ML20239A227

Compliance Evaluation Rept Supporting Amend to Coc GDP-1, Supporting Addition of New Criticality Accident Alarm Sys Cluster,Changing Surveillance Frequency & Correcting Cross Reference

ML20239A227
Person / Time
Site:	07007001
Issue date:	08/24/1998
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20239A222	List: ML20239A220 ML20239A227 ML20239A229
References
NUDOCS 9809080326
Download: ML20239A227 (2)

Text

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, k UNITED STATES l g g NUCLEAR REGULATORY COMMISSION o WASHINGTON, D.C. 30666-0001

• • • • • August 24, 1998 DOCKET: 70-7001 CERTIFICATE HOLDER: United States Enrichment Corporation Paducah Gaseous Diffusion Plant Paducah, KY

SUBJECT:

COMPLIANCE EVALUATION REPORT: APPLICATION DATED MAY 13,1998, AS REVISED AUGUST 12,1998; CAAS SURVEILLANCE FREQUENCY REVISION FOR TSR 2.3.4.7; AND CROSS REFERENCE REVISION FOR TSR 2.2.

4.4 BACKGROUND

By letter dated May 13,1998, the United States Enrichment Corporation (USEC) requested an an.ertdment to Certificate of Compliance GDP-1 for the Paducah Gaseous Diffusion Plant (PGDP). The request was to revise Technical Safety Requirement (TSR) 2.6.4.1 to add a new criticality accident alarm system (CAAS) cluster, revise TSR 2.3.4.7 to change a surveillance frequency, and to revise TSR 2.2.4.4 to correct a cross reference. The new cluster (AC) proposed for inclusion in TSR 2.6.4.1 covered DOE operations in C-746-O-1.

Because the staff has no regulatory authority over DOE, the staff requested (by letter dated July 9,1998) that USEC remove this part from the amendment request. By letter dated August 12,1998, USEC withdrew the proposed revision to TSR 2.6.4.1 that would have added cluster AC in the C-746-O-1 facility to the TSR.

DISCUSSION Surveillance Requirement 2.3.4.7a-1 currently requires a quarterly surveillance for the calibration of the CAAS equipment. This TSR covers the product withdrawal facility.

USEC has proposed changing the calibration frequency to annual. The TSRs that cover the CAAS for the other facilities all require an annual calibration. it appears that the quarterly calibration requirement was inserted due to an editorial error between revisions 4 and 5 during the initial review, and was not caught by USEC or NRC staff. The staff did not require quarterly calibration for this system during the initial certification review. There is no technical reason why the CAAS for the product withdrawal facility should be calibrated on a more frequent basis than similar systems in other areas of the facility. The ANSI standard addressing alarm systems, ANSI /ANS 8.3, " Criticality Accident Alarm System,"

does r,at address calibration frequency, it does recommend periodic testing. The TSR contains a surveillance requirement to conduct quarterly tests of the CAAS. The staff believes that the annual calibration together with the quarterly testing of the system is adequate, is consistent with the CAAS calibration requirements for other buildings at the Paducah site, and meets ANSI /ANS 8.3 requirements.

In this amendment, USEC has also requested to correct a cross reference between TSRs.

TSR 2.2.4.4, Cylinder Heating-Cylinder Accountability Weight, Required Action A.2.1 currently contains a cross reference to TSR 2.1.3.3 instead of TSR 2.2.3.3. The required 9009000326 980824 PDR ADOCK 07007001 C PM .

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, cctions in TSR 2.2.4.4 est:blish tha cctions to tcks wh:n tha a: countability w:ight of a {

cylinder to be heated in the feed facilities exceeds the maximurn filllimit. Currently l Required Action A2.1 requires setting the autoclave steam pressure control system set point l consistent with the cylinder category per TSR 2.1.3.3. TSR 2. l.3.3 establishes the I requirements for operating the autoclave steam pressure control system for the Toll Transfer and Sampling Facility (C-360). TSR 2.2.3.3 establishes the same controls for the autoclave steam pressure control system for the feed facilities (C-333A and C-337A). Limiting the steam pressure indirectly limits the volume of liquid UF6 in the cylinder, preventing loss of ullage and over pressurization. Both TSR 2.1.3.3 and 2.2.3.3 contain the same requirements, but for different f acilities. With the proposed change to the cross reference contained in TSR 2.2.4.4, Required Action A.2.1 will now reference the autoclave steam pressure control system TSR for the feed f acilities. The correction will avoid any potential )

confusion of the operator. '

ENVIRONMENTAL REVIEW lssuance of an amendment to Certificate of Compliance GDP-1 to revise the TSRs to change a CAAS surveillance frequency and to correct a cross reference is subject to the categorical exclusion provided in 10 CFR 51.22{c)(19). Therefore, neither an environmental assessment nor an environmental impact statement is required for the proposed action.

CONCLUSION The proposed revisions to TSR 2.3.4.7 to revise a CAAS surveillance frequency and to TSR 2.2.4.4 to correct a cross reference are appropriate and will continue to provide adequate protection to the public health and safety. The staff recommends that the revised TSRs be approved.

The Region 111 Inspection staff have no objection to this proposed action.

Princioal Contributor Merri Horn DISTRIBUTION: (Control No. 420S)

Docket 70-7001 NRC File Center PUBLIC Rlli KO'Brien, Rlli NMSS r/f NMSS dir. ofc. r/f FCSS r/f FCOB SPB r/f PHiland, Rlli fFC SPB b hBf SPB.

b M NAME orn:ij Hoadley D tin erson DATE f /17/98 98 f /0/98 $/N/98 C = COVER E = COVER & ENCLOSURE N = NO COPY OFFICIAL RECORD COPY l

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