ML20216G242
| ML20216G242 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant, Paducah Gaseous Diffusion Plant |
| Issue date: | 04/15/1998 |
| From: | John Miller UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| EA-97-447, EA-97-448, GDP-98-0057, GDP-98-57, NUDOCS 9804200071 | |
| Download: ML20216G242 (4) | |
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O USEC i
A Global Energy Company JAMES H. MILLEh Dir: (301) 564-3309 VICE PRESIDENT, PRODUCTION Fax: (301) 571-8279 April 15,1998 GDP 98-0057 United States Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001 Paducah Gaseous Diffusion Plant (PGDP)
Portsmouth Gaseous Diffusion Plant (PORTS)
Docket Nos. 70-7001 and 70-7002 Reply to Notice of Violations (NOVs) EA 97-4478 and EA 97-448 Nuclear Regulatory Commission (NRC) letter dated March 24,1998, transmitted NOVs concerning Safety Analysis Report Update (SARUP) submittals for PGDP and PORTS which did not meet the requirements in the compliance plans for these facilities.
USEC's reply to this NOV is enclosed. As indicated in the referenced NRC letter, the reason for the violations, the corrective actions taken, and the corrective actions to prevent recurrence are adequately addressed in USEC's letter to NRC dated December 24,1997 (see USEC letter GDP 97-0203).
The referenced NRC letter requested USEC to provide NRC with a detailed schedule and plan for completion of SAR Chapter 3 upgrades by April 23,1998. Please note that on March 30,1998, in response to a related request for additional information from NRC', USEC submitted to NRC a Chapter 3 update project schedule (see USEC letter 98-0062).
Additionally, the referenced NRC letter requested USEC to communicate any changes affecting SARUP Chapter 4 to NRC within thirty (30) days of the date that USEC identifies such changes.
Pursuant to Compliance Plan Issue 2, USEC is required to inform NRC of any changes that are made to the SARUP amendment, in accordance with 10 CFR 76.68. that could render the SARUP to be
" incorrect, inaccurate, or incomplete, until such time as the SARUP is approved by NRC. Therefore,
'See NRC letter dated February 27,1998,"Paducah and Portsmouth Certification Amendment Request - Update the Application Safety Analysis Report," from Charles Cox to James 11. Miller.
h 6903 Rockledge Drive. Bethesda. MD 20817-1818 Telephone 301-564-3200 Fax 301-564-3201 http://www.usec.com j
Omces in Livermore CA Paducah, KY Portsmouth, OH Washington. DC
-a 9804200071 900415 l
PDR ADOCK 07007001 C
United States Nuclear Regulatory Commission April 15,' 1998 GDP 98-0057, Page 2 USEC is unsure as to the basis for NRC's request that such changes be communicated to NRC within thirty (30) days of the date that USEC identifies such ciianges. USEC would like to have further discussions with NRC on this request.
There are no new commitments in this submittal. Ifyou have any questions regarding this submittal, please contact Steve Toelle at (301) 564-3250.
Sir erely, J
es II. Miller ice President, Production Enclosure cc: NRC Region Ill Administratcr NRC Senior Res: dent inspectors - PGDP and PORTS NRC Special Projects Branch NRC Director, Division of Fuel Cycle and Safeguards, NMSS t
GDP 98-0057 Page lof 2 UNITED STATES ENRICllMSNT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATIONS (NOVs) EA 97-447 and 97-446 Restatement of Violations Paducah and Portsmouth Gaseous Diffusion Plants Certificate of Compliance Condit. ion 8 requires, in part, that the Corporation shall conduct its operations in accordance with the statements and representations contained in the Compliance Plan submitted July 12,1996, July 15,1996, July 18, 1996, and the revision submitted August 1,1996.
Paducah and Portsmouth Compliance Plan Issue 2 " Update the Application Safety Analysis Report" Plan of Action and Schedule Item 3 and item 4 require, in part, that by no later than August 17,1997, USEC shall submit an amendment to their Certification application which includes:
1).
identification of all information, findings, and recommendations which indicate differences between the DOE site-wide Safety Analysis Report and the USEC Application for Certification; 2) an evaluation of the effects of those differences on the safety of workers, and off-site members of the public; and 3) proposed modifications to the compliance certificate and/or facility, including proposed modifications to the Application SAR and Technical Safety Requirements (TSRs).
4) proposed resolution of matters contained in the DOE-approved site-wide Safety Analysis Report (SAR) not incorporated by USEC in its request for amendment of their Application for Certification.
Contrary to the above, on August 17,1997, USEC did not submit an amendment to the certification application which includes: 1) identification of all information, findings, and recommendations indicating differencu between the DOE site-wide Safety Analysis Report and the USEC Application for Certification; 2) an evaluation of the effects of those differences on the safety of workers, and off-site members of the public; 3) proposed modifications to the compliance certificate and/or facility, inchiding proposed modifications to the Application SAR and TSRs; and 4) proposed resolution of matters contained in the DOE-approved site wide SAR not incorporated by USEC in its request for amendment. Specifically, the August 18,1998 USEC submittal did not include Chapter 3 " Facility and Process Description" nor a complete Chapter 4 " Hazard and Accident Analysis" which addressed the four above items.
l USEC RESPONSE I.
Reasons for the Violations USEC letter to NRC dated December 24,1997 (see USEC letter GDP 97-0203), adequately addresses the reasons for these violations.
II. Corrective Actions Taken and Results Achieved j
On October 31,1997. USEC submitted the remaining portions of the SARUP, with the exception of Chapter 3, to NRC (see USEC letters GDP 97-0188 and 97-0189).
l On March 30,1998, USEC submitted a Certificate Amendment Request which proposed to revise the PGDP and PORTS Certificates of Compliance to add a new condition related to the Chapter 3 update (see USEC letter GDP 98-0059).
On March 30,1998, USEC submitted to the NRC a plan and schedule for completion of the update to Chapter 3 (see USEC letter 98-0062).
Additional corrective actions related to these violations are described in USEC letter to NRC dated December 24,1997.
IV. Corrective Action to Be Taken to Avoid Further Violation No additional corrective actions are required.
V.
Date of Full Compliance As previously noted, on October 31,1997, USEC submitted the remaining portions of the SARUP to NRC. Additionally, on March 30,1998, USEC submitted to NRC the plan and schedule for completing the Chapter 3 update and a CAR to add a new condition to the PGDP and PORTS Certificates of Compliance for the Chapter 3 update. Therefore, full compliance has been achieved.
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