ML20216J749
| ML20216J749 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 03/17/1998 |
| From: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20216J744 | List: |
| References | |
| NUDOCS 9803240065 | |
| Download: ML20216J749 (4) | |
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, suog p *- I*, UNITED STATES s p NUCLEAR REGULATORY COMMISSION
~ * ' WASHINGTON, D.C. 20555-0001
/ March 17, 1998 DOCKET: 70-7002 CERTIFICATE HOLDER: United States Enrichment Corporation Portsmouth Gaseous Diffusion Plant Portsmouth, Ohio
SUBJECT:
COMPLIANCE EVALUATION REPORT: APPLICATION DATED FEBRUARY 3,1998, HIGHLY ENRICHED URANIUM CYLINDER VALVE REPLACEMENT BACKGROUBQ On February 3,1998, United States Enrichment Corporation (USEC) submitted a certification amendment request (CAR) to temporarily, approxiniately six weeks, convert the X-705 South Annex from Nuclear Regulatory Commission (NRC) to Department of Energy (DOE) Regulatory Oversight Agreement (ROA) regulation for the replacement of inoperable highly enriched uranium (HEU) cylinder valves.
The need to convert the X-705 South Annex to DOE ROA regulation was first identified by a USEC letter dated July 30,1997, addressed to DOE with copy to the NRC. The letter identified the need for the conversion of the X-705 South Annex temporarily for HEU activities. The letter also contained a conceptual plan of action for the conversion and subsequent re-establishment of NRC regulation. In a letter dated September 10,1997, from the NRC to USEC, the NRC requested furtherjustification and a CAR providing further detail for the conceptual plan of action.
The February 3,1998, USEC letter was the CAR with further justification.
Possession limits defined in the Certificate of Compliance Safety Analysis Report (SAR) Table 1-3 for uranium enriched in isotope 235 from 10 percent up to 20 percent by weight and for uranium enriched in isotope 235 to greater than 20 percent by weight would prohibit the replacement of inoperable HEU cylinder valves in NRC regulated space. Under the " Joint Statement of Understanding Between Nuclear Regulatory Commission and Department of Energy on implementing Energy Policy Act Provisions on Regulation of Gaseous Diffusion Uranium Enrichment Plants," DOE retains title and possession of uranium enriched to 20 percent or more 2"U and is solely responsible for providing for, establishing and maintaining nuclear safety, safeguards, and security controls applicable to such uranium.
DISCUSSION The changes proposed in USEC's CAR involve SAR Section 3.7, "HEU DOWNBLENDING ACTIVITIES," Fundamental Nuclear Material Control (FNMC) Plan Section 2.2.7, *MBA Structure," and the Plan for Achieving Compliance at the Portsmouth Gaseous Diffusion Plant 2
(Compliance Plan) Issue A.4.," Possession of Uranium Enriched to Greater than 10% "U.*
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- 2 During the DOE ROA regulated HEU downblending activities, as described in SAR Section 3.7, several HEU cylinder valves became inoperable. To complete the downblending activities, those cylinders need the valves replaced. Historically, valve replacement on cylinders with solid UFe and whose internal pressure could not be determined was planned for the X-705 South Annex as described in SAR Section 3.3.1.3.2.3, " South Annex Operations." The basis for valve replacement in the South Annex is that replacement of the valve presents a risk to the worker from fluorine gas. Exposed to the alpha radiation from the radioactive decay of uranium and its daughter products, UFe will slowly disassociate into UF5 and fluorine gas. If a cylinder's intemal pressure cannot be determined because of an inoperable valve, the amount of fluorine gas cannot be determined. The ventilation and industrial hygiene practices in the South Annex protect the workers from fluorine out gassing. The criticality safety contingency of moderation control would be maintained through engineering and administrative controls for the short period of the valve replacement. With the NRC assuming regulatory oversight of activities in the X-705 South Annex on March 3,1997, the possession limits from SAR Table 1-3 prohibit HEU activities under NRC regulations. Therefore, the proposed HEU cylinder valve replacement cannot take place in the X-705 South Annex under NRC regulations.
The description in SAR Section 3.7 of HEU downblending activities included anticipated evolutions needed to complete the DOE ROA reguhted activity. Included were provisions for temporary reversion of portions of the X-705 Building to DOE .ROA regulations for decontamination of HEU oearing equipment with deposits in excess of the SAR Table 1-3 possession limits. The need to replace inoperable valves on HEU cylinders was not anticipated and, therefore, that activity was not described in SAR Section 3.7. In the CAR, USEC provided a change to SAR Section 3.7 recognizing the HEU cylinder valve replacement under DOE ROA regulations as an anticipated evolution and provided a description of that activity, similar to the description in SAR Section 3.3.1.3.2.3, " South Annex Operations."
Also included in the request, USEC provided a revision to Section 2 of the FNMC Plan and related Issue A.4 of the Compliance Plan to describe access control into the X-705 facility during the period of six weeks that the areas are temporarily converted to DOE ROA regulation, to verify that no theft or diversion of fissile material occurs during the valve replacement activities, and to certify that changing the status of the areas will not cause PORTS to exceed the HEU possession limit before retuming the areas to NRC regulation. PORTS will perform a static specialinventory of the areas at the end of the transition to confirm the facility status.
In response to the September 10,1997, letter from the NRC to USEC, DOE reviewed and approved the transition of the X-705 South Annex. Also in response to the September 10,1997 letter, USEC provided assurances in the February 3,1998, CAR letter that the transition would not interfere with NRC regulated activities for the time period of transition.
ENVIRONMENTAL REVIEW lssuance of the requested amendment to the Portsmouth Certificate of Compliance (GDP-2), to amend Sections 3.7.1 and 3.7.2 of the SAR, Section 2.2.7 of the FNMC Plan, and Issue A.4 of the Compliance Plan, is subject to the categorical exclusion provided in 10 CFR 51.22(c)(10) and will not have a significant impact on the human environment. Therefore, in accordance with 10 CFR 51.22(b), neither an environmental assessment nor an environmental impact statement is required for the proposed action.
3 CONCLUSION The proposed change to the GAR is a description of HEU cylinder valve replacement as a DOE ROA regulated activity. Cylinder valve replacement in the X-705 South Annex is already described in SAR Section 3.3.1.3.2.3 but possession limits for HEU prohibit that activity under NRC regulations. The SAR change would include the HEU cylinder valve replacement with other HEU evolutions that provide for transition of portions or all of the X-705 Building to DOE ROA regulations. Without the certificate amendment, the HEU valve replacement would have to be conducted in some other DOE ROA regulated area not currently analyzed for valve replacement.
The staff concludes that the proposed changes to the SAR, FNMC Plan, and the Compliance Plan provide an acceptable rationale and justification for the process to temporarily convert the X-705 facility from NRC to DOE ROA regulation so that replacement of inoperable cylinder valves can occur without any implication on material possession limits in the Certificate of Compliance SAR. The staff determines that these changes establish an adequate safety basis for the transition activities and do not decrease the effectiveness of the facility's safeguards program, and recommends that the revised changes be approved.
Princioal Contributor.g Charlie Cox Thomas Pham DISTRIBUTION. (Control No. 220S)
Docket 70-7002 PMDA NRC File Center PUBLIC YFaraz,PM DHartland, Rlli WSchwink,FCOB NMSS r# NMSS dir. ofc. r/f FCSSr# SPB r/f FCOB PHiland. Rlli Riti TPham,FCLB
- See previous concurrence OFC *SPB SPB E SPB SSB FCLB E FCLB NAME CCorij DHoadley DMartin eerson Madams MWebeh DATE 2/24/98 2/25/98 2/25/98 D/ k /98 2/26/98 3/3/98 C = COVER E = COVER & ENCLOSURE N = NO COPY OFFiclAL RECORD COPY
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3 NCLUSION The sed change to the SAR is a description of HEU cylinder valve replacement as a DOE ROA regu activity. Cylinder valve replacement in the X-705 South Annex is already described in Section 3.3.1.3.2.3 but possession limits for HEU prohibit that activity under -
NRC regulations. he SAR change would include the HEU cylinder valve replacement with other HEU evolutions that vide for transition of portions or all of the X-705 Building to DOE ROA regulations. Without the ificate amendment, the HEU valve replacement would have to be conducted in some other OA regulated area not currently analyzed for valve replacement.
The staff concludes that the propo anges to the SAR, FNMC Plan, and the Compliance .
Plan provide an acceptable rationale an iqstification for the process to temporarily convert the X-705 facility from NRC to DOE ROA regulaff so that replacement of inoperable cylinder valves can occur without any implication on material po ssion limits. The staff determines that these changes establish an adequate safety basis for the sition activities and do not decrease the effectiveness of the facility's safeguards program, and mmends that the revised changes be approved.
Pnncipal Contnbutors Charlie Cox Thomas Pham j
DISTRIBUTION:(ControlNo. 220S)
Docket 70-7002 PMDA NRC File Center PUBLIC YFaraz,PM DHartland, Rill WSchwink,FCOB NMSS r# NMSS dr. ofc. r# FCSS r# SPB r# FCOB PHiland, Rlli Rlli TPham,FCLB OFC SPB tSPlil h SPB , SPB FCLB b FCLB NAME Chrij Hoadley RPierson dam MWeber DATE O-G@8 h /NB 'd $/98 / /98 7 TM/98 1 / 83/98 C = COVER E = COVER & ENCLOSURE N = NO COPY OFFICIAL RECORD COPY a:\x705cer2.por o