ML20138L313

Provides Assessment of Tsr Clarification Which Addresses Application of Tsr SR 2.4.4.12-8 for Cells Shutdown on Day of Transition from DOE Operational SR to NRC Tsrs

ML20138L313
Person / Time
Site:	07007001
Issue date:	02/20/1997
From:	Pierson R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Woolley R UNITED STATES ENRICHMENT CORP. (USEC)
References
NUDOCS 9702240005
Download: ML20138L313 (2)

Text

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. er.k UNITED STATES

~70 ~7Co l i p(/f )6 8 NUCLEAR REGULATOhf COMMISSION j 'E WASHINGTON. D.C. 20065 0001

\ , , , , , *# February 20, 1997

-Mr. Robert L. Woolley, Manager Nuclear Regulatory Assurance and Policy U. S. Enrichment Corporation 2 Democracy Center 6903 Rockledge Drive Bethesda, MD '20817

SUBJECT:

TECHNICAL SAFETY REQUIREMENT CLARIFICATION - TSR 2.4.4.12-8

Dear Mr. Woolley:

Your January 24, 1997, letter informed the NRC of a USEC clarification on a Technical Safety Requirement (TSR) surveillance. The TSR clarification addresses application of TSR Surveillance Requirement 2.4.4.12-8 for cells shutdown on the day of transition from Department of Energy Operational Safety Requirements to NRC TSRs. Although your letter did not request a response from the NRC, we are providing our assessment of your TSR clarification.

TSR Surveillance Requirement 2.4.4.12-8 requires the use of the ACR motor stop button for planned cell shutdowns. It is clear from a reading of the TSR and the TSR basis that the TSR does not specifically address the issue of cells that were shutdown at the time of transition. The intent of the surveillance is to demonstrate the reliability of the cell trip function by utilizing the system for planned shutdowns. There are cells that were shutdown prior to transition that were not shutdown using the ACR motor stop button. Since the TSR does not provide an alternate method by which to demonstrate operability, it is not possible to met the surveillance requirement for those cells while the cell is shutdown.

USEC performed a clarification that provided an alternate means to meet the intent of the TSR surveillance requirement. The method would test the cell shutdown system by actuating the ACR motor stop button to open the breakers to verify the cell trip functions correctly while the cell is shutdown. The proposed testing of the circuit prior to restart of the cells appears logical and safety focused, and is consistent with the intent of the TSR surveillance.

However, the TSR clarification also changes the applicability of the TSR and would require prior NRC approval. Issuance of a TSR clarification is inappropriate in this instance. We strongly encourage USEC to submit a revised TSR to reflect the proposed surveillance.

I9 Please note that while TSR clarifications can be useful to plant staff to more fully understand the requirement of a TSR, the clarifications do not have NRC acknowledgement and have no legal authority. TSR clarifications must never 7

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contradict or change the wording, the meaning, or the intent of a TSR requirement. In order for the staff to recognize a TSR clarification, it A DO()g.

9702240005 970220 PDR ADOCK 07007001 PDR u

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o. l l \

R. L. Woolley, USEC 2 )

l would be necessary for USEC to (1) submit a certificate amendment to change  :

the TSR wording; (2) change the TSR basis statement via 76.68; or (3) obtain a written interpretation from the Office of Nuclear Material Safety and Safeguards regarding the intent of the TSR requirement.

If you have any questions, please contact Ms. Merri Horn of my staff at (301 415-8126).

Sincerely, Original Signed By Robert C. Pierson, Chief Special Projects Branch Division of fuel Cycle Safety and Safeguards Docket No. 70-7001 Certificate GDP-1 l

l DISTRIBUTION:

Docket 70-7001 NRC File Center- PUBLIC Region III NMSS r/f FCSS r/f SPB r/f K'0Brien, RIII CCox, RIII FCOB 0FC SPB C ISPB h SRpjA RIII, C SPE, NAME MiloN:ij M5Yoadley [Mhtin NGbear RFhrson DATE a //r/97 4/h/97 1/lh/97 / /97  %/ b /97 C = COVER E = COVER & ENCLOSURE N = NO COPY OFFICIAL RECORD COPY p:USECTSRC.MLH

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