ML21203A095
| ML21203A095 | |
| Person / Time | |
|---|---|
| Site: | 07003103 |
| Issue date: | 07/13/2021 |
| From: | Lorskulsint P Louisiana Energy Services, URENCO USA |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Security and Incident Response |
| References | |
| LAR-20-01, LES-21-077-NRC | |
| Download: ML21203A095 (8) | |
Text
LES-21-077-NRC July 13, 2021 USA The National Enrichment Facility 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
Subject:
Revised License Amendment Request, Quality Program Requirements for Redundant IROFS (LAR-20-01)
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 Information Regarding Quality Program Requirements for Redundant IROFS dated January 22, 2021.
- 3) LES-21-022-NRC, Response to LAR 20-01 RAI Regarding Quality Program Requirements for Redundant IROFS, dated February 12, 2021.
- 4) NRC Conference Call Summary between NRC and LES Regarding Redundant IROS Amendment Application, dated March 30, 2021
- 5) NRC Discussion and Option notes for virtual meeting held on May 17, 2021.
- 6) Email from Kevin Ramsey, NRC to Wyatt Padgett, Urenco USA, UUSA LAR-20-01, QL-2R (Redundant IROFS), June 3, 2021
- 7) Email from Wyatt Padgett, Urenco USA, to Kevin Ramsey, NRC, QL-2R (Redundant IROFS), June 8th , 2021.
- 8) Email from Kevin Ramsey, NRC to Wyatt Padgett, Urenco USA, UUSA LAR-20-01, QL-2R (Redundant IROFS), June 30, 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 of IROFS and a new quality program for such IROFS. In Reference 2, the U.S. Nuclear Regulatory Commission (NRC) responded with a request for additional information (RAI) for which UUSA responded in Reference 3. Since submittal of Reference 3, 2 meetings, Reference 4 and 5, have been held discussing additional concerns the NRC has regarding the license amendment request.
Additionally UUSA responded to Reference 6 in Reference 7 recommending we respond formally where NRC concurred in Reference 8.
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
© 2021 Louisiana Energy Services, LLC
LES-21-077-NRC contains detailed explanations to the concerns raised in References 5, 6 and 7. provides revised change pages to the Amendment Request. Enclosure 3 provides a copy of UUSA's Boundary Document Definition Procedure. provides an affidavit. UUSA considers the information provided in Enclosure 1 as Sensitive Unclassified Non-Safeguards Information (SUNSI), and requests that the information be withheld from public disclosure in accordance with 10 Code of Federal Regulations 2.390 and the guidance described in Regulatory Information Summary 2005-31, Attachment 2, Appendix 1. UUSA considers Enclosure 3 to be commercial in confidence.
Should there be any further questions concerning this submittal, please contact Wyatt Padgett, Licensing and Performance Assessment Manager at 575.394.5257.
Respectfully, Digitally signed by P.
Paul Lorskulslnt Date:2021.07.13 15:59:57 -06'00' Paul Lorskulsint Chief Nuclear Officer
Enclosures:
- 1) Explanations to additional NRC concerns on QL-2R
- 2) Revised Page Changes to the Licensing Basis Documents for LAR-20-01
- 3) EG-3-3100-02, IROFS Boundary Definitions, Revision 5
- 4) Affidavit Louisiana Energy Services, LLC UUSA I P.O. Box 1789 j Eunice I New Mexico I 88231 I USA T: +1 (575) 394 4646 I W: www.uusa.urenco.com
© 2021 Louisiana Energy Services, LLC
LES-21-077-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 11 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 Louisiana Energy Services, LLC UUSA I P.O. Box 1789 j Eunice I New Mexico I 88231 I USA T: +1 (575) 394 4646 I W: www.uusa.urenco.com
© 2021 Louisiana Energy Services, LLC
.LES-21;..077--NRC
.ENCLOSURE 4 Affidavit I, Paul Lorskulsint,. being ddly' sWon,, ,StEit~ that! ~m the Chief Nuclear Officer for Louisiana Energy Services ,(LES},,dtla tJRENCO USA(VUSA); thatlam authorized on the part of said company to sign and file with the Nuclear.Regulatory Commission ("NRC")*this document; ~nd that all statements made and matters set forth herein are *true and correct to th~ bes.t <>f n:iy knowledge; information, and belief:
- 1. LES wish~$ to *:nave. withheld from public disclosure* thefollowing .document:
LE~-21-077-NRC Enclosure 1, Explanations to additional NRC concerns on Ql-2R
~ES-21-077;.NRC Enclosurer3,, EG.:3;.3100.:02, IROFS s*oundafy 'Definitions; Revision!:$
.2; The inforrriation contained inJhe documents cited above for which exe.mption from pu~llc disciosunf is requested ;is 1}' proprietary ihforrnation related to*commerci~l aspects ofthe URENGO USA Fa¢iiity and* 2) sec1Jrity rel;ated informaticm. LES requests that the proprietary and Sensitive lJnclassified Non-Safegw:,1rds Information (SIJNSI) be exempt from disqlosur!=} pursuant to the provisions: iii 10 CFR Part 2.390(a)(4).
- 3. Public disclosure of the informati_on rn the above. enclosure to-'this submittal has. the potential to result if);substantial*han:n to, the competitive*position of LES, provide valu$ble
,bus1n,ss, information to competitors of LES which theY,could duplicate without havihg. to expend the.ir own resources~to develop, and reduce or foreclose the availability of profit opportunities.
- 4. Tbe infqr:rnation stated in this affidavit has been submitted in:1:1ccordahce with the applicable parts of10 CFR'2.~90, the guidance contained in NUREG.:1556, Vol. 20 1 Appendix CA and the guidanceJrom NRG RlS-2005-31, Attachment2, Appendix 1 (Fuel Gycle Facility Reviews).
S. TheJnformatlon soughttb be withheld is not in the public domain, to.the best of'LES's knowled9e and belief; Paul Lorskulsint Date Gl'.lief Nuclear Officer Lp!,Jlslana Energy Services, LLC I certify the. above named ;person appeared before me .and executed th.ls docum~nt on this !?*)i:hday of JUiy 2021. *
- NQtary. PubliQ Mycommlsslon expires: .'J\~'"'"" \\.t ,;~c~q
LES-21-077-NRC ENCLOSURE 2 Revised page changes to the Licensing Basis Documents:
UUSA, Quality Assurance Program Description (Redline strikethroughs were utilized)
SECTION 23 Quality Assurance Program for Quality Assurance Level 1 Fire Protection (QL-1F)
SECTION 24 QUALITY ASSURANCE PROGRAM FOR QUALITY LEVEL 2R This section outlines the requirements for the QL-2R Program. This section applies only to QL-2R components. The QL-2R Program is based upon the following:
Management measures will be identified for QL-2R components in accordance with UUSA procedures. OL-2R applies to the Redundant Administrative Control lROFS Other Equipment identified in Table 3.4-1 of the Safety Analysis Report.
SECTION 24.1 ORGANIZATION The organization. lines of responsibility and authority are established and documented.
SECTION 24.2 QUALITY ASSURANCE PROGRAM The program will provide for indoctrination and training. as necessary. of personnel performing activities affecting quality to assure that suitable proficiency is achieved and maintained LES will assess the adequacy of that part of the program for which QL-2R applies to assure its effective implementation.
SECTION 24.3 DESIGN CONTROL, DESIGN DOCUMENTATION AND RECORDS QL-2R component design requirements will be in accordance with UUSA requirements for QL-3 designs. QL-3 design requirements are described in Engineering Department procedures.
SECTION 24.4 PROCUREMENT QL-2R procurements shall be conducted in accordance with the UUSA requirements for QL-3 procurements. The QL-3 procurement process is described in Procurement Department procedures. The process includes requirements for: formal interfaces between UUSA and the supplier, identification of specific terms and conditions. procurement planning, complete and accurate description of needs. reviews and approvals by knowledgeable and responsible individuals. technical and quality requirements, verification of technical adequacy and completeness. design review, change review and approval, identification of deviations by suppliers.
methods of acceptance, procurement package closure and documentation.
SECTION 24.5 INSTRUCTIONS, PROCEDURES, AND DRAWINGS Activities affecting quality shall be prescribed by and conducted in accordance with approved procedures and other implementing documents (drawings, specifications. etc.) appropriate to the circumstances and to the level of detail necessary. Work activities are performed in accordance with written procedures. Procedures will contain the actions. acceptance criteria and method for evaluation to ensure prescribed activities have been satisfactorily accomplished.
SECTION 24.6 DOCUMENT CONTROL Documents that furnish documentary evidence of quality of critical elements are specified, prepared. and maintained. Documents will be legible, identifiable. and retrievable. Documents are protected against damage. deterioration. and loss. Requirements and responsibilities for document transmittal. distribution, retention, maintenance, and disposition are established. Requirements for the identification. generation, and control of Quality Assurance Documents for the QL-2R components will be in accordance with the requirements of Section 6 of the QAPD.
Quality Assurance Program Description LAR-20-01 Page 178
SECTION 23 Quality Assurance Program for Quality Assurance Level 1 Fire Protection (QL-1F)
SECTION 24.7 CONTROL OF PURCHASED MATERIAL EQUIPMENT AND SERVICES Measures are established to ensure conformance with procurement specifications and documents LES will define critical elements applicable to the components and material SECTION 24.8 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS The controls necessary to ensure that only correct and accepted items are used or installed will be required and specified in implementing procedures. including requirements for identification of materials, parts and components.
SECTION 24.9 CONTROL OF SPECIAL PROCESSES This section is not applicable to QL-2R components.
SECTION 24.10 INSPECTION Inspection required to verify conformance of an item or activity to specified requirements are planned and executed. Characteristics to be inspected and inspection methods to be employed are specified. Inspection results are documented.
SECTION 24.11 TEST CONTROL Procedures will provide management controls for testing of QL-2AC components. Documents generated utilizing these procedures will contain controls such as hold points, activity checklists, and in many cases. step-by-step signs-offs which indicate the status of testing.
SECTION 24.12 CONTROL OF MEASURING AND TEST EQUIPMENT Processes affecting quality of items or services are controlled. To maintain accuracy within specified limits. the LES QA Program requires that devices (e.g .* tools, gauges. instruments). and measuring and test equipment. including process-related instrumentation and controls that are used in activities affecting the quality of items. are properly controlled. calibrated. and adjusted at specified periods in accordance with written procedures. QL-2R components shall be calibrated in accordance with the UUSA requirements for QL-3 calibrations. The QL-3 calibration process is described in Maintenance Department procedures.
SECTION 24.13 HANDLING, STORAGE, AND SHIPPING Handling. storage. cleaning. packaging. shipping and preservation of QL-2R components is controlled in accordance with requirements of work control documents. shipping instructions or other specified documents. as applicable, to prevent damage or loss and to minimize deterioration.
Measures will be established for marking and labeling for the packaging. shipping. handling and storage of items. as necessary. to adequately identify, maintain and preserve QL-2R components.
Markings and labels will indicate the presence of special environments or the need for special controls, if necessary.
Quality Assurance Program Description LAR-20-01 Page 179
SECTION 23 Quality Assurance Program for Quality Assurance Level 1 Fire Protection (QL-1 F)
SECTION 24.14 INSPECTION, TEST, AND OPERATIONS STATUS Inspection, Test, and Operating status of QL-2R components shall be conducted in accordance with the UUSA requirements for QL-3 component inspection, test and operating status. The QL-3 process is described in UUSA approved procedures.
SECTION 24.15 NONCONFORMING ITEMS Controls for the Nonconforming Items for the QL-~R components will be in accordance with the requirements of Section 15 of the QAPD.
SECTION 24.16 CORRECTIVE ACTION Corrective Action requirements for the QL-2R components will be in accordance with the requirements of Section 16 of the QAPD.
SECTION 24.17 QUALITY ASSURANCE RECORDS Requirements for the identification, generation and control of Quality Assurance Records for the QL-2R components will be in accordance with the requirements of Section 17 of the QAPD.
SECTION 24.18 AUDITS Auditing requirements for the QL-2R components will be in accordance with the requirements of Section 18 of the QAPD.
SECTION 24.19 PROVISIONS FOR CHANGE Any removal of management measures designed to provide assurance of the Redundant Administrative Control lROFS Other Equipment used by the worker would be considered a reduction in commitment and require regulatory approval prior to implementation Quality Assurance Program Description LAR-20-01 Page I 80