ML20134M757

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Presents Licensee Understanding Re Certain Requirements Imposed by Technical Safety Requirements & Compliance Plan for Criticality Accident Alarm Sys.Concurrence W/ Understanding Requested
ML20134M757
Person / Time
Site: Portsmouth Gaseous Diffusion Plant
Issue date: 02/14/1997
From: Woolley R
UNITED STATES ENRICHMENT CORP. (USEC)
To: Pierson R
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
GDP-97-0015, GDP-97-15, NUDOCS 9702200397
Download: ML20134M757 (2)


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Ennchment Corpriration i

Q 2 Democracy Center 6903 RocMedge Dom Bethesda, MD 2081/

g Tel (301;564 3200 Fax (301) %4-3201 fuiteil Aahw I?nrichment Corporation February 14,1997 Mr. Robert C. Pierson SERIAL: GDP 97-0015 I

Chief, Special Projects Branch

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Division of Fuel Cycle Safety and Safeguards, NMSS j

- United States Nuclear Regulatory Commission Washington, D.C. 20555-0001 Portsmouth Gaseous Diffusion Plant (PORTS)

Docket No. 70-7002 Criticality Accident Alarm System (CAAS) for Nearby Buildings

Dear Mr. Pierson:

The purpose of this letter is to present USEC's understanding related to certain requirements imposed by the Technical Safety Requirements (TSRs) and the Compliance Plan for the Criticality Accident Alarm System (CAAS). We request your concurrence with our understanding of these provisions.

TSRs 2.1.3.1, 2.2.3.2, 2.4.3.1, 2.5.3.1, 2.6.3.4, 2.7.3.2, and 2.8.3.1 require that the CAAS be

" operable" and do not specifically recognize or explicitly exclude those areas of the plant where alarm coverage does not presently exist for nearby facilities. However, Compliance Plan Issue 44 explicitly i

recognizes that "several leased buildings that are located within 200 feet of buildings with criticality accident alarm system (CAAS) clusters (" clustered" buildings) do not have evacuation horns and lights activated by these clusters" and that "the criticality alarm horns from adjacent alarmed buildings cannot be heard within most of these unalarmed buildings". Therefore, the requirement that a criticality accident be annunciated into nearby buildings is not fully met at this time. The plan of action and schedule for Compliance Plan Issue 44 establishes completion dates for resolution of these j

noncompliances for routinely manned and routinely unmanned facilities of July 1,1997 and 0

July 1,1998, respectively.

Both the Compliance Plan and the TSRs are conditions of the Certif be complied with in a consistent, coherent manner. Compliance Plan Issue 44 specifically recognizes j

l that the CAAS TSRs have been altered by the Compliance Plan. In particular, the " Summary of Requirements, Commitments, and Noncompliances" section of Issue 44 specifically identifies the relevant TSRs (Reference page xvii and Issue 44, page 3) as the USEC commitments to which the i

Compliance Plan issue applies. Therefore, under the relevant TSR and Compliance Plan provisions, l

read together, USEC is required to have an operable CAAS and to be in full compliance with the applicable TSRs-except that full capability for annunciation in nearby buildings need not be provided until the dates wecifigljn the Plan of Action and Schedule for Compliance Plan Issue 44.

9702200397 970214. %

PDR ADOCK 07007002 C

PDR x my Portsmoutn. Ohio Wasnington. DC

Mr. Robert C. Pierson February 14,1997 GDP 97-0015 Page 2 To support USEC's continued preparation for NRC regulatory oversight on March 3,1997, we request your review and response to this letter by February 21,1997. As always, we are available to discuss this issue at your convenience.

Should you have any questions or require additional information, please contact me at (301) 564-3413 or Mark Smith at (301) 564-3244.

Sincerely,

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(

Robert L. Woolley Nuclear Regulatory Assurance and Policy Manager cc:

NRC Region III Office NRC Resident Inspector - PGDP NRC Resident Inspector - PORTS DOE Regulatory Oversight Manager

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