ML20207F257

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Informs That NRC Disagrees with Usec Conclusion for Not re-opening Issue 2 of Compliance Plan,Since Proposed Change to Sarup Submittal Constitutes Major Rev to Operating Safety Bases Contained in Technical Safety Requirements
ML20207F257
Person / Time
Site: Portsmouth Gaseous Diffusion Plant, Paducah Gaseous Diffusion Plant
Issue date: 06/02/1999
From: Ten Eyck E
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Adkins J
UNITED STATES ENRICHMENT CORP. (USEC)
References
TAC-L32118, TAC-L32119, NUDOCS 9906080141
Download: ML20207F257 (2)


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NUCLEAR REGULATORY COMMISSION l3 A-WASHINGTON, D.C. 20565-0001 l

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June 2, 1999 Mr. James N. Adkins Vice President, Productions l

U. S. Enrichment Corporation 2 Democracy Center 6903 Rockledge Drive Bethesda, MD 20817

SUBJECT:

PADUCAH AND PORTSMOUTH GASEOUS DIFFUSION PLANTS - REOPENING OF l

COMPLIANCE PLAN ISSUE 2 (TAC NOS. L32118 AND L32119)

Dear Mr. Adkins:

This refers to Mr. Toelle's letter, dated February 26,1999, which described your plans for modifying the certificate amendment requests for updating the Paducah (PGDP) and Portsmouth (PORTS) application safety analysis reports (SARUP) and a followup discussion at an April 17 NRC-USEC meeting. Your plan deletes the Technical Safety Requirements (TSRs) proposed as part of the SARUP submittals and instead adopts the current TSRs. Your plan also includes adding to the current TSRs, any additional TSRs proposed by the SARUP submittals, in addition, you indicated that you will revise SARUP TSR Basis statements as necessary to reflect the SARUP results and conclusions. To integrate the current TSRs into the SARUP, you also indicated that changes to the SARUP sections containing the accident analyses and the identification of the boundaries for Q and AQ structures, systems and components (SSCs) will be necessary.

In your February 26,1999, letter, you had concluded that Issue 2 of the Compliance Plans for PGDP and PORTS should not be "re-opened" since the proposed changes do not constitute a deficiency in the SARUP submittals and the wording in issue 2 of the Compliance Plan reflected an expectation that changes impacting the SARUP documents would be identified during the NRC review process. You reiterated this position at the April 7 meeting. The NRC staff disagrees with your conclusion since the proposed changes to the SARUP submittals constitute a major revision to the operating safety bases of PGDP and PORTS contained in the TSRs, accident analysis, and Q and AQ SSC boundary definition sections of the SARUP submittals.

Furthermore, the original SARUP submittal requirements were contained in Issue 2 of the PGDP and PORTS Compliance Plans. As such, the NPC staff requests that you reopen issue i

2 of the PGDP and PORTS Compliance Plans. Please provide appropriate descriptions of i

noncompliances, justifications for continued operation, and plans of actions and schedules l

(POAS) to the Department of Energy within forty five (45) days of this letter. Please incorporate the NRC review process in the reopened issues within the POAS, by requiring kid l

responses to NRC's requests for additional information (RAI) to be submitted within 30 days i

l unless otherwise requested by USEC and agreed to by the NRC. In addition, NRC staff

/,0j suggests that the rewrite of Chapter 3 be incorporated into the reopened Compliance Plan i

issues. This would result in your need to withdraw the Chapter 3 CARS dated March 30,1998, which proposed a new condition for the Certificates of Compliance (GDP-1 and GDP-2) for

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PGDP and PORTS.

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s Mr. J, N. Adkins, USEC :

If you have any questions regarding this matter, please contact Yawar Faraz at (301) 415-8113 or Melanie Galloway at (301).415-7266. Please reference the above TAC Nos. In future correspondence related to this subject. The NRC staff requests that you provide a written response to this letter within two weeks of the date'of this letter.

Sincerely, Originals signed by J.M. Piccone for/

Elizabeth Q. Ten Eyck, Director Division of Fuel Cycle Safety and Safeguards, NMSS Dockets 70-7001 and 70-7002 Certificates GDP-1 and GDP-2 cc:

Mr. Randall DeVault, DOE-OR Mr. Morris Brown, PORTS I

Mr. Howard Pulley, PGDP j

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I DISTRIBUTION: (Control Nos. 580S, 500S).

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k DATE 5/10/99 5/10/99 5/ 27 /99 5/13/99 dY/99 C = COVER E = COVER & ENCLOSURE N = NO COPY OFFICIAL RECORD COPY 6 l& *I