ML20198A928
| ML20198A928 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 12/17/1997 |
| 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-97-0212, GDP-97-212, NUDOCS 9801060136 | |
| Download: ML20198A928 (8) | |
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USEC A Global Energy Company JAMES H. MILLER Dir; (301) 564-3309 -
, VICE PRESIDENT, PRODUCTION Far (301) 5718279 December 17,1997 Dr. Carl J.- Paperiello SERIAL: GDP 97-0212 Director, Office of Nuclear Material Safety and Safeguards Attention: Document Control Desk U.S. Nuclear Regulatory Commissiori Washington, D.C. 20555-0001 Portsmouth Gaseous Diffusion Plants (PORTS)
Docket No. 70-7002 Request for Enforcement Discretion Regarding the, Certificate Amendment Request (CAR) for Compliance Plan issue 24
Dear Dr. Paperiello:
'In accordance with 10 CFR 76.45, the United States Enrichment Corporation (USEC or Corporation) submitted a request for amendment to the certificate of compliance for the Portsmouth, Ohio Gaseous Diffusion Plant (PORTS) by letter GDP 97-0180, dated October 21,1997. This CAR revises the Plan for Achieving Compliance with NRC Regulations at the Portsmouth Gaseous Diffusion Plant (Complianc ! lan), Issue 24, to remove the implication that measuring and test equipment (M&TE) are categorized as Q, AQ, and AQ-NCS, It also corrects an inconsistency within Compliance Plan issue 24 regarding the completion date for revising the calibration program procedures and training to meet more formal requirements for AQ SSCs by revising the subject
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completion date to June 30,1998 to match dates for the same actions given elsewhere in Issue 24.
Since this CAR is associated with a Compliance Plan action that is currently scheduled to be complete by December 31,1997,.USEC requested NRC review and approval of the CAR ty December 31,1997_ with the amendment becoming effective immediately upon approva USEC is aware that NRCjust recently received the results of the required Department of Energy (DOE) review of this CAR, and the NRC is beginning its review of the CAR. It now appears that there will not be enough he for NRC to complete review and approval of the CAR by December 31,1997, 9901060136 971217 6903 Rockledge Drive,11ethesda, MD 20817 '818 Telephone 301-564-3200 Fu 301-5643201 http://www.usec.com OtTices in Livermore, CA ~ Paducah, KY Portsmouth. 01-1 Washington, DC
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4 Dr. Carl J; Paperiello 1 s
" December 17,1997 :
10DP 97-0212 Page 2 l Therefore, USEC is requesting NRC enfbrcement discretion for the completion dates in PORTS :
Coh.pliance Plan issue 24:that are addressed.in the subject CAR.- The justification for this enforcement discretion request is contained in Enclosure 1. USEC letter GDP 97-0180 included the
- basis for USEC's determination that the proposed change associated with the subject CAR is not significant. This information is also provided here in Enclosure 2.
No new commitments are made in this submittal. Any questions related to this subject should be directed to Mr. Mark Lombard at (301) 564 3245.
Sincerely,
. /,
4 les 11. Miller ice President, Production
Enclosures:
As stated -
CC' NRC Region ill Office NRC Resident inspector-PGDP NRC Resident inspector 4 PORTS DOE Regulatory Oversight Manager
I!nclosure1 GDP 97-0212 Page 1 of 3 JUSTIFICATION FOR FNFORCEMENT DISCRETION
- 1. Re TSR that will be violated, No TSRs will be violatc<l.
- 2. :lhe circumstances surrounding the situation. includingtoot causes. the need for promnt action andJdenti11 cation orany relevant historical events.
UT,1?C submitted a certificate amendment request (CAR) for the Portsmouth, Ohio Gaseous Diffusion Plant (PORTS) by letter GDp 97 0180, dated October 21,1997. This CAR revises the Plan for Achieving Compliance with NRC Regulations at ths Portsmouth Gaseous DifTusion Plan, (Compliance Plan), Issue 24, to remove the implication that measuring and test equipment (M&Tli) are categorized as Q, AQ, and AQ NCS. It also corrects an inconsistency within Compliance Plan issue 24 regarding the completion date for revising the calibration program procedures and training to meet more Ibrmal requirements fbr AQ SSCs by revising the subject completion date to June 30,1998 to match dates fbr the same actions given elsewhere in issue 24.
Since this CAR is associated with a Compliance Plan action that is cunently scheduled to be complete by December 31,1997, USIIC requested NRC review and approval of the CAR by December 31,1997 with the amendment becoming effective immediately upon approval by NRC. USlic is aware that NRC just recently received the results of the requF ' Department of linergy (Doli) review of this CAR, and the NRC is beginning its review on..e CAR. It now appears that there will not be enough time fbr NRC to complete review and approval of the CAR by December 31,1997.
There is a need Ibr prompt action since the Lumpliance Plan issue 24 currently designates December 31,1997 as the completion date ihr the related actions. While other section; of this same Compliance plan issue designate June 30,1998 as the completion date,if this action is not completed by December 31,1997 it could be interpreted as a noncompliance. USEC had recognized this fact and that is uhat prompted the submittal of the CAR on October 21,1997.
There are no other relevant historical events.
linclosure i GDP 07-0212 Page 2 of 3
- 3. The safety basis for the rrguest. including an evaluation of the safety significance and notential consequences of the oronosed course of action. including any cualitative risk assnsment.
Continued operation of the maintenance program without approval of the proposed CAR is already addressed by the Justification for Continued Operation for Compliance Plan issue 24, therefore, there is no safety significance or potential consequences to the granting ofenforcement discretion. The JC0 is based on the June 30,1998 completion date for the subject actions, as described in other sections ofissue 24. There is no increase in risk associated with this request.
- 4. Ibe basis for thesertincate holder's conclusion that the noncomplimpe will not be of notential detriment to the oublic health and safety and that neither an USO nor a determination of signincance is involved.
These is no increase in the dose or exposure to plant personnel or members of the off site public as a result of this request. There is no increase in exposure to hazardous or toxic chemicals.
'lhere is no increase in radiological or chemical releases. There are no new or unusual sources of hazardous substances, waste, or any mixed waste that could be generated. There are also no new or unusual tources of radioact.ve waste that could exceed specified limits. Finally, there is no significant decrease in the effectiveness of the limergency Plan. USl!C has reviewed the potential for an unreviewed safety question nd has concluded that one does not exist.
It is important to note that this condition is temporary and nonrecurring, and will only exist until the NRC appmves and issues the associated Compliance Plan revision.
As part of the CAR submitted to the NRC by USI!C letter GDP 97-0180, USliC has arformed a Significance Determination which is also provided in IInclosure 2.
- 5. The basis of the conclaion that the noncomnllance will not involve adverse conscauences to the environment.
h%intenance activities will continue in accordance with the Certification Application and the Compliance Plan, Issue 24 JCO No new consequences will be introduced during this period.
There are no new wastes releases to be introduced as a result of this request.
- 6. Any orooosed comoensatory measures.
There is no need for compensatory actions other than as described in the JC0 for Compliance Plan issue 24.
GDP 97 0212 Page 3 of 3
- 7. lhe lustification for the duration of nancompliance.
The duration of the noncompliance will last until the CAR is approved by the NRC. No new or additional risk is being introduced by this period of noncompliance. The consequences of any current, approved accident will not be increased or changed since no physical change has or will be made.
8 blatement that the regucst has begn.ppproved by the Plant Onerations Review Committec (PORCL The infbnnation used in this request ihr Enforcement Discretion was reviewed and recommended for approval by our plant's PORC on December 16,1997.
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- 9. Ihc_Ig4Uest must address how the criteria for rrguesting enforcement discretion is met.
This request ihr enfbreement discretion is intended to avoid undesirable enforcement action as a result of verbatim compliance with the inconsistent Compliance Plan issue 24 completion date requirements. Without the enforcement discretion, it may be interpreted that the completion date fbr revisi o, the calibration program procedures and training to meet more fonnal requirements ihr AQ f
' % December 31,1997,instead of June 30,1998 as described elsewhere in issue 24.
- 10. Marked un TSR oages showing the nronosed TSR changes should be attached.
No TSR changes are associated with this request.
I1. Statement that prior adoption of approved line item imnrovements to the Tech Specs would have obviated the need for enforcement discretion.
Not applicable.
- 12. Any other information the NRC staff deems necessary before making a decision to exercise enforcement discretion.
No othei infbnnation has been requested by the Staff at this time.
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GDP 97-0212 Page 1 of 3 United States Enrichment Corporation (USEC) i Proposed Certificate Amendment Request Calibration Program for Measuring and Test Equipment Significance Determination The United States Enrichr.icnt Corporation (USEC) has reviewed the proposed changes associated with the certificate amendment request (CAR) submitted to the NRC by USEC letter GDP 97 0180, and provides the following Significance Determination for consideration.
- 1. No Overall Dmene in the Effectiveness of the Plant's Safety. Safeguards. or Security Programs.
The proposed changes will delete the implication that measuri.,g and test equipment (hi&TE) are categorized by Q, AQ, and AQ-NCS. Those hi&TE which are used on Q, AQ, and AQ NCS equipment are qualified for use on equipment of the highest quality level (i.e., Q) and may be used on any of the three categories of safety related equipment (Q, AQ, and AQ NCS). It also corrects an inconristency within issue 24 regarding the date for revising the calibration program to mett more fbrmal requirements fbr AQ SSCs by revising the subject completion date to June 30,1998, and to indicate that detailed calibration piacedures are Oveloped to control hi&TE as well as the Q. AQ NCS, and other AQ SSCs. The revised completion date matches dates given
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elsewhere in issue 24 lbr upgrading the work control process and preventive maintenance program fbr other AQ items, and also matches the Paducah Gaseous DifTusion Plant commitment dates fbr similar work. None of the proposed changes affect the associated Justification for Continued Operation, which will be in effect until the actions are complete. Therefcre, the proposed changes do not represent an overall decrease in the elTectiveness of the plant's safety, safeguards, or security programs.
2 No Significant Change to Any Conditions to the Certificate of Comnliance.
No aspect of the Certificate of Compliance (COC) is affected by these changes. Therefbre, no significant change to any conditions to the COC will result.
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- 3. No Significant Change to Any Condition of the Approved Comnliance Plan.
The proposed changes do involve changes to the approved Complian.c Plan, but as discussed in item 1 above they are required for consistency in completion dates; to clarify that hi&TE are not classified as Q, AQ NCS, or AQ; and to indicate that dctailed calibration procedures will be developed to control hi&TE as well as the SSCs. None of the proposed changes affect the associated Justification for Continued Operation, which will be in effect until the actions are complete. Therefore, the proposed changes are not significant with respect to safety or to meeting the Compliance Plan schedules previously established, end do not represent a significant change to any condition of the approved Compliance Plan.
i GDp 97-0212 page 2 0f 3
- 4. No Significant increase in the Probability of Occurrence of Conscauences of Previousiv Evaluated Accidents The proposed changes are required for consistency in completion dates; to clarify that hi&TE are not classified as Q. AQ NCS, or AQ; and to indicate that detailed calibration procedures will be developed to control hi&TE as well as the SSCs. None of the proposed changes affect the associated Justification Ibr Continued Operation, nor do they have any affect on the probability of occurrence of accidents previously evaluated. Therefore, the proposed changes do not represent any increme in the probability of occurrence of consequences of previously evaluated accidents.
S. No New or Different Kind of Accident These changes do not introduce any new or difTerent equipment or processes, nor do they involve a modification to existing equipment or operations. Therefbre, they will not result in the pas 3ibility of a new or dif ferent kind of accident.
- 6. No Significant Iteduction in hlargins of Safety.
As described in item 4 above, the probability and consequences of an accident are not affected.
The factors which comprise the safety margin, the administrative controls and engineered safeguards, are not affected by these changes. None of the proposed changes affect the associated justification Ihr Continued Operation, which will be in efTect until the actions are complete. Tincrefore, the proposed changes do not represent a reduction in any margin of safety.
- 7. No SignWicant Deercase in the liffectiveness of Any Program or Plan Contained in the Cenification Application.
The proposed changes have no affect on the programs or plans contained in the Certification Applicaticn. Therefore, no decrease in the effectiveness of any of the programs or plans contained in the Certification Application will result.
- 8. The Prooosed Changes do not Resuh in Undue Risk To 1) Public ilcalth and Safety. 2) Common Defruse and Security. and 31 the I!nvironment All hi&T E used on SSCs will be qualified for use on equipment of the highest quality level (i.e.,
Q). The proposed changes do not increase the consequence or probability of an accident and, therelbre, do act present an undue risk to the public. The proposed changes do not affect any common defense or security opcrations, therefore, no undue risk to common defense and security is presented. No undue risk to the environment is presented by the proposed changes because they do not alTect accident scenarios or operations that could affect the environment. No
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GDp 97-0212 Page 3 of 3 additional environmental risk is presented because the changes have no impact on plant efiluents or postulated accidents which might afTect the environment. Therefore, the proposed changes do not result in undue risk to the public health and safety, common defense and security, or the environment.
- 9. No Change in the Tynes or Significant Increase in the Amounts of Any Efiluents That May lle lleleased Offsite.
l Since M&TE which are used on safety releted equipment are always maintained for use on quipment of the highest quality level (i.e., Q), no affect on postulated plant accidents would wsult from the proposed changes. The proposed changes do not involve any process which would change or increase ellluents that may be released by the plant. Therefore, there is no change in the types or any increase in the amounts of any ellluents that may be released offsite.
- 10. No Significant increase in Individual or Cumulative Occupational Itadiation Exoosure.
The proposed changes de not modify any process or equipment which would alTect radiation exposure to any individual unsite. Therefbre, no increase in individual or cumulative occupational radiation exposure would occur.
11, No SignificanLCenstruction impac1 These changes do not involve construction of any plant structure or system, nor will they affect any planned or existing construction project. Therefore, there is no construction impact.
- 12. No Significant increase ittihe Potential for. or Itadipjpgical or Chemical Conseguences from.
l'reviousiv Analyzed Accjdents.
The proposed changes do not involve any new or modified operation which wonld increase the potential for an accident or any associated consequences. Therefore, these changes will not increase the potential (br, or radiological or chemical consequences from, previously analyzed accidents.
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