ML20248L650
| ML20248L650 | |
| Person / Time | |
|---|---|
| Issue date: | 03/06/1998 |
| From: | Weber M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Cygelman A ENERGY, DEPT. OF |
| References | |
| NUDOCS 9803230417 | |
| Download: ML20248L650 (19) | |
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M1 UNITED STATES
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j NUCLEAR REGULATORY COMMISSION i
t WASHINGTON, D.C. 20525 0001 March 6, 1998 Mr. Andre Cygelman U.S. Department of Energy 1000 Independence Avenue Rm. 6G050 Mailstop MD3 Washington, D.C. 20585
SUBJECT:
ABILITY TO LICENSE MIXED OXIDE FUEL FABRICATION OPERATIONS WITH COLLOCATED. NON-LICENSED NUCLEAR OPERATIONS, DEPARTMENT OF ENERGY (DOE) TASK ORDER NUMBER 97-1
Dear Mr. Cygelman:
The Office of Fissile Materials Disposition (MD) within DOE has informed NRC that it is currently evaluating the siting of prospective operations for effecting the disposition of surplus plutonium. The Fuels and Materials Examination Facility (FMEF) at the Hanford Reservation is being considered as a candidate for one two, or three sets of operations. These operations are the pit disassembly and conversion, the plutonium immobilization, and the mixed oxide (M0X) fuel fabrication operations.
MD anticipates, assuming future legislation grants NRC licensing authority, that the MOX fuel fabrication operations would be licensed by NRC. but the other two operations would not.
MD has requested that NRC discern whether collocating licensed and non-licensed operations that involve similar types of hazards and risks in the FMEF is possible.
This letter and its enclosure serve to respond to this request and close out DOE Task Order Number 97-1.
j l
DOE briefed NRC staff on the existing FMEF facility and on the proposed I
conceptual approaches for collocation on November 18. 1997. At this briefing, l
DOE specifically indicated that four requests be addressed in NRC's response to this task order.
DOE has submitted. by informal note dated December 5.
1997, a description of the FMEF and two conceptual approaches for collocation in this facility.
Staff has reviewed this information in a limited sense realizing that necessary future legislation may specify details of NRC licensing authority and that the detailed design review and license conditions will be developed w!.an the license application is reviewed.
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Mr. Andre Cygelman 2 The staff's general conclusion is that no issues have been identified to date which would prevent collocation of the licensed and non-licensed operations at the FMEF. However, based on our experience at commercial facilities and the gaseous diffusion plants, regulation of a collocated M0X fuel fabrication facility may be complicated and burdensome, depending on the degree of integration between the M0X facility and other nuclear facilities that would not be regulated by NRC. The enclosure to this letter. elaborates on the basis for this conclusion. We would suggest that DOE carefully consider these complications and the attendant tradeoffs in planning and designing the M0X fuel fabrication facility. This letter responds to your request and closes DOE Task Order Number 97-1. If you have any questions regarding this matter, please contact me at 301-415-7190. Sincerely, /s/ Michael F. Weber, Chief Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS
Enclosure:
As stated Distribution: NRC File Center PUBLIC NMSS R/F FCSS R/F FCLB R/F BBrach CEmeigh VPerin MWeber KWinsberg RFonner ED0 r/f
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~. Mr. Andre Cygelman 2 The staff's general conclusion is that no issues have been identified to date which would prevent collocation of the licensed and non-licensed operations at the FMEF. However, based on our experience at commercial facilities and the gaseous diffusion plants regulation of a collocated M0X fuel fabrication facility may be complicated and burdensome, depending on the degree of integration between the M0X facility and other nuclear facilities that would not be regulated by NRC. The enclosure to this letter elaborates on the basis for this conclusion. We would suggest that DOE carefully consider these complications and the attendant tradeoffs in planning and designing the M0X fuel fabrication facility. This letter responds to your request and closes DOE Task Order Number 97-1. If you have any questions regarding this matter, please contact me at. 301-415-7190. Sincerely. Q.jl.f/vil" Michael F. Weber Chief Licensing Branch Division of Fuel Cycle Safety and Safeguards. NMSS
Enclosure:
As stated
NUCLEAR REGULATORY COMMISSION RESPONSE l TO DEPARTMENT OF ENERGY QUESTIONS REGARDING POTENTIAL COLLOCATION OF A MOX FUEL FABRICATION FACILITY WITH OTHER NUCLEAR FACILITIES: RESPONSE TO DOE TASK ORDER 97-1 January 1998 Reauest No.1: Specify what requirements (if any) are needed to obtain, establish, and maintain an NRC license in the Fuels and Materials Examination Facility (FMEF).
Response
At this time, supplemental legislation is required for NRC to license a mixed oxide (MOX) fuel fabrication facility at the FMEF or other sites owned and operated by the Department of Energy. NRC's response assumes that necessary legislation granting NRC regulatory authority will be obtained and that the legislation would not substantially alter the existing regulatory framework that would otherwise apply to a commercial plutonium processing facility. The MOX fuel fabrication facility would be licensed under 10 CFR Part 70, along with other substantive requirements such as in 10 CFR Parts 19,20,51,73,74 and 75. NRC assumes that it will regulate the MOX fuel fabrication facility and DOE will regulate the safety and safeguards associated with transportation. As DOE is aware, NRC is currently revising 10 CFR Part 70 and implementing guidance. The Commission has directed the NRC staff to provide a draft proposed rule for Commission consideration by the end of July 1998. Following Commission review, proposed revisions to Part 70 would be published for public comment. Based on the current schedule, revisions to Part 70 could be promulgated in mid to late 1999. NRC may also need to revise 10 CFR Part 51 to add consideration of environmental impacts associated with the use of MOX fuelin commercial power reactors. However, this rulemaking would not be expected to directly impact NRC licensing of a MOX fuel fabrication facility at FMEF. NRC plans to rely to the extent practicable, at least in part, on DOE's Programmatic Environmental Impact Statement (PElS) on Plutonium Disposition and site specific environmental evaluations prepared by DOE in accordance with the National Environmental Policy Act (NEPA). These evaluations would be supplemented by NRC environmental analysis in accordance with NEPA to the extent necessary to support rulemaking and licensing decisions. NRC would review a license application for MOX fuel fabrication when it is received. The licensing review would include both safety and safeguards aspects of the proposed l fabrication facility. Specific conditions could be established in the license as legally l l ENCLOSURE l l ..-]
2 enforceable requirements. The license review would be conducted using a standard review plan (SRP) that would be specifically developed for a MOX fuel fabrication . facility. The SRP would be similar to the draft SRP that will be publisned with the proposed revisions to Part 70. However, the MOX SRP will contain acceptance criteria - that are tailored to plutonium process!ng facilities. The following is a ist of NRC regulatory guides for plutonium processing that were published in the 1970s. These regulatory guides would need to be w. J aed, rewritten, - and reissued, as appropriate, to reflect changes in the regulatory framework and - technology that have occurred over the last 20 years. Additional regulatory guidance
- may be required beyond those documents and topics identified below.
3.3 - Q6ality Assurance Program Requirements for Fuel Reprocessing Plants and for Plutonium Processing and Fuel Fabrication Plants 3.7 - Monitoring of Combustible Gases and Vapors in Plutonium Processing and Fuel Fabrication Plants 3.10 - Liquid Waste Treatment System Design Guide for Plutonium Processing and Fuel Fabrication Plants 3.12 - General Design Guide for Ventilation System of Plutonium Processing and Fuel Fabrication Plants 3.16 - General Fire Protection Guide for Plutonium Processing and Fuel Fabrication Plants 3.21 - Quality Assurance Requirements for Protective Coatings Applied to Fuel Reprocessing Plants and to Plutonium Processing and Fuel Fabrication Plants 3.29 - Preheat and Interpass Temperature Control for the Welding of Low-Alloy Steel for Use in Fuel Reprocessing Plants and in Plutonium Processing and Fuel Fabrication Plants 3.40 - Design Basis Floods for Fuel Reprocessing Plants and Plutonium Processing and Fuel Fabrication Plants 3.47 - Nuclear Crit!:ality Control and Safety of Homogeneous Plutonium-Uranium Fuel Mixtures Outside Reactors NUREG-1280 - Standard Format and Content Acceptance Criteria for the Material Control and Accounting Reform Amendment i.. 1
3 Reauest No. 2: Identify any precedents where NRC has issued license (s) for similar 3 situation (s). j
Response
There have been numerous examples in the past of collocated licensed and license-exempt activities. These examples, which are discussed in this response and the response to Request No. 4, are at the commercial nuclear fuel fabrication facilities and ) at the gaseous diffusion plants. Activities regulated by the NRC at these facilities took place in close proximity with other nuclear activities that were subject to regulation by DOE or the Energy Research and Development Administration. These examples offer i experience in dealing with collocation issues and demonstrate that effective regulation I of collocated facilities is possible for both nuclear safety and safeguards programs. The most recent collocation example is the NRC's certification of the gaseous diffusion plants (GDPs). The Atomic Energy Act of 1954, as amended by the Energy Policy Act of 1992, created the United States Enrichment Corporation (USEC), a government corporation, for the purpose of managing and operating the GDPs previously owned and operated by the Department of Energy (DOE). The Energy Policy Act also required that NRC establish standards for regulating the GDPs in order to protect the worker and public health and safety and to provide for the common defense and security. NRC published 10 CFR Part 76, " Certification of Gaseous Diffusion Plants," on September 23,1994 (59 FR 48944). The Atomic Energy Act of 1954, as amended by the Energy Policy Act of 1992 and the USEC Privatization Act of 1996, also required NRC to recertify the GDPs' compliance with these standards on a periodic basis, but not less than every five years. After disposition of public comments received in response to NRC's Notice of Certificate Decision (61 FR 9360, September 16,1996), NRC issued a Certificate of Compliance (which became effective on March 3,1997) and a Compliance Plan for each plant on November 26,1996. j l Throughout this transitionary period from DOE to NRC regulation of the GDPs, NRC and DOE entered into a series of Memoranda of Understanding (MOUs) to clarify the j regulatory roles for different activities for each 9qency. Thece agreements were necessary not only because of the mutual desire to effect a smooth transition to external regulation, but also because DOE maintains regulatory oversight for certain { operations at the site that remain under DOE Jurisdiction. This is one of the complications associated with collocation of nuclear facilities, which can be somewhat challenging when exempt activities occur within larger areas that are subject to NRC regulation. NRC currently maintains regulatory oversight for nuclear safety, safeguards, and security for the leased portions of the GDPs, with the exception of the Highly Enriched i
i 4 Uranium (HEU) Refeed activity in Buildings X-326 and X-705 at the Portsmouth GDP. NRC's certification of the GDPs is in part conditioned upon USEC adherence to a Compliance Plan prepared and approved by DOE for each GDP. The Compliance Plans document binding commitments for actions and schedules to achieve full compliance with NRC regulatory requirements. Modifications to the Compliance Plans require DOE approval prior to submittal to NRC for final approval. As defined in the various MOUs between NRC and DOE regarding regulatory oversight of the shared facilities, the following list describes some of the agreements which are of particular interest in considering the complications associated with collocation of nuclear facilities under separate regulatory regimes: DOE retains responsibility for all access authorization programs with respect to the facilities leased by USEC. DOE is responsible for the administrative determinations relating to granting, suspending, adjudicating, and denying a l security clearance, and for reinvestigating an individual's background for ) continued access. NRC is responsible for granting security facility approvals and for regulating the establishment of an information security program to ensure that Restricted Data, including both information and equipment, are appropriately classified and protected with respect to the facilities leased by USEC. . DOE and NRC coordinate with each other on proposed enforcement actions involving those shared systems or areas in Buildings X-326 and X-705 at the Portsmouth GDP involving HEU operations. USEC is responsible for all system components required for USEC low enriched uranium (LEU)/GDP operability. These components are subject to NRC inspection and enforcement, although they may be physically located in DOE space. l In accordance with the Federal Radiological Emergency Response Plan l (FRERP), NRC is the Lead Federal Agency (LFA) for an emergency involving DOE-owned GDPs operating under NRC regulatory oversight. If the origin of the emergency is determined to be in the DOE portion of the plant, then the LFA role l would be transferred to DOE. DOE and NRC have developed appropriate joint '~ procedures which will ensure compatibility in response to emergencies in leased areas under NRC regulatory oversight. l The emergency planning requirements for GDPs, including offsite notifications and classification levels and their corresponding emergency action levels, are in accordance with the site emergency plans and procedu.es which were coordinated among shared site regulators and tenants prior to implementation. In addition, the NRC has two classification levels for emergencies under 10 CFR Part 76, consistent with 10 CFR Part 70, whereas DOE has a three-tier classification.
5 DOE does not conduct inspections of nuclear safety, safeguards, and security in leased areas (i.e., those areas that are subject to NRC regulation), except where there is a shared safety, safeguards, or security feature in USEC leased space. However, DOE personnel may, during the course of performing DOE activities, identify nuclear safety, safeguards, or security concerns within the area of NRC responsibility. These concerns will be referred to the NRC Resident inspector for i appropriate action. Similarly, NRC will refer concems regarding nuclear safety, safeguards, or security deficiencies that occur in DOE regulated areas to the DOE Site Manager. 1 DOE coordinates with USEC to inform NRC of reportable events, under DOE j occurrence reporting system, for which DOE is responsible. j On occasion, DOE may need to move its nuclear materials through USEC areas to another DOE-regulated location. NRC does not require DOE to fill out Forms i 741 and/or 742 if the nuclear materials not in process only pass through USEC I areas, i.e., not normally involving more than one shift and remaining under DOE's continuous custody. Through implementation of the MOUs and other cooperative efforts (i.e., meetings, conference calls, etc.), transition from DOE regulatory oversight to NRC oversight of the leased portions of the GDPs was accomplished in a safe and effective manner. The extensive cooperation between the parties has improved the efficiency of the transition process. Since NRC assumed regulatory oversight of the GDPs on March 3,1997, the GDPs have provided adequate protection of health, safety, and environmental conditions, and have generally operated in compliance with NRC regulatory requirements. Exceptions are described in the Compliance Plans, which are authorized under the Atomic Energy Act and approved by NRC. Progress has been made on compliance issues since initial certification, thereby bringing the plants closer to full compliance with NRC regulations. USEC has taken prompt actions to reestablish compliance for those instances where, during the course of normal operation, violations of NRC requirements occurred. The Compliance Plans, while appropriate for existing facilities in transition between regulatory authorities as a means to define actions and l acceptable time periods for achieving full compliance under the new regulatory authority, would not be appropriate for the newly-licensed MOX facility which would meet applicable regulations from the time of initial licensing. One reference that is important to share with DOE is a meeting summary dated July 10, 1995, regarding shared site issues (attached). This reference provides insight into how NRC, DOE, and USEC discussed issues as they arose throughout the certification process. Becsuse of the successful interaction with DOE throughout the certification process for the GDPs, and, if collocating systems becomes a necessity, a similar approach could
1 ] 6 be taken to enhance the efficiency and effectiveness of regulation of collocated 1 facilities. Close coordination and open communication between the regulatory agen :les, along with written agreements documenting specific responsibilities for oversight of shared systems, would be necessary. Request No. 3: Identify other issues such as shared systems, operability, and classification.
Response
Any specific issues associated with shared systems, operability, and classification (information security) would be identified during NRC's review the details of the proposed facility when the license application is submitted. It would not be appropriate for NRC to prejudge the outcome of the licensing review. Nevertheless, as NRC and DOE discussed in the meeting on November 18,1997, NRC has identified some general issues that may arise at a collocated nuclear facility based on experience in regulating the GDPs and other commercial nuclear facilities. DOE discussed two conceptual approaches for shared systems with NRC staff and the public in the November 18th meeting. DOE also provided NRC with additional supporting information on December 5,1997. NRC understands that the actual design will be determined by the consortium of industry groups selected by DOE to construct and operate the facility. Based on the two general conceptual approaches described by DOE in the November 18th meeting, the discussion below identifies potential issues and complications associated with each approach, along with examples where these issues have arisen and have been resolved in the past. These issues have arisen in the general areas of nuclear safety, safeguards, emergency planning, and transportation. The first DOE conceptual approach, complete separation of the licensed and non-licensed activities with no shared systems or facilities, is clearly superior in terms of simplicity for the following reasons: (1) The MOX facility would receive plutonium and uranium oxide in an unclassified form for processing into MOX fuel. This is similar to existing operations involving processing of uranium oxide at the commercial nuclear fuel fabrication facilities, i I with which there is extensive experience. (2) Strict segregation of the NRC and DOE activities will be achieved by physically separating and isolating the NRC and DOE areas of the FMEF. C asequently, the interactions and interdependence of the activities would be identified, assessed, and minimized appropriately in the design of the facility, which would I be reviewed and confirmed by NRC in the licensing review. J (3) The entire MOX facility would be subject to and available for International Atomic 1
7 Energy Agency (IAEA) inspection. The DOE areas, which are completely ceparated, would not be under IAEA inspection. This should resolve any access restrictions for IAEA safeguards inspections. Based on DOE's November 18th presentation, NRC understands that this segregation approach would require remodeling and the addition of new structures. Annexes would be required for a separate entrance and independent utilities. A new NRC security area would need to be constructed to meet NRC physical protection requirements. There may be minor collocation issues that would need to be addressed, such as potential neutronic interactions through walls between systems containing fissile materials, distinguishing sources of environmental contamination based on environmental monitoring, and ccerdination and communication of emergency response information and associated actions. The second conceptual approach assumed shared systems between the MOX fuel fabrication facility under NRC regulation and other nuclear facilities under DOE regulation, such as the heating, ventilation, and air conditioning (HVAC) system and common access to the facilities. The description of this approach submitted by DOE did not identify the specific systems that would be shared or the design and performance specifications of the systems. As discussed above in response to question numoer 2, NRC and DOE would have to work closely together to define and develop a mutual understanding of the regulatory roles and responsibilities of each agency for shared site issues. Some associated issues that may have to be discussed and resolved for this conceptual approach are outlined below for certain shared features to illustrate the potential complications and burden associated with shared systems. Shared utilities and HVAC and other suooort systems (1) Configuration management and change control (2) Emergency response (3) Maintenance and calibration (4) Classification of material and information (5) System operability and reliability (6) Safety systems - ) l For example, in designing and assessing the safety and security of shared l utilities and HVAC and other support systems, DOE should consider how the following types of questions would be answered: Who is responsible for design, opera'.bn, ma'ntenance, testing, and monitoring of shared systems? Who is responsible for adherence to commitments and requirements for such systems? If a system is not operable, who is responsible for conective action, for notifications, and for authorizing restart when system operability is restored? l What is the change control process for such shared systems and how are the safety and security impacts of changes considered for the MOX fuel fabrication i
4 8 - facility? How does the sharing of systems affect the likelihood, type, and consequences of accident sequences at the fuel fabrication facility? What are i the enforcement implications on the MOX fuel fabrication facility if a shared system is not being operated in accordance with the safety basis or security plan? If a shared system is not operable, what limiting conditions on operations would apply? What are the impacts of shared systems on IAEA access for safeguards inspections (e.g., holdup in the ventilation system)? These issues would be evaluated as part of NRC's licensing review for the fuel fabrication facility and could require an extensive examination of safety and security systems that support other nuclear facilities under DOE regulation to ensure the MOX fuel fabrication facility can be operated safety and securely. Shared facility access (1) Personnel verification and searching systems (2) Physical protection (3) Material control and accounting (4) Training and qualifications (5) Fitness for duty (6) Radiation protection (contamination control) (7) Emerency response Shared personnel issues are complex in that the employees will have to clearly understand the two sets of regulatory requirements for their jobs, which may not be consistent and could vary from location to location within the facilities. In some cases, requirements could conflict with each other. For example, NRC's material control and accounting (MC&A) regulations require that MC&A permnnel are independent of the production personnel. NRC understands that this independence is not necessarily required under DOE regulation. In addition, shared access could complicate or delay resolution of diversion concerns and contamination incidents. For example, contamination of a worker that is detected in a shared change room could affect all the facilities that use that change room and increase the burden associated with identifying and correcting the source of contamination. Shantdfon-hardened walls and structures / rooms (1) Protection against natural phenomena hazards (e.g., earthquakes, tornadoes, hurricanes, etc.) (2) Radiation protection (due to the amount of shielding afforded in the w:lls between the different activities) (3) Emergency response . (4) Physical protectim (Access control; Searches) (5) Material coF nnd accc,unting (6) Configu, dco rr.1agement
9 (7) Training end qualifications (8) Personnel security clearances (9) Classification (i.e., IAEA inspectability) A primary example of a situation where NRC has had experience with shared rooms at an NRC licensed facility and its impact on IAEA inspectability is the BWX Technologies, Inc. (formerly B&W Navy) facility. Although in this case both parts of the facility were regulated by NRC, only one portion was open for IAEA safeguards inspections and access to other portions of the plant is carefully controlled to avoid disclosure of classified information. in this example, BWXT erects temporary barriers to accommodate the IAEA inspections and prevent disclosure of classified material. Similar measures could be required if the MOX fuel fabrication facility shared non permanent walls or rooms with nuclear activities that are subject to DOE regulation. Other Areas and Tooics (1) Collocated workers (DOE protection of these individuals as workers vs. NRC protection as members of the public) (2) Maintenance and functional testing (3) Emissions and monitoring (4) Event response and root cause evaluations (5) Compliance expectations and adherence to commitments (6) Decommissioning responsibilities These additional topics could also surface as issues during a licensing review of a MOX fuel fabrication facility that would be collocated with other nuclear facilities regulated by DOE. NRC and DOE are currently exploring the collocated worker issue as part of the Hanford Tank Waste Remediation System project. The other issues have surfaced at other commercial nuclear processing facilities that have shared systems or been in close proximity to other nuclear facilities (e.g., Rocketdyne facility (previously Atomics International) in Santa Suzanna, I California, or General Atomics in San Diego, California, which were both regulated by NRC, DOE, and the State of Califomia). If DOE opts for the second conceptual approach, which would rely on shared systems, NRC would expect to identify these types of issues before or during the licensing review and would seek to clarify roles and responsibilities through written agreements such that regulatory authority and responsibilities are clearly delineated, such as in the example of the GDPs. This list is not intended to be exhaustive, but illustrates the greater complexity of the second approach, and, correspondingly, the greater l coordination that would be necessary between our agencies. Based on a preliminary review and experience with shared systems at the GDPs, staff believes that the first approach is preferable and that NRC would license the strictly I l l 1
10 segregated NRC activity for both safety and safeguards (physical protection and material control and accounting). The first approach represents a clearer delineation of roles and responsibilities and would likely conserve significant resources that would otherwise be spent clarifying responsibilities and developing the associated agreements with DOE to clarify roles and responsibilities, as well as procedures for communication and coordination. The actual issues that pertain to the MOX fuel fabrication facility depend in large part on the specific design and operating procedures of the facility and will be reviewed upon receipt of an application for a license. Reauest No. 4: Identify conditions required to obtain and maintain *:.o '/.OX fuel facility license. Response: Please refer to response to Request No.1. NRC expects that specific scfety and safeguards conditions would be imposed in the license based on the results of the NRC's review of the license application and specific commitments by the applicant. With the exception of legislative authority, there are no issues identified at this time which would prevent the licensing of the collocated activities as generally proposed. NRC staff will not prejudge the environmental, safety, and safeguards reviews prior to receiving and reviewing an application. 1 l i i
--u,--~xm M. 'I [ July 10, 1995 MEETING SUMARY l l MEETING OF U.S. NUCLEAR REGULATORY COMISSION STAFF UNITED STATES ENRICHMENT CORPORATION AND U.S. DEPARTMENT OF ENERGY l DATE: June 13, 1995 TOPIC: SHARED SITE ISSUES On June 13, 1995, the NRC staff met with the United States Enrichment Corporation (USEC) and the United States Department of Energy (DOE) to discuss shared sita issues. Attachment 1 is the agenda for the meeting. The agenda items were the subject of further discussions summarized in attachment 2. is the list of attendees for the meeting. NRC contact: Merri Horn, 301 415-8126 Attachments:
- 1) Meeting Agenda
- 2) Summary of Meeting Discussion
- 3) List of Attendees cc: Mr. Rob Woolley, USEC Mr. Dale Jackson, DOE Docket Nos. 70-7001, 70-7002 DISTRIBUTION: v / e <> <I-NRC File Center '
PUBLIC KEverly, SEC BJones, OGC CCox, RIII TCombs, OCA GShear, RIII K0'Brien, RIII PTing, FCOB JRoth, FCOB FCEB r/f ETen Eyck, FCSS NMSS r/f FCEB Staff I ATTACHMENT
'y NRC/USEC/ DOE NEETING AGENDA SHARED SITE ISSUES June 13, 1995 Upcounty Government Center Room D (Third Floor) 12900 Middlebrook Road Germantown, Maryland 1. Presence of 3rd party tenants on site (other than USEC, DOE, and their contractors): a. Protection of tenants during accidents and normal operations b. Protection of site facilities and personnel against hazards introduced by the third parties 2. DOE activities in USEC leased space: a. Downblending b. Decontamination and cylinder cleaning' involving high enriched uranium c. Laboratory work 3. USEC assistance to DOE: a. Responses to incidents b. Security c. Support systems 4. Onsite transportation: a. USEC movement through DOE space b. DOE mnvement through USEC space 5. Internal and external dosimetry: a. Responsibility b. TLD processor accreditation (NVLAP vs. DOELAP) 6. Site environmental monitoring and reporting: a. Groundwater monitoring i b. Annual environmental report L c. Others l 7. Unclassified Controlled Nuclear Information (UCNI) I
Meeting Summary - June 13, 1995 Shared Fite Issues The first issue was the presence of other organizations on the site, such as the Ohio National Guard (ONG) and the Defense Logistics Agency (DLA). The concern stems from two aspects: 1) protection of the tenants or third parties and 2) protection of site facilities and personnel against hazards that the tenants may introduce to the site. USEC identified the location of the third party tenants utilizing large drawings of the site that identified leased and non-leased space. The largest third party tenant at the Portsmouth facility is the ONG, located primarily at the south end of the facility. The DLA is the other tenant at Portsmouth, however, the DLA is expected to leave the site ) by the end of the year. Both of these facilities are located outside the ) security portals. The ONG primarily uses their space for storage and repair i of vehicles. It is not believed that the ONG stores any munitions at the ~ site. In the past, the area has been used for helicopter landings in emergencies. This issue needs to be addressed by USEC. Permanently assigned ONG personnel have received basic training in rad protection and emergency planning, weekend workers may not have and DLA personnel have not received training. Both the lease and training responsibility currently resides with 00E. The NRC stated that the preliminary view was that the third party tenant workers would be considered members of the public under 10 CFR 20 for routine releases, but would be considered as onsite workers for accident or emergency conditions as long as they received training. The Paducah does not have any third party tenants on the site; however, the Kentucky Wildlife Management Area (KWMA). borders the site, beginning at the perimeter road. The preserve does not have any buildings or permanent residents. The area is a public use area and hunting is permitted. DOE stated that the area had been deeded to the State of Kentucky. This situation was not considered in the 1985 FSAR and will need to be addressed in some manner in the application. DOE agreed to share information on the leases with USEC and the NRC. Agenda items two and three, DOE activities in USEC leased space and USEC assistance to DOE, were discussed together. DOE clarified the leased vs nonleased space issue by indicating that there were some common areas. The common ares would be controlled by USEC but DOE would have access; this would include roadways, security portals, etc. DOE would be responsible for all nonleased space and USEC responsible for all leased space. Although retaining responsibility, DOE contracts out much of their activities to Lockheed Martin Utility Services. Therefore, LMUS provides emergency planning, security, fire protection, etc to DOE. DOE also anticipates that LMUS will conduct the activities associated with the HEU downblending for DOE /LMES. In one scenario, some HEU activities might occur in: leased space, and DOE would not regulate them. USEC would be in the position of possessing, but not owning the material. In some cases like decon, USEC would decon and clean out the equipment, package any uranium and transfer it to DOE. USEC and DOE were infonned that if an activity occurred in leased space, the NRC would hold USEC 1 accountable; on the other hand if an activity occurred in DOE space, DOE is
responsible and the NRC would not be involved. For example if DOE has waste material stored in leased areas, USEC would be accountable; DOE would be responsible for any USEC material stored in DOE space. Another example is the . HEU downblending at Portsmouth. If the downblending is to occur in USEC space, USEC might need to become a Category 1 facility. It is NRC's understanding that USEC wants to avoid being subject to Category I requirements. One option is to temporarily delease portions of the plant back to DOE. DOE and USEC need to have some arrangement in place regarding change control and configuration manageaunt of shared systems and areas. DOE and USEC must be informed of actions taken by the other that has the potential to impact their activities. The next agenda item was onsite transportation; DOE movement through USEC space and USEC movement through DOE space. Roadways are being treated as comaon areas. Each party will be responsible for its own transportation activities. DOE will need to abide by USEC requirements. DOE will rely on NRC/USEC to inform them of the applicable requirements. USEC does not anticipate any problems with DOE transport through USEC areas. Internal and external dosimetry was discussed in the context of who was responsible and NVLAP vs. DOELAP accreditation. USEC will be responsible for its workers and will use NVLAP accreditation. DOE will continue to use DOELAP and will issue dosimetry to DOE /LMES personnel and their contractors. Workers will only be issued one dosimeter, who ever issues the dosimeter will be responsible for all aspects. USEC stated that under 100 people would require dosimetry to meet Part 20 requirements. Average dose is 20 - 100 mrem per year. Site environmental monitoring and reporting was discussed to clarify that DOE will continue issuance of the site annual environmental report. DOE will place the NRC on distribution. DOE is responsible for the groundwater monitoring at the sites. USEC will provide the most recent data in the application each year to show compliance with Part 20. The last topic discussed was unclassified controlled nuclear information (UCNI). Although this is primarily a DOE concern, the NRC will hold USEC accountable for the control of UCNI in accordance with DOE requirements. DOE will provide USEC criteria. If the DOE guidance is not available for inclusion in the application, the topic will be addressed in the compliance plan.
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