ML20217A946
| ML20217A946 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 03/17/1998 |
| From: | Weber M NRC |
| To: | |
| Shared Package | |
| ML20217A914 | List: |
| References | |
| NUDOCS 9803250305 | |
| Download: ML20217A946 (5) | |
Text
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pWE y 1- UNITED STATES y
j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20566 0001
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- March 17, 1998 DOCKET: 70-1257 LICENSEE: Siemens Power Corporation Richland, WA
SUBJECT:
SAFETY EVALUATION REPORT: AMENDMENT APPLICATION DATED AUGUST 22,1996, MODULAR EXTRACTION / RECOVERY FACILITY (MERF)
BACKGROUND in a submittal dated August 22,1996, and supplementary information dated January 27, March 7, May 1 and 21, September 9, December 2, and November 10,1997; and February 2 and 6,1998, Siemens Power Corporation (SPC) applied for a license amendment to add authorization for low level radioactive waste (LLRW) shredding and uranium recovery from LLRW in a modular unit. SPC has been making substantial progress in reducing its inventory of LLRW over the last few years. A significant portion of the remaining LLRW inventory requires additional processing before disposal at a LLRW site for two reasons: (1) the waste contains a substantial amount of recoverable uranium which SPC intends to reclaim and (2) the waste includes
- wet waste" (mop heads, filter' cartridges, rags, etc.), prefilters, and high efficiency i particulate air (HEPA) filters contaminated with nitric acid, ammonium fluoride, ammonium nitrate, and other chemicals that result in the materials' being classified as dangerous waste under State of Washington Dangerous Waste Regulations. After processing, SPC will render the waste non-dangerous so that it may be disposed of as LLRW or it will be incinerated in SPC's Solid Waste Uranium Recovery (SWUR) facility.
SPC has contracted with Recovery Dynamics Corporation (Recodyne) to process waste at SPC in a Modular Extraction / Recovery Facility (MERF). SPC's license will authorize the sorting, shredding, and uranium recovery in Recodyne's MERF.
DISCUSSION The MERF will be located approximately 50 feet northwest of the Lagoon Uranium Recovery (LUR) facility on an existing blacktop pad. The sorting / shredding, material handling / laboratory, and leaching / extraction process areas comprise three metal modules attached side-to-side.
l The modules are designed to withstand 100 mph wind loading and the roof is designed to I withstand a load of 60 psf. Attached to the modules is an un-insulated shed (Weatherport) !
where bulk chemicals and the steam generator are located for the waste treatment process.
SPC will first empty the waste drums into a glovebox and sort prior to shredding. Certain waste
.will be shredded to facilitate uranium recovery or incineration. SPC will conduct uranium recovery in the MERF and incineration in the SWUR facility. The leaching / extraction process consists of a commercial washer / extractor where nitric acid dissolves recidual uranium from the shredded waste material (filters, rags, wet wastes, etc.). To assist extraction, this process is heated to 140'F by live steam injection. The nitric acid / uranium solution is then removed from the washer / extractor, neutralized with sodium hydroxide, and precipitated with hydrogen
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peroxide. Precipitated uranium is then filtered from the solution and stored elsewhere'on-site.
The leached solids are then washed, compacted, and assayed in preparation for either off-site
. disposal or on-site incineration.
Recodyne will operate the MERF under the following design requirements:
- 1. Uranium will be recovered in a form suitable for use as feed to SPC's solvent extraction facility in the Engineering Laboratory Operation'(ELO) Building.
- 2. Final waste forms will be suitable for burial as LLRW or incinerateo a 5dC's SWUR facility.
- 3. Process equipment and operations will meet SPC's requirements for chemical safety,-
criticality safety, fire safety, radiation protection, and environmental protection.
CHEMICAL SAFETY REVIEW NRC staff reviewed the MERF process and raised 3 primary concerns:
- 1. The compatibility of organic material with nitric acid in the washer / extractor.
- 2. Thermal degradation of the hydrogen peroxide in the Weatherport.
- 3. The potential for chemical interactions in the Weatherport.
Some of the waste material to be processed contains organic material such as solvents and lubricating oils. NRC staff was'concemed that these materials may not be compatible with the nitric acid solution used in the washer / extractor, especially the alcohol soaked rags (typically 10 - 50% alcohol). SPC performed limited tests and did not observe any incompatible reactions; SPC also noted the rags will be pre-rinsed prior to mixing them with the nitric acid solution in the washer / extractor. The staff still has concems on the processing of alcohol rags.
Although SPC does not believe that the method to process the alcohol rags poses a safety problem, SPC has agreed to provide further documentation and/or evidence of material compatibility and will apply for a separate amendment for processing alcohol rags. To provide additional assurance that SPC does not process the alcohol rags, the staff recommends the following condition:
S-4 The licensee shall not process alcohol rags through the Modular Extraction / Recovery Facility.
. The second concem involves thermal degradation of the hydrogen peroxide stored in the Weatherport. The Weatherport is not temperature regulated and the hydrogen peroxide will be stored near the steam generator and during hot summer months Hydrogen peroxide
- decomposes at elevated temperatures, off-gassing oxygen and increasing the risk of fire. The
- Material Safety Data Sheet (MSDS) submitted by SPC recommends storing hydrogen peroxide away from combustible material and in cool dry places below 100'F. The staff expressed its concem and in response, SPC evaluated the high temperature scenario and concluded the off-
. gassing oxygen from the hydrogen peroxide was minimal.' However, SPC has committed to
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provide ventilation to prevent heat and chemical off gas buildup and prohibit transient combustible storage in the Weatherport. ]
The last concern was related to the previous concern and was the intermingling of the chemicals stored in the Weatherport (i.e., nitric acid, sodium hydroxide, and hydrogen peroxide). The chemicals are heavy oxidizers and are incompatible with hydrocarbon fuels and cellulosic materials. . SPC committed to utilizing secondary containment pans under each drum or tote, designed to hold 100% of the chemical if the container leaks. Also, the propane supply lines to the steam generator will be kept underground and exposed only beneath the steam generator. Gas detection will be installed to shutdown the propane supply if a leak should a occur. SPC commits to provide ventilation to prevent fume buildup, prohibit storage of transient combustible material, and perform periodic inspections for leaks in the Weatherport.
Based on the commitments made by SPC and the review of the material submitted by SPC, ths
- staff concludes that SPC has demonstrated an adequate level of chemical safety to perform j
. proces, sing in the MERF.
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GlTlCALITY SAFETY REVIEW SPC will operate the MERF under batch control limits with the maximum amount of U-235 of up to 5% enriched uranium allowable in the MERF at any one time to be 450g U 235. The minimum critical mass committed to by SPC for optimally moderated, fully reflected 5%
enriched UO2according to Table 11.14.2 of SPC's application is 40 kg UO2 . Forty-five percent of 3 this mass is equivalent to 18 kg UO2 which equates to a required safety limit of 790 g U-235. !
SPC has committed to maintain the mass of U-235 in the entire process at any one time less than or equal to 450 g, thus ensuring an adequate safety margin.
To ensure the batch limits are not exceeded, SPC sorts the initial waste material and performs a nondestructive assay analysis to establish the U-235 content of the material. Then, SPC will perform a second sorting prior to introduction of the materialinto the process, thereby ensuring the batch limits are not exceeded. After a batch of this waste material is processed, a complete clean out of the materialis required. SPC will perform independent inspections to assure that the equipment does not have any significant holdup of material prior to permitting another batch to be processed.
The MERF will be located within the existing criticality detector system's coverage.
Based on a review of the material submitted and the commitments made by SPC, the staff ]
concludes that the criticality safety limits and controls for the MERF are adequate.
FIRE SAFETY REVIEW The MERF modules are constructed of thick tubular steel and heavy welded steel plate. The walls are insulated with isocyanurate foam board and covered with aluminum faced plywood for decontamination purposes. The facility is situated an acceptable distance from other facilities and does not pose an exposure fire threat. The facility is designed to contain radioactive contamination and exhaust through HEPA filtration. Fire detection is provided by heat and L'
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4 smoke detectors and manual pull stations are located near egress points. The alarm system enunciates both locally (to alert operators) and at a constantly manned guard station.
Personnel have multiple egress paths and tire extinguishers are provided for incipient fire fighting. HEPA filters are protected with water spray and the sorting glovebox is protected with CO, fire suppression system. Manual fire suppression is provided by the plant personnel and ;
j the local fire dopartment. Fire hydrants are located throughout the SPC complex for manual fire suppression.
The Weatherport is attached to the exterior wall and houses process chemicals and a propane fired steam generator. The Weatherport has flammable gas detection and fire detection which will sound an alarm to alert operators and automatically secure the propane supply. The licensee has concluded that a fire involving these chemicals will not involve the radiological material inside the MERF Based on the above, the staff concludes that SPC and Recodyne provided an adequate level of fire safety to conduct processing in the MERF, ENVIRONMENTAL REVIEW From 1994 to 1997, the licensee has reduced its inventory of solid low level radioactive waste (LLRW) by approximately 58%. The MERF will allow the !!censee to further reduce this inventory to meet a solid waste inventory goal of 10,000 ft' by September 1998 [ Letter, L.J.
Maas (SPC) to M.F. Weber (USNRC), " Update on Siemens Power Corporation's (SPC's)
Progress on Reducing inventory of Stored Low-Level Radioactive Waste (LLRW)," June 3, 1997].
Processing material in the MERF will result in airborne and liquid effluents. To control uranium particulate in airbome effluents, the MERF air exhaust system will include a pre-filter, HEPA )
filter and a 35-foot exhaust stack with isokinetic sampling instrumentation. In addition, waste !
sorting and shredding will be done in HEPA filtered punch glove boxes. The HEPA filters will be tested to confirm 99.97% efficiency for removal of 0.3 micron particles prior to installation, and tested in-place for 99.95% efficiency for removal of 0.8 micron particles. The licensee {
estimates the annual uranium release through the stack will be approximately 2.5 microcuries, which is less than 20% of the activity released annually in gaseous effluents facility-wide. In addition, a liquid scrubber will be used to treat the process off gas from various chemical process tanks as well as air from the drum dumper area of the glove box, the washer hood, the de-watering filter, and the laboratory area. ,
l SPC will discharge liquid effluents from the MERF to Lagoon 3. Uranium from Lagoon 3 is further recovered in the LUR facility and ammonium is recovered in the Ammonia Recovery Facility (ARF). The LUR and ARF facilities are authorized and described in SPC's current license. !
The environmental protection measures described in Chapters 5 and 13 of SPC's license will !
apply to operations in the MERF. These measures establish effluent and environmental monitoring frequencies, type of analyses, and administrative action levels. Action levels established for monitoring results will ensure that investigation and corrective action are initiated before releases exceed regulatory levels.
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5 The MERF will be located approximately 50 feet northwest of the LUR facility on a blacktop pad. SPC will survey the pad for radioactive contamination, and decontaminate as necesi,ary, after the MERF is removed at the end of the recovery campaign.
NRC staff has reviewed the applicant's amendment application and has determined that the
~ following conditions have been met:
- 1. There is no significant change, in the types or significant increase in the amounts of any effluents that may be released offsite.
- 2. There is no significant increase in individual or cumulative occupational radiation exposure.
- 3. There is no significant construction impact.
- 4. There is no significant increase in the potential for or consequences from radiological accidents.
Accordingly, pursuant to 10 CFR 5.22(c)(11), neither an environmental assessment nor an environmental impact statement is warranted for this action.
CONCLUSION The NRC staff has reviewed the proposed amendment and has determined that the operation of the MERF will have no adverse effect on the public health and safety or the environment subject to License Condition S-4 which prohibits the processing of alcohol rags. Therefore, the amendment should be granted, The Region IV inspection staff has no objection to this proposed amendment.g j
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PRINCIPAL CONTRIBUTORS: ']v 'ea'I r ' i q 'l Kimberly J. Hardin PaulW. Lain Susan D. Chotoo Donald E. Stout Michael E. Adjodha
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