ML20149J858

Forwards Addl Info CP & OL Application,Per at Clark .Info Includes Centrifuge Machine Contamination, Decommissioning,Radioactive & Classified Waste Disposal, Environ Rept & HVAC Sys

ML20149J858
Person / Time
Site:	05000603
Issue date:	02/03/1988
From:	Bell D ALL CHEMICAL ISOTOPE ENRICHMENT, INC.
To:	Thompson H NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
29034, NUDOCS 8802230255
Download: ML20149J858 (17)

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All Chemical isotope Enrichment, Inc.

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.x U.S. Nuclear Regulatory Commission ,

Document Control Desk Office Nuclear Material Safety & Safeguards / /*~I.d\ '

Washington, D.C. 20555 Attn: Mr. Hugh L. Thompson, Jr.

55396-M::SS Docket Material Docket No. 50-603 Gentlemen:

In response to your letter dated December 28, 1987 from Dr. A.

Thomas Clark, Jr. please find enclosed the requested additional information. This information applies to AlChemIE's construction permit and operating license application for AlChemIE Facility - 1, CPDF.

We look forward to meeting with you in February to discuss our responses.

Very truly yours, f_L/ f k- c.-

Dennis L. Bell $ eg\ e'- g lJn Chief Executive Officer

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Ane Ridge Cefice Park Suite 202 B 702 liknois Ave. Ook Ridge. TN 37830 (615) 482-0029

Additional Information for A1ChemIE Facility - 1, CPDF, Docket No 50-603 Request Centrifuge Machine contamination Please provido information which supports your discussion in Section 4.2.2.1 of the Preliminary Safety Analysis report pertaining to contamination of contrifuge machinos by uranium.

Specifically the Appendix mentioned in that section is not contained in the document. If the Department of Energy has provided information in this regard, it should be provided as part of your application.

Responso As it relates to A1ChemIE's PSAR for Facility - 1, CPDF, Docket 50-603, the referenced Appendix A was inadvertently omitted.

Copies of the requisite DOE letter documenting the contamination levels at CPDF are transmitted herewith.

Although not specifically stated in Appendix A the uranium contamination is in the form of uranyl fluorido (UO This low level of contamination will be plated on the contEk.Ffbg) o.

components and in the form of dust. In any caso the bulk of the uranyl fluorido should be insido the centrifuge rotors. 1 Request Decommissioning Please provido any written agrooments you have executed with the Department of Energy with regard to decommissioning.

Responso Article 7 of Contract No. DE-R005-880R21776, Contrifugo Equipment Agreement and Bill of Salo, betwoon DOE and A1ChemIE states:

"7. Decontamination and Disposal. A1ChemIE shall be responsible for the decontamination and disposal of all classiflod or contaminated equipment of which it has acquired ownership. It shall ascertain the cost for the protoction, docontamination, and disposal of the entiro classified or contaminated inventory reco1ved by A1ChomIE. A1ChomIE shall provido assuranco, in an amount and form acceptable to DOE, that adequate funds will be availablo for decontamination and disposal of all classified and/or contaminated equipment should AlchemIE, for any reason, fail to do so."

A similar clauso will be contained in the lease and sales agroomont betwoon A1ChemIE and DOE for the CPDF facility.

Request Radioactive and Classified Waste Disposal Please provide any written agreements you have executed with the Department of Energy with regard to acceptance of waste material 3

1) which is radioactively contaminated and 2) which is, in whole or in part, classified.

Response

In A1ChemIE's negotiations with DOE relative to the lease of the CPDF facility and the procurement of the equipment from the Gas Centrifuge Enrichment Plant (GCEP) the disposal of classified and uranium contaminated equipment and materials has been discussed. Although no formal agreements have been reached it is our understanding that this equipment and materials will be i stored or buried by DOE at the ORGDP site. This is noted in the attached Waste Managerment Plan.

l Enviromental Report

1. Request Provide information describing the engineering features that will be used to prevent or mitigate the release of hazardous chemicals to the environment.

RESPONSE: (a) Loading and unloading of the feed, product and tails cylinders will be performed within an enclosed loading dock. Accidental release due to '

cylinder rupture associated with the task will be contained within this enclosed loading dock. If an accidental release should occur, the dock will be decontaminated prior to continued use.

All materials used for decontamination will be collected and packaged for disposal in accordance with the enclosed Waste Management Plan.

(b) Feed, product and tails cylinders will be stored within the facility in a '

dedicated nominally air tight storage room. The storage room will be equipped with halogen and hydrocarbon monitors with an audible alarm. If a cylinder should leak, it will be removed, repaired or the contents will be transferred to a new cylinder. The j stor690 room Will be surveyed for '

contaminant deposition and decontaminated, if necessary. j I

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(c) The gas centrifuge process is an inherently high vacuum system operating in the low torr to micron range, and with a low process gas inventory. Also, any disruption of this vacuum results in automatic process shut down. At shut down, isolation valves will automatically close preventing process gas release. Gas within the system will then be evacuated into a withdrawal cylinder prior to restarting the process system.

(d) All existing floor drains will be sealed prior to facility operations.

(e) All potentially hazardous chemicals associated with facility operation will be collected, packaged and disposed of as outlined in the enclosed waste management plan.

(f) Based upon the small amount of process gas in a centrifuge at any time and the fact that the process operates in a high vacuum, it is highly unlikely that a release of the process gas could be detected.

(g) All sanitary waste water will be processed by ORGDP by agreement with DOE and the Tennessee Department of Health and Environment (TDHE).

(h) The only planned releases to the environment directly associated with the CFDF operation are Xenon, Krypton and off-gas systems as discussed in 2(e) below. Those releases have been discussed with the THDE Division of Air Quality and it is expected that they will approve their release to the atmosphere.

2. Request Describe the off-gas systems for the process equipment, the ventilation system for the building, and the drain systems for process or hazardous chemical handling area.

RESPONSE: (a) There are five process off-gas systems in the building as follows: 1) Purge vacuum (PV), 2) Evacuation vacuum (EV),

3) Feed Purge and Evacuation (FPE), 4)

Tails Purge and Evacuation (TPE). and 5)

Product Purge and Evacuation (PPE).

Each of these systems will contain a cold trapping, a chemical trapping or a mechanical trapping system to collect the process gas, other than Xenon or Krypton as noted above, that has entered any of the off-gas piping systems during both normal process operations and '

off-stream operations (cylinder change-out, etc).

These traps will be installed in the inlet to vacuum pumps or in the purge piping as appropriate. All five of the process off-gas systems will be i connected to a single common vent above the roof.

(b) HVAC System Feed Area The existing feed area has an independent HVAC System, however, this area will not be used by A1ChemIE.

Present plans are to utilize small "portable" systems for each process gas utilizing a hot water bath or forced hot air heating system. These systems will be self-contained and located in the cascade area as noted below and therefore require no further HVAC.

Cascade The cascade area consists of two pad-mounted HV units and one platform-mounted unit. The first unit i is located on the northeast end of the building and serves the north side of l the building from the diesel generator i

. room to corridor #1. This unit has a  ;

capacity of 33,600 cfm. The outside and return air are controlled by a syitch.

The thermostat is set at 85 F to ,

maintain the cascade area temperature.

4 The second HV unit is located on the northwest side of the building and i

serves the north side of the building from corridor #1 to the northwest corner and the west side of the building. This unit has a capacity of 36,000 cfm. Both aforementioned units have freeze controllers to shut the unit down when the coil discharge temperature is below its setpoint.

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The third cascade area unit is split into two 30,000 cfm capacity units, located on a platform in the equipment area at the east end of the cascade.

One 30,000-cfm unit serves the east wall and around the south wall to the existing withdrawal area. The other 30,000-cfm unit feeds a perforated duct '

that runs along the top of the service module. Twelve temperature transmitters are located on the service module.

The service module temperature g

trgnsmitters are get at 83 F and 80 F. When the 83 F temperature is sensed, an alarm is sounded, and tpe unit is shut down when the 80 F temperature is detected. The second area unit follows the same procedure, with the two duct temperature g g  :

transmitters set at 78 F and 75 F, <

respectively. A drop in temperature, as described above, indicates a problem with the unit. The unit is shut down to ,

prevent cold air from blowing on the machines.

The cascade area also contains 12 roof-mounted, damper-controlled ventilators (primarily used for summer ventilation) and six roof-mounted smoke removal fans. Should a fire occur, the operator will be alerted to shut down the system, thus sealing the building.

Administrative controls will i

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i Central Control Room (CCR)

The CCR is cooled by a roof-mounted air conditioner equipped with a steam-type humidifier. The unit contains a steam coil for heating, and cooling tower water is used as the cooling media in the condenser section. In the unlikely :

event of a release in the cascade area, t operation of the CCR will be possible without danger to personnel through  :

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recirculation of the room air and shut-off of make-up from the outside. -

(c) All floor drains will be sealed prior to operation of the facility. All potentially hazardous chemicals '

associated with facility operation will be collected, packaged and disposed of per the Waste Management Plan.

3. Request Describe the quantities and types of hazardous materials which would be released from the facility under normal and abnormal circumstances. Such estimates should be supported by analysis and the environmental impact of these releases should be stated.

RESPONSE: No identified hazardous materials will be released from the facility under normal or abnormal circumstances.

4. Request Based upon analysis discussed in Item 3, provide an environmental monitoring plan indicating species to be sampled and analayzed and methods and frequencies for such monitoring.

1 RESPONSE Environmental monitoring is not proposed for this facility.

5. Roquest Indicate the environmental regulations which  !

are related to your facility and your plans  :

for implementation. I i

RESPONSE: ( a) Air Emissions: AlchemIE is working very 1 j closely with the TDHE-Air Quality ,

a Division in omission evaluation. l A1ChemIE plans to acquire a TDHE-Air i j

Ouality Permit for the discharge of Xenon, Krypton and process off-gas I

exhaust (see 2a above).. j (b) Hazardous Waste

An evaluation of the projected hazardous waste stream i 1

indicates that the facility will be j classified as a small waste generator.

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A1ChemIE is seeking a determination from the TDHE-Division of Waste Management.

The TDHE determination is expected by February 15, 1988.

(c) Solid Waste: An evaluation of the proj ec ted solid waste stream indicates i that "special waste" will be generated.  ;

A1ChemIE is seeking a determination from the TDHE-Division of Waste Management.

The TDHE determination is expected by February 15, 1988. Classified waste both contaminated and uncontaminated, will be transferred to DOE for storage or burial at the ORGDP.

(d) Water Discharge Permit: All waste water will be directed into the ORGDP sanitary sewer system for treatment.

The blodegradable cooling tower waste water and blowdown as well as the I

machine cooling water wastes, will also be directed to ORGDP facilities. A water discharge permit is not expected ,

to be required. l' TDHE-Division of Water Management is l expected to provide a determination by February 15,1988.

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b Department of Energy  ;

Oak Ridge Operations '

P. O. Box E 1I 1 e Oak Ridge. Tennessee 37831 May 12, 1987 SB-87-192 Mr. William A. Pfeifer, Director Special Projects AlchemIE Pine Ridge Office Park, Suite 202-8 702 S. Illinois Ave.

Oak Ridge, TN 37830

Dear Mr. Pfeifer:

ESTIMATES OF CONTAMINATION LEVELS IN OAX RIDGE GASEOUS PLANT (ORGDP) CENTRIFUGE FACILITIES

Reference:

William A. Pfeifer to Wilbur L. Walker letter, dated February 26, 1987.

Based on your request, estimates have been made for the uranium These contamination levels currently existing in the ORGDP Centrifuge Facilities.

estimates are based on accountability records and should be considered preliminary until such time as we can locate allI believeof the supporting the level data which formed the basis of the estimates. However, of infomation provided will meet the requirements for NRC.

if you do require more exact estimates or estimates giving distributions among machines and headers, this would require removing machines and piping sections.

If you have any questions, please call me.

Sincerely, 8~ad a. a 4-.

Ronald T. Ooten, Acting Director Enrichment Expansion Projects Division E0-23:0oten Attachment cc:

W. Hanning, E0 22 W. Walker, EO-20

Attachment A total of 21.3 kg uranium 1: carried on the accountability books for the CPDF. The average urtnlum content in the machinH bued on previous studies is estimated to be 95 2 32 grams per machine. We feel that this is a rouonable estimate for all machines regardless of position (stage) la the cucade. This usumption is bued on the fact that a hlsh percentage of the machine contamination is due to initial moisture and organic materlet on inside of rotor. The quantity of 21.3 Kg is distributed among 120 machines which were in CPDF and the usociated piping, but not includir'2 the feed, product, or waste cylinders. Thus, the total uranium contamination and average U-235 content for the machines is 11.4 Kg and 0.09 Kg respectively with upper and lower confidence limits of & 331/3%.

. The total uranium in the process piping is thus 21.3 - (120 X .095 Kg) = 9.9 Kg. We asala estimate the lower and upper 95 percentile limits u 6.6 and 13.2 KgU, respectively.

The U 235 content is approximately 0.04 Kl.

The CPDF cascade operstles history can be summarized at:

22 months at 2.88 4 0.1% U-235 product

• 1 month at 3.7 2 0.1% U 235 product

! :Leah a. 2.2 a 0.1% U 235 product Because of the nature of UFe reactions with moisture or surface contamination, we could expect to find hot spots in the CPDF in which the U 235 concentration la total ursnjum might be u hi 8h u 3.7 2 0.1 percent. We would not expect to find hot spots in the other facilities greater than 1.1% U-235 concentrations.

The total uranium contamination in the CVTF/FAEF is carried on the accountability books u 3.2 Ks. Twenty machines have been run in these facilities. A conservative estimets of 70 grams per ma: hine would menn a total urtalum content in machines of 1.4 Kg ursalum. Thus, there would be 1.8 Kg uranium in the piping system.

An estimate of U-235 content can be estlmated as follows:

Machinee - 1400 sm at 0.011 wt fraction U-235 = 15.4 sm Piping system - 1800 sm at 0.008 wt fraction U 235 = 14.4 sm Totalin System 29.8 sm An estimate for AMDL la somewhat more tenuous since they were development machines. There is presently one machine in the fac!!1ty. A total of 9 or 10 machines had been run in AMDL. The bulldup of utentum la the machines is estlmsted u 45 gms per machine (about 1/2 of that for the CPDF). Thus, the total uranium in the 10 machines would have been 430 grams. Therefore, the total uranium in the piping system would have been 585 grams. At present, the uranium contamination would be:

Machine 45 grsms at 1.1% U 235 - 0.5 s m Piping $35 grams at 0.71% U 235 = 4.29 gm 630 grams 4.34 sm

r Attschreat (cont.)

In addition to the above, small quantitles of uranium deposits will exist in the purge sad evacuation systems. It is estimated that 10-15 Kas uranium were collected We thus estimate on the severtl traps and that the usociated piping might contain 10% of th a distribution finer thaa this would be a guesstimate.

Gamma radiation surveys during the lut few days have failed to reveal data to determine uranium deposit or the assays thereof.

i More exact estimates and estimates giving dist.rlbutions amons machine and headers (including assays) la the seven stages will require removing machines We will and piping se with complete dissolution and determination of the uranium contamination.

continue to estimate the distribution of contamination within the process piping and will provide a recommendation at a later date relative to obtainin5 the additional data.

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WASTE MANAGEMENT

SUMMARY

120 MACHINE GAS CENTRIFUGE PLANT CPDF FACILITY STABLE ISOTOPE SEPARATION ALCHEMIE, INC.

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'i i i Description Classifi- Contami- Quantity Method of Disposal of Waste cation nation U U Varies Commercial garbage, Paper & Other '

Office Materials once/ week Classified C . U Varies Return to DOE * '

Documents Floor Sweepings U U 100#/yr Commercial garbage, once/ week ,

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Sanitary Sewer U U 50gpa DOE /ORGDP treatment l max. plant

• Storm Drainage U U Varies DOE /ORGDP underground . !

system

• Steam Condensate U U 20gpm Return to DOE /ORGDP f max. steam plant

• I  :

Fire Water U U As reqd Storm drain *  !

u Cooling Tower U U 100 gal / DOE /ORGDP storm drain

• l yr l Blowdown, Biodegradable Machine Cooling U U ,

50 gal / DOE /ORGDP storm drain

• Water Leakage yr ,

or Drainage, l Biodegradable Crankcase Oil U U 50 gal / Commercial disposal, for Diesel yr change once/ year Generators Vacuum Pump Oil U Toxic 150 gal / ChemWaste, Emelle, Ala.

yr Dispose of in 50 gallon increments. l 1

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• Disposal at ORGDP to be negotiated with DOE as noted.

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DOccriptien Cleccifi- Contami- Quantity Method of Dirpo,c1 of Waste cation nation Off-Gas Trapping U Toxic 200#/yr ChemWaste, Emelle, Ala.

Ship to waste on six Materials months basis.

U U 150#/yr Commercial garbage as HVAC Filters replaced U Five Scrap metal & >

Machine Mount U commercial garbage Hardware sets infant failures, 2 sets /yr i

l Protective U U, 100#/yr Non-contaminated to Equipment Uranium, commercial garbage. ,

I Uranium to DOE /ORGDP. I (gloves, air Toxic, &

masks, etc.) Mixed Toxic to Emelle, Ala. l Bag mixed waste and store j for destruction in TOSCA '

facility at DOE /ORGDP or some other disposal site f as available. Selective i storage as used. Ship to waste on six months basis

• Misc. Nuts, Bolts U U 200#/yr Scrap metal and commercial Gaskets, etc. garbage Misc. Utility U U 500#/yr Scrap metal and commercial Mechanical Equip. garbage (pumps, valves, etc.)

Misc. Electrical U U 100#/yr Scrap meta 1 and l Electronic commercial garbage l Equipment, PC l Boards, etc.

I Gauges, Pressure U U 50#/yr Scrap metal, commercial Elements, Etc. and garbage and ChemWaste, Toxic Emelle, Ala. Selective storage as used. Ship to I waste on six months basis.

• Disposal at ORGDP to be negotiated with DOE as noted. l

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D0ccription C1cacifi- Contami- Quantity M9thod of Dirporni of Waste cation nation

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l Misc. Process U U, 500#/yr Unclassified Uranium uncontaminated to scrap l Equipment, Piping & Toxic, & metal and commercial l Valves, Flex. C Connectors, Mixed garbage. Classified, uranium, and i 0-rings, etc. uncontaminated .t o DOE /ORGDP. Unclassified toxic-contaminated to Emelle, Ala. Mixed and toxic contaminated, l unclassified and l classified, thru i mult1-atage decontamination and recovery. Classified J waste to DOE /ORGDP. '

unciansified waste to commercial garbage. ,

Selective storage as used. Ship to waste on six

- month basis.

• Failed C Uranium Five Rotor, column, scoops, Centrifuge infant heat shield, lower drive, failures lower suspension, upper suspension & diffusion pump to DOE /ORGDP for burial. Reuse casing, process lines, lower head, wiring harness, and support yoke. Ship to waste as failures occur.*

Failed C Mixed Two per Rotor, column, scoops, Centrifuge year heat shield, lower drive, lower suspension, misc. i gaskets and o-rings, thru l multi-stags i decontamination and recovery - waste to .

DOE /ORGDP for Burial. l Declassify upper suspension, clean in multi-stage I decontamination and recovery, reuse or waste l to scrap. Clean as required and reuse diffusion pump, casing,

• Disposal at ORGDP to be negotiated with DOE as noted.

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l D0ccripticn Ciccoifi- Centami- Method of Disposal i

of Waste cation nation Quantity process lines, lower head, I i

wiring harness, and support yoke. Ship to waste as failures occur.*  ;

Freon TP-35 C Mixed 10 gal / Bottle and store for yr destrJetion in the TOSCA facility at DOE /ORGDP or 4

some other waste disposal .

a site as available. Ship to l weste once/ year.

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Water / sand C Mixed 150 gal / Separate classified l' yr material, toxic, and  :

Mixture Uranium i uranium wastes.

I and classified waste to  :

DOE /ORGDP. Toxic waste to '

Emelle, Ala. Rouse sand.

1 Ship to waste once/ year.

• 011 from lower suspension, Centrifuge oils C U& 2 gal /

' Mixed yr upper suspension, and '

column damper are silicone i

base and will become part of failed centrifuge. The 2 50 to 60 cc of fluorinated hydrocarbon I oil in the diffusion pump l will be flushed with Freon l

TP-35 for destruction in the TOSCA facility at DOE /ORGDP or some other waste disposal site as it i

becomes available. Ship to waste once/ year.

• j Rags, Chemical C U& 25#/yr Bag and store for i destruction in the TO SC#,

{ Wipes, etc. Mixed  !

Facility at DOE /ORODP or

! some other waste disposal site as available. Ship ,

to waste on six months i I basis.

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) Vacuum System U Toxic 50 ChemWaste, Emelle, Ala.

Exhaust Trapping Gal /yr Ship to waste on six

{ months basis.

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• Disposal at ORGDP to ba negotiated with DOE es noted.

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