ML23348A373

Acu Msrr - Environmental Review Requests for Confirmatory Information - Closure Confirmation for CA- 2, 5 and 6

ML23348A373
Person / Time
Site:	05000610
Issue date:	12/14/2023
From:	Towell L Abilene Christian University
To:	Joseph Giacinto Office of Nuclear Material Safety and Safeguards
References
Download: ML23348A373 (1)

Text

From: Lester Towell To: Joseph Giacinto Cc: Benjamin Beasley; Patricia Vokoun; Peyton Doub

Subject:

[External_Sender] Re: ACU - RCI review response request Date: Thursday, December 14, 2023 4:20:57 PM

Joe, I confirm that the information in the Requests for Confirmatory Information RCI-CA-2 (for PSAR rev 0), RCI-CA-5 and RCI-CA-6 transmitted on December 14, 2023 is correct.

Lester On Thu, Dec 14, 2023 at 1:40 PM Joseph Giacinto <Joseph.Giacinto@nrc.gov> wrote:

Ben, During EA preparation we came across three more RCIs for which we request ACUs confirmation. For RCI-CA-2 and RCI-CA-5 and RCI-CA-6, we request that ACU submit confirmation via email reply that the information gathered during the audit which is listed below is correct or provide the associated correct information.

Joe Giacinto Environmental Project Manager RCI-CA-2:

Confirm that ACU believes that "active species" expected to be in effluent from the reactor off-gas system mixed with room air and ventilated to the roof as described in the ER was intended to refer to radioactive species.

RCI-CA-5:

Confirm the information provided below and in the associated table is consistent with sources of air emissions during operation and construction (types of equipment and estimated running hours, i.e., boilers, emergency/standby diesel or propane-fired generator, diesel-powered delivery trucks or other heavy construction equipment):

A small emergency generator is being considered to provide backup power for

experiments, but this has not been finalized. During operation there will be delivery trucks for process gas deliveries and general supplies. This may average one truck per week. There is no boiler.

During operation, ambient air will be blown across the radiator and exhausted to atmosphere. It is not expected to contain reportable emissions but will be monitored or radioactive nuclides. Air will also be circulated through the reactor trench and exhausted to atmosphere. It will also be monitored for radioactivity. A vent: from the salt purification neutralization systems as well as from the off-gas system will discharge to atmosphere after sampling to confirm that it meets acceptable limits for discharge.

a. The table below provides estimated emissions from the construction and operation of the MSRR.

Most of the emissions will come from the use of trucks to deliver either construction or operation related materials. Pollutant yield was selected from United States Bureau of Transportation Statistics (BTS) for Heavy Diesel Trucks in 2020. The justification column will explain assumptions made in combination with the BTS information that was used to generate the pollutant estimate. Not all pollutants listed are generated from delivery trucks, distinctions are made in the justification column.

Pollutant Emission Estimate Justification Construction Operations Carbon Monoxide 60kg 0.2 kg/Week Construction: 2 grams/mile for heavy trucks. Total of 30 trucks, traveling 1000 miles.

Operations: Weekly delivery assumes same yield but just 1 truck traveling 100 miles.

Hydro-Carbons 8 kg 0.027 kg/week Construction: 0.269 grams/mile for heavy trucks. Total of 30 trucks, traveling 1000 miles Operations: Weekly delivery assumes same yield but just 1 truck traveling 100 miles.

Lead 0 0 Nitrogen Dioxide 125 l(g 0.417 kg/Week Construction: 4.169 grams/mile for heavy trucks. Total of 30 trucks, traveling 1000 miles Operations: Weekly delivery assumes same yield but just 1 truck traveling 100 miles.

Nitrogen 0 50 kg/year Operations: Nitrogen emission is generated from purging nitrogen blanket In reactor enclosure. This will be 40,000 liters of nitrogen gas once per calendar year.

Ozone 0 0 Particulate Matter 3 kg 0.010 kg/week Construction: 0.103 g/mile for heavy trucks. Total of 30 trucks assumed 1000 miles Operations: Weekly delivery assumes same yield but just 1 truck traveling 100 miles.

Sulfur Dioxide 0 0 Hydrogen Fluoride 0 0 Hydrogen Gas 0 216 kg Operations:

Hydrogen gas is used during the chemical process which removes oxygen form the molten salt. Its estimated that approximately 216 kg of hydrogen gas would be needed to complete the purification process 3 times over the lifetime of the plant.

Nickel Compounds 0 0 Chromium 0 0 Compounds Beryllium 0 0 Compounds

b. A subsystem of the MSRR referred to as Radiation and Environmental Monitoring System {REMS) will employ an array of effluent gas detectors. As of now, the non- radiological aspect of REMS will monitor levels of hydrogen fluoride, oxygen, combustible gases, helium, and nitrogen.

c. The REMS will be used as an early detection measure for rising levels of hazardous non-radiological gas species. High level detection will trigger appropriate preventative.

measures such as personnel evacuation of the SERC or rapid gas evacuation of the Reactor Bay/Systems Pit/Trench. Additionally, systems which handle non-radiological species include design features which will limit or* extinguish potential hazards by safely trapping, neutralizing, or reducing the concentration of gases such as HF or Hydrogen.

References

1. Bureau of Transportation Statistics. "Estimated U.S. Average Vehicle Emissions Rates per Vehicle by Vehicle Type Using Gasoline and Diesel. U.S. BTS.

https://www.bts.gov/content/estimated-national-average-vehicle-rates-vehicle-vehicle-type-using-gasoline-and (accessed Jul. 20, 2023).

2. Environmental Protection Agency, "Initial list of Hazardous Air Pollutants with Modifications. U.S. EPA. https://www.epa.gov/haps/initial-list-hazardous-air-pollutants-modifications (accessed Jul. 20, 2023)

RCI-CA-6:

Confirm that The MSRR will not release greenhouse gases during normal operation, there will be no policy for greenhouse gas emissions specific to the MSRR and that ACU intends to include Renewable Energy Certificates as part of a long-term electric contract with TXU energy, that will supply electricity to the Abilene campus, including the SERC, where the MSRR will be installed.