ILLINOIS POLLUTION CONTROL BOARD
March
8,
1973
)
GENERAL ELECTRIC, MIDWEST
)
FUEL RECOVERY PLANT
)
)
)
v.
)
PCB 72-477
)
)
ENVIRONMENTAL PROTECTION AGENCY
)
)
)
OPINION and ORDER OF THE BOARD
(by Mr.
Dumeile)
The petitioner requests
a variance from Rule
207(e) (2)
of the
Illinois Air Pollution Regulations which provides that no existing
industrial process shall
emit more than ten pounds
of nitrogen
oxides per ton of nitric acid used in such process
after December 31,
1973.
Hearing was held on February
7,
1973.
At
the hearing
the
Agency did not introduce any evidence
in opposition
to the variance.
The
Midwest Fuel Recovery Plant
(MFRP)
is
located near Morris
in
Grundy County.
It
is wholly owned by General Electric.
The
MFRP
is
a chemical reprocessing plant designed to
take partially spent
fuel and to recover the unused uranium, plutonium and neptunium for
recycle
as
fresh fuel
in order to preserve these natural resources
and to provide waste
forms
suitable for long term storage.
This
is accomplished by dissolving the fuel material
in strong nitric acid
and subjecting
this
feed stream to chemical separation
steps
to purify
the uranium and other elements.
The plant
is designed
to process about
300
toils per year of spent
fuel which
is equivalent
to
the spent
fuel
from about
ten large nuclear power plants.
High activity wastes resulting from
this process are calcined to
an inert oxide
form and the other wastes are
immobil:ized for storage
on site
in reinforced,
lined concrete structures.
Because only
a
small amount of the products from the plant
are shipped
in
the
nitrate
form,
it
is necessary that the bulk of
the
nitric acid used
in
the
process
he decomposed and reconstituted
to minimize the utilization
of
nitric
acid
and to prevent potential large scale releases
to
the
environment.
The
control
equipment
incorporated
at
the
MFRP
to
achieve
such
a
maximum recycle system includes calciners,
scrubbers
and
absorbers installed at an aggregate cost of $2,500,000.
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—
219
-2-
A total of
1,200 pounds per day of nitric acid
is put into
tile
plant, however,
the actual daily use
in the plant
is ten times
that amount or 12,000 pounds
per day.
The emissions
from
the plant
are about 350 pounds per day of nitrogen oxides.
The difference
between
the use and consumption
is accounted for by recycling of
the nitric acid.
The acid
is
recovered for reuse by scrubbing the
offgases
of the calciners
and reconcentrating the acid
to
the
degree desired for the various processes.
A final scrubbing of
the
offgases
is done by
the V-560 vessel vent scrubber,
the primary
purpose of which
is
to remove radioactive constituents, primarily
iodine,
from
the
vessel
vent
header
and
the
condenser
vent
header
system.
The
offgases
are
then
passed
thru
a
silver
reactor
and
then
thru
a
final
offgas
filter.
They
are
then
discharged
into
the
air
tunnel,
filtered
thru
a
low
velocity
sand
filter
and
finally
dis-
charged
to
the atmosphere
from the top of the
300 foot main process
stack.
According
to the testimony,
the design estimate release of 350 pounds
per day of nitrogen oxides
from the main process stack would result
in a maximum annual average concentration at the plant site boundary
of less
than
0.1 micrograms per cubic meter and less than
0.01 micro-
grams per cubic meter
in
the general offsite region.
The additive
effect
of the proposed
MFRP
emission
at
the site boundary would be
less
than 1/1000th of the applicable ambient air quality standards
and would be less
than 1/10,000th of those standards
in the general
offsite area.
The standard is
100 micrograms
per cubic meter.
l)ue
to
the
requirement for handling both radioactive and non-radioactive
gases,
all
equipment
for
process
offgas
treatment
must
be
located
within the heavily
shielded
portion
of
the
process
canyon
area
and
must therefore be designed to be
installed,
operated and maintained
completely remotely.
Because the process offgas system has been designed
primarily to assure the highly reliable control of radioactive emissions,
any modifications
to this system must
be carefully evaluated to assure
that no adverse operating or reliability problems
result therefrom.
Further, because
the equipment will be required to operate
in
a radioactive
environment
tile
wastes
which
are
generated
by
such
equipment
will
be
radioactive
and must be disposed of
as
such.
Also, because the equip-
ment will
be
radioactive,
many
times
what
would
otherwise
be
a
minor
malfunction
or
failure
will result
in
the
equipment
having
to
he
replaced
in
its
entirety
because
the
radioactive
contamination
associated
with
the
equipment
would
render
such
repair
extremely
difficult
if
not
im-
possible.
The
petitioner
also
presented
testimony
on
two
systems
which
could
be
used
to
further
control
the
nitrogen
oxide
emissions.
Either
system
would
cost
about
$500,000
to
install
and
would
require
around
two years
for
development,
design,
approval,
construction
and
installation,
Prior
to
the
installation
of either system
a
suitable
detailed
design
analysis
would
have
to
be
performed.
The
analysis
would
include
the
capability
7
—
220
-3-
of
t~e equipment
to provide
the
required
operating
efficiencies
under
a
wide
range
of
both
normal
and
abnormal
operating
conditions
and
to
main-
tajil
the
intcgrit:y
of
tile
system
under
all
conditions
including
natural
disturbances
such
as
earthquakes
and
tornados.
Also,
prior
to
tile
installation
of
any
system,
AEC
authorization
would
have
to
he
obtained.
Pet:itioner
takes
the
position
that
because
of
the
substantial
complexi
associated
with
such
systems
and
the
potential
adverse
operational
and
safety
problems
associated
with
the
installation
at
the
MFRI~, the
current
nitrogen
oxide
emissions
are
already
as
low
as
practicable
for
a
plant
of
this
type
and
that
the
installation
of
additional
nitrogen
oxide
removal
equipment
is
neither
justified
nor
desirable.
The
Agency,
in
its
recommendation,
suggests
that
the
variance
should
be
granted.
Tt
states
that
the
fac:ilitv
emits
only
a
small
quantity
of
nitrogen
oxides
in
excess
of
the Regulations
and
that
the
nature
of
the
operation
raises
the
possibility
that
the
further
control
of
such
emissions
would
be
hazardous
and
expensive.
The
Agency
recommends
a
grant and under all the circumstances we will
grant
tile
variance
for
one
year
but
subj ect
to
certain
condi tions
which
have
been
recommended
by
the
Agency.
We
do
expect,
however,
that
if
tile petitioner returns
for an extension
of
the variance that
they will
be able
to prove
that
they have made substantial efforts between
now
and then
to solve
the problem.
This opinion constitutes
the Board’s
findings
of fact and conclusions
of
law.
ORDER
Petitioner
is granted a variance for its MFRP facility from Rule 207(e) (2)
of the Illinois Air Pollution Regulations until March
8,
1974 under the
following conditions:
1.
Within
thirty
days
after
the
plant
is
in
normal
operation,
tile
petitioner
shall
furnish
to
the
Agency
a
more
accurate
account
of
nitrogen
oxide
emissions
and
delineate
the
method
by which
the
f:igures
were
obtained.
2.
Petitioner shall
immediately notify
the
Agency
if
it
makes
any
process modifications affecting nitrogen oxide emissions.
3.
Petitioner shall supply,
install and maintain a continuous nitrogen
oxide
ambient air monitor of
a type
and
at
a
location
to
be
approved
by
the
Agency, within thirty days
after
this
Order.
Hourly
average
concentration
data
is
to
be
submitted
to
the
Agency
on
a
monthly
basis.
I,
Christan
L.
Moffett,
Clerk
of
the
Illinois
Pollution
Control
Board,
hereby
certify
the
above
Opinion
and
Order
were
adopted
on
the
~
day
of
March,
1973
by
a
vote
of
J-0
stan
Illinois
Pollution
trol Board
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221