ML20211A790

Forwards Info Requested During Briefing by NRC Staff on 990726 Re NRC Interactions with Usec

ML20211A790
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant, 07007001
Issue date:	08/04/1999
From:	Rathbun D NRC OFFICE OF CONGRESSIONAL AFFAIRS (OCA)
To:	Cates D HOUSE OF REP.
References
NUDOCS 9908240138
Download: ML20211A790 (25)

Text

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10trc. 0nv e cnuq g  % UNITED STATES -

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, g j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20065-0001 (o . August 4, 1999 Mr. Dwight Cates,Irwestgator Subcommittee on Oversight and Investigations Committee on Commerce United States House of Representatives

Washington, DC 20515

Dear Mr. Cates:

Enclosed, as outlined below, is the information requested by you and Ms. Edith Holleman, i Minority Staff, during a briefing by the NRC staff on July 26,1999. The briefing concerned NRC l Interactions with its certificate holder, United States Enrichment Corporation (USEC). I

1. Amendment requestsfor both gaseous diffusion plants (GDP) since NRC issued the initial certificate for the GDPs. (Enclosure 1) l.

2. Paducah Compliance Plan issue 36, Revision 3, dated July 17,1996, (Enclosure 2), which was in place at the time of transition on March 3,1997, and Revision 7, dated March 20, 1998, (Enclosure 3) which is the current version of the Paducah Compliance Plan and a chronology of the amendment requests and staff's actions on Compliance Plan Issue 36 at ,

Paducah during this time period. (Enclosure 4)

3. A copy of the USEC and DOE Agreement for DOE Material Storage at the Gaseous Diffusion Plants. (Enclosure 5)

4. The NRC staff is not aware of any "stop work" from DOE to USEC which prevents USEC from entering the Delaased Material Storage Areas (DMSA) to complete the seismic modifications at Paducah. DOE grants authorization for USEC to enter the unleased areas to complete work on a case-by-case basis. In the case of the DMSAs in question, DOE has not authorized access because of concerns with criticality safety.

Should you require any further information, please do not hesitate to contact me.

Sincerely, wce- e Dennis K. Rathbun, Director Office of Congressional Affairs

Enclosures:

1. GDP Amendment Requests 2.' Paducah 7/17/96 CP issue 36, Rev 3 i

3. Paducah 3/20/98 CP lssue 36, Rev 7

4. Amendment Rqst Chronology / Staff Actions on CP issue 36 Or'51

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5. USEC/ DOE Agreement l

cc: Edith Hellemen 9908240:38 990004 PDR AlhCK 07007001 C PDR

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o o Amendments to Certificates of Comoliance  !

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Paducah Title Submittal Date Status Cell Trip Function 9/30/96 issued Autoclave Manual Isolation 10/31/96 issued System Autoclave Containment 12/23/96 issued Valves Pressure Decay l Testing l

Feed Facility Crane Design 2/14/97 issued Features Definition of Completion 2/28/97 issued Times )

Revision to Fundamental 3/4/97 Issued Nuclear Materials Control and Accountability Plan and Compliance Plan issue MC&A Accountability Scale 3/17/97 issued Usage Administrative Control on 3/31/97 lssued Overtime Fire Protection / Movement 3/31/97 issued Prevention System j Cascade Cell Trip Function 4/14/97 issued Buildings C-331 and C-335, 4/23/97 issued l Seismic Upgrades l

Nuclear Criticality Safety 6/16/97 Issued Program Elements .

Autoclave Upgrades / Low 8/11/97 issued Instrument Air Pressure and  ;

Extended Downtime Safety Analysis Report 8/18/97 Upgrade 10/31/97 in Progress Revision 7/19/99 1

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1 Amendments to Certificates of Comoliance '

Paducah Closure of C-360 Autoclave 8/29/97 Issued Isolation Valves Following UF, Detection Product and Tails Withdrawal 9/15/97 issued CAAS Provide Cross Reference 10/6/97 issued Between CAAS TSRs Condition for Chapter 3 3/30/98 In Progress Upgrade Crans Design Features 4/24/98 issued Add New CAAS Cluster 5/13/98 Issued CAAS for C-710, C-720 5/27/98 Issued j Autoclave Manual isolation 5/29/98 Issued System Privatization issued Normetex Pump Safety Limit 9/11/98 Issued CAAS Audibility Upgrade 11/05/98 issued Criteria Siesmic Upgrade Date 1/12/99 in Progress Change Quality Assurance Program 2/12/99 In Progress CAAS Audibility Upgrade 3/01/99 In Progress TSRs Exec. VP Title Change 3/16/99 issued Cylinder Lifting Restriction 7/20/99 In Progress and Other Editorial Revisions l

l 2 ATTACHMENT 1

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Amendments To Certificates of Comoliance Portsmouth Title Submittal Date Status Withdrawal Stations Standby 11/8/96 lssued Operational Mode

' Change to Technical Safety - 12/23/96 issued Requirements for Administrative Controls on Overtime Additional Hypothetical 2/13/97 lssued Criticality Case for X-333 Definition of Completion 2/28/97 issued Times Air Gap Design Feature 4/28/97 , issued Scale Pit Raschig Rings 5/16/97 f Issued Autoclave Containment Issue'd Valve Pressure Decay 6/9/97 [

Testing Nuclear Criticality Safety 6/1F/97 Issued Program Elements Autoclave Upgrades 7/1/97 Issued Autoclave Smoke Detection 7/30/97 issued System

- Safety Analysis Report 8/18/97 Upgrade ' 10/31/97 in Progress Revision 7/22/99 M&TE QA Clarification 10/21/97 issued HEU Cylinder Valve 2/3/98 Issued Replacement

- TSR 2.8, CAAS - 2/27/98 Issued l 1

Freon Degrador 3/16/98 Issued 1 ATTACHMENT 1

a 8 f Amendments To Certificates of Comoliance Portsmouth Condition for Chapter 3 3/30/98 in Progress Upgrade X-342/344 Sprinkler System 4/30/98 issued Low Cylinder Pressure Shut 5/26/98 issued 1 Off

X-744H CAAS Coverage 6/11/98 issued Privatization issued Statistical Sampling of 8/7/98 issued Russian Cylinder Receiving Cylinder Fill 8/24/98 Issued Weights Cleaning of HEU Cylinder 10/14/98 issued Date Change (CP issue A4)

Upgrade of Sampling 12/23/98 lssued Autoclave (CP issue A2)

Quality Assurance Program 2/12/99 in Progress Exec. VP Title Change 3/16/99 issued Reopening CP issues 8,9, 5/14/99 In Progress ;

and 23 a

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4 Issue 36, Page 1 Seismic Capability of Buildings C-331 and C-335 (new issue)

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REQUIREMENTS 10 CFR 76.35(a)(4), (6), and (8) "The application for an initial cenificate of compliance must include the information identified in this section. (a) A safety analysis repon which must include the following information: . . (4) An assessment of accidents based on the requirements of f 76.85; . . . (6) A description of equipment and facilities which will be used by the Corporation to protect health and minimize danger to life or property (such as . . . provisions for protection against natural phenomena; . . (8) A description of the plant site, and a description of the principal structures, systems, and components of the plant."

10 CFR 76.85 "The Corporation shall perform an analysis of potential accidents and consequences to establish the basis for limiting conditions for operation of the plant with respect ,

to the potential for releases of radioactive material. Special attention must be directed to assurance  !

that plant operation will be conducted in a manner to prevent or to mitigate the consequences from I a reasonable spectrum of postulated accidents which include . . natural phenomena in order to ensure adequate protection of the public heahh and safety. Plant operating history relevant to the '

assessment should be included. In performing this assessment, the full range of operations should be considered including, but not necessarily limited to, operation at the maximum capacity I contemplated. The assessment must be performed using an expected release rate resulting from I anticipated operational occurrences and accidents with existing systems and procedures intended j to mitigate the release consequences, along with site characteristics, including meteorology, to j evaluate the offsite radiological consequences."

l COMMITMENTS I l

Source: Safety Analysis Repon l

2. Site Characteristics (Rev. 3, 5/31/96) l This chapter provides information on the location and site characteristics of the facility to  ;

address 10 CFR 76.35(a)(8), including the historical basis for site characteristics in geology and 6 seismology. This information is needed to suppon the assumptions that were used in determining the impacts of normal operation, the hazard and accident analysis as described in Chapter 4 of the application, and emergency operations, panicularly with regard to the contribution of natural seismic phenomena to the initiation of events and the site related assumptions that were used in evaluating accident consequences.

3. Facility and Process Description [Rev. 3,5/31/96)

This chapter provides information on the principal structures, systems, and components of the plant as well as information on the equipment and facilities that are used to protect health and minimize danger to life or property to address 10 CFR 76.35(a)(6) and 10 CFR 76.35(a)(8),

including (1) properties of uranium and uranium hexafluoride (UF.) and the process and facilities used for enriching OF. in the SU isotope; (2) UF. feed facilities and processes; (3) UF. enrichment facilities and processes; and (4) UF. product withdrawal facility and processes.

ATTACHMENT 2 PGDP Rev. 3. 7/17/%

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Issue 36, Page 2 Schmn capbiby of Buildings C-331 and c-335 This information is needed to suppon the assumptions that were used in determining the impacts of normal operation, emergency planning, and the hazard and accident analysis as described in Chapter 4 of the application regarding the contribution of facility and process design to initiation of events and the design-related assumptions that were used in evaluating accident consequences."

4. Accident Analysis [Rev. 3,5/31/96)

This chapter provides a description of the accident analyses that were performed to address 10 CFR 76.35(a)(4) and 10 CFR 76.85. The accident analyses consisted of(1) review of operations including the history of failures and accidents; (2) discussion of the methodology used in determuung the risk associated with hypothetical accidents; (3) identification of accident scenarios:

(4) consequences of accidents; and (5) determination of residual risk. The accident analyses considered natural phenomena including canhquakes.

DESCRIPTION OF NONCOMPLIANCE in 1985, the PGDP was analyzed for a 0.18g peak ground acceleration earthquake loadmg corresponding to an approximate 250-year canhquake return interval, the Evaluation Basis Earthquake (EBE) established in the 1985 Safety Analysis Repon (SAR). Building capacities were shown to be less than this canhquake demand but only minor structural damage was estimated, and l structural integrity was maintained. However, cenain cascade piping attachments known as  !

expansion joints or bellows were judged to fail in significant numbers within the buildings resulting l in a substantial combined release of uranyl fluoride (UO,F,) and hydrogen fluoride (HF) from the cascade facilities. Operations were limited to moderate power levels to keep the enrichment process ,

sub-atmospheric until these expansion joints were improved.

Recently, structural seismic loading capacity analyses, performed as pan of the general safety analyses update of the Paducah Gaseous Diffusion Plant (PGDP), have identified that significant j plant damage could occur in two of the main cascade buildings, C-331 and C-335, below the Evaluation Basis Earthquake. This damage could involve the failure of the approximately 20-foot j wide spans which traverse each building in three locations of each building's roof. The similarly supponed mezzamne and cell floor sections could also fail. The affected spans are attached at one column line and supported by a sliding suppon known as a " rocker arm." At a seismic loading above 0.05g, the building columns might be displaced out of phase to a distance greater than the available travel of the extension bracket suppon causing the spans to fall. Previous acceptance by DOE of the facility's seismic capability relied on the integrity of the buildings for events up to the Evaluation Basis Eanhquake. This potential for loss of the building integrity has been detennined to be an unreviewed safety question and outside the plant's authorization basis.

JUSTIFICATION FOR CONTINUED OPERATION In response to the Unreviewed Safety Question, structural modifications to improve the bracing in the affected buildings have been developed and are in progress. Specifically, structural

(; cross bracing will be added at specific column locations in the nonh-south and east-west directions in Buildings C 331 and C-335 as identified in the conceptual and detailed design reports which are currently being prepared to raise the capacity of the structures to a 0.15g magnitude earthquake as defined by the SAR Upgrade Program site specific hazard curve. These modifications will fri@ Rev. 3,7/17/96

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Seismic Capability ot' Buildings C-331 and C 335 1ssue 36, Page 3 reduce displacements thus ensuring the overall building integrity. The modifications are scheduled for completion over an 18-month period concluding in July 1997. Completion of the modifications will bring the PGDP process building structures into compliance within the interpretation of the 1985 SAR and current seismic requirements for GDP hazardous facilities. However, the upgraded SAR seismic equipment analysis is not yet complete. Additional modifications to equipment could be recommended depending on the findings of the remaining equipment evaluations and the i analyses of the HF and UO:F: projected releases.

I PGDP plans to continue operation with two process buildings, C-331 and C-335, in a seismically weak condition until the completion of building reinforcement modifications in July 1997. Continued operation of the processes in these buildings is justified in the interim since l' the increased risk to the general public and on-site workers is within an acceptable level. The risk increase to the public is a small increase in the chance of an exposure to UO:F: and HF causing minor to moderate renal injuries. The risk increase to some on-site workers is a moderate (factor of 2 to 3) increase in the chance of both exposure to toxic releases and physical injury. (See the "Paducah Gaseous Diffusion Plant Justification for Continued Operation: Temporary Operation of Bi! dings C-331 and C-335 with Potentially Severe Structural Damage Due to Evaluation Basis Eanhquake Loads, prepared by the Department of Energy Regulatory Oversight, Oak Ridge TN, dated May 17,1996.) Compensatory measures were initiated upon recognition of the structural deficiency and will remain in place until the corrective modifications are complete. These measures muumize the number of shift personnel in the affected buildings during the interim period, and the allowed power level in the two buildings is limited to maintain the cascade subatmospheric thereby minimizing the release after a seismic event.

The conclusion that the risk level is acceptable during the interim operating period is supponed by evaluations of the consequences to the public and on-site workers from conservative release scenarios based on the projected and boundi:,g building failures that are possible up to the evaluation basis canhquake. Physical effects such as the impact of a seismically induced fire also were examined as part of these scenarios.

The projected structural response of the two buildings up to an Evaluation Basis Earthquake (250-year return interval, peak ground acceleration equivalent: 0.15 g) is the inward collapse of three areas of each building's roof, mezzanmes, and cell floor. Rese areas are about 20 feet wide and run the length of each building in the direction of the structural expansion joint between internal stmetural units. He collapse could cause the release of UF., UO:F2 , and HF. In addition, there is some probability that the buildings could collapse in response to the loading of earthquakes that produce accelerations approaching 0.15g. Based on the possible structural response, four exposure cases were evaluated. A bounding case (Case 1) assumed that the building collapsed (i.e.,

the building fell over onto its side) and the entire contents of the cascade system was released into the collapsed structures. It should be noted that the load bearing capacity of the conveners located throughout the building on the cell floor would prevent the complete flattening of the structure and provide a vertical air space approximately 8 feet high. The analyzed quantity of the UO2 F 2 and HF released was not reduced by physical considerations such as the material that would remain in the cascade piping and equipment or may deposit in the building or the vicinity of the building due to aerosol deposition. However, the effects of thermodynamics and the mixing of fluids (water vapor and R-il4 Freon) in the building were considered. Case 2 used a conservative, but more realistic, engineering analysis basis that inckded an esumate of the UF, that would remain in the converters following the cascade system ruptures. The amount of aerosol deposition that would occur during the residence time of the release cloud in the buildings was also considered. This release case is PGDP Rev. 3, 7/17/96

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e Issue 36, Page 4 seismi: Capability of Buildings C-331 and C-335

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a conservative but defendable estimate of the bounding physical state of the building. Cases 3 and 4 a're similar cases of the buildings' expected actual structural response to an Evaluation Basis Earthquake event (including the failure of areas of the buildings at the stmetural expansion joints).

Case 3 is based on a highly conservative estimate of the cascade damage that would be sustained if the roof, mezzamne, and cell floor failed as predicted and no aerosol deposition occurred. Case 4 is the same as case 3 with consideration given to aerosol deposition.

The results of the four evaluation cases are summarized in the following table:

Table 1. Uranium Uptake and HF exposure

• to Individuals Evaluation Case Meteorology Maximum Maximum HF Exposure HF Exposure Class-Wind Uranium inhaled Uranium inhaled Concentration Concentration spes,: (. .,Me) Mass (mg) at 1 Mass (mg) at 5 (ppm)-1 mile (ppm)-5 miles

- mile miles l

I. Building Co!! apse-No retention in D-4 139 70 38 19 Cascade (Bounding Case)

II. Building Collapse-Conservative D4 45 16 15 5 estimate of q retention in l

Cascade  ;

l III. Panial Building Failure F3 32 7 17 3 with No Aerosol Deposition IV. Panial Buildmg Failure

, F-3 20 4 11 2 with Aerosol Deposition

• HF caposures are based on I hour average concentrations.

"Ihe results of all but the bounding case (Case 1) show the potential for only a mild exposure, i nearly within the accident evaluation guidelines. The bounding case consequences indicate the potential for significant renal injury, that would not be potentially life threatening at one mile distance from the release point. One mile is essentially the distance to the site boundary from the buildings in question. The risk of exposure to the general public of moderate (uptake of 100-150 mg of uranium) and low (50-100 mg uptake) renal injuries was estimated to be 0.15 injuries and 0.78 injuries / year, respectively, assummg no benefit from an emergency response. If emergency response is considered and credited with a factor of 2 benefit due to either sheltering er evacuation, then the risk is essentially zero, at 0.15 low level renal injuries / year. Given the highly conservative nature of the evaluation of the release and the low consequences, continued operation does not pose a significant undue risk to the public during the period of operations until building modifications are completed.

The risk to workers in the buildings was estimated as well. Based on an assumed 5 percent chance of building collapse and a 50 percent chance of being present in the building (i.e., on shift),

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l Seismic Capability of Buildings C-331 and C-335 1ssue 36, Page 5 l l

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the mjury rate to tndividual workers was estimated at apprcximait 1xW' per year with a total injury rate risk estimated at 2.6 x 10-2 injuries per year (for an operating staff of 26). This is judged to be acceptable and is no greater than the risk of general of5ce work on-site. Injury from structures may even be higher in the office buildings, although the probability of exposure to HF and UO:F. releases would be greater in the process buildings.

Therefore, it is concluded that the risk to the public and the on-site workers from the unmitigated response of Buildings C-331 and C-335 is not extreme and can be accepted without undue harm with the compensatory measures imposed on operations remaining in effect until the modifications are complete while the structural weaknesses are being corrected.

I PLAN OF ACTION AND SCHEDULE The actions to upgrade the seismic capabilities of Buildings C-331 and C-335 are as fo'llows: 1

1. Based on a Directive for Information provided to USEC by DOE on September 22,1995, the USEC evaluation of the currently available information from the DOE safety analysis upgrade effort related to seismic capabilities at the facility completed on October 23,1995, the DOE ]

evaluation of the USEC response dated October 31,1995, and USEC's proposed resolution documented on January 9.1996, the following actions are being implemented to ensure the protection of the workers and public health ar.d safety:

. Until the completion of modifications discussed below, operations in Buildings C-331 and C-335 will be limited to subatmospheric pressure within the enrichment cascade equipment.

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• Operations personnel will be instructed on the specific emergency procedures for shutting down the affected enrichrnent cascade equipment and building ventilation systems following a seismic event.

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- Building access will be limited to only those individuals essential to operations.

inspections, or those personnel performing the modifications until they are complete. j

• Modifications to increase the seismic capability for floor and roof sections in Buildings C-331 and C-335 will be completed by December 31,1997, (pending DOE approval of USEC request with justification for a delay from July 31,1997 - current commitment date to DOE).

2. At the time of transition from DOE regulatory oversight to NRC regulatory oversight, USEC will inform NRC of the interim measures still in effect for the affected buildings and equipment and the current status of upgrading the seismic capabilities of the affected buildings and equipment.

3. Documentation prepared for the design of the modification and other relevant information conceming implementation will be provided to the NRC, upon issue, for information and review.

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l Issue 36, Page 6 Seismic ca;nbiAity of Buildings C-331 and c-335

4. By December 1,1997, USEC shall submit for NRC approval an updated seismic risk analysis l

for the Paducah plant site. The analysis shall:

. Consider all available regional and site-specific data published by the U.S. Geological Survey.

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- Provide an estimate of the peak ground acceleration for a seismic. event with a 250-year l

return period. If the estimate is greater than 0.15g, then the return period for a 0.15g event shall also be estimated.

Any proposed modifications that may result from this analysis shall be subject to a backfit analysis pursuant to 10 CFR 76.76(b).

SUMMARY

OF REQUIREMENTS, COMMITMENTS, AND NONCOMPLIANCES l- Issue: Seismic Capability of Buildings C-331 and C-333 Code of Federal Regulations Part Title 10 76.35(a)(4), 76.35(a)(6), 76.35(a)(8), 76.85 Application Commitment Section Safety Analysis Report 2.1.1. 2.6, 3.1, 3.3, 3.4, 4.2.2.6, 4.6.1, 4.7,  ;

Table 4.9-1 Application Noncompliance Statement Section  ;

Safety Analysis Report 2.7. 3.16.1, 4.10 l l

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l PGDP Rev. 3. 7/17/96

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Issue 36, Page 1 Seismic Capability of Buildings C-331 and C-335 (new issue)

REQUIREMENTS 10 CFR 76.35(a)(4), (6), and (8) "The application for an initial certificate of compliance must include the information identified in this section. (a) A safety analysis report which must include the following information: . . . (4) An assessment of accidents based on the requirements of 6 76.85;

. . . (6) A description of equipment and facilities which will be used by the Corporation to protect health and mmmuze danger to life or property (such as . . . provisions foi p;otection against natural phenomena; . . . (8) A description of the plant site, and a description of the principal structures, systems, and components of the plant."

10 CFR 76.85 "The Corporation shall perform an analysis of potential accidents and consequences to establish the basis for limiting conditions for operation of the plait with respect to the potential for releases of radioactive material. Special attention must be directed to assurance that plant operation will be conducted in a manner to prevent or to mitigata the consequences from a reasonable spectmm of postulated accidents which include . . natural pher.omena in order to ensure adequate protection of the public health and safety. Plant operating history relevant to the assessment j

should be included. In perfonning this assessment, the full range of operations should be considered including, but not necessarily limited to, operation at the maximum capacity contemplated. The l assessment must be performed using an expected release rate resulting from anticipated operational occurrences and accidents with existing systems and procedures intended to mitigate the release consequences, along with site characteristics, including meteorology, to evaluate the offsite radiological consequences."

l COhBIITMENTS l Source: Safety Analysis Report

2. Site Characteristics [Rev. 3,5/31/96]

This chapter provides information on the location and site characteristics of the facility to address 10 CFR 76.35(a)(8), including the historical basis for site characteristics in geology and seismology. This information is needed to support the assumptions that were used in determining the impacts of normal operation, the hazard and accident analysis as described in Chapter 4 of the application, and emergency operations, particularly with regard to the contribution of natural seismic phenomena to the initiation of events and the site related assumptions that were used in evaluating accident consequences.

3. Facility and Process Description [Rev. 3,5/31/96]

This chapter provides information on the principal structures, systems, and components of the f

plant as well as information on the equipment and facilities that are used to protect health and minimize danger to life or property to address 10 CFR 76.35(a)(6) and 10 CFR 76.35(a)(8),

including (1) properties of uranium and uranium hexafluoride (UF.) and the process and 2

facilities used for enriching UF. in the "U isotope; (2) UF. feed facilities and processes; ATTACHMENT 3 PGDP Rev. 7. 3/20/98

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Issue 36, Page 2 seismic capability of Buildings C-331 and c 335 l

(3) UF. enrichment facilities and processes; and (4) UF. product withdrawal facility and processes.

This information is needed to support the assumptions that were used in determining the impacts of normal operation, emergsy planning, and the hazard and accident analysis as described in Chapter 4 of the application regarding the contribution of facility and process design to initiation of events 1 and the design-related assumptions that were used in evaluating accident consequences." l

4. Accident Analysis [Rev. 3,5/31/%]

This chapter provides a description of the accident analyses that were performed to address 10 )

CFR 76.35(a)(4) and 10 CFR 76.85. The accident analyses consisted of (1) review of operations including the history of failures and accidents; (2) discussion of the methodology used in determmmg the risk associated with hypothetical accidents; (3) identification of accident scenarios: (4) j consequences of accidents; and (5) determmation of residual risk. 'Ihe accident analyses considered  ;

natural phenomena including earthquakes. l DESCRIlTION OF NONCOMPLIANCE In 1985, the PGDP was analyzed for a 0.18g peak ground acceleration earthquake loading corresponding to an approximate 250-year canhquake return interval, the Evaluation Basis Earthquake (EBE) established in the 1985 Safety Analysis Report (SAR). Building capacities were shown to be less than this canhquake demand but only minor structural damage was estimated, and structural integrity was maintained. However, cenain cascade piping attachments known as expansionjoints or bellows were judged to fail in significant numbers within the buildings resulting in a substantial combined release of uranyl fluoride (UO:F:) and hydrogen fluoride (HF) from the cascade facilities. Operations were limited to moderate power levels to keep the enrichment process sub-atmospheric until these expansion joints were improved.

Recently, structural seismic loading capacity analyses, performed as pan of the general safety analyses update of the Paducah Gaseous Diffusion Plant (PGDP), have identified that significant plant damage could occur in two of the main cascade buildings, C-331 and C-335, below the Evaluation Basis Earthquake. This damage could involve the failure of the approximately 20-foot wide spans which traverse each building in three locations of each building's roof. The similarly supported mezzanme and cell floor sections could also fail. Th'e affected spans are attached at one column line and supported by a sliding support known as a " rocker arm." At a seismic loading above 0.05g, the building columns might be displaced out of phase to a distance greater than the available travel of the extension bracket support causing the spans to fall. Previous acceptance by DOE of the facility's seismic capability relied on the integrity of the buildings for events up to the Evaluation Basis Eanhquake. This potential for loss of the building integrity has been determined to be an unreviewed safety question and outside the plant's authorization basis.

l l JUSTIFICATION FOR CONTINUED OPERATION in response to the Unreviewed Safety Question, structural modifications to improve the bracing f

l in the affected buildings have been developed and are in progress. Specifically, structural cross bracing will be added at specific column locations in the north-south and east-west directions in l Buildings C-331 and C-335 as identified in the detailed design which has been prepared to raise the capacity of the stmetures to a 0.15g magnitude canhquake as defined by the SAR Upgrade Program PGDP Rev. 7. 3/20/98

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Seismic Capability of Buildings C-331 and C-335 Issue 36, Page 3 site specific hazard curve. Dese modifications will reduce displacements thus ensuring the overall ,

building integrity. The modifica* ions are scheduled for completion over an 18-month period l concluding in July 1997. Completion of the modifications will bring the PGDP process building l structures into compliance within the interpretation of the 1985 SAR and current seismic l I

requiremems for GDP hazardous facilities. However, the upgraded SAR seismic equipment analysis is not yet complete. Additional modifications to equipment could be recommended depending on the findings of the remaining equipment evaluations and the analyses of the HF and UO F2 2 Projected releases. ,

I PGDP plans to continue operation with two process buildings, C-331 and C-335, in a seismically weak condition until the completion of building reinforcement. modifications. Continued l 4 operation of the processes in these buildings is justified in the interim since the increased risk to the general public and on-site workers is within an acceptable level. The risk increase to the public is a small increase in the chance of an exposure to UO2F: and HF causing minor to moderate renal l

injuries. The risk increase to some on-site workers is a moderate (factor of 2 to 3) increase in the l chance of both exposure to toxic releases and physical injury. (See the "Paducah Gaseous Diffusion l Plant Justification for Continued Operation: Temporary Operation of Buildings C-331 and C-335 l I

with Potentially Severe Structural Damage Due to Evaluation Basis Earthquake Loads,' prepared by the Department of Energy Regulatory Oversight, Oak Ridge, TN, dated May 17, 1996.)

Compensatory measures were initiated upon recognition of the stmetural deficiency and will remain in place until the corrective modifications are complete. These measures mimmize the number of shift personnel in the affected buildings during the interim period, and the allowed power level in the two buildings is limited to maintain the cascade subatmospheric thereby muumizing the release i after a seismic event. I I

The conclusion that the risk level is acceptable during the interim operating period is supported by evaluations of the consequences to the public and on-site workers from conservative release scenarios based on the projected and bounding building failures that are possible up to the evaluation basis earthquake. Physical effects such as the impact of a seismically induced fire also were examined as part of these scenarios. l The projected structural response of the two buildings up to an Evaluation Basis Earthquake I (250-year return interval, peak ground acceleration equivalent: 0.15 g) is the inward collapse of three areas of each building's roof, mezzanines, and cell floor. These areas are about 20 feet wide and run the length of each building in the direction of the structural expansion joint between internal I structural units. He collapse could cause the release of UF., UO:F2 , and HF. In addition, there is I some probability that the buildings could collapse in response to the loading of earthquakes that produce accelerations approaching 0.15g. Based on the possible structural response, four exposure l

cases were evaluated. A bounding case (Case 1) assumed that the building collapsed (i.e., the '

building fell over onto its side) and the entire contents of the cascade system was released into the 4 collapsed structures. It should be noted that the load bearing capacity of the conveners located thrcughout the building on the cell floor would prevent the complete flattening of the structure and provide a vertical air space approximately 8 feet high. The analyzed quantity of the UO:F: and HF l released was not reduced by physical considerations such as the material that would remain in the cascade piping and equipment or may deposit in the building or the vicinity of the building due to aerosol deposition. However, the effects of thermodynamics and the mixing of fluids (water vapor and R-il4 Freon) in the building were considered. Case 2 used a conservative, but more realistic, engineering analysis basis that included an estimate of the UF, that would remain in the converters l following the cascade system ruptures. The amount of aerosol deposition that would occur during l I

PGDP Rev- 7.3/20'98

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\ l Issue 36, Page 4 Seismic Capability of Buildings C-331 and C-335 the residence time of the release cloud in the buildings was also considered. This release case is a conservative but defendable estimate of the bounding physical state of the building. Cases 3 and 4 l

are similar cases of the buildings' expected actual structural response to an Evaluation Basis Earthquake event (including the failure of areas of the buildings at the structural expansion joints).

Case 3 is based on a highly conservative estimate of the cascade damage that would be sustained if the roof, mezzanme, and cell floor failed as predicted and no aerosol deposition occurred. Case 4 is the same as case 3 with consideration given to aerosol deposition. I The results of the four evaluation cases are summanzed in the following table:

j Table 1. Uranium Uptake and HF exposure" to Individuals l Evaluation Case Meteorology Maximum Maximum HF Exposure HF Exposure Class-Wind Uramum Inhaled Uranium Inhaled Concentration Concentration speed (m/sec) Mass (mg) at 1 Mass (mg) at 5 (ppm)-1 mile (ppm)-5 miles mile miles I. Building Collapse-No retention in D-4 139 70 38 19 ,

Cascade (Bounding l Case)

11. Building Collapse-Conservative estimate of D-4 45 16 15 5 retention in Cascade III. Partial l Building Failure p,3 3; 7 37 3 with No Aerosol Deposition IV. Partial I

Building Failure with Aerosol F3 20 4 11 2 Deposition

• HF exposures are based on I hour average concentrations.

The results of all but the bounding case (Case 1) show the potential for only a mild exposure, nearly within the accident evaluation guidelines. The bounding case consequences indicate the potential for significant renal injury, that would not be potentially life threatening at one mile distance from the release point. One mile is essentially the distance to the site boundary from the buildings in question. The risk of exposure to the general public of moderate (uptake of 100-150 mg of uranium) a-d low (50-100 mg uptake) renal injuries was estimated to be 0.15 injuries and 0.78 injuries / year, respectively, assuming no benefit from an emergency response. If emergency response l is considered and credited with a factor of 2 benefit due to sheltering, then the risk is essentially zero, at 0.15 low level renal injuries / year. Given the highly conservative nature of the evaluation

of the release and the low consequences, continued operation does not pose a significant undue risk to the public during the period of operations until building modifications are completed.

1 The risk to workers in the buildings was estimated as well. Based on an assumed 5 percent chance of building collapse and a 50 percent chance of being present in the building (i.e., on shift),

PGDP Rev. 7, 3/20/98

a -

Seismic Capability of Buildings C 331 and C 335 1ssue 36. Page 5 the injury rate to individual workers was estimated at approximately 1 x10" per year with a total injury rate risk estimated at 2.6 x 104 injuries per year (for an operating staff of 26). This is judged to be acceptable and is no greater than the risk of general office work on-site. Injury from strucmres may even be higher in the office buildings, although the probability of exposure to HF and UO:F:

releases would be greater in the process buildings.

Therefore, it is concluded that the risk to the public and the on-site workers from the unmitigated response of Buildings C-331 and C-335 is not extreme and can be accepted without undue harm with the compensatory measures imposed on operations remaining in effect until the modifications are complete while the structural weaknesses are being corrected.

PLAN OF ACTION AND SCIIEDULE The actions to upgrade the seismic capabilities of Buildings C-331 and C-335 are as follows:

1.

Based on a Directive for Information provided to USEC by DOE on September 22,1995. the USEC evaluation of the currently available information from the DOE safety analysis upgrade effort related to seismic capabilities at the facility completed on October 23,1995, the DOE evaluation of the USEC response dated October 31,1995, and USEC's proposed resolution documented on January 9,1996, the following actions are being implemented to ensure the protection of the workers and public health and safety:

Until the completion of modifications discussed below, operations in Buildings C-331 and l C-335 will be limited to subatmospheric pressure within the enrichment cascade equipment.

{

Operations personnel will be instructed on the specific emergency procedures for shutting  ;

down the affected enrichment cascade equipment and building ventilation systems following a seismic event.

Building access will be limited to only those individuals essential to operations, inspections, or those personnel performing the modifications until they are complete.

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.

2. At the time of transition from DOE regulatory oversight to NRC regulatory oversight. USEC will inform NRC of the interim measures still in effect for the affected buildings and equipment and the current status of upgrading the seismic capabilities of the affected buildings and equipment.

3. Documentation prepared for the design of the modification and other relevant information concerning implementation will be provided to the NRC. upon issue, for information and review.

PGDP Ret 3.20 95

o Issue 36, Page g seismic capability of Buildings c.331 and C-335 4

4. By Dsuhr 1,1997, USEC shall submit for NRC approval an updated seismic risk analysis for the Paducah plant site. The analysis shall:

. Consider all available regional and site-specific data published by the U.S. Geological Survey.

- Provide an estimate of the peak ground acceleration for a seismic event with a 250-year return period. If the estimate is greater than 0.15g, then the return period for a 0.15g event shall also be estimated.

Any proposed modifications that may result from this analysis shall be subject to a backfit analysis pursuant to 10 CFR 76.76(b).

SUMMARY

OF REQUIREMENTS, COMMITMENTS, AND NONCOMPLIANCES Issue: Seismic Capability of Buildings C-331 and C-335 Code of Federal Regulations Part Title 10 76.35(a)(4), 76.35(a)(6), 76.35(a)(8), 76.85

. Application Commitment Section ,

i Safety Analysis Report 2.1.1, 2.6, 3.1, 3.3, 3.4, 4.2.2.6, 4.6.1, 4.7, I Table 4.9-1 .

1 Application Noncompliance Statement Section l Safety Analysis Report 2.7, 3.16.1, 4.10 PGDP Rev. 7,3/20/98

7 . .

PADUCAH GASEOUS DIFFUSION PLANT COMPLIANCE PLAN ISSUE 36 CHRONOLOGY The original Compliance Plan issue 36 required United States Enrichment Corporation (USEC) to complete the seismic modifications in Buildings C-331 and C-335 by 12/31/97.

4/23/97 USEC submitted an amendment to Compliance Plan Issue 36:

1. Requesting that the Nuclear Regulatory Commission (NRC) review three Unreviewed Safety Questions (USO) to determine adequate safety.

(These three USOs identified that the new installations for the seismic modifications might increase the probability of seismically-induced equipment failures, might temporarily weakan the structure, and might temporarily increase the probability of equipment failure because of postulated construction accidents.)

2. Requesting an extension of the completion date of the seismic modifications for up to 15 months after NRC's determination of adequate safety regarding the three USOs.

6/30/97 USEC informed the NRC that the seismic work would be suspended until NRC's review of the three USOs was completed.

7/24/97 The NRC responded to the 6/30/97 letter cautioning USEC that any suspension of work which could jeopardize meeting the scheduled completion date was at USEC's own risk.

7/23-25/97 NRC staff visited Paducah to review the seismic modification design and discussed the modification and the USOs with USEC and USEC contractor staff.

7/31/97 USEC submitted a change to the amendment request submitted on 4/23/97.

The change requested:

1. NRC review of the same three Unreviewed Safety Questions (USO) to determine adequate safety.

2. Extension of the completion date until 18 months after NRC's determination of adequate safety regarding the three USOs and NRC's determination that an updated seismic hazard analysis adequately calculated the seismic acceleration (magnitude of the earthquake) for the seismic accident.

3. Revision of Compliance Plan issue 36 to allow taking credit for sheltering people for personnel protection. i

4. Revision of Compliance Plan issue 36 to acknowledge that the final j modification design was completed. l S. Revision of Compliance Plan issue 36 to reference a Lawrence Livermore  !

National Laboratory (LLNL) report that was used by the Department of l Energy (DOE)(before transition to NRC regulatory oversight) to justify j continued operation under DOE oversight.  !

1 8/20/97 The NRC issued a Request for Additional Information (RAI) that asked for information that was referenced in the LLNL report and additional information for NRC staff to justify extending the completion date.

9/19/97 USEC provided the additional information.

!i ATTACHMENT 4  !

p . .

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l 12/16/97 The NRC issued a notice in the Federal Register notifying the public of the findings from the review of the revised amendment request. The NRC found that:

1. The three issues identified as USQs posed no undue risk to the public from the issues identified in the USQs.

2. The compliance plan should be updated to acknowledge that the seismic modification design was completed.

3. The compliance plan should be modified to allow credit for sheltering personnel to reduce risk.

4. A delay in the modification completion date until 18 months after approval of the updated seismic hazard was not justified based on USEC's 9/19/97 response for additional information, but adequate safety could be demonstrated for a completion dated extension to 6/30/99.

5. Revising the compliance plan to reference the LLNL report was not justified. The LLNL report was intended to justify the short term operation of Paducah and the risk analysis in the report did not provide justification for operations beyond the original completion date of 12/31/97.

12/30/97 USEC challenged the NRC findings noticed in the Federal Register by filing a petition with the Commissioners. The petition specifically requested the Commissioners to allow extension of the completion date to 18 months after the I NRC review and approval of the update seismic hazard analysis.

3/19/98 The Commission decided against USEC's petition and issued Memorandum and Order, CLI 98-02, to affirm the staff's requirement to complete the seismic modification by 6/30/99.

1/12/99 USEC submitted an amendment request to change the seismic modification

. completion date to 6/30/00.

1. The NRC staff sent RAls dated 1/27/99 and 4/7/99 requesting a more detailed risk analysis for on site workers that would demonstrate

, adequate safety and reasonable assurance that the new completion date would be met.

2. USEC responded to the RAls with letters dated 2/18/99,4/27/99, and 5/14/99.

6/30/99 The NRC found that the information provided by USEC assured adequate safety for the workers and issued a Notice of Enforcement Discretion (NOED) while continuing to review the amendment request.

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USEC and DOE Agreement for

. DOE MatastalStorate at the Gaseous DWusion riants deckeranad .

Deparanent of Energy (DOE) materials have been stored in parts of everal buildings and areas currently leased by the Unied States Enrichment Corporatica (USEC) at both gaseous diffusion plants (GDPs).

At the request of USEC, pursuant to Secdon 3.4(b) of the lasse, DOE armes to reduce the leasehold as necessary to wan=nanime the storage of DOE -Wquipment. USEC will assume the financtal and physical responsibility for, to the eatent required by the Nuclear Regulatory Commission (NRC),1) completing the necessary visual inspeedsas to identify enriched uranium deposits,2) segregating equipment containing identified deposits; 3) estabhshlag and maintaming the required boundaries identified in this agreement, and 4) maintaining the necessary documentation to support these commitments.

Since the DOE fonnerly leased storage areas will not be imed to USEC, they are not subject to 10 CFR Part 76 requiresnents and NRC regulation. Addidonally, activides within these areas (e.g. inspecnons and surveys) will confona to DOE requirements and are not subject to becoming a Compliance Plan item.

DBMIME The following prenuses support the propond resolution of DOE material storage:

1. This joint USEC and DOE agreement for DOE material storage does not modify, amend, or alter in any way the Lease Agreement between USEC and DOE for the GDPs, or any memoranda of agreement, or any other agreement twa a USEC and DOE. Exhibit A to the I.mase Agreement will be modified to reflect which areas of USEC formerly leased space will now be listed as DOE space.

2 ~ DOE acdvities conducted in formerly leased storage locations, including ingress and egress both within and external to the leased buildings, will be managed in accordance with applicable DOE requirements. This includes DOE personnel and their contractors / subcontractors. DOE assumes full responsibility for the safety, safeguards, and security of DOE activines.

3. All fiand asset equipment (columns, pi ping, electrical, etc.) located in or traversing formerly leased spacc (within the confines of the cascade bui; dings or any other leased building) remain the responsibility of USEC. All activities related to flaed asset equipment will be subject to NRC regulation. ' Ibis includes USEC personnel and their contractors / subcontractors. USEC assumes full responsibility for the safery, safeguards, and security of USEC activities.

DOE Material Storare Centrols The following controls will be established to ensure safe storage is maintained in those areas designated for DOE

. material storage.

1. - Location of DOE Material /Equipement Formerly I4ased Storage Areas DOE material and equipment that is either contaminated or potentially contaminated with radioactivity, or i:ontains uranium ber@g material (i.e., pmoess equipment, low level radioacdve waste, hazardous (TSCA) waste contermanten with uvantum. uranium tetrafluoride (UFJ, etc.) will be physically located on property that is formerly leased by USEC. If this storage is within USEC leased buildings. the floor area directly supporting the material and out to the DOE /USEC formerly leased storage area boundary will be under the control of DOE. Tbc boundary will be clearly unarked through the use of ropes, dikes, and/or painted lines; and will also be marked with signs.

If the mananal storage ama is located outside of USEC leased buildings, then the ground supportmg the material is under the control of DOE and will be an area formerly leased by USEC. Boundaries are required for these areas that contain notecontainanzad materials, and may be used to mark containerized material areas. Signs shall be used to identify the areas. Boundaries are not seguired for containerised material areas and, as an altemative, the containers may be labeled as DOE.

ATTACHMENT 5

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The location and boundaries of DOE formariy leased material storage areas will be determined and established prio to cerd6cadon, or addressed as a Compliance Plan activity, Establishment of new and/or the relocation of existin X)E storage amas within USEC leased bundings after NRC assumes regulatory ovenight will be coordinated

.mongDOE, NRC, and USEC.

1. Proteetion of DOE Equipment 'nat Contains Uranium Deposits Process equipment desi pied to contain UF, (i.e., compressors, conveners, pipes, and valves, etc.) in DOE formerly leased storage assas wil; be inspected for visible deposits (does not include surface contamination) of enriched uramum beadng material. The purpose of this inspeedon is to ensure that the equipment does not contain uranium deposiu that could be easily retrieved without the use of special equipment. The inspection will consist of a visual check of the exterior and interior (if accessibic) of the app icable equipment. Dismantling the equipment for inspectionis not requimd.

If equipment is found to contain visible deposits of enriched uranium bearing materials, the equipment will be secured by a ysical barder. For man-portable e within the E formerly leased storage area (i.e.,quipment, this barrier shall consist of a locked bar locked gate, fence, wall, etc.). For non. portable equipment it could be a barrier affixed to the opening of the equipment. Like other DOE cquipment, this equipment wi!! also be located within a clearly marked area which was formerly leased by USEC.

3. Mat =*===== of DOE Material / Equipment Formody I4ased Storage Areas DOE will resure that DOE formerly leased storage areas are maintained in accordance with DOE requirements.

DOE will evaluate planned and unplanned disturbances 1) to ensure no significam risk impact on USEC's NRC.

' regulated space, and 2)in accordance with DOE requirements forimpact on DOE space, DOE will prohibit disturbances of formerly leased storage areas, except as necessary to conduct decontamination or consolidation to maimam or improve safe storage conditions, or to remove material / equipment from the buildings. USEC will be responsible for maintainmg the boundary and activities required by NRC at the boundary (i.e., radiation survey etc.).

USECis allowed access to the DOE storage areas to conduct essential plant operations, to conduct DOE authorized work on stored matenal/ equipment, and to respond to emergencies. If USEC acces: results in the unauthorized disturbance of DOE material / equipment, DOE will be immediately notified by USEC.

4. Limitations on the Additina of New DOE Materials / Equipment Addition of mawiale to the formerly leased storage armas will be limited to properly characterized TSCA waste generated onsite. In the event an unforeseen situation arises that requires addition of matenal/ equipment to the formerly leased storage area other than properly characterized TSCA waste, the addition will be coordinated between

- DOE, USEC and NRC.

USEC can not add to these areas without expms wrinen DOE permission.

5. Transfer of Mataris# Equipment It may be necessary for USEC to transfer equipment and/or material out of a DOE formerly leased storage area for USEC's use afterNRC comrnances seguladon. Tansfers are contingent upon USEC performing the following: 1) obtaining DOE approval,2) measuring the uranium content of the material / equipment through Non.Dertructive Assay (NDA),3) issuing an NRC Form 741 for the transfer of nuclear material (if applicable), and 4) notifying the NRC site assident prior to movement of the matenal/ equipment into leased space.

(*-'=radtwt a O kg g 4 Q M

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Pariis fateI / George P. Xifskes Date (ofEnergy United States Enrichment Corporation Assistant Manager for Executive Vice President Knrichment Facilicies

DOE u=W=1 Storsac Areas Memorandum of Agreement Between DOE and USEC RegardingDeleased MaWal Storage Areas (DMSA)

DOE and USEC will develop a priarmsation plan by January 17,1997, thar will USEC activides to be j, &,rmed at USEC's expansa including:

1.

Dianantling and removing Asad process equipment located in or travemng buildings so long as renoval wiH not require shut down of any USEC operan 1

ConfDrmance with ramaa==hla DOE wasta =~-'=nce criteria, not to be more r than that of tygdcal commerdal facihtiaa.

3.

C^af^=d=_ of materials with other DOE areas.

4.

14asing areas back after materials are conschdated into other DOE areas.

USEC shall perform tha. fallowing activities at USEC expense on or before March 3,1 1.

Each DMSA shan be assigned a unique identification number. USEC sha!! provide inventory to DOE of the type and appmaimate quantity of each DMSA (both indoor a outdoor tacanann). DOE and USEC shall agma on inventory.

1 DOE shall maks availah!c its landfE! and scrap yards for USEC waste.

Generalcondidans:

1.

Any can'and ,luba oillealm, waterleaks, or otherintrusion into the DMSAs by USEC shall be cleanad uphopaired within 24 hows by USEC.

2.

Randuzion and dosure of open issues shall be resolved as deturmined by the January 1 1997, plan.

3.

DOE shan venfy DMSA inventory upon completion of the inventory.

4.

Any unresolved movenant of maecrial by USEC into DMSA without DOE concurrence shan resultin DOE normennan of the action to NRC.

5.

DOE and USEC agros that DMSAs, as idem:15cd an segmocring drawags CSE-19601-A01 through CSE 19601-All, are r turned to DOE control and ovenaght.

Tunnie C Hodges

-- A Steve Polston DOE Sits Manager USEC Rapstacatanve

/2-3~M Dat. .

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f. -

Department of Energy Oak Ridge Operations Post Office Box 62 Oak Ridge, Tennessee 37831 8651 August 12. 1997 Mr. George P. Rifakes Executive Vice President {

United States Enrichment Corporation '

l 2 Democracy Center 6903 Rockledge Drive Bethesda Maryland 20817

Dear Mr. Rifakes:

PADUCAH AND PORTSMOUTH GASEOUS DIFFUSION PLANTS CONFIGURATION EXHIBITS A AND B TO THE LEASE-AGREEMENT BETWEEN THE UNITED CORPORATION AND THE DEPARTNENT OF ENERGY Please find enclosed documentation that defines our intentions and im31ementation methodology to ensure configuration control of the Lease Exqibits A~and B and their associated drawings. I believe it is prudent to  ;

document our management expectations to ensure that our personnel and support i personnel have access only to those documents reflecting our most recent agreements.

The enclosed document represents both your concurrence and my concurrence of these directives and expectations.

If you have any further questions or comments, please contact me at (423) 576-0892. l Sincerely.

MY W. Parks Assistant Manager Enclosures for Enrichment Facilities cc's on Page 2.

O

.. _r 9 .*. . . .

• l l. .

George' P. . Ri fakes .. August 12. 1997 cc w/ enclosures:

, J. C. Hodges. EF-22. C.103. PAD E. W.- Gillespie. EF-21. PORTS R.~M.'DeVault. EF-20/OSTI L

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n ... .

• ' LEASE EXHIBITS A AND 8 CONFIGURATION CONTROL DIRECTIVES BACK@DUND Pursuant to the Energy' Policy Act of 1992, the Departm United States Enrichment Corporation (USEC).

landlord 00E agrees. in its' role as 1 language to maintain the controlled copy of the Lease, comprising the lease Exhibits A through F. the Building lease Status drawings. the DOE Material Storage Agreements (OMSA). and the associated DMSA drawings.

Configuration control is required for Exhibit A. Exhibit 8. the DMSAs(which are supplements to Exhibit.A), and their respective drawings. This set of documents is defined for this directive as tae Lease Configuration Control Documentation. This directive shall apply only te the Lease Configuratiori Control Documentation.

~

CONTR01 AND DISTRIBUTION

'ofDOE-ORO will maintain the Lease Configuration theDocumentation.

Control master data file that com3 rises the latest re electronic media versions will derive their input from this master.30th the hardcopy a 00E-0R0 will supply ~hardcopies to USEC and each site's DOE Site Manager.

00E-0R0 will supply the electronic media version as follows:

• ' The medium used for distribution from DOE-ORD will be via compact disc-read only(CD-ROM).

DOE-ORO will send controlled copies of the electronic media version to USEC. USEC will forward copies to LMUS at each respective site.

DOE-ORO will also send controlled copies to each DDE Site Manager for distribution to each site's LMES organization.

• Both LMES and LMUS Document Control will ensure that the CD ROM is  !

maintained in their control center as the controlled electronic media site

. copy and also ensure that any CD-ROM version (s) in existence, which are not the latest issue. are returned to 00E-0R0 and USEC respectively.

• - Both server.LMES and LMUS will ensure that the CD-ROM is loaded into their net These controls ensure that all personnel will have accurate and ready '

. access to a controlled copy of the buildings, areas. and structures which are leased to USEC. owned by USEC or retained by DOE.

Both LMES and LMUS-will enter the Building Lease Status and DMSA drawings-

.into their respective document control systems at each site. Revisions to 4 these drawings will be performed per the change control procedures at each respective site. It is important to note that the drawings will be revised by DOE-ORO as approved by USEC and DOE-ORO prior.to completion of the

4 change control process. Each organization will revise their change control procedures to address these requirements. Potential discrepancies or errors observed in the documentation shall be reported.

The format of the Building Lease Status drawings and the DMSA drawings have been modified to assist in configuration control as follows:

• Signature blocks for DOE-0RD and USEC management approval have been added.

The present drawing numbers have been replaced with drawing numbers specific to each respective site (assigned by each respective site's LMES organization).

• The building lease ma) drawings reference the currently approved revision level of the Lease Ex11 bit A which is the map's main input. The DMSA .

drawings reference the currently approved agreements between DOE and USEC.

Nothing in this directive shall be construed as modifying the Lease or any exhibits thereto. ,

Subsequent documentation will address Exhibit B.

CONCURRED BY:

N. w . PA e44g

1. oe hParks De nent of Energy D[e /

Assistant Manager for Enrichment Facilities

( Li 11 George P. Rifakes Date United States Enrichment Corporation ,

Executive Vice President '

O

y - ...

4l gs@ MRO t UNITED STATES

[O j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20eeHo01 n

A,*****/' .

August 2, 1999 MEMORANDUM TO: Tom Combs, Senior Congressional Liaison  !

Office of Congressional Affairs FROM: Robert C. Pierson, Chief , e Special Projects Branch Division of Fuel Cycle Safety y '(. k -

and Safeguards, NMSS

SUBJECT:

INFORMATION REQUESTED BY MR. DWIGHT CATES Attached is the information requested by Mr. Dwight Cates, majority staff, and Ms. Edith Holleman, minority staff, of the House Commerce Committee's Subcommittee on Oversight and Investigations during our meeting of July 26,1999. This information includes:

1. Amendment requests for both gaseous diffusion plants (GDP) since NRC issued the initial cerShte for the GDPs. (Attachment 1)

2. Paducah Compliance Plan lasue 36, Revision 3,' dated July 17,'1996, (Attachment 2),

, which was in place at the time of transition on March 3,1997, and Revision 7, dated March 20,1998, (Attachment 3) which is the current version of the Paducah Compliance Plan and a chronology of the amendment requests and staff's actions on Compliance Plan issue 36 at Paducah during this time period. (Attachment 4)

3. A copy of the USEC and DOE Agreement for DOE Material Storage at the Gaseous Diffusion Plants. (Attachment 5) .

- 4.' We are not aware of any "stop work" from DOE to USEC which prevents USEC from entering the Deleased Material Storage Areas (DMSA) to complete the seismic modifications at Paducah. DOE grants authorization for USEC to enter the unleased areas to complete work on a case-by-case basis, in the case of the DMSAs in question, DOE has not authorized access because of concems with criticality safety.

Attachments:

1. GDP Amendment Requests

2. Paducah 7/17/96 CP issue 36, Rev 3 -

3. Paducah 3/20/98 CP lasue 36, Rev 7

'4. Amendment Rqst Chronology / Staff Actions on CP lssue 36

5. USEC/ DOE Agreement I

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CONGRESSIONAL CORRESPONDENCE SYSTEM i

DOCUMENT PREPARATION CHECKLIST i

! This check list is to be submitted with each document (or group of Os/As) sent for processing into the CCS.

1. BRIEF DESCRIPTION OF DOCUMENT (S) d auM On hd

2. TYPE OF DOCUMENT X CORRESPONDEN E HEARINGS (Os/As)

3. X NON-SENSITIVE DOCUMENT CONTROL X SENSITIVE (NRC ONLY) i

4. l CONGRESSIONAL COMMITTEE AND SUBCOMMITTEE (if applicable)

Congressional Committee Subcommittee .

5. SUBJECT CODES (A) }

(B)

(C)

6. SOURCE OF DOCUMENTS  !

(A) 5520 (DOCUMENT NAME (B) SCAN (C) ATTACHMENTS (D) OTHER '

7. SYSTEM LOG DATES

, (A)S//4/1f DATA OCA SENT DOCUMENT TO CCS (B) DATE CCS RECEIVED DOCUMENT (C) DATE RETURNED TO OCA FOR ADDITIONAL INFORMATION (D) DATE RESUBMITTED BY OCA TO CCS (E) DATE ENTERED INTO CCS BY (F) DATE OCA NOTIFIED THAT DOCUMENT IS IN CCS i l

COMMENTS:

RELEASE TO PDR  !

2()0092 11/0398 P.\DISRTIJS.DMS