef luorina tor OU gas is o by V
Sale or UO2 Vaste Process Ventilation System Powder Tr ea tmen t Off gas 5-Gallon Pails S tack for Discharge to Environment
Dr.
E. Y. Shum
' Novembcr 17, 1980
- - page 13 10.0 Question Page 24 - The statemer.t tha,t "the d,tij convetsian ptocess does of f et an envitomental advarttage due to the lowc,1 volume of Liquid tatstes genetated pet uutit weight of tutartium hexafluoride convetted" does not seem to be substantided by the data given in the table in Section 6.5.
The ptajected volume in the table is 501, gtea.tet than the istltial voiume (1.8 MGPO vs.1.2 MGPO) and tJie plaitt thtoughpit inc.tcase is giv en a.s 40*,. Plea.se ciarify this.
10.1 Ref erenced Information on page 24 The liquid wastes from both conversion processes can be treated using similar technology.
The dry conversion process does offer an environmental advantage due to the lower volume of liquid wastes generated per unit weight of uranium hexa-fluoride converted.
10.2 Table in Section 6.5, pages 27 and 28 6.5 Ef fluent Characteristics - The ef f ects that the proposed actions have on plant effluent streams are presented below in tabular form.
The average allowable releases for both 1978 and the forecast allowable releases for the period of proposed licensing action are shown in order to provide a basis for comparison.
Allowable releases are those quantities specified either in State issued environmental permits or Nuclear Regulatory, criteria or license conditions in the cases of uranium chemical concentration or activity concentration.
Actual releases are and would be expected to continue l
below these levels.
Allowable Releases 1978 Forecast Treated Liquid Discharges to River o process F luor ide, average pounds / day 29 80 Nitrogen, average pounds / day 77 145 Copper, average pounds / day 1
1 Nickel, average pounds / day
.5
.5 Chromium, average pounds / day
.5
.5 Volume, million gallons / day 1.2 1.8 Activity concentration, uCi/cc 3 x 10-5 3 x 10-5 j
,pH, standard units 6-9 6-9 Treated Discharge to Atmosphere o Sanitary Volume, million gallons / day 0.075 0.075 pH, standard ~ units 6-9 6-9 Biological oxygen demand, average pounds / day 18.8 18.8 Total suspended solids, average pounds / day 18.8 18.8
'Dr. E. Y. Shum
- Novemb2r 17, 1980
. - Pnge 14 Allowable Releases 1978 Forecast o Activity concentration, uC1/cc 3 x 10-12 3 x 10-12 o Nitrogen dioxide No visible No visible emission emission Transfer of Ammonium Nitrate Liquid for Of f site Treatment o Uranium, parts /million - max.
5*
5
- At 4% enrichment,. this equates to s1 x 10-5 uCi/cc.
~
10.3 GE Response to Question
'The data given for liquid ef fluents in the table in Section 6.5 represent allowable daily average discharges specified in the NPDES permit for this facility.
The table heading should be:
Allowable Releases NPDES Permit NPDES Permit Issued 8/72 Issued 8/78 The activity concentrations shown in the table are the 10 CFR 20 criteria and not an NPDES requirement.
It should also be noted that we have applied for a routine renewal of the NPDES permit and have not requested any increase in allowable discharge quantities.
In other words, the activities described in the NRC licensing application are not expected to cause an increase in ef fluents over currently permitted levels for the anticipated life (5 years) of the NPDES permit.
A comparison of the allowable discharge volumes in the 1978 permit (1.8 MGFD) to that requested in the 1980 renewal application, would show no change.
I.
11.0 Questions Page 21 - is the da.t1 givest iit tine table in Section 6.5 for fluo. tide and nittogen ca.stect? Witit tite plan,t tlttoughptt increased by 401, tdty are tite.teleases of fluorides increased by a factoIt of 2.7 and nittogen retca.se.s by a fac. tor of 2?
11.1 Referenced Material in Section G.5 Picase see Section 10.2 on Page 13 of this attachment.
l
~
~
- Dr. E. Y. Shum l
.Novembsr 17, 1980 Attachnent 1 - Page 15 11.2 GE Resoonse to Questions Again, the data are correct and the table headings should read as above.
A comparison of the al'lowable cischarge quantities for fluoride and nitrogen in the lif78 permit with the values requested in the 1980 permit renewal would show no change.
12.0 Questions In.1ela.ticn to tite data given in Sect. ion 6.1, u:lth a 5Of inctcese bt plaatt.teicases to.the rivet, it aculd be expected 6:at dte concenttaticas of ccppet, nickel and chtcmium aculd be affceted b scme degree as the.
tat.:t quanti. ties of these ma.teria.i.s a.te expected to.temai>t constant.
Ptezse cla.tif t).
Are ute "p.tesent" values given 41 die table in Section 6.7 b: sed on the mea.Satements ude fc.t the.se contaminants?
12.1 Referenced Information on Pages 29 and 30 6.7.1 Ambient Concentration Summary - The impact of the present and forecast releases on ambient concentrations are summarized in the table below for comparison.
In addition, each of the identified ef fluents is discussed further in subsequent paragraphs.
Incremental Additions to River Concentrations at 10 Year, 7 day low flow of 15-cfs Present Future Treated Liould Discharges to River o Process Fluoride, ppm 0.35 0.99 Nitrogen, ppm 0.95 1.8 Copper, ppm
.012
.012 Nickel, ppm
.006
.006 Chromium, ppm
.006
.006 Volume ratio, discharge:
river
.12
.185 Activity concentration, uCi/cc 3.6 x 10-6 5.5 x 10-6 pH, standard units No change No change l
__ w w -
.. m u w Dr. E. Y. Shum
' November 17, 1980
. - Page 16-Incremental Additions to River Concentrations at 10 Year, 7 day low flow of 15-cfs Present Future o Sanitary Volume, rates discharged to river
.0009
.0009 pH, standard units No change No change Biological. oxygen demand, ppm
.23
.23 Total suspended solids,' ppm
.23
.23 Treated Discharges to Atmosphere o Activity concentration at site bpundary 3 x 10-14 3 x 10-14 o Nitrogen dioxide, ppm
<.05
<.05 Transfer of Ammonium Nitrate Liquid for Of f site Treatment o Uranium, ppm - maximum 5*
5
- At 4% enrichment, this equates to s1 x 10-5 uCi/cc.
12,2 GE Response to Questions (1) The copper, nickel and chromium concentrations are a function of variations in treated effluents from plating operations, variations in degree of corrosion of plant piping and. variations in final lagoon chemistry as well as the variations in total water volume discharged.
It is not anticipated that the total quantity discharged will exceed the allowable quantities specified in the 1978 permit.
No increase has been requested in the 1980 permit renewal application.
(2) The present values given the table in 6.7 are not based upon, measurements but are derived from daily monitoring results for 1979.
For reference, 1979 data on treated process liquid releases are in the table shown below-1979 Data on Treated Process Liquid Releases Data from Daily Effluent Monitoring Volume Lbs/ Day, Monthly Avg.
pH Range MGD F
N Cu Ni Cr JAN 6.6-8.7
.650 16 73
.09
.10
.07 FEB 6.5-8.7
.604 26 71
.08
.08
.07 MAR 6.6-8.7
.610 18 49
.06
.07
.06 s
m emen=s.
~
- Dr. E. Y. Shum
. November 17, 1980 A t tac hmen t 1 - Page 17 Volume Lbs/ Day, Monthly Ave.
pH Range MGD F
N Cu Ni Cr APR 6.5-8.9
.590 26 60
.05
.06
.06 MAY 6.0-8.9
.647 28 67
.06
.08
.06 JUN 6.5-9.0
.638 24 51
.08
.06
.07 JUL 6.6-8.7
.610 29 48
.08
.08
.07 AUG 6.5-8.8
.571 15 25
.08
.10
.08 SEP 6.6-8.8
.765 25 54
.10
.07
.06 OCT 7.0-8.8
.780 30 57
.08
.07
.07 NOV 6.8-8.7
.658 28 73
.06
.06
.06 DEC 6.6-9.0
.587 40 67
.06
.08
.06 13.0 Question P.tge 30 - Wlst a.te tite ustLLs fo1 kJte activity concetttation a.t tite site bcunda.ty for disclatge.s to tite atmospitete?
13.1 GE Response to Question The units for the activity concentration at the site boundary for discharges to the atmosphere are microcuries per cubic 3
centimeter (pCi/cm ),
14.0 Questions Page 31 - Please supplement informa. tion in Sec, tion 6.7.2.5.
Tite pH of tite discitatge is appatottly cortected from a pH g.teatet ti:an 10 to a pH ist tite 6-9.tange. Wlat is tite agott used fo.1 pH adjushnott and wl:a.t is its concentta4Lon (Table, Section 6.7) witet it ettets tite.tivet?
14.1 Referenced Information in Section 6.7.2.6 (6.7.2.5 deals with activity concentration in treated liquids discharged to the river. )
6.7.2.6 pH Eff ect - The pH of the discharge is anticipated to have no discernable effect on the receiving stream.
j Prior to 1974, the discharge was released with an alkaline pH greater than 10 without discernable effect I
on river pH.
The present mode of adjusting the I
discharge to the 6-9 pH range before release results in an even less of a potential effect.
i 14.2 Table in Section 6.7 Please see this attachment, page 15.
14.3 GE Response to Questions
)
Sulfuric acid is used to adjust the pH of the final lagoon l
effluent (the discharge point for treated process wastes) to the specified 6-9 ran e.
s
Dr. E. Y. Shum Novembsr 17, 198.0 A t tac hmen t 1 - Pnge 18 The sulfate concentration at the lagoon outfall averaged 170-ppm for the period from June 1979 to May 1980.
The concentration at the confluence with the NE Cape Fear Riiter is variable and dependent upon the amount of rainfall runoff that mixes with the lagoon ef fluent.
The sulfate concentraticr.
in the river is also dependent upon rainfall.
While the sulfate concentration in the river is usually under 20-ppm, during extended periods of low rainf all, back-mixing from the ocean occurs in the river and it is not unusual for the river concentration to exceed 170-ppm during these periods.
15.0 Question Genetai - Will ti e addition to tite conveuica faci!lties cau.se an t
ci:ange at.tlte sunbe.t of petsannel a.t tite Wilmington Plan.t?
\\
15.1 GE Response to Question No significant changes in the number of personnel at the GE Wilmington fuel manuf acturing plant are expected as a result of adding the new GECO conversion lines.
I l
l l
l l
A. L. Kaplan
- bmw I
r l
l l
l 3
GENER AL h ELECTRIC Dr.
E. Y.
Shum November 17, 1980 9
ATTACICIENT 2 QUESTIONS ON INCINERATOR REPLACEMENT 1.0 Question Ovet ylszt period is tlte quantity of combustibie unste genetated?
1.1 Ref erenced Information on Page 1
- Introduction - In connection with the manufacturing of nuclear fuel at the Wilmington plant, a quantity of combustible waste contaminated with uranium is generated.
Approximate quantities of combustible waste generated are as follows:
Number of waste boxes, each 60 cubic feet (1.7 cubic meters) in volume 400 Volume, total 24,000 cubic f eet (1,020 cubic meters)
Net weight per box (average) 1,000 lbs (450 kgs)
Total 400,000 lbs (180,000 kgs)
Net UO2 content per box (. average) 25 lbs (11.3 kgs)
Total 10,000 lbs
(.4,500 kgs)
Net uranium content, total 4,000 kgs U Net U-235 content, total 100 kgs U-235 1.2 GE Response to Question l
The information in the above table represents approximate quantities of combustible waste generated annually.
2.0 Question i
Pages I and 2 - The dimensions for tJte unste boxes ate given as 4 x 4 x 4 feet, or 64 cubic f eet. The volume of a box is given in tite table as 60 cubic feet. C!hicit value is cortet.t?
- See Section 3.3 on Page 3 of this attachment for corrected table, i
i Dr. 1s. Y. Shum o
November 17, 1980 - Pnge. 2 2.1 Referenced Information on Pages 1 and 2 (1) Information in table on Page 1:
Number of waste boxes, each 60 cubic feet (1.7 cubic meters) in volume 400 Volume, total 24,000 cubic feet (1,020 cubic meters)
(2) Information on Page 2:
~
2.1 ' Design Criteria - Incinerator - 1) Combustible solid waste will be incinerated "as is" within 4 ' x 4 ' x 4' wooden boxes.
2.2 GE Response to Question'~~
Both the stated volume (60 cubic f eet per box) and stated dimensions (4 ' x 4 ' x4' wooden boxes) are rounded off values used for convenience.
Actual values are as follows:
o Outside dimensions
-4'x4' x 3.5',
each box (in luding skids) o Inside volume
(.i.e., volume of waste contents)
- 46. 32 cubic f eet per box 3.0 Question Page 2, Itan 8 - The quantity of boxes indica.ted to have been accumula,ted in one yea.1 is 600. The ptoduction da.ta on Page 1 is htsed upon 400 bo xes. Please. cla,t.ify.
~
3.1 Referenced Information on Page 2, Item 8 2.1 Design Criteria - Incinerator - 8). The incinerator capacity operating at (first year) 3-shifts, 5 days per week, must be capable of incinerating within a one year time frame 2,500 boxes (1,000 boxes backlog plus *600 generated.*)
3.2 Referenced Information on Page 1 1.0 Introduction - In connection with the manufacturing of
~
nuclear fuel at the Wilmington plant, a quantity of combustible waste contaminated with uranium is generated.
Approximate quantities of combustible waste generated (annually) are as'follows:
Number of waste boxes, each 60 cubic feet (1.7 cubic meters) in volume 400
, D r. E. Y. S h um November 27, 1980 A t tac hmen t 2 - Page 3 3.3 GE Response to Question The correct generation rate several years ago was about 400 waste boxes per year, rising to a rate of about 600 per year during 1980.
The incinerator is actually being designed with a capacity for burning about 2,000 boxes per year during a single shift of operation.
Thus, the data in Section 1.0 can all be multiplied by a factor of 1.5 (to adjust then for this increase in generation rate as shown below).
Number of waste boxes, each about 56 cubic ft (1.585 cubic meters) in volume, in 1 year 600 Volume, total
~
33,600 cubic feet (951 cubic meters)
Net weight per box (average) 1,000 lbs (450 kgs)
Total 600,000 lbs (270,000 kgs) 2contentperbox(averagN) 25 lbs Net UO (11.3 kgs)
Total 15,000 lbs (6,800 kgs)
Net uranium content, total 6,000 kgs U Net U-235 content, total (assuming maximum authorized enrichment of 4%)
150 kgs U-235 4.0 Question it is. stated in Section 3.1 &tt "r.o c.tganics" teill be incine11ted; hatcevet "papst, acod, pizs. tics" a.te c.tganics. Picase clatify.
4.1 Referenced Information in Sec tion 3.1 3.1 Incineration - The contaminated waste incinerator will have a nominal rating of 1,500 lbs/hr of type 1 waste (paper, wood plastics, etc., *no organics *).
The boxes of combustible waste will be delivered from storage by forklift and placed on a gravity roller conveyor.
From the gravity roll conveyor, the crates will be transferred to a powered conveyor and conveyed to the incinerator via a single ram feeder.
A pumping station will be installed for burning contaminated waste oils from 5-gallon pails.
The incinerator will be fired 'with natural gas or propane l
from the existing storage f acilities.
Exhaust from the l
incinerator will be passed through a refractory-lined pipe to the scrubbing section of the facility.
~
. Dr. E. Y. Shum November 17, 1980 A t tac hment 2 - Page 4 4.2 GE Response to Question The term " organics" as used above is the same as that used in the description of " waste composition" in our air emission permit application for the incinerator, as 'shown below:
Type of waste or refuse to be incinerated:
Industrial process waste description - Combustible wastes containing small quantities of low enriched uranium.
The wastes are comprised of:
~
~
Cloth (mopheads, rags, coverall')s o
o Elastomers and plastics (polyethylene, PVC)
~ Paper.1 cardboard and kraft) o o
Wood o
Waste oil 5.0 Qu est io n Page 8 and Figu.te 3 - The ptccess ficto diagtam shotes a heat teccuety wtit in the offgas siteam; hoteever, no mmtion of.thi.s wtit.is made in the ptocess description on page 8.
Picase clat.if y.
5.1 Referenced Information on Page 8 3.0 Process Description - The proposed incinerator facility has been designed for the incineration of contaminated combustible waste generated at the Wilmington nuclear fuel plant, according to the design. criteria described in Section 2.0.
The process is divided into three systems:
incineration, scrubbing and ash collection.
Figure 2 shows a conceptual schematic of the proposed process flow for this incinerator facility, while Figure 3 shows the details of the proposed process flow.
3.1 Incineration - The contaminated waste incinerator will have a nominal rating of 1,500 lbs/hr of Type 1 waste (paper, wood plastics, etc., no organics).
The boxes of combustible waste will be delivered from storage by fork-lift and placed on a gravity roller conveyor.
From the gravity roll conveyor, the crates will be transferred to a powered conveyor and conveyed to the incinerator via a single ram feeder.
A pumping station will be installed for burning contaminated waste oils from 5-gallon pails.
The incinerator will be fired with natural gas or propane from the existing storage facilities.
Exhaust from the incinerator will be passed through a ref ractory-lined pipe to the scrubbing section of the facility.
Dr. E. Y. Slium November 17, 1980 A t tacilmen t 2 - Page 5 FIGURE 2 - CONCEPTUAL PROCESS FLOW DI AGRAM e
n - r. s u.t vrita 8"4 RAM A18NG M
stag W
--+
r-trA;t
-t g
gg gg; O'Jtt t C':!Ut rt1*tt St a=#
'P A
L
w' a"t T E ca...,-riew...
- "M mATU4At CAS 1
(
l t
e sr
__,...,t....
arr. *> s,,=11 0*ican t a..t wt w s t a tt!q i
- A:rts patrA7f
<,,te m,
quA get twa=?tt o
h E
ASM 5:s;p S
- t** vat AIII CatifIC l CRIw3 g 9tIU r t(,g g C
I l fe '. l W85t!
- Acrx t.
ST:'Act u.
s er=,
4Je 6
4 wa;gg t
To ritttt e r.; t at a err. tpg
,;.4....
1
'!*(4*!t y
WE'S I
14*'.'Ct3 CM AT T gyggg y
rit := Ar ic rA.
I J,
l l
P00R ORIGINAL
Dr. 15. Y. Shum November 17, 1980 A t tachmen t 2 - Page 6 FIGURE 3 - DETAILED PROCESS FLOP.* DIAGRAM
. _.)..
- 7.....[.i f iI a 'lll,, I.7P !";!.. ' l
..y,,,,,....
.. if et - '
~
g i
/ da; it!.WJ 'T I'.
,s lg g 3. !!!E'$'Illi-5 d'
f,.
g1,l s
s r
n A
o,gm;.. t -;., m. i p:
..y.
i
_i n
2 i.
o I. 3
~ ' 0.,
I!!i@f[@M "i.hi
'G lO p"o.i
- t I
r -- 4 -l'g,) 4 ]
i3 t
t I
43 8 I I' h ',e g l
[l L[::==3,.~ll, d;,;hk
'f,.f' f.t!
3
- f il ti dt-
.;nin ' l't. ij.j tJ.;u.!U tii -
-:2
- ' 3 gn
- q r--'
+!
si[
- Y.'.'.3!,
- [9 c.w lllll !.$jl.i..II.$qb.!,;,M
= = -
[.cr(c, I
~~
M 2._.2 m.
.[w] U d k ll lllllll Ij *3 j!
h3{ (h J
I'p
-4 i
's M
- '3 J'
'u
.J b
1.
i I
IIhh,5blhillll
!!)!?N
!llllllll[
~
~
d'M, 3
h i
iEEii jII' f #@hEhlillIIIIII
]
'g" l(
9 im
!ylliglllll I
~
T-d Diiii? Widillt 9
e dig dii!!N!Hld d
r+
8 ib,b i
3IM $l1!! ji1 3
(l l N l
ch jd [i]f*,::[
og 3 M M u'!B lll1 Hi M
f gh!!g 6!j jgbid.i.e og-g i
fO n..
%,_u st i
w
.= 9 I,
ir ga gggj giij
=
bin.
y e,jd gj.$
[
l r
,dwe. l
.i u..su 2
l' S i fi q s
O i
>ll i9 &awmii fj k. 4 it 1
- - c. >,,
iMJWW t%]
~
~
E
- 4
- e I nullu E It ?"!a'{'
dH li'.tHilk 4
g@lMNhetf li e'l I
l 41 lIl l
~
.!B
- ia itoJ g
3 t,
1 I. ;
nr,e 4
s
.ji
.Nb na.
g x
l I
l I
--"A ll 8 Mibl8Lu it:
j i
I g< Pin ile iiMM !
i dNI Dd3@S$
l1 h[
$1 (Y
r P
libitM d
L i
~
'P0~0F BRIGINAE
~ "
. Dr. E. Y. Shum November 17, 1980 - Pnge 7 3.2 Scrubbing - Incinerator flue gas will pass through a refractory-lined Hastelloy "C" gas quencher where the temperature will be reduced from 2,0000 F to 300 F.
- Quenched gas is passed through a Hastelloy "C"
adjustable throat Venturi scrubber for particulate matter removal.
From the Venturi, the gas stream will enter a packed scrubber where it will be scrubbed with a potassium hydroxide solut ion (pH 7. 0).
The scrubber will be constructed of a fire retardant FRP with polypropylene packing.
The scrubbing efficiency will be 99.5% of the entering hcl, NH F and HNO3; the discharge from the 4
scrubber will be passed through a mist separator, ' heated to 2000 F and discharged through the stack.
Stack emissions level will be continuously monitored to measure activity levels in the gaseous effluent.
Plant water will be used for emergency quenching if re-circulating water flow has been interrupted.
A diesel powered emergency generator and a compressor will also be installed to ensure continuity of all critical process equipment.
3.3 Ash Collection - The incinerator will be shut down once per day for ash removal.
The ash will be vacuumed and passed through a cyclone separator fitted with micro-metallic filter elements to remove fines.
The discharge ash from the cyclone separator will be transferred to 5-gallon buckets and ground in a SWECO vibromill.
The ash from the vibromill is discharged to 5-gallon buckets, the uranium content is assayed, and accountability weighed.
The buckets are then transf erred to pad storage pending offsite recovery of the uranium.
5.2 Referenced In forma t ion _In Figure 3 Please see page 6 of this attachment.
5.3 GE Response to Question The heat recovery unit was originally planned.
- However, later analysis demonstrated that the unit was not. economically feasible.
Therefore,. this unit is no longer included within the project scope and it has been eliminated from the detailed prbcess flow schematic shown in Figure 3.
A new process flow schematic is shown on Page 8 of this attachment.
The new detailed conceptual schematie will be provided when it has been completed (within about 4 months).
-.. ~ -
.-a
-.:x- - ~ ~..
~
'Dr.
E.
Y. Shum November 17, 1980 A t tachmen t 2 - Page 8 CONTAMINATED COMBUSTIBLE WASTE INCINERATION l
% 2'35 wastr_$,
Pr.Or.YK W
6
-)
)
SCM
_S a
cutt:t 7.::::
ratsta
.g, V
)%
C'M'.CM A f R NALTAL OA4
~
v_
"_ u_
Pn;?tAPf
) W 5
VctrDPt
_?
F f.C?f D I NCIt'EP.AM.4 C'JtJJMfa SCPLM0ta CMJM; C*iAy2 7.A
/'.
nj A3M SCPtm 2
d Cae::T:c l waTta 7
c,
~
I FILTra 9,
PACTM t.
g.,
(
hET WA3?E AE.L STCPMI Q
RAD N
WA171
~
TO 55 v
FILTER SCT13DO CWJAS
- 'd PZ:ttAita itttA
!!sDUCD-CovT s
FM gy ritTPAT!:M
}
\\
l l
l l
P00R ORIGINAL O
i l
~
Dr.
E. Y. Shum November 17, 1980 Attachmen t 2 - page 9 G.0 Question Figure 3 - Thete a,te no flame sensors or flame conttal deuice.s fa.1 the
.btebtetatot or the af tetbutnet indicated on the diagtam. Wha.t ptovisions '
a.te made to btsute that tutbu.tncd na-tutal 91.s at ptopane sciLL not entet the remahidet of the system?
6.1 Referenced Material in Figure 3 please see page 6 of this attachment.
6.2 GE Response to Question The total incinerator system will be controlled by a programmable process control device (brand name of Eagle Signal Company).
This device senses the temperatures and other primary operating conditions within the incinerator system.
The temperatures in the incinerator and af terburner are designed to provide complete burning of natural gas or propane, respectively.
If these temperatures vary significantly from the design values, the control device.will shut down the system.
If the control device fails, the systen will be shut down (i.e.,
it is fail-safe).
7.0 Questions Pag e 3 -
It is sta,ted bt Section 3.f tha.t "The setubbbtg efficience) taill be 99.5?,
of.the ente, ting HCL, NH F and HNO." With.the leide vatiabilitij bt 4
3 contambiants in "as is" latste (page 2), how can.this etitstion be satisfied?
It is S tutted b1 Sect, ion 3.2 tha.C " stack edssions level teill be contbtucasty monito.ted to measu.te activitij levels in the gaseous ef fluent. " How teill the levels of othe,t contambtants, F, Cl, and NOx bi the offgas sttcam be de,tetmhted?
7.1 Referenced Information in Section 3.2 3.2 Scrubbing - Incinerator flue gas will pass through a refractory-lined llastelloy "C" gas quencher where the temperature will be reduced from 2,0000 F to 3000 F.
~ Quenched gas is passed through a liastelloy "C" adjustable-throat Venturi scrubber for particulate matter removal.
From the Venturi, the gas stream will enter a packed scrubber where it will be scrubbed with a potassium hydr-oxide solution.
The scrubher wi11 he cons.tructed of a fire retardant FRp with polypropylene packing.
The scrubbing ef ficiency will be 99.5% of the entering IIC1,
"Dr.
E. Y. Shum November 17, 19S0 Attachmen t 2 - Page 10 NII F and IINO ; the discharge from the scrubber will.be 4
3 passed through a mist separator, heated to 2000 F and discharged through the stack.
Stack emissions level will be continuously monitored to measure activity levels in the gaseous effluent.
Plant water will be used for emergency quenching _if re-circulating water flow has been interrupted.
A diesel'
. powered emergency generator and a compressor will also be installed to ensure continuity of all. critical process equipment.
7.2 Referenced Information on Page 2 in Section 2.1 2.1 Design Criteria - Incinerator - 1) Combustible solid wa,ste will be incinerated "as is" within 4' x 4' x4' wooden boxes.
7.3 GE Response to Questions (1) Although there is a wide variability in contaminants contained in "as is" wastes, on a box-by-hox basis, on the average over a number of boxes, the variability will not be large enough to cause the design specifications for scrubber ef ficiency to be exconded when averaged over the period of time used for determining compliance with regulatory requirements for atmospheric and liquid effluents.
(2) Fluoride discharge levels in the offgas stream will be determined in the same manner as is presently done for the chemical discharge stacks.
Chloride and oxides of nitrogen levels will not be measured.
Calculations demonstrate that we are within regulatory limits for visible emissions and ambient air quality.
(.T hese calculations are addressed in the answers to Question 8 I
below.)
8.0 Qu estion s Pag e 14 -
A.te tite alt emis sion quarttlties given in Section 6.2 to be added to titose given on page 28 of tite Envitousnental Info.tmation subnLtted on Decenbet 29, 1979?
Also, sinow tite calculation wi. tit assumplic>ts used fot tite proje:ted disci:atge of radiotcgicai artd cincmical ef f tuents a.s swnma,tized in i
Table I.
l I
L
Dr. E. Y. Shum November 17, 1980 A t tac hment 2 - Page 11 8.1 Referenced Material in Section G.2 on Page 14 6.2 Air Emission Quantities - Estimated quantities of dif f erent materials in air emissions from the proposed incinerator facility are shown in Table 1.
These quantities are well within limits set by state and federal agencies for such discharges.
Table 1 - Air Emission Quantities Emission Quantity, Maximum U ra n ium
.3 x 10-12 uCi/ml at the stack hcl 50 lbs/hr NH F
~
120 lbs/hr g
HNU3 70 lbs/hr 8.2 GE Response to Questions The actual estimated quantities of these materials in air emissions from the proposed incinerator facility corrected from those in Table 6.2, are shown below:
Expected Airborne Discharge Design Limit
- Operating Limit
- Uranium activity (annual average)
<1x10-11 uCi/ml
<3x10-12 uCi/ml
~
Particulate
<.08 grains /dscf
<.02 grains /dscf hcl
.07 lbs/hr
.01 lbs/hr Fluoride
<200 grams / week
<100 grams / week NO 2 lbs/hr
<2 lbs/hr x
- Values at stack The values for uranium discharge to the atmosphere given on page 28 of the Application Amendment N-2, Expansion of Plant Conversion Capacity, submitted on 12/21/79, are regulatory limits at the site boundary.
The information in the table above are actual design values and the limits of expected operating values for the.various airborne discharges (including uranium).
Therefore, the values in the table above are not to be added to values given on Page 28 of the submittal dated 12/21/79.
e+
~
- Dr. C. Y. Shum November 17, 1980 A t tachmen t 2 - Page 12 Calculations used for the projected discharge of radiological and chemical effluents as summarized in Table 1 above are as follows:
(1) Assumptions Average weight of box contents = 800 lbs o
.\\laximum throughput of incinerator = 928 lbs/hr o
o' Estimated weight per box of chloride from neoprene, vinyl gloves, PVC, etc. = 1.21 lbs/ box o
Estbnated weight per box of NH F from mops, rags, 4
e t c ~. = 1.75 lbs/ box Estimated weight per box of sulfur from polysulfide o
shoe covers, contaminated oil, etc. = 0.41 lbs/ box
.o 600 boxes.per year (2) Yearly average rate (600 boxes) o Chloride:
1.21 lbs C1/ box x 600 boxes / year x 99.2% =
6.2 lbs/yr N!! F:
1.75 lbs NH F/ box x 600 boxes / year x 99.2% =
o 4
4 8.7 lbs/yr o
Sulfur:
0.41 lbs/ box x 600 boxes /yr x 99.0% =
2.6 lbs/yr o
N it rogen 1.0 lbs/ box
- x 600 boxes /yr =
ox id es :
600 lbs/yr 9.0 Question Genetal - Nitt tItc opera, tion of Cite bec6teta,to.t cause an.y citange bt tire 4taffbig EcvcLS fo1 tite Wilmbtgton plant /
9.1 GE Response to Question No significant changes in the number of personnel at the GE Wilmington fuel manuf acturing plant are expected as a result of operating the replacement incinerator facility.
- Based upon material balance from revision B of architect-engineer's process flow sheet dated 7/28/80.
-~
GENER AL h ELECTRIC Dr. E. Y. Shum November 17, 1980 ATTACIBIENT 3 QUESTIONS ON ENVIRONMENTAL REPORT (NEDO-20197, JANUARY 1974) 1.0 Question Page 1 Will de new hcine,ta.cor stacit be visible f. tem of faite locations?
1.1 Referenced Material on Page 1-23 (and 1-22) 1.6.1.2 Buildings & Structures - Photographs of the site, its surroundings and principal buildings are contained in Sections 1 through 4.
Buildings are typically single-story light manuf acturing structures of modern design, with bricks and stone used on office and laboratory annexes to relieve the Spartan appearance of the maia structures.
Except for a flagpole and water tank., there are no prominently high structures.
The operations do not require significant gaseous releases (steam, smoke, etc.), and none are visible from adjacent property or the public roads.
Other than buildings, water tanks, and a flag pole, there are specially constructed lagoons - a part of the extensive water treatment systems.
Fourteen wells are located on site.
1.2 GE Response to Question The new incinerator discharge stack will be visible only from portions of the wooded area along the southern fence line.
2.0 Question Page 1-24, Table 1 Have ne enem3y requitemeds differed from.the ptojections fa.t yea.ts 1973-1978?
2.1 Referenced Material in Table 1-2 on Page 1-24 Table 1 Summary of Plant Energy Requirements Electricity, Natural Gas, Year megauntt hrs megawatt hrs 1969 49,100 88,800 1970 65,700 114,500
S Dr.
E.
Y. Shum November 17, 1980 A t tac hmen t 3 - Page 2 Electricity, Natural Gas, Year megawatt hrs megawa t t brs 1971 66,000 137,800 1972 69,000 137,500 1973*
75,000 149,500 1974*
75,S00 151,000 1975*
75,000 149,500 1976*
133,500 266,100 1977*
138,800 276,600 1978*
179,300 357,300
- projected 2.2 ' GE Resconse to Question ~~' ~
The actual energy requirements for 1973-78 have not differed signif icantly f rom the projected values for those years.
3.0 Question Pages 1-24 arid 1 Nili tite expansicut of tlte caswetsicot facility aatd tlte teplacanent of t!te.incinetaict cause a clanige ist atctgy c.t teatet teytitemcLLs yet unit of ptcduction?
3.1 Ref erenced.ilaterial on Pages 1-24 and 1-25 1.6.1.4 - Plant Energy Requirements - The primary energy source for the plant site is electricity, utilized for manuf acturing activities, and building heat and air conditioning.
The secondary energy source for the plant is natural gas, utilized for steam generation and other process operations.
A liquid propane facility is provided as a backup source to enable the natural gas service to be diverted during periods of high residential demand.
The total energy requirements are quite low and are detailed in Table 1-2, with projected loads from 1973 through 1978.
See Table 1-2 above.
While the electrical and natural gas energy usage for 1972 was equivalent to only 109,300 megaun t t hours, the potential realizable electrical energy from that year's production of nuclear fuel was 125,500,000 megawatt hours.
These low input energy levels account for the negligible thermal discharge from the facility.
Dr. E. Y. Shum November 17, 1980 - Page 3 1.6.1.5 - Plant Water Requirements - There are 14 wells on the site to furnish water for the plant.
Water usage for 1969 through 1972, and estimated-usage for 1973 through 1978, are as follows:
Year Water Usage, Millions of Gallons 1969 (estimated) 240 1970 295 1971 310 1972 310 1973*
335 1974*
350 1975*
360 1976*
430 1977*
480 1978*
510
- Projected About 94 percent of the water withdrawn from these wells is returned to the Northeast Cape Fear' River and its purity meets the North Carolina state regulations as they apply to sanitary and industrial wastes.
Waste system and process system descriptions are found elsewhere in this report.
3.2 GE Response to Question The expansion of the conversion facility and the replacement of the incinerator will not cause a significant increase in energy or water requirements per unit of production.
In l
fact, introduction of the GECO conversion process should significantly decrease the water requirements (if not the energy requirements) per unit of production.
l 4.0 Quest io n Page 1-25 -- Ha,s the plastt ccstthtued to opeta.te ht a. safe mannet.shtee 1974?
4.1 Referenced Material on Page 1-25 (and 1-26) 1.6.1.5 - Chemical & Radiological Summary - The manufacture of nuclear fuel (Figure 1-2) at the Wilmington facility requires the use of various chemicals and uranium dioxide (UO ).
When the facility was 2
designed, careful attention was given to the safe l
use of these materials - safe for people working
~
Dr.
E. Y. Shum November 17, 1980 - l' age 4 in the plant, saf e for people living and working in areas around the plant, and safe for the environment.
Five years of operating experience has validated the design basis.
Uranium hexafluoride (UF6) is received at the plant by truck transport, and chemically processed to prepare uranium dioxide (UO2).
The UF6 is shipped in cylinders within Model OR-30 protective shipping containers (Figure 5-1 and 5-2),
certified under Department of Transportation (DOT) regulations, which comply with AEC regulation 10 CFR 71.
This packaging is designed to prevent
' release or criticality under the most severe accident conditions.
Low-enric hmen t radioactive materials are also
~
shipped and received in other forms, including finished fuel assemblies, returned, unirradiated fuel rods, low specific activity uranyl nitrate so lu t io ns, and waste materials shipped to licensed vendors for of f site disposal.
All of these ship-ments are made in containers which meet the DOT specifications and AEC regulat ions.
Radiation exposure to transportation workers, on lookers, and people along with shipping route is well within established limits.
The highest exposure possible for the truck drivers under normal shipping condit ions is extremely low (i.e.,
if one driver handled the total year's plant product io n, he would receive less than 5 mrem, or less than 5 percent of natural background radiation dosage.)
Bulk tank truck shipments of anhydrous ammon ia, aqueous ammonia, nitric acid, hydrofluoric acid, hydrated lime, and sodium hydroxide solutions are received and utilized on-site.
The frequency of these receipts is less than 25 per week.
These materials are all shipped in accordance with DOT regulations.
4.2 GE Response to Question The plant has continued to opera *c in a safe manner in all respects since 1974.
- 5. 0 Question Page 2-1 (first pttag.tapit) - Ya.s titere been ant] significa>tt citange in tite Ltud use pttte,trts in the region atcand tite SLte.shtce !?74?
t
^
Dr. E. Y. Shum November 17, 10SO Attachmen t 3 - Page 5 5.1 Referenced Material on Page 2-1 (First paragraph) 2.1 Location & Layout - General Electric's plant at Wilm in gto n, North-Carolina, is situated on a 1664-acre site in New Hanover County, approximately 6 miles north-of the city of Wilmington.
(Refer to maps, Figures 2-1 and 2-4.)
New Hanover County is located-in the south-eastern corner of the state, in the coastal plains reg ion.
The county J.s bounded by the Atlantic Ocean and by Pender and Brunswick counties.
The region around the site is sparsely settled, and the land is characterized by heavily timbered tracts occasionally penetrated by short. roads.
Farms, single family dwellings, and light commerical activities-are located chiefly along highways.
5.2 GE Response to Question There has not been a significant change in land use patterns around the plant site since 1974.
The trend toward increase in number of residences in this portion of the county is continuing.
A small housing development has been started about 500-feet from the north property line (about 4000-feet from F"O).
G.0 Quest ion s Page 2 Have titete been ang.significant citanges in tite Ncrtit Ca<talina h'atet Quality Standatds cr in tite designation fcr tite No.ttitcast Cape Fea.t Rivet since 197J?
Have titete been any significatt citanges in the EPA.tequitements c.t s tanda.tds tita.C may af f eet tltc National PoLEu. tant Discitatge Eliminaticn Sys tem Discita.tge Petmit NC 0001228? htill the prcposed GE incinetztet and plant expansion or ctitet GE activities casite resatt in an inetease of cffluent dischstge and exceed the Limits aLicteed undet tite cauctt NPOES permit? If so, please discass.
t 6.1 Referenced Material on Dage 2-17 2.5.1.3 Related Classification of Receiving Streams - The l
pH of the river water is generally acid although l
values as high as 9, indicating a basic pH, have been measured.
Fluorides are present in concentrations of nearly 1 ppm and are thought to be of natural origin from fluoride-bearing minerals.
- Nitrates, ammonta and other ions are also present in varying I
l l
l
Dr.
E. Y. Shum 0
November 17, 1980 - Page G but low concentrations.
The color of the river is dark brown, indicative of the contributions from swamps in the drainage area.
Detailed ecology information is given in paragraph 2.7.
The river is classed as "SC" at the site by the North Carolina Office of Water and Air Resources.
This classification means that the best use of the water in this classification is designated as
" fishing, and any other usage except bathing or shell fishing for market purposes."
The North Carolina Water Quality Standards are included in Appendix 2-2.
A-copy of the conditions for the National Pollutant Discharge Elimination System Perm it issued by the US Environmental Protection Agency is also attached as Appendix 4-3.
6.2 GE Response to Questions (1) North ~ Carolina has~ revised the State Water Quality Standards.
The primary change has been to add additional quality criteria for toxic substances and pesticides to the state standards.
The US EPA " Quality Criteria for Water" was used as the basis for these additions.
The most significant changes were made for higher water classifications (e.g.,
Classes A and B).
The classifi-cation of the NE Cape Fear River is Class C, swamp water, at the plant site.
It has not been necessary to revise NPDES permit criteria in order to meet these standards.
(2) There have not been significant changes in EPA requiro-ments that affect NPDES (National Pollutant Discharge Elimination) Permit NC0001228.
The addition of the
~incineratcr and the dry conversion capability will not exceed the limits allowed under the current NPDES permit.
General Electric is in the process of planning and installing the capability to manufacture aircraft engine components at this site.
It is too early in the planning stages to establish what, if any, affect this new manuf acturing capability will have on the NPDES permit.
The anticipation is that any effect will be min imal.
7.0 Questions.
Pcge 4 l Gtetutd atttet samples ate.taken f tcm tite vic.inity of tite calcium fluc. tide l
p.it.s on a peticdie htsis.
Do tite anitftjtical.tesat.ts ccattimte to sitcw l
no vtetea.se at fluo. tide?
l
~
Dr.
E. Y. Shum November 17, 1980 A t ta. hmen t 3 - Page 7 Plc.1sc ptcvide 9tcund m ttt sampling data and.tesult.s since 191J.
Had leakage been detected in any cf the ensite lagccas? Mt.tenedial ac.ta.cn tctli be taken if Lagoon leakage is found?
7.1 Referenced Material on page 4-3 Two small, fenced areas on the site have been set aside for landfill storage of calcium fluoride, a byproduct of plant processes.
It is anticipated that the calcium fluoride, an extremely stable material, will ultimately be reprocessed for its chemical value.
One of these storage areas is in the far northwest corner of the site.
The other is adjacent to the discharge lagoons.
These storage sites are monitored to assure that they exert no adverse environmental impact.
Locations of these pits are shown in Figure 6-3.
o Calcium fluoride pit in northwest corner of site - After an investigation of the suitability of the terrain and groundwater level and with the approval of the State of North Carolina, this area has been used as a storage area for calcium fluoride solids and covered with dirt to prevent wind scattering.
There are four groundwater taps around t he perimeter of this area.
Groundwater samples are taken periodically and analyzed to be certain that no materi'al is leaving the pit.
These samples have shown no increase in the level of these materials.
o Calcium fluoride pits adjacent to discharge lagoons - This area has been used to store calcium fluoride solids removed from the discharge lagoons.
There are twelve groundwater taps around the perimeter of this area.
Ground-water is analyzed periodically and has shown no increase in the level of these materials.
7.2 GE Resconse to Questions (1) The results of the analyses frcm the shallow ground water samples taken in the vicinity of the calcium fluoride storage area show no continued buildup of fluoride concentrations.
There is no change from background levels in the storage pits in the northwest corner of the site and in the majority of the wells at the final process lagoon area.
Two of these later shallow wells do show fluoride concentration in the 2-4 ppm range.
Ground water sampling results in these storage areas are shown in Table 2.
(2) Nitrates were detected in the shallow ground water at the waste treatment lagoon area.
Deterioration of an underground manhole and connecting piping between the
'l a
Dr. E. Y. 3 hum November 17, 1980 At tachmen t 3 - I'nce 8 nitrate lagoons was determined to be the cause and was corrected.
Nitrate values are slowly returning to normal.
In the other instance, deterioration of a sump in the equipment area at the waste treatment facility was detected at the nearest shallow ground water monitoring well.
The sump was repaired.
Contaminant values have
~
stabilized and it is anticipated that they will slowly return to normal.
Ground Water Samoling Results by Storage Area 1!edian Values pH F. pom U,
ppm NOn, ppm N!!,. ppm Calc ium fluoride pits in NW corner of property (4 wells):
1976 G.6 0.12
<0.01 0.11 0.02 1977 6.0 0.25
<0.01 0.2 0.7 1978 3.4 0.2
<0.01 2.2
<0.15 1979 0.3
<o.01 1980-0.46
<o.01 Final ef. fluent ' lagoons (12 wells):
1975 7.1 0.2
<o 01 0.5 1.0 1976 6.9 0.2
<o,01 1.4 1.0 1977 7.2 0.2
<0.01 1.4 0.G 1978 7.2 0.2
<o 01 0.G 0.4 1979
'7.2 0.2
< o 01 0.5 1.1 1980*
7.0 0.25
<o.01 0.G 1.1
- 198,0 - one-half year 8.0 Question Page 4-5 and Tables 4-1 and 4 Will tite planned 1-cdifica.ticns to tite convetsicn p.tocess o.t tite incistetata.t cause ant) sigstificant changes in tJte sto.utge quantities o.1 Loca,tions of chemicats used onsite?
8.1 Referenced llaterial on Page 4-5 and Page 4-4 and in Tables 4-1 and 4-2 4.2 Ef fects of Plant Operations - The following subsection evaluates the potential ef f ects of the General Electric plant operations on f ence-line neighbors, wildlife, or other aspects of the local ecology.
Approximately two-thirds of the total plant operations (equipment and tube
Dr. 1:. Y. Shum November 17, 1980 A ttachmen t 3 - Page 9 manuf acturing) are primarily involved with metal-forming operations.
These operations have had insignificant adverse effects on the environment during 5 years of operation.
The remaining operations are involved with the highly specialized manuf acture of fuel assemblies for nuclear power reactors, so important in meeting national energy goals.
These operations have also had insignificant effects on the plant environment, and conservative control procedures ensure continuing minimal effects in the future.
The.f uel manufacturing operations involve low-enriched uranium as well as tonnage quantities of ammonia, nitrate, and fluoride.
Accordingly, these materials receive principal emphasis in the following discussion.
A detailed listing of all chemicals used onsite, including maximum inventories and locations, is shown in Tables 4-1 and 4-2.
(Tables 4-1 and 4-2 are shown on pages 10 and-11 of this f
a t tac hm en t, respectively.)
8.2 GE Response to Questions Additional chemical storage f acilities associated with these licensing activities are not planned for the immediate future.
9.0 Question Page 4-5 and Table 4 Lte tite quantities of contambwtts li5.ted bt Table 4-3 based on measu.ted c.t calculated value's?
9.1 Referenced Material on Page 4-5 and in Table 4-3 4.2.1.1 Waste Ef fluents - Summaries of the various liquid and gaseous ef fluents are presented in Table 4-3.
The plant sewer system is diagrammed in Figure 4-3.
Discharges of materials that contain nitrogen, uranium and fluoride are considered the most significant for potential environmental effects because these discharges account for the major part of the total waste ma terial'.
Even though the tabulations show that insignificant amounts of gaseous wastes are emitted to the atmosphere, these wastes, particularly those containing uranium and fluoride, are discussed in detail in the following section.
(Table 4-3 is on pages 12 and 13 of this attachment.)
9.2 GE Response to Question The quantities of contaminants listed in Table 4-3 are derived from the measured data where available or calculations where data is not available.
1)r.
E. Y. Shum November 17, 1980 Attaclvnent 3 - Page 10 Table 41 CHEMICAL INVENTORY-MAXIMUM Chemical Pweent Specific Men.
Building Relative Formula Concentration Gravity Storage Area Location Material 100 550 gats Equio Outside (CH ): CO 550 gals Fuel Outside Acetorse (Liquid 1.........
3
.100 15 M gals Ecuip Cutside NH 100 0.771 3
15 M ga:s Fuel Cutside Anhydrous Amt,or a (L:cuid!.....
Aqueous Ammonia (L au.dl.
NH.OH 29.4 1.218 20 M gais Fuel Outside 7 M gals Fuel Outside Hydrochforic head (Licuid)
~ hcl
~
30 1.150 110 ga!s Ecuip Outsid-37 1.143 5 M gats Outside Fuel Hydro?:curic Ac;d (Liquidl..
HF 121 5M#s H s COCH 100 0.S47 550 gats Fuel in side
..Ci3 Isostearie Acid (Licued)...
3 Lure (Fcader!
Ca0 100 N.A.
1C0 M tb Fuel Outside 56 1.355 5 M gals Tube Outside HilO 56 1.355 5 M gals Fuel Ou: side Nitrrc Acid (L:cwd) 3 67.3 1.410 550 ga!s Equio Outsade 50 2 M gits Tube Outside Sodium Hydroside ll.cuid)
NaOH 1.51 50 7 M gals F uel Outside 93 1 835 110 gais Fuel Outside H SO.
2 93 1.835 110 gals Equip Outside Sulchuric Ac2d it.icuid)
Proprietary N.A.
N.A.
110 gals Tube Insde Cegreasal (L*qu.dl..
Uranium Hexaffuoride (Solid).
U F.
N.A.
N.A.
200 tons Fuel Outside Uranyl Nitrate (Crystil)
..... UO (NO 12
- 6H O N.A.
1.0 25 tons Fuel Outside 2
3 2
nom:
- r yo.cai
Dr. E. Y. S hitm No.einber 17 1980 A t tachtnen t 3 - Page 11 Table 4-2 GASES INVENTORY-MAXIMUM Chemical Percent Ma aimum Building Relative Material Formula Concentration Storage Area 1.oca tion e.
2400 gal Fuel Outside A
100 1500 gas Tube Outside Argon 1500 gal Equio Otstside Carbon Diox:de.
CO 100 6 tons Fuel inside 2
220 M f t '
Eausp inside He 100 220 M f t' F uei Outside Helium 220 M f t' Tube Outside Hz 100 65 M f t' Fuel Outside Hydrogen 10.5 M gal Fuel Outside N:trogen N:
1C0 150lbs Fuct In s.d e r O gal Equip Outside A
Oxygen t
100 6 M gal Fuel Outside C H, 100 143 M gal Fuel Outside Propane 3
P00R.0RIGINAL
~
Dr. E. Y. S hum November 17, 1980
. - Page 12
- c-E -$ 5 s 1 U L
m I i 1 iM I l l I i i l 1MMMM i1M MM i i I
'E g e -.e p uC O 3-D.
u E
E 2
-t T
4 1 I i l 8 I i 1 I I I I I I I I 6 I I i i i I o
o
,E I i
- ,.s e
$~
=
em
.c-o 6
.~
b o n =r
,,a
-ooo Y
a
- gii, C,
-.n Ne
~ _. _ _ _.
--C -
- 1 g o s. o I i O oc
- 4 I I I I I I I I I
I i i l
-3y7 b
-1 I
- ==
3 1 oo-b ocoD coo 2
oo o
o oooo ooo u-Oz
_+
5 2
2 :-
eE
-e
-~
-=
m c ~::-
=
2 -==---
2 321:2: 313 4-
- =
C2 3EEE EE 1
4~
u
-1 o--o
=.:
a
==
- a
- ~
~ = v c ~ - ~ or -
--om
=2
=co
=-o
~=
c o o o r~ o c
<r a o 3 S o c = :o d o c
c l 1 1 I d->
I
,1 Y v ceod eN 5
1 i o-I 3
Mnir 2'
. "3
. e 5'
.e o 6
o w
's 3 w
n E-
=c 55 e -
==
ce E
+
C aC
=
M<
gu e e c E*
E Ee
.- g c
a chEEe n
m a
g e E, E c.
-c ae a
2 on o
en e-Pd r=. 08. e. es ce oo oo g o, N,
N I gr m M l ->
c-M-Mo1 I I I oo 1 1 I VV o
o 2 -9
-3 O
=
o
=
u,a o e
=
2 c'.
2 2
.o E
E U2 4
3 53 g
<g c
~-
- _ g!,w o
u a
>-o c
c,
-E e.
=m?22538E d
N x.
x x
x
- c. c, c.
c, n n c-5 o o u000o00oo0E: 0000c: S s
3
=zuzu=an==wzsaaz=zy=ggg-a u. z,- = z u o
+ +
- +++**
- * **+,,+**
c;
?
3 2
-o r
5
- a 2
~
u v
5 x
=c O
2 m ::
s l',. e ?=
=
c 4*
k 5
'eE-m>
d E
c
- c w
' sc : E5
=
o 3
5 c
e : ; c: E u., U -'j - h 0 2
5E
- s c2
-m ?
=
o
'O e
c.
= s U"
-s C 9 E
5 5
EG c5~
C E y@ $3 9
8
-5 5
55355 363359c 5
5 ;; e ;; --
629 O
C m r. :.0DRin.?.* A' 4 0 >t 5
o o
N U
P0 lR' C2 u
+
Dr.
F.,
Y.
Slium o
November 17. 1980 A t taclunen t 3 - I' age 13 e :r
~~
C 5 :o $
E0 ~E s =u 3
c: a 3 2u
- c 1
MM i n cga m i I I I I I I I I l
3' 3 =.
2 = =.
3o
- 3 v
co 0
3, U"
u" o
e 3
S o
Z E
k 3
5
=
4
~
-~
c:
c: >
c e. o. o.
o es m
In oo--
I i n.
3 :.
I I I I I n3 33 3-2-
u o
c:
c:
5s c-E E =o e
e 5%0 em 3
g
.3 2 u o
g =e..a 8
o 2c s. =a i
o8I I
,3' o I i i e i I I I I I I
-3 c
od 3
co o *o o *=
u u
c E
Z o
o Z
2 o
b c>
o C
of m nno e m n
43 2
E3 o.N -,e o e." o n ooo
-n-o o
3-
.o m
o u
-nw nw 7
c:
c
=
1 I I o 1
=
3u e.
$.5 2 "3
t :2 2
m 7 o o D
3.a 0
.* st -
.5 J
1 6 536; 2
y e
o,
=
g a
85 3s>
U EEcc'E2 e
aaEEEcaEaE E
e Zu 24Wm a a c. L'a a n aa e
e 5:
O a
3 3 :s '%
n n m.r - - o. a ae
?
e*
o
~ r3 :=
X ar noo
.no-3 3
Z2.E I I e i d
oooo---
=
8 u
7 9
e uz i
o i
c4 E
=
c 2
- R' 63 c
.5 j B **g 3
c e 3 ?
m c
g s
C E5E O o c k'C 20..
3 or o
2=
7
~
nn nn 3
H 3 D u.l:
3 u. Z Z Z u u A v w a m
e.
d 3e e y
3 e N O
. y n
e *2 w
e p 3
e -
T 43 b.
h$ {
L'$
e
=. ~
i a
o u.
7, y
5 2d o e
u Eo es.5 n
s3z s
~
o.5,-
=
d c
c; e
g
.=
e d
C c
c
. o =
i 2
b U C
3 Ss. o.>8.2E 25 o
3 c.
=
u
~
W 5
ot E C
% =3
'3 o 5 W
=
=
- s s
c
- u e
2 4
a, d 6 5
~3
.: G
- 5 2
=
e
=
- ~ - -
.,e-e-
- - + -
r
Dr. E. Y. Shum e
November 17, 1930 A t tac hmen t 3 - png e 14 10.0 Question Page 4-10 and Table 4 Wilt the planned nodifica.ticas to tlte convetsion ptocess at the incineta, tot cause anif significant changes in the.tesou,1ce ccmmi.tmen.ts listed in Table 4-26?
10.1 Ref erenced Material on Page 4-40 (and pages 4-42 and 4-43) and in Table 4-21
~
4.3 Resources Committed - Low-enriched uranium fuels must be used to produce electricity.
Therefore, the short-term and long-term commitment of environmental resources involved in the fabrication of nuclear fuel
~~
must be evaluated.
The considerations of environ-mental resource commitments f rom the construction and operation of the General Electric facilities at
_ ilmington are summarized in Table 4-21 and in the W
following discussion:
4.3.1 Land - Table 4-21 gives the distribution of GE's land commitments and shows that no land is permanently committed.
4.3.2 Biotic Communities - The current survey of biotic c'emmunities shows that the major portion of GE's land is functioning as a wildlife refuge, a desirable situation considering the encroachment tendencies of human neighbors.
The surrounding regions are large in area, with large inventories of biotic populations compared with similar populations found on the Wilmington GE site.
Consequently, the land area and the biotic populations represented on it are but a small f raction of the like resources available in the general region.
IIowever, the effects to date of the plant operations show no serious negative ef fect on the onsite biotic populations, much less with those offsite, and it is concluded that no significant commitment of biotic resources has occurred as the r.esult of plant construction and operation.
4.3.3 Water - The consideration of water applied only to the extent of use or diversion and represents no irretrievable commitment either with respect to the quality or extent of the source or to the Northeast Cape Fear River to which the water is diverted.
This is because water is being withdrawn from aquifers at rates well below available incoming supp.y.
4.3.4 Fossil Fuel - The uranium dioxide fuel produced in 1 year at the Wilmington Plar.: can supply the annual fuel requirements for more than a hundred 1000-MWe
---n---
Dr. E. Y. Slium November 17, 1980 A t tac!vnen t 3 - Page 15 Table 4 21 RESOURCE CCMMITMENTS Total Resource Use Lanti ( Acreil 150 Temperarily committed Istant use) 1370 Undisturtxd area 144 Otsturbed area (burrew) 0 Permaree tfy committed Water (10' gall 365 Ground water diverted to Northeast Cape Fear River per year Fuel 179 3 Electrical energy (10' VW d/yl 3
81.4 Ecuevafent coat (10 tent)
Natural gas for steam and crocess (10' set) 357.3 E ttluents Chemicals (tenslyearl Gases.gf 2570 696
- NCe E
- Hydrocarbons II 4
.CO 0.05 p
Liquids M8 l
N as NH3 II2 N as NOs 4
F-l Solids
'0"I l
CaFs i
l Radiological (gCi/yr) l Gases ~
3 6 x 10 U
i Liquids U
Solids (buried)
U Thermal (10' 8tu) 50..NO.hytt,wytmes, sad CO, we etffwet 98"s from tm
- Noee P_00R O
Dr. E. Y. Shum November 17, 1980 - l' age 1G light-vnter reactors.
The electrical energy output from these nuclear reactors is the same as that which would be produced if 250 million tons of coal
- were consumed in. coal-fueled plants.
Resources committed, shown in Table 4-21, do not consider, of course, the significant electrical energy required to enrich the UF6 for feed to the fuel plant.
Table 4-21 shows the annual resources committed by the fuel plant site to produce the nuclear fuel.
Approximately 35J_x 106 scf of natural gas are consumed in furnace operations, most of which is used in the fuel-making process.
This quantity of natural gas could be used to generate roughly 40,000 MW-br of electricity, which is less than 1 percent of the annual output of a 1000-MWe reactor.
Therefore, the commitment of such fossil energy resources to uranium-fuel fabrication is justified when the available alternatives ( fossil and nuclear) are compared for energy production, i.e.,
their fuel cycles.
4.3. 5 Ef fluents - In Table 4-21, the gaseous effluents (50 NO hydrocarbons, CO) correspond to the 3,
x, effluents produced when fossil-fuel is used to generate the Wilmington plant electrical requiremen ts.
4.3.6 Chenicals - The commitment of approximately 1400 tons of chemicals per year, as indicated in Table 4-21, is considered to provide an economic investment of resources when this mass is compared with that of the oxygen-consuming alternatives (coal and natural gas) to produce electrical energy.
Approximately 75 per-cent of the mass of process chemicals, i.e.,
CaF,
2 is available for potential reclaiming or further processing.
There are no significant irretrievable commitments o f chemical resources.
4.3.7 Radiation Exposure - The resource to be considered in this paragraph is the potential for exposure to harmful radiation of human or other biotic populations
- The figures for energy consumption and the corresponding quantity of coal required to supply this need are based on information published by the USAEC Directorate of Licensing, Fuels and Materials, " Environmental Survey of the Nuclear Fuel Cycle," United States Atomic Energy Commission, Nov.
1972.
m_,
... 6 Dr. E. Y. Shum November 17 1980 Attaclunent 3 - Page 17 that might lie in the pathway to human populations.
The extremely small exposure potential is shown by historical analysis in paragraph 4.2.3 and by the conservative e'stimates shown in Table 4-21.
The airborne concentrations are sufficiently small that a fence-line neighbor might stand continuously at the boundary without receiving more exposure than is measurable in background radiation from natural causes.
4.3.8 Summary of Irretrievable Commitments - In summary.
there have been no irretrievable commitments of resources at the Wilmington site.
10.2 GE Response to Question No significant changes in the resource commitments are expected from the planned modifications to the conversion process or the incinerator.
11.0 Question Pagc 5-l6 - Tlie analt) sis af titc amount af,tadioactivity du.thsg a I8 fissions scLtit tite acc.ident c.titicallty excwtsian tats based on 10 lastistg one second. Tite.tegulato1t) position 1. given.bt NRC Reg Guide 3.34 LS.t/1tt an excwtsion is assumed to occu.t ht a ven.ted vessel and multiple excwtsions occu.t scLtit bwtsts lasting 0.5 seconds at intetuals of 10 mblates fo.1 a petiod of 8 Inowts. A tattti of I x 1019 fissions occut dwting tite excwtsions.
Picase.tevise tite ctltica.LLtij anattjsls given on pages 5-16 and 5-18 and extend to covet tite conditiorts cf 1019 fissions set fottle in Reg Gaide 3.34.
11.1 Referenced Material on pages 5-36 through 5-18 5.4.3.1 Criticality Accident postulation - It is reasonable, based on the past accident experience, to assume that the most probable maximum criticality accident will result in a. total of 1018 fissions.
Since there are no significant fission products existing in the mass of uranium prior to the initiation of the accident, the only fission products which corld be released are those formed during the accident-The assumptions used in determining the amount of radioactivity released where as follows:
o The release results f rom 1018 fissions in a liquid supercrit ical system.
o Initial fission product inventory is zero and the accident lasts one second.
Radioactive decay begins at this time.
Only. volatile fission products are considered to be released.
Dr. E. Y. 3 hum November 17, 1980 A t t ac hmen t 3 - Page 18 o The volatile fission product cloud is released from the liquid system and is draan into the building ventilation system.
The time required for the cloud to exit the stack is based on the rate of room air changes in the UFO conversion and is 13 minutes.
o The velocity of the cloud once it is released from the conversion area stack is one m/see toward the southern site boundary which is 574 feet from the stack.
Time for this travel is 3
~
minutes.
Therefore, the fission products are 16 minutes old at the time the site boundary is reach ed.
A conservative age of 10 minutes is
- used in the-calculations.
It should be noted that an individual at the site boundary would receive exposure from both internal and external sources of radiation.
The doses (Table 5-5) were calculated from the individual's subnersion in a semi-infinite cloud of beta and gamma cmit ters, from inhalation of the fission prcducts, and from the direct radiation associated with the incident.
The dose from prcmpt fission gamma rays and neutrons were obtained frcm the Referenec: Y-1272, Y-12 plan t Nuclear Saf ety llandbook, J.
L'. ?lac h t er, et al.,
March 27, 1973, Union Carbide Nuclear Co., Oak Ridge, Tenn.
The wholebody dose due to submersion in the fission product cloud was calculated by the standard seni-infinite cloud assumptions (
Reference:
Safety Guide 3).
The inhalation dose to the thyroid was calculated based upon the resulting short-lived radioactive waste contained in the fission products.
A median atmospheric diffusion factor at the nearest site boundary of 10-3 was used in these calculations.
Table 5-5 l
Doses to an Individual at the Nearest Site Boundary l
Resulting from a Criticality Acci ent 1
Direct dose (prompt neutrons and gamma rays) 2.G Rem Submersion dose 2.1 Rem Inhalation dose (thyroid) 0.8 Rem
Dr. L. Y. Shum November 17, 1980 - Pnge 19 As can be seen from Table 5-5, the doses to an individual at the nearest site boundary from a criticality accident are smaller than the maximum permissible occupational exposure for individuals working with radioactive materials.
Therefore, even the incredible case of a criticality accident in the fuel fabrication plant in which low-enriched uranium is processes, no significaut environmental impact ( i. e., radiation dose to an individual at the nearest site boundary) would result.
m 11.2 GE Response to Question The analysis described above will be extended to cover the conditions of 1019 fissions set forth in Regulatory Guide 3.34, as soon as possible.
12.0 Question l' age 6-3 and Table 6 Please extend the infattration given in Table 6-1 te ihetztdc the latest avaltable data on tutet impatitics.
12.1 Referenced 1!aterial on Page 6-3 (and on Page 6-1) and in Table 6-1 6.1 Preoperational Environmental Programs 6.1.1 Water - Early programs undertaken by GE to obtain baseline information for the Northeast Cape Fear River were to determine levels of chemical concentrations.
Since the waste discharges frem GE were expected to be typically those of a small chemical plant, the areas of concern included chemicals in river water and ground water.
The liquid samples taken from the plant effluents, from the Northeast Cape Fear River, and from surface and ground water (wells) are one-quart " grab" samples.
Figure 6-1 shows the location for these preoperatio,nal samples from the Northeast Cape Fear River.
Baseline data (1968-1969) from the analysis of river water samples were tabulated in Section 4.
It was recognized in 1969 that additional information was needed on the complex mixing characteristics of the estuarine system involving the Northeast Cape Fear River.
Cooperation was given to the North Carolina Department of Water and Air Resources and the Depart-ment of the Interior in a dye mixing study conducted during 1969 to 1970.
An abstract of the study follows:
~
e-o Dr.
1', Y. Shum trovember 17, 1980 - Page 20 Abstract This report presents the results of a fluorescent-dye-tracing study to determine the concentrations of a pollutant that would be present in the Northeast Cape Fear estuary at various rates of continuous. waste injection and fresh-water inficw.
Rhodamine WT dye was introduced into the estuary at a constant rate over a 24.8-hour period (two tidal cycles) at a point 6.4 miles upstream from the mouth in Wilmington, N.
C., and concentrations were monitored at several selected sections in the tide af fected part of the river for 17 days. The range between high and Icw tide in this reach of the estuary averages about 3.5 feet,'and there is usually strong ficw in both directions.
Results of the dye study indicate that if a pollutant were injected at a rate of 100 pcunds per day under the conditions of relatively low inflow existing at the time, concentratien would ultimately build up to 20 micrograms of dye per liter of water 1,000 feet dewnstream. The flushing time during the study is estimated to be 17 days. These results are extrapolated to include periods of lower or higher inficw. For example, at average intervals of 10 years, it is estimated that inflow is so low tha t 100 days are required for a pollutant to travel the 6.4 miles f rom the point of waste release to the mouth of the river.
Under these conditions, it is expected that 1,000 feet downstream from the point of waste discharge, daily maximum concentrations will average about 130 micrograms per liter for each 100' pounds of pollutant injected per day.
Results of the continuous discharge measurement of ficw made by current meter during a complete tidal cycle.are presented as a part of this report. Da ta from this measureme.1t and other evidence indicate that net upstream flow in the estuary is possible over a period of several days.
Ground water was sampled and analyzed in 1968.
Resulting data for impurity concentrations in the plant well water supply are shown in Table 6-1 for the years 1968, 1972 and 1973.
(See page 21 of this attachment for Table 6-1.)
12.2 GE Response to Question The information in Table 6-1 has been extended up through 1980 as shown in the table on page 22.
7
Dr. E. Y.
Shum November 17, 1980 Attaciunen t 3 - Page 21 I
Table 6-1 ON. SITE WELLS IMPURITY CONCENTRATION
- Comparable Chemical 1968 1972 1973 Standaed'
=
Cbicium (Cal 100 50 0.3 fron (Fel 0.09 0.7 Magnesium (*.tg) 7 2
Scdium (Ni) 57 26 0.05 Manganese (Mn) 0.01 0.01 Uranium (U)
< 0.01
< 0.01 0.01 Bicarbonate (HCO )
132 198 3
Carbenate (CO )
0 0
3 Hydro s yl (C HI O
C.foride (C1) 40 16 20 250 250 Sulf ate (50,i 1
6 Nitrate (NO )
NIL 0.03 0 07 44 3
Flueride (F) 0.01 0.14 1
0.10 C.6 Ammonia (NH )
3 0.08 Fhoschoreus (P)
Tota! Hardness 107 132 Alkafinity 123 162 37 500 5
Alkalinity
- O 6.0-8.5 pH 73 Total Solids 200 219 205 500 Free CO 13 8
2 Silica (SiO )
17 16 2
l Notes:
- Facts pe* M.4 tion fpomt a Water Quahry Criteria.1968 Edition IPeress@e we ves iPownl a
b ?.%tnvl Oreage c Phencomthafem I
l
. s, Dr. 1;. Y. Shum g
November 17, 1980 A t tac t: mon t 3 - Page 22 ONSITE WELLS IMPURITY CONCENTRATION Parts per Million Chemical 1974 1975 1976 1977 1978 1979 1980 64 51.5 40.5 Calc ium 1.9 1.9 3.1 Iron 2.7 3.0 4.3 Magnesium
~
13.0 19 14.1 Sodium 0. 41 4 0.2
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01 161.0 148.0 Bicarbonate 0.0 0.0 Carbonate liydroxyl Chloride 12 20 15 19 21 23 19 3.0
<1.0
<0.5 Sulfate
<0.1 0.18 0.12 0.11
<0.02
<0.10 Nitrate 0.15 0.14 0.23 Fluoride Ammonia 0.08
<0.05 0.20 0.12
<0.2
<0.02 0.34 12 0.29 0.09 0.14 0.30 0.37 Phosphorous 168.0 148.0 150 Total hardness Alkalinity
- Alkalinity **
6.9 7.2 7.4 pH 238 253 204.0 37.0 259 Total solids Free CO2 Silica
- Methyl orange
- Phenophthalein 1707G