ML20236U546

Submits Response to NRC RAI Re Criticality Safety Evaluations for Un Bulk Storage Sys & Adu Conversion Process

ML20236U546
Person / Time
Site:	Westinghouse
Issue date:	07/24/1998
From:	Goodwin W WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:	Gaskin C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
CON-NRC-98-033, CON-NRC-98-33 TAC-L30812, TAC-L30877, NUDOCS 9807300264
Download: ML20236U546 (3)

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h NRC-98-033 July 24,1998 U. S.. Nuclear Regulatory Commission i

ATTN: Mr. Charles E. Gaskin Licensing Section 1, Licensing Branch FCS&S Division, NMSS 11545 Rockville Pike Mail Stop T8D14 Rockville, MD 20852-2738

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING CRITICALITY SAFETY l

EVALUATIONS (TAC NOS. L30812 AND L30877) DATED JUNE 26,1998 l

REFERENCE:

1)

NRC LETTER TO WESTINGHOUSE (MR. ROBERT A. WILLIAMS)

DATED NOVEMBER 25, 1997 REGARDING REQUIRED CRITICALITY SAFETY ANALYSIS SUMMARIES 2)

NRC LEITER TO WESTINGHOUSE (MR. ROBERT A. WILLIAMS)

DATED J ANUARY 28,1998 REGARDING A REQUEST FOR ADDITIONAL INFORMATION

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3)

WESTINGHOUSE REPLY (NRC-98-014) TO A NOTICE OF VIOLATION C'

DATED APRIL 17,1998 4)

WESTINGHOUSE LETTER (NRC-98-027) TO NRC DIRECTOR, OFFICE OF &

NMSS, REQUESTING REPLACEMENT OF LICENSE SAFETY CONDITION, DATED JULY 13,1998.

This letter is in response to your subject request for additional information (RAI) regarding our criticality safety evaluations (CSE's) for our UN Bulk Storage System (TAC No. 30812) and ADU Conversion Process (TAC No. 30877).

On November 25,1997, you requested additional technical information (Reference 1) pertaining to our criticality safety analyses (CSA's) for twelve (12) different plant processes / process systems, including the two mentioned above. CSA summaries, or CSE summaries and fault trees, for each of the listed processes / process systems had been previously submitted to NRC, during the period September 29,1995 - April 30,1997, to comply with Condition S-2 of our Materials License SNM-1107. Because of the significant level of effort required to respond to that RAI, which would have greatly detracted from the substantial ongoing effort to upgrade our CSA's/CSE's and develop integrated safety assessments (ISA's), you agreed to our request to 9007300264 980724 l

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b L*j NRC-98-033 Page 2 July 24,1998 i

defer our response to your RAI until this matter could be discussed at the January 9,1998 Westinghouse /NRC Management meeting.

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Westinghouse presented arguments for not responding to the November 25, 1997 RAI at the subject mars;ement meeting. NRC management subsequently agreed to withdraw the RAI as l

later documented in your letter to Westinghouse dated January 28,1998 (Reference 2). It was l

also agreed by NRC management that your technical reviews would be better served by a da ect

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l site visit as documented in your same letter. Accordingly, site visits to the Columbia Plant were i

made by Licensing Branch representatives during the periods January 13-15 and March 31 -

l April 3,1998.

Since the subject management meeting, Westinghouse has continued to devote extensive effort to upgrading existing CSA's/CSE's and developing ISA's for plant process / process systems in accordance with the schedule documented in our letter to NRC dated April 17,1998 (Reference 3). ISA summaries, in the form of SNM License Annexes, and fault trees for the Plant Ventilation Systems and UN Bulk Storage System were submitted to you on March 31,1998 and April 30,1998, respectively. The ISA summary and fault trees for the ADU Conversion Process is scheduled to be submitted to you on or before August 15,1998.,

Upon review of your most recent RAI, we have concluded that it requests essentially the same l

information as the November 25,1997 RAI, for the two processes / process systems in question.

We also submit that the CSA/CSE/ISA summaries (License Annexes) being provided to you, since the January 9,1998 management meeting, are much more extensive and detailed than those l

previously provided. Consequently, it is respectfully requested that you reconsider your latest l

RAI for the following reasons:

1) Westinghouse believes that the information currently being provided should be more than sufficient to meet its codunitment to, and demonstrate compliance with, Condition S-2 of our Materials License SNM-1107.

Moreover, at the request of the NRC License Project Manager, we have submitted a request (Reference 4) to replace License Condition S-2 with l

the CSA/CSE/ License Annex upgrade schedule.

2) Provision of additional detailed information, over and above that previously committed to, will seriously detract from our substantial ongoing efforts to upgrade existing CSA's/CSE's and develop ISA's as currently scheduled.

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3) Detailed information regarding CSA's/CSE's/ISA's is on file at the Columbia Plant and remains readily available for NRC review at any time, as necessary to supplement the l

License Annex summaries being submitted.

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NRC-98-033 Page 3 July 24,1998 i

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4) Westinghouse continues to believe that NRC's technical reviews of CSA/CSE/ISA i

information would best be accomplished by reviewing the information being formally submitted by Westinghouse coupled with onsite visits to the Columbia Plant.

l Please advise if you have any questions, or need additional information.

Sincerely, WESTINGHOUSE ELECTRIC COMPANY l

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W. L. Goodwin, Manager Regulatory Affairs l

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