ML20210V442

Forwards Response to Questions in Ltr & Hazard Analyses & 0501

ML20210V442
Person / Time
Site:	Framatome ANP Richland
Issue date:	09/09/1997
From:	Edgar J SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER
To:	Weber M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
JBE:97:146, TAC-L30896, NUDOCS 9709230334
Download: ML20210V442 (9)

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SIEMENS:

September 9,1997 JBE:97:146

. U.S. Nuclear Regulatory Commission Attn: Mr. M.F. Weber, Chief Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS Washington, DC 20555

Subject:

- NRC RAI (TAC No. L30896)

Ref.:

Letter, K.J. Hardin to L.J. Maas, " Request for Additional Information, Amendment Application dated August 22,1996 and the Hazard Analyses dated March 3 and May 1, 'i 997 (TAC No. L30896)".

~ Attached are Siemens Power Corporation's (SPC's) response to the questions in the referenced letter.

/

Very truly yours, 8{B. Edgar Jam Staff Engineer, Licensing

/pg Enclosures s\\

toe *EENEdI l!!ElElR.IEEjH.iB.

c Siemens Power Corporation Nuclear Division 2101 Horn Rapids Road Teh (509) 375 8100 Engineering & Manufacturing P.o. Box 130 Fax:

(509) 375 8402 Richland, WA 9S352 0130

$1. F. Web:r Attachment September 9,1997 Page 1 Attachment

1) NRC Reouest Drawing FOO3, sheet 2 of 2, dated 4/23/96, indicates that precipitated uranium will be pumped through a filter.

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?

SPC Responso Most of the piping throughout the facility is either welded, fused or solvent cemented.

Mechanical fittings are minimized. Splash guards will be installed on all flanged fittings on pipes which carry corrosive liquids. Safety shields will be instdlied on rotameters. Filtration by the Oberlin Filter is achieved automatically within a stainless steel enclosure, inspection of the piping prior to startup will evaluate any add.tional requirements to protect the worker from being sprayed with process solutions. Daily inspection of the facility for leaks and spills is required. The operator will notify supervision any time there is a leak in the piping, connections or the tiher. Operations will not proceed until the leak has been fixed.

Additionally, the operators are required to wear safety glasses in the facility. When changing out chemical drums / totes in the Raw Material Storage Area, the operator is required to wear eye, hand, body and foot protection that is resistant to the chemical being handled.

b) How are these safety devices maintained and tested, to ensure that they remain in place and will function if needed?

SPC Resoonse Safety shields and splash guards will be inspected for correct installation. They will not be removed without approval from the supervisor and then they must be replaced before operations can begin. Periodic safety inspections will check that these protective devices are in place and in a fu!!y functional condition.

2) NRC Reouest 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.

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?

$1. I'. Wsbir Attachment September 9,1997 Page 2 SPC Responsa These scenarios have not formally been analyzed but are considered very unlikely. In the I

caso of propane, it assumes that a major propane leak occurs, the propane gas detector has failed, and that there is a breach in the walls of the Raw Materials Storage Area, it should be noted thbt the propane storage tank is remote from the f acility and the lines from the tank to the facility are underground. Scenarios related to the process chemicals are similarly unlikely, l.a., requiring chemical container leakage and breaching of the walls of the Raw Material

' Storage Area, b) What effect would this type of release have on operators in the modular extractionhecovery f acility (MERF)?

SPC Response As discussed above, the likelihood of any of these chemicals reaching the MERF operations -

area, via the postulated accident scenario, is very low. The risks are further mitigated by a number of factors, including good physiological warning properties via smell or sensory irritation (propane, nitric acid vapor, sodicm nydroxide, hydrogen peroxide), very low volatility i

(sodium hydroxide) or toxicologicalinertness (propane), if any of these chemicals were detected in unocceptable concentrations in the MERF operating areas, the operator would 3'

investigate the source and initiate corrective action. Operations would cease until the source was eliminated. The presence of high concentrations, albeit highly unlikely, would necessitate evacuation until the situation could be corrected.

3) NRC Reauest

-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 FOO3, sheet 1 of 2, dated 4/23/96,-indicates that the nitric acid concentration is 9 percent lower than the concentration !isted in the Hazards Analysis, page 6, Section 2.10.

a) Please confirm the concantration that will be used in the MERF.

SPC Resoonse The actual concentrations for the respective chemicals used in the MERF facility are as i

follows:

t 30% Hydrogen Peroxide 50% Sodium Hydroxide 68% Nitric Acid Originally the concentration of hydrogen peroxide was to be 35%. However, it was felt that the 30% concentration would be safer to handle. Nitric acid, at a concentration of 57%, was

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$1. F') absr Attachmsnt September 9,1997 Page 3 3

to be downloaded from SPC's bulk tank, but our chemical supplier was able to supply nitric acid (68%) in stainless steel totes at a price that could not justify the cost of building a new downloading station. By receiving full totes of nitric acid from the supplier, instead of filling i

totes from our bulk tank, we feel that the added safety from reduced handling more than offsets the danger due to higher concentration, in both cases, the drawings were not i-updated to reflect the change in concentrations. The sodium hydroxide concentration (50%)

has not been changed.

41 NRC Reouest 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 tests 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.

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 occurO gJ SPC Respongg Bench scale tests evaluated HEPA filter media, prefilters and wet wastes. The wet wastes,

-_ containing organics, did not result in an incompatible reaction. -The alcohol rags were not tested. However, once in the washer / extractor, a pre-rinse cycle will be run to remove most of the alcohol prior to the addition of nitric acid. Incompatible reactions with very low residual concentrations of alcohol are not expected. Only three batches (50,30-gallon drums) of alcohol rags will be run.

5) NRC Reauest 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 f acility, a)-Has the compatibility of dodecane, lubricating oils, nitric acid and hydrogen peroxide with ammonium nitrate been considered and documented?

SPC Resoonse The explosion hazard referenced in the hazard analysis was due to postulated accumulation of ammonium nitrate solids in the ductwork followed by welding of the ductwork without

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M. P. Wabsr Attachment

- September 9,1997 Page 4 f

inspection and removal of these solids, it was not related to incompatible chemical reactions associated with dodecane, lubricating oils, nitric acid and hydrogen peroxide. However, bench-scale testing did not exhibit incompatible reactions with these chemicals due to ammonium nitrate.

b) What measures have been taken to promote worker safety and prevent these potential incompatible reactions from occurring?

SPC Rergpngt Low concentrations of ammonium nitrate are expected in the process solutions. We do not anticipate, nor did bench-scale tests demonstrate any significant incompatible reactions.

Significant quantitles of white solids on any of the waste materials will require, by procedure, a pre-rinse cycle in the washer / extractor to significantly reduce the ammonium nitrate concentration prior to the addition of nitric acid.

6)' NRC Reauest 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.

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?

_SPC Resoonse The washer / extractor's control syatem program will not allow the access doors to be opened during operation. A1 operator cannot access the washer unless the program has been terminated. With the door open, the solenoid valve for injecting steam into the washer will not open, b) is there a device that prevents opening the door until the temperature has cooled sufficiently to prevent injury to the operator?

SPC Resoonse Access to the washer / extractor under normal operating conditions is intended to occur at the end of the cycle, following a cold water (70 F) rinse step. The washer / extractor's microprocessor is the device that ensures that this cold water rinse occurs and that solenoid valves controlling steam and chemical addition remain closed to prevent injury to the operator during loading and unloading operations c) Are safety controls tested to ensure that they will perform as expected at startup and during operations?.

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. F. Webir Attachmsnt September 9,1997 Page 5 SPC Resoonse

-The safety features for the washer / extractor will be tested in a formal Acceptance Test Procedure (ATP). The door interlocks and the solenoid valves for chemical ard steam

_ addition will be specifically tested to ensure that the operator cannot gain access until it is safe to enter. Daily operation of the washer / extractor and its control system will then be closely monitored. Any problem or malfunction will require immediate resolution before operations can continue.

d) How will these controls be tested?

SPC Resoonse The washer extractor will be operated with c!ean waste materials prior to startup. All of the safety controls and interlocks will be evaluated at that time, per the ATP, to ensure they are functioning properly,

7) NRC Reauest 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 washar and UNH tank are: (1) High temperature indication, (2) Operator will be attending the machine during operation, and (3) Routine calibration, a) If the temperature sensing device fails, what happens with the temperature control valve?

SPC Response The temperature control valve will close to shut down the flow of steam if the temperature sensor fails, b) is the temperature sensing device loses power, would the high temperature indicator still

- operate?

SPC Resoonse The high temperature indicator would not operate if the sensor loses power.

c) Are there separate temperature sensing devices for the temperature control valve and the temperature indicator?- Are there redundant temperature sensing devices?

SPC Resoonse There is only one sensor that provides the input to the indicator and the control valve. There are no redundant temperature sensing devices.

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fA.12. Web:r Attcchm:nt September 9,1997 Page 6 d) If the MERF facility loses electrical power, does the temperature control valve fall in a safe position,' i.e., closed?

SPC Resoonse In the event of a power failure, the temperature control va!ve will fail in the closed position and shut off the flow of steam._

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?

~ SPC Response l

Routine calibration means that the temperature sensor will be tested to ensure that the accuracy of the reading is within allowable tolerances. ' Additionally, a functional test will evaluate the operation of the temperature control valve by inputting a high temperature signal into the controller. This testing will be conducted annually, f) Are'there separate temperature sensing devices for the UNH Hold Tank and Washer /kxtractor temperature control valve?

SPC Resoonse There are separate temperature control devices for the UNH Hold Tank and _the washer / extractor.

8) NRC Reauest 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 fol.owing 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'11/12/96, hydrogen peroxide will be stored in the Raw Material / Storage Area Weatherport Enclosure, which includes the steam boiler, a) Will the storage conditions recommended in the MSDS be met.

SPC Resoonse The hydrogen peroxide will not be stored in direct proximity to the boiler.- However, storage of chemicals in the Weatherport enclosure is subject to ambient conditions. Therefore, the temperature may exceed 100* F in the summer. All other conditions will be met.

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.- k I. Web:r E

Attachment September 9,1997-Page 7 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?

SPC Response The temperature in the Raw Material Storage' Area will not be maintained. However, the manufacturer of hydrogen peroxide has been contacted regarding storage at temperatures greater than 100* F (weather conditions for the Richland area). They indicated that the rate of thormal decomposition is very slow and should not pose a problem. Also, each chemical tote or drum will be stored on individual containment basins to prevent intermingling of chemicals as a result c8 a spill or leak.

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_9) NRC Reauest Prior to opening drums at the Sortir.g Station, are they checked for bulging or other signs of -

4 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 curing operator training classes?

i SPC Response The plastic drums containing wet waste are the only ones likely to be pressurized and then mainly in hot weather. They will be visually inspected for bulging. Every drum will be opened and vented in the glovebox. The operators will be made aware in training sessions that the drums can be pressurized and to use caution when opening.

10)NRC Reauest -

The MERF Hazards Analysis, EMF 1946, Revision 0, Section 9.10, Nitric Acid Supply System, page 6, and the Siemens RAI response to Question 1.3, datea 1/27/97, states tMt concentrated nitric acid is pumped via a metering pump through a flow totalize, to a hold tank where the nitric acid solution is made up, a) How is the concentration of the nitric acid solution controlled and verified?

SPC Response Water will be added to the UNH Hold Tank to a preset level. The nitric acid flow controller will be set for the specified volume of nitric acid. The operator will confirm that nitric acid is flowing and that the desired volume has been delivered. A check of the tank level (level gauge)_will confirm that the correct arr, sunt of acid is added.

. M. F. Webtr Attachmsnt September 9,1997 Page 8 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 (oxidizer) and organic (lubricating oils greases, dodecane, alcohol) co'itaminants? What controls are in place to prevent this?

SPC Response The highest concentration of nitric acid that can be achieved for u e in the washer extractor would be approximately 6 molar. To achieve this concentration requires the addition of excess nitric acid to the point of overflowir:g the tank.

Bench-scale tests were conducted with nitric acid concentrations as high as 5 molar without any observable incompatible reactions with the organic contaminants. Therefore, it is not expected that at 6 molar, these reactions would occur.

A flow controller is used to ensure the correct addition of nitric acid into the UNH Hold Tank.

Additionally, an operator would be at the tank, by procedure, to ensure that the nitric acid volume does not exceed the preset level (pec the level gauge) for making a 3 molar solution.

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