ML20350B762

Louisiana Energy Services, LLC - Exemption from Criticality Accident Alarm System Requirements Not Needed (L-2019-LLA-0217)

ML20350B762
Person / Time
Site:	07003103
Issue date:	12/22/2020
From:	Kevin Ramsey NRC/NMSS/DFM/FFLB
To:	Padgett W Louisiana Energy Services
KMRamsey - NMSS/DFM/FFL - 301.415.7506
References
EPID L-2019-LLA-0217
Download: ML20350B762 (3)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 22, 2020 Mr. Wyatt Padgett, Manager Licensing and Performance Assessment Louisiana Energy Services, LLC P.O. Box 1789 Eunice, NM 88231

SUBJECT:

LOUISIANA ENERGY SERVICES, LLC - EXEMPTION FROM CRITICALITY ACCIDENT ALARM SYSTEM REQUIREMENTS NOT NEEDED (ENTERPRISE PROJECT IDENTIFIER L-2019-LLA-0217)

Dear Mr. Padgett:

The U.S. Nuclear Regulatory Commission (NRC) staff has completed its evaluation of your letter dated November 21, 2019 (Agencywide Document Access and Management System (ADAMS) Accession No. ML19330D902), requesting an exemption from criticality accident alarm system (CAAS) requirements to take equipment out of service for maintenance. The regulation in Title 10 of the Code of Federal Regulations Section 70.24 (10 CFR 70.24),

Criticality accident requirements, states that each licensee shall maintain a monitoring system meeting the requirements specified. We have determined that the regulation permits temporary outages of the CAAS or associated equipment, provided that compensatory measures that achieve an equivalent safety function are implemented. Therefore, an exemption is not needed to perform the maintenance described in your application. You may wish to revise your commitments and procedures in accordance with your change control process to clarify this matter.

We have also considered whether the event described in your letter was required to be reported under 10 CFR 70.50(b)(2). You reported that before the CAAS was taken out of service compensatory measures were established that achieved an equivalent safety function during the outage, including the use of temporary criticality monitoring equipment. Under those circumstances, we do not consider taking the CAAS out of service to be a reportable event under 10 CFR 70.50(b)(2). Under 10 CFR 70.50(b)(2)(iii), an equipment outage is not reportable when redundant equipment is available and operable to perform the required safety function. In unplanned outages, compensatory measures should be implemented as soon as possible.

Please note that inspectors will evaluate whether you took appropriate actions in a timely manner in response to an unplanned failure of the CAAS.

Your submittal was assigned Enterprise Project Identifier (EPID) L-2019-LLA-0217. The EPID is considered CLOSED.

W. Padgett 2 In accordance with Title 10 of the Code of Federal Regulations Section 2.390, Public inspections, exemptions, requests for withholding of the NRCs Agency Rules of Practice and Procedure, a copy of this letter will be available electronically for public inspection in ADAMS.

The ADAMS is accessible from the NRC Web site at: http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

If you have any questions regarding this matter, please contact me at 301-415-7506, or via e-mail to Kevin.Ramsey@nrc.gov.

Sincerely, Kevin M. Digitally signed by Kevin M. Ramsey Ramsey Date: 2020.12.22 07:54:21

-05'00' Kevin M. Ramsey, Senior Project Manager Fuel Facility Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 70-3103 License No. SNM-2010 cc: les@listmgr.nrc.gov

ML20350B762 *via email OFFICE DFM/FFLB/PM* DFM/FFLB/LA* DFM/NARAB/BC* DFM/FFLB/BC* DFM/FFLB/PM*

NAME KRamsey ELee RChang DMarcano KRamsey DATE 12/15/2020 12/162020 12/16/2020 12/21/2020 12/22/2020