DSHW-1993-002471 - 0901a0688013c11e

MEMORANDUM
TO:
FROM:
DATE:
RE:
DSHW TN
1993.11248
Lynn Men I ove
Bob Swart f^^^O
June 23, 1993
Hercules NOI for Remediation of Fluorine Cylinders
Attached is a copy of a modeling protocol submitted by Hercules.
The Environmental Engineer, Chris Falkenberg, initially modeled by excluding E and F
stabilities since he said they would be doing the remediation in daylight hours. However,
in light of the recent information concerning the non-exclusion of stable cases, I informed
him that he would have to remodel using E and F stabilities.
It is already known that such conditions would present an exceedance; therefore, he wants
to know if he can self impose restrictions from stable conditions. I told him he would have
to discuss this with the permitting Engineer. He is expecting a call from the Engineer in the
next day or two.
Chris D. Falkenberg
HERCULES
Bacchus Works
Magna, UT 84044-0098
251-5313
cc: B. LeBaron
f:\aq\plan\robeit.S\wp\herc_fl
Need for Trial Operation
A number of safety concems exist with this project that could best be answered by
venting one of the fluorine cylinders under trial conditions. Such an operation would resolve
questions about cylinder restraint, the remote firing system, and the reaction of the fluorine to
the explosive charge. Hercules proposes to vent one of the fluorine cylinders at our Pit 38
facility on a trial basis. This facility is specifically designed for this type of explosive
operation. An unexpected reaction at Pit 38 would involve just one cylinder in comparison to
the 64 that remain at the Fluorine Transfer Station.
The proposed order of operations would be to 1) vent the trial cylinder at Pit 38, 2)
vent the 10 N2F4 cylinders at the Fluorine Transfer Station, and then 3) vent the remaining 53
fluorine cylinders at the Fluorine Transfer Station.
The attached map shows the location of Pit 38. Access to Pit 38 is by a single road
that can be barricaded during hazardous operation. The fluorine cylinder placed at Pit 38
would be 3,125 feet from the nearest Hercules property line. This is somewhat closer than
the Fluorine Transfer Station which is 4,150 feet from the nearest property line.
SCREEN modeling results for venting a single cylinder at Pit 38 are shown below. For
the modeling, the emissions from a single cyUnder were averaged over an 8 hour period to
determine the mass flow rate input to the model. This value was found to be 0.126
grams/sec. The model predicted acceptable fenceline fluorine concentrations for Stability
Classes A through E.
SCREEN MODEL RESULTS
TRIAL VENT OF A SINGLE FLUORINE CYLINDER AT PIT 38
Stability Class
A
B
0
D
E
Fenceline Boundary Standard
TLV/100
0.016 mg/m^
0.016 mg/m^
0.016 mg/m^
0.016 mg/m^
0.016 mg/m^
SCREEN Prediction
8 Hour Fenceline Concentration
0.0004 mg/m^
0.0004 mg/m^
0.0008 mg/m^
0.002 mg/m^
0.006 mg/m^
It is suggested that the Approval order be modified by adding the following statement:
"For testing and safety purposes, a single fluorine cylinder may be vented at the Plant 1 Pit
38 facility prior to beginning operations at the Fluorine Transfer Station. AU pertinent
Approval Order requirements that apply to the Fluorine Transfer Station also apply to the Pit
38 operation."
Total Amount of Released Gas
Item 6 on the draft Experimental Approval Order limits the total amount of released
gas to 432 pounds. This amount actually refers to the total available amount of fluorine gas.
The total amount of tetrafluorohydrazine gas (12.5 pounds) should be included in this amount.
The final weight of the two gases added together is 432 plus 12.5 or 444.5 pounds. If you
develop any further questions during review of this issue, please contact me at 251-3574 or
Chris Falkenberg of my staff at 251-5313.
Sincerely,
^/^^^^r
E. R. Anderson, Manager
Environmental Engineering
and Hygiene
ERA/CDFalkenberg/
Enclosure