ML19253A055
| ML19253A055 | |
| Person / Time | |
|---|---|
| Site: | 07003103 |
| Issue date: | 09/05/2019 |
| From: | Cowne S Louisiana Energy Services, URENCO USA |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| LES-19-133-NRC | |
| Download: ML19253A055 (4) | |
Text
SEP O 5 2019 LES-19-133-NRC Attn: Document Control Desk Director, Division of Fuel Cycle Safety, Safeguards & Environmental Review Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Louisiana Energy Services, LLC NRC Docket No. 70-3103
Subject:
UUSA Comments on Building a Smarter Fuel Cycle Inspection Program USA The National Enrichment Facility
References:
- 1) Charter for Building a Smarter Fuel Cycle Inspection Program, ML19114A047
- 2) August 8, 2019 Building a Smarter Fuel Cycle Inspection Program, ML19199A480 Louisiana Energy Services, also dba URENCO USA (UUSA) has participated in the public meetings the NRC has held regarding the subject initiative undertaken by the NRC and will continue to support this effort. UUSA applauds the NRC in pursuing this transformative initiative and has some recommendations and comments provided in Enclosure 1. This letter is in response to the Reference 1 Proposed Project Plan, which requests feedback prior to the 4th Public Meeting being held later this month. The comments provided in Enclosure 1 are a result of UUSA's review of Reference 2.
Should there be any questions regarding this submittal, please contact Paul Lorskulsint, UUSA Deputy Compliance Manager, at 575-394-5176.
Respectfully, I~
n R. Cowne uclear Officer and Compliance Manager.
UUSA comments on Building a Smarter Fuel Cycle Inspection Program
~
Louisiana Energy Services, LLC UUSA I P.O. Box 1789 I Eunice I New Mexico 188231 I USA T: +1 (575) 394 4646 I W: www.uusa.urenco.com
CC: email Karl Sturzebecher, Project Manager - UUSA U.S. Nuclear Regulatory Commission Karl.Sturzebecher@NRC.gov Jacob Zimmerman, Fuel Facility Licensing Branch Chief U.S. Nuclear Regulatory Commission Office of Nuclear Material Safety and Safeguards Jacob.Zimmerman@NRC.gov Robert Williams, Region 11 Projects Branch I Chief U.S. Nuclear Regulatory Commission Robert.Williams@nrc.gov Margie Kotzalas, Licensing and Oversight Branch Chief U.S. Nuclear Regulatory Commission Office of Nuclear Material Safety and Safeguards Margie.Kotzalas@nrc.gov
ENCLOSURE 1 UUSA Comments on Building a Smarter Fuel Cycle Inspection Program Proposals A & C In the August 8, 2019 presentation provided by the NRC1, proposals for revisions to IMC 2600 Appendix B were provided for both Category I and Category Ill facilities. Proposals A and C took into account the licensee having an NRG-accredited Corrective Action Program with a periodic focused inspection performed annually.
UUSA presently has an accredited Corrective Action Program. The current benefits of the accreditation allow UUSA to receive Non-Cited Violations (NCVs) from the NRC for both self-identified and NRG-identified Severity Level IV violations. Without the program, NRG-identified Severity Level IV violations would require a Notice of Violation (NOVs) response from the licensee.
UUSA CAP Background The January 2013 revision of the NRC Enforcement Policy enabled the NRC to disposition SL IV violations for fuel cycle facilities as NCVs, if the NRC determined that the applicant or licensee had an adequate corrective action program (CAP), the licensee entered the violation into its CAP, and the criteria in Section 2.3.2 of the Enforcement Policy were met.
UUSA began communications with the NRC in 2013 with a series of letters requesting the NRC review and approve our CAP. The communication resulted in a series of letters and Request for Additional Information (RAI) responses. In following NUREG-2154, "Acceptability of Corrective Action Programs at Fuel Cycle Facilities" 2, UUSA learned that additional commitments would be required for the NRC to begin issuing NCVs to UUSA for NRG-identified issues. UUSA issued changes to its Quality Assurance Program Description (QAPD) near the end of 2013 and the NRC approved and began inspecting the program in 2014.
UUSA voluntarily committed to revising the QAPD, not simply to avoid responding to NRC identified Severity Level IV Violations, but also to invoke our commitment to our CAP as one of our management systems that supports a healthy nuclear safety culture. A facility that has a low threshold for identifying issues which can effectively evaluate and correct issues is capable of demonstrating sustained performance over periods longer than the snapshot observed during a routine inspection UUSA implements our CAP with a low threshold for identifying issues which far exceeds the license basis minimum. UUSA has demonstrated that we identify issues completely, accurately, and in a timely manner in accordance with our program. Our facility evaluates problems to ensure that corrective actions address causes and extent of conditions commensurate with their safety significance. The facility periodically analyzes information from the cbrrective action program and other assessments to identify programmatic and common cause issues.
UUSA strongly urges the NRC to endorse Proposals A & C in the next revision of Inspection Manual Chapter (IMC) 2600.
1 ML19199A480 2 NUREG-2154 was later withdrawn by the NRC and instead issued as Regulatory Guide 3.75 in July 2014
Proposals B & D UUSA also supports the endorsement of Proposals B & Din the next revision of IMC 2600 and believes the current inspection scope should be evaluated and reduced, regardless if an accredited Corrective Action Program exists. Proposals B & D can and should coexist with Proposals A & C.
Comments It is our understanding that for Proposal C, the Emergency Preparedness (EP) Exercise inspection will be absorbed into the EP inspection which is on the Focused Inspection rotation.
To provide clarification, UUSA recommends that the EPX be listed in the bottom row of table C to avoid confusion.
The number of estimated resources for a Corrective Action Program are not identified in IMC 2600 Appendix B and should be included. UUSA has not challenged the recent resource allocation for this inspection but is more capable of budgeting expenses when the allocation is known.
Again, UUSA appreciates the NRG working with the Industry on this initiative to make the Inspection program more efficient from both ends.