ML20056F886
| ML20056F886 | |
| Person / Time | |
|---|---|
| Site: | Claiborne |
| Issue date: | 08/24/1993 |
| From: | Jim Hickey NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Leroy P DUKE ENGINEERING & SERVICES |
| References | |
| NUDOCS 9308310268 | |
| Download: ML20056F886 (23) | |
Text
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l Docket No. 70-3070' NG 2 41993 Mr. Peter G. LeRoy Licensing Manager Louisiana Energy Services c/o Duke Engineering & Services, Inc.
l P.O. Box 1004 Charlotte, NC 28201-1004 i
Dear Mr. LeRoy:
1 This is a follow-up to our open meeting on August 16, 1993.
In that meeting the Nuclear Regulatory Commission staff and its contractor, Science l
Applications International Corporation (SAIC), met with you to discuss our letter of August 11, 1993, with comments on the revision of your proposed license conditions.
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On June 18, 1993, you had submitted a revision of the license conditions addressing our previous comments of May 6, 1993. Discussion of each of our comments led to clarificationc that resulted in additions, corrections and
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deletions which are stated it
attached Enclosure 1.
Note that comment numbers 35a, 38a, 38b, 38c, 99a 16a are new. is a list of attendees.
As stated in our letter of August 11, 1993, we requested LES to submit the l
revised license conditions as soon as possible. We are available to meet or answer questions, as necessary to expedite the process.
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Sincerely, hob.'h.97kkk, Chief Enrichment Branch i
Division of Fuel Cycle Safety and Safeguards, NMSS
Enclosure:
As stated cc: Attached list DISTRIBUTION: Docket No. 70-3070 I
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ENCLOSURE 1 AUGUST 24, 1993 l
REVISED NRC STAFF COMMENTS ON LES' PROPOSED LICENSE CONDITIONS Note that:
strikeout indicates deletion from NRC letter dated 8/11/93 ; and i
redline (;
[)indicatesadditiontoNRCletterdated8/11/93.
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General Comments l
l 1.
Include a definitions section.
2.
Whenever the license conditions designates a named official "or designee" deletsL"jor desig' nee." as the approving official for ; number of eet4v+ tics, add " equivalently quaMfied designee."
3.
Specify the time frame for submit 4+ng-ehamjes en those plans.hcre the changes-de-not-deefease the effeet4veness of the plan, e.g., Emergency Plan, f44MG-Nan, Physica' Security, ete 4.
Replace "sS 20.1001-20.2401" by "sG 20.1001-20.2402."
j 5.
Consider implementing a tracking system which should include corrective actions from audits and inspectors' findings, as.;cll as aud Ms.
6.
There is no need to propose commitments that are already required by regulations.
Regarding validation of computer codes importantifo3afstysand l
7.
safeg0ards and verification of software importantLtoj safetyjand[ safeguards, include the requirement that software control will~be in'~accordance with Part
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2.7, " Quality Assurance Requirements of Computer Software for Nuclear Facility l
Applications," of the NQA-2a-1990 Addenda to "ASME NQA-2-1989 Edition Quality Assurance Requirements for Nuclear Facility Applications" or some other acceptable software QA standard.
F6r. ~nticl ear cri ticsl'i ty fsafety' codes;i see comment'#124.
Specific Comments l
l Chapter 1.0 Standard Conditions and Special Authorizations 6 1.1 Name. Address. and Corporate Information 1.
First line.
Delete H est.;crd i.e. "LES" before " Louisiana Energy
- Services, L.P...."
2.
Delete second and third sentences.
i 3.
Add site address.
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i 6 1.2 Site' Location i.
4.
Define the areas where licensed activities are to be conducted.
i 5.
Delete the last three sentences.
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i E 1.3 License Number and Period of License 6.
031ete this section.
61.4 Possession Limits 7.
Possession limits should be given in metric units with English units in parenthesis.
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6 1.4 A Special Nuclear Material f
B.
Add "(S"9)" after the-head 4ng "Special "uclear Material".
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9.
Add another sentence at the end of the first bullet to read as follows:
"That is, the measured U-235 enrichment value plus its measurement uncertainty at the 95% confidence level (expressed as absolute weight percent U-235) shall not exceed 5.000."
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10.
Add another sentence at-the end of the-second bullet which specific the max 4 mum amount of uranium SNM to be posses:cd at any one time that can exist 4n a chemical fere-ethee-than-UF -
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t 6 1.4.B Source Material 41.
^dd "(SM)" af ter the heading "Scuece Material."
12.
Modify the last twc line; cf third bullet tc read as follows+
...lengee-than-B-year', follev.ing its removal (disconnec-t-len) from the-EG eascade enrichment system "
43.
Add-another sentence to the 1;+t bullet.vhich specific; the ma*4 mum-amount-of SM uranium to be possessed at any one time that can exist-4n-a i
chemical form other than-UFg 14.
If LES were to possess the maximum quantity of natural and depleted UF the possession limit for source material would be exceeded by 42,400 pounds.6 t
i 6 1.4.C Bvoroduct Material 15.
Delete the paragraph beginning with " Additional radionuclides may be..."
including the two bullets. This 4; unlikely to occ-ur in the near futuee-LES can not add additional radionuclides without NRC approval.
LES must apply-fee a license amendment if it-decide; to apply a newly developed calibration and sample process 4ng-technology requiring use of radionuclide; not specified in thic section.
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b 61.5 Authorized Activities i
16.
Add specifie uses of the individual byproduct radionuclides.
l 17.
.5 1.5.D.
Revise this statement to read as follows:
" Chemical, spectrometric, radio-chemical, and non-destructive assay analyses of SouFcd Material SM and Sp;sciallNucle'afjMatdrial SNM materich, including effinents i
and stored waste.
j 18.
s 1.5.E.
Delete the words " hazardous" and " industrial." The NRC does not authorize treatment, etc., of hazardous and industrial wastes.
6 1.5.1 Location Where Material Is Used j
19.
Do not describe processes where licensed material will be used. Just identify the locations where licensed material will be used.
For example, delete the following sentences:
First paragraph, first and last sentence.
Second paragraph, all except first and fifth sentences.
6 1.6 Exemptions and Special Authorizations 20.
Commit to updating the SAR and ER cn a ct frequency; at least evsff i
enee-4e two years.
21.
I; it LES' intent to label all containcr; on site in accordanee-with-44 CFR 20? An exemptica frc= labeling require = cat: could be considered.
6 1.6.1 Safety Evaluation Process 22.
Commit to inform 16g the NRC regarding changes which affect but do not Also decreasetheeffectivenessoftheQAprog;ramasdescribedintheSAR. ' '
f speQffaN#@ehcyi;fo61submittingitheRhanges) 23.
Delete item (b) since it is required by regulations.
i 24.
Add items f, g, and h to the list as follows: f) unreviewed safety issues, g) a significant change in the types or significant increase in the amounts of any radioactivs effluents that may be released off site, and h) a significant increase ^in individual or cumulative occupational radiation l
exposure.
6 1.6.2 Exemptions and Special Authorizations 25.
Note that 1.6.2. A is based on a letter we sent you. However, selaFe the NRG-4+ currently reviewing this issue ;; applicable to all licensecs ahd'it is
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unresolved at this time.
26.
UnderB,committoinformtheNRCofachangewithin60fdsjsadefinite i
per-40d (e.g., 30 dayst so that the staff has an up-to-date ' ecord'of CEC r
owners, lienholders, etc.
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27.
Under C, add the date of the Guideline and state that it is provided as Appendix A.
Section 1.8 can then be deleted.
l 6 1.7 Financial Information and Commitments I
28.
The once a year reporting required by License Condition 1.7.A is probably sufficient for sale-leasebacks provided LES considers sale-leasebacks j
to be changes in ownership and plans to report them.
However, for limited partner changes, commit to report the information Withiki60idays.L scener in case problems ccmc up dueing the year (e.g., bankruptcj)' ii.;hich-the-NRG would need to have current-4nformation. Add a statement to this section. tith i
such a commitment.
l 6 1.8 Reference for Section 1 l
29.
Delete this section.
Replace " Reference 1" in Section 1.5.2.C by
" Appendix A."
l Chapter 2.0 Oroanization and Administration i
6 2.1 Oroanizational Resoonsibilities and Authority
- 30..Provideorganizationchart/sf0r?safet)fand[safsguardsirl elated positions.
l 1.
i 31.
Under-Ar-add-the fellowing to the end of the paragraph:
"the CEC l
Manager shall have-the authority to approve and issue Depaeteent Directives j
and procedures."
32.
Under H, last word; capitalize first letter of the word " manager."
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r 32a; under K;qforiths.HPlManager,) provide.....vthe: type;of. equip"menta,n :the, statement" training /of!pepsonnellinttheluseMfequipment."
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6 2.2 Personnel Education and Experience Reouirements 33.
State that the CEC Manager shall have held, as a minimum, a bachelor's l
degree in an engineering or scientific field and have a minimum-of six years
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of responsible nuclear experience.
34.
State that the QA Manager shall have at least two years experience in a i
QA organization at a nuclear facility.
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35.
State that all Superintendents shall have held, as a minimum, bachelor's degrees in an engineering or scientific field ~and have a minimum of four years of responsible nuclear experience.
t 35s[51hcluds:the'jesponsibilitiesland]quslificationsjoffthefChemistEy and Ind0strial1 Safety:Managerslin,the2 License; Conditions;2:-StateLthatsthe~
Chemistry; (Industri al Safety l andi Heal th Physifss (HP.)f Mina'gers1shall ::'eacW havel~
asfalminimum,fa1 bachelor's1degreelin?aniengineeringfory:scientificjfie]d,fand I
- t. !
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atllssst;{thFss[iAafs"of resibisibls}spsri,shesi.inelssh;;'dfLtheir/ respect'ivs areasj 35.
Stoic t-hat the Health Physic: M nagee-shall hold,
- a minimum, a bathclcr's in scientific field, and three year; cf responsible experience in l
the arcas-ef health physics, chemical safety and industrial ;;fety.
l 37.
The Projects Manager shall have held, as a minimum, a BS degree in an engineering or scientific field and'have three years of responsible nuclear s
experience, including one year of experience in the administration of nuclear j
criticality safety reviews.
38.
Specify the type of equipment in the statement " train 4ng of personnel-4n the use of equipment."
38a.' lIniaddit'ionLtoLthe~rsquirementF estsblished)byLLESTfor!the~nublsas criticality (safety anslyst anditheireviewerbtheianalyst1shall)have;
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' uccessfully completed a? trainingfpr'ogramb;appropriatektoltheuscopetof.
s operations,1in(the phys;ics?ofEcriticality;and iniassociated!s'afety; practices.
The Lindependent! reviewerfshallf possessLa1 BS : degreef inJ engineering Jor/ science '
and havelthejequivalentfof f two; ysarsioff.fulh timb experiencefasialtrained analyst.
4 2.3 Safety Committee 38b;7Theisdopbiof7eviewsfcond0ctedLbj/thelFisilitibsiSAfstyfRevisw!C6mmi'ttee (FSRC) 4shallyinclude,1:'as' aiminimum,Ereviews of o'ngoingTan.dJpropossd".
radiol ogi calkchemi cal,i i ndustri al : and 'nucl e ar: cri ti cal i ty ^ s afety ;act i si _ti e_s and;! practices.. Radiologicalp: chemical; ?industriaU and---nuclearicriticality "
safety [ investigation,j-audit?andinspectionLreportsVshally begincluded Tin: the i
reviews; 38c; ;Ths' memb'ershipiof?the FSRCfshalllincldd61sipsrsonihsvinghas;:a~ minimum,1~
the7qualificationsfofd af nuclearicriticali tyjanalyst?
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39.
First paragr-aph, specify:
.-that types of techniecl revic'....ill be donc by FSRC.
.;hether memberc of FSRC are also the auditer; for the annual audit-40.
The safety committee should also review the training program, incident reports, root cause reports, and violations of regulations or license conditions.
41.
Provide crit'eriaffor specific conditions on the selection of auditors and FSRC members.
? 2.5 Trainina 1
1 42.
Commit to providing training to FSRC members 4n-audit precedure; and on possible error modes of management control systems.
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43.
Includepsrformanchihased.QAtrainingintheformal, planned,and documented training' prog' ram for all LES employees.
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44.
Appfopfisti training should also incidde eevee visitors and contractors.
A5.
Commit to providing indoctrination training to all employees before they-perform work at the CEC.
46.
Training should also address Part 19 issues and environmental protection.
47.
Training and retraining should also include chemical and industrial l
hazards, in addition to radiological and criticality safety. control.
l 48.
Add fire safety preparedness to the disciplines included in the indoctrination training of employees.
j 49.
Delete the last full sentence on Page 2-9.
f 6 2.6 Operatino Procedures t
50.
The sentence beginning "Before initial enrichment" should be changed to l
reflect that procedures will be in place and all training on procedures will l
be conducted prior to initiation of operations. The part about availability i
for NRC inspection should be deleted.
Procedur-es-ere ah-: ys available for imC
-inspection.
i 51.
State clearly in this section that procedures will identify limits and l
controls important to safety.
52.
State e4ea ly in this section that there will be procedures for the maintenance and testing, of systems and components, and instrumentation (including calibration) important to safety.
53.
Procedures should be reviewed for adequacy at least once every two years (maximum intervals of 27 months).
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6 2.6.1 Preparation of Procedures 54.
Define term " required procedure." Suggest revising first line to read:
"Each precedure-4eveMeg licensed =terial; shall be prepared..
55.
In the first paragraph, " Safety-related procedures," should be changed to " Procedures important to safety."
-56.
Move the second paragraph to Section 2.6.
57.
Clarify whether the independent review is to be outside the department or outside LES.
5 2.6.2 Chances to Procedures 68.
Under A, add "shall" after "preparcr" and make " document';" ;ingulaer 50.
Under B, r+vi ;c "t4te-change i'; not impicment+d" to "the-change shah-not-be implemented."
60.
Under C, add " ant or marc" af ter "by", deletc "a" and make "rc.iewer" I
phr++r 61.
Under D, identify the position titles under which chemical and/or l
radiation safety, criticality ';afet-y and MC&A reviews will be performed.
i 62.
Include a review on the effect of changes in radioactive environmental f
effluents.
s 2.7 Internal Audits and Inspections
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63.
Define audits and inspections withoutireference_ toLRegulat'opyjJu'ide; j
3.52.
64.
Include preventive maintenance, training, emergency planning, and QA in the list of minimum activities to be assessed by the audit program.
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- 65... Define " annually" and " semi-annually." Specify.ths.imaximum"intsrvall for each period, such as annually = 360 1 30 days.' These :should be; placed.in the definitions section.
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2 66.
Clarify if the audit discussed in this section is the same as that conducted by the FSRC. Page 2 12, fir';t parageaph, to the4est sentence-edd+
"he-eath--of-the-ar+a "
67.
Page 2-12, second paragraph:
= inspections is in the midst of paragraphs concerning audits.
It should be moved to the end of Section 2.7.
delete " routinely" and insert "in accordance with a written plan.
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Also in the second sentence, replace semi-annually by " quarterly."
third sentence: insert after " action," "shall _ be documented in a
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written report going to the apprcpriate level of management manager for j
follow-up action."
clearly indicate who (by position title /s) is responsible for the
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inspection program.
6 2.8 Investications and Reportina 68.
Suggc';t rcvi+4eg-4hc first paeageaph:
Tc c+mply 4,ith Spccis4-hc4eae Material repor+ing-+equirements (e.g.,10 C.F.P. s 70.50), off normal l
oesurrences shall be reported to and investigated by the Compliance
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Super-intendent.
Repoet-ing any r+por4aMc accurrence to the-appr+pr4ste egency(s) shall be the responsibility of the Comp 14ance Superirttendent-i 69.
Investigations should include root cause analysis.
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70.
Environmental protection should also be addressed +f apprcpriate.
Chapter 3.0 Radiation Protection l
1 6 3.1.1 ALARA Policy 71.
There should be a commitment to prepare an ALARA report at least f
annually. The report should include reviews of radiological exposure and effluent release data for trends; required audits and inspections; and the use, maintenance, and surveillance of equipment for exposure and effluent control.
72.
Identify the position responsible for preparing the ALARA report. Commit I
to submitting it to the CEC Manager, and the members of the FSRC.
6 3.1.2 Radiation Work Permit Procedures 73.
Suggest the word closecut instead of termination of the RWP.
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74.
RWPs should be issued for activities at a fraction of the levels i
specified in the regulations.
75.
The RWP should be posted at the location of the work area.
k 76.
Second bullet.
Add Radiation Control Zones (RCZs) to Radiation Control Areas (RCAs). Add RW "radicactive cont =ination" by " radiation exposures i
exceeding action levels" tol"radioastipsidontaininstion{"
77.
Delete the first sentence of the third bullet.
l 6 3.1.3 Written Procedures 78.
Add the word " written" between " approved" and " procedures."
i 6 3.2.1 Restricted Area-Personnel Contamination Control l
c 79.
Describe the minimum protective clothing required in RCAs and RCZs.
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80.
Last sentence. Describe the type of monitoring that personnel will be required to perform upon pers_onnel exiting the RCA.
Include the type /s of instrument /s that will be~used.
i 81.
Third line. Add " external" before " radiation levels."
82.
For clarity, separate discussions of RCA and RCZ.
6 3.2.2 Ventilation 83.
Spellj6ut DeHne "TSA."
S4.
Sec-end4isc.
"Particdate" should be plural.
85.
Commit to using filters.
Provide filter types, the+e particulate removal efficiencies, thefe testing and criteria for replacement.
l 86.
Previde the air flow rate theeugh-the plant exhaust stack.
87.
Require filters to be replaced if the filters ee-e*haust system fails to function properly or if the differential pressure exceeds the manufacturer's rating for the filter. The integrity of the HEPA filters Systsm should be evaluated based on some criteria (i.e pressure differential scross the filter). ANSIL guidance l5i111belacceptable; l
6 3.2.3 Work Area Samolina 88.
Set action levels for investigation and corrective action.
t 89.
The representativeness of the work station air samplers should be l
checked annually as well as when process or equipment changes have been made.
l 90.
Second paragraph.
State whether the Alpha-in-air monitors are active or passive.
Identify the radionuclides for which airborne concentrations will be determined using Alpha-in-air monitors.
Provide the LLDs for these radionuclides.
91.
Commit to provide locations of air monitor; for "RC review and appeeval prior to operations.
7 92.
Second paragraph, third linc.
Insect " air" between " continuous" and
" samples."
93.
Second paragraph, fourth line.
Insert "and analyzed" between " changed" and "at."
94.
First bullet, first line.
Replace "or" by "and."
Replace " leading" by "that may lead." On the second line, insert a comm; after the first word
("eran4cm") and " concentration" should be plural.
j 95.
Second bullet, first line.
Before "following," replace "or" by "and."
96.
Last paragraph. Move this paragraph to Section 3.2.6 entitled " Surface Contamination."
l 97.
Provide action levels in terms of radionuclide air concentrations and describe the actions to be taken if these leve7s are exceeded.
i 6 3.2.4 Radioactivity Measurement Instruments a
Need in appropriate section of License Conditions, a commitment to leak 98.
test calibration sources. Seen. heS. tandafdM_ond.i.ti6ns; a.t.t. achedit_o.Tthis I,
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99.
Provide more detail in this section such as theltypes a list of l
instruments, rangeQtheir alarm set peints, calibration requirements, and maintenance requirements., etc.
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99'ai (Shc6 rid?pahgriphMDsistii!"Tschhids115sFvitesjkeal6Kthe.in 6 3.2.5 Radiation Exposure 100.
Replace "Whole Body:" by "TEDE:" which is the total effective dose l
equivalent and consists of an annual exposure resulting in a 50-year committed internal dose component and an external dose component.
i 101.
s 3.2.5.1, second bullet. Move information contained in this bullet to Section 3.2.6 entitled " Surface Contamination." Describe the minimum protective clothing requirements for areas with removable surface contamination greater than 1000 dpm/100 cm2 beta-gamna or greater than 20 i
dpm/100 cm2 alpha.
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6 3.2.6 Surface Contamination 102.
Pro' vide Dewr4be nethods of surface contamination surveys.
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r 103.
Specify survey frequencies.
104.
Surveys should be conducted for areas other that just the UF6 process
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areas.
For example the TSAR storage areas, change rooms, cafeteria, etc.
105.
Specify the limits for cleanup.
E 3.2.7 Bioassay Procram 105.
First paragraph. The fir.st sentence may be interpreted as a commitment to perform bioassay measurements for all personnel wearing external dosimetry devices.
Is this the intent?
If not then provide criteria for performing bioassay measurements.
107. Commit to conducting bioassay measurements in accordance with guidance associated with 10 CFR 20. Describe the bioassay program by providing measurement methodologies, sample collection frequencies, MDAs, etc.
l 108.
Commit to evaluating internal doses quarterly.
l 109.
Bioassay should occur sooner than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after suspected or known exposures.
Specify the time period that would allow detection of an intake of 10 mg.
110.
Set action levels for work restriction.
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Chapter 4.0 Nuclear Criticality Safety 111. Commit to including nuclear criticality safety limits on parameters to l
be controlled and corrective measures to return a parameter to its normal control band in the operating procedures.
14.1.2. Manactment Responsibilitics I
112.
Second paragraph. Add the fcllev.ing sentence at the end of the ;ccond paragraph "This process shall consider the rc ults of nuclear criticality safet-y inspection; and audits."
6 4.1.4 Doeratina Procedures 113.. Commit to conducting nuclear criticality safety department activities, whichEsrelrequired~byithe license, in accordance with written procedures.
56th proceoures shallbe'napprovid 'by the nuclear safety manager.
114.
Following treatment of used Fomblin oil but prior to releasing the oil from safe mass control, commit to analyze two independent samples for both the waste and the recovered Fomblin oil. Agreement between sample results shall be obtained or the entire sampling and analysis process shall be repeated.
I 115. Commit to analyzing every week at least two independent samples of the contents of each efflusht collection tank in the UF handling area. Agreement 6
between sample results shall be obtained, or the tank shall be resampled.
If the V content exceeds 100 ppm, LES shall sample the tank on each operating shift until the source of the uranium is identified and controlled.
t 116. Commit to analyzing' two independent samples of each TSA effluent collection tank when one-half full and prior to discharge. Agreement between results shall be obtained or the sampling process shall be repeated until agreement is obtained.
If the contents exceeds 1000 grams uranium, corrective action shall include hourly sampling until the source of the uranium is identified and controlled.
116a/Th'e;;11censee5halliin.slyze?tsofindEpe6 dent {ssmpl#siofJthsMitFiciaEid.
baths each week?asswelltas,Lindependent(sample's4 whenstheftankicontentscreach; estimated.40%,160%,i;an'd:85L od theJtankisafe smassilimit? Agreement shalli be"
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obtainedxbetweeniboth; analyses:;orfnew samplesGhall.1be?analyzedi 51f(theT '
e s t imat ed :1 i mi ti arei exceeded Mcbrrect i veiacti on s; shall d i ncl udel adjust i nF the tank (inventory l record L and? investigating [the?c'ausef of[thsEnonconservat i' e ~
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- estimate, 117. Commit to limiting the Chemical Laboratory area to not more than 7.0 kilogram of uranium. The administrative limit shall be ensured maintaining a current inventory by logging transfers into and out of the laboratory.
HB.
L;;t paeagraph.
Provide the action levch and actions to be taken if Mc:e levch are exceeded, for accumuhtien of uranium in filter; and duct i
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119. Commit to surveying vent htica ducts servicing the enriched uranium processing areas annuallyf(fsjsini!mumjihalllinsiddefem6v)ilEofnthelur.ani.umi maximum interval of 15 months.
IfiffiniuRis I
foUndscoreectiVelacti6ntas E 4.1.5 Postina 440.
Provide details regarding posting of criticality safety limi-t; in t-he l
TW S 4.1.5 Pereceration: Testiac and Inscccticn 141.
!nsert " criticality" before ";afety evaluations."
6 4.1.7 Desian Procedures 122.
Commit to establishihg a configuration control program shich and, with 90 day; cf the isseance of the license, submit it to the NRC f5(spproval.
The conf 4 eeation conteel program shall, as a minimum, include the following:
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a.
For all possession, use, and storage activities with enriched uranium at the facility, LES shall maintain written records of:
(1) the current description of all enriched uranium processes at the facility, (2) a current identification of potential criticality accidents which were identified by a i
systematic achident haaards analysis process for all current activities, (3) for each of"the" potential criticality accidents identified above, a current safety analysis which identifies all necessary limits on parametric controls to prevent an inadvertent critical configuration, and (4) administrative requirements to ensure that the engineered systems to limit the parametric controls will be installed, maintained, and operated as designed.
b.
For each potential criticality accident identified above, LES shall implement and maintain independent engineered or administrative controls such that the double contingency principle of ANSI /ANS-8.1 is satisfied.
c.
In addition to identifying the limits and controls in (a) above, LES shall document the requirements for maintenance, surveillance, personnel training, posting, and control of written procedures to ensure the effectiveness of the limits and controls.
123.
Prior to the use of vacuum pumps, LES shall provide to the NRC a safety analysis which demonstrates the use of the LES' solid angle method for safely spacing vacuum pumps, and shall obtain NRC approval of the use of the solid angle method.
6 4.2.2 Multiple Units or Arrays 124.
Prior to using the MONK code for CEC process design changes which are made without NRC approval, state that a summary report on the MONK code will be provided tofthe?NRCif6riappr69al. The report shall specify the range of applicability W d'bther paFameten specified in ANSI /ANS-8.1. The validation report shall be maintained at the CEC facility.
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l 125.
Commit to maintainihg a minimum 30-centimeter spacing, edge-to-edge, between units spaced by the surface density method.
k 4.2.4 Special Controls MS.
Oclete-the first sentence.
It is not c licen:c cond m ent j
127.
For the centrifuges, cascades, and assay units, thsifollbwihp
- c. 6mmitsents_jsh6ul.d_ibefma.de -^-
4'
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a.
Limit the maximum inside diameter of the centrifuge housings to the safe diameter specified in Table 4.2-1 of the Proposed License Conditions.
b.
Intr, duce no enriched uranium as feed material to the cascades.
c.
Provide control room monitoring of cascade header pressure, power, feed supply power, feed supply pressure and valve position, cooling water temperature and flow, product take-off system pressure and valve position, and i
tails take-off system pressure and valve system.
For unusual monitoring i
4 results, procedures shall describe corrective action including shutdown requirements.
d.
Provide no interconnections which would allow enriched uranium to flow i
to the feed system.
j e.
For each authorized enrichment campaign, calculate the control valve i
settings and instruct the operators, in writing, of the correct valve settings. The new valve settings shall be independently confirmed and j
recorded.
If resulting pressures do not compare with predicted pressures, corrective actions shall be initiated.
i f.
For each new campaign, analyze the UF6 product for enrichment within 24 l
hours and compare the results with predicted results.
If an adjustment is required, the actions in (f) above shall be repeated.
g.
Analyze samples from each cascade at least every 6 months (maximum 7 month intervals) for enrichment. Adjustments to operating parameters shall be j
made, if necessary, as in (f) and (g) above.
128.
For the product take-off system, theif6110 wing")cominitmihtUshBuldsbe l
made eemev&-te:
a.
Verify by cylinder weight, baroscope inspection, and vacuum testing that no internal contaminants are present before the cylinder is brought to the t
loadout area.
b.
Limit the contents of each product cylinder to-the authorized fill limit by use of the continuously monitored load cell system.
Prior to initial use of the load cell system, a maintenance and test program shall be developed and implemented.
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c.
Vent volatile gases to the Product Vent System.
Investigations shall be conducted and corrective actions taken whenever a predetermined number of vent cycles per cylinder has occurred.
i d.
During and after filling cylinders in the product filling station and prior to moving the cylinder, solidify the UF only with cool air.
6 e.
Heat product cylinders for blending or sampling only in autoclaves and
.(
only by using electrically heated air. The autoclave pressure and temperature shall be automatically controlled, continuously monitored, and alarmed during l
the heating cycle. After blending or sampling, but prior to moving the cylinders, solidify the UF by circulating water in. structurally independent 6
cooling coils which are external to the autoclave.
j f.
Limit the hydrogen to uranium ratio to not more then 1.0.
129. On a quarterly basis (maximum interval of 4 months), LESisil1JsdH69 eemst-to inspect the product and product blending desublimirs" tFvsFify that i
no solid uranium compounds remain in the desublimers after the UF is 6
transferred to the product cylinders.
If uranium solids are present, the i
material shall be removed prior to reuse of the desublimer system.
t 130. For each product and product blending desublimer system, ths7follbwihg
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cominitmihts9houldibejmads ccmmit to:
i a.
Use only chemical traps, pumps, and piping which satisfy the geometric i
i limits specified in Table 4.2-1, of the Proposed License Conditions.
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b.
Maintain a positive pressure nitrogen atmosphere between the inner i
desublimer vessel and the outer shell. The positive pressure shall be
'i continuously monitored and alarmed to detect loss of atmosphere.
c.
Heat and cool the desublimer vessel by freon in external closed loop heating and cooling coils.
d.
Fit each inlet and outlet pipe with two valves in series, each of which l
is automatically operated by signal from continuous monitoring presscre and temperature sensors.
i e.
Record the number and frequency of cylinder vents to control the i
desublimer inventory and to detect abnormal venting intervals.
Any abnormal venting shall be investigated.
f.
Develop and implement a preventative maintenance and test program for the nitrogen pressure monitor alarm system, the pressure temperature sensors and valve system, and the vent frequency and interval monitoring system.
j 131.
Fc-chemical traps for mobile pump sets, theffol16winij Mommitmsnts shdulldl5Tmadecommitto:
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r a.
Limit the trap inside diameter to 18.5 centimeters.
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b.
Limit the pump free volumes to not more than 7 liters.
1 c.
Limit the K, of each pump set to not more than 0.93.
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d.
Provide a frequency for weighing and replacing the activated carbon in the chemical traps.
r 132.
Provide a survey frequency for verifying that no uranium is i
accumulating in the contingency dump traps.
Provide action levels and l
corrective actions to be taken if the action levels are exceeded.
133.
For contingency dump traps, the;following commitsents{sheildlb@ mads ecmmit to:
~
a.
Limit the inside diameter of the dump traps to not.more than 51.7 centimeters.
t b.
Prior to use, independently verify and document that the contingency traps have been loaded with the correct amount and type of NaF power and pellets.
c.
Replace the trap media immediately following an emergency dump.
i 134.
For process piping, commit to limit inside diameters of process piping to not more than 21.9 centimeters. When the process requires pipe bends or pipe intersections, the piping shall fit inside a maximum 18 centimeter inside diameter envelope.
Chapter 5.0 Environmental Protection 135. Add page numbers to the figures and tables.
6 5.1 Effluent Control Systems 136. At a minimum, there should be a commitment that radiological effluent i
streams are treated.
i 6 5.1.]
Gaseous Effluents 1
137.
Filters should be removed at least daily and analyzed for gross alpha and not weekly as stated.
138. Composites of the daily samples should be done quarterly and analyzed for uranium with an LLD of less than or equal to IE-18 pCi/ml.
i 139. Th'eltext?isLunclear Chrify whether action levels and LLDs are for the l
weekly or "qu'a'rterly ~analysi s. Action levels and LLDs should be set for both the daily and quarterly samples. Clafifyjtheparagraph3 140. Suggest adding a commitment as follows:
"If a parameter important to the dose assessment changes, a report shall be submitted within 30 days which describes the changes in parameters and includes an estimate of the resultant
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change in dose commitment.
In the event the calculated dose to any member of the public in any consecutive 12-month period is about to exceed the limits specified in 40 CFR 190.10, immediate steps shall be taken to reduce emissions so as to comply with 40 CFR 190.10. A report shall be prepared and submitted to the Commission within 30 days which identifies the cause of exceeding the limit and the corrective actions to be taken to reduce release rates."
441.
In T,abic 5.1 1, why are the action levels different for the 3 units?
l They should be the same.
- 5.1.2 Liouid Effluents 142.
In the first paragraph LWD should be spelled out.
143.
In the second paragraph, the reference to Part 20 release limits should contain the Part 20 Table number.
144.
It is not clear if the LWD or the STS sample is the one to be used to show compliance with Part 20.
Please clarify.
145.
Composites of the compliance sample should be analyzsd donc and samined
^
quarterly for uranium and for Tc-99. Specify LLD for these samples.
146. The LLD for the STS sample should be much lower than (at least a factor of 10) as-opposed to at the range of the action level.
147.
Specify the LLD for gross beta.
148. The sludge from the STS system should be sampled semiannually for uranium accumulation.
Provide Suggest adding the following commitments:
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149.
i The NRC shall be infomed within 30 days if the State-permitting agency revokes, supersedes, conditions, modifies, or otherwise nullifies the effectiveness of the State-issued HPDES permit for the discharge of liquid effluents.
The NRC shall be informed within 15 days if the State-issued NPDES permit for the discharge of liquid effluents is violated.
150. Second paragraph. Clarify lthat State whether the Sewage Treatment System effluent is released ori a~ continuous or batch basis.
Commit to conducting continuous ee-bateh sampling accordi+ gly.
151.
Last paragraph. Add "less than or equal to" after " activity shall be."
6 5.2 Environmental Monitorina 152.
In the first line change the word " establish" to " implement." SpecM y when-the program..ill be implemented:
1 453.
Change; to the program specified in the license condition cannot be made-et4teut prior NRC-epproval.
Aspects that are not specified in the license conditions can be chenged 0; stated.
154.
Commit to reviewing monitoring data on an annual basis for trends and evaluate impacts to the public and environment.
l 155.
First paragraph. Add sampling of sediment to the ' ist of media to be l
sampled.
Insert, after " program" inflinell,; "in accordance with Table 5.2.1."
156.
On page 5-3, 3rd paragraph, Specify the LLD for uranium and gross beta.
Also add the LLDs for soil and vegetation samples.
i Table 5.2-1 Radiological Monitorina Proaram 157.
Suggest splitting this table into 2 separate tables, one for the
[
l preoperational and one for the operational program. This will make it easy to remove the preoperational requirements once the facility receives licensed l
material.
i 158.
Clarify what the analysis frequency is. Describe how composite samples are done.
Be sure to include the quarterly composite for air samples that is analyzed for uranium (at a minimum this should be done at the sample location j
for the nearest resident).
159.
Reinsert a brief description of the sampling locations.
Include a j
sample number for easy reference. Delete the word " potential."
r 160.. Storm-water sampling should be included, this could be at the hold up basin.
j 161..
The table s,tates that all surface water samples will be collected on a j
continuous basis'.
Is this your intent?
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162.
Table 5.2.1.
Delete: Note #2: iThese. terms 3 hould!bsidefinedLin thi definitions;section. Hetc f2.Ocfines unh s Mistics in p6rcen n des.' Change i
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thE dhttFt44htyificm percentages to whole days.
Table 5.2-2 Action levels for Environmental Analyses 163. Add the levels for gross beta and uranium.
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164.
Replace "yCI/ML" by "pCi/ml" and pCI/G "by" "yCi/g."
i Chapter 6.0 Special Processes j
i 6 6.2 Occupational Safety 165.
Provide action levels for HF and the corrective actions to be taken if these are exceeded.
Provide exposure limits for HF.
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! 5.3 Back ur Utilitics ISS.
Provide the min 4 mum time that back up power aill be provided to criticality alarms during ; loss of power event.
6 6.5 Limitina Conditions for Operation 6 6.5.1 Autoclaves 167.
In item a, change "with any autoclave" to "any autoclave with.
Add "*"
between "260" and "F."
168. Based on the SAR, there is no reasca to believe that CEG-oced; to operate such that the feed autoclave pressure shouldinotibe 4s higher than 44 psia, and sampling and blending autoclave pressures'shouldindt}be are higher than 87 psia.
6 6.5.2 Yard Transporters 169. Gue-analysi hows that The fuel capacity should not be greater than approximately 70 gallons.
6 6.6 Other Special Commitments 170. Aad section on product and feed cylinder maintenance and surveillance.
171. Statifthat none of the feed, product and tails cylinders Wil1 should be stacked.
4 6.6.1 Tails Cylinder Maintenance and Surveillance 172. Under D, after "only designated vehicle" insert "with less than 70 gallons of fuel."
173. Under F, blariffiLES'Ti.ntentiod state the frequency or time frame fee 1-he anti-corrosion' treatment.
174. Under H, need to define what is "significant deterioration" and to develop procedure to resolve "significant deterioration problems in the storage yard."
175. Need to add Section 6.6.4 stating the following: " Final design of the CEC will involve the structures, equipment, equipment layout, control systems logic, and safety features presented and described in the_SAR.
The design and construction will be in accordance with the standards identified in the SAR."
6 6.6.2 Liouid UF6 176. Delete "and cannot by design."
i Chapter 7.0 Decommissionino Plan i
177 Spell out-what is acent-by " cessation of cperations."
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178.
In the fourth line the text should read "to levels acceptable for unrestricted use."
179. Commit to promptly cleaning up spills and contamination outside normally-contaminated plant areas-.
Chapter 8.0 Radioloaical Continaency Plan t
i
-460-State-that-ehanges which do not decrease the effectivenc;; cf a CEC ; dan i
een be made a&thout NRC approval and that t-hese change; ;hould bc submitted t-e the NRC withio some ;ct time frame.
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181.
Change the title to " Emergency Plan."
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ATTACHMENT (Page 1 of 2)
LICENSE CONDITION FOR LEAK TESTING SEALED SOURCE WHICH CONTAINS ALPHA AND/OR BETA-CAMKA EMITTERS APRIL 1993 A.
1.
Each cealed source containing more than 100 microcuries of beta and/or gamma emitting material or more than 10 microcuries of alpha emitting material, other than Hydrogen-3, with a half-life greater than 30 days and in any form other than gas, shall be tested for leakage and/or contamination at intervals not to exceed 6 months.
In the absence of a certificate from a transferer indicating that a test has been made within 6 months prior to the transfer, a sealed source received from another person shall not be put into use until tested.
2.
The periodic leak test required by this condition does not apply to sealed sources that are stored and not being used.
Prior to any use or transfer to another person, the source shall be leak tested unless they have been tested within 6 months prior to the date of use or transfer.
B.
The test shall be capable of detecting the presence of 0.005 microcuries of radioactive material on the test sample. The sample shall be taken from the sealed source or appropriate accessible surfaces of the container or from the device where the sealed source is mounted or stored in which one might expect contaminatzon to accumulate. Records of leak test results shall be kept in units of microcuries and maintained for inspection by the Commission.
If the test reveals the following:
1.
The presence of 0.005 microcuries or more of removable contamination from the sealed sources other thau described below, or 2.
The presence of 0.05 microcuries or more of removable contamination from the teletherapy sealed source, or 3.
An indication that the irradiator sealed source which is stored in the water pool for shielding purposes is leaking.
The licensee shall immediately withdraw the sealed source from use and shall cause it to be decontaminated and repaired by a person appropriately licensed to make such repairs or to be disposed of in accordance with the Commission regulations.
Within 5 days after determining that any source has leaked, the licensee shall file a report with the Division of Puel cycle Safety and Safeguards, U. S. Nuclear Regulatory Commission, Washington, DC 20555, describing the source, test results, extent of contamination, appatcut or suspected cause of source failure, and corrective action taken. A copy of the report shall be sent to the Administrator of the NRC Regional Office having jurisdiction listed in Appendix D, Title 10, Code of Federal Regulations, Part 20.
ATTACHMENT (Page 2 of 2)
LICENSE CONDITION POR LEAK TESTING SEALED URANIUM SOURCES APRIL 1993 A.
Each uranium source shall be tested for leakage at intervals not to exceed 6 months. In the absence of a certificate from a transferor indicating that a test has been made within 6 months prior to the transfer, the sealed source shall not be put into use until tested.
B.
The test shall be capable of detecting the presence of 0.005 microcurie of alpha contamination on the test sample. The test steple shall be taken from the source or f rom appropriate accessible surf aces of the device in which the sealed source is permanently or semipermanently mounted or stored. Records of leak test results shall be kept in units of microcuries and maintained for inspection by the commission.
C.
If the test reveals the presence of 0.005 microcurie or more of removable alpha contamination, the licensee shall immediately withdraw the sealed source from use and shall cause it to be decontaminated and repaired by a person appropriately licensed to make such repairs or to be disposed of in accordance with the Commission's regulations.
Within 5 days after determining that any source has leaked, the licensee shall file a report with the Division of ruel cycle safety and Safeguards, U.S. Nuclear Regulatory Commission, Washington, DC 20555, describing the source, test results, extent of contamination, apparent or suspected cause of source failure, and the corrective action taken. A copy of the report shall be sent to the Administrator of the nearest NRC Regional Office listed in Appendix D of Title 10, Code of Federal Regulations, Part 20.
D.
The periodic leak test required by this condition does not apply to j
sealed sources that are stored and not being used. The sources excepted from this test shall be tested for leakage prior to any use or transfer to another person unless they have been leak tested within 6 months prior to the date of use or transfer.
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ENCLOSURE 2 Attendees of meeting between LES and NRC at OWFN August 16, 1993 HyjE TITLE ORGANIZATION PHONE #
y Yawar Faraz Asst. Proj. Manager NRC/FCEB (301)504-2669 Merri Horn Env. Proj. Manager NRC/FCEB (301)504-2606 Jerry J. Swift Reviewer NRC (301)504-2609 Lidia A. Roche' Proj. Manager HMSS (301)504-2695 George H. Bidinger Sr N.P. Engineer NRC (301)504-2683 Gene Holler Attorney NRC (301)504-1520 Joe Price SER Task Manager SAIC (301)353-8374 Peter LeRoy LES Licensing Mgr.
LES (704)382-2834 Erich Kraska Sr. Technical Mgr.
(202)337-6644 Donald Joy MC&A Technical Review NRC (301)504-2352 Dave Ditmerer Security NRC (301)492-4144 John Hickey Chief, FCEB NRC (301)504-3425 i
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