ML20153C633
| ML20153C633 | |
| Person / Time | |
|---|---|
| Site: | 05000603 |
| Issue date: | 08/17/1988 |
| From: | ALL CHEMICAL ISOTOPE ENRICHMENT, INC. |
| To: | |
| Shared Package | |
| ML20151Y386 | List: |
| References | |
| 24649, NUDOCS 8809010210 | |
| Download: ML20153C633 (11) | |
Text
REVISION
. AUGUST 1988 10CFR50.33 - General Information a) All Chemical Isotope Enrichment, Inc.
(AlChemIE) b) AlChemIE, Inc.
Pine Ridge Office Park, Suite B-202 702 South Illinois Avenue Oak Ridge, Tennessee 37830 c) AlChemIE's business will be to enrich stable isotopes using the gas centrifuge technology developed by the U.S. Department of Energy. Th3 isotopes will be used in medical, research and industrial applications.
d) AlChemIE, Inc. is a private corporation incorporated under the laws of the State of Tennessee. The principal location for business will be the AlChemIE i
Facility 1 -
CPDF in Oak Ridge, Tennessee. This facility was formerly the Centrifuge Plant Demonstration Facility of the Department of Energy Name A_ddress Citizenship Ben Mullins P.O. Box 506 USA Oak Ridge, TN 37831 S.A. Irving Rt. 7 Dixon Road USA Lenior City, TN 37771 A.A. Carey Rt. 7 Dixon Road USA Lenior City, TN 37771 M. Miller Rt. 2 Box 248 USA Powell, TN 37849 A1ChemIE is not owned or dominated by any alien, foreign corporation or foreign government, e) The class of license applied for is a Class 103 for commercial 10CFR50.22.
and industrial facilities as defined in The license is sought for a period of forty (40) years, f) As it relates to AlChemIE's financial data, please refer to our submittal to the NRC dated July 22, 1988.
8809010210 080017 PDR A
ADOCK 05000603 PDR I
L
As 3 t relates to decontaminatio' n_ and - decommissioning of the facility _ at the end of its'useful life A1ChemIE'has prepared a cost assessment of the A1ChemIE Facility - 1
-CPDF. -In addition the Department of Energy - (DOE)-
requires assurance that adequate funding will be available for the find disposition of all classified and uranium contaminated equipment and materials received from DOE. The gas centrifuge equipment and piping includes classified material, uranium contaminated material and' Resource Conservation and Recovery Act (RCRA) controlled material. After commercial operations < begin, this equipment,-and associated auxiliaries will- become contaminated or be further contaminated by -the feed compounds. The product residue, in many cases, is a, toxic material and
-must have its disposal strictly' controlled.
Decommissioning of this facility at the end of its life will require disposal of parts of the-process equipment and auxiliaries in one of the following.
classifications:
o Classified burial grounds o Uranium contaminated burial grounds o Toxic material burial grounds.
o Landfill for industrial refuse All classified equipment and material must be buried in a DOE classified burial ground, and although uranium contaminated materials are acceptable at the DOE facility, toxic substances are not. All classified items contaminated with toxic material will be decontaminated before burial.
In each of thu respective commercial burial grounds, unclassified uranium contaminated and toxic materials can be received but not co-mingled. Uranium contaminated materials must_go to the radioactive material burial ground and toxic' material must go to the toxic material burial ground. Finally, industrial landfills may not receive any classified, uranium contaminated or toxic materials. Therefore, a major portion of the decommissioning ef fort _will involve segregating each class of material into discrete categories for final disposal while trying to keep the cost of the decommission to a minimum.
, , i
For cost estimating purposes it should be noted that when the CPDF begins operations as a stable isotope enriching plant, the introduction of RCRA' controlled substances will occur in two stages. Presently the 120 machines installed in the CPDF have low lovels of uranium contamination internally. When operations begin, a cascade of 40 machines will-be used to process various RCRA controlled substances. Approximately - one year af t.or operations begin, another 80 machines will begin being used to process material that may leave RCRA controlled residue. Hence, the decommissioning scope, and therefore the cost, will increase with time. Centrifuge machir.es will also fail with time.
This in turn will reduce the total decommissioning cost at plant shutdown since these failed classified and/or contaminated machine components received from DOE will ba disposed of as appropriate and as required at the time of failure. Thus, estimates for decommissioning and disposal of the classified and contaminated equipment received from DOE or contaminated by A1ChemIE are listed below under two headings in order to establish a range of costs. These estimates are for:
(1) 120 machine plant in operation employing 40 machines to process feed material that may leave RCRA controlled residues, and (2) 120 machine plant in 1 operation employing 80 machines to process feed '
material that may leava RCRA controlled residues.
l Summary of Decommissioning Costs & Funding Requirements fo't CPDF l
120 Machine Plant 120 Machine Plant in Operation - 40 RCRA in Operation - 80 RCRA Total cost $ 3, ' '33,14 4. 00 $3,354,250.00 Scrap value 245,000.00 245,000.00 Not total cost S2,888,144.00 $3,109,250.00
To assure that the appropriate funds are available A1ChemIE will set aside funds in escrow and/or through debt financing. The funds will be obtained from A1ChemIE's sales. Starting in 1988 through . 1993 A1ChemIE expects sales to increase from 4 million to approximately 95 million.
g) Applicable to nuclear power reactors.
h) Modification of the facility, that is, the _ centrifuge cascade will depend on the product being manuf actured.
As new product requirements are defined additional modifications will be made. Consequently modifications-will be an ongoing project.
- 1) Applicable to electrical generating and distribution facilitiec j) This application does not contain Restricted Data.
)
l l
l
, l i
/
10 CFR 50 NONAPPLICABILITY (Revision 1 to November 17, 1937 Submitted)
Pursuant to 10 CFR 50.12(a)(2)(ii) the following averments of nonapplicability to 10 CFR 50 are hereby tendered. The facility ,
to be licensed is for the production of stable isotopes only.
i Part Explanation 50.10(e) Not applicable - Applies to a utilization facility I
50.21 Does not apply A Class 103 lic.ense, 50.22, is applicable. ,
50.33(g) Not applicable - for nuclear power reactors 50.33(1) Not applicable -
for electric power production facility 50.33a(a) Not applicable - for nuclear power reactors. Note through (d) that Anti-trust issues relative to the equipment and facilities were also addressed with DOE.
50.34(a)(1) Part 100, Site Evaluation Factors is no applicable in that it applies to Nuclear Power Reactors.
50.34(a)(3), Not applicable - applies to nuclear power reactors (4),(5),(7),
(11) 50.34(b)(2) Not applicable - applies to nuclear power reactors (4),(5) and plants processing radioactive materials 50.34(b)(6) Not applicable - In that there are no radiological (111),(iv) hazards associated with the production of stable isotopes the inclusion of the requisite plans in the FSAR are not required. In addition SECY88-88 !
limits the review to issues relating to common l defense and security and NEPA findings. '
50.34(b)(6) Not applicable - applies to nuclear power reactors (ii),(v11) and fuel processing plants i "O.34(b)(6) Not applicable -
The intent of the technical I (vi),50.36 specifications are to assure safe operating and !
control limits to prevent or mitigate radiological I releases from nuclear reactor plants or nuclear !
fuel processing plants. Since the residual i uranium in the centrifuge and associate piping is l
/
fixed and in the form of uranyl fluoride (UO F2) n releases posing a threat to the safe y and health of the public will occur. As it relates to safeguards, the administrative and ,
monitoring controls are contained in the A1ChemIE Security Plan.
50.34(b)(8) Not Applicable - Licensing of operators in 50.54(1-1), accordance with 10CFR55 for a stable isotor,e (j ),(k),(1) production facility is not requireJ. since plant (m),(y) operations pose no radiological threat to public health and safety.
50.34(b)(9) Not applicable -
applies to nuclear power reactors.
50.34(c)(d) Applies except that the security plan will be (e) prepared in accordance with 10 CFR 95 and not 50.54(p) in accordance with 10CFR73. 10CFR73 provides requirements for security to prevent radiological sabotage and theft of special nuclear material.
Since A1ChemIE will be processing only non-radioactive isotopes there are no concerns relative to the release of large amounts of radiation (SECY88-88). As it relates to special nuclear material there are approximately 170 grams of U-235 contained in uranyl fluoride and plated on the interior surfaces of the rotor and piping.
Since this material is not in a useable form and theft impossible, this is not of concern.
Therefore, for security purpose AlchemIE is required to protect the classified information and l equipment and have a program in place to provide l assurance that no uranium is being enriched in the i plant. These requirements aro met by the A1ChemIE j security plan written in accordance with 10CFR95 and the NRC "Proposed License Conditions for Safeguards Licensing of A1ChemIE Operations at i CPDF."
- For part (e), this plan is not classified.
50.34(f) Not applicable - appifes to nuclear power reactors i
50.34(g) Not applicable - Standard Review Plans for t W s j i
50.34a Not applicable - applies to nuclear power reactors 50.36a Not applicable - applies to nuclear power reactors 50.41 Not applicable -
The application is for a class 103 license.
50.43,50.44 Does not apply. Applicable to commercial nuclear power production facilities, i l
)
50.46,50.47 Does not apply. Applicable to Nuclear Power 50.48,50.49 Reactors.
50.54(a) Not applicable. A quality assurance program in accordance with Appendix B is not required.
50.54(o) Not applicable. Containment requirements for water cooled reactors.
50.54(q),(r) Not applicable - applies to nuclear power reactors (s),(t),(u),
(w),(z),(bb) 50.55 (e) Not applicable - The plant has already been constructed and its operation will not pose radiological safety problems. For AlChemIE's operations, a significant breakdown would be in ,
the area of security and safeguards. Reporting l requirements are delineated in the security plan as required by Part 95.
50.55 (f) Not applicable since Appendix B to 10 CFR 50 is not required.
50.55a Not applicable - applies to nuclear power reactors 50.57(a)(5) Insurance requirements of part 140 are not ,
applicable to A1ChemIE operations. That is !
nuclear idemnity insurance is not required. !
Additionally Price -
Anderson has not been reinacted.
50.57(c) Applicable to power reactors. l 50.60,50.61 Not applicable -
Fracture Toughness requirements for nuclear reactors.
I 50.62 Not applicable -
ATWS requirements for power )
reactors. !
1 50.64 Not applicable -
limits on HEU in domestic non-power reactors 1 50.71(e) Not applicable - applies to nuclear power reactors l
50.72, 50.73 Not applicable - applies to nucleer power reactors ;
Appendices A, Not applicable - applies to nuclear power reactors '
B,F,G,H,I,J, K,H,N,0,0,R i
l l
J
10 CFR 50 EXEMPTION REQUIREMENTS Pursuant to the provisions of 10 CFR 50.12(a)(2)(ii), A1ChemIE hereby requests a specific exemption from the following Parts of 10 CFR 50, for the reasons hereafter stated:
- 1. A special exemption is requested from 10 CFR 50.34(a)(10) and (b) (6) (v).
A. 10 CFR 50. 34 ( n ) ( 10 ) requiren a discussion of the applicant's preliminary plans for coping with emergencies and references Appendix E as setting forth the items in said plan. A review of Appendix E shows that it concerns, "The potential radiolog'. cal ha;ards to the public associated with the operation of research and test reactors and fuel facilities licensed under 10 CFR 50 and 10 CFR 70."
< Appendix E, I. Introduction, third paragraph).
AlChemIE is not operating research or test reactcrs or fuel facilities and, by project definition and the parameters of the license sought, will pose no "potential radiological release." The AlChemIE facility is to be used for the production of stable isotopes.
B. 10 CFR 50.34 (b) (6) (v) also addresses emergency plans and references Appendix E.
C. Under the authority of 10 CFR 50.12 (a) (2) (ii),
the Commission may, upon application, grant exemptions from the requirements of 10 CFR 50 if "special circumstances" are present. Special circumstances are deemed present whenever "Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule."<11).
D. As stated earlier, A1ChemIE will not be processing special nuclear materials and poses no threat of radiological release. SECY 88-88, dated June 7, 1988, states "The chemical hazards, if any, are unrelated to materials licensed under the Atomic Energy Act."< COPY ATTACHED).
E. The primary issue in NRC's granting AlChemIE a license is assuring adequate protection of common defense and security. This has been addressed in AlChemIE's Security Plan. Also, and as published in Federal Register noticus 53FR15317 and 53FR15315, dated April 28, 1988, the requested license would govern possession of the centrifuge machines, but not the enriched stable isotopes produced.
l l
l . e i
F. AlChemIE is developing handling, operating and emergency procedures for each chemical compound that is to be processed. These procedures will be reviewed and approved by DOE prior to use of any chemical compound in the Centrifuge Plant Demonstration Facility. Additionally, under its Air Quality Permit from the Tennessee Department of Health and Environment, AlChemIE is required to report releases of toxic gases.
i For the foregoing reasons, AlChemIE verily feels that special circumstances exist which make it appropriate and proper to exempt AlChemIE from 10 CFR 50.34 (a) (10) and (b) (6) (v), and pursuant to 10 CFR 50.12 (a) (2) (ii) A1ChemIE does hereby make application for said exemptions.
1 i
I l
. l ,
10 CFP 50 - SUPPLEMENTARY INFORMATION PART EXPLANATION 50.34(a)(9) The technical quclifications of AlchemIE personnel 50.34(b)(7) to support the safeguards requirements of Section 19 to the Security Plan are as follows:
- 1. AlChemIE's current technical staff consists of two (2) chemists with doctoral degrees, three engineers with masters degrees, two in nuclear physics and one in energy conversion.
- 2. A1ChemIE's operations staff will consist of personnel with, as a minimum, a two year technical degree, or equivalent.
50.35 (b) Prior to operation with any toxic or hazardous gas AlChemIE is required by DOE to perform a safety analysis. This analysis includes en environmental impact assessment for accidental re) eases and the development of
- handling, operating, fire fighting and clean up procedures. The proc <sdures are also provided to the emergency re spo.tse teams, fire fighting, medical, security, etc., at the Oak Ridge, Gaseous' Dif fusion Plant. In addition, the State of Tennessee, Department of Health end Environment also requires notification of accidental releases.
50.42(a) Although AlChemIE vill posses come uranium it is not in a usable form. The uranium is in the form of uranyl fluoride (UO,F9) and is plated out on the centrifuge rotof and associated piping.
Previous operations producing stable isotopes using contaminated centrifuge machines has shown that the uranyl fluoride remains in the machines and piping.
)
e e
l-oocxer No. Ed-4d3 CONTROL NO. [YdM9 1 DATE OF DOC. Ucusl 17 /982 DATE RCVD. 4 iS rcur
,Jlpaa/__ V- N b gf FCAr LPDR l& E REF. I MFEGUARDS /
- FCTC '
OTHW [
DMEhl- lN MAL $ D '
//
l
_, - n