ML20198E593

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Responds to NRC 981201 RAI Re Changes Made to Certification Application,Per 10CFR76.68.Info Re Appropriateness of Removing Criticality Accident Alarm Sys Lights as Safety Sys Components in Bldg C-710 Encl
ML20198E593
Person / Time
Site: Paducah Gaseous Diffusion Plant
Issue date: 12/18/1998
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-98-0273, GDP-98-273, NUDOCS 9812240095
Download: ML20198E593 (3)


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o USEC A Global Energy Company December 18,1998 l

GDP 98-0273 Dr. Carl J. Paperiello Director, Office of Nuclear Material Safety and Safeguards Attention: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Paducah Gaseous Diffusion Plant (PGDP)

Docket No 70-7001 Response to Request for Additional Information - Paducah Update to Certification Application

Dear Dr. Paperiello:

By letter dated December 1,1998 (Reference 1), the NRC requested additional information regarding changes made to the certification application under 10 CFR 76.68. This letter identified a concern over the appropriateness of removing the criticality accident alarm system lights as safety system components in Building C-710 and associated facilities without obtaining prior NRC approval.

USEC's response to this concern is provided in Enclosure 1.

Should you have any additional questions concerning this subject, please contact Mark Smith at (301) f 64-3244. There are no new commitments contained in this submittal.

Sincerely, S. i

/

lf Steven A. Toelle Nuclear Regulatory Assurance and Policy Manager N h

. <~ r 9812240095 981218 PDR ADOCK 07007001 C

PDR I

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6903 Rockledge Drive, liethesda MD 20817-1818 Telephone 301-564-3200 Fax 301-564-3201 http://www.usec.com Offices in Livermore, CA Paducah, KY Portsmouth. OH Washington, DC

s.

Dr. Carl J. Paperiello December 18,'1998 -

L GDP 98-0273, Page2 '

References:

Letter from Merri Horn (NRC) to Mr. James H. Miller (USEC), "Paducah Update to Certification Application, December 1,1998.

Enclosures:

United States Enrichment Corporation, Paducah Gaseous Diffusion Plant,'

Docket No. 70-7001, Response to Request for Additional Information Paducah Update to the Certification Application cc:

Mr. Robert C. Pierson, NRC HQ NRC Region III Office

' NRC Resident Inspector - PORTS NRC Resident Inspector - PGDP s

i

N, GDP 98-0273 Page1of1 United States Enrichment Corporation Paducah Gaseous Diffusion Plant Docket No. 70-7001 Response to Request for AdditionalInformation Paducah Update to the Certification Application Ouestion:

"USEC has stated that the changes to the Safety Analysis Report were made in accordance with 10 CFR 76.68 and did not require prior NRC approval. Our review of those changes has identified a concern over the appropriateness of that conclusion as it relates to removing the criticality accident alarm system lights as safety system components in Building C-710 and associated facilities.

Downgrading the lights to non-safety system components could be viewed as decreasing the effectiveness of the nuclear criticality safety program. Please explain the basis for the change."

1 Resoonse:

The C-710 Building and associated facilities (C-709) have had the criticality accident alarm system (CAAS) upgraded to satisfy Compliance Plan Issues 8 and 50. The original C-710 CAAS did not have alami homs for the roof and surrounding outdoor area within the evacuation zone. The plant credited red rotating beacons mounted on the exterior of C-710 for alerting personnel in the vicinity of the building that the CAAS alarm is in effect. The upgraded CAAS added outdoor alarm horns for evacuation of personnel within the 12 Rad boundary that extends outside of the C-709 and C-710 buildings. The outdoor alarm horns replaced the red warning lights as a more effective method to satisfy the CAAS safety function to immediately evacuate personnel. The upgraded CAAS provides detection and audibility alarm coverage, which meets the requirements of OSIIA 1910.96 and i

ANSI /ANS 8.3. The addition of audible alarm horns (20 fold increase in the number of horns over the formerly installed CAAS) on the outside of the C-709 and C-710 facilities provides a comparable alarm signal necessary for immediate evacuation ofpersonnel for the 12 Rad boundary. A limitation when using audible alarms is recognizing the source of the sound in areas with close structures which could cause the sound to reverberate. Ilowever, this is not a concern for the CAAS alarm homs installed outside the C-709 and C-710 facilities due to the relatively open spaces surrounding the facility. Other CAAS protected facilities in the plant are remotely located from the C-709 and C-710 facilities. This separation prevents confusion which could be caused by simultaneous initiation of i

other CAAS facility alarm horns. With the new CAAS installation, the effectiveness of the criticality safety program has been enhanced over that which was formerly installed.