ML20133B751
| ML20133B751 | |
| Person / Time | |
|---|---|
| Site: | Claiborne |
| Issue date: | 12/23/1996 |
| From: | Wascom R LOUISIANA, STATE OF |
| To: | Holler E, Horn M, Moore T Atomic Safety and Licensing Board Panel, NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS), NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| References | |
| NUDOCS 9701060133 | |
| Download: ML20133B751 (23) | |
Text
10-3070 a
)
State of Louisiana
(
)
Department of Environmental Quality b
%I.J. "3IIKE" fos 1 ER, J R.
J. D \\l.E Gl\\ 1:%
GOVERNOR M CRI.I \\RY MEMORANDUM To:
Addressees as Li.ed From:
Ronald Wascom Deputy Assistant Secretary Date:
December 23, 1996
Subject:
Air Permit for Louisiana Energy Services The State Air Permit has been reissued to Louisiana Energy Services (LES).
Operation of the facility under this permit remains contingent upon The U.S.
Nuclear Regulatory Commission issuing LES a license.
A copy of the permit is enclosed for your convenience.
Enclosure c:
Mr. Percy Harris Wster Pollution Control Division l
Me. Wyvenne Landry i
Air Quality Division
/
A/F DA
/
('3 -A^
9701060133 961223 PDR ADOCK 07003070 C
PDR OFFICE OF AIR QUALITY P.O. BOX 82135 BATON ROUGE LOUISlANA 70634 2135 AN EQUAL CPPORTUNITY EMPLOYER M.
mw
Diane Curran, Esq.
Administrative Judge Harmon, Curran, Gallagher &
Richard F.
Cole Spielberg Atomic Safety and Licensing
- /o Institute for Energy and Board Environmental Studies U.S. Nuclear Regulatory 6935 Laurel Avenue, Suite 204 Commission Takoma Park, Maryland 20912 Washington, D.C.
20555 Nathalie Walker, Esq.
Eugene Holler, Esq,.
Sierra Club Legal Defense Fund Office of the General Counsel 400 Magazine Street U.S. Nuclear Regulatory Suite 401 Commission New Orleans, LA 70130 Washington, D.C.
20553 J. Michael McGarry, III, Esq.
Joseph DiStefano Winston & Strawn Louisiana Energy Services, L.P.
1400 L Street.N.W.
2600 Virginia Avenue, N.W.
Washington, D.C.
20005-3502 Suite 610 Washington, D.C.
20037 Michael Mariotte i
Executive Director Roland J. Jensen j
Nuclear Information and Louisiana Energy Services, L.P.
Resource Service 2600 Virginia Avenue, N.W.
1424 16th Street, NW Suite 608 i
Suite 601 Washington, D.C.
20037
)
Washington, DC 20036 Merri Horn Robert G. Morgan Enrichment Branch Duke Engineering and Services, Division of Fuel Cycle Inc.
Safety and Safeguards, JMSS 230 South Tryon Street U.
S. Nuclear Regulatory P. O.
Box 1004 Commission Charlotte, NC 28201-1004 Mail Stop O-8A33 Washington, D.C.
20555 Administrative Judge Thomas S. Moore, Chairman Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Administrative Judge Frederick J.
Shon Atomic Safety and Licensing Board i
U.S. Nuclear Regulatory Commission Washington, D.C.
20555 A
s State of Louisiana Department of Environmental Quality 4
P MJ. MIKE" FOSTER, JR.
J. D ALE GWENS GOVERNOR SECRETARY I
Mr. Roland J.
Tensen President I
Louisiana Energy Services, L.P.
2600 Virrinia Av, Suite 608 Washington D C 20037
Dear Mr. Arnold:
RE:
Permit modification, Claiborne Enrichment
- center, Louisiana Energy Services, L.P.
(LES), Homer, claiborne Parish, Louisiana a
This is to inform you that the permit modification for the above referenced facility has been approved under LAC 33:III.501.
Th#s submittal was approved on the basis of the emissions reported ard the approval in no way guarantees the design scheme presented vill be capable of controlling the emissions as to the types and quantities stated.
A new application must be submitted if the reported emissions are exceeded after operations begin.
The
- synopsis, data sheets and conditions are attached herewith.
Operation of this facility under this permit is contingent upon issuance of a license by the U.
S.
Nuclear Regulatory Commission.
It will be considered a violation of the permit if all proposed control measures and/or equipment are not installed and properly operated and maintained as specified in the application.
The permit number cited below should be referenced in future correspondence regarding this facility.
/ f ay of bEh 1996.
Done this
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Permit No.:
0620-00057-01 Very truly yours, Gusta A. Von Bo ungen, P.E.
Assistant.', Secretary GVB/WL c: Northwest Regional Office OFFICE OF AIR OUALITY P.O BOX B2135 BATON ROUGE. LOUIStANA 705M 2'2E F
AN EOUAL OPPORTUNITY EMPLOYER g
s
-e; AIR PERMIT BRIEFING SEEET j
AIR QUALITY DIVISION L,OGISIAx1 DEPARTMENT OF ENVIRONMENTAL QUALITY CLAIBORNE ENRICEMENT CENTER LOUISIANA ENERGY SERVICES, L. P.
RONER, CLAIBORNE PARISE, LOUISIANA l
I.
BACKGROUND Louisiana Energy Services, L. P., hereinafter referred to as LES, proposes to construct and operate a uranium enrichment plant to supply fuel for the commercial nuclear power.
industry.
LES is currently in the process of obtaining a license to construct and operate the Claiborne Enrichment Center (CEC) from the U.
S.
Nuclear Regulatory Commission.
The original schedule called for construction activities to commence in August 1993, and for the first of three commercial units to begin operation in March 1996.
These dates slipped ~
in the Permit No. 06't0-00057-00, issued January 20, 1995, to August 1995, and June 1998, respectively due to litigation.
Subsequently, by judgement dated April 4,
1996, the First Circuit court of Appeal vacated the permit and remanded the matter to DEQ for further proceedings. An amplified Record of Decision was prepared and the permit was modifi.ed to reflect new starting dates for construction and operation.
II.
ORIGIN As a result of the First Circuit Court of Appeal's vacating Permit No. 0620-00057-00, the Department of Environmental Quality expanded the Record of Decision and modified the permit to reflect new starting dates for construction and operation.
The synopsis and data sheets are based on the application and Emission Inventory Questionnaire dated June 29, 1992.
Details of the gaseous affluent vent system i
(GEVS) have been extracted from the Safety Analysis Report (SAR).
III. DESCRIPTION 4
CEC receives solid. feed urani'un hexafluoride (UF ) with a zug concentration of.approximately 0.7%.
Any UF released during the separation process forms HF gas and uranium aerosol which will le discharged through the GEVS after filtration.
The GEVS will also discharge small quantities of solvent fumes from degreasing operations.
The UF. is passed through a l
l 2
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p i.
i AIR PERMIT BRIEFING SEEET AIR QUALITY DIVISION j
LOUISIAME DEPARTMENT OF ENVIRONMENTAL QUALITY CLAIBORNE ENRICBMENT CENTER LOUISIANA ENERGY SERVICES, L. P.
ROMER, CuhIBORNE PARISE, LOUISIANA series of centrifuges in gaseous phase to physically separate the uranium isotopes.
Enriched UF6 product will contain fron l
2% to 5% "U.
Annual facility product output is estimated at 2.4 MN pounds (0.3 MM pounds UF per unit).
Emission controls consist of a 99.7% efficient pre-filter, a 99.97% high efficiency particulate air (HEPA) filter, and 99% efficient activated carbon unit, all in series at the GEVS (Emission Point 001). -Also at Emission Point 001 is an enclosed design degreaser equipped with condensing coils for vapor recovery.
There are ten air pollution sources identified in the application.
Two of these, the construction phase fugitive emissions and the fugitive solvent emissions from the assembly of the centrifuge, are temporary (these are not included in the perm %) and are estimated to produce air emissions for a period of 17 months and 32 months, respectively. Three of the sources - the diesel fuel storage tanks, diesel fuel day tanks
- are components of the system to and diesel generators provide backup power for the facility in the event of a power outage.
The two diesel generators will be the only large stationary combustion sources at the facility.
Estimated operating time is 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> per year. Two of the sources, the diesel powered fire pump and the diesel fire pump fuel tank, are components of the fire protection system.
The pump and tank.are small.
Estimated pump operating time is only thirty (30) ' hours per year.
The diesel powered fire protection pump is the only stationary combustion source currently expected to operate on a regular basis.
)
l The remaining emission points are the three plant unit stacks.
Two of the three plant stacks' emissions (Units. 2 and. 3) contain only heating, ventilation, and air conditioning (HVAC) exhaust and nitrogen emissions from the system used for process cooling.
The remaining stack (Unit 1) vents gases from the separations processes, decontamination process, degreasing operations, workshops, wasta processing, storage areas, HVAC, and nitrogen system.
The process vents are all routed to this stack (Gaseous Effluent Vent System - GEVS) for l
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AIR PERNIT BRIEFING SEEET AIR QUALITY DIVISION LOUISIANA DEPARTNENT OF ENVIRONNENTAL QUALITY
~
CLAIBORNE ENRICENENT CENTER LOUISIANA ENERGY SERVICES, L. P.
RONER, CLAIBORNE PARISE, LOUISIANA l
monitoring purposes due to the potentially hazardous radionuclides.
one GEVS serves the LES plant.
It consists of a piping network which serves all of the UF. processing systems and operates at sub-atmospheric pressure. The piping is connected l
to five parallel filter stations.
Each is capable of handling j
25% of the effluent.
Four are on line and the fifth acts as a stand-by.
Each station consists of a pre-filter, an i
absoluta filter (high efficiency particulate air filter -
HEPA) and an activated charcoal filter.
The filter stations vent through one of two air fans.
Each is capable of handling 100% of the affluent.
One is on line, the other acts as a spare.
Gases from the UF. processing systems pass through the pre-filter which removes 99.7% of the uranium compounds and particulates having a p~ article size greater than 5 microns (p) and protects the HEPA filter.
The gases next pass through the HEPA filter which removes 99.97% uranium aerosols (mainly UO F particles) having a particle size greater than 0.3 p, 2
then through the activated charcoal filter which captures 99%
of the hydrogen fluoride (HF).
HF detectors in the GEVS provide alarms at 5.0 ppa HF concentration to give a safety margin of 100 times the allowable limits for HF releases. The remaining clean gases pass through the air fan, which maintains the sub-atmospheric pressure upstream of the filter stations, and are discharged via the vent stack.
Details of the gaseous affluent vent system (GEVS) have been extracted from the Safety Analysic Report (SAR).
-The GEVS provides the ventilation and hazardous contaminant removal for the following systems, equipment and areas.
The GEVS is connected via hard-piping to:
.A.
. The Feed, Tails, Product, and Product Blanding Vent
- Systems, B.
All autoclaves and l
C.
All discharge lines from mobile vacuum pump sets.
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ATR PERMIT BRIEFING SEEET l
AIR QUALITY DIVISION LOUISIANA u PARTMENT OF ENVIRONMENTAL QUALITY a
CLAIBORNE ENRICEMENT CENTER LOUISIANA ENERGY SERVICES, L. P.
{
ROKER, CLAIBORNE PARISE, LOUISIANA 1
I series of centrifuges in gaseous phase to physically separate i
the uranium isotopes.
Enriched UF. product will contain from 2% to 5% "U.
Annual facility product output is estimated at i
2.4 MM pounds (0.8 MM pounds UF. per unit).
Emission controls consist of a 99.7% efficient pre-filter, a 99.97% high l
officiency particulate air (HEPA) filter, and 99% efficient activated carbon unit, all in series at the GEVS (Emission l
Point 001).
Also at Emission Point 001 is an enclosed design l
degreaser equipped with condensing coils for vapor recovery.
4 There are ten air pollution sources identified in the application.
Two of these, the construction phase fugitive j
emissions and the fugitive solvent emissions from the assembly of the centrifuge, are temporary (these are not included in i
the permit) and are estimated to produce air emissions for a l
period of 17 months and 32 months, respectively. Three of the sources - the diesel fuel storage tanks, diesel fuel day tanks i
and diesel generators are components of the system to l
provide be.ckup power for the facility in the event of a power l
outage.
j I
The two diesel generators will be the only large stationary combustion sources at the facility.
Estimated operating time is 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> per year. Two of the sources, the diesel powered fire pump and the diesel fire pump fuel tank, are components j
of the fire protection system.
The pump and tank are small.
Estimated pump operating time is only thirty -(30) hours-per year.
The diesel powered fire protection pump is the only stationary combustion source currently expected to operate on
}
a regular basis.
[
j The remaining emission points are the three plant unit stacks.
~
Two of the,three plant stacks' emissions (Units 2 and 3) contain only heating, ventilation, and air conditioning (HVAC) i exhaust and nitrogen emissions from the system used for process cooling.
The remaining stack (Unit 1.).--vents gases i
from the separations processes, decontamination process, degreasing operations, workshops, waste processing, storage i
areas, HVAC, and nitrogen system.
The process vents are all routed to this stack (Gaseous Effluent Vent System - GEVS) for i
3 i
3 l
p i
i
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l AIR PERMIT BRIEFING SNEET AIR QUALITY DIVISION i
LOUISIANA DEPARTMENT OF ENVIRONMENTAL QUALITY I
3 CLAIBORNE ENRICEMENT CENTER LOUISIAN1 ENERGY SERVICES, L. P.
l EOMER, CLAIBORNE PARISE, LOUISIANh i
The degreasing unit to be used during the centrifuge asse: ably j
phase is an enclosed design equipped with condensing coils for j
vapor recovery.
I As a result of the First Circuit Court of Appeal's vacating Permit No. 0620-00057-00, the Department of Environmental l
j Quality expanded the Record of Decision and modified the permit to reflect new starting dates for construction and j
cperation.
The synopsis and data sheets are based on the i
application and Emission Inventory Questionnaire dated June 29, 1992.
l After completion of the construction phases, estimated air i
emissions from the facility in tons per year are summarized as follows:
j Pollutant En.1;.a i
PM o 0.3 i
SO 0.3 2
l NO, 2.6
}
CO 0.71 j
f VOC 0.09 l
CFC-113 9.5 l
CH 0.01 4
HF 0.007 l
i All four diesel storage tanks are equipped with submerged fill pipes.
Both 10,000 gallon diesel storage tanks shall comply with New Source Performance Standard 40 CFR 60.116b, of i
Subpart Kb-Standards of Performance for Volatile Organic Liquid Storage vessels (Including Petroleum Liquid Storage l
Vessels) for Which Construction, Reconstruction, or Modification Commenced after July 2,3, 1984.
.s i
LES shall comply with all applicable provisions of 40 CFR 61, j-of Subpart I-National Emission Standards for Radionuclide Emissions From Facilities Licensed by the Nuclear Regulatory i
l Commission and Federal Facilities Not Covered by subpart H.
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AIR PERNIT BRIEFING SEEET I
AIR QUALITY DIVISION LOUISIANA DEPARTNENT OF ENVIRONNENTAL QUALITY CLAIBORNE ENRICRMENT CENTER LOUISIANA ENERGY SERVICES, L. P.
l NONER, CLAIBORNE PARISE, LOUISIANA j
I i
IV.
TYPE OF REVIEW l
This permit was reviewed for compliance with the Louisiana Air i
Quality Regulations, New Source Performance Standards and NESHAP regulations.
Prevention of Significant Deterioration regulations do not apply.
q 1
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This facility is classified as a minor source with respect to Toxic Air Pollutants (TAP).
V.
PUBLIC MOTICE The proposed Permit No. 0620-00057-00 was public noticed, as detailed below, due to the public interest generated.
Notice of Joint Public Hearing of the Office of Air Quality and Radiation Protection and Office of Water Resources requesting written comments was published in the following newspapers on the dates indicated.
Newspaper Location Date Published The Advocate Baton Rouge October 6, 1994 Gardian Journal Homer October 6, 1994 Naynesville News Haynesville October 13, 1994 The Times Homer October 5, 1994 The Ruston Daily Leader Ruston October 6, 1994 The Gazette Farmerville October 14, 1994 Minden Press Herald Minden October 5, 1994 A Public Hearing was held in the Homer High School Auditorium in
- Homer, Louisiana on October 18, 1994, at 7:30 p.m.
Deadline for written comments to be received following the hearing was November 4, 1994.
Thirty-four (34) letters were received with comments.
These written comments and comments from persons present at the hearing were considered prior to a final decision on the proposed permit.
This modification does not require public notice since there is no change in emissions.
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SPECIFIC CONDITIONS CLAIBORNE ENRICHMENT CENTER LOUISIANA ENERGY SERVICES, L. P.
HOMER, CLAIBORNE PARISH, LOUISIANA 1.
Diesel Generator Fuel Tanks, Emission Point No. 005, shall comply with New Source Performance Standards, 40 CFR 60.116b, of Subpart Kb-Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage vessels) for Which Construction, Reconstruction, or Modification Commenced after July 23, 1984.
2.
Permittee shall comply with all applicable provisions of 40 CFR 61, Subpart I-National Emission Standards for Radionuclide Emissions From Facilities Licensed by the Nuclear Kegulatory Commission and Federal Facilities Not Covered by Subpart H.
Seh 9
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j LOUISIAMA AIR EKISSION PERMIT
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j GENERAL CONDITIONS l
I.
This permit is issued on the basis of the emissions reported in the application for approval of emissions and in no way guarantees that the design scheme presented will be capable of controlling the emissions to the type and quantities i
stated.
Failure to
- install, properly operate and/or maintain all proposed control measures and/or equipment as L
specified in the application and supplemental information l
shall be considered a
violation of the permit and LAC 33:III.501.
If the emissions are determined to be greater than those allowed by the perinit or if proposed control measures and/or equipment are not installed or do not perform according to design efficie.ncy, an application to modify the permit must be submitted.
l II.
The permittee is subject to all applicabla provisions of the Louisiana Air Quality Regulations.
Violation of the terms j
and conditions of the permit constitutes a violation of these regulations.
III.
The attached data sheets and/or Emission Inventory Questionnaire sheets establish the emission and operating 1
i limitations and are a part of the permit.
The synopsis and l
data sheets ' ara based on the application and Emission Inventory Questionnaire dated June 29, 1992. Details of the gaseous of11uent vent system (GEVS) have been extracted from the Safety Analysis Report (SAR).
As a result of the First i
circuit Court of Appeal's vacating the original permit, the Department of Environmental Quality expanded the Record of l
Decision and modified the permit to reflect new starting
~
dstes for construction and operation.
i e
IV.
This permit shall become invalid, for the sources not constructed, if:
A.
construction is not commenced, or binding agreements or contractual obligations to undertake a program of i
construction of the project are not entered into, within two (2) years (18 months for PSD permits) after issuance of this permit, or; B.
if construction is discontinued for a period of two (2) years (18 months for PSD permits) or more.
The administrative authority may extend this time period upon'a satisfactory showing that an extension is justified.
This provision does not apply to the time period between construction of the approved phases of a phased construction project.
However, each phase must commence construction within two (2) years (18 months for PSD permits) df its projected and approved commencement date.
9
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j LOUISIAME nIR FMISSION PERMIT
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j GENERAL CONDITIONS V.
The permittee'shall submit semi-annual rep. orts of progress i
outlining. the status of construction, noting any design l
changes, modifications or alterations in the construction schedule which have or may have an effect on the emission rates or ambient air quality levels.
These reports shall continue to be submitted until such time as construction is certified as being complete.
Furthermore, for any significant change in the design, prior approval shall be obtained from the Louisiana Air Quality Division.
VI.
The permittee shall notify the Department of Environmental Quality, Air Quality Division within ten (10) calendar days from the date that construction is certified as complete 1.nd the estimated date of start-up of operation.
'ib appropriate Regional Office shall also be so notified. within the same time frame.
VII.
Any emissions testing performed for purposes of demonstrating compliance with the limitations set forth in paragraph III shall be conducted in accordance with the methods described in the Division's test manual or any other methods approved by the U.S,.
EPA.
Any deviation from or modification of the methods used for testing shall have prior approval from the Louisiana Air Quality Division.
VIII.
The emission testing described in paragraph VII above, or established in the specific conditions of this permit, shall be conducted within sixty (60) days after achieving normal production rate, but in no event later than 180 days after initial start-up (or restart-up after modification).
The Air Quality Division Surveillance Section shall be notified at least (30) days prior to testing and shall be given the -
i opportunity to conduct a pretest meeting and observe the emission testing.
The test results shall be submitted to the Air Quality Division within forty-five (45) days after i
the complete testing.
As required by lac 33:III.913, the permittee shall provide necessary sampling port in stacks or j
ducts and such other safe and proper sampling and. tenting i
facilities for proper determination of the emission limits.
IX.
The permittee shall, within 180 days after start-up of each project or unit, report to the Louisiana Air Quality Division any.significant difference in operating anission rates as compared to those limitations specified in paragraph III.
This report shall also include, but not be limited to, malfunctions and upsets.
X.
The permittee shall retain records of all information resulting from monitoring activities and infornation indicating operating parameters as specified in the specific 10
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v l
LOUISIANA AIR EKISSION PERMIT l
GENERAL CONDITIONS j
conditions of this permit for a minimum of at. least five (5) j years.
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l XI.
If for any reason.the permittee does not comply'with, or will not be able to comply with,.the amicsion limitations specified in this permit, the permittee shall provide. the Air Quality Division with the following information in writing within five (5) days of such conditions:
A.
Description of noncomplying emission (s);
B.
Cause of noncompliance; C.
Anticipated time the noncompliance is expected to 4
l continue, or, if corrected, the duration of the period of noncompliance; l
l.
D.
Steps taken by the permittee to reduce and.elimina.te_
the noncomplying emissions; and i
E.
Steps taken by the permittee to prevent recurrences of
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l the noncomplying emissions.
l XII.
Permittee shall allow the authorized officers and employees I
j of the Department of Environmental
- Quality, at all reasonable times and upon presentation of identification, i
a i
to:
j l
A.
Enter upon the permittee's premises where regulated
)
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facilities are
- located, regulated activities are l
conducted or where records required under this permit j
are kept; j
B.
Have access to and copy any records that are required to be kept under the terms and conditions of this i
permit, the Louisiana Air Quality Regulations, or the l
Act; 1
l C.
Inspect any facilities, equipment (including monitoring j
methods and an operation and maintenance inspection),
or operations regulated under this permit; and, D.
Sample or
- monitor, for the purpose of assuring i
compliance with this permit or as otherwise authorized-by the Act or regulations adopted thereunder, any j
substances or parameters at any location.
l r.
j XIII.
If samples are taken under Section XII.D. above, the officer or employee obtaining such samples shall give the owner, 1
l operator or agent in charge a receipt describing the sample j
obtained.
If requested prior to leaving the premises, a portion of each sample equal in volume or weight to the 1
i portion retained shall be given to the owner, operator or agent in charge.
If an analysis is made of such samples, a l
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LOUISIAN& AIR ENISSION PERMIT i
GENERAL CONDITIONS
}
copy of the analysis shall be furnished promptly to the
)
owner, operator or agency in charge.
l XIV.
The permittee shall allow authorized officers an'd employees i
of
.the Department of Environmental
- Quality,
.upon.
i presentation of identification, to enter upon. the l
permittee's premises to investigate potential or alleged i
j violations of the Act or the rules and regulations adopted j
thereunder.
In such investigations, the permittee shall be notified at the time entrance is requested,of the nature of the suspected violation.
Inspections under this subsection shall be -limited to the aspects of alleged violations.
However, this shall not in any way preclude prosecution of 1
j all violations found.
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XV.
The permittee shall comply with the reporting requirements l
specified under IAC 33:III.918 as well as notification l
requirements specified under IAC 33:III.927.
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XVI.
In the event of any change in ownership of the source described in this permit, the permittee and the succeeding l
owner shall notify the Louisiana Air Quality Division, i
within ninety (90) days after the event, to amend this e
4 permit.
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XVII.
Typical emissions associated with routine operations that are under control upon release, that are predictable in nature, and that are quantifiable as described in this permit application, are considered authorized discharges.
1 Any significant deviation from the emissions specified in the permit application for such discharges, by event, shall be reported to the department according to IAC 33:I.3901.
Actual emissions resulting from such activities must be l
reported to the department on an annual basis.
These emissions are not reflected in the permit totals as they are short term and/or intermittent in duration and have no i
significant impact on air quality.
Examples of such events include but are not limited to cleaning equipment, startups, shutdowns, opening off-line equipment (dual units), and releases to control devices such as flares or incinerators.
This permit condition does not authorize the maintenance of a nuisance or a danger to public health and safety.
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A W
s AIR QUALITY DATA SEEET PAGE 1 CLAIBORNE ENRICBMENT CENTER LOUISIANA ENERGY SERVICES, L. P.
BORGR, CLAIBORNE PARISE, LOUISIAMA 1
Location of plant:-
15 UTM:
256.6 km E 3366.0 km N I
De2cription of location:
Anoroximatelv 5 mi. NE of Homer. LA. off I Hwy 9 Estimated starting date Estimated starting operation 1
]
cf construction January 1998 will begin June 2001 i
Type of Dispersion Calculations Used:
NA NEW X
OR MODIFIED EMISSION SOURCES Uranium Enrichment Plant 1
(Type of Source)
)
Emicsion operating Operating Schedule Point No.
Description Rate (Max)
H/D D/W W/Y or Tank Capacity 001 Unit 1 Stock (Geseous Eff tuent 52,590 cfm 24 7
52 vent & N, systems & WAC) i 1
002 Unit 2 Stack (N, Syster & WAC) 17,190 cfm 24 7
52 003 Unit 3 Stock (u, System & NVAC) 17,190 cfm 24 7
52 004 Stan6r Diesel Generator Day Tanks (2) 600 set each 24 7
52 i
i 005 Diesel Generater fuel Tanks (2) 10,000 set each 24 7
52 006 stan6y Dieset Generator Exhausts (2)
NA 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> per year 009 Diese! Emergency Psap (Fire Protection)
NA 0.5 1
52 010 Dieset Fust storspe Tank 100 set 24 7
52 6
(for Fire Protection system) l i
i
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b AIR QUALITY DATA CHEET PAGE 2 CLAIBORNE ENRICHMENT CENTER LOUISIANA ENERGY SERVICES, L.P.
HOMER, CLAIBORNE PARISH, LOUISIANA HAXIMUM/ AVERAGE EMISSION RATES ARE LISTED IN LB/HR Emis:: ion Permitted Emissions HEIGHT TEMP.
FLOW RATE Foint No.
'F CFM i
2 0.10/0.10 45.5/11.7 120 90 52,590 001 002 Nitrogen vent enty 120 90 17,190 003 Nitrogen vent enty 120 90 17,190 NA es6 tent NA
<0.001/<0.001 004 NA anblent NA 0.028/0.014 005 006 6.0/6.0 6.0/6.0 52.0/52.0 0.2/0.2 14.0/14.0 0.2/0.2 NA NA NA 009 0.2/0.2 0.2/0.2 2.3/2.3 0.23/0.23 0.5/0.5 NA NA NA NA anblant NA 4.001/<0.001 310 8
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AIR QUALITY DATA SEEET j
i PAGE 3 1
CLAIBORNE ENRICEMENT CENTER LOUISIANA ENERGY SERVICES, L. P.
BOMER, CLAIBORNE PARISE, LOUISIANA i
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Emicsion Permitted emissions are listed in tons per year.
j Paint No.
PM,
SO:
NOx VOC CO OTHER' i
I f
001 0.02 9.6 m
j ees 4.0, 005 0.06 006 0.3 0.3 2.6 0.01 0.7 009 4.01 4.01 0.06 4.01 0.01 i
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<0.001 T?t ts 0.3 0.3 2.6 0.09 0.71 9.6*
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' Includes 0 01 mothere 0.007 hydrogen fluoride, and 9.5 CFC 113.
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1 STATE OF LOUISIANA l
DEPARTMENT OF ENVIRONMENTAL QUALITY
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IN THE MATTER OF l
kndsiana Energy Services, LP.
Inadsiana Air Permit i
AIR PERMIT NUMBER:
i 0620-00057-01 l
i PROCEEDINGS UNDER THE i
ENVIRONMENTAL QUALITY ACT IA. R.S. 30:2001, et seg.
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HISTORICAL
SUMMARY
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Backymund On June 29,1992, the faussiana Deparonent of Environmental Quality (LDEQ), Office of Air
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Quality and Radiation Pmtection (OAQRP), neelved apermit application and Emission Inventory Questionnairs for a Louisiana Air Permit, fmm Iauisiana Energy Services, L.P. (LES) to condrud and operate the Gaiborne Enrichment Center (CEC). De U.S. Nuclear Regulatory Com=iccian (NRC) hasjuristietion over the ngulation ofthe radiological aspects ofthe pmposed facility.
The CEC, to be located in Gaiborne P6rish, on Parish Road 39, near Homer, will enrich uranium hexqfluoride (UF)for use in the commercial nuclearpower industry. Solidfeed non-endched wanlaan hexqfluoride (UF) contained in steel cylinde s with a "U concentmtion of appmximately 0.7%, pnsently amilablefmm a plant within the United States, will be enriched to 2% - 5% by physical separation accomplished thmugh a series ofgas centryuges, nefinal prodnet, enriched UFa, also a solid material stond in steel cylinden, will be housed in the Product and Feed Storage Ana until shipment to a conversion facility, and then to afacility where it is made intofuel.
Durin[the enrichment rmcess, in accordance with the pmposed NRC license, the "U is separated into pmduct sinam and tails stnam. ne tails sinam (depleted UF) is the reduced percentage af"U rangingfmm 0.20% to 0.34%. De tails,1520 cylinders overa 5-yearperiod, willalso be storedin steel cylinders on site outdoors at the Tails Stomge Area. Stomge cylinden will be supported by reinforced concrete chocks, and will not be stacked. Spacing of129ft' per cylinder will be pmvidedfor loading and unloading purposes. The cylinders will be tmnsported
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within thefaciuty on mobue clinder emnsporters. De Tails Stomge Area will be located south l
of the Separations Building.
Tails can be stored on site for a maximum of 15 years.
i Spectfleally, no cyunderflGed with depleted UFs shall be stored on site longer than 15 years f
foRowingplacement ofthat cyEnderin the depleted UF, storage area (12uisiana Energy Ser' vices l
Proposed License Condidens - Seaton 1.3 A letterfmm John W. N. Hickey, NRC to W. Howard l
Ameld, LES, dated Septaeber22,1992). Tails disposiden wig be conducted of-site at afacGity i
to be determined later by Louisiana Energy Services.
o De nanoni and disposition itf the depleted UF, (DUF) wlR include the connrsion ofDUFs to trinuantum actoxide (U,0) prior to disposal U,0, is a more stable physiochemicalform and more compadble, with nspect to aqfety, with long term disposiden of tails. LES indicated that i
the conrnrsion and disposiden of taus wiR be performed of-site at a non-LESfacGity. De
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eennexion of DUFs to U,0s wiE begin within 15 years ofinidadng enrichment at the proposed i
i facGity or efterpror'ueden of no mors than 80,000 tons of DUF,, whicheur occunfirst.
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De proposedfeeGity is planned to be located approzinnatelypre miles northeast of Homer, in Qaiborne ?>rish, on 70 acus of developed land in the center of a 442-acre site. Major i
structuns and areas of the pmposedfaciuty are the sepamtions building, centrifuge assembly buGding, ofics/ security building, standby dieselgenerator building, cylinder nctipt and dispatch
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building, feed andproduct stomge arwa, and tails stomge area. Facility boundaries include a l
150-foot bager of tnes along State Route No. 9 to the north, Lake Avalyn (15.52 acres) to the l
east, and Bluegi!! Pond (2.58 acns) in the southwestem portion. De nmainder of the pmperty is bounded by snes and bmsh.
m Pursuant to Fedem! Law, umalum enrichmentfaciuties are ngulated by the Nuclear Regulatory l
Commission (NRC). Jurisdicdon includes standardsforthe enrichment pmcess itself, associated i
i mdiadon lents, levels ofr=A'&n materials emitted to the air as a contaminant and the stomge l
and Anal disposidon of radioaedn materials, including r=Ai&ve waste (tails). Having i
completed the Sqfety and Envimamental enluadonforthefacility, the NRC is curnstly engaged in the Scensing process Dese standards and emission limits will be pmvidedfor in the NRC license. Federal authoritypreempts state regulation with regard to those aspects of the mdiation l
license c'enrod by the NRC. Statejurisdiction is limited to aspects of thefacility not ngulated l
by the NRC, Le., aonradlaectin discharges of emissions of contaminants to the air. Hence this airpermit addnsses only those issues not covered by the NRC license.
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h RECORD OFDECISION De Depannent of Envinamental Quality, ODice ofAir Quality and Radiation Protection issued j
LES afinal airpermitfor the CEC efecdve January 20,1995. However, byjudgement dated 1
April 4,1996, the First Circuit Court of Appeal vacated the pennit and nmanded the matter to the Department of Ensinamental Quality for further paceedings.
De Department of Envimamental Quauty neelved an August 2,1996 letter, with attachments,fmm the Sierm C2ab 12 sal D$ense Pkad, Inc. opposing the issuance of a consolidated Louisiana air permit to i
Louisiana Energy Services.
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Prior to issuing the air permit, LES' pennit application was thomughly nyiewed. A public l
hearing was held in Homer on October 18,1994. Public nodcesfor the digit permit andpublie i
hearing were published in the opfeial State newspaper and sit other area newsparen. Ik l
Depannent qf Envimamental Quality ncaired written and oral comments during the public comment period, and prepared a " Response to Comments", summarizing responses to the signflicant comments. De evidence in the ncord supports the Department's decision to issue l
the air permit for the pmposed facility. In connection with the decision by the Court, the Department of Envinnmental Quality, Opice of Air Quality and Radiation Pmtection has conducted a de novo review of that infonnation and remains of the opinion that afinalpermit should be issued to LESfor the CECfacilityfor the nasons setforth below.
I BAllIC FINDINGS OF FACT l
De troe primary efects of site prepamtion and plant construction on air quality are the l
construction phase fugitive emiss ens (dust and vehicle emissions) and the fugitive solvent l
emissionsfmm the degreasing unit to be used during the assembly of the centrifuges. Dese an tempomry, but will be addressed.
l Emissions fmm vehicles were independently estimated by' the U.S. Nuclear Regulatory l
Commission StqVandfound to be below the Envimamental Pmtection Agency de minimis levels, aflnding with which the Departmeat coneurs. Operatton of mobile equipment such as emaes andfmnt end loaden are not ngulated sourses at afacility.
i Dust genemtion will be minimized by techniques such as wetting, using containment methodsfor l
sandblasting, covering trucks when tmnsporting dusty material, promptly removing dusty material l
from paved mods, and pmmptly planting or covering bare areas once earthmoving activity is completed. Specific conditions for abatement of dust are not nonnally included in a pennit l
unless thefacility is engaged in dry bulk cargo tmnger, i.e. stomge and tmnsshipment ofgmins, j
orrs, coal, coke and/or cement; or the use of these materials in theirpmcesses.
Glomfluomcarbons are pennittedfor use in the degreasing process, and released as afugitive i
emissions. Glorofluomearbon (CFQ emissions would not have an adnise health effect, but may make a small contribution to the damage to the stratospheric c:ene layer. De degreasing 3
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unit to be used dudag the centrifuge assembly phase is an enclosed design equipped with condensing coils for n;por reconry. LES has identified Azarel
- 6000 and 9000 series as j
r potendalsubmitutesfori,1,24dchlorel,2,2-trifluoroethane(Frwon R-113). Axan!* components 1
are low nnporpressure aHphatic hydrocarbons that would limit the nicase of volatile organic i
compounds.
Uranium is the only radionedn material expected to be released and, as previously stated, its release is owgulated solely by the NRC. Mrs ars ten airpoGudon point sourses identilfed in the app 8caden. Arte of the point sources are dieselfuel storage tanks, subject to NefSource Performance Saandards because qftheir size, diesel)kel day tanks and a smaR diesel tankfor the JErr proceedon system. M day tanks and the sma0 diese! sankfor thefire protecdon system
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would qualif> as insignffleant sources since the pronsulgadon of LAC 33:111.501 in j
Novenaer 1994. Mse are adC lacInded as emission points in the remde because of expediency.
M two dieselgeneratore are the only large stadenary consbunden sources at thefaciuty, and ars perminedfor use in the ennt of a powerfailure. M pernsisted emission ratesfor these arefor l
actual operadng due only to make certain they are operadonal when emergency situadens occur.
Dnergency situadens cannot be andcipatedforpernahdngpurposes. Dis ispmvidedforin the reguladens as a subsdtuden for nornaal power genemting systems, assuming that no anore ensissions will be generatedfmm operadon of emergency equipment duringpower outages than from nornaal power genercting systems. M remaining emission points are the three plant stacks. Had this been a permit for a facility not innind with mdioactive material, a small source perunit would have been issued, since the lent of emissions is so low (less than 25 tons peryear of any regulated pollutant) and the emission points arefew. In this case, because of thepublic interrvt in thisfacility, the regularformat was used. Itpmvides mour detailregarsting the process andpoBuden contmis. Most sneau source permits are issued tofacilities with simple processes requiring mininnal contmis.
Mpotendaland realadurse environmental ep'ects ofthe Claibome Enrichment Center (CEC),
during operadon han been avoided to the maximum extent possible. Dis is due in part to the inherendy benign nature ofthefacGity and the gas enrichmentprocess that will take place thers, and in part to dorts to she the CEC in a locadon that is not especiaUy envimamentally sensidn.
Another contributingfactor is the dort to construct and operate thefaciGry according to the NRC Heense and the air pernsit to preclude the adnise impact upon the environment, the surrounding area and nearby residents.
Mitration and monitoring operations will guard against adverse air quality impact arid release of chemicals at levels which could be detrimentalto human health. Gasesfmm the UFaprocessing systems are routed through the gaseous efluent vent system (GEVS). It consists of a piping network which serves a0 ofthe UFaprocessing systems and opemtes at sub-atmospheric pressure.
DEpipling is connected tofin pamReifilter stations. Each is capable of handling 25% of the eBluent. Four are on line and the)(fth acts as stand-by. Each station consists of a 99.7% pre -
filter which remons particulates having a particle size greater than 5 miemns (p) and protects the high eBleiency particulate air (HEPA) filter. De gases next pass through the HEPA filter 4
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whkh nuores 99.97% umnium aemsols (mainly U0,F, panicles) having a particle she greater than 0.3p, then through the aeduced charcoalfilter whkh captures 99% ofthe hydafluoric acid (HF). Hydrogenfluoride detecton in the GEVS provide alarms at 5.0 ppm HF concentmtion to give a sqfety margin of100 times the allowable linksfor HF releases. De nmaining clean gases pass through one oftwo airfans (one acts as a spart), which maintain the sub-atmospheric pressure apstream of theJiker stadens, and are discharged via the vent stack. De stack is monkored to guard against the nisase of radionuc5 des.
ULTIMATE FINDINGS / CONCLUSIONS L
Rave the painadal and real adurar enviroannental <Wects of the proposed facuite been avoided to de sanzimam enrest pendfat YES: Considering the design of the pmpossdfaciuty with the controls described above, the Department of Environmental Qualityfinds that the potential and real adverse efects of the proposedfacility have been avoided to the maximum extentpossible. De controls which wig be employed are the same contals required by any other source with compamble potentials to emit in an attainment area wkhin the state. To reiterate, the Department'sjurisdiction is limited to emissions of nonradiological compounds, and to that extent, the emissions of thisfacility are no dWerentfrom any otherfacility with emissions of comparable magnkude.
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> r-r A--* are that the I-~-r c,.;,,.deks ne formert YES: De social and economic benefits of the CEC will be gained by the residents of the Claiborne Parish area, the ownen of thefaciuty, thefacility's employees, the LES customen, and American utility companies. Also, secondary social and economic benefits may be rulimi by nuclear utilides and their custemen, due to the presence of a U.S. based source of umnium enrichment.
As discussed above, specific air quality impacts willinclude the efects of site prepamtion, plant construction, and the operation phase. De impact during the construction phase is no dWerent from what it would befor anyfacility not engaged in an activity involving mdioactive materials.
Uranium is the only r=Al~4re material expected to be nicased and the state has nojurisdiction over r=Ai=4ve nicases. De statejurisdiction applies only to those aspects of thefacility not regulated by.the NRC. As stated above, at the levels thefacility will be permittedfor, there would be virtually no impact on air quality. Derefore, the positive impact which would accrue to the anafwm the stimulusprovided by economic growth would outweigh 'the enWierirnentalimpact.
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Air dare skaraann profedr gMck womM o#st more parecdon to the env&omment thaar de amsosed facGity wkhout madale cautaGiar somearhoansestal benefits?
NO: M reason for IMs prpject is get to provide akernadn enery sources or even to supply addidonal enero. M peini is to provide an skernadn source of enrichment for the esining nuclearpowerplants and an advanced, Mghly <0feirat technolog. Currently the only domestic t
source of enrichment is de US DOE using an older and enerv intensin gaseous dWusion technology. By providing an abernadn densesde source of enriched uranium and an updated technolov, IMrfeeGity couldfanraMy goet economics, l. e. the price of enrieked uranium, l
and enery consumpden needed to produce the enriched uranium. M other 'akernadus" argued (e.g. solar, geothermal, etc.) cannot de so. M only real "ahernadus' would be to nly upon the enriched uranium asaGaNefrom the European suppKerr (using both centrifuge and gaseous dWunion) orfrom theformer Soviet Union which has yet to be simwn to be a nGaNe sappuer.
Dear akernedrer do not acMen one pf thefundamental goals of the profeet:
an akernadn, gaMg, domente sourse of enriched uraniumfor U.S. utiudes, saing an advanced,
<0teient and environmentaRy benign technology.
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Arrnerr ahnramtre sheg pMeh womM o#ermore pratenton to the environnsent than the messaand facGity site wirAomt madale cartaging somemvironmental 6emeifts?
NO: Disfaci5ty wiu produce the same emissions, ngardless of where it would be located.
Since we determined that the emissions wiU have linde or no impact on the local air quality at this locadon, no akernadve site wouldprovide more environmentalprotection.
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Air ther* =Mpadar agespyrus wMch would o#er peory protecdon to de empirosasest dan de facGity as proposed without medale cartaGiar acaespironnuestal heme /kr?
NO: M permitted emissions an essential to the operation of the facility and cannot be eliminated completely. Howent, the controls requiredto meet regulatory nquinments, discussed 1
in the Basic Rndings wiu be employed. Mse an the same ngulatory requinments any other newfaciuty would han to meet.
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M Departnsent of Environmental Quality has performed an extensive review of the air permit
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applicadon for the uranium enrichment facility and nsponses to the Environmental Impact Questions. M Departmentfinds theprocedurrs proposed to be adequate to prevent unnecessary exposure to employees, the public, and to prevent potential nicase to the environment.
Nter considering the entin ncord in this matter and based on the findings henin, I have decided to grant an airpermit to Louisiana Energy ServicesQr the construction and operation
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of the Claiborne Enrichment Center.
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lb w $ W i M 1-l D6e
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' Gustave A. Von Bodungen, P.E' Assistant Secretary
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