ML20128G915
| ML20128G915 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant, Paducah Gaseous Diffusion Plant |
| Issue date: | 10/04/1996 |
| From: | Woolley R UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Ten Eyck E NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| GDP-96-0180, GDP-96-180, NUDOCS 9610090168 | |
| Download: ML20128G915 (10) | |
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United States Ennchment Corporation 2 Democracy Center 6903 Rockledge Drive Bethesda, MD 20817 Tel. (301) 564-3200 Fax: (301) 564-3201 Liiiteil States l',tirielitiierit ('orporatiori October 4,1996 Ms. Elizabeth Q. Ten Eyck SERIAL: GDP 96-0180 Director Division of Fuel Cycle Safety and Safeguards, NMSS United States Nuclear Regulatory Commission Washington, D.C. 20555-0001 Paducah Gaseous Diffusion Plant (PGDP)
Portsmouth Gaseous Diffusion Plant (PORTS)
Docket Nos. 70-7001 & 70-7002 Response to NRC Request for Information
Dear Ms. Ten Eyck:
Your letter dated September 26,1996, requested USEC to provide the following information:
Confirmation of the schedule for completing the Compliance Plan requirements regarding DOE-owned materials in USEC leased space.
A description of our programs for evaluating radioactive contaminants in feed material at both sites and assuring that contaminants are controlled so that they do not cause a safety problem during use or processing.
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9610090168 961004 PDR ADOCK 07007001 C
PDR Othces in Paducah, Kentucky Portsmouth, Ohio Washington, DC
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Ms. Elizabeth Q. Ten Eyck Oi:tober 4,1996 GDP 96-0180 Page 2 Enclosures 1 and 2 to this letter provide our responses to the above requested information. If you l
have any questions or require additional information, please contact me at (301) 564-3413 or Russ Wells at (301) 564-3245. There are no new commitments contained in this submittal.
Sincerely, i
Robert L. Woolley l
Nuclear Regulatory Assurance and Policy Manager l
cc: cc:
l NRC Region III Office l
NRC Resident Inspector - PGDP NRC Resident Inspector - PORTS l
DOE Regulatory Oversight Manager DOE IIQ l
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Ms. Elizabeth Q. Ten Eyck Obtober 4,1996
' GDP 96-0180 Page 3
Enclosures:
1.
Confirmation of Compliance Requirements for DOE-owned material in USEC leased space.
2.
Description of USEC programs for evaluating radioactive contaminants in feed material at both sites.
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Confirmation of Cempliance Requirements for DOE-Owned Material in USEC Leased Space
Background
The storage of DOE-owned material in USEC leased spaces has been the subject of several letters among DOE, USEC, and NRC (see References 1 through 4). As discussed in Reference 4, USEC and l
DOE have entered into an agreement for DOE material storage at the GDPs. The issue of DOE-owned 1
l material is further addressed in the Compliance Plans for the GDPs (i.e., issue A.5 for PORTS and A.7 l
for PGDP). These portions of the Compliance Plans describe the actions to be taken by USEC to demarcate and delease those areas at the GDPs that currently contain DOE-owned material. The actions to be taken by USEC under these Compliance Plan Issues are listed below:
1.
Complete approval of a UE2-level procedure that controls establishment and maintenance of DOE material storage area boundaries and controls access to these areas and reporting to DOE of unauthorized disturbance of the areas. The scheduled completion date for this action is November 30,1996.
2.
Demarcate the location and boundaries of DOE material storage areas in leased premises and return these areas to DOE control and oversight. The scheduled completion date for this action is December 31,1996.
Following the completion of these actions, the DOE-owned material that is currently in USEC-leased space will become the responsibility of DOE, including the ultimate disposal of this material. USEC believes that this is consistent with the Commisioners' understanding of this issue. At the NRC staff briefing of the NRC Commissioners on Certification of USEC on August 28,1996, Dr. Paperiello stated:
"The areas in which DOE material is stored will be deleased and returned to DOE, which has agreed to assume responsibility including regulatory responsibility for the areas for the contained material. Note that, DOE still owns the site and continues to conduct its own self-regulated operation separate from USEC in both leased and deleased areas. This situation will require special attention and coordination after certification to assure that DOE activities do not negatively impact the safety of USEC operations regulated by NRC."
Confirmation of Comnliance Plan Action Dates USEC has reviewed the status of the efforts underway to fulfill the above Compliance Plan due dates and has determined that those efforts are on schedule. DOE has agreed to assist us in our efforts to delease the areas containing DOE-owned material. The current status of the efforts needed to complete these Compliance Plan issues is provided below:
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- l. Completion of UE2 level procedure PGDP and PORTS personnel are scheduled to meet on October 8,1996, to develop this procedure. Following this meeting, a draft of this procedure will be finalized and the review and approval process will commence. This procedure is scheduled to be completed by November 30, 1996.-
- 2. De-Leasing DOE-owned Storage Areas The activities needed to fulfill this Compliance Plan Action are:
Develop plant and building drawings showing storage locations.
Post storage locations with signs indicating DOE material storage.
e Delease the storage locations.
The status of these activities is described below:
Develon nlant and building drawings Cascade building areas containing DOE-owned material have been identified and engineering drawings are being drafted. Walkdown of the DOE material storage areas (DMSAs) inside and outside the balance of plant buildings are in progress. The final drawings denoting the DMSAs are expected to be finalized by November 15,1996.
Posting of storage locations At PORTS, several outside locations (e.g., scrap metal boxes) have postings that currently meet the requirements of the USEC/ DOE agreement. At PGDP, the posting process has not yet commenced. A meeting is scheduled for October 8,1996, at PORTS with USEC and DOE personnel to discuss the wording for the postings. The posting of the DMSAs is scheduled to be completed by December 15,1996.
Deleasing the storage locations.
Following the completion of the drawings denoting the DMSAs, USEC will work with DOE to delease these areas to DOE. This activity is scheduled to be completed by December 31,1996.
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References i
- 1. DOE letter to NRC, J. W. Parks to E. Ten Eyck, " Evaluation of DOE Stored Materials at the Gaseous Diffusion Plants," dated December 22,1995.
Regulation of Department of Energy (DOE) - Owned Material Stored in Leased Areas," dated January 9,1996.
- 3. DOE letter to NRC, J. W. Parks to E. Ten Eyck, " Department of Energy Material Stored in Leased s 'N Space," dated. April 11,1996.
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- 4. DOE letter to USEC, J. W. Parks to G. P. Rifakes, " Agreement for Department of Energy Stored materials at the Gaseous Diffusion Plants."
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Description of Programs for Evaluating Radioactive Contaminants in Feed Material j
introduction Based on our October 2,1996, discussion with the NRC staff, it is USEC's understanding that the concern regarding potential contaminants in feed material relates to the following:
Description of the USEC program for controlling and sampling for radioactive contaminants in feed material; and Description of the USEC program for assuring that there are no significant adverse health or j
safety impacts associated with feed material that may not fully meet applicable ASTM standards.
There are several sources of material received by USEC at PORTS and PGDP that are either utilized as feed, blendstock, or direct shipment without further processing. The various types of feed material are discussed in the paragraphs below.
- 1. Commercial Natural Feed Materials Commercial natural UF feed is received at both plants from several suppliers. Currently, PGDP feeds commercial natural UF. At both plants, two feed cylinders per month are sampled to 6
determine confonnance with ASTM C787-1990. No analysis for U-236 is currently performed because suppliers have been shown historically to have provided feed that is of virgin origin. Thus, this material meets the ASTM specification, C787-90, for radionuclides as " Commercial Natural UF "
6 by having a U-236 content ofless than 20 ug/g-U. No technetium, or radionuclide.malyses other than U-235, are required for this feed material because ofits natural origin. Occasional sampling for technetium has been perfomied on request and has consistently indicated that the feed material is of virgin origin. In the unanticipated event that the U-236 content were to exceed the specification limit, evidence of this would appear in the PGDP or PORTS product and USEC would initiate corrective actions accordingly.
- 2. Enriched Feed Materials Enriched feed material is of two types: 1) Paducah product shipped to PORTS for further enrichment; and 2) other "in process" material. Enriched product received from PGDP at PORTS is considered in-process material in SAR Chapter 1, Table 1-3, Note f and is therefore exempt from the ASTM specification for feed. A statistical sampling plan is followed for NMC&A purposes. An average of two cylinders per month are sampled for assay and purity, as a minimum. Although technetium analysis is not required per the specification, PGDP analyzes for it on a frequency of two product cylinders per month and PORTS analyzes for it on an as-requested basis for product control purposes. Technetium is present in the cascades at both PGDP and PORTS as a legacy from the 1960s and 1970s, when uranium from reactor production was blended into the process system.
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. Additianally, stored material (typically enriched) that was originally withdrawn from the cascade, and legacy inventory materials are considered in-process. These materials may or may not meet the ASTM specifications, but are exempted from these requirements at PORTS as discussed in the previous paragraph. Information on the assay and purity of these materials either from production data or from sample analysis is typically available. Whenever it is expected that the concentrations of either U-234, U-236 or technetium may impact product quality, the material feed rates are controlled to minimize that impact. In the case ofIIEU refeed, technetium traps will be installed in the PORTS Product Withdrawal (PW) facility to minimize the impact of this contaminant.
Regardless of the feed source, PORTS product meets ASTM C996-90 requirements with the occasional exception that the technetium limits for enriched commercial grade product are exceeded.
Technetium analyses are being performed routinely even though the U-236 content trigger point of the ASTM standard is rarely exceeded. In some instances, product with an elevated technetium content has been accepted by the customer by agreement. In other cases, the out-of-specification product is refed or blended to meet specification requirements. These instances of out-of-specification product do not reflect a radiological safety concern as discussed further in section 4 of i
this enclosure.
- 3. Russian Feed Material and Other Enriched Feeds At the NRC briefing to the Ccramissioners on certification of USEC, a question was raised conceming the possibility of contaminants being introduced into the cascade process from Russian feed material. As was indicated by USEC at the Commissioners' briefing, the Russian material meets the ASTM specifications for nuclear fuel. Additional infom1ation on this material is provided below:
Enriched material is often received from other outside sources. Currently the largest flow of this material is LEU derived from Russian 11EU, commonly referred to as Derived Enriched Uranium (DEU). This material is purchased under an international agreement. It is certified by its producers to meet the ASTM C996-90 Standard Specification for Uranium flexafluoride Enriched to Less than 5% U-235. Approximately 250 2-1/2-ton cylinders of this material have been received through August,1996. Each of the cylinders has been accompanied by or preceded by documentation provided by Russia denoting all required chemical analyses pertaining to the ASTM specification.
In addition, radionuclide analyses have also been provided. No Russian data to date has indicated any out-of-specification condition.
PORTS has performed analyses on 1S sample coritainers that are representative of the DEU in each 30B cylinder. All but one have been analyzed for assay, purity and U-236. All analysis results have met the ASTM C996-90 specification for these components. A technetium analysis has been performed on all cylinders exceeding the U-236 trigger point of the specification (1/2 the specification limit). In only a few cases has technetium been detectable.
'See response from G. P. Rifak'es to a question from Commissioner Diaz on page 9 of the transcript from the Commissioners' Briefing on Certification of USEC on August 28,1996.
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. Currently, except 1or 100 pounds or less of DEU material which is vented to the cascade at the time of sampling and/or transfer, none of the DEU cylinders 'iave been fed to the cascade. Most of the 30B DEU cylinders have been sampled by PORTS, and the contents of the 2S sample containers subjected to analyses similar to those performed on the contents of the IS containers.
These analyses have shown consistent agreement with those obtained from the IS samples.
A few 30B DEU cylinders have been blended to date, with only uranium isotopic and purity analyses perfonned. The blended cylinders were then subjected to additional analyses. All of the material so produced has met the ASTM C996-90 specification. It is expected that the blending activities will increase in frequency.
USEC plans to have a witness program in place in Russia in the near future. The initiation of witnessing will allow USEC to eliminate the onsite sampling of Russian DEU 30B cylinders. It has already been shown, as discussed above, that the Russian sampling in IS containers provides consistent agreement with the samples obtained at PORTS.
A second significant input of potential feed material from Russia has come in the category of
" Matched Sales". This material has met the ASTM C996-90 product specifications for material produced from commercial natural enriched material. All of the cylinders received through August, 1996, have been sampled for assay and purity for NMC&A purposes. Additional analyses have been performed on most cylinders for the remaining isotopic analyses and technetium, with the exception of certain cylinders that were to be blended. The U-236 content of this material has been low enough to not require additional radionuclide or fission product analyses. Nevertheless, PORTS has analyzed some of the material and found typically none or negligible quantities of these contaminants present.
A large fraction of the Matched Sales material has been fed to the cascade.
Enriched feeds, other than Russian material, are occasionally received. This material is statistically sampled and analyzed for U-236 as a check for radionuclides, technetium, and fission products. Purity and uranium isotopic analyses are also performed. The material is either blended, fed or sent directly to a customer.
- 4. Health Physics and Radiological Protection In addition to the feed material sampling programs discussed above, the Radiation Protection group at each site implements a Radiation Protection program to ensure that radioactive materials, including those found in feed materials, do not adversely affect health and safety. This program is described in detail in the Certification Application, Safety Analysis Report, Section 5.3, Radiation Protection Program. Measures to address personnel exposure control and measurement activities, respiratory protection, contamination control, and personnel training are described in this program.
Ilealth Physics technicians are trained to identify possible sources of radiological hazard, including those that may originate u contamination in feed material. This program satisfies 10 CFR Part 20, Standards for Protection Against Radiation, except as discussed in the Compliance Plans for the GDPs. Relevant aspects of this program are:
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Radiological work permits (RWPs) are used for work activities in contamination, radiation, or airborne radioactivity areas. The RWP serves as the basic implementing tool of the E2-3
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, Radiation Protection program and provides information to the worker concerning radiation hazards, protective clothing, job / task identification, and special instructions such as hold points.
2.
Radiological surveys of cylinders and cylinder work areas provide information regarding contamination and radiation levels. Receipt surveys are performed on all incoming cylinders l
to identify extemal contamination and radiation levels. This information is then used to develop the requirements of appropriate RWPs and posting information. Abnormal radiation l
levels are investigated and appropriate corrective actions implemented.
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To the extent practicable, radioactive materials are contained and/or confined during use and processing. In areas where hook-ups and disconnects of equipment could result in airbome radioactivity concentrations in excess of 10% of limits, work area air monitoring is l
established and appropriate respiratory protective equipment is utilized.
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