ML20205R711

NRC Staff Testimony of Jj Swift Addressing ASLB Inquiries Dtd 881018.* Supporting Info Encl.Related Correspondence

ML20205R711
Person / Time
Site:	05000000, 05000603, 05000604
Issue date:	11/04/1988
From:	Swift J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS), NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:
Shared Package
ML20205R677	List: ML20205R673 ML20205R711
References
88-570-01-CP-OL, 88-570-1-CP-OL, 88-571-01-CP, 88-571-1-CP, CP, CP-OL, NUDOCS 8811100102
Download: ML20205R711 (14)

Text

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UNITED STATES OF AE RICA NUCLEAR REGULATORY COPHISSION

_BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

ALL CHEMICAL ISOTOPE ENRICHMENT, ) Docket No. 50-603-CP/0L i INC. )

) ASLBP No. 88-570-01-CP/0L (AlCheu!E Facility-1 CPDF) )

and In the Matter of )

, .\

ALL CHEMICAL ISOTOPE ENRICHMENT, ) Docket No. 50-604-CP INC. )

) ASLBP No. 80-571-01-CP (A1 Chem!E Facility-2 Gliver Springs NRC STAFF TESTIMONY OF Jerry J. Swift ADDRESSING ATOMIC SAFETY AND LICENSING BOARD INQUIRIES OF OCTOBER 18, 1988

My name is Jerry J. Swift. A copy of my professional qualifications is attached.

The purpose of this testimony is to address the Atomic Safety and I Licensing Board's inquiries of October 18, 1988, relating to the NRC Staff's Environmental Assessments dated September 14, 1988. The Board's inquiries and ,

j the Staff's responses thereto are set forth below seriatim.

I l Background i

Although the NRC ("Staff") has responded to the Atomic Safety and Licensing  !

Board's request for additional information, dated October 18, 1988, in the  ;

paragraphs below, it is igertant to note that several inquires of the Board's l request imply that the NRC has regulatory authority over the safety of thw t chemicals the applicant may use in its process. As the Comission made clear  ;

in the Notices published in the Federal Register on April 28, 1988,(53 FR 15313 and 15317), a license issued by The MC for enriching stable isotopes "would i govern possession of the centrifuge machines, but not the enriched stable  ;

isotopes produced" (emphasis added). The Comission approved the staff's l Policy Issue memorandum which was previously supplied to the Board, regarding '

the Federal Register Notices wherein it was noted that "In this case, however, t the chemical hazards, if any, are unrelated to materials licensed under the j

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Atomic Energy Act. Such hazards would be subject to regulation by other agencies ,

(e.g., Environmental Protection Agency under the Resources Conservation and Recovery Act, and the Toxic Substances Control Act). Therefore, in this instance the staff believes that the Cumission should not exercise any authority it may have over chemical hazards that may arise from operation of the machines to produce non-radioactive materials." In furtherance of this observation, the Staff notes that the issues listed in the FR Notices pursuant to the Atomic Energy Act of 1954, as amended, specifically have excluded the issue of the health and safety of the public as regards applicant's chemical operations. This issue is left to the State of Tennessee and other appropriate federal agencies to address. Only the protection of the comon defense and security is at issue for the Board's and the Staff's consideration. Therefore, in its environmental analysis the Staff considered only environmental aspects related to the use of the chemicals by the applicant, not details related to chemical safety such as safety procedures to protect workers.

AlchemIE received copies of the inquiries; the responses below were prepared I after consultation with AlchemIE in order to receive information necessary to prepare this testimony, i

With Respect to Facility-1

1. (Page 2, line 26) Why has the staff not requested nere explicit information en feed material and processing rate so that it can perform an analysis of material rq1 eases that will be applicable to AlchemIE's Facility-l? What did Staff base its analysis on and why is it deemed "conservative"? L Staff Response: The level of production associated with the AlchemIE facilities will depend upon the development of the market for enriched naturally occurring isotopes. In the environmental reports and safety analysis reports, AlchemIE ,

Jentified production levels for various materials. These production levels were optimistic (high) estimates and were used to bound the environmental analysis.

The Staff's environmental analysis is considered conservative because these production levels which the Staff used are higher than A1ChemIE actually expects  !

to occur. In additiM , the release fraction tssumed by the Staff is at least a factor of ten greater than the DOE estimates for the performance of a gas j centrifuge plant.

2. (Page 7, line 27) When will the design of the portable feed carts become available? Since the most serious accident that could occur involves the release of the toxic contents of a cylinder, would it not be important that the carts definitely (as opposed to "may") provide secondary confinement for feed cylinders?

Staff Response: The preliminary designs for the portable feed and withdrawa'l carts have been cogleted. A1 Chem!E has provided a copy for the Staff (see attachment). Final designs will be completed after the construction permit for

, the CPDF has been issued by BC and af ter DOE has leased the CPDF to A1 Chem!E.

The primary function of the feed carts will be to provide a versatile method to

) hold the feed cylinders and some feed and withdrawal equipment, such as heating or cooling devices, in the inmediate area of the cascades. The design concepts

t being considei*ed for the heating or cooling of materials (particularly the coolint operations) involve O e use of insulation or other covers. These may provide some additional confinement although that is not one of the primary objectives of the system. Secondary confinement of these materials is not required in normal industrial practice. A1 Chem!E has comitted to DOE to preparing detailed handling, operating and safety procedures for each of the materials before it is actually processed in the facility. Recently AlchemIE has completed a G) tailed safety analysis of the materials it expects to process in the coming years. This analysis has led AlchemIE to conclude that feed and withdrawal cylinders of toxic materials will be limited in quantity (e.g., to 5 kg) so that operational personnel will be adequately protected and secondary confinement is not necessary.

3. (Page 8, line 5) The same questions apply to the portable withdrawal carts as those reised with regard to the feed carts in Question 2. In addition, how will the dry ice in isopropyl alcohol or liquid nitrogen system used for condensation be designed and work?

Staff Response: The response to the issue of secondary confinement is the same as for Question 2.

The dry ice - isopropyl alcohol cooling system will involve the withdrawal cylinder setting in an open top vessel with the annulus between the cylinder and the inner vessel wall filled with an isopropyl alcohol, mixture. Dry ice at atmospheric pressure will have a temperature of about -78 C which makes this the limiting temperature for this system. The system will evolve gaseous CO 2 as it cools the cylinder. Theisopropyjalcoholisusedasaheattransfer medium that will not freeze at the -70 C operating temperature.

j The liquid nitrogen cooling system will be similar to the isopropyl system in

that the cylinder will be positioned in another vessel and the annulus between the two will be filled with liquid nitrogen. The addition of liquid nitrogen will be controlled by a liquid level controller and the top of the outer vessel will be covered to insulate the annulus and exclude moisture and air.

4. (Page 9, line 2) When will AlchemIE decide on the method of gas treatment (cold trapping, chemical trapping, or mechanical trapping) to be used, or will the method used be selected specifically on the basis of the physical and chemical properties of the material being processed? What environmental effects would result from the different treatments?

Staff Response: A1 Chem!E will decide on the msthod of gas treatment prior to the beginning of any actual processing of a specift: material. The criteria to be used in selecting the treatment system will inc'ude the compliance with Tennessee air standards, the protection of the operating iersonnel and the public and to the extent practical, minimizing valuable materisl losses.

As stated on page 24 of the EA, release fractions of less than 1E-3 were used

in considering the inpacts of normal operation. This release fraction is considered to be very conservative in light of the DOE estimates for gas centrifuge plants enriching uranium. Most of the toxic or hazardous materials l

4-which may be processeJ by AlchemIE have low va)or 3resst.res which means that their management would be similar to that of V i w11ch has a release fraction of less than 1E-4. The estimated release quantitier, are less than a gram per day (probably orders of magnitude less) and it is expected that the releases will not be detectable in the environment. No environmental effects are expected to result from normal releases.

5. (Page 9, line 11) When will procedures be developed from data supplied by the manufacturers of feed materials for the handling, operating, and safety procedures to protect workers and the environment? Will Staff review the data supplied by the manufacturers and provide an opinion as to its adequacy?

Staff Response: Handling, operating, and safety procedures for the protection of workers and the environment will be prepared prior to processing the specific material. The Staff does not consider 8t necessary to review the manufacturer supplied material safety data sheets because the standards for the content of material safety data sheets are established and monitored by the Occupational Safety and Health Administration pursuant to 29 CFR 1910.1200 and 29 CFR 1903.

6. (Page 11, line 20) The same question raised with respect to dry ice and isopropyl alcohol and liquid nitrogen under question 3 applies here.

Staff Pespon g: The answer provided in question 3 also applies here.

7. (Page 13, line 5) Why has A1 Chem!E not attempted to estimate the gaseous discharges expected from the building ventilation system and the evacuation and purge i,ystems for the cascade? Shouldn't they be required to do so in order that Staff's assessment be premised on more than mere belief?

Staff Response: A1ChemIE has not attempted to develop detailed estimates of the gaseous discharges expected from the building ventilation system and the evacuation and purge systems because the engineering details to support a more rigorous assessment are not available. The Staff considers the estimates it prepared to be conservative (higher than expected to actually occur) and these show that the amount of material that will be discharged will be minimal. On this basis, the Staff does not believe that additional assessment is required.

8. (Page 18, line 24 and continuicg on p. 19 through line 8) What might the effect of A1ChemiE's facility-1 be on the ecology of the endangered species, Cimicifuga rubifolia and tampsilis orbiculata, and on other species in the Clinch riiier or elscwhere in the vicinity of the facility?

Staff Response: The analysis conducted by the Staff indicates that the releases of hazardous or toxic materials to the local environment will be extremely small and are not expected to be measurable in the environment. These releases are not expected to result in any impact on the endangered species in the Clinch River or elsewhere in the vicinity of the facility.

9. (Page 23, line 19) What is the status of A1ChemIE's application for an air permit from the TDHE7 Has A1CHemIE satisfied the requirements of TDHE for a license?

Staff Response:. AlchemIE received a construction air permit from the TDHE.

The initial permit was only valid for 3S days and has expired. A1 Chem!E is in the process of requesting a renewal of the permit. They have prepared and submitted to the TDHE the material required in support of an operating permit.

The TDHE is currently reviewing this information.

10. (Page 24, line 9) Since the air emissions from the AlchemIE Facility-1 may be higher than those from gas centrifuge plants used by Staff to make its estimates, A1ChemIE and/or the Staff should attempt to estimate the emissions to be expected from Facility-1.

Staff Response: The Staff has made what it considers to be bounding estinates using release fractions greater than those in DOE reports for gas centrifuge plants designed for uranium hexafluoride. The analysis based on these estimates does not indicate that there will be any problems. Based on this, the Staff does not believe that additional, more precise estimates are required.

11. (Page 27, line 3) If an accident releasing dimethylcadmium from a cylinder in the room containing the centrifuges should occur producing a concentration at the icwer levels of the room that was substantially greater than the ACGIH TWA-TLA, it would be hazardous for the workers in the room. Have emergency plans for actions to protect the workers been developed, and if so, what are they? If they have not been developed, they should be before the facility goes into operation.

12. (Page 27, line 20) The question about einergency plans given an accidental release of dirrethylcadmium is also applicable in an accidental release of tin hydride.

Staff Response to 11 and 12. As required by DOE, A1ChemIE will prepare emergency plans for each of the toxic or hazardous materials that it will process.

These plans will be prepared befcre any processing of the material is initiated.

These emergency plans will include evacuation plans and recovery plans.

13. (Page 29, line 10) The probability and u sequences of an accident resulting frcm the transportation of gas cylinders appears not to have been considered but should be.

Staff Response: Haterials identical to or very similar to those being processed by AlchemIE are produced, handled, and transported on a routine basis in the IM ted States. The transportation operations will be conducted in according with DOT requirements. The small incremental amount of material transportation that is associated with the AlchemIE operations will have no significant impact on the risk to the public or the environment. For this reason, the Staff does not believe that the probability and consequences of transportation accidents have to be considered.

With Respect to Facility-2 To the extent that the questions raised with respect to Facility-1 are applicable to Facility-2, they should also be answered with regard to Facility-2. In addition, we have several different questions about Facility-2 which are listed below.

Staff Response: To the extent that the questions raised by the Board with respect to Facility I are applicable to Facility 2 they havs been answered with regard to Facility 2 as follows:

All of the above answers are applicable to Facility 2. In addition, the Board has several different questions concerning Facility 2 which are answered below.

1. (Page 6, line 8) Why is the prstsure in the cascade area to be maintained slightly above atmospheric? In the vent of an accidental release of a toxic gas in the cascade area, would it not be in the interest of public safety to have the pressure within the building to be slightly less than atmospheric?

Staff Response: The safe operation of the centrifuges requires a uniform circumferential temperature to avoid bending of the casings thich can lead to centrifuge destruction. Experience in the centrifuge demontcration program has shewn that the required temperature control is very difficult to achieve with a building which has negative internal pressure. Cold air leaking through building walls has caused centrifuges to destruct.

In addition, the a'1alyscs that have been performed show that there is no significant hazard to th public that would be significantly mitigated by the use of a negative pressure for the process room.

2. (Page 12, Table 2.2) Why will the electric and the compressed air demands for Fac111ty-2 be so much greater than those of Facility-17 Staff Response: The electric and compressed air demands for Facility-2 are projected to be greater than Facility-1 because Facility-2 will have 600 machines while Facility-1 has only 120 machines.

3. (Page 13, line 17) Provide more detailed information about presently over-taxed drain pipes resulting from water infiltration into the Oliver Springs i

sanitary waste facility during periods of heavy rainfall. Also indicate when Oliver Springs expects to replace the leaking pipes and how A1ChemIE's facilities or the environment might be affected if A1 Chem!E's facilities go into operation before the leaking pipes are replaced.

Staff Res>onse: Because there are no floor drains in the process area and because of the Al;hemIE plans for managing the toxic and hazardous material, no toxic or hazardous material of significant amount is expected to be released to the sewer lines or system.

However, it is the Staff's understanding that the Town of Oliver Springs has an active program to assess the condition of its main sewer lines and repair or replace as necessary. It is also our understanding that a schedule for repair or replacement will be available after the assessment program is com)1ete. It

! is further understood that Oliver brings has an apprcved sewer reha)111tation program that meets all of the State of Tennessee requiremants.

4. (Page 15 Table 2.3) Why will Facslity-2 produce so much more commercial garbage and solid ChemWaste than Facility-17 In addition, explain why Facility-2 will produce less oils and solvents for comercial disposal, more ChemWaste in oils and solvents, and more oils and solvents from the TOSCA or RCRA facility, than will be produced by Facility-1.

Staff Response: Facility-2 will produce more waste material in most categories than Facility-1 because Facility-2 has 600 machines while Facility-1 has 120 machines. In the category of oils and solvents for comercial disposal.

Facility-1 has more waste because the CPDF has two diesel generators while Facility-2 will have only one.

5. (Page 19, line 10) Obtaining data on terrestrial fauna specific to the Oliver Springs area thculd not pose an unreasonable or expensive task. In the absence of data one could not expect there to be any evidence of threatened or endangered species, even if such were present. A survey of the fauna of the area should be conducted and the results made known to the Board.

Staff Response: NRC staff has requested AlchemIE to conduct a survey of the flora and fauna of the Facility-2 area and make the results known to the Board.

The Staff will provide its analysis of the survey conducted by AlchemIE either in writing prior to the evidentiary hearing, or in verbal testimony at the hearing.

6. (Page 25, line 7) Staff states that "A1 Chem!E will apply to the *** TDHE for an air permit " whereas at page 23, line 19 of the Assessment for Facility-1 it was stated that "A1ChemIE has applied *** to TDHE for an air permit." Does this mean that AlchemIE has an application for Facility-1 pending, but has not yet submitted an application for Facility-27 If so, when does A1ChemIE expect to submit its application for a permit for Facility-27

_ Staff Response: A1ChemIE has applied for an air permit for Facility-1. AlchemIE will apply for an air permit for Facility-2 after being granted an NRC Construction Permit. The Construction Permit will contain a license condition requiring that AlchemIE apply for an air permit for the Oliver Springs facility.

7. (Page 25, line 20) Why doesn't A1ChemIE attempt to make specific estimates of the release fraction from Facility-2 so that the Staff's assessment can be more s)ecific than merely stating that the release fraction from Facility-2 "may be hig1er" because of the higher vapor pressure of some of the )rocess materials and tha "likely" greater number of cylinder connections and num>er of cascades in operation at one time?

Staff Response: The detailed engineering information is not available to support a more detailed estimate of the releases associated with the operation of the Facility-2. The Staff considers its estimate conservative. Because this analysis predicts no significant impact, the Staff does not believe that additional analysis 's required.

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Jerr.y J. Swif t

! PROFESSIONAL QUALIFICATIONS I as esployed in the fuel Cycle Safety Branch, Divition of Industrial and  !

Medical Nuclear Safety Office of Nuclear Materials Safety and Safeguards, U.S. I Nuclear Regulatory Comission (NRC). My position is Section Leader Advanced -

1 Fuel and Special Facilities Section. The business of sty Section is primarily the licensing and regulation of commercial enrichment facilities and of source i and special nuclear material licensees other than those which fabricate nuclear  !

1 reactor fuel or prepare uranium hexafluoride from yellowcake. Licensees in these last two groups are re ulated by the Uranium Fuel Section for which I was i 1 Section Leader during most o FY 1988.

I i

I From April 1987 to Aujlust 1987, I was employed in the Radiation Protection Branch, Office of Nuc. ear Reactor Regulation, NRC as a health physicist, dtaling 4

with radiological aspects of nuclear power plant operations.

i Froe 1985 to 1987, I was em>1oyed in the Reliability and Risk Assessment  !

l Branch of the U.S. Nuclear teflulatory Comission, as a Reliability and Risk l 1 Analyst. Much of sty work durnng this period concerned the January 4,1986 accidental release of uranium hexafluoride in Oklahoma and the April 26, 1986 j accident at the Soviet Chernobyl plant. [

i From 1984 to 1985, I was employed in the Radiological Assessment Branch of the [

U.S. Nuclear Regulatory Comission, primarily in evaluation of environmental f j radiological impacts of nuclear power plants operations. j j From 1982 to 1964, I was em>1oyed in the Clinch River Breeder Reactor Program  !

1 Office of the U.S. Nuclear tegulatory Cosmission, primarily evaluating  !

l potential accident sequences which could lead to radiological consequences.

i From 1980 to 1982, I worked at the U.S. Department of Energy on the t

environmental, health and safety aspects of a variety of nuclear technologies,  !

includinji fusion devices, accelerators, transportation, waste management.

sewage s udge irradiation and enrichment technologies.

From 1972 to 1980, I was employed in the Office of Radiation Programs of the j i U.S. Environmental Protection Agency, as a Nuclear Engineer and Environmental [

{ Engineer. During this period, I was involved in evaluating the potential t

radiation doses and radioactive contamination of the environment that might i result from severe reactor accidents, with application to the development of

Protective Action Guides. I was also involved in the evaluation of normal operating releases from nuclear fuel cycle facilities in support of the T l development of 40 CFR 190 "Environmental Radiation Protection Standards for (

j Nuclear Power Operations." I assisted in development work for standards and *

, guidance by EPA on management of high level wastes and uranium mill tailings.

l I aided EPA's participation in nuclear policy reviews by Presidents Ford and i Carter. I managed EPA's lengthy review of the Reactor Safety Study. WASH-1400. j i l I f L ._ _ _ _ i

I 2

From 1970 to 1972, I held a position as Physicist in the Institute fur Reaktorsicherheit, (now the Gesellschaft fur Reaktorsicherheit mbH) in Cologne Germany; in this position, I was primarily concerned with evaluating the nature and quantities of radioactive materit's that might be released in postulated nuclear reactor accidents, and the e 'ulting radiation doses that might be experienced. I was also involved ir t "sting siting conditions.

While a graduate student at the Catholic University of America, from 1966 to 1970 I held the position of Assistant University Radiological Safety Official, performing health physics functions throughout much of the University. i I received the degree of Geological Engineer from the Colorado School of Mines in 1955, a Master of Science degree in Nuclear Engineering from Iowa State University in 1965, and a Ph.D. degree in Nuclear Engineering from the Catholic University of America Washington, D.C. in 1971. I have current certification in Health Physics from the American Board of Health Physics.

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Dear Jerry:

In our discussions on Wednesday, A1ChemIE indicated that sketches for food and withdrawal carts would be provided. For your usss in replying to the ASLB's questions please find attached a sketch of a feed system, a withdrawal system refrigeration cart, and typical withdrawal, large and small, pumping stations.

If you have any questions or require additional information please call me or Mr. Ernie Evans. I hope the onclosed is of use in preparing your responses.

Very truly yours, ALCl{EMIE, INC.

William A. Pfeifer Director of Special rojects WAP/bc Enclosures 80? adkhokt M&

Pine Ridge Office Pork. Suite 202-B 702 minois Ave.. Ook Ridge. TN 37830 (615) 4 2-002

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i FIGURE 1 ,

SMALL WITHDRAWAL CART PUMPING S)STD4 A withdrawal cart will have a pumping system like the one shown l here. For some products it will be larger as shown in Figure 2.

In addition there will be cold traps which will be cooled using solid CO2 (Dry Ice) or liquid nitrogen or mechanical refrigeration. .

4 Application Edwards mechanical booster pumps are being used in a growing number of applications where fast DMT' ..

pump down times are required and where environ- #

mental or energy usage considerations are ruling out afternative methods.

The mechanical booster, when backed by an oil a sealed mechanical pump or a liquid ring pump, is usefulin the pressure range 500 to 10* torr. Higher j,[

vacuum can be attained by using two or more j booster pumps in series.  ;

Mechanical boosters ccmbine high pumping speeds  :

with small physical size and their most efficient t range of pumning speeds fills the ' gap'left between ,

standard speed curves of rotary pumps, vapor dif- l fusion pumps and vapor booster pumps-see , ,

curve.They can be used as the final stage of a pump system or they can be used as part of the baching system for vapor booster and diffusion pumps.

I TYPICAL PERFORM ANCE CURVES FOR ALL TYPES OF VACUUM PUMPS 2000 Q, gf C

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boostere include steel degassing p9nts, coating

' giM Db iot b plants, furnaces, wind tunnels, space simulators, to4 io 4 iod to

• io* io impregnation plants, drying and aegassing prncess P AISSUM:Tona plants, semiConducto. FUduction, packaging equip-ment, pharmaceutical freeze dryers, preparation of 1 Vapor dif fusion pump. 2 Oil vapor booster pump. vacuum spectrographs for meta!!urgical analysis 3 Mechanical booster pump bried by Rotary pump, 4 Rotary pump. and evacuation of large vacuum chambers.

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LARGE W111[DRAWAL CART PUMPING SYSTEM l l

In addition to this pumping system there will be a mechanical refrig- I eration system to cool cold traps. This refrigeration system will be about as large as thfa pumping system. Such a combination will  !

l service two withdrawal streams, i.e. product and tails.

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FEED SYSTEM ft)R DIMETHYL ZINC (DMZ)

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Vactan I\mp The equipment for a feed system will be contained in a space approxi-mately 3' wide X 4' long by 5' high.

i FIGURE 4 l

COLD TRAP WEILS WITH MECHANICAL REFRIGERAT100t i

Dese are used for withdrawal of product and tails. "Jhese units were used for collecting UF at the GCEP. .

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