ML20196E022
| ML20196E022 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant, Paducah Gaseous Diffusion Plant |
| Issue date: | 06/17/1999 |
| From: | Toelle S 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-99-0098, GDP-99-98, NUDOCS 9906280013 | |
| Download: ML20196E022 (6) | |
Text
r USEC A ciob.utn.rsy comp nr June 17,1999 GDP 99-0098 -
Dr. Carl J. Paperiello Director, Office of Nuclear Material Safety and Safeguards i
Attention: Document Control Desk
]
U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Paducah Gaseous Diffusion Plant (PGDP)
Portsmouth Gaseous Diffusion Plant (PGRTS)
Docket Nos. 70-7001 and 70-7002 Notification of Change in Regulatory Commitments
Dear Dr. Paperiello:
j The purpose of this letter is to notify the Nuclear Regulatory Commission (NRC) of a change in j
regulatory commitments. These commitments were made in USEC letters GDP 97-0188 and GDP 97-0189, dated October 31, 1997, which submitted certificate amendment requests (CARS) containing the Safety Analysis Report Updates (SAR Update) required by Issue 2 of DOE /ORO-2026, " Plan for Achieving Compliance with NRC Regulations at the Paducah Gaseous Diffusion j h Plant" and DOE /ORO-2027, " Plan for Achieving Compliance with NRC Regulations at the Portsmouth Gaseous Diffusion Plant"(the Compliance Plans) for NRC review and approval. The specifics of these commitment changes are provided below.
M h
t
Background
In USEC letters GDP 97-0188 and GDP 97-0189, USEC stated that it was "re-evaluating [the analysis of the autoclave head-to-shell 0-ring leakage provided in the DOE SAR Upgrade reports]
to more accurately define the reaction process. Laboratory testing is in progress to better define the reaction rate, and the resulting pressure and temperature generated. This information will be incorporated into the autoclave model and is expected to result in lower temperatures and pressures.
The re-evaluation will also address the potential for liquid and gas release across the autoclave seal."
USEC committed, in part, that "The results of the re-evaluation and revised analyses, including any necessary changes to the SARUP, will be submitted to the NRC by June 30,1999."
i I
I 9906280013 990617 j
PDR ADOCK 07007001 C
.PDR l
6903 Rockledge Drive, Bethesda. MD 20817-1818 Telephone 301564-3200 Fax 301-564-3201 httpd/www.usec. corn OfBces in Livermore, CA Paducah, KY Portsmouth, OH Washington, DC
.m.
Dr. Carl J. Paperiello June 17,1999 GDP 99-0098, Page 2 Descrintion of Revised Commitment "The results of the USEC re-evaluation of the analysis of the autoclave head-to-shell 0-ring leakage provided in the DOE SAR Upgrade reports and revised analyses, including any necessary changes to the SARUP, will be submitted to the NRC by October 15,1999."
huiliD ation for Revised Commitment The laboratory testing, which was conducted at PORTS, has been completed and the results are currently being incorporated into the autoclave model. In addition, calculations addressing the potential for liquid and gas release across the autoclave seals are in progress. However, several documents supporting the SAR Update accident analysis must also be revised prior to submitting proposed changes to the SAR Update CAR for NRC review. The complexity of these document revisions requires additional time to ensure that they are complete and accurate.
If you have any questions, please contact Mark Smith at (301) 564-3244. Commitments contained in this submittal are included in Enclosure 1.
Sincerely,.
Ah @
g Steven A.Toelle Nuclear Regulatory Assurance and Policy Manager i
Enclosure:
Commitments Identified in this Submittal cc: NRC Region III Office
. NRC Resident Inspector - PGDP NRC Resident Inspector-PORTS Mr. Randall M. DeVault, DOE E
P GDP 99-0098 Page1ofI COMMITMENTS IDENTIFIED IN THIS SUBMITTAL
The results of the [USEC] re-evaluation [of the analysis of the autoclave head-to-shell 0-ring leakage provided in the DOE SAR Upgrade report] and revised analyses, including any necessary changes to the SARUP, will be submitted to the NRC by June 30,1999."
This commitment is revised to read as follows:
The results of the USEC re-evaluation of the analysis of the autoclave head-to-shell 0-ring leakage provided in the DOE SAR Upgrade report and revised analyses, including any necessary changes to the SARUP, will be submitted to the NRC by October 15,1999,
The results of the [USEC] re-evaluation (of the analysis of the autoclave head-to-shell O-ring leakage provided in the DOE SAR Upgrade report] and revised analyses, including any necessary changes to the SARUP, will be submitted to the NRC by June 30,1999."
This commitment is revised to read as follows:
The results of the USEC re-evaluation of the analysis of the autoclave head-to-shell 0-ring leakage provided in the DOE SAR Upgrade report and revised analyses, including any necessary changes to the SARUP, will be submitted to the NRC by October 15,1999.
[
06/21/99 MON 14:31 FAI 740 897 4541 PORTS NRA
@ 001
)
j o.
UNITED STATES ENRICHMENT CORPORATION Portsmouth Gaseous Diffusion Plant
' Nuclear Regulatory Affairs Office i
!pd-h DATE:
This transmittal consists of pages Facsimile: (740) 897-4541 Verification: (740) 897-2575 USEC HQ -(301) 564-3210 0
Lisa Jarriel O
ark Smith O
Mark Klasky Steve Toelle O
Russ Wells O
Amy Rebuck NRA - PADUCAH - (502) 441-6798 O
Larry Jackson O
Mike Beren O
Randy Janne O
Steve Cowne PORTS ORGANIZATION MANAGERS O
Morris Brown, General Mgr.
2909 O
Pat Musser, Enrichment Plant Mgr.
2705 O
Melonie Valentine, Admin. Support 4790 0
Jim Morgan, Customer Service 4756 O
Bob Helme, Engineering 3785 O
Ken Tomko, ES&H 3422 O
Mike Wayland, Maintenance 4540 0
Steve Casto, Work Control /Matis. Mgmt.
3720
)
O Sandy Fout, Operations 3719 O
PSS 3793 O
Ron Smith, Production Support 4101 O
Lee Fink, SS&Q 2644 O
John Cox, Site and Facilities Support 4640 0
Dave Couser, Training & Procedures 3788 O
Jim Anzelmo, Commitment Mgmt.
2909 O
John Henricks, Corporate Finance 2909 O
Mark Scott, Corporate Info. Technology 2679 O
Bob Bush, Corporate Procurement 3469 OTHER O
O Ydtmet Ma2_
From:
Persem Message:
e g
F 06/21/99 MON 14:32 FAI 740 897 4541 PORTS NRA
@ 002 s.
Discussion points for Response to NRC Letter Dated June 11,1999, n
p f.
CP Issues 8,9, and 23 (TAC NO. L32123)
Date: 6/21/99 NRC concern:
The 7/30/00 date to complete implementation of Priority 2 upgrades should be changed to 3/3/00 because their review of revision 5 of the NCS CAP found the 7/30/00 date to be " unsubstantiated."
Response
Letter GDP 99-2020, dated April 30,1999, contained sufficient infonnation about the scheduling of Priority 2 upgrades, but it did not emphasize detailed scheduling information. Imponant facts that l
need to be emphasizedinclude:
The limiting resource is the SMEs. This includes the personnel supporting AQ-NCS flow-down.
AQ-NCS flow-down is resource consuming and has a great schedule impact.
Task 3 activities (Priority 1 & 2 NCSA/E upgrades and implementation and NCSA/E additional reviews) were not intended to be performed in series: i.e., the additional reviews and AQ-NCS flow-down were intended to be performed concurrent with the Priority 2 upgrades. In addition, Task 21, FMO Identification, will be performed concurrent with Priority 2 NCSA/E upgrades Experience from the past 3 months ofimplementing priority 1 NCSA/Es indicates the l
site, and in particular the SMEs, can support the implementation of only 6 NCSA/Es per l
month. (this also correlates with 39 Priority 1 NCSA/Es to be implemented in 6 and %
months) A higher level of achievement does not appear possible because this is our current rate, while under the direction of a special, high-level management team. Also consider, the current schedule is skewed - a higher number of completion dates - toward the end.
There are a total of 160 NCSA/Es to be implemented over 26 months, which also equals l
6 per month.
rs.ngine the Priority 2 completion date would result in shifting work (e.g., Priority 2 l
NCSA/Es rather than implementation of NCSA/Es from the additional reviews). Note, j
the commitments in GDP 98-2027, dated 6/30/98, to upgrade AQ-NCS flow-down per Task 3 schedule was possibly accelerated when the " additional review" category was i
l created (i.e., change in work paths from implied series to parallel).
l The commitment to complete changes to AQ-NCS classifications resulting from additional reviews is 5/19/00. Moving the Priority 2 completion date to March 3,2000, has a definite negative impact on meeting the 5/19/00 commitment date. See attached block diagram.
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