ML20150D624

Forwards Addl Info Re 880203 Environ Responses to NRC 871228 Request.Info Includes Detailed Floor Plan,Commitment to Develop Procedures for Toxic,Hazardous Chemicals,Expected Water Usage & Procedures for Environ Permit Amends

ML20150D624
Person / Time
Site:	05000603
Issue date:	03/15/1988
From:	Bell D ALL CHEMICAL ISOTOPE ENRICHMENT, INC.
To:	Thompson H NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
29142, NUDOCS 8803240397
Download: ML20150D624 (12)

Text

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March 15, 1988 G

% )/p U. S. Nuclear Regulatory Chunission <C c Doctznent O:ratrol Desk Office Nclear Material Safety & Safeguards Washingtcn, D.C. 20555 Attention: Mr. Hugh L. hp, 55396->NSS Docket Material

Reference:

AlChemIE, Inc. letter dated February 3, 1988, addressing NRC's request, dated December 28, 1987, for additicnal information Gentimen:

On February 9,1988, representatives frcm A1ChanIE met with the NRC to discuss various itans related to the licensing of AlChemIE Facility-1, CPDF. In the discussico of the envircrrnental responses subnitted by A1ChanIE in the above referenced letter, Mr. Jim Hanmelman, SAIC, verbally requested additional informaticn. Subnitted as attachnents, heretn, is the additional informaticn.

'Ihis includes:

1. A detailed floor plan of CPDF showing the location of heating, ventilating, and airetniiticning trdts. It should be noted that except for offices, the building is not airconditicnod. Air for heating and '

ventilating in the cascade area is supplied by the HV-703-10, 11, and 12 I units.

2. A1ChamIE's ccmnitment to develop handling, operating and safety procedures for toxic, hazartbus chenicals.

3. Procedures for Envimsiuntal Permit amendnents

4. An Accident Analysis for an osnitzn hexafluorido release l

S. Expected Water Usage  !

Should you have any questicns, please ccntact Mr. William Pfeifer at AlChemIE.

Sincerely, ALCHEMIE, INC. #

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s L. Bell ~

Chief Executive Officer +[6/

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P K 3 vi a n , p cc: Dr. A. 'Ihcanas Clark, Jr./NRC l Pine Ridge Othee Park. Suite 202-8 702 lilinois Ave.. Ook Ridge, TN 37830 (6 5)p8 -0029

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UHS-Steam Heaters General location of IIVAC units in CPDF

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l Handling of Toxic, Hazardous Chemical Compounds 1

In that the majority of the feedstock compounds utilized by l A1ChemIE for isotopic enrichment in the gas centrifuge are toxic i

and hazardous, extreme care must be taken to protect operations '

personnel and to prevent an inadvertent release to the environment. For each feedstock compound being processed, l detailed handling and operating procedures will be developed.

i More specifically, manufacturers (suppliers) of the feedstock compounds are required to provide material safety data sheets l for the toxic and hazardous compounds. These data sheets ;

contain information on:  ;

1. Physical and chemical properties

2. Chemical reactivity i

3. Stability  ;

4. Fire hazard i

5. Fire fighting technique l

6. Toxicology

7. First aid I

8. Industrial hygiene practices

9. Handling spills

10. Corrosivity to materials of construction

11. Storage requirements

12. Disposal of unused materials j l

13. Disposal of containers 1 i

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A1ChemIE will use this data and other data supplied by the manufacturer to develop handling, operating, and safety I

i procedures for each compound. This data will also be used for l

training personnel.

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1 PROCEDURES FOR ENVIRONMENTAL PERMIT AMENDMENTS AT ALCHEMIE FACILITY 1.- CPDF I. TENNESSEE DEPARTMENT OF HEALTH AND ENVIRONMENT (TDHE) NATIONAL 1

POLLUTION DISCHARGE ELIMINATION SYSTEM (NPDES) PERMIT Proposed Amendment Process:

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1. AlchemIE will notify TDHE and DOE of any proposed changes in waste water processing requirements; utility water processing requirements; feed compound additions or deletions and/or other items that could possibly require a NPDES permit amendment. This notification will be given to TDHE and DOE -

prior to the proposed action.

2. AlChemIE will meet with TDHE NPDES personnel and DOE personnel for detailed discussions of the proposed change.

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3. AlChemIE will await TDHE NPDES personnel comments with respect to NPDES pemit requirements.  !

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4. AlchemIE will meet with DOE personnel to discuss TDHE requirements. AlchemIE and DOE will enter into an agreement with respect to TDHE requirements.

5. A revised NPDES Pemit Application will be submitted to TDHE I

by DOE reflecting the proposed AlChemIE action and DOE treatment / discharge process.

6. TDHE will process the application, issue a draf t permit, and place the application on a 30-day public notice.

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7. TDHE will issue a revised NPDES permit to 00E, assuming all ,

requirements are satisfied, after the 30-day public notice has -

expired. i AlChemlE will not initiate any facility modification or' feed compound addition / deletion until the above process has been completed to the satisfaction of TDHE and 00E, NOTES:

1. AlChemIE will not require a NPDES permit at A1ChemIE Facility 1 - CPDF. All waste water and utility water will be discharged through DOE treatment systems subject to an agreement between AlChemIE and 00E.

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.. .s II. TENNESSEE DEPARTMENT OF HEALTH AND ENVIRONMENT, DIVISION OF SOLIU WASTE MANAGEMENT C0 ORDINATION A. SOLID WASTE MANAGEMENT:

1. AlChemIE will notify TDHE and DOE of any proposed changes in their Solid Waste Management Plan that could affect the pick up and disposal of solid waste by a private contractor. This notification will be given to TDHE and DOE prior to the proposed action.

2. AlChemIE will meet with TDHE Solid Waste personnel for detailed discussions of the proposed change.

3. AlChemIE will await TDHE Solid Waste personnel comments with respect to solid waste disposal requirements.

4. AlChemIE will mect with DOE personnel to discuss TDHE solid waste disposal requirements.

5. AlchemIE will revise their Solid Waste Management Plan based upon TDHE and DOE suggestions. However, AlChemIE will endeavor to contract with a private company for pick up and disposal of solid waste.

B. CLASSIFIED WASTE MANAGEMENT:

1. AlChemIE will work directly with DOE for the disposal of classified materials.

2. DOE will work directly with TDHE for disposal of classified materials.

C. HAZARD 0US WASTE MANAGEMENT:

1. AlChem1E will notify TDHE and DOE of any proposed changes

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4 in feed compounds and proposed changes in the Hazardous Waste Management Plan that could affect pick up and disposal of hazardous waste by a private contractor.

This notification will be given to TDHE and DOE prior to the proposed action.

2. AlChemIE will meet with TDHE Hazardous Waste personnel for detailed discussions of the proposed change.

3.. AlChem!E will await TDHE Hazardous Waste personnel comments with respect to hazardous waste management and disposal requirements.

4. AlChemIE will meet with DOE personnel to discuss TDHE I hazardous waste requirements.

5. AlChemIE will revise their Hazardous Waste Management Plan based upon TDHE and DOE requirements. However, AlchemIE will endeavor to contract with a private company for pick up and disposal of hazardous waste.

r III. TENNESSEE DEPARTMENT OF HEALTH AND ENVIRONMENT, AIR POLLVTION CONTROL (APC) PERMIT Proposed Amendment Process:

.. AlChemIE will notify TDHE of any proposed facility changes that would create or delete an emission point. In addition, TDHE will be notified of proposed new feed compounds or deletion of feed compounds. This notification will be given to TDHE prior to the proposed action.

2. AlChemIE will meet with TDHE, APC personnel for detailed discussions of the proposed change. ,

3. AlChemIE will await TDHE, APC comments with respect to permit requirements.

4. AlchemIE will prepare and submit an APC Construction Permit indicating proposed change to the existing permit.

5. TDHE, APC will process the application and place the ,

application on public notice.  !

6. TDHE, APC will issue the requested construction pemit, assuming all requirements have been satisfied.

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7. AlchemIE will make requested changes. j 1

8. AlchemIE will prepare and submit an APC Operating Pemit.

9. TDHE, APC will issue the requested operating permit, assuming all requirements have been satisfied.

AlChemIE will not initiate any facility modification or feed l

compound additions / deletions until the above process has been completed to the satisfaction of TDHE.

ACCIDENT ANALYSIS-0SMIUM HEXAFLUORIDE RELEASE osmium is one of the more than 31 elements which may be isotopically enriched by gas centrifuge. The feed material for enrichment of osmium is osmium hexafluoride (OsF 6 ) held in feed containers containing 539 lb of OsF 6. The possibility for a release of OsF6 during the transport and connection exists due to a breach of the feed vessel from mishandling or improper connection. If a breach of a feed vessel occurs, the resulting off-site concentrations can be determined.

Assume a feed vessel breach occurs and results in the release and reaction of 10% of the vessel's content. If OsF6 reacts like UF6 in contact with moist air, the following reaction takes place:

OsF6 + 2H 2O > 4HF + Oa0 F22 This reaction would result in 54 lb (1.49 moles) OsF6 reacting to form 6.45 Kg (322 moles) of Hydrogen Fluoride (HF). HF is a colorless gas which is toxic and has a Threshold Limit value (TLV) of 2.5 mg/m 3.

The CPDF building has a volume of 4.58 x 10 6 ft3 and a total exhaust rate of 129,600 ft / 3 min. This results in one complete air change every 35.35 minutes. If the entire HF release is uniformly exhausted in one air change, a release rate of 3.07 gm/sec results.

If the release is assumed to be exhausted from the top of the 75-ft high building and with no additional plume rise or turbulent effects, the resulting ground level concentrations at the plume centerline can be determined with the following equation (Turner, 1970):

X(x,o,o;H) = r cy oz u * "(*

U X = Concentration x = Distance down wind from release Q = Release rate H = Stack height J u = Wind speed affecting plume ay = Horizontal dispersion coefficient -

oz = Vertical dispersion coefficient A conservative wind speed value of 1 m/sec will be used for the concentration calculations. The actual average viad speed for the Oak i Ridge area is approximately 2 m/sec. The horizontal and vertical dispersion coefficients are for stability category F (Turner, 1970) and provide conservative values for atuospheric stability.

-20 At loom, 500m, 1 km, 2km, and 5 km, concentrations of 4.85 3 x 10 mg/m 3 , 0.18 mg/m 3 , 0.55 mg/m 3

, 0.40 mg/m3 , and 0.16 mg/m ,

respectively, result from the release. All of these values are well below the TLV of 2.5 mg/m 3 for HF. The low concentrations closer to the stack are due to the inability of the plume to disperse to ground level in that short time.

Concentrationsencounteredbythe,ggesestpublicreceptor,at approximately 100m, are 4.85 x 10 mg/m3 . This value is below the 1

detectable limit.

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l Expected Water Usage 1 A1ChertIE Facility-1, CPDF and Fac111ty-2 Oliver Springs For piping design, 50 gpn was utilized at CPDF and 75 gpm at Oliver Springs. Actual flow rates are otmputed as follows. ,

1. Assune 100 gal / day per perscn

2. Maxinun of 50 people at each facility i

Water Usage = 100 x 50 = 5000 gal / day = 3.5 gal / min ,,

'Iherefore actual water flow rate to the CPDF water treatanEnt plant and the City of Oliver Springs treatment plant is conservatively estimated to be about 3.5 gpm.

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