International Isotopes Inc.

April 25, 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 following document is provided as a response to the US Nuclear Regulatory Commission

RAIs pertaining 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 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-2011-27

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 5--)
Environmental Protection

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 IUP 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 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 Sssupplemental information

.an also be found in various se.tions of the LA as well as thle 414 ER are provided in each

section, as appropriate.

Response to Environmental Protection RAIs

Page 1
Environmental Protection

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

to the ER. Since the ER is not part 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 IUFP 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

ER Chapter TIitle of Chapter Protect-Health and Minimizeh iStatement Addressed inj

~ Dang~er to Life and Property ~ LA or ISA

Introduction of the 13 addressed

Chapter 1 Environmental Report 20 4 not addressed

3 partially addressed

Chapter 2 Alternatives 4 4 addressed

Description of the 22 21 addressed Chapter3 affected Environment 2 partially addressed

20 addressed

Chapter 4 Environmental Impacts 21 1n addressed

I not addressed

11 addressed

Chapter 5 Mitigation Measures 12 1p 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

IIFP Environmental 93 addressed Report 6 not addressed

Response to Environmental Protection RAls

Page 2
Statements Made in the ER to Corresponding

ER Chapter Title of Chapter Protect Health and Minimize Statement Addressed in

Danger to Life and Property LA or ISA

5 partially addressed

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 IIFP 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 7th paragraph of Section 1.1.2 of the IIFP License

Application, Revision A, will be replaced with the following:

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 Table 7-1. The primary applicable codes and standards (editions

applicable at time of design) for the design and building requirements of the liFP Facility include

the following:

" Uniform Plumbing Code (UPC) as amended by the New Mexico Plumbing Code

(NMPC. .... nternatio na...E..er Conservation_ Code I E a.. ...e. i..................

ergy

Conservation Code (NMECC).

" Uniform Mechanical Code (UMC) as amended by the New Mexico Mechanical Code

(NMMC).

• International Buildingz Code (IBC) as amended by the New Mexico Commercial Building

Code (NMCBC).

* National Electrical Code (NEC) as amended by the New Mexico Electrical Code

(NMEC.

" International Fire Code (IFC).

" ASME/ANSI B16 Standard for Pipe and Fittings.

* ASME/ANSI B31 Pressure Piping (includes, power piping. process piping, gas piping.

* ASME Section VIII, Div I Design and Fabrication of Pressure Vessels. Latest Edition.

* API 620 Design and Fabrication of Atmospheric Storage Tanks.

* AISC Standards for Steel Construction.

* ASTM Standards for Steel Building Construction.

Response to Environmental Protection RAls

Page 3
0 ACI for Concrete Construction.

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 plant. A summary of licenses and permits that are currently known to be required

are listed in the 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- 11B for revisions in the LA, former Section 1.6.3.6 (new

1.7.3.4 "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 1(IIFP, 2009a.) summarizes the applicable environmental

Response to Environmental Protection RAIs

Page 4
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:

" NPDES General Permit for Industrial Stormwater,

" General Construction Permit,

" Air Construction (Air Quality: New Source Review/Authority to Construct) Permit,

* Air Operations Permit ifrequiredg

* NESHAP Permit if recuired.,

" Groundwater Discharget Permi.t/Liiquid Wa(ste wage)_Permit.

" EPA Hazardous Waste IDN.mb.er,

" Drinkingy Water System Permit

* Radiation P~rotection lPermit. ?.. .;j........... ld D l i~ ....t .e . . ..l.. ......... !? ;

Above .................. Ground Stor Tank I Regto. istration_.

*NPIDES Storm Water Pollution Prevention Plan(SPj/NtceolnetNO) ........ . t .t .A....C. .e.........................

.... - ........ .... -........ ........ *StateAccess,(Highwaqy Rigyht of Way) Permit. . C lean__Wate. Act, Section 404. and

_Rare, Threatened, and EndangeredSpecies Survev.y .P.ermnit.

IIFP 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 I1FP LA. Miscellaneous regulations include the following:

" 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 50. Sections 1-25. and implementing regulations at NMAC Title 11, "Labor Workers Comipensation.' Chapter 5. "Occu ational 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

requiremnents beyond the federal 0OSHA reg-ulations are adequaptely addressed.

* Groundwater monitoring wells are permitted through Office ofthe 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 changjes in groundwater

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

and hydrological 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 plant 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.

Response to Environmental Protection RAIs

Page 5
License Documentation Impact: The ITFP License Application, Revision A, Section 9.2.2

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

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 DUF6 are visually inspected for damage and surveyed for radiation

and removable contamination. Cylinders and cylinder valves shall be inspected for ANSI N14.1

requiremnents. 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 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 DUF4 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.

Response to Environmental Protection RAIs

Page 6
License Documentation Impact: In the IIEFP 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 facility in Hobbs, New Mexico receives DUF6 material in a solid physical state typically

contained in 14-ton type 48-Y or 48-G cylinders owned by the 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. The 48-Y cylinder is approved for multi-shipments, provided the ANSI standards;

which include a 5 year hydrostatic test requirement are met. Empty 48-Y cylinders are returned to

the customer following de-conversion. Radioactive material shipmnents will be transported in

pckages that meet the reqiirements of 10 CFR 71 and 49 CFR 171-173. Transportation routes

for both incoming DUF6 feed and outgoing uranium wastes will be those routes designated bv the

U.S. Department of Transportation to minimize the potential impacts to the public from the

transportation of radioactive materials. If any DUE4 is received, it will be contained in approved

shipping containers in accordance with DOT regulations.

Response to Environmental Protection RAIs

Page 7
Environmental Protection

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 of monitoring samples, and evaluation of samnpling data

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

during normal operating conditions and thereby denmonstrating attainment of A.1..,ARA goals and

effluent limit compliance. Identification of•the quaLntity of rmaterial released from the facility

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

determined quantity of radioactive material released friom 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% of the will be initially set at 20% of the 10

CFR 20 Appendix B values. 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 Chapt e-Section 4.2.2, Radiation Protection "ALARA Goals."

Response to Environmental Protection RAIs

Page 8
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.

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. 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.

Response to Environmental Protection RAIs

Page 9
Environmental Protection

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.

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 plant scrubber system (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 of' tile LiFP

ER (IllFP. 2009) addr-esse, the pfoeess de.eription and the effluent . ontro.l. in.orpo..ated into the

design of the f4aility, and Chapter 6 (IM.P, 2009) of the 111212 ER dlscrlibe,- thle staelk sampling and

measatrements-.

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. JIFP FEP/DUP ER

Table 2-1 provides a list of design efficiencies for process vent off-gas treatment eq tipnentnti_

IIFP FEP/DUP ER. 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. HIFP ER Figure 6-1 illustrates the planned monitoring locations at the site. IIFP ER.

subsections 6.1.1, 6.1.2. and 6.1.3 provide additional details about effluent and radiological

.mon o i. ..... g . E.ffluent c otr.ol .. - a ..... conservatio . . .. ..... n featuresI ......... . -. ..are.e.c. ibed.......l......E-P/D ER

subsection 4.13.4. Section 3.1.10 of the IIFP Integrated Safety Analysis Summary (ISA.) (IFFP.

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-gas treatment equipment as does 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.

Response to Environmental Protection RAIs

Page 10
Environmental Protection

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,_R-ai n Proteetion 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 ALARA Committee include the COO/Plant Manager, the Radiation

Protection Manager, selected Department Managers, and the ESH Manager

Response to Environmental Protection PAls

Page 11
Environmental Protection

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 priority' has been assignied to fninimnizing the gener~ati on efw'as~te fliretigh reduetieon,

reuse, of- i'ecc lin"g. The IE:11 failit;' utilizes various engineer'edwaste minimization system's, aid

eper-ationial pr-oeedures that aim at con1Serving1, mfaterials MEd recycling impor~tant compounids; suc

as the r-egener-ation anid reuse of the plant scruabbing, system potassium 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 plant incorporates several waste minimization systems in its operational procedures and

design that aimn at a highl priority of conservinc- miaterials and lreventin the spread of

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

Reevcl ing on-site is ani important strategy of the wvaste minimization program. for example: 1')

r~eIL r tp and] recycling, of pjotassiumr hydroxide (KOH) scrubbing Solution for use in -the plant

scruLbbing system. This design and operation eliminates the need to otherwise discharge the flow

as treated wastewater and also conserves the use of the treating ageint and saves cost; 2) collection

and recycling of steam condensate back to the* fa~cility' steam boilers, where aPplicable, for saving

energy and miinimnizing disposal, and 3) conserving4 valuable water resources by using air coolers

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

Another important aspect of the I IEP waste minimization proggram is the employment of waste

segzregation 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 contanmination. training is provided wvith emphasis on minimizing waste and

controlling disposal costs. The Outer packaging associated with consumiables is removed prior to

use in a conamiat- area to minimize poet~lfrcnaiain and tofacilitate recycling and

dlisposalI of the c lean segregated materials.

Response to Environmental Protection RAts

Page 12
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 processincg

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

office paper waste, aluminum cans and scrap metal, 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 Recover,' Act (RCRA)_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.

Plant 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 .lF7P minimizes the number

of changes in direction to the extent practicable.

Mechanical integritv 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 lea.k op• iping and equipment are prevented or minimized. Design and op.ertional

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

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

in minimizing contamination. IIFP uses fluoride detector instrumentation, particu late 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

hazardous materials are st spected., posted areas and warning lights are utilized to protect

employee health and communicate potential contamination problems. Suspected or known

leakage problemns are investigated, the equipment operation curtailed if needed and the leakage resolved incluId~ing.ak c.l..eann.u where arlicable.

The TIFP facility is designed to minimize the usage of natural resources. Closed-loop cooling

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

bv 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 scrubbing system and Environmental Protection Process are designed to recycle K1OH thus

•qserving. tlhe treaCti l- nt•.Seqnda.ry.v ontai1nment for tanks anrd tank system.s 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 ofsamole flumid leaki i t e,..,eground. Areas involving diesel refuelingare also provided with

secondary containment.

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

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

Response to Environmental Protection RAIs

Page 13
inspection. Suitable waste is volumpe 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 unit where it receives primary. secondary

and tertiary treatment. The effluent from sanitary treatment is used in the facility for process

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

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

equipment 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;

* Ion-exchange units suitable to collect soluble uranium from solution:

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

and

* Tanks to provide hold capability Land precipitation ca pacitv for soluble uranium.

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

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

Items from 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 from 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 Buildin(gare

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

materials are contained in tanks and other appropriate containers and are strictly controlled by

procedures.

Practices Consistent with Regulatory Guide 4.21 include:

A. Minimizint Facility Contamination

. Worker access to contaminated areas is controlled to assure that workers wear.mM2per

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 s ill collection areas are provided: _o !.e....n~ ~ ~ s. ~ ........ ~ ~ .... -_.. I[e.t...n..e...s.......... d.e..

* Floor liners and catch basins are inclu•ded in areas of high.r eleak potential:

" Personnel surveillance techniques are part of the leak identificatiogn r ;

* 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.

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

potential out-leakage during maintenance and inspection:

* Decontamination Building and equipment are provided to clean equipment. where

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

* Floors are appropriately sloped for spills; * Drains from locker rooms and cleanup showers innpotential 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_ vells are provided and sampled both up_gradient and down g !radient with

established baselines:

" Storm water retention basins have two impermeable barriers;

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

dies

* Areas to support radioactive material handling are in contained areas;

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

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

discharge, and

* Plant ventilation system desigms 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 minimize

the number of changes in direction to the extent practicable.

B. Minimizing 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 DFLU 4 Process Building.

FEP Oxide Staging Building, the facility operations Decontamination Building. DUEF4

Container Storage Building, DU F 1 Container Staging Building and the FEP Process

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

features.

. All areas of -plant th- " e " ,.sectioned .are in " to Unri-estricted "-and Restricted Areas. Restricted

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

"xosure 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 tinder the Radiation Protection Program, and serve to minimize the spread of

contamination and simplify the eventual decommissioning.

* Routine radiological surveys will be conducted throughout the facilities' operations life

that will minimnize the likelihood that radioactive contamination goes Undetected and will

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

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

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

activities occurringinside these areas.

* Local air Filtration is provided for areas with potential airborne contamination to prcid~.~e

its spread. Containment equipment with hoods that exhaust through dust collectors, that

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

packaged or withdrawn from process systems.

* 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 plant 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 tertiaiy treated to

meet all discharge standards. and is either evaporated or used as harvested water for

fa Jli trees, grass and shrubs. 'he faci lity is designedl•ornou HQid itprocess water

discharges. Engineered systems are used to provide for regeneration of scrubbing

solutions and recycle within the process systems.

C. Facilitating Decommissionin2

0

0

0

0

0

S

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 volumes during decontamination and

simplif\' 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 systerms, provided for required operation and maintenance,

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

significant portion of radioactive contamination prior to disassembly and prevent leakage to theggepral environment upon openinLg of ip ig;

Design drawings, produced for all areas of the plant. 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

pr roective equipmlent and limit their time inl the areas:

Radioactive and hazardous wastes produced during decommissioningz 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

Response to Environmental Protection RAIs

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

licensed ..i.•.• ....... r radioactive ..... .._ .i ... ..... •........................... or _ hazardouIs Waste disposal d......s- ..± ..*facilities ..) ..-. ........ .i.!i .. •.J.....................- located -....................... elsewhere. ..y. Noni- - ..........

hazardous 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 I [IFP document control and management process.

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Environmental Protection

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 IlFP 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 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.

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 .13. and the following subsections and Section 4.6 and the followin,

subsections. These controls are also described in the llF'P FEP/DUJP ER IFP. 2009a)_-.,

subsections 2.1.3. 4.6.2.2, 4.6.2.3, 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

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 significantly 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.

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Response to Environmental Protection RAIs

Page 19
Environmental Protection

EP-8. Section 9.2.2.1, 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 4-24 of the JIFP FEP/DUP 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 11FP FEP/DUP ER (I|FP, 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 pr..ved iii the 11F2 ER, Chapter . are shown in Table 4-24 of the I[FP FEP/DUP ER

(IIFP. 2009a). Calculations and modeling of airborne radioactive materials, with the conservative

assumptions used in the calculations and inodelinig, 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 site.

Response to Environmental Protection RAls

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Environmental Protection

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), lIFP 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 plhme: direct radiation clue to

deposited radioactivity on the ground surface (ground 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 C-P-A8-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 close calculations (documented in ER Section 4.12.2.2) will be used as

necessary. Table 4-25 of the ER provides the annual and committed dose equivalents for

exposures to the maximally exposed individual (MEl) from gaseous effluents. Table 4-26 from

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

from gaseous effluents. The estimated dose rate for sit boundary locations, the MEl. and the

nearest resident is provided in Table 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

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

Reporting Requirements" +02R ,lF2009.

Environmental Protection

EP-IO. 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.

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 d ischarge are

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

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

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

monitored as described in Section 6. 1 .1.1 of the ER.

There are two 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 firom the SE 4 and BF, process systems. The process off-gas firom the DUF4,jjf and BF 3

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

treated gas firom the last stage of the scrubbers exists the Plant KOH Scrubbing System Stack

(number 01

The llFP E, Cha, .. pr f(,I-FP-, 2009)-ade., th .....estimat . e locat-i•- aw-eoefe1ftueH

discharges an. d mon.iter ing estimated loca ions fi-r site. Liquid plant effluents are maintained

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

described in ER Section 6. I1.1.2.

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Environmental Protection

EP- 11. 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 ITFP ER Chapter 6 addresses the Effluent Monitoring Program (EMP) (IIFP, 2009c). The

purpose of the Effluent Monitoring Program (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 facility effluent remains ALARA. The REMP is discussed in

Section 6.1.1 of the IIFP FEP/DUP ER.

The effluent stacks, whereelicensed 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 asigi,+i- -t25% increase in gross radioactivity, or

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

concentrations.

Response to Environmental Protection RALs

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Environmental Protection

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 and frequencies.

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

lFP 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: The subject paragraph from LA Revision A Section 9.2.2.1

will be revised as follows:

The EMP establishes appr-epriate 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 performed in accordance with Regulatory Guide 4.15

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

Streams and the Environment" anid Regulatory Guide 4.16, "Monitoring and Reporting

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

Fuel Processing and Fabricattion Plants and Uranium -lexafluoride 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. IIFP 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

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

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

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

locations of the environmnental sampling stations and monitoring locations. Further. Section 6.1.1

Response to Environmental Protection RAIs

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Environmental Protection

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)(/) of the SRP, NUREG-1520, addresses Radionuclide-Specific Analysis for

effluent monitoring.

RESPONSE: Plant preventive maintenance procedures will be specified to be maintained onsite

and implemented. Section 9.2.2.1, Sample Collection and 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: Section 9.2.2.1, 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., DUF6, uranium oxide, DUF4, and DUO2F 2), 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 Program falls under the oversight of the IIFP Radiation Safety Program. Section 6.1.1

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

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

monitored pathwayýs. The effluent sangprogram for the IIFP facility is designed to determine

the quantities and concentrations of radcionuclides discharged to the environment. Uranium

isotopes and daughter products are expected to be the prominent radionuclides in the gaseous effluent. Process stacks and air venlts are (1) sampled con1tinuLtously throug the use of air filters

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

composite analysis.

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

implemented. These preventive maintenance procedures, and the associated configuration

management for these 1tproce !ýdutres, are described in LA subsection 11.2.2.

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Page 25
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."

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 signi-eant 50% increase in gross radioactivity in

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

radionuclide composition.

Response to Environmental Protection RAIs

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Environmental Protection

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 will be revised as follows:

ER Chapter- 6 (!Wl'lFP 2009) ffe~efitS the requaired miinimum d~

giros- alpha analyses; perfor-med en gaseous effluient saiples.

ýteetame coneneftration (M4DC)fr

ER Chapter 6.1.1.1 describes the gaseous effluent monitoring requirements For the facility. A

minimumdetectable concentration (MDC) of at least 3.7x 1 0- Bq/il( .0x I0 15 -jL!.l) will be

required for all gross alpha analyses performed on gaseous effluent samples.

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Environmental Protection

EP-15. Section 9.2.2.1, 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.

Response to Environmental Protection RAIs

Page 28
Environmental Protection

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)6) 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. IlFP defines an air-contaminant source as ani'

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. 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

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

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Page 29
Environmental Protection

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 any figures, 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 I1FP 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.

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

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

The subsection will read as follows:

Waste Management 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 l]FP 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 IlFP Facility depending on the locations and

characteristics of the waste stream. The main buildinegs involved are the FEP Process Building,

FEP Oxide Staging Building. Decontamination Building,. Environmnental Protection Process

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

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

speci fhc descriptions.

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

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

s t bu il.-d.ings .an . .location .. ...i sp. as .. .r-awin . .i.-c g C Revis...1 ion..ad 1 .... is p-.artot - :he

engineering drawing package provided to the NRC as separate document files of the I1FP ILicense

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

of the 1icense Application

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Table 1-3, Chapter 1, General Information of the License Application shows the estimated annual uq.an.[t59pf wa_•setgener at the II.P Facil The glamor t Of .it.Int 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 Staging Building.

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

located in the FEP Process Building. The 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 tempptrarilv in the FEP Oxide Sta 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

Staginguildin r and the FEP Process Building is a fire barrier. This buildingis 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 Decontamination Building serves as a facility with equipment to managze Low-Level

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

Building is located adj1acent toand on the north side of the DUF4 Building. The construction

provides for a fire barrier between the Decontamination Building and the DUEF4 Building. This

building is used for decontamination of equipment 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 LLW and mixed dry solid waste.

loading station, weighing scales, drying equipment, primary and secondary dust 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 sorted, if needed, prepared,

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

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

faci liitv.

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 fromn liquid streams is

collected, dried for volume reduction and to meet acceptance criteria and sent to an off-site

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

the de-conversion processes.

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The EPP Building and adjacent area is used to treat and manage fluoride-bearing waste liquors. The design of the IIFtI Facility includes equipment to regenerate spent potassium hydroxide

(KOFI-) solutions that can be reused and recycled in the plant scrubber 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 luoride-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 subject liquors to a solid is the means by which fluoride wastes are managed with

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

packaging procedures for the CaFb are conducted in the Environmental Protection Process (EPP)

Building. In this area, the CaF3 is filtered from 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 IIFP License Application Section 1.1.2.1 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 building4

Part of the Material Warehouse is used for managing non-radioactive waste. Designated areas

inside the Material Warehouse and some collection containers onl thle adiacenLt 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 t•~~.. IWWarehouse 2L~g[~ a:e_! k_ _e ar-ea. a e. ..... Waste e ..sent ._M ......... to ._; ........... this ....-- _!e -.. area ....J! must .. ... u. si.......t... be _ .• ap .b pypved •. ._ .. .e. ...... • ...... ~ for release •e. to licensed .t% .{ ~. _nse

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

ta n .aybte icend to ott-site facilities a for or minimization, and then sent, if requiredt

to anl off-site licensed waste disposal facility.

One area in the waarehouse is desiqnated for these type wastes. Another area in the warehouse is

set aside to manage small quantities of Resource Conservation and Recovery Act (RCR.A) waste

that is not otherwise handled at the EPP. The RCRA waste is packaged. labeled, manifiest and

loaded for shipm-ent. A permitted transport contractor is used to transport the waste to a permnitft~ed_

RCRA facility for disposal.

De...ptions of.the proposed ill,' waste management systems arc provided in the !IFP Chapter 3.

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Page 32
Environmental Protection

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 subsections will be deleted from Section

9.2.2.1, Effluent Monitoring and moved to a new section 9.2.2.2 Environmental Monitoring. This

is described in response to RAI EP-19.

BH-V+F-4 1 ~-HfHL~IlL.H 1V1UIIiLUU1I1~

'The followAing SectionHS addr-ess the aeceptanee criteria related to enivir-onmenial monitoring.

Raekore-nd anid Baseline Mea.-uriements Priore to faicilit oper-ations, soil and groundwatersampes will be collected from the site and analyzed to deter-mine a baseline to be used it

evaluat,+in~g changes "in oet envioirnmenital conditions caused by facility Operations. Air: mnd

wat. samples .ill.be colle.ted fo.m remote lo.ations in or.de to provide ba•c•iground data di,.in

Mo nitoringP(P. at the 1[2P eility is a .2009e) mjor part of the effluent compliance

progr-am. it provides a supplementary check of C-oontainmn n fletcntos salse

proees~s for- collecting data for-assessin? radiological impacts on the enirons and estimatinig thie

potential impacts on- the p..bie, a..nd .upp.rtshe demonstration . f comiliance with- applicable

radiation ... te.tio, n standards and guidelines.T typ,•s.. w an.• " ney . .sa..p. ing and analyses

are s......m.arized in the llIFPn UER 1.., "hapter.". I., Radioloic•al n m t onti in........... .ng Prgram.

En..vir.onmenta..a. media identified fo' sampling consist of ambien- tair, gr.oundwater, soil/sediment

dir-ect Fadiation. and vegetationi.

g

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Environmental Protection

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-1520),

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, (f) 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 deleted from the previous section, 9.2.2.1, Effluent Monitoring and expanded to

address all 9 SRP topics identified in Section 9.4.3.2.2(2) of the SRP (NIUREG-1520).

License Documentation Impact: The following section 9.2.2.2, Environmental Monitoring, will

be added as described below.

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 Facility establishes a

process for collecting 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 plant

operations in order to develop a sufficient database. Prior to facility operations,_soil-an4

gr-oundwa-ter" 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. Veg•tqtion arid soil sam les-both from on and off-site locations willbe c.llected on a quarterly

Response to Environmental Protection RAIs

Page 34
basis in each sector during the pre-operational REMP. The REMP is described in the IIFP ER

Section 6.1.2 "Radiological Environmental Monitoring". Air and water samples will be collected

from remote locations in order to provide background data during operations.

Monitorin2

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 EM4P (I IFP, 2009e) at the llF-P faceility is a majior- pait of the effluent compliacprgm.t

'ro\ides a sup3plementary he k of .. containment and efflu.ent c.ntrol. , establishes a p-ocess feo

collecting data for. as.esing radiologi.al impaet. on the envi.. ons and . eStima.. ting. the potential impacts on the public, and suppotis the demonsti-atieii of complianceewithi applicable radiation

protection standards and guidelines. The types and fi.e.uen.y ofsampiing and analy..ses a. e

summari;Zed in the 11.12-1 ER Chapter 6.1, Radiological Environmental Monitoring Proegram

Enviironmenital media identified fori sampling eonsist of ambient air, gr-oundwater, soil/sediment,1

direct ra~diation, and kvegetation.

Direct Radiation Monitorin2

Direct radiation monitoring of the stored DUFK, cylinders will be accomplished by use of

environmental thermoluminescent dosimeters (TLDs) placed at the plant perimeter fence line or

other location(s) close to the DUFLcvlinders.

Air Monitoring

Air samples will be collected at locations that are close to the plant that would provide the best

op po.rt . mtv t d.eýtjct identijlt .lant -rel ated radioa ctivity in the ambient air. Air monitoring

stations will be situated along the fence perimeter, next to the Stormwater Retention Basins.

nearest resident, and "control coinparative" location. The control sample location will be established beyond 5 k_ (5 mi) in an u wind sector. Air samp.lers will operate on a continuious

basis.

Vegetation and Soil

Vegetation and soil samples, both from on and off-site locations will be collected in five different

sectors. Vegetation samples may include vegetables and grass, depending on availability. Soil

s.aples will be collected in the same vicinity as the vegetation samples.

Groundwater

Groundwater samples from monitoringv wells will be collected. A background well will be located

on the up-gradient side of the plant. Two wells will be located down gradient to the plant. One

well will be located on the southeast side oftthe Full DUF 6 Cylinder Storage Pad.

Sediment

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Sediment samples will be collected from the stormwater runoff retention basis on site to monitor

for any buildup of uranic material being de osited.

Stormiwater

Storinwater samples will be collected firom the site Stormwater Retention Basin and the DUF6 cylinder storage pads.

Sampling Locations and Frequencies

Table 6-2 of the IIFP ER. summarizes the sampling locations, friequencies, and type of analysis to

bperlormed for each Sample Type described previously. Section 6.1 of the llFP ER lists the

proposed sampling and monitoring locations for environmental sampling. The exact locations will

be finalized with the completion of final site design.

Monitoring Procedures

Monitoring procedures will employ well-known acceptable analytical methods and

instrumentation. The instrument maintenance and calibration program will be appropriate to the

given instrumentation, in accordance with manufacturers' recommendations.

IIFP will ensure that the on-site laboratory and any contractor laboratory used to analyze WITUP

samples participates in third-party laboratory intercomparison programs appropriate to the media

and analvtes being measured. IIFP will require that all radiological and non-radiological

laboratory vendors are certified b•_the National Environmental Laboratorv Accreditation ProgEiam

(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 veeaio, udatrsdimnent. and stoirmwatýj.ýer samjples will initialyb 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 C -R 20 Appendix 1B valUes. Action levels will be reviewed and adjusted annuallv as

necessary.

Minimum Detectable Concentration

Minimum Detectable Concentrations (M[DCs) 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,

3.7xl (,l Bq/mnl (1 .Ox I 0f [i Ci/mnl).

Data Analysis

As specified in approved written procedures, data analysis methods and criteria used in evaluating

and reporting the environmental sampling resuIlts will be appropriate and indicate when an action

level is being approached in time to take corrective actions.

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Status of Licenses, Permits and Approvals

The federal, state, and local requirements for enviromental monitoring are followed in

accordance with the licenses and permits described in LA Section 9.2.2.11, "Federal and State

Standards for Discharges."

Monitorin2 for "High" and "Intermediate" Consequence Accidents

The ISA 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 from potential radioactive and non-radioactive releases.

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Environmental Protection

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 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, 2009f), which includes the evaluation of high and intermediate

consequence events involving releases of radioactive material to the environment._ Tihe-ISA

proeess is deser-ibed in detail in LA C.apter 3, integrated and the ISA detail and

.e.ult, a..e pr..,ided as; the !I•. ISA Summary. Accident sequences that could result in

radiological or non-radiological releases to the environment are described in ISA Section

"Processes, Hazards. and Accident Sequences. Demonstration of compliance provided in Section

4 .of .the.S........ ..A S. ummar....... ..y.. S-e. c tion..... 5 ..... . A ...... .S ..the .um .m.ar.... .de. ..c .s s t.e . s Hazard Analysis..........

Methodology.

Table 5-10. "Risk Matrix and Risk Index Values in the ISA Sumnmary 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 Part 20. If an

accidental release results in concentrations exceeding this metric, the accident is assigned a

Response to Environmental Protection RAIs

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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 IROeS were designated for accidentalbreleases

on thle environment outside the site boundary.

Response to Environmental Protection RAIs

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