ML20058P659

Forwards Rev 6 to Criticality Safety Engineering Rept Push- Pull Instructions, Rev 16 to SAR Push-Pull Instructions & Proposed License Conditions

ML20058P659
Person / Time
Site:	Claiborne
Issue date:	10/14/1993
From:	Leroy P LOUISIANA ENERGY SERVICES
To:	Jim Hickey NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
Shared Package
ML20058P662	List: ML20058P659 ML20058P673 ML20058P682
References
NUDOCS 9310250142
Download: ML20058P659 (71)

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c LOUISANA s,.. iw4 EyERGY c"*""c '"' ~ ~'

October 14,1993 c

Mr. John W. N. Hickey, Chief Enrichment Branch Division of Fuel Cycle Safety and Safeguards, NMSS U. S. Nuclear Regulatory Commission Washington, D.C. 20355

Subject:

Docket No.: 70-3070 Louisiana Energy Services Claiborne Enrichment Center Revisions to Licensing Documents File: 6046-00-2001.01

Dear Mr. Hickey:

On October 6,1993, you and members of your staff called with clarifying comments affecting the Claiborne Enrichment Center Proposed License Conditions (PLC), the Criticality Safety Engineering Repon (CSER), and the Safety Analysis Report (SAR).

Most of the comments resulted from outstanding issues not completely resolved during the LES/NRC meeting held on September 8,1993. LES's responses to your comments are provided in the enclosed revisions to._LES licensing documents. Enclosed documents include five copies of revisions to the PLC (Revision 3) and the CSER (Revision 6), and twenty-four copies of revisions to the SAR (Revision 16). Also enclosed is Attachment A, which explains the changes made in these revisions.

If there are any questions concerning this, please call me at 704-382-2834.

Sincerely, f

$Y Peter G. LeRoy gf f

Licensing Manager.

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October 14,1993' Mr. John W. N. Hickey, Chief Page 2 xc:

'(1 copy of enclosures)

Mr. Morton B. Margulies, Esq., Chairman Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Ms. Diane Curran, Esquire Harmon, Curran, Gallagher, &. Spielberg 2001 S Street, NW, Suite 430 Washington, D.C. 20009-1125 Mr. R. Wascom Office of Air Quality and Radiation Protection Louisiana Department of Environmental Quality PO Box 82135 Baton Rouge, Imuisiana 70884-2135 Ms. Nathalie Walker Sierra Club Legal Defense Fund 400 Magazine Street Suite 401 New Orleans, Louisiana 70130

L Attachment A Page 1 of 4 The following items explain the changes requested by the NRC and the responses provided by LES.

Comments on the Proposed License Conditions (PLC) 1.

(Section 1.3C) - Delete Iridium from the list of authorized byproduct materid. Use of Iridium at the CEC by a licensed contractor does not require the CEC to have a license for

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the material.

Deleted as requested.

t 2.

(Section 1.3C) Delete the penultimate paragraph of the section (beginning with "In addition...)

i This paragraph has been deleted. A number of specific radionuclides have instead been i

added to the list of authorized radionuclides.

3.

(Section 1.3C) State whether or not all byproduct material will be sealed sources.

All byproduct will not necessarily be in sealed sources. This information has been stated in Section 1.3C.

4.

(Section 1.5.1) Revise "a) through d)" to read "a) through e)" in the 7th paragraph.

l This correction has been made as requested.

5.

(Sections 2.lF and 2.lG) Add to these sections the responsibilities listed in the penultimate paragraph of Section 1.5.1.

These responsibilities have been added to sections 2.1F and 2.1G as requested.

6.

(Section 2.2) Define equivalence to a bachelor's degree.

A definition has been added to Appendix C.

7.

(Section 2.2) No education credit should be applied towards fulfillment of experience requirements for key CEC management positions.

The option to fulfill a part of the experience requirements for key CEC positions with education credit has been deleted.

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7 Attachment A Page 2 of 4 8.

(Section 2.3) Revise to use wording of comment #32 in NRC letter dated 9/1/93.

Wording has been revised as requested.

9.

(Section 2.5) include procedure changes as a required topic for retraining.

i This requirement has been added as requested.

10.

(Section 4.2.1) Provide commitments requiring NRC approval prior to use of Monte-Carlo computer codes, similarly to the commitment in Section 4.2.2.

Commitment has been added as requested.

I 1.

(Section 4.2.4.4) Revise the Km for alternate designs or analyses to a maximum allowable value of 0.93.

i Revised as requested.

4 12.

(Section 4.2.4) Include a commitment to visually inspect the Fomblin oil for completeness of cleaning prior to releasing the oil from a geometrically safe containct.

This commitment has been added as requested.

l 13.

(Section 4.1.4.5) Describe the location of the HF alarms referenced in this section.

These HF alarms are located both upstream and downstream of the Gaseous Effluent Vent System filter train, as shown on SAR Figure 6.8-12, " Utility Flow Diagram, Gaseous Elliuent Vent System."

14.

(Section 4.1.7.1) Based on the analysis already submitted, the last sentence of this section may be deleted.

Sentence deleted as suggested.

15.

(Section 6.6.5A) Add the words " Quality assurance of software and" to the beginning of this section.

Added as requested.

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Attachment A Page 3 of 4 t

16.

(Section 6) Add a commitment that LES shall transport filled product cylinders only using LES-approved transport equipment.

This commitment has been added in a new Section 6.6.6.

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Comments on the Criticality Safety Engineering Report (CSER) 17.

(Section 4.1.2I) Consistent with planned changes to the FNMC and the PLC, revise the 6-month sampling ofindividual cascades to one year.

Revised as requested.

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i 18.

(Section 4.1.2) Correct the reference to monthly mass balances; the dynamic inventory will be performed bi-monthly (i.e.. every other month) for the CEC.

The reference to a monthly mass balance has been deleted.

19.

(Section 4.4.1) Revise the last paragraph of this section to be consistent with the last i

paragraph of Section 4.2.4.4 of the PLC regarding chemical trap change-out.

This section has been revised as requested.

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20.

(Section 4.8.2) Include a commitment to visually inspect the Fomblin oil for i

completeness of cleaning prior to releasing the oil from a geometrically safe container.

This commitment has been added as requested.

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Comments on the Safety Analysis Report (SAR) 21.

(Section 8.2.1) State the bases for the general dose estimates listed in Table 8.2-1.

The dose estimates are based upon historical data from the operating Urenco centrifuge enrichment facilities. This has been added to section 8.2.1.

22.

(Section 8.2.2.1) Although it is stated in the second paragraph that "As a minimum. a monitor (frisker), step-off pad and container for any discarded protective clothing are provided at the egress point from the RCZ to prevent the spread of contamination", no l

monitor is explicitly shown on Figure 8.2-1, sheet 2 of 3.

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Attachment A Page 4 of 4 f

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Specific monitor /frisker locations for RCZ exits are not shown in Figure 8.2-1 because exact boundaries between the RCZs and RCAs will be established in accordance with the criteria provided in SAR section 8.2. Monitors / friskers will be provided at RCZ exits as stated in SAR section 8.2.2.1.

23.

(8.2.4.1.1) Confirm that the Contaminated Workroom shown in Figure 8.2-1, sheet 2 of 3. is considered part of the Contaminated Equipment Workshop described in SAR section 8.2.4.1.1.

I The Contaminated Workroom is considered part of the Contaminated Equipment Workshop. This section has been revised to state this explicitly.

l 24.

(8.2.4.3) Add Tables 8.2-5 and 8.2-6 to the last sentence of this section.

The tables have been added as requested.

i 25.

(Table 8.2-2) "Whole body" should be " Total Effective Dose Equivalent."

i "Whole body" has been replaced with " Total Effective Dose Equivalent" as requested.

t 26.

(Section 11.1.4) No education credit should be applied towards fulfillment of experience requirements for key CEC management positions.

The option to fulfill a part of the experience requirements for key CEC positions with education credit has been deleted.

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F Page 1 of 1

_s Louisiana Energy Services Proposed License Conditions Push-Pull Instructions Revision 3, October 14, 1993

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Remove Insert

" List of Effective Pages

" List of Effective Pages pages 1 through 4 pages 1 through 4

" Table of Contents"

" Table of Contents" pages i through vii pages i through vill

" Introduction"

" Introduction"

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page I-1 page I-1 pages 1-1 through 1-8 pages 1-1 through 1-9 pages 2-1 through 2-16 pages 2-1 through 2-16 Figure 2.1-1 (page 2-17)

Figure 2.1-1 (page 2-17) pages 3-1 through 3-8 pages 3-1 through 3-8 t

pages 4-1 through 4-10 pages 4-1 through 4-10

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Table 4.2-1 (page 4-11)

Table 4.2-1 (page 4-11) i pages 6-1 through 6-4 pages 6-1 through 6-4 Appendix C Appendix C page 1 pages 1 through 2 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 latest revision and date of the revision affecting the page.

l 3)

All changes or additions to texc of each document are i

indicated by a sidebar (l) in the right hand margin.

In the case of deletion of text, the hidebar appears in the right hand margin with a perpendicular line towards the text (1 )

indicating where material was deleted.

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LOUISIANA ENERGY SERVICES PROPOSED LICENSE CONDITIONS LIST OF EFFECTIVE PAGES Pace / Table / Figure Number

• Revision Number. Date of Revision Table of Contents i

Rev. 3,10/14/93 ii Rev. 3,10/14/93 iii Rev. 3,10/14/93 iv Rev. 3,10/14/93 v

Rev. 3,10/14/93 vi Rev. 3,10/14/93 vii Rev. 3,10/14/93 viii Rev. 3,10/14/93 Introduction p I-1 Rev. 3,10/14/93 Section 1.0 p 1-1 Rev. 3,10/14/93 p 1-2 Rev. 3,10/14/93 p 1-3 Rev. 3,10/14/93 p 1-4 Rev. 3,10/14/93 p 1-5 Rev. 3,10/14/93 p 1-6 Rev. 3,10/14/93 p 1-7 Rev. 3,10/14/93 p 1-8 Rev. 3,10/14/93 p 1-9 Rev. 3,10/14/93 NOTE: p = page F = Figure T = Table Inuisiana Energy Services Revision 3 Proposed License Conditions October,1993 NRC License SNM -

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l LOUISIANA ENERGY SERVICES 1

PROPOSED LICENSE CONDITIONS i

LIST OF EFFECTIVE PAGES Section 2.0 p 2-1 Rev. 3,10/14/93 p 2-2 Rev. 3,10/14/93 l

p 2-3 Rev. 3,10/14/93 l

p 2-4 Rev. 3,10/14/93 p 2-5 Rev. 3,10/14/93 p 2-6 Rev. 3,10/14/93 p 2-7 Rev. 3,10/14/93 p 2-8 Rev. 3,10/14/93 p 2-9 Rev. 3,10/14/93 p 2-10 Rev. 3,10/14/93 p 2-11 Rev. 3,10/14/93 p 2-12 Rev. 3,10/14/93 p 2-13 Rev. 3,10/14/93 p 2-14 Rev. 3,10/14/93 p 2-15 Rev. 3,10/14/93 O

p 2-16 Rev. 3,10/14/93 F 2.1-1 (p 2-17)

Rev. 3,10/14/93 Section 3.0 p 3-1 Rev. 3,10/14/93 p 3-2 Rev. 3,10/14/93 p 3-3 Rev. 3,10/14/93 p 3-4 Rev. 3,10/14/93 p 3-5 Rev. 3,10/14/93 p 3-6 Rev. 3,10/14/93 p 3-7 Rev. 3,10/14/93 p 3-8 Rev. 3,10/14/93 NOTE: p = page F = Figure T = Table O

Louisiana Energy Services Revision 3 Proposed License Conditions October,1993 NRC License SNM -

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LOUISIANA ENERGY SERVICES t

PROPOSED LICENSE CONDITIONS LIST OF EFFECTIVE PAGES i

Section 4.0 i

p 4-1 Rev. 3,10/14/93 p 4-2 Rev. 3,10/14/93 p 4-3 Rev. 3,10/14/93 p 4-4 Rev 3, 10/14/93' p 4-5 Re. 3,10/14/93 p 4-6 Rev. 3,10/14/93 p 4-7 Rev. 3,10/14/93

~l p 4-8 Rev. 3,10/14/93 p 4-9 Rev. 3,10/14/93 p 4-10 Rev. 3,10/14/93 T 4.2-1 (p 4-11)

Rev. 3,10/14/93 l

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

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T 5.1-2 (p5-6)

Rev. 2,09/14/93

'i T 5.2-1 (p 5-7 through 5-12)

Rev. 2,09/14/93 T 5.2-2 (p 5-13)

Rev. 2,09/14/93 F 5.2-1 (p5-14)

Rev. 2,09/14/93 i

F 5.2-2 (p 5-15)

Rev. 2,09/14/93 F 5.2-3 (p 5-16)

Rev. 2,09/14/93 1

NOTE: p = page F = Figure T = Table Inuisiana Energy Services Revision 3 Proposed License Conditions October,1993 NRC License SNM -

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LOUISIANA ENERGY SERVICES PROPOSED LICENSE CONDITIONS LIST OF EFFECTIVE PAGES Section 6.0 j

p 6-1 Rev. 3,10/14/93 p 6-2 Rev. 3,10/14/93 p 6-3 Rev. 3,10/14/93 p 6-4 Rev. 3,10/14/93 Section 7.0 t

p 7-1 Rev. 2, 09/14/93 Section 8.0 I

p 8-1 Rev. 2, 09/14/93 i

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. 3,10/14/93 p2 Rev. 3,10/14/93 NOTE: p = page r

F = Figure T = Table

-c Louisiana Energy Services Revision 3 Proposed License Conditions October,1993 NRC License SNM -

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Proposed License Conditions Table of Contents Section Pace Number INTRODUCTION I-1 1.0 STANDARD CONDITIONS AND SPECIAL AUTHORIZATIONS 1-1 1.1 NAME, ADDRESS, AND CORPORATE INFORMATION 1-1 1.2 SITE LOCATION 1-1

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L3 POSSESSION LIMITS 1-2 1.4 AUTHORIZED ACTIVITIES 1-5 1.4.1 Location Where Material Is Used 1-5 t

i 1.5 EXEMIrTIONS AND SPECIAL AUTHORIZATIONS 1-6 l

O 1.5.1 Safety Evaluation Process 1-6 l

i 1.5.2 Exemptions And Special Authorizations 1-7 1

1.6 FINANCIAL INFORMATION AND COMMITMENTS 1-9 I

2.0 ORGANIZATION AND ADMINISTRATION 2-1 2.1 ORGANIZATIONAL RESPONSIBILITIES AND AUTHORITY 2-1 i

2.2 PERSONNEL EDUCATION AND EXPERIENCE REQUIREMENTS 2-5 l

l 2.3 SAFETY COMMITTEE 2-8 l

2.4' APPROVAL AUTHORITY FOR PERSONNEL SELECTION 2 2.5 TRAINING 2-10 2.6 OPERATING PROCEDURES 2-11 O

Louisiana Energy Services Revision 3 Proposed License Conditions October,1993 NRC License SNM -

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Louisiana Energy Services

-j Proposed License Conditions Table of Contents l;;

i Section

- Pace Number -

l 2.6.1 Preparation Of Procedures

.2-11 2.6.2 Chances To Procedures 2-11 l

i 2.6.3 Distribution Of Procedures 2-12 2,7 INTERNAL AUDITS AND INSPECTIONS 2-13 l

2.8 INVESTIGATIONS AND REPORTING 2-14 i

2.9 RECORDS 2-15 l

3.0 RADIATION PROTECTION 3-1

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I 3.1 SPECIAL ADMINISTRATIVE REQUIREMENTS 3-1 3.1.1 ALARA Policy 3-1 3.1.2 Radiation Work Permit Procedures 3 l 3.1.3 Written Procedures 3 i 3.2 TECHNICAL REQUIREMENTS 3-2 3.2.1 Restricted Areas - Personnel Contamination Control 3-2 i

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3.2.1.1 Radiation Control Areas 3-2 I

3.2.1.2 Radiation Control Zones 3-2 3.2.2 Ventilation 3-3 3.2.3 Work-Area Air Sampline 3-4 s

3.2.4 Radioactivity Measurement Instruments 3 -

3.2.5 Radiation Exposures 3-5

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r Louisiana Energy Services Proposed License Conditior.s Table of Contents -

Section Pace Number 3.2.5.1 Barriers 3 I

-I 3.2.6 Surface Contamination 3 1 3.2.7 Bioassay Procram 3-7

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3.2.8 Calibration Source Leak Tests 3-8 4.0 NUCLEAR CRITICALITY S AFETY 4-1 4.1 ADMINISTRATIVE CONDITIONS 4-1 4.1.1 Desien Philosophy 4-1 4.1.2 Manacement Responsibilities 4-1 4.1.3 Documentation Of Analyses And Reviews 4-1 q

4.1.4 Operating Procedures 4-2 1

4.1.4.1 UF Handling Area Effluent Collection Tank Sampling 4-2~

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4.1.4.2 TSA Effluent Collection Tank Sampling 4-2 4.1.4.3 Citric Bath Sampling and Analysis 4-2 4.1.4.4 Chemical Laboratory Uranium Limits 4-3

_.1 4.1.4.5 Active Ventilation Systems 4-3 4.1.5 Postina 4-3 1

4.1.6 Preoperational Testine And Inspection -

4-3 l

4.1.7 Design Procedures 4-4 4

4.1.7.1 Vacuum Pump Spacing 4-4 O

Louisiana Energy Services Revision 3 Proposed License Conditions October,1993 NRC License SNM -

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Proposed License Conditions

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Table of Contents i

Section Pace Number j

4.2 TECHNICAL CRITERIA 4.j 4.2.1 Individual Units 4-5 j

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 6 4.2.4.1 General 4-6 l

i 4.2.4.2 Product Take-Off System Controls 4-8

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l 4.2.4.3 Product / Product Blending Desublimer Systems 4-8

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4.2.4.4 Mobile Pump Set Components 4-9 4.2.4.3 Contingency Dump Traps 4-10 t

4.2.4.6 Process Piping 4-10

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4.2.4.7 Fomblin Oil Recovery System 10 i

5.0 ENVIRONMENTAL PROTECTION 5-1 5.1 EFFLUENT CONTROL SYSTEMS 5-1

.5.1.1 Gaseous Effluents 5-1 3

5.1.2 Liould Effluents 5-2 l

5.1.2.1 Liquid Waste Disposal System Effluent

'5-2 j

5.1.2.2 Sewage Treatment System Effluent 5-3' i

5.1.2.3 Sewage Treatment System Sludge

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O Inuisiana Energy Services Revision 3 Proposed License Conditions October,1993 NRC License SNkt -

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Proposed License Conditions

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j Table of Contents

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Section Pace Number.

5.2 ENVIRONMENTAL MONITORING 5-3.

i 6.0 SPECIAL PROCESSES 6-1 i

6.1 PROPRIETARY INFORMATION 6-1 6.2 OCCUPATIONAL SAFETY 6-1 l

l 6.3 BACK-UP UTILITIES 6-1 6.4 RADIOACTIVE WASTE MANAGEMENT 6-1 6.5 LIMITING CONDITIONS FOR OPERATION 6-2 6.5.1 Autoclaves 6-2 l

6.5.2 Yard Transporters 6-2 a

6.6 OTHER SPECIAL COMMITMENTS 6-2 6.6.1 Depleted UF, Feed, and Product Cylinder Maintenance And Surveillance 6-2 6.6.2 Liould UF, 6-3 l

i 6.6.3 Cylinder Fill Limits 6-3 i

6.6.4 Safety Analysis Report 6-4 i

6.6.5 Ouality Assurance Criteria 6-4 l

6.6.6 Cylinder Transport 6-4 7.0 DECOMMISSIONING PLAN 7-1 i

8.0 EhERGENCY PLAN 8-1 4

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louisiana Energy Services Revision 3 Proposed License Conditions October,1993 j

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' i Louisiana Energy Services Proposed License Conditions Table of Contents l

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Section APPENDIX A Guidelines for Decontamination APPENDIX B Leak-Tesdng Sealed Sources 3

i APPENDIX C Definitions i

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l Louisiana Energy Services j

Proposed License Conditions List of Tables Table 4.2-1 Safe Values for Uniforrn Aqueous Solutions of 5% Enriched UO F2 2

Table 5.1-1 CEC Stack Effluent Action Levels Table 5.1-2 Liquid Effluent Action Levels and Lower Limits of Detection.

t Table 5.2-1 Radiological Environmental Monitoring Program

'l Table 5.2-2 Action Levels and Lower Limits of Detection for Environmental Analyses j

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i Inuisiana Energy Services Revision 3 Proposed License Conditions October,1993 NRC License SNM -

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Proposed License Conditions

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List of Figures

-i Figure 2.1-1 LES CEC Key Managerial Functions

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Figure 5.2-1 Surface Water Chemistry Monitoring Locations l

I Figure 5.2-2 Locations of Site Monitoring Wells and Surface Water Staff Gauges j

i Figure 5.2-3 Air Particulate Sampler Locations 1

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I'NTRODUCTION

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This document - Louisiana Energy Services'(LES), Proposed License Conditions - provides l

proposed license conditions for the Claiborne Enrichment Center (CEC). - These license conditions state to what performance requirements LES is committed. This document follows I

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, "[i]nformation provided in previous submittals... filed with the NRC i

under the license may be incorporated by reference provided such references are clear and l

specific." Therefore, this document does not contain the detailed descriptive information that l

I has been provided in the Safety Analysis Report (SAR). This document is written to permit inspection and verification of the stated performance requirements.

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Louisiana Energy Services Revision 3 Proposed License Conditions October,1993 NRC License SNM -

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1.0 STANDARD CONDITIONS AND SPECIAL AUTHORIZATIONS O

1.1 NAME, ADDRESS, AND CORPORATE INFORMATION Louisiana Energy Services, L.P. (LES) is a Delaware limited partnership. LES has no

-l subsidiaries or divisions.

I 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

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Claiborne Parish where the facility is located. The information office address is:

518 East Main Street, PO Box 809 l

Homer, Louisiana 71040

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The site address is:

O Route #4 Homer, Louisiana 71040 i

i 1.2 SITE LOCATION 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 of land, on a 70 acre developed area. Licensed activities occur in the following areas of the

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developed 70 acres:

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Separations Building which includes the Technical Services Area (TSA).

Cylinder Receipt and Dispatch Building Product, Feed, and Depleted UF Storage Areas.

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i Louisiana Energy Services Revision 3 Proposea License Conditions October,1993 i

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1. 3 POSSESSION LIMITS The following types, maximum possess:on quantities, and forms of byproduct, source, and j

~t special nuclear materials are authorized-i A.

Special Nuclear Material:

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1,543,000 kilograms (3,402,000 pounds)* of uranium (primarily in the form of j

uranium hexafluoride (UF )) enriched above natural but no more than 5.000 6

weight percent in the U " isotope. This maximum e.nrichment value includes 2

considerations of measurement uncertainty.

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This uranium possessed at the CEC will be in the form of UF and other 6

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.

The maximum quantity of source material possessed in the form of natural i

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 l

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 i

6 cylinder filled with depleted UF shall be stored on site' longer than 15 years j

6 following placement of that cylinder in the depleted UF storage area.

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i 1 kilogram - 2.205 lbs.

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1 Louisiana Energy Services Revision 3 l

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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 all three physical forms - gas, liquid and solid.

C.

Byproduct material:

RADIONUCLIDE CURIE USE l

LIMIT l

H-3 1.0 Instrument calibration and/or quality control C-14 0.5 Instrument calibration and/or quality control l

Cr-51 0.1 Instrument calibration and/or quality control Mn-54 0.1 Instrument calibration and/or quality control Fe-55 0.1 Instrument calibration and/or quality control Fe-59 0.1 Instrument calibration and/or quality control Co-57 0.1 Instrument calibration and/or quality control Co-58 0.1 Instrument calibration and/or quality control

'i Co-60 0.1 Instrument calibration and/or quality control Ni-63 0.25 Instrument calibration and/or quality control l

and/or internal instrument standard j

Ni-65 0.25 Instrument calibration and/or quality control and/or internal instrument standard Zn-65 0.1 Instrument calibration and/or quality control Sr-89 0.1 Instrument calibration and/or quality control Sr-90 0.1 Instrument calibration and/or quality control Y-90 0.1 Instrument calibration and/or quality control l

Tc-99*

1.1 Instrument calibration and/or quality control' l

Ag-110m 0.1 Instrument calibration and/or quality control l

Cd-115m 0.1 Instrument calibration and/or quality control l

I-131 0.1 Instrument calibration and/or quality control l

Ba-133 0.25 Instrument calibration and/or quality control l

and/or internal instrument standard l

Cs-134 0.3 Instrument calibration and/or quality control and/or internal instrument standard Cs-137 0.3 Instrument calibration and/or quality control and/or internal instrument standard O

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RADIONUCLIDE CURIE USE LIMIT

<1 i

Eu-152 0.1 Instrument calibration and/or quality control Ra-224 0.1 Instrument calibration and/or quality control l

Ra-226 0.1 Instrument calibration and/or quality control Ra-228 0.1 Instrument calibration and/or quality control.

Ac-226 0.1 Instrument calibration and/or quality control Ac-227 0.1 Instrument calibration and/or quality control Ac-228 0.1 Instrument calibration and/or quality control Th-228 0.1 Instrument calibration and/or quality control Th-229 0.1 Instrument calibration and/or quality control Th-230 0.1 Instrument calibration and/or quality control Th-232 0.1 Instrument calibration and/or quality control Th-234 0.1 Instrument calibration and/or quality control i

U-233 0.1 Instrument calibration and/or quality control U-234 0.1 Instrument calibration and/or quality control' U-235 0.1 Instrument calibration and/or quality control U-236 0.1 Instrument calibration and/or quality control U-238 0.1 Instrument calibration and/or quality control Pa-231 0.1 Instrument calibration and/or quality control I

Pa-232 0.1 Instrument calibration and/or quality control.

Np-234 0.1 Instrument calibration and/or quality control Np-235 0.1 Instrument calibration and/or quality control Am-241 0.1 Instrument calibration and/or quality control

• 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

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Byproduct material may be in solid, liquid, or gaseous form. Byproduct material is not necessarily restricted to sealed sources.

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1xuisiana Energy Services Revision 3 l

Proposed License Conditions October,1993 NRClicense SNM -

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i 1.4 AUTHORIZED ACTIVITIES

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The follow' g activities are authorized to be performed at the CEC:

m 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.

.l i

t B.

Receive, possess, use, store and ship classified information and matter in accordance l

with 10 C.F.R. Parts 10,25 and 95.

i 4

i C.

Produce uranium enriched in the U isotope up to and including 5.000% by weight.

235 l

D.

Chemical, spectrometric, radio-chemical and non-destructive assay analyses of source j

and special nuclear material, including effluents and stored waste.

l E.

Treatment, storage and/or preparation for off-site disposal of liquid and solid wastes l

produced or handled at the CEC. This includes mixed and radioactive wastes.

I i

F.

Decontamination of equipment before maintenance, repair or disposal and decontamination of contaminated wastes to reduce contamination levels.

i 1.4.1 Location Where Material is Used i

i The cylinders are unloaded, weighed for inventory control and inspected for integrity and damage at the Cylinder Receipt and Dispatch Building.

l r

Inside the Separations Building, the UF is enriched to no more than 5.000 weight percent in 6

235 the U isotope by mechanical separation.

l 1

All byproduct materials to be used for calibration or radiography purposes are used and stored l

inside the Separations Building.

l i

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i Louisiana Energy Services Revision 3 Proposedlicense Conditions October,1993

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NRClicense SNM -

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I 1.5 EXEM17FIONS AND SPECIAL AUTHORIZATIONS O

1.5.1 Safety Evaluation Process l

l l

LES shall be authorized to make facility, process, and proccoural changes without prior NRC

(

approval provided that any proposed change does not involve:

l a) a change to the LES CEC License Conditions, f

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, t

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 e) a significant increase in individual or cumulative occupational radiadon exposure.

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 j

the change meets any of the above criteria requiring prior NRC approval, shall state the basis -

l 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 j

accordance with Section 2.9.

l Any proposed change which involves any of the criteria in a) through e) above shall not be l

made without prior NRC approval.

i i

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 Support

[

Superintendent or designee prior to making the change. For changes which involve

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O Louisiana Energy Services Revision 3 i

Proposed License Conditions October,1993

-I NRC License SNM -

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8

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.

l 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 j

effectiveness of the Quality Assurance Program will be submitted as part of the biennial update of the SAR. Proposed changes which decrease the effectiveness of the Quality Assurance Program shall not be implemented without prior approval of the NRC.

1.5.2 Exemptions And Special Authorizations A.

The following authorizations are based upon the finding that these arrangements are 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 mongage, p! edge, or lien of or upon such leasehold or limited partnership interests.

Any such mortgage, pledge, lien, sale and leaseback or limited partnership interest 4

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 j

activities.

l 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

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O Louisiana Energy Services Revision 3 l

Proposed Ucense Conditions October,1993 i

NRC Ucense SNM -

17 Docket # 70-3070

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i e

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l 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.

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 j

Commission authorizing such possession, or the consent of the Commission to the transfer of the license.

"Cmditor" as used herein includes, without implied limitation:

i The trustee under any mongage, pledge or lien of or upon a facility made to f

I secure any creditor; Any trustee or receiver of the facility appointed by a court of competent jurisdiction in any action brought for the benefit of any creditar secured by such mortgage, pledge or lien or for the benefit of any lessor or trustee under a sale and leaseback transaction or limited partner; l

Any lessor or trustee under a sale and leaseback transaction or the legal representative or assignees of such lessor or trustee; Any limited partner or the assignee or legal representative of such limited l

panner; j

Any purchaser of such facility at the sale thereof upon foreclosure of such j

mortgage, 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 pannership agreement; or Any assignee of any such purchaser.

i Provided, however, that nothing in the foregoing conditions shall preclude the licensee.

l 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, I

liens, and limited pannership changes, within 60 days of the change (s).

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O Louisiana Energy Services Revision 3 i

ProposedLicense Conditions October,1993 i

NRC License SNM -

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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 "Guid-lines for Decontamination of Facilities and l

Eauipment Prior to Release for Unrestricted Use or Termination of Li nses for Byproduct, Source, or Special Nuclear Material", U.S. NRC, Division of Fuel Cycle j

Safety and Safeguards, April,1993. 4 pp. This reference is provided as Appendix A.

l t

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 containers. Instead, a sign stating "Every container in this area may contain radicactive material" shall be posted.

1.6 FINANCIAL INFORMATION AND COMMITMENTS A.

LES shall submit annually to the NRC its financial statements, including statements of income, assets, liabilities, net worth, and cash flow. Any changes to construction and operating budgets and/or changes in ownership shall be included with this submission.

j 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 i

unit costs at least every five years.

C.

Reductions of the nuclear liability insurance below the amount of $200 million shall f

not be made without prior NRC approval.

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O Louisiana Energy Services Revision 3 Proposed License Conditions October,1993 NRC License SNM -

J.9 Docket # 70-3070 i

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i I

2.0 ORGANIZATION AND ADMINISTRATION O.

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.

j 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 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 wie sopropriate regulations, codes and standards. This-l position shall be indepr -aent f.. other management positions at the facility to ensure the QA Manager has d t ac.:ss to the CEC Manager for matters affecting quality.

2 C.

Operations Superintendent I

-i The Operations Superintendent shall report to the CEC Manage; and shall have the J

responsibility of directing the day-to-day operation of the facility. This includes such activities as ensuring the correct and safe operation of UF prccesses, proper handling O

Louisiana Energy Services Revision 3 Proposed License Conditions October,1993 NRC License SNM -

2-1 Dacket # 70-3070

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1

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 Scheduling (IS) Superintendent shall report 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 ensudng 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 material and compliance with environmental regulations. Changes to the facility or to operations 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. In the event of the absence of the CEC Manager, the Compliance Superintendent may assume the responsibilities and -

authorities of the CEC Manager.

O Inuisiana Energy Services Revision 3 Proposed License Conditions October,1993 NRC License SNM -

2-2 Docket # 70-3070

i G.

Technical Support Superintendent i

O The Technical Support (TS) Superintendent shall report to the CEC Manager and shall have the responsibility of providing technical support to the facility. This includes activities associated with health physics, criticality safety, chemistry, industrial safety

{

and engineering and computer support. Changes to the facility or to operations which.

[

involve chemical, radiation hazard, or criticdity considerations shall be reviewed and approved in writing by the Technical Support Superintendent or designee prior to making the change. In the event of the absence of the CEC Manager, the Technical Support Superintendent may assume the responsibilities and authorities of the CEC j

Manager.

j H.

Security Manager l

i The Security Manager shall report 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 obta' ming proper I

security clearances for facility personnel and support personnel. In matters involving i

physical protection of the facility or classified matter, the Security Manager has direct access to the CEC Manager.

j I.

Safeguards Manager l

l The Safeguards Manager shall report to the Compliance Superintendent and shall have l

the responsibility for ensuring the proper implementation of the Fundamental Nuclear j

Material Control (FNMC) Plan. This position shall be separate from and independent of the operations, maintenance, and technical support departments to ensure a definite division between the safeguards group and the other departments. In matters involving safeguards, the Safeguards Manager has direct access to the CEC Manager.

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O Louisiana Energy Services Revision 3 Proposed License Conditions October,1993 NRC License SNM -

2-3 Docket # 70-3070

J.

Emergency Preparedness Manager The Emergency Preparedness Manager shall report to the Compliance Superintendent and shall have the responsibility for ensuring the facility remains prepared to react and respond to any emergency situation that may arise. This includes emergency preparedness training of facility and facility support personnel and the conduct of periodic drills to ensure facility personnel training is maintained up to date.

K.

Health Physics Manager The Health Physics Manager shall report to the Technical Support Superintendent and 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:

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 concerning actions at the facility and offsite deemed a

necessary for limiting exposures to facility personnel and members of the general public, and taking prime responsibility for decontamination activities.

In matters involving radiological protection, the Health Physics Manager has direct access to the CEC Manager.

O louisiana Energy Services Revision 3 Proposed License Conditions October,1993 NRC License SNM -

24 Docket # 70-3070 i

L L.

Projects Manager O

The Projects Manager shall report to the Technical Support Superintendent and shall have the responsibility for the implementation of facility modifications and the approval of facility procedures and modifications for criticality safety. The Projects Mahager also provides engineering support as needed to support facility operation and maintenance. This support includes performance testing of systems and equipment.

f i

M.

Chemistry Manager l

1 i

The Chemistry Manager shall report to the Technical Suppon Superintendent and shall

[

have the responsibility for the implementation of chemistry analysis and safety -

l programs and procedures for the facility. 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 programs and i

procedures. This shall include programs and procedures for training individuals in j

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 i

shall be determined to be acceptable by the CEC Manager. " Responsible nuclear experience" j

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 j

following requirements for key positions. This shall be done in writing and only on a case by case basis.

_j

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Louisiana Energy Services Revision 3 Proposed License Conditions October,1993

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^

NRC License SNM -

25 Docket # 70-3070 e

e

~

A.

CEC Manager O

The CEC Manager shall be appointed by the President of LES as the overall manager of the Claibome Enrichment Center. This appointment reflects confidence in the individual's ability as an effective programs and business manager. The 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 equivalent) in an engineering or scientific field and six years of responsible nuclear I

experience.

l B.

Quality Assurance Manager i

The Quality Assurance (QA) Manager shall have a minimum of eight years of responsible j

nuclear experience in the implementation of a quality assurance program. The QA Manager j

shall have at least two years experience in a QA organization at a nuclear facility.

-l i

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 nuclear experience.

N D.

Integrated Scheduling Superintendent The Integrated Scheduling (IS) Superintendent shall have, as a minimum, a bachelor's degree l

5 (or equivalent) in an engineering or scientific field and four years of responsible nuclear experience.

i d

E.

Maintenance Superintendent The Maintenance Superintendent shall have, as a minimum, a bachelor's degree (or

~

'I equivalent) in an engineering or scientific field and four years of responsible nuclear experience.

4

O Louisiana Energy Services Revision 3 Proposed License Conditions

. October,1993 l

NRC License SNM -

2-6 Docket # 70-3070

2 4

s - - -i 4

F F.

Compliance Superintendent The Compliance Superintendent shall have, as a minimum, a bachelor's degree (or equivalent) i in an engineering or scientific field and four years of responsible nuclear experience.

4 i

G.

Technical Support Superintendent 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.

.q 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 t

experience requirement.

.i I.

Safegaards Manager The Safeguards Manager shall have five years of experience in the management of a safeguards program for special nuclear material, including responsibilities for material control, i

material accountability, and physical security. No credit for academic training may be taken toward fulfilling this experience requirement.

j J.

Emergency Preparedness Manager l

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.

K.

Health Physics Manager i

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 I

with implementadon of a health physics program.

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l Louisiana Energy Services Revision 3 Proposed License Conditions October,1993

.i NRC License SNM -

27 Docket # 70-3070 I

I

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L.

Projects Manager O

I The Projects 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.

-j The Projects Manager shall also have at least one year of experience in the administration of nuclear criticality safety reviews.

Within the Projects group shall be at least one individual with a minimum of two years.

i 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' I

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 i

associated with implementation of a facility chemistry program.

-j l

N.

Industrial Safety Manager l

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 j

associated with implementation of a facility safety program.

-j -

2.3 SAFE Y COMMITTEE

'f 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. The scope of reviews conducted by the FSRC shall include,

'l

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O Louisiana Energy Services Revision 3 Proposed License Conditions October,1993 i

NRC License SNM -

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1 l

~

i as a minimum, reviews of ongoing and proposed radiological, chemical, industrial and nuclear criticality safety activities and practices. Radiological, chemical, industrial and nuclear f

criticality safety investigation, audit and inspection reports shall be included in the reviews.

FSRC reviews shall also address the following:

d Environmental protection

.ALARA policy implementation i

=

Changes in facility design or operations

=

Training programs Incident reports, including root cause evaluations, and violations of regulations or

[

license conditions.

c The FSRC shall conduct at least one facility audit per year for the above areas. ' Audits shall l

be conducted as described in Section 2.7.

I The Facility Safety Review Committee shall be composed of at least five (5) members, j

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 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.

l 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 3

. the FSRC shall receive training on possible error modes'of management systems.

The Facility Safety R.eview 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 unit 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 l

calendar year with a maximum interval of 180 days between any two consecutive meetings.

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Louisiana Energy Services Revision 3 Proposed License Conditions October,1993 NRC License SNM -

29 Docket # 70-3070 4

A

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. Following 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 AUTHORITY 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.

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, e

environmental protection, and emergency procedures.

In depth training 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 O

louisiana Energy Services Revision 3 Proposed License Conditions October,1993 NRC License SNM -

2-10

. Docket # 70-3070

procedure changes, and updating and changes in required skills. Changes to training shall be l

l 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 l

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 j

of licensed material.

i All procedures shall be reviewed at least biennially.

All new procedures or changes to existing procedures shall be subjected to the safety evaluation requirements as described in Section 1.5.1.

2.6.1 Preparation Of Procedures i

Procedures shall be prepared, reviewed, and approved in accordance with written procedure

. I requirements. Procedures shall identify limits and controls imponant 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.

.f 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.

l i

i 2.6.2 Chances To Procedures j

Changes to procedures shall be processed as described below.

A.

The preparer documents the change as well as the reason for the change.

l i

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.

j O

1 Izmisiana Energy Services Revision 3 I

Proposed License Conditions

~ October,1993 NRC License SNM -

2.))

Docket # 70-3070

C.

The procedure 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 hazards, including radiological effluents. Approved changes shall be so indicated in writing by the Technical Support Superintendent or designee.

For proposed changes having a potential impact on criticality safety, a criticality safety review shall be performed. Approved changes shall be so indicated in writing by the Technical Suppon Superintendent or designee.

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.

2.6.3 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 Mandals). Revisions to facility manuals shall be controlled and distributed consistently with this index. Facility manual indexes shall be regularly reviewed and updated. Superintendents O

Louisiana Energy Services Revision 3 Proposed License Conditions October,1993 NRC License SNM -

2 12 Docket # 70-3070

F

-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.

Audits and inspections shall be conducted by Quality Assurance group personnel'and other:

individuals technically 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:

preventive maintenance, training.

emergency planning,

• Quality Assurance, a radiation protection, criticality safety control,

• hazardous chemical safety, fire protection, and environmental protection.

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.

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

.f (FSRC or QA), and re-examined during future audits to ensure corrective action has been completed.

Louisiana Energy Services Revision 3 Proposed License Conditions October,1993 l

NRC License SNM -

2 13 Docket # 70-3070

-i

l Inspections shall be performed routinely by qualified staff personnel that are not directly l

responsible for production activities being inspected. Inspections shall be conducted at least semi-annually. Deficiencies noted during the inspection requiring corrective action shall be l

forwarded to the supervisor of the applicab!c area or function for action. Future inspections j

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 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 l

action. Future inspections shall include a review to evaluate if corrective actions have been effective.

2.8 INVESTIGATIONS AND REPORTING To comply with the reporting requirements of 10 C.F.R. (e.g.,10 C.F.R. ! 70.50), off-normal l

occurrences shall be reported to and investigated by the Compliance Superintendent.

Depending upon the severity of the occurrence, the occurrence may be reportable to a governmental agency. Reporting any occurrence to the appropriate agency (s) shall be the responsibility of the Compliance Superintendent.

l 3

The process of incident identification, investigation, root cause analysis, environmental protection analysis, recording, reponing, and follow-up shall be addressed in and performed 3

by written procedures. Radiological, criticality, hazardous chemical, and industrial safety 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 j

shall be maintained as specified in Section 2.9.

I 7

The Compliance Superintendent shall maintain a record of corrective actions to be f

implemented as a result of off-normal occurrence investigations. These corrective actions

_j shall include documenting lessons learned, and implementing worker training where indicated, j

and shall be tracked to completion by the Compliance Superintendent or designee.

l i

~

1 Louisiana Energy Services Revision 3 Proposed License Conditions October,1993 l

NRC License SNM -

2-14 Docket # 70 3070

.)

i

2.9 RECORDS O

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 calibrations; B.

Records of changes made to procedures; C.

Records of audits and inspections D.

ALARA findings The following records shall be retained for the duration of the facility licerse:

E.

Records of all Reportable Events; O

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 control areas (including for example, ALARA findings, routine radiation survey results);

I 1.

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

O Louisiana Energy Services Revision 3 Proposed License Conditions October,1993 -

NRC License SNM -

2-15 Docket # 70-3070 '

1

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:.

l 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.

l 1

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 l

temperatures.

O l

1

-(

N Louisiana Energy Services Revision 3 Proposed License Conditions October,1993 NRC License SNM -

2-16 Docket # 70-3070

P OV d

pd Figure 2.1-1 Louisiana Energy Services Claiborne Enrichment Center Key Managerial Functions CEC Manager I

i l

I i

1 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 l

l l

Louisiana Energy Services Revision 3 l

Proposed License Conditions October,1993 NRC License SNM-^

2-17 Docket # 70-3070 l

I

3.0 RADIATION PROTECTION

!b 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 repon 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 f

radioactivity area limits specified in 10 C.F.R. 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:

l The HP Manager or designee is responsible for determining the need for, issuing, and i

closing out RWPs.

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 contaminatior,.

RWPs shall include requirements for any necessary safety controls, personnel 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.

Louisiana Energy Services Revision 3 Proposed Lictnse Conditions October,1993 NRC License SNM -

3-1 Docket # 70-3070

i

'i RWPs shall clearly defme and limit the work activities to which they apply. ~ The RWPs shall be closed out when the applicable work activities are teiminated.'

3.1.3 Written Procedures I

Activities related to radiation protection (e.g., decontamination and maintenance of processing equipment, radiation monitoring) shall be conducted in accordance with approved written procedures. Distribution of procedures is described in Section 2.6.

3.2 TECHNICAL REQUIREMENTS q

i 3.2.1 -

Restricted Areas - Personnel Contamination Control l

Radiological access zones shall be defined and marked to control personnel contamination.

3.2.1.1 Radiation Control Areas i

Radiation Control Areas (RCAs) at the CEC are defined as areas accessible to individuals in

' t j

which external radiation levels could result in excess of 5 mrem /hr (0.05 mSv/hr) at 30 cm from the radiation source or from any surface that the radiation penetrates. Personnel that i

have not been trained in radiation protection procedures shall not be allowed access to the l

RCA without escort by trained personnel.

l Access to and egress from an RCA shall be through monitor stations at the RCA boundary.

j All personnel shall be required to monitor themselves prior to exiting the RCA using l

monitoring instruments which detect gross alpha contamination.

-)

3.2.1.2 -

Radiation Control Zones -

l t

Greater access control shall be provided by establishing Radiation Control Zones (RCZs)

{

wherever any of the following conditions are likely to exist:

j' f

Airborne Radiation:

ia 2 30% of the weighted Derived Air Concentration (DAC) listed in 10 C.F.R.

a Part 20, Appendix B to Q@ 20.1001-20.2402, for specific radionuclides.

I (O

i

/

i Louisiana Energy Services

' Revision 3 Proposed License Conditions October,1993 i

NRC License SNM -

32 Docket # 70-3070 l

t F

..r.

u,-,1

-w-

-e,N

,n, wc

2 5.0 E-14 pCi/ml for alpha emitters not listed in 10 C.F.R. Part 20, Appendix 7

(

B to ss 20.1001-20.2402, or unknown alpha emitters.

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.

s 20.1003.

Alpha Contamination:

2 Within an RCA,2 5000 DPM/100 cm 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 Ventilation pO 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 filters. HEPA filter design efficiency shall be 2 99.97% for particles > 0.3 microns; activated carbon filter design efficiency shall be 2 99% for hydrogen fluoride. Filter festing 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.

Filter 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.

HVAC systems serving affected areas shall be shut down during any abnormal release of UF.

~

Louisiana Energy Services Revision 3 Proposed License Conditions October,1993 NRC License SNM -

3-3 Docket # 70-3070 1

3.2.3 Work-Area Air Sampling Airborne activity in work areas shall be regularly determined in accordance with written 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 US (D compound). The lower limit of detection shall not exceed l

5% of the values listed in Appendix B of 10 CFR @f 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 frequencies:

Weekiv, and following any indication of release that may lead to airborne concentrations of uranium when uranium concentration are expected to exceed 10% of the values listed in 10 C.F.R. % 20.1003, Airborne radioactivity area, (1) and (2).

This frequency shall apply to radioactive material shipping, receiving, inspection, and storage areas.

Each shift, following changes in process equipment or process control, and following detection of any event (i.e., leakage, spulage, or blockage of process equipment) that may have resulted in releases in excess of 107c of the values listed in 10 C.F.R. {

20.1003. Airborne radioactivity area, (1) and (2).

The representativeness of the work station air samplers shall be checked annually.

Plant areas surveyed as described in this section shall include as a minimum UF processing 6

areas, decontamination areas, waste processing areas, and laboratories. Continuous air 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.

Action levels shall be based on trending of data collected during plant operation.

Investigations shall be performed if airborne activity:

~

Louisiana Energy Services Revision 3 Proposed License Conditions October,1993 NRC License SNM -

3-4 Docket # 70-3070

a.

exceeds 10% of the values listed in 10 CFR 20.1003 for Airbome radioactivity

[J 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.

3.2.4 Radioactivity Measurement Instruments 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 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 sensitivity 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 accordance with Regulatory Guide 8.12, Revision 2, " Criticality Accident Alarm Systems."

3.2.5 Radiation Exposures Occupational exposures shall be determined, validated, and controlled in accordance with 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 quarterly to ascertain 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

" Louisiana Energy Services Revision 3 Proposedlicense Conditions October,1993 NRC License SNM -

35 Docket # 70-3070

storage protocol, and work practices. Anytime the administrative limit is exceeded, the (v)

Health Physics (HP) Manager shall be ir. formed. The HP Manager shall be responsible for determining the need for and recommending investigations or corrective actions to the responsible superintendent (s). Copics 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 I rem / year 5 rem / year Equivalent (TEDE) internal + external (routine operations) 3.2.5.1 Barriers O

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.

Self-monitoring is required upon exit from the controlled areas. Personnel shall be instructed 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 Su-face 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 O

Louisiana Energy Services Revision 3 Proposed License Conditions October,1993 NRC License SNM -

36 Docket # 70-3070

contaminated. Survey locations, methods, and frequencies shall be specified in procedures

(]

approved by the HP Manager. The type of monitoring shall include direct and removable 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 mbbing with moderate pressure.

Methods and instruments used in surveys of removable surface contamination shall be capable of detecting tiie alpha radiations at and beinw 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-garmna 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), persornel work.ing 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 U " (conservatively assuming all uranium activity is U ").

2 2

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. Pan 20, Appendix B to s 20.1001-20.2402, Table 1, Column 3, then bioassay shall be conducted within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after suspected or known exposure. Follow-up bioassay measurements shall be conducted to determine

" Louisiana Energy Services Revision 3 Proposed License Conditions October,1993 NRC License SNM -

3-7 Docket # 70-3070

~~

committed effective dose equivalent.

()

U 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 scaled calibration sources shall be performed in accordance with Appendix B.

q N.)

i l

~ Louisiana Energy Services Revision 3 Proposed License Conditions October,1993 NRC License SNM -

38 Docket # 70-3070

r J

4.0 NUCLEAR CRITICALITY SAFETY 4.1 ADMINISTRATIVE CONDITIONS J

]

4.1.1 Design 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.

j safety to require at least two unlikely, independent, and concurrent changes in process i

conditions before a criticality accident is 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.

l r

4.1.2 Management Responsibilities t

Management positions responsible for criticality safety shall be as described in Section 2.1.

O 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 l

these analyses. Performance and independent review of analyses shall be performed by l

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.

Ii t

New analyses which involve criticality safety that rely on methods other than safe by l

favorable geometry shall require documented, explicit acknowledgement of this fact by the l

approver of the analysis.

4.1.3 Documentation Of Analyses And Reviews

l 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 3 Proposed License Conditions October,1993

. NRC License SNM -

41 Docket # 70-3070.

i accordance with written procedures. Analyses shall be filed and shall be readily retrievable, I,,

as described in Section 2.9.

V 4.1.4 Or>eratine 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.

Procedures shall include nuclear criticality safety limits and controls derived from nuclear criticality safety evaluations. The procedures shall inchule corrective measures required to return criticality safety parameters to their normal control band.

4.1.4.1 UF Handling Area Effluent Collection Tank Sampling Two independent samples of each UF Handling Area Effluent Collection Tank shall be 6

analyzed weekly. Agreement between results shall be obtained or the sampling process shall be repeated until agreement is obtained. If the uranium content exceeds 100 mg/ liter, corrective action shall include sampling and analysis each shift until the source of the

[V]

uranium is identified and controlled.

4.1.4.2 TSA Effluent Collection Tank Sampling Two independent semples of each TSA Effluent Collection Tank shall be analyzed when 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 of uranium, corrective action shall include hourly sampling until the source of the uranium is identified and controlled.

4.1.4.3 Citric Bath Sampling and Analysis Two independent samples of the citric acid baths shall be analyzed when the tank contents 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.

Agreement between the two analyzed samples shall be obtaine<!, 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.

' Louisiana Energy Services Revision 3 Proposed License Conditions October,1993 i

NRC License SNM -

42 Docket # 70-3070

4.1.4.4 Chemical Laboratory Uranium Limits L.-

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 repon 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 Techni;al Support Superintendent. The following criteria shall be used, as a minimum, to initiate an evaluation:

p 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 Posting 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 Suppon Superintendent or designee.

4.1.6 Preoperational Testing And Inspection Prior to stan-up of new or modified systems, an inspection shall be performed to ensure the design, installation, and operating instructions are consistent with safety evaluations.

'Inuisiana Energy Services Revision 3 Proposed License Conditions October,1993 NRC License SNM -

4-3 Docket # 70-3070

4.1.7 Design Procedures

(.)

V Activities related to criticality safety design shall be performed in accorda ice 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.

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 inadvertent critical configuration, and (4) administrative requirements to ensure that the engineered systems to limit the parametric controls will be installed, maintained, i.nd operated as designed.

b.

For each potential criticality accident identified above, LES shall implement and maintain independent engineered or administrative controls such that the double contingency principle of ANSI /ANS-8.1 is satisfied.

c.

In addition to identifying the limits and controls in (a) above, LES shall document the requirements for maintenance, surveillance, personnel training, posting, and control of written procedures to ensure the effectiveness of the limits and controls.

i 4.1.7.1 Vacuum Pump Spacing Prior to use of the vacuum pumps for transporting UF, LES shall provide to the NRC a e

Lcmisiana Energy Services Revision 3 Proposed License Comfitions October,1993 NRC License SNM -

44 Docke: # 70-3070

safety analysis which demonstrates the criticality safety of vacuum pump configuration and

/_T t,

/

operation.

4 v

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.

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, KENO 5A-PC) run on verified software. Prior to using these codes for determining criticality safety, a summary report of the codes 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 report shall be maintained at the CEC facility.

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.

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Louisiana Energy Services Revision 3 Proposed Dcense Conditions October,1993 NRC Ucense SNM -

45 Docket # 70-3070

4.2.2 Multiple Units Or Arrays

,m i

\\

V Control of 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 report 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 i

a.

The plant design shall not include direct application of water to feed cylinders, product i

cylinders, and desublimers while in process.

b.

The moderation within the product cylinders shall be controlled by operating features, l

~ Louisiana Energy Services Revision 3 Proposed License Conditions October,1993 NRC License 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

.a cylinder is connected to the plant UF systems.

c.

Where mass sampling is used to ensure that criticality safety limits are maintained, 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 Product 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 capability 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 enrichment within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 6

and results compared with predicted results. Required adjustments shall be performed in accordance with item h above.

~ Louisiana Energy Services Revision 3 Proposed License Conditions October,1993 NRC License SNM -

47 Docket # 70-3070

4.2.4.2 Product Take-Off System Controls

_[

')

O a.

Prior to use, empty product cylinders shall be checked to verify no internal 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.

c.

Volatile gases shall be vented to the Product Vent System. If a predetermined limit 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 solidified using only cool air as the cooling medium.

6 e.

Product cylinders shall be heated for blending or sampling only in autoclaves, and 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.

T nydrogen to uranit.m "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.

~

Louisiana Energy Services Revision 3 Proposed License Conditions October,1993 NRC License SNM -

4-8 Docket # 70-3070

c.

The desublimer vessel shall be designed for external heating and cooling, using closed 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 shall include the nitrogen blanketing alarm system and the pressure sensor / control system of the desublimer inlet and outlet valves.

l 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 6

present, the material shall be removed such that a maximum of 10 kg remains prior to reuse of the 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 <0.93. This criticality safety analysis shall be l m

completed in accordance with Section 4.1.3 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 the NRC (as described in Section 4.2.2 above).

a.

The design of the cold trap inside diameter shall not exceed 18.5 cm.

b.

The chemical traps shall be designed with an internal diameter no greater than the safe diameter provided in Table 4.2-1.

c.

The pumps shall be designed such that pump free volume shall not exceed 7 liters.

i 2

l d.

The k, for an infinite array of mobile pump sets shall not exceed 0.93.

~

Louisiana Energy Services Revision 3 Proposed Deense Conditions October,1993 NRC License SNM -

49 Docket # 70-3070

For initial CEC operation, activated carbon in mobile pump set chemical traps shall be

(

)

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 b 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.

c.

Contingency dump trap media shall be replaced immediately following a emergency dump involving significant amounts of UF.

6 4.2.4.6 Process Piping

(~]

The internal diameter of process piping shall not exceed the safe diameter provided in Table

'u 4.2-1. Where the process requires pipe bends or pipe intersections, the piping shall fit inside a maximum 18 cm. diameter envelope.

4.2.4.7 Fomblin Oil Recovery System Cleaned batches of Fomblin oil shall be visually inspected for cleanliness and sampled and tested for uranium content prior to releasing the batch from safe-by-geometry containers.

" Louisiana Energy Services Revision 3 Proposed License Conditions October,1993 NRC License SNM -

4.jo Docket # 70-3070

i TAHLE 4.2-1 Safe Values for Uniform Aqueous Solutions of 57c Enriched UO F 2 2 PARAMETER -

CRmCAL VAWE SAFETY FACTOR '

' SAFE VAWE' f

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 Mass (No Double 35.5 kgU 1.34 26.4 kgU Batching Possible)

Mass (Double 35.5 kgU 2.23 15.9 kgU Batching Possible)

Areal Density 11.5 gU per sq cm 2.23 4.6 kgU per sq ft equivalent to 10.6 kgU per sq ft Solid Angle 9-10 k,y (for k n < 0.8) e O

d 1

Inuisiana Energy Services Revision 3 Proposed License Conditions October,1993 NRC L.icense SNM -

4.))

Docket # 70-3070

6.0 SPECIAL PROCESSES p

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 minimum, organic solvents and HF.

Permanent alpha-in-air monitors shall have an alarm setpoint such that a UF release will 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 2

2 2 U

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 MAN.AGEMENT 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 3 Proposed license Conditions October,1993 NRC License SNM -

6-1 Docket # 70-3070

1 accordance with written procedures, and shall be reviewed as described in Sections 2.3 and p

2.7. The Health Physics Manager shall be responsible for radioactive waste management.

6.5 LIMITING CONDITIONS FOR OPERATION 6.5.1 Autoclaves a.

The CEC shall not operate any autoclave with air temperature exceeding 260 F.

b.

The CEC shall not operate such that UF, in a feed autoclave is raised to a pressure 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.

6.6 OTHER SPECIAL COMMITMENTS

(]J 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 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 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 the UF storage yards.

6 E.

Only trained and qualified personnel shall be allowed to operate vehicles in the UF storage yards.

6

~ Louisiana Energy Services Revision 3 Proposed License Conditions October,1993 NRC License SNM -

6-2 Docket # 70-3070

F.

DUF cylinders shall be inspected for damage prior to placing a filled cylinder 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 c.~_9ing.

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.

G.

If inspection of a DUF cylinder reveals significant deterioration (i.e., leakage, 6

f cracks, excessive distortion, bent or broken valves or plugs, broken or torn stiffening rings or skirts, or other conditions that may affect the safe use of the cylinder), the contents of the cylinder shall be transferred to another cylinder, and the defective cylinder properly discarded. The root cause of any significant deterioration shall be determined and if necessary additional inspections of cylinders shall be made.

H.

Proper documentation on the status of each DUF cylinder shall be available on 6

site, including content and inspection dates.

6.6.2 Liquid UF,.

LES shall not transport any cylinder containing liquid UFe.

6.6.3 Cylinder Fill Limits UF cylinders shall not be filled in excess of the shipping limit maximum specified in 6

~ Louisiana Energy Services Revision 3 Proposed License Conditions October,1993 NRC License SNM -

6-3 Docket # 70-3070

Appendix 1, "UF Cylinder Data Summary," of ORO-651, Revision 6 " Uranium

(\\

Hexafluoride: A Manual of Good Handling Practices."

/

6.6.4 Safety Analysis Repon 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 (SA.R). The design and constmetion 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.

Quality assurance of s( :tware, and verification and validation of software important to l safety and material cc and accountability shall be in accordance with pan 2.7, u

" Quality Assurance T q :r. ments 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."

[

B.

Quality assurance controls of items and activities imponant to safety shall be in accordance with ASME-NQA-lb-1991 addenda to ASME NQA-1-1989, " Quality Assurance Program Requirements for Nuclear Facilities."

6.6.6 Cylinder Transpon LES shall transport filled product cylinders using only LES-approved transpon equipment.

i

~ Louisiana Energy Services Revision 3 i

Proposed License Conditions October,1993 NRC License SNhi -

64 Docket # 70-3070

l Appendix C, Page 1 of 2.

O%

Revision 3 October,1993 i

DEFINITIONS The defined terms of this section are applicable throughout these [ Proposed] License f

Conditions.

Annually:

365 days

• 60 days.

i Audits and Inspections:

'i Audits are formal examinations made to verify that operations are being conducted according l

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.

Biennial:

I 24 months 90 days.

Eauivalent to Bachelor's Decree:

l Higher education completed in a country outside of the USA which meets requirements at

'l least as rigorous and extensive as USA requirements for a bachlor's degree from an accredited college or university.

imponant to Safety:

j Those stmetures, 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.

?

Preoperational:

Beginning of site construction activities until receipt oflicensed source material at the site.

Ouanerly:

90 days 20 days.

e l

O Semi-annually:

183 days 30 days.

i t

l i

I Appendix C, Page 2 of 2 Revision 3 October,1993 -

i i

Total Effective Dose Eauivalent:

Annual exposure with a 50-year committed internal dose component and an external dose component.

-l l

l l

1 I

I O

c

.