Landfill No. 1 and Landfill No. 2.

Q. Were wastes other than PA filter cake disposed ofin these units?

Petition will be modified with the following:

Landfill No.1 was operated from 1972 to 1976 as a permitted industrial landfill. BWXT

was not required to maintain detailed records associated with the landfills operation.BWXT has investigated the landfill under the auspices of a Nuclear RegulatoryCommission decommission action. Based on that investigation, BWXT has determined that

the majority of waste managed in the landfill was PA filter cake. However, it is known thatsmall quantities of zircaloy machining chips were periodically disposed of the landfill along

with the PA filter cake.2. Page 44 ofthe petition states that, “Tables 1 and 2 (Exhibit 6) identifS’ chemicals that are not

hazardous to human health and chemicals that are not discharged to the waste treatment facilities.

Therefore these chemicals have been eliminated from further consideration.” The petition text

than lists “elimination categories,” some of which appear as parentheticals in these tables, and

some do not.

Q. Please clarify the status ofthe chemicals on Tables 1-5 in Exhibit 6.

The petition will be modified with the following bolded words.

Tables 1 and 2 (Exhibit 6) include chemicals that are not hazardous to human health and/orchemicals that are not discharged to the waste treatment facilities. Therefore these chemicals

have been eliminated from further consideration.

3. Exhibit 6, Table 3 lists the solvent EZE-43 1. However, this Trade Name chemical compound

does not appear on Table 4.

Q. Pleaseprovide a description ofthis solvent.

The Material Safety Data Sheet for EZE 431 has been provided. EZE 431 is an aliphatic

hydrocarbon based industrial cleaner. It Is used in small quantities as a surface cleaner formetal components. The spent cleaner is managed as a RCRA characteristic (DOOl) waste.

The cleaner can not be added to the wastewater treatment system. It has been added to

Table 4.
Page 30 ofthe petition states that, “BWXT recovers uranium using an acid dissolution process.Clad fuel components are dissolved in a solution of nitric acid, hydrofluoric acid, and aluminum

nitrate.”

Q. Are cladfuel components spentfuel rods? Spentfuel rods are classfled as irradiated

material.

The clad fuel components are not spent fuel rods. BWXT recovers fuel components thatare not spent. The recovered fuel components have not been irradiated.

5. Page 31 includes a description ofthe Compact Reactor Fuel Development Process. Included

in the process is the use of unspecified organic solutions.

Q. Do concentrations ofthe organic solutions end up in the wastewater? Ifso, what are

the organic compounds? ( BWXT has specific area operating procedures that prohibit the discharge of organic

solutions from the radiological processing areas to the waste water treatment system. The

spent organic solutions are managed as mixed and/or low-level radioactive wastes via anNRC licensed energy recovery vendor and the resultant ash is sent to a licensed

radiological waste disposal site.

6. Page 30 contains a description ofthe down-blending operations. Page 31 indicates that, “The

puzpose ofthe CRF Process is to convert uranium solutions into fuel.

Q. Do these processes include the conversion ofuranyl nitrate to uranyl dioxide, or touranium metal? Ifso, how is this accomplished?

BWXT operates a fully lièensed commercial Dowublending facility. The facility downblends highly enriched uranium (greater than 20% by weight of the uranium isotope 235)to a fully conforming commercial grade low-enriched uranium with an enrichment of 4%U-235. This process produces primarily either uranyl nitrate solutions or uranyl nitratehydrate crystals, which are transported to nuclear fuel fabrication facilities.

7. The data on the sludge from the October 1993 study shows that the majority ofthe activity isassociated with the isotope U2.

2/3
uranium 234, 235 and 238. There are other uranium isotopes present at insignificantlevels, and of course they all are the same chemically. The HEU is enriched by weight In

U. The specific activity ofU (based on its half life) is 2.142 micro-Curies per gram.

The uranium Isotope Uhas a specific activity of 6,143 mlcro-Curies per gram, thus

although the mass ofUin the HEU is low relative to U, it is a significant portion of the

total activity in the uranium.

BWXT does not use TOPO.

3/3

PRODUCT NAME: EZE 431

CHEMICAL DESCRIPTION: Aliphatic hydrocarbon

PRODUCT CLASS: Industrial cleaner

MSDS CODE: E31 2

Section 2. INFORMATION ON INGREDIENTS

CAS %by

Chemical Name Number Weight OSHA PEL ACGIH TLV

Isoparaffinic hydrocarbon 64742-48-9 100 None establishesd TWA 300 ppm (supplier

. recommendation)

Section 3. HAZARDS IDENTIFICATiON

********************* EMERGENCY OVERVIEW

Clear liquid with a mild solvent odor.

WARNING’

May cause eye, skin and respiratory tract irritation. UG 1 9 1991

Aspiration may cause lung damage.

Combustible liquid and vapor. — - .—,, 0 T

****************************************************************

PRIMARY ROUTES OF ENTRY: Eye and skin contact, inhalation

TARGET ORGANS: Eye, skin, mucous membranes, central nervous system, lung

MEDICAL CONDITIONS AGGRAVATED BY EXPOSURE: Skin contact may aggravate an existing dermatitus

condition.

POTENTIAL HEALTH EFFECTS:

EYE CONTACT: This product may cause some minor irritation upon contact with the eye.

MSDS Code: E31 2 Page 1

Issue Date: 05/1 2/97 Continued on Page 2
IARC:

OSHA:

FLASH POINT:

O

High vapor/aerosol concentrations (greater than approximately 1000 ppm) are irritating

to the eyes and the repiratory tract and may cause headaches, dizziness, anesthesia, drowsiness,

and other central nervous system effects.

SUBCHRONIC, CHRONIC:

The product was administered by inhalation to rats for 6 hours/day, 5 days/week for 12 weeks at

concentrations of 0, 300, or 900 ppm. No treatment-related mortality occurred. There were no

significant alterations in hematology or clinical chemistry parameters. Body weights were decreased in

male treatment groups. Relative mean kidney weights were significantly elevated in males at 300 and 900ppm, and relative mean liver weights were elevated in males at 900 ppm.

Histological findings were limited to the kidneys of male rats and were indicative of light hydrocarbon

nephropathy. These kidney effects are a result of the accumulation of alpha-2u-globulin, a protein specific

to the male rat, in the proximal renal tubule. These kidney effects are specific to male rats and are notconsidered to be of biological relevance to humans.

CARCINOGENICITY:

NTP:

*No ingredients listed in this section*

*No ingredients listed in this section*

No ingredients listed in this section*

Section 4. FIRST AID MEASURES

EYE CONTACT: In case of contact, immediately flush eyes with plenty of water. Seek medical aid if irritation

persists.

SKIN CONTACT: In case of contact, flush skin with plenty of water. Remove contaminated clothing. Seek

medical aid if irritation persists. Wash clothing before reuse.

INGESTION: If swallowed, do NOT induce vomiting. Seek medical aid immediately. Never give anything by

mouth to an unconscious person.

INHALATION: If inhaled, remove to fresh air. If not breathing, give artificial respiration. If breathing is

difficult, give oxygen. Seek medical aid.

Section 5. FIRE-FIGHTING MEASURES

104°F

This product is a combustible liquid.

MSDS Code: E31 2 Page 2

Issue Date: 08/12/97 Continued on Page 3
FIRE & EXPLOSION HAZARDS: Vapors are heavier than air and may travel along the ground or be moved by ventilation and ignited by pilot lights, other flames, sparks, heaters, smoking, electric motors or other

ignition sources at locations distant from material handling point. Never use cutting or welding torch on

or near drum (even empty); product (or even residue) can ignite explosively. All five gallon pails and larger metal containers should be grounded.

DECOMPOSITION PRODUCTS: Thermal decomposition or combustion may produce carbon dioxide, carbon

monoxide, and various hydrocarbons.

NFPA RATINGS: Health = 1 Flammability = 2 Reactivity = 0 Special Hazard = None

Hazard rating scale; O=Minimal 1 =Slight 2=Moderate 3=Serious 4=Severe

Section 6. ACCIDENTAL RELEASE MEASURES

STEPS TO BE TAKEN IF MATERIAL IS RELEASED OR SPILLED: Remove all sources of ignition. Wearing

appropriate personal protective equipment, contain spill, collect onto non-combustible absorbent like

sand or earth and place into suitable container. Do not use sawdust, wood chips or other cellulosicmaterials to absorb the spill. Keep spills and Gleaning runoff out of municipal sewers and open bodies ofwater.

Section 7. HANDLING AND STORAGE

MSDS Code: E312

Issue Date: 08/12/97

Page 3Continued on Page 4

HANDLING: Avoid contact with eyes.

Avoid prolonged or repeated contact with skin.Avoid breathing vapor or mist.

Keep away from heat and flame.Use with adequate ventilation.

Wash thoroughly after handling. Keep container closed when not in use.

STORAGE: Store in a cool, well-ventilated area away from incompatible materials.

• Keep away from heat and flame.

Protect material from direct sunlight.

Section 8. EXPOSURE CONTROLS I PERSONAL PROTECTION

PERSONAL PROTECTIVE EQUIPMENT:

EYE/FACE PROTECTION: Chemical splash goggles and face shield
should be developed by a person knowledgeable of the intended use conditions and equipment.

Section 9. PHYSICAL AND CHEMICAL PROPERTIES

BOILING POINT: 320 - 351 °F SOLUBILITY IN WATER: Negligible

VAPOR PRESSURE: 2 mmHg @ 68°F SPECIFIC GRAVITY: 0.75 @ 60°F

VAPOR DENSITY (air=1): 4.94 pH: Not applicable

%VOLATILE BY WEIGHT: 100 FREEZING POINT: <-76°F

APPEARANCE AND ODOR: Clear liquid with a mild solvent odor.

VISCOSITY: 1.3 cSt @ 77°F

Section 10. STABILITY AND REACTIVITY

CHEMICAL STABILITY: Stable HAZARDOUS POLYMERIZATION: Will not occur

CONDITIONS TO AVOID: Keep away from heat and flame. Avoid high temperatures.

INCOMPATIBILITY: Strong oxidizing agents

DECOMPOSITION PRODUCTS: Thermal decomposition or combustion may produce carbon dioxide, carbon

monoxide, and various hydrocarbons.

Section 11. TOXICOLOGICAL INFORMATION

ON PRODUCT:

Product Oral LD50 (rat): > 10 g/KgProduct Dermal LD50 (rabbit): > 3.16 g/Kg

MSDS Code: E312 Page 4

Issue Date: 08/1 2/97 Continued on Page 5
RCRA STATUS; Discarded product, as sold, would be considered a RCRA Hazardous Waste based on the

characteristic of ignitability. The EPA Hazardous Waste Number is DOOl.

DISPOSAL: Dispose of in accordance with local, state and federal regulations.

Section 14. TRANSPORT iNFORMATION

DOT CLASSIFICATION:

Class/Division: 3 (Note, however, that 49 CFR 1 73.120 (b)(2) of the DOT regulations allows a flammable

liquid with a flash point at or above 38°C (100°F) to be reclassed as a “combustible liquid” for

domestic transportation purposes, if it (1) does not meet the definition of any other hazard class and

(2) is not being transported by vessel or aircraft, unless other means of transportation is

impracticable.)

Proper Shipping Name: Petroleum distillates, n.o.s.

Label: Flammable liquidPacking Group: illID Number: UN 1268

Section 15. REGULATORY INFORMATION

OSHA Hazard Communication Status: Hazardous

TSCA: The ingredients of this product are listed on the Toxic Substances Control Act (TSCA) Chemical

Substances Inventory.

CERCLA reportable quantity of EPA hazardous substances in product:

Chemical Name RQ

No ingredients of this product have CERCLA reportable quantities.

Product RQ: Not applicable (Notify EPA of product spills exceeding this amount.)

SARA TITLE Ill:

Section 302 Extremely Hazardous Substances:

Chemical Name CAS# RQ TPQ

There are no SARA 302 Extremely Hazardous Substances in this product.

MSDS Code: E312 Page 5Issue Date: 08/1 2/97 Continued on Page 6
Section 16. OTHER INFORMATION

HMIS RATINGS: Health = 1 Flammability = 2 Reactivity = 0

Personal Protective Equipment = X (to be specified by user depending on use conditions)

Hazard rating scale: O=Minimal 1 =Slight 2=Moderate 3=Serious 4Severe

MSDS REVISION SUMMARY: Reason for reissue: Update to new format.

lhfle this information and recinendations set forth herein are believed to be accurate as of the date hereof, CALGON CORPORATION MAKES NO WARRANTY WITH RESPECT HERETO AND DISCLAIMS ALL LIABILITY FROM RELIANCE THEREON.

PREPARED BY: J.J. Kowalski

C.

MSDS Code: E312 Page 6

Issue Date: 08/1 2/97 Last Page