ML22336A221
| ML22336A221 | |
| Person / Time | |
|---|---|
| Site: | 07003103, 07109362 |
| Issue date: | 12/07/2022 |
| From: | Bernie White Storage and Transportation Licensing Branch |
| To: | Carrie Safford Division of Fuel Management |
| Shared Package | |
| ML22336A219 | List: |
| References | |
| EPID L-2021-LRM-0119 | |
| Download: ML22336A221 (4) | |
Text
December 7, 2022 MEMORANDUM TO: Carrie Safford, Deputy Director Division of Fuel Management Office of Nuclear Material Safety and Safeguards Signed by White, Bernard FROM: Bernard White, Senior Project Manager on 12/07/22 Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards
SUBJECT:
SUMMARY
OF OCTOBER 4, 2022, MEETING WITH URENCO USA TO DISCUSS THE SCOPE OF ITS QUALITY ASSURANCE PLAN
Background
On October 4, 2022, a virtual meeting was held, at the request of the Louisiana Energy Services doing business as Urenco USA (UUSA) with the U.S. Nuclear Regulatory Commission (NRC) staff to discuss the UUSA quality assurance (QA) plan as it relates to a proposed exemption for approval to ship uranium hexafluoride that is enriched to 10 weight percent uranium-235 (235U) in the Model No. DN30 package. The list of meeting attendees is provided as Enclosure 1. The presentation used in the meeting is provided as Enclosure 2. The NRC previously met with UUSA on the exemption on December 13, 2021 (Agencywide Documents Access and Management System [ADAMS] Accession No. ML22004A169).
UUSA requested the meeting to discuss the scope of its Part 71 QA plan. The existing UUSA QA plan (ML15247A244) is considered a user-only plan, which only authorizes those activities related to licensee use of a package and does not extend to package design and fabrication.
The discussion at the meeting centered on whether the exemption request is considered a design change or confirmatory calculations.
Discussion At the meeting, UUSA provided a brief overview if its proposed exemption and its QA Plan for shipments it makes pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part 71, Packaging and Transportation of Radioactive Material. UUSA stated that, for shipments of enriched uranium hexafluoride it makes to fuel fabricators, the NRC approval of its QA Plan is for a user-only of these packages, as UUSA does not design or fabricate packagings.
CONTACT: Bernard White, NMSS/DFM (301) 415-6577
C. Safford 2 UUSA stated that it would perform all the calculations for the exemption under its procedures for its QA Plan that NRC approved for UUSAs enrichment activities under 10 CFR Part 70, Domestic Licensing of Special Nuclear Material. Specifically, UUSA briefly discussed procedures that it uses when performing engineering calculations to support the plant design changes, other activities for onsite uranium, and calculations that are not considered design calculations.
Since UUSA is not proposing to make changes to the packaging design, only changes to the maximum authorized enrichment, UUSA stated that it considers calculations to increase the enrichment of the uranium hexafluoride transported in the DN30 package to be confirmatory calculations to ensure the existing design maintains criticality safety and dose rate margins.
UUSA does not consider these calculations to be design calculations. UUSA stated that based on this, it will revise its Part 71 QA plan description and QA manual to provide authority to perform and use confirmatory, non-design calculations for the revision to the DN30 contents, establish a bridge between the two QA related documents and, as necessary, make other conforming changes. UUSA also stated that these changes have been screened and evaluated in accordance with 10 CFR 71.106, Changes to Quality Assurance Program, and based on UUSAs evaluation, do not require prior approval by the NRC.
The NRC stated that it had not thought about considering these types of calculations to be confirmatory calculations but had always considered them to be design calculations. The NRC also stated that it could not make that determination at this meeting, since it would need legal review to make this interpretation. NRC stated that it understands that UUSA would like to submit the exemption request to the NRC by the end of 2022 and therefore, would expeditiously write up its understanding of the issue and concerns and send them to the NRCs Office of the General Counsel for review.
There was also discussion about UUSA submitting an exemption to 10 CFR 71.101(f) to be able to consider its QA plan approved for its activities under 10 CFR Part 70 as a previously approved QA plan, as if it were a A Commission-approved quality assurance program that satisfies the applicable criteria of subpart H of this part, Appendix B of part 50 of this chapter, or subpart G of part 72 of this chapter. The NRC stated, if needed, it would consider this exemption request.
Docket Nos. 70-3103 and 71-9362 EPID No. L-2021-LRM-0119
Enclosures:
- 1. Meeting Attendees
- 2. Meeting Presentation
C. Safford 3
SUBJECT:
SUMMARY
OF OCTOBER 4, 2022, MEETING WITH URENCO USA TO DISCUSS THE SCOPE OF ITS QUALITY ASSURANCE PLAN DOCUMENT DATE: December 7, 2022 DISTRIBUTION:
NRC Meeting Attendees K. Jamerson, NMSS H. Lindsay, NMSS ADAMS Accession Nos.: ML22336A219 (pkg), ML22336A220 (slides),
ML22336A221 (memo)
OFFICE NMSS/DFM NMSS/DFM NMSS/DFM NAME BWhite SFigueroa YDiaz-Sanabria DATE 12/05/2022 12/05/2022 12/06/2022
MEETING ATTENDEES Meeting
Title:
Summary of October 4, 2022, Meeting with Urenco USA to Discuss the Scope of its Quality Assurance Plan
Participants:
Urenco USA and the NRC Date: October 4, 2022 Location: Teleconference NAME AFFILIATION Bernie White NRC Jon Woodfield NRC Aaron Thomlinson NRC Matt Bartlett NRC Aida Rivera-Varona NRC Wyatt Padgett UUSA Kevin Slavings UUSA Olimpio Torres UUSA Chris Schwarz UUSA Jim Freels UUSA Members of the Public Jay Thomas TN Americas LLC Peter Vescovi TN Americas LLC Enclosure 1