ML20199L943
| ML20199L943 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 02/03/1998 |
| 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) |
| Shared Package | |
| ML20070L427 | List: |
| References | |
| GDP-98-0009, GDP-98-9, NUDOCS 9802100069 | |
| Download: ML20199L943 (7) | |
Text
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J r USEC A Global Enerrgy Company JAMES H. ELLER Dir. (301)564 3309 VICE PRE 81 DENT, PRODUCTION Fax:(301) $718279 February 3,1998 Dr. Carl J. Paperiello SERIAL: ODP 98-0009 Director, Of0cc of Nuclear Material Safety and Safeguards Attention: Document Control Desk 6
U.S. Nuclear Regulatory Commission Washington, D.C. 20555 0001 i
Portsmouth Gaseous Diffusion Plants (PORTS)
Docket No. 70-7002 Certificate Amendment Request liighly Enriched Uranium (IIEU) Cylinder Valve l
Replacement INFORMATION TRANSMITTED 11EREWITil IS PROTECTED FROM PUBLIC DISCLOSURE AS CONFIDENTIAL COMMERCIAL OR FINANCIAL t
INFORMATION AND/OR TRADE SECRETS PURSUANT TO 10 CFR 2.790 AND 9.17(a)(4)
Dear Dr. Paperiello:
In accordance with 10 CFR 76.45, the United States Enrichment Corporation (USEC or Corporation) hereby submits a request for amendment to the PORTS Certificate of Compliance.
This Certificate Amendment Request (CAR) revises Safety Anslysis Report (SAR) Section 3.7, Fundamental Nuclear Materials Control Plan (FNMCP) Section 2, and The Plan for Achieving Compliance at the Portsmouth Gaseous Diffusion Plant (Compliance Plan). Issue A.4. The revision establishes the process for temporary conversion of the X 705 South Annex from Nuclear
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Regulatory Commission (NRC) to Department of Energy (DOE) regulation for the replacement of
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inoperable llEU cylinder valves. This activity is required to support the llEU Refeed project described in Compliance Plan A.4, in that the subject ilEU cannot be fed to the cascade with the gf/)
currently installed cylinder valves.
The NRC letter from Robert C. Pierson to Steven A. Toelle of USEC dated September 10, C
1997,"Portsmouth Gaseous Diffusion Plant (PORTS)- Temporary Conversion of Portions of X 705 c
from NRC to DOE Reguiatory Oversight," requested further justification to demonstrate that NRC A
regulated activities such as decontamination of Planned Expeditious llandling (PEII) equipment and Q pf,( \\jd -
6903 Rockledge Drive,licihesda h1D 20817 *1818
~~ ',(f relephone 301564 3200 Fax 301-564 3201 hirp:#www.usec.com l
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9002100069 900203 PDR ADOCK 07007002 C
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Dr. Carl). Pape,riello February 3,1998 GDP 98 0009, Page 2 components will not be adversely affected during the temporary conversion process. The llEU cylinder valve change out will not impact the NRC regulated PEll or other activities for the following reasons:
1.
A total of only nineteen 8 inch and/or 12 inch cylinders are currently anticipated to require valve replacement. The maximum anticipated valve replacement time is approximately four weeks for all cylindert with one week required to complete the necessary tumover activities for conversion back to NRC regulation, one week to cedify that the areas do not contain material greater that Category 111 possession limits, and one week to receive NRC and DOE approval to return the areas to NRC regulation.
2.
PEli activity is scheduled well in advance of the actual work beginning. Currently, there are no PEli activities scheduled for the X 705 South Annex during April and May 1998. There l
is no foreseeable conflict or impnet on PEli activities in the X 705 South Annex as long as i
NRC approval of this CAR can be obtained, NRC and DOE approval of the conversion start date is obtained, and the llEU cylinder valve replacemer' activities are initiated by April 14, l
1998 (note that this stad date allows only a few days for contingencies, and includes the ten working days notification requested by DOE in their letter of August 21,1997). This would allow the X 705 South Annex to be retumed to NRC regulation on or before May 29,1998, in no case will llEU cylinder valve replacement be scheduled to interfere with a planned PEli activity or any other NRC regulated activity in the X 705 South Annex.
3.
If PORTS finds that a PEli or any other NRC regulated activity needs to be performed in the X-705 South Annex before the llEU cylinder valve replacement activity is started, these other activities will be given priority and will be completed before the llEU cylinder valve replacement begins, if this occurs, USEC will contact NRC and DOE to detennine revised acceptable start and end dates for the llEU cylinder valve replacement activity.
4.
Should it become necessary to immediately work PEll or any other NRC regulated activity during the actual llEU cylinder valve replacement, the llEU activity will be halted and facility tumover activities will commence, if this situation occurs, USEC will contact NRC and DOE immediately to determine a revised plan for completing the 11EU cylinder valve replacements. to this letter provides a detailed description and justification for the proposed changes to SAR Section 3.7, FNMCP Section 2, and Compliance Plan, issue A.4. Enclosure 2 is a copy of the revised pages and removal / insertion instructions. The revised pages are provided for NRC review and approval. Enclosure 3 contains the basis for USEC's determination that the proposed changes associated with this certificate amendment request are not significant.
Dr. Carl). Pape,riello February 3,1998 OJP 98 0009, Page 3 liased on currently scheduled PEli activities, the llEU refeed schedule, and the required lead time for the llEU cylinder valve replacement activity (including obtaining NRC and DOE approval of the conversion date), approval of this CAR by March 30,1998 should allow sufficient time for.
the llEU cylinder valve replacement to begin on April 14,1998 and be completed on or before May 29,1998. Therefore, USEC requests NRC review and approval of this CAR by March 30,1998.
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The amendment should become efTective 7 days aller issuance.
DOE has approved the revisions to Compliance Plan issue A.4 that are included in Enclosure 1, as documented in their letter to USEC dated November 18,1997.
This letter also serves as USEC's request to NRC and DOE (by copy of the letter) to begin llEU eylinder valve replacements in the X 70$ South Annex on April 14,1998 and complete before May 29,1998, USEC's request to begin llEU cylinder valve replacements is contingent upon NRC approval of the temporary conversion process outlined in this CAR.
In accordance with 10 CFR 76.33(c), proposed replacement pages for the proprietary documents listed below are being submitted with this letter. USEC specifically requests that the proposed replacement pages for the following documents be withheld from public disclosure:
-(1)
United States Enrichment Corporation, Fundamental Nuclear Materials Control Plan, Portsmouth Gaseous Diffusion Plant (Proprietary), and (2)
United States Enrichment Corporation, The Plan for Achieving Compliance at the Portsmouth Gaseous Diffusion Plant, Issue A.4 (Proprietary).
The enclosed USEC affidavit provides the information required by 10 CFR 2.790(b)(4).
New commitments made in this submittal are listed in Enclosure 4. Any questions related to this subject should be directed to Mr. Mark Lombard at (301) 564 3248.
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l ies 11. Miller j
' ice President, Production 1
Enclosures:
- 1. Detailed Description of Change
' 2. Removal / Insertion Instructions and Changed Pages
- 3. Significance Determination
_4. List of New Commitments to NRC
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C Dr. Carl J. Paperiello February 3,1998 ODP 98-0009, Page 4 cc:
NRC Region 111 Omce
' NRC Resident inspector. PODP NRC Resident inspector. PORTS l
IX)E Regulatory Overtight Manager -
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OATil AND AFFIRhiATION 1, James II. Miller. swear and amrm that I am Vice President, Production, of the United Ski.a Enrichmeat Corporation (USEC), that I am authorized by USEC to sign and file with the Nucles;;teg.datory Commisslon this Certificate Amendment Request for the Portsmouth Gaseous Diffuslot Plars, dutt.t.ter t,mtFar with the contents thereof, and that the statements made and matters set forth therein are true and correct to the best of my knowledge, information, and belief.
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Jpfn,cs'il. Miller Wee President, Production l
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On this 3rd day of February,1998, the olliecr signing above personally appeared before n:e, is known by me to be the person whose name is subscribed to within the instrument, and t,cknowledged that he exceuted '.he same for the purposes therein contained.
In witness hereofI hereunto set my hand and omeial seal, blbill A
- 1) auric hi. Knisley, Notary Publie State of hiaryland, hiontgomery County hiy commission expires hlarch 17,1998
OATil AND AFFIRMATION I, James 11. Miller, Vlec President, Production, United States Enriclunent Corporation (USEC), having been duly sworn, do hereby aflirm and state:
1.
I am an oflicer of USEC and have been authorized by USEC to (a) review the information owned by USEC which is referenced herein relating to the Portsmouth Gaseous DifTusion Plant and which USEC seeks to have withheld from public disclosure pursuant to section 147 of the Atomic Energy Act (AEA), as amended,42 U.S.C. Q 2167, and 10 CFR 2.790(a)(3),
2.790(a)(4),2.790(d)(1) and 9.17(a)(4), and (b) apply for the withholding of such infonnation from public disclosure by the Nuclear Regulatory Commission (NRC) on behalf of USEC.
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2.
Pursuant to 10 CFR 76.35(h) and 10 CFR 76.35(b), respectively, USEC has prepared i
a Fundamental Nuclear Materials Control Plan, Portsmouth Gaseous DifTusion Plant (FNMCP), and The Plan for Achieving Compliance at the Portsmouth Gaseous Diffusion Plant, Issue A.4, which describe the measures used by USEC at the Portsmouth plant to control and account for special nuclear material that USEC uses, possesses, or has access to. USEC is submitting replacement pages to these plans to the NRC for approval under 10 CFR Part 76.45, 3.
10 CFR 2.790(d)(1) states that correspondence and reports to or from the NRC containing infonnation concerning an applicant's msterial control and accounting program for special nuclear material not otherwise designated as Safeguards Information or classified as National Security Infbnnation or Restricted Data are deemed to be co.lidential commercial or financial information exempt from public disclosure. Accordingly, USEC requests that the subject replacement pages for the Portsmouth Fundamental Nuclear Materials Control Plan and The Plan for / chieving Compliance at the Portsmouth Gaseous Diffusion Plant, Issue A.4, be withheld from public disclosure pursuant to section 147 of the AEA,42 U.S.C. @ 2167, and 10 CFR 2.790(a)(3),
2.790(d)(1) and 9.17(a)(4).
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4, J,ames 11. hiiller, having been duly swom, hereby confinns that I am Vlee President, Production, of USEC, that I am authorized on behalf of USEC to review the information attached hereto and to sign and file with the Nuclear llegulatory Commission this affidavit and the attachments hereto, and that the statements made and matters set forth herein are true and correct to the best of my knowledge, information, and belief.
_f fg Jatiiepi1. hiiller he6 President Production l
On this 3rd day of February,1998, the ofTicer signing above personally appeared before me, is known by me to be the person whose name is subsc.ibed to within the instrument, and acknowledged that he executed the same for the purposes therein contained, in witness hereofI hereunto set my hand and official seal.
hlLA is llObli/n flaurie hi. Knisley, Notary Public I
State of hiaryland, hiontgomery Coun[ty hiy commission expires h1 arch 17,1998
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