ML20132C925

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Forwards Notice of Const Approval for SPC Dry Conversion Facility from Division of Radiation Protection of Washington State Dept of Health (WDOH)
ML20132C925
Person / Time
Site: Framatome ANP Richland
Issue date: 12/09/1996
From: Edgar J
SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER
To: Weber M
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
JBE:96:125, NUDOCS 9612190066
Download: ML20132C925 (11)


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"SIEMENS V

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December 9,1996 JBE:96:125 1-

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' U.S. Nuclear Regulatory Commission

- Attn: Michael F. Weber, Chief l

Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS D

Washington, DC 20555 L

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Dear Mr. Weber:

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Ref.:

Letter,'J.B. Edgar to E.G. Adensam, dated April 28,1993 in the referenced letter Siemens Power Corporation (SPC) committed to forward to the NRC a copy of the Washington State Department of Ecology (WDOE) Notice of Construction approval

' for SPC's Dry Conversion facility. Instead of the WDOE, it is now the Division of Radiation Protection of the Washington State Department of Health (WDOH) which issues approvals of Notices of Construction. Enclosed is a copy of WDOH's approval letter.

In reviewing the application portion of SPC's recently renewed NRC Materials License we have discovered an omission in Chapter 15 and three minor needed corrections in Chapter 11.

Through an inadvertent omission the Chapter 15 process description and safety. analysis J

sections for the Dry Conversion Building, submitted October 21,1994 were left out of the October 28,199fi application. The Dry Conversion Building information from October 21, i

1994, the safety analysis section of which has been slightly revised to reflect only dry conversion, is resubmitted for completeness. (Originally the safety analysis discussed both ADU and dry conversion. Revised Chapter 15 sections submitted on October 2,1995 dealt y

with ADU conversion, necessitating lirniting the present submittal to dry conversion information.) Two copies each of pages'15-75 through 15-78, are submitted to convey this

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information. This information will be updated in the near future when the Dry Conversion j

Criticality Safety Analyses (CSA's) are completed.

. In addition, in Chapter 11 (paragraph 11.3.17) the education and experience statement for the jI Manager, Safety submitted February 9,1996 was erroneously replaced by his previous statement when the position was the Supervisor, Safety. This is being corrected. Two other 1

changes to education and experience, statements are also being made. in paragraph 11.3.18

/s the title and current position are revised to Lead Criticality Safety Specialist. In paragraph 11.3.19 the experience statement has been revised to describe present duties. Two copies of each of pages 11-28,11-29, and 11-3C are enclosed to describe the above changer to Chapter 11.-

.9612190066 961209

-PDR. ADOCK 07001257 C

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- Siemens Power Corporation Y

Nuclear Division 2101 Hom Rapids Road Tel:

(509) 375-8100 En neering & Manufacturing Box 130 Fax:

(509) 375-8402

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Distribution JBE:96:125 December 9,1996 Page 2 If you require additional information, please call me at 509-375-8663.

Very truly yours,:

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James B. Edgar i

Staff Engineer, Licensing 4

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Enclosures 4

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-XXXXX AIR 95-306 i

ST ATI O! WASHINGTON DEPARTMENT OF HEALTH Airdustnal Center. Bktg 5 Mai! biopXQtXX e Olynpa. Mashington 935(M e

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March 14,1995

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1 Mr. B. A. Femreite, Richland Plant Manager Siemens Power Corporation Nuclear Division

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Engineering and Manufacturing Facility P. O. Box 130 Richland, Washington 99352-0130

Dear Mr. Femreite:

1 My staff has completed reviewing the Notice of Construction for the Dry Conversion i

Building in accordance with WAC 246-247. After the meeting with Mr. Jim Edgar and Randy Acselrod of my staff, this Notice of Construction is approved.

Please note that WAC 246-247 must be strictly adhered to. This approval is for all conditions of the Notice of Construction application contents.

if you have any questions, please do not hesitate to call me at (360) 586-0254 or Randy Acselrod of my staff at (360) 586-8950.

Sincerely, Allen W. Conklin, Head Air Emissions and Defense Waste Section Division of Radiation Protection AWC/RA/jr cc:

Deborah McBaugh 3

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i Siemens Power Corporation - Nuclear Division eup.2 SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM-1227, NRC DOCKET NO. 70-1257 i

PART 11 - SAFETY DEMONSTRATION nev.

1

-36 Operations Manager, Nuclear Fuel Manufacturing, responsible for daily direction and overall coordination of the activities of the manufacturing process of C-E nuclear products. Assigned as Emergency Director for the Nuclear Fuel Manufacturing facilities and Product Development laboratories. (1989)

Plant Manager, ABB-Combustion Engineering Nuclear Fuel Manufacturing, responsible for all aspects of the safe operation of the NRC licensed manufacturing facilities producing finished nuclear fuel assemblies and related components to the j

commercial nuclear power industry. (1990-1992)

Project Director, ABB Combustion Engineering Windsor Site Remediation, responsible for the safe and cost effective characterization and environmental remediation of the ABB Windsor site areas contaminated under AEC contact.

Provided liaison with DOE, NRC, EPA, and Connecticut DEP. (1992) 1992-Present j

Employed by Siemens Power Corporation as Manager, Safety, Security, and Licensing, reporting directly to the Vice President, Engineering and Manufacturing and is responsible for developing, administering, and auditing the licensing, industrial safety and health, health physics, criticality safety, environmental surveillance, ALARA, security j

and safeguards programs for SPC's facility at Richland, Washington.

i 1

    1. ENDMENT APPUCATION DATE:

PAGE NO.:

October 28,1996 11-27 SPC NO:3330 947 (R 1/07/92)

Siemens Power Corporation - Nuclear Division ew.2 SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM-1227, NRC DOCKET NO. 70-1257 PART 11 -SAFETY DEMONSTRATION REv.

37 11.3.17 Manaaer. Safety - T. C. Probasco Education BS Microbiology 1970 Oregon State University BS Military Science 1970 Oregon State University Certified Safety Professional 1982 Board of Certified Safety Professionals Experience 1970-1972 Highway Engineering Technician for the Oregon State Highway Department.

1972-1975 Employed by a food processing company.

Supervised chemical and bacteriological laboratories in the Quality Assurance Department. (1972-1973)

Safety Engineer. (1973-1975) 1975-Present i

Employed by Siemens Power Corporation.

Plant Safety Engineer. (1975-1984)

Plant Criticality Safety Engineer. (1975-1984)

Supervisor, Radiological and Industrial Safety, responsible for supervising Health Physics Technicians, Radiological Safety Specialist, and Industrial Hygiene Specialist. (1985-1989)

Supervisor, Safety, responsible for supervising Criticality Safety Specialists, Health and Safety Specialist, Radiological Safety Supervisor, Health and Safety Technicians, and the Health Records Clerk. (1990-Present)

Manager, Safety, responsible for emergency preparedness and for supervising Criticality Safety Specialists, Health and Safety Specialist, Radiological Safety Supervisor, Health and Safety Technicians, and The Health Records Clerk. (1996-Present)

A 1ENOMENT APPLICATION DATE:

PAGE NO.:

December 9,1996 11-28 sPC-ND:3330 947 (R-UO7/92)

SiemenS Power Corporation - Nuclear Division EMF-2 SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM-1227, NRC DOCKET NO. 70-1257 4

1

- PART 11 - SAFETY DEMONSTRATION

gev, 37 11.3.18 Lead Criticality Safety Specialist - C. D. Manning i

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- Education BS Nuclear Option of General Engineering 1982 Idaho State University Experience 4

1976-1984 Employed by Union Pacific Railroad.

1984-1985 Employed by Newport News Reactor Services as a Radiological Control Engineer.

Training HPT technicians and operators Shielding and dosimetry requirements 1

- Auditing radiological control program compliance 1985-1987 Employed by Rockwell Hanford Company as a Criticality Safety Engineer.

Criticality safety analyses Auditing criticality safety program compliance j

1987-1990 Employed by Westinghouse Hanford Company as a Nuclear Safety Engineer.

Cognizant Safety Engineer for the Plutonium Metal Production Line.

Event investigation Team Leader Plant criticality safety approval authority 1990-Present Employed by Siemens Power Corporation as Lead Criticality Safety Specialist.

l Engineer responsible fo'r all aspects of the criticality safety program.

AMENOMENT APPLCATION DATE:

PAGE NO,:

December 9,1996 11-29 SPC-NO 3330 947 (41107/92)

SiemenS Power Corporation - Nuclear Division eup.2 SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM-1227, NRC DOCKET NO. 70-1257 PART 11 - SAFETY DEMONSTRATION Rev.

37 11.3.19 Criticality Safety Specialist - J. M. Deist Education BS Nuclear Engineering 1990 Kansas State University Nuclear Criticality Safety Short Course 1994 University of New Mexico i

SCALE Training Course 1995 Oak Ridge National Laboratory Experience 1990-1992 Employed by Kansas State University as a Graduate Research Assistant in the Nuclear Engineering Department.

l Radiation Detection Laboratory Assistant Neutron Activation Analysis Laboratory Assistant 1992-Present i

Employed by Siemens Power Corporation.

PWR Neutronics Engineer (1992-1996)

- Lead Neutronics Engineer for H.B. Robinson plant Neutronics input for safety analysis Startup and operations data Incore monitoring data Safety Analysis Report and Startup and Operations Report i

Criticality Safety Specialist (1996-Present)

Criticality safety analysis Criticality safety audits AMENOMENT APPLCATON DATE:

PAGE NO :

December 9,1996 11-30 SPC-NO.3330.947 (R-1/07/92)

Siemens Power Corporation - Nuclear Division sup.2 SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM-1227, NRC DOCKET NO. 70-1257 PART 11 - SAFETY DEMONSTRATION REv.

37

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15.1.14 Dry Conversion 15.1.14.1 Vaporization - UF. cylinders are moved by forklift and overhead monorail hoist to the vaporization facilities in the Dry Conversion Building. In the vaporization room a cold valve check is performed to evaluate the condition of the cylinder valve. The cylinder must have the appropriate vacuum to prevent rupture during heating. If the cylinder is found not to be under negative pressure, a negative pressure is drawn on it and the valve is checked for leakage. A rcplacement valve is installed if a leak is indicated.

UF. cylinders are then placed in electrically heated autoclaves and connected to a welded, heated, and insulated stainless steel header system used to transport UF gas to the dry conversion reactor. A backup safety shutoff valve is installed next to the cylinder valve for added protection against uncontrolled release of gas from the cylinder.

The vaporization autoclaves, each limited to a single cylinder are designed to act as pressure vessels cap 21e of containing all UF. released in a worst case leak from a UF. cylinder. %y UF. leakage within the autoclaves will be contained and recovered.

UF. cylinder temperature and pressure are monitored and recorded during heatup and vaporization. In addition to control thermocouples, separate thermocouples and a pressure sensor are used on the autoclave to independently shutdown power in case of an over temperature or over pressure condition.

Burnout of a thermocouple causes the control instrumentation to drive upscale and safely shutdown cylinder heating.

As with the ADU system the weight of each UF. cylinder is confirmed upon receipt to preclude rupture of an overfilled cylinder during the solid-to-liquid phase change and subsequent volume expansion which occurs during cylinder heating.

Personnci connecting and disconnecting UF. cylinders are required to use protective clothing including coveralls, rubber shoe covers, and plastic gloves. Seprrate self-contained breathing equipment, avid suits and fresh air supply are available in case of emergency.

15.1.14.2 UF, to U-Oxide Conversion - In the dry conversio'1 process vaporized UF.

is reacted with a steam-nitrogen-hydrogen atmosphere in a fluidized bed reactor to form dry UO powder. In addition to those used for reactor 2

temperature control, thermocouples are provided for over-temperature protection and for under-temperature interlocks of steam, hydrogen and AMENOMENT APPLCATION DATE:

PAGE NO.:

December 9,1996 15-75 SPC-ND 3330 947 (R 1/07/92)

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Siemens Power Corporation - Nuclear Division EMF 2

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SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM-1227, NRC DOCKET NO. 70-1257 PART ll-SAFETY DEMONSTRATION rav.

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37 J

l UF.. These low temperature interlocks are included for moderation control to ensure no liquid water can form in the reactor. High pressure in the i

reactor will also shut off the UF flow. During normal operation to attain complete reaction and assurance that no UF. gas may pass through the I

off-gas filter system, an excess of steam.is supplied. The UF. flow is 4

terminated should the steam to UF. ratio become low.

15.1.14.3.

U-Oxide Calcination - The calcination system, consisting of a rotary

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j calciner, is used to reduce the fluoride content of uranium dioxide from the

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i conversion reactors to acceptable levels.

The calciner operates at

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temperature from' 600 *C to 800 *C in an atmosphere of steam and -

I hydrogen.

Interlocks are used to prevent high and low calciner l

temperature and high pressure. The low temperature control is to ensure i'

no liquid water can be present.

l The calciner product is transferred by gravity to the UO stabilizer where 1

2 the O/U ratio is adjusted.

~ 15.1.14.4' Process Off-Gas - The HF-bearing offgas from this conversion and U-Oxide calcination processes, consisting of nitrogen, hydrogen, HF, steam and some entrained UO2 powder, is passed through two banks of sintered -

metal filters which quantitatively remove all oxides of uranium. The filtered j;

UF-bearing offgas is then condensed to form liquid nydrofluoric acid at a nominal concentration of 45 wt%. Non-condensed offgas is treated with a.

caustic scrubber to remove residual HF. Before discharge to the building h

stack the offgas is treated with a flare to destroy H and is passed through 2

a HEPA filter.

15.1.14.5 HF Collection'- The. hydrogen Fluoride (HF) collection process includes two stage condensers for the' reactor and calciner offgas, a condensate receiver tank, and an HF storage and loadout station. An inline uranium analyzer is used to monitor the uranium content of the HF condensate. In

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the unlikely event there is high uranium content in the offgas condensate, the process is shutdown automatically. Leak detection and ambient air HF monitors at the HF collection pad are used to detect HF leaks and protect personnel. These systems will alarm both locally and in the control room.

Appropriate protective clothing is wom for all hands on activities in which contact with HF is possible.. Hands on activitias include sampling, unloading storage tanks to trucks and maintenance activities.

During i

handling of HF tanks employees will wear protective clothing respirators.

The coproduct HF will be marketed commercially as an industrial chemical.

AMENOMENT APPLCATION DATE:

PAGE NO.:

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December 9,1996 15-76 SPC-NO:3330 947 (R-1/07/92) l j

Siemens Power Corporation - Nuclear Division eus.2 SPECIAL NUCLEAR MATERIAL LICENSE NO SNM-1227, NRC DOCKET NO. 70-1257 PART 11 - SAFETY DEMONSTRATION REV.

L 37 l

j 15.1.14.6 Process Offaas Scrubber - After passing through the condensors the offgas is scrubbed with a 5.5% NaOH solution to remove the small amount

_ of residual HF. - The scrubber discharge is sampled and discharged to a j

waste lagoon.

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15.1 *4.7 Solid Waste Handlina - Dry conversion waste will be limited to contact I

contaminated matedals from handling the uranium oxide product and '

production equipment. It will either be incinerated or buried.

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'15.1.14.8-Criticality Safety

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Criticality' Safety of UF. cylinders is ensured by using moderation control and plant wide enrichment limitations (equal to or less than 5 wt% 2"U).

Prior to its introduction into the conversion area, each UF. cylinder is checked for enrichment using a gamma counter to verify the shippers values and to verify equal to or less than 5 wt% 2"U.

If cylinder enrichment is greater than 4.7 wt%, a sample from the master cylinder is analyzed, prior to introduction into the conversion area, to verify equal to or less than 5 wt% 2"U.

Criticality safety in dry conversion equipment is attained through moderation control. All l

powder is verified dry in the reactor and calciner. Interlocks exist in both the reactor and calciner to ensure that the existence of liquid water is not possible' The entire process l area of the Dry Conversion building is moderator controlled.

15.1.14.9 Radiation Protection Conversion of UF to UO is performed' in restricted areas and the processes are.

2 contained in the reactor and associated dry conversion equipment. Personnel entering the j

area are required to wear radiation monitoring devices and protective clothing / equipment

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appropriate for the work to be performed. Personnel are required to survey themselves prior to exiting the controlled area. Equipment leaving the controlled area must be released by Radiological Safety personnel.~ All personnel also receive initial and yearly refresher training on radiation protection principles and requirements.

Airbome uranium contamination is controlled by extensive use of hoods _which are l-maintained at negative pressure and ventilated to the process offgas (POG) system.

L aoutine surveys are performed and housekeeping practices are enforced to minimize surface and airbome contamination in the conversion areas. Air is continuously sampled l

and periodically analyzed to detect any airbome contamination.

t f-AMENOMENT APPUCATION DATE:

PAGE NO.:

December 9,1996 15-77 SPC.NO.3330 947 (R 1M7/92)

Siemens Power Corporation - Nuclear Division eup.2 SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM-1227, NRC DOCKET NO. 70-1257 PART 11 - SAFETY DEMONSTRATION Rev.

37 i

Urine sample analyses and lung counts are periodically performed for personnel who work in the controlled access area. The frequencies of such testing are described in Chapter 3.

15.1.14.10 Fire Protection The Dry Conversion building is rated as noncombustible. Fire loading is kept to a 4

minimum through monthly inspections. Fire extinguishers, alarm pull boxes, and heat detectors are strategically placed throughout the conversion areas. Where moderation control is in place, water exclusion signs are posted to alert local fire fighters of areas where water is not to be introduced. In these areas high expansion foam, dry chemical or CO would be used to combat a fire.

2 There are two high temperature unit operations in the conversion area. The conversion reactor which operates between 400 and 650 C and the rotary calciner which operates from 600 to 800 C. Both systems utilize overtemperature interlocks to avoid overheating.

Hydrogen is used in the Dry Conversion system in both the reactors and the calciner. The reactors are sealed to outside air and operated under nitrogen purge at near atmospheric pressure. Due to the lack of driving force the probability of leakage of air into the system i

is remote. The calciners are sealed presenting the leakage of air into the system.

15.1.14.11 Environmental Safety Hazardous materials are contained to prevent their introduction into the environment. All unit operations are served by POG vent lines or by hoods. Hoods are maintained at a negative pressure and vented to the POG system. Floors are sealed and have no drains.

l The POG system treats and removes fumes and particulates from the exhaust air using

'j sintered metal filters, scrubbers and two stages of HEPA filtration. See sections 15.1.14.4 through 15.1.14.6 for description of offgas treatment.

All room and building air is processed through the heating, ventilation, and air conditioning j

system and then HEPA filtered to remove particulates.

Solvent contaminated rags from the controlled area are disposed of in special containers distributed throughout the conversion area. The rags are treated as mixed hazardous waste and stored in a secured area for future disposal.

15.1.14.12 Reactions of Hydrocarbons with UF.

Reactions of hydrocarbons with UF is discussed in Section 15.1.5.

AMENOMENT AP *LCATON DATE:

PAGC NO.:

December 9,1996 15-78 SPC-ND:3330.947 (R-1/07/92)