ML20126A019
| ML20126A019 | |
| Person / Time | |
|---|---|
| Site: | Claiborne |
| Issue date: | 12/14/1992 |
| From: | Leroy P LOUISIANA ENERGY SERVICES |
| To: | Jim Hickey NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9212170191 | |
| Download: ML20126A019 (10) | |
Text
Pop Olhce Box 1004 Chodone, NC 28201 1004 December 14, 1992 Mr. John W. H. Hickey, Chief Fuel cycle Safety Branch Division of Industrial and Medical Nuclear Safety office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Subject:
Docket No.: 70-3070 I
Louisiana Energy Services claiborne Enrichment Center Disposition of Depleted Uranium Hexafluoride File: MTS-6046-00-2001.01
Dear Mr. Hickey:
This letter is in response to your letter to Louisiana Energy Services (LES) dated September 22, 1992 regarding the disposition of depleted. uranium hexafluoride (DUF ) produced atLthe Claiborne 6
Enrichment Center (CEC).
As an applicant for a license to~ possess byproduct, source, and special nuclear material, LES is required by.
10 CFR Parts 40.36, 70.22(a)(9),
and 70.25 to-submit a
decommissioning funding plan containing a
cost estimate for decommissioning and a description of the method of assuring' funds for decommissioning. However,- the costs LES will incur for removal-and disposition of DUF6 are more properly characterized as operational and maintenance (O&M) in-nature and thus should be treated in a manner different from the costs of decommissioning the-CEC at the end of its useful life.
4 The decommissioning funding plan as well as the' cost estimate-for.
i
~DUF disposition are detailed in the LES License Application, 6
Exhibit I, the LES Safety. Analysis Report (SAR), section 11.8, and the LES Environmental Report (ER)=section 4.'4.
Tho' cost estimate-for removing DUF was-provided in' the same sections as the 6
decommissioning -cost-estimate: as a-matter of convenience since--DUF6 oventually;must:be removed-from-the-site in order-to release the
-site for unrestricted use.-
Regarding decommissioning:itself',1LES understands that ~at this time it is not necessary for LES to submit:
a decommissioning plan required-by 10 CFR Parts 30.36, 40.42, andt 70.38.
The decommissioning: plan will be' submitted to the NRC for approval-shortly before cessation-of licensed activities.
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4 Mr. John W. 11. Ilickey, Chief December 14, 1992 Page 2 The "LES CEC Depleted Uranium llexafluoride Management Study" referred to in your letter provided further detailed bases for LES' created at the CEC.
decisions concerning disposition of the DUF6 Specifically, one option in the report analyzed conversion of DUF6 to DUF4 and then packaged, transported, and disposed of in a llear-Surface Disposal Facility licensed in accordance with 10 CFR part 61.
LES analyzed this option because it conformed to processes that are currently licensed and available in the United States.
Your letter of September 22, 1992 indicated that LES should convert in a licar-Surface Disposal DUF to U 0 and not dispose of the U Og 6
38 3
Facility.
Disposal should be in another alternative; deep mine disposal was suggested.
Recognizing that the regulatory framework for disposal of DUF6 is currently under consideration for revision, LES has prepared the following estimate in response to your letter and as an option in addition to the previously submitted disposition options.
Table 1 (attached) compares the previously submitted figures with additional ones prepared in accordance with the following assumptions e LES has the DUF produced at the CEC converted to depleted 6
triuranium octoxide (U 0 ) for disposition.
The conversion 3 3 and dicposition are performed at non-LES f acilities of f-site.
e LES commences conversion of DUF to U 0 within 15 years of 6
3 s initiating enrichment at the CEC or after production of no more than 80,000 tons of DUF, whichever occurs first, 6
For the purposes of the decommissioning and DUF6 disposition o
cost estimate, LES assumes that the depleted U0 will be 3s aisposed of in a facility, other than a near-surface disposal facility, under cognizance of the liRC.
These additional figures provide a sufficient basis for assessing the adequacy of the O&M cost estimates contained in the ER.
The cost estimates in the License Application, Safety Analysis Report and Environmental Report will be updated in the near future to reflect the additional figures.
LES believes that commitment - to - a definitive or prescriptive resolution of the manner of disposition would be premature at this time. -
The Energy Policy Act of 1992
(" Energy Act"), Sec. 1016 requires that a uranium inventory study be performed by the United States Department of Energy
(" DOE") by October 24, 1993.
Among other things, this study shall include " recommendations for the future use and disposition of such (uraniumj-inventories."
The
i Mr. John W.
H. Ilickey, Chief l
December 14, 1992 Page 3 referenced inventories include depleted tailings (i.e.,
depleted l
By the year 2000, it is expected that three The
- DOE, the United States Enrichment domestic entities Corporation ("USEC"), and Louisiana Energy Services ("LES") will possess significant quantities of depleted uranium hexafluoride.
l The DOE currently possesses over 1 billion pounds of DUF.
The j
6 newly created United States Enrichment Corporation (USEC, seo below) will continue to produce DUF6 at a rate approximately 5-8 times that of the CEC, commencing on July 1, 1993.
production at the CEC only begins later this decade.
l The Energy Act also requires that NRC, in consultation with the Environmental Protection Agency (EPA), must review the operations of the USEC with respect to the gaseous diffusion enrichment facilities leased by them from the DOE.
The Energy Act requires that the NRC establish standards to govern the gaseous diffusion enrichment facilities in order to protect the public from radiological hazard and provide for the common defense and security.
LES anticipates that there would be no basis to apply different standards to USEC-generated DUF6 than to that produced at the CEC.
The establishment of similar standards for the USEC should allow the depleted uranium hexafluoride produced by the USEC and LES-to be handled in a similar manner.
This also will allow LES to assume the availability of reconversion and disposal facilities, and economies of scale in methods of handling the material.
Also LES will not be at a competitive disadvantage in these areas with LES' major domestic competitor. The two years allowed by the Energy Act for the NRC to establish the standards for the gaseous diffusion enrichment facilities will permit additional information to be gathered by the NRC, EPA, DOE and LES on the disposition of depleted-uranium hexafluoride, well in advance of the time scale for production from the CEC.
The-DOE uranium inventory study referred to above will be a suitable forum for coordinating joint action among the three (or more) parties responsible for producing and disposing of the national inventory of depleted uranium.-
I enclose a copy of the letter LES sent DOE stating our belief that. this material represents a potential. national resource, and that its future storage and ultimate use or disposition should be handled jointly among the parties involved.
LES has offered to participate in the study phase of the program and to contribute LES' appropriate share of the disposition costs themselves.
As stated currently in the License Application, Exhibit I, LES will-
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review and adjust as necessary the decommissioning cost estimate and decommissioning funding at least once ovary five years.
At such timos, or more often if appropriato, LES will also review the cost basis of depleted uranium hexafluorido disposition.
This element of O&M costs will be recovered in the current pricing of the facility's product and need not be provided in advance as a surety fund.
The funds thus gathered from enrichment services will be set asido by LES in a separate account to ensure the necessary funds are available to dispose of the curront DUF6 inventory possessed by LES at any point in timo.
Should thu estimatos for disposition of DUF6 provided in this letter not prove adequato, LES will adjust product pricing accordingly.
Since our domestic competitors would be dealing with similar regulations, LES anticipatos being able to recover any necessary prico adjustments in the market place.
LES will also limit the on-sito inventory of DUF to the amount 6
speciflod in your September 22, 1992 letter.
If there are any questions concerning this, please do not hesitate to call me at (704) 373-8466.
Sincerely,
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k Peter G.
LeRoy Licensing Manager PGL/N71.112 Enclosures 1.. -.
a Mr. John W. H. Hickey, Chief December 14, 1992 Page 5 xc:
(w/ enclosures)
Ms. Diane Curran, Esquire Harmon,-Curran, Gallagher, & Spielberg 2001 S Street, NW, Suite 430 Washington, DC 20009-1125 Ms. Nathalie Walker Sierra Club Legal _. Defense Fund 400 Magazine Street Suite 401 New Orleans, LA 70130 Mr. R. Wascom Office of Air Quality and Radiation Protection Louisiana Department of Environmental Quality PO Box.82135 Baton Rouge, Louisiana 70884-2135 i
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Table 2 DU 0 Disposition Estimated Costs 3 3 The CEC when operating at nominal capacity of 1.5 million SWU per year will produce approximately 3(X) 48G cylinders of depleted UF per year Each cylinder of depleted UF. will result in approximately 1I tons (22JXX) pounds) of depleted U 0, when converted. Therefore, 3
the CEC will produce approximately:
300 cylinders / year x 11 tons DU 0s/ cylinder = 3300 tons DU 0 / year 3
3 3 The activities associated with deep mine disposal may be estimated by comparison with remedial action associated with uranium processing sites. As stated in The Energy Policy Act of 1992, Title X - Remedial Action and Uranium Revitalization, reimbursement made to licensees for remedial action shall not exceed $5.50 per ton of material. This figure ($5.50/ ton) agrees well with the cost (-$70 million - $5.40/ ton) of disposition of 13 tons of material at the Union Carbide Uravan Mill.
Therefore, using $5.50 per ton of DU 0,, the cost ($1992) of dispositioning 3300 tons of DU 0, 3
3 per year will be:
3300 tons DU 0, x $5.50 per ton = $18,150 ($1992) 3 escalating this at 4% per year to $1996:
$18,150 ($1992) x (l.04)4 = $21,250 ($1996)
Therefore, $21,250 per year will be used for the purpose of estimating the dispositioning costs for DU 0.
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W. Howard Arnold Prescent November 6,1992 l
Mr. Leo Duffy, Assistant Secretary for Environmental Restoration and Waste Management United States Department of Energy 1000 Independence Avenue, SW Washington, DC 20585 Re:
Louisiana Energy Services Claibome Enrichment Center Energy Policy Act of 1992 Uranium Inventory Study LES File #: 8.4.6
Dear Mr. Duffy:
The Energy Policy Act of 1992 (" Energy Act"), Sec.1016 requires that a uranium inventory study be performed by October 24, 1993. Among other things, this study shall include The
" recommendations for the future use and disposition of such [ uranium) inventories."
referenced inventories include depleted tailings (i.e., depleted umnium hexafluoride)
By the year 2000, it is expected that at least three domestic entities - the Department of Energy
(" DOE"), the United States Emichment Corporation ("USEC"), and Louisiana Energy Serv
("LES") will possess significant quantities of depleted uranium hexafluoride ("DUE ").
Rather than have three or four separate entities deal with this issue in different ways and on different dme scales, we would suggest that DOE take the lead and establish a national program for the hand 11ag of this potentially valuable material. Such a progmtn would be most econom for all parties because of economics of scale, and a single point of control would allow the environmental consequences of shipment, conversion, handling and storage to be minimized Absent such a coordinated program, one or more of these entides could take actions which mig prejudice the opdmum solution of this situation. LES rould be pleased to participate i a program, and we would be prepared to provide assistance in the study phase and s expenses for conversion, storage and disposidon on an equitable basis.
LES applied for a license to construct and opente the Claiborne Enrichmen't Center ("
in January 1991. The application is currently under review by the United States Nuclear o
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l November 6,1992 Page 2 Regulatory Commission ("NRC"). We expect a license to construct and operate the facility to j
be issued in the third quarter of 1994. One of the outstanding licensing issues is disposition of the depleted uranium hexafluoride produced at the CEC. Although not a waste, the NRC has indicated they believe it will be treated as such.
Depleted uranium is a potential energy source, and should be preserved in retrievable form.
One potential is as input to a future enrichment plant, which would become economical were the price of separative work to drop significantly or the price of natural uranium ore to rise dramatically. Another potential is as breeding material in liquid metal reactors. Such reactors have been demonstrated to be technically feasible, and may become economical if the price of.
natural uranium ore becomes high enough. However, such uses are undoubtedly decades away, and extended storage of the material will be required before it can be decided that the material is indeed useful or should be dispositioned.
The LES license application postulated that UF, would be sufficient!y stable for extended periods, but the NRC, by letter to LES dated September 22,1992 (copy enclosed), has stated its preference for disposition to be as U,0, in a facility not as yet defined other than that it is
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not licensed under 10 CFR part 61. Such an approach, our studies show, could be quite costly and result in a dispo plan which reaches well beyond the low level of risk presented by depleted tails. However, we do agree that U,0, is stable, non-corrosive, and insoluble in water so that it would be an excellent form for either extended storage or disposal. In a draft study prepared for DOE by Martin Marietta dated September 1991, it is stated that a preferable option (as opposed to disposing of the DU,0,) may be to create a strategic reserve and store the converted material in retrievable form in a facility designed for indefinite, low maintenance operation. This is currently being done in France with a portion of the DUF. being generated in the Eurodif gaseous diffusion facility.
DOE currently possesses essentially all the DUF. inventory in the United States. However, the USEC will begin to generate this material as soon as the DOE facilides come under its operational control via the lease specified in the Energy Act. Since the Energy Act also specifies that the USEC must be certified by the NRC within two years, we anticipate that the NRC requirements indicated to us in the letter of September 22 will apply to the USEC as well.
The LES licensing and the USEC certification regulations are now being examined by the NRC, prompting an early resolution of this issue. This schedule is compatible with the time fran your uranium inventory study, so we urge that you define its scope broadly enough to in these issues. As our date of commencement of operations is no earlier than the middle of 1997, and the deadline for removal of the first DUF. from the CEC site is well beyond 2010, we expect that there will be sufficient time for us to coordinate the specific armngements for actual handling of our material once the plan is in place. Indeed, in this time period other-parties could also generate depleted uranium in the United States. For ecuple, the Energ wa d
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Mr. Leo Duffy November 6,1992 Page 3 contemplates licensing the Atomic, Vapor Laser Isotope Separation ("AVLIS") technology currently owned by DOE to a private entity who would build an enrichment plant.
i As stated above, LES would be pleased to participate with you and the USEC in discussing this matter at your earliest convenience. We are prepared to provide input to your study, and would look forward to working with you in the implementation phase when our inventory of DUF,is to be dealt with.
Sincerely, 4
bJAd WHA /pp Enclosure l
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September 22, 1992
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Docket flo:
70-3070 Louisiana Energy Services. L.P.
ATTN:
W. Howard Arnold President 2121 K Street, N.W.
Suite 850 Washington, DC 20037 Gentlemen:
Since disposition of depleted uranium (DU) tails is an important decommissioning licensing issue for the proposed Claiborne Enrichment Center, the Nuclear Regulatory Commission performed an assessment of the issues involved.
Our evaluation assumes that the bulk of DU tails will eventually be disposed of as a waste. We examined the acceptability cf disposal of the LES enrichment plant tails, as depleted UF,,, in a licensed 10 CFR Part 61 disposal f acility as suggested by LES's " Depleted Uranium Hexafluoride Management Study." We have completed our review of this proposal.
Based on our analysis, we have reached the fellowing conclusions.
The preferred chemical form for final disposition of the DU tails is 0 0Even if stored regardless of U-235 concentration.
processed and depleted of U-235, the bulk of DU tails must still be disposed is the more stable physicochemical form and the of. Compared with UF, U 03s 4
more compatible, as regards to safety, with long-term disposition of tails.
Conversion of the DUF to for final disposition is not acceptable because its physicochemical, long DUFterm stability is incompatible with final disposal 4
under 10 CFR Part 61.
The Environmental Impact Statement (EIS) supporting 10 CFR Part 61 did not contemplate large volumes of DU tails. Our analysis, using methodology similar to that used for the Part 61 EIS, concludes that near-surface disposal of such large quantities of DU tails is not appropriate, both because of its potential radiological impact and its chemical toxicity. However, cther disposal alternatives under 10 CFR Part 61 may be viable; e.g., deep mine disposal.
Therefore, disposal options, other than near-surface disposal, must be considered for the DU tails.
Dis)osall options must be accompanied with supporting analyses. The analyses slould include funding provisions for storage, tails conversion to the oxide form, final disposition and, if applicable, transportation custs.
Your analyses should also consider an appropriate schedule for conversion and
- disposal.
Since you are proposing to start production in phases, which may take several years, the conversion of DUF to DU 0, or other suitable waste 6
3s form,.should start 10 to 15 years after initiating production,' or after generating 80,000 tons of tails, whichever is reached first.
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In summary, demonstration of viable means of DU tails ultimate disposition and provision _for financial assurance are needed.
It is recognized that the total volume of waste to be generated for the LES Claiborne Enrichment Center is part o? a much larger national inventory. Therefore, LES DU tails disposition may b? cddressed as part of the national inventory disposal scheme.
We would be pleased to discuss these matters further with you after you have considered them.
If you have any questions, please contact Dr. Lidia A.
Roche' at (301) 504-2695.
Sincer?.ly,
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.tl. Hickey, Chief Fuel Cycle Safety Branch Division of Industrial and Medical Safety Office of Nuclear Material Safety-and Safeguards cc: Attached list k
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' ATTACHED LIST Dr. W. Howard Arnold Mr. Michael Mariotte President Executive Director Louisiana Energy Services Nuclear Information and 2121 K Street, NW Resource Service Suite 850 142416th Street, NW Washington, DC 20037 Suite 601 Washington, DC 20036 Mr. Peter G. LeRoy Licensing Manager Administrative Judge Louisiana Energy Services Richard F. Cole c/o Duke Engineering & Services. Inc.
Atomic Safety and Licensing Board P.O. Box 1004 U.S. Nuclear Regulatory Commission Charlotte, NC 28201-1004 Washington, DC 20555 Mr. J. Michael McGarry, Ill Administrative Judge Winston & Strawn Frederick J. Shon 1400_L Street, NW Atomic Safety and Licensing Board Washington, DC 20005 U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Ronald L. Wascom Deputy Assistant Secretary Office of Commission Appellate Office of Air Quality and Adjudication Radiation Protection U.S. Nuclear Regulatory Commission Louisiana Dept. of Environ. Quality Washington, DC 20555 P.O. Box 82135 Baton Rouge, LA 70884-2135 Morton B. Margulies', Chairman Atomic Safety and Licensing Board Ms. Diane Curran U.S. Nuclear Regulatory Commission Harmon, Curran, Gallagher, &
Washington, DC 20555-Spielberg 2001 S Street, NW Suite 430
- Washington, DC 2009-1125 Natalie M. Walker, Esq.
Sierra Club Legal Defense Fund, Inc.
400 Magazine Street, Suite 401 New Orleans, LA 70130 y
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