ML22336A220
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| 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
UUSA 10 CFR 71 Subpart H Quality Assurance Program Jim Freels UUSA Licensing
© 2021 Louisiana Energy Services, LLC
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 2
Agenda
- UUSA agenda
- Background information
- Overview of the UUSA 10 CFR 71 Subpart H Quality Assurance Program
- UUSA proposed solution
- Discussion of proposed solution 3
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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 4
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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 5
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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 71 Subpart H Quality Assurance Manual (QAM) 6
UUSA 10 CFR 71 Subpart H QA Program Limitations
- 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 7
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 8
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 9
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 10
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 11