ML20134J837
| ML20134J837 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 11/04/1996 |
| From: | John Miller UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Paperiello C NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML19353D976 | List: |
| References | |
| GDP-96-0192, GDP-96-192, NUDOCS 9611180090 | |
| Download: ML20134J837 (8) | |
Text
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United Stats Enrichment Corporation 2 DemocracyCenter 6903 Rockledge Drive Bethesda, MD 20817 Tel: (301)S64-3200 Fax:(301) 564-3201 j
i JAMES H. MILLER Dir: (301) 564-3309 VicE PRESIDENT, PRODUCTION Fax: (301) 571-8279 i
i November 4,1996 i
Dr. Carl J. Paperiello SERIAL: GDP 96-0192 Director, Office of Nuclear Material Safety and Safeguards Attention: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Portsmouth Gaseous Diffusion Plant (PORTS)
Docket No. 70-7002 Certificate Amendment Request-Changes to Compliance Plan Due Dates for IIEU Related Issue INFORMATION TRANSMflTED HEREWITH IS PROTECTED FROM PUBLIC DISCLOSURE AS CONFIDENTIAL COMMERCIAL OR FINANCIAL INFORMATION AND/OR TRADE SECRETS PURSUANT TO 10 CFR 2.790(d)(1) AND 9.17(a)(4)
Dear Dr. Paperiello:
In accordance with 10 CFR 76.45, the United States Enrichment Corporation (USEC or Corporation) hereby submits a request for amendment to the proposed certificate of compliance for the Portsmouth, Ohio Gaseous Diffusion Plant (GDP). This certificate amendment request revises the completion date specified in the DOE /ORO-2027, Plan for Achieving Compliance with NRC Regulation at the Portsmouth Gaseous DifTusion Plant, for removal of Highly Enriched Uranium (HEU) not associated with suspension and refeed programs from all leased areas. Specifically, USEC is requesting this date be revised from November 15,1996, to February 28,1997 As described in USEC letter GDP 96-0163, certain portions of the Compliance Plan for the Portsmouth plant contain confidential commercial or financial information or trade secrets that are exempt from public disclosure pursuant to Section 1314 I
of the Atomic Eneruv Act of 1954. as amended, and 10 CFR 2.790 and 9.17(a)(4).
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Dr. Carl J. Paperiello November 4,1996 GDP 96-0192 Page 2 Issue A.4 of the Plan For Achieving Compliance with NRC Regulations for the Portsmouth Gaseous Diffusion Plant, requires, in part, that HEU not associated with the suspension and refeed programs be either removed (except for a de minimis total quantity across all leased areas not to exceed 999 grams of 2"U) from all leased areas or blended to Low Enriched Uranium (LEU), by November 15, 1996.
Removal of HEU from X-326 and X-705 (i.e., HEU associated with suspension and refeed programs) is addressed by separate action items in A.4. As part of the implementation support for the Russian Transparency Program (Memo of Understanding with Lockheed Martin Energy Systems), PORTS is to provide special HEU UF. standards for the U.S. Department of Energy (DOE). These standards will be used by U.S. monitors in Russia as part of a blind sampling program.
The HEU will come from existing DOE standards material in 2S cylinders currently stored in the X-345 Building. The standards, once prepared in the X-710 Building (a leased building), are to be shipped to Russia in Russian provided sample cylinders. This work has been delayed awaiting arrival of the sample cylinders from Russia. As it currently stands this work cannot be completed prior to the aforementioned November 15,1996 deadline. A contingency plan has been developed which would
- require the HEU now in 2S sample cylinders to be transferred into smaller Hoke tubes within the X-710 Building. Once the Russian Sample cylinders are received the smaller Hoke tubes would be transferred into the Russian cylinders at a rate that would not exceed the Plant's permitted HEU quantity (i.e.
category III limits) in leased facilities. The success of this contingency plan is based on transferring the material in the 2S sample cylinders into the Hoke tubes. An extension for completion of this Issue A.4 action item is requested from November 15,1996, to February 28,1997. PORTS will continue to operate under the commitments and conditions identified in the Compliance Plan Issue A.4 Justification For Continued Operation section. HEU limits in the affected leased areas, specifically the X-710 Building, will be met prior to transition to NRC Regulatory Oversight. to this letter provides a detailed description and justification for the proposed change. provides a copy of the new page for Compliance Plan Issue A.4. Enclosure 3 contains the basis for USEC's determination that the proposed change associated with this certificate amendment request is not significant. Since this proposed certificate amendment request involves near term commitment dates only and not changes to programs or the facility as described in the Certification Application, USEC requests NRC review and approval at your earliest convenience. The amendment should become effective immediately upon issuance.
In accordance with 10 CFR 76.33(e) and consistent with the NRC's December 11,1995 letter, the enclosed Compliance Plan issue is considered to be proprietary commercial and financial information pursuant to 10 CFR 2.790(d)(1) and 9.17(a)(4) and is exempt from public disclosure. This Compliance Plan issue has been clearly identified as proprietary information.
Dr. Carl J. Paperiello November 4,1996 GDP 96-0192 Page 3 Any questions related to this subject should be directed to Mr. Russell D. Wells at (301) 564-3413.
i Sincerely, mes H. Miller Vice President, Production
Enclosures:
As Stated cc:
NRC Region III Oflice NRC Resident Inspector - PGDP NRC Resident Inspector - PORTS Mr. J. Dale Jackson (DOE)
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OATil AND AFFIRMATION I, James H. Miller, swear and affirm that I am Vice President, Production, of the United States Enrichment Corporation (USEC), that I am authorized by USEC to sign and file with the Nuclear Regulatory Commission this Certificate Amendment Request for the Portsmouth Gaseous Diffusion Plant, that I am familiar with the contents thereof, and that the statements made and matters set forth therein are true and correct to the best of my knowledge, information, and belief.
mes H. Miller Subscribed to before me on this hday of Mhh
[,1996.
f-i0)h w -& I Notary Public CAThMlN5 E VEEl MOTA2Y RE11C STATi OF A'1W'AN'O My Commlukm bpira Ts:uccf4,1 %7 d
GDP96-0192 Page1 ofI United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Plan for Achieving Compliance with NRC Regulations at the Portsmouth Gaseous Diffusion Plant
[ Compliance Planl Issue A.4 Detailed Description of Change This change extends the completion date committed to in Compliance Plan Issue A.4 (first action item) for removal ofHEU from allleased areas (except for de minimis total quantities not to exceed 999 grams of 2"U) from November 15,1996 to February 28,1997.
As part of the implementation support for the Russian Transparency Program (Memo of Understanding with Lockheed Martin Energy Systems), PORTS is to provide special HEU UF standards for DOE.
6 These standards will be used by U.S. monitors in Russia as part of a blind sampling program. The HEU will come from existing DOE standards materialin 2S cylinders currently stored in the X-345 Building.
The standards once prepared are to be shipped to Russia in Russian provided sample cylinders. This work has been delayed awaiting arrival of the sample cylinders from Russia. As it currently stands this work cannot be completed prior to November 15,1996 which is the efTective date of the requirement 1
established in Compliance Plan Issue A.4 that limits the amount of 2"U in leased facilities. A contingency plan has been developed which would require the HEU now in 2S sample cylinders to be transferred into smaller Hoke tubes within the X-710 Building (a leased facility). Once the Russian Sample cylinders are received the smaller Hoke tubes would be transferred into the Russian cylinders at a rate that would not exceed the Plant's permitted HEU quantity (ie. category III limits) in leased facilities (X-710). The success of this contingency plan is based on transferring the material in the 2S sample cylinders into the Hoke tubes. It has been determined that the necessary "U transfers into Hoke 2
tubes can be performed prior to February 28,1997.
PORTS will continue to operate under the commitments and conditions identified in the Compliance Plan issue A.4 Justification For Continued Operation section. HEU limits in the affected leased areas, specifically the X-710 Building will be met prior to transition to NRC Regula'.ory Oversight.
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GDP96-0192 Page1of2 Proposed Certificate Amendment Request j
Portsmouth Gaseous Diffusion Plant Letter GDP96-0192 Removal / Insertion Instructions Remove Pages Insert Pages COMPLIANCE PLAN DOE /ORO-2027/R3 CIIANGE A, APPENDIX Issue A.4 Issue A.4 Pages 7/8 Pages 7/8
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GDP96-0192 Page1of3 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Plan for Achieving Compliance with NRC Regulations at the Portsmouth Gaseous Diliusion Plant
[ Compliance Plan l Issue A.4 Significance Determination The United States Enrichment Corporation (USEC) has reviewed the proposed changes associated with this certificate amendment request and provides the following Significance Determination for consideration.
1 No Significant Decrease in the Effectiveness of the Plant's Safety. Safeguards or Security Prourams The completion date for the Compliance Plan Issue A.4 (first action item) is not addressed in plant safety, safeguards or security programs contained in the Application for United States Nuclear Regulatory Commission Certification for the Portsmouth Gaseous Diffusion Plant. Therefore, the effectiveness of these programs remains in affect. Additionally, the extension of the completion date still falls before transition to Regulatory Oversight which is when these programs are required to be in place.
- 2. No Significant Change to Any Conditions to the Cedificate of Compliance None of the Conditions to the Proposed Certificate ot' Compliance for Operation of Gaseous Diffusion Plants (GDP-2) specifically address the due dates for Compliance Plan Issues. Thus, the proposed due date changes have no impact on any of the Cenditiens to the Proposed Certificate of Compliance.
- 3. No Significant Change to Any Condition of the Acoroved Compliance Plan J
The approximate due date increase of three months for Compliance Plan Issue A.4 (first action item) will not significantly affect the Compliance Plan conditions. PORTS will continue to operste under the commitments identified in the Compliance Plan Justification For Continued Operation section.
In essence, PORTS shall operate the plant (X-710) safely by continuing to utilize existing procedures and nuclear criticality safety controls and specifications previously developed for the purpose of handling HEU.
- 4. No Significant increase in the Probability of Occurrence or Consecuences of Previousiv Evaluated Accidents PORTS has historically been authorized to possess materials that are of"high strategic significance" and has safely managed the inventory of uranium quantities and enrichments greater than those of
" low strategic significance" Accident scenarios involving HEU were evaluated during the evolution of the 1985 Safety Analysis Report and Operational Safety Requirements. The extension of the time for the continued handling of HEU in excess of the 999 gram limit within the X-710 Facility will not increase the probability of occurrence or consequences of the postulate criticality accidents currently 4
identified in the SAR.
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GDP96-0192 Page 2 of 3
- 5. No New or Different Tvoc of Accident PORTS has historically been authorized to possess materials that are of"high strategic significance" and has safely managed the inventory of uranium quantities and enrichments greater than those of
" low Grategic significance" Accident scenarios involving HEU were evaluated during the evolution of the 1985 Safety Analysis Report and Operational Safety Requirements. The extension of time for the continued handling of 23'U in excess of the 999 gram limit within the X-710 Facility will not create any new or different type of accident.
6.
No Significant Reduction in Margins of Safety PORTS has historically been authorized to possess materials that are of"high strategic significance" and has safely managed the inventory of uranium quantities and enrichments greater than those of j
" low strategic significance" Accident scenarios involving HEU were evaluated during the evolution 1
of the 1985 Safety Analysis Report and Operational Safety Requirements. The extension of time for the continued handling of 23'U in excess of the 999 gram limit within the X-710 Facility will not j
reduce the margin of safety as defined in the Technical Safety Requirements document.
- 7. No Significant Decrease in the Efrectiveness of any Prourams or Plans Contained in the Certificate Anolication The completion date for the Compliance Plan Issue A.4 (first action item) is not addressed in any programs or plans contained in the Application for United States Nuclear Regulatory Commission Certification for the Portsmouth Gaseous Diffusion Plant. Therefore, the effectiveness of these programs remains in affect. Given that the programs described in the Application are not required to be implemented until Transition to NRC Regulatory Oversight and the fact that these Compliance Plan activities will be completed by this date, there is no impact on the effectiveness of these programs or plans.
- 8. The cronosed changes do not result in undue risk to 1) oublic health and safety. 2) common defense and security. and 3) the environment.
The extension of the time for the continued handling of 235U in excess of the 999 gram limit within the X-710 Facility does not increase the probability or consequence of any potential criticality accident. Postulated criticality or UF releases (2 to 3 Kgs) accidents at the PORTS plant do not 6
impact the general public and only have minimum potential to adversely affect the health and safety of the local work force. As such, this change does not represent an undue risk to public health and safety. In addition, this revision has no impact on plant efiluents or on the programs and plans in place to implement physical security.