ML20055C470
| ML20055C470 | |
| Person / Time | |
|---|---|
| Issue date: | 05/03/1990 |
| From: | Cunningham R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Bernero R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20055C471 | List: |
| References | |
| FOIA-90-220, REF-PROJ-M-48 NUDOCS 9005090343 | |
| Download: ML20055C470 (43) | |
Text
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. MEMORANDUM F0,-
Robert M. Bernero, Director Office of Nuclear Material Safety j
i and Safeguards FROM:
Richard E. Cunningham Director Division of Industrial and Medical Nuclear Safety, NMSS
SUBJECT:
GENERATION RATE OF UF TAILS FROM AN ENRICHMENT PLANT 6
i Your quick calculation of the generation rate of depleted uranium hexafluoride j
tails for the Louisiana Energy Services (LES) plant, based on. annual U.S.
1 reactor fuel needs, is approximately correct.
For SGTR, ORNL made some calcu.
i lations of tails generation from the LES plant on a 1.5 million SWU per year basis.
They determined that 20014. ton cylinders would be filled annually, based on a product assay of 2.8 percent U.235 and a tails assay of 0.2 percent U-235.
Assuming-the same tails assay, but a product assay of 3.6 percent l
U-235, they determined that 19014. ton cylinders would be filled annually.
These values compare favorably with your estimate of about 230 cylinders per year.
When the NRC team visits the Urenco plants in June 1990, they will check on
-l the quantity of tails cylincers filled at those plants.
One reason that L
there may have been a fewer number of cylinders than expected stored at the Gronau or Almelo plan s is~that Vrenco offers to transfer tails back to its j
customers, and some customers may have accepted the effers.
We have consulted with both LLWM and SGTR on the issue of' tails generation, not only from the proposed LES plant, but also from the DOE plants.
In the latter regard, your estimate _of' 1500 14. ton cylinders per year is not-inconsistent with DOE's estimate of some 30,000 to.a0,000 tails cylinders, i
-attributable to commercial uranium enrichment, that have been accumulated at i
the gaseous diffusion plants.
b-Richard E. Cunningham, Director Division of Industrial and Medical Nuclear Safety, HMSS cc:
G. Arlotto, HMSS i
R. Bangart, LLWM L.
~R. Burnett, SGTR DISTRIBUTION:
NRC File Center CHaughney IMNS Central File JSwift IMAF R/F V PLoysen NMSS R/F rmvw y IMSB R/F (OSOfd30
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L DATE :05/01/90
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- 05/3/90
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UFFICIAL RECORD. COPY
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-DLKE ENGINEERING:
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LES Project Par *med Diane - suita 200 P. O. Bom 38911 Mail st3 PP028 Charlotte, NC 28235 1
-l TELECQ27 Er. QUEST ro33g FAR No. (704) 373-8700 Verification No.-(704) 373-4854 Joey Jordan, Project sacratarY l
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1 1/3 agenda 1
KRc/LEB Meeting c
L January 11, 1990 1
nid Bandanas site selection, Update from LES, Closing on land, January 12, 1990 in Shreveport.
Expect to start baseline environmental' sampling (pre-timbering) -January 20,.1990.-
i Issuance of. operating' License considering assembly of centrifuges and construction activities -in cascade halls, while enrichment is in progress.
Update from M. McGarry or B./ Shields..
Safety and QA classes class I Structures, systems and components necessary to ensure the capability to prevent or mitigate credible'(10E-6)-
!t' accidents whose consequences could result in potential j
offsite exposures in excess of 26 mg/ cubic meter Hydrogen ~ Fluoride (HF). to the body or lungs, or 40 mg uranium to the kidneys.
The quality of these structures, systems Land components would be ensured by application of. all' 18. criteria -outlined in 10 'cFR 50, Appendix B as explained by ASME NQA-1-1989.
Examples: Feed autoclaves and equipmentSwithin feed autoclaves.
l Class II-Structures, systens and components which are essential for prevention of credible to worker permanent injury o(r loss of life from the -10E-4) incidents _l radiolegical'or chemical hazards:of UF6, but are not Class I.
Such worker injury would' occur if uranium uptake to the kidney exceeds 100 mg or unprotected i
exposure to RF concentrations. greater than 100 mg/ cubic meter for periods over 1 minute.
l The quality of these structures, systems and components would be i
- ensured - by application of selected criteria outlined in 10 CFR 50,-Appendix B.
Examples: Non-feed autoclaves.
Class III-Structures, systats and components which are not class I nor Class II.
The quality of these structures, systems and components would be I
ensured by engineering practices consistent with normal industrial practice.
Examples: Centrifuges.
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4 Agenda Mac/LES Nesting January 11, 1990 Security Information.
Update from Nac.
Status of Fluor Facility Security Plan.
Anti-Trust estions.
No problems with NRC questions.
Should be respon g June, 0.990.
New Business I28 QA Program.
Description of LES QA program by Robert i
Justice.
, Region IV activities.
Update from the NRC on any activities-necessary to review the LES QA program.
Material control and Accountabi ity.
Update from NRC on new guidelines that will be superseding 10 CFR 74.31.
SAR Table of Contents.
Several sections have been added to
- outline in-R/G 3.25.
Reference attached outline.
. Definition of Accidents, Abnormal Operations and - Normal System operation with Normal System Upsets.
=
Normal System operation:
Any operating condition that does not result in any interruption of SWU production, but may. require automatic or worker. adjustment for process to continue normally.
All piping systems remain intact and automatic or worker adjustment are considered routine.
For example, an adjustment to UF6 feed rate.
These conditions would be described in a subsection of SAR Section 6.3.
F Normal System Upsets:
4 r
' Any loss or interruption of SWU production; however, no release of UF6 occurs.
All UF6 piping systems remain Intact.
For' example, loss of all AC power or loss of centrifuge cooling water.
The design of the plant prevents these conditions from ' causing r
releases.
These conditions would be described in a separate subsection from " Normal System Operation" in SAR Section 6.3.
a Y
Abnormal Operation:
An abnormal condition t? at has the potential of releasing UF6
=
that could affect onsite personnel.
These conditions would be E
described in SAR Section 9.1.
FI
-IP Erag
-3/3 Agenda BBC/ lab Baeting Jannary 11, 1990 Aooident:
Any loss of UF6 piping or confinement system'with some release of-UF6..
The release has the -potential of affacting public.-
Detailed operator or automatic actions. are necessary - to stop release.of UF6.
Mitigation-of the release prevents exceeding the-offsite dose limits. ' For arample, loss of, cylinder pressure boundary while in the autoclave.
These conditions would be' described in SAR Section 9.2.
. Emergency Planning.
Use of guidelines. approved; for= other
~
fuel cycle facilities. April 7,
1989.
LES should use these guidelines for -developing any necessary Esergency-Plans.
An additional: criteria for emergency planning should be 2 mg/ cubic mater RF, similar to 2.mg Uranium.
NRC Resources necessary to support LES review.
Estimate from the NRC on the man-power - and dollars expected. to support.
review of the LES application and licensing process.
Johnston Legislation for enrichment facilities.
Comments from the NRC on the impact of this' legislation: on ;the LES application as well as the expected timing of updates to the Code of Federal' Regulations after the legislation is approved.
Date of next meeting.
(February-22, 1990?)
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e Regulatory Guide 3.25 Standard Format and contant Guide of Safety Analysian Reports for Utsnium Enriremnant Pacilities.
LES Modifications Add following sections 1,7 Agggovah Fugls' Accident Aetion Plan-The FSAR should describe the applicability-. of -
the recommendations of NUREG-1198 and NUREG-1198, Supplement 1 to the facility.- Design or administrative features of the facility that
-implement the recommendations of the Lessons-Learned Group should' be discussed.
18 Rnrichment Facility Licanmincr Reauiramanta The FSAR. should describe the application of recent Commission' actions to the facility, The Advance Notice of-Proposed Rulemaking for Regulation of
. Uranium Enrichment Facilities (Fed Reg, April 22,-1988) outlines the parts of le ?FR 50 that apply to the licensing of an enrichment facility.
'the application of. the following and features of the ' facility that relate to the following should also be discussed in this sectiour.
-Bulletins
-Generic Letters
-Regulatory Guides
-Recent Rulemakings (e.g., 10 CFR ' 50.63 Loss of All AC Power, 10 CFR 52 Early' Site Permits; Standard Design certifications; and Combi.ned Licenses for Nuclear Power Reactors) 1.9 Abbreviations. Acronyms and Glo==avv The. PSAR should contain a listing of the abbreviations' and acronyms used in the FSAR.
Also, a glossary should be provided defi.ning :those terms unique to the enrichmant facility.and its processes, l
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Regulatory Guide 3.25-u g&mndar11 Format and content Guida of Sal'ety i,
Analysis Esports for Uranium Enrirement Fact 1ities.
T.ES.Modificultiamp Nodify fellowing' sections:
Add-to Section 6.3, Enrichment and other Processing Systems,
.k a
subsection concerning normal process upsets.
1 Add to Section-8.3.2, Process Vents,1 a discussion' of the design-capability to confine HF and other chemical forms of UF6.
Add to Section
- 8. 5.1,. Elfluent and Environmenta1 Monitoring Program, a' discussion of the impact of EF on the environment:and a discussion of ' the inclunion of -HF sampling in the facility sampling program..
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1/2 Agenda NRc/LES Neeting November 8, 1989 old Busineng i
Site Selection, Updete from LES, Reference attached news release.
Natural Phenomena, Update from LES.
Foreign Domination, Update from LES.
Issue of operating License, Update from LES, Interpretation of Act.
Part 20 Revision, Update from NRC.
Anti-Trust questions, initial comments from LES.
Approximate 5% unrichment limit, written commitment from LES.
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Knw Businese Rwg Guide 3.25, Sections 5.4 and'G.6 (Future Technical 1
Information) unnecessary.
Does NRC want something. specific in these sections.
Design completion for submission of License Application.
i 10 CFR 52.79(b) & (c) imply that outline of Design commitments paying special attention to Inspections, Tests, Analyses and Acceptance criteria will allow for resolution of these issues at the Construction Permit hearing.
The description in the AIF. paper (attached) of the design and engineering information that would'be available for inclusion or as basis for the license application is the appropriate level of design detail.
Certain desi engineering activities, for example pipe routing,gn and dynamic stress analysis and interaction analysis, would be described-in the license application.
The completion of these activities would be in the form of detailed Design commitments, for example:
"The autoclave will be designed in accordance with ASME/ ANSI code and will be supported to withstand an earthquake of acceleration.
The non-safety related structures, syatens and components that could physically interact with the autoclave during an,y design basis events, will be supported so that the autoclave will remain intact during the events."
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November 3, 1989 CLAIBORNE PARISH, LA.-- Louisiana Energy Services announced t d l
that it has selected one site for further study for the ur o ay enrichment services facility announced in June.
anium 450-acre site is cur:.antly owned by Avalyn LeSageLo
, the l'
)
"Of the several fine sites we have studied, the LeSag i
appears to be the best," LES President Howard Arnold said. "Not e property make Lt ideally suited to support the plant's found I
heavy excavation, and technical studies and to complete the administ i
of the purchase," Arnold said.
s t
LES is a joint effort of three electric utilities for metear fuel enrichment services. Enrichment is o
, riuor Daniel, Inc.
?
steps necessary to prepare uranium for use as a nuclear fuel a several Construction of the $750 million plant is scheduled to be i with full operation in 1996. It will be capable of supplying g n in 1992, approximately 15 percent of the enrich ent requirements of the U S nuclear industry.
The three electric utilities are Duke Power Co.
in MinneapolisGraystone Corp., a subsidiary of Northern States Power C, of Char Orleans. The engineering and construction fiz1a of riuor Dand Lo ompany, based based in Marlow, England, with offices in Washingtoni aniel, Inc.,
um
, D.C.
Claiborne Parish was selected for the facility from more th potential sites nationwide, an 100 i
l For further information, contact:
Joe Maher (North Carolina) 704/373-8323 t
Mary Boyd (Louisiana) 318/927-6166 ll I!
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4 APPENDIX 3 I
Design information Requirements for Design Certification and Construction and Operating License Appilaations l-t I
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m oroer to su!Dort the NRC review one 4*;prevel of a stenoara design to leaa to a DC or COL the ccrootstes m general arrangement mforms.
tion deve60pment.
plant or subsystem cessgn must be sufficientty gornp6ete so that the appicant and the NRC have Functional /Ferformance Specifications for l
, clear cef niten of all safety aspects m order that l
construction and testeg can be performee m ac.
Components one Matenets - Design entens cercance with proopproved methodology and Specifications that will identify functenal I
procedures ano measures agamst preapproveo ac.
and performance requirements for systems ano components m the balance of plant.
geptance entona. Accoromply, the following dessen ano engmeenng mformatson would be con.
tameo in the application as appropnate, cepenomg Acceptance / Test Recurements - Identification on the scope of the oeseen and whether the appts.
of applicable codes. stancares, regulatens j
caponis for a DC or a COL and acceptance cntens to be used in con.
struction, metallation. and tesung.
Deseen Basis Critene - Identification of the entene Probabiliste Risit Assessment Methodology --
l upon.whech the design of the plant will be 1
basec. Included m this section will be refer.
identification of the methodologies, assumo.
ences to the General Design Critons tions, ano procedures to be used m the per.
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(10CFR50 Appenois Al. Stancara Revow formance of the probabilistic nsk assess.
ment.
Plan iNUREG.08001, and the ccces and stan.
deres uses m cosign, construction ano opere.
tion tASME. IEEE. etc.). Other regulatory re.
Preparation of such an application wou6d recuare qurements identified wdl include emergency that tes oesegn encenaarm_e be essenteily com.
1 plans. Quality assurance program, matenets
.P.le% The follow.ng desegn cocumeNf51mtlfrew.
roovirements, redelogeal (ALARA) assess.
' Age pued be espected to be avaliable es neces.
monts. emergency core coolmg systems se:y for NRC review as applicable. cepenome on
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(ECCS) ova 6uations, fire protection. secunty sne scope of the design and whether the apples.
plan and technical specifications, tionis for a DC or a COL 1
Analysis and 00 sign MethcJs - Identification of Design Sasic Critens - This information will be the angmeenng methods, assumptions, addressed in General Dessen Critone Specifi.
l desegn guides, analyttal approaches and cations and Functional Design Critene Spe.
computer coces to be used in the plant cifications.
design. This wel include methodologies for seesmic design, pipe stress analysis one fluid Plant General Arrangements of Structures and flow oesign. Additionally, load comomations will be identified, components - Spatial onentation of waits, l
floors, busidings, and the touspment and sys.
tems withm these structures will be identified Functional Design and Physical Arrangement of on General Arrangement drawings.
i Aussliary. Balance of Plant and Nuclear Steam Supply Systems - Descnotion of the Process and instrumentation Diagtsme (P&lO) -
maior plant parameters and functional design Direction of fluid flow, process mformaten.
roouirements resultmg from &%S and tur.
and the components that are part of the bine generator se6ection, and wde reference plant systems will be identified on P&lDs.
i l
approonate preapproved venoor supplied i
documents. This wdi include listings of base Controt Loge Otagrams - Reactor protecten, en.
systems. structures and components, func.
gmeenng safety features, and balance of tional descnotions of buildings, mator equio.
plant systems will be identifed on Control ment layouts. and mterface requirements Logic Otagrams, identified by maior vendors.
P! ant Physical Arrangement Sufficient to Accom.
System Functional Desenptions - System pur.
modate Systems anc Components - Generst pose, function, and operational recurements arrangement information eenvoo from the wdl be 6dentified in System Functional Oe.
scriptions, motor plant parameters and functional design reouirements Other reouirements such as Component and Procurement Specifications component removal. oull sosce, memtenance meloding Acceptance Test Recurements -
consecerations. ano personnes access are m.
Eouipment ano matenal performance require.
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ments wd be scentified on component and procurement specifications. Additionally, The plan wW address the use of guarc thee9 specificatens wW include procurement waschmert. physical bemers, and visual su!
mformenon and the requesste codes and sten.
vedence r ?ch that sabotage theft or osvCn i
dards to which the meterals and components s6en of fuear matenaldoes not occur.
wd be testeel.
s At. ARA / Radiation Protecten Plan - A prograr Construenon and installation Specifications -
wd be identified to protect emf..oyees fror These speerfications wW identify the entene redemon exposure and to keep smotoys!
and methods by which systems, structures doses as low as reasonabfy acnievaci!
and components are erected or installed in (AL. ARA) while the plant is bosng constructo operated. and modifled, l
the facehty. These specificanons will include k
eceeptance, mopoccon, and testeg require.
Accsdent Analysis - A determiness enemmatiel' ments and entene, of undesirable events will be performee t(
Suppomng Design Documentation such as bound.
determine the necessary response of suct.
ing sate data and calculations sufficient to events should occur. This anaeysis weil con.
support the above level of design datasi -
seder occurrences classified as operations transeents, faults of moderste frequency, m.
Reguarements for systems, structures or components associated with the boundmg frecuent faults, and limrtmg fouets.
(
site will be identified. Typecal informaten necessary to establish these rooustements m.
Draft Techancel Specificanone iPRAI. - These s
spoorfications wd provide a desanotion of cludes meteorology, geology, hydrology, subsurface and foundacons, seeemology, plant operetton with respect to safety limits 1 flood studies and auxiliary sources of nuclear and tim 6 ting safety system estungs, limitmg service water, condetions for operecon, survedence require.
ments, design features, admweswetswo con. I Quality Assurance Program - A QA program wrA trots, snel definitions. The preones of for..
muleeng drott technscal spoesfiestone wW in.
be identified which assures conformance of -
volve obtsming standard techrased the eteegn, construcnon and operemon of the facility to appicable regulatory standares tions from the NRC and C__..
-, which ;
specifications are applicable, wasch nees -
such as 10CFR50 Appendia 8. approved in.
modificaten, provision of apphoeble values :
dustry standards such as ANSI, and corre.
of persmeters and venables, figures, graphs. <
sponding daughter standards or equeve6ent altamatives. The program includes the sur.
and other informaten requered to complete,
vedance and inspection of design, construc.
the standard technical specificatone.
tion, and operation of the facWty.
Probabilistic Risk Assessment - A systematic Emergency Plens - These plans will identty sc.
and structured methodology wd be appliec i tions to be fellowed in tale event of a plant to obtain quantitative estimates of the nske malfuncnon mesuding both on site and off.
of vanous meltunccons throtan the use of,
site evacuanons, accepted probabelistic and stenencal tech..
niouse and consecuence eveeuseon metnoos.
Secunty Plan - This plan will identfy provisions Due to its comprenenerve and systematic for the physcal protecton of the plant con.
nature. PRA methodology is a powerful tool ;
for esematmg the impact of design alterns.
sistent with the requirements of 10CFR73, tives on a plant's margm of safety.
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JAN 12 90
! Proposed uranium plant L
has La. senator all aglow lske of proposed.. I'rl'For a U.S. senator d
p~acuisia urensum pient
- rw4sHINGTON - A new Amu.
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to Say an enflCb-
{j.me"tlaY= Mould &
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1 1 ""t* ' ?$.Y mentplant willpro-e T %*'E*.au.e and I"*"l
. ;',t'O dame no environ-wd
,ier et.ao.of.she.a,t is.hao.
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mentalfallout is a 4
gross distortion of
.t' the nood news.
u ne h, sew.. a. de nded by s.,on.m ovee reals.ty,, -
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- weien, group. and.
handful of apprehensive north ories Jouisiarse residents, is the busi.
p. M, N,,,,, h er, g,,
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mess would handle potentially-g,,,,g,,
Marcrous radioactive raatenal.
p The project is a $*60 million s
tion. cials, seys the company's enrich. -
p$nned for C ai tne P r eh.
and a European corg8I***
k8'** ll"ti"IY **
ment process le cleaner and safer peer Homer. The factory will 1
twip prepare uranium for loading Eaway Servias,is aimlag to cut than oil refineries, chemical P
late commercial nuclear voertere into main from tlw gomnesat's plaats and many other industrial W motuaDy may have tlw es, momenoth and largely obeelste activities.
'a pacity to procoes 16 percent of enterprises, which also predase
. ashe people who an agalast l
America's nuclear fuel. If the melear weapons M this are these that want to abut
. minat opees as planned la 1993,it U.S. Sea. J. Benneet Johassen, down the suelear option la this i
. Ekdy would be the trat palvesety D.La.. has lobbied the plass's soustry," Johnessa said. "The 6
ewned heest plant la the. lavestors to it la 14eistaan.. way for them to de that le to I
Onited onBag it a saample of the oppees suelear energy at every t
. For decades the federal govern-todustrial iversificaties the stag. no matter what the dan.
ment has had a sisonopoly on the state neep to fuel an economic. get.
J American enrichment business. recovery Johnston, along with' But a consortium of U.S. utilities.many federal government of6 see unAfstWM. A.4 4
i A
\\\\
1 h
f
1 l
ues - um a Ur lum M "e# CmV '"*e 2 treek la the emnehment.
'm
- sees, of has serious that uranism pressened at %
g Sti avelaar epities askmeel-as c
km 1 and has se eaCchmerit plant poses a assi' ove r to sesidenta h weedd east et least ash 6f k
And son
- 88 b4Eles to being the shoo ines g,,,pumaan whb envirgamental a.m y
senium their will emit no ines air or water, But sentend I But Johnstaa. Base Depart-meat officials and esecutises leaks and acci ots are inevi*
table.
from 1.eislana Eug Services "For a U.S. eerator to ney an
- contend. bat any comparison with the r,overnment's rations enrichment plant will produce no is seriot sly flawed, enor-environmental fallout,,is a rems
. meus Enew Department ta, distortior. sf realit said Pet which r.ro amon the est in-M
. director of, Rahoec.
dustrie. lants i the wo were tive sete Campaagn, an anti-g,sh t a 1960s mad are widely nuclear organisation. -
Johnston has won plaudits for considered obsolete. They are his support from the mayor of contaminated with asbestos, PCBs and other meterials that Homer and most other local 015-long eine, have been banned for cials, abo for yeen have watebed ennronmental reasons. Much of the aroe's. econo.my bobble alon8 the 3overaaeat's projected with oil wells, timber cleanup costa would toward and dairy farmlag. And state these contaminasta, depart-federal vernment of6cials fa*
meat the European songe-F the government aa revious enrichment operstloa enriebes ursaise for meth a say the laat abound nuclear weapone as we8 as for pose no inore of threat than nuclear reactors. Weapons. grade many chemical p! ants. Esen uranium is enriched ab;ut 20 son,e ennronmentabats see htste times as touch as the lower grade cause for alarm.
used in reactors.
So why are some local tesl*
Enriebin uranium consists dents worried?
malaly o incresslag tbe "It's like the cal T.an element,a concentration of the horse and they'se sin it read 0y $anionable isotope U 235.
through the sete." g to said Roa Unlike government plants.whieb Anderson, e Homer roeident and see a vast rWaing process to a needer of a bud & leeal oppo-a h,-Aer and less Assio-ention up call Citiseas '
. Louisiana Energy est utnear Trash. "It'a'so-to see e compoet onetive." he said of the ube-eentri e method that will alue to he recessed at the the Eghter iso-A staat "and don't ease if it's it saa asia seuse senser;tape usemises. b peo-has basa used by so there how k."
Lauloissa par-For and other oppo-sat osepany, foe asata, the confrontation le semi-The urnaism brought niecent of a 1987 battle when late the se eelid uran 3um aeveral thousand Homer real-
. onoverted to gas for dents proteeted a low level au-and shi eut in its c) ear waste dump pr for d form. Esperta at with h area. Residente Clai-the process say the uraniuts be-borne Parish crowded lato a high comes highly eadioactive only school football sta&um chanting after it paseos th r
" Heck me'te in N we won't at see t reactor whieb lines raDy. A a whieb fuel and n,abes it irreesta.
has yet to open, was a ~^t But sa aseideatal release of shonen to house nuclear waste evenium benaeuoride would react from laulslana and four other with air to ersete the toxic ses states.
I
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.Kd.roge~a*Tuoride, e ebenical b
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.i.aus w,w,id o,e.to.t es.
e e
i mou f
leer s
uranium Ish over boa poseems esatanas about tlw ease radoeWrity as astural uranium, and buisiana Energy plans to store it in stael drums on the 450. acre plant site. Both i
bulsiane Energy Services and Energy rtment of5eish, =bc store d ted uranium in the i
same la blon, say technolog>
being developed eventually m allow 6e entraction of mon (ov f.
235 from the enrichment by.
product. In the meantime theet of5ciah bepe to sell some,of the depleted uranium for use la the small numbe applicatione,r of commercial such as armor.
piercing bullete and airplane i
ese the thousands of tons of lepleted uranium produced since the 1960s has been dio-carded, but a Nucl n
Co
- n ofncia specu sted that e
. product a M be dis-posed of in a dusop %. km level radioactive waste, such as the on. ;Saned for Nekt aa.
a Some public interest groups beve criticised Johnston for eponeonag legislation that estab.
lished licensing procedura for actor licennias.
' ' Johnston contends McGa.
enrichment planta but failed to W
"We thlali hn an enough vern's group and others an try.
l require oblic hearin they a operating.gs before envkommental and safety impli-ing to erect rasenocks la front of 4
Johnstoa estions ao that citizens abound get any nuclear development.
attac an anneadment to as a formal, ca hear.
"It's not true to say this pre.
unrelated pubtle lands bill late ing, given that seats the danser of a avelest 4
last taist would give citisses the la very peo ladustry, plant and shoutil be treated like a the to seclu'on the Nuclear said bid McGovern, an atm auclear plant," Johnaton aald.
r' Comalasion for hear. with the U.S. Public laterest Re.
Nie's no reason this industry ings be it would not require search Group, an advocacy orge, should have to go throu them, as in the case of nuclear re.
nisation.
boops with those delays.jh those f
a
4 Q p n_ _ _3 namesmnd e sanos -
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NEW ORI.F A'45,1,l',
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Roelhtsri Uranium plant up to people IEbg Sy eD aWDeRsON which the plant goes till deter.
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g Capital 6 erne f,,) g g Q mine whether the plant gods
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t BATON ROUGE - Gov.
Roemer said be favors the Roemer said Monday that a plan plant, we'ich would prepare
.I <
to build a $760 milboa uramum uranium to loading into com.
enrichment plant near Homer in u*ecial roan ire, because it could
'I ~'
3 Claiborne Parish abound stimu. Provide bune ode of jobs for en o
late the rural north Loulolans area hard hit b; unemployment.
1
- 8 economy, but the fate of the pro.
U S. Sen. J. Bun..t Johnstoh.
-;{
ject miU be up to the people who D.La, sho is up for re election hve there.
- !3 this year, has lobbied the plant's Ia "l have heard recently that. Investon to locate in Louisiana.
some of my neighbors in that Johnston says the uratuum plant c
I{-
parish are unhappy" with the would be cleaner and safer than i
, I '=
proposal because of fears of nu.
Oil refineries and petrochemical clear radiation. Roemer said. "I PI"8"-
t, 5 "
mit meet with them or their te.
On another matter. Roeme-resentatives and talk through tfie. maid he will stay out of ths U.S.
I, problem.
Senate race, at least for now.
,,if then la e problem, I won't Johnston's main chauewrs are Re a
stand idly by. N plant abound Jr.pubhean mau Sea. h Begert g
not conee in if then le an envi.
of New Orhana, who em the j.; t sommental basard.
4 aostamios a hs 8mur.
.Ey "Our taformatles now le that eenvention, and state Rep.
Duke, R.Maalrie, a for.
lt does not pose one" Roemer mar Ku Khan Klan hador.
. l.gfl enid. "If the voters of Est abstrict Roemer aald he has not besa feel efferently til take a differ. asked for an endorsement but -
~
eat position., Ultimately, the would consider the request if be Jog.}
neighbors in the neighborbood in is.
i I
........ ~
f re i-e LES Project Panhard Place ~ Buita 200 P. C. Bas 36911
[
Ma13, stop PPOS t
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1
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TELECOPY REQUEST FCEM e
l FAI No. (704) 373-8700 J
Verification No. (704) 373-4854 Joey Jordan, Project Secretary DATE:
/27a /*M l
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E APERT __ JCA A u# A D4TE PUSU5NE01 M *^
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tisens Afslast Noelear"Te@ve the e
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tamelomlefficialsamaskingusto Smith Ita len D.
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in.e a.re to.ign, ore the fact.that l,iv.
ve the right to be 4to%,med-free.awt-,
es.
bl Paul CarNn,
=
,s at ni, - is h eataan
~, cm C B. illy Cr.ew Latty womro'hima (atom atrack.
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In1945)andthefactthetpeopleare cause can Shaus Coleman, PrincIDa Coleman,,
dseases. cer and other terminal
. stID su,ffering the consequences Emma Jean Colemaa eman Carlos Thomas, Buster Col.
. some 45 ym2s later, ignore h We have a right to be frightened tham,,CaMnWortham.
Brenda Wah
.MlleIsland and Chernobyl, as well despite all the ladustry claims.,
Dias,C WHlis,L
- Janet, Dias, Joe
- as othernuclearplant accidents.
Amerlea'sindustrytrackreestdon W
Veronics CMw, Bope j
. Just what is reestion? And why den with hasardous wasta has
- WH11s, miray.laurencec.
- the sleepless nights? The term is been toanythlenst.Wehave Ray,Essie ton, Vivian Ridley,
. broad enough to include sunlight, a ri t tobefrightenedof " new Dawson Ridley, Leroy Hamuton, process fran anindustry $at has Lissie Angstricia Dawson,$heQA it most m
W:5, @ @ C "s*J;
- E,ht wthy.h as M
Rev atoms.Theyare constantly of lanes thatalwayscrashed.
Crew,F M s M M
<redeans-isasuua' tnftheachchanga.enerryIs cha.ng, io be.ome nomeaina ma--nar-and v-n. leman, Jessica Jones, Sharon G. Co w
relans-it'D rm, ercras*h."Woom"youDythatd8818 l*rrine,
,EuJ-anuvav%
- 75 '
8 ed.Anatomofradioactiveuradum as radia h'*p*arti *f8 y
he famlifes who are 11ving in I
88Bsbecomeloeised hoormalities in DNA can occur. Birth defects Center Spring, Forest Grove 'An.
cancerandothertermhldiseases, tioch and Friendship Commun,ities
/[)
(mostlyDistrict8) 5,L/
can also occur from exposure to fmetline W the pr,areliving at the lonMagradiation.
oposed uranium TheenergyWradiatknmovesin.
enrichment faculty and we exneet visibly.Furthermore secrecyand the right topartleipate as equalsin belf truths have bee,n assoelated decisions affecting our lives, wlmthisfacilityfrorn the chDdrenandbomeson themattarof anditsbouldbo g
lewby exposure to hazardous waste. We l
wearetendul angryandsuspicious have the right, as front line of anything,they tell us. This members toactionand umnimo edchmentfacQltyisless whichwD}preserveaur poHey aand lasa onMmDefrom ourhomes.
to have ourneeds and concess be So themajarfaetoriadecisionmakin know.Inviewof allthefacts thatare n and anknown about radia*
We tapoct the above issues to o'g.
e sddreeted.
tion, itis safetosay that the i
uranluta enrichment facilit this Cittsens lastNuclearTreA closetoourbornesisthe i
ofa bullinaChinacloset.
- LisaFord, heDe14Fard, weart a black communi, ao itis to Clifford C Battle Vada L.W Lee Aunthum, William..tllams, put a bud in our closet. is Mary Winiams, Aasie Williams,, Norah i
ekayforblackstoacceptprogressat BanksJr.LHlleBanks,LibP. Fed, L.C. Ford Frankle Ford Addie i
e Williams, haanle Willis, Yulanda W1111a, Easter Hunter, Kennedy Hunter IAndra WIHis Altho Wulis Johns.WR!ia.KathleenCrew,Bartera, _
g g7g*.
Applewhite, Elmira A. Wafer, Joe Henry Youngblood Easie Lee CONTINUED ON NEXT PAGE: YES,,,,
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NUCLEAR
3-g l
JohnstonT.y,
.gggp,.Mraws fie 1
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<,4 e'd 4 oc w r'e e. thi %vu " - not n-1:Moe - e
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" sth er maaoot tae U.%tC
,ii :
ess),
tagi oos by Sea. J. Bemm GovEoy Roemer,n Wadnanday - not tbs state - would have sole o
Johnston would limit public input endorsed the plant, saying he be. authority for' ca.eite laspecuens, into a proposed $760 mituos came satisfied it was a clean indus. with the state probably becoutlag' uranium.cnnehment plant near try" committed to safety" based on involvedin the event of an accident Homer ad reduce licensing r,.
a June 9.1989, meeting with in. or diacharge,said BdlSpell. adam.
quirements, environmentalists say. - wetors and state environmentalof. istrator of the nuclear energy L
The amendment would cut the ficials. The meeting was just hours division of the Louisiana Depart.
i number of public heanags citinaos before the plant was announced in ment of Environmental Quality, could request frum the Nuclear Homer.
't don't think that arrangement Regulatory Commission from two "I made it clear that this plant, will compromlae the public's safe.
,to one, said Howard Arnold, presi, like others in Louisiana, will be re.
ty," le would take issue with that.
Speu said. "I'm sure some dent of Loutstana Energy Services, quired to meet alt requirements as.
peop a consortium of five companies tablished by our state Department The NRC is the logical agency to plannmg to build the plant. But LES of Environmental Qus!!ty," regulate the plant. I don't have the has held several public meetings Roemer said in a prepared state. manpower for effective regn.
around Homer and will continue ment.
lation."
supplying data to inquiring eitinens, "I felt satisfled that they were Johnston's proposal weald mese be said Wednesday, committed to the safety of thelocal that no license is rWared before In pushin ston, D.la..g the legislation John.citizens and our environment. I am construction of the plant 1 com.
is helping companies convinced the ecor.1mic impact of plete. Borson said.
that have given him $27.450 in cam.
this plant will be beneficial to the "It seems like Sen.Johnstonis re.
paign cash over the past 11 years, economy of Northwest Louisiana. I ally trying to push this home state environmentalists said.
have confidence in the technology project at the expense of the local Johnston dentes being influenced that will be used by the plant."
citizens there," he said Wednesday, by campaign contnbu' ons or that The plant has s his legislation woua stifle public troversy in Homer, purred con.
"It seems such a simple thing to get where some the input of the people in the neigh.
comment on the high tech plant, residents - many of who are black borhood who are going to be most which would convert uranium hes.
and live near the proposed site - aflected."
alluonde into fuel pellets Ior nu.
fear the potential environmental In a letter to Johnston in Novem.
clear reactors.
and health impacts of leftover ber, NRC Chairman Kenneth M.
"This only shows the erttemes to radioactive uranium to be stored on Carr supported Johnston's legis.
which the and nuclearlobby willgo site in 14. ton steel cylinders. last lauon.Carr said under existinglaw, in their etfort to generate mass hys.
month, they formed CANT -
uranium. enrichment facilities have teria about the plant," Johnston Citizens Against Nuclear Trash -
the samelicensing requirements as said.
and are actively trytng to block the nuclear reactors,"which are entire.
"Thelicensing proce,ss for this fa.
facility and its " waste dump" ly different from uranium enrich.
cillty will indeed allow local input Meanwhile,others to Claiborne - meet fsedities la ecocek, com.
and it wtll guarantee a safe, clean among them private eltisens, plexity,and degree of risk."
and eimronmentally benign oper, elected officials and economic de.
Under Johnston's amendment, ation." he said. "My amendment velopment leaders - say the plant uranium. enrichment plaats would will simply bring the benefits (jobs) poses marginal risks and would have the same raquirements now to Claiborne Pansh sooner."
create some200 permanentjobsfor madeof"otherchemicalprocessing Meanwhile, in a letter to Rep.
a parish economy suffering nearly facilities, which also use uraniam Ronald Dellums, D. Calif., the - 10 t unemployment.
besafluoride," Carr said.
watchdog group Public Citisen sides have trotted out es.
Rep. Jim McCrery, R.I.s., said urged Dellums and other Coo.
perts, some raising concerns about Wednem'ay be has requested infor.
gressional Black Caucus members radioactivity anc others scytag mation from the Department of to oppose Johnston's amendment radioactivelevels around the plant Energy re the potential awaiting final OK in the Haiase, wouldn't increase signifleantly.
safety hazards of proposed plant The amendment will 6ase liceae.
Johnston's amendment, attached and will await a response before ing and other NRC requirements on to an unrelated et11,*would ~re.
taking a posi. tion se Johnston's the plant proposed on a rural 433 classify thefacilityasa chemk.al-proposal acre tract five miles northeast of not nuclear - plant, speeding the Johnston.wbo chairs the key 8es.
Horner, said Dan Boreon, Public federal licensing process. Johnston, ate Energy and Natural Resources Cittson's nuclear policy analyst.
the NRC and state envireamental Commalttee, has wom" Senate' ap.
l "Unfortunately, there are many officials say the redesignation is apt prevalofhisamendmentbutawaits h attempts to takeadvantage of'have as the plantusesa chemicalprocess final House actica, y'
DrKE ENGINEER 1sc Ng o,3 l
03 06.90-ot:01 0704 373 6700 a,r. c j
m vu i
_I Packard Place - Suite 200 P.O. Box 36911 Mail Stop PP025
[
charlotte, N.C.
28236
.l TalaamN Raquest Form
{
FAX #
(704) 373-8700 Verification No. (704) 373-4854 Joey Jordan, Project secretary 1
Dates zd t.).sso
-/
[36/,
- f2-d 4 Fr Telephone Number Sub$ect ket kip 6 V, /fV6 / [r$ & h1 a
Fax #: [J6/
M92-_$25'9 Verification #
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Telephone Number:
This transmittal contains
/8 pages excluding cover sheet.
4 o
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,,,YY
03/04epo 07:02 0704 373 6700 DrKE ENGINEER!SG 3 00 4
Aganda 1/1 IDtc/LES Meeting Earch 9, 1990, 9830 AE LES participants: Peter LeRoy Bill Griffim Bill Mowry Safety and Ok classes safety classes Discussion of description and justification for the safety l
classes LES will be using.
QA classas Discussion of description of the Quality Assurance Plan that will be applied to the three different safety classes.
The Quality Assurance Plan will be graded to ensure the level of Quality Assurance applied to the systems, e,tructures and components (88c) at the LES facility is commensurate with the public or worker safety function of the 88C.
l Attachments The first two pages of attar hmartts show-the quantities of UF6 that produce certain exposure levels, cartain distances f. rom the l
separations building.
The calculational method used was identical to the method used in NUREG 1140, A Regulatory Analysis l
on Emergency Preparedness for Fuel cycle and other Radioactive Materials Licenseas, January, 1988.
This would result in all e
l three types of autoclaves - feed, sampling and blanding being classified as Systan class I components.
The next four pages of attachments is a listing of the quality assurance requirements from Appendix B that will be applied to class I and class II structures, systems and components.
The last eleven pages (note there is no page 11) of attachments is a discussion and justification for the concentration levels that LES. proposas be allowed for an individual to be exposed to uranium and hydrogen fluoride while at the site boundary and as a facility worker, s
- -.. - -, - -... -,, ~. - -
~
os os.eo of:o 0704 ses 6700 otn tsontraisc acos enananeta arranemns or try g g
This tabis shows the amount of UF-s rectired in order for an ites to be grouped in Clase 1.
This shows results based en three sita boundary 41stanose and three alternative exposure limits.
l I
~
Quantity of UF site soundary site soundary required to eNosed,the Distanee Exposure Limit corresponding exposure
]
limit 400 moters-40 mg of U 8300 kg 25 mg/s" NF 3800 hy l
350 meters (1) 40 my of U 8360 kg Is ag/m-IF 3700 kg 400 meters (3) 40 se of U 4600.kg r
as as/a nF a000 by i
as l
l Alternative Exposure Limits Discussed by NRC i
350 matars 10 my of U 3100 D.y 3400 kg (3) l 18 as/s" IF l
1 3s0 matars 10 mg o 5
2100 kg (3) 33 RF(4)l 4900 kt 600 meters 10 ny U
1100 (3) le xF 1300 (1)
This is the case we are surrently using.
This includes a site boundary distance of 350 meters. 8 It also includes exposure 11alte of 40 mg U and as ag/a art theen were taken 3
frun the ANFR levels of 40 mg U and to ag/m EF.
Any component in the plant, heated to 54'C,at or above atseepherie pressure,and containias 3700 kg of UFg, is designated as Class I.
TABLE.Ano
O po,sito 07:03 0704 373 6700 DUKE ENGINEERING 4004 l
I i
I The naziman I/0 value soons at about 600 meters for the (2) assumed worst meteorel Leal sentition (class F).
This corroepends to the-1 level of release to eneseed the Dessume the ling and blending publis espesure limit.auteolaves sentain 2500 kg of UF,, these would r
as class 1.
it we switch te either of the alternative (3)
Note that,iscussed by NBC, the thrasheid level of eriteria d contre 11ed by the uranium critation rather than the criteria.
Because the sampling and blend auteeleves eentain 2500 kt of UF4 these would be fled as Class I under either alternati,ve dieousted by HR0 at the January
- meetiat, 2
(4)
Based on 800 NF at 15 minutes duration of exposure.
e 9
3
(
s TABLE.AAC
. ~
. _ - ~ _.
f 93)osipo 07:03 0704 373 4700 DUKE ENGINEERING toos.
.i j
?
SIDO(ARY OF APPLICABILITY OF TASK FORC2 DoctrKENTED QUALITY ASSURANCE PROGRAM PROVISIONS ACCORDING TO QAL DESIGNATION t
PPM Section/
Criteria Control Measure M QAL-2 f
^
1.
Organization organize, interfaces define functions X
X Describe X
X Independent QA X
X Stop work recommendation X
X 2.
QA Program Indoctrination X
x Training X
X Documented QA program X
X-Cartification of 1.nspectors X
NR Certification of test personnel X
NR Certification of NDE personnel X
NR certification of auditors X
X Management assessment X
X 3.
Design Control Design inputs identified, documented, and selection reviewed and approved X
X Design activities prescribed l
and documented X
X Design analysis - planned, controlled, documented X
X (List of specific items to be documented)
X NR Calculations identified by subject, originator, reviewer, date X
X Computer programs to be i
verified and valid X
X Changes controlled in manner of initial design / program X
X l
Interfaces controlled X
X Independent design verification X
NR*
Documented procedvres X
X j
Supporting records X
X l
- Design outputs typically will be 1.ndependently verified, regardless of QAL designation.,
WJL2-20/mc
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PPM Section/
cri+=ria control Mammure OM-i OAL-2 4.
Procurement Evaluated / approved suppliers X
NR Document Review Define technical /QA requirements X
X specify submittals X-
-X Right of access X
X 1
FDI disposition approval for nonconformances to be delivered X
X Assurar.ca review for procurement i
documents and changes X
X i
5.
Instructions and Documented X
X Procedures Performance as prescribed X
X Appropriate quantitative /
qualitative criteria specified X
X 6.
Document control Specify which documents X
X Assure correct dominents/
changes are used X
X l
Documente reviewed, approved as specified X
X control distribution X
X-
.i 7.
Control of Approved sources X
NR Supplier-objective evidence evaluation X
X X
NR Furnished Items Supplier audits X
X source, inspection, as appropriate 8.
Idantification Identify to assure that only i
and Control of correct and accepted items Items are used x
X t
l 9.
Control of Qualified personnel X
X l
Processes cartified NDE personnel X
NR 10.
Inspection Planned, documanted, specified inspection requirements X
X Results documented X
X l
Qualified inspectors X
X certified inspectcre X
NR l-Independent i.nspectors X
X Inspection records, with minimum info specified X
X Document and report nonconformances X
X WJL2-20/mc
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4 i
'i PPM Section/
criteria control M==sure OAL-1 cir-2 i
11.
Test control Planned tests, specifying I
characteristics to be tested and methods X
X l
Qualified personnel X
X certified personnel X
NR Results documented and evaluated X
X verification testing for computer programs (specific requirements)
X NR i
12.
Control of Calibration /recalibration I
Measuring and control system
- X X
Test Equipment Standards traceable to nationally i
recognized standards (NBS)
X X
M&TE marked to show status X
X Records maintained X
X careful handling / storage X
X r
l 13.
- Handling, Documented instructions, Storage,and requirements X
X shipping _
special procedures, when needed X
X l
Qualified personnel X
X u
1 14.
Inspection, Status indicated on item or Test, and on documents traceable i
operating to item X
X Status Authority for application and removal to be specified X
X 15.
Control of Identify, document, evaluate,
' Nonconformir g sags.egate, dispose of, Items notify those concerned X
X Control further processing, installation, delivery pending resolution X
X Competent evaluators for disposition X
X Technical justification for use-as-is/ repair X
X Reinspection after rework /
repair X
X Records, including as-built X
X l
WJL2-20/mc l
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PPM Section/
Criteria
, Control Measure OAL-1 g 16.
Corrective Promptly identify and correct.
X X
Action If signficant concern, fisc cause to preclude recurrence X
X Document corrective action-X X
Follow-up to verify effective implementation-X X
17.
QA Records Specify, prepare, maintain X
X Must be valid, legible, authenticated, identifiable, retrievable X
X Written procedures for control of X
X t
Indexed X
X Protected Storage X
X 2-hour fire rated protection for one-of-a-kind records X
NR 18.
Audits Planned and scheduled X
X l
Written checklists X
X certified lead auditor required X
X objective evidence examined X
X Results documented and reported X
X Follow-up to verify corrective actio.. effectively implemented X
X i
e WJL2-20/mc
~
g oo, Dnat EscIxtralso opos'reo of:os 0 704 sts 4700 Las assoavas LarxL JusTIstanT308 1.0 DfTI M E! M I M The Las Projast proposes to classify items of Importanos to publie Safety by using the following limiting levels of exposuret 8 M the (1) kidney Sbe of 40 mg uranium and (8) 36 mg EF/2 We believe that utilising 9 ag 4esa
- 4 % 1.
mg boey or lungs.
We likewise alirrt. thn ?,t MF/n is unnecessarily conservative.
3 would be unnecessarily conearvative to use other vCuea 8 fee substantially below the 40 mg uranium and 26 mg HF/a enrichment plant type sooidents which are typically shorter than 15-30 minutes.
The LES Project proposes to classify Important to Worker Safety (1) 100 mg by using the following limiting levels of exposures uranium k.idney uptaka and (3) unprotooted XF exposures to 100 mg Ep/3 for over 1 minute.
3 2.0 DEFINITIONR On behalf of the LES Uranium Centrifuge Enrichment Project, Fluor Daniel, Irvine (FDI) and Duke Engineering Services, Inc. (DESZ) has developed definitions by which the plant's systems, structures and components are classified ascerting to their importanos as te protection of the publie haaith and safety og Two of these definitions are given respectively worker safety.
in paragraph 3.1 and 2.2.
I 1
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MaNeft 7, 1990 3.1 DEPORTANT TO PUBLIG #AFETY strussures, systems, and eenponents reportant to safety are those neoessary to assures 1.
The capQility to prevent er nitigate credible (10 )
4 aooidents whose consequences could result in potential offsite exposures in eroess of to ag/38 RF to the body 33 lungs or 40 ag uranium kidney uptake.
3.
The onpability to safely shut down the plant and maintain it in a safe shutdown condition.
33 ZMPORTANT TO WORNER SAFETY structures, systems, and eenyonants which are essential for 4
prevention (<10 ) of worker permanent injury or loss of life from the radielegical or ehemiaal hasards of UF, hug are not Important to Public Safety.
Such permanent injury to the workar will occur it uranium uptake to the kidney exceeds 100 mg or unpretected exposure to 2F canoentrations greater th&R 100 mg/m3 fer periods of over one minute.
3.0 The basis ter the uranium and RF valuas in the definitions are primarily based upon the ANPR for licensing of enrichment plante (ref.1), well developed dompetic and international health physics principais, papers given in the May 1988 confersnoe on tft ames wandiina. Pr==maina. and transoortation and miscellaneous other data taken from available texts and reports on chemical I
WRM3=8/ad 2
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% 011 Ma d 7, 1990 Touieology.
A significant underlying premise for public Realth a%d Safety is that no irreversible effects are encountered.
Observable transient. effects are and should be eseepted for low probabiitty postulated accidents which any never ooour.
3.1 URANZUN EXPOSURE The Anya supplasantary Information provided a rang et valuas which the osamtssion's staff found to be below the threshold of any long ters er permanent biological damage to individuals.
The stated range for uranium axposure is an intake of 9 to 40 ny throughout the socident scenario.
It is the view of the LT,8 pre $eet that 40 mg uranius to the kidney is an appropriate level for limiting public exposure, while 9 ag is unnecessarily conservative.
The Las Project is and will be limited to natural uranium feed materials. (ie, no reprocessed UFg) and uranium-235 ' enrichment levels less than 10%.
The radiological aspects of the exposures are very small compared to the heavy metal and ehemical temioity.
Furthermore, the largest sources of uranium in the facility are those cylinders of natural er depleted (tails) UF6 which have even lower radielegical/chanical hasard raties than anriched uranium.
Aeoordingly, the values chosen for the LES project are
~
based upon chemical toxicity and need not be reduced significantly to account for a radiological owpesure component.
This can be verified by the comparison of chanical toxicity and WRK3=6/ad 3
03?ddf90',67: 06 0704 373 6700 DUKE-ENGINEERING'
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'*b March 7,.1990
.radie tosioity developed for a 97.5% U-235 anriched' case (ref.'t).
It should he remembered that U-834 has a spesifie activity 3900
' times traass and isooo times U-ass and further natural uranium has only 0.7% U-235 end.006% U-234.
For convenience, the comparison table from Ref 1 is included here.
comparisen of chemical Texietty and Radiotoximity-of-soluble Uranium
- Adsorbed-Dose.ES11VR14ht of Soluble Radiation Uranium Dose Acute Health Effects (ag-U/)tg)
( 4C1) chemical Toxicity RadictoMicity 7
o.03 0 16 No effect No effect 0.058 0.30 Renal injury De e2 fact 1.63 6 45 50% lethality No effect is.29 100.
Lathat onset of Radiological Effects
- At 97.5% U235 and 1.13% U234 enrichment. (4) vasta-e/ad 4
homseso ~
4 07:07 07ar m stoo4 otn Escistraiso g o13 a
n Natch 7, 1990
. Another reference (ref 3) reports that two Australian uranium mine workers received a short tura exposure of uranium dust.
An
=
- evaluation of thess' exposures revealed that one workar received
-'an intake of 40 25 uranium.
This resulted in a casaitted radiotoxio dose equivalent in a range of 67 to 137 millisieverts (may.67 to 1.37 rem respectively) based on ICRP 30 dose modeling
_ procedures.
This exposure relates to a 1.4 X 10'8 probability of a 1'atal malignancy.
No chanical toxio or radiatoxio physiological effects were actually observed.
This ia evidence that a 40 mg uranius exposure is below a permanent damage threshold.
r In another reference (ref 4) the uxpesuras of thirteen National-Lead Workers were evaluated.
Their exposures wara from UFer Us s 0
and other-uranium concentratee including diuranates.
Eight of the exposures were to UF.
In one case a workar attempted to 6
in a t nnsfer line..In another L
halt a small-leak of heated UF6 case eeven workers were exposed while attempting to step a laak from a heated 10 tr tJFg cylinder from which the valve had been
-ine.vertently removed.
Despite several instances of urinary h
uranium sencontrations in tha :cange of 0.7 ag/l to 1.8 ag/1, E
corresponding to inhalations of 10-20 mg uranium, no evidence of kidney damage was observed.
In only one case was elevated (1.5mg%) protein found.
While such elevated protein is an indloater of renal damage this valv.s is too low to be a positive n
indicator.
7 WPJt3-6/md 5
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March 7,1990 3.3 HF EXPOSURE The ANFR background'information aise provided 13 to 28 ag/M as a range of HP concentrations which aro below the threshold og significent irritation or more serious injury.
Relying again on the above premise for public health and Safety, what values eheuld be chosan?
-For EF, NIo8K/ OSHA has established 30 mg/m min-for short periods 3
(up to 30 minutes) as Immediately Dangerous to Life or Realth 3
(IDLE), while 2.4 mg/m is an acceptable upper limit for reogrring daily 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Time Weighted Average exposures.
The NIC8H/ OSHA definition for Inmediately Dangerous to Life or Realth i
is nF=v4-m level from which one can escape within 30 minutes without escape impairing symptoms or irreversible health attects."
It is NIOSE/08Eh position that higher concentrations are permissible for short term accidents typicai of a hex conversion centrifuge enrichment plant.
It we consider that enrichment ' plant aooidents are likely to be less than 30 minutas in length, we can compare the 36mg/m value with 30 mg/d value.
3 We can argue tht the 26ms/s? valua is more conuarvative.
American Industrial gygiene Association has developed Emergency Response planning ouidelines for use by emergency response agencies such as EPh, FEMA, Do?
- to.
Tneir established guidelinen are below the IDLR values u*t by 08MA/NICSR.
They are ERPG-1, ERPG=2, and IRPG=3 as defined salow:
e,,,
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' 0704.47s,s?oo-
. DUKE ENGINEERING:
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3 X
March-7,.1990 ERPG-1 M e maximus airborne concentration below which, fit.
J is believed, nearly all individuals exposed for-up d
to 1. hour without experiencing er developing'-
effects more serious than mild irritation, other 1
X-mild transient health affects or perseption of a clearly objectionable odor.
ij.
ERPG-3 The maximum airborne concentration below which, it.
L is believad, nearly all individuale exposed-for.up 4
to 1 hose without experiencing or developing effects more serious than mild irritation, other alid transient health effects or symptoms which t
.oculd impair an individuale ability to take
]
protective action, a
j Emps-3 Maximum airborne concentration below which, it is i
believed nearly all individuals could be exposed.
fet up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> without experianaint or, developing life-threatening health effects.
i The EP (hydrefluorie acid, vapor or cloud) values for the thsee BRPG's are respectively 5 ppa, 20 ppa and 50 ppa.
In dry air, EF o
in ppm is equal to 0.9mg/E.
4.o suppLamamTART INNRMATIoM CN WORRER SAFETY G
Prom the above information regarding the public safety, we can new dtaw parallel conclusions about acceptable values to which a W5083-6/md 7
-m-
--_____m_
_______________m-
_______.__._m
3 3 -- -
si dssttatso
~~
aon y
e..-
Mareb 7, 1990 worker may be exposed.
such a worker, la the oeue of hisLwork,.
will receive medical examinations, includint uranium bioassays, conventionally, workers are allowed larger exposures.
Aeoordingly from the literature we have selected limiting values which we believe should not be exoteded during unlikely:
accidents.
Per incidents which-could exooed these threshold'
/ values, we are giving special consideration la project activities.
These special considerations analogous to Importance-to Publio Safety, will require special design, construction,
-installation, end operational procedures to assure that a verker-will not be exposed to levele above those established'as.
Important to Worker safety.
~ The NZOSE/ OSHA HF (aerosol / vapor) value for IDIE is 100mg/d/ minute with such exposures lialted to a few minutes, or not more than 30 mg(RF)/M for exposures the order. 30 minutes.
The NICSE value is the principal basis of-the value selected by I28.
osakta permissib1'a exposure level for daily time weighted averages ('ivA) over a hov.rs is 3 ppa EF.
This is censistent with--
levels set by the American congress of Governmental Industrial Hygienist (ACGIE).
NIOSH has also set a value of 6 ppm HF for 18 minute exposures rapested 4-6 times daily.
A00ZR has set 28 8
mg/m as -a limit for infrequent short tera exposures.
WRM3-6/ad 8
03:06?90 i07: 090 3704 373.5700:
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March 7,-1990
~;
other values directed toward individual exposure limits can be found:in Patty's Industrial Bygiene and Toxicology (Ref 5).
This
- i refarenea work reports thatt (1) the' lowest lethal j
a
'eencontrations for a 5 minute exposure to HF gas is in the range l
of so-aso pga, and (a) the lethal concentration (%) for 5, is and 60 minute exposures-are considered to be~450 to 1000 ppa, 500 to 800 pga;and 30-600 ppa respectively.
In human studies, i
. exposures of 120 ppa for i minute caused conjunctival and respiratory irritation with stinging of the skin..
No long ters l
l or permanent; effects were observed.
These and other dat'a available in the 1.iterature are justification for L3s's use of 100 mg (RF)/a for up to 1 minute l
8 where workers can evacuate the area or avail themselves of.
a breathing apparatus available in their proximity.
5.O CONCLUS;rpN Relying upon expected analysia of worst ease accidents from UP6 cylinders and the slow transport of the released vapors in F1 atmospherie conditions, it is clear that the concentrated partions of a pluas will pass an individual within a half hour.
l Thus.the 26 mg/M EF concentration provided in the ANPR provide ample saiety margin below the established AIBA ERPG=3 guidancei this in turn, assures a 1-hour exposure without life-threstaning health effects.
Intuitively, it should be evieent that naither very short tera nor long term releases will create dangerous concentrations for a protracted periods of time.
WRM3-6/ad 9
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07:09-12704 373 6700 Dt'KE ENGINEERING:
~ gon March 7, 1990 Table-3-providea sama semparisons of uranium and IEF values estab11 abed by government / quasi government egencies or other reputable sources.
.Considering the above we believe that substantial margias of safety have been built into our selected values which are meant to cover finita anankity type accidents with durations ranging; from a few minutes te 15-30 minutes.
4 l
l W10t3=6/ad 10
us.u evu' ' !vi du '
u.v4-a4a=$,uv v ac c.m.s cu..s., =
e s-March 7, 1990 urERENCES 1.
ANMR 10CFR76, Federal Register, April-33, 1988, 2.
Acute Tegicity of Uranium rem 6 fluoride, Uranyl Fluoride and Rydrogen Fluoridal Robert A Just, ORNL, 1988.
'3.:
Assassing Dese Equivalent from an Intansive short Tara Uranium Product l
Inhalation; Jiri Kavanicki, Health Physics, pps. 673-678, 1987.
4.
A Review of Uranium Excretion and Clinical Urinalysis. Data in Accidental Exposurd casas Michael W. Boback, National Lead (NCUJ-1119).
5.
Patty's Industrial Hygiene and Toxicology.
Wiley Press N.Y., N.Y.,
3rd Edition 1945.
WMts-6/a4 12
h.h.
NOV8719c9 9
ProjectNo,M.45
)istribution_:
OKasun SGDB r/f Dr. W. H. Arnold, President RBurnett LTelford, INFOSEC Louisiana Energy Services PLoysen,INSB RCunningham, INNS 2600 Virginia Avenue N.W., Suite 610 RBrady DSEC Washington, D.C.
20037 RFonner, 06C
Dear Dr. Arnold:
This is to advise you that during the course of our development of amendments to 10 CFR Part 74, related to material control and accounting regulation for uranium enrichment, we intend to contract with Martin Marietta Energy Systems, Inc., through the Department of Energy's (DOE) Oak Ridge Operations Office, for technical assistance. This action is being taken now to assure completion of the requirements development process consistent with your proposed license application schedule.
While this is a generic rulemaking effort, it may be necessary to discuss site or process specific information with the contractor, who also will be assisting us in preparing guidance documents. At the suggestion of NRC's Division of Security to assure that Louisiana Energy Services proprietary information is not disclosed to unauthorized parties, the-proposed, unclas.
sified contract requires that the organization perfonning the work (Martin
.Marietta's International Programs Divisi a, which is not part of the enrich.
ment operation) not disclose any NRC. identified proprietary infonnation, to DOE employees, contractors, or to other personnel.
If you have any questions on this matter, please call Mr. Robert L. Fonner, Special Counsel for Fuel Cycle and Safeguards Regulations, at_(301) 492 1643.
Sincerely, Donald J. Kasun Acting Chief Domestic Safeguards and Regional Oversight Brench Division:of Safeguards and Trensportation, NMSS Mr. Peter G. LeRoy u
Duke Engineering 8 Servicts Inc.
Mail Stop PP02A P.O. Box 36911 Charlotte, North Carolina 28236 Mr. D.J.W. Lumley IP;' N Fl First Secretary (Energy)
British Embassy
' p, S
3100 Massachusetts Avenue H.W.
R ett o g ps/ 7 w 7 7 jf.
Washington, D.C. -20008 11 89
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- IMNS
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