ML18064A074
| ML18064A074 | |
| Person / Time | |
|---|---|
| Site: | 07003103 |
| Issue date: | 03/02/2018 |
| From: | Lesser M NRC/RGN-II/DFFI |
| To: | Cowne S Louisiana Energy Services |
| References | |
| IR 2018001 | |
| Download: ML18064A074 (8) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 March 2, 2018 Stephen Cowne, Chief Nuclear Officer and Compliance Manager Louisiana Energy Services, L.L.C.
P.O. Box 1789 Eunice, NM 88231
SUBJECT:
LOUISIANA ENERGY SERVICES, L.L.C., URENCO USA FACILITY -
LICENSEE PERFORMANCE REVIEW OF LICENSED ACTIVITIES (NRC INSPECTION REPORT 70-3103/2018-001)
Dear Mr. Cowne:
The U.S. Nuclear Regulatory Commission (NRC) staff in our Region II Office and the Office of Nuclear Material Safety and Safeguards completed a periodic review of Louisiana Energy Services, L.L.C., URENCO USAs (UUSA) inspection results and facility performance in conducting NRC-licensed activities. The review covered the period from January 1, 2016, through December 31, 2017. The performance of UUSA was evaluated in the following performance areas: Safety Operations, Radiological Controls, Facility Support, and Other Areas. The enclosure to this letter provides the results of our review and constitutes the basis for establishing the NRC oversight program for your facility. The details regarding the Safeguards portion of the review are documented in a separate letter marked Official Use Only- Security-Related Information due to the sensitive nature of the information.
The staff determined that UUSA has continued to conduct its activities safely and securely, and in a manner that protects public health and the environment. Based on our review of activities, no areas needing improvement were identified in the performance areas of Safety Operations, Radiological Controls, Facility Support, and Other Areas. Therefore, the NRC plans to conduct the core inspection program for a gas centrifuge fuel facility as described in NRC Inspection Manual Chapter (IMC) 2600, Fuel Cycle Facility Operational Safety and Safeguards Inspection Program, for the review period of January 1, 2018, to December 31, 2019.
Throughout the implementation of the inspection program and the review of plant events in this performance review period, the inspectors identified examples of repetitive compliance issues consisting of failure to request NRC approval for changes to the licensing basis and failure to implement administrative safety controls. While these issues did not result in escalated enforcement actions and did not raise to the level of an area needing improvement as defined in NRC Inspector Manual Chapter 2604, Licensee Performance Review, the NRC staff determined that these issues could be indicative of weaknesses in the correction action program (CAP). The inspection staff also identified issues with the implementation of CAP procedures in the Safeguards area, but these will be documented in a separate letter marked Official Use Only- Security-Related Information due to the sensitive nature of the information.
S. Cowne 2 Inspection Manual Chapter (IMC) 2600, lists As Needed, procedures used in support of implementation of the inspection program and these procedures are to be performed as necessary, or at the frequency designated in that inspection procedure. Inspection Procedure (IP) 88161, Corrective Action Program Implementation at Fuel Facilities, was used to certify the UUSA Corrective Action Program and is one of the procedures recognized by IMC 2600.
Once the CAP has been determined to be effective, IP 88161 requires that an inspection of that program be performed on a biennial basis.
In light of the examples identified during inspections and the biennial inspection program requirement, the NRC will adjust the core inspection program in the upcoming performance review period to conduct an inspection of your CAP in accordance with IMC-2600, Appendix B, Table 2, Inspection Procedure 88161, Corrective Action Program Implementation at Fuel Cycle Facilities. The CAP inspection scope will consider all performance areas covered under the NRC core inspection program. The purpose of this inspection is to verify that the program is implemented in accordance with the program elements described in your Quality Assurance Program Description, as incorporated by reference in Special Nuclear Material License SNM-2010. The inspection will validate that the program is effectively implemented to identify, prioritize, evaluate, and correct safety issues. The inspection results will also inform future NRC decisions for the disposition of violations of regulatory requirements.
On June 22, 2015, the NRC issued Generic Letter (GL) 2015-01, Treatment of Natural Phenomena Hazards in Fuel Cycle Facilities to: (1) request that licensees submit information to demonstrate compliance with regulatory requirements regarding the treatment of natural phenomena events in the facilities integrated safety assessments and (2) determine if additional NRC regulatory action was necessary to ensure compliance with the licensing basis and existing NRC regulations. The NRC completed its review of licensee information and conducted inspections on-site in accordance with Temporary Instruction 2600/016, Inspection Activities Associated with NRC Generic Letter 2015-01. On June 21, 2017, the NRC closed GL 2015-01 for LES with no further regulatory action based on the staff evaluation and the results of the inspection (ADAMS Accession No. ML17164A226).
The results of our Licensee Performance Review will be discussed with you at a meeting open to the public on April 26, 2018, via webinar. During the meeting, you will have an opportunity to discuss your performance in the same major areas as evaluated by the NRC.
In accordance with Title 10 of the Code of Federal Regulations Section 2.390 of the NRC's "Rules of Practice and Procedure," a copy of this letter and its enclosure will be made available for public inspection at the NRC Public Document Room and accessible electronically through the ADAMS in the NRC Library at http://www.nrc.gov/reading-rm/adams.html.
S. Cowne 2 Please refer questions and comments regarding your licensee performance review to Mr. Omar López-Santiago, Chief, Projects Branch 1, who can be reached by telephone at 404-997-4703.
Sincerely,
/RA/
Mark S. Lesser, Director Division of Fuel Facility Inspection Docket No. 70-3103 License No. SNM-2010
Enclosure:
Licensee Performance Review cc: (See page 3)
S. Cowne 3 cc:
Butch Tongate, Cabinet Secretary New Mexico Department of Environment Office of the Secretary 1190 St. Francis Drive P.O. Box 26110 Santa Fe, NM 87502-0157 Matt White, Mayor City of Eunice P.O. Box 147/1106 Ave J Eunice, NM 88231 The Honorable Sam D. Cobb, Mayor City of Hobbs 200 E. Broadway Hobbs, NM 88240 Cheryl Chance, Mayor City of Jal P.O. Drawer 340 Jal, NM 88252 Chair Ron R. Black Lea County Board of County Commissioners Lea County Courthouse 100 North Main Avenue, Suite 4 Lovington, NM 88260 Daniel F. Stenger, Counsel Hogan and Hartson 555 13th Street, NW Washington, DC 20004 Santiago Rodriguez, Chief Radiation Controls Bureau NM Environment Department PO Box 5469 Santa Fe, NM 87502-5469 David Sexton, Managing Director UUSA, President and Chief Executive Officer Louisiana Energy Services, LLC URENCO USA P.O. Box 1789 Eunice, NM 88231 Dave.Sexton@Urenco.com cc: (Contd on page 4)
S. Cowne 4 (cc: contd)
Lisa Hardison, Manager Communications & Public Relations Louisiana Energy Services, LLC URENCO USA P.O. Box 1789 Eunice, NM 88231 lisa.hardison@urenco.com Perry Robinson, Outside General Counsel URENCO USA P.O. Box 1789 Eunice, NM 88231 Richard A. Ratliff, PE, LMP Radiation Program Officer Bureau of Radiation Control Department of State Health Services Division for Regulatory Services 1100 West 49th Street Austin, TX 78756-3189
ML18064A074 SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DFFI RII:DFFI HQ:NMSS HQ:NMSS HQ:NMSS SIGNATURE /RA/ /RA/ /via email/ /RA/ /RA/
NAME KKirchbaum OLópez-Santiago CErlanger MKotzalas JZimmerman DATE 2/27/2018 2/27/2018 2/28/2018 2/28/2018 2/28/2018 E-MAIL COPY? YES NO (YES) NO YES NO YES NO YES NO LICENSEE PERFORMANCE REVIEW FOR LOUISIANA ENERGY SERVICES, L.L.C., URENCO USA ASSESSMENT PERIOD: JANUARY 1, 2016 to DECEMBER 31, 2017 The following is a summary of the performance of Louisiana Energy Services, L.L.C., URENCO USA in the conduct of Nuclear Regulatory Commission (NRC) licensed activities.
OPERATIONS PERFORMANCE AREA: SAFETY OPERATIONS This area is comprised of plant operations, nuclear criticality safety, and fire protection.
Program Areas Needing Improvement
- No specific area needing improvement was identified in Safety Operations.
Recommended NRC Inspection Effort
- Maintain the core inspection effort in Safety Operations.
PERFORMANCE AREA: RADIOLOGICAL CONTROLS This area is comprised of radiation protection, environmental protection, waste management, and transportation.
Program Areas Needing Improvement
- No specific area needing improvement was identified in Radiological Controls.
Recommended NRC Inspection Effort
- Maintain the core inspection effort in Radiological Controls.
PERFORMANCE AREA: FACILITY SUPPORT This area is comprised of maintenance and surveillance, training, emergency preparedness, and permanent plant modifications and included licensing activities.
Program Areas Needing Improvement
- No specific area needing improvement was identified in Facility Support.
Recommended NRC Inspection Effort
- Maintain the core inspection effort in Facility Support.
Enclosure
2 PERFORMANCE AREA: OTHER AREAS This area is comprised of special issues.
Program Areas Needing Improvement
- No specific area needing improvement was identified in Other Areas.
Recommended NRC Inspection Effort
- Maintain the core inspection effort in Other Areas. An inspection of the Corrective Action Program will be performed to verify the program is being implemented to properly identify, track, and correct items of safety significance in accordance with the program elements described in your Quality Assurance Program Description, as incorporated by reference in Special Nuclear Material License SNM-2010.