ML20262H070
| ML20262H070 | |
| Person / Time | |
|---|---|
| Site: | 07003103 |
| Issue date: | 09/08/2020 |
| From: | Cowne S Louisiana Energy Services, URENCO USA |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| LAR-20-01, LES-20-00074-NRC | |
| Download: ML20262H070 (10) | |
Text
SEP O 8 2020 LES-20-0007 4-NRC Attn: Document Control Desk Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Louisiana Energy Services, LLC NRC Docket No. 70-3103
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Subject:
License Amendment Request revising Quality Program Requirements for Redundant IROFS (LAR-20-01)
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ac The National Enrichment Facility
References:
- 1) LES-16-00178-NRC, License Amendment Request 16-06, Change to Classification of Administrative Control lROFS and Quality Level Requirements, dated March 8, 2017.
- 2) LES-18-027-NRC, Withdrawal of License Amendment Request LAR-16-06, February 22, 2018.
Pursuant to the requirements of SNM-2010, Condition 30, Section 19 of the UUSA Quality Assurance Program Description and in accordance with 10 CFR 70.34, Louisiana Energy Services, LLC (LES), dba URENCO USA (UUSA), hereby requests an amendment to Material License SNM-2010.
The proposed amendment creates a new Quality Level, QL-2R, to be applied to Redundant IROFS administrative control equipment. A similar graded approach was attempted previously in Reference 1, which was later withdrawn in Reference 2 as UUSA recognized the proposed regulatory requirements were not clearly defined. provides an affidavit whereby UUSA considers the information provided in as Sensitive Unclassified Non-Safeguards Information (SUNSI), and requests that the information be withheld from public disclosure in accordance with 10 CFR 2.390 and the guidance described in RIS 2005-31, Attachment 2, Appendix 1. provides a description and analysis of the proposed change, basis for the change, and safety significance of the proposed change. Enclosure 3 provides the pages of the License Basis Documents proposed to be revised with the changes annotated on the pages.
If you have any questions regarding this License Amendment Request, you may contact Wyatt Padgett, Licensing and Performance Assessment Manager, at 575-394-5257.
~i~
Chief Nuclear Officer
Enclosures:
- 1) Affidavit
- 2) Description of Proposed Changes (LAR-20-01)
- 3) Markup Pages to the Licensing Basis Document
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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: via email Damaris Marcano, Fuel Facility Licensing Branch Chief U.S. Nuclear Regulatory Commission Office of Nuclear Material Safety and Safeguards Damaris.Marcano@nrc.gov Robert Williams, Chief - Region II Projects Branch I U.S. Nuclear Regulatory Commission Robert.Williams@NRC.gov Karl Sturzebecher Project Manager U.S. Nuclear Regulatory Commission Karl.Sturzebecher@NRC.gov Brannen Adkins Senior Fuel Facility Inspector U.S. Nuclear Regulatory Commission, Region II Brannen.Adkins@nrc.gov
ENCLOSURE i Affidavit I, Stephen Coll'me, beir,g duly swom, state that I am the Chief Nuclear Officer for Louisiana Energ9 Servic.es (ll=S), dba URENCO USA (UUSA); that l am authorized on the part of satd company to sign and file wlth the Nuclear Regulatory Commission (NRG) this document and that an statements made and matters.setforth herein are true and correct tot.he best ofmy knowledge, inforfl'.latlon, ano belief:
'L LE$ wishes to tiave wit~he.ld from put;?!ic disclosure the foHowing document LES-20-00014-NRC Enclosure 3, Markwp Pages to the Ucensirig Basis Documents (ISA Summary only}
- 2. The informati.on contained in the documents cited above for which exemption frompubUy.
disclosure is requested iS t) proprietary inforrhation re!atectto commercial aspects of the URENCO USA Facility and 2} security related information. LES request$ that the proprietary and Sensitive Undassmect Ncm-Safeguards !nf<mnation (SUNS!} be exempt from disclosure pursuantto the provisions in rn CFR Part 2,390(a)(4).
3, Public disclosure ofthe. information in the above enciosure to this submittal has the potenUai to resuJt in substantial harm to. the competitive position of LES, provide vah.mble
,.. bllsin!!;!ss information to competitors of LES which they could duplicate without having to
,, ;;j~xpE:Jnd their own resources to develop, and reduce or foreclose the availability of profit
- .***'::opportunities.
4: J~linforrnation stated in this affidavit has been subn,itted in accordance with the t:,ppllc.lb!e parts of 10 CFR 2.390. the guidance contained in NUREG~1556, VoL 20,
... /App,fridixCA and t11e guid,;1nce from NRC RIS.*2005~31. Attachment 2, Appendix 1 (Fuel
< CYc!e, Faciilty Reviews).
- 5. The information sought to be wlthhekl is not in the public domain, to the best of LE~:i's Rnow!edg~ and belief.
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LES-20-0007 4-NRC ENCLOSURE 2 UUSA Quality Program Requirements for Redundant IROFS License Amendment Request (LAR-20-01) 1 tntroduction This change proposes to modify the Safety Analysis Report (SAR), Quality Assurance Program Description (QAPD) and the Integrated Safety Analysis Summary (ISAS) to define a new class of Items Relied On For Safety (IROFS). The new class, Redundant IROFS, is defined as more than one IROFS that is able to prevent or mitigate an accident scenario independent of each other to meet the performance requirements of
UUSA has three types of IROFS: Passive Engineered Controls, Active Engineered Controls and Administrative Controls (AC). A new Quality Program was developed for Redundant AC IROFS, which will be required to meet Quality Level 2R (QL-2R) requirements. Redundant AC IROFS allow the facility to be placed into a conservatively lower risk regime.
The new Quality Program is only for equipment associated with Redundant AC IROFS.
Active Engineered Controls, Passive Engineered Controls and Administrative Controls that are either Sole of Multiple IROFS will still be required to adhere to their respective Quality Levels and requirements. The revised requirements will allow more flexibility when identifying IROFS to allow more IROFS to be applied to existing accident
- scenarios. For IROFS that are Redundant, the Quality Level Program for the equipment is being changed from QL-2AC to QL-2R. The new quality program meets the requirements of 10 CFR 70.22(f) and the programmatic elements follow the structure of 10 CFR 50 Appendix B.
2 Background
A Sole Item Relied on for Safety (IROFS) is a single item, or feature, that is relied upon to prevent or mitigate an accident for which the consequences could exceed the performance requirements in 10 CFR 70.61. It is acceptable to rely on Sole IROFS, because these IROFS reliably provide sufficient prevention or mitigation features to ensure that the associated accident sequence results in an acceptable risk. However, Sole IROFS are undesirable as they become the only control for mitigating or preventing an accident. The failure probabilities of Sole IROFS are typically higher than the cumulative failure probabilities of multiple IROFS. While IROFS are maintained to be available and reliable when needed, failures are expected. Failures are predicted by means of the failure probability index number.
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LES-20-0007 4-NRC URENCO recognizes that reducing reliance on Sole IROFS is advantageous to the public, the NRC and URENCO. URENCO has made changes to the ISA in the past to remove the reliance on sole IROFS and continues to make improvements. When possible, it is desirable to create Multiple IROFS and if possible Redundant IROFS.
- Redundant IROFS make it possible to meet the performance requirements of 10 CFR 70.61 when other IROFS, or sets of IROFS, have been found degraded. URENCO is defining a Redundant IROFS as an IROFS which is capable of preventing, or mitigating, the consequences associated with the applicable accident scenario in its entirety, and its existence is unnecessary to meet the performance requirements of 10 CFR 70.61 as other IROFS are capable of meeting the performance requirements of 10 CFR 70.61 independently.
The new Quality Program, QL-2R, is being proposed only for a subclass of Redundant IROFS, Redundant AC IROFS. Active Engineered Controls, Passive Engineered Controls, Administrative Controls that are either Sole or Multiple will still be required to adhere to their respective Quality Levels and requirements. Currently UUSA has implemented numerous graded quality programs for IROFS. QL-1G is applied exclusively to Passive Engineering IROFS27e. QL 1-F is applied exclusively to fire protection IROFS and currently to Passive Engineered IROFS35. QL-2AC is applied exclusively to Support Equipment for Administrative Control lROFS and QL-1 is applied to the remaining IROFS.
Note: The performance of all Administrative Control IROFS has been and will remain QL-1. The programs QL-2AC and QL-2R are for the equipment associated with the performance of such IROFS.
J Proposed Change 3.1 Summary of Proposed Change The proposed changes require modifications to the ISA Summary, QAPD and SAR to incorporate the new requirements. No new IROFS have been identified for inclusion in the Licensing Basis Documents (LBD). At such time a new IROFS is identified as Redundant, UUSA will be able to incorporate the IROFS into the LBDs under its change authority through 10 CFR 70. 72, or with an amendment in accordance with 10 CFR 70.34.
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LES-20-0007 4-N RC 3.2 Modification to Integrated Safety Analysis Summary 3.2.1 ISA Summary Section 3.1, General Integrated Safety Analysis Information
& Section 3.8.1 IROFS Changes to terminology are being made so that Redundant IROFS can be defined.
Changes to the Classes of IROFS are being made to create the new class of IROFS, "Redundant."
Changes to Table 3.8-1, Items Relied on for Safety, is being modified to show the notation of Redundant that will be used in the future.
3.3 Modification to Safety Analysis Report 3.3.1 SAR Section 3.2.6, Risk Index Evaluation Summary, Section 3.4.34, Batch Transfers, Section 3.4.38, IROFS will Comply with Design Requirements,
& Table 3.1.10, Failure Probability Index Numbers There are many necessary administrative changes needed to the LBDs to allow this new approach as the word "Redundant" has been used interchangeably with "Multiple".
Redundant and Multiple are being clearly defined in the SAR and modifications to the LBDs are being made to reflect this change.
3.3.2 SAR Section 3.4.44, Administrative Control IROFS Support Equipment &
Table 3.4.1, Administrative Control IROFS Support Equipment Changes are being made to allow for the equipment used for Redundant Administrative IROFS to exist as Other Equipment. Additionally, a placeholder is being made to Table 3.4-1 to allow for the inclusion of a Redundant IROFS.
3.3.3 SAR Section 3.4.45, IROFS Class Classes of IROFS are being defined to delineate what Redundant IROFS are and their differences from multiple IROFS.
3.3.4 SAR Section 11.8, Other QA Elements Classes are being made to reflect consistent terminology and describe QL-2R as being part of the UUSA management measures.
3.4 Modification to Quality Assurance Program Description 3.4.1 QAPD Section 1, Organization, Section 2, Quality Assurance Program, Section 18, Audits, Section 20, Quality Assurance Program for Quality Assurance Level 2, & Section 22, Quality Assurance Program for Quality Assurance Level 2AC Numerous changes to terminology are being made to include the new QL-2R.
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LES-20-0007 4-NRC 3.4.2 QAPD Section 2, Quality Assurance Program, & Section 24, Quality Assurance Program for Quality Assurance Level 2R Changes are being made to introduce the new Quality Level proposed. The criterion utilized follow the structure of ASME NQA-1 and 10 CFR 50 Appendix B, but do not commit to the standard or regulation.
- 1) Organization
- 2) Quality Assurance Program
- 3) Design Control
- 4) Procurement Document Control
- 5) Instructions, Procedures, and Drawings
- 6) Document Control
- 7) Control of Purchased Material, Equipment, and Services
- 8) Identification and Control of Materials, Parts, and Components
- 9) Control of Special Processes
- 10) Inspection
- 11) Test Control
- 12) Control of Measuring and Test Equipment
- 13) Handling, Storage and Shipping
- 14) Inspection, Test, and Operating Status
- 15) Nonconforming Items
- 16) Corrective Action
- 17) Quality Assurance Records
- 18) Audits 4 Safety Significance, Technical Basis and Impact of Change Redundant AC IROFS equipment will be designated as QL-2R, while the safety function of the IROFS will still remain QL-1. UUSA Management Measures will apply to Redundant AC IROFS to ensure they are available and reliable to perform their required functions when needed. No change is being proposed for Passive Engineered Controls, Active Engineered Controls, or Non-Redundant Administrative Controls.
A Redundant IROFS is being defined as an IROFS, which is capable of preventing or
-mitigating the consequences associated with the applicable accident scenario and its existence is unnecessary to meet the performance requirements of 10 CFR 70.61 as
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other IROFS are capable of meeting the performance requirements of 10 CFR 70.61 independently. This graded approach to the requirements allows URENCO to implement IROFS providing a conservatively lower risk for accident scenarios where difficulties in implementing controls exist. This in turn provides better protection for the worker and public and reduces the number of Sole IROFS implemented at the facility.
The NRG has previously approved graded quality programs for UUSA. For fire protection engineered IROFS, the NRG has previously approved QL-1 F. For structural IROFS, the NRG has previously approved QL-1G. For Administrative Control Support Equipment, the NRG has previously approved QL-2AC. The graded requirements approach for these scenarios has proven effective in maintaining the health and safety Page 7 of 11
LES-20-0007 4-NRC of the workers and public. The proposed Quality Level QL-2R, reduces requirements from that currently required for QL-2AC. The following Table identifies the changes:
NQA-1 Criterion QL-2AC QL-2R Organization Defined No Change Quality Assurance Program Defined No Change Design Control Defined, similar to QL-3 No Change Procurement Document Control Defined, similar to QL-3 No Change Instructions, Procedures, and Defined No Change Drawings Document Control Defined, requires use of QL-No Change 1 program Control of Purchased Material, Defined No Change Equipment, and Services Identification and Control of Defined No Change Materials, Parts, and Components Control of Special Processes N/A to QL-2AC No Change Inspection Defined N/A to QL-2R Test Control Defined N/A to QL-2R Control of Measuring and Test Defined, similar to QL-1 Defined, similar to QL-3 Equipment Handling, Storage and Shipping Defined No Change Inspection, Test, and Operating Defined Defined, similar to QL-3 Status Nonconforming Items Defined, requires use of QL-No Change 1 program Corrective Action Defined, requires use of QL-No Change 1 program Quality Assurance Records Defined, requires use of QL-No Change 1 program Audits Defined, requires use of QL-No Change 1 program Minimal changes are being made in the applicable requirements and UUSA considered NRC feedback in the selection of the criteria specified. The quality program applied is appropriate and ensures that the identified IROFS will remain available and reliable to perform their functions when needed.
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LES-20-0007 4-NRC With the requirements change, the facility has more flexibility in applying a Redundant Administrative Control lROFS rather than a Sole Administrative Control. These changes improve the risk regime for the facility.
5 Implementation As stated previously no new IROFS have been identified for inclusion in the Licensing Basis Documents. At such time that a new IROFS is identified as Redundant, UUSA will be able to incorporate the IROFS into the LBDs under our change authority through 10 CFR 70.72. At that time the Quality Program may be reduced and the IROFS would be listed as Type "R", but only if the IROFS is Redundant for all applicable accident sequences.
Upon approval UUSA will undertake efforts to identify new IROFS for accident scenarios. While UUSA will focus on scenarios that have sole enhanced administrative control lROFS, the flexibility this graded approach allows will be considered for all accident scenarios. Currently, the following accident sequences have sole administrative enhanced IROFS: 1) Moderation control in 30B cylinder accident sequences 2) Fire Accident Sequences where combustible loading is used, 3) Chemical accident sequences where worker evacuation is used and 4) Over-enrichment accident scenarios.
6 Environmental Considerations On the basis of 10 CFR 51.22(c)(11 ), UUSA claims categorical exclusion thereby obviating an environmental review of this LAR. Additionally, there are no environmental impacts associated with the changes proposed in this LAR. The proposed changes do not meet the criteria in 10 CFR 51.60(b)(2), since they do not involve a significant expansion of the site, a significant change in the types of effluents, a significant increase in the amounts of effluents, a significant increase in individual or cumulative occupational radiation exposure, or a significant increase in the potential for or consequences from radiological accidents. Consequently, a separate supplement to the Environmental Report is not being submitted.
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LES-20-0007 4-NRC 7 Conclusions UUSA is seeking a graded quality assurance program so that flexibility in the selection of IROFS can improve the overall risk prevention and mitigation for the facility. The quality program applied is appropriate and ensures that the identified IROFS will remain available and reliable to perform their functions when needed. The new quality program meets the requirements of 10 CFR 70.22(f) and the programmatic elements follow the structure of 10 CFR 50 Appendix B.
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