ML20245E177
| ML20245E177 | |
| Person / Time | |
|---|---|
| Site: | 07000004 |
| Issue date: | 09/11/2020 |
| From: | Office of Nuclear Material Safety and Safeguards |
| To: | American Centrifuge Operating |
| Faraz Y | |
| Shared Package | |
| ML20245E173 | List: |
| References | |
| Download: ML20245E177 (5) | |
Text
REQUEST FOR ADDITIONAL INFORMATION AMERICAN CENTRIFUGE OPERATING, LLC, AMERICAN CENTRIFUGE PLANT LICENSE AMENDMENT REQUEST - HIGH ASSAY LOW-ENRICHED URANIUM (HALEU)
DEMONSTRATION PROGRAM Chapter 4 Radiation Protection
- 1. Qualification of the Radiation Protection Manager (RPM)/Supervisor Title 10 to the Code of Federal Regulations 70.22(a)(6) requires licensees to be appropriately qualified. Regulatory guide (RG) 1.8, Revision 4, Qualification and Training of Personnel for Nuclear Power Plants recommends the NRC staffs minimum qualification necessary to ensure that assigned personnel can independently evaluate risks and safely execute the responsibilities associated with their positions. This includes the need for individuals with no prior Radiation Protection Manager (RPM) experience to have 6 months of time onsite before being assigned RPM duties.
Section 2.1.2.4.2, Radiation Protection Manager / Supervisor of the license application removes the previous commitment for the RPM/Supervisor to have at least 6 months of time onsite before being assigned RPM duties.
Restore the commitment for the RPM/Supervisor to have at least 6 months of experience at a uranium processing plant before assuming the management position or provide an equivalent commitment consistent with RG 1.8.
- 2. Personnel Monitoring Program Title 10 to the Code of Federal Regulations 70.22(a)(8) requires licensees to have the appropriate procedures to, protect health and minimize danger to life or property. In addition, 10 CFR 20.1101, Radiation protection programs, requires licensees to use sound radiation protection principles to achieve occupational doses and doses to members of the public that are as low as is reasonably achievable (ALARA). The guidance in NUREG-1520, Section 4.4.7.3, Regulatory Acceptance Criteria, sub-bullet three indicates the personnel monitoring program should include administrative limits. The 10 CFR 20.1502, Conditions requiring individual monitoring of external and internal occupational dose, requires appropriate monitoring of personnel.
The proposed revision to Section 4.7.2, Personnel Monitoring, of the license application replaces the sentence, The established personnel monitoring program consists of the following: with the alternative text, A personnel monitoring program can include the following as determined by the RPM. This proposed change eliminates the commitment to implement the five bullets that follow this statement and makes them optional, contingent on the radiation protection manager (RPM). Making administrative dose limits, personnel dosimetry, and dose records optional does not appear consistent with the regulations.
Modify the proposed text in the license application Section 4.7.2 to establish that the bulleted items in that section are required, and not subject to removal or decrease by the RPM. This could be accomplished by restoring the original text. Clarify that ACO provides a commitment to maintain a baseline level of personal monitoring that includes administrative exposure limits, 1 Enclosure 2
personnel dosimetry, and dose records.
- 3. Neutron Dose Measurements Title 10 to the Code of Federal Regulations 70.9, Completeness and accuracy of information, Section (a) requires that information submitted to the NRC staff be complete and accurate.
3.1 The license application Section 4.7.2, Personnel Monitoring states that, the ACP maintains onsite capability to determine neutron flux and energy. Table 4.8-2, Radiological Protection Instrumentation and Capabilities, removes instruments specifically designed to measure neutron dose or dose rate.
Clarify if the neutron dose monitoring is done solely through dosimetry. Clarify what measuring devices are used to, maintain onsite capability to determine neutron flux and energy, and confirm the accuracy of Table 4.8-2. Confirm that the statements regarding neutron monitoring in Section 4.7.2 and Table 4.8-2 are not contradictory.
3.2 Section 4.6.1, Ventilation, the first sentence references gulpers as a device independent of the ventilation system. This term and its use as part of the ventilation system are not well defined in Chapter 4.
Provide a cross-reference to the description of gulpers in the ISA Summary, (e.g., Section 3.8.2), or any other relevant cross-reference.
Chapter 6 Chemical Safety
- 1. Use of Threshold Quantities when Evaluating Chemical Hazards in the ISA Title 10 to the Code of Federal Regulations 70.62 calls for applicants to conduct an integrated safety analysis that includes consideration of (1) chemical hazards of licensed material and hazardous chemicals produced from licensed material, and (2) facility hazards that could affect the safety of licensed materials and thus present an increased radiological risk. This language is consistent with the NRC-OSHA memorandum of understanding (MOU) which identifies NRC and OSHA regulatory responsibilities (ADAMS Accession No. ML11354A432). Neither 10 CFR Part 70 nor the MOU identifies any threshold quantities in the definition of NRCs regulatory responsibility.
Section 3.1.2.3.1.3.1 of the license application discusses eliminating a chemical hazard from the ISA consideration if the inventory is below the OSHA or EPA threshold quantity. The OSHA and EPA threshold standards do not apply to chemical hazards under NRCs regulatory authority (i.e., chemical hazard generated from licensed material operations or an accident sequence involving the chemical hazard could result in a reduction of the ability of plant personnel to control licensed material operations, and thereby protect the public).
Provide justification for the ISA methodologys elimination of the analysis of chemical hazards under NRCs regulatory jurisdiction if the inventory is below the OSHA or EPA threshold standards.
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Chapter 7 Fire Safety
- 1. National Fire Protection Association Codes Title 10 to the Code of Federal Regulations 70.22(a)(7) requires the applicant to provide a description of equipment and facilities that will be used by the applicant to protect health and minimize danger to life or property. Section 7.4.3 of NUREG-1520 states that the NRC reviewer will use national recognized codes and standards (including NFPA codes) when evaluating the fire safety program. This information is necessary to determine if the applicant has demonstrated an adequate level of fire safety.
Table 7.1-1 of the license application lists all National Fire Protection Association (NFPA) codes applicable to the ACP. Provide clarification on whether or not ACO intends to meet all aspects of the codes listed. For example, NFPA 801, Standard for Fire Protection for Facilities Handling Radioactive Materials (NFPA, 2020) has guidelines for performing a Fire Hazards Analysis (FHA), but the license application does not mention in Section 7.2, Fire Hazards Analysis this particular NFPA code.
- 2. Emergency Response Title 10 to the Code of Federal Regulations 70.22(a)(7) requires the applicant to provide a description of equipment and facilities that will be used by the applicant to protect health and minimize danger to life or property. Additionally, the provisions of 10 CFR 70.22(a)(8) require the applicant to provide proposed procedures to protect health and minimize danger to life and property. Section 7.4.3.5 of NUREG-1520 states that the applicant should document the fire emergency response organizations for licensed facilities.
Section 7.1.3 of the license application describes the emergency response organization.
However, the licensee has not provided adequate information about the qualified responder that will perform the fire protection functions. Provide information about who this qualified responder is, their location, and any memoranda of agreement (MOA) that exist between the applicant and the qualified responder. This information is necessary to determine if the emergency responder is sufficiently close to the site and has adequate staffing, training, and equipment to respond in the event of a fire emergency.
Chapter 11 Management Measures and QAP
- 1. Software Design Control Title 10 to the Code of Federal Regulations 70.62(d) requires establishment of management measures to ensure compliance with the performance requirements of 10 CFR 70.61. The definition of Items Relied on for Safety in 10 CFR 70.4 includes systems, which could include software, firmware, microcode, Programmable Logic Controllers, and/or any digital device, that are relied on to prevent potential accidents at a facility that could exceed the performance requirements in 10 CFR 70.61 or to mitigate their potential consequences.
Section 3.0 of the Quality Assurance Program Description (QAPD), Section 1.4.3.D of the license application, and proposed Condition 19.a of NRCs Materials License contains the updated references to ASME NQA-1-2008 and NQA-1a-2009 for software design control from ASME NQA-1-1994. The proposed reference information includes Part I, Requirement 11 Test Control and Part II, Subpart 2.7, Quality Assurance Requirements for Computer Software for 3
Nuclear Facility Applications. However, the licensee did not include all the applicable software design control requirements included in ASME NQA-1-2008 and ASME NQA-1a-2009, which now includes Part I, Requirement 3, Section 800 Software Design Control. Software design control requirements are now contained in Section 800 of Part I, Requirement 3 while Subpart 2.7 in Part II now provides the work practice requirements to implement those software design control requirements in Part I, Requirement 3, Section 800. Provide the additional reference information needed to encompass all the applicable software design control requirements to update the three locations where this reference information is found in this amendment request, or justify for not including it. The requested information is required to assess compliance against 10 CFR 70.62(d).
- 2. Toxic Chemical Emergency Response Procedure Training Title 10 to the Code of Federal Regulations 70.62(d) requires establishment of management measures, which includes training, to ensure compliance with the performance requirements of 10 CFR 70.61.
Sections 11.3.1.6.1 and 11.3.1.6.2 of the license application provides requirements for operations technician and operations shift supervisor training respectively and includes the deletion of training on required emergency operating procedures, which was replaced by alarm response operating procedures. However, Section 11.4.9 requires emergency procedures for toxic chemical releases as a topic to be covered in procedures separate from alarm response procedures. Provide a reference to the training requirement in the license application for an operations technician and operations shift supervisor on the required emergency procedure for toxic chemical releases or add it to the application. The requested information is required to assess the reasonableness of the management measures as required by 10 CFR 70.62(d).
- 3. Personnel Training Limitations Title 10 to the Code of Federal Regulations 70.62(d) requires establishment of management measures, which includes training, to ensure compliance with the performance requirements of 10 CFR 70.61.
Section 1.2 of the QAPD and Section 11.2.1 of the license application contains additional language to the responsibilities for the maintenance work center supervisor. Specifically, personnel training limitations was added with respect to the maintenance work center supervisors direction of activity to provide support services on facilities and equipment within approved personnel training limitations. Clarify what personnel training limitations are being referred to with this new qualification. For example, does this include approved support services by personnel who are not trained in the support area but perform the work with a special approval and/or justification, or simply support services that are only conducted within the scope of the training the personnel receive. The requested information is required to assess the reasonableness of the management measures as required by 10 CFR 70.62(d).
- 4. Calibration of Stop Watches Title 10 to the Code of Federal Regulations 70.62(d) requires establishment of management measures to ensure compliance with the performance requirements of 10 CFR 70.61. The definition of Items Relied on for Safety in 10 CFR 70.4 includes equipment and components that are relied on to prevent potential accidents at a facility that could exceed the performance requirements in 10 CFR 70.61 or to mitigate their potential consequences.
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Section 12.0 of the QAPD contains additional language for equipment where calibration control is not necessary, specifically for stop watches. However, ASME NQA-1-2008, Requirement 12, Control of Measuring and Test Equipment, does not include stop watches as an example of commercial equipment that does not require calibration and control measures. Provide justification for why stop watches do not need calibration control for the Centrus American Centrifuge Plant facility, or remove that as an example. The requested information is required to assess the reasonableness of the management measures as required by 10 CFR 70.62(d).
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