ML20196E651
| ML20196E651 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant, Paducah Gaseous Diffusion Plant |
| Issue date: | 11/25/1998 |
| From: | Adams J 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 | |
| ML20138L931 | List: |
| References | |
| GDP-98-0259, GDP-98-259, NUDOCS 9812040092 | |
| Download: ML20196E651 (7) | |
Text
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a USEC A Global Energy Company i
November 25,1998 GDP 98-0259 Dr. Carl J. Paperiello Director, Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 i
Paducah Gaseous Diffusion Plant (PGDP)
Portsmouth Gaseous Diffusion Plant (PORTS)
Docket Nos. 70-7001 & 70-7002 Submittal of NRC Form 327, "Special Nuclear Material (SNM) and Source Material (SM)
Physical Inventory Summary Report" INFORMATION TRANSMITTED IIEREWITH IS PROTECTED FROM PUBLIC DISCLOSURE AS CONFIDENTIAL COMMERCIAL OR FINANCIAL INFORMATION AND/OR TRADE SECRETS PURSUANT TO 10 CFR 2.790(d)(1) i
Dear Dr. Paperiello:
As required by 10 CFR 74.17(a) and the Fundamental Nuclear Material Control Plans (FNMCPs),
j the United States Enrichment Corporation (USEC) is submitting to the United States Nuclear Regulatory Commission (NRC) "SNM and SM Physical Inventory Summary Reports" for the Paducah, Kentucky, and Portsmouth, Ohio, Gaseous Diffusion Plants (PGDP and PORTS, respectively). These Form 327 documents in Enclosures 1 through 12 cover the inventory periods ending September 30,1998, for both plants.
All enclosed doemnents contain confidential commercial or financial information and/or trade secrets that are exempt from public disclosure pursuant to Section 1314 of the Atomic Energy Act of 1954, as amended, and 10 CFR 2.790(d)(1). USEC hereby requests that the enclosed Form 327 documents be withheld from public disclosure.
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The inventory for Portsmouth was taken at 1400 hours0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br /> on September 30,1998. The inventory for Paducah was taken at 1700 hours0.0197 days <br />0.472 hours <br />0.00281 weeks <br />6.4685e-4 months <br /> on September 30,1998.
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Dr. Carl J. Paperiello i
Novpmber ;!5,1998 i
GDP-98-0259, Page 2 i
k includes bi-monthly, cascade inventory data for Portsmouth for the period August 1, 1998, through September 30,1998:
The Form 327 for Uranium in Cascades includes two Prior Period Adjustments (PPAs):
L Per agreement between the Department of Energy (DOE) and NRC, holdup of Highly Enriched Uranium (HEU) in shutdown process equipment in Building X-326 has been entered into the accounting records. This resulted in a booked credit to the cascade inventory account of 791,850 grams uranium and 429,369 grams U.
235 The purity of heel material remaining in cylinders of HEU which were refed to the cascade in prior periods was adjusted to UF purity values. The uranium purities originally booked, using historical data, were determined to be too high. This correction resulted in a PPA of-8,926 grams uranium and -6,433 grams U.
235 The Inventory Differences (ids) resulting from the cascade bi-monthly, dynamic physical inventory exceeded the 2-sigma Warning Level control limits. Per regulatory and procedural requirements, a Problem Report was filed and Nuclear Materials Control and l
Accountability (NMC&A) has initiated an investigation. Initial review indicates two
' potential causes:
Surge and holding drums in the process buildings contained a significant amount j
ofmaterial at the time ofinventory. There is a large uncertainty associated with measurement of material in these drums, primarily due to sampling variability.
Understatement of the amount of UF in these systems could have contributed to the ids.
The daily tails balance on the day ofinventory (September 30) was approximately 15,000 pounds greater than it was at the last inventory (July 31). This indicates that freeze out of UF in shutdown equipment or adjacent piping is a likely cause i
6 of the ids. through 6 describe the results of the annual static inventory conducted at Portsmouth.
The inventory covers the period October 1,1997, through September 30,1998. includes Depleted Uranium Inventory, ids were within expected limits.
Dr. Carl J. Paperiello November.25,1998 GDP-98-0259, Page 3 includes Normal Uranium Inventory.
The ids for Normal Uranium indicated a gain of material in excess of the 2-sigma control limit. Exceeding this ids limit is attributed to the requirement to report transactions of this material type in rounded values (nearest kilogram). includes Low Enriched Uranium (LEU) Inventory, ids were within expected limits. includes Iligh Enriched Uranium Inventory.
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The ids for high enriched ur.mium indicated a gain of material in excess of the 3-sigma control limit. This ids is attributed to the cross-over of material types in the accounting records for both laboratory and decontamination activities. includes Total Plant Inventory.
The ids for the total plant uranium also exceeded the 2-sigma control limits. Because the cascade ids are the major contributor to the total plant ids. this problem will be investigated as part of the Cascade Problem Report investigation noted earlier. Also, the impact of PPAs entered into the accounting records during this period will be evaluated. includes bi-monthly, cascade inventory data for Paducah for the period August 1,1998, through September 30,1998:
The ids reported on Line 6 includes an adjustment of-727,114 grams uranium and -
235 4,994 grams U, to correct contaminated material shipped from the cascade; an adjustment of +314 grams uranium and +2 grams U to correct for stack loss; and an 235 adjustment of+2,228 grams uranium and -16,119 grams U to correct assay changes for 235 product withdrawals from the cascade in July. A PPA is entered on Line 8 to reDect this one-time correction.
Line 7 includes an entry to correct for statistically signi6 cant biases which were present in accountability measurement systems. The corrections were derived from measurement control data for accountability measurements performed during the inventory period.
The resulting ids for uranium element and for U were outside of the Significant ids 235 limit; however the23'U was within the allowable Major ids limit. The ids is likely the result of material returning from the cascade that was freezing out due to low power levels and subsequent low process heating levels during July inventory time.
Dr. Carl J. Paperiello November 25,1998 GDP-98-0259, Page 4 through 12 describe the results of the annual static inventory conducted at Paducah.
The inventory covers the period October 1,1997, through September 30,1998. for Paducah includes Cascade Inventory.
The ids reported on Line 6 includes an adjustment of +32,972 grams uranium and +8 grams 23'U, to correct contaminated material shipped from the cascade; an adjustment of-1,812,889 grams uranium and -10,791 grams U to correct for FY1997 Scale Bias 235 Correction; an adjustment of +0 grams uranium and -109,075 grams U to correct for 235 the FY1997 Gas / Solid Assay Bias Correction; and an adjustment of+312 grams uranium 235 and +2 grams U to correct for stack loss. A PPA is entered on Line 8 to reflect this one-time correction.
Line 7 includes an entry to correct for statistically significant biases which were present in accountability measurement systems. The corrections were derived from measuren3ent control data for accountability measurements performed during the inventory period.
235 The resulting ids for uranium element and for U were within all control limits.
- for Paducah includes Total Plant Inventory.
The ids reported on Line 6 includes an adjustment of-175,373 grams uranium and -
235 114,166 grams U. A PPA is entered on Line 8 to reflect this one-time correction.
These PPA's are detailed in the respective annual Form 327s for the Depleted, Enriched, Normal and Cascade material balances.
Line 7 includes an entry to correct for statistically significant biases which were present in accountability measurement systems. The corrections were derived from measurement control data for accountability measurements performed during the inventory period.
The resulting ids for uranium element and for : U were within all control limits.
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- 0 for Paducah includes the LEU Inventory.
The ids reported on Line 6 includes an adjustment of-972 grams uranium and -8 grams 235U to correct contaminated material shipped from the cascade; an adjustment of 235
+186.204 grams uranium and +1,343 grams U to correct for FY 1997 Waste Shipment; and an adjustment of 0 grams uranium and +355 grams U to correct for the FY 1997 235 Gas / Solid Bias. A PPA is entered on Line 8 to reflect this one-time correction.
Dr. Carl J. Paperiello Noyember 25,1998 GDP-98-0259, Page 5 The resulting ids for uranium element and for U were outside of the Signincant ids 235 limit; however the 235U was within the allowable Major ids limit. I for Paducah includes Normal Inventory.
The resulting ids for uranium element is outside the Limit Error ofInventory Difference (LEID), but within the Signincant ids. The resulting ids for U is within the control 235 limit. 2 for Paducah includes Depleted Inventory.
The ids reported on Line 6 includes an adjustment of-32,000 grams uranium and 0 grams 235U, to correct contaminated material shipped from the cascade; an adjustment of +1,437,000 grams uranium and +4,000 grams U to correct for FY1997 Scale Bias 235 Correction; and an adjustment of+14,000 grams uranium and 0 grams 235U to correct for the FY1997 Waste Shipment. A PPA is entered on Line 8 to reflect this one-time correction.
The resulting ids for uranium element is within the control limit. The resulting ids for 235U was outside of the LEID; however the 235U was within the allowable Major ids limit.
There are no new commitments made in this letter. S5,uld you have any questions or comments on the enclosed information, please call me at (301) 564-3410 or Mark Lombard at (301) 564-3248.
Sincerely, 1
John G. Adams Safety and llealth Assurance Policy Manager
Enclosures:
As stated cc: NRC Region Ill Of6ce NRC Resident Inspector - PORTS NRC Resident inspector - PGDP
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AFFIDAVIT OF JAMES H. MILLER SUPPORTING APPLICATION TO WITHHOLD FROM PUBLIC DISCLOSURE FORM 327 DOCUMENTS FOR THE PADUCAH AND PORTSMOUTH GASEOUS DIFFUSION PLANTS I, James H. Miller, Vice President, Production, United States Enrichment Corporation (USEC), having been duly sworn do hereby affirm and state:
4 1.
I am a manager of USEC and have been authorized by USEC to (a) review the information owned by USEC which is referenced herein relating to the Paducah and Portsmouth Gaseous Diffusion Plants and which USEC seeks to have withheld from public disclosure pursuant to section 147 of the Atomic Energy Act (AEA), as amended, 42 U.S.C. f 2167, and 10 CFR 2.790(a)(3), 2.790(a)(4),
2.790(d)(1) and 9.17(a)(4), and (b) apply for the withholding of such information from public disclosure by the Nuclear Regulatory Commission (NRC) on behalf of USEC.
2.
Pursuant to 10 CFR 74.17(a), USEC has prepared a Form 327, Special Nuclear Material (SNM) and Source Material (SM) Physical Inventory Summary Report for each of the Paducah and Portsmouth Gaseous Diffusion Plants which describes the amount of nuclear material possessed by USEC at each plant. 10 CFR 2.790(d)(1) states that correspondence and reports to or from the NRC containing information concerning an applicant's material control and accounting program for special nuclear material not otherwise designated as Safeguards Information or classified as National Security Information or Restricted Data are deemed to be confidential commercial or financial information exempt from public disclosure. Accordingly, USEC requests that the Paducah and Portsmouth Form 327 documents be withheld from public disclosure pursuant to section 147 of the AEA,42 U.S.C. # 2167, and 10 CFR 2.790(a)(3), 2.790(a)(4), 2.790(d)(1) and 9.17(a)(4).
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3.
James li. Miller, having been duly sworn, hereby confirms that I am Vice President, Production, of USEC, that I am authorized on behalf of USEC to review the information attached hereto and to sign and file with the Nuclear Regulatory Commission this affidavit and the attachments hereto, and that the statements made and matters set forth herein are true and correct to the best of my knowledge or belief.
James II. Miller On this 25th day of November,1998, the Vice President signing above personally appeared before me, is known by me to be the person whose name is subscribed to within the instrument, and acknowledged that he executed the same for the purposes therein contained.
In witness hereof I hereunto set my hand and official seal.
hUALL Ld h x.
Arie M. Knisley, Notary Public State of Maryland, Montgomery County My commission expires March 1,2002 i
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