ML20147C695
| ML20147C695 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant, Paducah Gaseous Diffusion Plant |
| Issue date: | 10/04/1996 |
| From: | Salisbury D AFFILIATION NOT ASSIGNED |
| To: | Paperiello C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| CON-#197-17978 NUDOCS 9702060419 | |
| Download: ML20147C695 (4) | |
Text
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Carl J. Paperiello. Director Orrice or Nuclear Materials and Safeguaras
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Nuclear Regulatory Commission
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Washington. D.C. 20555 y/
October 4, 1996 (VIA:
THE U.S. POSTAL SERVICE, Priority Mail)
Re:.
Amendment to Petition of October 3.
1996 of Diana Salisoury. Issuance of Certification Decielon for Gaseous Dittusion Uranium Enrichment Plants located in Piketon. Ohio and Paducan Kentucky, Federal Register Notice of Septemoer
- 19. 1996. CFR Vol. 61. No. 183. pages 49360-49360. Docket Nos. 70-7001 6 70-7002 Lear Director:
~
Please consloer Inis correspondence an exercise or legai rionts requestea in petition dated October 3.
1996.
Including out not limited to, rignt to amend originai petition.
The petitioner requests tnat NRC address tre following issues and provide responses to the followeig BEFORE IS$UANCE OF CERTIFICATION IS GRANTED TO USEC cempnasis added).
1.
THE 1996 BASELINE ENVIRONMENTAL REPORT. DOE /EM-0290.
June 1996. Volume III, states that when uranium processes are no longer needed. DOE will shut down and decommission the Portsmouth Gaseous Diffusion Plant.
Considering the present projected surplus of LEU as compared to market demand in the next five to ten years, when does NRC project that uranium enrichment processes will no longer be needed?
How does HEU and LEU production in Russia and agreement purchase between Russia and the United States affect need for uranium processes at Portsmouth and/or Paducah?
2.
"Under the provisions in the United States Enrichment Corporation lease. STABILIZATION AND SHUT DOWN iemphasis added) activities are the responsibility of the Enrichment Corporation, except for legacy contamination;*
(THE 1996 BEMR. DOE /EM-0290, June 1996, Vol. III, page 64.)
The same,/
DOE report indicates that a new approach for recyp, ling..
process equipment and other radioactive metals into usable products wl!! be used involving all gasecue diffusion ~
process buildings and nonprocess buildings demolished down to concrete slabs.
The Department will transport metal materiale removed from the buildings. Including structural steel removed during building demolition to Nuclear Regulatory Commission-licensed recyclers.
The metal wi'1,1 be 3
9702060419 961004 350 PDR ADOCK 07007001 C
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disassembled as necessary.
. recycled unere economically reasible, rolled. and taoricatea into use j
for products such as storage and disposal boxes, barreis i
j and pallets.
Melt slag and any unused metals will be i
transported to back to Portsmouth for disposal.
Radiologically contaminated metal waste from recycling 4
will be disposed of in the onsite disposal cells.
l (1996 BEMR. DOE /EM-0290. June 1996. Vol. III, page 66.)
a i
What entity " owns" the process buildings and nonprocess i
buildings?
Under terms of lease from DOE to USEC. does USEC i
own the buildings?
DOE responsibility for " legacy
{
contamination" requiree clarification.
Does lease agreement from DOE to USEC provide for DOE responelollity for j'
materials disposed as waste and USEC " ownership" of tne
]
portion of the buildings that can be recycled into usable l
products?
3 i
3.
DOE scenario from the same report contends that:
1ditn proper metallurgical processes, radioactive contaminants j
migrate to the slag curing smelting, with tne exception of i
technetium-99 which migrates to the metal."
(IBID)
Wnat technology presently exists to remove technetium from tne metal. in this case. steel?
What regulations does NRC or i
any other federal agency presently have in place to regulate level of technetium-99 contamination allowed in production and/or sale of products?
Does NRC or any other federal agency regulate level of contaminatic, allowed, type ( s) of products which can be marketed, and/or any restrictions as 4
to where such products can be manufactured and/or marketed?
4.
DOE landlord funding allocations appear to involve different processes at Portsmouth GDP and Paducah GDP.
Could NRC please clarify DOE financial responsibilities with i
specific explanation of the difference (s) between:
1.
no directly appropriated landlord costs at the Portsmouth GDP and 2.
planned budget requests based on priorization.
What direct impacts do these budget process differences have upon DOE /USEC scenario of future missions at these two plants?
5.
How long does the DOE plan to remain active in its
" l andl ord" capacity at the Portsmouth and Paducah.GDP sites?
DOE management program is presently operating in 30 states and territories.
By 2020, DOE management program is expected to operate in only 21 states.
By 2020 and by 2060 does DOE plan to allocate funding for " landlord" activities in Ohio and Kentucky?.
How long and to what extent does DOE plan to be responsible for these sites?
.80 percent of sites requiring mediation will completely remediated by 2021.
Only surveillance y.
y. -.,
,-r, y
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i page 3 and monitoring and waste management at sites for programs with research or production missions remain after that point.
( 1996 BEMR. DOE / EM-0290. Vol. I pg.
4-11.)
Would implementation of full privatization of the GDP sites result in these sites being commercial facilities?
6.
Could NRC please clarify. from federal acquisition regulations. what if any, conflicts. irregularities. ana or/ violat ions exist in the following legal agreements, understandings, and contract awards:
SITE MANAGEMENT STRUCTURE:
Ettective July 1.
1993, and in accordance with Energy Policy Act, tne Department of Energy leasea tne piant Production operations at Portsmouth Gaseous Dittusion Plant to tne United States Enrienment Corporation for six years.
The Department and the United States Enrienment Corporation negotiated the lease of spectric Plant racilities, outlined in Memoranaum of Agreement, wnicn oeilnes their respective roles unaer the lease, ano developea the amninistrative program elements necessary to support their respective roles.
Uncer these agreements, the Department of Energy retains the environmental restoratlon and waste management functions at the Portsmouth Gaseous Diffusion Plant. and Lockheea Martin Energy Systems, Inc. currently manages these operations.
The subsidiary corporation. Lockheed Martin Utility Services. Inc., currently manages plant production operations.
7.
Please provide me with a copy of the Memorandum of
-Agreement (MOA) referenced above between DOE and USEC within 10 working days.
This specific request for one particular document is not intended to preclude or in any way limit my request of October 3 1996 petition to review ANY AND ALL j
DOCUMENTS (emphasis added) used by the director in lesuing findings referenced in CFR notice of September 19, 1996.
8.
DOE defines "1996 Base Case" as covering "the majority of activities that must be carried out to fully clean up and manage all newly generated legacy waste associated with the nuclear weapons complex."
(1996 BEMR, Vol. I, pg. 3-9.)
Some activities, including the Portsmouth GDP and Pacucah GDP, are excluded frcm 1996 Base Case.
At two sites (Paducah Gaseous Diffusion Plant. Kentucky.
and the Portsmouth Gaseous Diffusion Plant. Ohio),
facility stabilization and deactivation costs is subject to an agreement between the United States Enrichment Corporation and the Department of Energy. WHICH ASSIGNS
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4 page 4 THESE RESPONSIBILITIES TO THE UNITED STATES ENRICHMENT CORPORATION (emphasis added).
(1996 BEMR. Vol.
1, pg. 3-10.)
Could NRC please clarify how CFR notice of September 19, 1996 by NRC that " DOE retains ownership of the facilities and will be responsible for eventual decommissioning of the sites" can be reconciled with DOE statement of assignment ot responsibility to USEC?
What entity, if any, is responsible for cost of cleanup, monitoring and surveillance, ana for liability and how long, until what approximate date(s), does any such entity intend to assume responsibility to protect the public nealth, worker safety, Interests of the citizens of this country, and the natural environmentC Respectfully submitted.
[_ y.,,
L l<-["u r Diana Salisbury for SYCAMORE VALLEY ENVIRONM 4TAL AWARENESS GROUP 7019 Ashridge Arnheim Road Sardinia, Onlo 45171 (513) 446-3135
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