Discusses Compliance Evaluation Rept Re Application ,revised 970214 & 0616 for Autoclave Manual Isolation SysML20151L421 |
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07007001 |
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07/16/1997 |
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NRC |
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NRC |
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References |
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NUDOCS 9708060328 |
Download: ML20151L421 (3) |
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Category:INTERNAL OR EXTERNAL MEMORANDUM
MONTHYEARML20217D5431999-08-31031 August 1999 Submits Notes from 990831 Meeting with Us Enrichment Corp. NRC & Us Enrichment Corp Reached Agreement on How to Proceed ML20211G9741999-08-26026 August 1999 Informs That on 990812,NMSS Completed three-day Licensing Review of Activities Associated with Usec 990526,certificate Amend Request (CAR) to Reopen Compliance Plan Issues 8,9 & 23 Dealing with Nuclear Criticality Safety Program ML20210U0261999-08-13013 August 1999 Notification of Cancelled 990816 Meeting with DOE & Usec in Paducah,Ky to Discuss Usec Access to DOE Controlled Areas to Complete Compliance Plan Required Seismic Mods to Cascade Bldgs ML20210Q7921999-08-12012 August 1999 Notification of 990819 Meeting with Us Enrichment Corp in Rockville,Md to Discuss Activities at GDPs ML20210Q0601999-08-11011 August 1999 Notification of 990816 Meeting with Usec & DOE in Paducah,Ky to Discuss Usec Access to DOE Controlled Areas to Complete Compliance Plan Required Seismic Mods to Cascade Bldgs ML20206T4641999-05-19019 May 1999 Forwards May 1999 Monthly Repts for Special Projects Branch (Spb) Performance Indicators Showing Progress Spb Has Made Implementing Goals for Steamlining Certification Activities for Paducah & Portsmouth ML20206Q7601999-05-0606 May 1999 Informs That Usec Recently Initiated Cancellation Proceedings to Existing Payment Surety Bond for Decommissioning Funding Program Via Aon Risk Svcs.Nrc Providing Original Copies of Attachments 1 & 2 ML20154G2671998-10-0606 October 1998 Notification of 981015 Meeting with Usec in Rockville,Md to Discuss Criteria for Completing & Closing Portsmouth & Paducah Compliance Plan Issues ML20151Z5201998-09-16016 September 1998 Notification of 981001 Meeting W/Us Enrichment Corp in Rockville,Md to Discuss Activities at Gaseous Diffusion Plants ML20248A8991998-05-22022 May 1998 Submits One Potential Abnormal Occurrence, Seismic Risk from Liquid U Hexafluoride at Withdrawal Facilities at Paducah Gaseous Diffusion Plant, Per 980423 Request.Ao Is Provided in Wordperfect File on Attached Disk.W/O Disk ML20217E3051998-04-23023 April 1998 Forwards Signed Original Confirmatory Order Modifying Certificate for Paducah Gaseous Diffusion Plant for Transmittal to Ofcof Fr for Publication.W/O Encl ML20212H3071998-04-0202 April 1998 Revised Notification of 980408,15 & 17 Meeting W/Us Enrichment Corp (Usec) to Discuss Usec Privatization.Rev Due to Location of Meeting ML20248L2121998-03-10010 March 1998 Submits TAR Re Review of Request for Criticality Accident Alarm Sys (CAAS) Exclusion for Portsmouth Gaseous Diffusion Plants & Paducah Gaseous Diffusion Plant ML20198S3681997-11-0707 November 1997 Forwards from Us Enrichment Corp Requesting Exemption from Fy 1997 Annual Fees for Paducah & Portsmouth Gaseous Diffusion Plants Under 10CFR171.11(a) for Review & Input.Provide Comments No Later than 971126 ML20212B9211997-10-20020 October 1997 Requests Technical Assistance in Reviewing Following Project Re SRP for Gaseous Diffusion Plant Facilities ML20217F8061997-10-0707 October 1997 Requests Technical Assistance in Reviewing Certificate Amend Request for Paducah Gaseous Diffusion Plant to Revise TS Requirement on Criticality Accident Alarm System for Product Withdrawal Facilities ML20141H6331997-07-30030 July 1997 Notification of 970731 Meeting W/Usec in Rockville,Md to Discuss Status of Safety Analysis Rept Upgrade Project ML20141H8041997-07-30030 July 1997 Notification of 970814 Meeting W/Us Enrichment Corp in Rockville,Md to Discuss Activities Related to Gaseous Diffusion Plants Operated by Us Enrichment Corp ML20151L4211997-07-16016 July 1997 Discusses Compliance Evaluation Rept Re Application ,revised 970214 & 0616 for Autoclave Manual Isolation Sys ML20140D9691997-06-0909 June 1997 Notification of 970611 Meeting W/United States Enrichment Corp in Piketon,Oh to Discuss Regulatory Issues ML20141B1361997-05-12012 May 1997 Revised Notification of 970515 Meeting W/Us Enrichment Corp in Bethesda,Md to Discuss Activities Related to Gaseous Diffusion Plants Operated by Licensee.Location of Meeting Has Been Changed ML20140G2031997-05-0202 May 1997 Responds to 970329 Request to Review & Provide Comments on Gaseous Diffusion Plants RTM-96 Supplements ML20138A1341997-04-22022 April 1997 Requests Technical Assistance in Review of Approval of Alternate Schedule for Submittal of Matl Balance & Inventory Composition Repts at Portsmouth Gaseous Diffusion Plant & Paducah Gaseous Diffusion Plant ML20137T1041997-04-11011 April 1997 Informs of 970417 Meeting W/Usec in Rockville,Md to Discuss Activities Re Gaseous Diffusion Plants Operated by Usec ML20140C4351997-04-10010 April 1997 Notification of 970410 Meeting W/Usec in Rockville,Md to Discuss Contamination Surveys of Outside Areas ML20137Q2001997-04-0909 April 1997 Informs of Cancellation of 970410 Meeting W/Usec in Rockville,Md to Discuss Contamination Survey of Outside Areas of Gaseous Diffusion Plants ML20140G2111997-03-29029 March 1997 Requests Review or Draft RTM-96 Supplements for Paducah & Portsmouth Gaseous Diffusion Plants ML20137K3191997-03-27027 March 1997 Discusses Certificate Evaluation Rept for Application Re Feed Facilities Crane Design Features ML20137C3051997-03-21021 March 1997 Requests Technical Assistance in Review of Certificate Amend Request for Paducah Gaseous Diffusion Plant to Revise Fundamental Nuclear Materials Control Plan ML20137A2301997-03-17017 March 1997 Requests Fr Notice Announcing Availability of Criteria for Staff Implementation of Backfitting Requirements for GDPs & NMSS GDP Backfit Procedure Be Published & Placed in PDR & Lpdrs Assigned to Portsmouth & Paducah GDPs ML20136F4811997-03-12012 March 1997 Summary of 970327 Meeting W/Usec to Discuss Activities Re Gaseous Diffusion Plants Operated by Usec ML20135E2251997-03-0404 March 1997 Notification of 970312 Meeting W/Usec in Piketon,Oh to Regulatory Issues ML20134L4921997-02-13013 February 1997 Notification of 970227 Meeting W/Usec Staff in Rockville,Md to Discuss Application for Laser Enrichment Facility ML20134D1141997-01-31031 January 1997 Notification of 970206 Meeting W/Usec in Rockville,Md to Discuss Merits of Criticality Accident Alarm Sys Exclusion Request ML20134D0721997-01-30030 January 1997 Notification of 960213 Meeting W/Usec in Rockville,Md to Conduct Monthly Status Meeting ML20134F8691997-01-30030 January 1997 Discusses Certificate Evaluation Rept for Application Re Cascade Cell Trip Function ML20133B6651996-12-31031 December 1996 Discusses 961111 Emergency Preparedness Training Tabletop Exercise Conducted at NRC Headquarters & Forwards Lessons Learned ML20132E0981996-12-16016 December 1996 Notification of 961218 Meeting W/Usec in Rockville,Md to Discuss Coordinatation of Orderly Transition of Uranium Enrichment Plants at Paducah,Ky & Piketon,Oh ML20132A6171996-12-11011 December 1996 Informs That Ticket G960838 Will Be Considered Cancelled for Nmss,Per EDO ML20135E5361996-12-0505 December 1996 Notification of 961210 Meeting W/Usec in Rockville,Md to Discuss Possible Amends to Certificates to Operate U Enrichment Plants at Paducah,Ky & Piketon,Oh ML20134G5781996-11-0808 November 1996 Notification of 961114 Meeting W/Usec in Rockville,Md to Update General Status on Certification Related Activities ML20132A6011996-11-0808 November 1996 Informs That Reply to Request for Extension of Ticket G960838 Has Been Forwarded ML20132A5951996-11-0707 November 1996 Informs That Ticket G960838 Is Extended to 961218 ML20129D5051996-10-0909 October 1996 Requests Comments on Encl Petition from M Donham & K Hanson Re Decision of NRC Director of NMSS to Issue Certificates of Compliance for Operation of Two Gaseous Diffusion Plants by Us Enrichment Corp.Served on 961009 ML20128K5491996-10-0404 October 1996 Informs That Encl Ltr from V Colley Being Treated as Petition for Review Under 10CFR76.62(c) & Recipient Invited to File Response or Comments by 961015 ML20149G9531994-11-0404 November 1994 Notification of Upcoming Meeting W/Us Enrichment Corp on 941109 to Discuss Role in Preparation of Compliance Plan & Current Status of Format & Content of Certificate Application 1999-08-31
[Table view] Category:MEMORANDUMS-CORRESPONDENCE
MONTHYEARML20217D5431999-08-31031 August 1999 Submits Notes from 990831 Meeting with Us Enrichment Corp. NRC & Us Enrichment Corp Reached Agreement on How to Proceed ML20211G9741999-08-26026 August 1999 Informs That on 990812,NMSS Completed three-day Licensing Review of Activities Associated with Usec 990526,certificate Amend Request (CAR) to Reopen Compliance Plan Issues 8,9 & 23 Dealing with Nuclear Criticality Safety Program ML20210U0261999-08-13013 August 1999 Notification of Cancelled 990816 Meeting with DOE & Usec in Paducah,Ky to Discuss Usec Access to DOE Controlled Areas to Complete Compliance Plan Required Seismic Mods to Cascade Bldgs ML20210Q7921999-08-12012 August 1999 Notification of 990819 Meeting with Us Enrichment Corp in Rockville,Md to Discuss Activities at GDPs ML20210Q0601999-08-11011 August 1999 Notification of 990816 Meeting with Usec & DOE in Paducah,Ky to Discuss Usec Access to DOE Controlled Areas to Complete Compliance Plan Required Seismic Mods to Cascade Bldgs ML20206T4641999-05-19019 May 1999 Forwards May 1999 Monthly Repts for Special Projects Branch (Spb) Performance Indicators Showing Progress Spb Has Made Implementing Goals for Steamlining Certification Activities for Paducah & Portsmouth ML20206Q7601999-05-0606 May 1999 Informs That Usec Recently Initiated Cancellation Proceedings to Existing Payment Surety Bond for Decommissioning Funding Program Via Aon Risk Svcs.Nrc Providing Original Copies of Attachments 1 & 2 ML20199G7911998-12-22022 December 1998 Staff Requirements Memo Re SECY-98-275, Rept to Congress on Gaseous Diffusion Plants Located Near Paducah,Ky & Portsmouth,Oh ML20154G2671998-10-0606 October 1998 Notification of 981015 Meeting with Usec in Rockville,Md to Discuss Criteria for Completing & Closing Portsmouth & Paducah Compliance Plan Issues ML20151Z5201998-09-16016 September 1998 Notification of 981001 Meeting W/Us Enrichment Corp in Rockville,Md to Discuss Activities at Gaseous Diffusion Plants ML20248A8991998-05-22022 May 1998 Submits One Potential Abnormal Occurrence, Seismic Risk from Liquid U Hexafluoride at Withdrawal Facilities at Paducah Gaseous Diffusion Plant, Per 980423 Request.Ao Is Provided in Wordperfect File on Attached Disk.W/O Disk ML20217E3051998-04-23023 April 1998 Forwards Signed Original Confirmatory Order Modifying Certificate for Paducah Gaseous Diffusion Plant for Transmittal to Ofcof Fr for Publication.W/O Encl ML20212H3071998-04-0202 April 1998 Revised Notification of 980408,15 & 17 Meeting W/Us Enrichment Corp (Usec) to Discuss Usec Privatization.Rev Due to Location of Meeting ML20217H5251998-03-19019 March 1998 Staff Requirements Memo on 980319 Affirmation Session in Rockville,Md Re SECY-98-022, Petition for Commission Review of Director'S Decision on Paducah Seismic Upgrades Certificate Amend Request ML20248L2121998-03-10010 March 1998 Submits TAR Re Review of Request for Criticality Accident Alarm Sys (CAAS) Exclusion for Portsmouth Gaseous Diffusion Plants & Paducah Gaseous Diffusion Plant ML20216G4641997-12-18018 December 1997 Staff Requirements Memo Re SECY-97-270, Annual Rept to Congress on Gaseous Diffusion Plants Located Near Paducah,Ky & Portsmouth,Oh ML20198S3681997-11-0707 November 1997 Forwards from Us Enrichment Corp Requesting Exemption from Fy 1997 Annual Fees for Paducah & Portsmouth Gaseous Diffusion Plants Under 10CFR171.11(a) for Review & Input.Provide Comments No Later than 971126 ML20212B9211997-10-20020 October 1997 Requests Technical Assistance in Reviewing Following Project Re SRP for Gaseous Diffusion Plant Facilities ML20217F8061997-10-0707 October 1997 Requests Technical Assistance in Reviewing Certificate Amend Request for Paducah Gaseous Diffusion Plant to Revise TS Requirement on Criticality Accident Alarm System for Product Withdrawal Facilities ML20141H6331997-07-30030 July 1997 Notification of 970731 Meeting W/Usec in Rockville,Md to Discuss Status of Safety Analysis Rept Upgrade Project ML20141H8041997-07-30030 July 1997 Notification of 970814 Meeting W/Us Enrichment Corp in Rockville,Md to Discuss Activities Related to Gaseous Diffusion Plants Operated by Us Enrichment Corp ML20151L4211997-07-16016 July 1997 Discusses Compliance Evaluation Rept Re Application ,revised 970214 & 0616 for Autoclave Manual Isolation Sys ML20140D9691997-06-0909 June 1997 Notification of 970611 Meeting W/United States Enrichment Corp in Piketon,Oh to Discuss Regulatory Issues ML20141B1361997-05-12012 May 1997 Revised Notification of 970515 Meeting W/Us Enrichment Corp in Bethesda,Md to Discuss Activities Related to Gaseous Diffusion Plants Operated by Licensee.Location of Meeting Has Been Changed ML20140G2031997-05-0202 May 1997 Responds to 970329 Request to Review & Provide Comments on Gaseous Diffusion Plants RTM-96 Supplements ML20138A1341997-04-22022 April 1997 Requests Technical Assistance in Review of Approval of Alternate Schedule for Submittal of Matl Balance & Inventory Composition Repts at Portsmouth Gaseous Diffusion Plant & Paducah Gaseous Diffusion Plant ML20137T1041997-04-11011 April 1997 Informs of 970417 Meeting W/Usec in Rockville,Md to Discuss Activities Re Gaseous Diffusion Plants Operated by Usec ML20140C4351997-04-10010 April 1997 Notification of 970410 Meeting W/Usec in Rockville,Md to Discuss Contamination Surveys of Outside Areas ML20137Q2001997-04-0909 April 1997 Informs of Cancellation of 970410 Meeting W/Usec in Rockville,Md to Discuss Contamination Survey of Outside Areas of Gaseous Diffusion Plants ML20140G2111997-03-29029 March 1997 Requests Review or Draft RTM-96 Supplements for Paducah & Portsmouth Gaseous Diffusion Plants ML20137K3191997-03-27027 March 1997 Discusses Certificate Evaluation Rept for Application Re Feed Facilities Crane Design Features ML20137C3051997-03-21021 March 1997 Requests Technical Assistance in Review of Certificate Amend Request for Paducah Gaseous Diffusion Plant to Revise Fundamental Nuclear Materials Control Plan ML20137A2301997-03-17017 March 1997 Requests Fr Notice Announcing Availability of Criteria for Staff Implementation of Backfitting Requirements for GDPs & NMSS GDP Backfit Procedure Be Published & Placed in PDR & Lpdrs Assigned to Portsmouth & Paducah GDPs ML20136F4811997-03-12012 March 1997 Summary of 970327 Meeting W/Usec to Discuss Activities Re Gaseous Diffusion Plants Operated by Usec ML20135E2251997-03-0404 March 1997 Notification of 970312 Meeting W/Usec in Piketon,Oh to Regulatory Issues ML20134L4921997-02-13013 February 1997 Notification of 970227 Meeting W/Usec Staff in Rockville,Md to Discuss Application for Laser Enrichment Facility ML20134D1141997-01-31031 January 1997 Notification of 970206 Meeting W/Usec in Rockville,Md to Discuss Merits of Criticality Accident Alarm Sys Exclusion Request ML20134D0721997-01-30030 January 1997 Notification of 960213 Meeting W/Usec in Rockville,Md to Conduct Monthly Status Meeting ML20134F8691997-01-30030 January 1997 Discusses Certificate Evaluation Rept for Application Re Cascade Cell Trip Function ML20133B6651996-12-31031 December 1996 Discusses 961111 Emergency Preparedness Training Tabletop Exercise Conducted at NRC Headquarters & Forwards Lessons Learned ML20132E0981996-12-16016 December 1996 Notification of 961218 Meeting W/Usec in Rockville,Md to Discuss Coordinatation of Orderly Transition of Uranium Enrichment Plants at Paducah,Ky & Piketon,Oh ML20132A6171996-12-11011 December 1996 Informs That Ticket G960838 Will Be Considered Cancelled for Nmss,Per EDO ML20135E5361996-12-0505 December 1996 Notification of 961210 Meeting W/Usec in Rockville,Md to Discuss Possible Amends to Certificates to Operate U Enrichment Plants at Paducah,Ky & Piketon,Oh ML20134G5781996-11-0808 November 1996 Notification of 961114 Meeting W/Usec in Rockville,Md to Update General Status on Certification Related Activities ML20132A6011996-11-0808 November 1996 Informs That Reply to Request for Extension of Ticket G960838 Has Been Forwarded ML20132A5951996-11-0707 November 1996 Informs That Ticket G960838 Is Extended to 961218 ML20129D5051996-10-0909 October 1996 Requests Comments on Encl Petition from M Donham & K Hanson Re Decision of NRC Director of NMSS to Issue Certificates of Compliance for Operation of Two Gaseous Diffusion Plants by Us Enrichment Corp.Served on 961009 ML20128K5491996-10-0404 October 1996 Informs That Encl Ltr from V Colley Being Treated as Petition for Review Under 10CFR76.62(c) & Recipient Invited to File Response or Comments by 961015 ML20149G9531994-11-0404 November 1994 Notification of Upcoming Meeting W/Us Enrichment Corp on 941109 to Discuss Role in Preparation of Compliance Plan & Current Status of Format & Content of Certificate Application 1999-08-31
[Table view] |
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UNITED STATES J NUCLEAR REGULATORY COMMISSION E
E WASHINGTON, D { k,l{h i
\ *****l U9] jdug19,g $9f6 DOCKET: 70-7001 PUBLIC DOCUMENT Rotti CERTIFICATE HOLDER: United States Enrichment Corporation Paducah Gaseour Diffusion Plant Paducah, KY j
. I
SUBJECT:
COMPLIANCE EVALUATION REPORT: APPLICATION DATED OCTOBER 31,1996, REVISED FEBRUARY 14, AND JUNE 16, 1997, AUTOCLAVE MANUAL ISOLATION SYSTEM BACKGROUND By letter dated October 31,1996, the United States Enrichment Corporation (USEC) requested an amendment to the proposed certificate of complL we for the Paducah i Gaseous Diffusion Plant (PGDP). The request was based on th:
- posed certificate because the final certificate was not issued until Novem12er 26,1996. The sequest is to incorporate a new Technical Safety Requirement (TSR) 2.4.4.13 associated with the Autoclave Manual Isolation System and to revise the appropriate pages in the Safety Analysis Report (SAR). By letters dated January 15,1997, the staff requested additional information. Staff review of the Feb'ruary 14,199L USEC response, generated a second i request for additional information dated May 1,1997. USEC responded to the second request by letters dated May 16, and June 16,1997. This amendment request was submitted in accordance with Compliance Plan issue 3.
DISCUSSION in Compliance Plan issue 3, Action 1, USEC committed to install manual push buttons l which would be used to place the feed facility autoclaves into containment upon I confirmation of a uranium hexafluoride release. The push buttons were to be installed at l the Operations Monitoring Room (OMR) door and at the crane bay exit near the local l
- cylinder yard and would be activated by the operator as the operator left the area upon i seeing a release. A third push button was to be installed in the Area Control Room (ACR).
The Compliance Plan required USEC to submit a TSR for the autoclave manual isolation system, i The autoclave manual isolation system provides a mechanism to remotely isolate all the l autoclaves in the feed facility in the event of a uranium hexafluoride release from piping outside the autoclave. The manual isolation device allows the simultaneous isolation of all autoclaves in the affected facility. Previously this was conducted individually for each autoclave by simulating a high-high conductivity signal which would place the autoclave 1
into containment mode. Placing the autoclave into containment eliminates the source of uranium hexafluoride available for release thus terminating the release.
The system, as installed, consists of two local (within the feed facilities) actuation devices (pull buttons) located in the OMR and at the cylinder yard crane bay exit, and one remotely l '
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- i. 2 i located actuation device in the associated cascade building ACR. The cylinder yard crane bay exit is the most likely point of egress frorn the autoclave area in the event of a release. ,
(Note that USEC installed pull buttons versus the push buttons designated in the !
compliance plan to reduce the potential for inadvertent actuation; the staff finds the pull j buttons to be an acceptable alternative). The remainder of the system consists of the programmable logic controller, the autoclave isolation valves, and the interconnections j between the components. The actuation device sends a signal to the programmable logic i controller which then sends a signal to close the isolation valves on the autoclaves, i TSR 2.2.4.13 requires the autoclave manual isolation system actuation devices to be operable while the autoclave is in the closed mode or in a heating, feeding, or heeling operational mode, if only one local device is available, an operator is appropriately ,
stationed, within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, to activt 'e the operable actuation device, if both local devices j are inoperable, one device must be restored to an operable status within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. If I operability is not restored within the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> window, actions must be immediately taken to l close containment valves or place the autoclave in an open or out of service mode, or i operations can continue by establishing radio communication with the ACR to ensure !
immediate capability to actuate the system from the ACR in the event of a release and l restoring operability within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Since at least one of the actuation devices is i available during operations and there is a UF. release detection system in the area, the 4 ;
hour window is acceptable. The surveillance required by this TSR is an annual functional ;
test of the system actuation devices. The actuation device and the signal sent from the l actuation device to the programmable logic controller are tested annually. The l programmable logic controller, valve closure signal, and the isolation valves are tested i quarterly as part of the surveillance for the autoclave high pressure isolation system. An I annual surveillance is acceptable for testing the system under this TSR.
USEC also submitted changes to the SAR to remove the Compliance Plan references and to make the system a Q system under the quality assurance program. As part of the original amendment package, USEC submitted changes to the Compliance Plan to reflect pull button actuation devices versus the push button type specified in the Compliance Plan.
The staff has determined a revision to the Compliance Plan is not necessary and therefore will not include the Compliance Plan changes in the amendment to the Certificate.
ENVIRONMENTAL REVIEW lssuance of an amendment to Certificate of Compliance GDP-1 to include a new TSR that addresses the autoclave manual isolation system is subject to the categorical exclusion q provided in 10 CFR 51.22(c)(19). Therefore, neither an environmental assessment nor an i environmental impact statement is required for the proposed action. i l
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I CONCLUSION I i
1 The proposed TSR 2.4.4.13 on the Autoclave Manual isolation System provides a means ;
j to remotely isolate all facility autoclaves in the event of a uranium hexafluoride release '
from the piping outside the autoclave. This system is considered an enhancement in l support of the mitigation of a release. The staff recommends that the new TSR and the !
l SAR changes be approved. Issuance of the certificate amendment will close Action 1 of l
Compliance Plan issue 3.
The Region !!! Inspection staff have no objection to this proposed action. l l l l
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Princioal Contributor l Merri Horn i
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