ML24302A199
| ML24302A199 | |
| Person / Time | |
|---|---|
| Site: | 07003103 |
| Issue date: | 11/06/2024 |
| From: | Rowley J NRC/NMSS/DFM/FFLB |
| To: | Lorskulsint P Louisiana Energy Services |
| Shared Package | |
| ML24302A198 | List: |
| References | |
| EPID L-2023-LLA-0107 | |
| Download: ML24302A199 (1) | |
Text
OFFICIAL USE ONLY-SECURITY RELATED INFORMATION OFFICIAL USE ONLY-SECURITY RELATED INFORMATION UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Paul Lorskulsint, Chief Nuclear Officer and Head of Compliance Louisiana Energy Services, LLC P.O. Box 1789 Eunice, NM 88231
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION REGARDING LOUISIANA ENERGY SERVICES, LLC LICENSE AMENDMENT REQUEST 23 ELIMINATION OF IROFS50a, b, c, d, e, h, i, and j (ENTERPRISE PROJECT IDENTIFICATION NUMBER L-2023-LLA-0107)
Dear Paul Lorskulsint:
By letter dated August 3, 2023 (Agencywide Documents Access and Management System
[ADAMS] No. ML23220A389), Louisiana Energy Services, LLC, dba Urenco USA, requested an amendment to its Materials License. The amendment request proposes an elimination of several of the 50-series of items relied on for safety (IROFS), specifically IROFS50a, b, c, d, e, h, i, and j. The proposed change would eliminate IROFS for vehicle impacts and fires associated with construction activities. Our review of your application has identified that additional information is needed before final action can be taken.
The additional information, specified in the enclosures, should be provided within 30 days from the date of this letter.
Pending your response, we anticipate completing our review by the end of December 2024.
This date could change depending on the findings of our technical review, urgent assignments, or other factors. We will promptly communicate any significant changes to this schedule. transmitted herewith contains Security Related Information. When separated from Enclosure 2, this letter and are decontrolled.
November 6, 2024
OFFICIAL USE ONLY-SECURITY RELATED INFORMATION P. Lorskulsint 2
OFFICIAL USE ONLY-SECURITY RELATED INFORMATION In accordance with Title 10 of the Code of Federal Regulations Part 2, Agency Rules of Practice and Procedure, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room (PDR) or from the Publicly Available Records component of the NRCs ADAMS. ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. The PDR is open by appointment. To make an appointment to visit the PDR, please send an email to PDR.Resource@nrc.gov or call 1-800-397-4209 or 301-415-4737, between 8 a.m. and 4 p.m. eastern time (ET), Monday through Friday, except Federal holidays.
If you have any questions regarding this communication, please contact me at 301-415-4053, or via email to jonathan.rowley@nrc.gov.
Sincerely, Jonathan G. Rowley, Project Manager Fuel Facility Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No.: 07003103 License No.: SNM-2010
Enclosures:
- 1. Fire Safety RAI (public)
ML24302A198(pkg, non-public); ML24302A199(ltr & encl 1);
ML24302A200(encl 2, non-public)
OFFICE NMSS/DFM/FFLB NMSS/DFM/FFLB NMSS/DFM/FFLB NMSS/DFM/FFLB NAME JRowley JGoodridge JDowns JRowley DATE 10/31/24 11/1/24 11/6/24 11/6/24
OFFICIAL USE ONLY-SECURITY RELATED INFORMATION OFFICIAL USE ONLY-SECURITY RELATED INFORMATION Fire Safety RAI-1 The fire safety request for additional information (RAI) is issued to determine whether the application provides commitments for adequate protection against fires and explosions that could affect the safety of licensed materials and thus present an increased radiological or chemical risk.
Regulatory Basis In compliance with Title 10 of the Code of Federal Regulations (10 CFR) Paragraph 70.22(a)(7),
applications need to include a description of equipment and facilities to protect health and minimize danger to life or property.
In accordance with the acceptance criteria provided in NUREG-1520, Revision 2, including sections 7.4.3.2, Fire Hazards Analysis, 7.4.3.3, Facility Design and 7.4.3.5, Fire Protection and Emergency Response, which provide an acceptable approach for demonstrating compliance with the regulations.
Description of Issue The Urenco USA (UUSA) calculation CALC-S-00168, Human Error and Vehicle Crash Likelihood, analyzes the annual likelihoods for accident sequences of VC2-2 for a vehicle crash into the uranium byproduct cylinder (UBC) storage pad with fire, VC1-1 for an unmitigated vehicle crash with fire in Separations Building Module (SBM)-1001/SBM-1003 UF6 Handling Area, VC1-4 for an unmitigated vehicle crash with fire into SBMs or Cylinder Receipt and Dispatch Building (CRDB), and VC1-5 (an unmitigated vehicle crash with fire into SBM cascades, CRDB, or Centrifuge Assembly Building [CAB]). UUSA presents the annual likelihoods in table 5-1 for Mode #1 (construction traffic plus normal plant traffic crashes) and table 5-2 for Mode #2 (Normal plant traffic crashes) of CALC-S-00168.
Information Needed Explain how the Input 4.5 (= 0.0025 fires per crash), used for crash with fire, is determined.
Fire Safety RAI-2 The fire safety RAI is issued to determine whether the application provides commitments for adequate protection against fires and explosions that could affect the safety of licensed materials and thus present an increased radiological or chemical risk.
Regulatory Basis In compliance with 10 CFR 70.22(a)(7), applications need to include a description of equipment and facilities to protect health and minimize danger to life or property.
In accordance with the acceptance criteria provided in NUREG-1520, Revision 2, including sections 7.4.3.2, Fire Hazards Analysis, 7.4.3.3, Facility Design and 7.4.3.5, Fire Protection and Emergency Response, which provide an acceptable approach for demonstrating compliance with the regulations.
OFFICIAL USE ONLY-SECURITY RELATED INFORMATION 2
OFFICIAL USE ONLY-SECURITY RELATED INFORMATION Description of Issue UUSA stated, in CALC-S-00174, Consequence Analysis for Vehicle Impacts on Areas of Concern, that the SBM UF6 Handing Areas and the CRDB are built to meet the International Building Code (2003) and the fire rating for the exterior walls is 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and the roofs have a 1-hour fire rating for all SBMs and the CRDB.
Information Needed Describe the basic fire safety features in the areas of UBC storage pad, SBM-1001/SBM-1003 UF6 Handling Area, SBM cascades, CRDB, and CAB to ensure a fuel pool fire, caused by vehicle crash, would not cause any damage to facility structure/equipment, and would not migrate to other areas. The description for each of the five areas may include, but not limited to, the following fire safety features:
a) fire-rated barriers to contain fire in each area (e.g., wall, doors, CAB roof),
b) combustible materials installed or stored (e.g., type and amount),
c) fire suppression system (e.g., sprinkler system and fire extinguishers),
d) detection system (e.g., fire alarms and monitors), and e) Other measures to prevent fire spread and migration.