ML22336A220
| ML22336A220 | |
| Person / Time | |
|---|---|
| Site: | 07003103, 07109362 |
| Issue date: | 12/07/2022 |
| From: | Freels J Louisiana Energy Services |
| To: | Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML22336A219 | List: |
| References | |
| EPID L-2021-LRM-0119 | |
| Download: ML22336A220 (1) | |
Text
© 2021 Louisiana Energy Services, LLC Jim Freels UUSA Licensing UUSA 10 CFR 71 Subpart H Quality Assurance Program
2 Introduction Urenco USA (UUSA) attendees Wyatt Padgett, P.E. - Head of Compliance Kevin Slavings - Quality Assurance Manager Olimpio Torres - Principal Quality Assurance Specialist Chris Schwarz - Licensing and Performance Assessment Manager Jim Freels - Licensing Consultant
3 Agenda UUSA agenda Background information Overview of the UUSA 10 CFR 71 Subpart H Quality Assurance Program UUSA proposed solution Discussion of proposed solution
4 Background
Convention used at UUSA and in this presentation 10 CFR 70 Quality Assurance Program Description (UUSA Licensing Basis Document) is known as the:
- Quality Assurance Program Description (QAPD)
- UUSA document title and number:
- Quality Assurance Program Description, no document number 10 CFR 71 Subpart H Quality Assurance Program is known as the:
- Quality Assurance Manual (QAM)
- UUSA document title and number:
- 10 CFR 71 Subpart H Quality Assurance Manual for Packaging and Transportation of Radioactive Materials for Urenco USA, QA-1-2000-01
5 Background
UUSA plans to increase enrichment at facility to less than 10 weight percent (wt%) U-235 UUSA is looking ahead for transportation requirements using DN30 transportation package Previous studies by Oak Ridge National Laboratories support this approach1,2 UUSA intends to submit an exemption/deviations to regulatory framework regarding maximum enrichment that can be domestically transported (e.g., 10 CFR 71.55(g)(4), various DN30 Certificate of Compliance conditions)
Special Permit Authorization will also be required from Department of Transportation 1 R. Hall, B. J. Marshall, W. A. Wieselquist, Assessment of Existing Transportation Packages for Use with HALEU, ORNL/TM-2020-1725, Oak Ridge, TN, September 2020 (ML21040A518) 2 E. Saylor, A. Lang, B.J Marshall, R. Hall, Analysis of the 30B UF6 Container for Use with Increased Enrichment, ORNL/TM-2021/2043, Oak Ridge, TN, May 2021
6 Background
No physical modifications to transportation package, only change will be increased enrichment UUSA will evaluate transportation package to confirm safety and regulatory margins remain due to increased enrichment Areas of confirmatory evaluation include criticality safety and radiation shielding calculations To perform these confirmatory calculations UUSA will have to revise its 10 CFR 70 Quality Assurance Program Description (QAPD)
UUSA will have to revise its 10 CFR 71 Subpart H Quality Assurance Manual (QAM)
7 UUSA 10 CFR 71 Subpart H QA Program Limitations NRC-approved 10 CFR 71 Subpart H QA Program Docket number: 71-0940 Submittal date: 2 January 2009 NRC Approval Form for QA Program Approval: 12 January 2009 (ML090140082)
NRC Revised Approval Form for QA Program Approval: 28 August 2015 (ML15247A244)
Conditions (in part)
Authorizations
- Procurement, maintenance, repair and use
- All other activities (i.e., design, fabrication, assembly, testing and modification) to be satisfied by obtaining certifications from package suppliers that activities were conducted per their NRC-approved QA Program
8 UUSA 10 CFR 71 Subpart H QA Program Limitations UUSA Quality Assurance Program Description (QAPD) implements the authorizations provided in the NRC Quality Assurance Program Approval (ML15247A244)
The UUSA QAM also implements the UUSA Quality Assurance Program Description (QAPD) requirements for radioactive packaging and provides a description of the requirements applicable to 10 CFR 71, Subpart H work contained in the QAPD The QAM Section 3, Design Control, identifies UUSA as a USER ONLY of transportation packagings and that UUSA does not design or fabricate packagings
9 Proposed Solution UUSA maintains and uses 10 CFR Part 70 QAPD-compliant procedures for calculations EG-3-4200-03, Preparation and Control of Engineering Calculations
- Applies to engineering calculations prepared to support UUSA-approved design
- Applies to design analyses and calculations which are covered by the Configuration Management policy in Safety Analysis Report EG-3-3200-02, Nuclear Criticality Safety Analysis/Evaluation
- Applies to activities involving or affecting uranium on-site CR-3-1000-05, Preparation and Control of Non-Design Calculations
- Establishes requirements for preparation, review, approval and revisions of calculations performed outside Design Engineering
- Does not apply to calculations done per EG-3-4200-03 or EG-3-3200-02
- Implements rigorous, formal framework for calculations
10 10 Proposed Solution Solution activities UUSA defines calculations for increased enrichment as confirmatory calculations of existing design to support increase while maintaining margins of criticality safety and radiation limits These are not design calculations per existing procedures UUSA to use CR-3-1000-05, Preparation and Control of Non-Design Calculations, as QAPD-compliant procedure for non-design calculations for criticality and radiation shielding evaluations for domestic DN30 transportation package use with LEU+
UUSA will revise QAPD and QAM to
- provide authority to perform and use confirmatory non-design transportation package content calculations and use the results of those calculations in accordance with the UUSA program including any applicable regulatory reviews and approvals
- establish a bridge between the two controlling QA-related documents in Section 3, Design Control
- make other conforming changes, as necessary
11 11 Proposed Solution Solution activities (cont)
Draft changes to QAPD have been screened and evaluated in accordance with 10 CFR 71.106 and the UUSA implementing procedure QA-3-2000-06, Quality Assurance Program Description Change(s)
Draft QAPD changes have been found to not require NRC approval prior to implementation When changes are implemented in the QAPD, UUSA will submit the change to the NRC within the 30 day window for NRC notification