ML18360A180
| ML18360A180 | |
| Person / Time | |
|---|---|
| Site: | 07003103 |
| Issue date: | 12/18/2018 |
| From: | Cowne S Louisiana Energy Services, URENCO USA |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| LAR-18-15, LES-18-160-NRC | |
| Download: ML18360A180 (6) | |
Text
LES-18-160-NRC DEC 1 8 2018 Attn: Document Control Desk Director Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Louisiana Energy Services, LLC NRC Docket No. 70-3103
Subject:
LAR 18-05, Change to Nuclear Liability Insurance Amount In accordance with 10 CFR 70.34, Louisiana Energy Services, LLC ("LES"), also dba URENCO USA ("UUSA") hereby requests an amendment to Material License SNM-2010.
The proposed change in this License Amendment Request (LAR) is to UUSA License Basis Documents and the Materials License, SNM-2010, to reduce the amount of the required Nuclear Liability Insurance maintained in accordance with 10 CFR 140.13b. provides a description and analysis of the proposed change, basis for the change, and safety significance of the proposed change. Enclosure 2 provides the markups of the License Basis Documents and the proposed revision to SNM-2010 with the changes annotated on the pages. The Technical Basis described in Enclosure 1 utilizes information from the calculation provided in Enclosure 3.
UUSA considers the information provided in Enclosure 3 as proprietary information in accordance with 10 CFR 2.390(a)(4). UUSA requests that Enclosures 1 and 3 be withheld from public disclosure. The enclosure 4 Affidavit supports this request.
If you have any questions regarding this License Amendment Request, you may contact Wyatt Padgett, Licensing and Performance Assessment Manager, at 575-394-5257.
Respectfully, Ste en Cowne Chief Nuclear Officer and Compliance Manager
Enclosures:
- 1) Change to Nuclear Liability Insurance Amount (LAR-18-15)
- 3) CALC-S-00156, Beyond Design Basis Accident Event for Liability Insurance Estimates
- 4) Affidavit LES,PO Box 1789, Eunice, New Mexico 88231,USA T: +1575394 4646 F: +1575394 4545 W: www.urenco.com/LES
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cc via email:
Karl Sturzebecher, Project Manager - UUSA Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Karl.Sturzebecher@NRC.gov Jacob Zimmerman, Enrichment & Conversion Branch Chief Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Jacob.Zimmerman@NRC.gov Omar Lopez-Santiago, Projects Branch I Chief Region II U.S. Nuclear Regulatory Commission Omar.Lopez-Santiago@NRC.gov
ENCLOSURE 4 Affidavit I, Stephen Cowne, being duly sworn, state that I am the Chief Nuclear Officer and Compliance Manager for Louisiana Energy Services (LES), dba URENCO USA (UUSA);
that I am authorized on the part of said company to sign and file with the Nuclear Regulatory Commission ("NRC") this document; and that all statements made and matters set forth herein are true and correct to the best of my knowledge, information, and belief:
- 1. LES wishes to have withheld from public disclosure the following document:
LES-18-160-NRC Enclosure 1, Change to Nuclear Liability Insurance Amount (LAR-18-05)
LES-18-160-NRC Enclosure 3, CALC-S-00156, Beyond Design Basis Accident Event for Liability Insurance Estimates
- 2. The information contained in the document cited in 1 above for which exemption from public disclosure is requested is proprietary information related to commercial aspects of the URENCO USA Facility. LES requests that this information be exempt from disclosure pursuant to the provisions in 10 CFR Part 2.390(a)(4).
- 3. Public disclosure of the information in the above enclosure to this submittal has the potential to result in substantial harm to the competitive position of LES, provide valuable business information to competitors of LES which they could duplicate without having to expend their own resources to develop, and reduce or foreclose the availability of profit opportunities.
- 4. The information stated in this affidavit has been submitted in accordance with the applicable parts of 10 CFR 2.390 and the guidance contained in NUREG-1556, Vol.
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- z/¢g-step en Cowne Date Chief Nuclear Officer and Compliance Manager Louisiana Energy Services, LLC I certify the above named person appeared before me and executed this document on this /6-lhday of December 2018.
~1/CtL~m ow Notary Public My commission expires:, l\\Oe, \\l.Q, ;;tBO
ENCLOSURE 2 Markup changes to UUSA Safety Analysis Report and proposed changes to SNM-2010 (Redline strikethroughs were utilized)
1.2 Institutional Information final executed copies of the reviewed financial assurance instruments for that building are provided to the NRC.
LES shall in accordance with 10 CFR 140.13b, (CFR, 20031), prior to and throughout operation, have and maintain nuclear liability insurance in the type and amounts the Commission considers appropriate up to a limit of $300 million to cover liability claims arising out of any occurrence within the United States, causing, within or outside the United States, bodily injury, sickness, disease, or death, or loss of or damage to property, or loss of use of property, arising out of or resulting from the radioactive, toxic, explosive, or other hazardous properties of chemical compounds containing source or special nuclear material.
The amounts of nuclear energy liability insurance required may be furnished and maintained in the form of:
- 1.
- 2.
- 3.
- 4.
- 5.
An effective facility form (non-indemnified facility) policy of nuclear energy liability insurance from American Nuclear Insurers and/or Mutual Atomic Energy Liability underwriters; or Such other type of nuclear energy liability insurance as the Commission may approve; or A combination of the foregoing.
$5 million to recei1Je and maintain onsite, an in1Jentory of< 50 kg of natural or depleted
~
e as "test material".
$300 million to recei'le and maintain onsite, an in1Jentory > 50 kg of Ure on site as "feed material".
If the form of liability insurance will be other than an effective facility form (non-indemnified facility) policy of nuclear energy liability insurance from American Nuclear Insurers and/or Mutual Atomic Energy Liability Underwriters, such form will be provided to the Nuclear Regulatory Commission by LES. The minimum amount of Liability Insurance required for LES is
$100 Million. The effective date of this incremental insurance will be no later than the date that LES takes possession of the abo1Je specified quantity and enrichment of Ure.,.
Effecti1Je No1Jember 26, 2002, nuclear energy liability Facility Form policy number NF 0350 was issued to LES for the planned NEF with the limit of liability of $1,000,000. This standby limit will apply until the plant takes possession of Ure in a quantity listed in #4 or #5 above, at which time it is anticipated that the liability insurance coverage limit will be increased to $5 million for "test material", or the $300 million limit for quantities of UF., in excess of the 50 kg "test material" limit.
Until such time as LES takes possession of source material UFs, the effects described in 10 CFR 140.13b invol1Jing source material are not possible. Therefore, the $1,000,000 standby liability policy, in addition to appropriate construction coverage, is considered to be sufficient for the construction phase. LES will provide proof of liability insurance of a type and in the amounts to col/er liability claims required by 1 O CFR 140.13b prior to taking possession of source material.
Information indicating how reasonable assurance will be provided that funds will be available to decommission the facility as required by 10 CFR 70.22(a)(9) (CFR, 2003b), 10 CFR 70.25 (CFR, 2003c), and 10 CFR 40.36 (CFR, 2003d) is described in detail in Chapter 10, Decommissioning.
Safety Analysis Report Page-1.2-14 LAR-18-05
OFFIGIAb USe 0 Nb¥ SeGURl::r¥ RebAl'.eC INFORMAl'.ION NRC FORM 374A U.S. NUCLEAR REGULATORY COMMISSION Page 6 of 13 License Number SNM-2010 MATERIALS LICENSE Docket or Reference Number SUPPLEMENTARY SHEET 70-3103 LAR-18-05 (UUSA-PCS-ISSP)Revision 1, dated April 14, 2015.
ac.
URENCO USA Facility, Centrifuge Monitoring System, and Medium Frequency Drive, Information System Security Plan (UUSA-CMS-MFD-ISSP), Revision 1, dated April 14, 2015, and Revision 2, dated June 22, 2018.
ad.
URENCO USA Facility, Plant Control Training System and Enhanced Training System Information System Security Plan, (UUSA-PCTS-ETS-ISSP) Revision 1, dated April 14, 2015, and Revision 4, dated June 22, 2018.
ae.
UUSA Information System Security Baseline Common Control Catalog, Revision 1, dated April 14, 2015.
11. Introduction of UFs into any module of the NEF shall not occur until the Commission completes an operational readiness and management measures verification review to verify that management measures that ensure compliance with the performance requirements of 10 CFR Section 70.61 have been implemented and confirms that the facility has been constructed and will be operated safely and in accordance with the requirements of the license. The licensee shall provide the Commission with 120 days advance notice of its plan to introduce UFs in any module of the NEF.
- 12. The licensee is hereby granted the special authorizations and exemptions identified in Section 1.2.5 of the UUSA Safety Evaluation Report, dated June 2013.
- 13. This license was originally issued for a period of 30 years from the date of license issuance. Based on an amendment request dated May 6, 2011, the license expiration date has been extended to June 9, 2040.
- 14. For the disposition of depleted UFs (DUFs) the licensee shall not use a DUFs deconversion facility that employs a process that results in the production of anhydrous hydrofluoric acid.
- 15.
The licensee shall maintain full liabilitt insurance, as reguired under 10 CFR 140.13b, at a minimum of
~100 million. a. +he liseRsee shall pFe11iEle pFeef af $5 FflillieR liaeility iRSl:lFaRGe, as FeEJl:liFeEI l:lREleF rn GFR PaFa§Faph 14(U dB, at least dG Elays pFiaF ta the plaRReEI Elate feF aetaiRiR§ pessessieR ef test FflateFial (less thaR eF eEJl:lal te 5Q k§) ef ElepleteEI eF Ratl:lml UF6.,.
- 9.
+he liseRsee shall pF9¥iEle pFeef af fl:lll liaeility iRSl:lFaRse, as FeEJl:liFeEI l:lREleF 1 Q GFR PaFa§Faph 14 Q. 1 dB, at least dG Elays pFieF te the plaRReEI Elate feF eetaiRiR§ feeEI Ff!ateFial (§FeateF thaR 5Q k§
~). If the liseRsee is pFepesiR§ te pFe*t'iEle less thaR $dQQ FflilliaR ef liaeility iRSl:lFaRse se*t'eFa§e, the liseRsee shall pFe*t'iEle, te the ~JRG feF Fe11iew aREI appFe*t'al, aR e11al1:JatieR sl:lppeFtiR§ liaeility iRSl:lFaRGe se1,em§e iR aA'lel:lRts less thaR $dQQ FflillieR, at least 12Q Elays pFieF ta the plaRReEI Elate foF eetaiRiR§ feeEI FflateFial.
- 16. a & bDeleted C.
The licensee shall provide an updated Decommissioning Funding Plan, including a decommissioning cost estimate update and final copies of the proposed financial assurance instruments, to NRC for review at least 6 months prior to initiating operations in the next cascade in an Assay Unit within any subsequent separation building module (SBM) or licensed material into OFFIGIAb USe 0Nb¥ SeGURl::r¥ RebAl'.eC INFORMAl'.ION