ML20301A439

Enclosure 1 - Responses to Nrc'S Requests for Additional Information Related to the License Amendment Request for the High Assay Low Enriched Uranium Demonstration Program - License Application Chapters 4, 6, 7, and 11

ML20301A439
Person / Time
Site:	07007004
Issue date:	10/14/2020
From:	American Centrifuge Operating, Centrus Energy Corp
To:	Office of Nuclear Material Safety and Safeguards
References
ACO 20-0036, EPID L-2020-LLA-0085
Download: ML20301A439 (11)

Text

Enclosure 1 of ACO 20-0036 Responses to NRC's Reques*ts for A~ditional Info~ation Related to the License. Amendment Request for th~ High Assay Low Enriched Uranium Demonstration Program ....:.,

. . License Application'Chapters 4, 6,.7, and i1

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• Information Contained Within *

• Does Not Contain Export Controlled Information *.

Reviewmg Official #1014 Date* 10/14/2020

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Enclosure 1 ACO 20-0036

• Page 1 oflO_

REQUEST FOR ADDffiONAL INFORMATION AMERICAN CENTRIFUGE OPERATING, LLC, AMERICAN CENTRIFUGE PLANT LICENSE AMENDMENT ~QUEST - IDGH ASSAY LOW-ENRICHED.URANIUM

. . ,(HAL~U) DEMONSTRATION PROGRAM Chapter 4 Radiation Protection

1. Qualification ,of the Radiation Protection Manager (RPM)/Supenrisor Title 10 fu 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 staff's m.itiim~ qualification necessary to ensure that assigned personnel can independently t?Valuate risks and safely execute the responsibilities associated with their positions. This includes the neeq 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 peing assigned RPM dirties.

• Restore th~ com.nµtment for the RPM/Supervisor to have at least 6 months of experience at a uranium* processing plant before assuming tb,e management position or provide* an equivajent

. commitment consistent with RG 1.8.

ACO Response:

Up<;m request from NRC, . inc~uded experience requirement *for the -Radiation Prqtection Manager/Supervisor in accordance with RG :.18, Section 4.3 3. Revised License Application Section 2.1.2.4.2 to "The RPM/Supervisor has, as a minimu~ a bachelor's degree in engineering, health physics, RP*, or the physical sciences or equivalent technical exp¢ence, and four years experience m

. RP, including six months of prior Radiation Protection Manager/Supervisor experience at a nuclear facility."

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2. Personnel Monitoring Program '* .

. Title 10 to.the.Code *ofFederal Regulations 70.22(a)(8) requir~ licensees to have the appropriate

.. procedures to, "protect health and minimfae danger to life or property." In additio~ 10 CFR 20.1101,Radiation.protection programs,',' requires licensees to use "sound radiation protectiorr principles to achieve occupational doses and doses ~ membet:s of the public that 8:fe as low_~ is reasonably achievable (ALARA)." The guidance.in NUREG-1520, Section 4A.7.3, "Regulatory\

A~ptance Criteria,': sub-bullet three indicates the personnel monitoring program should inc~ude

• Enclosure 1 AC020-0036 Page2 oflO adnrinistrative limits. The I' 0 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 !)dministrative dose li.mits, personnel dosimetry, and dose records optional does not appear'

• consistent wit:4 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. T4is* could be accomplished by restoring the original text. Clarify that ACO provides a commitment to maintain a baseline level of personal monitoring, that includes* ~ v e exposure limits, personnel dosimetry, *and dose records. ,

• ACO Response:

Revised License Application Section 4.7.2, Personnel Monitoring'~, to ,replace, the proposed sentence.of"A personnel monitoring program can include the following as determined by the RPM

• and restore the. original text of "The established personnel monitoring program consists of the following:" to 'clarify- that ACO provides a commitment to maintain a baseline level of personal monitoring that includes administrative exposure limits, personnel dosimetry, and dose_records.

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3. Neutron Dose -

Measurements '

• ' Title 10 to, the Code ,of Federal Regulaµorzs 70.9, "Completeness and accur,acy 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 Itjstnimenfa#on and Capabilities," removes instn.up.ents 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 inori.itoririg in Section 4.7.2 and Table 4.8-2 are not contradictory. - ..

3.2 Section -4.6.1, Ventilation,,~ the first sentence 'referen~s "gulpers" as a device inqependent of the ventilation system. This term and its use as part of the ventilation*sy~m are*not yvell defined in Chapter 4. ,

• Enclosure 1 AC020-0036

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~vide a cross-reference to the description of gulpers in the ISA Summary, (e.g., Section 3 .8.2), or

• any other relevant cross-referen~.

ACO Response:

3.1 The 5th Bullet in Section 4. 7.2 reference the FNADs .used in response to a criticality event. The FNADs consist of a set of TLDs to prov~.de the dose and a set of activation foils that would be

• evaluated to determine neutron energies. The foils as well as biological material, such as blood or hair samples, collected after a criticality would be sent to a qualified laboratory for ~ysis, since Centrus does not currently have the eq~pment for this analysis. ACO contracts with the.U.S .

. Department of Energy (DOE) through its prime contractor to obtain laboratory support located on the Portsmouth Gaseous Diffusion Plant rese;rvation.

• While neutrons-are not expected for routine ~peratio~, ~ a best practice, n~utron dose* monitoring is performed solely through dosimetry. Quarterly personal dosimeters have a fourth 1LD-600 chip that is neutron sensitive. The personal nuclear accident dosimeter (known as PNAD) is the.Indium foil described in the last paragraph of Section 4.7.2. This foil can be evaluated with on-site handheld detectors to screen.personnel who may have been exposed to lffrads during a criticality ev~nt

• Table 4.8-2 will be modified to include the REM 500 and Teletector instruments. These instruments were deleted as part of the April 2020 submi:ttal; however, the ori~ text has been restored.

Routine use of these instruments is not expected during HALED; however,.they are included in the inventory of the Site Emergency Response organization. . . .

3.2 Gulpers are portable ventilation units designed to capture minor release of UF6 and reaction

• products and are used primarily during cylinder conn¥cts, disconnects, and system- openings -to minimize personnel exposure to ~ 6 and HE Gulpers are discussed in detail in Addendum 1 of the ISA Summary for the American Centrifuge Pl!:filt - HALED Demonstration Section 3 .8.2. Revised .

4.6.1 "Ventilation" tQ include the reference to Addendum Lofthe ISA Summary fot: the Ametj.cati Centrifuge Plant

Enclosure 1 ACO 20--0036

• Page4 oflO Chapter 6 cliemical Safety.

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1. Us.e of Threshold Quantities when Evaluating Chemical Hazards in. the ISA J

• Title 10 to the Code* of Federal Reguldtio~ 70.62 calls for applicru;its t~ c;c;nduct ah 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 niaterials and thus present an increased radiological risk. This ,language is consistent with the NRC-O~HA memorandum of understan_dmg (MOU) which.identifies NRC and OSHA regulatory responsibilitjes (.t\PAMS Accession No. ML11354A432). Neither 10 CFR Pl!,rt 70 nor the ¥OU identifies any threshold quantities in the definition ofNRC's regulatory responsibility.

Section. 3.1.2.3.1.3.1 of the license ~plication discusses eliminating a chemi~ hazard :fu)m 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 NRC's 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 methodology's e ~ o n of the analysis. of chemical liaz.ards under NRC' s regulatory jurisdiction if the inventory is below the OSHA or EPA threshold standards.

ACO Response:

The chemi~ screening criteria provided in Section 3~1.i.3.1.3.1 will be deleted.. The screeiring criteria 4; not used to elimin~~ chemical hazards that fall unµer NRC's regulatory juriscij.ction. The ACP ISA Team examines each hazardous substa,nce on its own characteristic;s and use and considers

• its potential contribution as an initiator for events involving release of radiological material, hanµ-dous energy, or hazardous c~emicals. * *

• Enclosure 1 AC020-0036 Page 5 oflO Chapter 7 Fire Safety

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• National Fire Protection ~sociation Codes Title 10 lo 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 an4 mioimiz.edangerto life or property. Section 7.4.3 ofNUREG-1520 statesthattheNRCreviewerwilf' *

• use national recognized_ codes and standards (including NFPA codes) when evaluating the fire safety program. This information is necessary to determine if the applicant~ demonstrated an adequate' levef of fire safety.

Table 7.1-1 ofthe li~ose application lists all National Fire Protecti~n Association (NFPA).codes applicable to the ACP. Provide-clarification on whether or not ACO intends to meet all aspects ofthe codes listed. For example, NFPA 801, "Standard for Fire Protection for Facilities Handling Radioacµve 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 NFPAcode.

ACO Response:

S~on 1.4.6 identifies the NFPA codes applicable to ACP.

• As noted at the beginning of Section

1.4, the extent to which the Licensee satisfies the requirements .of each code or standard is identified individually in the sub-sections. For NfPA-801-2020, subsection 1.4.6 states that the Licensee will utilize this standard for any future.modifications to the.fire protection program as stated in Section 7.1.1 of this license*application. Su~section 1.4.6 s~ould refer to Sectio_p. 7.0 ~er than Section 7 .1.1; tp.erefore, this typographical error will be corrected.

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Section 7 .0 states that new buildings/f~ilities meet codes and standards applicable at the time of design. Modifications to existing btµldings/facilities are evaluated relative to the safety benefit that ,

could be achieved from applying current codes and standards. Justification for any deviations from the codes and standards ofrecord are d~umented in ~ting and approved by the 'Au~ority Having Jurisdictioi:i (AID).. * * * *

• Additiona.Uy, Section, 7.1 states* that the specific* NFPA stan~ applicable to the ACP are identified in Table 7.1-1 ofthis chapter which includes NFPA 801-2020. Any change where full compliance with the applicable NFPA standards is not maintained will be documented and justified by the AHJ. Therefore, FHAs performed in supportofHALEU Oemonstration will be performed using the guidelines identified in NFPA 801-2020. *

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Enclosure 1 AC020-0036 Page*6ofl0

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 minimi:ze danger to life or property: Additionally, the provisions of 10 CFR 70.22(a)(8J require the applicant to provide proposed procedures to protect health and miniufrze danger to life and property.

Section 7.4.3.5 of NUREG-1520 states that the applicant should document the fire emergency response. organizati~ns for licensed faciUties. ** * *

• . Section 7.1.3 ofthe 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 mepioranda of agreement (MOA) that e)tj~ between the applicant and. the qualified responder. This information is necessary to determine if the emergency responder is sufficiently

c1ose to ~<? site and has adequate staffing, training, and equipment to ryspond in the event of a fire emergen'?Y*.

ACO Response:

ACO contracts with the U.S. Department of Energy (DOE) thr~:mgh its prime contractor to. provide emergency response organization functions uµder Reverse Work Authorization #902093 "Fire .

Services/Emergency ~ement/PSS *support/or HALED." DQE, through its prime contractor,.is responsible to *provide emergency response capabilities* to support ACP facilities with a Field Emergency. Response Qrganiz:ation staffed, trained, and equipped to respond to emergencies and/or abnormal events at ACP facilities. This 'includes, brit is not limited to, providing the necessary staipng, training,. and equipment* for conpucting emergency *planning, drills, and exercises; coordinating and staffing an emergency operations center, providing an incident command system, and management of emergency response activities at ACP facilities.

• Enclosure 1 ACO20-:()036 Page 7 oflO

• Chapter 11 Management Measures and OAPD

1. . Software De:Sign Contro_l

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Title 10 to the Code* of Fede:ral RegulatiollS 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, firpiware, mi~rocode, Programrilable Logic Controllers, and/or ruiy 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 (4.3.D of the license application, and proposed Condition 19.. a of NRC's Materials License contains the updated references to ASME NQA-1-2008 and NQA-1 a-2009 for software design control from AS:ME NQA-1-1994. The proposed reference information includes Part I, Requirement *11. Test Control and Part II, Subpart 2.7, Quality Ass,qance Requirements for Computer Software for Nuclear Facility ApplicatiollS. However, the licensee did not include all the applicable software design control requirements 'included inASME NQA.:1-2008 andASME NQA-la-2009, whi~hnow 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 itnplement 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 req~ or justify for not including it. The requested infon;natio~ is required to assess*compliance against 10 CFR 70.62(d).

ACO Response:

Revised License Application Section 1.4.3 D to state if design controls related to Items, Relied On For Safety (IROFS) consist of computer programs they will be developed, validated,,and managed in accordance with NQA-1-2008 and NQA-la-2009, Basic Part I, Requirement 3, Design Control, Section 800, Requirement 11, Test Control and Part II~ Subpart 2. 7, Quality. Assurance R,equiremen,ts for Computer Software for N:uclear Plant Facility Applicatio~. The proposed QAf>D Section 3.0

• and License Application Section 1.4.3 only identified d~ign ouwuts as this has historically been th~

focus since it correlates with the implementation portion ofNQA-1-2008, Part II, Subpart 2. 7~ ACP agrees that if any IROFS that use software, firmware, mic~de,' Programmable Logic*Controllers, 1;1D.3/or any digital device, including~ devices t1;iat implement data ~pnnuniCl:!,1:i_on protoco~,

then compliance with Section 800 of Part I, Requirement. 3 is required.  : .

• As such, *section 3.0 of the Quality Ass.uranceProgram.Description(QAPD), Section 1.4.3.D ofthe license appli~o*~ and proposed Con~tio~* 1_9.a ofNRC's Materials License will~ ~vised to include reference to Part I, Requirement 3; Section 800 for software design control .requirements associated with IROFS only. *

• Enclosure 1 ACO 20--0036 Page8 oflO 2 .. Toxic Ch.emical E~ergency Respons~ Procedure Training Title 10 to the Code of Federal Regulations 70.62(d) requires ~stablishment of management measures; which includes training, to ensure compliance with:the perforniance requirements of 10

. CFR 70.61. .

Sections i 1.3.1.6.1 and 11:3.1.6.2 of the license application p~vides requi,:ements for operations technician and operations shift supervisor training res~vely and includes the deletion oftraining

• 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 a,larm response procedures. Providf: a reference to the training requirement in the license app).ication for an operatipns 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 a;;sess the reasonableness of the management measures as required by 10 CFR 70.62(d).

ACO Response:

~e Phase I1I training provided in Sections 11.3.1.6.1 and 11.3.1.6.2 include classroom and OJT on the IROFS identified in'the ISA Snmmary or Addendum 1 ofthe,ISA Sl1mmary. LA-3605-0003A, Addendum I of the ISA Summary for the American Centrifuge Plant - HALEU Demonstration,

• includes* IROFS 7.3.8.3, Trained Operator Actions. This IROFS refers to.the worker's ability to recognize a hazardous material release and 'minimiz:e the w9rker's exposure to the release by immediately evacuating the potentially* affected area or by sheltering in p*lace, as* appropriate.

Therefore, the Phase III training oµ_ IROFS 7.3 .8.3 addresses the t::r:aining for toxic chemical rel~s.

3. *. Personnel Training Limitati~ns 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 hmguage to the responsibilities for the*maintenance work center supervisor. Specifically, personnel training .

.limitations" was ~ded with respect to the maintenance work center supervisor's direction of activity t0 provide sµpport 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 bu(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

• :receiye. The requested information is required to assess. the reasonableness of the management measures as required by 10 CFR 70.62(d). :

r Enclosure 1 AC020-0036 Page9 oflO ACO Response:

Personnel training limitations" refers to a situation in which a person has not successfully completed required training. Their line managenient is responsible for placing work restrictions or removing the employee from duty where training is deficient. Although the reference to personnel training limi~tions was added to Section 1.2 of the QAPD and Section 11.2.1 ofthe License, it is not a new process.

Section 11.3 of the License states that the Training and Qualification prograni is designed to ensure that those personnel who perform activities relied on for safety have the applicable knowledge and ,

skills necessary to design, operate, and maintain the plant in a safe mann~. The Performance Based Training methodology is used for those tasks associated with the design, modification, operation, or of tnaintenan~ ofIROFS identified in the ISA Summary, or Addendum 1 the ISA Summary for.the ACP - HALED Demonstration.* Personnel are indoctrinated, trained and tested as necessary to ensure that they are qualified on practices important to public and worker safety, safeguarding of licensed material, and protection of the en~nment.

Section 11.3.1 states that the training group notifies line management of personnel who have not successfully completed initial training or who are past due for identified continuing training. Line map.agement is responsible for placing work restrictions or removing employees from duty where training is deficient. If an individual has not completed the training and their job description requires the performance of a task that requires training, that individual would be restricted from perf,orming the task(s} which is referred to as a training limitation". Therefore, the Performance Based Training

• methodology and tnriping limitations ensure.personnel are adequately training prior to performing a task important to. safety.

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 th,e performance requirements of 10 CFR 70 .61. The definition 1

ofltems 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 ..

• Section 12.o'ofthe QAPD contains additional* language for equipment where calibration control is

• not necessary, specifically for stop wafyhes: 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 an'd 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 C_FR_70.62(d). .

Enclosure 1

, I ACO20-003~

Page 10of10 ACO Response:

• Section 12 of the QAPD will be revised to remove stop watches as an example.

Corresponding supplemental proposed changes to LA-3605-0001 are contained within Enclosure 4

• and QAPD are contained in Enclosure* 5. Supplemental proposed changes are identified by the following method:

• : *,!: **:.**:I:\;_.~*"':' .- Identifies text to he removed

• ~r~ !!"i!F@Jiri - -Identifies text to be added