ML18011A175
| ML18011A175 | |
| Person / Time | |
|---|---|
| Site: | Erwin |
| Issue date: | 01/03/2018 |
| From: | Freudenberger R Nuclear Fuel Services |
| To: | Office of Nuclear Material Safety and Safeguards |
| References | |
| 21G-18-0001, ACF-18-0001, GOV-01-55-04 | |
| Download: ML18011A175 (9) | |
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TM NUCLEAR FUEL SERVICES, INC.
a BWX Technologles, Inc. company 1205 banner hill road erwin, tn 37650 phone 423.743.9141 www.nuclearfuelservices.com Director, Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555
Reference:
Docket No.70-143; SNM-124 21 G-18-0001 GOV-01-55-04 ACF-18-0001 January 3, 2018
Subject:
Submittal of Internally Authorized Changes (IACs) for Calendar Year 2017 In accordance with 10 CFR 70.72(d)(2), Nuclear Fuel Services, Inc. (NFS), hereby submits a summary of the two (2) Internally Authorized Changes (IACs) that were completed at NFS during Calendar Year 2017.
The Summary of IA Cs Completed During Calendar Year 2017 (Attachment 1) includes for each IAC: IAC number, IAC Title and Reason for IAC, and the Date the IAC was Released for Operation. The "Reason for IAC" includes a brief description of why the change was made.
In accordance with Section 11.1.1, paragraph 1, of SNM-124, each IAC was reviewed by NFS safety disciplines, and the questions from 10 CFR 70.72(c)(1 - 4) were answered using the documentation format shown in Attachment 2. If the answer was "Yes" to any of the questions, then NRC approval was required. Each IAC was also approved by the Safety and Safeguards Review Council (SSRC). All IACs included in Attachment 1 did not require pre-approval under 10 CFR 70.72 because responses to each question from 10 CFR 70.72(c)(1 - 4) were "No."
The Integrated Safety Analysis (ISA) Summaries that reflect changes to existing NFS operations were revised and are being submitted under separate cover letter in accordance with 10 CFR 70.72(d)(3). To assist in your review of the revised ISA Summaries, Attachment 1 groups the IACs by the ISA Summary that relates to each process change.
nuclear fuel services, Inc.
- a BWX Technologies, Inc. company
21G-18-0001 GOV-01-55-04 ACF-18-0001 If you or your staff have any questions, require additional information, or wish to discuss this further, please contact me at (423) 743-1705, or Mr. David Hopson, Senior Regulatory Advisor, at (423) 735-5021. Please reference our unique document identification number (218-18-0001) in any correspondence concerning this letter.
DRH/pdj Sincerely, NUCLEAR FUEL SERVICES,. INC.
Jl..i.;p,~
Richard J. Freudenberger, Director Safety and Safeguards : Summary of Internally Authorized Changes (IACs) Completed During Calendar Year 2017 : License Amendment Evaluation Form FM-NFS-HS-A-67-A
.QQQy:
Regional Administrator U.S. Nuclear Regulatory Commission Region II 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, GA 30303-1257 Mr. Leonard Pitts Senior Fuel Facility Inspector U.S. Nuclear Regulatory Commission Region II 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, GA 30303-1257 Mr. Marvin Sykes Chief, Project Branch I U.S. Nuclear Regulatory Commission Region II 245 Peachtree Center Ave., NE, Suite 1200.
Atlanta, GA 30303-1257 Ms. Leira Cuadrado Project Manager Fuel Manufacturing Branch
- Division of Fuel Cycle Safety, Safeguards, and Environmental Review Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Two White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 Mr. Larry Harris Senior Resident Inspector U.S. Nuclear Regulatory Commission 21 G-18-0001 GOV-01-55-04 ACF-18-0001
ATTACHMENT 1 Summary of Internally Authorized Changes (IACs)
Completed During Calendar Year 2017 1 page to follow 21G-18-0001 GOV-01-55-04 ACF-18-0001
Summary of Internally Authorized Changes (IACs)
Completed During Calendar Year 2017 218-18-0001 GOV-01-55-04 ACF-18-0001 The following changes involved the decommissioning of the BLEU Complex which began in 2016 and was completed in 2017. BLEU Complex ISA Summaries for the Uranyl Nitrate Building (UNB) and the Oxide Conversion and Effluent Processing Buildings (OCB/EPB) are now considered obsolete.
IAC No.
IAC Title/Description of Change/
Date IAC Released for Reason for Change
- Operation BLEU Complex D&D - Buildings 510/520/530/540/550 892
- demolition and associated equipment removal - no longer 05/12/16 needed (end of Areva/NFS contract)
The following changes were related to Decommissioning or Non-Nuclear activities and, therefore, do not relate to an ISA Summary.
IAC No.
IAC Title/Description of Change/
Date IAC Released for Reason for Change Operation Demolition. and Removal of Ground Water Treatment Facility (GWTF) - Building 335 and Associated GWTF 888 Process Equipment - no longer needed to support NFS' 09/07/17 D&D activities - the equipment has been removed and the building has been demolished.
ATTACHMENT 2 License Amendment Evaluation Form FM-NFS-HS-A-67-A 3 pages to follow 21 G-18-0001 GOV-01-55-04 ACF-18-0001
FM-NFS-HS-A-67-A, Revision 6 05/23/17 Page 25 of 28 Attachment A SAFETY AND REGULATORY REVIEW ROUTING FORM (Part I, Front Side)
FM-NFS-HS-A-67-A. RC\\*. 6, NFs.u:k\\-67 Authorization ofForm (inilials):Vlr'l(,!
Revision Dore: OS/23/2017 SAFETY & REGULATORY REVIEW ROUTING FORM art I Date In:
Date Out With Comments:
Date Approved:
Date Returned:
21G-18-0001 GOV-01-55-04 ACF-18-0001 UC-II Circle Review Type ~
Procedure - LOA - CA/CCP - FWP - WR - GH-44 Att. A - New Feed Material - Other Number:
Section:
Revision:
Title/
Subject:
Originator:
Phone No.:
ECR#:
Attached / None / NA A.
If I.
- 2.
- 3.
- 4.
- s.
I. *n,c change rc,quircs a modification to a license condition or to SNM-124.
yes. provide license pages wilh edits lo Licensing to support completion of Part II of this form to d<-tennine the t e of license chan c uin:d.
- 2. The change results in the creation of a new type of accident sequence thal, unless mitigated or prevented, would result in high or intcrrncdintc:
consequenc.:s ( exceed the perfonnnncc requirements of IO CFR 70.61 ) and has not rcviousl been described in the ISA summ
- 3. The change results in the usage of new processes, le<:hnologics, or conlrols for which NFS has no rior ex cricncc.
- 4. The change results in the removal, \\\\ithout at least an equivalent ~-plnccmenl of the safety function, of an item relied on for safety thlll is listed in the ISA summruy and is neccs.smy for compliance with the performance re uirements of IO CFR 70.61.
S. The change n:sulls in the alteration ofony item relied on for safety, list<'<l.in the ISA sirmmruy. thnl is the sole item preventing or mitigating an ae<:idcnt sc uence that exceeds the rformance re uirements in IO CFR 70.61.
C. Is ".,.re basis document available? Esam lcs Include ACE, FHA, FRE.
I. If yes, has a revision already been comj)lctcd Ihm addresses this change?
- 2. lfno to 111 of this section, is n revision needed prior to implementing the chan c?
- 3. Jfoo safety basis document is available, is one needed?
- 4. The change may affect criticnlity delcctor system coverage or audibility of criticali alarms or fire olanns.
S. Docs the change require a walkdo\\\\n?
D. Is a current IROFS/SRE list available? (circle one: Yes I No)
I. lfyes, is o revision needed prior to implcm<"llting the change?
- 2. Jfno, is o new list needed prior to Implementing the change?
TWMTS Engineer/Manager
<=
Initials
=>
<= Concurrence =>
Ind.
Rad.
Env.
RETURN COMPLETED FORM TO SAFETY DEPARTMENT ADMINISTRATIVE ASSISTANT Crit.*
ISA*
Fire YIN YIN YIN YIN YIN YIN YIN YIN YIN YNNA YNNA YNNA
\\'NNA
\\'NNA
\\'NNA YNNA NOTE: Kncn.ind1 or t.-illfully fabiryiog or concn.lina a mate-rial fat'I on lhii form, or making falst-, fictitious or fnudultul slltttaC'lltl or rrpttsrataition., herein couJd tomtirure
- fdoay punisbab~ uodtt t"cden:I Statute.
NFS PROPRl&IARY JN'fORM,\\TIQS 1bb donimnt. iaduding au Information coJitaJO('d htrclo, i.s pro~rty of Nuclfoar Fuft Scnicn, Inc. (NFS). If lbis donmtal h traasmittld or loaned loaoy 000,.NFS partks. it bsubjttt to fffllm OQ draiand,aod b aot to ~copied, Rpn:dllttd, madrH.. ilable ordb.cloKd by aahl partin., *itboul prlor*rittm n:untntof NFS.
FM-NFS-HS-A-67-A, Revision 6 05/23/17 Page 26 of 28 Attachment A SAFETY AND REGULATORY REVIEW ROUTING FORM (Part I, Back Side)
Safety & Regulatory Management Review Questions Placr commrnb. if nndcd. on thr bottom ofthb form I. Have the Safety and OU!cr reviewers completed and initialed the front of the form, and entered on the back of the fonn their comments? Also, has the TWMTS review lxcn com lctcd'l
- 2. SSRC comments from Procedure reviews have been resolved?
- 3. Add Procedure to SSRC review list? For new rocedures onl *)
- 4. Docs the change haven negative impact on NDJ\\ measurements or measurement systems? (lfycs:, notify the chwtgc originator and NOA.
- 5. IAC is re uired? lfvcs. send co v of form to Ori inator to initiate IAC roccss IAC Number
- 6. IAC Final Installation Reviews nrc complete?
If no. withhold a roval of LOA or SOP until rcvicws are com lcte or the IAC rcleasc is bcin tracked b on ORR.*
SSRC Snftl)*
VINA 218-18-0001 GOV-01-55-04 ACF-18-0001 SSRC c:holr VINA YIN/NA YfN/NA YIN/NA YIN YfN/NA
- 7. License document change is re uircd? (If yes. verify Pan 11 is ouaehcd, and send cop
- of form lo Liccnsin Mgr.)
YIN° NOTE f'OR QUESTIONS 8 AND 9: 'if question C.2, 0.1 or 0.2 is answered "yes" ensure the safety basis document (question 8) and/or the IROFS/SRE list uc-stion 9 is cncmted/reviscd rior to im lcmcntution of the chan c for rocedurcs ond LOAs.
YIN YIN YIN YIN TWMTS Engineer/Manager Industrial Safety Radiological Safety Environmental Safety Criticality Safety Safetv Anal:vsis <ISA)
"Impact to Screening Guideline Safely Initials
- Circle 1be applicable Comments Basis?
Chem YIN I 234567 Rad YIN I 234567 Fire YIN I 2 34 5 6 7
- If any are answered ~No" by an ISA Team Leader, circle criteria 11cm numbcr(s) thnt apply from Attachment B m the Screening Guideline column.
Fire Protection Other SSRC Safety SSRC Chairman NOTE: Maintain Record (Form) until Termination of License SNM-124
FM-NFS-HS-A-67-A, Revision 6 05/23/17 Page 27 of 28 Attachment A SAFETY AND REGULATORY REVIEW ROUTING FORM (Part II)
FM-NFS-IIS-A-67-A. Rev. 6, N~-67 Authori7.ation of Form (inirials):
Rc,*i~ion Date: OS/23/2017 SAFETY & REGULATORY REVIEW ROUTING FORM (Part II)
License Document Change (Administrative or Amendment) 21 G-18-0001 GOV-01-55-04 ACF-18-0001 LIC-11 As specified in SNM-124 License Condition S-2, the following are example.* or administrative changes that generally do not require prior NRC approval:
modifications to racility and process descriptions enhancements or clarifications of text grammatical corrections reformatting of text.
If the following questions are answered "no" the license document change is administrative. Gh*ejustlfication in the provided space and/or attach evidence. (e.g., redlined safety basis documents, procedure mark-ups, etc.)
Licensing If any of the questions are answered "yes" the license document change requires a license amendment and approval from the NRC orior to implementation of the chan<!e.
- i. The change decreases the level of effectiveness ofthc design basis as described in the License Application.
Y/N Justification:
- 2. The change results in a departure from the methods of evaluation described in the License Application used in Y/N establishing the desil!n basis.
Justification:
- 3. The change results in a degradation ofsafoty.
Y/N Justification:
- 4. The change affects compliance with applicable regulatory requirements.
YIN Justification:
- 5. The change conflicts with an existing license condition.
Y/N Justification:
Checklist for License Document Changes (To be completed by Licensing)
Licensing Initials Admlni.srr:a,n*e Amtndmenl The license page(s) has been modified.
The license page(s) hes been approved by the SSRC.
The licensing Sharepoint Site and eB have been updated to reflect the license document change.
A PIRCS entry, with a due date no later than 6 months from the time of implementation of the change, has been made for submittal of the license document page(s) to the NRC.
PIRCS ID
)
N'OTE: lt.:001tlo~y or 111,Ufully raWfyinz or coD.CC"atiog
- m**~rial fad on tbis rorm. or mali.inc falw, fictitious or (nuduln1t stt1m1c-nb or rrprncntarion, hcrrin could C"on,1imtc
- fdony puobb.abk under f,'t'dcral Sl.lltutcs.
i4'FS PROPRIF.T ARV l~FOR:\\t,\\TIO~ Tbb documrnt. Including all lnformatioo contalnf'd hcrrln, 11 propcny or ~uclnr Fud Sen*lcu. IP<'. (NFS). tr lhll donararnl b tnnsmfntd or li,antd to any noo-Nfo"S partic,.. ~r b wbjttt to rrtum on demand, and b not to be coplt'd, rrproduttd. made anilabk or di.sdostd by uld partin. "ithout prior wrinm corueo1 or 1'FS.