ML20198E426
| ML20198E426 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 12/15/1998 |
| From: | Toelle S UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Paperiello C NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| GDP-98-0279, GDP-98-279, NUDOCS 9812240054 | |
| Download: ML20198E426 (2) | |
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4.
USEC A Global Energy Cornpany l
Decernber 15s 1998 GDP 98-0279 Dr. Carl J. Paperiello 1
Director, Office of Nuclear Material Safety and Safeguards Attention: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Paducah Gaseous Diffushon Plant (PGDP)
Docket No. 70-7001 Notification of Deletion in Regulatory Commitments - Criticality Accident Alarm System Audibility Upgrades
Dear Dr. Paperiello:
Pursuant to Compliance Plan issue Cl, " Transition from Department of Energy (DOE) Regulation to the United States Nuclear Regulatory Commission (NRC) Regulation," USEC requests NRC consent to delete the following four (4) regulatory commitments associated with modifications to the Criticality Accident Alarm System (CAAS) to resolve audibility issues. These commitments were made in the following USEC letters: USEC letter to DOE Regulatory Oversight Manager from Nuclear Regulatory Assurance Policy Manager dated May 1,1996, on Criticality Accident Alarm System (CAAS) Inaudibility; PGDP Event Report PAD-1996-0030 to DOE; PGDP Event Report ER-98-010, dated June 9,1998, to NRC; and, PGDP Event Report ER-98-013, Rev.1, dated July 10, 1998, to NRC. USEC requests NRC consent to delete these commitments since they are redundant to the actions contained in Compliance Plan Issues 46 and 50.
Description of Commitments Prior to transition from DOE to NRC oversight, a number of commitments were being pursued on the Criticality Accident Alarm System to rescIve audibility issues documented in various problem reports and event reports. These actions are being implemented as part of Compliance Plan Issues 46 and 50. Compliance Plan Issues 46 and 50 require plant modifications to ensure that the CAAS alarm horns are capable of being heard throughout the affected areas of the process building and to provide CAAS alarm horns for those unalarmed facilities within the eucuation area of CAAS-clustered buildings, respectively. The first commitment to the NRC was made in the May 1,1996, letter to the DOE Regulatory Oversight Manager. In this letter USEC committed to " perform the l-engineering and install the necessary plant modifications to ensure that the CAAS alarm horns are capable of being heard throughout the affected areas of C-331, C-335, and C-337," The 1996 DOE event report (PAD-1996-0030) committed PGDP as follows: " Evacuation horns will be installed in the unalarmed buildings located within the evacuation area of CAAS clustered buildings if nearby C'A AS horns cannot be heard." These commitments were subsequently contained in USEC letter I
9812240054 981215 I~
PDR ADOCK 07007001[
C f@ A j PDR 3erhesda, MD 20817-1818 Telephone 301-564-3200 Fax 301-564-3201 http://www.usec.com i
Oflices in Livermore, CA Paducah, KY Portsmouth, OH Washington, DC
Dr. Carl J. Paperiello December 15,'1998 GDP 98-0279, Page 2 to NRC dated March 1,1997 (reference sSEC letter GDP 97-0023), which contained a list of open commitments at the time of transition to NRC Regulatory Oversight.
In 1998, two event reports were sent to the NRC related to plant air failures. In those reports commitments were made to modify the air systems to minimize CAAS reliance on plant air.
Specifically, ER-98-010 stated," Engineering will complete a construction project to reduce CAAS dependence on the existing air system by installing air accumulators and air distribution piping that will be dedicated to supply compressed air to CAAS horns." ER-98-013, Rev.1, committed that
" Engineering will complete a construction project that will remove the CAAS dependence on the existing air system by installing air accumulators and air distribution piping that will be dedicated to supplying compressed air to the CAAS horns."
Description of Change USEC proposes to delete the above commitments.
Justification for Commitment Change The above commitments are redundant to the actions contained in Compliance Plan Issues 46 and
- 50. Per these Compliance Plan issues, a CAAS Modification Project has been initiated to design and install additional CAAS horns with dedicated air supplies to ensure adequate audibility throughout the process buildings and for unalarmed facilities within the evacuation area of CAAS-clustered buildings. Because of recent design changes and the application of the new design to all CAAS systems at PGDP, the Compliance Plan due date needed changing. As a result, a Certificate Amendment Request (CAR) was submitted to the NRC on November 5,1998. This CAR proposed to change the Compliance Plan Issue due date from December 15,1998, to January 18,2000. The Compliance Evaluation Report associated with this CAR was issued on December 7,1998, and recoramends that the Compliance Plan be revised to reflect the new completion date for Issue 46 and
- 50. USEC is deleting the above regulatory commitments since they are redundant to the actions contained in Compliance Plan issues 46 and 50, which require NRC approval to change.
Please contact Larry Jackson at (502) 441-6796 if you have any questions regarding this matter.
Sincerely, a
S. 4.
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Steven A. Toelle Nuclear Regulatory Assurance and Policy Manager cc: NRC Region III Office NRC Resident Inspector - PGDP