ML20237B962
| ML20237B962 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 08/13/1998 |
| From: | Toelle S UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Paperiello C NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20138K686 | List: |
| References | |
| GDP-98-0177, GDP-98-177, NUDOCS 9808200124 | |
| Download: ML20237B962 (8) | |
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^USEC A ciob. en.rsy comp.ny August 13,1998 GDP 98-0177 Dr. Carl J. Paperiello Director, Office of Nuclear Material Safety and Safeguards Attention: Document Control Desk U.S. Nuclear Regulatory Commission I
Washington, D.C. 20555-0001 Portsmouth Gaseous Diffusion Plant (PORTS)
Docket No. 70-7002 '
Holdup of Uranium Enriched to Greater Than or Equal to 10 Weight Percent 235U in Process Equipment INFORMATION TRANSMITTED HEREWITH IS PROTECTED FROM PUBLIC DISCLOSURE AS CONFIDENTIAL COMMERCIAL OR FINANCIAL INFORMATION AND/OR TRADE SECRETS PURSUANT TO 10 CFR 2.790 AND 9.17(A)(4)
Dear Dr. Paperiello:
In a letter dated July 29,1998 (Reference 1), the Nuclear Regulatory Commission (NRC) referred to a Department oi' Energy (DOE) letter dated July 14,1998 (Reference 2). Both letters regard holdup of uranium enriched to greater than or equal to 10 weight percent 235U in process equipment at the Portsmouth Gaseous Diffusion Plant (PORTS) due to legacy DOE operations. Based on the information provided in Reference 1, the United States Enrichment Corporation (USEC) understands that the NRC has regulatory jurisdiction over all diffuse and inaccessible uranium enriched to equal
-to or greater than 10 weight percent 235U remaining in installed equipment in USEC-leased and NRC-certined areas and which remains inaccessible. USEC further understands that DOE has
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regulatory jurisdiction over this material which is accessible or is contained in uninstalled
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- equipment, and also over the removal ofinstalled equipment containing such material. The DOE
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regulatory jurisdiction of these activities in USEC-leased space will be in accordance with the-
- DOE /USEC Regulatory Oversight Agreement (ROA).
1 The following information clarifie: and describes the known situations which currently exist at the N/$80 l
PORTS sites involving the subject material. Now that security sweeps have been completed, USEC has reasonable assurance that.~1ditional loose items containing material greuer than USEC's l
possession limits will not be discovered in the X-326 or X-705 facilities (other than those known j
situations involving material in installed and uninstalled equipment described below). This submittal does not address the discovery of this type of material in other areas of the PORTS plant. While discovery of this type of material in areas not specifically described below has a low probability, 9808200124 9808131
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"" N e, Bethesda, MD 20817-1818 leephone$ui-w+nuu rax 301-564-3201 http://www.usec. corn j
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J Dr. Carl J. Paperiella Apgust 13,1998 GDP 98-0177, Page 2 there is a chance it may be found due to previous DOE operations. If any material in excess of USEC's possession limits is discovered in any USEC-leased and NRC-certified area, USEC will notify the PORTS NRC Resident Inspector and move the material to a DOE material storage area as soon as possible (typically within one shift, but in no case to exceed seven calendar days).
Materialin Installed Eauipment USEC has determined that the subject material (enriched to greater than or equal to 10 weight
. percent "U) that exists inside ofinstalled equipment in USEC-leased and NRC-certified space is 2
described by the following situations:
Retained inventory of solid uranium compounds plated out on the inside surfaces of both shutdown and operating equipment in the X-326 facility due to previous DOE operations to generate highly enriched uranium (HEU) in the X-326 facility.
Material held'up in installed X-705 equipment such as wash columns, calciners, and ventilation ducts.
Materialin Uninstalled Egipment USEC has determined that the subject material (enriched to greater than or equal to 10 weight percent "U) that could exist as loose items or inside ofuninstalled equipment in USEC-leased and 2
NRC-certified space is described by the following situations:
Specific components in the X-326 facility that need to be removed for maintenance or other operational purposes.
Material and equipment in the X-326 facility such as alumina traps, seal exhaust oil and GP containers from always safe vacuums that are generated as part of ongoing operations.
X-705 equipment that may need to be removed for maintenance purposes to support ongoing operations.
USEC Response to NRC Reauest Reference 1 requested that USEC provide the following information to the NRC:
1.
Submit information demonstrating inaccessibility of all uranium enriched to greater than or -
equal to 10 weight percent "U which is located in installed equipment in NRC-certified 2
areas.
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- Dr. Carl J. Paperiello August 13,1998
- GDP 98-0177, Page 3 2.
L Describe the process by which USEC would arrange for the proper control and continued assurance ofinaccessibility of the subject material, and assurance that removal of the s@ ject material from installed equipment, such as in alumina from chemical traps, and the opcmng and closure ofinstalled equipment containing s'uch material, such as in cutting into or
- resealing shutdown cascade equipment, would be conducted under DOEjurisdiction.
3.
Provide the available measured quantities and assays of the subject material contained in installed equipment and piping and describe the controls relied upon to ensure its protection.
-4.
The NRC has determined that USEC must account for all such material located in NRC-certified areas in USEC internal MC&A records and inventory reports to the Nuclear Material Management and Safeguards System (NMMSS).
5.
. Describe the applicable material control and accountability (MC&A) and reporting requirements USEC would apply to transfer actions associated with the removal ofinstalled equipment.
For the X-326 Building, USEC's response to the NRC request in Item 1 above is contained in
. Enclosure 2, the response to Item 2 above is contained in Enclosure 3, the response to Item 3 above is contained in Enclosure 4, the response to Item 4 above is comained in Enclosure 5, and the
. response to Item 5 is contained in Enclosure 6.
The X-705 Building presents a much different situation than the X-326 Building in that the amount of material holdup in X-705 is very small. The amount of holdup of material in X-705 is provided in Enclosure 9 along with a description of the associated controls.
Due to the nature and importance of this information and its applicability to actions or agreements
. between NRC, DOE and USEC, USEC requests that NRC and DOE (by receir. of a copy of this submittal) review the information contained within and provide positive confirmation to USEC that i
the information regarding these actions is acceptable to NRC and DOE.
Enclosures 2 through 10 of this submittal contain confidential commercial or financial information or trade secrets that are exempt from public disclosure pursuant to Section 1314 of the Atomic Energy Act of 1954, as amended, and 10 CFR 2.790 and 9.17(a)(4). USEC requests that Enclosures 2 through 10 of this submittal be withheld from public disclosure. The enclosed affidavit provides the information required by 10 CFR Q 2.790(b)(4) with respect to this request.
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- 4 Dr. Carl J. Paperiello
' August 13,1998 GDP 98-0177, Page 4
. A list of new commitments made in this submittal is contained in Enclosure 10. Any questions
' related to this subject should be directed to Mark Lombard at (301) 564-3248.
F Sincerely, A
- $. N.
/E Steven A. Toelle.
Nuclear Regulatory Assurance and Policy Manager
Enclosures:
- 1. Affidavit of Steven A. Toelle Supporting Request to. Withhold From Public Disclosure Certain Portions of the Portsmouth Gaseous Diffusion Plant Letter GDP 98-0177
- 2. USEC Response to NRC Request, Item 1
- 3. USEC Response to NRC Request, Item 2 -
. 4. USEC Response to NRC Request, Item 3
- 5. USEC Response to NRC Request, Item 4
- 6. USEC Response to NRC Request, Item 5
. 7. -X-326 NDA Data - Quantitative 1
- 8. X-326 NDA Data-Assay.
- 9. X-705 Building IIoldup and Associated Controls
- 10. List of New Commitments Made in This Submittal -
cc: Mr. Robert C. Pierson, NRC NRC Region III Office NRC R.esident Inspector - PORTS -
NRC Resident Inspector-PGDP Mr. Randall M. DeVault, DOE 1
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Dr. Chr! J. Paperiello August 13,1998 GDP 98-0177, Page 5
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REFERENCES
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' Letter from Robert C. Pierson (NRC) to James H. Miller (USEC), "Portsmouth Gaseous Diffusion Plant - Holdup of Uranium Enriched Above 10 Weight Percent U-235 in Process Equipment (TAC No. L32088)," July 29,1998.
2.
Letter from Joe W. Parks (DOE) to Elizabeth Q. Ten Eyck (NRC), " Regulatory Jurisdiction of '
2 Legacy "U Holdup at the Portsmouth Gaseous Diffusion Plant," July 14,1998.
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l GDP 98-0177 Page 1 of 3 AFFIDAVIT OF STEVEN A. TOELLE SUPPORTING REQUEST TO WITHHOLD FROM PUBLIC DISCLOSURE CERTAIN PORTIONS OF THE PORTSMOUTH GASEOUS DIFFUSION PLANT LETTER GDP 98-0177
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l I, Steven A. Toelle, swear and affirm that I am Nuclear Regulatory Assurance and Policy Manager, United States Enrichment Corporation (USEC), and do hereby affirm and state:
1.
I have been authorized by USEC to (a) review the information owned by USEC which I
is referenced herein relating to the Portsmouth Gaseous Diffusion Plant and which USEC seeks to have withheld from public disclosure pursuant to section 147 of the Atomic Energy Act (AEA), as amended,42 U.S.C.
2167, and 10 CFR 2.790(a)(3),2.790(a)(4),2.790(d)(1) and 9.17(a)(4), and (b) apply for the withholding of such information from public disclosure by the Nuclear Regulatory Commission (NRC) on behalf of USEC.
2.
Pursuant to 10 CFR 76.35(h), USEC has prepared Letter GDP 98-0177, which describes the measures used by USEC at the Portsmouth plant to control and account for special nuclear material enriched to equal to or greater than 10 weight percent 235U that USEC uses, possesses, or has access to. USEC is submitting this information in Enclosures 2 through 10 to Letter GDP 98-0177.
3.
10 CFR 2.790(d)(1) states that correspondence t n. eports to or from the NRC containing information conceining an applicant's material control and accounting program for special nuclear material not otherwise designated as Safeguards Information or classified as National Security Information or Restricted Data are deemed to be confidential commercial or financial 1
l information exempt from public disclosure. Accordingly, USEC requests that Enclosures 2 through I
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Enclos~ure 1
. GDP 98-0177 Page 2 of 3 10 to Letter GDP 98-0177 be withheld from public disclosure pursuant to section 147 of the AEA, 42 U.S.C. { 2167, and 10 CFR 2.'790(a)(3),2.790(d)(1) and 9.17(a)(4).
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4.
Pursuant to 10 CFR 76.35(1), USEC has prepared Enclosures 2 through 10 to Letter GDP 98-0177, which describe the measures used by USEC at the Portsmouth plant to protect special nuclear material enriched to equal to ci greater than 10 weight percent 235U.' Enclosures 2 through 10 to Letter GDP 98-0177 describe the measures used by USEC at the Portsmouth plant to physically protect and control and account for the subject special nuclear material that USEC uses,
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possesses, or has access to.
5.
10 CFR 2.790(d)(1) states that correspondence and reports to or from the NRC which contain information concerning an applicant's physical protection or material control and accounting program' for special nuclear material not otherwise designated as Safeguards Information or classified as National Security Information or Restricted Data are deemed to be confidential commercial' t-financial information exempt from public disclosure. Enclosures 2 though 10 to Letter GDP.98-0177 contain such information. Accordingly, USEC requests that 2 through' 10 to j
Letter GDP 98-0177 be withheld from public disclosure pursuant to section 147 of the AEA,42 l
.U.S.C.
2167, and 10 CFR 2.790(a)(3),2.790(d)(1) and 9.17(a)(4).
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GDP 98-0177 Page 3 of 3 ~
6.
Steven A. Toelle hereby confirms that I am Nuclear Regulatory Assurance and Policy Manager of USEC, that I am authorized on behalf of USEC to review the information attached hereto and to sign and file with the Nuclear Regulatory Commission this affidavit and the attachments hereto, and that the statements made and matters set forth herein are true and correct to the best of my knowledge, information, and belief.
S. 4.
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Steven A. Toelle On this 13th day of August 1998, the authorized individual signing above personally appeared before me, is known by me to be the person whose name is subscribed to within the instrument, and acknowledged that he executed the same for the purposes therein contained.
In witness hereofI bereunto set my hand and official seal.
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barmen N. Dobsod, Notary Public l
(tate of Maryland, Montgomery County My commission expires January 28,2002
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