ML20198A856

Provides Info Relevant to Two Apparent Violations Identified in 971027 & 1126 Ltrs Re Info Relevant to SAR Update for Paducah & Portsmouth Gaseous Diffusion Plants

ML20198A856
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant, Paducah Gaseous Diffusion Plant
Issue date:	12/24/1997
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-97-0203, GDP-97-203, TAC-L32043, TAC-L32044, NUDOCS 9801060114
Download: ML20198A856 (31)

Text

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'USEC A Global Energy Company JAMES H. Maarn D<; (301) 564-3309

%ce PnrsioENT, PnooOCTION Far (301) 571-8279 December 24,1997 Dr. Carl J. Paperiello SERIAL: GDP 97 0203 Director, Olrice of Nuclear Material Safety and Safeguards Attention: Document Control Desk U S. Nuclear Regulatory Commission Washington, D.C. 20555 0001 Paducah Gaseous Diffusion Plant (PGDP)

Portsmouth Gaseous Diffusion Plant (PORTS)

Docket Nos. 70-7001 & 70 7002 Compliance Plan issue 2 - Response to NRC Request for information on Safety Analysis Report Update (TAC Nos. L32043, L32044)

Dear Dr. Paperiello:

By letter dated October 27,1997 (Reference 1), the NRC informed USEC of its intent to hold on December 1,1997, an open predecisional enforcement conference with USEC concerning two apparent violations involving failures to comply with Condition 8 of the Certificates of Compliance for the Paducah and Portsmouth gaseous difTusion plants. The apparent violations concerned the August 18, 1997 certificate amendment requests (References 2 and 3) submitted by USEC in response to issue 2 " Update the Application Safety Analysis Report," of the Plans for Achieving Compliance with NRC Regulations at the Paducah and Portsmouth Gaseous Diffusion Plants (References 4 and 5).

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By letter dated November 26,1997 (Reference 6), the NRC: (1) requested USEC's position on //

information received from DOE relevant to the two apparent violations, and (2) informed USEC that the Decemtwr 1,1997 conference was cancelled and would be rescheduled aller considering USEC's response to the DOli information.

The purposes of this letter are to: (1) provide information relevant to the two apparent violations identified in the NRC's October 27,1997 letter, and (2) provide the information requested in the NRC's November 26,1997 letter. Refer to the enclosure for this information.

9901060t14 971224 PDR ADOCK 07007001 C

PDR

, v 6903 Rmkledge Drive, l\\ethesda, MD 20817 1818 Telephone 3015M 32001:ax 3015M-3201 http://wwwusec.com 00kes in 1.lvermore, CA Paducah; KY lbrismouth, Oli hhington, DC

__ - ___ _ _____ - __ - _-____ - ________ - -__J

D Dr. Carl J. Paperiello December 24,1997 GDP 97 0203 Page 2 Should you have any questions on the enclosed information, please contact me at (301) 564 3309 or Steve Toelle at (301) 564-3250. There are no new commitments made in this submittal.

Sincerely, b

(

J ies 11. MUlcr ice President, Production

Enclosure:

Information Relevant to USEC SAR Update, Paducah Gaseous Diffusion Plant, Portsmouth Gaseous Diffusion Plant, Docket Nos. 70 7001 & 70 7002, December 24,1997.

CC:.

NRC Region til Office NRC Resident Inspector - PGDP NRC Resident inspector - PORTS Mr. Joe W. Parks (DOE)

Mr. Randall M. DeVault (DOE) 4 k

______.___m._ _ _ _ _

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Dr. Carl J. Paperiello December 24,1997 GDP 97-0203 Page 3 REFERENCES

1. Letter from Carl J. Paperiello (NRC) to hir. William 11. Timbers (USEC), " Apparent Violations Concerning Paducah and Portsmouth certificate Amendment Requests, Dated August 18,1997 -

Update of the Application Safety Analysis Report," dated October 27,1997.

2. Letter from James.11. hiiller (USEC) to Dr. Carl J. Paperiello (NRC), " Certificate Amendment Request Update the Application Safety Analysis Report," Paducah Gaseous Diffusion Plant, Letter No. GDP 97-0147, dated August 18, 1997.

3. Letter from James.11. hiiller (USEC) to Dr. Carl J. Paperiello (NRC), Certificate Amendment Request - Update the Application Safety Analysis Report," Portsmouth Goseous Diffusion Plant, Letter No. GDP 97 0148, dated August 18,1997.

4, issue 2," Update the Application Safety Analysis Report," of DOE /ORO-2026, Plan for Achieving Compliance with NRC Regulations at the Padu;ah Gaseous Diffusion Plant, Revision 3,7/15/96.

5. 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, Revision 3, 7/15/96.

6. Letter from Carl J. Paperiello (NRC) to hir. William 11. Timbers (USEC), " Cancellation of Predecisional Enforcement Conference and Request for Information (TAC Nos. L32043, L32044),"

dated November 26,1997.

OATli AND AFFIRMATION i

I, James 11. Miller, swear and affirm 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 Regulatory Commission the document titled, "Information Relevant to USEC SAR Update, Paducah Gaseous Diffusion Plant, Portsmouth Gaseous Diffusion Plant, Docket Nos. 70 7001 & 70-7002, December 24,1997," that I am familiar with the contents thereof, and that the statements made and matters set forth therein are true and correct tu the best of my knowledge, information, and belief.

[

nes 11. Miller On this 24th day of December,1997, the oflicer 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 hereofI hereunto set my hand and ollicial seal.

A.Ld r_

- State of Maryland, Montgomery Co(J a(irie M. Knisley, Notary Public unty My commission expires March 17,1998 3

Enclosure to GDP 97 0203 Page1of16 Information Relevant to USEC SAR Update Paducah Gaseous Diffusion Plant Portsmouth Gaseous Diffusion Plant Docket Nos. 70-7001 & 70-7002 December 24,1997

1.0 INTRODUCTION

By letter dated October 27,1997 (Reference 1), the NRC informed USEC ofits intent to hold on December 1,1997, an open predecisional enforcement conference with USEC concerning two apparent violations involving failures to comply with Condition 8 of the Certificates of Compliance for the Paducah and Portsmouth gaseous diffusion plants. The apparent violations concerned the August 18, 1997 certificate amendment requests (References 2 and 3) submitted by USEC in response to issue 2," Update the Application Safety Analysis Report," of the Plans for Achieving Compliance with NRC Regulations at the Paducah and Portsmouth Gaseous Diffusion Plants (References 4 and 5).

By letter dated November 26,1997 (Reference 6), the NRC: (1) requested USEC's position on information received from IX)E relevant to the two apparent violations, and (2) informed USEC that the December 1,1997 conference was cancelled and would be rescheduled after considering USEC's response to the DOE information.

The purposes of this enclosure are to: (1) provide information relevant to the two apparent violations identified in the NRC's October 27,1997 letter, and (2) provide the information requested in the NRC's November 26,1997 letter.

2.0 INFORMATION RELEVANT TO APPARENT VIOLATIONS Issue 2 of the Compliance Plans (cps) describes actions and activities related to the preparation of an upgraded site-wide Safety Analysis Report (SAR) by DOE and the submittal of an update to the certification applications by USEC based on the DOE information. In the NRC's October 27, 1997 letter, the following two apparent violations were identified related to the actions required by CP issue 2:

" Based on its review, the NRC has determined that USEC apparently failed to meet:

1.

Item 3 of the Plan of Action and Schedule in Compliance Plan issue 2, in that USEC filed by August 17,1997, the amendment to its certification application for each PGDP and PORTS, but it did not include: a) identification of all information, findings, and recommendations indicating differences between the DOE site-wide Safety Analysis Report

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Enclosure to l

GDP 97 0203 Page 2 of 16 i

and the USEC Application for Certification; b) an evaluation of the l

effects of those differences on the safety of workers, and off-site members of the public; and c) proposed modifications to the compliance certificate and/or facility, including proposed modifications to the Application SAR and TSRs.

l 2.

Item 4 of the Plan of Action and Schedule in Compliance Plan Issue 2, in that USEC filed by August 17,1997, the amendment to its certification application for each PGDP and PORTS, but it did not propose resolution of matters contained in the DOE-approved site wide SAR not incorporated by USEC in its request for amendment.

The failure to submit the above information for PGDP are two apparent violations of Condition No. 8 of Certificate of Compliance GDP 1.

The failure to submit the above information for PORTS are two apparent violations of Condition No. 8 of Certificate of Compliance GDP 2."

Based on the information presented in the NRC's October 27,1997 and November 26,1997 letters, USEC has identified two issues relative to the apparent violations:

Issue 1: Late Submittal of USEC SAR Update USEC's August 18,1997 certificate amendment requests were incomplete. The remaining portions of the SAR Update infonnation were not submitted for NRC resiew until October 31,1997.

lasue 2: Lack of an Update to Application SAR Chapter 3 USEC's August 18,1997 and October 31,1997 certificate amendment requests are incomplete. An update to the facility and process descriptions in Application SAR Chapter 3 has not been submitted for NRC resiew.

Root causes and corrective actions for these two issues are discussed in the following sections.

Enclosure to GDP 97 0203 Page 3 of 16 2.1 1ssue 1: Late Submitta, of USEC SAR Undate 2.1.1 Root Causes The following root causes have been identified for the delay in the completion of the USEC SAR Update certificate amendment requests from August 17,1997 to October 31,1997.

l 1.

There was not enough time to complete the USEC activities that were originally

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anticipated as part of CP issue 2. In particular, additional time was required to: (a) prepare the Technical Safety Requirements (TSRs); (b) develop detailed boundary definitions for Q and AQ structures, systems, and components (SSCs)t and (c) complete cross-discipline review and PORC approval of all sections of the SAR Update.

s Early in the development of CP issue 2, both DOE and USEC recognized the extensive amount of work that would be required to incorporate the information from the DOE site wide SAR Upgrade into the USEC certification applications. In early versions of CP issue 2, both DOE and USEC originally requested that the USEC submittal of the SAR Update certificate amendment requests be made as part of the next regular filing for an application for renewal as required by 10 CFR 76.31, or within 6 months of receiving the DOE approved information and supporting documentation, whichever came later (see References 7 and 8). Howevct, the schedule for submittal of the USEC SAR Update was accelerated dramatically by DOE in response to NRC comments during February and March 1996, and an absolute date of August 17,1997 was established in Compliance Plan Issue 2 (see References 9 and 10).

The short schedule established by CP issue 2 resubd in the need for a substantial number of engineering, safety analysis, operations, regulator, od subcontractor personnel in ocder to complete the SAR Update effort. Prior to receipt, the DOE site wide SAR Upgrade on February 14,1997, USEC had completed the preparation of a detailed plan and schedule for preparitig the SAR Update certificate amendment requests by August 17,1997, in accordance with CP Issue 2. All necessary resources were assigned prior to February 14,1997 consistent with the plan requirements. The plan induded the following activities:

Review,1cvise, and supplement the DOE hazard and accident analyses Review and revise the DOE site characteristics information Prepare revised TSRs in proper format based on the DOE site wide SAR Review all DOE supporting documents

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Achieve turnover of all DOE databases and computer codes, including training and code documentation Address outstanding issues from NRC questions during initial eeritification Prepare revised boundary definitions for Q and AQ SSCs based on the DOE hazard

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and accident analysis results m

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0 Enclosure to GDP 97-0203 Page 4 of16 Prepare new appendix to Application SAR Section Si to describe nuclear criticality

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safety controls for plant processes Prepare infonnation required to satisfy the requirements ofiterns 3 a),3.b), and 4 of the Plan of Action and Schedule for CP Issue 2 Incorporate plant changeJ since the DOE cut-off date of September 30,1995

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i Obtain cross-discipline review and PORC approval of all sections of the S AR Update submittals.

This list of activities provides an indicatic'i of the extensive amount of work that had to be completed by USEC in order to satisfy the requirements of CP Issue 2 within the established schedule.

As USEC's efforts to prepare the SAR Update submittals progressed, several activities were detennined to involve more work and time than originally anticipated in the project plan. In response, additional USEC/LMUS and subcontractor personnel were assigned to the project, llowever, even with the added resources, additional time war Jed beyond August 17,1997 to complete the following activities:

Prepare the Technical Safety Requirements (TSRs)

Develop detailed boundary defiaitions for Q and AQ SSCs Complete cross-discipline review and PORC approval of all sections of the SAR Update.

2.

In accordance with CP issue 2. U3EC expected to receive the DOE site-wide SAR Upgrade and supporting documents by February 15,1997. Ilowever, copies of all DOE supporting documents were not received by USEC until April 1997.

Item 1 of the Plan of Action and Schedule for Compliance Plan Issue 2 states, in part:

"1.

The current DOE site-wide safety analysis upgrade efforts will be completed and approved by DOE in accordance with DOE Order 5480.23, " Nuclear Safety Analysis Repons," and consistent with the intent of DOE STD 3009-94," Preparation Guide for U.S. Department of Energy Nonreactor Nuclear Facility Safety Analysis Reports." The approved DOE site.

wide Safety Analysis Report and supporting documentation wSI Gen be forwarded to USEC by February 15. 1997."

(emphasis added)

i Enclosure to GDp 97-0203 Page 5 of 16 l

i By letter dated February 14,1997 (Reference 11), DOE transmitted a copy of the approved, upgraded, site wide Safety Analysis Reports to USEC. However, copies of the approximately 400 supporting documents (calculations, analyses, reports, etc.) were not transmitted by DCE's contractor, Lockheed hiartin Energy Services (LhfES), until hiarch 31,1997 (Reference 12) and were not received by USEC until April 4,1997.

Review of the supporting documents was a critical task in USEC's efforts to prepare the SAR Update certificate amendment requests (see the discussion for root cause #1 above).

Consequently, USEC devoted significant resources to work with DOE /LhiES and ensure copies of all necessary supporting documents for both PGDP and PORTS were turned-over to USEC.

i Although some of the supporting documents were received by USEC prior to February 15, 1997, most were not received until April 4,1997. Further, copies of several supporting documents were not received until late April 1997 following USEC's review of the hiarch 31, 1997 LhiES transmittal and the identification of additional documents required. The late receipt of the DOE supporting documents contributed to the delay in cornpleting the USEC SAR Update certificate amendment requests.

3.

In order to complete the preparation of USEC's SAR Update submittals, discrepancies between Application SAR Chapter 3 and actual plant conditions had to be evaluated against the information contained in the SAR Update certificate amendment requests, This task was not originally anticipated as part of USEC's efforts in response to CP issue 2 and contributed to the delay in completing the SAR Update certificate amendment requests.

As described in USEC letters dated August 18,1997 and October 31,1997 (References 2,3, 13, and 14), the facility and process descriptions in Chapter 3 of the PGDP and PORTS Application SARs contain known discrepancies from as-found conditions in the plant. In their August 12,1997 letter (Reference 15), DOE stated that all information used as input to the hazard and accident analysis was independently verified and determined to be representative of the plant. Ilowever,in order for USEC to ensure the completeness and accuracy of the SAR Update submittals to the NRC, allidentified discrepancies in Application SAR Chapter 3 as of i

the submittal date had to be evaluated against the information contained in the SAR Update certificate amendment requests. The efTect of the discrepancies was determined to be minor and necessary changes were made tn the submittals.

The etTort to review the Chapter 3 discrepancies against the SAR Update submittals was not originally anticipated by USEC as part of its activities in response to CP Issue 2.

The discrepancies in Chapter 3 had not been identified by USEC when CP issue 2 was finalized.

- The resources required to complete these evaluations contributed to the delay in completing the USEC SAR Uphte certificate amendment requests.

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Enclosure to 4

GDP 97-0203 Page 6 of16 2.1.2 Corrective Actiong The following corrective actions have been identified for the delay in the completion of the i

USEC SAR Update certificate amendment requests from August 17,1997 to October 31,1997.

1.

Upon recognizing the schedule slippage, USEC assigned additional resources to the project and promptly notified the NRC.

As discussed in Section 2.1.1, USEC's efibns in ri to CP issue 2 were performed in accordance with a detailed project plan and schedule. x..,,dule performance was continuously monitored throughout the project. Upon the first indications that the project schedule was slipping past the August 17,1997 date, additional USEC/LMUS and subcontractor personnel were assigned to the project, in addition the NRC was promptly notified of the potential schedule slip in the NRC/USEC Senior Management Meeting on May 15, 1997 USEC provided ihnher notification of the schedule slip to the 14RC in meetings on June 27,1997, July 22,1997, July 31,1997, and August 14,1997.

2.

When it became clear the schedule could not ac fully achieved, USEC applied for amendments to extend the schedule for an additional 2% months.

On July 18, 1997, when it became clear that the August 17,1997 date could not be fully achieved despite the addition of personnel resources to the project, USEC submitted certificate amendment requests to the NRC (References 16 and 17) to extend the schedule to October 31, 1997. As part of these amendment requests, USEC concluded that the Justification for Continued Operation (JCO) contained in CP issue 2 required no changes and that continued operation was justified during the extended period.

3.

A partial submittal of the SAR Update information was made to the NRC on August 18, 1997.

On August 18,1997, USEC submitted completed portions of the SAR Update f ar NRC review (References 2 and 3). The submittals also included an identification of known limitations or inaccuracies related to the SAR Update and a portion of the information required by items 3.a),

3 b), and 4) of the Plan of Action and Schedule for CP issue 2.

4.

The remaining sections of the USEC SAR Update were submitted to the NRC on October 31,1997, with the exception of Chapter 3.

On October 31,1997, USEC submitted all sections of the SAR Update to the NRC for review (References 13 and 14), with the exception of Chapter 3 (see the discussion for issue 2 that follows), The submittals also included: (a) an identification of known limitations and inaccuracies related to the SAR Update, (b) an identification of physical and operational

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Enclosure to GDP 97-0203 Page 7 of16 modifications that will be required to transition to the SAR Update, and (c) the information required by items 3.a),3.b), and 4) of the Plan of Action and Schedule for CP issue 2.

2.1.3 Conclusions USEC concludes the following regarding the delay in the submittal of the SAR Update certificate amendment requests from August 17,1997 to October 31,1997:

There was no increased potential for exposures, radiation or contamination levels, or releases caused by the aclay in the submittal date from August 17,1997 to October 31, 1997. The JCO for CP issue 2 remained valid during the extended period.

USEC did not demonstrate a willful or careless disregard for completeness or accuracy

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in the August 18,1997 SAR Update submittals. Indeed, the delay in submitting all of the information required by CP issue 2 was due to USEC's hi h regard for ensuring that the E

information prosided would be complete and accurate in all material respects. Only information that was fully complete, confirmed, and approved by August 18,1997 was submitted to the NRC on that date. The remaining portions of the SAR Update were submitted on October 31,1997.

USEC exercised diligence throughout the process to achieve a complete and accurate submittal in the most expeditious schedule possible. Project progress was continuously and closely monitored. Additional resources were assigned in an efTort to offset schedule delays.

USEC kept the NRC informed of the progress of the SAR Update and the potential for delay.

USEC submitted requests to extend the SAR Update submittal date on July 18,1997.

Although it ultimately was not possible for the NRC to complete its review of these extension requests prior to expiration of the August 17,1997 CP completion date, USEC's requests were submitted within a reasonable time prior to that date and were not unduly delayed.

The late submittal of the USEC SAR Update was partially due to circumstances that were not within the control of USEC. The DOE supporting documents were received late. The review ofdiscrepancies identified against Application SAR Chapter 3 was an activity not originally anticipated by USEC as part of CP issue 2. The 6 month schedule established by CP issue 2 proved to be inconsistent with USEC's obligation to ensure the completeness and accuracy of the SAR Update submittals.

t Enclosure to GDP 97-0203 Page 8 of16 2.2 lasue 2: Lack of an Update to Application SAR Chapter 3 2.2.1 Boot.Causen The following root causes have been identified for why USEC's SAR Update submittals to-date do not include an update to Application SAR Chapter 3.

1.

The wording of CP Issue 2 is unclear and non-specific regarding the requirements for updating Application SAR Chapter 3," Facility and Process Description." This lack of clarity and specificity contributed to an inconsistent understanding of the requirements by NRC, DOE, and USEC.

Early in the process of preparing CP issue 2, USEC expressed concern with respect to the clarity and specificity of the Compliance P'an requirement to incorporate the DOE site wide SAR Upgrade into the certification applications. By letters dated October 10,1995 and November 6,1995 (see References 18 and 7), USEC provided comments and suggested revisions to the Revision 1 version of Compliance Plan issue 2 prepared by DOE. These comments and changes centered on USEC's interest in a Aving a clear, unambiguous definition of the commitment to integrate the results of the DOE site-wide SAR Upgrade into the USEC certification applications. Several meetings between NRC, DOE, and USEC were held to discuss USEC's concerns.

By comparing the DOE version of Revision 1 of Compliance Plan issue 2 to the wording in the current Revision 3 versions of the Compliance Plans (References 4 and 5), it is evident that substantial clarification of the requirements related to the new hazards and accident analyses was achieved. However, through this same comparison, it can also be seen that little, if any, clarification was achieved of the requirements for updating Application SAR Chapter 3,

" Facility and Process Description." This lack of clarity has contributed to an inconsistent understanding of the requirements by NRC, DOE, and USEC.

Sections of CP issue 2 that are related to the facility and process descriptions in Application S AR Chapter 3 are i a ntified in Table 1. By reviewing the wording in these CP sections, at least two different interpretations regarding the update of the facility and process descriptions are possible:

(1) The facility and process description chapter of the Application SAR should be updated to: (a) reflect the as-built configuration of the plant, and (b) be consistent with the results of the revised hazards and accident analyses. The update should include safety class, safety significant, and non-safety support systems (see Table 1, items 1 and 3).

(2) The facility and process description chapter of the Application SAR should be updated only to be consistent with the results of the revised hazards and accident analyses. A separate chapter (s) or section(s) should be developed to provide descriptions of safety

o Enclosure to GDP 97-0203 Page 9 of 16 l

class and safety significant SSCs that are consistent with the as built configuration of the plant (see Table 1, items 2,4, 5, and 6),

These two different interpretations as to what updates to Application SAR Chapter 3 are required by CP issue 2 have been the subject of significant discussions between the NRC, DOE, and USEC over the past several months.

By reviewing the DOE site wide SARs, it is apparent that the DOE documents satisfy the second interpretation:

Chapter 2 of the DOE site-wide SAR is entitled," Facility Description." The basis of DOE Chapter 2 was the Revision 3 version of Chapter 3 of the USEC Application SAR.

Conforming changes only were made by DOE in the organization and content of this chapter to ensure consistency with the new accident analysis (primarily terminology issues).

Chapter 4 of the DOE site wide SAR is entitled, " Safety Structures, Systems, and Cornponents." For each safety class and safety significant system, a safety function, functional requirements, summary level system description, system evaluation, justification for classification, and identification of controls is provided. The summary-level system descriptions provide a general identification of system capabilities.

Chapter 5 of tae DOE site wide SAR is entitled, " Derivation of Technical Safety

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Requirements." This chapter includes component level descriptions for SSCs requiring TSRs.

2.

The facility and process descriptions in Application SAR Chapter 3 contain known discrepancies from as found conditions in the plant. These discrepancies also exist in the facility description chapter of the DOE site-wide SAR Upgrade (Chapter 2), Further, DOE has confirmed that potentialinaccuracies exist in their Chapter 2. Consequently, Chapter 2 of the DOE site-wide SAR Upgrade was not used by U3EC to update Application SAR Chapter 3.

As described in USEC letters dated August 18,1997 and October 31,1997 (References 2,3, 13,-and 14), the facility and process descriptions in Chapter 3 of the PGDP and PORTS Application SARs contain known discrepancies from as found conditions in the plant. To-date, approximately 300 discrepancies have been identified for PORTS and approximately 80 for PGDP. USEC has reviewed these as found plant conditions against the facility descriptions in Chapter 2 of the DOE site wide SAR IJpgrade and has concluded that similar discrepancies exist to those identified against Chapter 3 of the Application S AR.

The potential for inaccuracies in Chapter 2 of the DOE document was also confirmed by DOE in their letter dated August 12,1997 (Reference 15).

Consequently, because Chapter 2 of the DOE r

o Enclosure to GDp 97-0203 Page 10 of16

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document contains inaccurate descriptions of plant systems, structures, components, and processes,it could not be used by USEC to update Application SAR Chapter 3.

3.

Compliance Plan Issue 2 recognizes that USEC's submittal to the NRC would be limited by the DOE's submittal to USEC. Because an as built facility description chapter was not provided in the DOE site-wide SAR Upgrade USEC could not include an update to Application SAR Chapter 3," Facility and Process Description," as part ofits SAR Update certificate amendment requests.

Item 1 of the Plan of Action and Schedule for Compliance Plan Issue 2 states, in part, that:

" Areas or topics to be addressed by the DOE site wide Safety Analysis Report are identified below. Because USEC's update to the Application SAR will be based on the DOE site-wide SAR, the treatment (scope, content, level-of-detail) of an area or topic in the update to the Application S AR will be limited to the treatment of that area or topic in the DOE site-wide Safety Analysis Report applicable to USEC facilities and operations."

This statement clearly recognizes that USEC's submittal of the SAR Update to the NRC would be limited by the DOE's submittal of the site wide SAR Upgrade to USEC.

As discussed in root cause #2 above, the facility description chapter in the site-wide SAR Upgrade provided to USEC by DOE on February 14,1997 is not consistent with the as built configuration of the plant. Consequently, USEC could not submit the DOE chapter as part of its SAR Upda,e ;ertificate amendment requests.

4.

There was not enough time for USEC to perform a systematic review, update, and confirmation of Application SAR Chapter 3 prior to August 17, 1997. USEC has committed to a multi-year effort to complete this activity.

As described in letters dated August 18,1997 and October 31,1997 (References 2,3, and 19),

USEC has committed to a substantial effort to perform a systematic review, update, and confirmation of the information containe:1in Application SAR Chapter 3 and to make the necessary changes to the SAR Update analyses and supporting documents. Preparation of the changes to Chapter 3 will be completed by October 31,1999 and the necessary changes to the analyses and suppvrting documents will be completed by October 31, 2000. These dates reflect a best possible schedule for completing this effort considering the numbei and extent of the systems involved and the amount ofinformation that must be reviewed and updated. This schedule is also consistent with the NRC's position regarding reactor licensee FSAR compliance verification programs. It was not possible for USEC to complete an updat.: of Application SAR Chapter 3 la the time available between receipt of the DOE site-wide SAR

O Enclosure to GDP 97 0203 Page1Iof16 Upgrade on February 14,1997 and the required submittal date of the USEC SAR Update on August 17,1997.

2.2.2 Corrective Actions The following corrective actions have been identified for the lack of an t,pdate to Application SAR Chapter 3.

1.

The accuracy of the information contained in the SAR Update certificate amendment requests was confirmed, in their letter dated August 12,1997 (Reference 15), DOE confirmed the potential for inaccuracies in the facility description chapter (Chapter 2) of the site wide SAR Upgrade.

Ilowever, DOE also confirmed that all information used as input to the hazard and accident analysis was independently verified and determined to be representative of the plant.

As part of USEC's efforts, the DOE analyses were reviewed and modified as necessary for plant changes since the DOE cut-off date of September 30,1995 (to include changes up to April 30, 1997--six months prior to the October 31,1997 submittal as required by CP issue 2). In addition, identified discrepancies in Application SAR Chapter 3 were evaluated against the information contained in the SAR Update certificate amendment requests and changes were made as necessary.

Consequently, USEC believes that any future discrepancies in Application SAR Chapter 3 will have little or no effect on the S AR Update information submitted for NRC resiew.

2.

USEC has committed to performing an update of Application SAs Chapter 3.

As described in letters dated August 18,1997 and October 31,1997 (References 2,3, and 19),

USEC has committed to perform a systematic review, update, and confirmation of the information contained in Application SAR Chapter 3, 2.2.3 Conclusions USEC concludes the following regarding the lack of an update to Application SAR Chapter 3:

The lack of clarity and specificity in the wording of CP Issue 2 contributed to an

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inconsistent understanding of the requirements by NRC, DOE, and USEC.

Application SAR Chapter 3 contains known discrepancies from as-found conditions in t

the phnt and needs to be updated.110 wever, an accurate facility description chapter was

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not included in the DOE site-wide SAR Upgrade. Consequently, USEC could not submit

i Enclosure to GDP 97-0203 Page 12 of16 an update to the facility and process descriptions contained in Application SAR Chapter l

3 as part ofits SAR Update certificate amendment roquests.

There was not enough time for USEC to complete an update to Application SAR Chapter 3 prior to submittal of the SAR Update certificate amendment requests.

USEC has committed to complete a systematic review, update, and confirmation of I

Application SAR Chapter 3.

USEC did not demonstrate s willful or careless disregard for completeness or accuracy in the August 18,1997 and October 31,1997 SAR Update submittals. Only information i.

that was fully complete and confirmed accurate was submitted to the NRC. Because the IX)E Chapter 2 was confirmed to be inaccurate, it could not be submitted to the NRC as an update to Application SAR Chapter 3.

The information used as a basis for the new hazard and accident analyses was independently verified to be accurate by DOE. USEC has updated the DOE information for recent plant changes and for the identified discrepancies in Application SAR Chapter 3.

l The lack of an update to Application SAR Chapter 3 was due to circumstances that were not within the control of USEC. The DOE site wide SAR Upgrade did not include an accurate facility description chapter that could be used by USEC as pr : of the SAR Update.

Discrepancies between the Application SAR and as-found conditions in the plant continue to be processed in accordance with plant procedures to ensure continued safe operatior.

until the discrepancy is ultimately resolved.

3,0 RESPONSE TO DOE FACT SHEET Appendix A provides a detailed response to the items identiSed in the DOE fact sheet as transmitted by the NRC's November 26,1997 letter.

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Enclosure to GDP 97-0203 Page 13 of16 Tabla 1 Sections of CP lasue 2 Related to Update of Application SAR Chapter 3' P

CP lasue 2 Item Section Wording i

Requirements "10 CFR 76.35(a)(4),(6), and (8)dThe application for an initial certification of compliance must include the information identified in this section. (a) A safety analysis report which must include the following i

information:...(4) An assessment oraccidents based on the requirements of

( 76.85;...(6) A description of equipment and facilities which will be used by tb Corporation to protect health and minimize danger to life or property (such as handling desices, working areas, shields, measuring and monitoring instruments, devices for the treatment and disposal of radioactive effluent and wastes, storage facilities, provisions for protection against natural phenomena, fire protection systems, criticality accident alarm systems, etc ;.18) A descriotion of the olant site. and a descriotion of the orincioal structures erstems. and comoonents of the plant.'"

2 Commitments "3. Facility and Process Description [Rev. 3, $/31/96]

This chapter provides information on the principle structures, systems, and components of the plant as well as information on the equipment and facilities that are used to protect health and minimize danger to life or propeny to address 10 CFR 76 35(a)(6) and 10 CFR 76.35(a)(8) including...This information is needed to sunoort the assumotions that Mere usqd in determinine the imonets of normal operation. the harard and accider_t analysis. and emercency operations as described in Chanter 4 of the Aeolication recardine the contribution of facility and process desien to initiation of events and the deaicn related assumntions that were used in evaluatine accident consecuenceji,"

3 Description of "The Safety Analysis Repon (SAR) submitted with the Application (the Noncompliance Application S AR) for the initial certification of ompliance is based, in part, on the 1985 Final Safety Analysis Report (1 SAR) and approved safety evaluations performed by the plant since the issuance of the 1985 FSAR...The 1985 FS AR has a number of areas which need to be undated with resocet to the description of hazards, descriotion of clant SSECs

! Structures. Systems. Eauioment. and Components). human activities, and supporting safety analyses, including the following..D) the 'as-exists'.

olant conficuration does not match clant descriptions in the 1985 FS AR;..."

' Emphasis added throughout.

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Enclosure to GDP 97-0203 Page 14 of 16 Table 1 i

Sections of CP issue 2 Related to Update of Application SAR Chapter 3' (Continued)

CP issue 2 Item Section Wording 4

Description of "The Application SAR is based on the 1985 FSAR and needs to be Noncompliance revised, the upgraded DOE SAR contains new information including the development of supporting documentation for scenario identification, source term analysis, and consequence analysis... Additionally. the facility and orocess Acceriotions are reouired to be uodated baceA on the fmal accident annivses resultinc from the IX)E site wide safety analysis unerade effort. as well as other oroeram neerades such as the Conficuration Manacement Procram.."

5 Plan of Action "b) Facility Description and Schedule 1)

The facility and cauioment description will be revised to accuratelv deoict the olant safety class and safety sienif emi slagtures. systems. and comoonents. and related suonort systems as of a soccified date.

2)

The physical and process boundaries between DOE and USEC facilities will be dermed as of a specified date."

6 Plan of Action "d) Safety Structures, Systems, and Components and Schedule 1)

A descriotion of systems. structures. and comoonenig determined to be safety class or safety sienificant will be develooed based on the results of the harard and accident annivsis This willinclude_idCD1ifjcation of the suoport systems. functional reouirements. cerformance criteria necessary to orovide reasonable assurance that the functional tcquirements will be met. and identification of assumotions needine Tecimical Safety Reauirement coveract "

f 8 Emphasis added throughout.

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Enclosure to GDP 97-0203 Page 15 of 16

4.0 REFERENCES

1.

Letter from Carl J. Paperiello (NRC) to hir. William li. Timbers (USEC), "Appt. rent Violations Concerning Paducah and Portsmouth Certificate Amendment Requests, Dated August 18,1997

-- Update of the Application Safety Analysis Report," dated October 27,1997.

2.

Letter from James 11. Miller (USEC) to Dr. Carl J. Paperiello (NRC), " Certificate Amendment Request Update the Application Safety Analysis Report," Paducah Gaseous Diffusion Plant, Letter No. GDP 97 0147, dated August 18,1997.

3.

Letter from James.11. Miller (USEC) to Dr. Carl J. Paperiello (NRC), " Certificate Amendment Request Update the Application Safety Analysis Report," Portsmouth Gaseous Diffusion Plant, Letter No. GDP 97-0148, dated August 18,1997.

4.

Issue 2, " Update the Application Safety Analysis Report," of DOE /ORO 2026, Plan for Achiesing Compliance with NRC Regulations at the Paducah Gaseous Diffusion Plant, Resision 3,7/15/96.

5.

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, Revision 3, 7/15/96.

6.

Letter from Carl J. Paperiello ('NRC) to hir. William 11. Timbers (USEC), " Cancellation of Predecisional Enforcement Conference and Request for Information (TAC Nos L32043, L32044)," dated November 26,1997.

7.

Letter from George P. Rifakes (USEC) to Dr. Carl J. Paperiellc, (NRC), " DOE Compliance Plans and USEC Comments," Paducah Gaseous Diffusion Plant, Portsmouth Gaseous Diffusion Plant, Letter No. GDP 95-0027, dated November 6,1995.

8.

Letter from Joe W. Parks (DOE) to Mr. George P. Rifakes (USEC), " Revised Pians for Achieving Compliance at the Paducah and Portsmouth Gaseous DifTusion Plants," dated February 1,1996.

9.

Letter from Randall M. DeVault (DOE) to Mr. Robert L. Woolley (USEC), " Revised Plan for Achieving Compliance. Issue 2 for Portsmouth and Paducah," dated March 22,1996.

10. Letter from Robert L. Woolley (USEC) to Mr. John W. N. Hickey (NRC), " Revision 2 to issue 2 of the Plans for Achieving Compliance," Paducah Gaseous Diffusion Plani, Portsmouth Gaseous Difrusion Plant, Letter No. GDP 96-0063, dated March 27,1996.

Enclosure to GDP 97-0203 Page 16 of16

11. Letter from Joe W. Parks (DOE) to hir. George P. Rifakes (USEC), "Paducah and Portsmouth Final Safety Analysis Reports," dated February 14,1997, transmitting copies of KY/EM-174,

" Safety Analysir Report, Paducah Gaseous Di&sion Plant, Paducah, Kentucky," Revision R0-A, and POEF-LhiES 89, " Safety Analysis Report, Portsmouth Gaseous Di&sion Plant, Portsmouth, Ohio, Revision R0-A."

12. Letter from Kenneth D. Keith, Jr. (LhfES) to S. D. Routh (USEC), " DOE Contract DE-AC05-840R2100 Gaseous Di&sion Plant Safety Analysis Report, Transmittal of Upgraded Final Safety Analysis Report References," dated hiarch 31,1997.

13. Letter from James. H. Miller (USEC) to Dr. Carl J. Paperiello (NRC), " Certificate Amendment Request - Update the Application Safety Analysis Report," Paducah Gaseous Di&sion Plant, Letter No. GDP 97-0188, dated October 31,1997.

14. Letter from James. H. Miller (USEC) to Dr. Carl J. Paperiello (NRC), " Certificate Amendment Request - Update the Application Safety Analysis Report," Portsmouth Gaseous Di&sion Plant, Letter No. GDP 97-0189, dated October 31,1997.

15. Letter from Joe W. Parks (DOE) to Mr. George P. Rifakes (USEC), " DOE Safety Analysis Reports," dated August 12,1997.

16. Letter from James. H. Miller (USEC) to Dr. Carl J. Paperiello (NRC), " Certificate Amendment Request - Update the Application Safety Analysis Repcrt," Paducah Gaseous Di&sion Plant, Letter No. GDP 97-0121, dated Juiy 18,1997.

17. Letter from James. H. Miller (USEC) to Dr. Carl J. Paperiello (NRC), " Certificate Amendment Request - Update the Application Safety Analysis Report," Portsmouth Gaseous Di&sion Plant, Letter No. GDP 97-0122, dated July 18,1997.

18. Letter from Robert L. Woolley (USEC) to Mr. John W. N. Hickey (USEC), "DO6 SAR Upgrade Commitment," Paducah Gaseous Di&sion Plant, Portsmouth Gaseous Di&sion Plant, Letter No. GDP 95-0023, dated October 10,1995.

19. Letter from James. H. Miller (USEC) to Dr. Carl J. Paperiello (NRC), " Submittal of Plan for Update of Safety Analysis Report (SAR) Chapter 3," Paducah Gaseous Di&sion Plant, Portsmoutt Gaseous Di&sion Plant, Letter No. GDP 97-0187, dated October 31,1997.

a e

Fnc%_we to GDP 97-0203 Appendix A USEC Detailed Response to DOE Fact Sheet DOE Fact Sheet Statement USEC Response f

DOE Fact Sheet No ispse necessary.

United States Enrichment Corporation (USEC) Potential Violation - Failure to Update Paducah and Portsmouth Application With DOE Site-Wide Safety Aonlysis Report (SAR) by Aueust 17.1997

Background:

USEC submitted a letter to U. S Nuclear Regulatory Commission (NRC) on August 18,1997 proposing a substantial delay in the schedule to meet the commitment of Compliance Issue 2, " Update the Application Safety Analysis Report". A three year delay involving a substantial effort was proposed by USEC based on the need to " ensure completeness and accuracy". Subsequently, the NRC issued a letter to USEC notifying them of a preliminary finding of a potential violation for failing to meet USEC's Compliance Plan Commitment on ISSUE 2. A meeting has been scheduled by the NRC for December 1,1997 to discuss the matter before a final determination is made. This NRC has described this meeting as a transcribed " pre-decisional" open enforcement raceting.

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GDP 97-0203 -

Appendix A USEC Detaile 3 Response to DOE Fact Sheet DOE Fact Sheet Statement USEC Re ;m Meeting Topic:

Disagree. Both USEC and DOE originally requested a longer time for -

USEC to prepare the SAR Upd te certifrate amendment requests but USEC in previous managerial status meetings with the NxC has the NRC disagreci Thae was adequate time in the Comphance Plan

'I indicated that the DOE Site-Wide SAR contains discrepancies in schedule for USEC to fully assess, understand, and plan the erfort. It -

systems descriptions which would cause USEC to miss the was based on that ur.derstanding and planning, that allowed USEC to completion date of the Compliance Plan issue 2 commitment to forecast that the August 17,1997 submittal would be delaytd until

" ensure completeness and accuras y". In addition, they have October 31,1997 because of: (1) the late receipt of the DOE indicated the Compliance Plan " Plan of Action and Schedule" did supporting documena; (2) the need to resiew the SAR Update not allow them sufficient time to fully assess and unders:and the sections for the discrepancies identified against Application SAR scope of the efTort.

Chapter 3; and (3) the additional time requred to prepare the TSRs, Q and AQ bounday definiticms, and complete necessary resiews.

Fatts:

Agree. However, this DOE fact is no* related to the late submittal of the USEC SAR l'pdn or the lack of an update to the facility and I.

USEC has been the lessee / operator of the Gaseous Diffusion process descriptions in Applicadon SAR Chapter 3.

Plants (GDPs) since July 1,1993. As such, the corporation has been in control of the activities at the Portsmouth and Paducah GDI's.

Page 2 of i1

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s Enclosure to GDP 97-0203 Appendix A USEC Detailed Respor :to DOE Fact Sheet

' DOE Fact Sheet Statement USEC Response l

2.

USEC was committed to perfonn reviews of Facility and Sentence 1: Disagree. Item 2 of the Pland of Action and Schedule System descriptions during the DOE Site-Wide SAR Update for Compliance Plan issue 2 states:

by revision 2 of the Compliance Plan approved and submitted to the NRC in early 1996. Thus, USEC was "2.

USEC will provide information required to responsible for ensuring the technical accuracy and validity complete the DOE site-wide Safety Analysis of the Facility and System descriptions. The Compliance Report and will proside technical resiews of Plan, issue 2, also committed USEC by August 17,1997 to the ongoing analyses to ensure that the compare the new information, findings and analyses accurately reflect the facility recommendations contained in the DOE site-wide SAR to configuration."

the application SAR and 1) identify the differences,2) evalua:e the effects of those difTerences on safety, and 3)

Based on the above wording, Compliance Plan issue 2 did not commit propose modifications.

USEC to perform resiews of Chapter 2," Facility Description "

included in the DOE site-wide SAR Upgrade. USEC did review facility and system description information used to prepare the hazard and accident analyses desenbed in Chapter 3 of the DOE docurlent.

Sentence 2: Disagree. USEC is responsible for ensuring the technical accuracy ofits submittals to the NRC on the SAR Update.

DOE is responsible for ensuring the technical accuracy of the DOE site-wide SAR Upgrade.

Sentence 3: Agree. This information was pr:nided to the NRC in USEC's S AR Update submittals dated August 18,1997 and October 31,1997. However, this DOE fact is not related to the late submittal of the USEC SAR Update or the lack of an update to the facility and process descriptions in Application SAR Chapter 3.

Page 3 of 11

s Enclosure to

_GDP 97-0203,

Appendir A USEC Detailed Response to DOE Fact Sheet DOE Fact Sheet Statement USEC Response 3.

USEC and/or its primary contractor, Lockheed Martin Agree.

Utilities Services (LMUS), were informed of and involved in determining the CoFtent and methodology utilized by the DOE and its contractor personnel to develop the site-wide SARs.

Safety Analysis Report Upgrade (SARUPyDOE personnel a.

made presentations to USEC throughout 1993,1994,and 1995 to discuss program intent and approach b.

A presentation was made in summe f 1995 to NRC by Sentences 1,2, and 4: Agree. However, based on References I and l

USEC and SAR Upgrade Program personnel identifying the 6, it is apparent that the NRC did not specifically acknowledge that the SARUP plan to revise plant / system d-scriptions of safety DOE site-wide SAR Upgrade would not include a systematic review, i

i class and safety significant systems only. Non-safety system update, and confirmation of the facility and process description descriptions would be obtained from the application write-chapter (including safety class, safety significant, and non-safety up. The Gaseous Diffusion Plants (GDPs) configuration of SSCs).

record would be September 30,1995. This was acknowledged and int.luded in the Compliance Plan which Sentence 3: Agree.

states,"The facility and equipment description will be revised to accurately depict the plant safety class and safety significant structures, systems and components and related support systems as of a specified date."

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s NL=re to

GDP 97-0203 Appendix A USEC Detailed Response to DOE Fact Sheet DOE Fact Sheet Statement USEC Response c.

Facility and System description drafts were transmitted to Agree. IIowever, the facility and system desenpuon drafts discussed the plants from.fune 1993 to May 1994 for review.

in this DOE fact were:

Minimal review was received from the plants. Paducah Gaseous DifTusion Plant (PGDP) informed the DOE SAR.

(1)

Included as part of USEC's Revision 0 of the Certification Upgrade project that PGDP.would perform any needed Applications. Revision 0 was rejected by the NRC.

modifications to the Facility and System description. By May 1994, a complete drafl of Portsmouth Gaseous -

(2)

Not included by DOE in the February 1997 site-wide SAR DifTusion Plant (PORTS) Facility and System desciiption for Upgrade documents.

cupport of the USEC Application was provided. The same information for PGDP was placed on hold awaiting USEC modifications. A limited review of the PORTS descriptions was provided by the plants. Reviews and revisions of PORTS descriptions (in various phases) was placed on hold due to a USEC issue on regarding responsibility for control of the SAR project (i.e. DOE or USEC control).

Page 5 of11

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hetamre to GDP 97-0203 -

Appendix A USEC Detailed Response to DOE Fact Sheet '

DOE Fact Sheet Statement USEC Resm:e d.

An enormous number of draft documents covering Sentence h Agree. The draf1 documents were provided by DOE for -

i descriptions, Hazards analysis, Plant Safety Operational plant resiew and the documents were subsequently resiewed by PGDP.

Analysis (PSOA), accident scenarios, source terms, and PORTS.

consequence analysis, safety related structures, systems and components, potential technical safety requirements, and Sentences 2 and 3: Disagree. Resiew prioritics for the DOE work programmatic descriptions were sent to the plants primarily products were assigned consistent with ove..dl plant priorities During through hard v and E-mail for review, accuracy checks, the summer of 1995, primary priorities were placed on re-submitting i

and general co.a.. ent beginning in summer 1995. Review the certification applications and respondmg to NRC questions.

of these products varied from keen interest to non-responsive. Review interest was a function of the direct However, this DOE fact is not related to the late submittal of the bearing on plant operations.

USEC SAR Update or the lack of an update to the facility and process descriptions in Application SAR Chapter 3.

Examples of DOE cfforts to obtain USEC review and Agree. However, this DOE fact is not related to the late submittal of agreement on the SAR upgrade are given below-the USEC SAR Update or the lack of an update to the facility and process descriptions in Application SAR Chapter 3. The PSOA Meetings were held with PGDP and PORTS plant methodology approach is not part of tie facility and process personnel and USEC representatives in late 1994 and description.

carly 1995 to agree on PSOA methodology approach.

System analysis fault trees supporting PSOAS were Agree. However, this DOE fact is not related to the late submittal of sent to the plant in May 1995 and updated fault the USEC SAR Update or the lack of an update to the facility and trees to match the 9/30/95 plant configuration were process descriptions in Application SAR Chpter 3. The systun submitted for review in September 1996.

analysis fault trees are not part of the facility and process description.

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Enclosure to GDP 97-0203 Appendix A USEC Detailed Response to DOE Fact Sheet l

DOE Fact Sheet Statement USEC Response He first PSOA drafts which included system Agree. 11owever, this DGE fact is not related to the late submittal of description information were provided for plant the USEC SAR Update or the lack of an update to the facility and review in January of 1996. He majority of the process descriptions in Application SAR Chapter 3. He PSOA PSOAS were iss. red for review between January and documents are not part of the fa:ility and process description. The May of 1996. A meeting was held in mid-July of system description informatien in the PSOAS was reviewed by USEC. 1996 at PORTS to obtain and discuss comments on the PSOAS provided by that date_

The DOE SAR upgrade project sent PGDP the final Agree. Ilowever, this DOE fact is not related to the late submittal of drail of the Plant flazard Screening document in the USEC SAR Update or the lack of an update to the facility and September 1995 requesting a review and sign off or process descriptions in Application SAR Chapter 3. He plant hazard modification.

screemng documents are not p rt of the facility and process description.

Process hazard analysis for PORTS facility X-344a Agree. However, this DOE fact is not related to the late submittal of was sent for review on November 8, '995 and a the USEC SAR Update or the lack of an update to the facility and review meeting was requested. Other hazard process descriptions in Application SAR Chapter 3. De process analysis were provided at a rapid pace.

hazards analyses are not part of the facility and process description.

A meeting was requested by e-mail to PGDP and Agree. Ilowever, this DOE fact is not related to the late submittal of PORTS to determine and agree on the configuration the USEC SAR Update or the lack of an update to the facility and and assumptions for accident source terms. De process desenptions in Application SAR Chapter 3. Accident source meeting occurred at PGDP on December 13, 1995.

terms are not part of the facility and process description.

Meeting notes capturing assumpt:ons were distributed for confirmation on December 20,1995.

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Enclosure to GDP 97-0203 Appendix A USEC Detaited Response to DOE Fact Sheet DOE Fact Sheet Statement USEC Response A review of PGDP radiological process hazards Agree, liowever, this DOE fact is not related to the late submittal of analyses was requested on January 31,1996. A the USEC SAR Update or the lack of an update to the facility and request for information on chemical hazards was process descriptions in Application SAR Chapter 3. Process hazards repeated on February 9,1996.

analyses are not part of the facility and process description.

Facility description information as written in Agree The drafl of DOE Chapter 2 was similar in content to Chapter Chapter 2 of the SAR was sent to PGDP for review 3 of the USEC Application SA R.

in February 1996. The response from PGDP (USEC) on March 5,1996 was for DOE to make the descriptions consistent with the NRC Application SAR. Agreement was reached with PORTS (3/1/96) to limit the DCE SAR non-safety details which could impact the USEC Application SAR.

On July 8,1996, PGDP was provided for review Agree. Ilowever, this DOE fact is not related to the late submittal of copies of PSOA for cascade and balance of plant for the USEC SAR Update or the lack of an update to the facility and revi. v. Recommended review meeting was set up.

process descriptions in Application SAR Chapter 3. The PSOA documents are not part of the facihty and process description.

Page 8 of 11

~.

Enclosure to GDP 97-0203 Appendix A USEC Detailed Response to DOE Fact Sheet DOE Fact Shat Statement USEC Response On July 11,1996, SARUP e-mail to PORTS Agree.

discussed notification by PGDP that USEC had given specific instructions to the plants p.ot to 1.

Descriptions of USEC programs and plans (included in o

review any of the programmatic chapters of the draft Application SAR Chapters 5 and 6 and Volume 3) were SAR. 'lhe importance of reviewing some of these reviewed aM approved by the NRC as part ofinitial chapters was stressed. The NCS chapter was certification. The programmatic chapters included in the DOE particularly stressed.

site-wide SAR Upgrade are not identical to the USEC programs and plans approved by the NRC. Therefore, the On August 8,1996, PGDP e-mail reiterated specific DOE programmatic chapters were not further reviewed and USEC instructions. Stressed Programmatic Chapters have not been included as part of USEC's SAR Update should be NRC application Rev. 3 verbatim.

submittals.

2.

A new Appendix A on NCS controls was included in USEC's SAR Update submittal.

However, this DOE fact is net related to the late submittal of the USEC SAR Update or the lack of an update to the facility and process descriptions in Application SAR Chapter 3.

Several meetings were held to discuss specific Agree. Ilowever, this DOE fact is not related to the late submittal of subjects with plant personnel and USEC the USEC SAR Update or the lack of an update to the facility and representatives. Examples include:

process descriptions in Application SAR Chapter 3. Dispersion modeling and consequence and source term analysis are not part of the.

i

- Dispersion modeling, May 1996 facility and process description.

- Consequence & source term analysis, July 1996 i

Page 9 of 11 r

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Enclosure to GDP 97-0203 Appendix A USEC Datailed Response to DOE Fact Sheet DOE Fact Sheet Statement USEC Response All SAR chapters were provided to the plants for Agree. Ilowever, these chapters did not include an updated facility review beginning in February 1996 and continuing and process description chapter that would resolve the as-found through draft issuance of SAR for DOE review in discrepancies that have been identified against Application SAR September 1996.

Ch.pter 3.

4.

DOE transmitted drafts for approval copies of the SARs Agree. Ilowever, these draft SARs did not include an updated facility September 30,1996 to USEC and the plants.

and process description chapter that would ruolve the as-found discrepancies that have been identified against Application SAR Chapter 3.

5.

DOE transmitted approved site-wide SARs for the Agree. Ilowever, these documents do not include an updated facility Portsmouth and Paducah GDPs and the accompanying and process description chapter that would resolve the as-found Safety Evaluation Reports (SERs) to USEC on February 14, discrepancies that have been identified against Application SAR 1997.

Chapter 3.

6.

USEC n'et with NRC in August,1997 concerning USEC's Disagree. Inits August 14,1997 meeting with NRC, USEC stated lack of compliance with the August 17,1997, commitment that:

date. In this meMing USEC stated that there were only several minor discrepancies in the SAR analysis and 1.

There were sev::ral knosm limitations or inaccuracies i

descriptions of safety class and safety related systems.

associated with the DOE analyses to be included in SAR Therefore, safety related items from the DOE SAR that Update Chapter 4,"IIazards and Accident Analysis."

required resolution by USEC would take at most a few weeks. His schedule is significantly different to the three 2.

An approximately 1810 24 month effort would be needed to years for resolution that USEC is currently 1,roposing. As complete a sptematic rewrite, update, and confirmation of such, only non-safety related inconsistencies are the issue.

Application SAR Chapter 3 and an additional 9 to 12 months may be required to make any necessary changes to Chapter 4 and the supporting documents.

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. Enria==re to GDP 9*-0203 -

Appendia A USEL Detailed Response to DOE Fact Sheet

~

DOE Fact Sheet Statessent USECR e

==

Conclusion:==

Agree. Ilowever, the DOE information does not include an updated facility and process desenption chapter that would resolve the -

As evidenced by the many exchanges of information between.

discrepancies that sve been identified agamst Application SAR DOE /USEC/NRC during the development process of the DOE site-Chapter 3.' In addition, necessary supportug documentation was not wide SAR, DOE made a conscientious and consistent effort to fully provided to USEC until April 1997.

ensure that the technical information was available to USEC for '

their review.

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