ML20214E484
| ML20214E484 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 04/30/1987 |
| From: | Mccullugh R SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER |
| To: | Jonathan Montgomery NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20214E458 | List: |
| References | |
| NUDOCS 8705220105 | |
| Download: ML20214E484 (15) | |
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EO-ADumC8DNUCLEARFERLS. CORPORA 110N
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April'30, 1987.
' U.S. Nuclear Regulatory Commission', Region - V Attention:.Mr. J mes L. Montgomery,' Chief Nuclear Materials' Safety and Safeguards Branch.
1450 Maria Lane, Suite 210 Walnut Creek,-CA 94596 License No. SNM-1227 Docket No. 70-1257
Dear Mr.= Montgomery:
This refers to the team assessment of operational safety conducted November 3-7, 1986 by the NRC.and various other Federal and State ~ agencies and to.the-final report of that assessment.
We have reviewed the final report of the assessment and-a copy of the-results of that review is enclosed.
Please recognize that although our response to individual comments or recommendations from that-review!are ~ believed to be valid, as -we work with the appropriate authorities in ca specific.~ area any actions could turn out to be different from those projected at.this time.
In reviewing the assessment report, we found that in 'a preponderance of cases, we had reached similar, or identical conclusions as the assessment team and frequently, already had implementation programs in ~various ' degrees: of completion.
In only a few cases are there areas of disagreement. We are also, pleased that there was no violation.of regulation or. law cited in the assessment.
report.
i Very truly yours, kbW$ f R. W. McCullugh RWM:kk Enclosure h52 O
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RESPONSES TO NRC SAFETY ASSESSMENT TEAM REPORT Recommendation 3.A.(1):
Evaluate the necessity of using moderation and concentration controls as opposed to the inherently safer mass and geometry controls.
Response
It is an industry practice and the practice of Advanced Nuclear Fuels to preferentially use geometry control vs. moderation and concentration controls to assure criticality safety.
Moderation controls, concentration controls, and mass controls are implemented in systems where no practicable alternatives exist and where. administrative and other controls assure a very low probability of accidental criticality. -The adequacy of these controls is continuously monitored.
Recommendation 3.A(2):
Reconsider use of f avorable geometry containers in uranium recovery operations.
Response
The drums used to contain the product from uranium recovery operation are controlled by mass and spacing limits.
Favorable geometry containers would be the preferred control.
However, use of smaller containers would require handling and storage of many more units.
When potential accident conditions with large arrays and frequent handling are compared to relatively small arrays and less frequent handling, the additional safety margin becomes less than one would expect.
The containers have been evaluated at numerous potential accident conditions.
Stringent administrative controls with close supervision and auditing are used to assure safety in the uranium recovery operations.
Recommendation 3.A.(3):
Earlier removal of empty UF6 cylinders from the vaporization rooms be re-evaluated by Exxon in light of the need to maximize the opportunity for prompt unrestricted egress during an emergency.
Response
Empty UF6 cylinders are routinely decontaminated outside the vaporization chests before they are returned outside. Generally, the empty cylinder is set on the floor of the vaporization room while the crane is used to bring in the next full cylinder.
. The recommended reevaluation was completed with the conclusion that even with an empty cylinder on the floor, there is adequate room for rapid operator egress from one of the two available exits (one exit is to the outside; the second is into the conversion room which is an acceptable emergency escape route from the vaporization room).
Recommendation 3.A.(4):
Exxon should assure that moderation control signs are placed in a manner that clearly indicates the area to which they apply.
Response
Moderation signs are placed in a manner as to be readily noticeable to employees entering that area. To avoid confusion as to what area is indicated as moder-ated by the. signs, each piece of moderated equipment is also designated with special 2-inch wide black / white checkered tape placed around the equipment.
If the checkered tape can not be placed around the equipment, as in the vertical powder blenders, a special sign (outlined in the criticality specifications) is attached to the equipment.
Recommendation 3.B.(1):
Document evaluation of vehicle accident involving a fire around stored UF6 cylinders.
Response
Advanced Nuclear Fuels will document an evaluation of vehicle accident involving a fire around the stored UF6 cylinders addresseu in the study " Source - Term Development for Evaluation of Emergency Preparedness Needs for Non-Reactor Facilities" Recommendation 3.B.(2)(a):
The licensee should revise process shutdown procedures no. P66,339 and P66,353 for lines 1 and 2 respectively to incorporate instructions to operators for manually scramming all UF6 related process equipment prior to evacuation of the UF6 facility in an emergency such as a fire.
Response
The two subject operating procedures are being revised to add a statement for manual shutoff of the UF6 valve in the event of an emergency such as fire.
Recommendation 3.B.(2)(b):
Evaluate health hazards associated with the use of Dimethyl Silicone fluid #50 centistokes at 5900F and determine protective measures employees and fire fighters would need in an emergency.
Response
Dimethyl silicone fluids, also known as dimethyl polysiloxane, consist of linear silicon-oxygen polymers that have methyl groups attached to the silicon atoms.
4 Dimethyl polysiloxane fluids are non-toxic.
Ingestion of large amounts would be expected to have a laxative effect, much like that of white mineral oil.
Dimethyl polysiloxane fluids slowly degrade at high temp'eratures-in inert
~(oxygen free) environments by polymer " cracking" and rearrangement of silicon-oxygen bonds, which results in the formation of lower molecular weight poly-siloxane by-products.
Dimethyl polysiloxane fluids can react slowly with ' oxygen, when heated to high temperature in the presence of air, to form formaldehyde, oxides of carbon and (at very high temperatures) silicone dioxide.
4 Formaldehyde gas and airborne silicon smoke emitted during oil oxidation' are
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considered the only health hazards associated with the use of dimethyl-. silicone fluids at 5900F, These by-products are irritating and toxic. The Advanced Nuclear Fuels' ADU dryers are installed and operated to avoid oil oxidation.
The oil recirculation, heating, and processing equipment makes _up a closed, oxygen free,. system. The surge tank vapor space is purged-continually with-nitrogen to further reduce the possibility of oil coming in contact with oxygen.
Protective measures needed for emergencies that involve hot oil leaks at dryer operating temperatures, or that'_ involve fires in.the ADU dryer area include
- self-contained breathing air for the emergency personnel to protect them from the oil oxidation by-products inhalation hazards.
Recommendation 3.B.(3)(a):
Evaluate compartmentalizing with _ fire rated construction, in the Gadolinia Solvent Extraction Recovery area of the ELO Building.
Response
The liquids used in this f acility are classified as combustible rather than flammable under the National Fire Code (NFC). The construction of the f acility is adequate per the NFC for the fire load of the rooms.
Recommendation 3.8.(3)(b):
Consider use of explosion proof mixer motors, electrical and other fixtures where flammable liquids are present.
Response
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Af ter reviewing the National Fire Code (NFC) and our process conditions, it was concluded that ANF is already in compliance.with the NFC and with the NRC recommendation and no further action is required.
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.The process in question is solvent extraction where dodecane/tributyl phosphate is used to extract uranium from an aqueous solution.
NFC 321 Section 1.2, classified liquids based on flash point.
" Flammable" liquids are those with a flash point below 1000F.
" Combustible" liquids are those with flash points above 1000F.
NFC 325M records the flash point of dodecane at 1650F. ' This is elevated somewhat by the presence of tributyl phosphate (flash point = 2480F).
The solvent extraction organic phase is therefore a combustible liquid.
It is further classified as Class III based on a flash point exceeding 1400F (NFC Section 1-3.3).
NFC Section 1-1.3 states "When Class II or Class III liquids are heated above their flash points, ventilation or electrical classification may be necessary in the immediate area".
Maximum solvent temperature in the solvent extraction process occurs at the introduction of heated strip water..This temperature is controlled to 1400F,
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well below the flash point.
In cddition, that is the temperature in the bulk of the liquid, but drops off rapidly to ambient in the vapor. All areas where electrical components are located are down to or very near ambient.
l In conclusion, we are not dealing with a flammable liquid which would require l
explosion proof electrical classif ication.
We are dealing with a Class III combustible liquid well below its flash point. We are therefore in compliance with the NFC and the NRC recommendation and no ventilation or electrical classification is necessary.
Recommendation 3.B.(4)(a):
The section of 6-inch pipe feeding the fire main loop from the south should be upgraded to at least a 10-inch pipe.
Response
The City of Richland is taking steps to ihprove the southern supply to the plant to provide water volume and pressure adegnte for fire protection.
A meeting was held with City staff on March 16 wherein bypassing of the 6-inch connection with a 12-inch between the City's 16-inen main and ANF's southern feed was identified as the needed corrective action.
The work should be completed later this year.
Pecommendation 3.B(4)(b):
Provide position indication on the submerged sectional isolation valves for the underground fire main.
Response
Action was initiated to provide position indication of the submerged sectional isolation valves of the plant's fire main loop.
Vendor information has been requested and is forthcoming.
It is anticipated that the actual work can be completed in about six months.
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Recommendation 3.B(5)(a):
Perform a thorough. review of Material Safety Data Sheets for all' hazardous chemicals stored and used onsite and. identify the fire, explosion, reactivity and health hazards associated with these materials. Pre-Fire Plans should be upgraded to reflect this information and local labels 'and other forms of warning
-should be placed at the storage /use locations.
Response
ANF has maintained a complete and accurate MSDS. file for several years and will continue to review and update our~ sheets.as necessary to assure completeness and accuracy.
Our Pre-Fire Plan will contain the latest revision of the Material Safety Data Sheet. Also, an extensive labeling program in accordance with State "Right-to-know" Regulations is in progress and will be completed soon.
Recommendt. tion 3.8.(5)(b):
The onsite and offsite Pre-Fire Plans should be upgraded.
They should be consistent with each other and should contain accurate information about process operation status prior to evacuation and Fire Department response. Addition-ally, the Pre-Fire Plans'should address assianment of responsibility to site personnel assisting in fire emergencies, process hazards, normal facility fire loads, exposure to yard storage'and other precautionary measures to be takeniin predictable abnormal conditions during a fire.
The status of the upgradin the Pre-Fire Plans will be reviewed during subsequent inspections (86-08-03)g of
Response
ANF will be upgrading its Pre-Fire Plans to conform to local Fire Department.
recommendations and format. This will be ' concluded by the end of this year.
Recommendation 3.B.(6):
Upgrade of fsite Fire Department and emergency fire response training to include quarterly training sessions. At least two of these sessions should include an unannounced fire drill in which the critique of each individual participant and group performance is evaluated and documented.
Response
The Richland Fire Department has agreed to increase our present schedule of three training sessions a year (radiological' contamination control, mass casualties triage and annual fire department walkthrough)~ to four sessions. We will add one announced fire drill in additi,on to our schedule of two criticality evacuation drills a year.
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. Recommendation 3.B(7):
l Evaluate the local requirements concerning open burning of materials and l
restrain all open burning to those limitations.
Response
ANF contacted the Richland Fire Inspector's office and the Benton/ Franklin Air Pollution Board for guidance.
Neither Government entity had any problems with our Burn Program. Our current Burn Permit No. B86-412 with the City of Richland covers this operation. Our only limit is to burn on burn days.
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Recommendation 3.C.(1):
l Cycle manually operated valves that back up critical automatic UF6 valves at a frequency that will assure their operability.
Response
The manual valves backing up the critical automatic UF6 valves are actuated each time a cylinder is changed out or a UF6 pigtail is connected or disconnected.
Recommendation 3.C.(2):
Conduct periodic internal audits of (electric) systems and engineering function.
Response
A procedure for conducting internal audits of our electrical system will be prepared and implemented.
Recommendation 3.D.(1):
Update the site diagrams in the Pre-Fire Plans with appropriate locations of hazardous materials, especially those that would require special fire-fighting techniques.
Response
The site diagrams' will be upgraded when the Pre-Fire Plan is revised.
Recommendation 3.D.(2):
Implement a method to audit the plant accident prevention program, either internally or externally, for verification that the program is being followed.
. Response:
An annual independent audit shall be conducted to confirm that all organizations are in compliance with the ANF Safety Program.
Recommendation 3.D.(3):
i Institute a method of audit of. the lock and tag safety practices to assure compliance with the procedure.
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Response
Health and Safety Council Inspection Team personnel will perform a monthly audit of work in progress to assure that lock and tag safety practices are being followed as part of the monthly Health and Safety-Council Safety Inspection.-
Recommendation 3.D.(4):
Institute a plan to provide drains or dikes for storage tanks.
Response
A plan has been approvcd which calls for the elimination of the West Tank Farm, eventual elimination of 01 tanks near the building in the East Tank Farm and disposal of the sulfuric acid tank. All liquid chemical storage tank pads will be either diked to the full capacity of the tank or drained to a lagoon via 'a sump and pump.
When completed, this will provide full compliance with the NRC recommendation.
l Recommendation 3.D.(5):
The types of items on the list of miscellaneous safety items provided to the safety manager for correction should be made available and included during in-house safety inspections.
Response
The ANF liealth and Safety Council that provides the management team that inspects the plant monthly for safety-related and hensekeeping items will be given a detailed inspection guide to use during these inspections which includes the items referred to above.
Recommendation 3.E.(1):
A continuous ammonia monitor should be installed in the precipitation area above the vaporization facility.
. Response:
ANF previously had a continuous ammonia monitoring system which did not work in an acceptable manner. We will review the market again for a system that will provide the needed protection for-our employees, but in the meantime our policy is to monitor the ammonis levels in the Line I and Line II upstairs areas on a quarterly basis.
Sampling is done with 8-hour personnel monitors drawing air from the breathing zone.
Personnel who work in the area and Maintenance personnel are tested.
Normal ammonia levels run well below the 25 ppm limit.
Annual Hazard Communication Classes for area personnel stress the hazards of ammonia vapor and the need to immediately report spills or upset conditions.
In the future, additional emphasis will be placed in training classes on the use of proper respirators when ammonia levels are detectable.
Recommendation 3.E.(2):
Baseline urinary fluorides should be established for employees working in the UF6 conversion areas and etching lab.
Response
l We f ail to see the value of having a single baseline for an individual.
In the event of serious accident with suspected fluoride overexposure, the urinary l
fluoride value would be determined at that time.
A baseline value of zero can be properly assumed, assigning all of the inhaled fluoride to the accident.
t Recommendation 3.E.(3):
i Maintain compressed air nozzle pressure below 30 psi.
Response
All compressed air nozzles have been checked to assure that the air pressure was beloe 30 psi. One unit found to have a higher pressure was removed.
A testing l
device has been f abricated and will be used during monthly Health and Safety Council Safety Inspections to check the air pressures of these nozzles.
l Recommendation 3.E.(4):
A routine inspection schedule should be followed in inspecting glove box gloves for holes and wear.
Response
l The Standard Operating Procedures governing enrichment cleanouts have been determined to be an appropriate place to add inspections of glove box gloves l
because enrichment cleanouts occur on a frequency of one to four times per I
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. month lThe three SOP's' governing enrichment cleanout's (P66,556 for Chemical Operations; P66,426 for Ceramic Operations; P66,425-for Rod Fabrication Operations) will include inspection of gloves for holes and wear.
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~ Recommendation 3.E.(5):
Maintain the'SCBAsiat least 80%_ charged.
Response::
The monthly Preventive Maintenance Checklist used to inspect.our SCBA's has.been i
revised to state that the SCBA air bottles are to be changed when the air' pressureis.lessithan1800 psi (81%'ofmaximum).
i Recommendation 3.E.(6):
Give additional attention to proper.use of hearing protectors by employees.
Response
l Hearing Conservation Classes have been given yearly since 1982. The last class l
given in February of 1987 gave additional attention to the proper use of hearing protectors by employees, i
f Recommendation 3.E.(7):
j Make a complete review of all Material Safety' Data Sheets (MSDSs) for complete-ness and accuracy.
Response
Most of the Material Safety Data Sheets on hand are those sent by the Chemical Manufacturer.
Therefore, ANF is not in the position to know if they are i
accurate.
However, we will review our MSDS file to assure that'_we have' a MSDS '
I to cover all the chemicals that we have on plant site, l
l Recommendation 3.E.(8):
Correct the incompatible storage of chemicals observed in the chemical storage areas.
Response
The WISHA representative provided us with a list of his findings. These findings have been acted on and steps have been taken to assure continued storage compatibility.
. Recommendation 3.E.(9):
j Give additional attention to properly securing gas cylinders.
Response
A representative from a local compressed gas distributor was invited in and gave l
an in-depth presentation on associated hazards and handling techniques for gas-l cyli nders.
Also, the Maintenance supervisors were instructed to remind all Maintenance l
personnel to secure cylinders properly and to be aware of others who also handle I
cylinders.
Recommendation 3.F.(1):
Exxon should incorporate Benton County and Battelle into the planning process.
Response
ANF has invited the Benton County Department of Emergency Management to observe I
and participate in two of our training exercises this year. Battelle Northwest has been invited to participate in one major exercise to be held later in the year.
I Recommendation 3.F.(2):
1 Exxon should review and update the Emergency and Radiological Contingency Plan and supporting appendices. The update should incorporate the chemical emergency issues.
Response
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ANF will be upgrading its Emergency and Radiological Contingency Plan and l
supporting appendices to incorporate the newly mandated emergency response procedures for hazardous chemical spills.
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Recommendation 3.F.(3):
Make the scenarios for annual exercises more complex; e.g.,
involve active participation of offsite agencies / organizations and consider interaction of l
onsite components with Emergency Cadre and offsite agencies / organizations.
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Response
l This year's scenario for the annual exercise will include participation by Benton County Department of Emergency Management, City of Richland Department of Fire and Emergency Services, Kadlec Medical Center, Northwest Health Services
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. and Battelle Northwest. The exercise will include a fire drill, a criticality evacuation drill, mass casualty triage, plant emergency response team partici-pation as well as the Emergency Cadre.
Recommendation 3.F.(4)(a):
Designate Plant Emergency Directors onsite during swing, holiday and weekend shifts who can initiate all emergency response actions without prior approval.
Response
The Emergency and Radiological Contingency Plan (XN-NF-32) specifically defines the emergency response actions to be taken in accordance with the seriousness of the emergency event.
Recommendation 3.F.(4)(b):
The Emergency and Radiological Contingency Plan should be amended to permit immediate and unilateral emergency response actions such as personnel rescue, fire suppression and damage control without the need for approval or concurrence of the offsite PED.
Response
The Emergency and Radiological Contingency Plan (XN-NF-32) carefully differen-tiates between the various levels of emergency events; some of which permit immediate response, others of which do not.
Recommendation 3.F.(5):
Contact DOE and other of f site laboratories to determine what standardized sampling and sample preparation procedures to use during an emergency to facilitate valid data intercomparisons.
Response
In the event of an emergency, it is postulated that the major need for chemical analysis would be for the uranium content on soils.
There would be a lesser need for fluoride contamination on soils.
Both are considered.
Methods of soil sampling have been reviewed with Battelle Northwest.
This organization is responsible for environmental sampling for the DOE Richland Operations. Their method of sampling is compatible with that done by ANF.
Sample preparation, i.e. homogenization and sub-sampling is done by U.S.
Testing. Their procedure is somewhat different than ANF. The ANF procedure i s being changed to more closely represent the U.S. Testing technique.
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. Analysis for trace uranium can be done by U.S. Testing and Westinghouse Hanford.
Higher concentration of uranium can be done by Westinghouse by titration.
They can also perform fluoride analysis by pyrohydrolysis.
All of these procedures are comparable to those used by ANF.
Recommendation 3.F.(6):
A detailed description, supplemented by plant diagrams, should be incorporated into the Emergency and Radiological Contingency Plan to identify the specific locations of the radiological and chemical materials which are processed or stored.
Resanse:
l The Pre-Fire Plan will have the specific locations of the radiological and chemical materials which are processed or stored on plant.
This will be incorporated by reference in the Emergency and Radiological Contingency Plan.
Recommendation 3 F.(7):
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Exxon should institute an annual independent audit of their Emergency Prepared-ness Program.
The report distribution should include the Industrial Health and l
Safety Council.
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Response
An annual audit of the ANF Emergency Preparedness Program will be performed by an independent agent.
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Recommendation 3.F.(8):
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Improve documentation of critiques of exercises and drills, and of any resulting l
open items which require followup corrective actions.
Response
Documentation will be more extensive. Any open items will be followed by the Health and Safety Council until completed.
Recommendation 3.F.(9):
Conduct independent audits of emergency response actions during annual exer-cises.
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Response
Independent audits will be performed per the recommendation.
t Recommendation 3.G.(1)(a):
,7 Obt ai n and analyze groundwater s ampl es for the presence. of _various organics -- at a minimum include the volatiles such as chlorinated solvents used as degreasers.
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Response
The chlorinated solvents used on plant site are 1,1,1-Trichloroethene,and 1,1,2-Trichloro - 1,2,2-Trifluoroethane. Approximately two 55-gallon drums of -
each chemical are stored on plant site as new chemical. Up to two 55-gallons drums of each chemical (5-50% solvent)-may be stored on plant as hazardous waste.
The waste chemical is stored in a special diked area that can hold all liquid from any spill. The processes that use these chemicals are above ground and very localized.
Leaks or spills from storage or use would be immediately noticed and corrective action taken. ANF will take test well samples for these solvents so that we have a reference to background. Further sampling need only be done after a spill that could effect groundwater levels.
Underground fuel or chemical storage tanks or piping systems are new and leakage is not expected.
Any leakage detection by volume loss would call for well-sampling when such a leak could effect groundwater organic levels.
4 Recommendation 3.G.(1)(b):
Discontinue the practice of spraying used oil on roads for dust control unless information can be provided which conclusively shows that the contents of the waste oil are biodegradable and non-toxic.
Response
This has been discontinued.
Recommendation 3.G.(2):
Explore thoroughly the possible production of toxic chemicals during incinera-tion in light of the overall concept of environmental impact of the various site activities.
The second area of concern is that of incineration of chemical / industrial wastes on site.
The licensee is now 'in the process of applying for a permit to incinerate much of the wastes now stored above ground on site.
The purpose of this is to facilitate the process of uranium recovery from these wastes.
There is considerable public concern about the possibility of toxic chemicals being generated by the incineration of " Hazardous" wastes, and even of " municipal" T
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, wastes in such incinerators.
The possible toxic chemicals generated include dibenzofurans, dibenzodioxins, polycyclic aromatic hydrocarbons (PAH), etc.
To satisfy both air and hazardous waste requirements at the state and local level, the licensee may possibly have to obtain other permits or forms of clearance with the Washington State Department of Ecology and the local air authority.
This could possibly include requirements for emission monitoring, identification of materials to be burned, test burning, etc.
Response
The local air authority has given approval for construction and operation of the planned ANF incinerator and the Washington State Department of Ecology currently has the facility under review. The incinerator is designed for high destruction and removal efficiency by combining high temperature secondary chamber operation (22000F) with a residence time in excess of two seconds and an excess oxygen content of at least three percent.