ML20199L359

Compliance Evaluation Rept Approving Cross Ref for Product & Tails Withdrawal & Cascade Facilities Criticality Accident Alarm Sys

ML20199L359
Person / Time
Site:	07007001
Issue date:	11/25/1997
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20199L355	List: ML20199L350 ML20199L359 ML20199L363
References
NUDOCS 9712020004
Download: ML20199L359 (2)

Text

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[pu:g ' *i UNITED STATES

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NUCLEAR REGULATORY COMMISSION WASHINoToN. D.C. 20666-0001

%*****/ November 25, 1997

. DOCKET: 70 7001 CERTIFICATE HOLDER: United States Enrichment Corporation Paducah Gaseous Diffusion Plant Paducah,KY

SUBJECT:

COMPuANCE EVALUATION REPORT:

APPLICATION DATED OCTOBER 6,1997, PRODUCT AND TAILS WITHDRAWAL AND CASCADE FACILITIES CRITICALITY ACCIDENT ALARM SYSTEM CROSS REFERENCE BACKGROUNQ By letter dated October 6,1997, the United States Enrichment Corporation (USEC) requested an amendment to the Certificate of Compliance for the Paducah Gaseous Diffusion Plant (PGDP). The request is to revise Technical Safety Requirement (TSR) 2.3.4.7 and TSR 2.4.4.2, Criticality Accident Alarm System (CAAS) to add a new Required Action under Condition A of both TSRs which provides a cross reference between the two TSRs. The changes represent an attempt to assure all necessary Required Actions are performed when the C 310 CAAS is !noperable.

DIEUSSION Building C-310 contains both cascade equipment and product withdrawal equipment which is covered by the same CAAS, Currently, the requirements concerning the CAAS are provided in separate TSRs - TSR 2.3.4.7 covers product withdrawal and TSR 2.4.4.2 covers cascade operations. The plant stuff has experienced difficulties in implementing these TSRs during CAAS inoperabilities which have resulted in violations because not all of the required actions were completed, USEC is proposing to add the cross reference to explicitly point out the relationship between the CAAS TSRs for the product tails withdrawal and the cascade facilities. The proposed revision should alleviate a human factors concern and leave less room for operator error. The proposed changes do not present any new or changed requirements, they are mainly administrative changes to link two elements of the CAAS TSRs for C-310 more clearly. The staff has determined that these changes will not adversely affect safety, rather they clarify safety requirements for staff performing safety functions.

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EtiVBONMENTAL REVIEW lssuance of an amendment to cross reference Technical Safety Requirement (TSR) 2.3,4.7 and TSR 2.4.4.2, Criticality Accident Alarm System, will have no significant impact on the human environment. Therefore, in accordance with 10 CFR 51.22 (c)(19), neither an environmental assessment nor an environmental impact statement is warranted for the proposed action.

CONCLUSION Based on the discussion, the staff concludes that providing a cross reference for the product and tails withdrawal and cascade f acilities CAAS TSRs will clarify necessary required actions and imnrove human factors. Therefore, the staff recommends that the revised TSRs be approved.

The Region tilinspection staff and the Operations Branch inspection staff have no objection to this prc;ased action.

Princioci Contributor:

Priya Pate!

DISTR!BUTIO!J: (Control No. 330S)

Docket 70-7001 Public NRC File Center KO'Brien, Rlli PHiland, Rill NMSS R/F FCSS R!F SPB R/F Rlil FCOB oFC sPB d SP8 iSPB SPB [

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