ML20135D689

Informs That Notice of Enforcment Discretion Is Warranted Because NMSS Is Clearly Satisfied That Noted Action Involves Minimal or No Safety Impact

ML20135D689
Person / Time
Site:	07007001
Issue date:	02/28/1997
From:	Paperiello C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	John Miller UNITED STATES ENRICHMENT CORP. (USEC)
References
NUDOCS 9703050415
Download: ML20135D689 (3)

Text

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p f '*h 1- UNITED STATES j

i- g NUCLEAR REGULATORY COMMISSION -

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, o, f-February 28, 1997

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- .' Mr. James H. Miller l 4 LVice President, Produ' ction

U. S. Enrichment Corporation  ?

2 Democracy Center j 6903 Rockledge Drive j i Bethesda, MD 20817 l 4, I

SUBJECT:

NOTICE OF ENFORCEMENT DISCRETION FOR UNITED STATES ENRICHMENT l CORPORATION (USEC) REGARDING PADUCAH GASEOUS DIFFUSION PLANT i NOED NO. GDP97-1 l 1-  !

Dear Mr. Miller:

l l l: By letter dated February 14,1997, you requested that the NRC exercise discretion not to .

! enforce compliance with the design features required in Technical Safety Requirement I (TSR) 2.2.5.2, Crane Design. By that letter, USEC submitted a certificate amendment

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request and requested enforcement discretion if the.NRC could not act on the amendment prior to NRC assuming regulatory authority on March 3,1997. You stated that the plant l l .

would not be in compliance with TSR 2.2.5.2 which requires the cranes in the feed facility ,

L to have two DC rectified shoe brakes. You indicated that the Department of Energy has ['

I authorized enforcement discretion which will expire when the NRC assumes regulatory I jurisdiction on March 3,1997. You requested that a Notice of Enforcement Discretion  ;

(NOED) be issued pursuant to the NRC's policy regarding exercise of discretion for an ,

L operating facility, set out in Section Vll.c, of the " General Statement of Policy and  !

i Procedures for NRC Enforcemn Actions" (Enforcement Policy), NUREG-1600, and be  ;

i effective until the NRC issues the amendment to change the design requirement.  !

! On February 12,1997, USEC discovered that the actual field configuration of two feed l facility cranes did not match the design requirements as stated in the TSR. The cranes do ,

not have two DC rectified shoe brakes as required by the design feature specified in the j- TSR.' Each crane does have at least two brakes. The C 337A North crane has one DC i rectified shoe brake and one ratchet and pawl brake. The C-333A West crane has one DC  !

i I rectified shoe brake and one eddy current brake. The cranes are used to lift solid uranium j hexafluoride cylinders and place the cylinders into the autoclaves in the feed facility.

L USEC states that the field configuration (of the brakes) is the DOE approved design and it l meets the requirements of ANSI B30.2.0-1967, " Overhead and Gantry Cranes." You L assert that the current configuration was found acceptable to protect the public health and l safety by DOE. USEC states that the brakes have been inspected by site personnel and an g i - outside third party and that the brakes are in good condition. USEC states that allowing continued operation unreviewed safety question.ofUSEC the cranes states thatwill if the not reduce cranes cannot the be margin used, the of plant safetyl and tha i

' would have to discontinue feeding cylinders into the cascade, reduce power, and take

actions to place the cascade in the recycle mode. USEC states that operating in recycle i NRC HLE CENTE COPY

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. . Mr. J. H. Mill:r, USEC 2 r .

would introduce the additional risk associated with abnormal operating conditions, including the slight increase in the likelihood of criticality and the potential for exceeding I plant enrichment levels.

NRC recognizos that all cranes in the feed facilities do have at least two independent braking systems and the brakes in place were part of the approved design. Also, we agree l that ANSI B30.2.0 does not require that both brakes be DC rectified and the brakes in place do appear to meet the brake requirements in the standard. There are no known safety issues associated with continued use of the cranes with the current brake l

I configuration. Failure to correctly designate the configuration of the brakes in the TSR I was an administrative oversight on the part of USEC. USEC has indicated that without l use of the cranes, USEC would need to place the cascade into recycle mode. We agree I that operation in recycle mode does introduce abnormal operating conditions, including an increase in the potential for enrichment levels to exceed the plant limits and a slight increase in the potential for criticality. Compliance with the design requirement for the l brakes that is specified in the TSR would result in an unnecessary plant transient.

Although, USEC should have discovered this discrepancy earlier, the staff believes that overall plant safety is enhanced by allowing USEC to continue using the cranes so that the ,

facility does not have to operate in a recycle mode for a long period of time.

On the basis of the staff's evaluation of your request, the staff has concluded that an j NOED is warranted because we are clearly satisfied that this action involves minimal or no '

safety impact and has no adverse radiological impact on public health and safety.

Therefore, it is our intention to exercise discretion not to enforce compliance with the design requirement in TSR 2.2.5.2 which requires two DC rectified shoe brakes for the period from March 3,1997,12:01 am until final action is taken on USEC's certificate amendment request. This NOED is dependent upon USEC maintaining the hoist brakes in accordance with ANSI B30.2. However, as stated in the Enforcement Policy, action will normally be taken, to the extent that violations were involved, for the root cause that led to the noncompliance for which this NOED was necessary.

Sincerely, Odginal Signed By Carl J. Paperiello, Director Office of Nuclear Material Safety and Safeguards Docket 70-7001 Certificate GDP-1 cc: Mr. Randall DeVault, DOE Mr. Steve Polston, PGDP DISTRIBUTION:

Docket 70-7001 N W 6 Center PUBLIC NMSS r/f FCSS r/f SPB r/f OFC SPB G SPB C SPB C Rlli SPB FCSS[ NMyS, g NAME Nrn:ij dbNhfey IldNn h RPihon ETerfNyck Chpkeilo DATE ). h//97 J /;797 ')-0797 2 /S/97 4%h7 $()J[97 2 /8/97 C = COVER E = COVER & ENCLOSURE N = NO COPY G:\NOED1 OFFICIAL RECORD COPY

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Mr. J. H. Millar, USEC 2 r- ,

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' would introduce the additional risk associated with abnormal operating nditions, i luding the slight increase in the likelihood of criticality and the pot tial for exceeding pla enrichment levels.

All cranes ' the feed facilities do have at least two indepen nt braking systems and the brakes in plac were part of the approved design. Also, Si B30.2.0 does not require that both brakes DC rectified and the brakes in pia do appear to meet the brake i requirements in the s dard. There are no known fety issues associated with continued l

use of the cranes with t urrent brake configur ion. Failure to correctly designate the i configuration of the brakes i e TSR was a dministrative oversight on the part of USEC. USEC has indicated that 'thout u of the cranes, USEC would need to place the j cascade into recycle mode. Operati i ecycle mode does increase the potential for enrichment levels to exceed the plan i and does slightly increases the potential for ,

criticality. Compliance with the d ign requ ent for the brakes that is specified in the  !

TSR would result in an unnece ary plant transi . Although, USEC should have discovered this discrepancy arlier, the staff believe at overall plant safety is enhanced by allowing USEC to con ue using the crpnes so that t facility does not have to operate in a recycle m e for a long period of time.

On the basis of the ff's evaluation of your request, the staff has cluded that an NOED is warrante'd because we are clearly satisfied that this action invo minimal or no safety impact and has no adverse radiological impact on public health and sa .

Therefore, it is our intention to exercise discretion not to enforce compliance with e i design requirement in TSR 2.2.5.2 which requires two DC rectified shoe brakes for th l period from March 3,1997,12:01 am until final action is taken on USEC's certificate l amendment request. However, as stated in the Enforcement Policy, action will normally be taken, to the extent that violations were involved, for the root cause that led to the noncompliance for which this NOED was necessary. j l

Sincerely, Carl J. Paperiello, Director Office of Nuclear Material Safety and Safeguards Docket 70-7001 Certificate GDP-1 cc: Mr. Randall DeVault, DOE Mr. Steve Polston, PGDP DISTRIBUTION:

Docket 70-7001 NRC File Center PUBLIC NMSS r/f FCSS r/f SPB r/f i OFC SPB SPl!l @ SPB SPB FCSS NMSS NAME MHorn:ij bley DMartin RPierson ETeri Eyck CPaperiello DATE / /97 h h97 / /97 / /97 / /97 / /97 C = COVER E = COVER & ENCLOSURE N = NO COPY G:\NOED1 OFFICIAL RECORD COPY

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