ML20136H697

Discusses Process of Placing Operation in Safe Condition or Timing of Conditions,Per

ML20136H697
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant, 07007001
Issue date:	03/17/1997
From:	Pierson R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Woolley R UNITED STATES ENRICHMENT CORP. (USEC)
References
NUDOCS 9703190276
Download: ML20136H697 (2)

Text

_. _ _ . _ _ - . _. .-_ _ _- __ _ _ _ _ ._. _.

March 17, 1997

, Mr. Robirt L. Woc!!ey, Manager .

. Nucl:ar R::gulttory Assuranca and Policy U. S. Enrichment Corporation 2 Democracy Center 6903 Rockledge Drive Bethesda, MD 20817

SUBJECT:

RESPONSE TO EVALUATION OF AS FOUND CONDITIONS LETTER (GDP 97-0022)

Dear Mr. Woolley:

Your February 28,1997, letter documented your understanding of the requirements of 10 l CFR 76.68(b) regarding the evaluation of as-found ccaditions. Your letter did not address 3 placing the operation in a safe condition or the timing of the actions.

The first step should be to irnmediately place the plant in a safe operating condition and, then make the operability and reportability determinations in a prompt manner. The decision on the disposition of the as-found condition should not take an extended period of time. The corrective action to either modify the safety analysis report (SAR) to conform I

with the as-found condition or to modify the as-found condition to conform with the SAR should be conducted in a timely manner commensurate with the potential safety significance of the issue. Operation outside the envelope of the SAR is not allowed. We agree that the original as-found condition does not need to be evaluated under 10 CFR

, 76.68(a) un6:e you plan to continue with the condition as discussed above. As a point of clarification,. if the corrective action is to modify the as-found condition to conform with I

the SAR,10 CFR 76.68 would not require an evaluation to determine if prior NRC approval ,

is necessary because the NRC has already approved the SAR. It would be necessary to I perform an evaluation of the actions necessary to bring the as-found condition back into conformance with the SAR. ,

1 If you have any questions, please contact Ms. Merri Horn of my staff at (301415-8126). l Sincerely,

! Odginal Slgned By

, Robert C. Pierson, Chief

. Special Projects Branch 4

Division of Fuel Cycle Safety and Safeguards Docket No. 70-7001,70-7002 Certificate GDP-1, GDP-2 DISTRIBUTION: ,

l Docket 70 7001 Docket 70-7002 .NRC File Centera PUBLIC 5 f)

Region lli NMSS r/f FCSS r/f SPB r/f K'OBrien, Rlli h CCox, Rlli G:\USEC68B.MLH *See previous concurrence OFC *SPB 'SPB 'SPB 'SPB SPB ,

NAME MHorn YFaraz DHoadley DMartin RPhon DATE 3/11/97 3/11/97 3/11/97 3/12/97 $/d/97 C = COVER E = COVER & ENCLOSURE N = NO COPY

~ "

OFFICIAL RECORD COPY 9703190276 970317 DR ADOCK 0700 1

[] { ggg g

l Mr, Robert L. Woolley, Manager uclear Regulatory Assurance and Policy U. . Enrichment Corporation 2 De ocracy Center 6903 kledge Drive Bethesda, D 20817 Dear Mr. Wooll -

Your February 28,1 7, letter documented your under nding of the requirements of 10 CFR 76.68(b) regarding e evaluation of as-found ditions. Your letter did not address placing the operation in a s condition or the t' ing of the actions.

The first step should be to imme ety pi e the plant in a safe operating condition and, i then make the operability and reporta ty determinations in a prompt manner. The i decision on the disposition of the a oun ondition should not take an extended period of i

time. The corrective action to er modify safety analysis report (SAR) to conform  !

with the as-found condition to modify the as- nd condition to conform with the SAR  !

should be conducted in a ety manner commensur with the potential safety significance of the iss . Operation outside the envelop f the SAR is not allowed. We agree that the origi as-found condition does not need to evaluated under 10 CFR l 76.68(a). As a int of clarification, if the corrective action is t odify the as-found I condition to form with the SAR,10 CFR 76.68 would not requir n evaluation to determine ' prior NRC approval is necessary because the NRC has alte approved the SAR.I ould be necessary to perform an evaluation of the actions neces y to bring the as fo d condition back into conformance with the SAR.

you have any questions, please contact Ms. Merri Horn of my staff at (301415 81 ).

Sincerely, Robert C. Pierson, Chief Special Projects Branch Division of Fuel Cycle Safety l

and Safeguards 1 Docket No. 70-7001, 70-7002 Certificate GDP-1, GDP-2 1

DISTRIBUTION:

Docket 70-7001 Docket 70-7002 NRC File Center PUBLIC Region lll NMSS r/f FCSS r/f SPB r/f K'OBrien, Rlli CCox, Rlil lOFC SPB C SPB d. _

SPB d/ A, S SPB lNAME M$oYn YFM hNadley NN RPierson l 3 /g/97 8 ////97 //

lDATE J / /97 7 //2/97 / /97 C = COVER E = COVER & ENCLOSURE Id = NO COPY i OFFICIAL RECORD COPY