ML20059L223
| ML20059L223 | |
| Person / Time | |
|---|---|
| Site: | Claiborne |
| Issue date: | 01/21/1994 |
| From: | Loysen P AFFILIATION NOT ASSIGNED |
| To: | Jim Hickey NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9402030308 | |
| Download: ML20059L223 (14) | |
Text
.-
L a.
]fu-jpg PETER LOVSEN ASSOCIATES.
HEALTH AND S AFETY ENGINEERING 2B7 LONG PDINT RD AD CROWNSVILLE. M ARYLAND 21032 (410)923-6087-January 21, 1994 i
U.S.
Nuclear Regulatory Commission ATTN:
John W.N.
Hickey; Chief, Enrichment Branch Division of Fuel Cycle Safety and Safeguards Office of Nuclear Material Safety and Safeguards Washington, DC 20555 Ref:
Draft Environmental Impact Statement Louisiana Energy Services, L.P.
Docket No. 70-3070 i
Dear Mr. Hickey:
In its Draft Environmental Impact Statement (DEIS) for the ccnstruction and operation of Claiborne Enrichment Center, Mcmer, Louisiana (NUREG-1484), the Nuclear Regulatory Commission asked any interested party to submit comments on the report for I
consideration by the staff.
My comments are enclosed.
I van the staff's licensing project manager for the proposed action from its inception until January 1992, when I retired from the NRC and began Peter Loysen Associates.
I have been following the progress of the action since that time.
My interest then, as nov, has been verker and public health and safety and protection
- f 'hu en.ranment.
Based upon my knowledgc of the project and
- i my revicv Of the DEIS, I believe that there are flavs in the DEIS that make it difficult to understand whether the potential environmental consequences of the proposed action are acceptabic.
My camments are intended to encourage the staff to improve the content and quality of the DE!S so that the environmental acceptability of the project can be'better ascertained in the-Final Environmental Impact Statement.
i Sincerely, l
l a MA--
Peter Loys47:
u f
Enclosure:
DEIS comments i
0'<n<J,O
>1
~
t' 9402030308 940121 ADOCK 07003070' hk.
PDR PDR J.
C-
i COMMENTS ON DRAFT ENVIRONMENTAL IMPACT STATEMENT LOUISIANA ENERGY SERVICES, L.P.
DOCKET NO. 70-3070 GENERAL I was disappointed by the style of presentation and lack of editing in the DEIS.
Although environmental impact statements are intended for a technically informed audience, this one misses the mark.
It is difficult to read, even by one familiar with such documents.
The Final Environmental Impact Statement (FEIS) needs to have more of a story line and to have the sometimes obtuse and disparate statements in the DEIS tied together.
Changes in the estimated environmental impacts of the proposed action that have resulted from interaction between the NRC staff and LES should be described.
The FEIS should clarify what statements, assessments, and conclusions in the DEIS are attributable to LES, and what ones are those of the NRC.
Furthermore, wherever a significant item is attributed to LES, the FEIS should state whether the staff agrees or disagrees, and whether the staff has performed its own review of the item.-
While the DEIS is called a " Draft," that term is not intended to mean a rough draft, as the DEIS is, but rather a polished document prepared for comment on substantive. issues by federal, state, and other agencies, the parties, and interested persons for consideration in preparation of the FEIS.
The DEIS also lacks standardization of terms, abbreviations, and units, as well as tense and punctuation.
The FEIS vould be improved by uniformity in these areas and better differentiation among sections, sub-sections, and paragraphs by distinctions in font styles, type sizes, line spacing, indentation, etc.
The difference between Section 2.4.8, Decontamination System, and Section 2.5, Decontamination and Decommissioning, is an example of the differentiation problem.
These sub-sections have similar-looking titles and appearance, but they are of different outline levels and cover different topics.
Many of my following comments on entitled sections of the 4
DEIS are technical.
Some of the comments are in question format.
Others address the style of presentation and editing.
I urge you to take advantage of whatever editing services may be available to you in preparation of the FEIS.
ABSTRACT It is incredulous that the NRC can, in the Abstract of the DEIS or even elsewhere in the report, propose to issue a license 1
1 1
1 l
h to the applicant to authorize construction and operation of the
' CEC.
Not only is a conclusion premature that the facility can be constructed and operated with small and acceptable impacts on the public and the environment, a proposal to grant a license is not discussed'in the DEIS.
It vould be more appropriate to state that granting a license vould be contingent on required findings based on the FEIS, the Safety Evaluation Report, Safeguards requirements, Security requirements, and the decision of the Atomic Safety and Licensing Board after its hearings have been completed.
Following the proposition to issue a license, the staff then offers the opportunity to comment on the proposed action and treatment of environmental impacts.
Is this not putting the cart before the horse?
SUMMARY
AND CONCLUSIONS Although the Summary and Conclusions does not follow the outlin0 of the DEIS very well, it does address most of the subject matter in the DEIS, but not in a balanced manner.
For example, site selection, decontamination and decommissioning, and j
tails disposition - important topics to many - are given little or no attention in the Summary and Conclusions; while socio-economic impacts are given much attention.
Table S-1 is almost impossible to understand until reading the similar (but not identical) Table 4.2.4 and the supporting text in sub-section 4.5.1, Input-Output Multipliers.
Despite such attention to socio-economic impacts, the Summary and Conclusions fails to i
address the public safety and budgetary problem of high crime arising from drug-trafficking, described in sub-section 4.2.1.7.1, Public Services, as the most significant negative 7
social impact of the facility.
In the Introduction, you state that the DEIS discusses the effluent and environmental monitoring programs proposed to assess the potential environmental impacts of facility construction and operation.
Actually, you should assess the ootential impacts in the DEIS (as correctly stated in the introductory paragraph of Section 4, Environmental Consequences) and the actual impacts through the monitoring programs.
The last sentence in the Introduction is convoluted.
Even though I think I understand what it means, It doesn't belong here.
In Need for Action, using either kilograms or tonnes for throughput values vould eliminate some confusion for those who may not be able to convert, especially since a tonne is neither defined nor listed in the List of Acronyms (see also sub-section 2.1).
With whom would CEC be a complementary and competitive supplier for enrichment services? DOE /USEC?
Foreign suppliers?
2
1 l
~
i In Environmental Impac;s of Construction, what is the significance of the statements that the CEC design was influenced by several local-environmental factors in order to ensure ooerational safety and-that the CEC is designed to ensure no imoact on buildings from severe weather and seismic events?
(See
-)
also sub-section 2.2.2.)
i In Radiological Impacts, some of the annual dose and dose rate limits and expected releases, doses, and dose rates are given in SI units and metric units, but some in SI units only.
The reference to 40 CFR Part 190 standards does not specify that they are annual limits.
While it may be true that the estimated i
doses from normal operations are small fractions of the doses received from background radiation, it should be stated that (if true) these doses are also, and importantly, small fractions of the various applicable limits.
For the largest possible impact that would result following catastrophic failure of a hot UFs cylinder, you state that uranium intakes 'n excess of 10 mg could be observed as far as 10 km from the release point.
You should state the intakes at the plant fenceline and at the location of the nearest resident.
Why does this paragraph contain a statement that the staff concludes that operation of the CEC does not pose a significant threat to public health and safety.
In Decontamination and Decommissioning, you state that nositive environmental impacts include release of the facilities and land for unrestricted use, discontinuation of water and t
electrical power use, and reduction in vehicular traffic.
This implies that there are neoative environmental impacts from construction and operation of the CEC.
These positive impacts.
are not only not balanced against the negative impacts in the DEIS, they are not. discussed at all.
FOREWARD Contrary to the initial statement in the Foreward that the information in this report vill be considered by the NRC staff in the (environmental) review of the license application by Louisiana Energy Services, L.P.,
the information it the consideration by the staff.
LIST OF ACRONYMS Many of the items in this List are not acronyms, but rather abbreviations, shorthand, and notations, some of which are in
+
common use and need no definition or are defined in the report.
Regardless, it would be more useful and instructive to replace the List of Acronyms with a Glossary of Terms, in which the most 3
i
significant items could be explained.
For example, there is little need for a definition of mph (mile per hour), but there is
. for SWU (separative work unit), CEDE'(committed effective dose equivalent), and TEDE (total effective dose equivalent).
PURPOSE AND NEED This section contains a convoluted sentence similar to that in the Summary and Conclusions that the DEIS.is a vehicle to provide the public with a dynamic mechanism to comment on the content and issues treated in the document.
The Need portion of the section needs.to be updated to reflect the creation and activities of the U.S.
Enrichment I
Corporation, including the agreenent between the United States and Ukraine which provides that the Corporation will purchase.
significant quantities of blended down enriched uranium for subsequent sale to U.S.
commercial nuclear utilities.
It should also be made clear that LES will provide enrichment-services only to U.S.
commercial nuclear utilities.
With that in mind, what is the purpose of Table 1.1, World Enrichment Services Requirements, Mid-Range-Projections in Millions of SWU?
The statement that the proposed action has been proven _to be an energy-efficient technology as compared to the aging gaseous diffusion technology that is currently used in the United. States should be revised to make it clear that construction and operation of the CEC (the action) has not yet been proven to be-anything.
Slighting of the gaseous diffusion technology, however old and less energy-efficient it may be, is inappropriate here.
The scop!ng process is an important aspect in the planning and preparation of environmental impact statements.
NRC regulations prescribe specific steps that should be taken in the scoping process, one of which steps is a public scoping meeting.
The public scoping meeting in connection with this DEIS produced extensive comments that were summarized in a referenced NRC report.
These summarized comments and a discussion of the remainder of the scoping process should be presented here (or in a separate section of the DEIS) so that readers can determine how the scoping process vas followed and the results implemented.
The status of actions by state agencies and federal agencies other than NRC should be stated, at least to the extent that applications for the necessary permits and licenses have been filed.
The statement that an NRC licensing decision on the proposed action vill be contingent upon an anorooriate EIS and an adecuate safety evaluation of the' facility is meaningless.
In fact, unless the remainder of the contingencies are also.given, the statement is unnecessary.
4 1
PROPOSED ACTION AND ALTERNATIVES One sub-section of Proposed Action and Alternatives is.out of logical order.
Sub-section 2.7, The Site Selection Process, should be placed directly after sub-section 2.1, proposed Action.
2.2.2, Plant Design and Layout - The.first paragraph states that the CEC is designed to ensure no imoact to buildings from rainfall, cyclonic vind storms.such as tornadoes and hurricanes, lightning, and seismic events.
However, the second paragraph-states that the Separations Building is designed to withstand a certain design basis tornado, and the third paragraph states that-none of the auxiliary structures are designed to withstand these parameters.
What is correct here?
What do Class I and Class II structures mean?
What do Assay A and Assay B mean?
2.2.4, Resource Requirements and Waste Generation - The title of Table 2.2 implies that concrete, steel, aluminum, and soil are consumed during construction, yet the column heading says that these materials are used.
In fact, some of the resources are consumed, and others are used.
In the table, does the aluminum used for construction include the centrifuges?
If so, it vould seem more appropriate to include centrifuge assembly somewhere in sub-section 2.2, Site Preparation and Construction, rather than in subsection 2.3, Description of Operation.
2.3, Description of Operations - Feed purification, product blending, and product sampling and assay are not functions of the plant.
They are parts of or steps in the process.
In Figure 2.4, the block entitled desublime between oroduct and vent chem / oil traos, with its secondary function lines, is curious and is not discussed in the subsequent text.
2.3.1, Feed Receipt and Storage - The statement about partial vacuum in UFs cylinders appears to be inconsistent with' the discussion of cold purification in the following sub-section.
What is ANSI-N14.1?
2.3.2, Feed Purification and Vaporization - Autoclave is first mentioned in this sub-section.
The term should be defined, and the operational and safety functions and purposes of autoclaves should be described.
It would also be helpful to describe desublimation.
2.3.3, Enrichment - While the term cascade is used in this discussion, it is not explained,'and there is an implication that UF6 gas goes through large numbers of centrifuges, all in parallel.
5
1 In Table 2.4, what are the distinctions among the. assay units.vith product assays of 2.5%?
Where are the-data for enrichments up to the maximum of 5%?
~
2.3.4, Product and Tails Removal - In Product Removal, you should mention that the UFs pressures achieved in the first and
-second stage compressions are still sub-atmospheric (if, in fact, they are).
.In Cascade Dump Systems, how'can the vacuum pumps of_the Contingency Dump System operate in the event of loss of electrical 1 power?
2.3.9, Utilization of Resources - The discussion about chlorofluorocarbons (CFCs) is confusing.
This sub-section mentions Freon R-11 (in kg) as a refrigerant and Freon TF (in liters) as a degreaser, while the-Summary and Conclusions and Table 2 5 mention Freon-113 (in kg) as a solvent, and' Table ~2.11 lists Freon-113 (in liters) as a solvent.
You should clarify the CFC types, and. settle on a single unit of measurement.
Because the year 2000, when CFCs will reportedly be banned from use, is at or near the time of the beginning of operations, the suitable substitute products should be proposed and their environmental impact evaluated now.
See also the discussion in sub-section 4.2.1.6, which has somewhat different language about LES' intention.
2.4.1, Gaseous Waste Management - Flow diagrams and/or layout drawings of the various ventilation systems would be helpful to understand the confusing text describing these systems.
What doen "The system is_ monitored for radioactivity and.
Will be shut down if limits exceed allovable releases" mean?
Even if you meant to say releases exceed allovable limits, how are allowable releases determined, when is the system shut down,-
7 and what is the impact of shutdown on other systems and the in-plant environment?
The text indicates that LES estimates the a.verace source term releases of uranium to be 120 microcuries per year.
However, in Table 2.5 (a]so attributable to LES), the annual cuantity is given as siG grams, the same as Urenco experience in Europe (in the text, but with no attribution).
This inconsistency should be resolved and the units made the same in the Table itself and the footnote to the Table.
Someone (LES, Urenco, or the staff) has made a conversion from 10 grams of uranium to 28 microcuries.
This is obviously not on the basis that the uranium is natural uranium, but on some lov enrichment.
The actual enrichment should be stated, not only here but elsewhere in the DEIS where the specific activity is 6
I v
used, and the basis for the enrichment used should be justified.
2.4.2, Liquid Waste Management --Recommendations elsewhere in the DEIS address-monitoring of liquid vaste streams for technicium-99, yet there is'no discussion or listing in the tables.in this sub-section about the origin and nature of the technicium-99 problem.
2.4.3, Solid Waste Management - Fomblin Oil is first mentioned here.
What is Fomblin 011?.What is it used for?~ Is it hazardous?
Is it included in one of the tables in sub-section 2.4.3?
2.4.4, Reprocessing _and Recovery Systems - If any of the I
CFCs mentioned in the Summary and Conclusions and sub-sections
~2.3.9, 2.4.0, 2.4.1, 2.4.3, and 4.2.1.6 include the. refrigerant used at the CEC, the statement that a two-stage vapor recovery.
unit orevents the discharge of any refrigerant to the environment.
needs to be revised.
2.4.5, Disposition of Tails - Disposition of depleted UF.
(tails) is one of the most environmentally important issues associated with the proposed action and which should be addressed in the DEIS.
Unfortunately, you have given it little attention; so little that it takes only a dozen lines in the report.
A much more thorough discussion of LES' proposal for and the staff's assessment of tails disposition is needed.
Some of the topics that_need to be included in an expanded version of this sub-section include:
1.
The-nature of LES' indication (does this mean a commitment?) to convert DUF.-to U20. within 15 years of initiating enrichment or after production of no more than 72,560 tonnes of DUF..
2.
The facilities that could be available and villing to perform the conversion in the time frame indicated.
3.
Rates of generation of tails, rates of conversion, and how much tails vould remain at the end of plant life.to be converted in conjunction with decontamination and decommissioning of the CEC.
4.
Inclusion of costs in the decommissioning plan to cover conversion of tails remaining at the end of plant life.
5.
Where and when the converted'U20.-vill be disposed, particularly in' view of the fact that disposal by i
shallov land burial of large quantities of uranium was not considered in the promulgation of 10 CFR Part 01.
What is a MSWU?
What are 48G' cylinders?
7
l 2.4.7, Transportation of Feed and Product Materials - Does the 73 tonnes of UF. a week to be transported include both feed and product?
j 2.4.8, Decontamination System - How doen equipment disassembly cenerate Fomblin Oil?
What do you mean that f
components are also degreased?
What is the LWD System?
What do you mean that the dryer is vented to the TSA HVAC System ductverk?
2.5, Decontamination and Decommissioning - The second t
paragraph seems to imply that tails are not vaste; yet sub-section 4.2.6.5 states that uranium tails represent what is essentially a vaste product.
The staff's position should be clarified.
What does it mean that the decommissioning plans will be impicmented using prope,L management and health and safety j
programs?
The third paragraph refers to the reuse or sale of equipment i
that is decontaminated to belov NRC limits.
You should refer to and make it clear that current NRC guidance applies only to surface contamination, and that there is none for bulk contamination.
You should also include an admonition that the guidance can change, and that LES would be required to follow any new guidance.
How does LES have decommissioning experience in Europe, and would the aluminum containing 2 to 4 parts per i
million uranium be acceptable for resale in the United States?
2.6, No-Action - The no-action alternative discussion 4
contains confusing statements, and it is biased toward the proposed action.
The advanced (nev, novel, or r&d?) technology mentioned in the Summary and Conclusions has now become well-proven.
You state that with denir?. of the license, demand for j
the CEC's output would be satisfied by other foreign competetive
'l suppliers.
Does this mean that LES is a foreign supplier?
Does l
Japan intend to offer enrichment services to customers other than those in Japan?
Are ther na benefits to the no-action alternative?
l 2.7, The Site Selection Process - In the last paragraph, you conclude summarily that none of the alternative sites are obviously superior to the LeSage site, and therefore the staff analyzed only the LeSage site in detail.
This conclusion is based on the statement that impacts at alternative sites are expected to be similar to impacts at the LeSage site.
- However, the staff failed to acquire from LES additional, detailed information on alternative sites outside the Homer, Louisiana l
area so that meaningful comparisons could be made.
2.2, Alternative Enrichment Technologies - You should make It clear that LES (and Urenco, from which the technology comes),
does not use technologies other than gas centrifugation for 8
t l
I
1.-
uranium enrichment.
Therefore, if an alternative were to be l
promoted, LES would not use it at the CEC.
Are there no characteristics of gaseous diffusion other than high energy consumption and capital cost requirements that f
distinguish this technology?
The characteristics of laser t
enrichment are'not mentioned at all.
2.9, Conclusions and Recommendations - This sub-section is obviously out of place-.
No evaluations have been made at this v
point in the DEIS, so no conclusions and recommendations can be made.
They should' appear in Section 5.0.
r THE AFFE INVIPONMENT 3.1, General Site Description - The location of Claiborne Parish in the Pine Hills subprovince of the north central portion of the Gulf Coastal Plain physiographic province does not-read like a general site description.
In fact, this statement is l
characteristic of r
-sections 3.1 through 3.5 of the Affected Environment in the 3e sub-sections, almost 100.pages in length, contain in_
ation in extreme detail that is far out or halance with other categories of information, especially the plant and its prccesse...
i 1.6, Sociosconomic and Local Community Characteristics and Services - This sub-section fails to contain any discussion about i
the extensive and vocal opposition to the proposed action by a j
group of citicens in the local community.
Inclusion of the results of the s<
ng process, especially the public scoping meeting, as I rec ended in my comments on Section 1, Purpoce q
and Need, vould provide an appropriate mechanism for the' discussion of this opposition.
ENVIRONMENTAL CONSEOUENCES This section is supposed to be the staff's evaluation of the j
environmental consequences of the proposed action.
- However, there'are numerous instances in the section vhere the
]
environmental consequences or conclusions are. referenced or i
attributed to LES.
This dichotomy should be eliminated by~
-limiting this section to the staff's evaluations and relegating LES' information to Section 2, Proposed Action and Alternatives.
You have not addressed the topic of site selection in this j
section.
It should be addressed in an additional sub-section, and in the same logical order as in Section 2.
j L
Conclusions.from Section'2, Purpose and Need, as well as any j
others developed in Section 4, should be presented in an t
9 l
q i
l
additional sub-section.
4.1, Site Preparation and Construction Description - The word Decerintion is obviously extrinsic.
4.1.1, Hydrology - The impacts of accidental spills of fuel, oil, and chemicals during site preparation and construction is vague.
You should describe the range of consequences to surface water and shallow and deep groundwater from such spills, as you have indicated would depend on various' factors.
l 4.2, Operation - The listing of selected features and designs, attributable to LES, include some strange statements.
These include:
- d. Process off-gas is discharced through desublimers 12 s ed i d i f v and reclaim as much UF. as nossible.
t
- e. Licuids and solids in the process systems collect uraniem corn ^unds.
- f. Procanses used to clean ur vastes and effluent create h'. r own vastes and effluent as well, contrcl of these !? als o i
aggomn11ched by 11 auld and solid vaste handlino systems and Lg2bnicuer.
t 4.2.1.4, Noise - The frequency of noise resulting from the gas centrifuges and motors is quite discernable to humans in the vicinity of the equipment, but not outside of the cascade halls.
A mo:c likely source of noise is the exhaust ventilatior. blowers that v112 be operated continuously.
i 4.2.1.6, Air Pollution - The discussion about hydrogen fluoride (HF) in this sub-section is unusual, in that it includes-a primer on HF and fluoride toxicology.
This is unlike any other discuselon in the DEIS.
You state that the potential. impact of HF releases.on surrounding vegetation is expected to'be negligible based on reference to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> exposure data.
How can this statement be justified if, as also stated, continuous exposure to HF is more harmful to vegetation that intermittent exposures?
(I. assume that routinelv, as used in the second paragraph, means continuously, even though you have used the1vord intermittent in.
the fourth paragraph.)
What is the basis for the statement in the. sixth paragraph, "Accordingly, Freon-113 releases are expected not to-exceed 1.24 4 ;
E-4 mg/m'?"
4.2.1.7.1, Public Services - I mentioned the public safety and budgetary problem in a comment on the Summary and 10 Y
t
Conclusions.
Perhaps this vould be an appropriate. place in the DEIS to discuss the positive impact of the security staff and.
features that will be required at'the CEC, at least during the operational and decontamination and decommissioning phases.
4.2.2, Radiological Impacts - This sub-section presents a fine exposition on a difficult to understand and probably the most important topic in.the DEIS.
The discussion.is clear, the evaluation procedures referenced-(because they rely on computer codes for use), and the results presented in mostly usable form.
My commenta on the subsequent sub-sections in this sub-section are few and mostly for further improvement in clarity.
4.2.2.1, Dose Evaluation Methods - What are the bases for selecting the annual releases of 120 microcurie to the atmosphere and 28 microcuries to surface waters?
How many grams are equivalent to these activity values, and what is the assumed-uranium enrichment?
'4 hat are the un".ts of the va2ues in Table
- 1. ".1 ?
The signif:c+nce of the. data presented in Tables.4.12 through 4.15 vould be improved by adding an additional line. showing the applicable dose limit (s).
How do the staff's results compare with LE0'?
The d;otinctio;. betseen CEDE and TEDE should be. explained.
4.2.2.4, Evaluation of Cumulative Radiological Impact for Routine Operations - The first part of this sub-section-appear to repeat the information in sub-section 4.2.2.
I in the analysis of infant doses, what vould the-doses be without local cows?
Is, in fact, any milk produced at the
]
assumed location?
i 4. 2. 2. E.1.,
Methoda of Accidan' Eva]uation - This sub-section sounds as though it were lifted from a draft of-the Safety 1 Evaluation Report (SER) for the CEC..If so, and.any significant details are changed in the final. version of theLSER, this information should be made available to DEIS reviewers.
t 4.2.2.6.4, Description and Evaluation of Accidents - An additional table or tables vould be useful'to show, for eachlof-1 the seven accidents described, the total amount of UF( at risk,-
the. rate of release, the amount assumed to be released, uranium intakes, radiation doses, and applicableLor appropriate limits.
s 4.2.3, Cumulative Environmental Impacts.- Why is this a:sub-l section devoted entirely to impacts on site. hydrology?
i 4.2.4, Adverse Environmental Impacts that Cannot be l
Avoided - The discussion in this sub-section appears to be almost j
11 I
u.
~
entirely on LES' information.
What does the staff think?
4,4, No-Action Alternative - Some of the disbenefits of the no-action alternative seem strained.
These include the removal of all trees on the site and a likely outmigration of skilled and higher income workers.
Other sub-s'ections indicate a lack of i
skilled and high income workers in the area.
j 4.5.5, overall Project Economics - I agree that actual costs may exceed contingencies in certain areas,- but not because the project partners have experience constructing and operating only one other centrifuge plant (in France).
Some of the partners have such experience with plants in the United Kingdom, Germany, and the Netherlands.
4.5.8, Summary - This sub-section would be a better summary of the Cost-Benefit Analysis if it were combined with much of the 1
information in sub-section 4.5.
i EFFL"ENT A'D ENVIPONMENTAL MONITOPING PROGRAMS i
5.2.1, Radiological Gaseous Effluent Monitoring Program
-It vculd.be useful to discuss how the provisions in the ANPR vere accrted for the LES proceeding.
Shouldn't the ALARA goal feature of the MOU between EFA and NRC te. Included in the discussion of applicable limits in the Summary and Conclusions and sub-section 4.2.2?
Does the ALARA l
goal apply to all pathways or just gaseous pathways?
- 5. 2. 3, Radiclogical Effluent Monitoring Under Accident Conditions - This sub-section contains some odd phrases, e.g.
the ANFR vould have recuired that an appropriate means be provided for measuring..., CEC (sic) intends to isolate the part of the
-j Separations Building in which the accident occurs..., Asmarinc this monitor survives the DBAs, it can be used to provide l'ive-i time monitoring...
5.2.],
Radiological Environmental Monitoring Program - How does LES' commitment to control effluents at the boundary of the unrestricted area from exceeding a CEDE of 50 mrem jibe vith the l
limits given in sub-section 4.2.2' i
Rather than finding that the sampling program and LLDs for the operational program are fully in coroliance with NRC receirements, it would be more appropr. late to state that they vi)) enable LES to meet NRC recuiremen+e t
The last paragraph is a conclusion or finding, not a part of the environmental monitoring program.
_j P
e 12 t
v.
ibl 5.3.2, Nonradiological Environmental Monitoring Program ~~
For the mo0L part, this sub-section does not describe the non-radiological environmental monitoring program.
FEDERAL AND STATE ENVIRONMENTAL REOUIREMENTS By order, the Commission established additional Federal requirements applicable to the LES proceeding..The ANPR and other features of the order should be summarized here.
Atomic Energy Act of 1954 - The authorlty of the Atomic Energy Act does not include setting national standards.
The statement that the NRC is authorized to survev... facilities for enrichment, etc. is curious and probably unnecessary.
Reference to a few parts of Title 13 seem unnecessary also.
Clean Air Act - The Clean Air Act does not ertablish reqUI49n5.
Em'Leion Standards for NRC Licensed Facilities - The' word ga (ouc c: airborne should be added before the word emiscion.
i 4
t s
f l
Y 3
i i
t 13
.