ML20149H884
| ML20149H884 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 07/18/1997 |
| 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) |
| References | |
| GDP-97-0122, GDP-97-122, NUDOCS 9707250225 | |
| Download: ML20149H884 (12) | |
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United States Enrichm:nt Corporation 2 Democracy Center L-6903 Pockledge Drwe Bethesda. MD 20817 Tet (301) 564-3200 Fax: (301) 564-3201 United States Enrichment Corporation JAMES H. MILLER Dir: (301) 564-3309 VICE PRESIDENT, PRODUCTION Fax: (301) 571-8279 July 18,1997 Dr. Carl J. Paperiello SERIAL: GDP 97-0122 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 - Update the Application Safety Analysis Report
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 Portsmouth, Ohio Gaseous Diffusion Plant (GDP). This certificate amendment request revises the completion date for submittal of the update to the application Safety Analysis Report (SAR) that is specified in DOE /ORO-2027, " Plan for Achieving Compliance with NRC Regulations at the Portsmouth Gaseous Diffusion Plant" (the Compliance Plan).
Issue 2 of the Compliance Plan requires, in part, that USEC submit an update to the application Safety Analysis Report based largely on the DOE site-wide SAR by August 17, 1997. USEC's efTorts to complete the SAR Update (SARUP) submittal have been underway since receipt of the DOE upgraded SAR in mid-February,1997 and a majority of the necessary activities have been completed. Ilowever, additional time is required to complete the resolution ofinternal comments from plant support groups, to evaluate changes to the plant and identified as-found conditions for their impact on S ARUP, to review the SARUP supporting documents, and to obtain final PORC approval of the proposea application changes. Consequently, USEC requests NRC approval of a change in the submittal date from August 17,1997 to October 31,1997.
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Dr. Carl J. Paperiello July 18,1997 l
GDP 97-0122 Page 2 Enclosure I to this letter provides a detailed description and justification for the proposed change. is a copy of the new pages for Compliance Plan issue 2. Enclosure 3 contains the basis for USEC's determination that the proposed change associated with this certificate amendment request is not significant, i
The amendment should become effective no later than 15 days from issuance.
Any questions related to this subject should be directed to Mr. Steve Routh at (301) 564-3251. There i
are no new commitments contained in this submittal.
Sincerely,
'%h ames H. Miller Vice President, Producticn
Enclosures:
1.
United States Enrichment Corporation (USEC), Proposed Certificate Amendment Request, Update the Application Safety Analysis Reports, Detailed Description of Change 2.
NRC Certificate Amendment Request, Portsmouth Gaseous Diffusion Plant, Letter GDP 97-0122, Removal / Insertion Instructions & Pages 3/4,9/10 of Compliance Plan Issue 2 l
3.
United States Enrichment Corporation (USEC), Proposed Certificate Amendment Request, Update the Application Safbty Analysis Report, l
Significance Determination i
cc:
NRC Region III Oflice, w/ enclosures i
NRC Resident Inspector - PORTS, w/ enclosures NRC Resident Inspector - PGDP, w/o Mr. Randall M. DeVault, w/ enclosures i
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i OATH AND AFFIRMATION 1
~ I, James H. Miller, swear and aflirm 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 l
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Regulatory Commission this Certificate Amendment Request for the Portsmouth Gaseous Diffusion i
Plant, that I am familiar with the contents thereof, and that the statements made and matters set forth
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- therein are true and correct to the best of my knowledge, information, and belief.
j James H. Miller i
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Subscribed to before me on this [
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,1997.
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Certificate Amendment Request Update the Application Safety Analysis Report Detailed Description of Change l
1.0 Purpose The purpose of this certificate amendment is to request NRC approval of a change in the submittal date for the update to the Application Safety Analysis Report that is specified in Issue 2, " Update the Application Safety Analysis Report," of DOE /ORO-2027, Plan for Achieving Compliance with NRC Regulations at the Portsmouth Gaseous Diffusion Plant (Compliance Plan). Specifically, a change in the submittal date specified in Item 3 of the Plan of Action and Schedule for CP Issue 2 from August 17,1997 to October 31,1997 is requested.
2.0 Description Compliance Plan Issue 2 requires USEC to prepare and submit an update to the Application Safety Analysis Report based largely on the DOE site-wide SAR. Specifically, Item 3 of the Plan of Action and Schedule for Compliance Plan Issue 2 requires that:
3.
By no later than August 17, 1997, USEC shall submit an amendment to their Certification Application which includes:
a) identification of all information, findings, and recommendations which indicate differences between the DOE site-wide Safety Analysis Report and the USEC Application for Certification.
b) an evaluation of the effects of those differences on the safety of workers, and off-site members of the public.
l c) proposed modifications to the compliance certifica.c and/or facility, meluding proposed modifications to the Application SAR and TSRs.
USEC's efforts to complete the SAR Update (SARUP) submittal have been underway since i
receipt of the DOE upgraded SAR (POEF-LMES-89, see Reference 1) in mid-February,1997 and a majority of the necessary activities have been completed. However, additional time is required to complete the following activities:
Resolve internal comments from plant support groups
' to GDP 97-0122
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Page 2 of 2
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Evaluate changes to the plant and identified as-found conditions for their impact on j
SARUP J
Review the SARUP supporting documents 1
Obtain final PORC approval of the proposed application changes Consequently, USEC requests NRC review and approval of a change in the submittal date from
, August 17,1997 to October 31,1997.
A review of the Justification for Continued Operation (JCO) for Compliance Plan Issue 2 has been performed to determine if any changes are required as a result of extending the SARUP submittal
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date.' The conclusions of this review are that no changes to the JCO are required (other than the submittal date change) and continued operation isjustified during the extended period.
Reference i
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POEF-LMES-89, Safety Analysis Report, Portsmouth Gaseous Diffusion Plant, Piketon, Ohio; Prepared by Lockheed Martin Energy Systems, Inc. for the U.S. Department of Energy; Transmitted by February 14,1997 Letter from Joe W. Parks (DOE) to Mr. George P. Rifakes, USEC.
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- to GDP 97-0122 3 Pages Total NRC Certificate Amendment Request Portsmouth Gaseous Diffusion Plant Letter GDP 97-0122 Removal / Insertion lustructions Remove Pages Insert Pages PLAN FOR ACIIIEVING COMPLIANCE WITTI NRC REGULATION AT TIIE PORTSMOUTII GASEOUS DIFFUSION PLANT (DOE /ORO-2027)
Issue 2, Update the Application Safety Issue 2, Update the Application Safety Analysis Report Analysis Report Pages 3/4,9/10 Pages 3/4,9/10 I
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Update thp Applicanon Safety Amlysis Repon Issue 2, Page 3 meteorology (including tornado and high winds). Additionally, the facility and process descriptions are required to be upw based on the final accident analyses resulting from the DOE site-wide safety analysis upgrade effort, as well as other program upgrades such as the Configuration Management Press,==. The SAR update will provide more accurate anmarm of release rates and on-site and off-site consequences needed to meet 10 CFR 76.85 for establishmg limiting conditions for operations.
JUSTIFICATION FOR CONTINUED OPERATION The safety of the GDPs has been connnully confirmed through: (1) the imnal Atomic Energy Commission reviews and approvals of GDP design, siting, and construction; (2) the performance, review, and approval of numerous additional safety analysis and aueaments performed to support continued operations under increasingly stringent standards; and (3) more than 100 combined years L
of operation for the 3 GDPs that has developed a generation of competent operating staff whose plant experience and knowledge continue to assure safe operations of the GDPs.
i DOE's current safety basis for authorizing the continued operation of the GDPs is based on the plants' implementation of, and adherence to, safety requirements in Operational Safety Requirements (OSRs) and plant procedures, developed through the long operating experience of the GDPs. This safety basis will continue to be utilized by the GDPs dunng te interim period of noncompliance until completion of the SAR Upgrade and impicmentation of the approved amendment request addressing results of the SAR Upgrade. The Technical Safety Regmrements (TSRs), which will take effect upon NRC assunung regulatory oversight of the GDPs, are based on the safety reqmrements in OSRs and additional safety requirements identified during the certification process. Current plant procedures that are safety related shall also remain in effect after NRC assumes regulatory oversight of the GDPsc Also, new safety procedures continue to be developed and implemented as part of the certification process. These existing and new safety procedures can be changed only in accordance with the procedure TSR which provides the necessary safety assessment and both management and technical review before a procedure is changed or replaced. TSRs cannot be changed without prior NRC approval.
The safety systems in the Certification Application contam commitments with regard to currently identified safety structures, systems, equipment, and components m assure te availability and reliability of features relied on for safety. In addition, the Certification Application also contains commitments to safety programs such as radiation protection, criticality prevention, etc.
The protection of workers, members of the public, and the environment is assured through' proper implementation.of the safety systems and programs described in the. Application and the Compliance Plan, which includes the SAR Upgrade. From the comprehensive analysis of all credible imnanng events based on "as-exist" plant configurations, and the consequences from these accidents, the SAR Upgrade will designate possible additional safety systems, equipment, components, and human activities. and also provide descriptions' of the various safety programs (based pnmarily from the Certification Application).
The combination of the use of expenenced plant personnel; implementation of, and adherence to, TSRs (which succeed the OSRs) and current as well as new GDP safety procedures; and commitments to comnamery measures and/or interim regulatory commitments will ensure that the GDPs continue to operate safely during the interim period of noncompliance until the SAR I
I PORTS Rev. 3,7/15/96
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Issue 2, Paga 4 PROPOSED Update the Application Sarety Analysis Repon RAC 97X0414 upgrade and accompanying GDP modifications for safety are approved by the NRC'and implemented at the GDPs.
l The DOE site wide safety analysis upgrade (SAR Upgrade) was initiated to address the I
deficiencies stated in the Description of Noncompliance, changes to the plant configuration implemented since the previous analysis was performed, and the revised DOE safety requirements issued since the development of the 1985 FSAR. This effort involves (1) comprehensive site characterization for natural and man-made phenomena (e.g., explosion off-site) evaluation; (2) systematic identification and analysis of hazards associated with each of the facilities; (3) determination of human actions, structures, systems, and components that are safety significant; (4) determinacon of credible accidents from the possible hazards; (5) evaluation of facility operational states for the limiting condition within each operational mode; and (6) determination of releases from the credible accidents and consequences from the releases for normal, off-normal, and accident conditions.
The DOE site-wide safety analysis upgrade effort has not yet completed all analysis of possible accident coaditions and consequences. However, the currently available preliminary results are generally consistent with previous analysis forming the GDP current operating safety basis and, to date, have not identified any additional significant accidents that have not been addressed in the 4
submitted SAR. Although the ongoing DOE site wide safety analysis upgrade may identify additional risks, insights, and wasures that can be taken to further reduce risks to workers and public health and safety and the environment, the upgrade is not expected to identify significant additional or higher risks than those considered in the submitted Safety Analysis Report.
l Although the final SAR Upgrade will not be submitted to the NRC until October,1997, preliminary SAR Upgrade results concerning safety significant issues (e.g., seismic) have and shall continue to be brought to the at:ention of the NRC staff. Where possible, features of safety systems and elements of safety programs that will enhance safety are being incorporated into the I
certification application. For those features of safety systems and remaining elements of safety l
programs which cannot be implemented by the time NRC assumes regulatory oversight of the plants, compensatory measures and/or interim regulatory commitments have been provided in the compliance plan during the interim period of noncompliance. These compensatory measures and/or interim regulatory comminnents are described in compliance plan issues related to the functional areas covering the pertinent safety issue.
If the upgrade efforts identify risks more severe than those submitted in the Safety Analysis l
Report, DOE will inform USEC of the identified risk within 5 working days. If such risk is i
identified before NRC assumes regulatory oversight for the facility, USEC will resolve the risk in accordance with DOE Regulatory Oversight Agreuaent requirement 3.3.2.7. This requires that management ensure that "as found" conditions which potentially involve an unreviewed safety question or a change in the authorization basis or an operational safety requirement are reported to DOE and that appropriate engineering reviews and safety assessments of the condition are performed and submitted to DOE for review. If any of the information is identified by USEC cr j
DOE as having a significant implication for the worker and/or public health and safety or j
common defense and security, then notification will be provided by USEC to the Administrator of NRC's Region III Office within 2 working days.
l After NRC assurvt regulatory oversight for the facility, USEC will address risks more severe i
than those submitted in the Safety Analysis Report in accordance with the commitments in the PORTS, July 18, 1997 PisOPOSED
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i Update the Application Safety Analysis Report PROPOSED issue 2, Page 9 RAC 77X0414 contrcis required to reduce the probability of significant accident scenarios will be described.
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Programmatic Controls
- 1) The programs discussed in the Chapter 6 through 17 descriptions in DOE-STD-3009-94 will be described for DOE activities at the facility. These programs include prevention of inadvertent criticality; radiation protection; hazardous material protection; radioactive and hazardous waste management; initial testing, in-service surveillance, and maintenance; operational safety; procedures l
, and training; human factors; quality assurance; emergency preparedness program; provisions for decontamination and decommissioning; and management, organization, and institutional safety provisions.
- 2) The programs described in Chapters 5 and 6 of the USEC Application for Certification, as well as the other supplemental program descriptions contained therein, will be assumed valid for USEC activities at the facility. These programs will be reviewed and evaluated for impact on DOE activities, and areas of interdependency will be identified. Any apparent conflict between USEC and DOE activities identified during this review will be resolved between USEC and DOE during the DOE site-wide Safety Analysis Report preparation, review, and '
approval by DOE.
2.
USEC will provide information required to complete the DOE site-wide Safety Analysis Report and will provide technical reviews of the ongoing analyses to ensure that the analyses accurately reflect the facility configuration.
3.
By no later thau October 31,1997, USEC shall submit an amendment to their Certification l
Application which includes:
a) identification of all information, findings, and recommendations which indicate differences between the DOE site-wide Safety Analysis Report and the USEC Application for Certification.
b) an evaluation of the effects of those differences on the safety of workers, and off-site i
members of the public.
c) proposed modifications to the compliance certificate and/or facility, including proposed modifications to the Application SAR and TSRs.
4.
At the same time the Application amendment is due, USEC shall also submit for NRC approval, its proposed resolution of matters contained in the DOE-approved site-wide Safety Analy;is Report not incorporated by USEC in its request for amendment of their Application for Certification.
S.
From September 30,1995, until NRC approves the submittals in paragraphs 3 and 4 above, changes made by USEC in accordance with DOE's ROA requirement concerning Unreviewed Safety Question Determinations (USQDs) or with 10 CFR 76.68 must be addressed either in the DOE SAR Upgrade results or in the amended safety analysis report submitted by USEC i
PORTS, July 18,1997 PROPOSED j
Issue 2, Page 10 Update the Appfcuion 50fety Analysia Repop based upon those results. The following will assure such changes are properly considered and b
addressed:
a) The plant configuration was considered to be frozen for the purpose of DOE's analysis on September 30,1995.
b) Changes made to the plants after b,- M 30,1995, will be addressed by USEC in its amendment Application. The amendment Application will reflect the plant as it exists 6 months before the amendment subminal.
c) Once the amendment is submined, USEC will inform NRC of changes that are made in accordance with 10 CFR 76.68 that could render the amendment to be mcorrect,
' inaccurate, or incomplete until the amendment is approved by NRC.
i d) NRC is notified of changes made in accordance with 10 CFR 76.68 as part of the annual Application for renewal required by 10 CFR 76.36.
6.
The update to the Application SAR will also reflect those commitments made by USEC to the NRC during the initial certification application process as identified in the Application and the responses to NRC questions / comments.
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SUMMARY
OF REQUIREMENTS, COMMITMENTS, AND NONCOMPLIANCES t
Issue: Update the Applicadon Safety Analysis Report i
j Code of Federal Regulations Part l
Title 10 76.35(a)(4), (6), and (8); 76.85
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Applicadon Commitment Secdon f
Safety Analysis Report 2,3,4 l
Applicadon Noncompliance Statement Secdon i.
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Safety Analysis Report 2.7, 3.9.1
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PORTS Rev. 3,7/15/96
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. to GDP 97-0122 Page1of2
- United States Enrichment Corporation (USEC)
Certificate Amendment Request Update the Application Safety Analysis Report 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 Overall Decrease in the EfTectiveness of the Plant's Safety. Safecuards. or Security Procrams No changes to the plant's safety, safeguards, or security programs are required as a result of an extension to the SAR Update submittal date. Thus, the efTectiveness of the plant's safety, safeguards, and security programs is unaffected by this certificate amendment.
2.-
No Significant Change to Any Conditions to the Certificate of Comnliance None of the Conditions to the Certificate of Compliance specifically address the SAR Update.
Thus, the proposed changes have no impact on any of the Conditions to the Certificate of Compliance.
3.
No Sienificant Change to Any Condition of the Anoroved Com_pliance Plan Issue 2 is the only portion of the Compliance Plan affected by the proposed changes. Extending the submittal date for the S AR Update is not a significant change because no changes to the JCO for Compliance Plan Issue 2 are required (other than the submittal date change).
4.
No Significant Increase in the Probability of Occurrence or Consecuences of Previonsiv Evaluated Accidents No changes to the existing application SAR are required as a result of an extension to the SARUP submittal date. For this reason, the probability of occurrence or the consequences of previously evaluated accidents will not be increased.
5.
No New or DifTerent Tyne of Accident i
No changes to the existing application SAR are required as a result of an extension to the S ARUP i
submittal date. For this reason, no new or different types of accidents will be created.
6.
No Significant Reduction in Margins o/ Safely 4
This certificate amendment request has no impact on the margins of safety as defined in the basis for any Technical Safety Requirement. Therefore, no significant reductions in margins of safety will result.
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GDP 97-0122 Page 2 of 2 7.
No Siunificant Decrease in the Effectiveness of any Program or Plans C.;ntained in the Certificate Apolication For the reasons discussed in the response to item 1 above, there will be no significant decrease in the effectiveness of any program or plan contained in Volume 3 of the ' Certification Application.
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 As discussed in the response to Item 4, the extension of the submittal date for the SAR Update -
will not result in a significant increase in the probability of occurrence or the consequences of-previously evaluated accidents. As' discussed in the response to Item 5, no new or different types of accidents have been identified. Thus,' there will be no undue risk to public health and safety or to the environment. The change in the submittal date has no impact on common defense and security.
9.
No Change in the Tvoes or Significant Increase in the Amounts of Any Efiluents that May be Released Offsite As discussed in the response to Item 4, there will be no increase in the consequences of previously evaluated accidents. Therefore, there will be no change in the types or significant increase in the amounts of any efIluents that may be released offsite.
10.
No Significant Increase in Individual or Cumulative Occunational Radiation Exoosure j
i The extension of the SARUP submittal date has no impact on plant operation. The Compliance Plan JCO will continue to remain in effect. No increases in individual or cumulative occupational radiation exposures are involved.
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No Significant Construction Imoact The extension of the SAR Update submittal date does not involve construction activities.
j Therefore, there is no significant construction impact.
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No Sienificant Increase in the Potential for Radiolouical or Chemical Conseauences from l
Previousiv Analyzed Accidents j
As discussed in the response to Item 4, there is no significant increase in the probability of occurrence of previously evaluated accidents. Therefore, there is no significant increase in the potential for radiological or chemical consequences from previously analyzed accidents.
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