ML20217Q999
| ML20217Q999 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 05/05/1998 |
| From: | Toelle S UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Paperiello C, Paperiello C NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| GDP-98-0083, GDP-98-83, NUDOCS 9805130075 | |
| Download: ML20217Q999 (3) | |
Text
3
)
)
pc ol e USEC A Global Energy Ca.mpany May 5,1998 GDP 98-0083 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 Request to Delete Regulatory Commitments - UF, Leak Detection Repair Project
Dear Dr. Paperiello:
Pursuant to Compliance Plan Issue C1," Transition from DOE Regulation to NRC Regulation,"
USEC requests NRC consent to delete the following regulatory commitments associated with implementation of modifications and repairs to the Process Gas Leak Detection (PGLD) System.
.p USEC has determined that existing Technical Safety Requirement (TSR) 2.4.4.1, which requires the PGLD detectors to be operable prior to exceeding atmospheric pressure for steady state operations, obviates the need for the commitments described below.
Description of Commitment USEC letter, GDP 97-002.i, dated March 1,1997, submitted to NRC a summary list of open USEC regulatory commitments to the Department of Energy (DOE) as required by Complianc e Plan Issue C1," Transition from DOC Regulation to NRC Regulation." The commitments that USEC requests be deleted are as follows:
1.
" Assure reset switches are replaced and reset switch status indicating lights are installed on high voltage PGLD systems in cascade areas currently not scheduled for above atmospheric operation but which have a potential to be scheduled for above atmospheric operation."
(UC95A0052/UC9512021-005) 2.
" Complete activities described in the Project Change Order for ESO Z91460. (i.e., Project Change Order No.1, dated May 1996, approved July 25,1996.) (UC96A0007/UC9615310-004) 9905130075 990505" i
PDR ADOCK 07007001 Q
C PDR-I 6903 Rockledge Drive, Bethesda. MD 20817-1818 em g-Telephone 301-564-3200 Fax 301-564-3201 http://www.usec.com Offices in Livermore, CA Paducah KY Portsmouth. OH Washington, DC gg 0 6 Y
u Dr. Carl J. Paperiello May 5l1998 '
GDP 98-0083, Page 2 1
)
The due date for the above commitments is June 30,1998 Prior to transition from DOE to NRC oversight, a number of actions were being pursued on the PGLD System to resolve issues documented in various problem reports and event reports resulting from component failures and recommended operational enhancements. These actions, which include the subject commitments, are being implemented as part of the Process Gas (UF.) Leak Detection (PGLD) Repair Project (Engineering Service Order [ESO] Z91460). The first com: dtment was intended to install " Ready Lights" to specifically indicate when the PGLD detector had oeen reset by the operator following detector actuation. The reset was to be accomplished using a reset switch which would also be replaced as part of the project. The original switches had begun to fail due to exceeding their expected duty. This commitment was originally made in Event Report PAD-1995-0032. The second commitment was intended to implement the above ESO which encompassed the replacement, upgrade, and modification ofvarious PGLD System parts to increase system reliability and reduce false actuations. This commitment was originally made in Event Report PAD-1996-0028.
Description of Change USEC proposes to delete the above commitments.
1 Justification for Commitment Change Prior to the DOE to NRC transition, USEC completed the necessary PGLD System repairs and
" Ready Light" modifications for those areas of the plant where cascade pressures were expected to exceed atmospheric pressure. These areas were Units 2-5 of building C-333. After transition to
'NRC, TSR 2.4.4.1 was implemented which recuires operable PGLD detectors or other compensatory actions prior to exceeding atmospheric prersure for steady state operations. The PGLD Project specifies not only the completion of actions which are necessary to declare portions of the PGLD System operable by the TSRs, but also include enhancements to improve reliability. Because the TSR requires UF detectors to be operable for steady state operation above atmospheric pressure, 6
USEC will be bound by the applicable Limiting Condition for Operation Actions until the repairs to inoperable systems are accomplished. Therefore, deletion of the subject commitments present no reduction in safety margin.
l The present TSR 2.4.4.1 requires a minimum number of operable UF. detectors prior to steady state operation in areas of the cascade where pressures are expected to exceed atmospheric pressure.
i Currently, upgrades to the PGLD system are planned to be performed in the following buildings:
C-331, Units 2 and 3; building C-333, Units I and 6; building C-335, Units 2 and 3; and building C-337, all units.
'Dr. Carl J. Paperiello May 5;1998 '
GDP 98-0083, Page 3 Deletion of the above commitments is appropriate in this instance as the TSR obviates the need for these commitments.
Please contact Larrf ackson at (502) 441-6796 if you have any questions regarding this matter.
J Sincerely,
/1 S. h.
lN
' Steven A. Toelle Nuclear Regulatory Assurance & Policy Manager j
cc: NRC Region III Office i
NRC Resident Inspector-PGDP l
.