ML20057A088
| ML20057A088 | |
| Person / Time | |
|---|---|
| Site: | Claiborne |
| Issue date: | 09/01/1993 |
| From: | Jim Hickey NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Leroy P LOUISIANA ENERGY SERVICES |
| References | |
| NUDOCS 9309130024 | |
| Download: ML20057A088 (17) | |
Text
- - -
- = _ -
Docket No. 70-3070 MA y US]
Mr. Peter G. LeRoy Licensing Manager Louisiana Energy Services c/o Duke Engineering & Services, Inc.
P.O. Box 1004 Charlotte, NC 28201-1004 j
i
Dear Mr. LeRoy:
j On August 24, 1993, we provided you with our revised comments on your proposed license conditions of June 18, 1993.
The revised comments contained editorial marks, so that you could see the changes from our original comments dated August 11.
Enclosed is a " clean" version of our August 24 comments with the editorial marks deleted. Note that we also added general comment #7 and i
comment #120, deleted comment #9, revised comment #25 and renumbered it #18, and renumbered all comments.
With respect to your request for a partial exemption from criticality monitoring requirements (proposed license condition 1.6.2.A), we had previously indicated that a partial exemption might be justified. However, upon further review, we do not anticipate granting the exemption.
The basis for your request is that a criticality event is unlikely in several areas.
This is not a sufficient justification.
The monitoring requirements in 10 CFR 3
70.24 presume that a criticality event is unlikely, but that monitoring should nevertheless be provided in the unlikely event that a criticality event should i
occur.
Therefore, you should promptly supplement your Safety Analysis Report j
to address required criticality monitoring in all areas where critical mass quantities of enriched uranium will be present, including process, product storage, and product shipping areas.
{
Sincerely,
)
Original Signed By John W. N. Hickey, Chief
'I Enrichment Branch i
Division of Fuel Cycle Safety l
and Safeguards, NMSS
Enclosure:
As stated cc:
Attached list RISTRIBUTION: Docket No. 70-3070 NRC File Center PDR/LPDR RFonner, OGC YChen JSpraul EHoller, OGC GBidinger CCain, RIV CNilson, RES YFaraz AGiarratana DJoy MVasquez, RIV RBrady, SEC TCombs, GPA DMartin MHorn FCEB r/f NMSS r/f JSwift RBurnett 0FC FCEB FCEB/,
FCEEl)
FCEB FCEB LRoche'/i) NkrIin Jhey NAME Y f/93
/
/93
/
/93 DATE
- 0) /
/93 f/ /93
/
/
C = COVER E = COVER & ENCLOSURE N = NO COPY (G:\\LESLC.LTR) 0FFICIAL RECORD COPY fSb0 NOS E col [@ [fM b
ENCLOSURE September 1, 1993 l
t REVISED NRC STAFF COMMENTS ON LES' PROPOSED LICENSE CONDITIONS NOTE: These comments are the same as comments dated August.24, 1993, except
-general comment #7 and specific comment #120 are added, former specific l
comment #9 is deleted, former specific comment #25 is revised and renumbered i
- 18, and all specific comments are renumbered.
j!
General Comments i
1.
Include a definitions section.
2.
Whenever the license conditions designate a named official "or designee" l
delete "or designee."
3.
Replace "ss 20.1001-20.2401" by "5s 20.1001-20.2402."
i I
4.
Consider implementing a tracking system which should include corrective I
actions from audits and inspectors' findings.
I l
5.
There is no need to propose commitments that are already required by regulations.
t I
6.
Regarding validation of computer codes important to safety and r
safeguards and verification of software important to safety and safeguards, j
include the requirement that software control will be in accordance with Part 6
i 2.7, " Quality Assurance Requirements of Computer Software for Nuclear Facility Applications," of the NQA-2b-1991 Addenda to "ASME NQA-2-1989 Edition Quality Assurance Requirements for Nuclear Facility Applications" or some other acceptable software QA standard.
For nuclear criticality safety codes, see comment #124.
7.
Regarding quality assurance of items and' activities important to safety and safeguards, include the requirement that quality assurance controls will i
be in accordance with the ASME-NQA-Ib-1991 addenda to "ASME NQA-1-1989 Edition j
Quality Assurance Program Requirements for Nuclear f acilities."
I Specific Comments
{
Chapter 1.0 Standard Conditions and Special Authorizations 6 1.1 Name. Address. and Corporate Information j
i 1.
First line. Delete "LES" before " Louisiana Energy Services, L.P...."
j t
2.
Delete second and third sentences.
i 3.
Add site address.
l l
r l t
'i i
E 1.2 Site location 4
Define the areas where licensed activities are to be conducted.
l 5.
Delete the last three sentences.
l 6 1.3 License Number and Period of License e
i 6.
Delete this section.
6 1,4 Possession Limits 7.
Possession limits should be given in metric units with English units in parenthesis.
E 1.4.B Source Material j
8.
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 1.4.C Byproduct Material 9.
Delete the paragraph beginning with " Additional radionuclides may be..."
including the two bullets. 'LES can not add additional radionuclides without NRC approval.
E 1.5 Authorized Activities t
10.
Add uses of the individual byproduct radionuclides.
11.
s 1.5.D.
Revise this statement to read as follows:
" Chemical, spectrometric, radio-chemical, and non-destructive assay analyses of Source Material and Special Nuclear Material, including effluents and stored waste.
12.
% 1.5.E.
Delete the words " hazardous" and " industrial." The NRC does
-i not authorize treatment, etc., of hazardous and industrial wastes.
{
r I
E 1.5.1 Location Where Material is Used l'
13.
Do not describe processes where licensed material will be used. Just identify the locations where licensed material will be used.
For example, i
delete the following sentences:
First paragraph, first and last sentence.
Second paragraph, all except first and fifth sentences.
l l
61.6 Exemptions and Special Authorizations 14.
Commit to updating the SAR and ER at least every two years.
I i
i
! i i
}
~
i i
E 1.6.1 Safety Evaluation Process l
l 15.
Commit to informing the NRC regarding changes which affect but do not
{
decrease the effectiveness of the QA program as described in the SAR.
Also specify a frequency for submitting the changes.
16.
Delete item (b) since it is required by regulations.
17.
Add items f, g, and h to the list as follows:
f) unreviewed safety l
issues, g) a significant change in the types or significant increase in the amounts of any radioactive effluents that may be released off site, and h) a significant increase in individual or cumulative occupational radiation l
exposure.
l
[
G 1.6.2 Exemptions and Special Authorizations 18.
Note that 1.6.2.A is based on a letter we sent you on December 23, 1992.
However, the condition should be deleted because the staff does not anticipate granting an exemption from 10 CFR 70.24.
19.
Under 8, commit to inform the NRC of a change within 60 days so that the staff has an up-to-date record of CEC owners, lienholders, etc.
l i
20.
Under C, add the date of the Guideline and state that it is provided as Appendix A.
Section 1.8 can then be deleted.
f
[
6 1.7 Financial Information and Commitments 21.
The once-a-year reporting required by License Condition 1.7.A is sufficient for sale-leasebacks provided LES considers sale-leasebacks to be changes in ownership and plans to report them.
However, for limited partner
(
changes, commit to report the information within 60 days.
!_1.8 Reference for Section 1 l
22.
Delete this section.
Chapter 2.0 Oraanization and Administration s 2.1 Croanizational Responsibilities and Authority j
23.
Provide organization chart /s for safety and safeguards related positions.
24.
Under H, last word; capitalize first letter of the word " manager."
25.
Under K, for the HP Manager, provide the type of equipment in the statement " training of personnel in the use of equipment."
l
. l I
I e
-w l
i i
6 2.2 personnel Education and Experience Reauirements l
26.
State that the CEC Manager shall have, as a minimum, a bachelor's degree in an engineering.or scientific field and six years of responsible nuclear experience.
27.
State that the QA Manager shall have at least two years experience in a QA organization at a nuclear facility.
i 28.
State that all Superintendents shall have, as a minimum, bachelor's l
degrees in an engineering or scientific field and four years of responsible j
nuclear experience.
29.
Include the responsibilities and qualifications of the Chemistry and Industrial Safety Managers in the License Conditions.
State that the Chemistry, Industrial Safety and Health Physics (HP) Managers shall each have, l
as a minimum, a bachelor's degree in an engineering or scientific field, and at least three years of responsible experience in each of their respective i
areas.
I 30.
The Projects Manager shall have, as a minimum, a BS degree in an l
engineering or scientific field and three years of responsible nuclear i
experience, including one year of experience in the_ administration of nuclear I
criticality safety reviews.
31.
In addition to the requirements established by LES for the nuclear i
t criticality safety analyst and the reviewer, the analyst shall have successfully completed a training program, appropriate to the scope of operations, in the physics of criticality and in associated safety practices.
The independent reviewer shall possess a BS degree in engineering or science 1
and have the equivalent of two years of full time experience as a-trained analyst.
I t
E 2.3 Safety Committee i
32.
The scope of reviews conducted by the facilities Safety Review Committee j
(TSRC) shall include, as a minimum, reviews of ongoing and proposed j
radiological, chemical, industrial and nuclear criticality safety activities and practices.
Radiological, chemical, industrial and nuclear criticality
.I safety investigation, audit and inspection reports shall be included in the t
.revi ews.
33.
The membership of the FSRC shall include a person having, as a minimum, the qualifications of a nuclear criticality analyst.
34.
The safety committee should also review the training program, incident i
reports, root cause reports, and violations of regulations or license conditions.
35.
Provide criteria for the selection of auditors and FSRC members.
l t
I
! l i
f
..~
d 6 2.5 Trainino 36.
Commit to providing training to TSRC members on possible error modes of management control systems.
37.
Include performance based QA training in the formal, planned, and documented training program for all LES employees.
38.
Appropriate training should also include visitors and contractors.
39.
Commit to providing indoctrination training to all employees before they perform work at the CEC.
40.
Training should also address Part 19 issues and environmental protection.
41.
Training and retraining should also include chemical and industrial hazards, in addition to radiological and criticality safety control.
42.
Add fire safety preparedness to the disciplines included in the indoctrination training of employees.
43.
Delete the last full sentence on Page 2-9.
6 2.6 Oneratina Procedures 44.
The sentence beginning "Before initial enrichment" should be changed to reflect that procedures will be in place and all training on procedures will be conducted prior to initiation of operations. The part about availability for NRC inspection should be deleted.
45.
State in this section that procedures will identify limits and controls important to safety.
46.
State in this section that there will be procedures for the maintenance and testing, of systems and components, and instrumentation (including calibration) important.to safety.
47.
Procedures should be reviewed for adequacy at least once every two years (maximum intervals of 27 months).
6 2.6.1 Preparation of Procedures 48.
Define term " required procedure."
49.
In the first paragraph, " Safety-related procedures," should be changed to " Procedures important to safety."
50.
Move the second paragraph to Section 2.6.
51.
Clarify whether the independent review is to be~outside the department or outside LES..
7 I
i 6 2.6.2 Chances to Procedures i
52.
Under D, identify the position titles under which chemical and/or radiation safety, and MC&A reviews will be performed.
53.
Include a review on the effect of changes in radioactive environmental effluents.
[
6 2.7 Internal Audits and Insoections 54.
Define audits and inspections without reference to Regulatory Guide j
3.52.
J 55.
Include preventive maintenance, training, emergency planning, and QA in
)
the list of minimum activities to be assessed by the audit program.
56.
Define " annually" and " semi-annually."
Specify the maximum interval for
{
each period, such as annually = 360 30 days.
These should be placed in the
.j definitions section.
1 57.
Clarify if the audit discussed in this section is the same as that l
conducted by the FSRC.
58.
Page 2-12, second paragraph:
i
- inspections is in the midst of paragraphs concerning audits.
It should be moved to the end of Section 2.7.
l delete " routinely" and insert "in accordance with a written plan.
=
Also in the second sentence.. replace semi-annually by " quarterly."
l third sentence: insert after " action," "shall be documented in a
)
written report going to the appropriate level of management for follow-up action."
I clearly indicate who (by position title /s) is responsible for the
=
inspection program.
6 2.8 Investications and Reoortina l
l 59.
Investigations should include root cause analysis.
j i
60.
Environmental protection should also be addressed.
Chaoter 3.0 Radiation Protection i
I 6 3.1.1 ALARA Policy l
l 61.
There should be a commitment to prepare an ALARA report at least i
annually. The report should include reviews of radiological exposure and j
effluent release data for trends; required audits -and inspections; and the use, maintenance, and surveillance of equipment for exposure and effluent control.
i 62.
Identify the position responsible for preparing the ALARA report. Commit l
to submitting it to the CEC Manager, and the members of the FSRC.
I f
T-
~.
I r
6 3.1.2 Radiation Work Permit Procedures j
63.
Suggest the word "closecut" instead of " termination" of the RWP.
l 64.
RWPs should be issued for activities at a fraction of the levels i
specified in +he regulations.
65.
The RWP should be posted at the location of the work area.
66.
Second bullet. Add Radiation Control Zones (RCZs) to Radiation Control Areas (RCAs). Add " radiation exposures exceedit g action levels" to t
" radioactive contamination."
i l
67.
Delete the first sentence of the third bullet.
6 3.1.3 Written Procedures t
68.
Add the word " written" between " approved" and " procedures."
6 3.2.1 Restricted Area-Personnel Contamination Control 69.
Describe the minimum protective clothing required in RCAs and OCZs.
70.
Last sentence.
Describe the type of monitoring that will be re f red upon personnel exiting the RCA.
Include the type /s of instrument /s tba'. will l
be used.
j 71.
Third line.
Add " external" before " radiation levels."
72.
For clarity, separate discussions of RCA and RCZ.
6 3.2.2 Ventilation
)
1 t
73.
Spell out "TSA."
j 74.
Commit to using filters.
Provide filter types, particulate removal
-l efficiencies, testing and criteria for replacement.
75.
Require filters to be replaced if the filters fail to function properly or if the differential pressure exceeds the manuf acturer's rating for the filter. The integrity of the HEPA filter system should be evaluated based on some criteria (i.e pressure differential across the filter). ANSI guidance i
will be acceptable.
f 6 3.2.3 Work Area Samolina l'
76.
Set action levels for investigation and corrective action.
2 l
77.
The representativeness of the work station air samplers should be checked annually as well as when process or equipment changes have been made.
i I
I l
, ~. _. _ _
=
. =
l 78.
Second paragr1ph. State whether the Alpha-in-air monitors are active or
[
passive.
Identify the radionuclides for which airborne concentrations will be l
determined using Alpha-in-air monitors.
Provide the LLDs for these j
radionuclides.
i i
79.
Second paragraph, fourth line.
Insert "ar.d analyzed" between " changed" i
and "at."
t 80.
First bullet, first line.
Replace "or" by "and."
Replace " leading" by "that may lead."
l 81.
Second bullet, first line. Before "following," replace "or" by "and."
I 82.
Last paragraph. Move this paragraph to Section 3.2.6 entitled " Surface Contamination."
s 83.
Provide action levels in terms of radionuclide air concentrations and i
describe the actions to be taken if these levels are exceeded.
E 3.2.4 Radioactivity Measurement Instruments 84.
Need in appropriate section of License Conditions, a commitment to leak test calibration sources. See the standard conditions attached to this enclosure.
j 85.
Provide more detail in this section such as the types of instruments, ranges, calibration requirements, and maintenance requirements.
l 86.
Second paragraph.
Delete " Technical Services Area of the."
j E 3.2.5 Radiation Exoosure l
l 87.
Replace "Whole Body:" by "TEDE:" which is the total effective dose equivalent.
1 i
4 88.
s.3.2.5.1, second bullet. Move information contained in this bullet to l
Section 3.2.6 entitled " Surface Contamination." Describe the minimum l
protective clothing requirements for areas with removable surface l
4 contamination greater than 1000 dpm/100 cm2 beta-gamma or greater than 20 l
dpm/100 cm2 alpha.
j
]
6 3.2.6 Surface Contamination i
89.
Provide methods of surface contamination surveys.
l 90.
Specify survey frequencies.
l i
91.
Surveys should be conducted for areas other that just the UF6 process areas.
For example the storage areas, change rooms, cafeteria, etc.
j i
92.
Specify the limits for cleanup.
l t !
l 1
r
I i
i E 3.2.7 Bioassay Proaram j
93.
First paragraph.
The first sentence may Le interpreted as a commitment j
to perform bioassay measurements for all personnel wearing external dosimetry devices.
Is this the intent? If not then provide criteria for performing bioassay measurements.
94.
Commit to conducting bioassay measurements in accordance with guidance associated with 10 CFR 20. Describe the bioassay program by providing i
measurement methodologies, sample collection frequencies, MDAs, etc.
l i
95.
Commit to evaluating internal doses quarterly.
l I
96.
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.
97.
Set action levels for work restriction.
Chaoter 4.0 Nuclear Criticality Safety 98.
Commit to including nuclear criticality safety limits on parameters to be controlled and corrective measures to return a parameter to its normal control band in the operating procedures.
l 6 4.1.4 Operatino procedures i
99.
Commit to conducting nuclear criticality safety department activities, i
which are required by the license, in accordance with written procedures.
Such procedures shall be approved by the nuclear safety manager.
i 100.
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.
101.
Commit to analyzino every week at least two independent samples of the contents of each effluent collection tank in the UF handling area.
Agreement 6
between sample results shall be obtained, or the tank shall be resampled.
If the U content exceeds 100 ppm, LES shall sample the tank on each operating i
shift until the source of the uranium is identified and controlled.
l 102.
Commit to analyzing two independent samples of each' TSA effluent l
collection tank when one-half full and prior to discharge.
Agreement between i
results shall be obtained or the sampling process shall be repeated until agreement is obtained.
If the contents exceeds 1000' grams uranium, corrective i
action shall include hourly sampling until the source of the uraniam is identified and controlled. '
l i
103. The licensee shall analyze two indepsndent samples of the citric acid j
baths each week, as well as, independent samples when the tank contents reach l
h y -
r 3
m "gww e
H
t
~
estimated 40%, 60%, and 85% od the tank safe mass limit. Agreement shall be obtaii ed between both analyses or new samples shall be analyzed. If the estimated limit are exceeded, corrective actions shall include adjusting the tank inventory record and investigating the cause of the nonconservative estimate.
104. 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.
105.
Commit to surveying the Gaseous Effluent Vent System ducts servicing the enriched uranium processing areas annually (maximum interval of 15 months).
j If uranium is found, corrective action as a minimum shall include removal of the uranium.
6 4.1.7 Desian Procedures i
106.
Commit to establishing a configuration control program which shall, as a
]
minimum, ind ude the following:
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 t
systematic accident analysis process for all current activities, (3) for each j
of the potential criticality accidents identified above, a current safety i
analysis which ideatifies 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 i
shall document the requirements for maintenance, surveillance, personnel training, posting, and control of written procedures in ensure the effectiveness of the limits and ccntrols.
10L Prinr 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 f
108.
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 to the NRC for approval.
The report shall specify the range of applicability ard other parameters specified in ANSI /ANS-8.1.
The validation report shall be maintained at the CEC facility.
! i
)
a
109. Commit to maintaining a minimum 30-centimeter spacing, edge-to-edge, between units spaced by the surface density method.
j 4 4.2.4 Special Controls 110.
For the centrifuges, cascades, and assay units, the following i
commitments should be made:
l a.
Limit the maximum inside diameter of the centrifuge housings to the safe f
diameter specified in Table 4.2-1 of the Proposed License Conditions.
l b.
Introduce no enriched uranium as feed material to the cascades.
I t
c.
Provide control room monitoring of cascade header pressure, power, feed supply power, feed supply pressure and valve position, cooling water i
temperature and flow, product take-off system pressure and valve position, and i
tails take-off system pressure and valve system.
For unusual monitoring results, procedures shall describe corrective action including shutdown requirements.
l d.
Provide no interconnections which would allow enriched uranium to flow
[
to the feed system.
For each authorized enrichment campaign, calculate the control valve e.
settings and instruct the operators, in writing, of the correct valve settings.
The new valve settings shall be independently confirmed and recorded.
If resulting pressures do not compare with predicted pressures, corrective actions shall be initiated.
f.
For each new campaign, analyze the UF6 product for enrichment within 24 f
hours and compare the results with predicted results.
If an adjustment is 1
required, the actions in (e) above shall be repeated.
j i
g.
Analyze samples from each cascade at least every 6 months (maximum 7
. month intervals) for enrichment.
Adjustments to operating parameters shall be made, if necessary, as in (e) and (f) above.
1 111.
For the prodt
.ake-off system, the following commitments should be j
made i
Verify by cylinder weight, baroscope inspection, and vacuum _ testing that a.
4 no internal contaminants are present before the cylinder is brought to the j
loadout area.
j i
b.
Limit the contents of each product cylinder to the authorized fill limit i
by use of the continuously monitored load cell system.
Prior to initial use
~f of the load cell system, a maintenance and test program shall be developed and l
implemented.
I c.
Vent volatile gases to the Gaseous Effluent Vent System.
Investigations-shall be conducted and corrective actions taken whenever a predetermined j
number of vent cycles per cylinder has occurred.
1 ;
i f
-l
)
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 Heat product cylinders for blending or sampling only in autoclaves and e.
only by using electrically heated air. The autoclave pressure and temperature shall be automatically controlled, ( sntinuously monitored, and alarmed during 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.
f.
Limit the hydrogen to uranium ratio to not more than 1.0.
112.
On a quarterly basis (maximum interval of 4 months), LES will survey the product and product blending desublimers to verify that no solid uranium compounds remain in the desublimers after the UF is transferred to the 6
product cylinders.
If uranium solids are present, the material shall be removed prior to reuse of the desublimer system.
t i
113.
For each product and product blending desublimer system, the following i
commitments should be made:
l i
Use only chemical traps, pumps, and piping which satisfy the geometric f
a.
limits specified in Table 4.2-1, of the Proposed License Conditions.
b.
Maintain a positive pressure nitrogen atmosphere between the inner i
desublimer vessel and the outer shell. The positive pressure shall be
[
continuously monitored and alarmed to detect loss of atmosphere.
i f
c.
Heat and cool the desublimer vessel by freon in external closed loop t
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 pressure and temperature sensors.
i e.
Record the number and frequency of cylinder vents to control the desublimer inventory and to detect abnormal venting intervals.
Any abnormal venting shall be investigated.
l f.
Develop and implement a preventative maintenance and test program for i
the nitrogen pressure monitor alarm system, the pressure temperature sensors and valve system, and the vent frequency and interval monitoring system.
114..For chemical traps for mobile pump sets, the following commitments l
should be made:
i a.
Limit the trap inside diameter to 18.5 centimeters.
b.
Limit the pump free volumes to not more than 7 liters c.
Limit the'K of each pump set to not more than 0.93.
g t
- l
L
.i i
d.
Provide a frequency for weighing and replacing the activated carbon in the chemical traps.
1 i
115.
Provide a survey frequency for verifying that no uranium is accumulating in the contingency dump traps.
Provide action levels and i
corrective actions to be taken if the action levels are exceeded.
l i
116.
For contingency dump traps, the following commitments should be made:
l a.
Limit the inside diameter of the dump traps to not more than 51.7
)
centimeters.
l b.
Prior to use, independently verify and document that the contingency I
traps have been loaded with the correct amount of activated Naf.
c.
Replace the trap media immediately following an emergency dump.
117.
For process piping, commit to limit inside diameters of process piping i
to not more than 21.9 centimeters. When *.he process requires pipe bends or pipe intersections, the piping shall fit inside a maximum 18-centimeter inside i
diameter envelope.
l t
Chapter 5.0 Environmental Protection 118.
Add page numbers to the figures and tables.
l
.i 6 5.1 Effluent Control Systems i
119. At a minimum, there should be a commitment that radiological effluent streams are treated.
6 5.1.1 Gaseous Effluents i
120.
Provide frequencies for replacing activated alumina in chemical traps.
121.
Filters should be removed at least daily and analyzed for gross alpha and not weekly as stated.
122.
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.
123. The text is unclear whether action levels and LLDs are for the weekly or i
quarterly analysis.
Action levels and LLDs should be set for both the daily j
and quarterly samples, Clarify the paragraph.
124.
Suggest adding a commitment as follows:
"If a parameter important to-
.l 4
~ 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 change in dose commitment.
In the event'the calculated dose to any member of l
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 -..
t to the Commission within 30 days which identifies the cause of exceeding the j
limit and the corrective actions to be taken to reduce release rates."
I 6 5.1.2 Liouid Effluents 125.
In the first paragraph LWD should be spelled out.
j 126.
In the second paragraph, the reference to Part 20 release limits should.
I contain the Part 20 Table number.
127.
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.
128.
Composites of the compliance sample should be analyzed quarterly for i
Specify LLD for these samples.
i
-l 129. The LLD for the STS sample should be much lower than (at least a factor i
of 10) the range of the action level.
t 130. Specify the LLD for gross beta.
f 4
131. The sludge from the STS system should be sampled semiannually fer i
uranium accumulation.
132.
Provide the following commitments:
l 4
The NRC shall be informed within 30 days if the State-permitting 4
i
=
agency revokes, supersedes, conditions, modifies, or otherwise nullifies
{
the effectiveness of the State-issued permit for the discharge of liquid effluents.
[
4 The NRC shall be informed within 15 days if the State-issued permit i
for the discharge of liquid effluents is violated.
133.
Second paragraph.
Clarify that the Sewage Treatment System effluent is released on a continuous basis.
Commit to conducting continuous sampling.
134.
Last paragraph.
Add "less than or equal to" after " activity shall be."
[
l Ei 5.2 Environmental Monitoring j
135.
In the-first line change the word " establish" to " implement "
j
}
136.
Commit to reviewing monitoring data on an annual basis for trends and evaluate impacts to the public and environment.
137.
First paragraph. Add sampling of sediment to the list of media to be j
sampled.
Insert, after " program" in line 1, "in accordance with Table 5.2.1."
l 138. On page 5-3, 3rd paragraph, Specify the LLD for uranium and gross beta.
l Also add the LLDs for soil and vegetation samples.
! i 5
s i
t
Table 5.2-1 Radioloaical Monitorina Proaram i
139.
Suggest splitting this table into 2 separate tables, one for the preoperational and one for the operational program. This will make it easy to remove the preoperational requirements once the facility receives licensed i
material.
l t
140.
Clarify what the analysis frequency is. Describe how composite samples are done.
Be sure to include the quarterly composite for air samples that is
_l analyzed for uranium (at a minimum this should be done at the sample location i
for the nearest resident).
l 141.
Reinsert a brief description of the sampling locations.
Include a
)
sample number for easy reference. Delete the word " potential."
l t
142.
Storm-water sampling should be included, this could be at the hold up basin.
I 143. The table states that all surface water samples will be collected on a continuous basis.
Is this your intent?
144. Table 5.2.1.
Delete Note #2.
These terms should be defined in the j
definitions section.
Table 5.2-2 Action levels for Environmental Analyses I
145, Add the levels for gross beta and uranium.
l l
146.
Replace "yCI/ML" by "pCi/ml" and pCI/G "by" "#Ci/g."
i Chapter 6.0 Special Processes f
4 6.2 Occupational Safety f
147.
Provide action levels for HF and the corrective actions to be taken if I
these are exceeded.
Provide exposure limits for HF.
i 6 6.5 timitina Conditions for Operation j
6 6.5.1 Autoclaves-I i'
148.
In item a, change "with any autoclave" to "any autoclave with. Add """
between "260" and "E "
149.
Based on the SAR, the feed autoclave pressure should not be higher than 44 psia, and sampling and blending autoclave pressures should not be higher j
than 87 psia.
l 6 6.5.2 Yard Transoorters 150.
The fuel capacity should not be greater than approximately 70 gallons.
l I
- t I
E 6.6 Other Special Commitments 151. Add section on product and feed cylinder maintenance and surveillance.
152.
State that none of the feed, product and tails cylinders will be stacked.
i 6 6.6.1 Tails Cylinder Maintenance and Surveillance 153.
Under D, af ter "only designated vehicle" insert "with less than 73 gallons of fuel."
154. Under F, clarify LES' intent on anti-corrosion treatment.
155. Under H, need to define what is "significant deterioration" and to develop procedure to resolve "significant deterioration problems in the i
storage yard."
156. Need to add Section 6.6.4 stating the following: " Final design of the r
CEC will involve the structures, equipment, equipment layout, control systems l
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."
T E 6.6.2 Liouid UF6 157. Delete "and cannot by design."
Chapter 7.0 Decommissionino Plan 158.
In the fourth line the text should read "to levels acceptable for i
unrestricted use."
159.
Commit to promptly cleaning up spills and contamination outside normally-contaminated plant areas.
Chapter 8.0 Radiolooical Contingency Plan 160.
Change title to " Emergency Plan."
t
(
l