ML20044C112

Forwards Rev 2 to Claiborne Enrichment Ctr Criticality Safety Engineering Rept, & Revised SAR Sections 4.5,11.1, 11.2 & 11.4.Withdraws Request for Exemption from 10CFR70.24(a), Criticality Accident... in

ML20044C112
Person / Time
Site:	Claiborne
Issue date:	03/15/1993
From:	Leroy P LOUISIANA ENERGY SERVICES
To:	Jim Hickey NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
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ML20044C113	List: ML20044C112 ML20044C114
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NUDOCS 9303180045
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March 15,1992 -~ Mr. John W. N. Hickey, Chief Fuel Cycle Safety Branch Division of Industrial and e Medical Nuclear Safety a Office of Nuclear Material Safety. and Safeguards - U.S. Nuclear Regulatory Commission g Washington, D.C. ~ 20555 g-Re: Docket No.: 70-3070 Louisiana Energy Seivices Claiborne Enrichment Center Criticality Safety Engineering Report ) s File: MTS-6046-00-2001.01 j 4 ai

Dear Mr. Hickey:

j Enclosed are three copies of the Claiborne Enrichment Center (CEC) Criticality Safety Engineering Report (CSER), revision 2. This revision incorporates LES' responses to j your requests for additional information (RAI) contained in LA. Roch6's letter to LES g dated December 23,1992. The specific RAI and their responses are provided as j Attachment A to this letter. Also enclosed is an "infonnation only" copy of Safety 1 Analysis Report (SAR) sections 4.5,11.1,11.2 and 11.4 which have also been revised. A ] . formal update to the SAR wiil be made in the near future. f "i 13 Please note that this letter withdraws,in part, LES' request for exemption from the j requirements of 10 CFR 70.24(a), Criticality Accident Requirements, contained in LES' 4 letter to R.M. Bernero dated January 31,1991. The exemption request applies now only 3 to areas of the CEC outside of the Technical Services Area (TSA), which is in the 1 Separations Building. As discussed further in LES' response to question 18 in j Attachment A, LES will comply with the requirements of 10 CFR $70.24(a) for the TSA. j 4 Please also note that as discussed in response to question 8 of Appendix A, the criticality y analysis for the mobile pump carts will be submitted by April 8,1993. ]2 h j I i' 1 '7 r 1 1 a. 9303100045-930315 l' 3 .PDR ADOCK 07003070 7 ~N 2 .1 'l

7 o; - March 15,1993 h . Mr. John W. N. Hickey, Chief Page 2 If there are any questions concerning this, please call me at (704) 373-8466. p Sincerely, fh b k Peter G. LeRoy Licensing Manager i PGUN83.393 Enclosures L (w/ one copy of enclosures) xc: f Mr. Morton B. Marguiles, Esq., Chairman ] Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington,'D.C. 20555 Ms. Diane Curran, Esquire Harmon, Curran, Gallagher, & Spielberg 2001 S Street, NW, Suite 430 Washington, DC 20009-1125 Mr. R. Wascom Office of Air Quality and Radiation Protection Louisiana Department of Environmental Quality PO Box 82135 Baton Rouge,Ixuisiana 70884-2135 . Ms. Nathalie Walker Sierra Club Legal Defense Fund 400 Magazine Street [ Suite 401 New Orleans, IA 70130 L l 'u..

? l Attachment A ' CRITICALI'IY OUESTIONS I In the review of the Safety Analysis Report (SAR) and the Criticality Safety Engineering Report (CSER), we have identified several problems with the safety analysis. The - SAR/CSER should be revised to describe an adequate administrative and technical. nuclear criticality safety program. The problem areas which need revision or supporting l justification are: 1. In Section 11.1.4.1 of the SAR, education and experience qualifications are provided (paragraph 1) for a Projects Individual. The adequacy of these qualifications cannot be assessed because the responsibilities and authority for this l individual were not specified in Section 11.1.2. l If an applicant proposes to make changes in the facility which would require new nuclear safety analyses, the staff requires that a trained individualperform the analysis and that a second trained individual with at least 2 years of experience in j analyses and safety program implementation independently review and approve the analysis. 1 y t

Response

SAR sections 11.1.3.1 I) and 11.1.4.1 I) have been revised to describe the responsibilities and authorities of personnel involved in criticality safety analyses. .f 4 2. In Sections 11.2 and 11.4 of the SAR, the application states that plant procedures will specify limits on control parameters and corrective measures to return a i parameter to its control band, as appropriate. Limits and corrective measures must be specified for all operations. Exceptions, if any, must be explicitly identified in the application. i Hesponse: SAR sections 11.2 and 11.4 have been revised to state that limits, corrective actions, and other facility activities are specifically incorporated into procedures (i.e., not "as appropriate"). j Attachment A l A-1 r f i p

n g I 3. In addition to the operating procedures discussed in Section 11, written procedures must be established and implemented for activities of the nuclear i criticality safety function.

Response

SAR section 11.4.1 n) has been added to state that procedures for criticality safety are prepared and implemented. 4. In Section 4.5 of the SAR, safety factors are provided for reducing critical mass or dimensions for process equipment. Safety factors or practices must be provided also to ensure that specified geometric configurations are maintained. Resnonse: f SAR section 4.5.5.11 Geometric Configurations has been added to ensure specified geometric configurations are maintained. l t 5. In Sections 4.2 and 2.1 of the CSER, the proposed limits for UF. product cylinders,i.e.,2 kg of hydrogen or H/U < 1, do not ensure nuclear criticality safety. In particular, a large array of cylinders, filled with UF moderated such 6 that H/U = 1, would not be subcritical. As shown by your evaluation in the CSER,570 g of hydrogen corresponds to H/U = 0.088. Accord:ngly, for 2000 g of hydrogen, the corresponding H/U is 03. This H/U can be shown to provide a greater margin for nuclear criticality safety.

Response

CSER, Appendix E has been revised to include a copy of BNFL's report " Nuclear Safety of the Storage of 308 Hex Containers on the Capenburst Site." This report demonstrates that the cylinders are criticality safe individually and in array at II/U s 1 or at < 2 kg hydrogen. i Attachment A I A-2

L L 6. In Section 2.1 of the CSER, the feed cylinders have been assumed to contain only natural UF.. However, the feed cylinders can be used for enriched as well as i l L natural UF. Provisions must be established and implemented to ensure that 6 enriched UF is not introduced as feed material. l I 6 o Resnonse: Additional information has been provided in CSER section 2.1 to indicate the provisions by which feed material is ensured to be natural uranium (i.e.,0.7 wi% U-235). l 7. In Section 4.3 of the CSER, criticality safety of the desublimers requires control i room monitoring of instruments measuring pressure and pressure changes. The { monitoring and control system must be calibrated and functionally tested periodically. ?

Response

A statement has been added to CSER section 4.3.2.5 to indicate that the desublimers' monitoring and control system instruments are periodically calibrated and functionally tested. [ l 8. In Section 4.4 of the CSER, the neutron interaction analyses from the chemical traps on mobile pumps and for mobile vacuum pumps must be provided.

Response

i This analyses will be forwarded for inclusion in the CSER by April 8,1993. Attachment A A-3 4 l 8

9. In Section 4.7 of the CSER, criteria for process pipe bends and joints must be provided. E

Response

An analysis has been performed of the process pipe bends and joints. The analysis demonstrates that the criticality safety is ensured for the process pipe bends and joints at the CEC. This analysis is included as Appendix 11 to the CSER. 10. In Section 4.8 of the CSER, the Fomblin oil recovery equipment should be described. A nuclear criticality safety analysis must be provided for the array of equipment in the hood.

Response

CSER section 4.8 has been revised to provide the requested analysis. 11. In Section 4.10 of the CSER, certain waste treatment processes will be undertaken i by a licensed contractor. However,if such processes are to be taken on the CEC . site, the activities must be authorized by the CEC license. The appropriate waste treatment process descriptions and nuclear safety analyses must be provided for such activities.

Response

No activities of the this type will take place on the CEC site. CSER section 4.10 has been revised accortlingly. I k h -i Attachment A A-4 1 t

12. '

In Section 4.11 of the CSER, positive controls to limit the uranium accumulative in the effluent collection tanks has not been demonstrated. If enriched uranium can collect in these tanks, positive controls, e.g., multiple inline monitors or inline - favorable geometry collection and sampling tanks, must be provided.

Response

CSER section 4.11.3 has been revised to provide the requested information. 13. In Section 4.11 of the CSER, the basis for nuclear safety of the effluent pits must be provided. For example, floor leakage into a pit and multiple tank spills into a pit must be evaluated.

Response

CSER section 4.11.2 has been revised to provide the requested information. 14. In Section 4.11 of the CSER, positive controls to limit the unanium accumulation j for each citric acid bath has not been demonstrated. The daily sampling does not provide high assurance that a critical mass accumulation will not occur. Therefore, the limit for each bath must be reduced significantly below a safe mass to allow for the poor quality of controls over the uranium accumulation in the [ baths.

Response

CSER section 4.11.4 has been revised to provide the requested information. p i N Attachment A I A-5 l t i ( i I -i

15. An array analysis for all waste liquid process and collection tanks must be provided.

Response

An analysis has been performed of the waste liquid process and collection tanks. The analysis demonstrates that the criticality safety is ensured for any tank spacing provided:

1) The minimum horizontal cross-sectional area of every tank is greater than 3400 cm*.

2) The maximum U-235 enrichment of uranium stored or pmcessed in each tank is no more than 5 wtE

3) The total uranium content of each tank is no more than 17 kg.

This analysis is i::cluded as Appendix I to the CSER. The design of the waste liquid process and collection tanks meets each of these criteria. 16. In Section 4.12 of the CSER, the potential deposition of uranium in the ductwork prior to the filter system must be controlled by either favorable geometry ducts, frequent inspections, or other safety features. Resnonse: CSER section 4.12 has been revised to provide the requested information. ? 17. A description of processing and waste handling for all areas such as the chemistry area should be provided. The basis for nuclear criticality safety of all areas must be provided in the application.

Response

CSER sections 4.10 and 4.11 have been revised to provide the requested information. Attachment A A-6

+ 18. In Section 6.0 of the CSER, the requested exemption from the criticality . monitoring system requirements of 10 CFR 70.24 has not been justified for the TSA. The lack of positive controls in the waste handling area does not support the request. On the other hand, the combination of process and safety controis-does provide justification for an exemption for the enrichment halls. Resoonse: .As noted in the cover letter,leulslana Energy Services (LES) is withdrawing in part-LES' request for exemption from the requirements of 10 CFR 70.24(a), Criticality Accident Requirements, contained in LES' letter to R.M. Bernero dated January 31, 1991. The exemption request applies now only to areas of the CEC outside of the Technical Services Area (TSA) in the Separations Building. SAR section 4.5 has been revised to reflect this partial exemption. SAR section 4.5.7 now includes a description of 3 the criticality monitoring system that will be installed in the Technical Services Area of [ the Separations Building. i 'i I I i If i i i Attachment A A-7 i l I i i

i I t h p TABLE OF CONTENTS o vc 4.5 NUCLEAR CRITICALITYLSAFETY. 4.5-1) 4.

5.1 INTRODUCTION

4.5-1 4.5.2 CONTROL' METHODS FOR PREVENTION OF. CRITICALITY: 4.5-21' 4.5.3- -SAFETY MARGINS AGAINST CRITICALITY 4 5-3 4.

5.4 DESCRIPTION

OF SAFETY CRITERIA VS FISSILE SYSTEM f-AND COMPONENTS 4 '. 5 - 4 4.5.5 SAFETY MARGINS FOR FISSILE SYSTEMS AND COMPONENTS 4.5-4 4.5.5.1 Centrifuaes and Cascades 4.5-4 4.5.5.2 Product Cylinders 4;5-4 4.5.5.3 Product Desublimers 4.5-6 4.5.5.4 Clean-up Traos in Desublimer Vent Systems and Mobile Vacuum Pump Sets 4.5-7 4.5.5.5 Continaency Dumo Tran - 4. 5 h 4.5.5.6 UF6'Pumos-4.5-8 14.5.5.7 Vacuum Puno' Oil 4.5-8 4.5.5.8 Vacuum Cleaners 4.5-8 4.5.5.9 Separation' Plant Liauid Effluent Tankace A and Other Processinn Eculoment 4.5-8_. A l 4.5.5.10 Solid Wastes 4.5 ! 4.5.5.11 Active Ventilation Systems '4.5-9 ] 14.5.5.12 Geometric Conficurations-4.5-9? - 4.5.6 CRITICALITY EVENT ANALYSIS 4.5-10 4.5.7 NEED FOR CRITICALITY-MONITORS' 4.5-10: i l f0R INFORMATM ONty 1 j 1 i i .i -4.5-1 March 1993: L1 ? L j

j 7 LIST OF TABLES-4.5-1 Safe Values-for Uniform Aqueous Solutions _of 5% Enriched [ UO2F2-l 4.5-2 Safety Criteria for. Building / Systems / Components 4.5-3 Cascade Average U-235 Enrichment vs. Cascade Tails and -Product Terminal Enrichment V i I I fg A 1 i ~i f l l 'f i I v i l i I .l l f I 4.5-11 March 1993 [

p, u_ _ _ ] I-L .4. 5 - NUCLEAR CRITICALITY SAFETY .lu 14.5.1 ~ INTRODUCTION' The CEC facility has been designed and will be constructed and operated.such that a nuclear criticality' event--is prevented. Nuclear criticality safety at the CEC facility-is assured by designing the facility, systems and. components with safety. margins such that safe conditions are maintained under-normal andl abnormal process conditions and any credible-accident such as

i P

flooding. See " Criticality Safety Engineering Report Claiborne y Enrichment Center" (Reference 1). The criteria used for criticality safety include adopting the N double contingency principle as stated in'theLANSI/ANS-8.1-1983) j standard, entitled " Nuclear Criticality Safety In Operations with Fissionable Materials Outside Reactors"L(Reference 2). -The adopted double contingency principle states that " process design. shall incorporate sufficient factors of safety to require _at least two.unlikely, independent, and concurrent changes in' l ~ process conditions before a criticality accident is possible." Using these criteria including the double' contingency principle,- l no low enriched uranium facility has ever had an accidental criticality. The plant will produce no greater thanLfive weight percent enrichment. Arguments to demonstrate the criticality. safety of all relevant systems and processes within the CEC are-j presented in Reference 1. The safety cases are' performed assuming a_U-235 enrichment of 5 wt% and include appropriate margins to safety. n The general criticality safety philosophy is to-prevent I accidental uranium enrichment excesses,. provide geometrical., safety.when practical, provide for moderation controls within the j UF6 processes and impose strict mass. limits onJcontainers of aqueous, solvent based, or acid solutionsLeontaining uranium. 1 Prevention of excessive enrichment'is assured by plant:and i I equipment features. The plant ~is divided 1into six distinctly. separate assay units with no common UF6. piping. UF6 blending (is 4 'done in a physically separate portion of the" plant.- Process-4 piping, individual centrifuges and traps are safe 1by limits- .placed on their diameters.. Product cylinders-and the desublimers.- ~ rely upon uranium enrichment, moderation control and mass' limits' ta) protect'against the possibility of a criticalityLevent.-~Each of the liquid effluent collection tanks which hold. uranium-in-D solution are. mass controlled, as none are. geometrically ~ safe. For further details see_ Reference 1. By: observing the double

i contingency principle throughout'the plant, accriticality accident.is prevented.

Despite this event being! highly unlikely, an evaluation ofsthe' effects of a criticality accident have been analyzed in accordance with NRC Regulatory Guide 3.34-(Reference 3). -The-4.5-1 March'1993 N - l 1 o

a 9011NFORMMl0N DNLY j results show that possible radiation = exposure levels to an --} individual.at the site boundary are substantially.less than thei existing l EPA guidelines'for implementing: emergency evacuation 1 j procedures. Therefore, the CEC is not required to have' emergency procedures.to protect the public from the effects of a' criticality accident. ] Training is provided to individuals who handle nuclear materialt. 1 at the CEC in criticality safety. The training is based upon-the j training program described in ANSI /ANS-8.20-1991, " Nuclear j Criticality Safety Training." The training program is developed J and implemented with input from the criticality safety staff,- training staff, and management. The training focuses.on the j) following: l f a. Analysis of jobs and tasks to determine what a worker must know to perform tasks efficiently. D b. Design and development of learning objectives based.upon the [ analysis of jobs and tasks that reflect the knowledge, skills, and abilities needed by the worker. c. Implementation of revised or temporary operating procedures. f i LES has reviewed the near-criticality incident described in NUREG-1450, " Potential Criticality Accident'at the General l Electric Nuclear Fuel and Component Manufacturing' Facility, MayL 29, 1991." Based upon'the description provided in Section 4 ofl j the NUREG the process at;the Wilmington facility is' unique to j that facility and is not performed at the CEC. In the. CEC, i operational-procedures and process design-limit the' amount.of: uranium, in aqueous solution, which may enter any process tank or. j vessel to less than 1/2.23 of the critical-mass.. 4.5.2 CONTROL METHODS FOR PREVENTION OF CRITICALITY The major controlling parameters.used in the CEC. facility'are ~ d geometry control, moderation control and/or limitations on the' mass as'a function of enrichment. Table 4.5-1 shows the' safe limits where geometry or mass are'used to ensure' safety. .l The values on Table 4.5-1 are chosen to be. critically safe when optimum light water' moderation exists,. reflection:is considered and limited enrichment exists within: isolated or interactive. t units, or arrays of units. Certain' selected units, e.g. the ~! product' cylinders and the product desublicers, are only safe' under conditions.of limited moderation.- In such' units, both-j design.and operating procedures are.used.to assure that these limits are not exceeded.- For further details see Reference 1. l Summarizing Reference 1;!All separation plant components, which. l 4 . handle enriched UF6,.other than the thirty inch containers and j 4.5-2 March'1993 i 1 i l ~

y -.T FOR INFORME0N ONLY -the product and blending system desublimers are. safe by geometry,- Centrifuge. array criticality is precluded by a. probability-t argument with multiple operational procedure barriers'(see. ~ Reference 1 for. details)'.. Product cylinder criticality is precluded'by total moderator or H/U ratio contro11as appropriate' 1 .(see Re.ference 1 for details). Desublimer-criticalitymis j precluded by total moderator control. In the Technical Services. Area (TSA) criticality' safety.for uranium loaded liquids is ensured by limiting the mass of uranium in any single tank to less than or equal to 1/2.23 of the critical-mass. Individual liquid storage bottles'are safe by_ volume. Interaction in storage arrays is allowed for. 4.5.3 SAFE MARGINS AGAINST CRITICALITY -l Process operations require establishment of criticality safety l limits. Such limits must consider contingencies that may-i invalidate conditions basic to their subcritical safety marginsa f These contingencies may require that safety margins be' increased, j 1 The CEC UF6 systems involve mostly gaseous operations. These 1 operations are carried out under reduced atmospheric conditions (vacuum) or at slightly elevated' pressures not exceedingLthree atmospheres. It is highly unlikely that any size changes of J process piping, cylinders, traps, or desublimers.under these j conditions, would lead to a criticality situation because a' volume or. mass limit may be exceeded. .f Within~the CEC Separations Building,'significant accumulations of-i enriched UF6 reside only in the product take-offEstations,_ sampling stations, blending facility or the product vent desublimers. All these, except the desublimers, contain the.UF6 in 30B cylinders. All these significant' accumulations are.within enclosures protecting them from direct assaults of-waterL The CEC design has minimized the possibilityLof accidental moderation by eliminating ~ direct water contact with these' containers of- ~ ' accumulated UF6. In addition, the CEC's stringent procedural controls for enriching the UF6 assure that it does not become i unacceptably hydrogen moderated while in process..The plant s UF6 systems operating procedures contain safeguards against' loss of moderation control. No neutron poisons'are relied upon to' j assure criticality safety. t Plant areas may contain enriched uranium in aqueous solutions, oils and'other wastes or contaminated fluids.- Safety factors-used in simple geometries containing such. materials'are. respectively: ,1 ^ a. ' Volume 1.34 b. Cylinder diameter 1.12 c. Slab thickness 1.18 4.5-3 March:1993 l i i i, ./4

c f0R LNFORHTION OLY d. Mass - no double batching possible 1.34 - double batching possible 2.23 These safety factors are taken from Reference 7. 4.

5.4 DESCRIPTION

OF SAFETY CRITERIA VS FISSILE SYSTEM AND COMPONENTS Each portion of the plant, system, or component that may possibly contain enriched uranium is designed with criticality safety as-an objective. Table 4.5-2, Safety Criteria for Buildings / Systems / Components, relates the safety criteria of Table 4.5-1 used to provide in-depth assurances that a nuclear criticality event is not possible. Where there are significant in-process accumulations of enriched uranium in UF6 or hydrated UO2F2, the plant design includes multiple features to minimize the possibilities for breakdown of the moderation control limits. These features eliminate direct application of water to product cylinders or desublimers while in l process. 4.5.5 SAFETY MARGINS FOR FISSILE SYSTEMS AND COMPONENTS 4.5.5.1 Centrifuaes and Cascades In Table 4.5-2, the allowable diameter (25.4 cm) is given for an infinitely long cylinder which is critically safe by geometry when filled with a uniform aqueous solution of uranium enriched to 5% U-235 at the optimum H/U-235 moderation ratio. The centrifuge diameter is less than 25.4 cm, so that a single centrifuge is therefore critically safe by geometry. Various square arrays of centrifuges have baen analyzed, spaced as installed on the concrete floor mounting element. The keff was calculated to be < 0.75 for an array of nine failed centrifuges. Furthermore, it is not credible that: the centrifuges in such an array would crash simultaneously, the crashes would lead to inleakage of moist air into the crashed centrifuges, all the crashed centrifuges would fill up with UF6 breakdown products and would have an H/U ratio that is near optimum. For further' details see Reference 1, Section 4.1. 4.5.5.2 Product Cylinders Enriched uranium is desublimed in 30B cylinders within the product take-off stations and in the blending facility. Each plant unit contains two sets of five product take-off stations arranged side by side, as shown in Figure 5.2-1. 7Vo sampling autoclaves are similarly arranged along the same row of product take-off stations. The minimum spacing between the UF6 product 4.5-4 March 1993 I

4 g take-off_ station centerlines is 1.5 meters. The spacing between 7 product _ sampling stations is 4.5 meters. These stations are effectively isolated, through solid angle considerations, thus j eliminating any threat of criticality. The product enrichment within a 30B container is limited to five j weight percent by the plant design and operating features. The UF6 content is limited to no more than the 30B cylinder fill limit by the plant design and operating features. The moderation l within the cylinder is controlled by a series of plant operating features. These features include, among others, checks.that the cylinder is clean and empty prior to the commencement of fill. Also, the moderator (H20, HF) entering the cylinder is monitored during the time the cylinder is connected to the plant UF6 systems. i The criticality safety for a close packed array of 30B shipping containers filled with UF6 is well established for defined ranges and limits on UF6 mass, uranium enrichment and moderator. This e is discussed in the four paragraphs below. BNFL calculations demonstrate that criticality cannot occur even d. in large arrays of moderation controlled product cylinders. All cylinders were considered to be completely full of 5% enriched UF6, moderated with a H/U ratio of 1, and lying on a concrete raft. Worst case external reflection / moderation conditions were ^ found by varying the density of the " water" in which thvay,were assumed to lie. A further calculation was performed with one-cylinder above (touching) the array to simulate movement in/out/over the array. In all cases the array proved to be well. subcritical. These calculations form the safety case for 30B cylinders at the CEC. Related safety cases for 30B cylinders are described below for completeness. ] ORNL document K-1686, Part XII (Reference 4) contains a criticality safety analysis of a 30-inch UF6 cylinder..This-analysis using the ANISN code indicates a km of 0.80, 0.825 and' 0.90 for UF6 with enrichments of 4.5 percent, 5.0 percent and 6.6 percent, respectively, when atomic H/U is the normal limit.of 0.088. This analysis also indicates that criticality cannot be achieved until the enrichment is above 10.0 percent. Criticality safety of close packed cylinders was experimentally verified by ORNL for the AEC, the predecessor of DOE and NRC. An array of seven close packed 30B containers filled with 4.5 percent enriched UF6, standing on end was submerged in water. This configuration is the most reactive. The tank tests showed no significant neutron multiplication. Large cylinder array analyses have been made by ORNL (Reference I 4). Such analyses modeled the authorized UF6 contents of.30B-cylinders as 38-inch diameter spheres, each reflected by one inch 4.5-5 March-1993 i '5

^ ~ ~ me e - w,.- .w. s n -- s ~--- -- s, } r 70R IN0RMA71BN ONLY 4 s ~ n y of H20, and eachioccupying'a cell. space of-147.9 cubic'. feet.: ~ .ThisicellLspace corresponds-to the effective volume of a 30B-icylinder? The. analyses assumed moderation of theLUF6 at F H/U-235 = 10. 1The' result of this analysisJindicated that- ~ subcritical spheres-(keff = 0.222) arrangedfin a cubic array require ~840 such spheres to achieve' criticality.~ A1keff of_0.90_- ..is yielded.by 380 spheres in such.an array. Consequently,lthis number of cylinders may then be conservatively placed inia" subcritical, unreflected cubic-array. -Placing'an equivalent s M number of cylinders in a planar array or double stacked array with spacing between rows to accommodate cylinder handling. vehicles would have a substantially smaller keff. Taken together, the BNFL analysis and test results' discussed j. above demonstrate that criticality cannot occur even in large. ~ arrays of moderation controlled product cylinders. For further details see Reference 1. 'y The CEC. facility design has provided for outside storage of cylinders. The product and feed storage area is separated from-the larger tails storage area. Refer to the site plan,-Figure-4.1-1. Product cylinders are placed in a separate part of the product and feed storage area. The product cylinders-are stored in co-planar array, with the individual cylinders placed on) concrete chocks and sited at a cylinder to cylinder spacing of 1 foot. The CEC arrangements for product cylinder. storage are safe from criticality. 4.5.5.3-Product Desublimers Product desublimers are fitted within the UF6 vent systems'which' are connected to the product take off and to the product. blending donor stations. Each product desublimerLhas a 16-inch inside diameter, a length of approximately 18 feet, and a volumefof 43,429 cubic inches (712 liters). Each of the three plant ~ units has three desublimers to service ten product.take-off; stations.. Additionally a single desublimer services the~ Product Blending System. Consequently, there are ten'such desublimers. Their -locations are shown on Figure 5.2-1. The product desublimers are spaced eight ft (2.438 m) center to center. No desubliner is closer than 15 ft (4.57 m).from the - nearest product take off station cylinder centerline-The midpoints of the=desublimers are offset:from the midioint line of the product take off' stations because of their longer length. This offset, shown on Figure 5.2-1,.is approximately five ft-(1.52 m). The product desublimer has an. operational fill limit of 500 kg UF6 although in the interest of giving suitable " gassing back" times the desublimer will ordinarily be operated up to 100 kg-UF6 fill. 4.5-6 March ~1993 a:

1 -_a T" ;Q D il'.J)' 7) R'ij r h"[3Ai pa tj A.pj c' I 5 W p t ' P V 2 5f3 g[ I p4 1 .we G ik wM i[ a geed u L$ u For criticality safety purposes we will consider the maximum theoretical UF6 fill of 3700 kg UF6. The desublimer is not safe by geometry at 5 wt% U-235 enrichment and criticality safety is achieved by moderator control. The total moderator entering the desublimer is controlled, see Reference 1. The criticality safety of an array of product desublimers and their interaction with nearby product take-off stations is shown by inserting the desublimer (keff=0.32) into the standard allowable safe solid angle formula (sr < 9 - (10keff)). Thus, a safe solid angle of up to six steradians is permitted. The solid angle of interaction of the desublimers with each other is 0.566 steradians. The solid angle of interaction between the closest desublimer and its neighboring product take-off station is 0.497 steradians. Using these solid angles a comparison can be made between the above formula limit and the sum for two desublimers and the adjacent product take-off station. This comparison shows the criticality safety of the arrays. For further details see Reference 1, Section 4.3. 4.5.5.4 Clean-un Traps in Desublimer Vent Systems and Mobile Vacuum Pump Sets A number of different types of clean-up trap are installed in the mobile vacuum pump sets and in vent systems downstream of the desublimers. Their location, function and operation are described in Section 6.3. All of these traps have an inside diameter of 25.4 cm or less. Maximum trap height is 91.4 cm. The traps are all safe by geometry at 5 wt% U-235, see Reference 1 for further details. 4.5.5.5 Continaency Dump Trap Each cascade of centrifuges is connected to an independent Contingency Dump System. This system is described in Section 6.3.8. Included in the Contingency Dump System is a contingency dump trap for each cascade. The average enrichment of the UF6 being dumped from a cascade depends on the product and tails enrichments. The range of variations of the cascade average U-235 enrichment is given in Table 4.5-3. Within the ranges of product enrichment up to five weight percent U-235 and tails enrichment up to 0.34 weight percent U-235 the average enrichment of the UF6 being dumped is always less than 1.5 weight percent U-235. The centingency dump trap is a vessel with an inside diameter of 20.5 inches (52 cm). Conservatively taking 1.5 wt% U-235 as the 4.5-7 March 1993

m. 'ha _ f0RINkDMATl0h 4 eb j contingency dump. trap _UF6 enrichment the trapfcan be seen tu um . safe by geometry, see Table 4.5-2.and Appendix'C'of Referenceil.. l-4.5.5.6 UF6-Pumos' The function and operation of the.UF6 pumps are described in-1 Section 6.3. Their. location and spacing are. described-in: s Section 5.2.2. 1 ~ + The pump. total free volumes are in all cases less than 14. liters. 1 The safe spherical volume'for an aqueous solution of enriched' j uranium at 5 wt% U-235 is 26.9 liters, taken-from Table-4.5-1. The interaction solid angle between pumps ~has been-calculated to a be 0.2 or less. The criticality safety of the pumps is therefore-assured. For further discussion see Reference 1. j i 4.5.5.7 Vacuum Pumn Oil t Vacuum pump oils are removed from the pumps in the Technical. l Services Area. 'The drained oil is placed.in individual 4 containers to facilitate analysis. The individual containers are-1 12 liters or less. The individual containers are ' stored ~irt an-array.which establishes a safe geometry for storage.. This safe storage array provides for 12-inch spacing between surfaces of~ l individual storage' locations arranged in;a planar array. Individual storage locations are limited to holding'one.12-liter or less container. Once' analysis has been completed, the oil' contents may be mixed into established larger containers, which. J are not safe-by geometry. This providesLsafe,Jefficient11onger-term storage until the oil is purified for reuse. For further S . details see Reference 1, Section 4.8. l t 4.5.5.8 Vacuum Cleaners J s Vacuum. cleaners may'be.used to collect UO2F2' power from plant.. i . equipment and surfaces.- The vacuum cleaners provided;for such-j activities will be safe by geometry having volumes less;than 2629 liters-and cylindrical diameters'less than 25.4'cm. Safe values - are provided in. Table 4.5-1. 4.5.5.9 Seoaration Plant Licuid Effluent Tankace and Other' Processina Eauipment -[ j Liquid wastes likely'to be contaminated with significant enriched 'l uranium are decontamination fluids and1TSA generated liquids.- All such potentially contaminated. wastes will be: contained in. 1 containers with a volume of 26.9 liters or:less placed;in a safe array, or.placed in non-safe. geometry tanks under procedures controlling total uranium content to less than 1/2.23: critical-- masses. A full ^ description of the tank system is provided in j sections 6.4.14, 6.4.17 and 6.4.19 of the SAR. Further details j d .4.5-8 ' March.1993 -t e_-.

p r m2=m - I y

==% - % _ { of Criticality Control Procedures are,given in Reference 1", Sections 4.11 and 4.13. All the liquid wastes above are processed through the Liquid-Waste Disposal (LWD) System, which is described in detail in SAR Section 6.4.14. The criticality safety case for the LWD System processing equipment is.also based on maintaining less than a safe mass of uranium in each piece of equipment; full details of the criticality analyses are given in Reference 1, Section.4.11. 4.5.5.10 Solid Wastes Solid wastes within several categories are generated during plant operations. Such wastes consist of citric cake and dry powder from the LWD System, pigtails, valves, small and large bore. piping, contaminated paper and re.gs, etc. Such vastes will.be surveyed for contamination and s2gregated accordingly. Contaminated solid wastes are segregated by type and placed in labeled containers, each limited to both a mass of U less than 4.6 kg U and of such dimensions that the overall areal density'of less than 4.6 kg U per square foot is achieved. These criteria-assure that accidental criticality is not possible by keeping each unit subcritical. The criteria also assure that arrays of. subcritical units will not be stacked or placed adjacent to each other in a critical configuration. For further details see Reference 1, Section 4.10. 4.5.5.11 Active Ventilation Systems l There are two ventilation systems installed in the plant which are designed to deal with airborne uranium activity. One, the Gaseous Effluent Vent System, is described in Section:6 3 7 of this Safety Analysis Report. The other, comprising parts of zul area ventilation system which might potentially have to deal with airborne uranium activity in the event of an abnormal release of material within the plant is described in Sections 6.4.1.1 and 6.4.1.2. Reference 1 describes' studies that show the. accumulation rates of uranium in these systems are veryLlow-(< 2 kg U/a) compared to the safe mass of 17 kg U assuming all the l uranium were enriched to 5%. These low accumulation rates coupled with the regular sampling of the filters renders a criticality incident highly unlikely. For further detail see Reference 1, Section 4.12. 4.5.5.12 Geometric Conficurations Geometric configurations stated in the design of storage arrays or other facility equipment (e.g., tanks).are maintained.. Any-changes to geometric configuration are implemented in accordance with the CEC facility modifications program. The CEC facility. modifications program is discussed in SAR Section 11.4.6.. A review of each modification for criticality safety impact is 4.5-9 . March 1993 k

' f specifically required. 1 ( -4.5.6 CRITICALITY EVENT ANALYSIS Although such an event will be prevented as described previously,. regulations require that a hypothetical consequence analysis be performed. Guidance for criticality event analysis'is given in the Commission's Regulatory Guide 3.34 (Reference 3).

However, an equation found on page 3.35-7 of Regulatory Guide 3.35 (Reference 5) was substituted to account for the elevated release and subsequent dispersion of radioactive material (fission products and uranium) being transported to and beyond the site-boundary.

The results of the criticality accident analysis are compared to the Environmental Protection Agency Protective Action Guides contained in the Manual of Protective Actions for Nuclear Incidents (Reference 6) and the values of 10 CFR 70.22 (i) (1) (i). The whole body prompt neutron and gamma dose to an individual located at 410 meters (near the site boundary) is calculated to be less than 0.0532 rem when the event assumes 1.0E18 fissions in the first pulse and three subsequent 1.9E17 pulses within 30 minutes of the event. The same individual would potentially inhale airborne radioactivity which could lead to a lung and thyroid dose of 0.13 mrem from radioactive iodine. Inhaled'or ingested uranium and other nuclides may lead to an internal dose of less than one mrem committed effective dose to the bone and other skeletal portions of the body. In conclusion, the impact of a criticality event upon members of the public at or beyond the site boundary is minimal. The results indicate that radiation doses to members of the public are so low that emergency plans for their protection are.not required for criticality purposes for the CEC Facility. 4.5.7 NEED FOR CRITICALITY MONITORS LES' letter submitting its license application to the NRC dated January 31, 1991, included a request for exemption from the requirements of 10 CFR S 70.24(a) in accordance with 10 CFR S 70.24 (d). The information contained in Section 4.5 and Reference 1 demonstrate that a criticality accident at the CEC is highly unlikely. However, based upon NRC's question 18 in their letter to LES dated December 23, 1992, the CEC Technical Services Area will include a criticality monitoring system in the Technical Services Area (TSA of the Separations Building. The criticality monitoring system will meet the requirements of 10 CFR S

70. 24 (a).

The reminder of the CEC does not require a criticality monitoring system. The criticality monitoring system in the TSA is designed, installed and maintained in accordance with Regulatory Guide 8.12, " Criticality Accident Alarm Systems," Revision 2, October 1988. This guide endorses ANSI /ANS 8.3-1986, " Criticality 4.5-10 March 1993

fi-

FOR INFORMAT!DN DNI.Y; Accident ' Alarm System. 'The following' exceptions to NRC's i

f endorsement of-ANSI /ANS 8.3-1986 areLnoted-by LES and are incorporated into the design, installation and operation of the CEC criticality monitoring system: a) Any facility areas where it has been determined that a . potential for criticality does not exist, and no criticality L monitoring is necessary must be granted by the NRC in 1 accordance with 10 CFR S 70.24. Note that LES has requested i an exemption from the requirements of 10 CFR S 70.24 (a) for facility areas outside the TSA (reference LES to NRC letters. I dated January 31, 1991 and March 15, 1993). b) All areas required to be covered by criticality detectors 1; are covered by two detectors. i f i i l i 4.5-11 March 1993- -i I 1

.I 'l l {! ) (T L 1 REFERENCES FOR SECTION 4.5 1. Louisiana Energy Services " Criticality Safety-Engineering Report," Revision 2, March 15, 1993. '2. ANSI /ANS 8.1-1983, " Nuclear Criticality' Safety in Operations With Fissionable Materials Outside Reactors." 3. NRC Regulatory Guide 3.34, Rev.1, " Assumptions Used for Evaluating the Potential Radiological Consequences of Accidental Nuclear Criticality in a Uranium Fuel Fabrication-Plant", June 1992. 4. Mallett, A.J. and Newlon C.E., " Protective Shipping Packages for 30-inch Diameter UF6 Cylinders", K-1686, Union Carbide Corporation Nuclear Division, Oak Ridge Gaseous Diffusion Plant, Oak Ridge, Tennessee, 1967. 5. NRC Regulatory Guide 3.35, Rev.1, " Assumptions Used for Evaluating the Potential Radiological Consequences of Accidental Nuclear Criticality in a Plutonium Processing and Fuel Fabrication Plant." July 1979. 6. " Manual of Protective Actions for Nuclear Incidents", EPA 520/1-75 '01-A, January 1990. 7. Appendix B of Regulatory Guide 3.52, Revision 1, November 1986, Standard Format and Content for the Health and Safety Section of License Renewal Applications for Uranium Processing and Fuel Fabrication. 8. Critical Dimensions of Systems Containing 235-U, 239-Pu, and 233-U, 1986, LA-10860-MS, Los Alamos National Laboratory. 9.

Thomas, J.T.,

" Nuclear Safety Guide," TID 7016, Revision 2, June 1978. 4 t 4.5-12 March 1993 i

t $Y bi TABLE 4.5-1 Safe values for Uniform Aqueous Solutions of 5% Enriched UO2F2 critical.Value Safety Factor -Safe Value-Parameter (From Reference 8) (From Reference 7) Volume 36.1 1 1.34 26.9 1 Cylinder Diameter 28.5 cm 1.12 25.4 cm Slab Thickness 14.2 cm 1.18 12.0 cm i Mass 38.0 kg U - no double 1.34 28.3 kg U batching possible - double batching 2.23 17.0 kg U p p saible 9 - 10 keff Solid Angle (for keff < 0.8) (From Reference 9) It i i -i i h I r I t I June 1992 t i

y ~...c ,g n_. ~ O.l ]; { (- y TABLE 4.5-2 q Safety. Criteria for Buildings / Systems / Components

g

-) .I. ' Building / System /componentL safety'criteriai Enrichment (< 5% U-235) Administrative Control Centrifuges Single Centrifuge Diameter s 25.4 cm Crashed Centrifuge Array .f Administrative Control 'l r Product Cylinders (30B) Moderation Control .l H/U s 1 or H <2 kg 6 i UF6 Piping Diameter .'< 25.4 cm -{ Chemical Traps Diameter < 25.4 cm i Product Desublimers Moderation Control H < 2.4 kg Tanks Mass < 17.O'kg U i Ventilation Filter Pack Administrative Control- .I Feed Cylinders Enrichment < 0.72 wt% U-235 Tails cylinders Enrichment < 0.72 wtt U-235 Contingency Dump Trap Diameter < 60.3 cm*- Enrichment < l.5 wtt U-235 UF6 Pumps Volume < 26.9 1 'h Solid Angle 9-10 keff f I Individual Uranic Liquid volume < 26.9 1 l Containers, e.g., Fomblin Oil Bottle, Laboratory Flask, Hop Bucket I vacuum Cleaners Volume <26.9 1. Oil Containers - 1 Derived frora Reference 8 (Figure 24) and Reference 7.. I l l March 1993 1 s

4 T..- s 1 lj j f TABLE 4.5-3 j t Cascade Average.U-235-Enrichment val. Cascade Tails and Product Terminal Enrichment 'l ' l Cascade Terminal Concentrations' . Average Cascade' I Concentration ~ ~ ~ ~ ~ ~ ~ ~ 'h Product (wt%) Tails!(wt%)' (wt%) . i '6

0. 3, 1.0 f

2 0.2 0.6 i 6 0.45 1.2 l 2 0.3 -0.8 I 1 i

I, i

I i i I i I i l i June 1992 1 l

.y-;

y f

, 1 FOR INFORMfil0N ON?l TABLE OF: CONTENTS- -I H .q /11.1 ORGANIZATIONAL STRUCTURE N.1-1 l '11.1.1 CORPORATE FINANCIAL RESPONSIBILITIES. '11.1-1 .l 5 11.1.2 CORPORATE FUNCTIONS, RESPONSIBILITIES, AND. AUTHORITIES 211.1d '11.1.3 OPERATING ORGANIZATION ' 11.1-2 '- ,j 11.1.3.1 -CEC Organization 11.1-2 11.1.3.2 Shift-Crew Composition 11.1-7 11.1.3.3 Facility Safety Review Board'(FSRC) and' R.adiation Safety Committee (RSC) 11.1-7' 0; =1 11.1.3.4 Approval Authority For' Personnel Selection 11.1-9:' 11.1.4 PERSONNEL QUALIFICATIONS REQUIREMENTS

11 L 1-9 f

0 11.1.4.1 Minimum Oualifications 11.1-9: 11.1.4.2 Facility Personnel Oualifications. 11.1-15 l ,j 11.1.5 TRAINING 11.1-15 1 I

- r

i i

i .t v i ? -.f .P i I -i i t .I; j 11.1-i March 1993 I I a O.. -

F s m I [- F':- LIST OF TABLES --~ = 1 11,1-1 Louisiana Energy Services. Organization-11.1-2 Louisiana Energy Services Construction and Operating' Organization f '11 1-3 Louisiana. Energy Services Claiborne Enrichment Center l ~ Operating Organization' h .i i 7 .t -j. i ? i a ? 't 11.1-ii January 1992- .: q i a e

i j 11.1 ORGANIZATIONAL STRUCTURE 1 11.1.1 CORPORATE FINANCIAL RESPONSIBILITIES 'LES is a limited partnership. It has been formed to provide uranium enrichment services for commercial nuclear power plants. The partnership is outlined in detail in Section-1.1.6. LES is responsible for the design, quality assurance, construction and operation of the facility. The President of LES reports to the LES Management Committee. This Committee is composed of representatives from the four general partners of LES - Urenco Investments, Inc., Claiborne Fuels L.P., Graystone Corporation, and Claiborne Energy Services, Inc. Table 11.1-1 outlines this relationship. i t 11.1.2 CORPORATE FUNCTIONS, RESPONSIBILITIES, AND AUTHORITIES l LES is responsible for the design, quality assurance, construction, testing, start-up and operation of the CEC. LES has contracted Urenco to prepare the reference design for the facility, while Fluor Daniel, Inc. and Duke Engineering &. l Services, Inc. are contracted to further specify structures and systems of the facility, including responsibility for specifying t the materials and equip.nent. Preparation of construction documents and construction itself are. f contracted to qualified contractors. LES has direct j responsibility for preoperational testing, initial start-up, operation and maintenance of the facility. t Urenco will design, manufacture and. deliver to the site the centrifuges necessary for facility operation. In addition, Urenco is supplying technical assistance and consultation for the + facility. Urenco has a great deal of experience in the gas centrifuge uranium enrichment process since it operates three gas-centrifuge uranium enrichment sites in Europe. Urenco is conducting technical audits of the design activities of Duke Engineering & Services and Fluor Daniel to ensure the design of the claiborne Enrichment Center is in accordance with the Urenco i reference design information. I As the facility nears completion, LES will staff'the facility to' l ensure smooth transition from construction activities to operation activities. Urenco, who has been operating gas centrifuge enrichment facilities in Europe for over 16 years, has personnel who are integrated into the organization to provide technical support during initial startup of the facility. 11.1-1 January 1992 k i P

f- $hhh @ 111.1.3 OPERATING ORGANIZATION ~ J-The operating' organization for LES is shown in Tables 11.1-2_and-t I 11.1-3. The positions shown are. functional and may not. correspond to actual-titles. The CEC is staffed at sufficient levels prior to operation to allow for training, procedure 5 development, and other pre-operational activities. 11.1.3.1 CEC Orcanization 3 i The functions and responsibilities of the facility supervisory-l staff are described in the succeeding paragraphs. a) CEC Manager The CEC Manager reports to the LES President and has direct' + responsibility for operation of the facility in a safe,; reliable and efficient manner. The CEC Manager is responsible for the-

l t

protection of the facility staff and the. general public from-radiation and chemical exposure and/or any~other consequencessoft an accident at the facility and also bears the responsibility for l1 compliance with the facility license. .The CEC Manager or designee (s) have the authority to approve and issue Department l' J Directives and procedures. b) Quality Assurance Manager ? The Quality Assurance.(QA) Manager reports to the CEC Manager and is responsible for implementing the Quality Assurance Program for the facility. ThisLincludes responsibility _for ensuring all-activities at the facility affecting quality are performed'in-accordance with appropriate regulations, codes and standards. This position is independent from other management positions at the facility to ensure the QA. Manager has-access to the CEC Manager for matters affecting quality. In addition, the QA Manager has the authority.and responsibility to. contact.directly-the QA Director and/or LES President with any Quality Assurance I concerns. c) Operations Superintendent The Operations Superintendent reports to the CEC ManagerL and: hasi the responsibility of directing the day-to-day. operation oftthef facility. This includes such activities as ensuring.theLcorrect and safe operation of the handling of-UF6, and the periodicz testing..of equipmentfto ensure safe and efficient. operation. In: the event of'the absence of the CEC Manastr,_thel Operations: i . Superintendent may assume the responsibilities : and authorities: of the CEC Manager. t N 1121-2 January =1992 q J .m Y y Y f

f0ilIUDHATIONadny d) Integrated Scheduling superineanaant The Integrated Scheduling (IS) Superintendent reports to the CEC Manager and-has the; responsibility of directing the scheduling of enrichment operations to ensure' smooth production at the -l-facility. This includes such activities as ensuring. proper feed -i material and maintenance equipment is available for the facility. The IS Superintendent is also responsible for providing administrative and human resource services to the facility. In the event of the absence of the CEC Manager, the'IS Superintendent may assume the responsibilities and authorities of the CEC Manager. e) Maintenance Superintendent The Maintenance Superintendent reports to the CEC Manager and has the responsibility of directing and scheduling maintenance l activities to ensure proper operation of the facility. This includes such activities such as repair and preventive maintenance of facility equipment. In the event of the absence of the CEC Manager, the Maintenance Superintendent nay assume the responsibilities and authorities of the CEC Manager. f) Compliance Superintendent The Compliance Superintendent reports to the CEC Manager and'has the responsibility of directing the activities _that ensure the facility maintains compliance with appropriate regulations and conformance with applicable codes. This includes activities associated with physical security, classified matter and information, licensing, emergency preparedness, safeguarding of special nuclear material and compliance with environmental regulations. In the event of the absence of the CEC Manager, the Compliance Superintendent may assume the responsibilities and authorities of the CEC Manager. g) Technical Support Superintendent The Technical Support (TS) Superintendent reports to the CEC Manager and has the responsibility of providing technical support to the facility. This includes activities associated with health physics, chemistry, industrial safety and engineering including criticality safety reviews, _and computer support. In the event of the absence of the CEC Manager, the Technical Support Superintendent may assume the responsibilities and authorities of the CEC Manager. i h) Security Manager The Security Manager reports to the Compliance Superintendent and has the responsibility for directing the activities of security personnel to ensure the physical protection of the facility. 7he 11.1-3 January 1992

k Security Manager is also responsible-for the protection of classified matter and information at the facility and obtaining proper security clearances for facility personnel and support personnel. In matters involving physical protection of the facility or' classified matter, the Security Manager has direct access to the CEC Manager. i) Safeguards Manager The Safeguards Manager reports to the Compliance Superintendent. and has the responsibility for ensuring the proper implementation of the Fundamental Nuclear Material Control (FNMC) Plan. This' position is separate from and independent'of the' operations, maintenance, and technical support departments,to ensure a: definite division between the safeguards group and the other i departments. In matters involving safeguards, the Safeguards i Manager has direct access to the CEC Manager. ] -t j) Emergency Preparedness Manager The Emergency Preparedness Manager reports to the Compliance Superintendent and has the responsibility for ensuring the facility remains prepared to react and respond to any emergency l situation that may arise. This includes emergency preparedness 't -training of facility personnel, facility support personnel, the training of, and coordination with, offsite emergency response organizations, and conducting periodic drills to ensure facility personnel and offsite response organization personnel training is maintained up to date. k) Health Physics Manager s The Health Physics Manager reports to the Technical Support Superintendent and has the responsibility for implementing the - health physics program. These duties include the-training of personnel.in use of equipment, control of radiation exposure of personnel, continuous determination of the radiological status of the facility, and conducting the radiological-environmental monitoring program. In matters involving radiological protection,-the Health Physics Manager has direct access to the CEC Manager. l 1) Projects Manager _l 1 1 The Projects Manager reports to the Technical' Support Superintendent and has the responsibility for the implementation of facility modifications and the approval of facility procedures-l-and modifications for criticality safety. The Projects Manager i also provides engineering support as needed to support _ facility operation and maintenance. This support includes performance 1 testing of systems'and equipment. -.j h 11.1-4 March 1993 d .i l I i w+

1 m) Chemistry Manager-g The_ Chemistry Manager reports to the Technical Support Superintendent and has the responsibility for maintaining chemical labs and other chemical support facilities for the CEC. This includes the analysis of environmental samples for chemical characteristics (e.g., temperature, pH). n) Industrial Safety Manager I The Industrial Safety Manager reports to the Technical Support Superintendent and has the responsibility for maintaining the-facility's fire protection systems and other systems that allow for the safe operation of the facility in accordance with Occupational Safety and Health requirements, o) Performance Manager The Performance Manager reports to the Technical Support Superintendent and has the responsibility for coordinating and maintaining testing programs for the facility. This includes testing of systems and components to ensure the systems and components are functioning as specified in design documents. p) Licensing Manager The Licensing Manager reports to the Compliance Superintendent and has the responsibility for coordinating facility-activities to-ensure compliance is maintained with applicable Nuclear Regulatory Commission (NRC) requirements. The Licensing Manager. is also responsible for ensuring abnormal events are reported to the NRC in accordance with NRC regulations. q) Environmental Compliance Manager The Environmental Compliance Manager reports to the Compliance Superintendent and has the responsibility for coordinating facility activities to ensure all local, state and federal environmental regulations are met. This includes submission of periodic reports to appropriate regulating organizations of H effluents from the CEC. r) Community Relations The Community Relations Manager reports to the Compliance -Superintendent and has the responsibility for providing information about the CEC and LES to the public and media. During an abnormal event at the facility, the Community Relations Manager ensures that the public and media receive accurate and up-to-date information. r 11.1-5 January 1992 [ [ T

V ~ ~ rgpsIg!Mailogg;g ~~ s) Maintenance Engineering Manager The Maintenance Engineering Manager reports to the Maintenance Superintendent and has the responsibility for providing maintenance support for equipment and systems at the CEC. This includes preventive maintenance for appropriate equipment to ensure systems and equipment at the facility operate safely and as designed. t) Maintenance Technicians Manager The Maintenance Technicians Manager reports to the Maintenance Superinten ent and has the responsibility for providing r maintenance support for equipment and systems at the CEC. This includes periodic inspection and adjustment of equipment and systems at the CEC to ensure systems and equipment at the facility operate safely and as designed. u) Production Scheduling Manager The Production Scheduling Manager reports to the Integrated Scheduling Superintendent and has the responsibility for developing and maintaining production schedules for enrichment services. v) Cylinder Handling Manager The Cylinder Handling Manager reports to the Integrated Scheduling Superintendent and has the responsibility for ensuring that cylinders of uranium hexafluoride are received and dispatched correctly at the CEC. w) Warehouse and Materials Manager The Warehouse and Materials Manager reports to the Integrated Scheduling Superintendent and has.the responsibility for ensuring spare parts and other materials needed for operation of the CEC are ordered, received, inspected and stored properly. x) Administration Manager The Administration Manager reports to the Integrated Scheduling Superintendent and has the responsibility for ensuring support functions such as accounting, word processing and document control are provided for the CEC. y) Human Resource Manager The Human Resource Manager. reports to the Integrated Scheduling Superintendent and has the responsibility for ensuring adequate' staffing and training is provided for CEC employees. 11.1-6 January 1992

' F i fy ) Operations Engineering Manager bd ~~~_) The Operations Engineering Manager reports to the Operations i I Superintendent and has the rerponsibility for ensuring safe operation of enrichment equipment and support equipment. -This includes the development of operating procedures for the CEC. aa) Operations Shift Technicians Manager The Operations Shift Technicians Manager reports to the. [ Operations Superintendent and has the responsibility for ensuring safe operation of enrichment equipment and support equipment. The Operations Shift Technicians Manager directs' personnel in order to provide enrichment services in a safe, efficient manner. j ab) Quality Assurance Inspectors Supervisor l The Quality Assurance Inspectors Supervisor reports to'the Quality Assurance Manager and has the responsibility for performing inspections related to the implementation of the LES Quality Assurance Plan, ac) Quality Assurance Auditors Supervisor The Quality Assurance Auditors Supervisor reports to the Quality Assurance Manager and has the responsibility for performing audits related to the implementation of the LES Quality Assurance Plan. ad) Quality Assurance Technical Support Supervisor The Quality Assurance Technical Support Supervisor reports to the Quality Assurance Manager and has the responsibility for providing technical support related to the implementation of the LES Quality Assurance Plan. 11.1.3.2 Shift Crew Composition The minimum operating shift crew consists of a Shift Supervisor, one control room operator, one Health Physics' technician, and one operator for each of the plant units. i 11.1.3 3 Facility Safety Review Committee (FSRC) and Radiation Safety Committee (RSC) The CEC facility maintains a Facility Safety Review Committee f' (FSRC) and Radiation Safety Committee (RSC) to assist with the safe operation of the facility. [i P r 11.1-7 January 1992 r

T-1 A k N - 11.1.3.3.l' Facility SafetyYiTi~eWTummittee-4ESRM d The functions of the Facility Safety Review Committee shall include responsibility for the following: a) An annual facility audit which considers the following: f Programs and projects undertaken by Health Physics and'the Radiation Safety Committee. Performance including, but not limited to, trends in airborne concentrations of radioactivity, personnel exposures and environmental monitoring results. Programs for improving the effectiveness of equipment used for effluent and exposure control. b) Review of proposed changes in authorized facility activities-which may affect nuclear or non-nuclear safety practices. c) Professional advice and counsel on criticality, radiation' and industrial safety issues affecting the nuclear-activities. l The committee shall consist of at least six members of'the CEC technical staff who are appointed by the CEC Manager. 'Other-members of management may also serve on the committee upon the-request of the CEC Manager. The committee is responsible to the CEC Manager.. Committee -i proceedings, findings'and recommendations shall be reported in writing to the CEC Manager and to the superintendents responsible for the areas of facility operations which were. reviewed by the committee. Such reports shall be retained for at least two-years. The committee shall hold at least three meetings each calendar year with a maximum interval of 180 days-between any two consecutive meetings. 11.1.3.3.2 Radiation Safety Committee-l The objectives of the Radiation Safety Committee are tofmeintain and improve the high standard of facility operations, to. maintain - occupational radiation exposures as low as reasonably achievable and to reduce the potential for other health and safety hazards. The committee meets-regularly:to maintain a continual' awareness. of the status of projects, performance measurementLand trends,- I and the current radiation safety conditions of enrichment operations. The maximum intervals between meetings:shall not. exceed 60 days. j l 11.1-8 January 1992 I

JOR INFOR\\iUl0N DNLY 1 4 A written report of.each Radiation Safety Committee meeting shall l be forwarded to all superintendents within 15 working days-ofrthe j meeting.. Records.of the committee proceedings'shall be. maintained for two years. i The committee shall consist of managers or representatives'from J 1 quality assurance, operations, integrated scheduling, maintenance, compliance and technical support. 11.1.3.4 Approval' Authority For Personnel' Selection-I The assignment of individuals to the position of' Superintendent I and manager shall be approved by the CEC Manager. s Assignments to all other staff positions-shall be made-within the. normal administrative practices of the CEC. 3 1 11.1.4 PERSONNEL QUALIFICATIONS REQUIREMENTS 11.1.4.1 Minirrem Oualifications The minimum qualification requirements for the facility positions that are directly responsible for its safe operation are outlined i below. The experience of each individual is determined [ acceptable by the President of LES. Different experience 'j requirements may be approved by the LES President. Substitution. of additional experience by academic training may be made only with prior NRC approval. This is done in writing and onlyfon a-case by case basis. l 1 a) CEC Manager t The CEC Manager shall hold a BS degree in an engineering-or l scientific field.and have a minimum of ten years of appropriate,- 1 responsible nuclear experience. A maximum of four years of the-j ten years may be fulfilled by academic training on a.one-for-one time basis. To be acceptable this academic training shall be.in-i engineering or scientific fields-unless specifically; approved by- -l the President of LES. -j b) Quality Assurance Manager j i The Quality-Assurance (QA) Manager.shall have a minimum-of eight U years of appropriate, responsible nuclear experience in the

f implementation of a quality assurance program.

A maximum of four l

years of the eight years may be fulfilled by academic training:on a.one-for-one time basis.

To be acceptable this ' academic tr'aining shall be in engineering or scientific fields, unless-specifically approved by the President of LES. t I i J 11.1-9 July 1992 j fi j

En ~ ~ y- .i FOR INFORMAIl0N MLY - ~.%e.. _ y c) _ Operations Superintendent The Operations Superintendent shall hold a BS degree in-an engineering or scientific field and-have a minimum of eight years of appropriate, responsible nuclear experience. A maximum of-four.. years of the eight years may be fulfilled by_ academic -training on a one-for-one time basis. To be~ acceptable this I academic' training shall be in engineering 'r scientific.fieldsi o unless specifically approved by the President of LES. i d) Integrated Scheduling Superintendent a t The Integrated' Scheduling (IS) Superintendent shall have a I i minimum of eight years of appropriate, responsible nuclear experience. A maximum of four years of the eight years may bel fulfilled by academic training on a me-for-one' time basis. To1 be acceptable this academic training shall be in. engineering or scientific fields, unless specifically approved by the President of LES. e) Maintenance Superintendent The Maintenance Superintendent shall hold a BS degree in an engineering-or scientific field and have a minimum.of eight' years of appropriate, responsible nuclear experience. A' maximum of four years of the eight years may be fulfilled by academic training on a one-for-one time basis. To be acceptable this academic training shall be in engineering or scientific--fields,- unless specifically approved by the President of LES. f) Compliance Superintendent The Compliance Superintendent shall hold a BS degree in an-J ~ engineering or scientific field and have a minimum of'eight-years of appropriate, responsible nuclear experience. LA maximum of' four years of the eight years may be fulfilled by academic training on a one-for-one time basis. To be acceptable:this. academic training shall be in engineering-or scientific fields ~, unless specifically approved by the President of LES. g) Technical Support Superintendent The Technical Support (TS) Superintendent shall hold'a BS degree-a in an engineering.or_ scientific field and havea-minimum of eight years of appropriate, responsible nuclear: experience. A maximum of four years of.the-eight years may be; fulfilled by academic l training on a one-for-one time basis. To be acceptable this academic training shall be'in engineering or'- scientific fields, unless-specifically-approved by the President _of LES. 11.1-10 July 1992-l t

FOR IN/0RUTJ01 DNlf h) Security Manager j 1 The Security Manager shall have a minimum of fiveJyears of I . experience in the-management of security at similar facilities. i) Safeguards Manager The Safeguards Manager shall have a minimum.of-five years of experience in the management of a safeguards program for'special nuclear material. j j) Emergency Preparedness Manager [ The Emergency Preparedness Manager shall have a minimum of five j ' years of experience in the implementation of. emergency plans'and procedures at a nuclear facility. k) Health Physics Manager The Health Physics Manager shall have a minimum-of five years of appropriate, responsible experience in the implementation of a health physics program at a nuclear facility. A maximum of two years of the five years may be. fulfilled by academic training on a one-for-one time basis. To be acceptable this~ academic. training shall be in engineering or scientific fields, unl'ess specifically approved by the President of LES. 1) Projects Manager The Projects Manager shall hold a BS degree in an engineering or scientific field and have a minimum of five years of appropriate, l: responsible nuclear experience. A maximum of two years of the-five years may be fulfilled by academic training on a.one-for-one-time basis. To be acceptable this academic training shall be.in. engineering or scientific fields, unless specifically: approved by- .{ the President of LES. The Projects Manager shallLalso havelat i least one year of direct experience-in the administration of-- ri criticality safety reviews. Within the Projects group shall be at least one individual with a 1 - minimum of two years experience'in the implementation of:a criticality safety program. This individual shall hold a BS -degree in an engineering or scientific field. Should changes to the facility be proposed.which require new - nuclear criticality safety analyses, trained' individuals:shall 'I perform'the analyses. Trained individuals with at'least two j ' years of. experience in analyses and criticality safety program implementation shall independently review and approve;the ,( analyses. 4 d 11.1-11 March 1993 .l 1 t g e. e--,- .e a

n. r FOR ERMATl!M my m) Chemistry Manager ~ ~ ~ - i The Chemistry Manager shall have a minimum of five. years of. appropriate, responsible nuclear experience. A maximum of two' years.of the five years may be fulfilled by academic training'on a one-for-one time basis. To be acceptable this academic . training shall beLin engineering or scientific fields, unless specifically approved by the President of LES. 'j n) Industrial Safety Manager i The Industrial Safety Manager shall have a minimum'of five years of. appropriate, responsible experience in implementing and supervising an industrial safety program, including fire 9 protection. A maximum of two years of the five years may bel fulfilled by academic training on a one-for-one time basis. To I be acceptable this academic training shall-be in industrial safety fields, unless specifically approved by the President of LES. q o) Performance Manager The Performance Manager shall have a minimum of five years of appropriate, responsible experience in implementing and. supervising a nuclear performance program. A maximum of two years of the five years may be fulfilled by academic training on a one-for-one time basis.. To be acceptable this academic training shall be in engineering or scientific fields, unless. specifically approved by the President of LES. p) Licensing Manager The Licensing Manager shall have a minimum of five years.of appropriate, responsible experience'in implementing and' supervising a nuclear licensing program. A maximum of two years of the five. years may be fulfilled by academic training on a one-. for-one time basis. To be acceptable this'achdemic training j shall be in engineering or scientific fields, unless specifically approved by the President of LES. q) Environmental Compliance Manager The Environmental Compliance Manager shall have a minimum of fivel ~ . years of appropriate, responsible experience in implementing and supervising a nuclear environmental compliance program. .A maximum of two years of the five years may be fulfilled by academic training on'a one-for-one time basis. To be' acceptable. a this academic-training shallLbe in engineering lor scientific . fields, unless specifically approved by the President of LES. I 11.1-12 March 1993 l i

FOR IN!0RWl0Nog ~*~ r)~ Community Relations Manager. The Community Relations. Manager shall have-a minimum-of three-

years of appropriate, responsible experience in implementing _and-supervising;a community relations program.

s) Maintenance. Engineering Manager [ Thel Maintenance Engineering Manager shall have a minimum.of five years of appropriate, responsible. experience in implementing 1and j supervising a.. nuclear maintenance' program. 4A maximum of two-years of.the five years may be fulfilled by academic ~ training on a one-for-one time basis.- To be acceptable,this; academic: training shall-be in engineering or scientific ~ fields, unless specifically approved by the President ofELES, t) . Maintenance Technicians. Manager '[ The-Maintenance Technicians Manager shall have a minimum of five s I years-of appropriate, responsible experience in implementing:and-supervising a nuclear maintenance program. A maximum of two' . years of the five years may be. fulfilled by academic training-on y a one-for-one time basis. To be acceptable this' academic training shall be in engineering or scientific fields, unless specifically approved by the1 President of LES. ]!'i u) Production-Scheduling Manager j The Production Scheduling Manager shall'have a minimum of three years of appropriate, responsible experience in implementing'and j supervising a continuous production scheduling program. j i v) Cylinder Handling Manager j The Cylinder Handling Manager shall have a minimum of three years l of appropriate, responsible experience in implementing'and' l supervising a continuous' production scheduling' program.- - i w)- Warehouse and Materials Manager 1 The Warehouse and Materials Manager shall have a minimum of three years of appropriate,-responsible experience in~ implementing'and-supervising a purchasing and inventory program. -j x). Administration Manager I The Administrative Manager shall have a minimum-ofLthree years-of? l appropriate, responsible experience in implementing'and; supervising administrative responsibilities at an industrial ~! facility. l i i 11.1-13 March 1993f j i 'f . a-1.-

y k 3 y) Human Resource Manager J The Human Resource Manager shall have a minimum of three years of appropriate, responsible experience in implementing and-l supervising human resource responsibilities at an industrial i facility. ~ z) Operations Engineering Manager l The Operations Engineering Manager shall have a minimum of five years of appropriate, responsible experience in implementing and-supervising a nuclear operations program. A maximum of two years of the five years nay be fulfilled by academic training on a one-for-one time basis. To be acceptable'this academic training shall be in engineering or scientific fields, unless specifically approved by the President of LES. aa) Operations Shift Technicians Manager The Operations Shift Technicians Manager shall have a minimum of five years of appropriate, responsible 5xperience in implementing and supervising a nuclear operations program. A maximum of two years of the five years may be fulfilled by academic training-on a one-for-one time basis. To be acceptable this academic training shall be in engineering or scientific fields, unless-specifically approved by the President of LES. i ab) Quality Assurance Inspectors Supervisor The Quality Assurance Inspectors Supervisor shall have a minimum-of five years of appropriate, responsible experience in implementing and supervising a nuclear Quality Assurance program. A maximum of two years of the five years may be fulfilled by academic training on a one-for-one time basis. To be acceptable this academic training shall be in engineering or scientific fields, unless specifically approved by the President of LES. ac) Quality Assurance Auditors Supervisor The Quality Assurance Auditors Supervisor shall have a minimum of-five years of appropriate, responsible experience in implementing l and supervising a nuclear Quality Assurance program. A maximum of two years of the five years may be fulfilled by academic y training on a one-for-one time basis. To be acceptable this academic training shall be in engineering or. scientific fields, 't unless specifically approved by the President of LES. l ad) _ Quality Assurance Technical Support Supervisor I The Quality Assurance Technical Support Supervisor shall'have a-minimum of five years of appropriate, responsible. experience in implementing and supervising a nuclear Quality Assurance: program. 7 11.1-14 MarchL1993' f F .c

.I: J0R INFORMIlON ONLY ^ A-maximum of two: years.of'the_five years may be fult111eu ur academic training'on.a one-for-one' time basis..To be-acceptable this academic' training shall be in engineering or scientific fieldsc unless specifically' approved by._the President of LES. l 11.l'-4.2 Facility Personnel Oualifications' fq The qualifications of'the individuals assigned to the key. facility positions outlined in section 11.1.3 will be provided to i -the NRC by LES as.soon as they'are available and before-receipt of nuclear material at the facility. Development and maintenance -i of qualification records and training programs are the-responsibility of the Human Resource Manager. 11.1.5 TRAINING -t The. training policy requires that employees; complete' formal nuclear safety training prior to unescorted access into controlled areas. The method for evaluating the understanding and effectiveness of the training includes passing'an initial ~ m examination covering formal training contents. l Such training is performed by instructors certified by the 3 ~ The. training program 1 contents are-- Compliance Superintendent. reviewed at least.every two years by the Compliance-Superintendent, the Technical Support Superintendent and the Health Physics Manager to ensure that the training program contents are current and adequate. Previously trained employees allowed unescorted access to. controlled areas are retrained at least every two years. The j system established for maintaining records of training and-j retraining is described ~in Section 11.4.2.. 't i i a =l 'i d 1 i i 11.1-15 March-1993' l q 0; 4

TABLE OF CONTENTS 11.2 TESTING - PREOPERATIONAL AND OPERATIONAL 11.2-1 11.2.1 OBJECTIVES 11.2-1 11.2.2 PROCEDURE FORMAT 11.2-2 11.2.3 PREOPERATIONAL AND START-UP TESTS 11.2-4 11.2.3.1 Procedures 11.2-.5 11.2.4 OPERATIONAL TESTING PROGRAM 11.2-6 11.2.4.1' Procedures 11.2-8 11.2.4.2 Periodic Testino 11.2-8 11.2.4.3 Special Testing 11.2-10 /h"kh Of L h h ~J -r.6 11.2-i January 1992-

r = N d' ~ LIST OF TABLES-d r <1 1. 2 - 1.' CEC Construction, Testing-andIOperation' Schedule':- zll 2-2 LUF6 Operational Tests, (%~ ~ $ il b,I Ll f5b hg 5.: 5 i l t l\\L \\ ~. ~.4, a q S P F i

i

.. -r 11.2-il-January.'1992). L f.s f i-e r s 4

11.2 TESTING - PREOPERATIONAL AND OPERATIONAL The overall CEC testing program is broken into the two major testing programs and within each testing program are two testing categories: a) Preoperational Testing Program 1) Functional Testing 2) Initial Startup Testing b) Operational Testing Program f 1) Periodic Testing g{1 { rg, g g1 wp 2) Special Testing 11.2.1 OBJECTIVES The objectives of the overall-CEC preoperational and operational-testing programs are to ensure that plant structures, systems, and components: a) have been adequately designed and constructed b) meet contractual, regulatory,-and licensing requirements c) do not adversely affect worker or the public health and safety d) can be operated in a dependable manner so as to perform their intended function. Additionally, the preoperational and operational testing programs ensure that operating and emergency procedures are correct and that personnel have acquired the correct level of technical expertise. Periodic testing at the CEC consists of that testing conducted on a periodic basis to monitor various facility parameters and to verify the continuing integrity and capability of facility structures, systems and components. Special testing at the CEC consists of that testing which does not fall under any other testing program. This testing is of a non-recurring nature and is intended to enhance or supplement existing operational testing rather than replace or supersede other testing or testing programs The following regulatory guides are used as guidance in developing testing programs and procedures: 1.68 "Preoperational and Initial' Startup Test. Prograns ' for Water-Cooled Power Reactors," Appendix C (November 1973). 11.2-1 March 1993 r

FOR INFORMAi!DR ORY k 3.25 " Standard Format and Content"of Safety. Analysis Reports for Uranium' Enrichment Facilities," Sections 11.2,_11.2.1, and 11.2.2 (December 1974). 3.52 " Standard Format and Content For the Health and Safety Sections of License Renewal Applications _for Uranium _ Fuel Fabrication Plants," Sections 2.7,'11.3, and 15.l_(July 1982). 11.2.2 PROCEDURE FORMAT TestLProcedures are sufficiently detailed that qualified personnel can perform the required functions without direct supervision. The format of test procedures is uniform to the extent practicable and consists of the following: a). Title Each procedure contains a title descriptive of the activities to which it applies. b) Purpose The purpose for which the procedure is intended is stated. This-statement of applicability is as clear and concise as practicable, c) References References are made to specific material used in the preparation and performance of a procedure. This includes applicable. 2 drawings, instruction manuals, specifications,-sections of the facility's Safety Analysis Report-(SAR) and License' Conditions. These references are listed in a manner as to allow ready ~ location of the material. References are given by both LES and-vendor designations where appropriate. d) Time Required As applicable, an estimate of the manpower and time requirements for performance'of the specified-testing activity are indicated, e)- Prerequisites Each procedure specifies those items-which are required to be completed prior to the performance of'the specified. testing (e.g.,-a previous test or special operating conditions)..This: listing also includes any_ tests that are to-be performed-concurrently with the specified testing. Provisions are made to 4; document verification of the completion of-the specified prerequisite tests. 11.2-2 March 1993: a v.

y s ,.As. J J L* 4 m i x

t 9

5 n" F8R INFORW3T!DN ONL" = f) .TestLEquipment. Each procedure contains a listing of specialitest equipment l required.in performing the.specified testing. Procedur'es contain-information and/or references for the items listed such as instruction' manuals or procedures. g) Limits and Precautions Limits on parameters being controlled and corrective measure's necessary to return a' parameter to its normal control ~ band are specified. Procedures specifically incorporate limits and~ corrective measures for all operations affecting criticality. safety. Precautions are'specified which alert the-individual performing 'dl l the task, of those situations for which important measures need. l to be taken early, or where extreme care must be used to protect' personnel and equipment or'to' avoid an abnormal or'an' emergency-situation. t -..} h') Required Facility or: Plant Unit Status f The procedure specifies the. facility or plant unit status' necessary..to perform the specified testing. _ Provisions-:are made d. to document compliance with the status specifi~ed. i ) Prerequisite System Conditions The procedure specifies the prerequisite system conditions: necessary to perform the specified testing. Provisions'are~made -j-to document compliance with the conditions'specified. ~ 1; j) Test Method Each procedure contains a-brief-descriptive section-which summarines the method to be'used for performing ~the_specified ~ testing. .a - k) Data Required Each procedure specifies any_ data which must be' compiled;in the' q - performance of the specified testing in: order to.verifyL c satisfactory completion of the specified. testing. n This finclude~s l I a' description:of'any calculations necessary to' reduce raw data-tod a' workable form. 1 y - 1)

Acceptance Criteria'.

Eachiprocedure states'the criteria for evaluating the ~ acceptability-of the results of the specified testing. Test __ results are reduced to a meaningful and readily understandable-a 11.2 March 1993-a ,.7:w ,,-,i t r

~. . = l. .I i f form in order to facilitate evaluation of their acceptability.7' ~ Adequate provisions are made to allow documentation of the acceptability, or unacceptability, of test results. i m) Procedure j This section.contains step-by-step directions in the degree of-i detail necessary for performing the required testing. References f to documents other than the subject procedure are included, as j applicable. However, references are identified within these step-by-step directions when the sequence of steps requires that l other tasks (not specified by the subject procedure) be performed prior to or concurrent with a procedure step. Where witnessing l of a test is required, adequate provisions are made in the test-procedure to allow for the required witnessing.and to document the witnessing. Cautionary notes, applicable to specific steps, l are included and are distinctly identified. i i n) Enclosures f I Data sheets, checklists and diagrams are attached.to the i procedure. In particular, checklists utilized to avoid or. d. j simplify lengthy or complex procedures are attached as i enclosures. I 11.2.3 PREOPERATIONAL AND STARTUP TESTS f The constructor is responsible for completion of all as-built drawing verification, purging / flushing, cleaning, hydrostatic-(or. pneumatic) testing, system turnover and initial calibration of l instrumentation in accordance with design and installation i specifications provided by the architect engineers and vendors. As systems or portions of systems are turned over to CEC, l preoperational testing shall begin (see Table 11.2-1, for testing 1 schedule). The Technical Support Superintendent is responsible l for coordination of the preoperational and startup test program. l l The preoperational test' plan including test summaries for all I systems is available to the NRC at least ninety (90) days prior-to the start of testing. This includes any subsequent changes to the preoperational test plan. Preoperational testing as.a -i minimum includes all system or component tests required by the. l pertinent design code which were not performed by the constructor i prior to turnover. In addition, preoperational tests _ include all testing necessary to. demonstrate that the system, component or j structure is capable of performing its intended function. j s Preoperation functional testing at the. CEC consists of that testing conducted to initially determine various facility-parameters and to initially verify the capability of structures, l 1 systems and components to meet performance requirements. The tests conducted are primarily associated with safety-related (QA. 11.2-4 March 1993 .l i -1 q

1 TCR INFORWl0N ONLY l Level 1) and other QA' Level.2 structures,. systems and components, 4 but may alsoLinclude a number of other tests of a technical or financial interest to'LES. 1 1 Preoperation functional tests are performed following completion of construction flushing and hydrostatic testing, system turnover i and initial ~ calibration of required instrumentation. The major objective of.preoperation functional testing is to verify that structures, systens and components essential to the ~ safe : operation of the plant are capable of performing their intended ' function. Preoperation functional tests are completed: prior.to UF6: l introduction. Other preoperational tests, not required prior to UF6 introduction and not safety related, such as Office Building Ventilation Tests, may be completed following_UF6 introduction" Tests (or portions of tests), which are not required to be l completed are identified in the test plan. j For systems and components which'are not System Class I,. j -acceptance criteria are established only to ensure worker-safety, t the performancelof intended functions. l reliable and efficient operation of thefsystem and.to demonstrate ? Initial startup testing at the CEC consists of that ' testing which f includes initial UF6 introduction and all subsequent testing i through the completion of Enrichment Setting Verification for-1 each cascade and assay unit. - " Enrichment Setting verification" 4 I is.the verification of.a selected enrichment weight'percentsby. measurement of a physical sample collected during the " Enrichment-t Setting Verification" test run. Initial startup testing is performed beginning with the t introduction of UF6-and ending with'the start.of commercial j operation. The purpose of initial startup testing is'to ensure 'l safe and orderly UF6 feeding and to verify' thermal and hydraulic parameters assumed'in the, CEC Safety Analysis. Examples of. -[ initial startup tests include passivation and zero product-flow-1 (filling phase). Summaries of.these tests are provided.in. Table-1 11.2-2. l a The startup tests' required prior to operation are summarized 1in' Table 11.2-2'. j 11.2.3.1 Procedures' d i All aspects of initial startup testing are conducted under: appropriate test procedures.. See section 11.4.1"for a' detailed-description of facility procedures. The use of properly. reviewed and approved test procedures-is required for all preoperational and startup t'ests. The'results of eachlpreoperational test are - 3 reviewed and approved by the responsible group superintendent- ,j t 1 11.2-5 March 11993 I !"t x <k w w -y-m r+

er-a L VOR INFORMl!T!M ]NLY l before they are used as the basis of continuing the test. program. The results of startup testing are reviewed and approved by the Superintendent of Technical Services prior to proceeding to the j -next significant enrichn,ent level. In addition,-the results of' i each. individual startup test will receive the same' review asithat I described for preoperation functional tests. All modifications to safety related systems which are found necessary are reviewed and approved by the responsible group superintendent and the CEC' l Manager. -l The impact of these modifications on future and completed testing ..j is evaluated during this review process and retesting is conducted as required. l Copies of approved test procedures are made available to NRC personnel approximately 60 days prior to their intended use, and-not less than 60 days prior to the scheduled introduction of UF6 for startup tests. r ? The overall preoperational testing program and all preoperation. l functional tests are reviewed, prior to initial UF6 introduction, by the CEC Manager and all Superintendents to ensure that all l prerequisite testing is complete. [ A review, evaluation and approval program is conducted forL initial startup testing, similar to that conducted for the.- preoperational functional testing. In addition, the results of each UF6 test are approved by the Operations Superintendent and ll Urenco prior to proceeding with the remaining UF6 tests. i The CEC operating, emergency and surveillance procedures are use-tested throughout the testing program phases and are also used in j the development of preoperation functional and. initial startup j procedures to the extent practicable. The trial use of operating procedures serves to familiarize operating personnel with systems' E! and plant operation during the testing phases and also servesito f ensure the adequacy of the procedures under actual..or simulated J 'perating conditions before plant operation'begins. j o r Procedures which cannot be use-tested during the testing program j phase are revised based on initial use-testing, operating. i j experience and comparison with the as-built systens. This i z ensures that these procedures are as accurate and comprehensive, as practicable. { i 11.2.4 OPERATIONAL TESTING PROGRAM The operational testing program consists of periodic testing-and-- special testing. Periodic testing is conducted at the CEC toi j monitor various facility parameters and to verify the continuing 1 integrity and capability of facility structures, systems and components. Special testing which may be conducted at the CEC is a 11.2-6 March.1993-j I .i 1

i WJR IEHANN ORY testing which does not fall Ludet vthcr tcoting pr:O*nm and any is of a non-recurring nature. i The Performance Manager has overall responsibility for the development and conduct of the operational testing program and in conjunction with the Compliance Superintendent ensures that all testing commitments and applicable regulatory requirements are i met. l The Compliance Superintendent shall ensure that new surveillance requirements or testing commitments are identified to the Performance Manager. The Performance Manager shall make responsibility assignments for new testing requirements. l Surveillance commitments, procedures identified to satisfy these commitments and surveillance procedure responsibility assignments for the Claiborne Enrichment Center are identified by the Periodic Test (PT) Program data base. The PT program is also used to ensure surveillance testing is completed in the required time interval for all groups. Test Coordinators are also used for operational testing. The Test Coordinator has the responsibility to be thoroughly familiar with the procedure to be performed. He should have an adequate period of time in which to review the procedure and the associated system before the start of the test. It is the responsibility of the appropriate section or group head to designate and ensure that each Test Coordinator meets the appropriate requirements. The Test Coordinator has the following responsibilities regarding the conduct of testing: a) Verification of all system and plant unit prerequisites. b) Observance of all limits and precautions during the conduct of the test. c) Compliance with the requirements of the SAR and any other facility directives regarding procedure changes and documentation. d) Identifying and taking corrective actions necessary to resolve system deficiencies or discrepancies observed during the l conduct of the test. e) Verification of proper data acquisition, evaluation or resnits, and compliance with stated acceptance criteria. f) Ensuring that adequate personnel safety precautions are observed during the conduct of the test. J i 11.2-7 March 1993

e ne a g)~ Coordinating.and observing additional manpower and support . required from other groups or organizations, 11.2.4.1 Procedures Periodic and special' testing procedures are sufficiently detailed that qualified personnel can perform the required functions-i without direct supervision. The administration of periodic and' special testing procedures are the same ones used for preoperation functional test and initial'startup test procedures as identified in Section 11.2.3.1. Spaces for' initials and dates are required for the following sections: a) Prerequisite Tests - b) Required Facility (or Plant Unit) Status c) Prerequisite System Conditions d) Procedure e )' Enclosures (where calculations are made) i Generic procedures and enclosures'for recording data for periodic and special tests are used,'whenever possible. Also whenever-possible, the enclosure is designed as a self-sufficient document. I which can be filed as' evidence that the subject ~ test was performed. Enclosures used as self-sufficient documents should contain sign-off blanks (Initials /Date).to verifyLthat [ prerequisite. tests, required facility status and prerequisite facility or plant unit status and prerequisite system conditions' L are met before conduct of the test. q 11.2.4.2 Periodic Testing I The periodic testing program at the CEC consists ofutesting i conducted on a periodic basis to determine various facility. parameters and to verify the continuing capability of structures, systems and components to meet performance requirements. ) The CEC periodic test program verifies that the facility: ~ i a) Complies with all regulatory and licensing requirements.. . b) Does not endanger the health and safety of the public. c) Is capable of operation in a dependable manner so as'to. [ perform its intended function. -f The CEC-periodic testing. program begins during the preoperational testing stage and continues throughout the facility's life. ,l

l A periodic testing schedule is established to-ensure'that alll

[ required testing is performed and. properly-evaluated on a_ timely-i basis. The schedule is revised-periodically, as necessary, to1 e reflect changes inithe: periodic testing' requirements and experience gained during plant operation. Testing is scheduled; such:that the safety of the plant is never dependent on the- -l ~ 1 11.2-8 January l1992- } ~, f r' ~-

=,. e t l0R WDRWlON ONI.y 1 performance of=a structure, system or component'which has.not' ~ +been tested'within its specified testing-interval. j Periodic test. scheduling is handl'ed through the Integrated! -l Scheduling Section and'the PerformanceLSection maintains the l periodic test status index on the facility. computer using the.PT .[ program. The purposefof this index is to-assist groups'in ? assuring that all surveillances~are being~ completed within the: 9 required test. interval. The PT program includes all periodic t'esting, calibration or inspection required by regulatory requirements or' licensing commitments. l The PT program provides the following information for each l surveillance- '[ a) Test # b) Title

t c)

Equipment # q d) Work Request # (if applicable) j e) Test. Frequency

j f)

Plant Unit # j g) Last date test was performed -j

h)

Next date test is due j j In the event that a test cannot'be performed within its' required j interval due to system or plant unit conditions, the responsible!.. j section notifies in writing, on_the applicable' form,Jthe-l- 1 Compliance Superintendent, Operations Superintendent, and the-4 Performance Manager. A copy-is retained by.the originating group as a= record'of the transmittal. The responsible.groupilists the. + earliest possible date the test could be. performed-and the latest, ~ ] date'along with the required system or unit-mode condition.: i However, the responsible group will. ensure.that~the test-is'. J performed as soon as required conditions are met,.regardless'o2..- 1[ the estimated date given earlier, j = d~ Periodic testing and surveillance associated.with QA Condition 11 l and-2 structures, systems and components-are performed in- '.o accordance with written procedures,.as follows: i a) . Testing and surveillance related to. structures and' '[ electrical and mechanical systems =and components may..be performedf ~ using CEC - Maintenance Procedures. y l ' b)I . Testing and~ surveillance.related(to instrumentation and 1 electrical systems and components may:be'conductediusing.CECX-Instrument; Procedures j d 1; - :r; 11.2-9. March'1993-d

{

F .h 4 :; mm., u

[ t g i c) Testing and surveillance related to' health-physics-activities may be performed using CEC - Health Physics Procedures. d) Testing and surveillance related to chemistry and - radiochemistry activities may be performed using CEC - Chemistry Procedures. e) Testing and surveillance related to operations may be performed using CEC - Operation Procedures, f) Testing and surveillance not performed using. Instrument Procedures; Maintenance Procedures, Health' Physics Procedures, Chemistry Procedures, nor Operation Procedures shall be performed using CEC - Periodic Test Procedures. 11.2.4.3 Special Testing Special testing is testing conducted at the CEC which is not a facility preoperational test, periodic test, post-modification test, or post-maintenance test. Special testing is of a non-' recurring nature and is conducted to determine facility' parameters and/or to verify the capability of structures,. systens and components to meet performance requirements. Purposes of special testing include, but are not necessarily limited to, the following: a) Acquisition of particular data for special analysis, b) Determination of information relating to facility. incidents. c) Verification that required corrective actions reasonably produce expected results and do not adversely affect the safety of operations, d) Confirmation that facility modifications reasonably produce expected results and do not adversely affect-systems, equipment + and/or personnel by causing them to function outside established -i design conditions; applicable to testing performed outside of:a post-modification test. ? The determination that a certain plant activity is a Special Test is intended to exclude those plant activities which are routine surveillances, normal operational evolutions, and activities for which there is previous experience in the conduct and performance of the activity. At the discretion of the CEC Manager, any. test may be conducted as a special test. In making this determination, facility management includes'the following evaluations of characteristics of the activity: a). Does the activity involve an unusual operational configuration for which there is no previous experience? l 11.2-10 . January 1992 l a e'I - = =

c-I I l j 'b) Does the activity have the propensity, if improperly conducted, to significantly affect primary plant parameters? c) Does the activity involve seldom-performed evolutions, meeting one of the above criteria, in which the time elapsed since the previous conduct of the activity renders prior experience not useful? I ' l-l f-l l 1 i l i 11.2-11 January 1992

s e-; - 3 g b ' E e{ i 7 Tab -1122 1 ~ ,, j. - CEC Construction Testina'& Operation' Schedule t t9 - 3 p-1j ~ Plant . Plant Plant l ITEN Unit'l EgitL1 Unit ~3' Receive Construction /- 8/93 8/93< 8/93 i Operation Permit. [ -Break Ground 8/93 '8/93-8/93-I Start. Concrete 1/94 1/94. 1/94' ii Foundation Complete 1/95 10/95 7/96J { Test Plan 4 . ( Receive Centritage 1/95 _10/95. -7/96 f,i [- Machine Parts Begin Preoperational 4/95 1/96 10/96-Tests .t Start Installation of 10/95 07/96 04/97 ^ Centrifuge Machines-Complete Operational 12/95 08/96'

05/97 Jf L

Test Plan j F Receipt of UF6 2/96 N/A* N/A } Begin Operational Tests 2/96 11/96 '08/97E 'r Production.begins.as 3/96 '12/96_- 09/972 { cascades'are brought on-line individually-4 commercial Operation 1/97 09/97 06/98'- 9 Nominal Rated ~ Output 3

i r

.t Not Applicable = 4 ^ ,{ January.21992L 5, .t t V ,( f .5 1 r 6 n

m

• g.'-

i ~

+,ey..,, _ ~ -. 'f '

s , Ll;_T[f; ' '\\ 1 4.' ~ L Table,11.2-2 : (Page 1) ' UF6 Ooerational Tests-m e-,;, 9 ?: g.

s e

Test Eaga p . Cascade'BypassiTest .2" ~ l 150 h' Vacuum %st - ~ ~.3 Feed Inlet Sequence-

4 g

Enrichment Setting Verification Test L S :- ', i 7 r a F' - M[MRMATlog g f ~ h -6 ii h 2 o; i ;;. .1 ? {', (. .,y-h ?

s I

-v p:.. t vi t ' f:.

a

. January 1992l ] q i ;. ;f

• fTf r

,1,_ 6 g, [ ] 14 i],, - ~m, 4 2

Table 11.2-2 (Page 2) Cascade Bypass Test Abstract Purpose To demonstrate the UF6 gas flow path from the Feed Autoclaves to the Tails 'and Product Takeoff Stations confirms predicted design. l To confirm the Autoclaves and T&amff Atations function as t designed. i L Is 1 jt Prerecuisites j 7 (To be provided with the Preoperational Test Plan)' Test Method (To be provided with the Preoperational Test Plan) Acceptance criteria (To be provided with the Preoperational Test Plan) i e [ l l t L . January 1992 4

r. i Table 11.2-2 (Page 3) 150 h Vacuum Test l Abstract Purnose To further outgas the cascades following the runup of the centrifuges. Prerecuisites ) Cascade Bypass Test complet b s e '?f I lj:f j(/ 77 [ l I Centrifuges runup i e lt*NSe ' ~- o' ::: f 4 Test Method ~ /'jl[l/ ff (To be provided with the Preoperational Test Plan) ' ' s "* /,/ Acceptance Criteria (To be provided with the Preoperational Test Plan) f i January 1992 t

~ l. Table 11.2-2 (Page 4) Feed Inlet Sequence l_ Abstract Purcose To allow controlled amounts of UF6 to react with impurities remaining in the cascades and to build up to full cascade feed. rate. Prerecruisites ,[ Cascades Bypass Test complete 150 h Vacuum Test complete \\' /h/ /*

• d e

Test Method q.f (To be provided with the Preoperational Test Plan) , = jf Acceptance criteria (To be provided with the Preoperational Test Plan) January 1992

g i f Table.11.2-2 '(Page ' 5)'. 4; Enrichment Setting-Verification Test i Abstract ^ Fj Purnose To verify that each cascade and assay unit' produces;:the. selected enrichment. l Prerecuisites Cascade Bypass' Test complete e 150 h Vacuum Ter,t complete e Feed Inlet Sequence complete e Test Method (To'be provided with the Preoperational Test Plan) - r .p Accentance criteria (To be provided With the Preoperational Test Plan) t t i ? .i ~ i I .2 January 1992-w

FOR INF0DlJ10N ONLY TABLE OF-COhrENTS-11.4

• FACILITY OPERATIONS 11.4-1

.1 11.4.1 FACILITY PROCEDURES 11.4-1 11.4.1.1 Preparation of Procedures 11.4-1 11.4.1.2 Administrative Procedures 11.4-2f 11.4.1.3 Procedures-11.4-3. 11.4.1.4 Chances to Procedures 11.4 11.4.1.5 Distribution of Procedures 11.4-7 11.4.2 FACILITY RECORDS 11.4-8 11.4.3 REVIEW AND AUDIT ORGANIZATIONS-11.4-11 11.4.3.1 Facility Safety Review Committee (FSRC) 11.4-12 11.4.3.2 Radiation Safety Committee (RSC) 11.4-14 l 11.4.3.3 Ouality Assurance 11.4-14. i 11.4.3.4 Claiborne Enrichment Center Organization 11.4-14 11.4.3-.5 Audited Organization -11."4-14 11.4.4 INTERNAL AUDITS AND INSPECTIONS 11.4-15 11.4.4.1 Criticality, Radiation, and Industrial Safety Audits 11.4-151 11.4.4.2 Environmental-Protection Audits 11.'4-15 [ 11.4.4.3 Independent Audits by Non LES CEC Personnel 11.4-16 11.4.5 INVESTIGATIONS AND REPORTING 11.4-16 11.4.6 MODIFICATIONS TO FACILITIES AND EQUIPMENT-11.4-17 6 i 11.4-i ' March 1993 i

l-FOR airBRMr f n 11.4 FACILITY OPERATIONS 11.4.1 FACILIT

Y. PROCEDURE

S EL / t All safety-related (system class I) operations are conducted ~through the use of procedures. Before initial enrichment activities occur at the facility, a list of titles of procedures that clearly indicate their purpose and applicability are made available to the NRC for their inspection. As noted throughout the Safety Analysis Report procedures are used to control activities in order to ensure the activities are carried out-in a safe manner. These activities would typically include: a) Procedures for cylinder handling b) Procedures for autoclave operation c) Procedures for takeoff stations operation d) Procedures for other production operations (e.g., blending) e) Procedures for implementing the Fundamental Nuclear Material Control (FNMC) Plan f) Procedures for implementing the Emergency Plan g) Procedures for implementing the Physical Security Plan h) Procedures for implementing the Security Plan for the ~ Protection of Classified Matter and Information i) Procedures for design changes to the facility j) Procedures for maintenance of facility structures, systems and components i k) Procedures for construction and testing of facility r structures systems and components 1) Procedures for inplementing the Quality Assurance Program j m) Procedures for training n) Procedures for criticality safety l 11.4.1.1 Preparation of Procedures For operating, abnormal, naintenance, instrument, periodic test, chemistry, radioactive waste management, health physics, emergency preparedness, annunciator responses, and modification procedures, each procedure is assigned to a member of the facility staff for development. Initial procedure drafts ~are I 11.4-1 March'1993

I reviewed by members of the facility staff, by personnel trom clie supplier of centrifuges (Urenco), and other vendors, as appropriate. Following resolution of review comments, if any, a revised procedure is prepared and forwarded to a previously designated qualified reviewer for review and comment. This qualified reviewer also makes the determination whether or not-any additional, cross-disciplinary review is required. After all required reviews have been completed a final version of the y procedure is prepared. U on approval by the CEC Manager and all p Superintendents, a procedure becomes available for use. If the procedure involves QA directly, the QA Manager also must approve the procedure. QA performs performance based audits to ensure procedure effectiveness. 11.4.1.2 Administrative Procedures Facility administrative procedures (Department Directives) are written by each department as necessary to control facility testing, maintenance, and operating activities. Listed below are several areas for which administrative procedures are written, including principle features: a) Operator's authority and responsibility: The operator is given the authority to manipulate controls which directly or indirectly affect the enrichment process, including a shut down of the process if deemed necessary by the Shift Supervisor. The operators are also assigned the responsibility for knowing the limits and set points associated with safety-related equipment and systems as specified in designated operating procedures. b) Activities affecting facility operation or operating indications: All facility personnel performing functions which may affect unit operation or control room indications are required to notify the Control Room Operator (operator) prior to initiating such action. Removal of an instrument or component from service requires the permission of the Shift Supervisor or Unit Supervisor. c) Manipulation of facility control: No one is permitted to manipulate the facility controls who is not an operator, except for operator trainees under the direction of an qualified operator. d) Relief of Duties: This procedure provides a detailed checklist of applicable items for shift turnover. e) Equipment control: Equipment control is maintained and documented through the use of tags, labels, stamps, status logs or other suitable means. f) Master surveillance testing schedule.: This procedure establishes a master surveillance testing schedule to ensure that 11.4-2 March 1993

f ~ required t.esting is performed and evaluatedTrrrtimely--bas 4 = Surveillance testing is scheduled such'that the safety of the facility is not' dependent on the performance of a structure, system or component which has not been tested within its specified testing interval. The master surveillance testing. schedule identifies surveillance and testing requirements, applicable procedures, and required test frequency. Assignment of responsibility for these requirements is also indicated. g) A Control Room Operations Logbook is maintained. This logbook contains significant events during.each shift such as enrichment changes, alarms received, or abnormal operational conditions. h) Fire Protection Procedures: Fire protection procedures'are written to address such topics as training cf the fire brigade, reporting of fires, and control of fire stops. The facility's Industrial Safety group has responsibility for fire protection' procedures in general, with the facility's maintenance section-having responsibility for certain fire protection procedures such-as control of repairs to facility fire stops. f The administrative control of maintenance is maintained as follows: a) In order to assure safe, reliable, and ef ficient operation,: a comprehensive maintenance nrogram for the facility's structures, systems and components is established. b) The Maintenance Superintendent is responsible for directing the performance of facility maintenance activities. c) Personnel performing maintenance activities are qualified in accordance with applicable codes and standards. -j j d) Maintenance is performed in accordance with written . procedures which conform to applicable codes, standards, specifications, and criteria. e)- Maintenance is scheduled so as not to jeopardize facility-operation or the safety of the enrichment systems. 3 f) Maintenance histories are maintained on facility' safety-related structures, systems and components. The administrative control of facility modifications is discussed-in Section 11.4.6. 11.4.1.3 Procedures Activities which affect the proper functioning of the-facility's Quality Assurance Level 1 or 2 systems and components are' 11.4-3 March 1993 1 i

l FOR lEDRMA?l0N DNLY l performed in accordance wi:h appre"ei 'evittem pr^ cad"vac Thone procedures, are intended to provide a pre-planned method of conducting operations of systems, in order to eliminate errors due to on-the-spot analysis and judgements. All procedures are sufficiently detailed that qualified l individuals can perform the required functions without direct supervision. However, written procedures cannot address all contingencies and operating procedures. Therefore, they contain a degree of flexibility appropriate to the activities bring performed. Typical procedures or checklists addressing operating activities j are: Functional Test of a Cascade Evacuation and Preparatory Work Before Run Up of a Cascade. Run Up of a Cascade Run Down of a Cascade Calibration of Pressure Transmitter Taking UF6 Samples of a Cascade Installation of UF6 Cylinders in Autoclaves and Preparation for Operation Removal of UF6 Cylinder from Autoclaves Installation of UF6 Cylinders in UF6 Take Off Stations UF6 Gas Sampling in Take off Lines UF6 Sampling in Homogenizing Autoclaves Emptying of Desublimer Exchange of Chemical Traps in Vent Systems Plant specific abnormal procedures are written for the CEC. These procedures are based on a sequence of observations and actions, with emphasis placed on operator responses to indications in the Control Room. When immediate operator actions are required to prevent or mitigate the consequences of an abnormal situation, procedures require that those actions be implemented at the earliest possible time, even if full knowledge of the abnormal situation is not yet available. The actions outlined in abnormal procedures are based on a conservative course of action to be followed by the operating crew. Typical abnormal procedures (consisting of appropriate subprocedures) are: Power Failure Loss of Heat Tracing Damaged UF6 Cylinder Repairs Temporary operating procedures are approved written procedures issued for operating activities which are of a nonrecurring nature. Examples of such uses are: 11.4-4 March 1993

~, =w. p F3R INmyggy gy;y 1 to~ direct operating activities during symcial'*ac*ina or_ j J maintenance, j i to provide guidance in unusual situations not within the scope of normal-procedures, and lll to ensure orderly and uniform operations'for'short periods 1 of time when the facility, a unit, a cascade, a' structure, a system or a component is performing in a manner not addressed by existing procedures or has been modified'in -i such a manner that portions of existing procedures do not if apply. j t'l The format of these procedures includes a purpose, limits and- . precautions, initial conditions and step-by-step instructions.for i each mode of operation and necessary enclosures. 1 Temporary operating procedures are sufficiently detailed that qualified individuals can perform the required functions without i direct supervision. Written procedures, however, cannot address _ j all contingencies and therefore contain_a degree of flexibility 'j appropriate to the activities for which each is applicable. t i Annunciator response procedures are written which specify j operator actions necessary to respond to an off-normal condition j as indicated by an alarm. The format for annunciator response- . procedures includes alarm set points, probableLcauses, automatic actions, immediate manual actions, supplementary actions,- and' applicable references. Maintenance of facility structures, systems and components is. performed in accordance with written procedures, documented 1 instructions,~ checklists, or drawings appropriate to the circumstances (for example, _ skills normally possessed by l qualified maintenance personnel may notLrequire detailed-step-by-step delineation in a written procedure) which conform to applicable codes, standards, specifications,- and criteria. Where sections-of related vendor manuals, instructions or approved. -[ drawings with acceptable tolerances do not provide adequate l guidance to assure.the required quality of work, an approved, written maintenance procedure is provided. The facility's maintenance group under the Superintendent of !^ Maintenance has responsibility for preparation and implementation-of maintenance procedures. j Maintenance, testing and calibration of facility safety-relat'ed instruments is performed in accordance with approved. written-procedures. i Testing conducted on a periodic basis to determine various facility parameters and to verify the continuing capability.of 2 11.4-5 March-1993 3 e'! i

.I h g } safety-related structures, systems and components to meet-q l -performance requirements is conducted infaccordance.with-t approved, written procedures. Periodic test procedures are. utilized to perform;such testing and are.sufficiently detailed 1 that qualified personnel can perform the required functions- <without direct supervision. l ~ Periodic' test procedures are performed by.the facilityfs a Technical Support, Operaticus and Maintenance groups. Chemical and radiochemical activities associated with facility. safety-related. structures, systems'and components are performed-

[

in accordance with approved, written procedures. The facility's chemistry section has responsibility for preparation andL i implementation of chemistry procedures, t Radioactive waste management activities associated with the if facility's liquid, gaseous, and solid waste systems are performed in accordance with approved written procedures. The facility's operations, chemistry and health physics sections have. ? responsibility for preparation and implementation ofEthe radioactive waste management procedures. t Likewise, other groups at the facility develop and implement i activities at the facility through the use of' procedures. s 11.4.1.4 Chances to Procedures q Changes to facility procedures are necessary to adapt to changing j facility conditions. Changes are processed by methodsLdescribed below. 1 a) The change to a procedure as well as the reason for the change is outlined. Changes can be initiated by any facility employee b) A safety review evaluation, is performed which fulfillsithm. requirements of the LES proposed' license' condition on safety. review of design or procedure changes. This evaluation-is'also performed to identify any possible unreviewed safety questions. c) A radiation safety review is performed which involves a review and' evaluation of radiation hazard considerations. Once the radiation safety review is complete, it is approved in writing by Health Physics and forwarded to the originator of'the procedure change. j d) A criticality safety review is performed by the Projects Manager when changes involve modifications to the parameters on which criticality safety was established. Once the criticality-safety review is complete it is approved in writing by the Projects Group Manager or designee and forwarded to the 11.4-6 March 1993' [

L l .originatorLof:the~proce' dure c e) The procedure with proposed' changes is reviewe a 2 squalified reviewer ~. The qualified: reviewer"is. independent o-1 originator. of'the. procedure change as'well as the: individual who' j . prepared the safety review evaluation. i f) The qualified reviewer. determines if a cross-dis'ciplinary-Ji review is necessary.. If a cross-disciplinary review is' necessary, the qualified reviewer is responsible for determining" i the group (s) for this review. -l g) The originator of the' procedure change'is responsible for 4 initiating and documenting the results of thefeross-disciplinary, review. Based on the results of the_ review'the proposed ~ ~ procedure change is either revised and a'newisafety review. i" evaluation and independent review are performed or.the proposed' procedure change is approved. If the safety review evaluation reveals.that a change.to the y license is needed to inplement the proposed changes,. the change ' is not inplemented-until prior approval is receivedLfrom the NRC j If the change is to a safety-related procedure,-thefchange~is reviewed and approved by the. Quality Assurance; department' prior' to implementation. j q All changes lto. procedures must be approved.by the CEC. Manager,,, j s Operations Superintendent, Maintenance Superintendent', Integrated. 1 Scheduling Superintendent, Compliance Superintendent, or the' Technical Support Superintendent or'their designees previously- . approved'by the CEC Manager. 11.4.1.5 Distribution-of Procedures l Originally issued procedures and procedure-.. revisions'are ~ distributed in a controlled. manner-'and?only after' receiving the necessary CEC management approvals. ~ a i The CEC shall establish and maintain'an index of'the'distributioni 3 r -of copies of all. facility manuals'~(such as'the Departmentf j ? Directives Manual, Operations and Maintenance Manuals,,etc.).. Revisions'to' facility. manuals are controlled and' distributed:in accordance with this index. Facility' manual indexes'are reviewed d and updated on. a periodic basis or as required.-- 1 Changes 1which.'do not' involve'a change in license ~ conditions-but d which require. procedures,'facilitytor equipment to: bel ti substantially different from those previously used are. initiated: only afterfthe. applicable conditions stated below are meti l a LMa'ch*1993 11.4-7: r Ia a 8 s' .;i )

• ).

1 t s ,3 e 4 6 J2

7; ~ J JOR INMygggy gg 1 a) Changes which involve radiation hazard considem ti - -are reviewed and evaluated iand approved"iniwriting'bygthe Heal D j 1 Physics group. 1 E b). ChangesLwhich. involve modifications to-the-' parameters on l which' criticality safety was. established are: analyzed and. l i approved in' writing by the Projects group and documented by:a-1 written criticality analysis. y 4 M c) Changes which involve a change-to the-facility.'as described! in the Safety Analysis Report are reviewed and. approved-by the: i Licensing group. l l l A request for a criticality and radiationisafety. analysis is i' prepared in writing by, or at the direction of, a group manageri for any proposed new activity or. change in activity:r'esulti'ng from proposed procedure changes which may, require a proposed-F change in criticality safety or radiological safety controls. ~ 9 Changed activities resulting from new. procedures or existing a procedure changes will not be' initiated until the criticality'andL, l radiation safety analysis demonstrating safety ofLthe activity- ~ A has been completed, a preoperational inspection has-been conducted to verify that the. installation'is in.accordance.with the safety analysis, and applicable procedures and/or. ] J instructions are issued. l The results of'these analyses are documented in nuclear safety j reviews and maintained-'for the period cf time they remain'- ,j applicable and in'accordance.with records. retention requirements, j Distribution of procedure changes.to appropriate groups and-individuals is'made by the group responsible for the procedure. This allows groups-and individuals to incorporate any effect of 1 the procedure change into their own work group' activities. -t 11.4.2 FACILITY RECORDS Records management shall be in a controlled and systematic manner; in order to provide identifiable and retrievable documentation. j The CEC maintains a Master File which access to, and:use oflis' s controlled. -Documents in the Master File shall be legible'.and shall be identifiable as to the subject to which they pertain, j ~ Documents shall be considered valid only if stamped, initialedi signed or otherwise authenticated'and dated by authorized. personnel. Documents'in the' Master File may be original copies.- or reproduced copie~s.. Computer storage of._ data may be used'in j the facility Master File. -l In order to prbclude deterioration.of records <in the Master File, 3 the following requirements are applicable: 11.4-8 .. March.:1993 i ,1 f 3 y I

J a).-Records shall not be stored _1oosely-nonnran nhall be-firmlyfattached in binders or1placed.in folders or envelopes.- Records should'be stored in-steel' file' cabinets. b) Special processed records, e.g., radiographs, photographs, negatives, microfilm, etc., which are light-sensitive,jpressure- 'l sensitive and/or temperature-sensitive, shall be' packaged and stored as recommended by the manufacturer of these materials, c) Computer storage of records shall_be.done-in a manner to preclude inadvertent loss and to ensure accurate and timely retrieval of data. A Master File storage system shall provideffor the accurate retrieval of information without undue delay. Written _ instructions shall be prepared regarding the storage ofl records-in a Master File, and a supervisor _shall be' designated with'the responsibility for implementing the requirements of the instructions. These instructions shall include, but not necessarily be limited to, the following-1 a) A description of the location (s) of the Master File and an identification of the_ location (s) of the various record types within the Master File. b) The filing system to be used. c) A method for verifying that records received are in agreement with any applicable transmittal documents and are-in-good condition. This is not_ required for documents generated within a section for use and storage in the same sections e satellite files. 1 d) A method for maintaining a record of the records received; e) The criteria governing access to and control'of the Master ~ E File. r f) A method for maintaining control of and accountability.for records removed from the Master File. .j g) A method for filing supplemental information and for j disposing of superseded records. .I A qualified Fire Protection Engineer will evaluate record storage ,{ areas (including satellite files) to assure records ~are' adequately protected from damage. The-Fire Protection' Engineer shall be'a registered Professional Engineer qualified for-1 membership grade status in the Society of Fire Protection Engineers. 11.4-9 -March 11993 i l-L + l

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Records associated with' personnel radiation ~'exposuresiare... a generated;and retainedLin such a manner'as to comply with the- 'I

relevant' requirements of._.10'CFR Part 20.

Theu-following 't additional radiation 1 protection records'will be' maintained for at least~two years: l a) Records of Facility' Safety Review Committee meetings., b) Surveys _of equipment'.for release to unrestricted areas. c) Instrument calibrations. 1 d) Classified / reportable incident reports. e) Safety audits. f) Personnel training and retraining. g) Radiation work permits. h) Surface contamination surveys. i) Concentrations of airborne radioactive material in the [ facility. j j) Radiological' safety analyses. t In addition, the following records-shall be retained for'at-least' l the periods indicated: 1a The'following shall be retained or at least 3 years: ] i 'a. Records of.all Reportable Events; i b. Records of surveillance _ activities,. inspections, and j calibrations; c. Records of changes In&de to. procedures; and d. Records of radioactive-shipments. The following records shall be retained for the duration of the e facility license: a. Records and drawing. changes reflecting design modifications made to systems and' equipment. described in'the Safety; Analysis-- Report; O b.. Records,of;r'adiation_ exposure for all individuals entering' . radiation control areas;- ~ ] 11.4-10 March [1993 i f a

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c. Records _of gaseous and liquid radioactive material released. to the environs; l 1 d. ' Records of training and qualification for current and past i ' members of the CEC staff i -i e. Records of reviews performed for changes made to: procedures ( or equipment or reviews of tests an experiments; f. Records of analyses required by the Radiological -l Environmental Monitoring Program that would permit evaluation of, 1; the accuracy of the analyses at a later date. These should j include procedures effective at specified times and QA records showing that these procedures were followed; and 4 g. Records of quality assurance activities required by the j Quality Assurance Program. These shall be retained for a period of time as recommended by ANSI N.45.2.9-1974. j t other retention times are specified for'other facility ~ records as i necessary to meet applicable regulatory requirements. These .i retention times are indicated in specific facility procedures. j i 11.4.3 REVIEW AND AUDIT ORGANIZATIONS j A review and audit program for operational quality assurance of j the CEC is established, and periodically reviewed by management, i to: verify that the facility is consistent with LES company policy, j a approved procedures and license provisions, l review important proposed facility modifications, tests and l procedures, j verify that reportable occurrences are investigated and j corrected in a manner whi~h reduces the probability of c recurrence of such events (reference section 11.4.5), and to detect trends which may not be apparent to a day-to-day observer. The intent of this program is to ascertain that the facility is { constructed and operated safely and in accordance with the license conditions. l -i a) The organizational structure for conducting the operational 'i quality assurance review and audit program is as follows. i 1) The Facility Safety Review Committee appointed by the j CEC Manager. i 11.4-11 March 1993 i.! i 7

e. ] FOR INFORnDV ~ The Radiation Safety. Committee appvint h the b i N 2) Manager. 3) . Regular audits conducted by the Quality. Assurance. { Department._ Each of the above shall have the authority necessary to discharge J its responsibilities adequately. Implicit in this authority { shall-be access to facility records and personnel asfrequiredEin order to perform reviews and audits properly. j i 11.4.3.1 Facility' Safety Review Committee'(FSRC)

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. provide review and audit of designated' activities in the areas .i Facility Safety Review Committee - The FSRC shall' function to' j of-a) Enrichment unit operations. ] i b) Chemistry and radiochemistry. .l j. c) Metallurgy (corrosion). { d) Instrumentation and control. I e) Radiological. safety. j t f) Engineering. ] t g)- Administrative control and quality assurance practices. 1 Further functions of the Facility Safety Review Committee includeL responsibility for the following: a) An annual ALARA review which considers the following: Programs and' projects. undertaken by the Health Physics group. l and the Radiation Safety Committee. j t Performance including, but not limited'to, trends in [ airborne concentrations of radioactivity, personnel exposures and environmental monitoring results. f Programs for improving the effectiveness of equipment used' I for effluent and exposure control. i b)- Review of major or proposed changes in authorized plant .j activities which may affect nuclear or non-nuclear safety practices. i -c) Professional advice and counsel on criticality,-radiation' l and industrial safety issues affecting the nuclear' activities. j 11.4-12 March,1993-l l i i i

E F FOR T03 MAT 10NL KY The FSRC begins functioning as deemedLnecessary by the CEC l Managar., and not later than the receipt of nuclear material at the CEC. The~ Chairmen, members and. alternate members of the Facility-Safety Review Committee are formally appointed by the CEC Manager;.shall have an academic degree in an engineering or physical science field; and, in addition, shall have a' minimum of five (5) years of technical experience, of which a minimum of three (3) years shall be in one or more of the areas listed above in section 11.4.3. The Facility Safety Review Committee shall be composed of at least five (5) members, including the Chairman. Members of'the FSRC may be from the LES corporate office or CEC technical staff. Consultants may be utilized by the Facility Safety Review Committee to provide expert advice to the FSRC, as determined necessary by the Director of the Facility Safety Review Committee. Staff assistance may be provided to the FSRC in order to promote the proper, timely and expeditious performance of its functions. ~ The Facility Safety Review Committee meets at least once per calendar quarter during the period of initial operation. Subsequently, the meeting frequency shall not be less than.three (3) each calendar year with a maximum interval of 180 daysL between any two consecutive meetings. A quorum of the FSRC consists of not less than a majority of the members or alternate members and includes the Chairman,-or designated alternate. The Facility Safety Review Committee shall report to and advise the CEC Manager on those areas specified in Section:ll.4.-3.1. Minutes shall be prepared and forwardedLto the~ CEC Manager.and the LES Fresident within fourteen (14) days following each formal meeting of the Facility Safety Review Committee. i t Records of FSRC activities are maintained for the life of the I facility. Audit reports shall be forwarded to the CEC Manager. and the LES Fresident and to the management positions responsible for the areas audited within thirty (30) days of completion of each audit. Copies of minutes of formal meetings and reports of audits performed under the cognizance of the FSRC shall be retained in an identifiable and retrievable manner as specified in Section 11.4.2. i 11.4-13 March 1993-3

.. } R l FOR INF0HATB DNLY l t 11.4.3.2 Radiation Safety Committee (RSC) l 1 The objectives of the Radiation Safety Committee are to improve ~ enrichment operations, to maintain occupational radiation [ exposures as low as reasonably achievable and to reduce the e potential for other health and safety hazards. l The committee meets monthly to maintain a-continua [ awareness of the status of projects, performance measurement and' trends, and. the current radiation safety conditions of enrichment operations. i The maximum intervals between meetings shall not exceed 60 days. -{ l A written. report of each Radiation Safety-Committee meeting shall i be forwarded to all superintendents within 15 working days of the. meeting. Records of the committee proceedings shall be maintained-for two years, j The committee shall consist of managers or representatives from quality assurance, operations, integrated scheduling, maintenance, compliance and technical' support. 11.4.3.3 Ouality Assurance Department The Quality Assurance Department conducts periodic audits of activities associated with the Claiborne Enrichment Center, in order to verify the facility's compliance with established requirements as detailed in Chapter 10. I r t 11.4.3.4 Claiborne Enrichment Center Organization l t The facility operating organization shall provide, as part of the normal duties of' supervisory personnel, timely and continuing monitoring of operating activities to; assist ~the CEC Manager in keeping abreast of general facility conditions and to verify.that-the day-to-day operating activities are conducted safely and in accordance with applicable administrative controls. These continuing monitoring activities are considered to-be an integral part of the routine supervisory function and are important to the safety of the facility operation. 11.4.3.5 Audited Organizations Audited organizations shall assure that deficiencies identified are corrected in a timely manner. i- -l l Audited organizations shall transmit a response.to each audit ~ report within the' time period specified in the audit. For each ~i identified deficiency, the response shall identify the corrective 1 action taken or to be taken. For each identified' deficiency, the response shall also address whether or not the deficiency is i considered to be indicative of other problems-(e.g., a specific 11.4-14 March'1993. 1 l i

FOR INF0MM ON ONLY l 9 ' audit. finding may'indicateca generic problem)Landithe corrective l action taken=oritoLbeLtaken for any such problems determined. l ~ With regardLto corrective action to be completed at some future j 'date, the audited organization shall notifyfthe auditing organization of-the completion of the committed' corrective action within thirty (30). days thereof. Other supplementary response-information may be provided'. -j 'l Copies of audit reports and responses thereto are retained in an-d ~ identifiable and retrievable manner asLspecified in Section y 11.4.2. 1 11.4.4 INTERNAL AUDITS AND INSPECTIONS r ~ Written operating procedures are based on LES and Urenco practices, applicable regulations and license conditions..' Audits ~i and inspections are performed to assure that p1'nt. operations-are a conducted in accordance with'the. operating procedures. j -r 11.4.4.1 Criticality, Radiation, and Industrial Safety i Audits i ~! Semi-annually, senior members of the ProjectsE(criticality safety) and Health Physics.(radiation safety) groups,.and i representatives from the industrial safety group conductLformal, scheduled safety. audits of enrichment and support areas in accordance with a' procedure approved by the CEC Manager. Such audits are performed to determine that. actual operations conform' I to criticality, radiation, and industrial--safety requirements. l q Personnel performing. audits do not report to the production organization and have no' direct responsibility for.the function-and area being audited. Records of'the instructions and procedures, persons' conducting' l" the audits or inspections ~, identified violations of license conditions and corrective' actions'taken.shall be maintained by? the' criticality sa'fety group or the radiation' safety group for a minimum' period of two years. 1 ' Audit results in-the form of corrective action items are reported 3 to the CEC manager-and staff for monitoring,until their closure. j 'I 11.4.4.2 Environmental Protection Audits j An' audit schedule of'the environmental. protection program'is. . developed by the Environmental Compliance Manager'on an' annual L basis. Audits are conducted'in accordance with;a written. 1 procedure approved by thefCEC Manager.to ensure'that; operational activities conform to' documented environmental requirements. l i .1 11.4-15 March 1993 1 l< -l .t

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1R MORMTM MY Personnel under the direction of the manager of the Environmental j Compliance group perform ~the environmental' protection audits. Personnel performing the audits ~do not report to the' production j organization and have no direct responsibility for'the function j and area being audited. The finding of an apparent nonconformance is communicated to.the -[ appropriate superintendent who is responsible for corrective j approved by the CEC Manager. The manager of the Environmental ~ [ action commitments in'accordance with documented procedures j Compliance group or designee is responsible for formal follow-up i and closure of identified nonconformances. Audit results in the form of corrective action items are reported to the' CEC manager + and staff for monitoring until their closure. 11.4.4.3 Independent Audits by Non LES CEC Personnel [ The CEC criticality safety and radiation safety programs are audited at a frequency of every two years by an appropriate function outside of the LES - CEC organization. The audit team j is composed of individuals whose audit qualifications are i approved by the CEC Manager. i Audit results are reported in writing to the CEC Manager, the Superintendent, and the managers of the criticality safety l (Projects Manager) and radiation safety (Health Physics) groups. The criticality safety group, Health Physics' group and/or Superintendent take necessary response actions in accordance withi a documented corrective action commitments. i Audit results in the form of corrective action items are reported 1 to the CEC Manager and staff for tracking until their closure. i 11.4.5 INVESTIGATIONS AND REPORTING Unusual events which potentially threaten or lessen the effectiveness of health, safety or environmental protection are identified and reported to the Licensing Manager. Each event is considered in terms of its requirements for reporting in i accordance with regulations and is evaluated to determine whether i it is to be classified as an incident. Each reported unusual incident is evaluated to-determine the level of investigation required. These evaluations and i investigations are conducted in accordance with approved procedures. The depth of the investigation depends upon the severity of the classified incident in terms of the levels of l uranium released and/or the degree of potential for-exposure of workers, the public or the environment. j -t The Licensing Manager is responsible for (1) maintaining a list- [ of agencies to be notified, (2) determining if a report to an t 11.4-16 March 1993 .i F

(( p l h agency is required, and (3) notifying tlis~spency when required, J The licensing function has the responsibility for continuing communicatians with government agencies and tracking corrective actions t. completion. 11.4.6 MODIFICATIONS TO FACILITIES-AND EQUIFMENT In order to provide for the continued safe and reliable operation of the CEC structures, systems and components, measures are implemented to ensure that the quality of these structures, systems and components is not compromised by planned changes (modifications). After issuance of the Facility Construction / Operating License, the CEC Manager is responsible for the design of and modifications to facility structures, systems or components. The design and implementation of modifications is performed in a manner so as-to assure quality is maintained in a manner commensurate with the remainder of the 4 system which is being modified, or as dictated by applicable [ regulations. i The administrative instructions for modifications are contained in the " CEC Facility Modification Manual" which is approved, including revisions, by the CEC Manager with concurrence of the-Manager of Quality Assurance. The manual contains the following l items necessary to ensure quality in the modification program:. j a) The requirements which shall be met to implement a modification. b) The requirements for initiating, approving, monitoring, designing, verifying, and documenting modifications. -The CEC Facility Modification Manual shall be written to' ensure that policies are formulated and maintained to satisfy the quality. J assurance standards specified'in 10 CFR Fart 50, Appendix.B, as applicable. a Each Facility Change Not'ification (FCN).shall have a safety evaluation performed in accordance with the requirements of the CEC License Conditions. Supporting. documentation'necessary to justify the conclusion reached in the safety evaluation'shall also be included. If the safety evaluation determines that an unreviewed safety' question is involved or that a license amendment is required, FSRC and NRC authorization is required ~ prior to implementation of the FCN. This authorization shall-be-documented.. In addition to, but not'necessarily a part of the safety evaluation process, each modification shall-be evaluated. for any required changes or additions to the facility's procedures, personnel training, testing program,~or regulatory' documents. Each modification is also evaluated and documented for radiation exposure, to minimize worker exposures in keeping with the 11.4-17 March 1993 t

i facility ALARA program,' criticality and worker safely requirements and/or restrictions. Other areas of consideration in evaluating modifications may include,.but are not limited to the review of: FCN cost, similar completed FCN's, QA aspects, potential operability or maintainability concerns, constructability. concerns, post-modification testing requirements, environmental considerations, and human factors. After completion of a modification to a structure, system, or component, the Projects Manager, or designee, shall ensure that all applicable testing has been completed to ensure correct j operation of the system (s) affected by the modification and- -documentation regarding the modification is complete. In order to ensure operators are able to operate a modified system safely, when a modification is complete, all documents necessary, i.e., the revised process description, checklists for operation and flowsheets are made available to operations and maintenance the moment the modified system becomes." operational." A formal notice of a modification being completed containing " red-marked" copies of applicable drawings is distributed to all Superintendents l within 5 working days. For modifications to Quality Assurance-Level 1 or 2 systems, structures, or components, as-built drawings incorporating the modification are completed within six months. These records shall be identifiable and-shall be retained as specified in Section 11.4.2. 11.4-18 March 1993 -}}