ML20249B926
| ML20249B926 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 06/18/1998 |
| From: | John Miller UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Knapp M NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| GDP-98-0126, GDP-98-126, NUDOCS 9806250057 | |
| Download: ML20249B926 (10) | |
Text
.
l~ v USEC A Global Energy company l
l JAMES H. MuER Dwt: (301)564-3309 l
VICE PRESIDENT, PRODUCTION fax: (301)571-8279 June 18,1998 GDP 98-0126 i
Dr. Malcolm R. linapp Acting Director, Office of Nuclear Material Safety and Safeguards Attention: DocumentControlDesk j
U.S. Nuclear Regulatory Conunission i
Washington, D.C. 20555-0001
~
l Portsmouth Gaseous Diffusion Plants (PORTS)
Docket No. 70-7002 Request for Enforcement Discretion Regarding the Certificate Amendment Request (CAR) for Compliance Plan Issue 11 i
Dear Dr. Knapp:
In accordance with 10 CFR 76.45, the United States Enrichment Corporation (USEC or Corporation) submitted a request for amendment to the Certificate of Compliance for the Portsmouth, Ohio Gaseous Diffusion Plant (PORTS) by letter GDP 98-0120, dated June 11,1998 (Reference 1). This Certificate Amendment Request (CAR) revises the Plan for Achieving Compliance with NRC-i Regulations at the Portsmouth Gaseous Diffusion Plant (Compliance Plan), Issue 11, to eliminate the action to tie evacuation homs in X-744H to the X-744G Criticality Accident Alarm System (CAAS). Issue 11 currently commits USEC to tie the evacuation horns in Building X-744H to the Building X-744G CAAS by July 1,1998. With the elimination of fissile operations in Building X-744H, a nuclear criticality safety evaluation concluded that due to the absence of fissile operations in the X-744H facility and the intrinsic nature of the residual contaminated material, which contain no visible quantities of uranium, that a nuclear criticality is not credible in the X-744H warehouse.
t Since the subject action in Compliance Plan Issue 11 is required to be completed by July 1,1998, USEC requested NRC review and approval of the CAR as soon as possible with the amendment 0
becoming effective five (5) days after NRC approval. It is apparent that there will be insufficient I
j time for NRC to complete the review and approval of this CAR by July 1,1998.
J cnV l
1 9906250057 900618 PDR ADOCK 07007002' C
PDR u 3
6903 Rockledge Drive, Bethesda, MD 20817-1818 bN I
Telephone 301-564-3200 Fax 361-564-3201 http://www.usec.com l
OHices in Livermore, CA Paducah, KY Portsmouth, OH Washington, DC t
Dr. Malcolm R. Knapp l
June 18,1998.
GDP 98-0126, Page 2 Therefore, USEC is requesting NRC enforcement discretion for the completion date in PORTS Compliance Plan Issue 11, addressed in Reference 1. As noted in letter GDP 98-0120 transmitting 3 -
the above CAR, USEC has implemented measures to ensure that a criticality is not credible in the X-74411 Building. The justification for this enforcement discretion request is contained in f. USEC letter GDP 98-0120 included the basis for USEC's determination that the l'
proposed change associated with the subject CAR is not significant. A copy of this significance determination is provided in Enclosure 2.
No new commitments are made in this submittal. Any questions related to this subject should be directed to Dr. Marc Klasky at (301) 564-3408.
Sincerely,
~
s H. Miller ce President, Production
Enclosures:
- 1. Justification for Enforcement Discretion l
- 2. United States Enrichment Corporation, Proposed Certificate Amendment Request, X-744H CAAS Evacuation Horns, Significant Determination
Reference:
- 1. Letter from James H. Miller (USEC) to Dr. Malcolm R. Knapp (NRC),
Certificate Amendment Request - Compliance Plan Issue 11 Revision, USEC letter GDP 98-0120, June 11,1998 cc: Robert C. Pierson (NRC)
NRC RegionIII Office NRC Resident Inspector, PGDP NRC Resident Inspector, PORTS Randall M. DeVault (DOE) ones 4
w v
-.ed
-=e e-=e wr*emupwede e ae*
yma a am
.<n smes+e
.sanva-
l-i GDP 98-0126 I
Page 1 of 4 t
JUSTIFICATION FOR ENFORCEMENT DISCRETION i
j
- 1. The TSR or other Certificate Condition that will be violated No TSRs will be violated. Condition 8 of the Certificate of Compliance (GDP-2) requires USEC to conduct its operations in accordance with the statements and representations contained in the l
Compliance Plan (DOE /ORO-2027). Issue 11 of the Compliance Plan requires evacuation homs
. in Building X-744H to be tied to the Building X-744G CAAS by July 1,1998. This action will
' not be accomplished in accordance with the Plan of Action and Schedule for Compliance Plan, Issue 11.
- 2. The circumstances surrounding the situation. including root can=cs; the need for prompt action and identification of any relevant historical events.
USEC submitted a certificate amendment request (CAR) for the Portsmouth, Ohio Gaseous Diffusion Plant (PORTS) by letter GDP 98-0120, dated June 11,1998. This CAR revises the Plan for Achieving Compliance with NRC Regulations at the Portsmouth Gaseous Diffusion Plant (Compliance Plan), Issue 11, to eliminate the action to tie evu:uation homs in X-744H to the X-744G Criticality Accident Alarm System (CAAS). Issue 11 currently commits USEC to tie the evacuation homs in Building X-744H to the Building X-744G CAAS by July 1,1998.
With the elimination of fissile operations in Building X-744H, the nuclear criticality safety 1
evaluation concluded that due to the absence of fissile operations in the X-744H facility and the
[
intrinsic nature of the residual contaminated material, which contain no visible quantities of
}
uranium, that a nuclear criticality is not credible in the X-744H warehouse.
Since the action associated with Compliance Plan Issue 11 is required to be complete by July 1, 1998, USEC requested NRC's review and approval of the CAR as soon as possible with the amendment becoming effective five (5) days after NRC approval. - It is apparent that there will be insufficient time for NRC to complete the review and approval of this CAR prior to July 1, 1998.
There is a need for prompt action since the Compliance Plan Issue 11 currently designates July 1,1998, as the completion date for the related action.
The only other relevant extenuating circumstance related to what should have been a more timely i[
CAR submittal was the complete revision and implementation of NCSA Plant 048, Contaminated hietal. Prior to the submittal of the CAR the revision of NCSA Plant 048 was
~ determined to be essential in order to provide the necessary assurance that the future or continued
[
use of X-744H mmains as assumed in the evaluations used to determine that a criticality in this O.
facility was not credible.
,r,
{
- 3. The safety hacia for the reaneet includine an evaluation of the safety cionificance and notential con =ennences of the oronosed course of action. includina any aunlitative risk mw.r.t i
j Continued operation of the X-744H warehouse, without approval of the proposed CAR, is addressed by the Justification for Continued Operation for Compliance Plan Issue 11. Due to the fact that the fissile operations that were ongoing in X-744H at the time of the Compliance Plan issuance that required CAAS coverage have been discontinued, there is no safety l
significance or potential consequences to the granting of enforcement discretion. There is no 1
increase in risk associated with this request since there are no longer fissile material operations ongoing in the X-744H building that involve uranium bearing solutions or the handling of any material that contain visible quantities of uranium.
In addition, it should be noted that there currently exists building evacuation homs which are tied to the X-744G CAAS via the slaved facility connection and would alarm in the event of a criticality in the X-744H building. Based on further analyses, a criticality in building X-744H ~
is not credible and the upgrade of the existing X-744H evacuation horns to meet CAAS evacuation hom requirements should not be required.
5
- 4. The basic for the certificate holder's conclusion that the noncompliance will not be of notential detriment to the workers or public health and safety. the environment. safeuuards or secunty and that neither an USO nor a determination of significance is involved.
L There is no increase in the dose or exposure to plant personnel or members of the off-site public as a result of this request. There is no increase in exposure to hazardous or toxic chemicals.
There is no increase in radiological or chemical releases. There are no new or unusual sources -
of hazardous substances, waste, or any mixed waste that could be generated. There are also no new or unusual sources of radioactive waste that could exceed specified limits. Finally, there
. is no significant decrease in the effectiveness of the Emergency Plan nor any programs or plans related to safeguards or security. USEC has reviewed the potential for an unreviewed safety question and has concluded that a USQ does not exist. In addition, this condition is temporary and non-recurring.
As part of the CAR submitted to the NRC by USEC letter GDP 98-0120, USEC has performed
,b a Significance Determination which is provided in Enclosure 2.
- 5. The hacie of the conclusion that the noncamnliance will not involve adverse concenences to the I
environment.
I Warehouse activities in the X-744H facility will continue in accordance with the comimtments contained in the Certification Application and as limited by NCSA Plant 048, Contaminated e
b (f
a =- - w - m
~
q.
I j-GDP 98-0126 i
Page 3 of 4 d
q Metal. No new accident consequences will be introduced during this period. There are no new waste releases introduced as a result of this request.
- 6. Any oronosed comnencatnry m-amures.
There is no need for compensatory actions other than the related controls imposed by NCSA Plant 048.
- 7. Thejustification for the duration of noncompliance.
The duration of the noncompliance will last until the CAR is approved by the NRC and implemented at the site. No new or additional risk is being introduced by this period of noncompliance. The consequences of any current, approved accident will not be increased or 1
changed since no changes will be made that will decrease the current safety margin or increase.
T the probability of any accident previously evaluated in the SAR. Measures have been impleinented to ensure a criticality is not credible in the X-744H, during and following the period ofnon-compliance.
- 8. A statement that the request has been anproved by the Plant Operations Review Committee (PORCL The information used in support of this request for Enforcement Discretion was reviewed and recommended for approval by the PORTS PORC on June 15,1998.
- 9. The reonest must address how the criteria for requesting enforcement discretion is met.
I This request for enforcement discretion is intended to avoid enforcement action as a result of verbatim compliance with the Compliance Plan Issue 11 action item that is no longer required I
due to operational changes associated with the subject facility. Without the enforcement discretion, it would be necessary to proceed with the specified facility modification which based on the current NCSA, would provide no corresponding safety, safeguards, security or 2
environmental benefit.
- 1
- 10. Marked-up TSR pages showing the proposed TSR changes should be attached.
J j_
No TSR changes are associated with this request. A Certificate Amendment Request to revise Compliance Plan Issue 11 was previously submitted in USEC letter GDP 98-0120, dated June 11,1998.
i en
-w------. - - - - - - -, - - - - - - -, - - - - -
s
[
GDP 98-0126 Page 4 of 4 -
- 11. Statement that orior adnotion of anoroved line item improvements to the Tech Soecs would u
haye obviatad the naad for enforcement diacretion_
Not applicable.
- 12. Any other information the NRC staff daems nacauary before makino a decision to exercise enforcement discretion.
No other information has been requested by the Staff at this time.
l r
l I
i l
(
1
)
l-1
._..________.--_____d
GDP 98-0126 4 Pages 4
United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request l
Compliance Plan Issue 11 Revision Significance Determination (Previously Included in GDP 98-0120) t l-I' m
?!
4 L :.
_ _ ~
\\
l i
GDP 98-0126 United States Enrichment Corporation (USEC) l 3
Proposed Certificate Amendment Request Compliance Plan Issue 11 Revision 1
Significance Determination 1
(Previously Included in GDP 98-0120)
The United States Enrichment Corporation (USEC) has reviewed the proposed changes associated with this certificate amendment request and provides the following Significance Determination for consideration.
1.
No Significant Decreate in the Effectivenen of the Plant's Saferv. Safeonards or Security Progranu The proposed change to the Compliance Plan does not affect any of the plant's safety, safeguards or security programs The proposed change revises Issue 11 to delete the action to tie the evacuation horns in Building X-744H to the Building X-744G CAAS by July 1,1998. The action is no longer required based on the fact that the iissile material operation (sorting and batching) that requires CAAS coverage has been removed from the X-744H. Due to the intrinsic nature of the -
materials allowed in the warehouse and the low fissile material density (no visible uranium) in the warehouse there is no credible risk of a criticality accident in X-744H. Therefore, there is no decrease in the effectiveness in the plant's safety, safeguards, or security programs as a result of the proposed change.
2.
No Significant Change to Any Conditions to the Certificate of Comnliance i-None of the Conditions to the Certificate of Compliance for Operation of Gaseous Diffusion Plants (GDP-2) specifically address Compliance Plan Actions and Schedules or the location of criticality accident alarm detectors. Thus, the proposed change will have no impact on any of the Conditions to the Certificate of Compliance.
3.
No Significant Chance to Any Condition of the Anoroved Comnliance Plan 1,
The Plan of Action and Schedule for Issue 11 of the Plan for Achieving Compliance with NRC Regulations at Portsmouth Gaseous Diffusion Plant currently commits USEC to tie the evacuation horns in Building X-744H to the Building X-744G CAAS by July 1,1998. As described in, the proposed change deletes the X-744H required action. The action is no longer required based on a Nuclear Criticality Safety Evaluation which concluded that CAAS coverage is q
no longer required and therefore the change to the Compliance Plan is not considered significant.
4.
No Significant increase in the Probability of Occurrence or Consequences of Previousiv Evaluated Accidents
.j There are no longer any fissile material operations ongoing in the X-744H facility that involve uranium bearing solutions or the handling of any materials that contain v.sible quantities of I'
uranium. Due to the intrinsic nature of the materials allowed in the warehouse and the low fissile material density in the warehouse there is no credible risk of a criticality accident in X-i 744H. The proposed change does not change the consequences of any previously analyzed accidents since they are based on credible criticality scenarios in which CAAS coverage is required.
p:
j
~
\\
l GDP 98-0126
)
Page 2 of 3 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request l
Compliance Plan Issue 11 Revision Significance Determination i
(Previously Included in GDP 98-0120) i 4.
No Sianinennt Increase in the Probability of Occurrence or Consequences of Previousiv Evninnted Accidenta (continued) i Therefore, the proposed change will not cause any increase in the probability of occurrence or consequences of previously evaluated accidents.
5.
No New or Different Tyne of Accident The proposed change does not modify plant equipment or add new operations to the facility. In fact the sorting and batching of solid contaminated burnables which necessitated the need for CAAS,
coverage has been discontinued in the facility. The CAAS horns are for mitigation of a criticality accident once it has occurred and are not an accident initiator. Therefore, this change will not result i
in a new or different type of accident.
6.
No Signi6 cant Reduction in Margins of Safety Based on the overall conclusion that there are no credible criticality accident scenarios associated with the X-744H Building, the margin of safety has been increased over that previously thought to exist when ie sorting and batching of sold contaminated burnables operation existed in the d
facility.
7.
No Significant Decrease in the Effectiveness of Any Programs or Plans Contnined in the Certificate Anotication l
The change to Compliance Plan Issue 11 will not result in a change to any of the programs or plans contained in the Certificate Application. Therefore, the proposed change will result in no decrease in the effectiveness of any programs or plans contained in the Certificate Application.
8.
The Pronosed Changes do not Result in Undue Risk to 1) Public Health and Safety. 2) Common Defense and Security. and 3) the Environment Due to the fact the consequences of a criticality have only onsite affects and the conclusion that there nre no credible criticality scenarios for the X-744H operation there will be no undue risk to the public health and safety. In addition, this change has no impact on plant effluents or on the j
programs and plans in place to implement physical security. Consequently the elimination of the i
Compliance Plan Issue 11 action to tie the X-744H evacuation horns to the X-744G CAAS will not pose any undue risk to the public health and safety, cummon defense and security and environment.
fv
^
1.
Z 9
i GDP 98-0126 Page 3 of 3 l
United States Enridment Corporation (USEC)
Proposed Certificate Amendment Request Compliance Plan Issue 11 Revision 9
Significance Determination l
(Previously Included in GDP 98-0120) 9.
No Change in the Tvoes or Significant Increase in the Amounts of Any Effluents that May be Released Offsite l
The consequences of a criticality are confined to plantsite and there will be no changes in the operation of X-744H nor in the manner in which it is maintained. The change will not increase the 4
probability of any previously analyzed accidents. The change to the Compliance Plan Issue 11 has no effect on the generation of effluents and therefore, it does not change the type or amount of effluents that may be released offsite.
10.
No Significant Increase in Individual or Cumulative Occupational Radiation Exposure The consequences of a criticality are confined to plantsite and there will be no changes in the operation of the X-744H Building. This change does not increase the probability of a criticality but concludes that the potential for a criticality is extremely low. The proposed change will not affect the radiological protection program actions in place to minmuze occupational exposures. Therefore, there is no increase in individual or cumulative occupational radiation exposure as a result of this j
- change, 11.
No Significant Construction Imnact The proposed change eliminates the need for a plant modification. Therefore, there is no construction impact.
l 12.
No Significar;t Increase in the Potential for. or Radiological or Chemical Consequences from.
Previousiv Analyzed Accidents The elimination of the need to tie the X-744H evacuation horns to the X-744G CAAS will not increase the probability of occurrence or consequences (radiological and/or chemical) of any postulated accidents currently identified in the SAR. This change does not alter the assumptions a
used in the accident analysis. Therefore, there is no significant increase in the potential for l
radiological or chemical consequences from previously analyzed accidents.
P 1
R u
1 6
l 4-t
)