ML20199C557

Forwards RAI Re Updates to Certification Application Documents Submitted by Ltrs 970415 & 0825.Addl Info Needed to Support Licensee Conclusion That Changes Did Not Require Prior NRC Approval.Info Should Be Provided within 30 Days

ML20199C557
Person / Time
Site:	07007001
Issue date:	11/07/1997
From:	Horn M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	John Miller UNITED STATES ENRICHMENT CORP. (USEC)
References
NUDOCS 9711200056
Download: ML20199C557 (3)

Text

-. -- .. - . - -- - . - _ - .

t

, November 7. 1997 .

Mr. Jam as H. Miller i

- Vice President, Production U. S. Enrichment Corporation 2 Democracy Center 6903 Rockledge Drive Bethesda, MD 20817

SUBJECT:

PADUCAH UPDATES TO CERTIFICATION APPLICATION Dear Mr. Miller.

This refers to your updates to the cutification application documents that have been submitted '

by letters dated April 15,1997 (Revision 8) and August 25,1997 (Revision 14). USEC has stated that the changes were made in accordance with 10 CFR 76.68 and did not require prior NRC approval. Our review of those changes has identified questions on the appropriateness of that conclusion for some of the changes. Additionalinformation is necessary to support your conclusion that the changes did not require prior NRC approval. The edditionalinformation, specified in the enclosure, should be provided within 30 days of this letter. Note that our review did not include Chapter 1 Appendix A which will be reviewed as a separate issue.

If you have any questions regarding this matter, please contact me at (301) 415-8126.

Sincersty, Original Signed By Merri Horn Project Manager Enrichment Section '

Special Projects Branch Division of Fuel Cycle Safety and Safeguards, NMSS Docket 70-7001 Certifica'e GDP-1 4 I h(Y

Enclosure:

As stated gg g cc: Mr. Steve Polston, PGDP I

Mr. Randall DeVault, DOE k Mr. Steve Toelle, USEC i DJSTRIBUTION: w/ encl.

Docket 70-7o01 10RC Pile Center

• PUBLIC Rlli KO'Brien, Rill ,

NMSS r/f FCSS r/f SPB r/f PHiland, Rill ,

l. OFC SPB E hsPB 6 SP_B ; h NAME Norn:ll YbHoadley in DATE i/ /6/97 h /(7/97 } / /97 I

G:\ mal 76-68..MH C = COVER E = COVER & ENCLOSURE N = NO COPY GIPICIAL RECORD COPY bh( bf 7 JId**288M c

3 Mpog,%[ '!llIII5IIl !

i Request for AdditionalInformation i Updates to CertificaHon Application United States Enrichroent Corporation }

Paducah Gaseous Diffusion Plant l Docket 70 7001 j i

Please provide the following information: .

i SafetyAnaly. sis Report  !

1. On page 3.3-20, Rev. 8, you deleted the commitment to ANSI Standard B 31.3, '

• Chemical Plant and Petroleum Refining Piping" for fabrication involving welded jcints.

Please provide additional information as to why USEC has concluded that deletion of  ;

i the ANSI standard commitment is an allowed change under S 76.68.

2. On page 3.3-35, Rev. 8, you deleted information that dry air is less than 10 ppm moisture and added inic'mation to indicate that the moisture content of the air stream is normally less than 50 ppm Please provide additionalinformation as to why USEC has l concluded that these changes do not decrease safety and are allowed changes under

$ 76.68, particularly considering that plant air can be used for moderation control.

3. On page 3.13 5, Rev. 8, you changed the commitment to ASME B31.3 to current plant practice for converter repair and retesting. Please provide additionalinformation as to i why USEC has concluded that this change is allowed under 9 76.68.

4. On page 4.3-49 Rev. 8, you removed the heellimits established for the cylinder cleaning and testing facility. Please provide additionallnformation as to why USEC has 1 concluded that this change is allowed under S 76.68.

5. On page 5.319, Rev,8, USEC changed the posting requirements for soil contamination areas from 30 pCl/g of uranium and/or 70 pCilg Tc99 to surface contamination greater than the total contamination levels in Table 5.3 2. Table 5.3 2 is the bloassay program and wouid i.ct 'oe an appropriate comparison. Please provide additionalinformation as to why USEC has concluded that they can change the levels requiring posting without L decreasing the effectiveness of the radiation safety program and why Table 5.3 2 - >

specifically hds been referenced.

Unitgency Plan

6. The changes made to the possession limits in Table 1-3, Rev.14 (pages 19 through 1-

11) do not match the possession limit table in Chapter 1 of the safety analysis report. In addition, (1) footnote f is inappropriate for material types A, B, and D, and (2) changing the enrichment level up to 10 percent is the same change for which USEC received a l

Notice of Violation in Inspection Report 97004. Please correct or explain the inconsistencies.

t

+

- . , , -- - r ~ --, - . - - . s,. , c+

e an e l

. 7* On page S 7, Rev. 8, you have deleted the annual retraining commitment for escorts.

Please provide additional information as to why USEC has concluded that deletion of the annual retraining requirement does not decrease the effectiveness of the Emergency Plan.

8. On page 6 5, Rev.14, you have deleted the commitment to conduct weekly tests on the STU ill phone, cellular phones, and facsimilo machines. Pierse provide additional information as to why USEC has concluded that deletion of the test requirements does not decrease the effectiveness of the Emergency Plan, c

-- - ____ _ - - - -