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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217N5861999-10-22022 October 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7002/99-09 Issued on 990827 ML20217H6911999-10-19019 October 1999 Ack Receipt of 990928 Application to Revise Technical Safety Requirements 2.2.3.15 & 2.7.3.14.Initial Administrative Review Finds Application Acceptable.Completion of Review Is Anticipated by 991215 ML20217N7591999-10-18018 October 1999 Provides Monthly Update on Progress of Installation of Seismic Upgrade Mods to Bldgs C-331 & C-335 ML20217M3861999-10-15015 October 1999 Provides Addl Changes to SAR Update Certificate Amend Request,Containing Changes That Resulted from re-evaluation of Autoclave head-to-shell O-ring Leakage Analysis Provided by DOE SAR Repts ML20217M2961999-10-15015 October 1999 Provides Addl Changes to Updated SAR Certificate Amend Request,Including Changes Made IAW Item 5 of Plan of Action Schedule for Compliance Plan Issue 2 & Changes That Resulted from Reevaluation of Autoclave head-to-shell O-ring ML20217N9141999-10-15015 October 1999 Forwards Rev 6 of NCS Cap,Providing Addl Details within Subtask 3.3,addl Ncsa/E Reviews & Establishes New Milestone to Conduct Addl Reviews IAW Procedure XP2=EG-NS1037, Review of Non-Priority 1 & 2 ML20217G1731999-10-14014 October 1999 Requests Addl Info Re Applications Dtd 990924,requesting Amends to Cocs for Paducah & Portsmouth GDPs for Revised QA Programs.Encl Identifies Specific Info Needed.Info Should Be Provided within 30 Days ML20217G4671999-10-14014 October 1999 Forwards Proprietary Insp Rept 70-7002/99-207 on 990920-23. No Violations Noted.Under Provisions of Section 2.790(d), Repts Containing Info Related to Licensee MC&A Program, Exempt from Public Disclosure ML20217G1811999-10-14014 October 1999 Forwards Reissued Amend to Coc for Usec Paducah Gdp.Coc Corrects Coc Issued on 991006.Amend Number & Effective Date Were Inadvertently Incorporated as 3 & 991026,instead of 4 & 991105 ML20217F6801999-10-12012 October 1999 Forwards Updated Paducah GDP Certificate Amend Requests at NRC for Approval ML20217F5481999-10-0808 October 1999 Discusses Insp Rept 70-7002/99-12 on 990810-0920 at Ports- Mouth Gaseous Diffusion Plant.No Cited Violations of NRC Requirements Were Identified During Insp ML20217B3521999-10-0606 October 1999 Forwards Amend 3 to Certificate of Compliance GDP-1 to Revise Six Technical Safety Requirements Sections.Sections Are 2.1.4.17,2.1.4.8,2.3.4.1,2.3.4.4,2.3.4.16 & 3.10.4.b. Compliance Evaluation Rept Also Encl ML20217B2801999-10-0606 October 1999 Forwards Insp Rept 70-7001/99-203 on 990921-23.No Violations Noted ML20217B6121999-10-0606 October 1999 Forwards Copy of Security Incident Log for Month of Sept 1999 ML20212K8941999-10-0404 October 1999 Forwards Insp Rept 70-7001/99-10 on 990720-0907 & Forwards NOV Indicating That Some Personnel Were Incorrectly Granted Unescorted Access to Controlled Access Areas Without Having Necessary Specific Training ML20217A4781999-10-0404 October 1999 Forwards Revised Event Rept 99-17,for Event Resulting from Determination That Sprinkler Sys Not Capable of Meeting Operability Requirements.Caused by Mineral Deposits.Provided Following Completion of Root Cause Evaluation ML20216J8931999-10-0101 October 1999 Forwards Copy of Security Incident Log & Associated Info for Sept 1999 ML20216J9081999-09-30030 September 1999 Forwards Revised Written Event Rept 99-10,rev 3,pertaining to Corroded Fire Sprinkler Heads Affecting Operability of high-pressure Fire Water (HPFW) Sprinkler Sys.No Commitment Contained in Rept ML20217M3701999-09-29029 September 1999 Submits bi-monthly Update on Progress of Mods to Upgrade Audibility of Criticality Accident Alarm Sys (Caas).Schedule for CAAS Audibility Upgrades Attached ML20212H5991999-09-27027 September 1999 Responds to Violations Noted in Insp Rept 70-7002/99-09. Corrective Actions:Engineering Evaluated Site Rail Track Insp Process for Improvement ML20216J7891999-09-27027 September 1999 Provides Required 30-day Event Rept 99-19 for Event That Resulted from Failure of Cascade Automatic Data Processing Data Processing Smoke Detection Sys at Portsmouth Gaseous Diffusion Plant.Encl 2 Is List of Commitments Made in Rept ML20212H1251999-09-24024 September 1999 Notifies NRC of Change in Regulatory Commitments Associated with Submittal Date for Update of Application SAR Chapter 3.Specifics of Commitment Changes of Listed ML20212H3801999-09-24024 September 1999 Responds to 990723 RAI Re 1999 Annual Update to Certification Applications ML20212G9401999-09-23023 September 1999 Responds to 990806 Reply to NOV in Ltr with Insp Rept 70-7002/99-04.Revised Reply Reviewed & Responses to Violations 1.B & 1.C Do Not Fully Address Needs as Clarified in 990715 Telcon.Resubmit Response within 30 Days of Ltr ML20212G0551999-09-23023 September 1999 Provides Revised 30-day Event Rept 99-06 for Emergency Condition That Was Declared Alert at Portsmouth Gaseous Diffusion Plant ML20212H3721999-09-22022 September 1999 Forwards NRC Form 790 Classification Record Documents for Paducah & Portsmouth GDPs That Were Generated During Month of Aug 1999.Without Encl ML20212F0981999-09-22022 September 1999 Forwards Insp Rept 70-7001/99-12 on 990830-0902.Purpose of Insp Was to Determine If Security Requirements Adequately Implemented & Included Review of Approved Plant Security Plan.No Violations Identified ML20217J1211999-09-20020 September 1999 Submits Listed Comments on NRC Proposed Rule, Reporting Requirements for Nuclear Power Reactors ML20212D4291999-09-17017 September 1999 Forwards Required 30-day Written Event Rept Re Criticality Accident Alarm Sys Response Time in Bldg C-710.Encl 2 Contains Commitments Contained in Submittal ML20212D4231999-09-16016 September 1999 Informs That Review of Event Rept Er 99-12 Revealed Listed Two Statements Inadvertently Omitted from Document ML20212B6611999-09-15015 September 1999 Forwards Insp Rept 70-7001/99-202 on 990816-20.No Violations Noted ML20212D2361999-09-15015 September 1999 Submits Monthly Update on Progress of Installation of Seismic Upgrade Mods to Bldgs C-331 & C-335 ML20212A5441999-09-14014 September 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7001/99-07 ML20212A5531999-09-14014 September 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7001/99-08 ML20216E6911999-09-13013 September 1999 Forwards 30-day Written Rept Er 99-18,re Actuation of Cascade ADP Smokehead in X-333 Bldg Low Assay Withdrawal Station.Caused by UF6 Release from Law A/B Compressor Shaft Seal Area.Planned C/As Will Be Provided in Revised Rept ML20211Q7761999-09-10010 September 1999 Forwards Insp Rept 70-7002/99-205 on 990816-20.No Violations Noted.Insp Consisted of Selective Exams of Computer Systems, Representative Records & Interviews with Personnel ML20211Q9951999-09-10010 September 1999 Forwards 30-day Written Rept ER-99-12,re Loss of Power to Autoclave Position 1 North & 1 South Process Gas Leak Detection (Pgld) in Bldg C-333-A.Caused by Electrical Short Circuit.Submitted Work Request 501636 for PI SEX-4 ML20211P2091999-09-0909 September 1999 Provides Staff Written Clarification of NRC Reporting Expectations of When Double Contingency Losses Should Be Reported to NRC IAW Bulletin 91-001, Reporting Loss of Criticality Safety Controls, & Suppl ML20216E4891999-09-0909 September 1999 Responds to Violations Noted in Insp Rept 70-7001/99-08. Corrective Actions:On 990602 Responsible Organization Manager Met with FP Engineer Performing Bldg Reappraisal & Made Clear Expectation for Prompt Reporting of Deficiencies ML20211Q8041999-09-0808 September 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7002/99-05 ML20211Q7171999-09-0808 September 1999 Forwards Required 30-day Written Event Rept 99-14,rev 1,re 990628 Event Involving Actuation of Brake Sys on Liquid U Hexafluoride Handling Crane at Plant.Revised Rept Includes Corrective Actions.Commitments in Rept Also Encl ML20211N8951999-09-0707 September 1999 Forwards Required 30 Day Event Rept 99-17,for Event That Resulted from Determination That 13 Sprinkler Sys Associated with High Pressure Fire Water Sys in Process Buildings Were Not Capable of Meeting Operability Requirements ML20211P3831999-09-0303 September 1999 Forwards Coc GDP-1,amend 3 & Coc GDP-2,amend 4 for Paducah (Pgdp) & Portsmouth (Ports) Gdps,Respectively by Revising Pgdp & Ports QAPs in Vol 3 of Respective Certificate Applications ML20211M6401999-09-0303 September 1999 Forwards Security Incident Log for Month of Aug 1999,per Requirements of 10CFR95.57(b) ML20211L6441999-09-0202 September 1999 Forwards Insp Rept 70-7001/99-11 on 990802-06.No Violations Noted.Insp Consisted of Selective Exam of Procedures & Representative Records,Interviews with Personnel & Observations of Activities in Progress ML20211M6941999-09-0202 September 1999 Forwards 30-day Written Event Rept 99-09,rev 1,for Event Involving Actuation of Brake Sys on Liquid U Hexafluoride Handling Crane at Plant.Revised Rept Includes Root Cause & Corrective Actions.List of Commitments,Included ML20211M3551999-09-0101 September 1999 Forwards Copy of Security Incident Log & Associated Info for Month of Aug 1999,IAW 10CFR95.57(b) ML20211L4871999-09-0101 September 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7002/99-07 Issued on 990709 ML20211K2081999-08-31031 August 1999 Discusses 990730 Revised Response to RAI Transmitted by NRC Re 990528 Response for Severity Level IV Violations Identified in Insp Rept 70-7002/99-06 ML20211K4041999-08-31031 August 1999 Forwards Responses to Remaining NRC Questions/Comments from 980601 & 0709 NRC RAIs Re SAR Update 1999-09-09
[Table view] Category:OUTGOING CORRESPONDENCE
MONTHYEARML20217N5861999-10-22022 October 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7002/99-09 Issued on 990827 ML20217H6911999-10-19019 October 1999 Ack Receipt of 990928 Application to Revise Technical Safety Requirements 2.2.3.15 & 2.7.3.14.Initial Administrative Review Finds Application Acceptable.Completion of Review Is Anticipated by 991215 ML20217G1811999-10-14014 October 1999 Forwards Reissued Amend to Coc for Usec Paducah Gdp.Coc Corrects Coc Issued on 991006.Amend Number & Effective Date Were Inadvertently Incorporated as 3 & 991026,instead of 4 & 991105 ML20217G1731999-10-14014 October 1999 Requests Addl Info Re Applications Dtd 990924,requesting Amends to Cocs for Paducah & Portsmouth GDPs for Revised QA Programs.Encl Identifies Specific Info Needed.Info Should Be Provided within 30 Days ML20217G4671999-10-14014 October 1999 Forwards Proprietary Insp Rept 70-7002/99-207 on 990920-23. No Violations Noted.Under Provisions of Section 2.790(d), Repts Containing Info Related to Licensee MC&A Program, Exempt from Public Disclosure ML20217F5481999-10-0808 October 1999 Discusses Insp Rept 70-7002/99-12 on 990810-0920 at Ports- Mouth Gaseous Diffusion Plant.No Cited Violations of NRC Requirements Were Identified During Insp ML20217B2801999-10-0606 October 1999 Forwards Insp Rept 70-7001/99-203 on 990921-23.No Violations Noted ML20217B3521999-10-0606 October 1999 Forwards Amend 3 to Certificate of Compliance GDP-1 to Revise Six Technical Safety Requirements Sections.Sections Are 2.1.4.17,2.1.4.8,2.3.4.1,2.3.4.4,2.3.4.16 & 3.10.4.b. Compliance Evaluation Rept Also Encl ML20212K8941999-10-0404 October 1999 Forwards Insp Rept 70-7001/99-10 on 990720-0907 & Forwards NOV Indicating That Some Personnel Were Incorrectly Granted Unescorted Access to Controlled Access Areas Without Having Necessary Specific Training ML20212G9401999-09-23023 September 1999 Responds to 990806 Reply to NOV in Ltr with Insp Rept 70-7002/99-04.Revised Reply Reviewed & Responses to Violations 1.B & 1.C Do Not Fully Address Needs as Clarified in 990715 Telcon.Resubmit Response within 30 Days of Ltr ML20212F0981999-09-22022 September 1999 Forwards Insp Rept 70-7001/99-12 on 990830-0902.Purpose of Insp Was to Determine If Security Requirements Adequately Implemented & Included Review of Approved Plant Security Plan.No Violations Identified ML20212B6611999-09-15015 September 1999 Forwards Insp Rept 70-7001/99-202 on 990816-20.No Violations Noted ML20212A5441999-09-14014 September 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7001/99-07 ML20212A5531999-09-14014 September 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7001/99-08 ML20211Q7761999-09-10010 September 1999 Forwards Insp Rept 70-7002/99-205 on 990816-20.No Violations Noted.Insp Consisted of Selective Exams of Computer Systems, Representative Records & Interviews with Personnel ML20211P2091999-09-0909 September 1999 Provides Staff Written Clarification of NRC Reporting Expectations of When Double Contingency Losses Should Be Reported to NRC IAW Bulletin 91-001, Reporting Loss of Criticality Safety Controls, & Suppl ML20211Q8041999-09-0808 September 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7002/99-05 ML20211P3831999-09-0303 September 1999 Forwards Coc GDP-1,amend 3 & Coc GDP-2,amend 4 for Paducah (Pgdp) & Portsmouth (Ports) Gdps,Respectively by Revising Pgdp & Ports QAPs in Vol 3 of Respective Certificate Applications ML20211L6441999-09-0202 September 1999 Forwards Insp Rept 70-7001/99-11 on 990802-06.No Violations Noted.Insp Consisted of Selective Exam of Procedures & Representative Records,Interviews with Personnel & Observations of Activities in Progress ML20211L4871999-09-0101 September 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7002/99-07 Issued on 990709 ML20211K2081999-08-31031 August 1999 Discusses 990730 Revised Response to RAI Transmitted by NRC Re 990528 Response for Severity Level IV Violations Identified in Insp Rept 70-7002/99-06 ML20211H2741999-08-27027 August 1999 Forwards Insp Rept 70-7002/99-09 on 990629-0809 & Notice of Violations Re Involving Inadequate Corrective Actions of Concern,Due to Staff Failure to Take Actions to Prevent Recent Derailment ML20211G9891999-08-26026 August 1999 Informs That on 990812,NRC Completed three-day Licensing Review of Activities Associated with Usec 990526,certificate Amend Request (CAR) to Reopen Compliance Plan Issues 8,9 & 23 at Portsmouth Plant ML20211B5021999-08-20020 August 1999 Forwards Amend 2 to Certificate of Compliances GDP-1, Revising Paducah GDP Technical Safety Requirements Re Audibility Requirements for Criticality Accident Alarm Sys at Facility & Related Sections of SAR ML20211A7011999-08-17017 August 1999 Forwards Copy of Final Amend to 10CFR76 for Info of Subcommittee.Final Rule Is Being Transmitted to Fr for Publication.Final Rule Will Amend Regulations That Apply to Paducah & Portsmouth Gaseous Diffusion Plants ML20210P7421999-08-10010 August 1999 Forwards Insp Rept 70-7001/99-08 on 990529-0719 & Nov. Violations of Concern Because Late Reporting of Problems with safety-related Equipment Could Negatively Impact Continued Availability of Equipment ML20210P6981999-08-10010 August 1999 Forwards Insp Rept 70-7002/99-11 on 990719-23.No Violations Noted.Insp Consisted of Selective Exam of Procedures & Representative Records,Interviews with Personnel & Observations of Activities in Progress ML20210L6571999-08-0404 August 1999 Informs That Staff Completed Initial Review of 990720 Application to Amend Coc GDP-1.Staff Anticipates Completing Review by 990930 ML20211A7901999-08-0404 August 1999 Forwards Info Requested During Briefing by NRC Staff on 990726 Re NRC Interactions with Usec ML20210F9761999-07-28028 July 1999 Forwards Compliance Evaluation Rept Prepared to Support Amend of Coc GDP-1 Re Criticality Accident Alarm Sys Audibility.Notice of Amend Forwarded to Ofc of Fr Also Encl ML20210G0391999-07-26026 July 1999 Forwards Compliance Evaluation Rept & Fr Notice for Revised Qaps,Per 990212 Application ML20210D8181999-07-23023 July 1999 Submits Response to SA Toelle Ltr Dtd 990614, 10CFR76.68(a)(3) Decreased Effectiveness Reviews & RAI for Paducah & Portsmouth Transmittals of 1999 Annual Update to Certification Applications ML20210V3481999-07-16016 July 1999 Informs That Staff Completed Review of New Payment Surety Bonds (Psb) for Paducah & Portsmouth Gdps,Which Were Provided in .Cancelled Psbs for Liberty Mutual Insurance Co & Safeco Insurance Co of America,Encl ML20209G2501999-07-14014 July 1999 Forwards Copy of Compliance Evaluation Rept Prepared to Support Resolution & Closure of Violation in Insp Rept 70-7002/97-203,re Failure to Have Adequate Benchmarks in Validation Rept Analysis of Models of U Sys ML20209F1031999-07-12012 July 1999 Forwards Insp Rept 70-7002/99-204 Conducted on 990614-17.No Violations Noted.Major Areas Inspected:Mc&A Safeguards Program.Rept Details Withheld,Per 10CFR2.790 ML20209F0611999-07-0909 July 1999 Forwards Insp Rept 70-7001/99-09 on 990621-25.No Violations Noted ML20209E8551999-07-0909 July 1999 Forwards Insp Rept 70-7002/99-07 on 990517-0629 & Nov. Violation of Concern Because Staff Displayed Lack of Rigor in Failing to Ensure That Nuclear Facility Criticality Safety Controls Were Implemented as Listed ML20209E8711999-07-0909 July 1999 Discusses Insp Rept 70-7002/99-08 on 990614-17 & Forwards Notice of Violation ML20209D4821999-07-0707 July 1999 Discusses Licensee 990702 Request That NRC Exercise Discretion Not to Enforce Compliance with Actions Required by Tsrs 2.2.3.2,2.4.3.1,2.5.3.1 & 2.7.3.2.NRC Concluded That NOED Warranted ML20209B7911999-07-0101 July 1999 Forwards Insp Rept 70-7002/99-203 Conducted on 990607-11.No Violations Noted ML20196K0981999-07-0101 July 1999 Forwards Insp Rept 70-7001/99-07 on 990413-0528 & Nov. Violations Re Failure to Fully Evaluate Situation in Which Safety Sys Relied Upon to Mitigate Consequences of Accident Was Inappropriately Returned to Svc ML20196H8421999-06-29029 June 1999 Discusses Insp Rept 70-7002/99-06 on 990322-26 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $55,000 ML20196F1121999-06-23023 June 1999 Responds to 990528 Response to NOV Submitted by with Insp Rept 70-7002/99-06.Response Not Fully Addressing Informational Needs in Notice.Response to Notice Requested to Be Resubmitted within 30 Days of Date of Ltr ML20196A1571999-06-17017 June 1999 Confirms Discussions Between K O'Brien & L Jackson to Conduct Meeting on 990630 to Discuss Apparent Violation ML20195J2001999-06-11011 June 1999 Ack Receipt of Certificate Amend Request Re Reopening of Compliance Plan Issues 8,9 & 23.Staff Has Completed Initial Administrative Review of Application & Anticipates Completing Review by 990831 ML20207H5001999-06-11011 June 1999 Discusses Insp Rept 70-7002/99-05 on 990406-0515 & Forwards Notice of Violation Re Weakness in Staff Knowledge & Implementation of Plant Procedures in Several Program Areas ML20207G2641999-06-0808 June 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7002/99-03 Sent on 990528.Reviewed Corrective Actions & Have No Futher Questions.Actions Will Be Examined During Future Insp ML20207F1311999-06-0404 June 1999 Responds to Requesting Copy of OI Rept 3-1998-033 Re Docket Potential Violation of 10CFR76.7 Concerning Employee Protection at Plant.Request Denied for Listed Reasons ML20207F2571999-06-0202 June 1999 Informs That NRC Disagrees with Usec Conclusion for Not re-opening Issue 2 of Compliance Plan,Since Proposed Change to Sarup Submittal Constitutes Major Rev to Operating Safety Bases Contained in Technical Safety Requirements ML20207A0121999-05-21021 May 1999 Forwards Insp Rept 70-7002/99-04 on 990222-0312 & Notice of Violations Re Inadequate Knowledge & Understanding by Some Staff & Mgt of Corrective Action 1999-09-09
[Table view] |
Text
_ _ _ _ ___ ___-_ _ ____ __ ______ __ __- .. _
,, o acg mod 7 <@2 y- k* UNITED STATES NUCLEAR REGULATORY COMMISSION f WASHINGTON, D.C. 2055M001
\...../ November 26, 1997 I
EAs97-447 & SI-448
. Mr. William H. Timbers President and Chief Executive Officer U. S. Enrichment Corporation 2 Democracy Center 6903 Rockledge Drive i Bethesda, MD 20817 i
SUBJECT:
CANCELLATION OF PREDECISIONAL ENFORCEMENT CONFERENCE AND REQUEST FOR INFORMATION (TAC NOs. L32043, L32044)
Dear Mr. Timbers:
By U.S. Nuclear Regulatory Commission letter dated October 27,1997, we informed you of our intent to hold on December 1,1997, an open predecisional enforcement conference with you conceming two apparent violations involving failures to comply with Condition 8 of the Certificates of Compliance for the Paducah and Portsmouth gaseous diffusion plants. On November 21,1997, NRC recnived from the Department of Energy (DOE) information relevant to the apparent violations conceming interactions between DOE and U. S. Enrichment Corporation (USEC) in updating system descriptions. In order to better understand the circumstances of the case and determine the appropriateness of enforcement action in this matter, it is necessary to obtain further information from USEC. Accordingly, pursuant to 10 CFR 76.70(e) please provide NRC within 30 days, and in writing and under oath or a#irmation, USEC's position on the enclosed DOE description of the interactions between USEC and DOE conceming system descriptions.
In light of this request for information, NRC is canceling the December 1,1997 confererce and will reschedule it after considering your response to this request.
,.I p ~ r o' 5 )
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Mr. W. H. Tinv rs, USEC 2 November 26, 1997 in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and its enclosures will be placed in the NRC Public Document Room and in each of the Local Public Document Rooms for the GDPs.
Sincerely, (Originalsignedby)
Carl J. Paperiello, Director Office of Nuclear Material Safety and Safeguards Dockets 70-7001,70-7002 Certificatea GDP-1 and GDP-2
Enclosure:
As stated l cc: Cteven Toelle, USEC Randall DeVault, DOE DISTRIBUTION: (TAC Nos: L32044, L320G)
Dockets 70-7001, 70-7002 NRC Fue Centar. PUBLIC NMSS Dir. Off. r/f FCSS r/f K. O'Brien, Rl!I P. Hiland, Rill M. Horn Y. Faraz D. Persinko C.Cox N. Mamish,OE J. Lieberman,OE P. Ting W. Schwink D. Hartlar.d, Rlli SPB r/f CP/PHOOPED/ NOVEMBER 35.1997 OF SPB* SPB* SPB* FCSS* OE* NMSS C ,f1 W
)h NA DMartin/ij DHoadley RPierson ETenEyck JLieberman CPaperiello ME DA 10/7/97 10/7/97 TE 11/25/97 11/26/97 11/26/97 // /)6 /97 G:\USECVIOL.dem OFFICIAL RECORD COPY
<2s _-
Mr. W. H. Timbers, USEC 2-
/
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice,"4 copy of this letter and its enclosures will be placed in the NRC Public Document Room an #n i each of the Local Public Document Rooms for the GDPs.
Sincerely, Cart #Paperiello, Director Offi le of Nuclear Material Safety d Safeguards Dockets 70-7001,70-7002 Certificates GDP-1 and GDP-2
Enclosure:
As stated cc: Steven Toelle, USEC Randall DeVault, DOE -
DISTRIBUTION- (TAC Nos: L32044, L32043)
Dockets 70-7001,70-7002 NRC File Center PUBLIC Rill NMSS Dir. Off. r/f FCSS r/f --
K. O'Brien/t llli P. Hiland, Rill M.Hom Y. Faraz D. Persinko C.Cox N Mamrsh,OE J. Lieberman.OE P. Ting W. SclWnk SPB r/f D. Ha41alid. Rill OFC SPB ksPB bh SPS _
NMSS nade , ( M '4 7%w ~ 4% / M'dycx
. I htko.,m.n cP.n.n.ii.
DATE /!1 7 -4emTP- // /1 f ,i / h 197 I / Nr/97 / 19 7 GAUSECVIOLdem
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OFFICIAL RECDRD COPY 1
DOE Fact Sheet United States Enrichment Corooration (USEC) Potential Violation - Failure to Update Paducah and Portsmouth Aoolication With DOE Site Wide Safety Analysis Reoort iSAR) by Auaust 17.1997
Background:
1 USEC submitted a letter to U. S. Nuclear Regulatory Commission (NRC) on August 18,1997, proposing a substantial delay in the schedule to meet the commitment of Compliance issue 2,
~
" Update the Application Safety Analysis Report'. A three year de!ay involving a substantial effort was proposed by USEC based on the need to " ensure completeness and accuracy" Subsequently, the NRC issued a letter to USEC notifying them of a preliminary finding of a potential violation for failing to meet USEC's Comp liance Plan Commitment on ISSUE 2. A meeting has been scheduled by the NRC for December 1,1997, to discuss the matter before a final determination is made. This NRC has described this meeting as a transcribed " pre-decisional" open enforcement meeting.
Meeting Topic:
USEC in previous managerial status meetings with the NRC has indicated that the DOE Site-Wide SAR contains discrepancies in systems descriptions which would cause USEC to miss the completion date of the Compliance Plan issue 2 commitment to " ensure completeness
, and accuracy". In addition, they have indicated the Compliance Plan " Plan of Action and l Schedule" did not allow them sufficient time to fully assess and understand the scope of the
} effort.
Facts:
- 1. USEC has been the lessee / operator of the Gaseous Diffusion Plants (GDPs) since July 1,1993. As such, tne corporation has been in control of the activities at the Podsmouth and Paducah GDPs.
- 2. USEC was committed to parform reviews of Facility and System descriptions during the DOE Site-Wide SAR Update by revision 2 of the Compliance Plan spproved and submitted to the NRC in early 1996. Thus, USEC was responsible for ensuring the technical accuracy and validity of the Facility and System descriptions. The Compliance Plan, issue 2, also committed USEC by August 17,1997 to compare the new information, findings and recommendations contained in the DOE site-wide SAR to the application SAR and 1) identify the differences,2) evaluate the effects of those differences on safety, and 3) propose modifications.
ENCLOSURE
l j
2
(
- 3. USEC and/or its primary contractor, Lockheed Martin / 'ities Services (LMUS), were !
informed of and involved in determining the content and methodology utilized by the DOE and its contractor personnel to develop the site-wide SARs.
- a. Safety Analysis Report Upgrada (SARUP)/ DOE personnel made presentations to USEC throughout 1993,1994, and 1995 to discuss program intent and approach,
- b. A presentation was made in summer of 1995 to NRC by USEC and SAR Upgrade Program personnelidentifying the SARUP plan to revise plant / system descriptions of safety class and safsty significant systems only. Non-safety system descriptions would be obtained from the application write-vo. The Gaseous Diffusion Plants (GDPs) configuration of record would be September 30,1995.
This was acknowledged and included in the Comp liance Plan which stales, "The facility and equipment description wi31 be revised to accurately depict the plant safety class and safety significant structures, systems and components and related support systems as of a specified date."
! c. Facility and System description drafts were transmitted to the plants from June 1993 to May 1994 for review. Minimal review was received from the plants.
Paducah Gaseous Diffusion Plant (PGDP) informed the DOE SAR Upgrade project that PGDP would perform any needed modifications to the Facility and l
System description. By May 1994, a complete draft of Ponsmouth Gaseous I Diffusion Plant (PORTS) Facility and System description for support of the USEC
} Application was provided. The same information for PGDP was placed on hold
} awaiting USEC modifications. A limited review of the PORTS descriptions was provided by the plants. Reviews and revisions of PORTS descriptions (in various phases) was placed on hold due to a USEC issue on regarding responsibility for control of the SAR project (i.e. DOE or USEC control).
- d. An enormous number of draft documents covering descriptions, Hazards analysis, Plant Safety Operational Analysis (PSOA), accident scenarios, source terms, consequence analysis, safety related structures, systems and components, potential technical safety requirements, and programmatic descriptions were sent to the plants primarily through hard copy and E-mail for review, accuracy checks, and general comment beginning in summer 1995. Review of these products varied from kaen interest to non-responsive. Review interest was a function of the direct bearing on plant operations. Examples of DOE efforts to obtain USEC review and agreement on the SAR upgrade are given below:
. Meetings were held with PGDP and PORTS plant personnel and USEC representatives in late 1994 and early 1995 to agree on PSOA methodd.ogy approach. ,
System ana!ysis fault trees supporting PSOAS were sent to the plant in '
May 1995 and updated fault trees to match the 9 .1/95 plant configuration were submitted for review in September 1996.
. The first PSOA drafts which included system description information were providad for plant review in January of 1996. The majority of the
.e
. 3 PSOAS were issued for review between January and May of 1996. A meeting was held in mid-July of 1996 at PORTS to obtain and discuss comments on the PSOAS provided by that date.
. The DOE SAR upgrade project sent PGDP the final draft of the Plant Hazard Screening document in September 1995 requesting a review and sign off or modification. '
. Process hazard analysis for PORTS facility X-344a was sent for review on November 8,1995, and a review meeting was requested. Other hazard analysia were provided at a rapid pace.
. A meeting was requested by e-mail to PGDP and PORTS to determine and agree on the configuration and assumptions for accident source terms. The meeting occurred at PGDP on December 13,1995. Meeting notes capturing assumptions were distributed for confirmation on December 20,1995.
. A review of PGDP radiological process hazards analyses was requested on January 31,1996. A request for information on chemical hazards was repeated on February 9.1996.
. Facility description information as written in Chapter 2 of the SAR was e.ent to P3DP for review in February 1996. The response from PGDP (USEC) on March 5,1996, was for DOE to make the descriptions consistent with the NRC Application SAR Agreement was reached with PORTS (March 1,1996) to limit the DOE SAR non-safety details which could impact the USEC Application SAR.
. On July 8,1996, PGDP was provided for review copies of PSOA for cascade and balance of plant for review. Recommended review meeting was set up.
. On July 11,1996, SARUP e-mail to PORTS discussed notification by PGDP that USEC had given specific instructions to the plants not to review any of the programmatic chapters of the draft SAR. The importance of reviewing some of these chapters was stressed. The NCS chapter was particularly stressed.
.- On August 8,1996, PGDP e-mail reiterated specific USEC instructions.
Stressed Programmatic Chapters should be NRC application Rev. 3 verbatim.
. Several meetings were held to discuss specific subjects with plant personnel and USEC representatives. Examples include:
- Dispersion modeling, May 1996
- Consequence & source term analysis , July 1996
. All SAR chapters were provided to the plants for review beginning in
s ,
[ 4 February 1993 and continuing through draft issuance of SAR for DOE review in September 1996.
- 3. DOE transmitted drafts for approval copies of the SARs September 30,1996, to USEC 1 and the plants.
- 4. DOE transmitted approved site-wide EARS for the Portsmouth and Paducah GDPs and the accompanying Safety Evaluation Reports (SERs) to USEC on February 14,1997.
- 5. USEC met with NRC in August 1997 conceming USEC's lack of compliance with the August 17,1997, commitment date. In this meeting USEC stated that there were only several minor discrepancies in the SAR analysis and descriptions of safety class and i safety related systems. Therefore, safety related items from the DOE SAR that required resolution by USEC would take at most a few weeks. This schedule is i
! significantly different to the three years for resolution that USEC is currently proposing.
l As such, only non-safety related inconsistencies are the is:iue.
Conclusion:
As evidenced by the many exchanges of information between DOE /USEC/NRC during the
, development process of the DOE site-wide SAR, DOE made a conscientious and consistent effort to ensure that the technical information was available to USEC for their review.