ML19304A103
| ML19304A103 | |
| Person / Time | |
|---|---|
| Site: | 07003103 |
| Issue date: | 10/24/2019 |
| From: | Cowne S Louisiana Energy Services, URENCO USA |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| LES-19-147-NRC | |
| Download: ML19304A103 (5) | |
Text
OCT 2 4 2019 LES-19-147-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:
Proposal for Building a Smarter Fuel Cycle Inspection Program Enrichment Facility
Reference:
LES-19-133-NRC, Letter from UUSA to NRC, UUSA comments on Building a Smarter Fuel Cycle Inspection Program, September 5, 2019 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 previously submitted comments in the Referenced letter. UUSA recently presented a proposal in a Public Meeting and herewith submits the proposal in Enclosure 1.
Should there be any questions regarding this submittal, please contact Paul Lorskulsint, UUSA Deputy Compliance Manager, at 575-394-5176.
Respectfully, R. Cowne Nuclear Officer and Compliance Manager.
UUSA Proposal on Building a Smarter Fuel Cycle Inspection Program
~
Louisiana Energy Services, LLC UUSA I P.O. Box 1789 I Eunice I New Mexico I 88231 I USA T: +1 (575) 394 4646 I W: www.uusa.urenco.com
CC: email Kevin Ramsey, Project Manager - UUSA U.S. Nuclear Regulatory Commission Kevin.Ramsey@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 II 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 Proposal on Building a Smarter Fuel Cycle Inspection Program A Corrective Action Program is capable of identifying issues which far exceed regulatory requirements. UUSA identifies issues completely, accurately, and in a timely manner. In accordance with our program, issues are identified and evaluated to ensure that resolutions address causes and extent of condition. Our facility takes effective corrective actions to address issues in a timely manner commensurate with safety significance. UUSA periodically analyzes information from the corrective action program and other assessments to identify programmatic issues and common causes.
An effective Corrective Action Program results in reducing the need for inspections. Issues are identified, evaluated and corrected in a timely manner. Records are retrievable by the NRG for enforcement action, if necessary. NRG inspection may identify failure to place issues in the corrective action program.
UUSA does not have any fundamental disagreements with NEI Proposal 11, NEI Proposal 22 or NRG Options 1 and 23* The details associated with NRG Option 1 need clarification UUSA is interested in the measurements associated with NEI Proposal 2 and looks forward to future discussions on these proposals. UUSA's proposal is intended to overlay and coexist with NRG Option 2.
The following table is based on NRG Option 2 which was provided by the NRG at the October 17th public meeting4* Markups and change bars were utilized to show the proposed additions.
The UUSA proposal creates comprehensive inspection activities to be performed triennially for
- 1) Fire Protection, 2) Radiation Protection, 3) Effluent Control & Environmental, 4)
Transportation and 5) Emergency Preparedness. Additionally, the proposal removes the annual Modifications Inspection and replaces with a triennial Comprehensive Modifications Inspection.
Additionally, a required Corrective Action Program Inspection is proposed triennially. It is expected that the Corrective Action Program and Comprehensive Plant Modifications inspections would each be performed in sequential years instead of the NRG proposed inspection regime as long as a licensee has committed to a corrective action program that requires the licensee to identify non-regulatory required issues.
1 ML19176A534 2 Letter from NEI to NRC, Industry Proposal 2 - Smarter Program for Fuel Cycle Facilities, October 15, 2019 3 ML19254A588 4 ML19288A317
Proposed Modification to NRC Option 2 Category I Fuel Facility Category Ill Fuel Uranium Conversion Gas Centrifuge Facility Fabrication Facility Facility Function/
Procedure or Inspection Estimated Inspection Estimated Inspection Estimated Inspection Estimated Program Procedure Resources Resources Resources Resources Areas Suite Frequency per IP (hrs)
Frequency per IP (hrs)
Frequency per IP (hrs)
Frequency per IP (hrs)
SAFETY OPERATIONS 88020 (OPR)
Biennial 30 Annual 90 Annual 90 Annual 90 Plant Operations 88135 (Resident Inspection Annual 79_7 ProQram)
Criticality 88015 Annual 180 Annual 90 Annual 90 Safety Fire Protection 8805X Biennial 30 Biennial 60 Biennial 60 Biennial 60 SAFEGUARDS MC&A Procedures as Annual 120 Biennial 60 Biennial 60 in IMC 2683 MC&A Procedures as Triennial 30 Triennial 30 30 (observation) in IMC 2683 RADIOLOGICAL CONTROLS Radiation Protection 88030 (RP)
Annual 30 Annual 30 Annual 30 Annual 30 Environmental 88045 (Effluent Protection Control and Annual 30 Annual 30 Annual 30 Annual 30 Env.)
Transportation 86740 (T)
Triennial 30 Triennial 30 Triennial 30 Triennial 30 FACILITY SUPPORT Emergency Preparedness 88050 (EP)
Biennial 30 Biennial 30 Biennial 30 Biennial 30 88051 (Exercise Biennial 48 Biennial 48 Biennial 48 Biennial 48 Observation)
Category I Fuel Facility Category 111 Fuel Uranium Conversion Gas Centrifuge Facility Fabrication Facility Facility Function/
Procedure or Inspection Estimated Inspection Estimated Inspection Estimated Inspection Estimated Program Procedure Resources Resources Resources Resources Areas Suite Frequency per IP (hrs)
Frequency per IP (hrs)
Frequency per IP (hrs)
Frequency per IP (hrs)
Plant Annual unless Annual unless Annual unless Annual unless Modifications 88070 88072is 30 88072is 30 88072is 30 88072 is 30 (Annual) performed performed performed performed Plant Modifications 88072 Triennial 90 Triennial 90 Triennial 90 Triennial 90 (Triennial)
ACCREDITED CORRECTIVE ACTION PROGRAM (IF LICENSEE HAS VOLUNTARILITY IMPLEMENTED AN ACCREDITED CAP\\
Corrective 88161 (CAP)
Triennial 90 Triennial 90 Triennial 90 Triennial 90 Action Program Fire Protection Triennial 45 Triennial 45 Triennial 45 Triennial 45
/8805X) 88030 (RP),
Triennial 30 Triennial 30 Triennial 30 Triennial 30 88045 (Effluent Control and Triennial 30 Triennial 30 Triennial 30 Triennial 30 Compre-Env.).
86740 hensive (Trans-Triennial 12 Triennial 15 Triennial 12 Triennial 15 oortation) 88050 (Emergenc}'.
Triennial 30 Triennial 30 Triennial 30 Triennial 30 Preo)
Plant Modifications Q
Q Q
Q 188070)
- Unless inspections are performed under an accredited CAP inspection.