ML26065A264
| ML26065A264 | |
| Person / Time | |
|---|---|
| Site: | Global Laser Enrichment Headquarters File:Global Laser Enrichment icon.png |
| Issue date: | 03/24/2026 |
| From: | NRC/NMSS/DFM/FFLB |
| To: | |
| References | |
| EPID L-2024-NEW-004, 2026-0306-80012 | |
| Download: ML26065A264 (0) | |
Text
Set 2 - Chapter 2 - Organization and Administration 1
REQUESTS FOR ADDITIONAL INFORMATION REGARDING THE REVIEW OF CHAPTER 2 - ORGANIZATION AND ADMINISTRATION REGARDING THE PADUCAH LASER ENRICHMENT FACILITY The U.S. Nuclear Regulatory Commission (NRC) staff developed the following requests for additional information (RAI) regarding the organization and administration to support NRCs review of the Global Laser Enrichment, LLC (GLE) Paducah Laser Enrichment Facility (PLEF) license application (LA).
Set 2 - RAI-1 Reporting potentially unsafe conditions Regulatory Requirements:
The provisions of Title 10 of the Code of Federal Regulations (10 CFR) 70.22(a)(6) state that each application for a license shall contain [t]he technical qualifications, including training and experience of the applicant and members of his staff to engage in the proposed activities in accordance with the regulations in this chapter[.]
The provisions of 10 CFR 70.23(a)(2) state that an application for a license will be approved if the Commission determines that [t]he applicant is qualified by reason of training and experience to use the material for the purpose requested in accordance with the regulations in this chapter[.]
Guidance:
The guidance in NUREG-1520, Revision 2, Standard Review Plan for Fuel Cycle Facilities License Applications, (ML15176A258) includes the acceptance criteria in Section 2.4.3.B, that state an applicants safety program description should include appropriate commitments relevant to item #6 - which says that the applicant should commit to a simple mechanism, available for use by any person in the plant, for reporting potentially unsafe conditions or activities to the health, safety, and environmental (HS&E) organization and that reported concerns should be promptly investigated, assessed, and resolved.
Description of Issue:
Section 2.4.1 of the PLEF LA references various resources for employees to report concerns -
however, additional clarity is needed on the reporting mechanism, to whom concerns should be reported, and how concerns are investigated, assessed, and resolved.
Information Needed:
Provide clarification in Chapter 2 of the PLEF LA on:
1.
The specific resources that will provide personnel with a simple mechanism for reporting potentially unsafe conditions or activities; 2.
The individual positions responsible for receiving reports of potentially unsafe conditions or activities (e.g., managers with authority to shut down potentially unsafe operations);
and 3.
How those concerns are promptly investigated, assessed, and resolved.
Set 2 - Chapter 2, Organization and Administration 2
Set 2 - RAI-2 Accessibility of position descriptions Regulatory Requirements:
Same Regulatory Requirement as RAI 1.
Guidance:
The guidance in NUREG-1520, Revision 2, includes the acceptance criteria in Section 2.4.3.A, that state an applicants safety program description should include appropriate commitments relevant to item #3 - which says, in part, that the qualifications, responsibilities, and authorities for key supervisory and management positions with HS&E responsibilities are clearly defined in position descriptions that are accessible to all affected personnel and to the NRC, upon request.
Description of Issue:
Section 2.2.3 of the PLEF LA provides information on the minimum qualifications, roles, and responsibilities for positions that are important to HS&E. Section 2.3 of the PLEF LA references written position descriptions. However, the NRC staff was unable to locate a commitment in Chapter 2 of the PLEF LA that the position descriptions will be accessible to all affected personnel and to the NRC, upon request.
Information Needed:
Provide a commitment in Chapter 2 of the PLEF LA for the position descriptions to be accessible to all affected personnel and to the NRC, upon request.
Set 2 - RAI-3 Authority to shut down potentially unsafe processes and approve restart Regulatory Requirements:
Same Regulatory Requirement as RAI 1.
Guidance:
The guidance in NUREG-1520, Revision 2, includes the acceptance criteria in Section 2.4.3.B, that state an applicants safety program description should include appropriate commitments relevant to item #4 - which says that the individual delegated overall responsibility for the HS&E functions should have the authority to shut down operations if they appear to be unsafe and, in that case, must approve restart of shutdown operations or licensed activities.
Description of Issue:
Section 2.3 of the PLEF LA provides information on key management roles, responsibilities, and qualifications. The authority to shut down potentially unsafe operations is referenced by the PLEF LA in Section 2.3.6.1 for the Nuclear Criticality Safety Manager, Section 2.3.8.2 for the Fire Safety Manager, and Section 2.3.8.4 for the Radiation Protection Manager. However, that authority is not referenced in the PLEF LA under Section 2.3.2 for the Plant Manager, Section 2.3.8 for the Compliance Manager, or Section 2.3.8.3 for the Environmental Health & Safety Manager. Furthermore, the NRC staff was unable to determine the appropriate authority at PLEF for approving the restart of processes that were shut down for being potentially unsafe.
Set 2 - Chapter 2, Organization and Administration 3
Information Needed:
Provide clarification in Chapter 2 of the PLEF LA on:
1.
Whether the Plant Manager, Compliance Manager, and Environmental Health & Safety Manager have the authority to shut down potentially unsafe processes (or even the facility as a whole); and 2.
Which manager(s) will have the authority to approve the restart of shutdown processes.
Set 2 - RAI-4 Quality Assurance (QA) Manager experience Regulatory Requirements:
Same Regulatory Requirement as RAI 1.
Guidance:
The guidance in NUREG-1520, Revision 2, includes the acceptance criteria in Section 2.4.3.A, that state an applicants safety program description should include appropriate commitments relevant to item #3 - which says, in part, that the qualifications for key supervisory and management positions with HS&E responsibilities are clearly defined in position descriptions.
Description of Issue:
Section 2.3 of the PLEF LA provides information on key management roles, responsibilities, and qualifications. Section 2.3.3 of the PLEF LA states that [t]he QA Manager should have, as a minimum, a bachelors degree (or equivalent) in engineering or scientific field and 4 years of quality assurance experience at a nuclear facility. All other qualifications in Section 2.3 of the PLEF LA state that the management position shall have certain qualifications. The use of should instead of - shall - for the QA Manager makes the minimum training requirements uncertain.
Information Needed:
Revise Section 2.3.3 of the PLEF LA to state that the QA Manager has the minimum qualifications.
Set 2 - RAI-5 Experience specified for Nuclear Criticality Safety Manager, Integrated Safety Analysis (ISA) Manager, and Licensing Manager Regulatory Requirements:
Same Regulatory Requirement as RAI 1.
Guidance:
The guidance in NUREG-1520, Revision 2, includes the acceptance criteria in Section 2.4.3.A, that state an applicants safety program description should include appropriate commitments relevant to item #3 - which says, in part, that the personnel responsible for managing the design, construction, operation, and modifications of the facility or licensed activities have
Set 2 - Chapter 2, Organization and Administration 4
substantive breadth and level of experience.
Additionally, NRC Regulatory Guide (RG) 1.8, Rev. 4, Qualification and Training of Personnel for Nuclear Power Plants (ML19101A395), provides the agencys most applicable guidance on what is considered substantive breadth and level of experience. RG 1.8, Rev. 4, references ANSI/ANS-3.1-2014, "Selection, Qualification, and Training of Personnel for Nuclear Power Plants," which generally specifies 4 years as the minimum experience for a middle level manager position.
Description of Issue:
Section 2.3 of the PLEF LA provides information on key management roles, responsibilities, and qualifications. The PLEF LA contains qualifications in Section 2.3.6.1 for the Nuclear Criticality Safety Manager, Section 2.3.6.2 for the ISA Manager, and Section 2.3.8.1 for the Licensing Manager. Those descriptions specify 3 years as the minimum experience for those middle level manager positions, which is lower than the 4 years of experience identified in guidance and does not include a justification.
Information Needed:
Justify or revise the 3 years of experience referenced in PLEF LA Section 2.3.6.1 for the Nuclear Criticality Safety Manager, Section 2.3.6.2 for the ISA Manager, and Section 2.3.8.1 for the Licensing Manager.
Set 2 - RAI-6 Qualifications for key Emergency Preparedness personnel Regulatory Requirements:
Same Regulatory Requirement as RAI 1.
Guidance:
The guidance in NUREG-1520, Revision 2, includes the acceptance criteria in Section 2.4.3.A, that state an applicants safety program description should include appropriate commitments relevant to item #3 - which says, in part, that the personnel responsible for managing the design, construction, operation, and modifications of the facility or licensed activities have substantive breadth and level of experience.
Description of Issue:
Section 2.3.8.6 of the PLEF LA states that [t]he minimum qualifications for key Emergency Preparedness personnel are defined in the Emergency Plan. The NRC staff reviewed the PLEF Emergency Plan dated June 27, 2025, but was unable to locate the minimum qualifications for key Emergency Preparedness personnel.
Information Needed:
Revise either Chapter 2 of the PLEF LA or the PLEF Emergency Plan to include the minimum qualifications for key Emergency Preparedness personnel.