ML20148L150
| ML20148L150 | |
| Person / Time | |
|---|---|
| Site: | Wood River Junction |
| Issue date: | 10/27/1978 |
| From: | Bowers C UNITED NUCLEAR CORP. (SUBS. OF UNC, INC.) |
| To: | Rouse L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| CEB-78-206, NUDOCS 7811200141 | |
| Download: ML20148L150 (11) | |
Text
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CORPOR/ATION 98 OCI 30 hI" "W """ "
TELEPHONE 401 304 7701 October 27, 1978 CEB 78-206 g,y
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i' U. S. Nuclear Regulatory Commission g
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L.
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Rouse, Chief f
g' ~' gyn Fuel Cycle and Material Safety Branch
\\C' MAIL MCP:N 7915 Eastern Avenue P X KET O M Silver Spring, MD 20910 g
&\\'t o Gentlemen:
In response to questions asked in telephone conversations of October 2nd and 3rd, 1978 between Mr.
R.
L.
Stevenson of your office, and Messrs. Schultz and Cronin of Fuel Recovery Operations, United NucleaI Corporation, we attach the following:
1.
A list of the current pages (and sections) now in review for this license (SNM 777, docket 70-820).
This list includes those pages revised as a result of the telephone conversations of October 2nd and 3rd.
2.
Formal statements that the process information provided for this amendment is no longer considered proprietary, and that on-site burial of treated waste is not considered as part of this amendment, j
3.
Added pages to section 925.17 regarding the Fire Safety aspects of the extraction process.
4.
A revised page for section 407.1 which provides for a l
single action limit for stack exhaust monitoring.
l I
Should you need any further information to complete your review and approval we will respond promptly.
Very truly yours,
' UNITED NUCLEAR CORPORATION l
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9.g e 63 C. E. Bowers 5
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General Manager Fuel Recovery Operation CEB:DFC:cag 7811200Wl-Attachments s
ATTACHMENT TO CEB 78-206 Page 1 ANSWERS TO QUESTIONS ASKED DURING TELEPHONE CONVERSATIONS BETWEEN R.
L. STEVENSON OF USNRC AND D.
M.
SCHULTZ AND D.
F.
CRONIN OF UNC-FRO Question No. l ~.
Please provide a list of current effective pages involved in the request for an amendment requested by letter C. E. Bowers to L.
C.
Rouse March 22, 1978 Answer:
The following correspondence concerned this pro-posed amendment:
C.
E.
Bowers to L.
C. Rouse March 22, 1978 CEB 78-38 C.E. Bowers to L.
C.
Rouse May 10, 1978 CEB 78-84 C.
E. Bowers to L.
C.
Rouse May 12, 1978 CEB 78-89 C.
E. Bowers to L.
C.
Rouse May 12, 1978 CEB 78-90 C.
E. Bowers to L. C.
Rouse Sept. 21, 1978 CEB 78-171 C.
E. Bowers to L.
C. Rouse Oct. 13, 1978 CEB 76-192 List of current effect!.ve pages:
Section Title Page No.
Date None General Table of Contents 1
5-10-78 100 Table of Contents 1
5-10-78 100 List of Figures 1
5-10-78 100 General Information Part 101 Corporate Information 1
5-10-78 100 Part 102 Location and Layout 1
5-10-78 100 Part 103 Summary of Activities 1
5-10-78 100 Part 104 Special Nuclear and Source 1
5-10-78 Material Possession Limits 100 Part 102 Sketch No. 102-I No page #
5-10-78 Location and Layout 100 Part 102 Sketch No. 102-II No page #
5-10-78 Location and Layout 400 Part Table of Contents 1
Not Dated1 Part 404 Facility & Equipment 1,la 9-21-78 Requiremen ts 1
Part 406 Surveillance 3
Part 407 Airborne and Liquid Effluent y
Monitoring 1
4 407.1 Airborne Effluent 1
10-27-78 407.1 Airborne and Liquid Effluent y
Monitcring 2
Not Dated 407.1 Sketch 407.1-I 1
Exhhust Stack Locations No page #
1 Should be dated 5/12/78 4 This page is included as an attachment to this letter.
ATTACHMENT TO CEB'78-206 Page 2 Section Title Page No.
Date 400 (con tinue d)
Part 407.1 Sketch 407.1-Ia Table of Exhaust Rates No page #
Not Dated 407.1 Sketch 407.1-Ib 1
Table of Exhaust Rates No page #
Part 407.2 Liquid Effluent Control 1
5-10-78 407.2 Liouid Effluent Control 2
5-10-78 2
407.2 At5achment to Part 407.2 1,2,3,4 Not Dated 407.2 Liquid Effluent Control 3
5-10-78 4
5-10-78 5
5-10-78 6
5-10-78 2
407.2 Exhibit A 1,2,3,4,5,6 Not Dated (letter to UNC dated 2/20/78) 407.2 Liquid Effluent Control 7
5-10-78 407.2 Sketch 407.2-I No page #
5-10-78 Liquid Waste Effluent Streams Sketch 407.2-II No page #
5-10-78 Lime Treatment Schematic Sketch 407.2-III No page #
5-10-78 Test Wells 1
Part 408 General Environmental 1
Not Dated Monitoring 1
408.1 General Environmental 1
Monitoring (Groundwater Monitoring) l 408 Metaorlogical Monitoring 2
900 Recovery Operations 4
Part 925.11 Waste Lagoons 3
10-27 -78 3
Waste Lagoons 4
10-13-78 4
Waste Lagoons 5
10-27-78
) Sketch 925.ll-I No page 35 5-10-78 Waste Lagoons 6
Ske tch 92 5. ll-II No page #
5-10-78 Waste Lagoons 2
Drawing MI-092-1 No page #
Not Dated Plan and Profile (drawing date 12/14/77) 2 Drawing MI-092-2 No page #
(drawing dated 12/19/77) 2 Drawing MI-092-3 No page #
(drawing dated 12/20/77 2
Drawing MI-092-4 No page #
(drawing dated 12/20/77) 1 Should be dated 5/12/78 2
Should be dated 5/10/78 3
These pages were substituted for the 5-10-78 version by letter dated 10-13-78, C.
C.
Bowers to L.
C.
Rouse, CEB 78-192 4
This page is included as an attachment to this letter.
5 Should be page 1.
6 Should be page 2.
i ATTACHMENT TO CEB 78-206 Page 3 Section Title Page No.
Date 900 (continued)
I Part 925.11 Sketch 925.ll-III No page #
10-13-78 (Above ground storage tank)
Sketch 925.ll-IV No page #
10-13-78 (Typical Staypost for Wall Retainer) 900 Part 925.17 Reclamation of Lagooned 1
5-12-78 Residues 2
5-12-78 3
5-12-78 4
5-12-78 4
5,5a 10-27-78 1 Sketch 925.17-I No page #
Not dated 1
D:.ving MI-094-4 No page #
(dated 3-17-78) 1 Drawing MI-094-3 No page #
(dated 3-13-78 1
Drawing MI-094-2 No page #
(dated 3-14-7 8) 1 Drawing IE-094-1 No page #
(dated 3-14-7 8)
Question No.
2.
Provide justification for onsite burial as landfill as described in Section 400, Part 407.2.3, Page 6 of the submission on 3/22/78.
Answer:
The request for burial made in the 3/22/78 letter was removed and replaced by pages submitted with our letter of May 10, 1978, and by deletion of a similar paragraph on page 5 of Section 925.11 sub-mitted with this letter.
- Question No.
3.
The letter of March 22, 1978 requested that certain process information be withheld from the public documen t room as proprietary information.
Answer:
The transmittal letter of March 22, 1978 was replaced entirely by the letters sent on May 10, May 12 (2),
1978.
The information presented in support of this proposed license revision is no longer considered to be proprietary.
The original request made in our March 22, 1978 letter is hereby formally withdrawn.
I Should be dated 5/12/78 4 These pages are included with this letter.
ATTACHMENT TO CEB 78-206 Page 4 Question No.
4.
Please complete the fire control and prevention information, describing the solvent's properties and the fire prevention and control measures.
Also describe measures taken to avoid hazardous nitration.
Answer:
Dage 5, Section 900, Part 925.17.2 as submitted with the May 12, 1978 letter (CEB 78-90) has been revised to expand the section on fire safety and is attached to this letter.
This change describes the normal extractant as Tributyl Phosphate which has a flash point of 295F, boils at 560F with a specific gravity of 1.0.
It has a health rating of 2, a flammable index of 1 and a reactivity index of zero (reference Fire Protection Guide on Hazardous Materiale, 3rd edition, 1967).
The carrier for this extractant is kerosene, with a flash point of 100F, ignition temperature of 410F, boils between 304-574F, and has a health index of zero, flammable index of 2, and a reactivity of zero (same reference).
The safety precautions which are normally required in the extraction area include:
a limit of 200 gallons of extractant in equipment, with bulk storage external to the building; no smoking; no open flames; and portable fire extinguishers.
These may be changed only by a specific safety review and authorization such as a safety work permit for routine maintenance or equipment repair, or an NIS authorization for equipment changes.
The used extractant is treated with sodium carbonate as a final wash before it ia re-used as a part of the process.
Thic treatment is designed to remove nitrates or products of nitration.
The same system has been in use in the present extraction process for some fourteen years, without any evidence of hazardous nitration.
Changes in these process chemicals are given an internal review.
Materials having hazard indices equal to or less than those listed above would be accepted without additional precautions.
If the hazard indices are greater, or unknown, then the added precautions needed would be determined by a literature search or by laboratory tests.
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l ATTACllMENT TO CEB 78-200 Page 5 Question No.
5.
On page 1, part 407.1, the action limits and cor-rective action to be taken need to be more specific.
Answer:
An explanatory paragraph has been inserted on this page defining the difference between a regulatory (or license) limiting value, and an internal action level.
An internal action level is always less than the limiting value.
It is established to improve internal controls, and assure that the regulatory (or license) limit is not exceeded.
The required documentation when a regulatory limit is exceeded is established by regulation; when an internal action level is exceeded, the documentation required is established by internal procedure.
Similarly, the corrective action required to prevent a recurrence must be more definite and positive when a regulatory limit is exceeded.
Plexibility to try different corrective actions may be allowed when an internal action level is exceeded.
These internal action levels are established to maintain levels "As Low As Reasonably Achievable".
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UNITED NUCLEAR l
C O R P O N A_
T l- 0 N
' FUEL RECOVERY OPE R ATIO N SNM 777 DOCKET 70-820 SECTION 400 HEALTil PHYSICS STANDARDS Prepared oct. 27, 1970 PART 407 AIRBORNE AND LIQUID EFFLUENT MONITonInn USNRC approval 407.1 Airborne Effluent
-Airborne effluent from each process exhaust stack will.be sampled continuously while the stack is in operation.
The maximum allowable concentrations and the averaging periods I
shall not exceed those specified in Title 10 Part 20 of the l
Code of Federal Regulations.
The volumes and concentrations are combined, weighing each concentration and flow rate to determine the average concentrations and total discharge (exhaust stacks are shown in Sketch 407.1-I which is a plan view).
This is equivalent'to physically combinio: a very low flow but high concentration duct with a very nigh flow but low concentration duct, It is preferable to sample each i
duct and control each system separately rather than combine several stacks and sample the composites.
In order to maintain levels "As Low as Reasonably I
Achievable" (ALARA), internal action levels (AL) are set j
below regulatory '(or licensed) limits for total microcuries released per week.
Tables 407.1-IA and B list the present exhausts, their flow rates, and the equipment serviced.
The following criteria apply:
1.
The total quantity. released per week shall not exceed 25 microcuries (alpha) per week.
2.
Emitted concentrations of radioactive particulates shall be controlled so that the overall average of all exhausts does not exceed the 10CFR20 level.
3.
Each operating exhaust stack shall be sampled continu-ously in a representative manner, and analyzed for gross alpha radioactivity.
l 4
Continuous fenceline sampling shall be provided.
Samples l
shall be analyzed for gross alpha radioactivity.
l 5.
Action levels may be changed by the authority of the Manager, Nuclear and Industrial Safety.
6.
Corrective action rhall be implemented as follows:
l a.
If internal action levels are exceeded, this shall be documented by the Nuclear and Industrial Safety
(
Department and brought to the attention of the l
operating group, l
b.
If a regulatory (or licensed) limit is exceeded, l
a written evaluation, stating that the problem l
causing the deviation has been identified and cor-rected, shall be prepared immediately after correction.
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6
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M n. UNITED NUCLEAR C O H P O H A T i O N FUEL RECOVERY O P E R A T I O_N SNM 777 DOCKET 70-820 Page 3
900:
RECOVERY OPERATIONS Pr e p a re d Oct. 27, 197 8 PART 925.11:
WASTE LAGOONS USNRC approval 925.11 Waste Lagoons General Description The waste lagoons are located within the fenced area sur-rounding the Fuel Recovery Operation.
Processed materials from which urt aium has been recovered are transferred to these lagoons, after a final analysis has been made for uranium content and after neutralization of free acids.
Release of material (up to 30 parts per million of U-2 35) to waste retention is allowed by signature of the Super-visor, Production; release at U-235 levels between 30 and 100 parts per million requires written approval of the Manager, Operations.
Each lagoon or holding pond has a watertight lining; Hypalon (trade name) or equivalent material is used.
Older (pre-1977) lagoons used overlapping polyethylene plastic sheets as liners.
The newer lagoons use the Hypalon material and are nr: row in design to avoid the need for field-closing of seams.
The lagoons installed in 1977 allow for settling in each trench, with overflow of supernate (with progressively fewer solids) into the next trench.
When sufficient solids have accumulated, they may be transferred to other ponds and allowed to dry, reprocessed to remove trace quantities of uranium, or shipped to an approved burial site for disposal.
A layout of the present lagoon system is given in Sketch l
925.ll-I.
A system of monitor wells surrounding this area is sampled regularly to detect any seepage into under-ground waters.
Sketch 925.ll-II shows the relative loca-tion of these test wells.
The area north of the present lagoon area, between the two fences, is set aside for additional lagoons.
Test wells T-5, 6,
8, and 9 intercept the underground water flow as shown on Sketch 925.11-1I.
These new lagoons are an improvc d design based on UNC-FRO experience (since 1964).
Provision for detection of any seepage is included in the design.
Tne second impermeable barrier layer (which provides for l
leak detection and containment) may be either bentonite clay 2-4 inches thick or a plastic sheet.
Note that the l
plastic sheet, being buried, does not require resistance I
to degradation by ultra-violet light.
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,UDC, y M.,.U NITED T5 UCLE AR C O R P.. O H A T I 0 N FUEL' RECOVERY OPERATION SNM 777 DOCKET 70-820
. SECTIO N
. 900:. RECOVERY ~ OPERATIONS Pr e p a re d Oct-2 7.,.
1 9 7 3 PART'
' 925.11:
WASTE LAGOOUS USNRC approvol-925.11 Waste Lagoons (continued)
. Environmental Controls = (continued)
Removal of the supernatant liquor, dilution, and pumping.to the river are permitted by written approval of the Manager, Nuclear and Industrial Safety only if the effluent at the discharge duct meets federal and state regulations for.
discharge to unrestricted areas before dilution by.the river.
An additional dilution. factor of 10,000 is provided, based on the observed ten-year flow rate of 27.034 cubic feet per second of the river (seven day average),-
and 1500 gallons per day of liquid effluent.
procedure Liquid wastes containing less than 100 parts per million of U-235 are transferred to holding tanks 1D14-A and -B.
Lime or other basic material is added until all acids have been neutralized; they are then pumped to the lagoons..
Selected lagoons may be used as settling ponds to allow solids to settle out for discharge.
Supernatant liquid may be transferred to a holding pond or tank, analyzed, and discharged upon written approval of the Manager, Nuclear and Industrial Safety.
Discharged' liquids are sampled at the duct outlet, and must meet federal and state limits for release to unrestricted areas.
Clean water (from process cooling systems or directly from the water supply) may be u ed to dilute the waste liquor to acceptable levels.
Accumulated solids are sampled and either (1) reprocessed (if practical to remove further amounts of uranium),
(2) stored in lagoons and allowed to harden, or
.i (3) transferred to an authorized burial site.
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r w n..U NITED NUCLEAR C O ft P O ft A T I O N FUEL RECOVERY OPERATION SNM 777 DOCKET 70-820 SECTION 900 RECOVERY OPERATIONS Prepared Oct. 27, 197E PART 925.17 RECLAMATION USNRC approval 925.17.2 (continued)
Industrial and Fire Safety All materials of construction are fire resistant and cor-rosion resistant.
Ventilation is provided to remove any toxic fumes.
Safety showers, eyewash fountains and personal safety equipment are required.
This area will meet the regulatory requirements as a safe and healthful place to work.
The organic extractant plus the organic solvent are listed by the National Fire Protection Association as low hazard material.
Flash Boiling Ratings Point Point Health Fire Reactivity Tributyl Phosphate 295F 560F 2
1 0
(used as 15% by volume)
Kerosene 100F 304-574F 0
2 0
Changes in these process chemicals are given an internal review.
Materials having hazard indices equal to or less than those listed above would be accepted without additional precautions.
If'the hazard indices are greater, or unknown, then the added precau-tions needed would be determined by a literature search or by laboratory tests.
The safety precautions which are normally required in the extraction area include:
a limit of 200 gallons of extractant in equipment, with bulk storage external to the building; no smoking; no open flames; and portable fire extinguishers.
These may be changed only by a specific safety review and authorization such as a safety work permit for routine maintenance or equip-ment repair, or an NIS authorization for equipment changes.
Uitration of the organic to create a more dangerous substance has not been a problem (for the last 14 years) with the same organic combinations.
Ilowever, the process includes a final wash with sodium carbonate solution before re-use, and an upper limit on the nitric acid content (8 normal).
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- UDC, y,e 3..U NITED NUCLEAR j
C O R P O H A T i O N FUEL RECOVERY OPERATION SNM 777 DOCKET 70-820 Page Sa SEC TI O N 900 RECOVERY OPERATIONS I
Prepared Oct. 27, 197 8 PART 925.17 RECLAMATION USNRC approval 925.17.3 Environmental Considerations Extension of the present building to form an extended north bay will not have an adverse impact on the envi-ronment.
The ground area covered by the building founda-tion is presently covered by impermeable asphalt or con-crete.
Therefore, there is no change in the groundwater recharge area.
The only exhaust from the process is carbon dioxide.
The excess calcium hydroxido used originally to neu-tralize acid effluent before discharge into the lagoens and holding ponds slowly picks up carbon dioxide from the air to form calcium carbonate.
When redissolved in acid, this releases carbon dioxide.
Exhausts are filtered and continuously sampled for air-borne radioactivity.
The material in process is much less concentrated than that in the main process area.
Therefore, the contribution to offsite radioactivity is not detectable (Reference UNC EI December, 1974).
.