ML20154A615
| ML20154A615 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 09/26/1998 |
| From: | UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | |
| Shared Package | |
| ML20154A608 | List: |
| References | |
| DOE-ORO-2027, NUDOCS 9810020361 | |
| Download: ML20154A615 (3) | |
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PLAN FOR ACHIEVING COMPLIANCE WITH NRC REGULATIONS AT THE PORTSMOUTH GASEOUS DIFFUSION PLANT (Compliance Plan-DOE /ORO-2027)
REMOVE / INSERT INSTRUCTIONS Revision 8 Remove Pages Insert Pages Issue 11 Pages I / 2 Pages 1/ 2 3
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r GDP-98-0202 Revision 8 to DOE /ORO-2027
" Plan for Achieving Compliance With NRC Regulations at the Portsmouth Gaseous Diffusion Plant" l
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l Issue 11, Page 1 l
Exceptions for Criticality Accident Alarm System i
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REQUIREMENT 10 CFR 76.89(a) "(a) The Corporation must maintain and operate a criticality monitoring and audible I
alarm system meeting the requirements of paragraph (b) of this section in all areas of the facility. The Corporation may describe for the approval of the Commission defined areas to be excluded from the monitoring requirement. This submittal must describe the measures that will be used to ensure against criticality, including kinds and quantities of material that will be permitted and measures that will be used to control those kinds and quantities of material."
COMMITMENTS
- 5. Nuclear Safety Programs
.5.2 Nuclear Criticality Safety 5.2.2 Program Elements 5.2.2.5 Criticality Accident Alarm System Coverage and Nuclear Accident Dosimetry (Rev. 3,5/31/96)
"A CAAS [ criticality accident alarm system) is provided to alert personnel if a criticality accident should occur.
l USEC will submu, in accordance with the Compliance Plan, the analyses for alarm settings, detector placement and the analyses required by 10 CFR 76.89(a) to demonstrate that criticality monitoring and alarm coverage is not required in certain areas of the facility."
DESCRIPTION OF NONCOMPLIANCE A criticality accident alarm system is not provided for all areas of the facility, Uraniutr..ylinder and low-level waste storage areas and some fissile materia. activities have been excluded consistent with DOE guidance. NRC approval has not been received for excluding the applicable plant areas (i.e., those centaining > 700 grams of *U) from criticality accident alarm system coverage.
JUSTIFICATION FOR CONTINUED OPERATION The existing Safety Analysis Report and other doeurnents identify plant locations where criticality accident alarm system monitoring is provided. He report and documents also recognize that the other plant areas do not have such monitoring. heas not covered by a criticality accident alarm system (i.e., uranium cylinder storage yards, low-level waste storage areas, and some tissile material transportation activities) were selected because of the intrinsic nature of the configurations and the materials allowed in the areas, including container integrity and/or low fissile material density. Many
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of these areas are not occupied on a regular basis. This approach is consistent with historical DOE l
requirements, which allowed plant areas to be excluded from criticality accident l
PORTS Rev. 3, 7/W96
Issue 11, Page 2 Excepdons for Criticality Accident Alarm System alarm system coverage because of documented analyses that there v'as no credible risk of a criticality accident in those areas.
PLAN OF ACTION AND SCIIEDULE 10 CFR 76.89(a) permits USEC to request NRC approval for specific areas to be excluded from criticaJty accident p.sm system coverage. USEC will provide criticality detector coverage in all areas of the p. ant except for those areas identified and justified by USEC and approved by NRC. Analyses that provide the technical justification for not providing criticality accident alarm system coverage in designated areas of the plant are being developed. Except for Buildings X-330, X-333, and X-700, analyses have been submitted to NRC that (1) verify the adequacy of the existing criticality accident alarm system and its detector locations for detecting a criticality accident and (2) justify that detectors are not required for monitoring other areas of the plant. The analyses for Buildings X-330, X-333, and X-700 will be completed by September 30,1996. This compliance plan issue will be modified to provide a plan and schedule for establishing adequate detector coverage if the adequacy of the current detector coverage is not verified by the NRC review.
SUS 131ARY OF REQUIRE 31ENTS, CO31311TSIENTS, AND NONCONIPLIANCES issue: Exceptions for Criticality Accident Alarm System Code of Federal Regulations Part Title 10 76.89(a)
Application Commitment Section Safety Analysis Report 5.2.2.5 Technical Safety Requiremeitts 2.1.3.1, 2.2.3.2, 2.4.3.1, 2.5.3.1, 2.6.3.4, 2.7.3.2. 2.8.3.1 Application Noncompliance Statement Section Safety Analysis Report 5.2.4.8 s
O PORTS Rev. 8, 9/26/98
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