ML20058B135
| ML20058B135 | |
| Person / Time | |
|---|---|
| Site: | Claiborne |
| Issue date: | 11/18/1993 |
| From: | Jim Hickey NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Leroy P LOUISIANA ENERGY SERVICES |
| References | |
| NUDOCS 9312010412 | |
| Download: ML20058B135 (12) | |
Text
Docket No. 70-30'0 l
Mr. Peter G. LeRoy N0l/ J g 7933 Licensing Manager Louisiana Energy Services, L.P.
i c/o Duke Engineering Services, Inc.
P.O. Box 1004 Charlotte, NC 28201-1004 I
Dear Mr. LeRoy:
This is followup to our o?en meeting on November 15, 1993, when we discussed the proposed product sampiing autoclaves for the LES Claiborne Enrichment Center.
In the meeting, we discussed the lack of final design details on the autoclaves in your current submittals, and asked technical questions in order to determine whether additional information was needed.
You answered our questions, and explained you view that LES has submitted a complete set of specifications for the autoclives which demonstrate compliance with NRC safety requirements.
You took the position that NRC should be able to proceed with licensing based on the current submittals, and, as appropriate, confirm adequate safety of the autoclaves as part of the required preoperational inspection process.
You compared this approach to that provided in 10 CFR Part 52 for reactors.
You also expressed concern that LES should have some flexibility on final design details prior to construction, as long as safety was not affected.
Upon review, we agree that the specifications and other information submitted on the autoclaves provide an adequate basis for the NRC staff to make the necessary safety findings and proceed with issuance of its Safety Evaluation Report.
Copies of the proposed agenda, slides which you presented at the meeting, and a list of attendees are enclosed.
Also, it is our understanding that you will respond to our November 10 letter, which requested revisions to your proposed license conditions and associated sections of your Safety Analyis Report, by December 3,1993.
If you have questions, please contact Dr. Lidia Roche' at 301-504-2695.
Sincerely, "Wird Signcd Dy John W. N. Hickey, Chief Enrichment Branch Division of Fuel Cycle Safety cc:
Attached list and Safeguards, NMSS
Enclosures:
As stated Distribution: Docket 70-3070 PDR/LPDR AGiarratana RFonner, OGC
<NRC' File Center
- CNilsen, RES JSpraul, HLPD FCEB r/f RBrady, SEC DJoy EHoller YChen 0FC FCEB h FCJIL FCib FCEB FCEB LRoche/ijk h4N Jbckey NAME j,
\\[G DATE
'/ //h' /93
// ////93
/// ///93
/
/93
/
/93 C = COVER E = COVER & ENCLOSURE N = NO COPY OFFICIAL PECORD COPY FBPA8ss L6ai87o RFaC HE CBM MY C
Docket No. 70-3070 Mr. Peter G. LeRoy NOV 1 b i
Licensing Manager Louisiana Energy Services, L.P.
c/o Duke Engineering Services, Inc.
P.O. Box 1004 Charlotte, NC 28201-1004
Dear Mr. LeRoy:
This is followup to our open meeting on November 15, 1993, when we discussed the proposed product sampling autoclaves for the LES Claiborne Enrichment Center.
In the meeting, we discussed the lack of final design details on the autoclaves in your current submittals, and asked technical questions in order to determine whether additional information was needed.
You answered our questions, and explained your view that LES has submitted a complete set of specifications for the autoclaves which demonstrate compliance with NRC safety requirements.
You took the position tbat NRC should be able to proceed with licensing based on the current submittals, and, as appropriate, confirm adequate safety of the autoclaves as part of the required preoperational inspection process.
You compared this approach to that provided in 10 CFR Part 52 for reactors.
You also expressed concern that LES should have some flexibility on final design details prior to construction, as long as safety was not affected.
Upon review, we agree that the specifications and other information submitted on the autoclaves provide an adequate basis for the NRC staff to make the
(
necessary safety findings and proceed with issuance of its Safety Evaluation Report.
Copies of the proposed agenda, slides which you presented at the meeting, and a list of attendees are enclosed.
Also, it is our understanding that you will respond to our November 10 letter, which requested revisions to your proposed license conditions and associated sections of your Safety Analyis Report, by December 3,1993.
If you have questions, please contact Dr. Lidia Roths' at 301-504-2695.
Sincerely, Original Signed By John W. N. Hickey, Chief Enrichment Branch Division of fuel Cycle Safety cc: Attached list and Safeguards, NMSS
Enclosures:
As stated Distribution: Docket 70-3070 PDR/LPDR AGiarratana RFonner, 0GC NRC File Center CNilsen, RES JSpraul, HLPD FCEB r/f RBrady, SEC DJoy EHoller YChen h
FCEL FCG FCEB FCEB 0FC FCEB LRoche/ijk Nb Jbckey NAME
// ///93
/
/93
/
/93 DATE
//.( /93
- ////93
/
C = COVER E = COVER & ENCLOSURE N = NO COPY OFFICIAL RECORD COPY
. Louisiana Energy Services UF Sampilng Autoclaves g
Level of Design Detail Notice and Order 56 FR 23310 (May 21,1991) lll. Commission Order, Criteria for the issuance of a License
- 2. Invokes ANPR General Design Criteria L
1 I
i..........
Louisiana Energy Services UF Sampiing Autociaves
^
e Level of Design Detail ANPR 53 FR 13276 (April 22,1988)
General: " Provide design criteria and design bases" GDC 1:
Quality Standards - 10 CFR 50, Appendix B GDC 2:
Protection Against Environment - Seismic GDC 8:
Design Protect against exceeding release limits Use suitable analysis or test i
ANPR was prepared prior to 1-step' rules.
j 2
Louisiana Energy Services UF Sampling Autoclaves.
e Level of Design Detail l
L Ensuring Safety With a 1-Step License /
Level of Design Detail Required for a l
License CONSIDERATIONS:
NRC & Nuclear Industry Precedent Risk of LES Accident 3
Louisiana Energy Services UF Sampling Autoclaves g
Level of Design Detail
)
1 Precedent Advanced Reactors: Design Certification Process Requirements for Design Certification (SECY-90-377 -November 8,1990
- Commission Approval of Requirements (Memorandum) - February 15,'1991
- ABB-CE System 80+
i Draft SER (NUREG 1462, 9/92)
Final SER (to be issued November.
1993) 4
'l
Louisiana Energy Services UF Sampling Autoclaves e
Level of Design Detail Level of Design Detail and Confirmation Required for a License Level of Detail Notice and Order is silent.
R/G 3.25:
An application referencing a certified design must also demonstrate compliance FSAR must contain all technical with the interface requirements established information required by [Part 52] and for the design under s 52.47(a)(1), and describe in detail the final plant design, have available for audit procurement current site information, and final safety specifications and construction and analyses.
installation specifications in accordance with s 52.47(a)(2).
10 CFR f52.47(a)(2):
The information submitted for a design certification must include performance requirements and design information sufficiently detailed to permit the preparation of acceptance and inspection requirements by the NRC, and procurement specifications and construction and installation specifications by an applicant.
2/15/91 Commission Memo:
Statements of Consideration specify that an essentially complete design is a design that has been finalized to the point that procurement specifications and construction and installation specifications can be completed.
5
' Louisiana Energy Services UF Sampling Autoclaves e
Level of Design Detail Level of Design Detail and Confirmation Required for a License Confirmation Notice and Order 10 CFR 52.99 s
The license will be conditioned to permit After issuance of a combined license, the the production operation of a plant unit ' Commission shall ensure that the required-3 only after the staff has inspected the inspections, tests, and analyses are installation of all systems in a plant unit performed and, prior to operation of the essential for beginning the enrichment of facility, shall find that the prescribed i
uranium and has verified that the initial acceptance criteria are met.....At construction of the plant unit is in appropriate intervals during construction, j
accordance with the requirements of the the NRC staff shall publish in the Federal license. Inspection results shall Register notices of the successful subsequently be published in the Federal completion of inspections, tests, and
- Register, analyses.
I 1
6
Louisiana Enargy Servicos UF Sampling Autoclavos g
Level of Design Detail ALTERNATIVE PROPOSAL Proposal for LES Application Part 52 Perspective L
1.
Consider Actual Safety Risks are orders of Significance of magnitude below nuclear Sampling Autoclave power plants.
2.
Commit to Limits Comparable power plant Specified in equipment would require Procurement Spec no more than specification (sufficient to support info.
the NRC's finding) 3.
Incorporate Goes beyond Part 52 for Specification Limits comparable equipment.
into License Conditions 4.
Allow No Changes To Changes allowed per 50.59, Specification Limits with opportunity for hearings.
5.
NRC Verification NRC verification through Required by Notice &
ITAAC program.
Order 7
NRC. LES MEETING Monday, November 15,1993,1:00 pm EST One While Flint North, Room 4 E 9 PROPOSED AGENDA Meeting Topic:
Level of Design Detail for Tilting Autoclave 4
NRC 1.
Statement of Additional Information Needed
'NRC 2.
Cla.rification of Intent /Use j
To what extent will the requested design infomu. tion become specific n.
conditions of the CEC license?
2 To what extent is it proposed that LES can revise this design information af:er J
b.
receipt of the license..
i.
without a license amendment, 4
without prior NRC approval, ii.
using a 50.59-like change procedure (i.e, internal to LES but available iii.
for NRC audit)'
LES 3.
LES Response; Ra:ionale for Response a.
ANPR Requirements b.
NRC and Industry Precedent
- SECY 90-377,11-8-90 *
References:
- NRC Memo, 12-28 92
- Autoclave RAI History c.
d.
Alternative Proposal ALL 4 Discussion / Resolution of Issues Agreed Course of Action (Scope / Schedule - LES & NTC)
ALL 5.
NRC 6.
Conclusion i
- First sheet attached
- Q NRC ATTENDANCE SHEET f
NAME AFFILIATION TELEPHONE Lidia A. Rochs NRC/NMSS 301 504-2695 John Hickey NRC/NMSS 301 504-3328 Peter LeRoy LES 704 382-2834 Hugh Hammond LES 704 382-0795 Robert Burnett NRC/NMSS, Director 301 504-3365 John MacEvoy Winston & Strawn/LES 202 371-5769 Dan Martin NRC 301 504-2369 1
Joe Price SAIC 704 318-4620 John R. Stokley SAIC 703 318-4662 Gene Holler NRC/0GC 301 504-1520 Jack Spraul NRC/QA 301 504-2446 Yawar Faraz NRC/NMSS 301 504-2669 Jim Hammelman SAIC 703 318-4628 Richard Bachmann NRC/0GC 301 504-1574 j
By phone Fluor Daniel reps LES contractor 714 975-5897 Bill Griffin Harvey Wallskog Leslie Vaughn
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LES SERVICE LIST
- Dr. W. Howard Arnold Mr. Michael Mariotte President Executive Director Louisiana Energy Services Nuclear Information and 2600 Virginia Avenue, N.W.
Resource Service Suite 608 1424 16th Street, NW Washington, DC 20037 Suite 601 Washington, DC 20036 Mr. Peter G. LeRoy Licensing Manager Louisiana Energy Services i
c/o Duke Engineering & Services, Inc.
P.O. Box 1004 Charlotte, NC 28201-1004 Mr. J. Michael McGarry, Ill Winston & Strawn 1400 L Street, NW Washington, DC 20005 Mr. Ronald L. Wascom Deputy Assistant Secretary Office of Air Quality and Radiation Protection Louisiana Dept. of Environ. Quality P.O. Box 82135 Baton Rouge, LA 70884-2135 Ms. Diane Curran Harmon, Curran, Gallagher, &
Spielberg 2001 S Street, NW Suite 430 Washington, DC 20009-1125 Nathalie M. Walker, Esq.
Sierra Club Legal Defense Fund, Inc.
400 Magazine Street, Suite 401 New Orleans, LA 70130