ML20198K726
| ML20198K726 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 12/11/1998 |
| From: | Toelle S UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Devault R ENERGY, DEPT. OF |
| References | |
| DOE-98-0041, DOE-98-41, NUDOCS 9812310139 | |
| Download: ML20198K726 (6) | |
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l December 11,1998 DOE 98-0041 i
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Mr. Randall M. DeVault J
Regulatory Oversight Manager i
Oak Ridge Operations U.S. Departmem of Energy Oak Ridge, Tennessee 37831-8651 Paducah Gaseous Diffusion Plant (PGDP)
Docket No. 70-7001 -
Compliance Plan Issue 36 - Seismic Capability of Buildings C-331 and C-335
Dear Mr. DeVault:
Enclosed' for your review and approval is a proposed revision to Compliance Plan Issue 36. This request is related to modificctions to upgrade the seismic capability of Buildings C-331 and C-335 as described in Issue 36 of DOE /OR-2026, Plan for Achieving Compliance with NRC Regulations r,t the Paducah Gaseous Diffusion Plant (Compliance Plan).
Compliance Plan Issue 36 requires modiEcations to increase the seismic capability for floor and roof sections in Buildings C-331 and C-335 to be completed by June 30,1999. This submittal proposes to change the Compliance Plan scheduled date for this issue to June 30,2000. Experience to date has shown that construction activities in the buildings are substantially more difficult than originally anticipated. In numerous locations, a significantly greater than expected effort has been required to remove and relocate interferences, remove existing steel, and install new steel. These unanticipated difficulties, coupled with the reduced worker productivity experienced in the high heat conditions of the process buildings, are projected to more than double the original estimated cost of the project with a resultant delay of 12 months in the overall construction schedule.
In accordance with the NRC letter from Robert Pierson to Steven Toelle of USEC dated October 23, 1997, DOE approval of Compliance Plan changes is required prior to submi+tal to NRC. Therefore, the subject Compliance Plan changes are provided in this submittal for DOE review itnd approval.
Once DOE approval is obtained, the changes will be submitted to NRC. to this letter provides a' detailed description and justification fm the proposed change.
The proposed r_evision to Compliance Plan Issue 36 is provided in Enclosare 2. In order to support I
the schedule for submittal of the Certificate Amendment Request (CAR) to NRC and obtain their 9912310139 981211 i
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C PDR 6903 Rockledge Drive, Bethesda, MD 20817-1818 Telephone 301-564-3200 Fax 301-564-3201 http://www.usec.com
,1 i Q' Offices in Livermore, CA Paducah KY Portsmouth, OH Washington, DC gg y 4 m
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- Mr. Randall M. DeVault December {l1,1998 DOE 98-0041, Page 2 approval of the CAR, USEC requests DOE review and approval of the Compliance Plan change by -
i January 8,1999.
i Any questions related to this submittal should be directed to Steve Routh at (301) 564-3251. There are no new commitments contained in this submittal.
Sincerely,-
S.D. Aih-Cr Steven A.Toelle Nuclear Regulatory Assurance and Policy Manager
Enclosures:
- 1. United States Enrichment Corporation (USEC), Certificate Amendment Request, Buildings C-331 and C-335 Seismic Upgrades, Detailed Description of Change
- 2. Certificate Amendment Request, Paducah Gaseous Diffusion Plant, Letter DOE 98-0041, Removal / Insertion Instmetions cc:
Mr. Robert C. Pierson (NRC) vNRC Region III Office NRC Resident Inspector - PORTS NRC Resident Inspector - PODP l
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DOE 98-0041 Page l 'of 2 United States Enrichment Corporation (USEC)
Certificate Amendment Request j
Buildings C-331 and C-335 Seismic Upgrades
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. Detailed Description of Change
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i Descriotion of Change The Plan of action and Schedule for Compliance Plan Issue 36 states :
. Modifications to increase the seismic capability for floor and roof sections in Buildings C-331 and C-335 will be completed by June 30,1999.
.l This Certificate Amendment Request proposes that the Plan of Action and Schedule for Compliance Plan Issue 36 be revised as follows:
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Modif: cations to increase the seismic capability for floor and roof sections ~in j
Buildings C-331 and C-335 will be completed by June 30,2000.
Justification for the Change.
As required by Compliance Plan Issue 36, modifications to upgrade the seismic capability of Buildings C-331 and C-335 are in progress. However, the construction activities to complete the seismic upgrades are proceeding slower than originally anticipated. Constmetion experience to date has revealed several unanticipated problems that have caused delays in constmetion:
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Removal and subsequent installation of replacement steel in an individual bay cannot be accomplished in two shifts as originally estimated. High ambient temperatures at j
the work sites severely curtail the amount of time that heavy labor can be performed.
Laborers spend a good percentage of each shift simply cooling down.
Demolition of existing bracing and gusset plates is taking more time than initially projected. Great care mur 3 taken to ensure the remaining structures, systems and
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components (SSC) are nd W by construction activities. Erection of protective l
structures, guards, drop nets, sic. in congested quarters is taking more time than initially projected.
As performance of the work progresses, more interferences have been discovered than
. were accounted for in the initial design, requiring increasci engineering, drafting, planning, scheduling, procuring, and construction time.
Additionally, plant w
DOE 98-0041 Page 2'of 2 maintenance personnel were originally identified as the work force which would move SSCs interfering with installation of the additional steel. "In plant" relocation resources are insufficient to support the expanded work load.
In order to recover some of the original installation schedule, two commitments regarding the construction sequence for performing these upgrades were revised to provide greater flexibility in managing the available construction resources (Reference 1).
In addition, other process improvements have been implemented which are reducing the amount of time required to complete work at each construction location. However, these improvements will not reduce task completion times to meet the initial estimates, and the delays experienced to date cannot be fully recovered.
Therefore, an extension of the June 30,1999 scheduled completion date is being requested.
References 1.
Letter from Steven A. Toelle (USEC) to Dr. Carl J. Paperiello (NRC), " Notification of Changes in Regulatory Conunitments - Compliance Plan Issue 36 - Seismic Upgrades to Buildings C-331 and C-335," Letter No. GDP 98-0198, November 25,1998.
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1 DQE 98-0041 2 Pages Total Certificate Amendment Request Paducah Gaseous DifTusion Plant Letter DOE 98-0041 Removal / Insertion Instructions Remove Pages Insert Pages PLAN FOR ACIIIEVING COMPLIANCE WITII NRC REGULATION AT TIIE PADUCAII GASEOUS DIFFUSION PLANT (DOE /ORO-2026)
Issue 36, Seismic Capability of Huildings Issue 36, Seismic Capability of Buildings C-331 and C-335 C-331 and C-335 Pages 5/6 Pages 5/6 l
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