ML20042H064
| ML20042H064 | |
| Person / Time | |
|---|---|
| Issue date: | 05/15/1990 |
| From: | Loysen P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Haughney C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-PROJ-M-45 NUDOCS 9005170145 | |
| Download: ML20042H064 (4) | |
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May 15, 1990 l
t projectNo,M-45 MEMORANDUM FOR:
Charles J. Haughney, Chief Fuel Cycle Safety Branch i
Division of Industrial and Medical Nuclear Safety, NMSS FROM:
Peter Loysen, Licensing Project Manager Advanced fuel and Special facilities Section Fuel Cycle Safety Branch Division of Industrial and i
Medical Nuclear Safety, NMSS
SUBJECT:
SUMMARY
OF MEETING _WITH LOUISIANA ENERGY SERVICES The NRC staff met with representatives of Louisiana Energy Services (LES) on May 3,1990, to resume detailed discussions on licensing matters.
(Meetings i
had been suspended since January 1990, pending formalization of the LES partnership.) A list of meeting attendees is enclosed.
The first and a main topic of discussion was the LES partnership agreement, which had been announced at a press conference in llomer, t.ouisiana, on April 27,
.3 1990.
Howard Arnold explained the arrangement of general and limited partners, and the participation, roles, and restrictions of each.
He emphasized the restrictions on the Urenco-related partners in the area of j
national security issues. LES had sent NRC a copy of the partnership i
agreement for review in connection with the meeting, but it was received only l
l the day before, it had not been analyzed, and no comments could.be made on whether LES can comply with NRC's license application prohibition against I
foreign ownership, domination, or control. LES requested that the partnership agreement be treated as proprietary informat-ion' pursuant to 10 CFR part 2.790.
The NRC staff will consider the request.
LES recognizes the'.need to prepare a non-proprietaty version of the partnership agreement as well, so that important features of the agreement and NRC's' review can be made public.
According to Joanna Becker, it wC1 not be necessary for LES to submit a l
written request for the NRC staff to consider the issue of foreign ownership, domination, or control; however, the staff may require additional information I
after initial review of the partnership agreement. Dr. Arnold stated that LES planned to submit in June 1990, the previously requested information for antitrust review.
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May 15, 1990 Charles J. Haughney t
peter LeRoy said that LES now plcns to use two safety (and quality assurance) classes -- one for systems, structures, and components necessary to deal with the values in NUREG-1391, " Chemical Toxicity of Uranium Hexafluoride Related to Radiation Doses" (500 mg-min /m* hydrogen fluoride and/or inhalation of 10 mg uranium), and one requiring good engineering practices with special requirements added by specification rather than classification. This appeared to the staff to be a reasonable approach.
Copies of NUREG-1391 were provided to LES. LeRoy 1
asked for the staf f's opinion on the Duke power Company OA Topical Report which I
had been sent to NRC at the end of last year as LES' OA program. Don Garrison and Jack Spraul said that, while the report may be suitable for 'Ouke power for i
its QA program, it lacked a connection to LES, including LES' management of the program. LES agreed to provide information to NRC on these matters.
The issue of plant operation while continuing construction (addition of modules and installation of centrifuge' cascades) was again raised.
LES suggested that completion of feed and product areas, but not centrifuge 4
cascades, might constitute "substantially complete" for the purpose of 10 CFR part 50.56, inasmuch as LES does not consider the cascades to be safety-related.
The NRC staff indicated that this suggestion did not appear to be reasonable, and Robert Fonner said that the staff must continue to consider the requirement and LES' plan for adding eouipment during operation.
LES asked if, under i
one-step licensing, such as a combined construction permit and operating license proceeding, a physical Security plan and a Material Control and Accounting plan need to be submitted with the initial application, Philip Ting advised LES that it was only necessary that such plans be submitted one year prior to receipt of licensed material, and that a commitment to have the plans in accordance with NRC performance criteria be included with the initial application.
However, fonner said that the plans might be necessary in connection with an adjudicatory hearing if there were safeguards issues to be litigated.
Lois Telford reported that additional personnel security clearances had been apprwnd or certified for employees of Urenco. Duke, and Fluor Daniel, and th6t a facility approval for Fluor Daniel had been approved.
However, she asked that LES designatp a central contact for the receipt of classified documents by the LES Hrtners.
For unclassified correspondence, the LES central contact will continue to be Dr. Arnold, with copies to peter leRoy.
NRC central correspondence contacts will continue to be Donald J. Kasun for safeguards, Raymond J. Brady for security, and Charles J. Haughney for safety, environmental, and project licensing management.
Myron Kratzer described the plan for shipment and importation of classified centrifuge components into the United States.
He said there would be weekly shipments of several containers of centrifuge components over a period of two No complete centrifuge maghine would comprise a shipment, and or more years.
at least one ship's officer would be cleared to permit custody of the components.
Procedures for clearance through Customs and storage prior to release for transport to the plant site were uncertain at this time.
Telford said that she would discuss this issue with Customs at a July meeting on classification.
Kratzer understood that ptotection of the centrifuCes in transit to the plant site by cleared persons would be required, and that Urenco intends to use the services of a company that can provide such protection.
Charles J. Haughney 3
May 15, 1990-The NRC staff reminded LES about its need te address the issue of UF tails i
6 disposition in the license application from the standpoints of waste management, environmental impact, and decommissioning, including financial assurance, i
Marcus Rowden described his expectation of LES' application for and NRC's issuance of a combined construction permit and operating license pursuant to 10 CFR Part 50 and his experience in developing a progra:" of inspections, tests, analyses, and acceptance criteria to demonstrate licensing readiness for l
Part 52 licensing.
While this program is designed for nuclear reactors, some of the concepts may be useful in the LES project. The attendees agreed that a single, combined license could be managed, and the NRC staff had advised the i
Commission that it will recommend such an approach to the Commission.-in connection with publication of a Federal Register notice on the license application.
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LES described its plan of system information development for the license application, including ITAAC (inspections, tests, analyses, and acceptance criteria) as previously mentioned by Rowden.
Most of the discussion centered on the matrix of systems, including safety /0A claises agd the information that would be provided for each syt. tem. Classifying only UF feed and product liquid sampling systems as class I may be supportable, but additional information, particularly piping and instrumentation drawings, would be necessary for L
systems with interfaces with class 1 systems and for other systems which might a
affect class I systems. The NRC staff asked LES whether it had performed natural phenomena-based accident analyses to determine that class I protection should be provided for the designated systems.
LES said that it had, and that it did not plan to perform further analyses to determine the effects of accidents beyond design bases. This may be supportable also; however, the staff pointed out that the matter could be raised in connection with an adjudicatory hearing.
Mr. Rowden asked what action had been taken on a draft licensing basis document that Urenco, Inc., had left with the NRC staff several years ago.
The staff said that it considered the general design criteria, other information contained in the 1988 Advance Notice of Proposed Rulemaking, and Regulatory Guides as providing the necessary licensing basis for uranium enrichment plants.
Nevertheless, LES is interested in pursuing further the concept of a licensing b.ssis document, and plans to send an updated version of its document by the end_-
of May, 1990.
No date was set for another meeting with LES.
Original Signed By Peter Loysen, licensing Project Manager Advanced Fuel and Special Facilities Section Fuel Cycle Safety Branch Division of Industrial and Medical Nuclear Safety, NMSS
Enclosure:
List of Attendees bec: M. McDaniel, LADEQ PL/ LOUIS 1ANA Distribution: Project M-46:PDR NRC File Center Meeting Attendees IMSB R/F IMIF R/F NMSS R/F"
,1Becker, OGC TCombs RFonner, OGC BBordenick, OGC CNilsen WFisher, RIV DKasun, SG PTing, SG RBrady, SEC JSwift PLoysen RHurt GComfort FBrown DGarrison, RIV
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0FFICIAL RECORD COPY
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t.0VISTANA ENERGY SERVICES Meeting, May 3, 1990 ATTENDEES Name Affiliation W. 1.ambe USNRC-NRR Gary Comfort USNRC-NMSS/IMNS Jack Spraul NRC-0A Howard Arnold LES J.B. Knotts Bishop, Cook, et al.
A. Lynn Silvious NRC/ Security Robert L. Fonner NRC/0GC Joanna M. Becker NRC/0GC Peter G. LeRoy-LES/DESS Charles J. Haughney NRC/NMS$
Peter Loysen NRC/NMSS D. L. Garrison NRC/RlY lois Telford NRC/SEC Chuck Nilsen NRC/RES Hans Schecter GPA/IP Patty Jehle NRC/0GC Mike Finkelstein NRC/0GC Joanna M. Becker NRC/0GC Dick Belprez Fluor Daniel Erich Kraska Urenco Jesse B. Swords Duke Engineering Myron Kratzer Urenco Joseph DiStefano Urenco/LES Marcus Rowden Fried Frank, et al.
Philip Ting NRC/NMSS J