ML20046B610
| ML20046B610 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 07/23/1993 |
| From: | Edgar J SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER |
| To: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20046B611 | List: |
| References | |
| TAC-L30506, NUDOCS 9308050240 | |
| Download: ML20046B610 (7) | |
Text
SIEMENS July 23,1993 U.S. Nuclear Regulatory Commission Attn: Mr. Robert C. Pierson Fuel Cycle Safety Branch Division of Industrial and Medical Nuclear Safety, NMSS Washington, DC 20555 License No. SNM-1227 Docket No. 70-1257
Dear Mr. Pierson:
Re:
Letter, M. Tokar to L.J. Maas,
- Modifications to Gadol inia Scrap Recovery Process in ELO Building (TAC No. L30506)," dated June 4,1993.
Enclosed are Siemens Power Corporation's (SPC's) answers to NRC's request for information contained in the referenced letter regarding SPC's amendment request for gadolinia scrap recovery process modifications. Also enclosed is a revised Figure 1 showing eight raffinate tanks with 50 gallon capacity each and revised pages 1-8,10-37,10-38,10-39,10-40,10-41, Figure 11-10.26, and pages 15-15 and 15-16 for the existing license and pages 10-35 through 10-52a, Figuro 11-10.26, and pages 15-38 through 15-44 for the August 26,1992 renewal application.
If you have any questions regarding this information, please call me at 509-375-8663.
Very truly yours, Ib.
Jamc&B. Edgar Staff Engineer, Licensing JBE:pm 030125 f
l Siemens Power Corporation l
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SPC RESPONSE TO NRC REQUEST FOR INFORMATION NRC Reauest 1.
The amendment request docs not include changes to Part I, Ucense Conditions, of the license. However, Table 1-1.1 should be amended to explicitly authorizo scrap recycling and reprocessing in the ELO Building.
SPC Response Table 1-1.1 has been revised to include scrap recovery in the ELO Building.
NRC Reauest 2.
Your request states that the modifications do not a!!ow airflow from the first floor to the basement. However, Figure 11-10.26 shows airflow from the raffinate tank room (tops of the raffinate tanks) on the first floor to the POG scrubber room in the basement. The first floor raffinaie tank room should be supplied with air from the basement.
SPC Response The raff;nate tank room is actually the same room as the POG scrubber room. The raffinate tanks are in a double high bay section of the room. The dotted line on Figure Il-10.26 means that a small amount of air goes from the top of the double bay, which is the same level as the first floor where maintenance access exists, to the bottom of the double bay through an opening akin to a grating.
NRC Reauest i
3.
Figure 1, Planned GSUR Layout, indicates two raffinate tanks at 200 gallons each.
However, your request states that the new raffinate storage includes eight tanks. Figure 1 should be corrected to indicate the correct number and capacity of the raffinate tanks.
S_P.,C Response P
i in fact there are two banks of four tanks each. Each tank has a capacity of 50 gallons which give; each bank a capacity of 200 gallons. Figure 1 has been revised accordingly.
NRC Reauest 4.
The Safety Demonstration should identify and describe the new steel tanks and pumps that are replacing the existing pumps and polypropylene tanks.
SPC Response 1
The new steel tanks and pumps will be located physically in the same locations as the j
existing polypropylene tanks and pumps. However, tank numbers will be modified due j
to the installation of the raffinate tanks.
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i NRC Reauest 5.
According to Figure 11-10.26 (Simplified Schematic HVAC System - ELO Building Expansion), part of the airflow exhaust from the new powder screening station in Room 52 goes through an existing HEPA filter to the K-46 system and part through the new DOG scrubber and dryer to the K-56 POG system. Clarify whether the pellet dissolver hood, containing the new powder screening station, is served by the existing HEPA filter system and K-46 or the new DOG scrubber and dryer system and K-56.
SPC Response The powder screening station and the charge port for the pellet dissolver are located in the pellet dissolver hood to mitigate potential airborne contamination. The hood itself is vented through K-46. The pellet dissolver offgas is vented through K-56, through a separate vent line.
NRC Reauest I
6.
The Safety Demonstration should describe how the vacuum cleaner system in the powder screening station is vented.
SPC Response The vacuum is a NILFISK vacuum and is a nuclear industry grade vacuum which has a HEPA filtered exhaust. The vacuum is certified using the DOS test for HEPA filter efficiency. It is therefore a standalone model and is not in a hood. Section 10.3.8 has been revised to include this description.
NRC Reauest 7.
Figure 11-10.26 should clearly indicate which new scrubber is the "mystair" and which is the "dissolver offgas" scrubber, it appears that the DOG scrubber serves the solvent extraction, pellet dissolver, and mop powder processing units; and the POG "mystair" scrubber is in line just before the K-56 POG system and serves the DOG scrubber and the raffinate tanks.
3 SPC Response You have correctly interpreted Figure 11-10.26. In the letter of January 18,1993, Figure.
2 shows the GSUR offgas system. The MYSTAIRE scrubber is the process offgas scrubber. The treated offgas from the dissolver offgas scrubber is fed to the MYSTAIRE scrubber. In order to clarify this point Figure 11-10.26 has been changed to add i
"MYSTAIRE" to the scrubber upstream of the K-56 exhaust fan.
l NRC Reauest 8.
A vertical line in the right margin of Section 10.3.8.5 indicates that this text is a new section describing the deluge system. However, Figure ll-10.26 does not show a deluge sysicm in the K-56 POG system. This section should clarify that only the K-46 system has a deluge unit.
i
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SPC Response Section 10.3.8.5 has been revised to indicate that only the K-46 system employs a deluge system.
NRC Reauest 9.
Section 10.3.8.6 should specify that it refers to the K-46 or the K-56 system, or both.
Figure 11-10.26 indicates that the K-46 system also has a HEPA filter bank, but Section 10.3.8.6 does not describe the HEPA bank in K-46. A section describing the K-46 HEPA filters should be added.
SPC Response Section 10.3.8 describes the fact that both the K-46 and K-56 systems are double HEPA filtered. Section 10.3.8.6 applies to both systems and has been revised to so indicate.
j
.NRC Reauest 10.
Figure 2 GSUR offgas diagram, indicates that 950 cfm from the " uranium recovery process"is not routed through the DOG scrubber, but goes directly to the POG scrubber.
However, Figure 11-10.26 indicates that some of the airflow from the solvent extraction process, which the reviewer assumes to be the same as the uranium recovery process, is directed through the DOG scrubber. The figures should be corrected to clarify whether or not these offgases pass through the DOG scrubber.
SPC Response The uranium recovery process in Figure 2 is the solvent extraction process and is e
diagrammed as a process step. Figure 11-10.26 is diagrammed on a room basis. The solvent extraction room shown in Figure 11-10.26 has the following ventilation scheme:
A.
Hood exhaust vented to K-46 B.
Room exhaust vented to K-46 C.
Process tank exhaust vented to K-56 D.
Dissolver exhaust vented to a DOG which in turn is vented to K-56.
Figure 11-10.26 has been revised to show the process tank exhaust stream that was omitted in the original submittal.
NRC Reauest 11.
The letter, text, and diagrams appear to use the terms " dryer" and " heater" interchangeably for the units that remove moisture from the air stream between the scrubber and HEPA filters, they should use consistent terminology to avoid confusion between the system descriptions and the diagrams.
SPC Response i
i
" Heater" and " dryer" after the scrubber refer to the same thing. " Heater" is the more correct term.- The intent of the " heater" is to prevent saturation of the HEPA filters.
The diagrams and text have been changed to use " heater" consistently.
l NRC Reauest 12.
The request indicates that stack discharges will more readily meet internal and State regulations and that liquid effluent will be minimized. The Safety Demonstration should provide estimates of the reductions in NO emissions and liquid effluents produced by l
x the system modifications and should estimate the Volume of Scrubber liquid that will be generated in the new K-56 system and reduced in the existing K-46 system.
l SPC Response There is no estimate yet of the reduction of the liquid and NO, emissions from the GSUR modifications. Reduction estimates will be obtained during start up in functional testing. Uquid effluent reductions are expected to be significant due to the fact that we are going from a steady rate usage to one based on actual operation requirements. NO emissions are expected to be reduced due to an improved x
scrubber design.
NRC Request 13.
The raffinate storage will increase from 40 to 400 gallons, a 10-fold increase in capacity. The amendment request should include a chemical safety analysis to l
describe any additional safety precautions that are needed to routinely handle this increased amount of raffinate. The chemical safety analysis should indicate whether i
the probability or severity of a chemical accident is increased, and, if so, what i
additional measures will be necessary to' mitigate such accidents.
l SPC Response increasing the capacity of the raffinate storage does not increase the risk as long as good design practices are used. These design practices should address the three 9
main hazards associated with raffinate which are sprays, spills and fumes. An explanation of how the design addresses these hazards, is presented below; i
Sprays - Welded stainless steel piping is used in the raffinate collection system piping.
Spray guards are installed over all flanged fittings. The tanks are constructed of reinforced polypropylene.
l t
Spills - A concrete curb has been constructed on the floor below the raffinate tanks i
which will hold the contents of four tanks (200 gallons). The concrete is seated with a chemical resistant coating. The reinforced polypropylene tanks and the welded j
stainless steel pipe also guard against spills and leaks.
l I
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Fumes - The new raffinate storage system is airtight, operated under a negative pressure, and vented to a process offgas scrubber. Therefore, all fumes are drawn through the POG system and not into the operating area.
In addition, the physical location of the new raffinate collection system in a separate room from the operators will decrease spill, spray, and fume hazards to operating personnel. To mitigate the consequences of spill or spray contact by operators there i
is a safety shower near the tanks.
j NRC Reauest l
14.
The amendment request should describe the practices that will be used to ensure criticality safety and include a criticality safety analysis of the modifications, particularly of the new raffinate storage tanks, new mixer / settler, new drum staging area, and
]
Tank-1 hood expansion.
SPC Response Generally criticality safety in the Gadolinia Scrap Recovery Facility is provided by control of the geometry of the solvent extraction equipment and the dissolvers, as well as through control of feed and product solution uranium concentration (mass). All process vessels except the powder dissolver and the 55 gallon UNH product drums are geometrically safe for the achievable uranium concentrations of the solutions in the i
gadolinia recovery process. Safe concentration in the powder dissolver is maintained by batch control of the powder added to the dissolver, Concentration in the UNH i
product drums is controlled by specific gravity measurement of the UNH prior to its transfer into drums. The amount of tributyi phosphate (TBP) specified for solvent extraction limits the theoretical maximum U concentration of the product to slightly 1
more than 20% of the critical concentration in a fully reflected 55 gallon drum.
The specific criticality safety analysis for the GSUR modifications has not yet been completed. It will be completed prior to startup with nuclear material and will be on file at SPC.
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l FIGURE I
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DOG 8 Tks 8 50 gal en, Scrubber Drun ANN Storage Delivery
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