ML21053A189

Louisiana Energy Services, LLC, Dba Urenco USA, Response to LAR 20-01 RAI Regarding Quality Program Requirements for Redundant IROFS

ML21053A189
Person / Time
Site:	07003103
Issue date:	02/12/2021
From:	Cowne S Louisiana Energy Services, URENCO USA
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Security and Incident Response
Shared Package
ML21053A188	List: ML21053A189
References
LES-21-022-NRC
Download: ML21053A189 (5)

Text

LES-21-022-NRC 2/12/2021 ATTN: Document Control Desk Director, Division of Security Operations Office of Nuclear Security and Incident Response U.S Nuclear Regulatory Commission Washington, D.C. 20555-0001 Louisiana Energy Services, LLC NRC Docket Number: 70-3103 (84§.~

Enrichment Fac1llty

Subject:

Response to LAR 20-01 RAI Regarding Quality Program Requirements for Redundant IROFS

References:

1) LES-20-00074-NRC License Amendment Request revising Quality Program Requirements for Redundant IROFS (LAR-20-01) dated Sept 8, 2020.

2) Request for Additional lnfonnation Regarding Quality Program Requirements for Redundant IROFS dated January 22, 2021 In Reference 1, Louisiana Energy Services (LES), dba URENCO USA (UUSA), proposed a License Amendment Request (LAR) to revise the Quality Assurance Program Description and Safety Analysis Report to incorporate a new class or IROFS and new Quality Program for such IROFS. In Reference 2, the U.S. Nuclear Regulatory Commission (NRC) responded with a request for additional information (RAI). contains answers to the questions in Reference 2. UUSA considers Enclosure 1 to contain commercial infonnation and Sensitive Unclassified Non-Safeguards lnfonnation (SUNS!) and requests it be withheld from public disclosure in accordance with 10 CFR 2.390. Should there be any questions concerning this submittal, please contact Wyatt Padgett, Licensing and Performance Assessment Manager, at 575-394-5257 Respectfully, Stephen Cowne Chief Nuclear Officer

Enclosures:

1) Response to RAI for LAR 20-01

2) Replacement Page Changes to the Safety Analysis Report Loulslana Energy Servlcas, LLC UUSA I PO Box 1769 I Eunice I New MeXJCO 188231 I USA T +1 (575) 394 4646 I W www uusa urenco com 0 2021 LOU1818ll8 Energy Services, LLC

LES-21-022-NRC cc Jacob Zimmerman, Fuel Facility Licensing Branch Chief U.S. Nuclear Regulatory Commission Office of Nuclear Material Safety and Safeguards Jacob.Zimmerman@NRC.gov Robert Williams, Chief - Region II Projects Branch I U.S. Nuclear Regulatory Commission Robert.Williams@NRC.gov Kevin Ramsey Project Manager U.S. Nuclear Regulatory Commission Kevin.Ramsey@nrc.gov Louh>>ana En8f'gy Sarv1ce11, LLC UUSA I PO Box 1789 I Eunice I New Mexico I 88231 I USA T +1 (576) 394 4846 I W www uusa urenco com Q 2021 Louisiana Energy Serv1ces, LLC

LES-21-022-NRC ENCLOSURE 2 Replacement page changes to the UUSA Safety Analysis Report (Redline strikethroughs were utilized)

3.4 Compliance Item Commitments Management measures are applied to the attributes of Administrative Control lROFS Support Equipment and other equipment attributes. Management measures are also applied to Administrative Control IROFS Support Equipment as defined in the Quality Assurance Program Description for QL-2AC equipment.

3.4.45 IROFS Classes For the three types of IROFS Administrative Control (AC), Passive Engineered Control (PEC) and Active Engineered Control (AEC) there are three classes which the IROFS can fall into. An IROFS cannot fall into multiple classes, i.e., separate classes for different accident scenarios depending on the IROFS applied to each accident scenario Sole IROFS: A Sole IROFS is an AC, PEC or AEC IROFS that upon its failure there are no remaining IROFS capable of preventing or mitigating the consequences for the accident scenario for which the IROFS applies.

Multiple IROFS: A Multiple IROFS is an AC, PEC or AEC IROFS that is part of a group of IROFS, not identified as redundant. which are needed for the performance requirements of 10 CFR 70.61 to be met.

Redundant IROFS: A Redundant IROFS is an AC IROFS or a group of AC IROFS, which is capable of preventing or mitigating the consequences associated with the applicable accident scenario individually or as a group. The use of a Redundant IROFS would greatly exceed the performance requirements of 10 CFR 70.61 as one independent IROFS is capable of meeting the performance requirements of 1 O CFR 70.61 and the Redundant independent IROFS is also capable of meeting the performance requirements of 10 CFR 70.61. All Redundant IROFS are relied on to prevent potential accidents that could exceed the performance requirements at UUSA.

Safety Analysis Report Page-3.4-13 I.AR 20-01

11.0 Management Measures 11.0 Management Measures Management measures are functions applied to item(s) relied on for safety (IROFS) and any items which are essential to the function of IROFS to provide reasonable assurance that the IROFS are available and able to perform their functions when needed. This chapter addresses each of the management measures included in the 10 CFR 70.4 definition of management measures.

Management measures are applied to the attnbutes of Administrative Control lROFS Support Equipment and other equipment attributes. These attributes are listed in SAR Table 3.4-1 and are defined in the respective IROFS Boundary Definition Document. Management measures are also applied to Administrative Control IROFS Support Equipment as defined in the Quality Assurance Program Description for QL-2AC and QL-2R equipment. Administrative Control IROFS Support Equipment is identified in SAR Table 3.4-1.

Management measures are implemented through a quality assurance (QA) program in accordance with 10 CFR 50, Appendix B (CFR, 2003b). The QA program also provides additional measures for ensuring that the design, construction, operation and decommissioning of IROFS are controlled commensurate with their importance to safety. The Louisiana Energy Services (LES) Quality Assurance Program is described in the LES Quality Assurance Program Description (QAPD). The NRC has evaluated the LES QA Program Description and concluded that the application of QA elements as described in the QA Program Description meets the requirements of 1 O CFR 70 (CFR, 2003g) and provides reasonable assurance of protection of public and worker health and safety and the environment (NRC, 2004).

LES maintains full responsibility for assuring that the National Enrichment Facility (NEF) is designed, constructed, tested, and operated in conformance with good engineering practices, applicable regulatory requirements and specified design requirements and in a manner to protect the health and safety of the public. To this end, the LES Quality Assurance Program conforms to the criteria established in 10 CFR 50, Appendix B, Quality Assurance Criteria For Nuclear Power Plants and Fuel Reprocessing Plants (CFR, 2003b). The. criteria in 10 CFR 50, Appendix B (CFR, 2003b), are implemented following the commitment to ASME NQA-1, Quality Assurance Program Requirements for Nuclear Facilities.

The QA Program described herein includes design, construction, pr~perational testing, and operation of the facility. This QA Program describes the requirements to be applied for those systems, components, items, and services that have been determined to be QA Level 1 as defined in the QAPD. LES and their contractors implement these requirements through the use of approved procedures. In addition, a quality assurance program as described in the QAPD is applied to certain other systems, components, items, and services which are not QA Level 1.

The information provided in this chapter, the corresponding regulatory requirement, and the section of NUREG-1520, Chapter 11 in which the NRC acceptance criteria are presented is summarized below.

Safety Analysis Report Page-11.0-1 I.AR 20-01