ML20196A351

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Advises That State of Tn Filed Request to Participate in Facility Proceedings as Interested State Per 10CFR2.715(c). State Does Not Oppose Licensee Applications,But Does Have Concerns to Be Addressed
ML20196A351
Person / Time
Site: 05000603, 05000604
Issue date: 06/17/1988
From: Bordenick B
NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To: Margulies M
Atomic Safety and Licensing Board Panel
References
CON-#288-6574 88-570-01-CP, 88-570-01-CP-OL, 88-570-1-CP, 88-570-1-CP-OL, CP, CP-OL, NUDOCS 8806300018
Download: ML20196A351 (7)


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'88 JUN 23 P4 :26 JUN 171988 0FFf EI 0; ii vi; . ,

00CKiian a n . r, it t ilM fD-Morton B. Margulies, Chairman Dr. Oscar H. Paris Administrative Judge Administrative Judge Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Emmeth A. Luebke Administrative Judge 5500 Friendship Boulevard, Apt. 1923N Chevy Chase, Maryland 20815 In the Mattars of ALL CHEMICAL IS0 TOPE ENRICHMENT INC.

(AlChemIE Facility-1 CPDF)

Docket No. 50-603-CP/0L; ASLBP No. 88-570-01-CP/0L and (AlChemIE Facility-2 Oliver Springs)

Docket No. 50-604-CP; ASLBP No. 88-571-01-CP

Dear Administrative Judges:

On May 31, 1988, the State of Tennessee, on behalf of the Commissioner of the Tennessee Departirent of Health and Enviror. ment, by and through the Office of the Attorney General for the State of Tennessee, filed a request to participate in the above captioned proceedings as an interested state pursuant to 10 C.F.R.52.715 (c). The Staff supported the State's participation in the mandatory construction permit hearing phase of these proceedings in a fiiing dated June 7, 1988.

The State's May 31 request stated, at page 3, that at this time it did not oppose the AlChemIE applications but that it did have certain concerns it l would like to see addressed. Attached is a letter dated June 9, 1988 from the

! Applicant to the Staff which purports to address the State's concerns. It does l not appear that copies of the letter in question went to anyone other than the

Staff. In any event, the Staff has act yet reviewed Applicant's response to 8806300018 890617 PDR ADOCK 05000603

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the State's concerns. Accordingly, this letter is sent to the Licensing Board and Counsel for the State of Tennessee at this time for informational purposes only..

Sincerely, p kik ernard M. Bordenick Counsel of NRC Staff

Enclosure:

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Docket No's: 50-603 ~l W 50-604 Nuclear Regulatory Commission Document Control Desk Office Nuclear Materials Safety

& Safeguards Washington, DC 20555 Attention: Mr. Hugh L. Thompson, Jr.

SS396-MNSS Docket Materials Gentlemen:

The State of Tennessee in their request to participate in l

A1ChemIE's licensing action as an interested State pursuant to 10CFR2.715(c) has raised two concerns relative to AlChemIE's I operation of the gas centrifuge machines. Provided herein is AlChemIE's response to those concerns.

Concern: It appears entirely possible that the centrifuge machines proposed for use by A1ChemIE may contain low levels of pr:r.1um not subject to regulation by the Commission, but subject to regulation by the State of Tennessee.

8EOG-M otRE SP-Pine Ridge Office Park. Suite 202-B 702 lilino!s Ave Ook Ridge. TN 37830 (615) 452-0020

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Nuclear Regulatory Commission June 9, 1988 Page 2 Response: The uranium contained within the machines is estimated to be 95 1 32 grams per machine at the Centrifuge Plant Demonstration Facility in Oak Ridge and 82 1 31 grams per machine for the machines being relocated from DOE's Piketon, Ohio facility. The total amount of uranium contained at the Centrifuge Plant Demonstration Facility, machines, piping, etc., is 21.3kg. The total amount of uranium in the machines being relocated from Piketon is 59kg. Piping is not being relocated from Piketon.

Under NRC and DOE cognizance AlchemIE as a part of its NRC license, will be required to comply with the reporting requirements of 10CFR74.11, 10CFR74.13 and 10CFR74.15. These require A1ChemIE to report loss or thef t or attempted thef t of special nuclear material, provide material status reports and provide nuclear material transfer reports, respectively. Consequently, A1ChemIE will be regulated by l

both the NRC and DOE.

j Concern: The process proposed by A1Cher.i1E has the potential for f

enhancing naturally occurring radioactive material as a product.

I Response: For. the isotopes listed in A1ChemIE's safety analysis report those that have naturally occurring radioactivity are listed in the attachment, hereto. As can be seen, only seven elements have naturally occurring radioactive isotopes and a.11 have a half life greater the 1010 years. Additionally, of these seven only tellurium and cadmium have any market potential at this time.

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l However, it is conceded that the gas centrifuge process will, in l either tne product or tails stream enrich these isotopes and 1

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Nuclear Regulatory Commission June 8, 1988 Page 3 consequently, the radiological effect of a release should-be estimated. If it is assumed that a product _or tails cylinder of the samo size as a feed cylinder and containing 176 pounds of pure radioactive te11urium-123 ruptures, then the radiological effects can be estimated. For. tellurium the critical ergan is the bone surface and from ICRP-30 the dose factor and effective equivalent dose factor are 0.26 rem /yCi and_0.01 rem /yC1, respectively. In that the facility volume at the A1ChemIE Oliver Springs facility is somewhat smaller than the Centrifuge Plant Demonstration Facility it was assumed that the rupture of the cylinder occurred there.

Based on calculations performed by Science Applications International Corporation it was estimated that the bone surface dose for a person in the plant in which the contents of the cylinder had uniformly dispersed and breathing the air for two hours after the rupture would be 3.23X10-4 rem. The offective dose after two hours would be 1.26X10-5 rem.

At the maximum point of air concentration, approximately one-half kilometer downwind, the dose to a person breathing the discharge for eight hours was 3.5X10-9 rem, bone surface and 1.37.10-10 effective dose. Finally, the dose to a person standing one-foot from an unruptured cylinder, neglecting the shielding effect of the cylinder was calculated to be 6X10-6 rem /hr.

Similarly for cadmium-113 where the critical organ is the kidney the j doses- were computed. The two hour kidney and effectiva doses are l 2.58X10-5 and 1.88X10-6 rem, respectively. At one-half kilometer

r Nuclear Regulatory ' Commission June 9, 1988 Page 4 and eight hour kidney and effective doses are 2.75X10-10 rem and 2.0X10-11 rem respectively.

As can be seen from the above, the calculated doses are very small.

These doses are significantly less than the limiting dose in 10CFR20.101.

Finally, ni natural abundance was found for carbon-14. It is assumed that its abundance is very small and therefore would not be enriched in any significantly quantity.

We trust that the above resolves the concerns expressed by the State of Tennessee, Division of Radiological Health. Should additional information be required please contact Mr. W.A. Pfeifer at AlChemIE.

Very truly yours, ALCHEMIE, NC.

Af y oh H. Smelser, Jr.

ief Executive Officer l

JHS/WAP/bc cc: A. Thomas Clark, Jr./NRC

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ATTACHMENT Isotope Abundance Half Life Decay Method Carbon - 14 Not defined 5730 yrs Beta" Vanadium - 50 0.25% 3.9X10 17 yrs EC, gamma, Beta Cadmium - 113 12.22% 9X10 15 yrs Beta" 14 Indium - 115 95.7% 4.4x10 yrs Beta' Tellurium - 123 0.9% 1.3X10 13 yrs EC Tantalum - 180 0.012% 13

> 10 yrs EC 4.5X10 10 yrs

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Rhenium - 187 62.6% Beta

, Osmium - 186 1.58% 2X10 15 yrs Alpha i

i Notes: 1) EC = electron captive

2) Carbon has been included in that some of the feed compounds contain carbon l

Reference:

Chart of the Nuclide, Knorts Atomic Power Laboratory, Thirteenth Edition, Revised July 1983.

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