ML20058G897
| ML20058G897 | |
| Person / Time | |
|---|---|
| Site: | Claiborne |
| Issue date: | 11/29/1993 |
| From: | Leroy P LOUISIANA ENERGY SERVICES |
| To: | Jim Hickey NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9312100171 | |
| Download: ML20058G897 (20) | |
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Post Olhce Box 1004 h
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Charlotte, NC 28201-1004 November 29,1993 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 Responses to NRC Comments on LES Proposed License Conditions File: 6046-00-2001.01
Dear Mr. I& key:
Please find enclosed LES' responses to your letter dated November 10,1993, which transmitted NRC comments on the LES Proposed License Conditions (PLCs), License Application, and the Safety Analys... Report (SAR). Attachment A repeats each NRC comment and details the LES response. These responses will be reflected in updates to the PLCs and the SAR which will be submitted to you on Dcccmber 3,1993.
The responses provided are the result of many conversations held with your staff since the receipt of your letter. We have attempted to reach consensus on all items. If the responses do not completely close the outstanding issues concerning the PLCs, please let us know as soon as possible.
If there are any questions concerning this, please call me at 704-382-2834.
Sincerely, Yh$. Yg Peter G. LeRoy Licensing Manager llAllLNROn011 Attachment n et n n..,3 l
9312100171 931129 PDR ADOCK 07003070 C
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Noven ber 29,1993-i Mr. John W. N. Hickey, Chief Page 2 4
(1 copy of attachment) l xc:
I Mr. Morton B. Margulies, Esq., Chairman
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Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l
Ms. Diane Curran, Esquire
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Harmon, Curran, Gallagher, & Spielberg i
2001 S Street, NW, Suite 430 l
Washington, D.C. 20009-1125 l
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Mr. R. Wascom Office of Air Quality and Radiation Protection Louisiana Department of Environmental Quality e
PO Box 82135 l
Baton Rouge, Louisiana 70884-2135 i
Ms. Nathalie Walker Sierra Club Legal Defense Fund 400 Magazine Street' Suite 401 New Orleans, Louisiana 70130 6
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r Attachment A Page 1 of 18 LES' RESPONSE TO:
NRC STAFF COMMENTS ON LES PROPOSED LICENSE CONDITIONS NRC Letter Dated November 10,1993
. l General Comments Aoplicable to:
Safety Analysis Reoort i
1.
Update the Safety Analysis Report (SAR) to reflect changes in the PLC. For example, your letter of October 14,1993, states that the boundary between Radiation Control 72mes (RC7s) and Radiation Control Areas (RCAs) will be based on the criteria provided in Section 8.2 of the SAR, (also reflected in Section 3.2.1 of the PLC). Howevei, Sections 3.2.1.2 and 3.2.3 of the PLC and Section 11.8.2.2 of the SAR, state that RCZs will be both permanent and temporary.
Such inconsistencies must be resolved.
l SAR Figure 8.2-1 has been revised to specify that RCZ locations are representative, and will be specified in accordance with the CEC License Conditions. In addition, the following SAR figures have been revised to reflect the Technical Services. Area (TSA) arrangement as shown in SAR Figure 1.2-3: Figures 4.4-1, 5.2-44, 6.4-1, 6.4 25, 6.4-27, I
8.2 1, 8.4-1.
2.
Add to Section 6.4.9 of the SAR the following commitments:
Administrative controls shall be implemented on operations such as a.
welding, torch-cutting, other " hot work," and any non-routine use of l
flammable or combustible materials. (For guidance, NFPA 51B, Fire l
Prevention in Use of Cutting and Welding Processes, should be consulted.)
I b.
Regular walk-down audits of the facility shall be implemented to detect and correct departures from good housekeeping practices or operating procedures that may influence fire safety. (Weekly or at least monthly i
audits are recommended.)
i The fire hazard analysis shall be reviewed and updated at biennialintervals i
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1 or sooner in case of substantial changes in the facility or processes.
Deficiencies,if any, revealed by the analysis shall be corrceted expeditiously.
These statements have been added as requested.
3.
Provide ranges and alarm set-points for monitors listed in Table 8.4-1 of the SAR.
I Realistic ranges and setpoints will be specified in procedures based on information developed during the final design process and/or during facility operation.
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1 Attachment A
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Page.2 of 18 l
License Conditions 4.
You have designed your Radiation Protection Program to only show compliance with the radiologicallimit of 5 rem a year. In addition,the program must also i
show compliance with the weekly 10 mg intake limit based on chemical toxicity of soluble uranium. You must also ensure that your action levels, lower limits of detections (LLD), intake criteria for controlling areas, and administrative limits are low enough to account for uncertainties in determining uranium intakes.
Toxicological limits are now also included m Section 3. An action level of 1 mg uranium j
intake per week has been added, with an LLD of either 0.02 mg in the total sample, or an LLD of 1E-13 pCi/ml concentration. Exceeding the action level would require calculation of personnel stay time, use of respirators, isotopic analyses, or some other method to ensure worker safety.
t Definitions of RCA/RCZ and various limits for radiation and toxicological protection have been revised for consistency. These are summarized below.
i RCA: (1) Area where airborne concentrations of radionuclides (corrected for background) are sufficient to have the area designated as an " Airborne i
Radioactivity Area" as defined in 10 CFR 20.1003.
(2) Area where the radiation levels (corrected for background) are sufficient to have the area designated as a " Radiation Area" as defined in 10 CFR 20.1003.
(3) Area where the contamination levels (sum of fixed and removeable, corrected 2
2 for background) exceed 150 dpm/cm alpha or 150 dpm/cm beta / gamma.
(4) Area where the intake of soluble uranium in one week could reach I milligram.
RCZ: (1) Area where airborne concentrations of radionuclides (corrected for background) are sullicient to have the area designated as an " Airborne l
Radioactivity Area" as defined in 10 CFR 20.1003 and will result in a Committed Effective Dose Equivalent (CEDE) that is greater than 25% of the annual organ or total body 50 CFR 20 limit if respiratory protection is not utilized.
4 (2) Area where the radiation levels (corrected for background) are suflicient to l
have the area designated as a "Iligh Radiation Area" as defined in 10 CFR 20.1003. Small areas within an RCA that meet the definition of an RCZ may be posted without having the entire area designated as an RCZ.
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I (3) Area where the removeable contamination levels (corrected for background) i exceed 1000 dpm/100 cm alpha or 1000 dpm/100 cm beta / gamma. This applies 2
2 only to areas that are accessible to workers when no work intrusive to facility
Attachment A Page 3 of 18 components is being performed. Small areas not accessed by workers and areas not accessible to workers may be posted without having the entire aren designated as an RCZ.
(4) Area where the intake of soluble uranium in one week could exceal 1 milligram.
5.
You should provide the full date on your PLC, not just the month.
The footer has been revised as requested.
6.
The term " designee" is used throughout the PLC. Define " designee."
The definition has been added to Appendix C as requested. " Designee: A person authorizal to carry out the responsibilities of another. Authorization shall be designated in writing and only to individuals determined to have the qualifications to carry out the designated responsibilities.
7.
The development and production of oil and gas wells from the surface within the 179 hectare (442 acre) CEC site boundary shall be prohibited for the duration of license.
This condition has been added to Section 6.6.
Decommissioning Funding Documents 8.
With reference to the decommissioning funding document forms submitted as part of the license application, <k following revisions are necessary for conformance with Regulatory Guide 3.bu.
Section 5 of the Form of External Trust Agreement (Exhibit I, Attachment a.
A to LES Application for Licenses) at page A-2 to include the following:
"No withdrawal from the Fund can exceed 20 percent of the outstanding 4
balance of the Fund unless NRC approval is attached."
b.
Section 5 of the Form of Standby Tmst Agreement (Exhibit I, Attachment
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C to LES Application for Licenses) at page C-2 to include the following:
"No withdrawal from the Fund can exceed 20 percent of the outstanding balance of the fund unless NRC approval is attached."
These revisions have been incorporated into the License Application, Revision 8, submitted by letter dated November 12,1993.
Specific Comments on License Conditions:
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Attachment A Page 4 of 18 Chaoter 1: Standard Conditions and Special Authori7ations t
6 13 Possession Limits t
9 LES' request for 300 millicuries of Cesium-137 and 100 millieuries of Cobalt-60 shall be limited to sealed sources. If unsealed materials are needed, much lower quantities may be requested.
As raguested, a note has been added to Section 13C such that the listed activities of Cesium-137 and Cobalt-60 are limited to scalal sources. In addition, new activity levels have been includal for the two nuclides in any form: 50 mci Cesium-137 and 20 mci Cobalt-60.
i 6 1.4 Authorized Activities i
6 1.4.1 Location Where Material Is Used 1
i 10.
Add the storage areas to this section.
The storage areas have been added as requestal.
6 1.5 Exemptions and Soccial Authorizations 6 1.5.1 Safety Evaluation Process J
l 11.
Under b), add " safeguards" to "...or component important to safety."
1 Safeguards issues are addressed in the Fundamental Nuclear Material Control Plan.
Any change which could decrease the elTectiveness of this plan cannot be implemented without prior approval of the NRC, as stated in the Code of Federed Regulations (10 i
CFR 70.32(c)(lii)). Accordingly, this change is unnecessary.
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12.
Add to the first full paragraph,on top of page 1-7: "LES shall implement the OA i
program as described in Chapter 10 of the SAR."
This sentence has been added as requested.
6 1.5.2 Exemptions and Soccial Auth( rizations
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13.
Under A, last paragraph,last line, revise to read as follows: " liens, or limited partnership, within 60 days of the change (s)."
This correction has been includal, as raguestal.
Chapter 2: Organization and Administration
Attachment A Page 5 of 18 l
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6 2.1 Ormmizational Responsibilities and Authority 14.
The Chemistry Manager is responsible for analysis of effluents. Clarify who is in charge of collecting the samples and making sure the effluents are below limits.
The Chemistry Manager responsibilities have been clarified as requested to include effluent sample collection and comparison of ellluent analysis results to limits.
15.
Clarify whether the Industrial Safety Manager is responsible for all facility safety programs or just industrial safety.
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The Industrial Safety Manager responsibilities have been clarified as requested. The l
woni " industrial" has been inserted between " facility" and " safety."
16.
Specify who is in charge of the training program.
l Section 2.1.D has been revised to indicate the Integrated Scheduling Superintendent is responsible for the training program described in Section 2.5.
17.
Identify the positions that have authority to shut down operations that threaten the health and safety of plant personnel, the public, or the environment.
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Section 2.1 has been revised to indicate as a minimum which positions have the l
authority to shut down operations that threaten the health and safety of plant personnel, the public, or the environment. In Section 2.1 this includes the CEC l
Manager and the superintendents.
18.
The Projects Individual and V esponsibilities should be included in f 2.1.
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Among his responsibilitiesincede conducting and reporting quarterly nuclear criticality safety inspections.
i The responsibilities of the " Projects Analyst" have been specified in paragraph 2.1.L, as -
i requested.
6 2.2 Personnel Education and Experience Reauirements 19.
The CEC Manager should also be familiar with chemical and industrial safety.
This requirement has been added as requested.
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Attachment A Page 6 of 18 20.
On page 2-6, revise the qualifications of the QA Manager as follows: "The Quality Assurance Manager shall have, as a minimum,a bachelor's degree (or j
equivalent)in an engineering or scientific field and at least four years of i
responsible nuclear experience in the implementation of a quality assurance program. The QA Manager shall have at least two years experience in a OA organization at a nuclear facility."
The qualifications have been revised as requested.
21.
On page 2-7, add to the qualifications of the Health Physics Manager the following sentence: "At least two years of experience shall be at a facility that processes uranium, including uranium in soluble form."
This qualification has been added as requested.
22.
On page 2-8, in the second paragraph, replace "at least one individual"with "a Project Individual."
The wonis "at leas' one individual" have been replaced by the term " Projects Analyst."
23.
On page 2 8, revise the third paragraph to read: "Should a change to the facility require a nuclear criticality safety evaluation, the analysis shall be performed by an individualwho, as a minimum, possesses the qualifications of the Projects Individual. An independent review of the analysis shall be performed by an individual who, as a minimum, has the education and training of a Projects 3
Individual. In addition, this individual shall have at least two years of experience performing criticality safety analyses and implementing criticality safety programs."
This revision has been incorporated as requested, referencing the Projects Analyst.
6 2.3 Safety Committee 24.
Add the QA program to the list of programs to be audited.
This has been 'added as requested.
6 2.5 Training 25.
Include a commitment to evaluate the training program at least every two years (no more than 27-month intervals), and to review the program content to ensure the programs are current and adequate.
This commitment has been added as requested.
26.
Specify that the effectiveness of all required training shall be evaluated with
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Attachment A Page 7 of 18 appropriate measurement tools.
This commitment has been added as requested.
6 2.6 Operatine Procedures l
27.
Training requirements shall be satisfied prior to " implementation of the procedure" and not prior to " receipt of licensed material."
This revision has been incorporated. To avoid misunderstanding of the intent of
" implementation," the word "use" has been substituted.
L 28.
Identify the purpose of the biennial review and who is responsible for conducting it.
The purpose of the biennual review of operating procedures (review for adequacy) has been added as requested. This has been specified as the responsibility of the Operations Superintendent.
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6 2.6.1 Preparation of Procedures 29.
Procedures should also identify limits important to environmental protection as l
applicable.
This has been added as requested.
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30.
To minimize the potential for conflict between departmental and administrative 3
procedures and maximize consistency throughout facility procedures, commit to developing and implementing policies for an integrated approach to procedure development and approval.
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This commitment has been added as requested.
i 6 2.7 Internal Audits and Inspections j
31.
The responsible Superintendent should respond in writing to deficiencies noted in inspections and audits.
This commitment has been added as requested.
32.
The second sentence, first paragraph, states: " Audits and inspections are the responsibility of the OA Manager." In light of the license condition that "The FSRC shall conduct at least one facility audit per year..." (page 2-9), the second sentence should read: " Audits (except those conducted by the FSRC), and inspections (except nuclear criticality safety inspections conducted by a Projects
Attachment A Page 8 of 18 Individual) are the responsibility of the QA Manager."
The word "These" has been inserkd at the beginning of the second sentence to clarify which audits and inspections are being discussed. Additionally, references to FSRC
" audits" in Section 2.3 have been revised to FSRC " reviews."
i 33.
The last sentence, first paragraph, revise to read: "As a minimum, they shall assess programs and activities related to:"
This commitment has been added as requested.
34.
In this section," Quality Assurance" is on the list of functions to be audited under the QA Manager. It should be made clear that the activities related to QA that are to be audited under the CEC QA Manager are QA activities performed by personnel outside the CEC QA organization. The activities performed by the CEC QA organization should be audited by personnel outside the CEC QA organization. For example, the activities of the CEC QA organization could be t
audited as part of the FSRC annual audit (see page 2-9).
This section has been revised accordingly.
6 2.9 Records 35.
Records of the FSRC activitics shah he maintained for the life of the facility.
This has been added as requested.
Chaoter 3: Radiation Protection i
6 3.2.1 Restricted Areas - Personnel Contamination Control i
36.
Delete " personnel" from the first sentence. The program should control contamination of all kinds.
i This has been deleted as requested.
37.
Specify action levels for skin and personal clothing contamination at the time of egress from RCAs and RCZs. (See Regulatorf Guide 8.24)
Action levels for skin and clothing contamination have been added as requested. Action 2
2 levels are 150 dpm/100 cm alpha, and 150 dpm/100 cm beta / gamma. These are selected to be consistent with the definitions of an RCA and RCZ.
6 3.2.2 Ventilation
4 Attachment A Page 9 of 18 38.
Commit to designing ventilation equipment such that normal air flow and leakage flow are from areas of lesser potential contamination to areas of higher potential
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contamination. Commit to performing quarterly checks (e.g., smoke tests) to ensure compliance with this requirement.
The design commitment has been incorporated as requestal, with the addition of one word: "cenerally from areas of lesser..." Smoke testing is not necessary since work area monitoring is performed and RCAs are set up as needed for worker protection.
39.
Commit to performing efficiency (leak) tests for 0.3 m AMAD particles in the GEVS and TSA HEPA filter systems prior to first use.
This commitment has been added as raluested.
40.
Commit to measuring the differential pressure across HEPA filter systems on a prescribed frequency (e.g., monthly). Commit to operating filters only within differential pressure values recommended by the manufacturer.
This commitment has been added, applicable to IIEPA filters in potentially contaminatal ventilation exhaust systems (i.e., TSA Ventilation System and the Gaseous Ellluent Ventilation System). The commitment is to measure differential pressure monthly, or to automatically monitor and alarm the difTerential pressure. Operating procedures will specify limits /setpoints on the differential pressure consistent with manufacturer's recommendations.
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41.
The last line uses the term " abnormal release." Quantify or define what constitutes an abnormal release.
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A sentence has been added stating "This shall include, as a minimum, any unplanned re! case which activates an alpha in-air or IIF alarm."
6 3.2.3 Work Area Air Sampling l
42.
The representatives of the air samples of the work station should be checked
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annually and when significant process or equipment changes have been made.
This commitment has been addal as raluested. The commitment includes the ratuiirment that proculures specify how representativeness is to be determined.
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43.
Propose an LLD which is lower than 5% cf the value listed in Appendix B of 10 CFR 20.1001 - 20.2402, Table 1, Column 3. For natural uranium,5% of the radiological DAC would result in a worker intake of about 2 mg for a weekly exposure. Note that for soluble uranium, footnote 3 of Appendix B of 10 CFR 3
20.1001 - 20.2402, implies a DAC of 0.2 mg/m based on the weekly intake limit of 10 mg.
Attachment A Page 10 of 18 A lower LLD is now specilled as follows: Either an LLD of 0.02 mg uranium in the total sample, or an LLD of IE 13 pCi/ml gross alpha concentration.
r 44.
First bullet. Propose an action level which is less than 10% of the radiological DAC. For natural uranium,10% of the radiological DAC would result in a worker's intake of about 4 mg for a weekly exposure. State whether the air concentration level is averaged over the entire week or applicable to any one given time. Replace "when uranium concentration are expected to exceed"...by..."when uranium concentrations are likely to exceed."
An action level of 1 mg of uranium has been included. The wording change has also been incorporated as requested.
6 3.2.4 Radioactivity Measurement Instruments t
45.
Commit to calibrating air flow measuring devices used for air samplers upon installation and subsequently on an annual basis.
A commitment to calibrate air flow measurement devices prior h m initial use of the e
devices has been included. A commitment to an annual calib., va or verification of the desices is also included. Verifications provide assurance that the instrument is measuring relevant parameters within the tolerances stated in procedures. Examples of i
calibration and verification are as follows:
Calibration of a germanium detecton This consists of a full energy / channel and efilciency/ energy calibration. It includes generation of curves that fit energy / channel and elliciency/ energy data with fit parameters. It is followed by a verification.
e Verification of a germanium detector: This consists of measurement of a known source / standard. It tests the calibration coefilcients generated during the most recent calibration. For a germanium detector, this would involves testing two or more points on the calibration curve. Data is thea compared to knowns via procedures to determine if the data is within the tolerance or acceptance limits.
46.
Commit to calibrating all radiation measuring instruments on at least a semi-l annual basis and following installation and maintenance.
A commitment to calibrate radioactivity measurement instruments prior to the initial use of the instruments has been included. A commitment to an annual calibration or verification of the devices is also included. See the response to Item 45 for clarification of calibration and verification.
47.
Commit to using calibration sources which are 5% of the stated value and traceable to NIST or equivalent.
o Attachment A Page 11 of 18 4
This commitment has been added as requestal.
48.
Commit to determining on a daily basis (less frequently only if necessitated by long counting intervals), the background and efficiency of laboratory counting instruments, when in use for radiation protection purposes.
This commitment has been added as requested.
6 3.2.5.1 Barriers 49.
Commit to maintaining a prescribed minimum air pressure differential (e.g.,0.25 inches water) in glove boxes containing removable surface contamination.
Commit to checking the differential pressure on a weekly basis while the glove box contains removable surface contamination.
A commitment has been addal to require that glove boxes be designed to maintain 0.1 inches of water differential pressure. This differential pressure of 0.1 inches shall be maintained anytime that use of the glove box is likely to result in excealing the limits of 10 CFR20.1003, Airborne radioactirity arra. If the required difTerential pressure is lost, use of the glove box shall cease until required differential pressure is restored.
50.
Commit to maintaining the air flow through the open face of hooda within a prescribed range (e.g.,100 to 150 feet per minute) when in use.
This commitment has been added as requested. A minimum face velocity of 100 rpm e
shall be maintained for hoods when in use. Additionally, air flow rates at other exhausted enclosures and close-capture points shall be adequate to preclude escape of airborne uranium and minimize the potential for intake by workers when in use.
51.
Commit to checking air flow rates through hoods on a monthly basis while in use.
This commitment has been added as requested for hoods, and also includes other exhausted enclosures and close-capture points (not applicable to the decontamination bath rim ver.t systems). The air flow rates will also be checked after modification of any hood, exhausted enclosure, or close-capture points.
6 3.2.6 Surface Contamination 52.
Identify the areas that will be surveyed for surface contamination and provide survey frequencies. NRC staff recommends that RCAs and RC7s be surveyed at lcmi once every month, and the lunch and change rooms be surveyed at least once every week.
A commitment has been added to survey the RCA/RCZ areas at least weekly, and the lunch and change rooms at least daily.
l Attachment A Page 12 of 18 53.
Commit to periodically surveying laundered protective clothing for gross alpha and gross beta contamination. Provide action levels. Propose actions to be taken if these levels are exceeded.
This commitment has been added as requested. Action levels shall correspond to the i
2 area where the protective clothing will be used, i.e.,150 dpm/100 cm for RCAs and 1000 dpm/100 cm for RCZs.
2 54.
Provide an action level for cleanup of removable surface contamination in an RCZ.
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Action levels have been added as follows: for removeable surface contamination,5000 dpm/100 cm alpha or 5000 dpm/100 cm beta / gamma; for fixed contamination,250,000 2
2 dpm/100 cm alpha or 250,000 dpm/100 cm beta / gamma.
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6 3.2.7 Bioassay Program 55.
Provide an LLD for urine bioassay samples in terms of pg/l. The LLD should be set so that a detection and measurement can be made of a single intake of less than 10 mg of soluble (Class D) uranium by a reference man. The air and bioassay sampling periods specified by license condition, and detection instrument capabilities should also be taken into account in setting an LLD.
An LLD of 5 g/ liter is added, assuming that the urine sample is taken within 10 days of the postulated intake and that at least 1.4 liters of the sample is available from a 24-hour sample period. If all reasonable attempts to obtain a 1.4 liter 24-hour sample within the 10 days fail, such that the 5 g/ liter cannot be achieved, the sample will be analyzed for uranium concentration (if measureable) and the worker's intake will be estimated using other data.
56.
Commit to restricting workers from activities that could routinely or accidentally result in internal exposures to soluble uranium,until a urinalysis result is less than a specific threshold value (e.g.,15 pg/l).
This commitment of 15 pg/l has been added as requested.
57.
First Paragraph. A bioassay program that is able to detect an intake activity of 5% of the ALI specified in 10 CFR Part 20 is inappropriate from the standpoint of the chemical toxicity of uranium. An intake of 5% of the ALI corresponds to about 150 mg of uranium-238 (175 mrem EDE). Criteria for performing bioassay should be based on intakes of less than 10 mg of depleted uranium. NRC staff recommends the first paragraph to be revised as follows:
" Internal radiological exposures shall be evaluated annually."
Attachment A Page 13 of 18 I
" Based on air sampling monitoring data, bioassays shall be performed for all personnel who could have had an intake of mg of uranium. The bioassay program shall be able to detect an intake activity corresponding to mg of uranium."
The above sentence " Internal radiological..." has been incorporated as requested. The next sentence " Based on air sampling. " is completed, specifying 1 mg. The last sentence "The bionssay program..." has been replaced, using the information in the response to Item 55.
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58.
Second Paragraph. Revise the beginning of the second sentence as follows: "If a worker could have inhaled radionuclide concentrations that would exceed..."
The sentence has been added as requested, using the wording "are likely to exceed" instead of "would exceal."
59.
Second Paragraph. Lower the criterion for performing a bioassay after suspected or known internal exposure to uranium. For a Class D compound of uranium,12 DAC hours corresponds to an inhalation of about 10 mg of uranium-238. The criterion for performing a bioassay should be set at a small fraction of the regulatory limit.
i This has been revised as ruinested, as addressul in items 4,43,55, and 56.
Chaoter 4: Nuclear Criticality 6 4.1.4.5: Active Ventilation Systems 60.
Add a license condition as follows: "At least every three years (maximum interval of 42 months), the licensee shall survey the ventilation ducts for uranium deposition. As a minimum,if uranium deposition (other than surface contamination)is found, corrective action shallinclude removal of the uranium.
This commitment has been added as requestal. Alternativelg,",LES may choose to demonstrate with measurements that the total quantity of U in a ductwork system is less than half of the safe critical mass, based on safe critical values specified in Table 4.2-1. For this latter approach, U"5 in any connected ductwork which could conceivably combine in normal or abnormal operating c<mditions, shall be added to determine the U5 total U "5 mass of the system. Corrective action shall be to remove U such that the total is less than half of the safe critical mass.
LES intends to perform surveys using U"5 measurements, in recognition that the NRC concern is to preclude criticality with appropriate license conditions. The phrase "other than surface contamination" is therefore interpreted in this light.
Attachment A Page 14 of 18 f
Chaoter 5: Environmental Protection 6 5.1.1 Gaseous Effluents 61.
Action levels for gross alpha shall be based on the weekly gross alpha analysis results and not the running quarterly average.
Action levels are now stated based on the weekly gross alpha as requested. - Additionally, isotopic analysis shall be performed should the running quarterly average also exceed limits.
62.
The LLD for alpha isotopic shall be 1E-17 Ci/ml.
j The LLD for semi annual composites (see Item 63 below) has been specified as IE-17 pCi/ml. The LLD for analyses in response to exceeding rtmning quarterly average action levels is specified as.lE-16 Ci/ml.
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63.
Isotopic analysis shall be conducted on quarterly composites.
I Modified to " isotopic analysis shall be conducted on semi annual composites." Analyses will be for U U235,and U238, 234 64.
The timeframe for preparing and submitting the report which identifies the cause of exceeding the 40 CFR 190.10 limit and the corrective actions to be taker, to reduce release rates shall be submitted within 30 days.
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Modified as requested.
65.
The last paragraph of this section concerning the chemical traps should be moved to {3.2.2 Ventilation.
The description of the GEVS has been modified to clarify how this is an effluent system, not a general ventilation system.
5 5.1.2.2 Sewage Treatment System Effluent 66.
CEC shall analyze a composite sample for Tc-99 on a semiannual basis. The LLD shall be at least 3E-7 pCi/ml.
1 This commitment has been added as requested.
67.
CEC shall also analyze the semiannual composite sample for uranium.
A commitment to analyze for total uranium has been added.
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Attachment A Page 15 of 18 l
4 5.2 Environmental Monitorine i
68.
Delete the first paragraph on page 5-4 which begins "Iecations of sample sites. "
i Samples that are specified in Table 5.2-1 cannot be changed without NRC l
approval. If the intent of this paragraph is to allow flexibilityin the exact sample location for a sample specified in Table 5.2-1, the text should be clarified.
l The paragraph has been deleted as requested.
69.
Commit to submitting a biennial report summarizing the monitoring program results.
i This commitment has been added as requested.
70.
On Table 5.2-1 Radiological Environmental Monitoring Program:
l Preooerational Monitorinc
~ AP1, AP2 Specify the sector.
e Rather than specifying precisely which sectors will be monitored, the criteria for selecting these sectors has been stated. Selection ofinitial sectors shall be based on Shreveport data. After live years (maximum 66 months) of onsite meteorological monitoring the sector selection will be reevaluatal. Sampling locations shall be modified in accordance with the criter!a. The reevaluation shall be performed every five years (maximum 66 months) after the initial and subsequent evaluations. Necessary l
changes shall be implemented within six months of the evaluation.
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AP6 Delete the 2nd sentence.
i b
in light of the response regarding API and AP2, this deletion is no longer necessary.
AP7 Location is not needed, represented by API, AP3.
In light of the response regarding API and AP2, this deletion is no longer necessary.
AP3 The maximally exposed individualis not located at the site bounday.
Figure 5.2-3 has been revisal to indicate the map of the sample sites shown is representative, subject to the criteria of Table 5.2-1.
Liquid / Shoreline Sediment Delete " Combine samples from... composites."
Deleted as requested.
Liquid / Bottom Sediment Delete " Combine samples from... composites."
wuLw-
Attachment A Page 16 of 18 Deleted as requested.
Operational Monitoring AP1, AP2, Specify the sector.
Rather than specifying precisely which sectors will be monitorni, the criteria for selecting these sectors has been stated. Selection ofinitial sectors shall be based on Shreveport data. After five years (maximum 66 months) of onsite meteorological monitoring, the sector selection will be reevaluntal. Sampling locations shall be 3
modified in accordance with the criteria. The reevaluation shall be performed every five years (maximum 66 months) after the initial and subsequent evaluations. Necessary changes shall be implemented within six months of the evaluation.
AP3 The maximally exposed individualis not k>cated at the site boundary.
Figure 5.2-3 has been revised to indicate the sample sites shown are representative, subject to the criteria of Table 5.2-1. As the sample sites are revised, Emergency Plan Figure 6.4-2 will be revised.
AP3 Isotopic analysis shall be conducted on a composite sample on a quarterly basis.
Modilini to " isotopic analysis shall be conducted on a composite sample on a semi-annual basis." Analyses will be for U*, U*, and UM.
AP6 Delete 2nd sentence.
i in light of the response regarding API and AP2, this deletion is no longer necessary.
AP7 Location is not needed, represented by AP1, AP3.
t In light of the response regarding API and AP2, this deletion is no longer necessary.
Liquid / Shoreline Sediment Delete " Combine samples from... composites."
Deleted as requested.
Liquid bottom Sediment Delete " Combine samples from... composites".
Deleted as requestal.
It is also LES' understanding that the NRC recommends gross alpha analysis of the stormwater samples which are taken in accordance with NPDES permit. A commitment has been added to perform this analysis and to take action iflevels exceed 20 picoeuries/ liter nbove background.
i v
Attachment A Page 17 of 18 Chaoter 6: Soccial Processes 71.
Feed autoclaves, feed purification cubicles, product and tails cylinder stations, and blending receiver cylinder stations shall be equipped with load cells to monitor cylinder contents and these load cells shall be operable at all times that the individual pieces of equipment are in use for UF transfer.
6 This commitment has been addal as requested.
6 6.2 Occupational Safety l
72.
Provide specific commitments related to training of personnel who have access to RCAs and RCZs. Include topics to be covered, refresher training requirements, and continuous evaluation of the effectiveness of the program.
This has been added as requested, including topics such as ALARA, time-distance-l shielding, types and characteristics of hazards, doses, employee right-to-know, and toxicity.
73.
For alpha-in-air monitors, add the equivalent alarm setpoint for alpha.
This setpoint cannot be selected at this stage of the design due to site-specific variables unknown at this time (e.g., background readings). Though specification at this point is unfeasible, it does not impact the stated commitment to alarm at 3 ppm IIF.
74.
For alpha-in-air monitors, specify locations, i.e., UF handling, utility. and 6
blending areas.
The UF IIandling Areas and the Illending Area have been specified for IIF monitoring.
6 The Utility Area, suggested due to potential leaks in the GEVS equipment contained therein, does not require IIF monitoring for worker protection. Should the GEVS fans be rimning, any leakage would be inward. If the system is not operable (fans not I
rtmning), no IIF would be brought into the Utility Area such that it could leak out. The GEVS fans are not located in the Utility Area, i
- j 6 6.5 Limiting Conditions for Operation E 6.5.1 Autoclaves 75.
Under 6.5.1.a, add: "...or air pressure exceeding psia."
This condition (at 50 psia) has been added as requested.
6 6.63 Cylinder Fill Limits F
a Attachment A Page 18 of 18 76.
Commit to checking the weight of feed cylinders.
This has been added as requested.
6 6.6.4 Safety Analysis Report 77.
Replace "The design and construction shall be in accordance with the standards i
identified in the SAR" with "The design, construction and operation shall be in i
accordance with standards and representations identified in the SAR."
This section has been revised as requested.
78.
Delete " License Condition" from the last sentence and replace it with "Section."
i This revision has been incorporated as requested.
S 6.6.5 Ouality Assurance Criteria 79.
Revise license conditions as follows:
'I e Item B: Quality assurance controls of System Class 1 items and activities shall i
be in accordance with the basic and supplemental provisions of ASME-NOA -!
1989,"Ouality Assurance Program Requirements for Nuclear Facilities," including i
the changes made by the ASME-NOA-la-1990 Addenda and the ASME-NOA-1b-
[
1991 Addenda.
- Item C: Quality Assurance of System Class II items shall be in accordance with SAR Section 10.19.
Item Il has been incorporated as requested. Item C has also been added, with the clarification that the SAR may be revised in accordance with Section 1.5.1.
Chapter 7: Decommissioning Plan i
I 80.
Append the following sentence to the second paragraph: "These cost estimates along with their bases will be submitted to the NRC for review."
This has been added, with the additional qualification upon request."
Chanter 8: Emergency Plan l
81.
Specify that LES shall maintain an NRC approved emergency plan.
{
This has been revised as requested.
F
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