ML20140H611

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Forwards NRC Consolidated Comments on Rtm Suppls for Paducah & Portsmouth Gdps.Comments Will Be Discussed During 970626 Conference Call
ML20140H611
Person / Time
Site: Portsmouth Gaseous Diffusion Plant, 07007001
Issue date: 06/16/1997
From: Yen-Ju Chen
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Eva Hickey
PACIFIC NORTHWEST RESEARCH CENTER
References
CON-FIN-J-5035 NUDOCS 9706180364
Download: ML20140H611 (14)
v • d • e


Text

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4 June 16, 1997 Ms. Eva Hickey Pacific Northwest National Laboratory l 2955 George Washington Way Richland, WA 99352

SUBJECT:

J5035, TASK #3 - NRC CONSOLIDATED COMMENTS ON THE RTM SUPPLEMENTS FOR THE GASEOUS DIFFUSION PLANTS (GDPs) l

Dear Ms. Hickey:

l l Enclosed are NRC's consolidated comments on the RTM Supplements for the Paducah and Portsmouth GDPs. Minor and editorial comments are marked up on the supplements. I i

We will discuss these comments in a conference call on June 26,1997, at 10:30 a.m. EDT.

During this conference call, please be prepared to discuss resoiutions of these comments and l

to determine the final deliverable date. '

If you have any questions, please contact me at 301-415-5615.

Sincerely, (Original /s/by)

Yen-Ju Chen Operations Branch Division of Fuel Cycle Safety i and Safeguards, NMSS Docket Files 70-7001 & 70-7002

Enclosures:

As stated DISTRIBUTION: /

Docket Files /

70-7001 & 70-7002 PDR,LPDR /

FCOB r/f FCSS r/f Tg (( hkh hk NMSS r/f g# .

l j YChen DOCUMENT NAME: RTM-COMM.LTR OFC FCOB (_. FCOB

, NAME YCheh W[hpidkfe/

DATE 06/4/97 06)k97

C = COVER E = COVER & ENCLOSURE N = NO COPY 9706180364 970616 ,

PDR ADOCK 07007001 C PDR I

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.c l UNITED STATES l g g NUCLEAR REGULATORY COMMISSION

Ms. Eva Hickey l Pacific Northwest National Laboratory l 2955 George Washington Way l Richland, WA 99352 l

l

SUBJECT:

J5035, TASK #3 - NRC CONSOLIDATED COMMENTS ON THE RTM SUPPLEMENTS FOR THE GASEOUS DIFFUSION PLANTS (GDPs) l

Dear Ms. Hickey:

Enclosed are NRC's consolidated comments on the RTM Supplements for the Paducah and Portsmouth GDPs. Minor and editorial comments are marked up on the supplements.

l l We will discuss these comments in a conference call on June 26,1997, at 10:30 a.m. EDT.

l During this conference call, please be prepared to discuss resolutions of these comments and to determine the final deliverable date.

If you have any questions, please contact me at 301-415-5615.

l ,

Sincerely,  !

W' - f-Y pn-Ju hen <

Operations Branch l Division of Fuel Cycle Safety l and Safeguards, NMSS Docket Files 70-7001 & 70-7002 ,

I Enciosures: As stated i

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,PORTSMOUTH SUPPLEMENT General

1. Make sure the Table of Content is correct, including the Table of Content for each section.
2. The presentation style and format between Paducah and Portsmouth Supplements are n ottle different. Try to make it consistent as practicable.
3. Font types and sizes should be consistent throughout the document. Use only one font type for the document. Different font sizes may be used for text, footnotes, tables, titles, etc., but make sure they are consistent.
4. The format should be consistent throughout the document. For example, the numbering system for figures, tables, and footnotes are different in each section.
5. Some sections have references at the end of the section, and some do not. All references should be listed in Section

12.0 REFERENCES

6. Consider using different color tabs for Facility sections (Section 2.0) and other sections, so that it is easier to find the needed information.
7. Make sure the references to other sections and page numbers are correct.
8. Check page numbers. Some of them are messed up.

Section 1.0 1 Indicate that Figure 1-1 is a flowchart for the NRC emergency response team. In addition, Figure 1-1 needs legend for solid and dotted lines.

Section 2.0

1. Throughout %ction 2, the text refers to Section 6.4.1 or Section 9.0 for additional information on criticality accidents. Which reference is correct? In addition, there is no Section 6.4.1.
2. Highlight the def ault source term values in the text or tables.
3. Sections 2.X.3, " Bounding Accident Consequences for UFu Release" tables, in several cases, the consequences for larger r6 tease are lower than the consequences for a smaller release. Explain the discrepancies. .

The distance of concern for HF, uranium intake, and radiation dose would probably be different. However, only one distance is provided in these tables. Is this value the most restrictive one?

Page 1 Comments on Portsmouth Supplement

4. Sections 2.X.3, the " Bounding Accident Consequences" tables for both UF, releases and criticality. The footnotes give values for " Protective Action Criteria (PAC)."

Provide references for these PAC values. If they are EPA values, indicate so.

Footnote (d) for these tables uses Protective Action Criteria (PAC). PAC is for l chemical releases and Protective Action Guidelines (PAG) is for radiological releases.

Should PAG be used rather than PAC?

l S. Sections 2.X.6, the " NOTE" box. The words " event" and " consequence" are either underlined or in Italic. Is it to highlight the information or is it an oversight? If it is j to highlight the information, make sure the markings are consistent.

6. Sections 2.13, 2.2.3, 2.3.3, and 2.4.3. The Portsmouth SAR (1996c) postulates l the worst case release rate of 130 lbs/sec, and 11,700 lbs of UF, could be released I before 10 mg U intake occurs at the site boundary. However, these sections have I more conservative results. Are the reasons for the discrepancy explained in Section 9.0 Technical Basis?
7. Sections 2.2.6 and 2.3.6. For the scenario "B-block Valve Closure Without l l Corresponding A-valve Closure." Both sections state that the amount of UF, released depends on operator response time. What is the reason for the different  !

l release amounts in these sections?

l

8. State in Sections 2.X.7 " Dose Versus Distance" the significance of using blue paper.

If a criticality event is not possible, indicate so in this section. Some sections already contain such information.

Indicate what is " stability class B-4," i.e. Paquill B with wind speed 4 m/s. Also briefly describe how does the consequence change with changes in stability class and wind speed.

The references of figure numbers and associated page numbers are inconsistent in this section. Downwind distance is provided in some cases but not in others. Such information (figure numbers, page numbers, and downwind distance) should be included as applicable.

i The downwind distance of HF for some UF, releases should be 16,000 m instead of 18,000 m.

For the " Uranium Intake" figures, the " Intake PAG" value is used as the reference.

Should it be " Intake PAC?" is it an EPA recommended value?

I

! Some " dose vs. distance" figures are not clear, e.g., the grid lines are fading. This l rnay be due to multiple duplications. Make sure the originalis clear enough for duplication.

9. Sections 2.X.8. Make sure all tables have a table number and a title.

Comments on Portsmouth Supplement Page 2

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Delete foc,tnote (b) from " Critical Safety Function Criteria" table. Since the column 1 already indicates the page number and reference, the footnote is not needed. j l

The title may lead people to think the tables are for criticality safety. Delete ]

" critical" from the title, so the new title reads " Safety Function Criteria." l l

Change the suctitle "UF, Confinement" to "UF Releases." l l

The " Mode of Operation" tables use information from SAR (1996a). However, some i descriptions of scenarios in Sections 2.X.6 use operational modes from SAR i (1996c). Make sure they are consistent by using the information from SAR (1996a). l l

10. Section 2.1, Table X-326-4, page 2.1-4. There are two footnotes (e). Should one of  !

them be footnote (f)? l

11. Section 2.1, Table X-326-8, page 2.19. The notation for footnote C is missing.
12. Delete Table X-326-13 on page 2.1-31. Building X-326 does not have the i freezer / sublimer system.
13. Section 2.5.6.2, page 2.5-8. According to Portsmouth, for the given scenario, the cylinder would solidify when 7,000 lbs of UF, were released.
14. Section 2.7 Figures X-342A-12 and X-342A-13 are not readable.
15. Section 2.9. Figures X-343-21 and X-343-22 are not readable.
16. Section 2.10. Consider to include 14-ton cylinder scenarios.

Figures X-344A-28 and X-344A-29 pre not readable.

17. Section 2.11, page 2.11-9. The .X-611 Ground Floor Plan does not appropriately reflect the X-611 complex, such as the location of X-611-E.
18. Figures X-705-5 and X-705-6 are not readable.
19. Figures X-710-1 and X-710-2 are not readable.
20. Figures X-720-1 to X-720-4 are not readable.
21. Section 2.24, DOE Facilities. Provide a brief description of each facility and hazardous materials. Such information should be consistent with the one provided in
Paducah Supplement.

1 Section 4.0

1. Section 4.1, under UFe. Check whether UF,is physically stored in X-300 building.

Comments on Portsmouth Supplement Page 3 l

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Figure 4 2, Portsmouth Gaseous Diffusion Plant Hazards Matrix. Make sure building nurnbers are clearly labeled and easy to read.

l 3. Figure 4-3. What is "UF, transfer location?" What is the difference between Figures j 4-2 and 4-3 in terms of UF, locations?

4. Figure 4-4 shows UFe detector locations in Building X-333. Is the layout similar for l Buildings X-326 and X-330? What is the direction for this figure?

i-l 5. Figure 4 7. Make sure building numbers are clearly labeled and easy to read. Clean I up the blocke showing population density. The population table is sufficient to show the number of people in each building.

l 6. Tables 4-5 and 4-6 should be used together with Figure 4-19.

i Section 5.0 l 1. Sections 5.1.1.2 and 5.1.1.3.a. Clarify that PSS, APSS, or designee, may respond to the incident as the IC. In addition, the IC does not classify the event, only the l Crisis Manager can formally classify an emergency.

2. Table 5-5, page 5-18. Provide the publication years to the references.
3. Table 5-6, page 5-18. For health effect "50% will die," indicate how 50% will die, e.g., from kidney failure.

l 4. Delete 1-131 from Table 5-8, page 5-20, since it is not applicable to GDPs. Clarify i the references to the table. Perhaps use RTM-96 as the reference.  !

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. 5. Figure 5.5, page 5-26. Clarify whether the population within 3 miles of the site q l < includes personnel working at Ohio National Guard and/or Defense Logistics Agency offices.

l 6. Update Figures 5-1 and 5-2. (Copies of the revision will be provided)

Section 6.0 l 1. .in Section 6.4, discuss why 12-inch concrete thickness was used for the radiological l calculations.

i l Clarify in the first paragraph that much more than 15 grams U-235 is required for I

criticality. This amount is the " trigger," beyond which NCS evaluation is required per the SAR.

2. The third paragraph in Section 6.5 implies that all three chemicals (chlorine, chlorine trifluoride, and fluorine) are managed under Process Safety Management. The only chemical which exceeds TO and is managed per 29 CFR 1910.119 is chlorine.

a Comments on Portsmouth Supplement Page 4

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' 3. Provide source / reference for Figure 6-1.  ;

Section 8.0 i

1. Figure 8-1. Clearly label the footnotes in the figure. What is the unit for the blocks?

Section 9.0

1. What is the rationale for using one-hour for exposure assumption? PGDP SAR used NIOSH/ OSHA 30-minute exposure. Besides, the odor threshold for HF is very low ]

(0.033 - 0.133 ppm), it is hard to image anyone would stay in this environment for a j few minutes. l l

2. The model seems to assume that all UF is carried out with the UF, plume and no UF is deposited out. Studies indicate that a large percentage of the UF would not be carried up and would be deposited close to the release point. I
3. HGSYSTEM/UF,is a suite (or a systerr) of five separate and distinct atmospheric dispersion models that can be run independently. The model suite also includes many pre- and post-processors. Do not refer to the model suite as the HGSYSTEM/UF, model or HGSYSTEM/UF, code.
4. Section 9.2.2.3, page 9-6. Equation 1, C,2T, = Ci ,2T ,, is confusing. T .n, i i may lead people to think the value should be in hours instead of seconds. Change the equation to C2T = C,2To . Indicate C is the computed concentration for what  ;

chemical. j

5. Section 9.2.2.3, page 9-7. The reference for the dose conversion factor should be referenced using DOE,1988 (DOE /EH-OO71).

Indicate the specific activity is for O.35% (tails assay) material and may be I somewhat low for cascade, transfer, and product withdrawal facilities. The l reference for the spa should be CSET 1996 (ES/CSET-2A), equation on page 17, Appendix E.  !

6. Section 9.2.3. Change fA to fa.
7. Section 9.2.3.2, page 9-10, under *HEGADAS/UFe." Area source releases are applicable for some UF, releases, such as spills of solid UF, from a ruptured storage cylinder.
8. Section 9.2.3.2, page 9-12, under " Stack Release Assessment using WAKE." The justification for not using lateral vent dispersion is not clear as written. Revise the ,

j reasons as: (1) not using lateral dispersion is conservative (i.e., resulting in higher i

consequence estimates) and (2) using lateral dispersion adds to modeling simulation complexity.

Comments on Portsmouth Supplement Page 5

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l Under " WAKE Model Runs for Cascade Releases," the WAKE runs were for Paducah C-337 building, which is similar to ?e X-333 building at Portsmouth. j

9. Section 9.2.3.2, page 9-14. The "fracoon of air leaving the roof" actually refers to the fraction of air leaving the unit by the roof vents compared to the motor exhausts l ducts.

]

DISCOMP divides all the released air from a unit between three representative vents (two roof and one motor exhaust) maintaining the release velocity. State this so I that it is clear why the release rates and vent sizes were redefined. J

10. Table 9-7, page 9-22. Should the ambient temperature be 70"F? j i
11. Section 9.2.3.2, page 9-24. Use 0.001 for f, value is not sufficient for range of releases. Other values should have been used in some cases. Provide more ,

l discussion and data on the effects of fx.  ;

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12. There is no dispersion modelin HGSYSTEM/UFe that is called " Mixer."

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13. Section 9.3.6, page 9-30. Provide the release rate for all chemicals.

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i Comments on Portsmouth Supplement P' age 6 i

,PADUCAH SUPPLEMENT '

General

1. Make sure the Table of Content is correct, including the Table of Content for each section.
2. The presentation style and format between Paducah and Portsmouth Supplements are a little different. Try to make it consistent as practicable.
3. Font types and sizes should be consistent throughout the document. Use only one font type for the document. Different font sizes may be used for text, footnotes, tables, titles, etc., but make sure they are consistent.
4. The format should be consistent throughout the document. For example, the numbering systern for figures, tables, and footnotes are different in each section.
5. Some sections have references at the end of the section, and some do not. All references should be listed in Section

12.0 REFERENCES

l

6. Consider using different color tabs for Facility sections (Section 2.0) and other sections, so that it is easier to find the needed information.
7. Make sure the references to other sections and page numbers are correct.
8. Check page numbers. Some of them are messed up.  ;

J Section 1.0 l

1. Indicate that Figure 1-1 is a flowchart for the NRC emergency response team. In addition, Figure 1-1 needs legend for solid r.nd dotted lines.

Section 2.0 l

1. Some sections do not always contain the complete reference to page numbers. For example, the text shows "pages ## to ##."

l Throughout Section 2, the text refers to Section 6.4.1 or Section 9.0 for additional 2.

information on criticality accidents. Which reference is correct? In addition, there is no Section 6.4.1.

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3. Highlight the default source term values in the text or tables.

1

4. Sections 2.1.2, 2.2.2, 2.3.2, and 2.4.2. The Paducah SAR (1996c) states that the 1 maximum inventory of a "000" cell at maximum power is 11,000 lbs at 3040 MW.

What are the bases for the values in the Supplement?

1 e

Comments on Paducah Supplement Page 1 1

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5. Sections 2.X..', " Bounding Accident Consequences for UF, Release" tables. In l several ca%s, the consequences for larger release are lower than the consequences for a smaller release. Explain the discrepancies. 7 l The distance of concern for HF, uranium intake, and radiation dose would probably be different. However, only one distance is provided in these tables, is this value the most restrictive one?  !

l '

l 6. Sections 2.1.3, 2.2.3, 2.3.3, and 2.4.3. The Paducah SAR (1996c) postulates the l worst case release rate of 130 lbs/sec, and 11,700 lbs of UF, could be released  ;

before 10 mg U intake occurs at the site boundary. However, these sections have

! more conservative results. Are the reasons for the discrepancy explained in Section -

9.0 Technical Basis?

i

7. Sections 2.X.3, the " Bounding Accident Consequences" tables for both UF, releases and criticality. The footnotes give values for " Protective Action Criteria (PAC)."

Provide references for these PAC values, if they are EPA values, indicate so.

Footnote (d) for these tables uses Protective Action Criteria (PAC). PAC is for chemical releases and Protective Avtion Guide!!nec (PAG)is for Miological releases. ,

Should PAG be used rather than PAC?

8. Sections 2.X.6, the " NOTE" box. The words "cvent" and " consequence" are either underlined or in Italic. Is it highlight the information or is it an oversight? If it is to highlight the information, make sure the markings are consistent.
9. Sections 2.1.6, 2.2.6, 2.3.6, and 2.4.6. Provide reference and basis for the release amounts. The values are not consistent with Paducah SAR (1996c). For example, the release amount for " coolant tube rupture"is assumed to be 11,000 lbs in the SAR (1996c), while the supplement value is assumed to be 5,000 lbs.

For the scenario "B-block Valve Closure Without Corresponding A-valve Closure."

All sections state that the amount of UF, released depends on operator response time. What is the reason for different release amounts in these sections?

10. State in Sections 2.X.7 " Dose Versus Distance" the significance of using blue paper, if a criticality event is not possible, indicate so in this section. Come sections already contain such information.

Indicate what is " stability class B-4,"i.e. Paquill B with wind speed 4 m/s. Also briefly describe how does the consequence change with changes in stability class

! and wind speed.

l l The references of figure numbers and associated page numbers are inconsistent in I this section. Downwind distance is provided in some cases but not in others. Such information (figure nurnbers, page numbers, and downwind distance) should be included as applicable.

Comments on Paducah Supplement Page 2 l

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The downwind distance of HF for some UF, releases should be 16,000 m instead of 18,000 m.

l l For the " Uranium Intake" figures, the " Intake PAG" value is used as the reference.

Should it be " Intake PAC?" is it an EPA recommended value?

l j Some " dose vs. distance" figures are not clear, e.g., the grid lines cre fading. This i may be due to multiple dup!! cation. Make sure the originalis clear enough for  !

duplication. I 1

11. Sections 2.X.8. Make sure all tables have a table number and a title.

Delete footnote (b) from " Critical Safety Function Criteria" table. Since the column already indicates the page number and reference, the footnote is not needed.

i The title may lead people to think the tables are for criticality safety. Delete

" critical" from the title, so the new title reads " Safety Function Criteria."

Change the subtitle "UF, Confinement" to "UF, Releases."

The " Mode of Operation" tables use information from SAR (1996a). However, some descriptions of scenarios in Sections 2.X.6 use operational modes from SAR i

- (1996c). Please make sure they are consistent by using the information from SAR (1996a).

i

12. Section 2.5.2 lists CIF 3as a hazardous material, but it is not discussed in Table C- i 310-3.
13. Section 2.5.3, Table C-310-1. The emergency classification level for the 10-ton

! cylinder valve failure scenario is listed as a Site Area Emergency, whereas the PGDP j EAL for this event is an Alert. Explain the discrepancy. '

14. Section 2.5.7 indicates that the calculations weie performed for UF, release of 200 .

and 1,000 lbs. However, the section contains figures for 200 and 10,000 lbs. Is it I a typo or are the consequences calculated from the wrong release amount?

15. Section 2.7.2, page 2.7-1. Does the amount of UF,in this summary address the j material housed in the 20,000 ft3 Hortonspheres?  !
16. Section 2.8.6 did not provide any UF, release scenario. However, UF, release is  !

possible from feed facilities, such as UF,line break ouNde autoclave or drop of heavy loads, in addition, Section 2.8.7 contains figures for UF, releases.

17. Section 2.14 did not discuss Building C-410-K. Description of F, f acilities should l

include the quantity of F2 cylinders allowed in C-410-K. l l 1

18. Section 2.15 discusses the use of criticality alarms. Note that C-745-H cylinder yard I does not have CAAS.

1 Comments on Paducah Supplement Page 3 l

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' 19. Section 2.16. Indicate this is not a complete list of DOE facilities. Also include C- ,

360 and its description in this section.

1 Section 4.0 i

l 1. Figure 4-7. Make sure building numbers are clearly labeled and easy to read. Clean

{

l up the blocks showing population density. The population table is sufficient to show l the number of people in each building. ,

2. Figure 4-14, Risk / Probability Matrix, should be used together with the " Hazard
- Rating and Consequence Definitions" and " Probability Rating Scale" tables. '

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! 3. Figure 4-18. What is "UF transfer location?"

Section 5.0 l 1. Sections 5.1.1.2 and 5.1.1.3.a. Clarify that PSS, APSS, or designee, may respond to the incident as the IC. In addition, the IC does not classify the event, only the Crisis Manager can formally classify an err.argency.

1

2. Section 5.1.1.3.d, the last sentence in the first paragraph. It indicates that the l duties and responsibilities are addressed in Section 9. However, Section 9 of the supplement does not contain such information. j
3. The event classifications for several EALs in Table 5 2 are different from the PGDP EALs.

I

4. Table 5-5, page 5-23. Provide the publication years to the references.
5. Table 5-6, page 5-24. For health effect "50% will dic," indicate how 50% will dic.

e.g., from kidney failure.

6. Delete 1-131 from Table 5-8, page 5-26, since it is not applicable to GDPs. Clarify the references to the table. Perhaps use RTM-96 as the reference.
7. Update Figures 5-1 and 5-2. (Copies of the revision will be provided)
8. The form in Figure 5-4 is not available in the supplement. Is this the form in l Portsmouth Supplement Figure 5-47 l

Section 6.0

1. In Section 6.4, discuss why 12-inch concrete thickness was used for the radiological l l calculations. l Clarify in the first paragraph that much more than 15 grams U-235 is required for criticality. This amount is the " trigger," beyond which NCS evaluation is required per Comments on Paducah Supplement Page 4 i i l

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1

the SAR.

2. The third paragraph in Section 6.5 implies that all three chemicals (chlorine, chlorine trifluoride, and fluorine) are managed under Process Safety Management. The only chemical which exceeds TQ and is managed per 29 CFR 1910.119 is chlorine.
3. Provide source / reference for Figure 6-1.

Section 8.0

1. Figure 8-1. Clearly label the footnotes in the figure. What is the unit for the blocks?

Section 9.0

1. What is the rationale for using one-hour for exposure assumption? PGDP SAR used NIOSH/ OSHA 30-minute exposure. Besides, the odor threshold for HF is very low (0.033 - 0.133 ppm), it is hard to image anyone vuould stay in this environment for a few rninutes.
2. The mode! seems to assume that all UF it. cmued out with the UF, plume and no UF is deposited out. Studies indicate that a large percentage of the UP would not be carried up and would be deposited close to the release point.
3. HGSYSTEM/UF,is a suite (or a system) of five separate and distinct atmospheric dispersion models that can be run independently. The model suite also includes many pre- and post-pr.ocessors. Do not refer to the model suite as the HGSYSTEM/UF, model or HGSYSTEM/UF, c. ode.
4. Section 9.2.2.3, page 9-6. Equation 1, C,2T, = C i.n,4 3 .n,,

is confusing. T .n, i may lead people to think the value should be in hours instead of seconds. Change the equation to C2T = C,2T,. Indicate C is the computed concentration for what chemical.

5. Section 9.2.2.3, page 9-7. The reference for the dose conversion factor should be DOE,1988 (DOE /EH-0071).

Indicate the specific activity is for 0.35% (tails assay) material and may be somewhat low for cascade, transfer, and product withdrawal facilities. The reference for the spa should be CSET 1996 (ES/CSET-2A), equation on page 17, Appendix E.

6. Section 9.2.3. Change f A to f,.
7. Section 9.2.3.2, page 9-10, under "HEGADAS/UFe." The area source releases are I applicable for some UF releases, such as spills of solid UF, from a ruptured storage cylinder.
8. Section 9.2.3.2, page 9-12, under " Stack Release Assessment using WAKE."

Comments on Paducah Supplera. t Page 5 l

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6, Revise the justifications for not using lateral vent dispersion as: (1) not using lateral dispersion is conservative (i.e., resulting in higher consequence estimates) and (2) using lateral dispersion adds to modeling simulation complexity.

Under " WAKE Model Runs for Cascade Releases," the WAKE runs were for Paducah C-337 building, which is similar to the X-333 building at Portsmouth.

l 9. Section 9.2.3.2, page 9-14. The " fraction of air leaving the roof" actually refers to

! the frar: tion of air leaving the unit by the roof vents compared to the motor exhausts ducts.

DISCOMP divides all the released air from a unit between three representative vents i (two roof and one motor exhaust) maintaining the release velocity. State this so that it is c! car why the release rates and vent sizes were redefined.

10. Section 9.2.3.2, page 9-17, under " WAKE Model Runs for Toll Transfer and Withdrawal Facility Releases." The toil transfer building (C-360) has six roof vents at 47,150 cfm each. Was this scenario modeled correctly?
11. Section 9.2.3.2, page 9-23. Use 0.001 for fa value is not sufficient for range of releases. Other values should have been used in some cases. Provide more discussion and data on the effects of fx.
12. Table 9-7, page 9-23. Should the ambient temperature be 70*F?
13. There is no dispersion modelin HGSYSTEM/UFe that is called " Mixer."
14. Section 9.3.6, page 9-28. Provide the release rate for all chemicals.

Comments on Paducah Supplement Page 6

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