ML20217K264

Discusses Consent to Confirmatory Order Re NRC Review of Certificate Amend Request for Paducah Gaseous Diffusion Plant,Dtd 971031.Consent to Issuance of Order Confirming Listed Commitments,Waive Right to Written Response to Order

ML20217K264
Person / Time
Site:	07007001
Issue date:	03/27/1998
From:	Paperiello C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	John Miller UNITED STATES ENRICHMENT CORP. (USEC)
References
EA-98-156, NUDOCS 9804070180
Download: ML20217K264 (5)

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p & UNITED STATES j

s" NUCLEAR REGULATORY COMMISSION

' t WASHlNGTON D.C. 2055% 0001 I 4 9 + . . , * ,o March 27, 1998 EA 98-156 I

Mr. James H. Miller j Vice President, Production U. S. Enrichment Corporation {

i 2 Democracy Center 6903 Rockledge Drive Bethesda, MD 20817

SUBJECT:

CONSENT TO CONFIRMATORY ORDER Dear Mr. Miller.

8 This letter is in reference to the Nuclear Regulatory Commission's (NRC's) review of a j certificate amendment request for the Paducah Gaseous Diffusion Plant (Paducah) dated  !

October 31,1997, submitted by your staff. The amendment request provided a Safety Analysis )

- Update (SARUP), including a new accident analysis chapter (Chapter 4). An NRC request for l

additional information (RAl) dated February 5,1998, identified questions about the conservative l nature of assumptions for the seismic accident scenario in Chapter 4. In response to the RAI, your staff reviewed Paducah's liquid uranium hexafluoride (UF.) withdrawal facilities' records and determined that the seismic accident analysis assumption of no liquid UF,in the accumulators underestimated the potential source term for the seismic accidsnt scenario. Your staff initiated immediate compensatory actions to reduce the source ierm in the accumulators.

In telephone discussions with your staff on February 18,1998, the NRC made it clear that a notification pursuant to 10 CFR 76.9(b) was warranted. Thereafter, your staff provided verbal notification to NRC Region 111 on February 19,1998, and a follow-up written report on February 20,1998, identifying the potential nonconservative assumption in the SAR updated accident analysis. Then, on February 24,1998, in telephone discussions with NRC, your staff also provided information that the withdrawal facilities' current operations were outside the Certification SAR because the Chapter 4 seismic accider' analysis assumed no liquid UF,in C-315 Building withdrawal facility's process piping, condense,,;, and accumulators.

Further compensatory actions and seismic modifications to bring the facility back into compliance with the SAR were identified in your letters of February 25,1998, March 5,1998, and March 11,- 1998. Based upon those letters, we understand that you agree to the commitments identified below. In view of the safety significance of the seismic vulnerabilities identified for the C-310/310A and C-315 Buildings at Paducah, the NRC has determined that to assure the adequate protection of public health and safety the commitments should be incorporated into the certificate. This will be effected by a Confirmatory Order Modifying Certificate (Order), following our receipt of your consent to these provisions:

9804070180 980327 PDR ADOCK 07007001

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4 r.. Mr. James H. Miller .2 y

1. .The borporation will by no later than September 30,1998, complete seismic modifications to the equipment containing liquid UF, in the C-310/310A and C-315 -

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. Buildings. Those seismic modifications will increase the seismic capacity of the~

. equipment to withstand an earthquake producing a peak ground acceleration of 0.165 g.' .

- 2. Until such time as the above seismic modifications are completed, the following .

additional administrative controls shall be followed

- a. When flow of liquid UF, has been diverted to the on-line accumulator in C-310A or C-315 for greater than one hour (nominal 2,000 and 5,000 pounds (Ibs) liquid UF, respectively at one hour), the Corporation will immediately:

i. Notify the Plant Shift Superintendent (PSS) of accumulator usage.-

li. Begin tracking of quantities by using calculated withdg.wal rates.

iii. Ensure that the PSS will initiate high priority actions for timely resolution of unscheduled outages.

- iv. ' Ensure that the Cascade Coordinator will take actions to reduce tails downflow and/or product or tails withdrawal rates to minimize accumulator use as appropriate.

- v. . Notify the NRC.

b. If the calculated accumulator inventory reaches 4,000 lbs liquid UF, in C-310A or L 10,000 lbs liquid UF, in C-315, flow of liquid UF, to the affected accumulator will -

be stopped immediately.

c. Access to the C-310/310A and C-315 Buildings will be limited to only those individuals essential to operations, inspections, or those personnel performing -

any modifications to fix the identified seismic failures.

If you consent to issuance of the Order confirming the above commitments, you are waiving

.your'right to submit a written response to the Order. In addition, you must sign the Written Response Waiver (enclosed) indicating that you agree to such commitments and retum the letter and signed waiver to me within 3 business days from the date of this letter at the U.. S. Nuclear Regulatory Commission, Two White Flint North,.11545 Rockville' Pike, Rockville, MD 20852-2738. After receiving your written consent, the NRC will issue the aforementioned Order.-

Questions conceming this letter should be address to me or Robert C. Pierson at (301) 415-7192.

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, Mr. Jim:s H. Mill:r 3 in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter will be e placed in the NRC Public Document Room.

Sincerely, it Carl J. Paperiello, Director Office of Nuclear Material Safety and Safeguards l

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Docket No. 70-7001 Certificate No. GDP-1

Enclosure:

As stated DISTRIBUTION:(TAC NO. L32057 Control No. 360S)

Docket 70-7001 NRC File Center PUBLIC EDO r# NMSS r# FCSS r# SPB r#

• SEE PREVIOUS CONCURRENCE OFC SPB* SPB* SPB* SP8*

NAME CCox:ij DHoadley DMartin RPwson DATE .

198 03/27198 03/27/98 OFC OGC* FCSS* NMS)tN O DEDR NAME LChandler ETen Eyck CJ r i HLThompson __

DATE 03/ 27/98 03/27/98 /98 / /98 C = COVER E = COVER & ENCLOSURE N = NO COPY consentitr OFFICIAL RECORD COPY p.

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Mr. J. H. Mill:r, USEC 2 f

2.- Until such time as the_ above seismic modifica', s are completed, the following additional

.,. administrative controls shall be fcilowed:

a. - When flow of liquid UFe has been diverted to the on-line accu lator in C-310A or C-315 for greater than one hour (nominal 2,000 and 5,000 unds (ibs) liquid UFe respectively at one hour), the Corporation will immediatel

1. Notify the Plant Shift Superintendent (PSS) of umulator usage.

ii. Begin tracking of quantities by using calculat withdrawal rates.

iii. Ensure that the PSS will initiate high priori actions for timely resolution of unscheduled outages.

iv. Ensure that the Cascade Coordinator i take actions to reduce tails downflow and/or product or tails wit rawal rates to minimize accumulator use as appropriate.

v. Notify the NRC.  !

b. If the calculated accumulatorinvent reaches 4,000 lbs liquid UFe in C-310A or 10,000 lbs liquid UFe in C-315, fio of liquid UF, to the affected accumulator will be stopped immediately,

c. Access to the C-310/310A d C-315 Buildings will be limited to only those individuals essential to o rations, inspections, or those personnel performing any modifications to fix the i entified seismic failures.

If you consent to issuance of the O er confirming the above commitments, you are waiving your right to submit a written res nse to the Order, in addition, you must sign the Written .

. Response Waiver (enclosed)i icating that you agree to such commitments and retum the )

letter and signed waiver to m within 3 business days from the date of this letter at the i U. S. Nuclear Regulatory ommission, Two White Flint North,11545 Rockville Pike,-

~I Rockville, MD 20852-273 After receiving your written consent, the NRC will issue the aforementioned Order.

Questione concemi this letter should be address to me or Robert C. Pierson at (301) 415- i 7192.

In accordance 'tt 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter will be placed in thez RC t*ublic Document Room.

Sincerely,

/

[ Carl J. Paperiello, Director Office of Nuclear Material Safety i

/ Docket No 70-7001 j

-/ Certificate No. GDP-1 j

Enclosure:

As stated DISTRIBUTION:(TAC NO. L32057 ControlNo. 360S)

Docket 70-7001 NRC File Center PUBLIC EDO r# NMSS r# FCSS r# SPB r#

-]

OPC sps sA_ f ,' I sps. . sps 3 f j NAME DMart ~ RP g I m1 M IE OPC 1 fr) l hCSS 2/ l NMSS '!

NAME Gad 'L; d%dbr Nr m Y Cw DATE _ s 03C998 03/DDS 03/ /98 uw C = COVER - E= & ENCLOSURE N e NO COPY a: consent.kr OPPICIAL RECORD COPY ~

'[, :Writtrn R sponsa Wrivtr

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.,. ., I, James H. Miller, Vice President, Production, United States Enrichment Corporation, hereby agree to comply with the commitments described in the Nuclear Regulatory '

' Commission's (NRC's) letter dated March 27,1998,' and agree to incorporating the commitments into a Confirmatory Order Modifying Certificate that will be effective upon issuance.- I recognize by signing below, I consent to the issuance of a Confirmatory Order Modifying Certificate with the commitments described in NRC's letter dated EtU 27,1998,'

and, by doing so, pursuant to 10 CFR 76.70, I will not have a right to submit a written response to this Order.

James H. Miller . Date l Vice President, Production J United States Enrichment Corporations l

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