07/30/99 13:33 ENRICHMENT FrC EF20T -ý 13014155390 -SCH tU ýfVkl NO. 328 P02

USEC and DOE Agreement for

DOE Material Storage at the

Gaseous Diffusion Plants

Department of Energy (DOE) matenals have been stored in parts of several buildings and areas currently leased by

the Uniied States Enrichment Corporation (USEC) at both gaseous diffusion plants (GDPs),

At the request of USEC, pursuant to Section 3.4(b) of the Lease, DOE agrees to reduce the leasehold as necessary to

accommodate the storage of DOE matehiai/equipment. USEC will assume the financial and physical responsibility for, to the extent required by the. Nuclear Regulatory Commission (NRC), i) completing the necessary visual

inspections to identify enriched uranium deposits, 2) segregating equipment containing identified deposits; 3)

establishing and maintaining the required boundaries identified in this agreement, and 4) maintaining the necessary

docurnentation to support these conmitments.

Since the DOE formrery leased storage areas will not be leased to USEC, they are not subject to 10 CFR Part 76

requirements and NRC regulation. Additionally, activities within these areas (e.g. inspections and surveys) will

conform to, DOE requirements and are not subject to becoming a Compliance Plan item.

The following premises support the proposed resolution of DOE material storage:

1. This joint USEC and DOE agreement for DOE material storage does not modify, amend, or alter in any way the Lease Agreement between USEC and DOE for the GDPs, or any memoranda of agreement, or any other

agreement between USEC and DOE. Exhibit A to the Lease Agreement will be modified to reflect which

areas of USEC formerly leased space will now be listed as DOE space.

2. DOE activities conducted in formerly leased storage locations, including ingress and egress both within and

external to the leased buildings, will be managed in accordance with applicable DOE requirements. This

includes DOE personnel and their contractors/subcontractors. DOE assumes full responsibility for the

safety, safeguards, and security of DOE activities.

3. All fixed asset equipment (columns, piping, electrical, etc.) located in or traversing formerly leased spacc (within the confines of the cascade buildings or any other leased building) remain the responsibility of

USEC. All activities related to fixed asset equipment will be subject to NRC regulation. This includes

USEC personnel and their contractors/subcontractors. USEC assumes full responisibility for the safety, safeguards, and security of USEC activities.

DOE Material Storagm Controis

The following controls will be established to ensure safe storage is maintained in those areas designated for DOE

material storage.

1. Location of DOE MateXial/Equipment Formerly Leased Storage Areas

DOE mazerial and equipment that is either contaminated or potentially contaminated with radioactivity, orcontains

uranium bearing material (i.e., process equipment, low-level radioactive waste, hazardous (TSCA) waste

contaminated with uranium, uranium tetrafluoride RTFJ.3, etc.) will be physically located on property that is formerly leased by USEC, If this storage is within USEC leased buildings, the floor area directly supporting the material and

out to the DOE/USEC formerly leased storage area boundary will be under the control of DOE. The boundary will

be clearly marked through the use of ropes. dikes, and/or painted lines; and will also be mariced with signs.

If the material storage area is located outside of USEC leased buildings, then the ground supporting the rnaterial is

under the control of DOE and will be an area formerly leased by USEC. Boundaries are required for these areas that

contain non-containerizad materials, and may be used to mark containerized material areas. Signs shall be used to

Identify the areas. Boundaries are not required for containerized material areas and. as an alternative, the containers

may be labeled as DOE.
07/30/99 13:34 ENRICHMENT FAC EF20T - 13014155390 N0,328 IAUi

The locaion and boundaries of DOE formerly leased material storage areas will be determined and established prior

to certificadion, or addres-sed as a Compliance Plan activity. Establishment of new and/or the relocation of existing

)OE storage areas within USEC leased buildings after NRC assumes regulatory oversight will be coordinated

.mong DOE, NRC, and USEC.

2. Protection of DOE Equipment That Contains Uranium Deposits

Process equipment designed to contain UF6 (i.e., compressars, conveners, pipcs, and valves, etc.) in DOE formerly

leased storage areas will be inspected for visible deposit•s (does not include surface contamination) of enriched

uranium bearing material. Th7e purpose of this inspection is to ensure that the equipment does not contain uranium

deposits that could be easily retrieved without the use of special equipment The inspection will consist of a visuaI

check of the exterior and interior (if accessible) of the applicable equipment. Dismantling the equipment for

inspection is not required.

If equipment is found to contain visible deposits of enriched uranium bearing materials, the equipment will be

secured by a physical barrier. For man-portable equipment, this barrier shall consist of a locked barrier around or

within the DOE formerly leased storage area (i.e., locked gate, fence, walL etc.). For non-portable equipment it

could be a barrier affixed to the op•ning of the equipment, Like other DOE equipmen, this equipment will also be

located within a clearly marked area which was formerly leased by USEC,

3. Maintenance of DOE Material/Equipment Formerly Leased Storage Areas

DOE will ensure that DOE formerly leased storage areas are maintained in accordance with DOE requirements.

DOE will evaluate planned and unplanned disturbances 1) to ensure no significant risk impact on USEC's NRCregulated space, and 2) in accordance with DOE requirements for impact on DOE space. DOE will prohibit

disturbances of formerly leased storage areas. except as necessary to conduct decontamination or consolidation to

maintain or improve safe storage conditions, or to remove material/equipment from the buildings. USEC will be

responsible for maintaining the boundary and activities required by NRC at the boundary (i.e., radiation surveys, etc.)-

USEC is.allowed access to the DOE storage areas to conduct essential plant operations, to conduct DOE authorized

work on stored material/equipment, and to respond to emergencies, If USEC access results in the unauthorized

disturbance of DOE material/equipment, DOE will be immediately notified by USEC.

4. Limitations on the Addition of New DOE Materials/Equipment

Addition of materials to the formerly leased storage areas will be limited to properly characmrized TSCA waste

generated orsite. In the event an unforeseen situation arises that requires addition of matmnalequipment to the

formerly leased storage area other than properly characterized TSCA waste, the addition will be coordinated between

DOE, USEC and NRC.

USEC can not add to these areas without axpress wrinen DOE permission.

5. Transfer of Material./Equipment

It may be necessary for USEC to transfer equipment and/or material out of a DOE formerly leased storage area for

USEC's use after NRC commr"nces regulation. Transfers are contingent upon USEC performing the following: 1)

obtaining DOE approval, 2) measuring the uranium content of the material/equipment through Non-Destructive

Assay (NDA), 3) issuing an N'RC Form 741 for the transfer of nuclear material (if applicable), and 4) notifying the

NRC site resident prior to movement of the matrial/e.quipment. into |led space.

a ~ _AeZ GV eorge P. Itfakes Date

"epurment of Energy United'Sts Enrichment Corporation

Assistant Manager for Executive Vice President

Enrichment Facilities
07/30/99 :13:35 ENRICHMENT FPC EF20T -* 13014155390 NO. . iŽ 

DOE Matsz-a Storage Areas

Memorandum of ACCm=Ct Betwe= DOE and USEC

Ri n Dtleased Maerial Storage Areas (DMSA)

DOE and USEC will develop a piortizaion plan by January 17,1997, that will de•ail a schedule of

USEC activities to be performed at USEC's apen including!

1. Dismantin and removing Ld proc=s equipment located in or traversing USEC leased

buildings so long as removal will not requim shut down of any USEC operatons.

2. ronoana= with reasonable DOE wase arzcptanca citeria, not to be more rmslictive

than that of typies commercial faclities

3, Consolidaion of matenals with oth"r DOE areas,

4. Leasing areas back after materials are consolidated into other DOE areus.

USEC &hWll perform the, fallowing actiitim at USEC xpewe on or before March 3, 1997:

1. Each DMSA shall be a nsiped a unique id=tcatl number. USEC shall prm idean

invmtory to DOE of the type and apprccimate quantity of each DMSA (both indoor and

outdoor locations). DOE and USEC dhal agree on inventory.

I DOE shall make availa•le its Iandfi aud &rp yards for USEC waste.

Generl condirians

1. Any c -amina•i•, lube oil leim, water leaks, or other intrusion into the DMSAs by USEC

shall be elean.edup/repaired within 24 houm by USEC.

2. Resoudon and daosur of open aue shol be rsolvd as dotcrmined by the January 17,

1997, pl•a

3. DOE shal verify DMSA inventory upon completion of the inventory.

4. Any unresolved movemont of matcrial by USEC into DMSA without DOE ccnm-zarnce

shall rsult in DOE notification of the action to NRC.

5. DOE and USEC awee that DMSAs, as idtfi ad on =eng eing drawings CSE-19601-AD1

through CSE-19601-AII, am rcturned to DOE conuol and overaight.

Jimmie C Hodges Stee Poiston

DOE Site Manager USEC R e-enta1itv

Date
ENRICHMENT FPC EF2.T -ý 13014155390 NO. 328 [Pb

07/30/99

Department of Energy

Oak Ridge Operations

Post Office Box 62

Oak Ridqe, Tennessee 37831

8651

August 12, 1997

Mr. George P. Rifakes

Executive Vice President

United States Enrichment Corporation

2 Democracy Center

6903 Rockledge Drive

Bethesda, Maryland 20817

Dear Mr. Rifakes:

PADUCAH AND PORTSMOUTH GASEOUS DIFFUSION PLANTS CONFIGURATION CONTROL OF

EXHIBITS A AND B TO THE LEASE AGREEMENT BETWEEN THE UNITED STATES ENRICHMENT

CORPORATION AND THE DEPARTMENT OF ENERGY

Please find enclosed documentation that defines our intentions and

implementation methodology to ensure configuration control of the Lease

Exhibits A and B and their associated drawings, I believe it is prudent to

document our management expectations to ensure that our personnel and support

personnel have access only to those documents reflecting our most recent

agreements.

The enclosed document represents both your concurrence and my concurrence of

these directives and expectations.

If you have any further questions or comments, please contact me at

(423) 576-0892.

Sincerely,

W Parks

Assistant Manager

for Enrichment Facilities

Enclosures

cc's on Page 2.
07/30/99 13:36 ENRICHMENT FAC EF20T -+ 13014155390 N0.,329 POS

George P. Rifakes -2- August 12. 1997

cc w/enclosures:

J. C. Hodges. EF-22. C-103. PAD

E. W. Gillespie, EF-21, PORTS

R. M. DeVault, EF-20/OSTI
07/30/99 13:36 ENRICHMENT FAC EF20T - 13014155390 N0. 32e LI

LEASE EXHIBITS A AND B

CONFIGURATION CONTROL DIRECTIVES

BACKGROUND

Pursuant to the Energy Policy Act of 1992. the Department of Energy(DOE)has leased portions of the Paducah and Portsmouth Gaseous Diffusion Plants to the

United States Enrichment Corporation(USEC). DOE agrees, in its role as

landlord, to maintain the controlled copy of the Lease, comprising the lease

Material language. Exhibits A through F, the Building Lease Status drawings. the DOE Storage Agreements (DMSA), and the associated DMSA drawings.

Configuration control is required for Exhibit A, Exhibit B, the DMSAs(which

are supplements to Exhibit A). and their respective drawings. This set of

documents is defined for this directive as the Lease Configuration Control

Documentation. This directive shall apply only to the Lease Configuration Control Documentation.

CONTROL AND DISTRIBUTION

DOE-ORO will maintain the master data file that com prises the latest revision

of the Lease Configuration Control Documentation. Both the hardcopy and the

electronic media versions will derive their input from this master:

DOE-ORO will supply hardcopies to USEC and each site's DOE Site Manager,.

DOE-ORO will supply the electronic media version as follows:

* The medium used for distribution from DOE-ORO will be via compact disc-read

only(CD-ROM).

* DOE-ORO will send controlled copies of the electronic media version to

USEC. USEC will forward copies to LMUS at each respective site.

* DOE-ORO will also send controlled copies to each DOE Site Manager for

distribution to each site's LMES organization.

* Both LMES and LMUS Document Control will ensure that the CD-ROM. is

maintained in their control center as the controlled electronic media site

copy and also ensure that any CD-ROM version(s) in existence, which are not

the latest issue, are returned to DOE-ORO and USEC respectively.

* Both LMES and LMUS will ensure that the CD-ROM is loaded into their network

server.

* These controls ensure that all personnel will have accurate and ready

access to a controlled copy of the buildings, areas, and structures which

are leased to USEC. ownedby USEC, or retained by DOE.

* Both LMES and LMUS will enter the Building Lease Status and DMSA drawings

into their respective document control systems at each site. Revisions to

these drawings will be performed per the. change control procedures at each

respective site. It is important to note that the drawings will be revised

byDOE-ORO as approved by USEC and DOE-ORO prior to completion of the
07/30/99 13:37 ENRICHMENT FRC EF20T -* 13014155390 NO.328 P08

change control process. Each organization will. revise their change control

procedures to address these requirements. Potential discrepancies or errors

observed in the documentation shall be reported.

The format of the Building

been modified to assist in

Lease Status drawings and the DMSA drawings have

configuration control as follows-

* Signature blocks for DOE-ORO.and USEC management approval have been added.

* The present drawing numbers have been replaced with drawing numbers

specific to each respective site(assigned by each respective site's LMES

organization).

* The building lease map drawings reference

level of the Lease Exhibit A which is the

drawings reference the currently approved

the currently approved revision

map's main input. The DMSA

agreements between DOE and USEC.

Nothing in this directive shall be construed as modifying the Lease or any

exhibits thereto.

Subsequent documentation will address Exhibit B.

CONCURRED BY:

oe Parks D /

De ent of Energy Assistant Manager for

Enrichment Facilities

George P. Rifakes

United States Enrichment Corporation

Executive Vice President

Date