International Isotopes Inc.

April 29, 2011

ATTN: Document-Control Desk

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

Subject: Submittal of Responses to Requests for Additional Information (RAI)

TAC L32739.

To Whom it May Concern,

The purpose of this letter is to replace the Official Responses to Environmental Protection RAIs

submitted via letter on April 25, 2011 with the version enclosed with this letter. This response to

RAIs pertains to the International Isotopes Fluorine Products Inc. December 30, 2009

application to license a depleted uranium hexafluoride de-conversion and fluorine extraction

process facility.

(1) Official Responses to Environmental Protection RAIs

Please contact me by phone at 208 524-5300 or email at jimillergintisoid.com if you have any

questions regarding this letter or require additional information.

Sincerely,

John J. Miller, CHP

Radiation Safety Officer

JJM-2011-29

Enclosure as Stated

cc: Dr. Matthew Bartlett

U.S. Nuclear Regulatory Commission

Mail Stop E2C40M

6003 Executive Blvd.

Rockville, MD 20852

4137 Commerce Circle, Idaho Falls, Idaho 83401

Phone: 208-524-5300, 800-699-3108 Fax: 208-424-1411

Website: www.intisoid.com • 1,).5 l
Enclosure 1 JJM-2011-29 April 29, 2011

Official Responses to Environmental Protection RAIs

Section 9 of the LA generally follows the acceptance criteria found in the SRP, (NUREG-1520).

However, Section 9 of the applicant's LA, together with the numerous references to other sections of the

LA and the ER do not provide a sufficient standalone description of the environmental protection

program. To be sufficient, references to chapters of the ER and other sections of the LA must focus on

specific subchapters of the ER and subsections of the LA- rather than on whole topic areas-which, in

some cases, are over 100 pages. For example, references must point to specific tables and figures, as

appropriate, particularly when citing numeric values or equipment locations (e.g., monitoring locations).

Modifications based on the following RAIs will provide greater transparency and traceability of technical

presentations, facilitate a timely document review process, assure that Section 9 of the LA is complete

and accurate, and allow the lay reader to follow the discussion better.

EP-1. Section 9.2.1, Radiation Safety. Please specifically identify each of the various subsections of the

LA and ER that contain supplemental information related to the four acceptance criteria for

Radiation Safety referenced in LA Section 9.2.1. Since the supplemental information is

referenced in the individual subjects identified within LA Section 9 (e.g., under the individual

headings in Sections 9.2.1.1 and 9.2.1.2), add a new last sentence to Section 9.2.1 similar to the

following: "Specific references to the supplemental information are provided below, as

appropriate. "

Section 9.4.3.2.1 of the SRP, NUREG-1520, addresses Radiation Safety Program in accordance

with 10 CFR 20.1101.

RESPONSE: The last sentence of Section 9.2.1, which states "Supplemental information can

also be found in various sections of the LA as well as the IIFP ER", will be replaced with this

sentence: "Specific references to supplemental information in the ER and LA are provided in

each of the subsections below."

License Documentation Impact: Section 9.2.1 of the License Application will be revised as

follows:

The following sections address the four acceptance criteria that describe the facility Radiation

Protection Program (RPP) as it applies to Environmental Protection. The RPP is discussed further

in Chapter 4, Radiation Protection, of the LA. Specific references to -Ssupplemental information

.an a.. be found in Various sectios of-the LA as Nye!! as the 111212 ER axe provided in each

section. as appropriate.

Environmental Protection RAIs Page I
Enclosure 1 JJM-2011-29 April 29, 2011

Official Responses to Environmental Protection RAIs

EP-2. Section 9, Environmental Protection - Section 9 of the applicant's LA relies heavily on references

to the ER. Since the ER is notpart of the LA, ensure that references to the ER are only used to

provide additional information and do not contain commitments. 10 CFR 40.32(c) requires the

application to contain adequate commitments to protect health and minimize danger to life and

property.

RESPONSE: A survey of the IIFP Environmental Report (ER) and the IIFP License Application

(LA) and the Integrated Safety Analysis Summary (ISA) was conducted. The ER was reviewed

for statements that were made to protect health and minimize danger to life and property. The LA

and ISA were also reviewed to determine if the corresponding statements covered in the ER were

addressed in the LA or ISA. The table below also shows the number statements made in the ER to

protect health and minimize danger to the life and property and the number of corresponding

statements made and addressed in the LA or ISA. Of the 104 different statements made in the ER

to protect health and minimize danger to life and property, only six of those were not addressed in

the LA or ISA and five were only partially covered in the LA or ISA. Statements not addressed

fully in the LA or ISA will be incorporated.

Table 1 Statements Made in the Environmental Report to Protect Health and Minimize Danger to

Life and Property in Comparison to Those Addressed in the License Application and

Integrated Safety Analysis Summary

Statements Made in the ER to , Corresponding I

ERChapter Title of Chapter . Protect Health andMinimize Statement Addressed in

. .... Danger ____ to Life and Property LA or ISA

Introduction of the 13 addressed

Chapter 1 Environmental Report 20 4 not addressed

E3 partially addressed

Chapter 2 Alternatives 4 4 addressed

Description of the 22 21 addressed Chapter 3 affected Environment 2 partially addressed

patill addressed

Chapter 4 Environmental Impacts 21 20 addressed

I not addressed

Chapter 5 Mitigation Measures 12 11 addressed

I partially addressed

Environmental 14 addressed

Chapter 6 Measurements and 15 14 addressed

Monitoring Program 1 not addressed

Chapter 7 Cost-Benefit Analysis 0 None required

Summary of

Chapter 8 Environmental 10 10 addressed

Consequences

Chapter 9 References 0 None required

Chapter 10 List of Preparers 0 None required 93 addressed

Totals IIFP Environmental 104, 6 notaddressed

Report patia 6 ddressed

• ," ...." ,,, 'i/.... • 5 partially addressed

Environmental Protection RAIs Page 2
Enclosure 1 JJM-2011-29 April 29, 2011

Official Responses to Environmental Protection RAIs

RESPONSE:

1.3.2.2 The primary applicable codes and standards (editions applicable at time of design) for

the design and building requirements of the IlFP Facility include the following:

" ASME/ANSI B16 Standard for Pipe and Fittings. Statements not addressed in

LA or the ISA Summary.

* API 620 Design and Fabrication of Atmospheric Storage Tanks. Statements not

addressed in LA or the ISA Summary.

* AISC Standards for Steel Construction. Statements not addressed in LA or the

ISA Summary.

* ACI for Concrete Construction. Statements not addressed in LA or the ISA

Summary.

License Documentation Impact: The 7 th paragraph of Section 1.1.2 of the IIFP License

Application, Revision A, (see also RAT SS-8 and GI-6B) will be replaced with the following:

The following is a list of applicable Federal, State. and local codes and standards that the DB

contractor will use during the detailed design, construction and startup stage of the project to

insure adequate protection against natural phenomena, environmental conditions, and dynam ic

effects. The DB contractor will also ensure, as part of the written contract, that design meets these

applicable federal, state and local codes and standards. Buildings, lighting, fire protection, and

building support systems are designed in accordance with latest revisions, of building and

construction codes including where applicable the National Fire Protection Association

(NFPA) standards, local and State codes, and related codes and standards. NFPA

Standards are listed in Chapter 7 of the LA. Table 7-1. The primary applicable codes and

standards (editions applicable at time of design) for the design and building requirements

of the IIUP Facility include the following:

2006 New Mexico Commercial Building Code (adopts by reference the 2006 International

Building Code (IBC) with amendments)

2006 New Mexico Energy Conservation Code (adopts by relference the 2006 international

energy conservation code (IECC) with amendments)

2006 New Mexico Plumbing Code (adopts by reference the 2006 Uniform Plumbing Code

(UPC) with amendments)

2006 New Mexico Mechanical Code (adopts by reference the 2006 Uniform Mechanical

Code (UMC) with amendments)

2008 New Mexico Electrical Code (adopts by reference the 2008 national electrical code

(NEC) with amendments)

2007 New Mexico Electrical Safety Code (adopts by reference the 2007 national electrical

safety code (NESC) with amendments)

2006 International Fire Code

2007 American Society for Mechanical Engineering (ASME) Section VIII. Division I

Design and Fabrication of Pressure Vessels.

2007 ASME B331 .1 "Power Piping"

2008 ASME B31.3 *Process Piping"

2006 ASME B3 1.5 "Refrigeration Piping and Heat Transfer Components"

2008 ASME 1331.9 "Building Services Piping" and

National Fire Protection Association NFPA applicable codes as detailed in Table 7-1

Environmental Protection RAls Page 3
Enclosure 1 JJM-2011-29 April 29, 2011

Official Responses to Environmental Protection RAts

"NFPA Standards of this License Application.

RESPONSE:

1.4.3.2 As part of this permitting process, a Stormwater Pollution Prevention Plan (SWPPP)

will be developed and a Notice of Intent (NOI) will be filed with the EPA at least two

days prior to the commencement of construction activities. SWPPP is not addressed in

LA.

1.4.4.15 NMAC, Title 20, Chapter 5, Part 2, "Registration of Tanks," establishes the state

standards for the regulation of petroleum storage tanks. If needed, such storage tanks

will be designed in accordance with state requirements and registration application

made. NMAC Title 20 is not addressed in the LA.

1.4.4.16 NMSA Chapter 74, Article 12, "Night Sky Protection," establishes requirements to

preserve and enhance the state's dark sky while promoting safety, conserving energy

and preserving the environment for astronomy. These requirements will be addressed

during detailed design of the facility. NMSA Chapter 74 is not addressed in the LA.

1.4.4.17 NMSA, Chapter 50, Sections 1-25, and implementing regulations at NMAC Title 11,

"Labor Workers Compensation," Chapter 5, "Occupational Safety and Health"

establishes state requirements for assuring safe and healthful working conditions for

every employee. These state regulations are being followed to ensure any additional

requirements beyond the federal OSHA regulations are adequately addressed. NMSA

Chapter 50 and implementing regulations are not addressed in the LA.

1.4.5.5 Permits will be obtained to conduct rare, threatened and endangered (RTE) surveys for

both plants and animals, in accordance with the timeframe requirements prior to

construction. Permits for ecological surveys are not addressed in the LA.

1.5 A number of licenses and permits will be required for construction and operation of the

IIFP Facility. A summary of licenses and permits that are currently known to be

required are listed in ER Table 1-3 (former Table 1-4). During the federal and State

permitting process, any changes in requirements will be re-evaluated. NPDES General

Permit for Industrial Stormwater, General Construction Permit, and State Access

Permit are addressed in the LA. Groundwater Discharge Permit/Plan, EPA ID

Number, Endangered Species Survey Permit, and the Stormwater Pollution

Prevention Plan are not addressed in the LA.

License Documentation Impact: Section 9.1.4 of the IIFP License Application, Revision A will

be revised as follows: (Also see RAI GI-I lB for revisions in the LA, former Section 1.6.3.6 (new

1.7. .4 "Groundwater Hydrology").

In addition to the NRC licensing and regulatory requirements, a variety of environmental

regulations apply to the IIFP Facility during the construction, and operation phases. These

regulations require permits from, consultations with, or approvals by, other governing or

regulatory agencies. IIFP ER Chapter I(IIFP, 2009a) summarizes the applicable environmental

regulatory requirements, permits, licenses, or approvals, as well as the current status of each, as of

the effective date of the ER. Permits include the following:

Environmental Protection RAIs Page 4
Enclosure 1 JJM-2011-29 April 29, 2011

Official Responses to Environmental Protection RAIs

* NPDES General Permit for Industrial Stormwater.

* General Construction Permit.

* Air Construction (Air Quality: New Source Review/Authority to Construct) Permit.

* Air Operations Permit if required.

o NESHAP Permit if required,

o Groundwater Discharge Permit/iLiquid Waste (sewage) Permit,

* EPA Hazardous Waste ID Number,

* Drinking Water System Permit

* Radiation Protection Permit.

* Above Ground Storage Tank Registration,

* NPDES Storm Water Pollution. Prevention Plan (SWPPP)/Notice of Intent (NOT),

o State Access (lighway Right of Way) Permit.

o Clean Water Act, Section 404, arid

" Rare. Threatened. and Endangered Species Survey Permit.

IlFP will also develop a Storm Water Pollution Prevention Plan (SWPPP) and file a Notice of

Intent (NOI) with the EPA at least seven days prior to the commencement construction activities.

An agreement has been obtained with the New Mexico Environment Department (NMED) on the

type and maximum quantities of depleted uranium and container possession limits. The NMED

Agreement is incorporated into this IIFP LA. Miscellaneous regulations include the fiollowing:

* NMSA Chapter 74, Article 12. "Night Sky Protection," establishes requirements to

preserve and enhance the state's dark sky while promoting safety, conserving energy and

preserving the environment for astronomy. These requirements will be addressed during

detailed design of the facilitv.

0 NMSA. Chapter 50. Sections 1-25. and implementing regulations at NMAC Title 11,

"Labor Workers Compensation," Chapter 5. "Occupational Safety and Health"

establishes state requirements for assuring safe and healthful workingz conditions for

every employee. These state regulations are being followed to ensure any additional

requirements beyond the federal OSHA regulations are adequately addressed.

* Groundwater monitoring wells are permitted through Office of the State Engineer (OSE)

and well locations along with the boring logs are submitted to the OSE. Site-wide

groundwater levels will be monitored routinely, and the groundwater monitoring well and

pumping well networks will be analyzed to confirm that the changes in groundwater

levels associated with the operation of the liFP are minimal. Future detailed engineering

and hvdrological studies will identify the appropriate systems and locations.

RESPONSE:

6.2.6 In order to monitor and characterize meteorological phenomena (e.g., wind speed,

direction, and temperature) during facility operation as well as consider interaction of

meteorology and local terrain, conditions will be monitored with a meteorological tower

located on site. A meteorological tower is not addressed in the LA.

License Documentation Impact: The IIFP License Application, Revision A, Section 9.2.2

paragraph one will be revised by adding a second sentence as follows:

Environmental Protection RAIs Page 5
Enclosure 1 JJM-2011-29 April 29, 2011

Official Responses to Environmental Protection RAIs

Effluent and environmental controls and monitors are maintained at and around the facility to

ensure that doses to the workers, the public, and the environment remain ALARA. In order to

monitor and characterize meteorological phenomena (e.g.. wind speed, direction, and

temperature) during plant operation. conditions will be monitored using a meteorological tower

located on site. In addition, monitors provide indication of potential off-normal occurrences

requiring further investigation. Guidance provided in Regulatory Guide 4.16, "Monitoring and

Reporting Radioactivity in Releases of Radioactive Material in Liquid and Gaseous Effluents

from Nuclear Fuel Processing and Fabrication Plants and Uranium Hexafluoride Production

Plants " (NRC, 1985) has been utilized in the preparation of the environmental protection aspects

of the RPP (IIFP, 2009b) where applicable.

RESPONSE:

5.2.12.2 Mitigation measures associated with DUF6 cylinder storage areas as follows: ... The

DUF 6 cylinder management program is addressed in LA Sections 1.1.3.2, 6.3,

6.3.1.2, 7.2, 7.3.6, and 7.4. DUF 6 cylinder valves and protectors are not addressed

in the LA.

License Documentation Impact: The IIFP License Application, Revision A, Rev A Section

1.1.3.2, fifth paragraph will be revised as follows:

Upon receipt, full cylinders of DUF 6 are visually inspected for damage and surveyed for radiation

and removable contamination. Cylinders and cylinder valves shall be inspected for ANSI N 14.1

requirements. Documents that contain information regarding cylinder ID, weight and uranium

assay that accompany the shipment are reviewed and verified for accuracy. Uranium assay is

qualitatively verified by performing a non-destructive gamma-survey measurement. Once

accepted for receipt, the cylinder is unloaded using the facility cylinder hauler vehicle and placed

in the Full DUF 6 Cylinder Storage Pad area until it is scheduled for feed to the de-conversion

process. Only designated vehicles with less than 280 liters (74 gal) of fuel shall be allowed on the

cylinder storage pads.

RESPONSE:

3.2.2.2 ... If any DUF 4 is received, it will be contained in approved shipping containers in

accordance with DOT regulations. Shipping of DUF 4 is not addressed in the LA.

Transportation routes for both incoming DUF6 feed and outgoing uranium wastes will be those

routes designated by the U.S. Department of Transportation to minimize the potential impacts to

the public from the transportation of radioactive materials. Using DOT transportation routes

is not addressed in LA.

4.2.6 Radioactive material shipments will be transported in packages that meet the

requirements of 10 CFR 71 and 49 CFR 173 (CFR, 2009m; CFR, 2009ii). 10 CFR 71

and 49 CFR 173 are not addressed in the LA.

License Documentation Impact: In the IIFP License Application, Revision A, Section 1.1.3.2,

a final sentence will be added to the third paragraph and will read as follows:

The IIFP Ffacility in Hobbs, New Mexico receives DUF 6 material in a solid physical state

typically contained in 14-ton type 48-Y (or 48-G) or in 10-ton type 48-X cylinders owned by the

Environmental Protection RANs Page 6
Enclosure 1 JJM-2011-29 April 29, 2011

Official Responses to Environmental Protection RAls

supplier (the IIFP de-conversion customer). These cylinders are built to American National

Standards Institute (ANSI) standards (ANSI, 2001) and are transported by truck trailers that are

Department of Transportation (DOT) approved. ThetDje 48-Y and type 48-X cylinders is-are

approved for multi-shipments, provided the ANSI standards; which include a 5 year hydrostatic

test requirement are met. Empty 48-Y or 48-X type cylinders are returned to the customer

following de-conversion. Radioactive material shipments will be transported in packages that

meet the requirements of 10 CFR 71 and 49 CFR 171-173. Transportation routes for both

incoming DUF 6 feed and outgoing uranium wastes will be those routes designated by the U.S.

Department of Transportation to minimize the potential impacts to the public from the

transportation of radioactive materials. If ant' DUF is received, it will be contained in approved

shitnoing containers in accordance with DOT reaulations.

Environmental Protection RAIs Page 7
Enclosure 1 JJM-2011-29 April 29, 2011

Official Responses to Environmental Protection RAIs

EP-3. Section 9.2.1.1, Radiological (ALARA) Goals for Effluent Control - This subsection states that

ALARA Goals are typically 10-20 percent of the 10 CFR 20 Appendix B values. Please provide

the specific ALARA Goals for air and liquid effluents and provide a more specific reference to LA

Section 4; provide a more detailed discussion regarding how compliance with ALARA goals is

demonstrated by discussing how each of the listed items (monitoring, analysis, and evaluations)

contributes to compliance; and as part of that discussion, include greater detail addressing each

of the three numbered items in LA Section 9.2.2.1 that are to be evaluated in order to assess

trends.

Section 9.4.3.2.1 (1) of the SRP, NUREG-1520, provides that ALARA goals are to be set at a

modest fraction (from 10-20%) of the 10 CFR 20, Appendix B values.

RESPONSE: In the absence of current effluent measures, the ALARA goals for air and liquid

effluents will be initially set at 20% of the 10 CFR 20 Appendix B values. As described in

Section 9.2.1.1, these goals will be reviewed annually and adjusted as appropriate. ALARA goals

are further described in LA Section 4.2.2, "ALARA Goals."

License Documentation Impact: LA Section 9.2.1.1, "Radiological (ALARA) Goals for

Effluent Control," will be revised including a new first paragraph and will read as follows to

include the specific ALARA goals stated above and to clarify the reference to LA Section 4.2.2.

Monitoring of facility effluents, analysis ofnmonitoring samples, and evaluation of sampling data

allow for the determination of the quantity of radioactive material released from the facility

during normal operating conditions and thereby demonstrating attainment of ALARA goals and

effluent limit compliance. Identification of the quantity of material released firom the facility

permit the evaluation of the success of control and containment of contamination. In addition, the

determined quantity of radioactive material released from the facility will allow for the estimation

of- potential off-site dose to the public. Finally, identification of an unexpected increase in

material quantities released from the facility allows for the detection of any unexpected release

pathways previously unidentified.

ALARA Goals are set to demonstrate compliance with 10 CFR 20, "Standards for Protection

Against Radiation" (CFR, 2009c) with respect to doses to the public, doses to the worker, and

environmental effluents, and are typically 10 20%will initially be set at 20% of the 10 CFR 20

Appendix B values (CFR. 2007'). Goals are set by the IIFP ALARA Committee and reviewed

annually to assess the need to adjust specific values based on what may be ALARA for the

particular measure. Compliance with the ALARA goals is demonstrated through monitoring,

analysis, and evaluation of air emissions, liquid effluents, and disposition of solid waste. Trends

are assessed using the monitoring results to evaluate the following: (1) facility operations control

and containment of contamination; (2) projections of potential dose to offsite populations; and (3)

detection of any unanticipated pathways for transport of radionuclide(s) within the environment.

In accordance with the ALARA Program, these monitoring results are summarized and presented

to the ALARA Committee on an annual basis. The ALARA Program and associated goals are

further described in LA Chapter-Section 4.2.2, "Radiation PrtectionALARA Goals."'

License Documentation Impact: The LA, Section 4.2.2 will be revised to reflect the initial

establishment of the ALARA Goals at 20% of the 10 CFR 20 Appendix B values as shown

below.

Environmental Protection RAIs Page 8
Enclosure 1 JJM-2011-29 April 29, 2011

Official Responses to Environmental Protection RAIs

Specific goals of the ALARA Program include maintaining occupational exposures, as well as

environmental releases, as far below regulatory limits as is reasonably achievable. With respect to

environmental effluents, ALARA Goals will be initially set at 20% of the 10 CFR 20 Appendix B

values (CFR. 2007). The ALARA concept is also incorporated into the design and operation of

the facility. The size and number of areas with higher dose rates are minimal. Per approved

written procedures, the time spent in these areas is controlled and projects are evaluated to ensure

workers receive the minimum exposure. Areas where personnel spend significant amounts of

time are designed to maintain the lowest dose rates reasonably achievable.

Environmental Protection RAIs Page 9
Enclosure 1 JJM-2011-29 April 29, 2011

Official Responses to Environmental Protection RAIs

EP-4. Section 9.2.1.2, Effluent Controls to Maintain Public Doses ALARA - Please provide more

specific references to subchapters within ER Chapters 2 and 6, and provide relevant tables or

figures, if any (e.g., facility diagram of referenced equipment or buildings). Section 9.4.3.2.1 (2)

of the SRP, NUREG-1520, provides that the applicant describe and commit to the use of effluent

controls to maintain public doses ALARA in accordance with 10 CFR 20.1101.

RESPONSE: LA Section 9.2.1.2, "Effluent Controls to Maintain Public Doses ALARA," will

be revised to provide more specific references to ER Chapter 2 and ER Chapter 6 as requested

and to references to the ISA, where applicable. Note: ISA Table 3-5 "Stack Heights and

Estimated Flow Rates" will be removed and replaced to match new ER Table 2-3 to match

information in RAI ER-9D.

License Documentation Impact: LA Section 9.2.1.2, paragraph one will be revised and a new

second paragraph will be added to provide references to effluent controls to read as follows:

Effluent controls are used to maintain public doses ALARA. Gaseous effluents, that may contain

depleted uranium, pass through pre-filters, high efficiency filters, and carbon-bed filters prior to

entering the _pplant KOl1 Sscrubber Ssystem (three-stages, in series). After scrubbing, the

effluents are discharged to the atmosphere via the scrubber system stack. Certain storage vessels,

powder transfer systems, and packaging stations, where depleted uranium particles are involved,

are connected to two-or-three -stage dust removal systems to ensure capture and recovery of

depleted uranium particles, prior to being vented to the atmosphere. The stacks are continuously

sampled and are routinely analyzed to measure radioactivity of the exhaust gases. Chapter- 2 -

the llFP E-R (11111, 2009)) addi-esses the proeess deseiriptiain and the effluent eoiiti~ols ineer-porated

into the design of he f~acility, and Chapter- 6 (11121, 2009) of the UI)F ER descr-ibes the stc

sMamplin and RRI!eaSUr-ement;.-

Effluent controls are described in the IIFP FEP/DUP ER (IIFP, 2009a) as part of the facility

process descriptions in Subsections 2.1.3.6. 2.1.3.7. and 2.1.3.9. In addition, IIFP FEP/DUP ER

Table 2-2 (former Table 2-1) provides a list of design efficiencies for process vent off-gas

treatment equipment, and IIFP FEP/DUP ER Table 2-3 (former Table 2-2) provides a list of

major process vent stacks. ER Section 6.1 identifies the proposed sampling and monitoring

locations for gaseous effluents, liquid effluents. and groundwater, and provides an overview of

the effluent monitoring program to achieve ALARA. I-lFP ER Figure 6-1 illustrates the planned

monitoring. locations at the site. IIFP ER subsections 6. 1.1 and 6.1.2 provide additional details

about effluent and radiological monitoring. Effluent control and conservation features are

described in subsections of lIFP FEP/DUP ER Section 4.13.4. Section 3.1.10 of the IIFP

Integrated Safety Analysis Summary (ISA) (IIFP, 2009d) describes the process vent stacks at the

IIFP Facility. Table 3-4 in the ISA provides the listing of design efficiencies for the off-_V-as

treatment equipment as does Table 2-2 (former Table 2-1) of the ER. Table 3-5 of the ISA

provides the stack heights and estimated flow rates of the maior process vent stacks.

License Documentation Impact: Remove and replace ISA Table 3-5 which provides the stack

heights and estimated flow rates of the process vent stacks as referenced in Section 9.2.1.2,

paragraph one revised above to match new ER Table 2-3 to match updated information in RAI

ER-9D.

Table 3-5 Stack Hci~hlits and Estimated Flow Rates

Environmental Protection RAIs Page 10
Enclosure 1 JJM-2011-29

Official Responses

April 29, 2011

to Environmental Protection RAIs

4

(01) Plant KOH Slightly East of the

Scrubbing System DUE., Process 90 20-100 HF/SiF_!BF4 2291,149

Stack BIuilding

Ambient

8

(02) Dust Slightly East of 10,888- C -olecor DUEF4 Process 80 3,800-7,600 LJF_/HF 21.776 Collector Systern Building

Ambient

8

(03) FEP [)ust West Side of FEP Uranium Oxide/ 10,888-

Collector System Process Building 80 38007600/BF 2

Ambient

_8

Particulates/SO,/

(04) Utilities Roof of Utilities 40 2V50-500 C716-1432

Boiler Stack Building M4ethane/CO/TOC/

CO,

.300 'F

8

(05) (Future Phase Northeast Corner of 10.888-

2 Plant Oxide Future Oxide 8s0 3,800-7.600 Uranium Oxide/HF 1776

Process Building

y5,stem

Ambient

1..2

(06) Laboratory East of Laboratov 30 3,000-4.000 Various trace 380-5.100

Hood Stack reagent chemicals

Ambient

8

(07) Calcium Fluoride ust Southwest Corner of

ClolldecDuto Collector the EPP 35 3,000-5.000 Paruiculates as C-.aF, 8.600-14,334

Ambient

8

(08) Decon Dust East of Decon 8 3,000-5A0 Trace Uranium & 81600-14,34

C ollector Stack B uildin............................................................. M etal G rit or Sand

Ambient

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Enclosure 1 JJM-2011-29 April 29, 2011

Official Responses to Environmental Protection RAIs

Table 3-5 Stack Heights and Estimated Flow Rates

42

(09) Lime Dust Northwest Corner of Particulates as

Collector Stack EPP 3CaL137

Ambient

8 . aF of Roof EPP Particuiates/SOi

Combustion Drvei 35 30-100 enOiVC/OC/ 8300

Stack Buildin-g Metane/CO/TOC/

500

8

U11 )Water East of EPP SteamiParticulates/S

Evaporator Stack Building 35 50-100 (,/NO,/VOC/Metha 143-300

ne/CO/"O/C!CO0

212 F

4

(12) +1 East side of Plant

near sanitary waste 355 214-283 O,,-/N[fO/l= CO-! CO 2.454-3.245 Generation Stack treatmert

250

8

(13) UFA4

Vacuum Transfer Roof of F EP 13.753-

[)ust Collector Building 80 4.800-10,600 Particulates as 4 3F

Stack

Ambient

8

LL4B-ý1ý Silo Above B3,,O-Sl___ _Dusts_. o BColSilco 8() 2.000-4.200( Particulates as 5.733-12,041

Stack

Ambient

ICet-t Utp 10 ,, tt U Iti48 to g cl meters bcubic f'eet-niultiply by 0.028317 to gel cubic meters

HFt - ttvdroaitii Fluoriide SiFt Siluicon felt tiluiot ide

Sf) . Sulfhr Di~oxide NO• Nitroet Oxides

I'C, .toal C), Žanic Chemicals CO. Crboti Dioxide N,..Nir ze ,. (x ,e

Di _ - 0Btwi Triifluot ide IT, -. tarujtimT Iettafluotide

VOC .. rlll ruii .hidu: CO -Curbei Monoxiode

Catej,Iini Iuoride, Cut0 Oi)ý - CalcitItII I droxide

itIA Wue (, flora, Trio)x...t

Environmental Protection RAIs Page 12
Enclosure 1 JJM-2011-29 April 29, 2011

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EP-5. Section 9.2.1.3, ALARA Reviews and Reports to Management - Section 9.4.3.2.1(3) of the SRP,

NUREG-1520, provides, among other things, that the applicant commit to report the results of

the annual review of the ALARA effluent control program to senior management. Please identify

the senior management to whom the results of the ALARA review are reported. Also, provide a

more specific reference to subsections within LA Section 4.

RESPONSE: The result of the ALARA review and recommendations for changes in facilities or

procedures that are necessary to achieve ALARA goals are reported to the ALARA committee.

Senior management members of the ALARA committee include the COO/Plant Manager, the

Radiation Protection Manager, selected Department Managers, and the ESH Manager. The

arrangement is described in LA Section 4.2.3.

License Documentation Impact: LA Section 9.2.1.3 will be revised as follows:

In accordance with the ALARA Program, the environmental protection aspects of the Radiation

Protection Program (RPP) are reviewed as part of the annual ALARA review. Review of the

ALARA Program is addressed in LA Chapter 4, RaPiati-n Prcteztioe Section 4.2.3. The ALARA

review includes analysis of trends in release concentrations, environmental monitoring data, and

radionuclide usage; the review then determines the need for operational changes to achieve the

ALARA effluent goals and evaluate designs for system installations or modifications. The results

of the ALARA review are reported to senior management, along with recommendations for

changes in facilities or procedures that are necessary to achieve ALARA goals. The senior

management members on the AILA RA Committee include the Chief Operations Officer, Plant

Manager, Radiation Protection Manager, selected Department Managers, and the ESII Manager

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EP-6 Section 9.2.1.4, Waste Minimization - Please identify and, if appropriate, provide a specific

description of waste-minimization systems and operational procedures regarding conservation

and recycling important compounds. Also, please identify the waste minimization practices that

are consistent with Regulatory Guide 4.21.

Section 9.4.3.2.1 (4) of the SRP, NUREG-1520, identifies, among other things, the elements of an

acceptable waste minimization program under 10 CFR 20.1406.

RESPONSE: Specific descriptions of waste minimization systems and procedures will be added

to the IIFP License Application Section 9.2.1.4. The additional descriptions will include the waste

minimization practices that are consistent with Regulatory Guide 4.21.

License Documentation Impact: Section 9.2.1.4 will be amended as follows (with new text

shown in red):

The highest proiyhas been assigned to Minimizing thle genieration Of waste thrceugh reduetion,

reuise, or- recyclinig.The IIFP facility utilizes vaiuscgncrdwat inimization s'vste ;s an~dd

ope.ation.al pr.. .dures that aim at conservmng ..materials and. recylig im r s; su.h

as . the regeneration and reuse of the plan.t scrubbing system potassiuim hydroxide solution. -The

facility is designed and operated in accordance with 10 CFR 20.1406, "Minimization of

Contamination" (CFR, 2009d) to minimize contamination, facilitate eventual decommissioning,

and minimize to the extent practicable the generation of radioactive waste. The waste

minimization practices during design, construction, and operation of the facility are consistent

with the guidance in Regulatory Guide 4.21, "Minimization of Contamination and Radioactive

Waste Generation: Life-Cycle Planning" (NRC, 2008).

The IIFP Facility incorporates several waste minimization systems in its operational procedures

and design that aim at a high prioritv, of conserving materials and preventing the spread of

contamination. The maior of those systems and procedures are discussed below.

Recycling on-site is an important strategy of the waste minimization program; for example: 1)

regenerating and recycling of potassium hydroxide (KOI-I) scrubbing solution for use in the Plant

KOI Scrubbing System. This design and operation eliminates the need to otherwise discharge the

flow as treated wastewater and also conserves the use of the treating agent and saves cost: 2)

collection and recycling of steam condensate back to the facilitv steam boilers, where applicable.

for saving energy and minimizing disposal, and 3) conserving valuable water resources bv using

air coolers and recirculation of process cooling water thereby avoiding once-through flow of

water.

Another important aspect of the IIFP waste minimization program is the employment of waste

segregation methods and procedures to facilitate recycling and to minimize contamination.

Various receptacles are provided to allow for segregation of clean and contaminated materials. To

prevent cross contamination, training is provided with emphasis on minimizin)g waste and

controlling disposal costs. The outer packaging associated with consumables is removed prior to

use in a contaminated area to minimize potential for contamination and to facilitate recycling and

disposal of the clean segregated materials.

Collected waste such as trash, compressible dry waste, scrap metals, and other candidate wastes

will be volume reduced, where feasible, at a centralized on-site or/and off-site waste processing

facility. An off-site facility will be used for the segregated "clean waste", such as cardboard,

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office paper waste. aluminum cans and scrap metal1 where recycling is practical and can be best

operated by a commercial vendor. ALARA controls will be maintained during facility operation

to account for standard waste minimization practices as directed in 10 CFR 20.1406 (CFR,

2009d).

Lubrication oils and other oils are segregated to prevent cross contamination. The oils are

collected and stored in sealed-concrete pad area utilizing curbs and dikes for containment in

accordance with Resource Conservation and Recovery Act (R.CRA) requirements. Noncontaminated waste oil is sent to an off-site recycle facility, where applicable. Oil that cannot be

recycled is disposed at an off-site licensed disposal facility.

Facility ventilation systems are designed to confine airborne radioactive materials within the

process area and as close to the point of origin as practicable. Construction materials for

ventilation materials are selected as to have a smooth internal surface finish and JIFP minimizes

the number of changes in direction to the extent practicable.

Mechanical integrity and preventative maintenance procedures are utilized in accordance with the

facility Process Safety Management (Chemical Safety Plan) program. In part, the inspections,

surveillance, scheduled and planned maintenance and audits provide a means by which potentials

for leaks on piping and equipment are prevented or minimized. Desihn and operational

procedures provide early detection if leaks do occur thus allowing prompt assessment to support

timely and appropriate response. Monitoring and surveillance programs are extremely important

in minimizing contamnination. I IF1 uses fluoride detector instrumentation, particulate detectors

and personnel surveillance techniques to minimize contamination. If leaks are suspected, the use

of area samplers is utilized to investigate and identify the area for correction. Where leaks of

hazardotis materials are suspected, posted areas and warning lights are utilized to protect

employee health and coMMUnica~te potential containination problems. Suispected or known

leakage problems are investigated, the equipment operation curtailed if -needed and the leakage

resolved including any clean LIp where applicable.

The IIFP Facility is designed to minimize the Usage of natural resources. Closed-loop cooling

systems have been incorporated in the designs to reduce water usage. Power usage is minimized

by efficient design of lighting systems, selection of high-efficiency motors, and use of proper

insulation materials. Solar panels and geothermal heating systems, where practical, are Utilized to

reduce carbon based fuel requirements.

The Plant KOH Scrubbing System and Environmental Protection Process are designed to recycle

KOH thus conserving the treating agent. Secondary containment for tanks and tank systems are

provided with a margin of safety to ensure containment in the event of a leak or spill of the

largest tank capacity per EPA requirements. Tank sampling stations are designed to minimize the

possibility of sample fluid leaking to the ground. Areas involving diesel refueling are also

provided with secondary containment.

Radioactive. hazardous and mixed wastes are generated at the 1IFP Facility. StIch wastes are

collected in labeled containers in each restricted area and transferred to a waste storage area for

inspection. Suitable waste is volume reduced, if feasible, then disposed at a licensed waste

disposal site.

A retention basin is Used for the collection and monitoring of general site storm water runoff.

Sanitary sewage effluent is discharged into a package tinit where it receives primary. secondary

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and tertiary treatment. The effluent fiom sanitary treatment is used in tile facility for process

water make-up or for landscape and watering of the site tree [arm.

An area (Decontamination Building) is provided in the operating facility for decontaminating

equipment that may need to be cleaned before repair or for cleaning of materials, where feasible,

prior to disposal. This system helps minimize the spread of contamination. Some of the

equipmnent and systems provided in this area include:

* High pressure water/steam/air equipment, with a sloped sealed-type floor runoff and

collection double contained sump pit;

* Totally enclosed grit blast unit with dust collection system;

" lon-exchange units suitable to collect soluble uranium firom solution:

* High efficiency filters suitable to remove small particulates of uranium from solution;

and

" Tanks to provide hold capability and precipitation capacity for soluble uranium.

The operating facility Decontamination Building includes an area to perform a series of steps

following equipment disassembly including degreasing. decontamination, drying, and inspection.

Items firom uranium processing systems, waste handling systems. and miscellaneous other items

can be decontaminated in this system. To minimize worker exposure, prevent airborne

radiological contamination resulting fr-om dismantling, air suits or portable ventilation units are

available. Decontamination of chemicals and wastes is provided by components, designated

containers, and air filtration systems. Pipe and vessels in the Decontamination Building are

provided with design measures to protect against spillage or leakage. Hazardous wastes and

mnt~irlnl ar onnmtainor in tank'a ancl nther anr'mit ennta iner'z ,inct qrv& '.rio:tlv ccnrctml lec hx'

procedures.

Practices Consistent with Regulatory Guide 4.21 include:

A. Minimizing Facility Contamination

* Worker access to contaminated areas is controlled to assure that workers wear proper

protective equipment and limit their time in the areas. Protective equipment is cleaned.

stored or disposed in proper locations and receptacles;

* Waste volume reduction is considered and implemented at every opportunity, including

training of employees:

* Leak and spill collection areas are provided:

o Floor liners and catch basins are included in areas of higher leak potential;

* Personnel surveillance techniques are part of the leak identification program;

* Monitoring is conducted for leaks or spills in area Control Room; for example, fluoride

detectors and airborne particulate detectors:

" Radiological boundary control and monitoring stations are used in strategic locations to

prevent carrying of uranium materials from Restricted areas into Unrestricted areas.

* Controlled purge and evacuation svstemns are used to prevent area contamination and

potential out-leakage during maintenance and inspection;

" Decontamination Building and equipment are provided to clean eq uipmnernt, where

applicable, that has been removed for repair and re-installation;

* Floors are appropriately sloped for spills:

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0

0

o

Drains from locker rooms and cleanup showers in potential contamination areas are

routed selectively to the Decontamination Building:

Proper ventilation systems maintain positive pressure in control room areas:

Secondary containment is provided in outside areas and includes excess capacity to

capture leaks or spills from the largest vessel in the area in accordance with EPA

requirements;

Monitoring wells are provided and sampled both uIp gradient and down gradient with

established baselines;

Storm water retention basins have two impermneable barriers:

Exterior tanks are located on or above concrete pads above grade and with curbs and

ikes

Areas to support radioactive material handling are in contained areas:

Drains for storm water are piped to retention basins with capability for samnpling;

Sanitary wastewater is piped to a tertiary treatment system and monitored prior to

discharg,e. and

Facility ventilation system designs confine airborne radioactive mnaterials within the

process area and as close to the point of origin as practicable. Construction materials for

ventilation materials are selected as to have a smooth internal surface finish and minimize

the number of changes in direction to the extent practicable.

B. Minim izing Contamination of the Environment

Building areas where uranium is processed and handled are separated physically from

other building rooms and areas where there is no need to have uranium present. These

areas have separate ventilation and filtration systems to preclude contamination spread.

Boundary control stations and hand/foot and portable monitors are used at applicable

locations to verify that personnel and items exiting Uranium process areas are not

spreading radiological materials into non-uranium areas. The DUF4 Process Building,

FE1P Oxide Staging Building, the facility operations Decontamination Building. DLJF,1

Container Storage Building,. DUF. Container Staging Building and the FEP Process

Building (in areas where licensed material is processed) meet these specific design

features.

All areas of the facility are sectioned into Unrestricted and Restricted Areas. Restricted

Areas limit access for the purpose of protecting individuals against undue risks from

exposure to radiation and radioactive materials. Radiation Areas and potential Airborne

Contamination Areas have additional controls to inform workers of the potential hazard

in the area and to help prevent the spread of contamination. All procedures for these areas

fall uinder the Radiation Protection Program, and serve to minimize the spread of

contamination and simplify the eventual decommissioning.

Routine radiological surveys will be conducted througjhout the facilities' operations life

that will minimize the likelihood that radioactive contamination goes undetected and will

provide a historical record which will simplify the site characterization process.

Non-radioactive process equipment and systems are minimized in locations subiect to

potential contamination. This limits the size of the Restricted Areas and limits the

activities occurring inside these areas.

Local air filtration is provided for areas with potential airborne contarnination to preclude

its spread. Containrnent equipment with hoods that exhaust throughI dust collectors. that

are designed with high removal efficiencies, are used where uranium materials are being

packaged or withdrawn from process systems.

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* The hazardous material processes include designs for purge and evacuation (P&E)

systems and dust-collection equipment as a means to provide effective clean out of

residual chemicals or dust from equipment or piping prior to opening systems for

maintenance. The P&E and dust collector systems have multiple collection equipment in

series (defense-in-depth) to ensure removal and treatment efficiency, redundancy,

effectiveness and reliability.

* Storm water runoff via the storm sewer system flows to a "double lined" retention basin

for either evaporation or for landscape (tree farm) watering. Prior to discharging collected

storm water can be sampled if needed. It is not likely that collected storm water would

exceed acceptable or regulated levels. but routine sampling for reuse or discharge are

conducted for further assurance. Domestic sanitary waste water is tertiary treated to meet

all discharge standards, and is either evaporated or used as harvested water for facilitv

trees, grass and shIubs. The facility is designed for no liquid process water discharges.

Engineered systems are used to provide for regeneration of scrubbing solutions and

recycle within the process systems.

C. Facilitating Decommissioning

" During construction, a washable coating is applied to designated floors and walls in the

Restricted Areas that have the higher potential to become radioactively contaminated

during operation. The coating serves to lower waste vol iimes during decontamination and

simpli•y the decontamination process;

" Sealed, nonporous pipe insulation is used in areas with higher potential to become

contaminated. This facilitates cleaning in event of a spill and will reduce waste volume

during decommissioning;

* Ample access is provided for efficient equipment dismantling and removal of equipment

that may be contaminated. This minimizes the time of worker exposure;

" Tanks have access for entry and decontamination. Design provisions are also made to

allow for removal of the wastes or materials contained in the tanks:

" Connections in the process systems. provided for required operation and maintenance,

allow for thorough purging at facility shutdown. This system and procedure remove a

significant portion of radioactive contamination prior to disassembly and prevent leakage

to the general environment upon opening of equipment or piping:

* Design drawings, produced for all areas of the facility, will simplify the planning and

implementing of decontamination procedures. This in turn will shorten the durations that

workers are exposed to radiation;

* Worker access to contaminated areas is controlled to assure that workers wear proper

protective equipment and limit their time in the areas:

Radioactive and hazardous wastes prodiiced CIuring decommissioning will be collected.

handled, and disposed of, in accordance with all regulations applicable to the facility at

the time of decommissioning. Generally, procedures will be similar to those described for

wastes produced during normal operation. These wastes will Ultimately be disposed in

licensed radioactive or hazardous waste disposal fIacilities located elsewhere. Nonhazardous and non-radioactive wastes will be disposed in a manner consistent with good

industrial practice, and in accordance with applicable regulations and

To facilitate decommissioning, the information relating to the facility design, facility

construction, design, modifications, site conditions before and after construction, onsite

contamination and results of monitoring and radiological surveys will be readily

recoverable through the IIFP document control and management process.

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EP-7. Section 9.2.2, Effluent and Environmental Controls and Monitoring - Please identify or provide

specific cross references to the subchapters of the ER and subsections of the LA that identify the

effluent and environmental controls that are at and around the facility. Also, please provide a

specific description of the portions of the Radiation Protection Plan (RPP) that address

environmental protection.

Section 9.4.3.2.2(1) of the SRP, NUREG-1520, identifies, among other things, the criteria of an

acceptable effluent monitoring program.

RESPONSE: Administrative and engineered controls for environmental effluents are described

in the LA, subsections 4.1 through 4.7, and in the IIFP FEP/DUP ER (IIFP, 2009a), subsections

2.1.3, 4.2.2, 6.1.1, 6.1.2, and 6.1.3. As described in LA Section 4.2, the ALARA program is a

subset of the Radiation Protection Program. With regard to effluent and environmental controls,

the ALARA principle demands that radioactive effluents are monitored, and that environmental

releases stay far below the regulatory limits. An additional aspect of the ALARA program

includes the preparation and review of an annual report to evaluate effluent release trends as a

means to ensure the ALARA programs are effectively implemented.

License Documentation Impact: In response to RAI-EP-7, a second paragraph will be added to

LA Section 9.2.2 (paragraph one was modified in response to RAI EP-2) and will read as follows

to include additional information:

Effluent and environmental controls and monitors are maintained at and around the facility to

ensure that doses to the workers, the public, and the environment remain ALARA. In order to

monitor and characterize meteorological phenomena (e.g. wind speed, direction, and temperature)

during plant operation, conditions will be monitored with a meteorological tower located oil site.

In addition, monitors provide indication of potential off-normal occurrences requiring further

investigation. Guidance provided in Regulatory Guide 4.16, "Monitoring and Reporting

Radioactivity in Releases of Radioactive Material in Liquid and Gaseous Effluents from Nuclear

Fuel Processing and Fabrication Plants and Uranium Hexafluoride Production Plants" (NRC,

1985) has been utilized in the preparation of the environmental protection aspects of the RPP

(IIFP, 2009b), where applicable.

Administrative and engineered controls for environmental effluents are described in ISA Sections

2.4.10, 2.4.11 and 3.1 and the following subsections of the ISA. These controls are also described

in the LA, Section 1.1.3 and the following subsections and Section 4.6 and the following

subsections. These controls are also described in the IIFP FEP/DUP ER (IIFP. 2009a).

subsections 2.1.3, former 4.6.2.2 (now 4.6.4.1). former 4.6.2.3 (now 4.6.4.2). 6.1. 6.2, and 6.3.

The Radiation Protection Plan (RPP) that addresses environmental protection is described in ER

Sections 6.1, 6.2 and 6.3 and is also described in LA Section 4.1-4.7. As described in LA Section

4.2. the ALARA program is a subset ofthe Radiation Protection Program. With regard to effluent

and environmental controls, the AlARA principle demands that radioactive effluents are

monitored and that environmental releases stay significantly below the regulatory limnits. An

additional aspect of the ALARA program includes the preparation and review of an annual report

to evaluate effluent release trends as a means to ensure the ALARA programs are effectively

implemented.

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EP-8. Section 9.2.2. ], Expected Concentrations - Please identify the concentrations, calculations, and

modeling of airborne and solid radioactive materials listed in this section. If available, provide

specific references to the ER and LA subsections (including specific tables or Figures) which

contain the information. Also, please identify or reference the conservative assumptions used in

calculations and modeling of those concentrations.

Section 9.4.3.2.2(1) (a) of the SRP, NUREG-1520, identifies Expected Concentrations for effluent

monitoring that are to be below limits specified in 10 CFR 20, Appendix B.

RESPONSE: Table 4-38 (former Table 4-24) of the ER (IIFP, 2009a) illustrates "Estimated and

Bounding Radiological Releases from the Stacks." Calculations and modeling of airborne

radioactive materials, and the conservative assumptions used in the calculations and modeling,

are documented in Section 4.12.2 of the ER (IIFP, 2009a).

License Documentation Impact: The second sentence in LA Section 9.2.2.1, under subsection

"Expected Concentrations" will be replaced and the subsection will read as follows:

The expected concentrations, based on calculations and modeling, of radioactive materials in

airborne and solid effluents were estimated using conservative assumptions. Those estimated

values are proved in the 111212 ER, Chapter 41. are shown in ER Table 4-38 (formner Table 4-24),

"Estimated and Bounding Radiological Releases from the Stacks during Phase I Operations "of

the IIFP FEP/DUP ER (IIFP. 2009a). Calculations and modeling of airborne radioactive

materials, with the conservative assumptions used in the calculations and modeling, are

documented in Section 4.12.2 of the ER. The concentrations controlled to be ALARA and below

the limits specified in 10 CFR 20, Appendix B, Table 2 (CFR, 2009c). As stated above, the plant

liquid effluents, that have potential for containing uranium, are recycled, reused and maintained

on the IIFP Ssite.

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EP-9. Section 9.2.2.1, Calculations of Total Effective Dose Equivalent- It appears that compliance

with dose limits for individual members of the public is demonstrated by calculation of the Total

Effective Dose Equivalent (TEDE) as opposed to calculation of annual average concentrations of

radioactive material released. Please provide more detailed discussions of the calculation of the

TEDE by pathway analyses to demonstrate that the appropriate models, codes, and assumptions

accurately represent the facility, site, the surrounding area, and the pathways considered. Also,

please provide citations to any relevant tables and discussion within the ER, e.g., Subsection ER4.12.

Section 9.4.3.2.2(1) (b) of the SRP, NUREG-1520, identifies Calculations of Expected Dose for

effluent monitoring within limits in 10 CFR 20.1301 through calibrations identified in 10 CFR

20.1302.

RESPONSE: To demonstrate compliance with 10 CFR 20.1301 (via calculation of the TEDE to

the individual likely to receive the highest dose), IIFP will apply the EPA Radiation Risk

Assessment software, CAP-88 or COMPLY. References to committed dose equivalents are also

provided.

License Documentation Impact: The subject paragraph in Section 9.2.2.1, "Calculations of

Total Effective Dose Equivalent" of the LA Revision A will be revised as follows:

Dose projections to members of the public are performed routinely to ensure the annual dose to

members of the public are kept ALARA and within the regulatory limit in accordance with

approved written procedures. Compliance as described in 10 CFR 20.1302, "Compliance with

Dose Limits for Individual Members of the Public" (CFR, 2009e); is demonstrated through either

the calculation of the total effective dose to the individual likely to receive the highest dose, or

through the calculation of annual average concentrations of radioactive material released in

gaseous and liquid effluents. To demonstrate compliance with 10 CFR 20.1301 (via calculation of

the TEDE to the individual likely to receive the highest dose), IIFP will apply the EPA Radiation

Risk Assessment software, CAP-88 or COMPLY. There are four primary exposure pathways

associated with plant effluent: inhalation; immersion in an effluent plume: direct radiation due to

deposited radioactivity on the ground surface (pround plane exposure) and ingestion of

contaminated food products. Of these four exposure pathways, inhalation exposures are expected

to be the predominant pathways at site boundary locations and also at off-site locations that are

relatively close to the site boundary. Input assumptions for the EPA codes will reflect the

configuration and location of the release points, site-specific meteorology. the potential location

of the maximally exposed individual, and the regional land use. Input assumptions similar to

those applied in the ER dose calculations (documented in ER Section 4.12.2.2.2 "Public and

Occupational Exposure Impacts") will be used as necessary. Table 4-41 (former Table 4-25) of

the ER provides the annual and committed close equivalents for exposures to the maximally

exposed individual (MEt) from gaseous effluents. Table 4-42 (former Table 4-26) firom the ER

provides annual and committed dose equivalents for exposures to the nearest resident firom

gaseous effluents. The estimated dose rate for sit boundary locations, the MEI, and the nearest

resident is provided in Table 4-45 (former 4-27). The guidance in Regulatory Guide 4.20,

"Constraint on Releases of Airborne Radioactive Materials to the Environment for Licensees

Other than Power Reactors" (NRC, 1996), is followed to determine compliance with dose limits

to members of the public. Compliance with the dose limits to the members of the public is

reported to the NRC in the semi-annual effluent report as required by 10 CFR 40.65 "Effluent

Monitoring Reporting Requirements"-(CF4,, 0•9tRý- .

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EP-] 0. Section 9.2.2.1, Effluent Discharge Locations - Please identify the locations of airborne effluent

discharges and monitoring. Also identify contributing sources, if any, for discharge points.

Section 9.4.3.2.2(1) (c) of the SRP, NUREG-1520, addresses Effluent Discharge Locations for

effluent monitoring.

RESPONSE: The subject paragraph from LA Section 9.2.2.1 will be revised to locate the

airborne discharges and contributing sources for discharge points. See also RAI EP-4.

License Documentation Impact: Section 9.2.2.1, "Effluent Discharge Locations" of the LA

Revision A will be revised as follows:

There will be two types of airborne effluent discharges firom the IIFP site - stack effluent

discharges and roof exhaust fan discharges. The locations of stack effluent discharges are

illustrated in the plot plan. "Modified Site Features with Sampling Stations and Monitoring

Locations" (Figure 6-1) of the IIFP FEP/DUP ER. Roof exhaust fans are located on buildings

which house areas where uranium is processed or handled. Both discharge types will be

monitored as described in Section 6.1.1.1 of the ER.

There are fourteen (14) stacks involving contributing sources in the airborne effluent discharge

locations. Two sources contribute to the effluent from the FEP Dust Collector Stack (number 03)

-- one each from the SiF4 and BF- process systems. The process off-ias from the DUF,4jL1 1 and

BF, are all scrubbed in the three-stage (in series) equipment of the Plant KOH Scrubbing System.

The treated gas from the last stage of tile scrubbers exits the Plant KOH Scrubbing System Stack

(number 01 ).

The 11121- ER Chapter 6 (U1'P, 2009), addsesses the estimated locatiotis of the airbornfe effluient

discharges and monitoring estimated locations for the site. Liquid plant effluents are maintained

on the I1FP site and there is no discharge of process wastewater. Liquid effluent monitoring is

described in ER Section 6.1.1.2.

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EP- l. Section 9.2.2.1, Continuous Sampling Airborne Effluents - Briefly summarize relevant portions of

ER Chapter 6 that are referenced. Please define (quantify) what is meant by "significant"

regarding increases in radiation levels that would trigger additional analyses. Also, please

summarize (briefly) the purpose of the Effluent Monitoring Program (EMP), and provide a more

specific reference to subchapters within ER Chapter 6 where the EMP is discussed.

Section 9.4.3.2.2(1)(d) of the SRP, NUREG-1520, addresses Continuous Sampling Airborne

Effluents for effluent monitoring under the Radiation Protection Program under 10 CFR 20.

1101.

RESPONSE: A 25% increase in radiation levels would be indicative of a significant increase in

radiation levels to trigger additional analysis. The purpose of the effluent monitoring program

will be briefly described and a reference to the location of the REMP discussion in Section 6.1.1

of the ER will be added to the subject paragraph..

License Documentation Impact: Section 9.2.2.1, "Continuous Sampling Airborne Effluents"

will be revised as follows:

The IIFP ER Chapter 6 addresses the Effluent Monitoring Program (EMP) (IFP, 2009c). The

purpose of the Effluent Monitoring Prorwam (EMP) is to ensure that surveys are performed as

necessary to demonstrate compliance with regulations and to demonstrate that the amount of

radioactive material present in the facilitv effluent remains ALARA. The REM P is discussed in

Section 6.1.1 of the IIFP FEP/DUP ER.

The effluent stacks. where licensed materials are involved, are sampled continuously and is

routinely analyzed to measure radioactivity of the exhaust air. The collection filters in the sample

systems are removed periodically and analyzed for gross alpha and beta activity. The filters are

composited periodically and an isotopic analysis is performed. Radiological analyses are

performed on ventilation air filters if there is a4gifeaat4-25%.increase in gross radioactivity, or

when a process change or other circumstances cause significant changes in radioactivity

concentrations.

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EP-12. Section 9.2.2.1, Sample Collection and Analysis - Please clarify what is meant by the term

"appropriate" sample collection and analysis methods andfrequencies for the effluent medium

and indicate the radionuclides sampled. Provide a brief summary of the EMP that addresses

sample collection and analysis andfrequencies.

Section 9.4.3.2.2(1)(e) of the SRP, NUREG-1520, addresses Sample Collection and Analysis for

effluent monitoring.

RESPONSE: Sample collection and analysis methods and frequencies for the effluent medium

will be performed in accordance with Regulatory Guide 4.15 "Quality Assurance for Radiological

Monitoring Programs (Normal Operations) - Effluent Streams and the Environment" and

Regulatory Guide 4.16, "Monitoring and Reporting Radioactivity in Releases of Radioactive

Materials in Liquid and Gaseous Effluent from Nuclear Fuel Processing and Fabrication Plants

and Uranium Hexafluoride Production Plants."

Section 6.1.1 of the FEP/DUP ER describes the Effluent Monitoring Program. Section 6.1 of the

IIFP FEP/DUP ER (IIFP, 2009a) describes the proposed sampling and monitoring locations for

gases effluents and liquid effluents. The subject subsection will be modified to include a

summary.

License Documentation Impact: LA Revision A Section 9.2.2.1, subheading "Sample

Collection and Analysis" will be revised as follows:

The EMP establishes appropriate sample collection and analysis methods and frequencies for the

effluent medium and the radionuclide(s) sampled. Sample collection and analysis methods and

frequencies for the effluent medium will be perfonrmed in accordance with Regulatory Guide 4.15

"Quality Assurance for Radiolomical Monitoring- Programs (Normal Operations) - Effluent

Streams and the Environment" and Regulatory Guide 4.16. "Monitoring and Reporting

Radioactivity in Releases of Radioactive Materials in Liquid and Gaseous Effluent from Nuclear

Fuel Processing and Fabrication Plants and Uranium Hexafluoride Production Plants." Sampling

methods ensure that representative samples are obtained using appropriate sampling equipment

and sample collection and storage procedures. Monitoring instruments are calibrated at least

annually or more frequently if suggested by the manufacturer. IlFP ensures that sampling

equipment (pumps, pressure gages, and air flow calibrators) are calibrated by qualified

individuals. Sampling equipment and lines are inspected for defects, obstructions, and cleanliness

as part of the plant preventive maintenance procedures.

Section 6.1.1 of the FEP/DUP ER describes the Effluent Monitoring Program. Section 6.1 of the

[IFP FEP/DUP ER (IIFP. 2009a) describes the proposed sampling and monitoring locations for

gases effluents and liquid effluents. Figure 6-1 of the IlFP FEP/DUP ER (IIFP, 2009a).

"Modified Site Features with Sampling Stations and Monitoring Locations," indicates the

locations of the environmental sampling, stations and monitoringz locations. Further, Section 6. 1.1

of the ER describes the sampling media, frequency, and analysis types to be performed.

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EP-13. Section 9.2.2.1, Radionuclide-Specific Analysis - Specify that plant preventive maintenance

procedures will be maintained onsite and implemented. Specify where monitoring reports are

discussed. Alternatively, briefly summarize what is meant by the term, summary reports. Also, in

the second paragraph, clarify what is meant by "a significant increase" in gross radioactivity.

Briefly summarize relevant portions of ER Chapter 6.1.1.

Section 9.4.3.2.2(1) (1 of the SRP, NUREG-1520, addresses Radionuclide-Specific Analysis for

effluent monitoring.

RESPONSE: Facility preventive maintenance procedures will be specified to be maintained

onsite and implemented. Section 9.2.2.1, "Radionuclide-Specific Analysis" will be revised as

indicated in the License Documentation Impact below.

Monitoring reports are discussed in Section 9.2.2.1, "Reporting Procedures."

A 50% increase in gross radioactivity will indicate "a significant increase" in gross radioactivity

Section 9.2.2.1, "Radionuclide-Specific Analysis" will be revised to add this clarification and to

briefly summarize gaseous effluents.

A brief summary of relevant ER Chapter 6, Section 6.1.1 will be added to subsection

"Radionuclide Specific Analysis."

License Documentation Impact: License Application, Section 9.2.2.1, "Radionuclide-Specific

Analysis" will be revised as indicated below:

Radionuclide-Specific Analysis

Radionuclide-specific analyses are performed on selected composited samples as indicated in

Chapter 6.1.1 of the IIFP ER (IIFP, 2009a). Because uranium in gaseous effluent may exist in a

variety of compounds (e.g., DUF 6, uranium oxide, DUF4, and DUO 2F2), effluent data is

maintained, reviewed, and assessed by the facility's Radiation Protection Manager to assure that

gaseous effluent discharges comply with regulatory release criteria for uranium. The Effluent

Monitoring Progyram f'alls under the oversight of the ilFP Radiation Safety Program. Section 6.1.1

addresses the Effluent Monitoring Program. As a matter of compliance with regulator

requirements, potentially radioactive effluent firom the facility is discharged only through

monitored pathways. The effluent sampling program for the IlIFP facility is designed to determine

the quantities and concentrations ofradionucilides discharged to the environment. Uranium

isotopes and daughter products are expected to be the prominent radionuclides in the vaseous

effluent. Process stacks and air vents are (I) sampled continuously through the use of air filters

and analvzed for gross alpha/beta and isotopic and (2) analyzed weekly with additional quarterly

composite analysis.

Facility preventive maintenance procedures will be specified to be maintained onsite and

implemented. These preventive maintenance procedures, and the associated configuration

management for these procedures, are described in LA subsection 11.2.2.

Monitoring reports, which include the quantities of individual radionuclide(s) estimated on the

basis of methods other than direct measurement, include an explanation and justification of how

the results were obtained. Monitoring reports are discussed in Section 9.2.2.1. "Reporting

Procedures."

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Radionuclide analysis may be performed more frequently at the beginning of the monitoring

program until a predictable and consistent composition is established. Likewise, the analysis

frequency may be increased when there is a signi1iet 50% increase in gross radioactivity in

effluents or a process change or other circumstance that might cause a significant variation in the

radionuclide composition.

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EP-14. Section 9.2.2.1, Minimum Detectable Concentrations -Please provide a more specific reference

to subchapters within ER Chapter 6. Provide a summary of relevant portions of Chapter 6 that

are referenced.

Section 9.4.3.2.2(1) (g) of the SRP, NUREG-1520, addresses Minimum Detectable Concentrations

for effluent monitoring for concentrations in 10 CFR 20, Appendix B.

RESPONSE: LA Section 9.2.2.1 will be revised to provide a reference to the subchapters within

ER Chapter 6 which addresses minimum detectable concentrations for effluent monitoring.

License Documentation Impact: LA Section 9.2.2.1, subheading "Minimum Detectable

Concentrations" will be revised as follows:

FIR Chapter 6 (HlFP, 2009) presents the required minimum detectable eoneentratioin (NeDC) for

gi-s alpha afialwsc pei-far.ed on gaseous effluent samplz ER Chapter 6.1.1.1 describes the

gtaseous effluent monitorine requirements for the facility. A m1inimum detectable concentration

(MDC) of at least 3.7x1]0' Bq/ril (I.Oxl0- FL-Ci/ml) will be required for all gross alpha analyses

nerformed oni gaseous effluent samr)les.

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EP-15. Section 9.2.2. ], Action Levels -Please identify the specific action levels. Also, identify any steps

involving effluent monitoring that would be taken before shutdown.

Section 9.4.3.2.2(1)(i) of the SRP, NUREG-1520, addresses Action Levels for effluent monitoring.

RESPONSE: Specific action levels will be set at 50% of the 10 CFR 20 Appendix B Table 2

values.

License Documentation Impact: Section 9.2.2.1, "Action Levels" will be revised as indicated

below:

Administrative action levels are established for effluent samples and monitoring instrumentation

as an additional step in the effluent control process. All action levels are sufficiently low so as to

permit implementation of corrective actions before regulatory limits are exceeded. Action levels

will be set at 50% of the 10 CFR 20 Appendix B Table 2 values. Effluent samples that exceed the

action level are cause for an investigation into the source of elevated radioactivity. Processes are

designed to include, when practical, provision for automatic shutdown in the event action levels

are exceeded.

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EP-16. Section 9.2.2.1, Federal and State Standards for Discharges - Please define the term, "aircontaminant source. " Also, provide a specific reference to the ER subchapter that provides the

status of all Federal, State, and local requirements.

Section 9.4.3.2.2(1)0) of the SRP, NUREG-1520, addresses Federal and State Standards for

Discharges for effluent monitoring.

RESPONSE: Air-contaminant source means any building, structure, or facility, or combination

thereof, which emits or is capable of emitting air contaminants to the atmosphere that are

regulated by Federal, State and local requirements.

License Documentation Impact: The definition of air-contaminant source and the specific

reference to the ER Section that provides status of all Federal, State and local requirements will

be included as a revision in the IIFP License Application Section 9.2.2.1 under "Federal and State

Standards for Discharges" to read as follows:

New Mexico Statutes Annotated (NMSA), Chapter 74, "Environmental Improvement," Article 2,

"Air Pollution," (NMSA, 2009a) and implementing regulations in the New Mexico

Administrative Code (NMAC) Title 20, "Environmental Protection," Chapter 2, "Air Quality,"

(NMAC, 2009a) establishes air-quality standards and permit requirements prior to construction or

modification of an air-contaminant source. IIFP defines an air-contaminant source as any'

buildin.,, structure, or facility, or combination thereof, which emits or is capable of emitting air contaminants to the atmosphere that are regulated by Federal. State and local requirements. These

regulations also define requirements for an operating permit for major producers of air pollutants

and impose emission standards for hazardous air pollutants. Accordingly, IIFP will file

applications and obtain appropriate air construction and operating permits, where applicable. The

UIFP Environmental Report Section 1.4 addresses applicable regulatory requirements and status.

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EP- 17. Section 9.2.2.1, Waste Management Procedures - Ifpossible, specify the Low Level Waste

disposal site that may be used. Please provide a reference, include anyfigures, to the plant

description in the LA or ER that contains the waste management facilities, as discussed in

paragraph 2 of this section.

Section 9.4.3.2.2(1)(n) of the SRP, NUREG-1520, addresses Waste Management Procedures for

effluent monitoring.

RESPONSE: Final selection of a low level waste (LLW) disposal site has not been made.;

however, Table 4-4 of the IIFP FEP/DUP ER (IIFP, 2009a) identifies transportation radiological

data for three possible licensed LLW disposal destinations (1) Energy Solutions in Clive, Utah,

(2) WCS, a Texas facility just inside the Texas border near Eunice, New Mexico, and (3) GTS

Duratek in Oak Ridge, Tennessee. Discussions have been conducted with Energy Solutions

relative to disposal and acceptance criteria of the uranium oxide waste that is a byproduct of the

IIFP Fluorine Extraction Process (FEP). Currently, the Energy Solutions disposal facility at Clive,

Utah is a licensed and acceptable facility for disposal of the uranium oxide and other LLW waste.

The WCS Texas facility is expected to also be available to accept LLW and uranium oxide by the

time the IIFP Facility becomes operational.

Additional information about the waste management facilities and descriptions is provided below

as amendments to the Section 9.2.2.1, "Waste Management Procedures." Some of the building

descriptions being added to Section 9.2.2.1 are also being revised in response to the Request for

Additional Information (RAI) General Information (GI)-6.B. In addition, Table 1-2 in the License

Application, "Building IIFP FEP/DUP Facility Building Sizes" referenced in Section 9.2.2.1,

"Waste Management Procedures" was revised in response to RAI GI-6B to include updated

building sizes.

Table 1-3 in the License Application, "Estimated Annual Quantities of Waste Generated at the

IIFP Facility" as referenced in Section 9.2.2.1, "Waste Management Procedures" will be revised

to include updated information.

License Documentation Impact: Subsection 9.2.2.1, Waste Management Procedures,"

paragraph two will be revised, the section will be expanded and paragraph three will be deleted.

The subsection will read as follows:

Waste Mana2ement Procedures

Solid waste management facilities with sufficient capability to enable preparation, packaging,

storage, and transfers to licensed disposal sites in accordance with the regulations, are

incorporated into the IIFP Facility design and are maintained in proper operating condition as

required to support the operation of the facility. Waste management procedures and processes are

performed in various buildings and areas of the tlFP Facility depending on the locations and

characteristics of the waste stream. The main buildings involved are the FEP Process Buildinm,

FEP Oxide Staging Building, Decontamination Building. Environmental Protection Process

(EPP) Building and the Material Warehouse. These maior buildings and areas are either described

below or references to other Sections of the I IFP License Application are provided for more

specific descriptions.

The locations of the buildings and areas discussed below are shown in the IIFP License

Application. General inflormation. Figure 1-5. A larger and more legible site drawing showing the

subiect buildings and locations is provided as Drawing I 00-C-0001, Revision E, and is part of the

engineering drawing package provided to the NRC as separate document files of the IiFP License

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Application. The subject building sizes are provided in Table 1-2. Chapter 1 General Information

of the License Application

TFable 1-3, Chapter 1. General Information of the License Application shows the estimated annual

quantity of waste generated at the lIFP Facility. The largest amount of solid waste generated is

the depleted uranium oxide that is a byproduct of the FEP process. This waste is managed using

the equipment and facilities of the FEP Process Building and the FEP Oxide Staing Building.

The depleted uranium oxide fr-om the FEP process is collected in the oxide storage hopper for

temporary storage until it is packaged for shipment. The depleted uranium oxide byproduct is

filled into Department of Transportation approved drums (or other approved transport containers).

The depleted oxide is filled into the packaging container using an enclosed filling (drum off)

station located in the F.EP Process Building. .he oxide hoppers and the drum-off stations are

located on the first level of the building. The filling station enclosure is connected to the FEP

oxide dust collection system to provide negative pressure in the enclosed filling station to contain

and capture dust during the filling process. After filling, the uranium oxide shipping containers

are then checked, labeled and staged temporarily in the FEP Oxide Staging Building for

scheduled loading and shipment by trailer truck to a licensed disposal site. The FEP Oxide

Staging Building is adjacent to. and on the east-side of the FEP Process Building. The wall

between the FEP Oxide Staging Building and the FEP Process Building is a fire barrier. This

building is a two level building with a reinforced concrete floor on the first level with

containment-type curbing. It is used for staging of oxide waste containers for loading into truck

trailers and transporting to an off-site licensed waste disposal facility. Equipment in the building

consists of weighing equipment, electrical and instrumentation monitoring and alarm panels and

controls, exhaust hood systems, piping and ductwork connections to the primary dust collector

system.

The Decontamnination Building serves as a facility with equipment to manage Low-Level

Contaminated Waste (LLW) other than the depleted uranium oxide waste. The Decontamination

Building is located adiacent to. and on the north side of the DUF4 Process Building. The

construction provides for a fire barrier between the Decontamination Building and the DUF4

Process Building. This building is used for decontamination of eCquipmnent for maintenance and

for handling and preparing LLW for shipments. The Decontamination Building contains an

equipment cleaning booth and hood system, equipment for sorting and packaging IW and

mixed dry solid waste, loading station. weighing scales. drying equipment, primary and

secondary duist collector system in series, contaminated-water holding tanks, primary and

polishing filters, associated pumps, piping, field equipment instrumentation panels. ion exchange

columns and associated controls and backwash systems.

Radioactive waste, including dust collector bags, ion exchange resin, crushed-contaminated

drums, contaminated trash. contaminated and carbon-bed trap material are collected in labeled

containers in each Restricted Area and transferred to a temporary radioactive waste storage area

located in the Decontamination Building. In this area LLW is soiled, if needed. prepared,

packaged, and surveyed. Suitable waste is volime-reduced using compaction equipment, if

feasible. The LLW is loaded and transported for disposal at an off-site licensed LLW disposal

facility.

Also in the Decontamination Building, relatively small volumes of miscellaneous waste liquors,

that have potential to contain depleted uranium, are concentrated. filtered and treated to remove

the depleted uranium from liquid steams. Depleted uranium removed from liquid streamns is

collected- dried fbr volume reduction and to meet accentance criteria and sent to an off-site

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licensed low-level-waste disposal site along with the waste depleted uranium oxides produced by

the de-conversion processes.

The EPP Building and adjacent area is used to treat and manage fluoride-bearing waste liquors.

The design of the ItFP Facility includes equipment to regenerate spent potassium hydroxide

(KOH) solutions that can be reused and recycled in the Plant KOH Scrubbing System. This

design and operation eliminates the need to otherwise discharge the flow as treated wastewater

and also conserves the use of the treating agent and saves cost. Also. aqueous waste solutions that

are not licensed material but contain fluoride or trace metals are treated in the EPP.

The treatment of fluoride-bearing, liquors results in a solid particulate calcium fluoride (CaF,)

which may be sold as a raw material for use in the fluorine chemical industry'. Converting the

fluoride in the subiect liquors to a solid is the means bv which fluoride wastes are managed with

potential use as a resource in other industrial markets. The treatment process, preparation and

packaging procedures for the CaF, are conducted in the Environmental Protection Process (EPP)

Building. In this area. the CaF is filtered firom the process and dried for shipment to customers.

where there is a demand, or shipped to an off-site Resource Conservation and Recovery Act

(RCRA) permitted disposal site if there is no feasible market demand. The EPP Building and

equipment is described in the [lFP License Application Section I. 1.2.1 and in the Integrated

Safety Analysis (ISA) Summary Section.3.1.8.

The Material Warehouse is located iust northeast of the Process Offices and Laboratory Building.

This warehouse is used to receive and store such items as piping components. electrical conduit.

wiring, equipment for capital construction proiects and spare parts. Small quantities of chemicals

such as paints, oils, and cleaning agents may be stored in the warehouse. No licensed materials

are stored in this building.

Part of the Material Warehouse is used for managing non-radioactive waste. Designated areas

inside the Material Warehouse and some collection containers on the adiacent outside curbed

concrete pads are used to collect, sort. package, if necessary, and load non-radioactive waste. This

waste has been segregated and surveyed to be determined as non-radioactive prior to moving to

the Material Warehouse area. Waste sent to this area must be approved for release to licensed

commercial disposal or recycling. This waste includes industrial sanitary wastes. such as

cardboard, paper, wood, scrap metal, etc. Some of these wastes, such as cardboard, paper, and

metal may be shipped to off-site facilities for recycle or minimization, and. then sent. if required,

to an off-site licensed waste disposal facilitv.

One area in the warehouse is designated for these type wastes. Another area. in the warehouse is

set aside to manage small quantities of Resource Conservation and Recovery Act (RCRA) waste

that is riot otherwise handled at the EPP. The RCRA waste is packaged, labeled, manifest and

loaded for shipment. A permitted transport contractor is used to transport the waste to a permitted

RCRA facility for disposal.

Deseiriptiens ofthe proposed 11FP waste Managemfenit SyStemFS are prOVided in the IIf-P Chapter -3.

License Documentation Impact: Table 1-3 in Section 1.1.6.1 of the License Application,

"Estimated Annual Quantities of Waste Generated at the 1IFP Facility" as referenced in Section

9.2.2.1, "Waste Management Procedures" above will be revised to include updated quantities.

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Table 1-3 Estimated Annual Quantities of Waste Generated at the IIFP Facility

Estimated Annual AmoiUnt Material ? , - ~ ,

Depleted uranium oxide 2,800,000-6,000, .... . 000

Other process LLW 420•0-68000 85.650-137,300

RCRA -32,300 -361 50- 203.I-)200-308,400"

Industrial waste including 71,000 108,500 60.650-9l300

sanitary waste

*Includes Calcium Fluoride which may not be RCRA Waste if sold.

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EP-18. Section 9.2.2.2, Environmental Monitoring - Environmental Monitoring is mislabeled as merely

being one of several topics under Section 9.2.2.1, Effluent Monitoring. Instead, Environmental

Monitoring should be identified separately as the second subsection under Section 9.2.2, Effluent

and Environmental Controls and Monitoring. Because Environmental Monitoring is the second

part of Section 9.2.2, it should be numbered separately as Subsection 9.2.2.2.

Section 9.4.3.2.2(2) of the SRP, NUREG-1520, addresses Environmental Monitoring.

RESPONSE: The referenced subsection will be removed from Section 9.2.2.1, Effluent

Monitoring as described below.

License Documentation Impact: The following subsection "Environmental Monitoring" will be

renumbered and moved from Section 9.2.2.1, "Effluent Monitoring" to a new section 9.2.2.2

Environmental Monitoring. This impact is described in response to RAI EP-1 9.

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EP-19. Section 9.2.2.2, Environmental Monitoring -As noted above, Section 9.2.2.2 should have been

the location within the LA to describe Environmental Monitoring. LA Section 9.2.2.1, Effluent

Monitoring, identifies 14 topics related to the effluent monitoring acceptance criteria. The

acceptance criteria closely track the topic headings identified in Section 9.4.3.2.2(1) of the SRP,

(NUREG-1520). However, Environmental Monitoring, which should have been numbered as LA

Section 9.2.2.2, did not identify the 9 SRP topics related to the environmental monitoring

acceptance criteria. LA Section 9.2.2.2 only identified two SRP topics in a very brief and

conclusory manner. These two topics only touch lightly on afew of the remaining (missing)

topics. Provide additional discussion to address all of the nine SRP topics and provide

additional specific cross-referencing.

Environmental Monitoring acceptance criteria in Section 9.4.3.2.2(2) of the SRP (NUREG-1 520),

which are labeled as being (a) through (i), address the specific information needed in the Effluent

Monitoring section of the LA, as discussed above. Provide a brief summary for each of these, as

well as a cross-reference to the appropriate LA or ER subsections or subchapters that provide the

needed additional detail. Note that it appears that some criteria are not addressed at all (e.g., (d)

analytical methods and instrumentation, maintenance and calibration program, (e) action levels

and actions to be taken, (/) identify MDCs for Environmental Monitoring that are at least as low

as those for Effluent Monitoring for air and water (g) data analysis methods and criteria, and (i)

adequacy of environmental data to assess impacts from any releases identified in the ISA).

Please provide this missing information.

Section 9.4.3.2.2(2) of the SRP, NUREG-1520, addresses Environmental Monitoring under 10

CFR 20.

RESPONSE: A new section 9.2.2.2, "Environmental Monitoring" will be added to include the

information moved from the previous section, 9.2.2.1, Effluent Monitoring subheading

"Environmental Monitoring". This section will be revised and expanded to address all 9 SRP

topics identified in Section 9.4.3.2.2(2) of the SRP (NUREG-1520).

License Documentation Impact: The following License Application, Section 9.2.2.2,

"Environmental Monitoring," will be renumbered, revised and expanded as described below.

Environmcntal Monitow-in

9.2.2.2 Environmental Monitoring

The following sections address the acceptance criteria related to environmental monitoring.

Background and Baseline Measurements

The Radiological Environmental Monitoring Program (REMP) at the IIFP Facilit- establishes a process for collectingz data for assessing radiological impacts on the environs. The REMP

includes the collection of data during pre-operational years in order to establish baseline

radiological information that will be used in determining and evaluating impacts from operations

at the plant on the local environment. The REMP will be initiated at least 12 months prior to

facility operations in order to develop a sufficient database. Prior to facility operationss-ei4i- n

gr.. .•..w..- samples will be collected from the site and analyzed to determine a baseline to be

used in evaluating changes in potential environmental conditions caused by facility operations.

Vegetation and soil samples, both frorn on and off-site locations will be collected on a Cuarterly

basis in each sector duringz the pre-operational REMP. The REMP is described in the IIFP ER

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Section 6.1.2. "Radiological Environmental Monitoring Program". Air and water samples will be

collected from remote locations in order to provide background data during operations.

Monitoring

The REMP Sampling Program is described in the IIFP ER Section 6.1.2.1. The following

sections describe the types of monitoring to be performed.

The ENV (lilFP, 2009e) at the IIFPR facility is a major part of the effluent compliance program. kt

provides a supplementar'; check of containment anid effluent controls., establishes a process forcollecting data fer assessing radilogical impacts n t, en-'irons Mid estimating, the potential

impacts On! the .ublic, and SUPP.r.s the demonstr-ation of cmpliance with applicable radiation

protection standards and guidelines. The types and fi-equency of sampling and analyses are

sumaizdin thea IIFP1 PR Chapter 6. 1, Radiological Environmental Mo4nitor-ing Proegram.

Enirofnmental mnedia identified for samipling conisist of amibienit air-, groundwater, soil/sediment,

direct radiation, and vegetation.

Direct Radiation Monitoring4

Direct radiation monitoring of the stored DUF6 cylinders will be accomplished by use of

environmental thermoluminescent dosimeters (TLDs) placed at the facility perimeter fence line or

other location(s) close to the DUJF(; cylinders.

Air Monitoring

Air samples will be collected at locations that are close to the facility that would provide the best

opportunity to detect and identify •acility-related radioactivity in the ambient air. Air rnonitorinlg

stations will be situated along the fence perimeter, next to the Stormwater Retention Basins,

nearest resident, and "control conmarative" location. The control sample location will be

established beyond 5 km (5 mi) in an upwind sector. Air samplers will operate on a continuous

basis.

Vegetation and Soil

Vegetation and soil samples, both from on and off-site locations will be collected in five difnkrent

sectors. Vegetation samples may include vegetables and grass, depending on availability. Soil

samples will be collected in the same vicinity as the vegetation samples.

Groundwater

Groundwater samples from monitoring wells will be collected. Two wells will be located down

gradient to the facility of which one well will be located on the southeast side of the Full DUF1 6

Cylinder Storage Pad. UpL to four up gradient wells may be needed along the east and northeast

side of the IIFP Facility.

Sediment

Sediment samples will be collected from the stormwater runoff retention basis on site to monitor

for any buildup of uranic material being deposited.

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Stormwater

Stormwater samples will be collected fi'om the site Stormwater Retention Basin and the DUF_6

cylinder storage pads.

Samplingi Locations and Frequencies

Table 6-2 of the IIFP ER summarizes the sampling locations. frequencies. and type of analysis to

be performed for each Sample Type described p)reviously. Section 6.1 of the I1FP ER lists the

proposed sampling and monitoring locations for environmental sampling. The exact locations will

be finalized with the completion of final site design.

Monitorin2 Procedures

Monitoring procedures will employ well-known acceptable analytical methods and

instrumentation. The instrument maintenance and calibration program will be appropriate to the

given instrutmentation, in accordance with manuflacturers' recommendations.

IIFP will ensure that the on-site laboratory and any contractor laboratory used to analyze IIFP

samples participates in third-party laboratory intercomnparison programs appropriate to the media

and analytes being measured. IIFP will reouire that all radiological and non-radiological

laboratory vendors are certified by the National Environmental Laboratory Accreditation Program

(NELAP) or an equivalent state laboratory accreditation agency for the analytes being tested.

Action Levels

Action levels will be established to identify concentrations at which an investigation will be

performed. as well as levels at which process operations would be shut down. Action Levels for

vegetation, soil, groundwater, sedimrient. and stornwater samples will initially be set at twice

background. Action levels for direct radiation monitoring samples will initially be set at 10% of

the 10 CFR 20 dose limits to the public. Action levels for air monitoring will initially be set at 1 %

of the 10 CFR 20 Appendix B values. Action levels will be reviewed and adiusted annually as

necessary.

Minimum Detectable Concentration

Minimum Detectable Concentrations (MDCs) will be specified for sample analysis on the basis

of the action levels. The MDCs will at least as low as those selected for effluent monitoring in air.

3.7x1 0' Bqinfl (1. Ox 10 u Ci/mI).

Data Analysis

As specified in approved written procedures, data analysis methods and criteria used in evaluating

and reporting the environmental sampling results will be appropriate and indicate when an action

level is being approached in time to take corrective actions.

Status of Licenses, Permits and Approvals

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The federal, state. and local reCquirenents for environmental monitoring are followed in

accordance with the licenses and permits described in L.A Section 9.2.2. 1, "Federal and State

Standards for Discharges."

Monitoring for "Hi2h" and "Intermediate" Consequence Accidents

The I SA did not identify any accidents that resulted in "High" or "Intermediate" consequences

with respect to environmental impact. However. the environmental monitoring will be adequate

for assessing impacts to the environment fr-om potential radioactive and non-radioactive releases.

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Enclosure 1 JJM-2011-29 April 29, 2011

Official Responses to Environmental Protection RAIs

EP-20. Section 9.2.3, Integrated Safety Analysis (ISA) - Clarify whether the IROFS also address the

consequences of accidental releases on the environment outside the site boundary. Briefly

summarize accidents that could impact the members of the public located outside the facility

boundary and any associated IROFS; provide appropriate specific references to the ISA.

Section 9.4.3.2.3 of the SRP (NUREG-1520) addresses environmental protection in the ISA.

RESPONSE: Accident sequences that could result in radiological or non-radiological releases to

the environment are described in ISA Section 3, "Processes, Hazards, and Accident Sequences.

Demonstration of compliance is provided in Section 4 of the ISA Summary. Section 5 of the ISA

Summary details the Process Hazard Analysis Methodology.

Table 5-10, "Risk Matrix and Risk Index Values" in the ISA Summary depicts the matrix for the

Severity of Consequences and Likelihood of Occurrences. Consequence categories are

determined for environmental exposure by comparison of the 24-hour averaged release of

radioactive materials outside the restricted area to 5000 times the values in Table 2 of Appendix

B to CFR Part 20. If an accidental release results in concentrations exceeding this metric, the

accident is assigned a consequence category of intermediate. If the likelihood category of the

accident is greater than 2 (not unlikely), then IROFS would be assigned to lower the Risk Index

to 4 or less.

There were no accident sequences identified which resulted in concentrations exceeding the

environmental performance metric therefore, no IROFS were designated for accidental releases

on the environment outside the site boundary.

ISA Summary Section 9.2.3 will be revised as shown below.

License Documentation Impact: Section 9.2.3 of the IIFP License Application, Revision A will

be revised to read as follows.

IIFP has prepared an ISA (IIFP, 2009d) in accordance with 10 CFR 70.62, "Safety Program and

Integrated Safety Analysis" (CFR, 2009t), which includes the evaluation of high and intermediate

consequence events involving releases of radioactive material to the enviromnent. The-ISA

P4`00e-,S 1S-- Oe;cH'eH! U• Eta+..+-E-A-4_-J-+Pte* .-. I"Iefgra.ea Nafet5' ,na+Y-s+s,--ar1 One i,.k aeatuS anar

results arc pro.ided ;a the PiH) P- A Summary. Accident sequences that could result in

radiological or non-radiological releases to the environment are described in ISA Section 3,

"Processes, Hazards, and Accident Sequences. Demonstration of compliance provided in Section

4 of the ISA Summary. Section 5 of the ISA Summarv details the Process Ilazard Analysis

Methodology.

Table 5-10. "Risk Matrix and Risk Index Values" in the ISA Summary depicts the matrix for the

Severity of Consequences and Likelihood of Occurrences. IROFS are established for any accident

for which the Risk Index is greater than 4. Consequence categories are determined for

environmental exposure by comparison of the 24-hour averaged release of radioactive materials

outside the restricted area to 5000 times the values in Table 2 of Appendix B to CFR Part 20. If

an accidental release results in concentrations exceeding this metric, the accident is assigned a

consequence category of intermediate. If the likelihood category of the accident is greater than 2

(not unlikelv). then IROFS Would be assigned to lower the Risk Index to 4 or less.

Environmental Protection RAIs Page 39
Enclosure 1 JJM-2011-29 April 29, 2011

Official Responses to Environmental Protection RAIs

There were no accident sequences identified which resulted in concentrations exceeding the

environmental perfornmance metric therelore, no IROFS were designated for accidental releases

on the environment outside the site boundary.

Environmental Protection RAIs Page 40