NUREG-1520, Recommends That 980504 Avlis Licensing Process License Application Be One Document W/O Part I/Part II Distinction. Staff Recommended Example of Application & Environ Rept Format,Encl
| ML20249C596 | |
| Person / Time | |
|---|---|
| Site: | 07003089 |
| Issue date: | 06/23/1998 |
| From: | Pierson R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Woolley R UNITED STATES ENRICHMENT CORP. (USEC) |
| References | |
| RTR-NUREG-1520, RTR-REGGD-03.052, RTR-REGGD-3.052 NUDOCS 9806300377 | |
| Download: ML20249C596 (6) | |
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UNITED STATES L
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j NUCLEAR REGULATORY COMMISSION c
WASHINGTON, D.C. 20566 4 001
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June'23, 1998 Mr. Robert L. Woolley, Manager AVLIS Nuclear Regulatory Policy and Licensing U.S. Enrichment Corporation 2 Democracy Center 6903 Rockledge Drive Bethesda, MD 20817-1818
SUBJECT:
ATOMIC VAPOR LASER ISOTOPE SEPARATION (AVLIS) LICENSING PROCESS LICENSE APPLICATION FORMAT AND CONTENT (Reference USEC Letter L-98-004 dated May 4,1998) l
Dear Mr. Woolley:
In the May 4,1998, letter sent by Mr. George Rifakes of the U.S. Enrichment Corporation to Dr.
Carl Paperiello of the U.S. Nuclear Regulatory Commission (NRC), he described the format and content that you intend to follow in your AVLIS application. More specifically, he proposed to submit a two part application as described in Regulatory Guide 3.52, Revision 1, with some deviations.
As you are aware,10 CFR Part 70 is currently being revised along with accompanying documents such as NUREG-1520," Standard Review Plan for the Review of a License Application for a Fuel Cycle Facility." The staff intends to prepare a Standard Review Plan -
specific to AVLIS by adapting the current draft fuel cycle facility Standard Review Plan in the latest draft version of NUREG-1520, to AVLIS. The staff expects to issue this document for public comment by September 1998. The staff's current position regarding the format and content of the AVLIS application is discussed in the paragraphs that follow; however, these are fluid because the revised Part 70 and the Standard Review Plan for AVLIS are either not final, or not yet developed.
l The staff recommends that your application be one document w2hout the Part 1/Part 11 1
distinction. The cornerstone of your application should be an Integrated Safety Analysis (ISA).
l The ISA should identify hazards and credible accident sequences that can result in radiological and non-radiological releases, along with their likelihood and consequences. It should also identify engineered and administrative controls deemed necessary to prevent or mitigate l
unacceptable consequences of the credible accidents. The recommended format of your application is shown in Enclosure 1. While some revision may be required to follow the guidance in the AVLIS Standard Review Plan, to be developed, following the format shown in at this time should minimize these revisions. The staff would like to emphasize, however, that the topics to be included in your application, as well as the depth of those topics that are included in the application, should be driven by the results of the ISA. The schedule you provided in your April 17,1998 letter calls for submittal of an ISA methods paper in June 1998.
The staff is willing to discuss the performance of an ISA with you, if you desire.
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s R. Woolley.
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~ Your proposal to develop and submit the Quality Assurance Plan, the Emergency Plan, an l
Environmental Report, and a Decommissioning Plan as reports separate from the application
'and to substitute them for portions of the application, is acceptable to accelerate the NRC j
review.. However, these documents should be included in the application, when submitted, for i
n completeness. The application should be a " stand-alone" document, to the extent possible, i
When preparing the Decommissioning Plan, Regulatory Guide 3.65, " Standard Format and -
i Content of Decommissioning Plans for Licensees Under 10 CFR Parts 30,40,70 and 72" and 1
NUREG/BR-0241, "NMSS Handbook for Decommissioning Fuel Cycle and Material Licensees",
and documents described therein, should also be followed in addition to those you referenced.
L' The recommended format and content of the Environmental Report is shown in Enclosure 2.
The content of the Environmental Report should be based on the content of Regulatory Guides
- 3.52 and 4.9 and should also be augmented using Draft NUREG-1555, " Standard Review Plan.
' for the Environmental Reviews of Nuclear Power Plants"(August 1997). Subsections within
' NUREG-1555 that are specifically directed toward reactors, such as cooling and transmission systems, should be adapted to enrichment facilities, if possible, or deleted, Again, the staff l
would like to emphasize that the depth of the environmental protection measures section and the environmental engineered and administrative controls deemed necessary, should be based -
t on the results of the ISA, in addition to the requirements under 10 CFR Part 51.
i i
C The staff anticipates that changes to the facility would be permitted without NRC approval provided that the change: 1) results in only a minimal increase in the likelihood or consequences -
of an accident previously analyzed, or 2) does not introduce the possibility for an unanalyzed -
I L accident.
' As previously discussed, the above guidance may change as we progress in the AVLIS review -
since many of the documents upon which it was based are undergoing revision or have not yet been developed. The staff intends to use the most recent guidance documents in its AVLIS 1
j; review since these documents most closely reflect the staffs recent thinking on Part 70.
If you have any questions, please call me at 415-7192 or Andrew Persinko, the AVLIS Project Manager, at 415-6522, o
?
Sincerely,
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Robert C. Pierson, Chief Special Projects Branch
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Division of Fuel Cycle Safety and Safeguards
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Office of Nuclear Material Safety and Safeguards Docket 70-3089 cc:
- Mr. George Rifakes -
Executive Vice-President U.S. Enrichment Corporation'
' 2 Democracy Center -
- 6403 Rockledge Drive Bethesda, MD 20817-1818 h __ t
R. Woolley '
and to substituta them for portions of the application, is accsptabis to accelsrate ths NRC review. However, these documents should be included in the application, when submitted, for lt
. comp e eness. The application should be a " stand-alone" document, to the extent possible.
When preparing the Decommissioning Plan, Regulatory Guide 3.65," Standard Format and.
' Content of Decommissioning Plans for Licensees Under 10 CFR Parts 30,40,70 and 72" and NUREG/BR-0241, "NMSS Handbook for Decommissioning Fuel Cycle and Material Licensees",
and documents described therein, should also be followed in addition to those you referenced.
1 The ' recommended format and content of the Environmental Report is shown in Enclosure 2.
The content of the Environmental Report should be based on the content of Regulatory Guides 3.52 and 4.9 and should also be augmented using Draft NUREG-1555, " Standard Review Plan for the Environmental Reviews of Nuclear Power Plants"(August 1997). Subsections within NUREG-1555 that are specifically directed toward reactors, such as cooling and transmission systems, should be adapted to enrichment facilities, if possible, or deleted. Again, the staff would like to emphasize that the depth of the environmental protection measures section and the environmental engineered and administrative controls deemed necessary, should be based on the results of the ISA, in addition to the requirements under 10 CFR Part 51.
The staff anticipates that changes to the facility would be permitted without NRC approval provided that the change: 1) results in only a minimal increase in the likelihood or consequences of an accident previously analyzed, or 2) does not introduce the possibility for an unanalyzed accident.
As previously discussed, the above guidance may change as we progress in the AVLIS review
. since_many of the documents upon which it was based are undergoing revision or have not yet been developed. The staff intends to use the most recent guidance documents in its AVLIS review since these documents most closely reflect the staff's recent thinking on Part 70.
If you have any questions, please call me at 415-7192 or Andrew Persinko, the AVLIS Project I
Manager, at 415-6522.
Sincerely, Robert C. Pierson, Chief Special Projects Branch Division of Fuel Cycle Safety and Safeguards Office of Nuclear Material Safety and Safeguards cc:
Mr. George Rifakes l
Executive Vice-President U.S. Enrichment Corporation 2 Democracy Center 6403 Rockledge Drive Bethesda, MD 20817-1818 DISTRIBUTION: Docket 70-3089 NRC File Center 1P_UBLIC e NMSS r/f FCSS r/f SPB r/f AMv5-4res.611
- see previous concurrence Sh OFC SPB E
SPB E
SPB E
NAME DPersinko:jh*
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DMartin*
R erson h/M /98 DATE 6/12/98 6/16/98 6/17/98 C = COVER E u COVER & ENCLOSURE N = NO COPY OFFICIAL RECORD COPY t__________
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2 1
When preparing 'the Decommissioning Plan, Regulatory Guide 3.65," Standar at and Content for Licensees Under 10 CFR Parts 30,40,70 and 72" and NUREG/BR4241,"NMSS j
Handbook for Decommissioning Fuel Cycle and Material Licensees", and do ments described therein, should also be followed in addition to those you referenced.
The recommended format and content of the Environmental Report i hown in Enclosure 2.
l The content of the environmental report should be based on the c nt of Regulatory Guides 3.52 and 4.9 and should also be augmented using Draft NUREGf-55," Standard Review Plan for the Environmental Reviews of Nuclear Power Plants"(Augup 1997). Subsections within NUREG-1555 that are specifically directed toward reactors, such as cooling and transmission systems, should be adapted to enrichment facilities, if possible, or deleted. Again, the staff would like to emphasize that the depth of the environmental protection measures section and the environmental engineered and administrative con 'Is deemed necessary, should be based on the results of the ISA.
The staff anticipates that changes to the facility ould be permitted without NRC approval i
. provided that the change: 1) results in only a inimalincrease in the likelihood or consequences of an accident previously an yzed, or 2) does not introduce the possibility for an -
unanalyzed accident.
As previously discussed, the above idance may change as we progress in the AVLIS review since man'y of the documents upo 4hich it was based are undergoing revision or have not yet been developed. The staff inten to use the most recent guidance documents in its AVLIS review since these documents, ost closely reflect the staff's most recent thinking on Part 70.
.lf you have any questions $ lease call me at 415-7192 or Andrew Persinko, the AVLIS Project h
Manager, at 415-6522.
Sincerely, Robert C. Pierson, Chief Special Projects Branch Division of Fuel Cycle Safety and Safeguards Office of Nuclear Material Safety and Safeguards
. DocketJ0-3089 L
DISTRIBUTION: Docket 70 3089 NRC File Center PUBLIC NMSS r/f FCSS r/f SPB r/f OFC SPB-8 hPB h
- SEB, SPB NAME' Persinko:ij 7 Hoadley Irtin RPierson DATE
[a /N98 h /N/98
/h/98
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/98 l-C = COVER E = COVER & ENCLOSURE N = NO COPY fi av5-4res.611 OFFICIAL RECORD COP l
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RECOMMENDED APPLICATION FORMAT 1.0 -. General Information
~ 1.1 -
Facility and Process Description 1.2 Institutionalinformation ;
- 1.3.
Site Description ~
- 2.0 Organization _ and Administration '
3.0 Integrated Safety Analysis 4.0 Radiation Safety 5.0 Nuclear Criticality Safety 6.0
- Chemical Process Safety.
- 7.0 Fire Safety L
8.0 : - Emergency Management 9.0 '-
Environmental Protection 10.0. Decommissioning 11.0 Management Control Systems 11.1 Configuration Management l
11.2 Maintenance.
11.3 Quality Assurance
~ 11.4 Training and Qualification.
11.5 - Procedures 11.6 - ; Human-System Interfaces 11.7.
Audits and Assessments
~
11.8 Incident investigations 11.9 Records Management i
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ENCLOSURE 1 1
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i RECOMMENDED FORMAT / CONTENT FOR ENVIRONMENTAL REPORT t
l.
Environmental Report l
- 1. Description of Proposed Action
-RG 3.52,10.1.1
-RG 4.9, Ch 1
- 2. Purpose of Proposed Action
-RG 3.52,10.1.2
-RG 4.9, Ch 1 l
- 3. Description of Affected Environment
-RG 3.52,10.1.3 l
-RG 4.9, Ch 2 and 3
)
l
-NUREG-1555, Ch 2 and 3
)
l
- 4. Environmental Considerations
-RG 3.52,10.1.4 i
-RG 4.9, Ch 4, 5, and 7
-NUREG-1555-Ch 4, 5, 7, 9, and 10
-Results of ISA
-Benefit Cost Analysis i
-RG 4.9, Ch 8 -
-NUREG-1555,10.4
- 5. Analysis
-RG 3.52,10.1.5
- 6. Status of Compliance
-RG 3.52,10.1.6 l
l 11.
Environmental Protection Measures The environmental protection measures should address three elements: (1) the radiation protection program (2) effluent and environmental controls and n.onitoring, and (3) the
- ISA. The ISA will identify accident sequences that can result in radiological and non-radiological releases to the environment, along with their likelihood and consequences.
The Environmental Monitoring Program indicated in RG 3.52,10.2.2 can also be augmented by RG 4.9, Ch 6 and NUREG 1555, Ch 6. Supporting functions, such as training of personnel, QA/QC, and organization and management, as they relate to environmental safety aspects, should be described.
l ENCLOSURE 2 I
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