ML20057B160

Forwards Revised Proposed Licensed Conditions for Claiborne Enrichment Ctr & Licensees Specific Response to Comment in

ML20057B160
Person / Time
Site:	Claiborne
Issue date:	09/14/1993
From:	Leroy P LOUISIANA ENERGY SERVICES
To:	Jim Hickey NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
NUDOCS 9309200093
Download: ML20057B160 (124)

Text

{{#Wiki_filter:5_ 5. .f I Post OEce Box 1004 { Charlotte, NC 28201-1004 September 14,1993 f Mr. John W. N. Hickey, Chief Enrichment Branch Division of Fuel Cycle Safety and Safeguards, NMSS U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Docket No.: 70-3070 Louisiana Energy Services Claiborne Enrichment Center Revision to Proposed License Conditions File: 6046-00-2(X)1.01

Dear Mr. Hickey:

Enclosed are five copies of the revised Proposed License Conditions (PLC) for the Claiborne Enrichment Center (CEC). These Proposed License Conditions have been (revised in accordance with the comments contained in your letters to LES dated August 11, August 24, and September 1,1993, and our meetings with you and members of your staff on August 16 and September 8,1993. The changes to revision 1 of the PLC have been highlighted (sidebarred). As requested, PLC paragraph 4.2.4.2c indicates "... gases shall be vented to the Product Vent System" (refer to comment 111.c) and PLC paragraph 4.2.4.5b indicates "... correct amount and type of NaF powder nnd pellets shall be independently verified and documented" (refer to comment 116.b). Also enclosed is Attachment A which provides LES' specific response to each comment . in the September 1,1993 letter. Please call me at (704) 382-2834 if there are any questions concerning this. Sincerely, f h Peter G. LeRoy Licensing Manager PGIJN99.993 ' (f;L' ( Enclosures V 9309200093.930914 h ADOCK0700gO. DR. s

i i Page 1 of 2 Louisiana Energy Services Proposed License Conditions Push-Pull Instructions Revision 2, September 14, 1993 Remove Insert " List of Effective Pages " List of Effective Pages pages 1 through 4 pages 1 through 4 j " Table of Contents" " Table of Contents i pages i through vi pages i through vii " Introduction" " Introduction" page I-1 page I-1 pages 1-1 through 1-8 pages 1-1 through 1-8 pdges 2-1 through 2-14 pages 2-1 through 2-16 Figure 2.1-1 Figure 2.1-1 (page 2-17) pages 3-1 through 3-6 pages 3-1 through 3-8 pages 4-1 through 4-4 pages 4-1 through 4-10 Table 4.2-1 Table 4.2-1 (page 4-11) pages 5-1 through 5-3 pages 5-1 through 5-4 Table 5.1-1 Tabler 5.1-1 through 5.1-2 (pages 5-5 through 5-6) Tables 5.2-1 through 5.2-2 Tables 5.2-1 through 5.2-2 l (pages 5-7 through 5-13) Figures L.2-1 through 5.2-3 Figures 5.2-1 through 5.2-3 l (pages 5-14 through 5-16) pages 6-1 through 6. pages 6-1 through 6-4 page 7-1 page 7-1 I page 8-1 page 8-1 Appendix A Appendix A pages 1 through 4 pages 1 through 4 Appendix B pages 1 through 2 Appendix C page 1 l l 1 J a, - - -, - --,,,-,--..a

Page 2 of 2 Louisiana Energy Services Proposed License Conditions Push-Pull Instructions Revision 2, September 14, 1993 Notes: 1) Each page affected by this revision has the month and year of the revision printed in the lower right hand corner of the page. 2) The " List of Effective Pages" contains the la test revision and date of the revision affecting the page. 3) All changes or additions to text of each document are 1 indicated by a sidebar (\\ ) in the right hand margin. In the case of deletion of text, the sidebar appears in the right hand nargin with a perpendicular line towards the text ( -; } indica ting where ma terial was deleted. U d t l m

l l i LOUISIANA ENERGY SERVICES PROPOSED LICENSE CONDITIONS LIST OF EFFECTIVE PAGES Pace / Table /Ficure Number

• Revision Number. Date of Revision Table of Contents i

Rev. 2, 09/14/93 ii Rev. 2, 09/14/93 iii Rev. 2, 09/14/93 iv Rev. 2, 09/14/93 v Rev. 2,09/14/93 vi Rev. 2, 09/14/93 vii Rev. 2, 09/14/93 Introduction p I-l Rev. 2, 09/14/93 Section 1.0 p 1-1 Rev. 2, 09/14/93 p 1-2 Rev. 2, 09/14/93 p 1-3 Rev. 2, 09/14/93 p 1-4 Rev. 2, 09/14/93 p 1-5 Rev. 2, 09/14/93 p 1-6 Rev. 2, 09/14/93 p 1-7 Rev. 2, 09/14/93 p 1-8 Rev. 2, 09/14/93 ' NOTE: p = page F = Figure T = Table Louisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNM - ) of 4 Docket # 70-3070

LOUISIANA ENERGY SERVICES PROPOSED LICENSE CONDITIONS LIST OF EFFECTIVE PAGES Section 2.0 p 2-1 Rev. 2, 09/14/93 p 2-2 Rev. 2, 09/14/93 p 2-3 Rev. 2, 09/14/93 p 2-4 Rev. 2, 09/14/93 p 2-5 Rev. 2, 09/14/93 p 2-6 Rev. 2, 09/14/93 p 2-7 Rev. 2, 09/14/93 p 2-8 Rev. 2,09/14/93 p 2-9 Rev. 2,09/14/93 p 2-10 Rev. 2, 09/14/93 p 2-11 Rev. 2, 09/14/93 p 2-12 Rev. 2, 09/14/93 p 2-13 Rev. 2, 09/14/93 p 2-14 Rev. 2, 09/14/93 p 2-15 Rev. 2, 09/14/93 p 2-16 Rev. 2, 09/14/93 F 2.1-1 (p2-17) Rev. 2, 09/14/93 Section 3.0 p 3-1 Rev. 2,09/14/93 p 3-2 Rev. 2,09/14/93 p 3-3 Rev. 2, 09/14/93 p 3-4 Rev. 2, 09/14/93 p 3-5 Rev. 2,09/14/93 p 3-6 Rev. 2, 09/14/93 p 3-7 Rev. 2, 09/14/93 p 3-8 Rev. 2, 09/14/93 ' NOTE: p = page F = Figure T = Table f.ouisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNM - 2 of 4 Docket # 70-3070

LOUISIANA ENERGY SERVICES PROPOSED LICENSE CONDITIONS LIST OF EFFECTIVE PAGES Section 4.0 p 4-1 Rev. 2, 09/14/93 p 4-2 Rev. 2, 09/14/93 p 4-3 Rev. 2, 09/14/93 p 4-4 Rev. 2,09/14/93 p 4-5 Rev. 2, 09/14/93 p 4-6 Rev. 2, 09/14/93 p 4-7 Rev. 2, 09/14/93 p 4-8 Rev. 2, 09/14/93 p 4-9 Rev. 2, 09/14/93 p 4-10 Rev. 2, 09/14/93 T 4.2-1 (p 4-11) Rev. 2, 09/14/93 i Section 5.0 p 5-1 Rev. 2, 09/14/93 p 5-2 Rev. 2, 09/14/93 p 5-3 Rev. 2, 09/14/93 p 5-4 Rev. 2, 09/14/93 T 5.1-1 (p5-5) Rev. 2, 09/14/93 T 5.1-2 (p 5-6) Rev. 2, 09/14/93 T 5.2-1 (p 5-7 through 5-12) Rev. 2, 09/14/93 T 5.2-2 (p5-13) Rev. 2, 09/14/93 F 5.2-1 (p 5-14) Rev. 2, 09/14/93 F 5.2-2 (p 5-15) Rev. 2, 09/14/93 F 5.2-3 (p 5-16) Rev. 2, 09/14/93 l

• NOTE:

p = page F = Figure T = Table louisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNM - 3 of 4 Docket # 70-3070 i

LOUISIANA ENERGY SERVICES PROPOSED LICENSE CONDITIONS LIST OF EFFECTIVE PAGES Section 6.0 p 6-1 Rev. 2, 09/14/93 p 6-2 Rev. 2, 09/14/93 p 6-3 Rev. 2, 09/14/93 p 6-4 Rev. 2, 09/14/93 Section 7.0 p 7-1 Rev. 2, 09/14/93 I Section 8.0 p 8-1 Rev. 2, 09/14/93 Appendix A p1 Rev. 2, 09/14/93 p2 Rev. 2, 09/14/93 p3 Rev. 2, 09/14/93 p4 Rev. 2, 09/14/93 Appendix B p1 Rev. 2, 09/14/93 p2 Rev. 2, 09/14/93 Appendix C p1 Rev. 2, 09/14/93 ' NOTE: p = page F = Figure T = Table Louisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNAf - 4 of 4 Docket # 70-3070

Louisiana Energy Services Proposed License Conditions Table of Contents Section Pace Number INTRODUCTION I-l l 1.0 STANDARD CONDITIONS AND SPECIAL AUTHORIZATIONS 1-1 1.1 NAME, ADDRESS, AND CORPORATE INFORMATION 1-1 i 1.2 SITE LOCATION 1-1 1.3 POSSESSION LIMITS 1-2 1.4 AUTHORIZED ACTIVITIES 1-3 1.4.1 Location Where Material is Used 1-4 1.5 EXEMPTIONS AND SPECIAL AUTHORIZATIONS 1-4 1.5.1 Safety Evaluation Process 1-4 1.5.2 Exemptions And Special Authorizations 1-6 1.6 FINANCIAL INFORMATION AND COMMITMENTS 1-8 2.0 ORGANI7ATION AND ADMINISTRATION 2-1 2.1 ORGANIZATIONAL RESPONSIBILITIES AND AUTHORITY 2-1 2.2 PERSONNEL EDUCATION AND EXPERIENCE REQUIREMENTS 2-5 2.3 SAFETY COMMITTEE 2-9 2.4 APPROVAL AUTHORITY FOR PERSONNEL SELECTION 2-10 2.5 TRAINING 2-11 2.6 OPERATING PROCEDURES 2-11 Louisiana Energy Services Revision 2 Proposed License Conditions Septernber,1993 NRC License SNM - i Docket # 70-3070 l

Louisiana Energy Services Proposed License Conditions Table of Contents Section Pace Number 2.6.1 Preparation Of Procedures 2-12 2.6.2 Chances To Procedures 2-12 2.6.3 Distribution Of Procedures 2-13 2.7 INTERNAL AUDITS AND INSPECTIONS 2-13 2.8 INVESTIGATIONS AND REPORTING 2-15 2.9 RECORDS 2-15 3.0 RADIATION PROTECTION 3-1 3.1 SPECIAL ADMINISTRATIVE REQUIREMENTS 3-1 3.1.1 ALARA Poliev 3-1 3.1.2 Radiation Work Permit Procedures 3-1 3.1.3 Written Procedures 3-2 3.2 TECHNICAL REQUIREMENTS 3-2 3.2.1 Restricted Areas - Personnel Contamination Control 3-2 3.2.1.1 Radiation Control Areas 3-2 3.2.1.2 Radiation Control Zones 3-2 3.2.2 Ventilation 3-3 1 3.2.3 Work-Area Air SamplinE 3-4 1 3.2.4 Radioactivity Measurement Instruments 3-5 3.2.5 Radiation Exposures 3-5 Louisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNM - ii Docket # 70-3070

Louisiana Energy Services Proposed License Conditions Table of Contents Section Pace Number 3.2.5.1 Barriers 3-6 3.2.6 Surface Contamination 3-6 a j 3.2.7 Bioassay Procram 3-7 ) 3.2.8 Calibration Source Leak Tes'.s 3-8 4.0 NUCLEAR CRITICALITY SAFETY 4-1 l 4.1 ADMINISTRATIVE CONDITIONS 4-1 l 4.1.1 Desien Philosonbv 4-1 l 4.1.2 Manacement Responsibilities 4-1 i 4.1.3 Documentation Of Analyses And Reviews 4-1 4.1.4 Operatina Procedures 4-2 l 4.1.4.1 UF Handling Area Effluent Collection Tank Sampling 4-2 4.1.4.2 TSA Effluent Collection Tank Sampling 4-2 1 ) 4.1.4.3 Citric Bath Sampling and Analysis 4-2 i i 4.1.4.4 Chemical Laboratory Uranium Limits 4-3 l 4.1.4.5 Active Ventilation Systems 4-3 4.1.5 Postinn 4-3 l 4.1.6 Preoperational Testine And Inspection 4-3 4.1.7 Design Procedures 4-4 l j 4.1.7.1 Vacuum Pump Spacing 4-4 4 F l Louisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNM - iii Docket # 70-3070 ) l

Louisiana Energy Services Proposed License Conditions Table of Contents Section Pace Number 4.2 TECHNICAL CRITERIA 4-5 4.2.1 Individual Units 4-5 4.2.2 Multiple Units Or Arrays 4-6 4.2.3 Technical Data And Validation Of Calculational Methods 4-6 4.2.4 Special Controls 4-6 4.2.4.1 General 4-6 4.2.4.2 Product Take-Off System Controls 4-8 4.2.4.3 Product / Product Blending Desublimer Systems 4-8 4.2.4.4 Mobile Pump Set Components 4-9 l 4.2.4.5 Contingency Dump Traps 4-10 4.2.4.6 Process Piping 4-10 5.0 ENVIRONMENTAL PROTECTION 5-1 5.1 EFFLUENT CONTROL SYSTEMS 5-1 5.1.1 Gaseous Effluents 5-1 5.1.2 Liouid Efnuents 5-2 1 5.1.2.1 Liquid Waste Disposal System Effluent 5-2 i 5.1.2.2 Sewage Treatment System Effluent 5-3 5.1.2.3 Sewage Treatment System Sludge 5-3 5.2 ENVIRONMENTAL MONITORING 5-3 l lxuisiana Energy Services Revision 2 Proposed License Conditions September,1993 \\ NRC License SNM - iv Docket # 70-3070

Louisiana Energy Services Proposed License Conditions Table of Contents Section Pace Number 6.0 SPECIAL PROCESSES 6-1 6.1 PROPRIETARY INFORMATION 6-1 6.2 OCCUPATIONAL SAFETY 6-1 6.3 BACK-UP UTILITIES 6-1 6.4 RADIOACTIVE WASTIi MANAGEMENT 6-1 6.5 LIMITING CONDITIONS FOR OPERATION 6-2 6.5.1 Autoclaves 6-2 6.5.2 Yard Transporters 6-2 6.6 OTHER SPECIAL COMMITMENTS 6-2 6.6.1 Depleted UFs, Feed, and Product Cvlinder Maintenance And Surveillance 6-2 6.6.2 Liouid UF 6-3 4 6.6.3 Cvlinder Fill Limits 6-3 6.6.4 Safety Analysis Report 6-4 6.6.5 Ouality Assurance Criteria 6-4 7.0 DECOMMISSIONING PLAN 7-1 8.0 EMERGENCY PLAN 8-1 APPENDIX A APPENDIX B APPENDIX C 11)uisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNM - y Docket # 70-3070

Louisiana Energy Services Proposed License Conditions List of Tables Table 4.2-1 Safe Values for Uniform Aqueous Solutions of 5% Enriched UO F 2 Table 5.1-1 CEC Stack Effluent Action Levels Table 5.1-2 Liquid Effluent Action Levels and Lower Limits of Detection Table 5.2-1 Radiological Environmental Monitoring Program Table 5.2-2 Action Levels and Lower Limits of Detection for Environmental Analyses i l l I a i l i i l l l l l 1 I Louisiana Energy Services Revision 2 7 Proposed License Conditions September,1993 NRC License SNM - vi Docket # 70-3070 i

Louisiana Energy Services Proposed License Conditions List of Figures Figure 2.1-1 LES CEC Key Managerial Functions Figure 5.2-1 Surface Water Chemistry Monitoring Locations Figure 5.2-2 Locations of Site Monitoring Wells and Surface Water Staff Gauges Figure 5.2-3 Air Particulate Sampler Locations 'l l J l 1 l l l J l Louisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNM - vii Docket # 70-3070

l'NTRODUCTION This document - Louisiana Energy Services (LES), Proposed License Conditions - provides proposed license conditions for the Claiborne Enrichment Center (CEC). These license conditions state to what performance requirements LES is committed. This document follows the format and content suggested for license conditions by Regulatory Guide 3.52, " Standard Format and Content for the Health and Safety Sections of License Renewal Applications for Uranium Fuel Fabrication" (Revision 1, November 1986). As provided in the Introduction to Regulatory Guide 3.52, "[ijnformation provided in previous submittals... filed with the NRC l under the license may be incorporated by reference provided such references are clear and i specific." Therefore, this document does not contain the detailed descriptive information that has been provided in the Safety Analysis Report (SAR). This document is written to permit inspection and verification of the stated performance requirements. 1 ,1 l i i i i i i t l l l l l l l i l l l l l Louisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNM - J.] . Docket # 70-3070 l

1 1.0 STANDARD CONDITIONS AND SPECIAL_ AUTHORIZATIONS 1.1 NAME, ADDRESS, AND CORPORATE INFORMATION Louisiana Energy Services, L.P. (LES) is a Delaware limited partnership. LES has no subsidiaries or divisions. LES' principal offices are located in Washington, D.C. The address is as follows: 2600 Virginia Ave., N.W., Suite 608 Washington, D.C. 20037 LES also has an information office located in Homer, Louisiana. Homer is the parish seat of Claiborne Parish where the facility is located. The infonnation office address is: 518 East Main Street, PO Box 809 1 Homer, Louisiana 71040 The site address is: 4 Route #4 j i Homer, Louisiana 71040 1 i l 1.2 SITE LOCATION l The facility is located in Claiborne Parish, Louisiana, approximately five miles to the northeast of Homer, Louisiana. It is located approximately in the center of 442 acres ofland, on a 70 acre developed area. Licensed activities occur in the following areas of the developed 70 acres: Separations Building which includes the Technical Services Area (TSA). l Cylinder Receipt and Dispatch Building Product, Feed, and Depleted UF Storage Areas. 6 i -l i lxuisiana Energy Services Revision 2 Proposed License Conditions September,1993 i NRC License SNM - J.] Docket # 70-3070 I ~ m, ww + w - r,-

1. 3 POSSESSION LIMITS l

The following types, maximum possession quantities, and forms of byproduct, source, and special nuclear materials are authorized: l A. Special Nuclear Material: 1,543,000 kilograms (3,402,000 pounds)* of uranium (primarily in the form of l uranium hexafluoride (UF )) enriched above natural but no more than 5.000 6 weight percent in the U " isotope. This maximum enrichment value includes 2 considerations of measurement uncertainty. This uranium possessed at the CEC will be in the form of UF, and other uranium compounds (e.g., uranium compounds in wastes) and will be present in all three physical forms - gas, liquid and solid. B. Source material: The maximum quantity of source material possessed in any form shall not exceed of 62.585,000 kilograms (138,000,000 pounds) of uranium. l The maximum quantity of source material possessed in the form of natural uranium feed material shall not exceed 8,526,000 kilograms (18,800,000 pounds) of uranium. The maximum quantity of source material possessed in the form of depleted UF derived from enrichment of natural uranium shall be the quantity produced 6 during 15 years of CEC operation, not to exceed 80,000 metric tons of depleted UF, (54,059,000 kilograms (119,200,000 pounds) of uranium). Specifically, no l cylinder filled with depleted UF, shall be stored on site longer than 15 years following placement of that cylinder in the depleted UF storage area. 6 1 kilogram = 2.205 lbs. l Louisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNM - 1-2 Docket # 70-3070 l 1

l This uranium possessed at the CEC will primarily be in the form of UF, will include 6 other uranium compounds (e.g., uranium compounds in wastes) and will be present in i all three physical forms - gas, liquid and solid. C. Byproduct material: RADIONUCLIDE CURIE USE LIMIT Technetium-99* 1.1 N/A Iridium-192 100 Radiography Cesium-137 0.3 Gamma calibration Americium-241 0.1 Alpha calibration l Strontium-90 0.1 Beta calibration i Yttrium-90 0.1 Beta calibration Cobalt-60 0.1 Higher energy gamma calibration Tritium 1.0 Instrument calibration or verification

• Tc-99 shall not exceed 0.001 micrograms per gram of total uranium in accordance with ASTM Standard Specification for Uranium Hexafluoride for Enrichment (C 787-90). (This is included only to address trace impurities in UF containers.)

6 In addition to the limits of the table above, any radioactive material with atomic numbers from 1 through 103 shall be authorized. The total cumulative quantity of these additional isotopes shall not exceed 1 Curie; the quantity of each individual isotope shall not exceed 100 millicuries. All additional nuclides are for calibration and/or quality control. Byproduct material may be in solid, liquid, or gaseous form. 1.4 AUTHORIZED ACTIVITIES l The following activities are authorized to be performed at the CEC: Louisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNM - J.3 Docket # 70-3070

l l A. Receive, possess, use, store and prepare for shipment authorized byproduct, source and special nuclear material in accordance with 10 C.F.R. Parts 19,20,21,30,40,70,71, 73,74 and 75. B. Receive, possess, use, store and ship classified information and matter in accordance with 10 C.F.R. Parts 10,25 and 95. C. Produce uranium enriched in the U235 isotope up to and including 5.000% by weight. D. Chemical, spectrometric, radio-chemical and non-destructive assay analyses of source and special nuclear material, including effluents and stored waste. E. Treatment, storage and/or preparation for off-site disposal of liquid and solid wastes produced or handled at the CEC. This includes mixed and radioactive wastes. l I F. Decontamination of equipment before maintenance, repair or disposal and decontamination of contaminated wastes to reduce contamination levels. 1.4.1 Location Where Material Is Used l The cylinders are unloaded, weighed for inventory control and inspected for integrity and damage at the Cylinder Receipt and Dispatch Building. Inside the Separations Building, the UF is enriched to no more than 5.000 weight percent in _ 235 the U isotope by mechanical separation. All byproduct materials to be used for calibration or radiography purposes are used and stored inside the Separations Building. 1.5 EXEMPTIONS AND SPECIAL AUTHORIZATIONS l 1.5.1 Safety Evaluation Process l LES shall be authorized to make facility, process, and procedural changes without prior NRC approval provided that any proposed change does not involve: i l Louisiana Energy Services Revision 2 \\ Proposed License Conditions September,1993 NRC License SNM - ).4 Docket # 70-3070

a) a change to the LES CEC License Conditions, l b) a significant increase in the probability of occurrence or consequences of an accident or malfunction of a structure, system, or component important to safety, c) the creation of the possibility for an accident of a different type than any evaluated previously in the Safety Analysis Report, d) a significant change in the types or significant increase in the amount of any radioactive effluents that may be released off site, or 1 e) a significant increase in individual or cumulative occupational radiation exposure. l d All proposed changes to facilities, processes, and procedures shall be subjected to a safety evaluation prior to making the change. The analysis shall determine and document whether the change meets any of the above criteria requiring prior NRC approval, shall state the basis for the determination, shall be independently reviewed, and shall be approved by the CEC manager or designee. The approver shall be responsible for ensuring that the independent reviewer (s) are qualified to perform the review for all potentially affected areas of safety concern. Documentation of the safety evaluation shall include the bases for the determination. Records of these evaluations shall be maintained for the life of the plant in accordance with Section 2.9. Any propos:d change which involves any of the criteria in a) through d) above shall not be made without prior NRC approval. Changes to the facility or to operations which involve chemical, radiation hazard, or criticality considerations shall be reviewed and approved in writing by the Technical Suppon Superintendent or designee prior to making the change. For changes which involve modifications to the parameters on which criticality safety is established, review shall include completion of new or revised analyses. Changes which involve a change to the facility as described in the Safety Analysis Report shall be reviewed and approved by the Compliance Superintendent or designee. The Safety Analysis Report will be updated at least biennially. Changes to the LES Quality Assurance Program as described in Chapter 10 of the SAR which do not decrease the Louisiana Energy Services Revision 2 Proposed License Conditions Septernber,1993 NRC License SNM - J.5 Docket # 70-3070

effectiveness of the Quality Assurance Program will be submitted as part of the biennial I update of the SAR. 1.5.2 Exemptions And Special Authorizations l -l I The following authorizations are based upon the finding that these arrangements are A. not inimical to the common defense and security of the United States. Entities may without individual application, or other action, create or transfer: lessor ownership interests through sale and simultaneous leaseback of the facility or a portion thereof where the lessor is a U.S. citizen or domiciliary organization: limited partnership interests in the facility, provided that licensee shall report changes to limited partnership interests as stated in the license application dated January 31.1991, as amended, to the Commission; or the mortgage, pledge, or lien of or upon such leasehold or limited partnership interests. Any such mongage, pledge, lien, sale and leaseback or limited pannership interest must be entered into for the purpose of obtaining financing and such interest must not carry with it the present right to possession of the facility or control of licensed activities. The rights of any creditor or the assignee of such creditor may be exercised only in compliance with and subject to the same requirements and restrictions as would apply to the licensee pursuant to the provisions of the license, the Atomic Energy Act of 1954, as amended, and regulations issued by the Commission pursuant to said act. t No creditor or assignee of such creditor may take possession of the facility or purport to exercise control over licensed activities prior to the issuance of a license from the Commission authorizing such possession, or the consent of the Commission to the transfer of the license. " Creditor" as used herein includes, without implied limitation: Louisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNM - 1-6 Docket # 70-3070

The trustee under any mortgage, pledge or lien of or upon a facility made to secure any creditor; Any trustee or receiver of the facility appointed by a coun of competent jurisdiction in any action brought for the benefit of any creditor secured by such mongage, pledge or lien or for the benefit of any lessor or trustee under a sale and leaseback transaction or limited partner; Any lessor or trustee under a sale and leaseback transaction or the legal representative or assignees of such lessor or trustee; Any limited panner or the assignee or legal representative of such limited partner; Any purchaser of such facility at the sale thereof upon foreclosure of such mongage, pledge, or lien or any purchaser of such facility upon exercise of any power of sale contained in any such mongage, pledge, or lien or in any sale and leaseback or limited partnership agreement; or Any assignee of any such purchaser. Provided, however, that nothing in the foregoing conditions shall preclude the licensee from seeking Commission approval of the creation or transfer of a financial interest on a case-by-case basis. LES shall inform the NRC of any changes in LES ownership, liens, and limited pannership changes, within 60 days of the change (s). B. Decontaminated material and equipment may be transferred to an unrestricted area and may be released from the facility for unrestricted use. Decontamination shall meet the guidelines of the NRC document " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material", U.S. NRC, Division of Fuel Cycle Safety and Safeguards, April,1993. 4 pp. This reference is provided as Appendix A. 1 C. LES is exempted from the requirements of 10 CFR % 20.1904 " Labeling containers" for those areas within the Controlled Access Area in which radioactive materials are processed, used, or stored, where it is deemed impractical to label individual Louisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNM - J.7 Docket # 70-3070

containers. Instead, a sign stating "Every container in this area may contain radioactive material" shall be posted. 1.6 FINANCIAL INFORMATION AND COMMITMENTS l A. LES shall submit annually to the NRC its financial statements, including statements of income, assets, liabilities, net worth, and cash Dow. Any changes to construction and operating budgets and/or changes in ownership shall be included with this submission. The report for each calendar year shall be due by June 30th of the following calendar year. B. LES shall establish and maintain a tails disposal fund based on expected tails disposal costs as tails are produced. LES shall determine and update expected tails disposal unit costs at least every five years. C. Reductions of the nuclear liability insurance below the amount of $200 million shall not be made without prior NRC approval. 4 1 4 i l 1 i Louisiana Energy Services Revision 2 Proposed License Conditions September,1993 l NRC License SNM - J.8 Docket # 70-3070

2.0 ORGANIZATION AND ADMINISTRATION The requirements of Sections 2.1 through 2.8 shall be effective 60 days prior to receipt of source material at the CEC. 2.1 ORGANIZATIONAL RESPONSIBILITIES AND AUTHORITY The following key managerial functions shall be performed at the CEC. Except where specifically noted, more than one function may be assumed by one individual. An organizational chart for the functions outlined below is provided in Figure 2.1-1. A. CEC Manager The CEC Manager shall report to the LES President and shall have direct responsibility for operation of the facility in a safe, reliable and efficient manner. The CEC Manager shall be responsible for proper selection of CEC staff for all key positions included in Section 2.1 and positions on the Facility Safety Review Committee. The CEC Manager shall be responsible for protection of the facility staff and the general public from radiation and chemical exposure and/or any other consequences of an accident at the facility. The CEC Manager shall bear the responsibility for compliance with the facility license. B. Quality Assurance Manager The Quality Assurance (QA) Manager shall report to the CEC Manager and shall be i responsible for implementing the Quality Assurance Program for the facility. This includes responsibility for ensuring all activities at the facility affecting quality are performed in accordance with appropriate regulations, codes and standards. This position shall be independent from other management positions at the facility to ensure the QA Manager has direct access to the CEC Manager for matters affecting quality. C. Operations Superintendent The Operations Superintendent shall report to the CEC Manager and shall have the responsibility of directing the day-to-day operation of the facility. This includes such activities as ensuring the correct and safe operation of UF processes, proper handling 6 Louisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNM - 2-1 Docket # 70-3070

of UF, and the periodic testing of equipment to ensure safe and efficient operation. 6 In the event of the absence of the CEC Manager, the Operations Superintendent may assume the responsibilities and authorities of the CEC Manager. D. Integrated Scheduling Superintendent The Integrated Schetiuling (IS) Superintendent shall repon to the CEC Manager and shall have the responsibility of directing the scheduling of enrichment operations to ensure smooth operation of the facility. This includes activities such as ensuring proper feed material and maintenance equipment is available for the facility. The IS Superintendent shall also be 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 shall report to the CEC Manager and shall have the responsibility of directing and scheduling maintenance activities to ensure proper operation of the facility. This includes activities such as repair and preventive maintenance of facility equipment. In the event of the absence of the CEC Manager, the Maintenance Superintendent may assume the responsibilities and authorities of the CEC Manager. F. Compliance Superintendent The Compliance Superintendent shall report to the CEC Manager and shall have the responsibility of directing the activities that ensure the facility maintains compliance with appropriate rules, regulations and codes. This includes activities associated with physical security, classified matter and information, licensing, emergency preparedness, safeguarding of special nuclear materid and compliance with environmental regulations. In the event of the absence of the CEC Manager, the Compliance i Superintendent may assume the responsibilities and authorities of the CEC Manager. Louisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNM - 22 Docket # 70-3070 j

G. Technical Suppon Superintendent The Technical Suppon (TS) Superintendent shall report to the CEC Manager and shall have the responsibility of providing technical suppon to the facility. This includes activities associated with health physics, criticality safety, chemistry, industrial safety and engineering and computer suppon. In the event of the absence of the CEC Manager, the Technical Support Superintendent may assume tne responsibilities and authorities of the CEC Manager. H. Security Manager The Security Manager shall repon to the Compliance Superintendent and shall have the responsibility for directing the activities of security personnel to ensure the physical protection of the facility. The Security Manager shall also be 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. 1. Safeguards Manager The Safeguards Manager shall repon to the Compliance Superintendent and shall have the responsibility for ensuring the proper implementation of the Fundamental Nuclear Material Control (FNMC) Plan. This position shall be separate from and independent of the operations, maintenance, and technical support depanments to ensure a defmite division between the safeguards group and the other depanments. In matters involving safeguards, the Safeguards Manager has direct access to the CEC Manager. J. Emergency Preparedness Manager The Emergency Preparedness Manager shall report to the Compliance Superintendent and shall have the responsibility for ensuring the facility rernains prepared to react and respond to any emergency situation that may arise. This includes emergency preparedness training of facility and facility suppon personnel and the conduct of periodic drills to ensure facility personnel training is maintained up to date. lxuisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNM - 23 Docket # 70-3070

K. Health Physics Manager The Health Physics Ma ager shall report to the Technical Support Superintendent and j shall have the responsibility for implementing the health physics program Duties shall include the training of personnel in use of radiological program support equipment. control of radiation exposure of personnel, continuous determination of the radiological status of the facility, and conducting the radiological environmental monitoring program. During emergency conditions the Health Physics Manager's duties shall also include: l providing Emergency Operations Center personnel information and recommendations concerning chemical and radiation levels at the facility, gathering and compiling onsite and offsite radiological and chemical + monitoring data, making recommendations conceming actions at the facility and offsite deemed necessary for limiting exposures to facility personnel and members of the j general public, and taking prime responsibility for decentamination activities. a In matters involving radiologica] protection, the Health Physics Manager has direct l access to the CEC Manager. L. Projects Manager l The Projects Manacer shall report to the Technical Support Superintendent and shall have the responsibility for the implementation of facility modification.s and the approval of facility procedures and modifications for criticality safety. The Projects Manage. also provides engineering support as needed to support facility operation and I maintenance. This support includes performance testing of systems and equipment. l l l Louisiana Energy Services Revision 2 Proposed License Condirions September,1993 NRC License SNM - 2-I Docket # 70-3070 l l

Chemistry Manager l The Chemistry Manager shall repon to the Technical Support Superintendent and shall I have the responsibility for the implementation of chemistry analysis and safety programs and procedures for the facJity. This includes chemical analysis of effluents from the facility, chemical safety programs, and reporting of chemical analysis of effluents to appropriate regulatory agencies. N. Industrial Safety Manager l The Industrial Safety Manager shall report to the Technical Support Superintendent and shall have the responsibility for the implementation of facility safety prograrns and procedures. This shall include programs and procedures for training individuals in safety and maintaining the performance of the facility fire protection systems. 2.2 PERSONNEL EDUCATION AND EXPERIENCE REQUIREMENTS The minimum qualification requirements for the facility functions that are directly responsible for its safe operation shall be as outlined below. The nuclear experience of each individual shall be determined to be acceptable by the CEC Manager. " Responsible nuclear experience for these positions shall include (a) responsibility for and contributions towards support of facility (s) in the nuclear fuel cycle (e.g., design, construction, operation, and/or decommissioning), and (b) experience with chemical materials and/or processes. Different experience requirements may be approved by the CEC Manager only as specified in the following requirements for key positions. This shall be done in writing and only on a case by case basis. A. CEC Manager The CEC Manager shall be appointed by the President of LES as the overall manager of the 1 Claiborne Enrichment Center. This appointment reflects confidence in the individual's ability as an effective programs and business manager. ~'he CEC Manager shall be knowledgeable of the enrichment process, enrichment process controls and ancillary processes, criticality safety control and radiation protection program concepts as they apply to the overall safety of a nuclear facility. The CEC Manager shall have, as a minimum, a bachelor's degree (or l lxuisiana Energy Serviccs Revision 2 Proposed License Conditions September,1993 NRC License SNM. 25 Docket # 70-3070

l i equivalent) in an engineering or scientific field and six years of responsible nuclear experience. B. Quality Assurance Manager The Quality Assurance (QA) Manager shall have a minimum of eight years of responsible nuclear experience in the implementation of a quality assurance progrun. A maximum of four years of the eight years may be fulfilled by academic training c' 4 one-for-one time basis. To be acceptable, this academic training shall be in engineenng or scientific fields, unless specifically approved by the CEC Manager. The QA Manager shall have at least two years experience in a QA organization at a nuclear facility. C. Operations Superintendent The Operations Superintendent shall have, as a minimum, a bachelor's degree (or equivalent) in an engineering or scientific field and four years of responsible nuc'. ear experience. A maximum of two years of the four 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 CEC Manager. D. Integrated Scheduling Superintendent The Integrated Scheduling (IS) Superintendent shall have, as a minimum, a bachelor's degree (or equivalent) in an engineering or scientific field and four years of responsible nuclear experience. A maximum of two years of the four 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 CEC Manager. E. Maintenance Superintendent The Maintenance Superintendent shall have, as a minimum, a bachelor's degree (or equivalent) in an engineering or scientific field and four years of responsible nuclear experience. A maximum of two years of the four 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 CEC Manager. Louisiana Energy Services Revision 2 Proposed License Conditions Septernber,1993 NRC License SNM _ 26 Docket # 70-3070

F. Compliance Superintendent The Compliance Superintendent shall have, as a minimum, a bachelor's degree (or equivalent) in an engineering or scientific field and four years of responsible nuclear experience. A maximum of two years of the four 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 CEC Manager. G. Technical Suppon Supenntendent The Technical Support (TS) Superintendent shall have, as a minimum, a bachelor's degree (or equivalent) in an engineering or scientific field and four years of responsible nuclear experience. A maximum of two years of the four 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 CEC Manager. H. Security Manager The Security Manager shall have a minimum of five years of experience in the responsible management of physical security at a facility requiring security capabilities similar to those required for the CEC. No credit for academic training may be taken toward fulfilling this experience requirement. I. Safeguards Manager The Safeguards Manager shall have five years of experience in the management of a safeguards program for special nuclear material, i u _ esponsibilities for material control, material accountability, and physical security. N .a c di, 4 auJemic training may be taken toward fulfilling this experience requirement. J. Emergency Preparedness Manager The Emergency Preparedness Manager shall have two years of experience in the implementation of emergency plans and procedures at a nuclear facility. No credit for academic training may be taken toward fulfilling this experience requirement. Louisiana Energy Services Revision 2 Proposed License Conditions September,1923 NRC License SNM - 2-7 Docket # 70-3070

Health Physics Manager The Health Physics Manager shall have, as a minimum, a bachelor's degree (or equivalent) in an engineering or scientific field and three years of responsible nuclear experience associated with implementation of a health physics program. A maximum of one year of the three 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 CEC Manager. L. Projects Manager i 1 The Projects Manager shall have, as a minimum, a BS degree (cr equivalent) m an engineering or scientific field and three years of appropriate, responsible nuclear experience. A maximum of one year of the three 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 CEC Manager. The Projects Manager shall also have at least one year of experience in the administcat2on of nuclear criticality l safety reviews. Within the Projects group shall be at least one individual with a minimum of two years experience in the implementation of a criticality safety program. This individual shall hold a BS degree (or equivalent) in an engineering or scientific field and have successfully completed a training program, appropriate to the scope of operations, in the physics of criticality and in associated safety practices. Should changes to the facility be proposed which require new nuclear criticality safety analyses, trained individuals shall perform the analyses. Trained individuals with at least two years of experience in analyses and criticality safety program implementation shall independently review and approve the analyses. The independent reviewer (s) shall possess a BS degree (or equivalent) in an engineering or scientific field. M. Chemistry Manager The Chemistry Manager shall have, as a minimum, a BS degree (or equivalent) in an engineering or scientific field and three years of appropriate, responsible nuclear experience associated with implementation of a facility chemistry program. A maximum of one year of li>uisiana Energy Se. ces Revision 2 Proposed License Conditions September,1993 NRC License SNM - 28 Docket # 70-3070

three years may be fulfilled by acadenne trammg 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 CEC Manager. N. Industrial Safety Manager The Industrial Safety Manager shall have, as a minimum, a BS degree (or equivalent) in an engineering or scientific field and three years of appropriate, responsible nuclear experience associated with implementation of a facility safety program. A maximum of one year of the three 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 CEC Manager. 2.3 SAFETY COMMITTEE The Facility Safety Review Committee (FSRC) shall report to the CEC Manager, and shall provide technical and administrative review and audit of CEC operations which could impact plant worker and public safety. This shall include a review of audit and ir.spection reports associated with the safety activities and practices listed below. The scope of activities reviewed and audited by the FSRC shall, as a minimum, include the following safety activities and practices: Radiological protection Nuclear criticality safety Chemical safety Industrial safety including fire protection Environmental protection ALARA policy implementation Changes in facility design or operations Training programs Incident reports, including root cause evaluations, and violations of regulations or license conditions. The FSRC shall conduct at least one facility audit per year for the above areas. Audits shall be conducted as described in Section 2.7. Louisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNM - 29 Docket # 70-3070

i l l The Facility Safety Review Committee shall be composed of at least five (5) members, i including the Director. Members of the FSRC may be from the LES corporate office or CEC technical staff. The five members shall include experts on operations and all safety ) disciplines (criticality, radiological, chemical, industrial). The Director, members and 1 alternate members of the Facility Safety Review Committee shall be 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 three years of technical experience, of which a minimum of one year shall relate directly to one or more of the safety disciplines (criticality, radiological, chemical, industrial). At least one member of the FSRC shall have the qualifications of the nuclear criticality safety analyst specified in section 2.2L. Members of i the FSRC shall receive training on possible error modes of management systems. The Facility Safety Review Committee shall meet at least once per calendar quarter during the period of initial operation. (The period of initial operation is defined on a plant umt basis. It includes first-time operation of a plant unit beginning with initial fill of the first cascade until 1 month after steady-state operation of that unit's last cascade.) Subsequent to the period of initial operation, the meeting frequency shall not be less than three (3) each calendar year with a maximum interval of 180 days between any two consecutive meetings. j Review meetings shall be held within 60 days of any incident which is reportable to the NRC. These meetings may be combined with regular meetings. Follor;ing a reportable incident, the FSRC shall review the incident's causes, the responses, and both specific and generic corrective actions to ensure resolution of the problem is implemented. A written report of each FSRC meeting and audit shall be forwarded to the station manager and superintendents within 30 days and be retained for at least three years. 2.4 APPROVAL AUTilORITY FOR PERSONNEL SELECTION The assignment of individuals to assume the key functions and responsibilities described in Section 2.1 and the FSRC shall be approved by the CEC Manager. The personnel requirements specified in Section 2.2 shall be incorporated into administrative procedures for hiring of personnel. lxmisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNM - 2.jo Docket # 70-3070

2.5 TRAINING Formal, planned training programs shall be established for CEC employees. Indoctrination training shall be provided to all employees before the employees perform work at the CEC and shall address: safety preparedness for all safety disciplines (i.e., criticality, radiological, chemical, + industrial - including fire protection safety), ALARA practices, issues related to 10 CFR Part 19, + environmental protection, and emergency procedures. + In depth traini1g programs shall be provided to individuals depending on job requirements in the areas of radiological safety (for all personnel with access to restricted areas) and in criticality safety control. Nuclear criticality safety training shall satisfy the requirements of ANSI /ANS 8.20 - 1991 " Nuclear Criticality Safety Training." All LES employees engaged in QA related activities shall receive performance based QA training. All visitors and contractors shall receive appropriate training prior to visiting the facility and/or performing work at the facility. Retraining of personnel previously trained shall be performed for radiological, chemical, industrial, and criticality safety at least annually, and shall include updating and changes in required skills. Changes to training shall be implemented if indicated due to incidents potentially compromising safety, or if changes are made to facilities or processes. Records of training successfully completed shall be maintained in accordance with Section 2.9 for all personnel. 2.6 OPERATING PROCEDURES Activities involving licensed materials shall be conducted through the use of approved written procedures. Applicable procedure and training requirements shall be satisfied prior to receipt of licensed material. l All procedures shall be reviewed at least biennially. l All new procedures or changes to existing procedures sha'l be subjected to the safety evaluation requirements as described in Section 1.5.1. l Louisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNM - 2.)) Docket # 70-3070 l

2.6.1 Preparation Of Procedures Procedures shall be prepared, reviewed, and approved in accordance with written procedure requirements. Procedures shall identify limits and controls important to safety. Maintenance and testing, including calibration, procedures shall be written and implemented for structures, systems, and components important to safety. Procedures important to safety shall be subjected to an independent review. The designated approver shall determine whether or not any additional, cross-disciplinary review is required. The CEC Manager or designee shall approve all procedures. 2.6.2 Changes To Procedures Changes to procedures shall be processed as described below. A. The preparer documents the change as well as the reason for the change. B. A safety evaluation shall be performed as specified in Section 1.5.1. If the safety evaluation reveals that a change to the license is needed to implement the proposed changes, the change is not implemented until prior approval is received from the NRC. C. The proce. dure with proposed changes shall be reviewed by a qualified reviewer. D. The CEC Manager, a superintendent, or a designee approved by the CEC manager shall be responsible for approving procedure changes, and for determining whether a cross-disciplinary review is necessary, and by which group (s). The independent review shall be by an individual outside of the group (i.e., responsibility of a different manager) that prepared the procedure change. The need for the following cross-disciplinary reviews shall be considered, as a minimum: For proposed changes having a potential impact on chemical or radiation safety, a review shall be performed for chemical and radiation hamrds, including radiological effluents. Approved changes shall be so indicated in I writing by the Technical Support Superintendent or designee. Limisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNM - 2.]2 Docket # 70-3070

1 For proposed changes having a potential impact on criticality safety, a + criticality safety review shall be performed. Approved changes shall be so j indicated in writing by the Technical Support Superintendent or designee. i For proposed changes potentially affecting Material Control & Accountability, + a material control review shall be performed. The approver of a procedure change is responsible for ensuring the procedure change was prepared and reviewed by qualified individuals. E. Records of completed cross-functional reviews shall be maintained in accordance with Section 2.9 for all changes to safety-related procedures. 2.63 Distribution Of Procedures Originally issued approved procedures and approved procedure revisions shall be distributed in a controlled manner. The CEC shall establish and maintain an index of the distribution of copies of facility procedures and manuals (e.g., Department Directives Manual, Operations and Maintenance Manuals). Revisions to facility manuals shall be controlled and distributed consistently with this index. Facility rnanaal indexes shall be regularly reviewed and updated. Superintendents or their designees shall be responsible for ensuring all personnel doing work which require the use of the procedures have ready access to controlled copies of the procedures. 2.7 INTERNAL AUDITS AND INSPECTIONS Audits and inspections are defined in Appendix C. l Audits and inspections shall be conducted by Quality Assurance group personnel and other individuals tecimically qualified to perform audits and inspections to determine that plant operations are conducted in compliance with regulatory requirements, license conditions, and written procedures. Audits and inspections are the responsibility of the QA Manager. As a minimum, they shall assess activities related to: Louisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License '".;n - 2-13 Docket # 70-3070

• preventive maintenance,

+ training, + emergency planning, + Quality Assurance. radiation protection.

• criticality safety control,
• hazardous chemical safety, fire protection, and environmental proteciion.

Audits shall be performed in accordance with a written plan which identifies and schedules audits to be performed. Audit team members shall not have direct responsibility for the function and area being audited. Team members shall have technical expertise or experience in the area being audited and shall be indoctrinated in audit techniques. Audits shall be conducted on an annual basis. -I The results of the audits shall be provided in a written report within 30 days of the audit to the CEC Manager, the FSRC, and the Superintendent responsible for the activities audited. Any deficiencies noted in the audits shall be responded to by the Superintendent or designee within 30 days, tracked to completion by an individual designated by the audit organization (FSRC or QA), and re examined during future audits to ensure corrective action has been completed. Inspections shall be performed routinely by qualified staff personnel that are not directly responsible for production activities being inspected. Inspections shall be conducted at least semi-annually. Deficiencies noted during the inspection requiring corrective action shall be forwarded to the supervisor of the applicable area or function for action. Future inspections shall include a review to evaluate if corrective actions have been effective. Inspections shall be performed in accordance with a written plan by qualified staff personnel l that are not directly responsible for production activities being inspected. Inspections shall be conducted in accordance with a written plan with a frequency commensurate with the activity being inspected. Deficiencies noted during the inspection requiring corrective action shall be documented in a written report going to the appropriate level of management for follow-up action. Future inspections shall include a review to evaluate if corrective actions have been effective. l Louisiana Energy Services Revision 2 Proposed License Conditions September,1993 1 NRC License SNM - 2 14 Docket # 70-3070

2.8 INVESTIGATIONS AND REPORTING To comply with the reporting requirements of 10 C.F.R. (e.g.,10 C.F.R. s 70.50), off-normal occurrences shall be reported to and investigated by the Compliance Superintendent. l Depending upon the severity of the occurrence, the occurrence may be reponable to a governmental agency. Reporting any occurrence to the appropriate agency (s) shall be the responsibility of the Compliance Superintendent. l The process of incident identification, investigation, root cause analysis, environmental I protection analysis, recording, reponing, and follow-up shall be addressed in and performed by written procedures. Radiological, criticality, hazardous chemical, and industrial safety l requirements shall be addressed. Guidance for classifying occurrences shall be contained in facility procedures, including a list of threshold off-normal occurrences. Records of reports shall be maintained as specified in Section 2.9. The Compliance Superintendent shall maintain a record of corre-ctive actions to be implemented as a result of off-normal occurrence investigations. These corrective actions shall include documenting lessons learned, and implementing worker training where indicated, and shall be tracked to completion by the Compliance Superintendent or designee. l 2.9 RECORDS Records related to health and safety shall be maintained in accordance with the requirements of Title 10, Code of Federal Regulations. The following records shall be retained for at least the periods indicated: The following shall be retained for at least 3 years: A. Records of instrument calibraticns; B. Records of changes made to procedures: C. Records of audits and inspections D. ALARA findings i Louisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNM - 2-15 Docket # 70-3070 l

The following records shall be retained for the duration of the facility license: E. Records of all Reportable Events: F. Records and drawing changes reflecting design modifications made to systems and equipment important to worker or public safety (e.g., changes to criticality analyses); G. Records of radioactive shipments; H. Records of radiation exposure for all individuals entering radiation contro! areas (including for example, ALARA findings, routine radiation survey results); I. Records of gaseous and liquid radioactive and hazardous material released to the environs: J. Records of training, qualification, and requalification as required by Section 2.5 for current and past members of the CEC staff; K. Records of safety evaluations described in Section 1.5.1; I L. Records of analyses required by the Radiological Environmental Monitoring Program that would permit evaluation of the accuracy of the analyses at a later date. These should include procedures effective at specified times and QA records showing that these procedures were followed: M. Records of quality assurance activities required by the Quality Assurance Program. These shall be retained for a period of time as recommended by NQA-1-1989; N. Records of plant radiation surveys and environmental surveys. Records shall be stored to permit easy retrievability. These records document the quality of items and activities performed at the CEC and shall be stored in cabinets or storage facilities which protect the records from damage from fire, water, dust, extreme humidity and extreme temperatures. l Louisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNM - 2-16 Docket # 70-3070

._m m m m f i J Figure 2.1-1 Louisiana Energy Services Claiborne Enrichment Center Key Managerial Functions CEC Manager I I I I I l Quality Operations Integrated Maintenance Compliance Technical Assurance Superintendent Scheduling Superintendent Superintendent Support Manager Superintendent Superintendent - Security - Health Physics - Safeguards - Chemistry - Emergency - Industrial Preparedness Safety Manager - Projects 1 1 1 Louisiana E' ergy Services Revision 2 n Proposed License Conditions September,1993 NRC License SNM-2-17 Docket # 70-3070

3.0 RADIATION PROTECTION I 3.1 SPECIAL ADMINISTRATIVE REQUIREMENTS 3.1.1 ALARA Policy LES shall maintain and implement a policy to keep occupational radiation exposures and radioactive contamination in effluents "As Low As Reasonably Achievable" (ALARA). Implementation of this policy shall be the responsibility of the Health Physics Manager. An ALARA report shall be prepared annually and shall address reviews of radiological exposure and effluent release data for trends, audits and inspections, and the use, maintenance, and surveillance of equipment for exposure and effluent control. The HP Manager shall be responsible for preparation of the report. Copies of the report shall be submitted to the CEC Manager and the Facility Safety Review Committee. 3.1.2 Radiation Work Permit Procedures Radiation work permits (RWPs) shall be issued for activities involving licensed materials not covered by operating procedures and where radioactivity levels are likely to exceed airborne radioactivity area limits specified in 10 C.F.R. Q 20.1003, or wherever deemed necessary by the HP Manager to maintain dose ALARA Criteria for ensuring RWPs are issued and closed out properly shall be as follows: The HP Manager or designee is responsible for determining the need for, issuing, and closing out RWPs. l Planned activities or changes to activities inside Radiation Control Areas (RCAs) and Radiation Control Zones (RCZs) or with licensed materials shall be reviewed by the HP Manager or designee for potential for causing radiation exposures to exceed action levels and radioactive contamination. RWPs shall include requirements for any necessary safety controls, personnel -j monitoring devices, protective clothing, respiratory protective equipment, air sampling equipment, and health physics coverage needed for the activity. Copies of current RWPs shall be posted at the location of the work area. l Lcusisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNM - 3.] Docket # 70-3070

1 i RWPs shall clearly define and limit the work activities to which they apply. The RWPs shall be closed out when the applicable work activities are terminated. l 3.1.3 Written Procedures Activities related to radiation protection (e.g., decontamination and maintenance of processing equipment, radiation monitoring) shall be conducted in accordance with approved written l procedures. Distribution of procedures is described in Section 2.6. 3.2 TECHNICAL REQUIREMENTS 3.2.1 Restricted Areas - Personnel Contamination Control i Radiological access zones shall be defined and marked to control personnel contamination. 3.2.1.1 Radiation Control Areas l Radiation Control Areas (RCAs) at the CEC are defined as areas accessible to individuals in which external radiation levels could result in excess of 5 mrem /hr (0.05 mSv/hr) at 30 cm l from the radiation source or from any surface that the radiation penetrates. Personnel that have not been trained in radiation protection procedures shall not be allowed access to the RCA without escort by trained personnel. Access to and egress from an RCA shall be through monitor stations at the RCA boundary. All personnel shall be required to monitor themselves prior to exiting the RCA using monitoring instruments which detect gross alpha contamination. 3.2.1.2 Radiation Control Zones l Greater access control shall be provided by establishing Radiation Control Zones (RCZs) l wherever any of the following cenditions exist: Airborne Radiation: 2 30% of the weighted Derived Air Concentration (DAC) listed in 10 C.F.R. Part 20, Appendix B to &@ 20.1001-20.2402, for specific radionuclides. l Louisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNM - 32 Docket # 70-3070

2 5.0 E-14 pCi/ml for alpha emitters not listed in 10 C.F.R. Part 20, Appendix B to ss 20.1001-20.2402, or unknown alpha emitters. l an individual present in the area without respiratory protection equipment could exceed, during the hours an individual is present in a week, an intake of 0.6% of the Annual Limit on Intake (ALI) or 12 DAC hours, as defined in 10 C.F.R. % 20.1003. Alpha Contamination: Within an RCA,2 5000 DPM/100 cm2 2 Outside an RCA,2 200 DPM/100 cm The RCZ may be permanent or temporary. Egress from each RCZ shall be specifically controlled using as a minimum a monitor (frisker), step-off pad and container for any discarded protective clothing. 3.2.2 Veptilation Ventilation exhaust air shall be released through the plant exhaust stack. All ventilated air to be released from normally contaminated areas (Technical Services Area only) shall be filtered to remove radioactive particles before release. The air shall be filtered using both HEPA and activated carbon Glters. HEPA filter design ef6cxncy shall be 2 99.97% for particles > 0.3 l microns; activated carbon tilter design ef6ciency shall be 2 99% for hydrogen fluoride. Filter testing shall be performed to demonstrate required efficiencies; manufacturer's testing shall be acceptable. Differential pressure across the filter train (s) shall be monitored at the frequency specified in written procedures. Filters shall be changed out if they fail to function properly or if the differential pressure exceeds the manufacturer's ratings. l Fiher inspection, testing, maintenance, and change-out criteria shall be specified in written procedures approved by the Technical Support Superintendent. Change-out frequency shall as a minimum be based on consideration of filter loading, including operating experience, differential pressure data, and any UF releases indicated by HF alarms. 6 HVAC systems serving affected areas shall be shut down during any abnormal release of UF. e I Louisiana Energy Services Revision 2 l Proposed License Conditions September,1993 l NRC License SNM - 33 Docket # 70-3070 1

.3 Work-Area Air Samplinn Airbome activity in work areas shall be regularly determined in accordance with written l procedures. Alpha-in-air type monitors shall be used to measure representative airbome concentrations of radionuclides. Active (i.e., on-line) monitoring for gross alpha shall be performed, assuming all alpha activity is due to U* (D compound). The lower limit of detection shall be equal to 5% of the values listed in Appendix B of 10 CFR ss 20.1001-20.2402 Table 1, Column 3. Monitors shall be permanently located in permanent Radiation Control Zones. Permanent monitors shall be operated to collect continuous samples. Air sampling shall be conducted using continuous air sampling devices and filters changed and analyzed at the following l l frequencies: Weekiv, and following any indication of release that may lead to airborne l concentrations of uranium when uranium concentration are expected to exceed 10% of j the values listed in 10 C.F.R. s 20.1003, Airborne radioactivity area, (1) and (2). l This frequency shall apply to radioactive material shipping, receiving, inspection, and l storage areas. Each shift, following changes in process equipment or process control, and following l j detection of any event (i.e., leakage, spillage, or blockage of process equipment) that i may have resulted in releases in excess of 10% of the values listed in 10 C.F.R. s 20.1003, Airborne radioactivity area, (1) and (2). The representativeness of the work station air samplers shall be checked annually. l j i Plant areas sun' eyed as described in this section shall include as a minimum UF, processing i areas, decontamination areas, waste processing areas, and laboratories. Continuous air i monitors (e.g., stationary samplers, personnel lapel samplers) may be substituted where ) conditions favor periodic sampling in all areas where continuous monitoring may not be reasonably achieved. P l Action levels shall be based on trending of data collected during plant operation. Investigations shall be performed if airborne activity: I 1 exceeds 10% of the values listed in 10 CFR 20.1003 for Airborne radioactivity a. ) i Louisiana Energy Services Revision 2 1 Proposed License Conditions September,1993 NRC License SNM - 34 Docket # 70 3070 a k 1 - ~. - - - -

i ) area, or b. shows a short-term increase of a factor of 10 over historical data from the previous 12 months. Corrective action shall include investigation and an evaluation of the need for changes, consistent with the principles of ALARA. -l 3.2.4 Radioactivity Measurement Instmments Integrating personnel dosimeters shall be used for monitoring external dose. In addition, personnel shall be required to monitor themselves prior to exiting an RCA. Monitoring equipment including "frisker" count rate meters and/or hand and foot monitors shall be i provided at RCA exit points. Instruments shall be calibrated and tested on a regular basis to provide assurance of instrument accuracy, precision, and reliability. Unreliable instruments shall be removed from service until repairs have been completed. Portal monitors and friskers will have sufficient sens' < ity to detect alpha contamination on personnel to ensure that the non-radiological areas of the facility (outside RCAs and RCZs) do not exceed the contamination limits specified in Section 3.2.1. Where criticality monitoring is required, the monitoring system shall be provided in l accordance with Regulatory Guide 8.12, Revision 2, " Criticality Accident Alarm Systems." 3.2.5 Radiation Ext,osures Occupational exposures shall be determined, validated, and controlled in accordance with l written procedures. Workers shall receive training regarding ALARA concepts such as time-distance-shielding to minimize their exposures. All personnel whose duties require them to enter the RCA shall be required to wear individual external dosimetry devices. External dosimetry devices shall be evaluated at least quanerly to ascenain external exposures. If 25% of the annual administrative limit is exceeded in any quarter, then an investigation shall be performed and documented to determine what types of activities may have contributed to the worker's external exposure. This investigation may include, but not be limited to procedural reviews, efficiency studies of the air handling system, cylinder storage protocol, and work practices. Anytime the administrative limit is exceeded, the Louisiana Energy Services Revision 2 Propoad License Conditions September,1993 NRC License SNM - 35 Docket # 70-3070

Health Physics (HP) Manager shall be informed. The HP Manager shall be responsible for I determining the need for and recommending investigations or corrective actions to the responsible superintendent (s). Copies of these recommendations shall be provided to the Facility Safety Review Committee. The administrative exposure limits shall be as indicated below. Administrative Radiation Exposure Limits Conditions of Exposure Administrative Limit NRC Limit Total Effective Dose 1 rem / year 5 rem / year Equivalent (TEDE) internal + extemal (routine operations) l 3.2.5.1 Barriers l The following design and operating considerations, as a minimum, shall be implemented at the CEC to reduce personnel radiation exposures: Except for inside the secondary containment of the autoclaves, the enrichment process shall be maintained below atmospheric pressure. Thus, the UF requires constant 6 containment. This containment precludes direct contact of radioactive materials by the operator. d Self-monitoring is required upon exit from the controlled areas. Personnel shall be instmeted to notify Health Physics if contamination is detected. All personnel working at the CEC are trained in emergency evacuation procedures in accordance with the CEC Emergency Plan. 3.2.6 Surface Contamination Contamination survey monitoring shall be performed for all UF process areas. Surveys shall 6 also include routine checks of non-UF process areas, including areas normally non-6 contaminated. Survey locations, methods, and frequencies shall be specified in procedures Louisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNM - 36 Docket # 70 3070

approved by the HP Manager. The type of monitoring shall include direct and removable l contamination measurements, and shall be based on the potential for contamination in these areas and operational experience. Removable surface contamination shall be considered uranium contamination that can be present on a surface and transferred to a dry smear paper by rubbing with moderate pressure. Methods and instruments used in surveys of removable surface contamination shall be capable of detecting the alpha radiations at and below the alpha contamination levels specified in Section 3.2.1 using proportional counters, alpha scintillation counters, thin window Geiger-Mueller tubes or other appropriate instruments. Personnel working in areas that are classified as airborne radioactivity areas or in areas where removable surface contamination is greater than 1000 dpm/100 cm2 beta-gamma or greater than 20 dpm/100 cm2 alpha must wear appropriate protective clothing. If the areas containing the surface contamination can be isolated from adjacent work areas via a barrier, such that dispersible material is not likely to be transferred beyond it, (with associated signs indicating the level and identity of contamination), personnel working in the adjacent area are not required to wear protective clothing. Radiation Control Zones shall be established for any areas of the CEC that exceed the contamination limits specified in Section 3.2.1. 3.2.7 Bioassay Procram Internal exposures for personnel shall be evaluated via body burden analysis, urinalysis, or an equivalent technique. Internal doses shall be evaluated annually. Bioassays shall be performed for all personnel who work in airborne radiation areas without respirators who have stay times which may result in a dose exceeding the limits of 10 CFR ss 20,1502. The bioassay program shall be able to detect activity corresponding to 5% of the Annual Limit on Intake (ALI) for U234 (conservatively assuming all uranium activity is U234), Continuous air monitoring in airborne radioactivity areas may be performed to complement the bioassay program. If a worker inhales radionuclide concentrations that exceed 12 DAC hours in one week (7 days) as specified in 10 C.F.R. Part 20, Appendix B to ss 20.1001-20.2402, Table 1, Column 3, then bioassay shall be conducted within 72 hours after suspected l or known oposure. Follow-up bioassay measurements shall be conducted to determine committed effective dose equivalent. ..u Louisiana Energy 5divices Revision 2 Proposed License Conditions September,1993 NRC License SNM - 37 Docket # 70-3070

Action levels resulting in worker restriction shall be specified in procedures approved by the HP Manager. 3.2.8 Calibration Source Leak Tests Leak testing of sealed calibration sources shall be performed in accordance with Appendix B. J l W I .I I 'f Louisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNM - 38 Docket # 70-3070

NUCLEAR CRITICALITY SAFETY 4.1 ADMINISTRATIVE CONDITIONS 4.1.1 Desinn Philosophy CEC criteria for criticality safety of systems and equipment shall include the double contingency principle as stated in the ANSI /ANS-8.1-1983 standard, entitled " Nuclear Criticality Safety In Operations with Fissionable Materials Outside Reactors." 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 process conditions before a criticality accident i.s possible." The general criticality safety approach shall be to prevent accidental uranium enrichment excesses, provide geometrical safety when practical, provide for moderation controls within the UF processes and impose strict mass 6 limits on containers of aqueous, solvent based, or acid solutions containing uranium. 4.1.2 Manacement Responsibilities Management positions responsible for criticality safety shall be as described in Section 2.1. The Projects Manager shall be responsible for initiating the performance of criticality safety analyses, for arranging for an independent review of these analyses, and for final approval of these analyses. Performance and independent review of analyses shall be performed by qualified individuals as described in Section 2.2.L. A process for determining the need for new or revised analyses shall be established and as a minimum include the safety evaluation process described in Section 1.5.1. l New analyses which involve criticality safety that rely on methods other than safe by favorable geomeuy shall require documented, explicit acknowledgement of this fact by the approver of the analysis. 4.1.3 Documentation Of Analyses And Reviews Criticality safety of design and operations shall be established by controlled, documented analyses. Analyses shall be prepared in sufficient detail such that an independent reviewer can determine and verify the bases, assumptions, and conclusions without recourse to the originator. Analyses shall be prepared, independently verified, approved, and revised in Louisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNM - 4.] Docket # 70-3070

l accordance with written procedures. Analyses shall be filed and shall be readily retrievable, i as described in Section 2.9. 4.1.4 Operatine Procedures All operations involving licensed materials shall be performed in accordance with written and approved safety and safeguards procedures. Criticality safety department activities required by the license shall be conducted in accordance with written procedures approved by the Projects Manager. These procedures shall meet the requirements specified in Section 2.6. l Procedures shall include nuclear criticality safety limits and controls derived from nuclear l criticality safety evaluations. The procedures shall include corrective measures required to return criticality safety parameters to their normal control band. 4.1.4.1 UF, Handling Area Effluent Collection Tank Sampling l Two independent samples of each UF Handling Area Effluent Col:ection Tank shall be 6 l analyzed weekly. Agreement between results shall be obtained or the sampling process shall 1 l be repeated until agreement is obtained. if the uranium content exceeds 100 mg/ liter, l corrective action shall include sampling and analysis each shift until the source of the uranium is identified and controlled. 4.1.4.2 TSA Effluent Collection Tank Sampling Two independent samples of each TSA Effluent Collection Tank shall be analyzed when half- { full and prior to discharge. Agreement between results shall be obtained or the samphng 1 process shall be repeated until agreement is obtained. If the contents exceed 1000 grams of uranium, corrective action shall include hourly sampling until the source of the uranium is l identified and controlled. l l l l 4.1.4.3 Citric Bath Sampling and Analysis Two independent samples of the citric acid baths shall be analyzed when the tank contents i reach estimated limits of 40%,60%, and 85% of the bath safe mass limit. This sampling and analysis shall be performed at least weekly even if the estimated limits are not reached. l Agreement between the two analyzed samples shall be obtained, or new samples shall be analyzed. If the estimated limits are exceeded, corrective actions shall include adjusting the bath inventory record and investigating the cause of the non-conservative estimate. Exuisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNM - 42 Docket # 70-3070 l

4.1.4.4 Chemical Laboratory Uranium Limits The Chemical Laboratory, excluding sample bottle storage areas, shall be limited to 10.0 kg of uranium at any one time. This limit shall be ensured by maintaining a current inventory by logging transfers into and out of the laboratory area. 4.1.4.5 Active Ventilation Systems Investigations shall be performed as specified below to evaluate CEC ductwork for deposition of uranic compounds. Ductwork to be evaluated shall be that which serves enriched uranium processing areas and is also designed to control airborne radioactivity. The results of the evaluations shall be documented in a written report, and shall address cumulative uranium accumulation, criticality safety, and worker safety, and shall make recommendations for action where safety could be compromised. The report and its recommendations shall be approved by the Technical Support Superintendent and copies provided to the CEC Manager and the Facility Safety Review Committee. Recommended actions shall be implemented, and shall be the responsibility of the Technical Support Superintendent. The following criteria shall be used, as a minimum, to initiate an evaluation: An increase in uranium collection 210 times more than the mean of the previous 12 months in the ductwork filters, based on an annual review of trends, or Anytime the HF alarm activitates just upstream of the final filter train in the Gaseous Effluent Vent System. 4.1.5 Postine Materials labeling and area posting shall be maintained to specify materials limits which affect criticality safety and which are subject to procedural control. Determination of necessary posting requirements shall be the responsibility of the Technical Support Superintendent or designee. 4.1.6 Preoperational Testine And Inspection Prior to start-up of new or modified systems, an inspection shall be performed to ensure the design, installation, and operating instructions are consistent with safety evaluations. Louisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNM - 43 Docket # 70 3070

4.1.7 Desien Procedures Activities related to criticality safety design shall be performed in accordance with approved written procedures. New designs or design modifications shall be subjected to the safety evaluation process described in Section 1.5.1. Wherever criticality safety is directly dependent on the integrity of a storage rack, tank, or other component or structure, the integrity of such structure or component shall be designed in accordance with appropriate codes and standards, or designed, tested, or otherwise confirmed by an engineer qualified to do so. The design, or the confirmation, shall be documented, reviewed by another qualified individual, and records of the confirmation and review maintained in accordance with Section 2.9. A configuration control program shall be established which shall, as a minimum, include the following: For all possession, use, and storage activities with enriched uranium at the facility, a. I 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 systematic accident 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 inadvenent 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. l 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. 4.1.7.1 Vacuum Pump Spacing Prior to use of the vacuum pumps for transporting UF, LES shall provide to the NRC a 6 safety analysis which demonstrates the criticality safety of vacuum pump configuration and i Louisiana Energy Services Revision 2 Pronosed License Conditions September,1993 NRC License SNM - 44 Docket # 70-3070

l operation. If the criticality safety analysis is based on LES' solid angle method for safely spacing vacuum pumps, LES shall obtain NRC approval of the use of the solid angle method utilized. 4.2 TECHNICAL CRITERIA 4.2.1 Individual Units Assumptions and design conditions used in criticality analyses are described in this section. Criticality safety of individual units at the CEC is assured through various combinations of methods. The primary method shall be through geometrical limits, but methods may also include moderator control, mass control, and limits on enrichment level. No criticality safety arguments for individual units shall be based on consideration of poisons, or shall depend on concentration arguments based on maintaining optimum heterogeneity. LES shall use the values provided in Table 4.2-1, along with the safety factors listed, for the basis for criticality safety where geometry or mass are used to ensure safety. The safe limits in Table 4.2-1 are validated as criticality safe when optimum light water moderation exists, reflection is considered and limited enrichment exists within isolated or interactive units, or arrays of units. j 1 i LES may also use the surface density method and/or the solid angle method to determine criticality safety; safe limits are provided in Table 4.2-1. LES may also use validated monte-carlo computer codes (e.g., UK MONK 06B, KEN 05A-PC) run on verified software. I Duct work gamma ray surveys, routine filter pack changes and inspections shall be performed to ensure no unsafe accumulation of uranium. For those areas in which continuous uranium in air monitoring is performed, the time integration of the sampling results provides information on the maximum credible quantity of airborne uranium over the sampling interval. On a case by case basis a combination of these methods shall be used to ensure compliance with the adopted double contingency principle. Louisiana Energy Services Revision 2 Proposed License Conditions September.1993 NRC License SNM - 45 Docket # 70-3070

4.2.2 Multiple Units Or Arrays Control at enrichment level, moderation, mass, and solid angle considerations precludes criticality for multiple units and arrays. LES may also use the surface density method, areal density arguments and validated monte carlo criticality computer methods to determine criticality safety of multiple units or arrays. No criticality safety arguments for multiple units or arrays shall be based on consideration of poisons, nor shall depend on concentration arguments based on maintaining optimum heterogeneity. Prior to using the MONK code for CEC process design changes which are made without NRC approval, a summary report of the MONK code shall be provided to the NRC for approval. The report shall specify the range of applicability and other parameters specified in ANSI /ANS-8.1. The validation repon shall be maintained at the CEC facility. A minimum 30-centimeter spacing, edge-to-edge, shall be maintained between units spaced by the surface density method. 4.2.3 Technical Data And Validation Of Calculational Methods Table 4.2-1 specifies safe mass and geometrical values which have been validated and shall be used for criticality analyses for the CEC. The table also provides safety factors which shall be applied to the CEC designs and analyses. Calculational methods shall be based upon safe geometries derived from the critical geometries and the application of safety factors provided in Table 4.2-1. The critical geometries have been validated by means of a monte carlo criticality computer code. The safety factors are taken from 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." 4.2.4 Special Controls 4.2.4.1 General The plant design shall not include direct application of water to feed cylinders, product a. cylinders, and desublimers while in process. b. The motleration within the product cylinders shall be controlled by operating features, l limisiana Energy Senices Revision 2 Proposed License Conditions September,1993 NRC Licen.se SNM - 46 Docket # 70-3070

including checks that the cylinder is clean and empty prior to the commencement of fill. Also, the moderator (H 0. HF) entering the cylinder shall be monitored during the time the 2 cylinder is connected to the plant UF systems. 6 Where mass sampling is used to ensure that criticality safety limits are maintained, l c. dual sampling and analysis shall be performed to establish mass amounts. d. The maximum internal diameter of the centrifuge housings shall not exceed the safe diameter specified in Table 4.2-1. e. No enriched uranium shall be introduced as feed material to the cascades. f. The following parameters affecting the cascades shall be monitored by operations personnel from the control room: ' Cascade header pressure Centrifuge motor power UF Feed System supply pressure and valve positions 6 Contingency Dump System pressure and valve positions Machine Cooling Water System temperature and flow Froduct Take-Off System pressure and valve positions Tails Take-Off System pressure and valve positions Procedures shall describe corrective actions required (including shutdown requirements) for lost monitoring cepability and unusual monitoring results. g. No interconnections shall be provided which allow enriched uranium to flow to the feed system. h. For each enrichment campaign, required valve settings shall be calculated and provided in written instructions to the operators. Valve positions shall be independently confirmed and recorded. If resulting pressures do not reasonably match predicted pressures, corrective actions shall be initiated. i. For each new campaign, UF product shall be analyzed for emichment within 24 hours 6 and results compared with predicted results. Required adjustments shall be performed in accordance with item h above. Louisiana Energy Senices Revision 2 Proposed License Coralitions September,1993 NRC License SNM - 47 Docket # 70-3070

4.2.4.2 Product Take-Off System Controls Prior to use, empty product cylinders shall be checked to verify no internal a. contaminants are present. Verification shall include weighing, inspection by boroscope, and vacuum testing of each cylinder. b. Product cylinder contents shall be limited to the authorized fill limit by use of the continuously monitored load cell system. A maintenance and test program for the load cell system shall be developed and implemented prior to initial use of the load cell system. Volatile gases shall be vented to the Product Vent System. If a predetermined limit c. on vent cycles per cylinder is exceeded, investigations shall be conducted and corrective actions taken. d. During and after filling cylinders in the product filling stations, and prior to moving the cylinders, UF shall be solidifi;d using only cool air as the cooling medium. 6 Product cylinders shall be heated for blending or sampling only in autoclaves, and e. only using electrically heated air as the heating medium. The autoclave pressure and temperature shall be automatically controlled, continuously monitored, and alarmed during the heating cycle. After blending or sampling, but prior to moving the cylinders, the UF shall be 6 solidified by circulating water in cooling coils external to the autoclave. f. The hydrogen to uranium "in-process" ratio shall not exceed 1.0. The ratio also shall not exceed 1.0 in product cylinders unless it can be shown the cylinders contain less than 2 kg of hydrogen. 4.2.4.3 Product / Product Blending Desublimer Systems The chemical traps, UF pumps, and piping for the Product and the Product Blending a. 6 Desublimer systems shall be designed to satisfy the geometric safe limits specified in Table 4.2-1. b. Alarms shall be provided which indicate loss of a positive pressure nitrogen blanket between the desublimer vessel and the outer shell. The desublimer vessel shall be designed for external heating and cooling, using closed c. imisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNM - 48 Docket # 70-3070

loop heating and cooling coils containing refrigerant. d. Inlet and outlet piping shall include two valves in series, one of which shall be automatically operated by signals from continuously monitoring pressure sensors. Procedures shall include instructions for loss of the sensors and/or failure of the valves. Cylinder venting operations shall be recorded in sufficient detail to control desublimer e. inventory and to detect abnormal venting intervals. Abnormal venting shall be investigated. f. Plant preventative maintenance and test programs shallinclude the nitrogen blanketing alarm system and the pressure sensor / control system of the desublimer inlet and outlet valves. g. At least every four months, the product and product blending desublimers shall be surveyed to verify that greater than 25 kilograms of uranium compounds do not remain in any desublimer after the UF, is transferred to the product cylinders. If greater than 25 kg are present, the material shall be removed such that a maximum of 10 kg remains prior to reuse te desublimer system. 4.2.4.4 Mobile Pump Set Components Mobile pump set components shall be designed to meet requirements a through d below. Alternatively, mobile pump sets in isolation or in an infinite array with other mobile pump sets shall be shown by analysis to have a k of <0.98. This criticality safety analysis shall be m completed in accordance with Section 4. 3 prior to implementing changes to items a through d below. The analysis shall be performed using a validated analysis method such as a Monte Carlo analysis, which has been approved by te NRC (as described in Section 4.2.2 above). The design of the cold trap inside diameter shall not exceed 18.5 cm. a. b. The chemical traps shall be designed with an internal diameter no greater than the safe diameter provided in Table 4.2-1. l The pumps shall be designed such that pump free volume shall not exceed 7 hters. c. l d. The km for an infinite array of mobile pump sets shall not exceed 0.93. For initial CEC operation, activated carbon in mobile pump set chemical traps shall be lxuisiana Er:ergy Services Revision 2 Proposed License Conditions September,1993 NRC License SNM - 49 Docket # 70-3070

l l weighed and replaced when the traps reach 80% of their calculated adsorption capacity. Subject to approval by the CEC Manager, this amount may be increased once recorded CEC operating data is sufficient to justify such an increase. 4.2.4.5 Contingency Dump Traps Design parameters of the contingency dump traps shall be based on a criticality safety a. analysis using validated, NRC-approved methodology (as described in Section 4.2.2 above). The analysis shall be performed in accordance with Section 4.1.3. b. Following each fill or replacement of a contingency dump trap, use of the correct amount and type of NaF powder and pellets shall be independently verified and documented. Contingency dump trap media shall be replaced immediately following a emergency c. dump involving significant amounts of UF,. 4.2.4.6 Process Piping The internal diameter of process piping shall not exceed the safe diameter provided in Table 4.2-1. Where the process requires pipe bends or pipe intersections, the piping shall fit inside a maximum 18 cm. diameter envelope. Limisiana Energy Services Revision 2 Proposed License Conditions September 1993 NRC License SNM - 4 10 Docket # 70-3070

TABI E 4.2-1 Safe Values for Uniform Aqueous Solutions of SFc Enriched UO F 2 2 l PARAMETER CRmCAL VALUE SAFETY FACTOR SAFE VALUE Volume 25 1 1.34 18.6 1 ] Cylinder Diameter 24.6 cm 1.12 21.9 cm Slab Thickness 12.4 cm 1.18 10.5 cm i Mass (No Double 35.5 kgU l.34 26.4 kgU i Batching Possible) 1 Mass (Double 35.5 kgU 2.23 15.9 kgU Batching Possible) I { Areal Density 11.5 gU per sq cm 2.23 4.6 kgU per sq ft equivalent to 10.6 kgU ) l per sq ft i i Solid Angle 9-10 k,n j (for k,n < 0.8) i l l l i 1 4 i i i i 1 i i i I. i I louisiana Energ, Services Revision 2 Proposed License Condition: September,1993 NRC Licerue SNh1 - 4.)) Docket # 70-3070 1

5.0 ENVIRONMENTAL PP.OTECTION 5.1 EFFLUENT CONTROL SYSTEMS Radiation levels in effluent shall be controlled and minimized to meet NRC regulatory limits and the CEC ALARA policy. Specific limits, and corrective actions should these limits be exceeded, are detailed in the following sections. 5.1.1 Gaseous Effluents Gaseous effluent releases shall be continuously monitored during CEC operation to verify concentration levels are within administrative and regulatory limits. HF monitors shall be provided in the Gaseous Effluent Vent System upstream of the filter train. Radioactivity of the discharge is continuously sampled. Downstream of ventilation system discharge, each exhaust stack shall contain an isokinetic sampler for continuous sampling and subsequent analysis. The filter from the isokinetic sampler downstream of the ventilation filters is removed at least weekly and analyzed for gross alpha. Should the HF alarm be activated due to high HF levels in the GEVS, the isokinetic filter shall be removed and analyzed daily until gross alpha levels return to normal. A running quanerly average shall be trended for comparison to action levels and administrative limits. The administrative limits for gaseous effluent shall be 5% of the regulatory limits, as specified in 10 C.F.R. Iw 20 Appendix B to %f 20.1001-20.2402, Table

2. Should the action levels for gross alpha (Table 5.1-1) be exceeded by the running quanerly average, further isotopic analyses shall be perfonned. The lower limits of detection for gross alpha shall be IE-15 pCi/ml, and for alpha isotopic analysis shall be IE-16 pCi/ml 23 2

238 for each of the U ', U ", and U isotopes. If action levels are exceeded, the CEC Manager and the Compliance Superintendent shall be notified. The cause of exceeding the action levels shall be investigated and corrected. Investigation and coITective action is the responsibility of the Compliance Superintendent. Investigation results and corrective action shall be documented and a copy provided to the FSRC. Situations requiring reporting shall be handled as described in Section 2.8. If a parameter changes which could significantly affect dose assessment, a report shall bc rubmitted within 60 days which describes the change and includes an estimate of the resultant charge in dose commitment. In the event the calculated dose to any member of the public in Louisiana Energy Services Revision 2 Proposed License Conditions Septernber,1993 NRC License SNM - 5.] Docket # 70-3070

any consecutive 12-month period is about to exceed the limits specified in 40 CFR 190.10, l immediate steps shall be taken to reduce emissions so as to comply with 40 CFR 190.10. A l report shall be prepared and submitted to the Commission within 60 days which identifies the cause of exceeding the limit and the corrective actions to be taken to reduce release rates. l For initial CEC operation, activated alumina in chemical traps shall be weighed and replaced when the traps reach 80% of their calculateri adsorption capacity. Subject to approval by the i CEC Manager, this amount may be increased once recorded CEC operating data is sufficient to justify such an increase. 5.1.2 Liquid Effluents The NRC shall be informed within 30 days if the state permitting agency revokes, supersedes, conditions, modifies, or otherwise nullifies the effectiveness of the state-issued permit for the discharge of liquid effluents. l The NRC shall be informed within 15 days if the state-issued permit for the discharge of liquid effluents is violated. 5.1.2.1 Liquid Waste Disposal System Effluent l Processing of potentially radioactive liquid effluent shall be performed such that the activity l levels are within 5% of the limits specified in 10 C.F.R. Part 20, Appendix B to s@ 20.1001-20.2402, Table 2, prior to discharge to the CEC Sewage Treatment System. Should the limits i for gross alpha (Table 5.1-2) be exceeded, the effluent shall be held up and returned for l further processing, or further analysis shall be perfomled to show the 5% limit is not exceeded. i ( All potentially radioactive effluent is treated in the Liquid Waste Disposal (LWD) system, l 4 forwarded to the Sewage Treatment System for final treatment, and discharged to Bluegill t l Pond. I j Lower limits of detection for liquid effluent gross alpha activity shall not exceed the values j specified in Table 5.1-2. Lower limits of detection for further isotopic analyses of liquid ) effluent shall not exceed 1.0E-Il pCi/ml for each uranium isotope. l ( ) Louisiana Energy Senices Revision 2 Proposed License Conditions September,1993 i NRC License SNM - S.2 Docket # 70-3070

5.1.2.2 Sewage Treatment System Effluent l Sewage Treatment System effluent shall be sampled and analyzed to verify activity levels are below the administrative limit of 0.5% of the release limits listed in 10 C.F.R. Part 20, Appendix B to Q 20.1001-20.2402, Table 2. Should the limits for gross alpha (Table 5.1-2) be exceeded, it shall be assumed the 0.5% limit has also been exceeded unless further analyses indicate otherwise. If the administrative limit of 0.5% is exceeded, the CEC Manager and Compliance Superintendent shall be notified. The cause of exceeding this limit shall be investigated and corrected. Investigation and corrective action is the responsibility of the Compliance Superintendent. Investigation results and corrective action shall be documented and a copy provided to the FSRC. Situations requiring reporting shall be handled as described in Section 2.8. The Sewage Treatment System releases effluent continuously. Discharge to the environment l is into Bluegill Pond, located within the CEC site boundary. Sewage Treatment System samples shall be collected, composited, and analyzed in accordance with the frequencies specified in the NPDES permit. Sampling shall be continuous. The Sewage Treatment System discharge samples shall be used to demonstrate compliance with 10 C.F.R. Part 20. Lower limits of detection for liquid effluent gross alpha activity shall not exceed the values specified in Table 5.1-2. Lower limits of detection for further isotopic analyses of liquid effluent shall not exceed 1.0! I pCi/ml for each uranium isotope. The CEC shall test a composite of the Sewage Treatment System liquid effluent for Tc" once per month for at least three consecutive months immediately following any product sample analysis which exceeds the ASTM C996-90 limits for Tc" 5.1.2.3 Sewage Treatment System Sludge Sewage sludge shall be sampled semi-annually for uranium accumulation. Investigation and any necessary corrective action shall be performed if activity due to uranium is greater than 20 picoCuries/ gram above background. 5.2 ENVIRONMENTAL MONITORING The CEC shall implement a radiological monitoring program in accordance with Table 5.2-1 l for evaluating radioactivity released from the plant. The program shall specify sample Louisiana Energy Services Revision 2 Proposed License Conditions Scptember,1993 NRC License SNM - 53 Docket # 70-3070

locations, sampling methods, frequency of sampling, and types of analyses performed. Samples shall be taken of air, soil, sediment, vegetation, surface water, and ground water. I j Locations of sample sites are shown in Figures 5.2-1 through 5.2-3, and may be revised only if a review determines that new sample sites provide as useful and representative data as these sites for trending and evaluating impact to the public. This review shall be the responsibility of the Compliance Superintendent, documented in writing, and approved by the CEC Manager l prior to implementing changes. Sampling methods and frequency shall be as specified in Table 5.2-1. All samples shall be i analyzed for gross alpha. Should the action levels (Table 5.2-2) be exceeded. further isotopic analysis shall be performed. l Additionally, if action levels are reached the CEC Manager and Compliance Superintendent l shall be notified immediately. The cause of exceeding these limits shall be investigated and i corrected. Investigation and corrective action is the responsibility of the Compliance Superintendent. Investigation results and corrective action shall be documented and a copy provided to the FSRC. i Environmental monitoring data shall be reviewed annually for trends and to evaluate impacts to the public and environment. i I Lower limits of detection for gross alpha for the environmental analyses shall not exceed the l values provided in Table 5.2-2. l .i l L 4 Lcmisiana Energy Services Revision 2 j Proposed License Conditions September,1993 l NRC License SNM - 54 Docket # 70-3070 l i

TABLE 5.1-1 CEC Stack EfUuent Action Levels STACK AVERAGING PEIUOD ACHON LEVEL - GROSS ALPIIA-Unit 1 Quarterly 1.2E-13 pCi/ml Unit 2 Quetterly 1.5E-14 pCi/ml Unit 3 Quarterly 1.5E-14 pCi/ml Louisiana Energy Semces Revision 2 Proposed License Conditions September,1993 NRC License SNM - 55 Docket # 70 3070

TABLE 5.1-2 Liquid EITluent Action Levels and Lower Limits of Detection Gross = - Gross = - Sample Location - Action Level LLD: LWD Discharge 1.5E-9 pCi/ml 1.5E-10 pCi/ml Sample Sewage Discharge 1.5E-10 pCi/ml 1.5E-11 pCi/ml Sample l i i 1 l l lxuisiana Energy Services Revision 2 Proposed License Conditions Septernber.1993 NRC License SNM - 56 Docket # 70-3070

Table 5.2-1 Radiological Environmental Monitoring Program Preoperational Monitoring Preoperational Pathway / Preoperational Sampling and Sample type Samples and Locations Collections Airborne API - One sample located in the sector with Air sampler with a Particulate the highest prevailing wind direction. To be particulate filter, operating located in the area with the highest Chi /Q for continuously and collected that sector near the site boundary. and analyzed weekly. AP2 - One sample located in the sector with the second highest prevailing wind direction. To be located in the area with the highest Chi /Q for that sector near the site boundary. AP3 - One sample located near the resident who is maximally exposed from the gaseous pathway. AP4 - One sample located in the west sector. To be located near the site boundary corresponding to the highest Chi /Q in that sector. AP5 - One sample located in the east sector near the site boundary corresponding to the highest Chi /Q in that sector. AP6 - One sample located in the south sector near the site boundary, corresponding to the highest Chi /Q in that sector. If this sector is already represented by another air sampling site corresponding to the API through AP4 sites above, then site AP7 is not needed. AP7 - One sample located in the north sector near the site boundary, corresponding to the highest Chi /Q in that sector. Exuisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNhi - 57 Docket # 70-3070

J Table 5.2-1 Radiological Environmental Monitoring Program Preoperational Monitorine l Preoperational Pathway / Preoperational Sampling and Sample type Samples and Locations Collections Airborne / SI-S16 - Samples to be collected near the site Collected and analyzed ] Soil boundary in each sector. One sample per site. quanerly. Combine samples from sixteen sectors into four composites. I Airborne / VI-V16 - Samples to be collected near the site Collected and analyzed Vegetation boundary in each sector. One sample per site. quarterly. Combine samples from sixteen sectors into four composites. Liquid / GW1 - Well #A1, Figure 5.2-2 Grab samples to be collected Ground Water and analyzed quarterly. GW2 - Well #B1, Figure 5.2-2 GW3 - Well #Cl, Figure 5.2-2 GW4 - Well #DI, Figure 5.2-2 GW5 - Well #El, Figure 5.2-2 GW6 - Well #F1, Figure 5.2-2 Liquid / SSI - To be collected near the outflow of Grab samples to be collected Shoreline Bluegill Pond. and analyzed quarterly. Sediment Combine samples from s en s et rs into four SS2 - To be collected near the inflow of

1. *E * **

Bluegill Pond from the Hold-Up Basin. SS3 - To be collected near the south shore of Bluegill Pond. SS4 - To be collected near the north shore of Bluegill Pond. SS5 - To be collected at Lake Claiborne. Louisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNM - 58 Docket # 70-3070

Table 5.21 Radiological Environmental Monitoring Program Preoperational Monitorine Preoperational Pathway / Preoperational Sampling and Sample type Samples and Locations Collections Liquid / BSI - To be collected from the east end of Grab samples to be collected Bottom Bluegill Pond. and analyzed quanerly. Sediment Combine samples from sixteen sectors into four BS2 - To be collected from the center of composites. Bluegill Pond. BS3 - To be collected from the west end of Bluegill Pond. BS4 - To be collected from the center of the Hold-Up Basin. BS5 - To be collected at Lake Claibome. Liquid / Surface SW1 - Inflow to Lake Avalyn. Grab samples collected and W ater analyzed quanerly. SW5 - Inflow to Bluegill Pond. SW6 - Bluegill Pond, near the center. SW7 - Outflow from Bluegill Pond. SW8 - Site drainage stream. SW9 - Outflow at the western property boundary. SWil - Hold-Up Basin. SW12 - Lake Claiborne. Take sample at inflow point of Cypress Creek. Louisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNM - S.9 Docket # 70-3070

Table 5.2-1 l Radiological Environmental Monitoring Program Operational Monitorine Operational Pathway / Operational Sampling and Sample type Samples and Locations Collections Airborne API - One sample located in the sector with Air sampler with a Particulate the highest prevailing wind direction. To be particulate filter, operating located in the area with the highest Chi /Q for continuously and collected that sector near the site boundary. and analyzed weeldy. AP2 - One sample located in the sector with the second highest prevailing wind direction. To be located in the area with the highest Chi /Q for that sector near the site boundary. AP3 - One sample located near the resident who is maximally exposed from the gaseous pathway. AP4 - One sample located in the west sector. To be located near the site boundary corresponding to the highest Chi /Q in that sector. AP5 - One sample located in the east sector near the site coundary, correspond;ng to the highest Chi /Q in that sector. AP6 - One sample located in the south sector near the site boundary, corresponding to the highest Chi /Q in that sector. If this sector is already represented by another air sampling site corresponding to the API through AP4 sites above, then site AP7 is not needed. AP7 - One sample located in the north sector near the site boundary, corresponding to the highest Chi /Q in that sector. Imisiana Energy Services Revision 2 Proposed License Conditions September.1993 NRC License SNM - 5.jo Docket # 70-3070

Table 5.2-1 l Radiological Environmental Monitoring Program Operational Monitorine Operational Pathway / Operational Sampling and Sample type Samples and Locations Collections Airbome/ SI-S16 - Samples to be collected near the air Collected and analyzed Soil boundary in each sector. semi-annually. Combine One sample per site. samples from sixteen sectors into four composites. Airbome/ VI-V16 - Samples to be collected near the site Collected and analyzed Vegetation boundary in each sector. One sample per semi-annually at the same site. time as soil sample collection. Combine samples from sixteen sectors into four composites. Liquid / GW1 - Well #Bl. Figure 5.2-2 Grab samples to be collected Y** """""" Y " GW2 - Well #C1, Figure 5.2-2 GW3 - Well #El, Figure 5.2-2 Liquid / SSI - To be collected near the outflow of Grab samples to be collected Shoreline Bluegill Pond. and analyzed semi-annually. Sediment SS2 - To be collected near the inflow of Combine samples from Bluegill Pond from the Hold-Up Basin. composites. SS3 - To be collected near the south shore of Bluegill Pond. SS4 - To be collected near the north shore of Bluegill Pond. SS5 - To be collected near surface water site SW12 at Lake Claiborne, fxuisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNM - 5-11 Docket # 70-3070

Table 5.21 Radiological Environmental Monitoring Program Operational Monitorine Operational Pathway / Operational Sampling and Sample type Samples and Locations Collections Liquid / BS1 - To be collected from the east end of Grab samples to be collected Bottom Bluegill Pond. semi-annually. Combine l SamP es from sixteen sectors BS2 - To be collected from the center of into four composites. Bluegill Pond. BS3 - To be collected from the west end of Bluegill Pond. BS4 - To be collected from the center af the Hold-Up Basin. BS5 - To be collected at Lake Claibome. Liquid / Surface SW1 -Inflow to Lake Avalyn. Collected continuously via Water integrating water sampling SW5 - Inflow to Bluegill Pond. e9uipment to obtain monthly composites. Analyzed SW6 - Bluegill Pond, near the center. monthly. SW7 - Outflow from Bluegill Pond. SW8 - Site drainage stream. SW9 - Outflow at the western propeny boundary. SW12 - Lake Claibome. Take sample at inflow point of Cypress Creek. Louisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNM - 5-12 Docket # 70-3070

TABLE 5.2 2 Action Levels and Lower Limits of Detection For Environmental Analyses ' SAMPLE TYPE GROSS== ACTION LEVEL - GROSS =c-LLD7 - (ABOVE BACKGROUND) j W ater 3.0E-10 pCi/ml 1.0E-12 pCi/ml Air 3.0E-15 pCi/ml 1.0E-18 pCi/ml Soil / Sediment 5.0E-6 pCi/g 3.0E-7 pCi/g Vegetation 1.0E-8 pCi/g 1.0E-10 pCi/g l Louisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNM - 5.]3 Docket # 70-3070 j

l N M / (PAR $H CG (39 .\\ 5 \\4 ,e f p l g -~l i e N !) 1N x piI g ,o ljl l ^ ^ *J %) _) - f_j N // l 7 ac=)GD N 6 I 7c-lPLUEGILL POND. [ t l / h. i j 9 = >o 4 i M[ l \\ l \\ A W. \\ v' j l' t s. 7 ,C% \\ f hl I i K. l = - ) = CYPRESS CREEK LOCATION (DFFSITE)

• CLA! BORNE ENRICHMENT CENTER Surface Water Chemistry j

tu manTv smav Monitoring Locations - currac c: man cce rt. -so Figure 5.2-1 I I c sec 5-14 i stA: E IN FECT REVISION 2 SEPTEMBER 1993 l

N 7: 9 PAR!SH ROAD f 39

• Y',

p -- -.. -.. _.. _. _. _... l I STAFF NW-1 WELL B-2 ,I I L..__. l WELL D-1 ,I WELL B-1 STAFF AV-1 \\ /

WELL A :

I I i I l i I I ~..-..] P l / p.._.._..._.._..j WELL F-1 l .I STAFF UN-1, WELL E-1 l l l I i I i I j WELL C-1 I j I I I 4--.~..-..-.._..._.._.._.._._._______.l_. / / CLAIBORNE ENRICHMENT CENTER Locations of Site Monitoring Wells and Surface Water Staff Gauges Figure 5.2-2 REVISION 2 5 73 SEPTEMBER 1993

N g .._-..--...-.. Q..... lAP-2 AP-1 AP-3 O l l I I 1..._... I l \\ l l xe anw (if ,I uu.tha N ]AP-4 '[" -){ 'h AP-5 i h19 N R@D I l %lc I i x l van umu.c .._-...--.._....b p----- ~~~ e ~ u l JM* j ~ em i %'* C_ -n r i l V .I l I f AP-6 ..-..-..-..--.._.._..__.._.-.._.._g.r_.._._,.j PARISH ROAD #39 LL.S. PROPERTY BDUNDARY CLAlBORNE ENRICHMENT CENTER ] - AIR PARTICULATE (AP) SAMPLER Air Particulate Sampler Locations j Figure 5.2-3 REVISION 2 5-16 SEPTEMBER 1993

6.0 SPECIAL PROCESSES j i 6.1 PROPRIETARY INFORMATION No proprietary information is applicable to these License Conditions. 6.2 OCCUPATIONAL SAFETY Safe handling practices for hazardous chemicals shall be incorporated into everyday operation through the use of written procedures and/or postings. These shall include corrective actions to take should incidents occur. Personnel who routinely work with or around hazardous chemicals shall be trained in the safe practices and in the proper response to incidents involving these chemicals. Procedures / postings and training shall address, as a mimmum, organic solvents and HF. Permanent alpha-in-air monitors shall have an alarm setpoint such that a UF release will 6 activate the alarm if calculated HF levels exceed 3 ppm. The calculated setpoint basis for alpha activity shall assume that the stoichiometric concentration of HF at the point of release is maintained throughout its dispersion, i.e., one molecule of U is equivalent to 4 of HF (UF6 + 2H;O --+ UO F: + 4HF). If the alarm sounds, the Industrial Safety Manager shall be notified, who shall initiate immediate corrective actions. Workers shall not perform work in affected areas, other than to repair damage, and then only with suitable respiratory protection and protective clothing. 6.3 BACK-UP UTILITIES Prior to receipt of licensed source material, an electric power supply shall be provided for backup during a loss of power event. Battery back-up shall power sufficient lighting for plant evacuation should this become necessary. Back-up power shall also be provided to criticality alarms in the Technical Services Area (TSA), and shall last long enough to allow orderly ceasing of activities. 6.4 RADIOACTIVE WASTE MANAGEMENT Radioactive wastes shall be collected, handled, packaged, stored, and transported in accordance with Title 10 and Title 49 of the Code of Federal Regulations. All processes shall be designed and operated in accordance with the CEC ALARA policy. Operations shall be in Louisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNM - 6-1 Dockes # 70-3070

rdance with written procedures, and shall be reviewed as described in Sections 2.3 and 2.7. The Health Physics Manager shall be responsible for radioactive waste management. 6.5 LIMITING CONDITIONS FOR OPERATION 6.5.1 Autoclaves The CEC shall not operate any autoclave with air temperature exceeding 260 F. I a. b. The CEC shall not operate such that UF in a feed autoclave is raised to a pressure 6 above 50 psia. The CEC shall not operate such that UF in a product sampling nor 6 blending autoclave is raised to a pressure above 100 psia. 6.5.2 Yard Transporters Yard transponers shall not have a fuel capacity greater than 70 gallons. l 6.6 OTHER SPECIAL COMMITMENTS 6.6.1 Depleted UF,. Feed, and Product Cylinder Maintenance And Surveillance l A. All filled Depleted UF (DUF ), feed, and product cylinders shall be stored on l 6 6 concrete saddles, or other saddles made of materials that do not cause corrosion of the cylinders. These saddles shall be placed on stable surfaces such as concrete or compacted gravel. B. DUF, feed, and product cylinders shall not be stacked. Storage array design l 6 shall permit visual inspection of all cylinders. C. Depleted UF cylinder valves shall be fitted with valve guards to protect the 6 cylinder valve during transfer and storage. D. Only designated vehicles with less than 70 gallons of fuel shall be allowed in l the UF storage yards. 6 E. Only trained and qualified personnel shall be allowed to operate vehicles in the UF storage yards. -{ i 6 l Louisiana Energy Services Revision 2 Proposed License Conditions Septernber,1993 NRC License SNM - 6-2 Docket # 70-3070 i

F. DUF cylinders shall be inspected for damage prior to placing a filled cylinder l 6 in a storage yard. DUF cylinders shall be reinspected annually for damage or 6 surface coating defects. These inspections shall verify that: 1. Lifting points are free from distortion and cracking. 2. Cylinder skirts and stiffener rings are free from distortion and cracking. 3. Cylinder surfaces are free from bulges, dents, gouges, cracks or significant corrosion (e.g., rust). 4. Cylinder valves are fitted with the correct protector and cap, the valve is straight and not distorted,2 to 6 threads are visible, and the square head of the valve stem is undamaged. 5. Cylinder plugs are undamaged and not leaking. 4 i G. If inspection of a DUF cylinder reveals significant deterioration (i.e., leakage, 6 I cracks, excessive distortion, bent or broken valves or plugs, broken or torn i l stiffening rings or skins, or other conditions that may affect the safe use of the ] cylinder), the contents of the cylinder shall be transferred to another cylinder, I and the defective cylinder properly discarded. The root cause of any significant deterioration shall be determined and if necessary additiona: ) inspections of cylinders shall be made. l H. Proper documentation on the status of each DUF cylinder shall be available on l site, including content and inspection dates. 1 a l 6.6.2 1.iquid UFs l l LES shall not transpon any cylinder containing liquid UF. l l \\ i 6.6.3 Cylinder Fill Limits li UF cylinders shall not be filleo in excess of the shipping limit maximum specified in 6 l Appendix 1, "UF Cylinder Data Summary," of ORO-651, Revision 6, " Uranium 6 l !1 l lxuisiana Energy Service-Revision 2 i Proposed License Conditions September,1993 l NRC License SNM - 6-3 Docket # 70-3070

i Hexafluoride: A Manual of Good Handling Practices." 6.6.4 Safety Analysis Report Final design of the CEC shall involve the structures, equipment, equipment layout, control systems logic, and safety features presented and described in the Safety Analysis Report (SAR). The design and construction shall be in accordance with the standards identified in the SAR. This shall not preclude the changing of the SAR in accordance with License Condition 1.5.1. 6.6.5 Ouality Assurance Criteria A. Verification and validation of software important to safety and material control and accountability shall be in accordance with part 2.7, " Quality Assurance Requirements of Computer Software for Nuclear Facility Applications," of the NQA-2b-1991 . Addenda to ASME NQA-2-1989, " Quality Assurance Requirements for Nuclear Facility Applications." l i { B. Quality assurance controls of items and activities important to safety shall be in accordance with ASME-NQA-lb-1991 addenda to ASME NQA-1-1989, " Quality Assurance Program Requirements for Nuclear Facilities." i l l \\ \\ l \\ l l l l l l i l l l l l louisiana Energy Services Revision 2 Proposed License Conditions September,1993 \\ NRC License SNM - 6-4 Docket # 70-3070 1

7.0 DECOMMISSIONING PLAN Upon cessation of operations at the CEC, the CEC shall be decommissioned in order to i permit release of the CEC site and facilities for unrestricted use. Spills and contamination outside normally-contaminated plant areas shall be promptly cleaned. Enrichment equipment shall be removed; only building shells and the site infrastructure shall remain. All remaining facilities shall be decontaminated, where needed, to levels acceptable for unrestricted use. l ConHdential and Secret Restricted Data material, components, and documents shall be destroyed or disposed of in accordance with the LES CEC Security Plan for the Protection of Classified Matter and Information. In accordance with 10 C.F.R. @ 95.53, a "Cenification of Non-Possession" of classified information on the CEC site shall be submitted to the NRC Division of Security. Depleted UF (tails), if not already sold or disposed of prior to e deconunissioning, shall be sold, or shall be converted to a stable, non-volatile uranium compound and disposed of offsite in accordance with applicable regulatory requirements. Radioactive, hazardous, and mixed wastes shall be disposed of in accordance with regul tory requirements. Based upon an LES evaluation of decommissioning costs, financial arrangements shall be made to cover costs required for releasing the site and facilities for unrestricted use. Present estimates of costs and planned funding arrangements are provided in Exhibit I of the License Application. Updates on decommissioning costs and adjustments to funding levels shall be performed periodically and at least every five years, consistent with the requirements of Title 10 of the Code of Federal Regulations. A detailed plan for completion of decommissioning shall be submitted for the CEC in accordance with the requirements of 10 C.F.R. s 70.38. Louisiana Energy Services Revision 2 Proposed License Conditions September,1993 NRC License SNM - 71 Docket # 70-3070

i 8.0 EMERGENCY PLAN l LES shall maintain an emergency plan. The plans for maintaining the capability to respond l to off-normal occurrences at the CEC are detailed in the Louisiana Energy Services Claiborne l Eruichment Center Emergency Plan. This plan conforms to the " Standard Format and I i Content for Emergency Plans for Fuel Cycle and Materials Facilities," Regulatory Guide 3.67, January,1992. ) i I l 2 I i k P i 4 s I Exuisiana Energy Services Revision 2 f Proposed License Conditions September,1993 NRC License SNM - 8-1 Docket # 70-3070 e a ,w w a a

Appendix A, p 1 of 4 Revision 2 September 1993 I 1 a i GUIDELINES FOR DECONTAMINATION OI' FACILITIES AND EQUIPMENT i PRIOR TO RELEASE FOR UNRESTRICTED USE l ) OR TERMINATION OF LICENSES FOR BYPRODUCT, SOURCE, I i i OR SPECIAL h"JCLEAR MATERIAL 1 l a i 1 i a l i 1 i i j U.S. Nuclear Regulatory Comission ) Division of Fuel Cycle Safety ~ and Safeguards 3 Washington, DC 20555 l i I 1 ( April 1993 i I i

I 1 1 Appendix A p 2 of 4 Revision 2 September 1993 l { i 4 i The instructions in this guide, in conjunction with Table 1, specify the 1 l radionuclides and radiation exposure rate limits which should be used in decontamination and survey of surfaces or premises and equipment prior to i abandonment or release for unrestricted use. The limits in Table 1 do not apply to premises, equipment, or scrap containing induced radioactivity for which the radiological considerations pertinent to their use may be different. l The release of such facilities or items from regulatory control is considered on a case-by-case basis. l 1. The licensee shall make a reasonable effort to eliminate residual contamination. I 1. Radioactivity on equipment or surfaces shall not be covered by paint, j plating, or other covering material unless contamination levels, as determined by a survey and documented, are below the limits specified in Table 1 prior to the application of the covering. A reasonable effort must be made to minimize the contamination prior to use of any covering. 3. The radioactivity on the interior surfaces of pipes, drain lines, or ductwork shall be determined by making measurements at all traps, and other appropriate access points, provided that contamination at these locations is likely to be representative of contamination on the interior of the pipes, drain lines, or ductwork. Surfaces of premises, equipment, or scrap which are likely to be contaminated but are of such size, construction, or location as to make the surface inaccessible for purposes of measurement shall be presumed to be contaminated in excess of the limits. l 4. Upon request, the Commission may authorize a licensee to relinquish possession or centrol of premises, equipment, or scrap having surfaces contaminated with materials in excess of the limits specified. This may i include, but would not be limited to, special circumstances such as l razing of buildings, transfer of premises to another organization i continuing work with radioactive materials, or conversion of facilities to a long-term storage or standby status. Such requests must: a. Provide detailed, specific information describing the premises, equipment or scrap, radioactive contaminants, and the nature, l extent, and degree of residual surface contamination. i b. Provide a detailed health and safety analysis which reflects that the residual amounts of materials on surface areas, together with other considerations such as prospective use of the premises, equipment, or scrap, are unlikely to result in an unreasonable risk to the health and safety of the public. I l l a t

Appendix A. p 3 of 4 Revision 2 September 1993 2-5. Prior to release of premises for unrestricted use, the licensee shall mah a comprehensive radiation survey which establishes that contamination is within the limits specified in Table 1. A ccpy of the survey report shall be filed with the Divisien of Fuel Cycle Safety and Safeguards, U.S. Nuclear Regulatory Commission, Washington, DC 20555, and also the Administrator of the NRC Regional Office having jurisdiction. The report should be filed at least 30 days prior to the ) planned date of abandonment. The survey report shall: a. Identify the premises. b. Show that reasonable effort has been made to eliminate residual q contamination. i c. Describe the scope of the survey and general procedures followed. 1 d. State the findings of the survey in units specified in the instruction. i ) Following review of the report, the NRC will consider visiting the { facilities to confirm the survey. i i I l i 4 i l l l l l I l i l l i j i 1 l i l s

TALa 1 Appendix A, p % _. 4 Revision 2 ACCEPTABLE SURFACE CONTAMINATION LEVELS September 1993 NUCLIDES* AVERAGE *" MAXIMUM *" REMOVABLE

• U-nat, U-235. U-238, and associated decay products 5,000 dptn <d100 cm' 15,000 dpm <d100 cm 5,000 dpm u/100 cm' Transuranics, Ra-226, Ra-228 Th-230, Th-228, Pa-231, Ac-227, 100 dpm/100 cm 300 dpm/100 cm" 20 dpm/100 cm' l-125,1-129 Th-nat, Th-232, Sr-90, Ra-223 Ra-224, U-232,1-126,1-131,1-133 1000 dpm/100 cm' 3000 dpm/100 cm 200 dpm/100 cm' Beta-gamma emitters (nuclides with decay modes other than alpha emission or spontar'eous 5000 dpm By/100 cm' 15,000 dpm By/100 cm' 1000 dpm Bf100 cm fission) except Sr-90 and others noted above.

"Where surface contamination by both alpha-and beta-gamma-emitting nuclides exists, the lirnits established for alpha-and beta-gamma-emitting nuclides should apply independently. "As used in this table, dpm (disintegrations per rninute) means the rate of emission by radioactive material as determined by correcting the counts per minute observed by an appropriate detector for background, efficiency, and geometric factors associated with the instrumentation. ' Measurements of average contaminant should not be averaged over more than 1 square meter. For objects of less surface area, the average should be derived for each such object.

• The maximum contamination level applies to an area of not more than 100 cm'.

"The amount of removable radioactive material per 100 cm of surface area should be determined by wiping that area with dry filter or soft 2 absorbent paper, applying moderate pressure, and assessing the amoant of radioactive material on the wipe with an appropriate instrument of known efficiency, When removable contamination on objects of less surface area is determined, the pertinent levels should be reduced proportionally and the entire surface should be wiped. The average and maximum radiation levels associated with surface contamination resulting from beta-gamma emitters should not exceed 0.2 mrad /hr at 1 cm and 1.0 mrad /hr at 1 cm, respectively, measured through not more than 7 milligrams per square centimeter of total absorber.

Appendix B, Page 1 of 2 Revision 2 September,1993 LEAK-TESTING SEALED SOURCES 1. Sources Which Contain Alpha and/or Beta-Gamma Emitters A. 1. Each sealed 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 transferor 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 surface of the container or from the device where the scaled source is mounted or stored in which one might expect contamination 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 than described below, or 2. The presence of 0.05 microcuries or more of removable contamination from the teletheraphy 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 ac.ordance with the Commission regulations. Within 5 days after determining that any source has leaked, the licensee shall file a report with the Division of Fuel 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 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.

Appendix B, Page 2 of 2 Revision 2 September,1993 II. Sealed Uranium Sources A. Each uranium source shall be tested for leakage at intervals not to exceed 6 months. b 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 sample shall be taken from the source or from appropriate accessible surfaces 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 regulation. Within 5 days after determining that any source has leaked, the licensee shall file a report with the Division of Fuel 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 repon shall be sent to the Administrator of the nearest NRC Regional Office listed in Appendix D of Title 10, Code of Federal Regulation, Part 20. D. The periodic leak test required by this condition does not apply to scaled 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 pet -

• ss they have been leak tested within 6 months prior to the date of use or transfer.

) i 4

Appendix C, Page 1 of 1 Revision 2 September,1993 DEFINITIONS The defined terms of this section are applicable throughout these [ Proposed] License Conditions. Annually: 365 days 60 days. 1 Audits and Inspections: Audits are formal examinations made to verify that operations are being conducted according i to established criteria. Inspections are routine reviews to check that operations are being conducted according to approved procedures. Audits are more formal and less frequent than inspections. 1 Biennial: 24 months 90 days. Important to Safety: Those structures, systems and components necessary to prevent or mitigate events that could result in exposure to any offsite individual to 25 mg/m'(30 min /t) 5 [where t= time in minutes] of hydrogen fluoride and/or inhalation of 10mg of uranium. Preoverational: Beginning of site construction activities until receipt of licensed source material at the site. Quarterly: 90 days 20 days. Semi-annuallv: 183 days 30 days. Total Effective Dose Equivalent: Annual exposure with a 50-year committed internal dose component and an external dose component.

Attachmetzt A General Comments 1. Include a definitions section. Definitions section has been added as Appendix C. 2. Whenever the license conditions designates a named official "or designee" as the approving official for a number of activities, add " equivalently qualified designee." The phrase "or designee" has not been deleted. Anytime a " designee" is appointed, it is done in writing by the individual responsible for the aethity. It is the responsibility of the responsible individual to ensure the " designee" is qualified to perform the activity. 3. Replace "{s 20.1001-20.2401" by "s@ 20.1001-20.2402." "ss 20.1001 20.2401" has been replaced by "ss 20.1001-20.2402." 4. Consider implementing a tracking system which should include corrective actions from audits and inspectors findings, as well as audits. This will most likely be part of a corrective actions tracking system implemented at the CEC, but this requirement has not been added to the Proposed Licertse Conditions (PLCs). 5. There is no need to propose commitments that are already required by regulations. Items proposed as license conditions that are currently regulations have been deleted from the PLCs. 6. Regarding validation of computer codes important to safety and safeguards and verification of software important to safety and safeguards, include the requirement that software control will be in accordance with pat 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. A new section 6.6.5A has been added to include criteria for software important to safety and material control and accountability. A-1

Attachment A 7. Regarding quality assurance of items and activities imponant to safety and safeguards, include the requirement that quality assurance controls will be in accordance with the ASME-NQA-lb-1991 addenda to "ASME NQA-1-1989 Edition Quality Assurance Program Requirements for Nuclear Facilities." A new section 6.6.5B has been added to include criteria for items and activities important to safety. As described in the SAR, Section 10.1.4, material control and accounting and security are included in the QA Level 2 program. Specific Comments Chapter i Standard Conditions and Special Authori7 itions 1.1 Name. Address, and Corporate Information 1. First line. Delete first word i.e., "LES" before " Louisiana Energy Services. L.P.. l "LES" has been deleted as requested. 2. Delete second and third sentences. Second and third sentences have been deleted as requested. 3. Add site address. The site address has been added as requested. 1.2 Site Location 4. Define the areas where licensed activities are to be conducted. The areas where licensed activities occur have been described as requested. 5. Delete last three sentences. The last three sentences have been deleted as requested. A-2

Attachment A 13 License Number and Period of License 6. Delete this section. This section has been deleted. The remaining sections in Chapter 1 have been renumbered. 1.4 Possession Limits 7. Possession limits should be given in metric units with English units in parenthesis. Possession limits have been revised to provide quantities in metric units with English units in parentheses. 1.4.B Source Material 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. Possession limits in section 1.3B have been revised to be consistent. 1.4.C Rvoroduct Material 9. Delete the paragraph beginning with " Additional radionuclides may be..." including the two bullets. This is unlikely to occur in the near future. LES cannot add additional radionuclides without NRC approval. Paragraph has been revised to limit authorization to specific ranges of nuclides, and the maximum possession quantity has been reduced. 1.5 Authori7ed Activities 10. Add uses of the individual byproduct radionuclides. Urcs of the individual byproduct radionuclides have been added. I 1. 1.5.D Revise this statement to read as follows: " Chemical, spectrometric, radio-chemical, and non-destructive assay analyses of SM and SNM materials, including effluents and stored waste." A-3

Attachment A The sentence has been revised as requested. 12. 1.5.E Delete the words " hazardous" and " industrial." The NRC does not authorize treatment, etc., of hazardous and industrial wastes. The words have been deleted as requested. 1.5.1 Location Where Material is Used 13. 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. Paragraphs have been revised as requested. 1.6 Exemptions and Special Authori7ations 14. Commit to update the SAR and ER on a set frequency; at least once in two years. A commitment to update the Safety Analysis Report has been added to section 1.5.1. The Environmental Report (ER) will not be updated. The ER is used as input into the Environmental Impact Statement prepared by the NRC. 1.6.1 Safety Evaluation Process 15. Commit to inform the NRC regarding changes which affect but do not decrease the effectiveness of the QA program as described in the SAR. Changes to the LES Quality Assurance Program as described in Chapter 10 of the SAR which do not decrease the effectiveness of the Quality Assurance Program will be submitted as part of the biennial update of the SAR. This commitment has been added to section 1.5.1. 16. Delete item (b) since it is required by regulations. Item (b) has been deleted as requested. A-4

Attachtnent A 17. Add items f, g, and h to the list as follows: f) unreviewed safety issues, g) a significant change in the types of signi0 cant increase in the amounts of any efDuents that may be released offsite. and h) a significant increase in individual or cumulative occupational radiation exposure. Items (f),(g), and (h) have been added with minor word changes to better describe the intent of the safety evaluation process. 1.6.2 Exemptions and Special Authori7.ations 18. Note that 1.6.2.A is based on the 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. This paragraph has been deleted as requested to avoid a delay of the licensing schedule. However, LES will continue to seek a partial exemption for certain areas of the CEC facility. 19. Under B, commit to inform the NRC of a change widlin a definite period (e.g.,30 days) so that the staff has an up-to-date record of CEC owners, lienholders, etc. A commitment to this effect has been added at the end of 1.5.28. 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. The reference has been incorporated into section 1.5.2C as requested. 1.7 Financial Information and Commitments 21. The once-a-year reporting required by License Condition 1.7.A is probably 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. This commitment has been incorporated into section 1.5.2B. See response to comment 19. A-5

Attachment A 1.8 Reference for Section 1 22. Delete this section. Replace " Reference 1" in Section 1.6.2.C by " Appendix A." Section 1.8 has been deleted. Chnpter 2 Orennization and Administration 2.1 Oreanizational Responsibilities and Authority 23. Provide organization chart /s. Figure 2.1-1 has been added showing the related positions. 24. Under H, last word, capitalize first letter of the word " manager." The word " Manager" has been capitalized. 2.2 Personnel Education and Experience Requirements 25. Under K, for the HP Manager, provide the type of equipment in the statement " training of personnel in the use of equipment." Radiological support equipment has been identified as the type of equipment as I requested. 26. State that the CEC Manager shall hold, as minimum, a bachelor's degree in an engineering or scientific field and have a minimum of six years of responsible nuclear experience. The education and experience requirements have been added as requested. 27. State that the QA manager shall have at least two years experience in a QA organization at a nuclear facility. The experience requirements have been added as requested. 28. State that all Superintendents shall hold, as a minimum, a bachelor's in an engineering or scientific field and have a minimum of four years of responsible nuclear experience. A-6

AttachTnent a The education and experience requirements have been added as requested. 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 Manager shall each have, as a minimum, a bachelor's in a scientific field, and at least three years of responsible cyperience in the areas of health physics, chemical safety and industrial safety. I The responsibilities and qualifications of the Chemistry Manager and the Industrial Safety manager have been added as requested. The Health Physics qualifications have been revised as requested. 30. The Projects Manager shall have, as a minimum, a BS degree in an engineering or scientific field and three years of responsible nuclear experience, including one year of experience in the administration of nuclear criticality safety reviews. The requested changes have been made. 31. In addition to the requirements established by LES for the nuclear 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 and have the equivalent of two years of full time experience as a trained analyst. The requested requirements have been added. 2.3 Safety Committee 32. The scope of reviews conducted by the Facilities Safety Review Committee (FSRC) shall include, as a minimum, reviews of ongoing and proposed radiological, chemical, industrial and nuclear criticality safety activities and practices. Radiological, chemical, industrial, and nuclear criticality safety investigation, audit and inspection reports shall be included in the reviews. The scope of reviews conducted by the FSRC have been modified as requested. 33. The member ship of the FSRC shall have a person having, as a minimum, the qualifications of a nuclear criticality analyst. A-7

Attachment A The composition of the FSRC has been modified to ensure one individual has, as a minimum, the qualifications of a nuclear criticality safety analyst. 34. The safety committee snould also review the training program, incident reports, root cause reports, and violations of regulations or license conditions. The requested items have been added to the scope of FSRC review activities. 35. Provide criteria for the selection of auditors and FSRC members. The third paragraph of section 2.3 provides the criteria for selecting FSRC members. The second paragraph of section 2.7 provides the qualifications of audit team members. 2.5 Traininc 36. Commit to providing training to FSRC members in audit procedures and on possible error modes of management control systems. Section 2.3 has been modified to include the requested training for FSRC members. 37. Include performance based QA training in the formal. planned, and documented training program for all LES employees. The requirement for performance based QA training in the formal, planned and documented training program has been added for all LES employees engaged in QA related activities. 38. Appropriate training should also include visitors and contractors. The requirement for providing training to sisitors and contractors has been added to section 2.5. 39. Commit to providing indoctnnation training to all employees before they perform work at the CEC. Section 2.5 has been modified to ensure indoctrination training is completed before an employee begins work. A-8 l

Attachment A 40. Training should also address Part 19 issues and environmental protection. 10 CFR Part 19 issues and environmental protection have been added as training topics to section 2.5. 41. Training and retraining should also include chemical and industrial hazards, in addition to radiological and criticality safety control. Chemical and industrial hazards have been added as training topics to section 2.5. 42. Add fire safety preparedness to the disciplines included in the indoctnnation training of employees. Fire safety has been added as a training topic to section 2.5. 43. Delete the last full sentence on page 2-9. The sentence has been deleted as requested. 2.6 Operatine 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. The sentence has been modified to reflect that procedures will be in place and all training on applicable procedures will be conducted prior to receipt of licensed material. The part about availability for NRC inspection has been deleted. 45. State in this section that procedures will identify limits and controls important to safety. Section 2.6 has been modified stating 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 A-9

Attacilment A Section 2.6 has been modified stating there will be procedures for the maintenance and testing, of systems, 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). Section 2.6 has been modified to require a bknnial (maximum interval 27 months) review of a procedure. 2.6.1 Preparation of Procedures 48. Define term " required procedure." Section 2.6.1 has been revised to more clearly define " required procedure." 49. In the first paragraph. " Safety-related procedures," should be changed to " Procedures important to safety." " Safety-related procedures" has been revised to " procedures important to safety." 50. Move the second paragraph to Section 2.6. The second paragraph of section 2.6.1 has been relocated to section 2.6. 51. Clarify whether the independent review is to be outside the department or outside LES. The independent review requirement has been modified to clarify that the independent review is to be outside the group preparing the revision (i.e., different manager). 2.6.2 Chances to Procedures 52. Under D, identify the position title under which chemical and/or radiation safety, criticality safety and MC&A reviews wii! be performed. A statement has been added to section 2.6.2 indicating that one of the responsibilities of the approver of a procedure change is to ensure that the procedure change was A-10

Attachment A prepared and reviewed by qualified individuals. 53. Include a review on the effect of changes in radioactive environmental effluents. Section 2.6.2 has been modified to include explicitly a review on the effect of changes in radioactive environmental effluents. 2.7 Internal Audits and Inspections 54 Define audits and inspections without reference to Regulatory Guide 3.52. Audits and inspections have been defined without reference to Regulatory Guide 3.52. The definition has been added to the definitions section. 55. Include preventive maintenance, training, emergency planning, and QA in the list of minimum activities to be assessed by the audit program. Section 2.7 has been modified to include preventive maintenance, training, emergency planning and Quality Assurance in the list of minimum activities to be assessed by the audit program. 56. Define " annually" and " semi-annually," such as annually = 360 30 days. These should be placed in the definitions section. Definitions of annually and semi annually have been added to the definitions section. 57. Clarify if the audit discussed in this section is the same as that conducted by the FSRC. Section 2.7 has been reworded to clarify that the audits discussed in section 2.7 are conducted by the Quality Assurance organization. 58. Page 2-12, second paragraph: " inspection;" is in the midst of paragraphs concerning audits. It should be I moved to the end of Section 2.7. delete " routinely" and insert "in accordance with a written plan. Also in the A-11

Attachment A second sentence, replace " semi-annually" by " quarterly." third sentence: insert after " action," "shall be documented in a written report going to the appropriate manager for follow-up action." clearly indicate who (by position title) is responsible for the inspection + program. The paragraph concerning inspections has been moved to the end of section 2.7. " Routinely" has been replaced with "in accordance with a written plan." " Semi-annually" has been replaced with "in accordance with a written plan with the frequency commensurate with the activity being inspected." The requested wording has been inserted as requested. The first paragraph has been modified to indicate that the Quality Assurance group is responsible for the inspection program. Individuals from other groups provide technical assistance as necessary to support the Quality Assurance group. 2.8 investications and Reportine 59. Investigations should include root cause analysis. Root cause analysis has been added to the investigation process. 60. Environmental protection should also be addressed if appropriate. Environmental protection analysis has been added to the investigation process. Chapter 3 Radiation Protection 3.1.1 ALARA Policy 61. There should be a commitment to prepare an ALARA report at least 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. i Commitment added as requested. j i A-12 i i

Attachment A 62. Identify the position responsible for preparing the ALARA mpon. Commit to submit it to the CEC manager, and the members of the FSRC. Commitment added as requested. 3.1.2 Radiation work Permit Procedures 63. Suggest the word "closcout" instead of " termination" of the RWP. Revised as requested. 64. RWPs should be issued for activities at a fraction of the levels specified in the regulations. Commitments to ALARA are included in Section 3.1.1. LES agrees that RWPs will certainly be issued below the regulatory limits. Specific limits will be controlled through CEC plant procedures. Clarification of minimum criteria for issuing RWPs is provided in the first paragraph of Section 3.1.2. 65. The RWP should be posted at the location of the work area. Revised as requested. 66. Second bullet. Add Radiation Control Zones (RCZs) to Radiation Control Areas (RCAs). Add " radiation exposures exceeding action levels" to " radioactive contamination." Added as requested. 67. Delete the first sentence of the third bullet. Deleted as requested. 3.1.3 Written Procedures 68. Add the word " written" between " approved" and " procedures." Added as requested. 3.2.1 Restricted Area - Personnel Contamination Control 69. Describe the minimum protective clothing required in RCAs and RCZs. Minimum protective clothing requirements are specified on RWPs (see Section 3.1.2,3rd A-13

Attacitment A Minimum protective clothing requirements are specified on RWPs (see Section 3.1.2,3rd bullet). There are no minimum protective clothing requirements generally applicable to the CEC. 70. Last sentence. Describe the type of monitoring personnel will be required to perform upon exiting the RCA. Include the type /s of instrument /s that will be used. This commitment was added; however, specific types of instruments have not been included. Instruments will be selected which are appropriate to perform the required measurements. Committing to specific types does not increase the safety of the facility but may result in undue expense and unnecessary restrictions. 71. Third line. Add " external" before " radiation levels." Added as requested. 72. For clarity, separate discussions of RCA and RCZ. l Separated as requested. 3.2.2 Ventilation 73. Spell out "TSA." Spelled out as requested. 74. Commit to using filters. Provide filter types, their paniculate removal efficiencies, their testing and criteria for replacement. l This information has been added as requested. 75. Require filters to be replaced if the filters fail to function properly or if the differential pressure exceeds the manufacturer's rating for the filter. The integrity of the HEPA filters should be evaluated based on some criteria (i.e., pressure differential across the filier). ANSI guidance will be acceptable. This information has been added as requested. 3.2.3 Work Area Samplina 76. Set action levels for investigation and corrective action. Commitments added as requested. A-14

Attachment A well as when process or equipment changes have been made. i Commitment added. Note however, that this type of good practice, along with many more, will be specified in detail in plant procedures. 78. Second paragraph. State whether the Alpha-in-air monitors are active or passive. Identify the radionuclides for which eirbome concentrations will be determined using alpha-in-air monitors. Provide the LLDs for these radionuclides. Commitments added as requested. 79. Second paragraph, fourth line. Insert "and analyzed" between " changed" and "at." Added as requested. 80. First bullet, first line. Replace "or" by "and." Replace " leading" by "that may lead." Revised as requested. 81. Second bullet, first line. Before following," replace "or" by "and." Revised as requested. 82. Last paragraph. Move this paragraph to Section 3.2.6 entitled " Surface Contamination." Relocated as requested. 83. Provide action levels in terms of radionuclides air concentrations and describe the actions to be taken if these levels are exceeded. Commitments added as requested. 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. Commitment added as requested - in new Section 3.2.8. 85. Provide more detail in this section such as the types of instruments, ranges, calibration requirements, and maintenance requirements. Additional commitments have been added as requested. A.15

Attachment A Additional commitments have been added as requested. i 86. Second paragraph. Delete " Technical Services Area of the." Revised as requested. 3.2.5 Radiation Exposure 87. Replace "Whole Body:" by "TEDE:" which is the total effective dose equivalent. Replaced as requested. 88. & 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 100 2 2 dpm/100 cm beta-gamma or greater than 20 dpm/100 cm alpha. Paragraph relocated as requested. Minimum protective clothing requirements are specified on FWPs in accordance with the requirements specified in Section 3.1.2. 3.2.6 Surface Contamination 89. Describe methods of surface contamination surr.p. A commitment has been added that survey methods will be specified in procedures approved by the HP Manager. 90. Specify survey frequencies A commitment has been added that survey frequencies will be specified in procedures approved by the HP Manager. 91. Surveys should be conducted for areas other than just the UF6 process areas. For example the TSA, storage areas, change rooms, cafeteria, etc. Commitment expanded as requested. 92. Specify the limits for cleanup. Commitments to ALARA are included in Section 3.1.1. Specific requirements for cleanup may vary widely depending on the type and frequency of work performed for each respective area. 3.2.7 Bioagav Procram j A-16

Attacitment A 93. First paragraph. The first sentence may be interpreted as a commitment to perfonn bioassay measurements for all personnel wearing external dosimetry devices. Is this the intent? If not, then provide criteria for performing bioassay measurements. Clarified as requested. 94. Commit to conduct bioassay measurements in accordance with guidance associated with 10CFR20. Describe the bioassay program by providing measurement methodologies, sample collection frequencies, MDAs, etc. Additional information is provided as requested. 95. Commit to evaluating internal doses quarterly. Annual evaluation of internal dose is sufficient since air sampling requirements results in thorough knowledge of plant conditions. The bionssay serves to verify the adequacy of radiation protection practices. 96. Bioassay should occur sooner than 72 hours after suspected or known exposures. Specify the time period that would allow detection of an intake of 10 mg. The primary retention half life for uranium in the kidney is 6 days (and is equal or greater than 6 days for other organs unless excreted essentially immediately after inhalation). For Class D uranium, therefore, either the uranium is excreted prior to any bloassay is likely to be performed, or its biological half life is at least six days. Assuming 10 mg intake of Class D uranium occurs at one time and using a 72 hour criterion, approximately 7.5 mg will remain in the kidney 72 hours post exposure. This amount will be detected, and in addition, follow-up measurements are required once uranium activity is detected. 97. Set action levels for work restriction. A commitment is added to specify action levels in procedures approved by the IIP Manager. Chapter 4.0 Nuclear Criticality Safety 98. Commit to include 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. Commitment added as requested to Section 4.1.4. 4.1.4 Operating Procedures A-17

Attacitmettt A 99. Commit to conducting nuclear criticality safety department activities, which are required by the license, in accordance with written procedures. Such procedures shall be approved by the nuclear safety manager. Commitment added as requested. 1(X). 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. Since the Fomblin oil recovery waste is maintained in criticality safe geometries (see CSER 4.10.2), there appears to be no benefit in performing the requested analyses on the waste. Regarding sampling and analysis of the recoscred oil prior to its release, double sampling would undesirably increase cost and also double the usage of carbon tetrachloride. LES requests reconsideration of this comment based on the following: The estimated total annual uranium throughput of the recovery system is 7 kg (Table 3 of the CSER), and the minimum oil throughput is estimated at 56 gallons (212 liters). Though the planned batch size is smaller, the maximum batch size is 18.6 liters, giving a minimum of 12 batches. Tims, the most uranium ever expected in a batch of unprocessed oil is 600 grams, significantly below the critical safe limit. Oil which has not been processed cannot be mistaken for cleaned oil; the processed oil is very clear and clean while the unprocessed oil is quite dirty. Release of unprocessed or poorly processed oil would not reasonably occur even without testing for uranium. Given that the processed oil is processed in small quantities, and each small quantity is tested separately, double-testing doesn't appear to result in any increase in safety, yet does increase use of CCI, and increases operating cost. 101. Commit to analyzing every week at least two independent samples of the contents of each effluent collection tank in the UF handling area. Agreement 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 shift until the source of the uranium is identified and controlled. Commitment added as requested. 102. Commit to analyzing two independent samples of each TSA ef0uent 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 exceed 1000 grams uranium, corrective action shall include hourly sampling until the source of the uranium is identified and controlled. Commitment added as requested. A-18

Attachtnent A 103. The licensee shall analyze two independent samples of the citric acid baths each week, as well as, independent samples when the tank contents reach estimated 40%,60%, and 85% of the tank safe mass limit. Agreement shall be obtained 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. i Commitment added as requested. 104. Commit to limit the Chemical Laboratory area to not more than 7.0 kilograms of uranium. The administative limit shall be ensured maintaining a current inventory by logging transfers into and out of the laboratory. Except for increasing the suggested limit from 7 to 10 kg, the commitment has been added as requested. Calculations which derived the basis of the 7 kg (double the calculated 3.5 kg) are very preliminary. 105. Commit to surveying ventilation ducts servicing the enriched uranium processing areas annually (maximum interval of 15 months). If uranium is found, corrective action as a minimum shall include removal of the uranium. l Due to the impracticality of ductwork surveys, an alternative commitment has been added in Section 4.1.4.5 based on monitoring filter accumulation. 4.1.7 Desien Procedures 106. Commit to establish a configuration control program which shall, as a minimum, include the following: For all possession, use, and storage activities with enriched uranium at the facility, a. 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 systematic hazards analysis process for all current activities, (3) for each of the potential criticality accidents identified above, a current safety analysis which 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 A-19

AttGChtnent A requirements for maintenance, surveillance, personnel training, posting, and control of written procedures to ensure the effectiveness of the limits and controls. Commitment added as requested. 107. Prior to the use of vacuum pumps, LES shall provide to the NRC a safety analysis which demonstrates the use of the solid angle method for safely spacing vacuum pumps, and shall obtain NRC approval of the use of the solid angle method. The commitment has been added as requested, yet allowing also alternative methods of qualification. 4.2.2 Multiple Units or Arrays 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. The report shall specify the range of applicability and other parameters specified in ANSUANS-8.1. The validation report shall be maintained at the CEC facility. Commitment added as requested. 109. Commit to maintain a minimum 30-centimeter spacing, edge-to-edge, between units spaced by the surface density method. Commitment added as requested, 4.2.4 Special Controls 110. For the centrifuges, cascades, and assay units, the following commitments should be made: Limit the maximum inside diameter of the centrifuge housings to the safe diameter a. specified in Table 4.2-1 of the Proposed License Conditions. b. Introduce no enriched uranium as feed material to the cascades. Provide control room monitoring of cascade header pressure, power, feed supply c. power, feed supply pressure and valve position, cooling water temperature and flow, product take-off system pressure and valve position, and tails take-off system pressure and valve system. For unusual monitoring results, procedures shall describe corrective action including shutdown requirements. A-20

Attachment A d. Provide no interconnections which would allow enriched uranium to flow to the feed system. c. For each authorized enrichment campaign, calculate the control valve settings and instmct 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 UF, product for enrichment within 24 hours and compare the results with predicted results. If an adjustment is required, the actions in (c) 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 made, if necessary, as in (e) and (f) above. Commitments added as requested, except for item g. The product flow of 7 cascaces is collected in one product cylinder. The isotopic concentration is determined for each product cylinder, thus, a continuous survey and verification of performance of each respective group of 7 cascades is performed. I11. For the product take-off system, the following commitments should be made: Verify by cylinder weight, baroscope inspection, and vacuum testing that no internal a. contaminants are present before the cylinder is brought to the 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. c. Vent volatile gases to the Gaseous Effluent Vent System. Investigations shall be conducted and corrective actions taken whenever a predetermined number of vent cycles per cylinder has occurred. d. During and after filling cylinders in the product filling station and prior to moving the cylinder, solidify the UF. only with cool air. Heat product cylinders for blending or sampling only in autoclaves and only by using c. electrically heated air. The autoclave pressure and temperature shall be automatically controlled, continuously monitored, and alarmed during the heating cycle. After blending or sampling, but prior to moving the cylinders, solidify the UF by circulating 6 water in structurally independent cooling coils which are external to the autoclave. f. Limit the hydrogen to uranium ratio to not more than 1.0. A-21

Attachment A Commitments added as requested, except for the following changes: Item e, omitted the words " structurally independent," and Item f, qualified that the limit applied while "in-process" and included an allowance for cylinders with small amounts of hydrogen (in accordance with the CSER, section 4.2.3.2). I12. On a quarterly basis (maximum intervals of 4 months), commit to inspect the product and product blending desublimers to verify that no solid uranium compounds remain in the desublimers after the UF is transferred to the product cylinders. If uranium solids are present, the material shall be removed prior to reuse of the desublimer system. Commitment added to 4.2.4.3.g; action levels and maximum quantities are also included. I13. For each product and product blending desublimer system, the following commitments should be made: Use only chemical traps, pumps, and piping which satisfy the gccmetric limits a. specified in Table 4.2-1, of the Proposed License Conditions. Commitment added as requested. b. Maintain a positive pressure nitrogen atmosphere between the inner desublimer vessel and the outer shell. The positive pressure shall be continuously monitored and alanned to detect loss of atmosphere. Nitrogen is used to eliminate moisture for protection of the insulating material. As noted in the CSER, Section 4.3.1E loss of the nitrogen is of no criticality significance. Criticality analyses have conservatively assumed full reficction due to water. LES has included a commitment to provide an alarm which will indicate a loss of the nitrogen blanket. Heat and cool the desublimer vessel by freon in external closed loop heating and c. cooling coils. Commitment added as requested. d. Fit each inlet and outlet pipe with two valves in series, each of which is automatically operated by signal from continuous monitoring pressure and temperatum sensors. Consistent with the description in the CSER, section 4.3, one of the two valves in series is a manual valve. The commitment wording has been revised accordingly. c. Record the number and frequency of cylinder vents to control the desublimer A-22

Attacitment A inventory and to detect abnonnal venting intervals. Any abnormal venting shall be investigated. Commitn ent added as requested. 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. Commitment added for nitrogen pressure and automatic valve operation as requested. Item e. commits to implementing a monitoring system, which will not fall under a preventative maintenance program. I14. For chemical traps for mobile pump sets, the following commitments should be made: 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. d. Provide a frequency for weighing and replacing the activated carbon in the chemical traps. Commitments have been c.dded as requested. Ilowever, provisions have also been included to allow deviation from the specific commitments in accordance widi specified NRC-approved methods. I15. Provide a survey frequency for verifying that no uranium is accumulating in the contingency dump traps. Provide action levels and corrective actions to be taken if the action levels are exceeded. Action levels for uranium accumulating in the contingency dump traps are not necessary, as follows: Each cascade is provided with a single contingency dump connection, leading, via that cascade's contingency dump valve, to the contingency dump trap for that cascade. The contingency dump connection to the cascade is made upstream of the cascade tails terminal valve. This connection means that tails material is permanently in contact with the cascade side of the contingency dump valve. This design ensures that any seat leakage on the contingency dump valve results in tails material accumulating in the contingency dump trap thus precluding any criticality hazard. The contingency dump trap has been analyzed and shown critically safe at 1.5 wt% U* A-23

AttGChinettt A at full physical fill limit and optimum moderation and at worst credible reflection. This analyzed U " enrichment is in excess of 1.2 wtSc, the maximum mean cascade 2 concentration achievabic within the cascade operating envelope. Consequently, inadvertent overfilling of the cascade contingency dump trap due to valve seat leakage does not constitute a criticality hazard. Calculations of trap fill rate due to valve seat leakage are somewhat academic as the answer depends on the seat leakage magnitude. From the point of view of critically hazard, the magnitude of this leak specifically and of uranium collection in the trap in general is irrelevant i16. For contingency dump traps, the following commitments should be made: a. Limit the inside diameter of the dump traps to not more than 51.7 centimeters. The latest version of the Criticality Safety Engineering Report no longer bases contingency dump criticality safety on a diameter of less than 51.7 cm. Accordingly, an alternative commitment has been included instead of the one suggested. b. Prior to use. independently verify and document that the contingency traps have been loaded with the correct amount of activated NaF. Commitment added as requested. c. Replace the trap media immediately following an emergency dump. Commitment added as requested, with qualification to avoid the need for replacing follmving dumping of insignificant quantities of UF.. I17. 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. Commitment added as requested. Chapter 5 Environmental Protection 118. Add page numbers to the figures and tables. l' age numbering scheme will be revised as requested. 5.1 Effluent Control Systems A-24

Attachment A 119. At a minimum, there should be a commitment that radiological effluent streams are treated. The commitment regarding treatment of gaseous effluent may be found in Section 3.2.2, Ventilation. The commitmcet to treat all potentially radioactive liquid effluent may be found in the first paragraph of Section 5.1.2, Liquid Efiluents. 5.1.1 Gascous Effluents 120. Provide frequencies for replacing activated alumina in chemical traps. Frequency added as requested. 121. Filters should be removed at least daily and analyzed for gross alpha and not weekly as stated. This frequency of sampling is unnecessary for this facility. IIF alarms will alert operators of any unusual UF6 release through the Gaseous Efiluent Vent System (GEVS). A commitment has been added to remove the filters daily following a higli-IIF alarm until gross alpha levels return to normal. 122. Composites 01 de daily samples should be donc quarterly and analyzed for uranium with an LLD of less than or equal to IE-18 pCi/ml. Since the gross alpha action levels are set assuming conservatively that all the alpha is due to U* (Class D compound), further quarterly analysis for uranium is unnecessary. If the gross alpha action levels provided in Table 5.1-1 are exceeded, further isotopic analysis for the uranium isotopes is performed. The commitment for an LLD of 1F 16 pCi/mi is provided; this value is selected to be consistent with the dose analysis presented in detail in Section 4.2 of the ER (see for example section 4.2.1.2.3). Only class D compound limits are relevant to gaseous effluent discharge. (It should also be noted that it is extremely difficult, practically speaking, to analyze a quarter's worth of filters and get meaningful results. License conditions for reactors also allow alternate means such as the one proposed for the CEC.) 123. The text is unclear whether action levels and LLDs are for the weekly or quarterly analysis. Action levels and LLDs should be set for both the daily and quarterly samples. The stated action levels have been clarified as applying to '.he running quarterly average. This running average is updated and reviewed weekly. Continuous monitoring of gaseous effluent for IIF provides satisfactory indication of any significant spikes in UF, release amounts between weekly review of the running average. Releases not detected A-25

Attacittnent A by the liF alarms would not be significant with respect to annual plant discharge limits. The action levels are set to indicate a need for further isotopic analysis; need for this analysis would not be indicated due to occasional spikes or " hiccups" in operation which are not significant enough to also affect the running quarterly average. 124. 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 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." Commitment added as requested, with qualification of "significant" added, and with a revision of time from 30 to 60 days. 5.12 Liouid Effluents 125. In the first paragraph, LWD should be spelled out. Revised as requested. 126. In the second paragraph, the reference to Part 20 release limits should contain the Part 20 Table number. Added as requested. 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. Clarification has been added as requested to Sect on 5.1.2. The final discharge from the i facility is from the Sewage Treatment System (STO, and the sampling point downstream of the STS (in accordance with NPDES sampling requirements) will be used to demonstrate Part 20 limits are not exceeded. In addition,it is intended that the facility license include a further restriction to 57c of these limits at the STS discharge. The LES administrative limit for STS discharge is 0.57c of the Part 20 limits. 128. Composites of the compliance sample should be done and sampled quarterly for uranium and for Tc-99. Specify LLD for these samples. Consistent with ASTM C996-90, UF, product samples will be measured for U u. If the 2 ASTM U2" limits are exceeded, Tc" will also be measured. LES does not expect Tc" to A-26 i

Attacilment A ever exist in significant quantities at the CEC site, and does not expect to have to measure product samples for Tc". Should Tc" actually be present in feed material,it would collect preferentially in the product stream. Therefore, using the product sample as a reasonable screening tool, LES has added a commitment to test a composite liquid effluent sample for Tc" once per month for at least three consecutive months immediately following any product sample measurement which exceeds the referenced ASTM limits for US. Gross alpha action levels have been added to the Proposed License Conditions for liquid effluents. Quarterly sampling and analysis for uranium is unnecessary since the action levels are set assuming that all the alpha is due to uranium. A commitment is also included such that if the gross alpha action levels (provided in a new Table 5.1-2) are exceeded, further isotopic analysis for specific uranium isotopes is performed. An LLD commitment has been included for each uranium isotope in liquid effluent for this purpose. 129. 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. The LLD for gross alpha screening has been revised, provided in Table 5.1-2. 130. Specify the LLD for gross beta. Gross beta analysis is not performed. The Proposed License Conditions have been clarified to explain how gross alpha is used for screening. 131. The sludge from the STS system should be sampled semiannually for uranium accumulation. Commitment added as requested. 132. Provide the following commitments: The NRC shall be informed within 30 days if the State-permitting agency revokes, supersedes, conditions, modifies, or otherwise nullifies the effectiveness of the State-issued permit for the discharge of liquid efDuents. The NRC shall be informed within 15 days if the State-issued permit for the discharge of liquid effluents is violated. Commitments added as requested. 133. Second paragraph. Clarify that the Sewage Treatment System effluent is released on a continuous or batch basis. Commit to conducting continuous sampling. A-27

AttGChinent A Commitment and clarification added as requested. 134. Last paragraph. Add "less than or equal to" after " activity shall be." Qualifications made as requested. 5.2 Environmental Monitorine 135. In the first line change the word " establish" to " implement." Revised as requested. 136. Commit to review monitoring data on an annual basis for trends and evaluate impacts to the public and environment. Commitment added as requested. 137. First paragraph. Add sampling of sediment to the list of media to be sampled. Insert, after " program" "in accordance with Table 5.2.1." l Revisions made as requested. l 138. On page 5-3,3rd paragraph, specify the LLD for uranium and gross beta. Also add the LLDs for soil and vegetation samples. LLD's for soil and vegetation have been added as requested to Table 5.2-2. Since gross alpha is used for screening, no commitments regarding gross beta or uranium analyses are specified. Table 5.2-1 Radiolocical Monitorine Procram 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 material. Table has been split as requested. 140. Clarify what the analysis frequency is. Describe how composite samples are done. Be sure to include the quarterly composite for air sampics that is analyzed for uranium (at a minimum this should be done at the sample location for the nearest resident). The analysis frequency has been clearly specified to match the sample collection frequencies. Please see response to item 122 regarding compositing of quarterly samples. A-28 l

Attachinettt A 141. Reinsert a brief description of the sampling location. Include a sample number for easy reference. Delete the word " potential." Revised as requested. 142. Storm-water sampling should be included, this could be at the hold up basin. Stormwater is covered by sample site #2 on Figure 5.2-1. (The hold-up basin does not maintain a water level during normal operation and is not suitable for operational sampling.) Stormwater sampling and analysis will be performed in accordance with the state-issued permit requirements, which are also addressed by comment #132. 143. The table states that all sudace water samples will be collected on a continuous basis, is this your intent? Yes - using a continuous integrating sampler. 144. Table 5.2.1, Delete Note #2. These terms should be defined in the definitions section. Revised as requested. Table 5.2-2 Action Izvels for Environmental Analyses 145. Add the levels for gross beta and uranium. Please see response to item 156. Since gross alpha is used for screening, no commitments regarding gross beta or uranium analyses are specified. 146. Replace " CI/ML" by " Ci/ml" and CI/G "by" " Ci/g." Revised as requested. Chapter 6 Special Processes 6.2 Occupational Safety 147. Provide action levels for HF and the corrective aedons to be taken if these are exceeded. Provide exposure limits for HF. This information has been added in Section 6.2. 6.5 I.imitine Conditions for Operation A-29

Attachment A 6.5.1 Autoclaves 148. In item a, change "with any autoclave" to "any autociave with. Add "'" between "260" and "F." The requested changes have been made. 149. Based on the SAR, there is no reason to believe that CEC needs to operate such that the feed autoclave pressure is higher than 44 psia, and sampling and blending autoclave pressures are higher than 87 psia. The requested changes have been made except that the pressures have been increased slightly (i.e.,44 to 50 and 87 to 100) to allow for design and instrumentation margins. 6.5.2 Yard Transponers 150. The fuel capacity should not be greater than approximately 70 gallons. The requested change has been made. 6.6 Other special Commitments 151. Add section on product and feed cylinder maintenance and surveillance. Section 6.6.1 has been modified to include feed and product cylinders. 152. State that none of the feed, product and tails cylinders will be stacked. Section 6.6.1B. has been modified as requested. 6.6.1 Tails Cylinder Maintenance and Surveillance 153. Under D, after "only designated vehicle" insert "with less than 70 gallons of fuel." Added as requested. 154. Under F, clarify LES' intent on anti-corrosion treatment. Since all UF. cylinders are treated in accordance with ANSI N14.1, this paragraph has A-30 l

AttGCitmettt A been deleted. 155. Under H, need to define what is "significant deterioration" and to develop procedure to resolve" significant deterioration problems in the storage yard." This information has been added to paragraph G as requested. 156. 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 st:mdards identified in the SAR." This section has been added. 6 6.2 I iouid UF6 157. Delete "and cannot by design." This phrase has been deleted. 7.0 Decommissionine Plan 158. The fourth line of the test should read "to levels acceptable for unrestricted use." This has been modified as requested. 159. Commit to promptly cleaning up spills and contamination outside nonnally-contaminated plant areas. This commitment has been added as requested. Chapter 8 Radiolacical Contincency Plan 160. Change the title to " Emergency Plan." The title has been changed to " Emergency Plan." A-31 (}}