ML23333A090

Louisiana Energy Services, LLC, Dba Urenco USA, Semi-Annual Safety Analysis Report (SAR) Update

ML23333A090
Person / Time
Site:	07003103
Issue date:	11/28/2023
From:	Padgett W Louisiana Energy Services, URENCO USA
To:	Office of Nuclear Material Safety and Safeguards, Document Control Desk
References
LES-23-162-NRC
Download: ML23333A090 (1)

Text

LES-23-162-NRC Attn: Document Control Desk Director Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Louisiana Energy Services, LLC NRC Docket No. 70-3103

Subject:

Semi-Annual Safety Analysis Report (SAR) Update In accordance with Materials License SNM-2010, Condition 30, Louisiana Energy Services (LES), dba Urenco USA (UUSA) herewith submits changes made under UUSAs own authority to the Safety Analysis Report (SAR) for the semi-annual period of May, 2023 through October, 2023.

The enclosure contains the marked up pages to the Safety Analysis Report for revision 50a. A description of each change is provided in the revision history. Revision bars, strikethroughs and underlines were utilized.

If you have any questions concerning this submittal, please contact Holly Harvey at 575.394.6526.

Respectfully, Wyatt Padgett Head of Compliance

Enclosure:

Marked up pages of the Safety Analysis Report Urenco USA Inc.

UUI l P.O. Box 1789 l 275 Hwy. 176 l Eunice l New Mexico l 88231 l USA T: +1 (575) 394-4646 l W: www.urencousa.com

© 2023 Urenco USA Inc.

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LES-23-162-NRC CC: via email Jonathan Rowley, Senior Project Manager - UUSA U.S. Nuclear Regulatory Commission Jonathan.Rowley@nrc.gov Samantha Lav, Branch Chief Fuel Facility Licensing U.S. Nuclear Regulatory Commission Samantha.Lav@nrc.gov Urenco USA Inc.

UUI l P.O. Box 1789 l 275 Hwy. 176 l Eunice l New Mexico l 88231 l USA T: +1 (575) 394-4646 l W: www.urencousa.com

© 2023 Urenco USA Inc.

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Enclosure Marked up pages of the Safety Analysis Report (revision bars, strikethroughs and underlines utilized)

SAFETY ANALYSIS REPORT Revision 50a0

Table of Contents Summary of Changes Rev 50a50 Issue /

Change Description of Change Date GCP-073:

SAR Section 1.1.3.2, pg 1.1-7, 1.1 Removed references to various Production Phases of Operations in Chapter 12, AC 171129: Updated SAR Section 1.3.2.3, pg 1.3-4 with Covenant Health Hobbs Hospital name change and updated the bed count from 250 to 99 AC 168390 - Updated SAR Section 1.2.1.2, pg 1.2-11 to state "The President and Chief Executive Officer" for consistency Corrected minor issues with SAR 5.6-7, pgs 5.6-7/10/11 tables (blue 50 /

LBDCR-22-016 text and have inconsistent fonts) 03/23/2023 AC 170888 - Updated SAR Section 8, pg 8.0-1 to indicate that the MOU files are kept by the Safety and Emergency Response Manager.

AC 170838: SAR Section 11.5.1, pg 11.5-1 Assessment, moved the nuclear criticality safety requirements from the 3rd paragraph that are applicable to the NCS assessment, into paragraph 7 discussion about the NCS assessment.

AC 169116: Revised table in SAR Section 12, p 12.0-2 to correct the accident sequence, as CHEM RELEASE-WORKER EVAC is not an EE sequence GCP-060:

Section 7.1.5 removed semi-annual for classroom training, and physical requirements.

50a LBDCR-23-002 Section 7.5.2.1 removed staffing of a minimum of 4 individuals, and three incipient firefighters.

Section 11.3.3.1.2 removed semi-annual requirement from classroom training.

Safety Analysis Report Page-i Rev 50a50

7.1 Fire Safety Management Measures LBDCR-23-002 The Fire Brigade Program provides entrance and educational requirements for fire brigade candidates as well as the medical- and job-related physical requirements. The Fire Brigade Training Program provides for initial training of all new fire brigade members, semi-annual classroom training and drills, annual practical training, and leadership training for fire brigade leaders.

The NEF Emergency Plan also discusses the use of offsite emergency organizations, drills and training.

Pre-Fire Plans Detailed pre-fire plans will be developed for use by the facility fire brigade.

The pre-fire plans include the location of fire protection equipment, approach paths for fire response, potential hazards in the area, power supply and ventilation isolation means, important plant equipment in the area and other information considered necessary by fire emergency response personnel.

Safety Analysis Report Page-7.1-3 Rev 50a50

7.5 Fire Protection and Emergency Response All fire protection water system control valves are monitored under a periodic inspection program and their proper positioning is supervised in accordance with NFPA 801.

Fire Emergency Response 7.5.2.1 Fire Brigade The facility maintains an incipient fire brigade made up of employees trained in fire prevention, fire fighting techniques, first aid procedures, emergency response, and criticality safety. The criticality safety training addresses water moderation, water reflection, product cylinder safety by moderation control, and water flooding. The fire brigade is organized, operated, trained and equipped in accordance with NFPA 600. The fire brigade is considered an incipient fire brigade as classified under NFPA 600, e.g., not required to wear thermal protective clothing nor self-contained breathing apparatus during firefighting. The intent of the facility fire brigade is to be able to extinguish all minor fires. The fire brigade members are trained and equipped to provide initial response to fire emergencies until offsite help from a neighboring fire department arrives.

This will include the use of hand portable fire extinguishers. When the local fire department arrives onsite, the local fire department works under a unified command structure for all fire fighting activities. The plant fire brigade, working with the plants Emergency Operations Center, will coordinate offsite fire department activities to ensure moderator control and criticality safety.

LBDCR-23-002 The fire brigade is staffed so that there are a minimum of four (4) individuals, consists of a Fire Brigade leader who acts as the teams Incident Commander, and three (3) incipient firefighters.

The Fire Brigade consists of any qualified plant personnel. Building Operators that make up the minimum shift crew composition can also be assigned to the fire brigade. One qualified member of the Emergency Response Organization/Fire Brigade will be assigned the function of Fire Brigade Safety Officer. The Fire Brigade Safety Officer is responsible to ensure that moderator concerns are considered for criticality safety during firefighting.

Periodic training is provided to offsite assistance organization personnel in the facility emergency planning procedures. Facility emergency response personnel meet at least annually with each offsite assistance group to accomplish training and review items of mutual interest including relevant changes to the program. This training includes facility tours, information concerning facility access control (normal and emergency), potential accident scenarios, emergency action levels, notification procedures, exposure guidelines, personnel monitoring devices, communications, contamination control, moderator control issues, and the offsite assistance organization role in responding to an emergency at the facility, as appropriate.

7.5.2.2 Off-Site Organizations LES will use the services of local, offsite fire departments to supplement the capability of the facility Fire Brigade. The two primary agencies that will be available for this response are the City of Eunice, New Mexico Fire and Rescue Agency and the City of Hobbs, New Mexico Fire Department. Both agencies are signatories to the Lea County, New Mexico Mutual Aid agreement and can request additional mutual aid from any of several county fire departments/fire districts.

A Memorandum of Understanding is in place between LES and these two local fire departments. The Memorandum of Understanding defines the fire protection and emergency Safety Analysis Report Page-7.5-5 Rev 50a50

11.3 Training and Qualifications D. Contents of the nuclear safety training programs and the radiation protection programs are reviewed and updated through curriculum meetings at least every two years. The safety training programs curriculum meeting is chaired by the Operations Manager, or designee. The radiation protection programs curriculum meeting is chaired by the Compliance Manager, or designee.

E. Operational personnel are further instructed in the specific safety requirements of their work assignments by qualified personnel during on-the-job training. Employees must demonstrate understanding of work assignment requirements based on observations by qualified personnel before working without direct supervision. Changes to work procedures including safety requirements are reviewed with operational personnel by their immediate supervisor or delegate.

Fire Brigade Training The primary purpose of the Fire Brigade Training Program is to develop a group of facility employees skilled in fire prevention, fire fighting techniques, first aid procedures, and emergency response. They are trained and equipped to function as a team for the fighting of fires. The intent of the facility fire brigade is to be a first response effort designed to supplement the local fire department for fires at the plant. The facility fire brigade is not intended to replace local fire fighters.

LBDCR-23-002 The Fire Brigade Training Program provides for initial training of all new fire brigade members, semi-annual classroom training and drills, annual practical training, and leadership training for fire brigade leaders.

11.3.3.2 Technical Training Technical training is designed, developed and implemented to assist facility employees in gaining an understanding of applicable fundamentals, procedures, and practices related to IROFS. Also, technical training is used to develop manipulative skills necessary to perform assigned work related to IROFS. Technical training consists of four segments:

Initial Training On-the-Job Training and Qualifications Continuing Training Special Training.

Initial Training Initial job training is designed to provide an understanding of the fundamentals, basic principles, and procedures involved in work related to IROFS that an employee is assigned. This training may consist of, but is not limited to, live lectures, taped and filmed lectures, self-guided study, demonstrations, laboratories and workshops and on-the-job training.

Certain new employees or employees transferred from other sections within the facility may be partially or wholly qualified by reason of previous applicable training or experience. The extent of further training for these employees is determined by applicable regulations, performance in review sessions, comprehensive examinations, or other techniques designed to identify the employees present level of ability.

Safety Analysis Report Page-11.3-5 Rev 50a50