ML20356A062
| ML20356A062 | |
| Person / Time | |
|---|---|
| Site: | 07003103 |
| Issue date: | 12/16/2020 |
| From: | Padgett W URENCO USA, Urenco, Urenco, Ltd |
| To: | Office of Nuclear Material Safety and Safeguards |
| KMRamsey - NMSS/DFM/FFL - 301.415.7506 | |
| Shared Package | |
| ML20356A060 | List: |
| References | |
| Download: ML20356A062 (4) | |
Text
UUSA Regulatory Relief Request 1.Submitter Name:
Wyatt Padgett 2.Submitter
Title:
Licensing & Performance Assessment Manager 3.Email Address:
Please enter the email address for which you would like to receive communications regarding this request.
LicensingUUSA@urenco.com 4.Phone Number:
Please enter the phone number for which someone from NRC may contact you regarding this request.
575-394-5257 5.Organization Name:
Please enter the name of your organization from your NRC issued license.
Louisiana Energy Services, LLC 6.Organization Street Address:
275 Highway 176 7.Organization City, State and Zip Code:
Eunice, NM 88231 8.License Number(s):
SNM-2010 9.Docket Number(s):
07003103 10.Need By Date:
The Need by date is defined as the date when your organization will be out of compliance if relief is not granted.
Please input date in format of M/d/yyyy 01-01-2021 11.Select NRC Technical
Contact:
Jacob Zimmerman 12.Provide a brief description and why reason regulatory relief is needed:
Use the area below to provide a brief description to support your organization's need for regulatory relief. Please specify which regulatory requirement(s) and/or license condition(s) your organization will not be able to maintain compliance and describe the challenges affecting compliance.
- 1. Explanation of circumstances
- a. What is the specific regulatory requirement, NRC order provision, license condition, or commitment in a licensing basis document (e.g., license application, security plan, emergency plan) from which the licensee is requesting relief?
Louisiana Energy Services, LLC, DBA Urenco USA, is requesting regulatory relief for calendar year 2020 from Material License SNM 2010, Condition 10b, Safety Analysis Report, Section 5, Regulatory Guide 3.71(C)(2)(e), ANSI/ANS-8.23, Section 8.3, which requires criticality accident alarm system (CAAS) evacuation drills to be conducted annually.
- b. What are the details surrounding the request for relief?
- i. What is the condition and operational status of the facility, including any degraded/out-of-service equipment or functions that may be of safety or security significance?
o There are no IROFS deficiencies currently that reduce the margin of safety or increase the probability of experiencing a criticality event. The CAAS evacuation drill was performed as required during calendar year 2019.
ii. To what specific portions of the facility is the requested relief applicable?
o The areas where the CAAS system is located in the Separation Building Module (SBM) 1001, SBM 1003, SBM 1005, Cylinder Receipt and Dispatch Building, and the surrounding areas.
iii. What specific functions/actions does the licensee no longer intend to perform?
o The Criticality/CAAS Alarm evacuation drill for calendar year 2020.
iv. What are the additional functions/actions that the licensee plans to take (i.e., compensatory measures, termination of certain processes)?
o A Criticality/CAAS Alarm Refresher Brief will be provided to all employees in lieu of the Criticality/CAAS actual evacuation drill, documented in the Learning Management System. This Refresher Brief will be completed by employees no later than January 15th, 2021.
- v. What is the root cause or relevant historical event that has influenced the request for relief? If the relief is needed in 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or less, why was it not within the licensees control to identify this issue sooner?
o New Mexico Public Health Order limits mass gatherings to five person or less, and conducting the Criticality/CAAS Evacuation Drill will violate this Public Health Order. There are four designated Criticality Assembly Areas, and it is conservative, based on the average number of persons onsite on an average day, to assume that more than five persons would respond to each Assembly Area in the drill. The Health Order is generally amended on a monthly basis and the Governor has consistently renewed requirements for mass gathering restrictions since March 16th, 2020.
- c. For how long will the relief be needed?
- i. A timeframe should be established for exercising enforcement discretion; and ii. The term should align with the associated regulatory action(s).
o UUSA requests the NRC grant relief for obligations to perform CAAS evacuation drills during calendar year 2020. UUSA intends to resume normal drill routines during calendar year 2021, at which time compliance would be restored provided that the New Mexico Public Health Orders allow for mass gatherings of 10 or more persons. No regulatory relief is being requested for calendar year 2021 at this time.
- 2. Basis for regulatory relief (i.e., how the NRC will determine whether reasonable assurance of adequate protection of safety and security would be maintained if the request were granted)
- a. What is the impact of granting the relief on the following:
- i. the public; o No impact, as the public are not included in the Criticality/CAAS Evacuation Drills.
ii. facility workers; o Small impact, Employees are trained to respond to Criticality/CAAS Alarms. The Criticality/CAAS Evacuation Drill tests the CAAS system and reinforces the behaviors of personnel responding to the CAAS Alarm. Employee knowledge of CAAS evacuation drill response requirements are also maintained with General Employee Training and Nuclear Criticality Safety Annual Training.
iii. the environment; and o No impact
iv. common defense and security?
o No impact
- b. What are the potential safety and/or security issues associated with deviating from normal operations?
o There are no safety and/or security issues associated with not performing the Criticality/CAAS Drill in the calendar year 2020. Personnel are trained on their response to the Criticality/CAAS Alarm System. The 2019 Criticality/CAAS Drill was performed successfully, with all objectives evaluated satisfactory and no Event Reports were initiated.
- c. How do any additional functions/actions that the licensee plans to take (e.g.,
compensatory measures, termination of certain processes) provide a comparable level of safety or security that the requirement would otherwise mandate?
o A written Criticality/CAAS Alarm Refresher Brief will be provided to all employees in lieu of the Criticality/CAAS actual evacuation drill, documented in the Learning Management System. This will provide awareness of the Criticality/CAAS Alarm system and the actions personnel should take in a written form, instead of the actual performance of assembling at the Assembly Areas.
- d. If applicable (i.e., in the case of exemptions from the regulations), why is the relief otherwise in the public interest?
o Granting this relief request would reduce potential spread of the COVID-19 virus in the local community. Otherwise, this activity is not applicable to the public interest.
- 3. Plan to return to normal operations
- a. What is the proposed course of action to resolve the situation such that relief is no longer needed?
o A Criticality/CAAS Alarm Refresher Brief will be provided to all employees in lieu of the Criticality/CAAS actual 2020 evacuation drill, documented in the Learning Management System. The 2021 CAAS evacuation drill is scheduled to be performed during the 2021 calendar year. This evacuation drill will restore compliance to the annual periodicity.
- b. How will the licensee maintain documentation of the lapsed functions/actions?
o An Event Report (EV 141291) has been written to document the cancellation of the 2020 Criticality/CAAS Evacuation Drill and will track restoration of compliance. UUSA will communicate to the NRC when compliance is restored.
- c. How will the lapsed functions/actions be resolved prior to the restart of normal operations?
o When the New Mexico Public Health Orders allow for mass gatherings of 10 or more persons, then the Criticality/CAAS Drill will be scheduled for the 2021 calendar year.