L-98-004, Forwards Proposed Format & Content for License Application Including Regulatory Guidance Used,For NRC Review
| ML20247F595 | |
| Person / Time | |
|---|---|
| Site: | 07003089 |
| Issue date: | 05/04/1998 |
| From: | Rifakes G UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Paperiello C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| L-98-004, L-98-4, NUDOCS 9805190442 | |
| Download: ML20247F595 (4) | |
Text
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USEC A Gobal Energy Company Docket No. 070-03089 May 4,1998 L-98-004 1
Dr. Carl J. Paperiello Deputy Director Nuclear Material Safety & Safeguards U.S. Nuclear Regulatory Commission
-Washington, DC 20555
Subject:
Atomic Vapor Laser Isotope Separation (AVLIS) Licensing Process License l
Application Format and Content
Dear Dr. Paperiello:
AVLIS deployment is closely tied to the schedule for USEC privatization.' Significant strides toward completion of privatization have been made. We are actively engaged in a process which we expect to result in a privatized USEC as soon as July 1998. This will lead to an AVLIS !icense application submittal in February,1999.
To support this schedule we have begun to prepare the license application. The application is being prepared to satisfy NRC licensing requirements and guidance. Attached is our proposed format and content for the license application including the regulatory guidance we are using. We believe that this proposed application format and content facilitates efficient NRC staff review of the license application and provides a solid basis for subsequent licensing decisions. In addition, the proposed approach to clearly define inspectable and verifiable license conditions should result in a license with license conditions that are readily manageable for both UL nd the NRC.
l l
.o 9905190442 990504 1
PDR ADOCK 07003099
\\
C PDR-6903 Rockledge Drive, Bethesda, MD 20817-1818 Telephone 301-564-3200 Fax 301564-3201 http://www.usec.com Offices in Livermore, CA Paducah, KY Portsmouth, OH Washington, DC
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t Dr. Carl J. Paperiello May 4,1998 -
L-98-004 Page 2.
- To support our schedule for submittal of a license application, we request your.
concurrence with our format and content and proposed implementation of the guidance
' documents, as described in Attachment 1, by July 31,1998. We look forward to working with -
you to achieve an efficient, predictable, and timely AVLIS licensing process. Should you require further information regarding these matters, please contact me or Rob Woolic at (301) 564-y 3413,.
Sincerely,
[
w George P. Rifakes Executive Vice President cc:
Drew Persinko f.
- Attachment.
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ATTACilNIENT I PROPOSED AVLIS LICENSE APPLICATION FORNIAT AND CONTENT NRC guidance for the format and content of an AVLIS license application includes:
- 1) Regulatory Guide 3.25, Standard Format and Content of Safety Analyses Reports for Uranium Enrichment Facilities, December 1,1974,
- 2) Regulatory Guide 3.52 Revision 1. Standard Fonnat and Content for the Health and Safety Sections of License Renewal Applications for Uranium Processing and Fuel Fabrication Plants, November 1,1986,
- 3) Draft Regulatory Guide 3.52 Revision 2, Standard Format and Content for the Health and Safety Sections of License Applications for Fuel Cycle Facilities, January 1995.
Each of these specify substantially different formats and contents.
Based on discussions with your staff, USEC is not planning to follow the guidance in Regulatory Guide 3.25. USEC proposes to submit a two part license application as debed in Regulatory Guide 3.52 Revision 1 structured as follows:
Part I - License Conditions - license conditions stating the performance requirements to which the licensee proposes to commit. Part I is written to permit inspection and verification of the stated performance requirements. These license conditions may not be changed without prior NRC approval.
Part II - Safety Demonstration - follows the format and content of Draft Regulatory Guide 3.52 Revision 2 dated January 1995. Although not final, USEC understands from its previous interactions with the NRC that Draft Regulatory Guide 3.52 Revision 2 represents the most recent publicly available guidance, compliance with which is most likely to produce an application that is acceptable and readily reviewable by NRC.
We plan to deviate from the Draft Regulatory Guide 3.52 Revision 2 format in that the following sections will be submitted as separate reports:
a) a Quality Assurance Program Description will be substituted for Section 3.3," Quality Assurance Program". The Quality Assurance Program Description was submitted to NRC as a separate report for approval in March 1997. USEC will maintain this as a separate report and refer to the report in Section 3.3 of Part IL b) an Emergency Plan based on the guidance provided in Regulatory Guide 3.67,-
" Standard Format and Content of Emergency Plans for Fuel Cycle and Materials Facilities", M92, will be substituted for Section 9," Emergency Management", and need only be supplied if required by 10 CFR Part 70. The emergency plan must be provided to offsite response organizations for comment 60 days before submittal (10 CFR 70.22(i). The emergency plan is being structured as a separate report to facilitate the offsite response organizations review and comment.
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l ATTACllMENT I (CONTINUED) l l
l c) an Environmental Report satisfying the applicable requirements of 10 CFR Part 51 will I
be substituted for Section 10. " Environmental Protection" The Environmental Report l
will be based on draft Regulatory Guide 3.52 Revision 2 (format and content) and Regulatory Guide 4.9, Revision 1,1975 (content only). The Environmental Report is being prepared as a separate report to facilitate NRC review and to distinguish it from the change control provisions that apply to Part II. These controls will need not apply to the Environmental Report.
d) a Decommissioning Plan satisfying 10 CFR 70.25 per the guidance in Regulatory Guide 3.66," Standard Format and Content of Financial Assurance Mechanisms Required for Decommissioning Under 10 CFR Parts 30,40,70, and 71", dated June 1,1990, will be substituted for Section 11 " Decommissioning". The Decommissioning Plan is being prepared as a separate report to facilitate review.
The plant as described in Part 11 may be changed without prior NRC approval if such proposed changes are shown 'oy evaluation to not reduce the effectiveness of the relevant programs, plans, or plant features. The evaluation process shall include performance of an integrated safety analysis, as appropriate. Changes shall require authorization by responsible management prior to implementation. A description of all changes shall be provided to the NRC at least biennially.
It is understood that Part II of the license application will be reviewed by the NRC in accordance with draft NUREG-1520, " Standard Review Plan for the Review of a License Application for a Fuel Cycle Facility" (April,1995).
Also included with the license application are the following plans that may be submitted early on the docket for staff review:
Fundamental Nuclear Material Control Plan - satisfies the applicable requirements in 10 CFR Parts 70 and 74. In addition, the FNMCP will be based on the guidance provided in NUREG/CR-5734,1991.
Physical Security Plan - satisfies the applicable requirements in 10 CFR Parts 70 and 73. In addition, the PSP will be based on the guidance in Regulatory Guide 5.59, Revision 1,1993.
Security Plan for Protection of Classified Matter - satisfies the applicable requirements in 10 CFR 70,95,25, and the National Industrial Security Program Operating Manual. In addition, the SPPCM will be based on the guidance in
" Security Plan Standard Format and Content for the Protection of Classified Matter for NRC Licensee, Certificate Holder, and Related Organizations," 1997.
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