ML20199H059
| ML20199H059 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant, Portsmouth Gaseous Diffusion Plant |
| Issue date: | 01/19/1999 |
| From: | Toelle S UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Pierson R NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| GDP-99-0002, GDP-99-2, TAC-L32104, NUDOCS 9901250103 | |
| Download: ML20199H059 (3) | |
Text
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CSEC f
A Global Energy Company
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January 19,1999 GDP 99-0002 1
Mr. Robert C. Pierson Chief, Special Projects Branch Office of Nuclear Material Safety and Safeguards Attention: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 i
Paducah Gaseous D;4usion Plant (PGDP)
Portsmouth Gascous Diffusion Plant (PORTS)
Docket Nos. 70-7001 & 70-7002 Reopening of Compliance Plan Issues
Dear Mr. Pierson:
This letter responds to the United States Nuclear Regulatory Commission (NRC) letter of December 18,1998, "Portsmouth and Paducah Gaseous Diffusion Plants: Criteria for Identifying Deficient Closure of and Reopening of Compliance Plan Issues (TAC No. L32104)." The United States Enrichment Corporation (USEC) is preparing Certificate Amendment Requests (CARS) to reopen PORTS Compliance Plan (CP) issue 9 and the portion ofissue 23 which relates to AQ-NCS systems.
The referenced NRC letter requested that USEC submit the associated CARS for these CP issues to DOE by January 31,1999. USEC will make a gool faith effort to comply with NRC's request; however, USEC anticipates that additional time will be required to complete the internal processing of these CARS. The CARS will be submitted to DOE no later than February 25,1999 (this supersedes our previous committed due date of March 15,1999, reference USEC letter GDP 98-0264 dated December 9,1998).
Additionally, USEC's letter of December 9,1998, also committed to reopen CP issue 8. USEC is currently evaluating the progress made in addressing the NCS issues under the NCS Corrective Action Plan to determine if programmatic issues still exist that would warrant reopening CP issue
- 8. If USEC determines that issue 8 should not be reopened, this justification will be submitted to j
g the NRC in separate correspondence.
(
USEC has also identified a deficiency related to action 1 of PORTS Compliar.ce Plan issue 23 concerning the flowdown of commitments from the Technical Safety Requirements, the Safety jt Analysis Report, and other plans and programs to procedures and training. USEC has notified the NN 9901250103 990119 PDR ADOCK 07007001h C
PDR'l 6903 Rockledge Drive, Bethesda, MD 20817-1818 Telephone 301-564-3200 Fax 301-564-3201 http://www.usec.com Omces in Livermore, CA Paducah, KY Portsmouth, OH Washington, DC
Mr. Robeh Pierson January 19,1999 GDP 99-0002, Page 2 PORTS NRC Resident inspector of this deficiency and we plan to reopen this action as part of the CAR for issue 23 related to AQ-NCS systems.
The referenced NRC letter al3o requested that USEC reopen CP issue 18, " Emergency Packets." In USEC letter GDP 98-0214 dated October 9,1998, USEC informed NRC that full compliance with this CP issue would be achieved by April 15,1999. Significant progress has been made on this issue, and USEC currently anticipates that full compliance will be achieved no later than January 31, 1999. Therefore, USEC does not plan to submit a CAR to revise this CP issue.
In NRC's letter of December 18,1998, NRC stated that, upon the discovery of a deficient CP action, the associated Justification for Continued Operation (JCO) must be immediately reinstated.
Furthermore, NRC stated that if USEC desires to implement a JCO different from the one in the CP, then USEC would immediately implement the new JCO and the "new JCO shall be provided to the NRC within 10 days of determining the deficient CP action." USEC intends to comply with these NRC expectations insofar as they are consistent with NRC guidance contained in Generic Letter 91-18, Rev.1, NRC Inspection Manual Chapter 9900, " Operations - Notice of Enforcement Discretion for Gaseous Diffusion Plants," and the requirements of 10 CFR Part 76.
USEC intends to make a good faith effort to meet the NRC's expectations with regards to appropriately addressing any deficient CP issue which is discovered. However, USEC believes that a CAR may not be able to be submitted to the NRC for reopening a deficient CP issue within two months in all cases. USEC does agree to notify the NRC in a timely manner of deficient CP issues or actions and to establish a schedule for submission of a CAR on a case-by-case basis.
Any questions regarding this matter should be directed to me at (301) 564-3250. The enclosure lists the commitment contained in this submittal.
Sincerely, n
- s. A:
I Steven A. Toelle Nuclear Regulatory Assurance and Policy Manager Enclosure ec:
NRC Project Managers - PGDP and PORTS NRC Region Ill Office NRC Resident inspector - PORTS NRC Resident Inspector - PGDP DOE Regulatory Oversight Manager t
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Enclosure GDP 99-0002 Page1of1 Listof. Commitments 1.
USEC is preparing Certificate Amendment Requests (CARS) to reopen PORTS Compliance Plan (CP) issue 9 and the portion ofissue 23 which relates to AQ-NCS systems. The CARS
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will be submitted to DOE no later than February 25,1999 (this supersedes our previous i
committed due date of March 15, 1999, reference USEC letter GDP 98-0264 dated December 9,1998).
j 2.
USEC's letter of December 9,1998, also committed to reopen CP issue 8. USEC is currently investigating the progress made in addressing the NCS issues under the NCS Corrective Action Plan to detemiine if programmatic issues still exist that would warrant reopening CP issue 8. If USEC detennines that issue 8 should not be reopened, thisjustification will be submitted to the NRC in separate correspondence.