ML20249A278

Forwards RAI Re Paducah Updates to Certification Application Submitted by 971215 & s.Addl Info Should Be Provided within 30 Days

ML20249A278
Person / Time
Site:	07007001
Issue date:	06/12/1998
From:	Horn M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	John Miller UNITED STATES ENRICHMENT CORP. (USEC)
References
NUDOCS 9806160262
Download: ML20249A278 (3)

Text

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l 7 June 12, 1998 Mr. James H. Miller Vice President, Production U. S. Enrichment Corporation 2 Democracy Center 6903 Rockledge Drive '

Bethesda, MD 20817

SUBJECT:

PADUCAH UPDATES TO CERTIFICATION APPLICATION

Dear Mr. Miller:

This refers to your updates to the certification application documents that have been submitted by letters dated December 15,1997 (Revision 21) and April 15,1998 (Revision 24). USEC has stated that the changes were made in accordance with 10 CFR 76.68 and did not require prior NRC approval. Our review of those changes has identified questions on the appropriateness of that conclusion for some of the changes. Additionalinformation is necessary to support your conclusion that the changes did not require prior NRC approval. The additional information, specified in the enclosure, should be provided within 30 days of this letter.

If you have any questions regarding this matter, please contact me at (301) 415-8126.

Sincerely, WWW Merri Horn Project Manager Enrichment Section [

Special Projects Branch Division of Fuel Cycle Safety /

and Safeguards, NMSS y Docket 70-7001 Cert;ficate GDP-1 kb

Enclosure:

As stated cc:- Mr. Howard Pulley, PGDP Mr. Steve Toelle, USEC DISTRIBUTION: w/ encl. .,

Docket 70-7001 ONMC Filo Center 4 8 PUBLIC Rlli Ko'Brien, Rill NMSS r/f FCSS r/f SPB r/f PHiland, Rlll MPWit, STB

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, e Request for Additional information Updates to Certification Application United States Enrichment Corporation Paducah Gaseous Diffusion Plant Docket 70-7001 Please provide the following information:

Safety Analysis Reoort

1. In Table 1-3 (pages 1-7 through 1-9), Rev. 21, some of the changes made to the possession limits need to be corrected as follows: (1) footnote f is inappropriate for material types A, B, D, and the 5th and 6th items under C; (2) footnote f should be removed from the end of the first description entry under C. The description provides for uranium enriched up to 2.75 percent. The addition of the footnote for item 4 would allow possession of samples in excess of 2.75 percent in conflict with the up to 2.75 percent allowance; (3) footnote f is not necessary for the 2nd, 3rd, and 4th items under C as these items already provide for assays greater than 2.75 percent; (4) changing the enrichment level up to 10 percent in item 2 under C is the same change for which USEC received a Notice of Violation in inspection Report 97004. Please correct or explain the basis for these changes. In addition, please clarify the addition of samples for analysis that has been added to material types A, B, and C, particularly for the higher enrichments since Paducah only processed low enriched uranium.

I

2. On page 3.3-57, Rev. 24, first change bar, it appears that some of the sentence was dropped. The sentence states what is excluded in C-315 but does not state what all other buildings do use for fine adjustment.

3. On page 3.10-1, Rev. 21, last sentence, why has storage areas been changed to permanent storage areas? Do you no longer utilize temporary storage areas?

Temporary storage areas must also be posted unless they meet the requirements of 10 CFR 20.1903

4. On page 3.11-1, Rev. 24, you have added the statement that the laboratory may provide analytical services to offsite customers under contract agreements. Please explain the basis for adding this statement. Paducah's authorizations in chapter 1 do not include conducting analytical services to offsite customers, it does provide for analysis of DOE environmental samples to support the site remediation activities.

5. On page 4.4-6, Rev. 21,5th paragraph, explain why the requirement to characterize l waste containers for enrichment has been removed. Enrichment can be a factor in i ensuring application of appropriate nuclear criticality safety controls. l

6. On page 4.4-9, Rev. 24, changing the frequency of the level and airflow sensors and I alarms testing frequency would appear to decrease the effectiveness of nuclear criticality safety for the spray booth operation. In addition changing the monthly calibration of the level sensors to a verification monthly could a!so be viewed as  !

decreasing the safety of the system. Please explain the basis for these changes.

c 2

7. In Table 5.17 (page 5.1-22) and references on page 5.1-11, Rev 21, explain why you have changed all references to the frequency of analysis to frequency of sampling. The frequency of analysis and the frequency of sampling are not interchangeable, in fact sampling often occurs more frequently than analysis when composite samples are utilized.. The change to sampling instead of analysis actually makes some of the information in the table incorrect. The flow proportional continuous samplers are not sampled on a weekly, monthly or quarterly basis; this is the frequency for analysis of the composito samples that are collected continuously. The analysis frequency is an important piece of information for the monitoring program and should be included in Chapter 5.1.

8. In Table 5.1-9 (page 5.1-24) and reference on page 5.1-12, Rev. 21, explain why you have deleted the analysis frequency. Again the analysis frequency is an important piece of information for the monitoring program and should be included in Chapter 5.1.

9. On Figure 5.1-4 (page 5.1-30), Rev. 21, explain why the alpha tape was removed from the figure.

10. On page 6.9-2, Rev. 24, explain the basis for changing when an investigation will be conducted for an event. Investigations were conducted for each reportable event and is now only conducted for those events requiring a written report. This change would appear to decrewse the effectiveness of the event investigation program. Even when events do not require a written report, it is still important to understand the root cause and to implement corrective actions to prevent recurrence.

11. On page 6.9-2, Rev. 24, explain the basis for changing when corrective actions will be developed for an event. Corrective actions were developed for each event or condition which required NRC notification and now only developed for those events or conditions requiring written reports. This change would appear to decrease the effectiveness of the corrective action program. See also question 10.

Radwaste Management Program

12. On pages 4 and 5, Rev. 21, explain why you have changed the language from wastes generated in radiological areas to wastes generated in areas controlled for transferable contamination. What types of waste, if any, are no longer being managed as low level waste due to the wording change?

13. On page 7,2nd line, Rev. 21, explain why you have changed the wording from are monitored to may be monitored, making the monitoring optional would appear to decrease the effectiveness of the program. If the intent was not to make monitoring optional but to allow other methods of monitoring, it would be clearer to either add the other methods to be used or end the sentence after contamination.

h-mm.. _ . . .