ML20210P122
| ML20210P122 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 08/22/1997 |
| From: | Hardin K NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Maas L SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER |
| References | |
| TAC-L30896, NUDOCS 9708260440 | |
| Download: ML20210P122 (4) | |
Text
3 1
3 August 22, 1997 i
Mr. L. J. Maas Ma.ager, Regulatory Compliance Siemens Power Corporation "2101 hom Rapids Road Richland, Washington 99352-0130
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION, AMENDMENT APPLICATION DATED AUCUST 22,1996 AND THE HAZARD ANALYSES DATED MARCH 3 AND MAY 1,1997 (TAC NO. L30896)
Dear Mr. Maas:
This refers to your application dated August 22,1990 and the Hazard Analyses dated March 3 and May 1,1997, requesting the revision of License SNM 1227 to include low-level radioactive waste (LLRW) shredding and uranium recovery from LLRW in a modular recovery unit as an authorized activity. Our review of the revision has identified additional information that is needed before final action can be taken on your amendment request. This additionalinformation is described in the enclosure to this letter.
The additional information should be provided in the form of responses to the individual comments within 30 days of the date of this letter. Please reference the above TAC number in future correspondence related to this request.
If you have any questions, please call me at (301) 415 8119.
Sincerely, p
Kimberly J. Hardin Licensing Section 2 Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS Docket 70-1257 i
License SNM 1227 p$Ch/l
Enclosure:
Request for Additional Inforniation DISTRIBUTION w/ enclosures;(Control No. 4EOS)
Docket 70-1257
- PUBLICb NRC File Center CHooker, RIV SChotoo FCLB r/f FCSS r/f NMSS r/f Region IV G:\\SIE-MERF.RAI OFC FCLB E
FCLB E
FCLB
{
FCLB f.
FCLB M
DStoutY7 KHardinh PShea g,,,g HAstwood#rf MWeberk NAME DATE 8/397 8/d/97 8/M7 I Bib /97 8/2%97 C = COVER E = COVER & ENCLOSURE N a NO COPY
~
9708260440 970822 OFFICIAL RECORD COPY PDR ADOCK 07001257 l
5
/
Hequest for Additionalinformation e
Application Dated August 22.1996 Siemens Power Corporation Docket 701257 1)
Drawing F003, sheet 2 of 2, dated 4/23/96, indicates that precipitated uranium will be pumped through a filter.
Questions:
a)
What safety devices are in place to prevent operators from being sprayed with uranium solution if a leak occurs in piping, connections, or the filter?
b)
How are these safety devices maintained and tested, to ensure that they remain in place and will function if needed?
2)
Drawing G003, sheet 1 of 1, dated 11/12/96, indicates the Raw Material Storage Area contains nitric acid, sodium hydroxide, hydrogen pe oxide, and a propane fired boiler 1
which is within 6 feet of the heating ventilation and air conditioning (HVAC) skid.
Questions:
a)
Has the possibility of a chemical release or propane release from the Raw Material Storage Area, being drawn into the HVAC air intake, been analyzed?
b)
What effect would this type of release have on operators in the modular extraction / recovery facility (MERF)?
3)
Drawing F003, sheet 2 of 2, dated 4/23/96, indicates that the hydrogen peroxide concentration is 5 percent higher than the concentration in the material safety data sheet (MSDS). Also, drawing F003, sheet 1 of 2, dated 4/23/98, indicates that the nitric acid concentration is 9 percent lower than the concentration listed in the Hazards Analysis, page 6 Section 2.10.
Question:
a)
Please confirm the concentration that will be used in the MERF.
4)
Reference Modular Extraction / Recovery Facility (MERF); Hazard Analysis, EMF 1946, Revision 0, page 2, Sections 2.1.4 and 2.1.5. There is a discussion about wet wastes and alcohol contaminated rags. The Fire Hazard Analysis (FHA) for the MERF, dated 2/12/97, page 1, discusses waste containing small amounts of tributyi phosphate (TBP),
dodecane, lubricating oils and greases (organics). Also on page 1 is the statement that bench scale t',sts were conducted on three of four waste types anticipated in the MERF, and at that time, alcohol rags had not been defined as a waste stream that would be treated in the MERF.
Question:
a)
Did the bench scale tests discussed above confirm that incompatible reactions between the organics, including alcohol, and oxidizers (nitric acid and hydrogen peroxide) are not going to occur and operators can safely perform the washing / extracting and precipitation steps without the potential of an incompatible reaction occurring?
Enclosure t
2
,5)
,. Attachment A, page 13 of the Modular Extraction / Recovery Facility (MERF): Hazard Analysis, EMF 1946, Revision 0, states there is a potential explosion hazard if ammonium nitrate accumulates in the facility.
Questions:
a)
Has the compatibility of dodecane, lubricating oils, nitric acid and nydrogen peroxide with ammonium nitrate been considered and documented?
b)
What measures have been taken to promote worker safety and prevent these potential incompatibio reactions from occurring?
6)
The washer / extractor will be heated by injecting saturated steam at (100 psig and 334 degrees Fahrenheit) into the washer / extractor drum to maintain a temperature in excess of 100 degrees Fahrenheit.
Questiom:
a)
What measures or controls are provided to prevent an operator from opening the washer door during injection of 334 degree saturated steam into the nitric acid solution?
b) is there a device that prevents opening the door until the temperature has cooled sufficiently to prevent injury to the operator?
c)
Are safety controls tested to ensure that they will perform as expected at startup anr during operations?
d) l' 4 will these controls be tested?
7)
Reference the MERF Hazards Analysis, EMF 1946, Revision 0, Attachment A, page 12.
The safeguards for the What if scenario where the temperature control valve fails on the steam line to the washer and UNH tank are: (1) High temperature indication, (2) Operator will be attending the machine during operation, and (3) Routine calibration.
Questions:
a)
If the temperature sensing device fails, what happens with the temperature control valve?
b)
If the temperature sensing device loses power, would the high temperature indicator still orerate?
c)
Are there separate temperature sensing devices for the temperature control valve and the temperature indicator? Are there redundant temperature sensing devices?
d)
If the MERF facility loses electrical power, does the temperature control valve fail in a safe position, i.e., closed?
e)
Does routine calibration, described in (3) above, involve a functional test where a high temperature is simulated and the temperature control valve is verified to close?
f)
Are there separate temperature sensing devices for the UNH Hold Tank and Washer / Extractor temperature control valve?
8)
Reference the MERF Hazards Analysis, EMF 1946, Revision 0, page 28, Attachment D, Material Safety Data Sheet 30 % Hydrogen Peroxide, Section 7-Handling and Storage.
The MSDS recommends the following for hydrogen peroxide sto'1ge: store in a cool, dry, well ventilated area; do not store near heat or flame; and, store below 100 degrees Fahrenheit. According to drawing G003, sheet 1 of 1, dated 11/12/96, hydrogen
s 3
, peroxide will be stored in the Raw Material / Storage Area Weatherport Enclosure, which includes the steam boiler.
Questions:
a)
Will the storage conditions recommended in the MSDS be met?
b)
How will these storage conditions be maintained? If they can not be maintained, have the consequences and associated risks with hydrogen peroxide thermal decomposition been considered?
9)
Prior to opening drums at the Sorting Station, are they checked for bulging or other signs of pressure build-up? If a drum is suspected to be pressurized, what measures are being used to relieve the pressure? Is a check for pressure in the drum required by procedure or covered during operator training classes?
10)
The MERF Hazards Analysis, EMF.1946 Revision 0, Section 2.10, Nitric Acid Supply System, page 6, and the Siemens RAI response to Question 1.3, dated 1/27/97, states that concentrated nitric acid is pumped via a metering pump through a flow totalizer to a hold tank where the nitric acid solution is made up.
Questions:
a)
How is the concentration of the nitric acid solution controlled and verified?
b) if the flow totalizer fails or pumps the incorrect amount, what is the highest nitric acid solution concentration that could be achieved in the washer / extractor? If a higher nitric acid concentration was obtained, would this result in incompatible reactions between the nitric acid (oxidizet, and organic (lubricating oils, greases, dodecane, alcohol) contaminants? What controls are in place to prevent this?
August 22, 1997 I
Mr. L J. Maas Manager, Regulatory Compliance Siemens Power Corporation 2101 Horn Rapids Road
(
Richland, Washington 99352-0130
SUBJECT:
' REQUEST FOR ADDITIONAL INFORMATION, AMENDMENT i
APPLICATION DATED AUGUST 22,1996 AND THE HAZARD l
ANALYSES DATED MARCH 3 AND MAY 1,1997 (TAC NO. L30896)
Dear Mr. Maas:
This refers to your application dated August 22,1996 and the Hazard Analyses dated March 3 and May 1,1997, requesting the revision of License SNM 1227 to include low level radioactive waste (LLRW) shredding and uranium recovery from LLRW in a modular recovery unit as an authorized activity. Our review of the revision has identified additional information that is needed before final action can be taken on your amendment request. This addF.ionalinformation is described in the enclosure to this letter.
q Tno additionalinformation should be provided in the form of responses to the individual comments within 30 days of the date of this letter. Please reference the above TAC number in future correspondence related to this request, if you have any questions, please call me at (301) 415 8119.
Sincerely, ggg Kimberly J. Hardin Licensing Section 2 Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS Docket 70-1257 License SNM 1227
Enclosure:
Request for AdditionalInformation DISTRIBUTION w/ enclosures:(Control No. 4EOS)
Docket 701257 PUBLIC 1 NRC File Centeri CHooker. RIV SChotoo FCLB r/f FCSS r/f NMSS r/f Region IV G:\\SIE MERF.RAI OFC FCLB E
FCLB E
FCLB
['
FCLB
['
FCLB M
DStouk7 KHardinh PShea m3 HAstwoodptf MWeberM NAME DATE-8/ 3 97' 8/D/97 8 0/97 I 8 & /97 8/22/97 C e COVER E = COVER & ENCLOSURE N = NO COPY OFFICIAL RECORD COPY
0 Request for AdditionalInformation Application l)ated August 22,1996 Siemens Power Corporation Docket 70-1257 1)
Drawing F003, sheet 2 of 2, dated 4/23/96, indicates that precipitated uranium will be pumped through a filter.
Questions:
a)
What safety devices are in place to prevent operators from being sprayed with uranium solution if a leak occurs in piping, connections, or the filter?
b)
How are these safety devices maintained and tested, to ensure that they remain in place and will function if needed?
2)
Drawing G003, sheet 1 of 1 dated 11/12/96, indicates the Raw Material Storage Area contains nitric acid, sodium hydroxide, hydrogen peroxide, and a propane fired boiler which is within 6 feet of the heating ventilation and air conditioning (HVAC) skid.
Questions:
a)
Has the possibi!ity of a chemical release or propane release from the Raw Material Storage Area, being drawn into the HVAC air intake, been analyzed?
b)
What effect would this type of release have on operators in the modular extraction / recovery facility (MERF)?
3)
Drawing F003, sheet 2 of 2, dated 4/23/96, indicates that the hydrogen peroxide concentration is 5 percent higher than the concentration in the material safety data sheet (MSDS). Also, drawing F003, sheet 1 of 2, dated 4/23/96, indicates that the nitric acid concentration is 9 percent lower than the concentration listed in the Hazards Analysis, page 6, Section 2.10.
Queedon:
a)
Please confirm the concentration that will be used in the MERF.
4)
Reference Modular Extraction / Recovery Facility (MERF): Hazard Analysis, EMF.1946, Revision 0, page 2, Sections 2.1.4 and 2.1.5. There is a discussion about wet wastes and alcohol contaminated rags. The Fire Hazard Analysis (FHA) for the MERF, dated 2/12/97, page 1, discusses waste containing small amounts of tributyl phosphate (TBP),
dodecane, lubricating oils and greases (organics). Also on page 1 is the statement that bench scale tests were conducted on three of four waste types anticipated in the MERF, and at that time, alcoho; rags had not been defined as a waste stream that would be treated in the MERF.
Question:
a)
Did the bench-scale tests discussed above confirm that incompatible reactions between the organics, including alcohol, and oxidizers (nitric acid and hydrogen peroxide) are not going to occur and operators can safely perform the washing / extracting and precipitation steps without the potential of an incompatible reaction occurring?
Enclosure
b 2
5)
Attachment A, page 13 of the MNular Extraction / Recovery Facility (MERF): Hazard Analysis, EMF 1946, Revision 0, states there is a potential explosion hazard if ammonium nitrate accumulates in the facility.
Questions:
a)
Has the compatibility of dodecane, lubricating oils, nitric acid and hydrogen peroxide with ammonium nitrate been considered and documented?
b)
What measures have been taken to promote worker safety and prevent these potential incompatible reactions from occurring?
6)
The washer / extractor will be heated by injecting saturated steam at (100 psig and 334 degrees Fahrenheit) into the washer /uxtractor drum to maintain a temperature in excess of 100 degrees Fahrenheit.
Questions:
a)
What measures or controls are provided to prevent an operator from opening the washer door during injection of 334 degree saturated steam into the nitric acid solution?
b) is there a device that prevents opening the door until the temperature has cooled sufficiently to prevent injury to the operator?
c)
Are safety controls tested to ensure that they will perform as expected at startup and during operations?
d)
How will these controls be tested?
7)
Reference the MERF Hazards Analysis, EMF 1946, Revision 0, Attachment A page 12.
The safeguards for the What if scenario where the temperature control valve falls on the steam line to the washer and UNH tank are: (1) High temperature indication, (2) Operator will be attending the machine during operation, and (3) Routine calibration.
Questions:
a)
If the temperature sensing device fails, what happens with the temperature control valve?
b)
If the temperature sensing device loses power, would the high temperature indicator still operate?
c)
Are there separate temperature sensing devices for the temperature control valve and the temperature indicator? Are there redundant temperature sensing devices?
d)
If the MERP facility loses electrical power, does the temperature control valve fail in a safe position, i e., closed?
e)
Does routine calibration, described in (3) abo'te, involve a functional test where a high temperature is simulated and the temperature control valve is venfied to close?
f)
Are there separate temperature sensing devices for the UNH Hold Tank and Washer / Extractor temperature control valve?
8)
Reference the MERF Hazards Analysis, EMF 1946, Revision 0, page 28, Attachment D, Material Gafety Data Sheet 30 % Hydrogen Peroxide, Section 7 Handling and Storage.
The MSDS recommends the following for hydrogen peroxide storage: store in a cool, dry, well ventilated area; do not store near heat or flame; and, store below 100 degrees Fahrenheit. According to drawing G003, sheet 1 of 1, dated 11/12/90, hydrogen r-e w y w
-e
~_.- -
3-
, peroxide will be stored in the Raw Material /Stort.ge Area Weatherport Enclosure, which includes the steam boiler.
Questions:
a)
Will the storage conditions recommended in the MSDS be met?
b)
How will these storage conditions be maintained? If they can not be maintained, have the consequences and associated risks with hydrogen peroxide thermal decomposition been considered?
9)
Prior to opening drums at the Sorting Station, are they checked for bulging or other signs of pressure build up? If a drum is suspected to be pressurized, what measures are being used to relieve the pressure? 18 a check for pressure in the drum required by procedure or covered during operator training classes?
10)
The MERF Hazards Analysis, EMF 1940, Revision 0. Section 2.10, Nitric Acid Supply System, page 6, and the Siemens RAI response to Question 13, dated 1/27/97, states that concentrated nitric acid is pumped via a metering pump through a flow totalizer to a hold tank where the nitric acid solution is made up.
Questions:
a)
How is the concentration of the nitric acid solution controlled and verified?
b)
If the flow totalizer fails or pumps the incorrect amount, what is the highest nitric acid rolution concentratiori that could be achieved in the washer / extractor? If a higher nitric acid concentration was obtained, would this result in incompatible 4
reactions between the nitric acid (oxidizer) and organic (lubricating oils, greases, dodecane, alcohol) contaminants? What controls are in place to prevent this?
4
_,.s
-..-r
.. - _, _ -_. -.,~.,-
August 22, 1997 Mr. L. J. Maas Manager, Regulatory Compliance Siemens Power Corporation 1
2101' Horn Rapids Road Richland, Washington 99352 0130
SUBJECT:
REQUEST FOR ADDITIONALINFORMATION, AMENDMENT APPLICATION DATED AUGUST 22,1996 AND THE HAZARD ANALYSES DATED MARCH 3 AND MAY 1,1997 (TAC NO L30896)
Dear Mr. Maas:
This refers to your application dated August 22,1990 and the Hazard Analyses dated i
March 3 and May 1,1997, requesting the revision of License SNM 1227 to include low level radioactive waste (LLRW) shredding and uranium recovery from LLRWin a modular recovery unit as an authorized activity. Our review of the revision has identified additional information that is needed before final action can be taken on your amendment request. This additional information is described in the enclosure to this letter, The additionalinformation should be provided in the form of responses to the individual comments within 30 days of the date of this letter. Please reference the above TAC number in future correspondence related to this request.
If you have any questions, please Call me at (301) 415-8119.
Sincerely, g,
g Kimberly J. Hardin Licensing Section 2 Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS Docket (01257 License SNM 1227
Enclosure:
Requent for AdditionalInformation DISTR _lBMTIOB w/ enclosures:(Control No. 4EOS)
Doa.ket 70-1257--
PUBLIC NRC File Center CHooker, RIV SChotoo FCLB r/f FCSS rif NMSS r/f Region IV -
G:\\SIE MERF.RAI O,'O FCLB E
FCLB E
FCLB
{
FCLB f.
FCLB M
DStouth KHardinM PShea n,,, g HAstwoodpd MWeberM NAME I
8/S/97 8/M(97 DATE 8/397 8/U/97 8/37 E = COVER & ENCLOSURE N = No COPY C = COVER OFFICIAL RECORD COPY NRC FIE CENTER QH't cr90 %eHe WP
Requc$t for AddliionalInformation Application Dated August 22.19%
i Siemens l'ow er Corporation Docket 701257 1)
Drawing F003, sheet 2 of 2, dated 4/?3/90, indicates that precipitated uranium will be pumped through a filter.
Questions:
a)
What safety devices are in place to prevent operators from being sprayed with uranium solution if a leak occurs in piping, connections, or the filter?
b)
How are these safety devices maintained and tested, to ensure that they remain in place and will function if needed?
2)
Drawing G003, sheet 1 of 1, dated 11/12/96, indicates the Raw Material Storage Area contains nitric acid, sodium hydroxide, hydrogen peroxide, and a propane fired boiler which is within 6 feet of the heating ventilation and air conditioning (HVAC) skid.
Questions:
a)
Has the possibility of a chemical release or propane release from the Raw Material Storage Area, being drawn into the HVAC air intake, been analyzed?
b)
What effect would this type of release have on operators in the modular extraction / recovery facility (MERF)?
3)
Drawing F003, sheet 2 of 2, dated 4/23/00, indicates that the hydrogen peroxide concentration is 5 percent higher than the concentration in the material safety data sheet (MSDS). Also, drawing F003, sheet 1 of 2, dated 4/23/96, indicates that the nitric acid concentration is 9 percent lower than the concentration listed in the Hazards Analysis, page 6, Section 2.10.
Question:
a)
Please confirm the concentration that will be used in the MERF.
4)
Reference Modular Extraction / Recovery Facility (MERF): Hazard Analysis, EMF 1946, Revision 0, page 2, Sections 2.1.4 and 2.1.5. There is a discussion about wet wastes and alcohol contaminated rags. The Fire Hazard Analysis (FHA) for the MERF, dated 2/12/97, page 1, discusses waste containing small amounts of tributyl phosphate (TBP),
dodecane, lubricating oils and greases (organics). Also on page 1 is the statement that bench-scale tests were conducted on three of four waste typt.s whipated in the MERF, and at that time, alcohol rags Nad not been defined as a waste stream that would be treated in the MERF, Question:
a)
Did the bench scale tests discussed above confirm that incompatible reactions between the organics, including alcohol, and oxidizers (nitric acid and hydrogen peroxide) are not going to occur and operators can safely perform the washing / extracting and precipitation steps without the potential of an incompatible reaction occurring?
Enclosure
o 2-5)
Attachment A, page 13 of the Modular Extraction / Recovery Facility (MERF): Hazard Analysis, EMF 1946, Revision 0, states there is a potential explosion hazard it ammonium nitrate accumulates in the facility.
Questions:
a)
Has the compatibility of dodeca 9, lubricating oils, nitric acid and hydrogen peroxide with ammonium nitrate beeri considered and documented?
b)
What measures have been taken to promote worker safety and prevent these potentialincompatible reactions from occurring?
6)
The washer / extractor will be heated by injecting saturated steam at (100 psig and 334 degrees Fahrenheit) into the washer / extractor drum to maintain a temperature in excess of 100 degrees Fahrenheit.
Questions:
a)
What measures or controls are provided to prevent an operator from opening the washer door during injection of 334 degree saturated steam into the nitric acid solution?
b) is there a device that prevents opening the door until the temperature has cooled sufficiently to prevent injury to the operator?
c)
Are safety controls tested to ensure that they will perform as expected at startup and during operations?
d)
How will these controls be tested?
7)
Reference the MERF Hazards Analysis, EMF 1946, Revision 0, Attachment A, page 12.
The safeguards for the What if 'cenario where the temperature control valve fails on the steam line to the washer and UNH tank are: (1) High temperature indication, (2) Operator will be attending the machine during operation, and (3) Routine calibration.
Questions:
a)
If the temperature sensing device fails, what happens with the temperature control valve?
b)
If the temperature sensing device loses power, would the high temperature indicator still operate?
c)
Are there separate temperature sensing devices for the temperature control valve and the temperature indicat er? Are there redundant temperature sensing devices?
d)
If the MERF facility loses electrical power, does the temperature control valve fail in a safe position, i.e., closed?
e)
Does routine calibration, described in (3) above, involve a functional tast where a high temperahwe is simulated and the temperature control valve is verified to close?
f)
Are there separate temperature sensing devices for the UNH Hold Tank and Washer / Extractor temperature control valve?
8)
Reference the MERF Hazards Anaiysis, EMF 1946, Revision 0, page 28 Attachment D.
Material Safety Data Sheet 30 % Hydrogen Peroxide, Section 7 Handling and Storage.
The MSDS recommends the following for hydrogen peroxide storage: store in a cool, dry, well ventilated area; do not store near heat or flame; and, store below 100 degrees Fahrenheit. According to drawing G003, sheet i of 1, dated 11/12/96, hydrogen
3 o
peroxide will be stored in the Raw Material / Storage Area Weatherport Enclosure, which includes the stea1n x ier.
Questions:
a)
Will the storage conditions recommended in the MSDS be met?
b)
How will these storage conditions be maintained? If they can not be maintained, have the consequences and associated risks with hydrogen peroxide thermal decomposition been considered?
9)
Prior to opening drums at the Sorting Station, are they checked for bulging or other signs of pressure build-up? If a drum is suspected to be pressurized, what measures are being used to relieve the pressure? Is a check for pressure in the drum required by procedure or covered during operator training classes?
10)
The MERF Hazards Analysis, EMF 1946, Revision 0, Section 2.10, Nitric Acid Supply System, page 6, and the Siemens RAI response to Question 1.3, dated 1/21/97, states that concentrated nitric acid is pumped via a metering pJmp through e flow totalizer to a hold tank where the nitric acid solution is made up.
Questions:
a)
How is the concentration of the nitric acid solution controlled and venfied?
b)
If the flow totalizer fmils or pumps the incorrect amount, what is the highest nitric acid solution concentr thn that could be achieved in the washer / extractor? If a higher nitric acid concentration was obtained, would this result in incompatible reactions between the nitnc acid (oxidizer) and organic (lubricating oils, greases, dodecane, clcohol) contaminants? What controls are in place to prevent this?
I s
1,
,-,--v y,,,v y-
-.v,r-
--..y--
.,e.
m 27w-----y,-x-.-m.-
,,r e---
-eav
,,,-,++..e.m-
-,e e.w w
g--m--,-.-
-. -+
e
- - - - ~~.