ML20136H332
| ML20136H332 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 03/04/1997 |
| 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 | |
| ML20057G470 | List: |
| References | |
| GDP-97-0028, GDP-97-28, NUDOCS 9703190118 | |
| Download: ML20136H332 (10) | |
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United States l
Enrichment Corporation i
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6903 Rockledge Dnve Bethesda. MD 20817 1
i Tel: (301)S64-3200 Fax: (301) 564-3201 Untitetl States furiclinietit Corporation l
l James H. Miller Dir: (301) S64-3309 Vice PRESIDENT, Production Fax: (301) 571-8279 1
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March 4,1997 Dr. Carl J. Paperiello SERIAL: GDP 97-0028 Director, Office of Nuclear Material Safety and Safeguards Attention: Document Control Desk U.S. Nuclear Regulatory Commission l
Washington, D.C. 20555-0001 l
Paducah Gaseous Diffusion Plant (PGDP)
Docket No. 70-7001 Certificate Amendment Request-Revision to FNMCP Section 4.4.3 and Compliance Plan Issue A.2 l
Dear Dr. Paperiello:
In accordance with 10 CFR 76.45, the United States Enrichment Corporation (USEC) hereby submits a request for amendment to the Certificate of Compliance for the Paducah, Kentuck,f Gaseous Diffusion Plant (PGDP), Certificate Number GDP-1. As stated in the Introduction to the USEC Application for United States Nuclear Regulatory Commission Certification, USEC-01 (the Application), Revision 6, "The programs, plans, procedures and other aspects of the facility's operations other than the SSCs are described as they will be when all Compliance Plan items are completed." By the nature of the manner in which the Application and the Plan for Achieving
' Compliance with NRC Regulations at the Paducah Gaseous Diffusion Plant (the Compliance Plan) were developed, the Application text was to describe the present state of the program (if no non-compliances were associated with the specific section) or the future state of the program (if non-compliances were identified).
Section 4.1.1, Equipment Volumes, of the PGDP Fundamental Nuclear Materials Control Plan pf/[)
(FNMCP)in Volume 3 of the Application, Revision 6, states that " System volumes are determined from dimensional measurement calculations." Therefore, it was, and is, USEC's intent to perform dimensional measurement calculations to determine sy lumes. Section 4.4.3 of the FNMCP, 4'
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GDP 97-0028 Page 2 which describes those aspects of the FNMCP that are not in full compliance with the program
-l described in the main body of the FNMCP, states that "The equipment volumes in C-400 need to be j
verified through calibration. Currently, the volumes are determined by measurement of dimensions."
This statement is not clear, and could be read to state that USEC will determine equipment volumes.
by a means other than the measurement of dimensions, which is clearly not the intent as outlined in i
Section 4.1.1 of the FNMCP. Section 4.4.3 of the FNMCP also does not draw the conclusion that dimensional measurement calculations are not adequate, nor does it provide a definition of the term
" calibration". Therefore, the method of determining equipment volumes in C-400 is not clearly defined by FNMCP Section 4.4.3 by itself, and a review of USEC's base commitment in FNMCP Section 4.1.1 must be considered when determining exactly what the non-compliance is and how it is to be resolved.
This problem is further obfuscated in the Compliance Plan, Revision 3, Change A, Issue A.2, Page 2, in the Description of Noncompliance for FNMCP Section 4.4.3, which states that " System volumes utilized for accountability measurements use calculated values and have not been determined by L
volume calibrations." This statement does not match FNMCP Section 4.4.3. The associated items in the Plan of Action for Compliance Plan Issue A.2 that address this noncompliance state that a" vessel calibration" program will be established and implemented for Building C-400. No defmition is provided in the Compliance Plan for the terms " volume calibration" or " vessel calibration".
Based on the above, several key points deserve consideration:
FNMCP Section 4.1.1 clearly states that system volumes will be determined by dimensional measurement calculations. The FNMCP was reviewed and approved by the NRC, and no questions were forwarded to USEC on this point.
FNMCP Section 4.4.3 is not clear in stating the non-compliance. Also, FNMCP Section 4.4.3 l
l only defined C-400 as an area of non-compliance relative to FNMCP Section 4.1.1. PGDP has i
never done volume calibration (i.e., the use of " prover" vessels to determine the volumes of l
vessels) for any vessels, therefore, if the performance of volume calibrations was really intended, l
C-400 is not the only facility where non-compliances would have had to be identified.
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The Description of Noncompliance in Compliance Plan Issue A.2 for FNMCP Section 4.4.3 does I
' not match the words in FNMCP Section 4.4.3.
PGDP has found the method of dimensional measurement calculation to provide adequate results for determining equipment volumes. This method has also been previously recognized and approved by DOE.
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Dr. Carl 1 Paperiello March 4,1997 GDP 97-0028 Page 3 By the very nature of the manner in which the various Application documents were developed, the content of the Compliance Plan is driven by the content of the Application. Therefore, the Application should be used to determine USEC's base commitments when discrepancies exist.
USEC should have provided a more effective review of the Compliance Plan against the FNMCP commitments and pursued revisions to FNMCP Section 4.4.3 and the Compliance Plan Issue A.2 earlier to correct the potential for problems in interpretation of the actual activity that was to be pursued to resolve the non-compliance.
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If USEC were required to perform volume calibrations for the C-400 equipment, the activity l
would result in the generation oflarge amounts of hazardous, radioactively contaminated waste j
and the potential for increased personnel radiation exposure.
l USEC is submitting this Certificate Amendment Request to revise the associated sections of the FNMCP and the Compliance Plan so that they are consistent with the conunitment in FNMCP Section 4.1.1 to utilize dimensional measurement calculations to determine equipment volumes. to this letter provides a detailed description and justification for the proposed changes. Enclosure 2 is a copy of the revised FNMCP and Compliance Plan pages.l Enclosure 3 contains the basis for USEC's detemiination that the proposed change associated with this certificate amendment request is not significant; and is, therefore, acceptable. The amendment should become l-effective upon issuance. contains pages out of the Application and the Compliance Plan that contain certain trade secrets and commercial and financialinformation exempt from public disclosure pursuant to Section 1314 of the Atomic Energy Act of 1954 (AEA), as amended, and 10 CFR 2.790 and 9.17(a)(4). In accordance with 10 CFR 76.33(e) and 2.790(b), revisions of these documents were l
previously submitted under separate cover by USEC letters. Affadavits for the FNMCP were l
submitted by USEC Letters GDP 95-0015 (for Revision 1), GDP 96-0028 (for Revision 2), GDP 96-0112 (for Revision 3), and GDP 96-0151 (for Revision 4). Since Enclosure 2 of this letter includes only pages from a revision previously submitted with affidavits, an additional affidavit is not included with this submittal. Issue A.2 of the Compliance Plan included in Enclosure 2 is considered to be i
proprietary commercial and financial information consistent with the NRC's December 11,1995 letter. USEC would expect the NRC to treat allinformation designated as proprietary with the same controls as the original submittals.
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Dh Carl 3. Paperiello March 4,1997 GDP 97-0028 Page 4 Any questions related to this subject should be directed to Mark Lombard at (301) 564-3248.
Sincerely, J
es H. Miller ice President, Production
Enclosures:
As Stated cc:
NRC Region III Office NRC Resident Inspector - PGDP NRC Resident Inspector - PORTS Mr. Randall M. DeVault (DOE) 1 t
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OATH AND AFFIRMATION 1
I, James H. Miller, swear and affirm that I am Vice President, Production, of the United j
i 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 l
Diffusion Plant, that I am familiar with the contents thereof, and that the statements made and matters l-set forth therein are true and correct to the best of my knowledge, information, and belief.
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I Subscribed to before me on this b. day of NRAL(L.1997.
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Page 1 of 2 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Revision to FNMCP Section 4.4.3 and Compliance Plan Issue A.2 Detailed Description of Change As stated in the Introduction to the USEC Application for United States Nuclear Regulatory Commission Certification, USEC-01 (the Application), Revision 6, "The programs, plans, procedures and other aspects of the facility's operations other than the SSCs are described as they will be when all Compliance Plan items are completed." By the nature of the manner in which the Application and the Plan for Achieving Compliance with NRC Regulations at the Paducah Gaseous Diffusion Plant (the Compliance Plan) were developed, the Application text was to describe the present state of the y
program (ifno non-compliances were associated with the specific section) or the future state of the program (if non-compliances were identified).
l Section 4.1 1, Equipment Volumes, of the PGDP Fundamental Nuclear Materials Control Plan (FNMCP)in Volume 3 of the Application, Revision 6, states that " System volumes are determined from dimensional mea.earement calculations." Therefore, it was, and is, USEC's intent to perform I
dimensional measurement calculations to determine system volumes. Section 4.4.3 of the FNMCP, which describes those aspects of the FNMCP that are not in full compliance with the program described in the main body of the FNMCP, states that "The equipment volumes in C-400 need to be verified through calibration. Currently, the volumes are determined by measurement of dimensions."
i This statement is not clear, and could be read to state that USEC will determine equipment volumes by a means other than the measurement of dimensions, which is clearly not the intent as outlined in Section 4.1.1 of the FNMCP. Section 4.4.3 of the FNMCP also does not draw the conclusion that dimensional measurement calculations are not adequate, nor does it provide a definition of the term
" calibration" Therefore, the method of determining equipment volumes in C-400 is not clearly defined by FNMCP Section 4.4.3 by itself, and a review of USEC's base commitment in FNMCP Section 4.1.1 must be considered when determining exactly what the non-compliance is and how it is to be resolved.
This problem is further obfuscated in the Compliance Plan, Revision 3, Change A, Issue A.2, Page 2, in the Description ofNoncompliance for FNMCP Section 4.4.3, which states that " System volumes utilized for accountability measurements use calculated values and have not been determined by volume calibrations." This statement does not match FNMCP Section 4.4.3. The associated items in the Plan of Action for Compliance Plan Issue A.2 that address this noncompliance state that a" l
vessel calibration" program will be established and implemented for Building C-400. No definition is provided in the Compliance Plan for the terms " volume calibration" or " vessel calibration" I
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GDP 97-0028 Page 2 of 2 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request l
Revision to FNMCP Section 4.4.3 and Compliance Plan Issue A.2 Detailed Description of Change Therefore, the following points were considered:
1 FNMCP Section 4.1.1 clearly states that system volumes will be determined by dimensional measurement calculations. The FNMCP was reviewed and approved by the NRC, and no j
questions were forwarded to USEC on tlus pomt.
FNMCP Section 4.4.3 is not clear in stating the non-compliance. Also, FNMCP Section 4.4.3 only defined C-400 as an area of non-compliance relative to FNMCP Section 4.1.1. PGDP has never done volume calibration (i.e., the use of" prover" vessels to determine the volumes of vessels) for any vessels, therefore, if the performance of volume calibrations was really intended, C-400 is not the only facility where non-compliances would have had to be identified.
l The Description ofNoncompliance in Compliance Plan Issue A.2 for FNMCP Section 4.4.3 does not match the words in FNMCP Section 4.4.3.
l PGDP has found the method of dimensional measurement calculation to provide adequate results for determining equipment volumes. This method has been approved by DOE.
By the very nature of the manner in which the various Application documents were developed, the content of the Compliance Plan is driven by the content of the Application. Therefore, the Application should be used to determine USEC's base commitments when discrepancies exist.
USEC should have provided a more effective review of the Compliance Plan against the FNMCP commitments and pursued revisions to FNMCP Section 4.4.3 and the Compliance Plan Issue A.2 earlier to correct the potential for problems in interpretation of the actual activity that was to be pursued to resolve the non-compliance.
If USEC were required to perform volume calibrations for the C-400 equipment, the activity would result in the generation oflarge amounts of hazardous, radioactively contaminated waste and the potential for increased personnel radiation exposure.
FNMCP Section 4.4.3 will be revised to clarify the noncompliance is that the current equipment volume dimensionsal measurement calculations in C-400 are based on historical data of undetermined origin or quality. The Compliance Plan Issue A.2 Description of Noncompliance will be revised to match the statement in FNMCP Section 4.4.3 and the Plan of Action and Schedule will be revised to state that the vessel dimensional measurement calculation program will be established and completed for C-400.
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GDP 97-0028 Page1 of3 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Revision to FNMCP Section 4.4.3 and Compliance Plan Issue A.2 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 Programs As stated in the Introduction to the USEC Application for United States Nuclear Regulatory Commission Certification, USEC-01 (the Application), Revision 6, "The programs, plans, procedures and other aspects of the facility's operations other than the SSCs are described as they will be when all Compliance Plan items are completed."
Therefore, Fur.damental Nuclear Materials Control Plan, Revision 6 (FNMCP)
Section 4.1.1 describes USEC's intentions for the method used to determine system volumes. However, the subject changes are needed to make Section 4.4.3 of the FNMCP; and the Plan for Achieving Compliance with NRC Regulations at the Paducah Gaseous Diffusion Plant, Revision 3, Change A (Compliance Plan), Issue A.2, consistent with USEC's commitment in FNMCP Section 4.1.1 to utilize dimensional measurement calculations to determine system volumes. As such, the subject changes are only required to provide consistency with the level of effectiveness of the FNMCP as defined in FNMCP Section 4.1.1, and do not constitute a overall decrease in effectiveness.
- 2. No Significant Change to Any Conditions to the Certificate of Comoliance The subject changes revise Section 4.4.3 of the FNMCP and Issue A.2 of the Compliance Plan for consistency with a commitment in Section 4.1.1 of the FNMCP. Thus, the proposed changes have no significant impact on any of the Conditions to the Proposed Certificate of Compliance.
- 3. No Significant Change to Any Condition of the Anoroved Comoliance Plan Revising issue A.2 of the Compliance Plan as described in this change is required to make it consistent with USEC's commitment in Section 4.1.1 of the FNMCP.
i Thus, the proposed changes to the Compliance Plan are not significant.
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W GDP 97-0028 Page 2 of 3 t
United States Enrichment Corporation (USEC) l Proposed Certificate Amendment Request Revision to FNMCP Section 4.4.3 and Compliance Plan Issue A.2 Significance Determination
- 4. No Significant increase in the Probability of Occurrence or Conseauences of j
Previousiv Evaluated Accidents l
l The subject changes do not involve a change to any previously analyzed accident, and, therefore, do not involve any increase in the probability of occurrence or consequences of previously analyzed accidents.
- 5. No New or Different Tyne of Accident The subject changes do not involve the addition of a new or different type of accident.
- 6. No Significant Reduction in Margins of Safety The subject changes are needed to make FNMCP Section 4.4.3 and Compliance Plan Issue.A.2 consistent with USEC's base commitment in FNMCP Section 4.1.1 to utilize dimensional measurement calculations to determine system volumes, Therefore, the margin of safety as approved by the NRC in the FNMCP program is being maintained, and in no way reduced, by these changes.
- 7. No Significant Decrease in the Effectiveness of any Programs or Plans Contained in the Certificate Aonlication The subject changes are needed to make FNMCP Section 4.4.3 and Compliance i
Plan Issue A.2 consistent with USEC's base commitment in FNMCP Section 4.1.1 to utilize dimensional measurement calculations to determine system volumes.
Therefore, the effectiveness of the NRC approved FNMCP program is being maintained, and in no way decreased, by these changes.
- 8. The oronosed changes do not result in undue risk to 11 oublic health and safety. 2) common defense and security. and 3) the environment:
The subject changes are needed to make FNMCP Section 4.4.3 and the Compliance Plan consistent with USEC's base commitment in FNMCP Section 4.1.1 to utilize dimensional measumment calculations to determine system volumes. As such, this change does not represent an undue risk to public health and safety and has no impact on plant effluents or physical security.
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GDP 97-0028 Page 3 of 3 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Revision to FNMCP Secticii 4.4.3 and Compliance Plan Issue A.2 Significance Determination
- 9. There is no change in the tyoes or significant increase in the amounts of any effluents that may be released offsite.
The subject changes have no effect on the generation or disposition of effluents since the action associated with the noncompliance is complete, and, therefore, the types or amounts of effluents that may be released offsite are not affected.
However, if volume calibrations had to be performed, this activity would generate large amounts of hazardous, radioactively contaminated waste. This could increase the potential for the release of effluents offsite. But, as stated above, the use of dimensional measurement calculations is an acceptable means of determining equipment volumes, and volume calibrations are not necessary, and have never been done at PGDP.
- 10. There is no significant increase in individual or cumulative occuoational radiation exoosure.
The subject changes will not impact radiation exposure to individuals since the action associated with the non-compliance has been completed. However, there is a potential for increased radiation exposure if actual volume calibrations had to be performed due to the increase in personnel stay time in the area in C-400. But, as stated above, the use of dimensional measurement calculations is an acceptable means of determining equipment volumes, and volume calibrations are not necessary, and have never been done at PGDP.
- 11. There is no significant construction imoact.
This change does not involve a plant modification, therefore, will not impact construction.
- 12. There is no significant increase in the notential for_ or radiological or chemical consecuences from. nreviousiv analyzed accidents.
The subject changes do not related to previously analyzed accidents and, therefore, l
have no effect on the potential for, or radiological or chemical consequences from, any previously analyzed accidents.
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