ML20216J792

Forwards Revised Affidavit & non-proprietary Version of Response to NRC RAI W/Info Licensee Considers Proprietary Blanked Out.Previous Affidavit Was Not Adequate for NRC to Judge Whether to Withhold Info in Response

ML20216J792
Person / Time
Site:	Framatome ANP Richland
Issue date:	03/19/1998
From:	Maas L SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LJM:98:028, LJM:98:28, NUDOCS 9803240078
Download: ML20216J792 (15)

Text

a 7SIEMENS

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March 19,1998 LJM:98:028 -

U.S. Nuclear Regulatory Commission 4

Attn: Document Control Desk l

Washington, DC 20555 i

i Gentlemen:

Subject:

Siemens Power Corporation Proprietary Information - Docket 70-1257 Ref.:

Letter, J.B. Edgar to M.F. Weber, " Response to LUR/SPF RAI," dated November 21, 1997 Siemens Power Corporation (SPC) has been informed by the NRC that the affidavit included with the referenced letter was not adequate for the NRC to judge whether to withhold the information submitted in an attachment to that letter from public disclosure. SPC is therefore submitting herein a revised affidavit. In addition, enclosed are six copies of a non-proprietary version of that attachment with the information SPC considers proprietary blanked out. This version may be publicly disclosed.

If you have questions or require more information, please contact me at 509-375-8537.

Ve truly yours, o

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L. J. Maas, Manager Regulatory Compliance

/pg Enclosures 9803240078 980319 PDR ADOCK 07001257 C.

PDR Siemens Power Corporation

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Nuclear Division Headquarters P.o. Box 130 Tel:

(509) 375-8100 g

Enginesting & Manuf acturing 2101 Hom Rapids Road Fax:

(509) 375-8402 Richland, WA 99352 0130

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Affid.vit cf R;ymond E. Vaugh;n 1, Raymond E. Vaughan, being first duly sworn, depose end says:

1. ' I am Manager, Safety, Security & Licensing of Siemens Power Corporation - Nuclear Division, a corporation duly organized and existing under and by virtue of the laws of the State of Delaware, with offices at 2101 Horn Rapids Road, City of Richland, County of Benton, State of Washington, and on whose behalf I make this affidavit.

2. I am familiar with the contents of the attachment to the November 21,1997 letter,

Response to LUR/SPF RAl" from Siemens Power Corporation - Nuclear Division to the U.S. Nuclear Regulatory Commission. This information:

(i) is owned by Siemens Power Corporation - Nuclear Division, (ii) has been held in confidence by Siemens Power Corporation - Nuclear Division pursuant to its internal policies, (iii) is presented to the U.S. Nuclear Regulatory Commission in confidence, (iv) is not available from public sources, (v) is of a type normally held in confidence by Siemens Power Corporation - Nuclear Division; and (vi) if publicly disclosed would likely cause substantial harm to Siemens Power Corporation - Nuclear Division's competitive position because Siemens Power Corporation - Nuclear Division has expended considerable resources in time and money in developing the LUR and SPF processes and the information claimed herein to be proprietary, if used by a competitor of Siemens Power Corporation - Nuclear Division, could result in such competitor's gaining a competitive advantage without expending such resources.

I am authorized to make the statements that are set forth herein and in the above-mentioned letter on behalf of Siemens Power Corporation - Nuclear Division and the statements made in this affidavit and said document are, to the best of my knowledge, information and belief, truthful and complete.

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Siemens Power Corporation - Nuclear Division By:

Ray d.Vaughan Manaaer, afety, Security & Licensino Title 3/tv /9 s?

Date State of Washington fi'"

SS County of Benton 1

Q Raymond E. Vaughan personally appeared before me known or proved to me to be

,1-the same person who executed the foregoing instrument and to be the Manager, Safety, Security & Licensing of Siemens Power Corporation - Nuclear Division and acknowledged to me that he executed the s.ame as his free act and deed and the free act and deed of Siemens Power Corporation - Nuclear Division.

Subscribed and sworn to before me this /8 day of M k,1998.

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[jJackieV. Marshall Notary Public 8/ollqg My' Commission Expire.s

Siemens Response to NRC RAI Dated 11/12/97 NRC Reouest-la) According to material safety data sheets, sodium hydrosulfite is a flammable solid and is reactive with small amounts of water. What safety measures are taken when handling or using sodium hydrosulfite to protect the worker and prevent any undesired reactions?

SPC Resoonse la) While handling the the operator will wear respiratory protection, gloves, and goggles as specified per the material safety data sheet. Many other protective measures are taken when using this chemical.

is packaged in plastic-lined water-tight 220 lb cans, stored in a weather-proof chemical storage building equipped with a heat detector, kept away from water sources and incompatible chemicals, and handled in areas having good outdoor ventilation. A safety shower and eye wash station are provided at the SPF building 30 feet away if needed. To avoid the reaction between and small amounts of water, the solution is made up by adding dry sodium hydrosulfite to a large amount of water instead of vice versa.

NRC Reauest 2a) The lagoon uranium recovery (LUR) processing equipment building enclosure is described in this section. Will fumes or offgas be generated when using sodium hydrosulfite? If so, how are fumes handled?

SPC Resoonse 2a) Sulfur dioxide odors may be detected during aqueous make-up of the sodium hydrosulfite solution. This is done in a separate non-radioactive chemical make-up room which has good outdoor ventilation through large roll-up doors.

The LUR tanks and building are HEPA filter ventilated with a 2000 cfm building exhauster and 10,000 cfm air recirculation system. To date, no sulfur dioxide or odors have been detected at the LUR tanks due to the low concentration Industrial hygiene (IH) personnel monitor levels of toxic gases generated during each chemical handling step to establish the appropriate level of protective equipment needed consistent with the MSDS. Any changes to an operation requires an IH evaluation and sampling.

NRC Reauest 2b) What is the concentration of sodium hydrosulfite used and stored onsite? Are any other chemicals used in the LUR process? If so, list where they are used, the concentration, the method of storage, and whether or not the chemicals come in contact with uranium.

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SPC Response 2b)

. Separately, sodium hydro'xide will be used at LUR to adjust the 3 pH of the lagoon liquids prior to the LUR process, but is not part of the LUR precipitation:

process.. Sodium hydroxide, 50 wt% is stored in a tank in the chemical make-up room. - A minor pH adjustment of the liquids from about 5.8 to 6.5 will require contact of caustici 4

with lagoon liquids, and thus with dilute uranium.'. About 4 ' gallons of sodium hydroxide w'ill-be added to a 6000 gallons ~of lagoon liquid to adjust the pH before the LUR process is :

. begun-NRC Reauest 4

2c) :Is heat added during processing and are any fumes generated during heating?

SPC Response

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2c) 1The LUR process does not use heat.

' No fumes are expected as

confirmed b'y lab testing (previously addressed in TAC No. L30893, January 28, 1997.)

Laboratory data'on gases have been provided in the answer to question 4 below.

NRC Reauest 2d) Please provide the balanced equation, along with the mass and heat balance for the

. reaction of sodium hydrosu!fite and uranium.

SPC Response 2d) The proprietary reduction reaction. equation and stoichiometric mass balance is as follows for the and^

NRC Reauest:

2'e) How is process' piping'and equipment integrity maintained in the LUR fac'lity to ensure i

a containment of both hazardous and ' energized material?

SPC Response.

-[ 2e) - All process piping and equipment in the'LUR facility is pressure-tested and leak-checked

.to ensure containment of liquids. Liquid leaks would be contained in the LUR/SPF building.

z i which is equipped with three sumps to collect liquids. One sump is in the LUR area, and two sumps are in the SPF area.; Pumps' are provided which remove liquids for reprocessing. The

SPF sump is equipped with 'a high level switch and process shutdown interlockf The SPF filter g

press operation, the only "high pressure" operation, is only operated with personnel in.

(attendance and any leaks.would be discovered and the process shut down.,

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NRC Reouest E 3) ' As describ'ed in the July 30,1996, submittal, have there been'any changes made to the

- approved LUR process? If so, describe any changes and their impact on safety.

SPC Response

3) No changes have been made to the approved LUR process for precipitation of uranium from-lagoon liquids. - A small centrifuge will be added to dewater solids, and lagoon liquids will be pH.

adjusted with sodium hydroxide before the LUR process occurs. Both changes will be

evaluated under existing safety and engineering change control programs. The use of 4 centrifuges is approved at SPC, Handling of sodium hydroxide requires that protective equipment worn when handling (see the answer to question 8 below). The centrifuge bowl will be enclosed in a protective housing.' Solids and liquids will be collected undemeath the

centrifuge inside a protective ventilated housing.

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' NRC Reouest 4a) Was an ' evaluation conducted on the compatibility of sodium hypochlorite and sodium nitrate with the contents of the lagoon? Explain the scope of the evaluation, along with

results, and the basis (i.e. experiments or calculations).-

SPC Response 4a) Yes. Both

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Method:

Threshold limit values -(TLV) apply to exposures 8 hr/ day and40 hr/wk and are for comparison purposes only.

The SPF feed tank T-670 is enclosed and vented through HEPA filters in the building exhaust system. T-670

- vapors are not discharged to work areas, and workers are not exposed to these vapors.

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.5a) ~ How is steam heat utilized at feed tank T-670? Is steam confined within piping and equipment 'such that workers are not exposed to steam? What is the temperature and -

pressure of the steam?

SPC Response

'5a)! Steam is confined to piping and workers are not exposed to steam. Steam is directly; injected into a recirculation line which transports liquids from T-670 and back again through a recirculation pump.

All steam lines are insulated to further protect workers and are equipped with steam traps and condensate drains to the SPF sump.

NRC Reauest

. 5b) What is the normal operating temperature of the feed tank process?

SPC Response 55a NRC Reauest 5c) What devices are used to control temperature and how are these devices maintained to ensure that they will operate as expected when called upon?. Are tests conducted to test functionality at specified frequencies? Please provide details of tests and frequencies.

SPC Response Sc); Flow controlle's and temperature sensors with high temperature shutoff interlocks are r

used to control temperatures. SPC maintains control loop and instrument calibrations and

. maintenance through an instrument repetitive maintenance system. Calibrations and functional tests to ensure accuracy and operability are performed annually, semi-annually, or quarterly, dependin'g on the individual instrument characteristics. Simulated field element signals are inputted at the field element or instrument and the full operating range, span, and response are calibrated from the element, transmitters, and signal converters to the controlling computer. There are dual thermocouples used as sensors and the:

- thermocouples are designed for a fail-safe high temperature failure mode.

NRC Reauest 5d) 'If a temperature controller fails, what is the maximum temperature expected in the

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feed tank? -Material safety data sheet information indicates that sodium nitrite is unstable with heat. At'this. maximum temperature, are there any. hazards with the sodium

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hypochlorite, sodium nitrite, and the lagoon water?. Please provide details of how these i hazards.were evaluatedJ j

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. 5db if a failure occurs, the maximum feed tank temperatur? would be about 212*F.

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.p, The feed' tank T-67'O is. ventilated into 2000 cfm building exhaust stream and not into '

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_7 ; working areas; therefore gases, if generated, would not be released into work areas.

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Finally, temperature sensors and control loops 'were installed in the both recirculation line and the feed tank. High' temperatures would activate a steam ' shutoff interlock in either control loop. Failure of both controllers simultaneously is unlikely. If the computer fails, 4

L the steam supply valve closes, other valves move to their fail safe position, and equipment

, - shuts down.

r NRC Reauest,

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Sa) The SPF process flow diagram indicates the presence of Chem Additive tank T-673. Is this where~ sodium hypochlorite and sodium nitrate are stored?

SPC Response 6a) Yes, SPC plans As mentioned below, NRC Reauest c

E 6b) - What is the temperature, pressure, composition, concentration, and flowrate of the 5 additives steam? Provide the mass-balance for input and output streams for tank-673.

SPC Response 6b)--

NRC Reauest Sc) Are chemicals stored in a cool, dry, and well-ventilated area. away from incompatible

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chemicals? 2 SPC Response

.s 16c) Yes. All chemicals are stored in the well-ventilated. chemical make-up room except for 4

the sodium hydrosulfite,Lwhich is stored away from the SPF in a' separate' chemical-p*.

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' 6dli Are personal protective equipment (e.g., goggles, face shields, gloves) and safety j 1

u equipment such 'as: respirators,' safety shower / eye wash stations and fire fighting -

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equipment readily available for these chemicals?

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' L6d)' Yes. '. Prot' active cloth'ing, as specified by MSDS, are readily ~available, and required for 1

the handling of all chemicals. Safety showers are provided inside the chemical make-up room, and outside th'e building and accessible, if needed, by personnel chemical storage building. Five total safety showers / eyewash stations are provided for the N

- LUR/SPF building.

NRC Reauest

7) ltem (7).was omitted in the original letter TAC No. L30929.-

T NRC Reauest 8a)5 Please provide: balanced equations for reactants and products, mass and heat balances, and predicted operating temperatures and pressures for the reactions with uranium and chemical additives in tank T-670. '

SPC Response Sa) SThe equation and rnass balance describing the

in tank T-670 us:ng sodium hypochlorite is as.follows:

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NRC Reauest

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8b): Identify hazards and corresponding safety controls for normal and accident conditions.

associated with chemicals in the LUR/SPF process? List chemicals and related controls.

Explain how these' safety controls are maintained and tested to ensure they are available and reliable?

SPC Resoonse 8b) Hazards and corresponding safety controls for normal and accident conditions

-associated with chemicals are summarized as follows:

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.mj pggg 7 Leakina oicina or eauipment. or soills Hazard:l Leaks and spills of lagoon materials in work areas can increase both the level of airborne contaminants present and the potential for personnel contact with ammonium and.

sodium fluorides, nitrates, sulfates, uranium, and other chemicals.

Controls:' All spills of radioactive material are contained in the L.UR/SPF building. The building is eq'uipped with a spill basin for the feed and filtrate tanks, and a sump for both the LUR and i

SPF sides. Both sumps are equipped with automatic pumpout. - Uquids or sludges which leak i

to the floor will be collected in a trench drain which directs all materials to the sump. The sump is equipped with a sludge pump which will transfer materials back to the feed tank for -

reprocessing, Any leaks or spraying of liquids which come into contact with personnel can be -

removed by one of three eyewash and safety showers located in the filter press room. Normal protective clothing also provides protection. Process water is provided to clean up leaks and spills.

Outside the building, piping is above ground and will be inspected as required for leaks. The '

' dredge can be shut down with an emergency stop switch if any leaks develop during the manned operation. Rocks will be screened out at the lagoon bank to prevent rock damage to

.the line. All outdoor piping will be heat traced, and hoses will be air purged, to prevent freezing.

Exceedina airbome radiation and chemical exoosure limits Hazard: Exposure to high levels of airbome radioactivity and chemical salts such as ammonium and sodium fluorides, nitrates, and sulfates occur from the spraying of lagoon materials from leaks in pipes and equipment.

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Pcga 8 Controls: The SPF process is equipped with an air filtration and monitoring ' system. A high

- airtiome radiation alarm activates and interlocks shutdown all pumps and equipment. This alarm also provides an indication of high chemical hazards since radionuclides and chemicals coexist in lagoon liquids and sludges. Personnel will exit the area, and don respiratory and

- other protective gear as needed to re-enter and correct the problem. The most likely source'of airborne contaminants is the filter press which holds contents under pressure and handles finished solids, or cakes. The filter press is entirely enclosed and is ventilated through the 2,000 cfm building exhaust and HEPA filtration system. The filter press room is ventilated

- through a 10,000 cfm recirculation system equipped with HEPA filters. Air sampling stations are located at the filter press and in other appropriate work areas and radiation protection

- personnel routinely analyze air sampler filter papers for contaminants.

. Process Tank Leaks Hazard: Leaks and spills of lagoon materials in work areas can increase both the level of

- airbome contaminants present and the potential for personnel contact with fluorides, uranium, and other chemicals.

Controls:

A spill basin surrounds the SPF feed and filtrate tanks and has the capacity to contain more

' than the entire contents of one tank should a leak occur. Other LUR or SPF tanks are located in rooms having sumps. The LUR sump pump transfers the spilled liquid to Lagoon 3, and the SPF sump pump transfers liquids to either the feed tank or Lagoon 3 for reprocessing.

Fallina off dredae into lacoon durina dredae operation Hazard: Falling off the dredge exposes personnel to corrosive chemical salts, possible -

drowning, radioactive contamination, and other risks.

Controls: The dredge is equipped with platform and handrails designed to OSHA Standards.

Operators working on the dredge will be provided with personal flotation / protection. The lagoons will be kept between 2 - 5 feet deep during normal operations.~ Eyewash and safety showers are provided at the LUR/SPF building and at Lagoon SA/5B to remove lagoon contaminants. A portable eyewash is kept on the dredge as well. Chemical and radiological protective clothing will also be wom, including life jackets, but safety showers and eyewash

- equipment will mitigate hazards associated with skin contact with lagoon salt solutions.

. Dredae hose leakina Hazard: A leaking dredge hose would release lagoon materials to the environment and could expose personnel to chemical salts and uranium. Sprays could cause contaminants to become airbome. Leaks and spills oflagoon materials increases the potential for personnel contact with ammonium and sodium fluorides, nitrates, sulfates, uranium, and other chemicals.

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CcLt 4 Ni hoses were pressure tested with water after installation and were operated under F

Emaxmc a pump dead head pressure to ensure that'each connection sealed properly and no leaks were detected.' All hoses systems are monitored directly by personnel with each use. All m

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Pega 9 hose leaks are contained in the lagoon. Should a leak occur, the operator will activate the emergency stop button provided on the dredge which immediately shuts down the pump. The dredge pump is equipped with a high pressure pump shutdown interlock, but the maximum pump output pressure was designed to be less than interlock limit and the hose pressure rating.

The polyethylene dredge hose consists of 20' rigid segments, joined by 5' flexible segments, to ensure that the hose will move freely with the moving dredge. The hose is encased with surlyn foam for flotation. Plant air connections are provided, and all hoses are purged with air after each use to remove materials from the line. This also provides freeze protection.

Overflow of the slurry feed tank Hazard: Leaks and spills of lagoon materials in work areas can increase both the level of airbome contaminants present and the potential for personnel contact with ammonium and sodium fluorides, nitrates, sulfates, uranium, and other chemicals.

Controls: Overfilling the slurry feed tank would spill liquids through the overflow line to the spill basin. A slurry feed tank high level alarm will sound which closes the feed valve, which halts dredge slurry flow and prevents overfilling. A tank high level alarm activates if the level is too high. The spill basin sump is also equipped with leak detection e!ement and alarm to alert personnelif the feed tank is overfilled. Spilled liquids can be pumped out of the basin using the SPF sump pump. A diverter valve hcs been provided to route flow from the sump to Lagoon 3 if the slurry feed tank is full.

Overflow of the filtrate tank Hazard: Leaks and spills of lagoon materials in work areas can increase both the level of airbome contaminants present and the potential for personnel contact with ammonium and sodium fluorides, nitrates, sulfates, uranium, and other chemicals.

Controls: Overfilling the slurry feed tank would spill liquids through the overflow line to the spill basin. A high level alarm and interlock shuts down the filter press feed pump and prevents overfilling with filtrates. The spill basin sump is also equipped with leak detection element and alarm to alert personnelif the filtrate tar'k is overfilled. Spilled liquids can be pumped out of the basin using the SPF sump pump. A diverter valve has been provided to route flow from the sump to Lagoon 3 if the slurry feed tank is full.

Failure of crocess lines or filter press by hioh feed line pressure Hazard: Leaks and spills of lagoon materials in work areas can increase both the level of airbome contaminants present and the potential for personnel contact with ammonium and sodium fluorides, nitrates, sulfates, uranium, and other chemicals.

Controls:

If a leak occurs, the SPF sump pump

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transfers liquids to either the feed tank or Lagoon 3 for reprocessing. The filter press is equipped with a ventilated enclosure to contain liquids or sludges which may leak or spray from j

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P:gs 10 between the plates during operation or abnormal conditions. Liquids are collected in the auger conveyor t, rough, and drain to the SPF sump.

Failure of process lines or filter press by hiah feed line temperature i

Hazard: Leaks and spills of lagoon materials in work areas can increase both the level of airbome contaminants present and the potential for personnel contact with ammonium and sodium fluorides, nitrates, sulfates, uranium, and other chsmicals.

Controls:

If a leak occurs, the SPF sump pump transfers liquids to either the feed tank or Lagoon 3 for reprocessing. The filter press is equipped with a ventilated enclosure to contain liquids or sludges which may leak or spray from between the plates during operation or abnormal conditions. Liquids are collected in the auger conveyor trough, and can be drained to the trench drain and SPF sump pump for reprocessing in the feed tank.

Propane Hazard: Propane is a flammable gas at room temperature, but is normally stored as a liquid in a tank under pressure. Propane used in the steam boilers can cause asphyxiation, fire, explosion, and death, if ignited or leaked to work areas. See MSDS for PROPANE or LIQUlFIED PETROLEUM GAS, Controls: All propane tanks and piping have been installed per code with appropriate safety devices, and handling is performed per plant procedures. The tanks are located far from the building and oriented to prevent building damage if ruptured. The combustion of propane to generate steam produces gases which are toxic. These gases are discharged from the room to prevent asphyxiation. The two steam generators are located in the SPF building, and combustion gases are discharged to the atmosphere through two stacks.

Waroina or failure of the LUR tanks due to hiah SPF filtrate temperatures Hazard: If the LUR tanks leak or fail from high temperatures, leaks and spills of lagoon materials in work areas can increase both the level of airbome contaminants present and the potential for personnel contact with ammonium fluorides, nitrates, sulfates, uranium, and other chemicals.

Controls: Temperatures above 140"F could cause warping or failure of the LUR precipitator tanks which are constructed out of polyethylene. SPF filtrates are cooled in the SPF feed tank T-670 after the heatup cycle, then further cooled in the filtrate tank during uranium sampling and analysis. In addition, a high temperature interlo::k will shut down the filtrate pump and prevent hot filtrates from reaching LUR. The LUR sump collects spilled liquids and the sump pump transfers liquids to Lagoon 3 for reprocessing.

,c Paga 11 Overflow of the LUR precioitator tanks Hainfd: Le'aks and spills of lagoon liquids or filtrates in work areas can increase both the level'

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of airbome contaminants present and the potential for personnel contact with ammonium

, fluondes, nitrates, sulfates, uranium, and other chemicals.

Controls:. Batch meters allows only a fixed quantity of LUR feed to be pumped to a LUR -

precipitator tank from either the Lagoon 3 LUR feed pump or from the SPF filtrate pump. When1 the batch setpoint is reached,' an electric valve closes to prevent the over-addition of liquids. In

addition, the SPF filtrate pump will also shut down on a high LUR tank level alarm. If the LUR '

tank overflows, overflow lines direct liquids to the LUR sump. Liquids are then pumped automatically for reprocessing.

Chemical Handhng and Precautions The lagoon slurries contain numerous dissolved and solid chemicals. The most toxic are

-ammonium fluoride and nitrate, and sodium fluoride and nitrate. These chemicals are solar concentrated in lagoon solutions and sludges. MSDS sheets provide specific handling and safety precautions. ' Process chemicals and chemicals stored in the lagoons are briefly discussed below. Protective equipment wom at the facility include coveralls, gloves, eye

. protection, shoe covers, respiratory protection, and other equipment as appropriate to the work and the MSDS. Control instrumentation such as level, temperature, pressure, and flow instrumentation are calibrated periodically under the instrument repetitive maintenance system and the frequency is annually, semi-annually, or quarterly as dictated by the individual instrument. A summary of specific chemical hazards of the chemicals used at LUR/SPF (per

. MSDS, and in dry or pure form) are discussed below. Actual LUR/SPF and lagoon chemicals are occur as dilute liquid solutions, and the specific hazards are were previously discussed in sections (1) through (7) above.

Ammonium fluoride is an inorganic salt present in lagoon solutions. It is corrosive and can decompose to ammonia in contact with strong bases, or it can decompose to HF acid with strong acids. See the MSDS for AMMONIUM FLUORIDE.

Ammonium nitrate is an inorganic salt present in lagoon solutions. It is an oxidizer, and when heated it can decompose to toxic fumes of nitrogen oxides, or can be explosive under certain conditions. See the MSDS for AMMONIUM NITRATE.

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PKgs 12 Diesel fuel is used to run the dredge generator. Diesel fuel is a ' petroleum distillate that is a mixture of petroleum hydrocarbons. It will be used in the dredge generator, and will be stored -

in fuel tanks on the generator. It is combustible, and is an inhalation hazard (oil mist),'and hazardous with skin contact, eye contact, or ingestion. Handling is required by the supplier J during tank filling. Adequate ventilation is required for handling. See MSDS for DIESEL FUEL

' OIL NO. 2-D.

Sodium hydroxide, or caustic, is a strong base. It may be added adjust the pH of lagoon liquids -

at LUR. It has an alkaline pH and may generate heat upon contact with water. Mists and -

vapors of sodium hydroxide are corrosive to the respiratory tract. Caustic is corrosive to all body tissue and reacts violently with aluminum and many other chemicals. Caustic solutions.

are irritants to eye, skin, and mucous membranes. Protective equipment shall be worn when handling it or containing spills. A spill basin is provided and is equipped with a pumpout line for transferring spilled caustic back into the tank for re-use. See MSDS for SODIUM HYDROXIDE.

Sodium nitrate is an inorganic chemical present in lagoon solutions, it is an oxidizing agent, and is unstable with heat above 5757. It can react under certain conditions with reducing

' agents, ammonia salts, and other chemicals. Protective equipment shall be wom when handling it or containing spills < See MSDS for SODIUM NITRATE.

Sodium Fluoride is an inorganic salt present in lagoon solutions. It is a stable compound which '

can react with strong acids to form HF acid, and can decompose with heat to fluorine.'

Protective equipment shall be wom when handling it or containing spills. See MSDS for SODIUM FLUORIDE.

Sodium nitrite is an organic salt, it is unstable with heat, and incompatible with acids, ammonium salts, activated carbon, cyanides, and reducing agents. The principal hazards are inhalation, skin contact, and ingestion. Safety precautions include avoiding contact with skin and eyes. See MSDS for SODIUM NITRITE.

NRC Reauest 8c) How is process piping and equipment integrity maintained in the SPF facility to ensure containment of both hazardous and energized material?

SPC Resoonse Sc) All process piping and equipment in the SPF facility is pressure-tested and leak-checked to ensure containment of liquids.~ Liquid leaks would be contained in the LUR/SPF building which is equipped with a three sumps to collect liquids. Both the LUR and SPF areas have liquid collection sumps and dedicated pumps which automatically remove liquids for t reprocessing.

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Pega 13 Bd) What is the operating pressure of: strainers F-675, filters F-674, and filter press F-6707 What safety measures are taken to protect workers if filters or strainers become blocked due to solids accumulation and materialleaks out under high pressure? Are these safety devices tested to ensure their availability and reliability in the event of blocked filter or strainer? If so, provide details.

SPC Resoonse 8d) The maximum operating pressures are as follows:

Max Fsig Design Psig Strainers F-675 70 150 Filters F-674 125 150 Filter Press F-670 125 225 For worker protection, the stroiners F-675 and filters F-674 are ASME code pressure vessels

- and have UM stamps and certification. In addition, the maximum possible pump operating pressures were designed to be under the code rating. Pressure gauges are provided for strainers F-675 and Filter Press F-670 to monitor buildup, and a differential pressure controller with feed pump shutdown interlock is provided for Filters F-674. Solids will be collected from the strainer baskets after each batch of lagoon slurry is pumped. Strainers F-675.1 - 4 are equipped with an overhead hoist to safely lift heavy loads. The baskets are limited to 8 inch diameter by 30 inches long which also limit the total amount of solids that could accumulate.

Filter pressure drops in F-674 and F-670 are monitored, and filter cloths are cleaned or emptied as needed, J