ML20059F753
| ML20059F753 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 01/10/1994 |
| From: | Pierson R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Burnett R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9401140139 | |
| Download: ML20059F753 (6) | |
Text
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UC['j NUCLEAR REGULATORY COMMISSION C
WASHINGTON. D.C. 20555 0001 f-
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.n. i o,ggz MEMORANDUM FOR:
Robert F. Burnett, Director Division of Fuel Cycle Safety and Safeguards, NMSS FROM:
Robert C. Pierson, Chief Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS
SUBJECT:
SIEMENS POWER CORPORATION WASTE MANAGEMENT UPDATE Siemens Power Corporation's (SPC) Richland manufacturing facility has several waste management systems and units, including the following:
1.
Six wastewater treatment lagoons, which store ammonia-and uranium-bearing liquid wastes, and other plant chemical wastes, prior to ammonia and uranium recovery and discharge to the Richland municipal wastewater treatment plant; 2.
Several outdoor container storage areas, which store dry and wet solid wastes in more than 11,000 polyethylene and steel containers of'several sizes and configurations; they are described in more detail in the enclosure to this memo; 3,
An incinerator, called the Solid Waste Uranium Recovery (SWUR) system, used for incineration of combustible solid wastes; the ash is stored in steel drums in the container storage areas.
Last summer, SPC created a new Waste Management Group to develop and implement a comprehensive plan for management of plant wastes.
This Plan has not been submitted to the Nuclear Regulatory Commission yet; however, at the December license renewal review team site visit, SPC committed to providing it.
It contains information that SPC believes is proprietary, and will be submitted with a 10 CFR 2.790 affidavit.
From what SPC has stated about the Plan, it' is heavily dependent on incineration of combustible wastes and recovery of uranium from the ash and relies also on Siemens' changing from chemical conversion to the dry conversion process. The' incinerator is presently shut down, while the ash accumulation problem is being addressed; the ash uranium recovery process is still under development; and the dry conversion change is several years in the future.
The incinerator's previous operational capacity was 90 kgs/hr of combustible waste, however, this capacity could change if the incinerator requires significant reconfiguration or operational changes.
There was a Region V Management Meeting at the Richland plant on December 9, 1993, at which the issue of the large number of waste containers was discussed, as well as the presence of 1,100 drums of waste from Siemens' Lingen, Germany, fabrication plant.
This management meeting is summarized in NRC meeting report no. 70-1257/93-13. After that meeting, Mr. Hugh Thompson 9401140139 940110 T
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Robert F. Burnett 2
expressed concern about the Lingen wastes, and in a meeting with Mr. Thompson on December 20, 1993, Fuel Cycle Licensing Branch (FCLB) explained the source of the drums. They are described in enclosure 1.
Mr. Thompson suggested encouraging SPC to move more aggressively toward processing the containers via the decommissioning plan and financial assurance mechanisms.
The current decommissioning plan and cost estimate do not include disposal of the waste container inventory. There are also two other issues associated with this alternative: one is that if NRC allows SPC to include the container inventory in the decommissioning plan, NRC, in effect, gives SPC permission to store the containers indefinitely, until they decommission the plant.
Other licensees also have waste containers stored on site, and FCLB needs to review these facilities to ensure consistency.
Because of these concerns, we met with Robert Fonner, 0GC, to ask under what basis could we require Siemens to submit their Waste Management Plan, and could we require them to take more assertive action to dispose of the waste containers.
Mr. Fonner stated we could issue a " Demand for Information,"
which we will do if SPC does not submit the Plan. He also stated we really do not have a basis for forcing SPC to dispose of the wastes as long as they are within their license, unless there is an environmental or safety hazard, which there does not seem to be right now.
(The containers are stored outdoors but seem to be in reasonably good condition, with no obvious leaking or corroding containers.) We plan to confirm this at a future inspection.
1 The waste containers and lagoons at SPC are also waste management units regulated by the Washington State Dangerous Waste Regulations. Washington is an authorized State under the provisions of the Resource Conservation and i
Recovery Act (RCRA) and the Hazardous and Solid Waste Amendments (HSWA), and SPC is operating these two units under Washington's interim status rules, However, SPC has not completely characterized the containerized wastes to determine which of them are designated Dangerous Wastes as defined in the State's rules.
SPC has identified some wastes as dangerous, and stores these 20-30 containers in a covered storage area.
The Washington Department of Ecology (WDOE) plans to require a Dangerous Waste permit application from Siemens within the next year and anticipates the permitting effort to take about 3 years.
WDOE has inspected the lagoons and container storage areas and I
has issued a notice of violation to require Siemens to characterize the lagoon contents and containerized wastes for dangerous waste designation.
Since our meeting with Mr. Thompson, FCLB has contacted two other licensees to better understand the magnitude of the problem at SPC when compared to other fuel cycle facilities. The two facilities contacted, General Electric (GE),
Wilmington, and Babcock & Wilcox (B&W), NNFD, were not operating over the l
holiday season. We received the waste inventory information from GE on January 6, 1994, but we are still awaiting the information from B&W NNFD.
j The GE waste is summarized in enclosure 2.
The waste inventory has been
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reduced significantly from the inventories of the mid-eighties.
This is from i
incineration of the dry combustible boxes.
The incinerator ash is i
1
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4 Robert F. Burnett 3
accumulating because GE plans to recover the uranium from this ash through use of an outside company.
Barnwell is not authorized to accept incinerator ash.
Comparing this summary and B&W's waste summary to Siemens' Waste Management Plan should help us understand the magnitude of the SPC waste in context with the waste inventories of other licensees.
When we have evaluated the Siemens' Waste Management Plan and we have received the waste summary from B&W NNFD, we will decide what course of action is best suited to get Siemens to reduce its waste inventory consistent with other i
licensees' waste accumulations and the economic and licensing issues which we must consider.
ORIGINALSIGNED BY Robert C. Piemon Robert C. Pierson, Chief Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS
Enclosures:
1.
Notes on Siemens' Drum Stceage dtd 12/20/93 2.
Summary of GE Waste dtd 01/06/94 Distribution:
NRC File Center PDR/LPDR NMSS r/f Docket No. 70 '257 FCSS r/f Region V FCLB r/f E Tentqtvs.
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y December 20, 1993 NOTES'ON SIEMENS DRUM STORAGE Siemens Power Corporation's Richland Manufacturing facility has approximately 11,000 containers stored on site. These containers fall into the following general categories:
1.
Dry combustible wastes, generated at the Richland Plant, in 55-gallon steel drums that are being stored prior to uranium recovery in the incinerator (Solid Waste Uranium Recovery - SWUR).
j 2.
Dry non-combustible wastes, generated at the Richland Plant, in SS-gallon steel drums, including discarded equipment and parts, contaminated tools, and other non-combustible waste that was sorted from the combustible waste that has been incinerated. ' Some of these are awaiting uranium recovery, others are awaiting compaction prior to disposal.
3.
Incinerator ash, from the SWUR, in 55-gallon steel drums that is being stored for uranium recovery.
4.
HEPA filters, from the Richland Plant, in steel boxes.
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5.
Combustible and non-combustible wastes, generated at the Richland Plant, in 55-gallon steel drums and polyethylene drums (wet wastes) that have not been segregated yet.
6.
Combustible and non-combustible wastes, dry and wet, generated at the Richland Plant, that may designate as Washington Dangerous Wastes.
These are awaiting characterization.
Siemens has established a new Waste Management Engineering Group and has developed a draft Waste Management Plan, which addresses these waste containers.
The Plan, which has not been provided to NRC yet,. includes the following components:
1.
better waste segregation at points of generation in the Plant; 2.
separation of current waste inventory into combustible and non-combustible fractions, with analysis for Dangerous Waste designation; 3.
incineration of combustible, non-dangerous, fraction; 4.
recovery of uranium from ash via solvent extraction; 5.
recovery of uranium from non-combustible fraction, where feasible;
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treatment of non-Dangerous, non-combustibles ~via compaction, or disposal; 7.
continued uranium and ammonia recovery from lagoon contents.
Siemens does not have a specific plan for management of mixed radioactive and dangerous wastes, if any are found in the current inventory.
RECEIPT AND STORAGE OF DRUMS FROM LINGEN, GERMANY.
When the Richland Plant accepts a fuel fabrication job from a customer in a foreign country, they require that the customer agree to accept all wastes generated during the job along with the products. Siemens uses the same process for its Lingen Plant.
Richland sends fuel pellets to Lingen for loading into rods, then Lingen sends the waste back to the Richland Plant. The waste drums contain dry combustible waste.
The Richland Plant has been doing this for years. They receive back a couple of shipments per year, with 30-40 drums per shipment.
The drums j
contain from less than 1 to as much as 10 grams of U-235 per drum.
Some of i
the Lingen drums have been incinerated, and the ash is being stored for-i eventual uranium recovery, 1
Since they started receiving back the drums, they have received 2329.
They have incinerated 1178, and have 1151 left and 32 ash drums.
The average uranium content is 59 g, the average U-235 is 2 g.
They import them under the general import license provision of 10 CFR 110.27. Chuck Hooker's E-mail of j
December 13, 1993, says there are 1,151 German drums containing a total of 68 i
kg of U, plus 140 drums of HEPA filters from Germany containing 3.8 kg-of U.
Jim Reese said Siemens had a small pilot project to recover the uranium from the incinerator (SWUR) ash, but it has never been turned into a full-scale recovery system.
The dry conversion expansion plans include a tentative plan to put an ash recovery system in the space where the chemical conversion lines are now.
Jim also said the legal issue of Siemens' receiving back the waste from Lingen had been investigated by NRC a few years ago, and NRC decided it was legal.
(I'll start looking for documentation)
JAN 06 N4 15:01 No.UU4 P.01
.. DRY COMBUSTIBLE BOXES (49 FT /30X) 165,865 FT8 INVENTORY ON 1/1/86 3,385 BOXES
=
INVENTORY ON 1/1/94 705 BOXES
=
34,545 FT8 BOXES BURNED IN 1993 627 BOXES a
30,725 FT3 CONSISTENT WITH AGING, MEASUREMENT REQUIREMENTS, AND MAINTAINING A SUFFICIENT QUEUE OF BOXES NEEDED FOR EFFICIENT INCINERATOR OPERATIONS, WE ARE MANAGING THE CURRENT INVENTORY ON AN ANNUAL BASIS BURI AL BOXES (BARNWELL)
INVENTORY ON 1/1/93 78 BOXES
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4,000 FT3 2,310 FTa INVENTORY ON 1/1/94 45 BOXES
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BOXES BURIED IN 1993 206 BOXES
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10,535 FT3 CONSISTENT WITH AGING, MEASUREMENT REQUIREMENTS, AND MAINTAINING A SUFFICIENT QUEUE OF BOXES NEEDED FOR EFFICIENT TRANSPORTATION TO BARNWELL, WE ARE MANAGING THE CURRENT INVENTORY ON A MONTHLY BASIS INCINERATOR ASH (RECOVERY) 2,610 FT3 INVENTORY ON 1/4/94 4,343 CANS
=
CURRENTLY NEGOTIATING REPROCESSING OPERATIONS WITH AN OUTSIDE COMPANY TO RECOVER URANIUM INVENTORY IN PROCESS OUTDOOR SCRAP (RECOVERY)
INVENTORY ON 1/4/94 13,987 CANS 7,480 FTs
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CURRENTLY DEVELOPING IMPROVED PROCESSES TO MORE EFFECTIVELY RECOVER URAN 1UM INVENTORY AND REDUCE GENERATION RATES Post it* brand f ax transmittal memo 7671
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