ML20217N485
| ML20217N485 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant, Paducah Gaseous Diffusion Plant |
| Issue date: | 08/15/1997 |
| From: | Rifakes G UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Jazel Parks ENERGY, DEPT. OF |
| References | |
| NUDOCS 9708260198 | |
| Download: ML20217N485 (5) | |
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Unit:d States Entienment c;rooration 2 D:mocrees Center 1
6903 Rockie:ge orive Bethesaa. VC 2c817 Tel. (301) 564 3200 Fax:(301) f.64 3201 GEoRoe P. RlFAKEB 0C (301)'A32 Execuitve Vice PREstoENT, OPERATIONS Fax. (301) 564 3208 August 15,1997 Mr. Joe W. Parks Assistant Manager for Enrichment Facilities U.S. Department of Energy Oak Ridge Operations P.O. Box 2001 Ohk R.idge, TN 378318651
Dear Mr. Parks:
United States Enrichment Corporation (USEC)
Paducah Gaseous DilTusion Plant (PGDP)- Docket No. 70-7001 Portamouth Gaseous Diffusion Plant (PORTS)- Docket No. 70-7002 Proposed Revision to the USEC and DOE Agreement for DOE Material Storage at the Gaseous Diffusion Plants Enclosed for your approvalis a proposed revision to the USEC and DOE Agreement for DOE Material Storage at the Gaseous Diffusion Plants that we originally approved on May 28,1996. The enclosure proposes to revise Section 5, " Transfer of Material / Equipment." This section, in part, currently requires that a Non Destructive Assay (NDA) be performed by USEC prior to moving equipment / material out of DOE Material Storage Area (DMSA).
There appears to be no benefit derived from USEC performing an NDA prior to remosing material / equipment from a DMSA when: 1) sampling / analytical data for the uranium content of the material / equipment is available, or 2) all surfaces (internal and external) can be visually inspected and verified to be free of uranium deposits; or 3) material / equipment history exists to show that it has not been used in a UFe process stream.
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4 Mr. Joe W. Parks August 15,1997 Page Two Accordingly, the proposed revision to the joint USEC and DOE DMSA agreement will permit that a NDA does not need to be performed prior to removal of material / equipment from a DMSA if the conditions specified in the proposed revision to Section 5 are met.
If you concur with this proposed revision please sign the Enclosure and return it to USEC.
Please feel free to contact Mr. Russ Wells, USEC Senior Regulatory Engineer, at (301) 564 3245 regarding this submittal. There are no new commitments contained in this submittal.
Sincerely, l
gg-
/
e rge P. Rifakes /-
ecutive Vice Pres dent Enclosure CC:
NRC Special Projects Branch NRC Regioa Ill Omce NRC Resident inspectors, PGDP and PORTS PGDP and PORTS DOE Site Omce DOE Regulatory Oversight Manager i
USEC AND DOE Agreement for DOE Material Storage at the Gaseous Diffusion Plants
Background
Department of Energy (DOE) materials have been stored in parts of several buildings and areas currently leased I
by USEC at both gaseous diffusion plants (GDP).
At the request of USEC, pursuant to Section 3.4(b) of the Lease, DOE agrees to reduce the leaschold as l
necessary to accommodate the storage of DOE material / equipment. USEC will assume the financial and physical responsibility for, to the extent required by the Nuclear Regulatory Commission (NRC),1) completing the necessary visual inspections to identify enriched uranium deposits,2) segregating equipment cor.taining identified deposits, and 3) establishing and maintaining the necessary documentation to support these commitments.
Since the DOE formerly leased storage areas will not be leased to USEC, they are not subject to 10 CFR Part 76 requirements and NRC regulation. Additionally, activities within these areas (e g., inspections and surveyr) will conform to DOE requirements and are not subject to becoming an NRC Compliance Plan item.
Premises The following premises support the proposed resoludon of DOE material storage:
- 1. This joint USEC and DOE approach to DOE material storage does not modify, amend, or alter in any visy the Lease Agreement between USEC and DOE for the GDPs, or any memoranda of agreement, or any other agreement between USEC and DOE.
2.
DOE ectivities conducted in formerly leased storage locations, including ingress and egress both within and ev.temal to the leased buildings, will be managed in acccedance with applicable DOE requirements, This includes DOE personnel and their contractors / subcontractors. DOE assumes full responsibility for the safety, safeguards, and security of DOE activities.
- 3. All fixed asset equipment (columns, piping, electrical, etc.) located in or traversing formerly leased space (within the confines of the cascade buildings or any other leased building) remain the responsibility of USEC. All activities related to fixed asset equipment will be subject to NRC regulation. This includes USEC personnel and their contractors / subcontractors. USEC assumes full responsibility for the safety, safeguards, and security of USEC activities.
DOE Material Storane Controls 1.
Location of DOE Material / Equipment Formerly Leased Storage Areas DOE material and equipment that is either contanitated or potentially contaminated with radioactivity, or contains uranium bearing material (i.e. process equipment, low level radioactive waste, hazardous (TSCA) waste contaminated with uranium, uranium tetrafluoride (UF.), etc) will be physically located on property that was formerly leased by USEC,= If this storage is within USEC leased buildings, the floor area directly supporting the material and to the DOE /USEC formerly leased storage area boundary will he under the control
t 0
of DOE. The boundary will be clearly marked through the use of ropes, dikes, and/or signs, and'or pamted lines; and will also be marked with signs.
If the material storage area is located outside of USEC leased buildings, then the ground supporting the material is under the control of DOE and will be an area formerly leased by USEC. Boundaries are required for these that contain non containerized materials, and may be used to mark containerized material areas. Signs shall be used to identify the areas. Boundaries are not required for containerized material areas and, as an i
attemative, the containers may be labeled as DOE.
The location and boundaries of DOE formerly leased material storrige areas will be determined and established prior to certification, or addressed at a Compliance Plan activity. Establishment of new and/or the relocation of existing DOE storage areas, within USEC leased buildings aller NRC assumes regulatory oversight will be coordinated among DOE, NRC, and USEC.
2.
Protection of DOE Equipment That Contains Uranium Deposits Process equipment designed to contain UF. (i.e. compressors, converters, pipes, and valves, etc.) in DOE formerly leased storage areas will be inspected for visible deposits of enriched uranium bearmg material. The purpose of this inspection is to ensure that this equipment does not contain uranium deposits that could be easily retrieved without the use of soccial equipment. The inspection will consist of a visual check of the exterior and interior (if accessible) of applicable equipment. Dismantling of equipment for aspection is not required if equipment is found to contain visible deposits of uranium bearing materials, the equipment will be secured by a physical barrier. For man portable equipment, this barrier shall consist of a locked barrier around or within the DOE formerly leased storage area (i e., locked gate, fence, wall, etc). For non portable equipment it could be a barrier affixed to the opening of the equipment. Like other DOE equipment, this equipment will also be located within a clearly marked area which was formerly leased by USEC.
3, Maintenance of DOE MateriaVEquipment Formerly Leased Storage Areas DOE will ensure that DOE formerly leased storage areas are maintained in accordance with DOE requirements.
DOE will evaluate planned and unplanned disturbances 1) to ensure no significant risk impact on USEC's -
NRC regulated space, and 2) in accordance with DOE requirements for impact on DOE space. DOE will prohibit disturbances of formerly leased storage areas, except as necessar/ to conduct decontamination or consolidation to maintain or improve safe storage conditions, or to remon materiaVequipment from the -
buildings. USEC will be responsible for maintaining the boundary and activities required by NRC at the boundary (l.c., radiation survey s, etc.)
USEC is allowed access to the DOE storage areas to conduct essential plant operations, to conduct DOE authorized work on stored materiaUequipment, and to respond to emergenciesi If USEC access results in the unauthoiized disturbance of DOE materiaVeqv5 nent, DOE will be immediately notified by USEC.
4.
Limitations on the Addition of New don
- terials/ Equipment a
- Addition of materials to the formerly leased storage areas located within USEC leased buildings will be limited to properly characterized TSCA waste generated onsite. In the event an unforseen situation arises that requires addition of materiaVequipment to the formerly leased storage area other than properly characterized TSCA w aste, the addition will be coordinated between DOE, USEC, and NRC.
USEC can not add to these areas without express written DOE permission.
5 Transfer of Equipment / Material It may be necessary for USEC to transfer equipment and/or material out of a DOE formerly leased storage area for USEC's use after NRC emunences regulation. Transfers are contingent upon USEC performing the following: 1) obtaining DOE approval,2) measuring the uranium content of the matenal/ equipment through Non Destructive Assay (NDA), except as noted in the following paragraph,3) issuing an NRC Form 741 for l
the transfer of nuclear material (if applicable), and 4) notifying the NRC site resident prior to movement of the material / equipment into leased space.
NDA measurements are not required if any of the following conditions are satisfied: 1) samplieg/ analytical data l
for the uranium content of the material / equipment is available; or 2) all surfaces (internal and extemal) can bc visually inspected and verified to be free of uranium deposits; or 3) matenal/ equipment history exists to show that it has not been used in a UF process stream.
CONCURRED BY:
8 P4/A7
,c.
Joe W. Parks Date Ge ggP. Rifakes V
Oate Department of Energy it States Enrichnient Corporation Assistant Manager for
- c cutive Vice President Enrichment Facilities
.