ML20135D699

Responds to Request for Review of & Response to Usec'S Understanding Related to Certain Requirements Imposed by Tsrs & Compliance Plan for CAAS Audibility Re Two Ltrs

ML20135D699
Person / Time
Site:	07007001
Issue date:	02/28/1997
From:	Pierson R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	John Miller UNITED STATES ENRICHMENT CORP. (USEC)
References
NUDOCS 9703050421
Download: ML20135D699 (3)

Text

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UNITED STATES NUCLEAR REGULATORY COMMISSION  ;

'E WASHINGTON, D.C. 20666-0001

%, . . . . . p February 28, 1997 i

Mr. James H. Miller Vicie President, Production U. S. Enrichment Corporation 2 Democracy Center 6903 Rockledge Drive Bethesda, MD 20817

SUBJECT:

LINKAGE OF CRITICALITY ACCIDENT ALARM SYSTEM (CAAS) TECHNICAL SAFETY REQUIREMENTS (TSRs) AND COMPLIANCE PLAN REQUIREMENTS FOR PORTSMOUTH (PORTS) AND PADUCAH (PGDP) GASEOUS DIFFUSION PLANTS  :

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Dear Mr. Miller:

This refers to two of your letters dated February 14,1997 (GDP 97-0013 for PGDP and GDP 97-0015 for PORTS) requesting a review of and response to USEC's understanding related to certain requirements imposed by the TSRs and the Compliance Plan for CAAS  !

audibility.

PORTS TSRs 2.1.3.1 b, 2.2.3.2b, 2.4.3.1 b, 2.5.3.1 b, 2.6.3.4b, 2.7.3.2b, and 2.8.3.1 b '

require CAAS audibility in all areas where the maximum foreseeable atsorbed dose in free air exceeds 12 rad. Issue 44 of the PORTS Compliance Plan (DOE /ORO-2027/R3 " Plan for Achieving Compliance with NRC Regulations at the Portsmouth Gaseous Diffusion Plant")

identifies severalleased buildings located within 200 feet of the buildings with CAAS clusters, which do not have evacuation horns and lights activated by these clusters. The completion dates for resolution of these noncompliances for routinely manned and routinely unmanned facilities are July 1,1997 and July 1,1998, respectively.

PGDP TSRs 2.1.4.5b, 2.2.4.3b, 2.3.4.7b, 2.4.4.2b, and 2.6.4.1 b require CAAS audibility in all areas where the maximum foreseeable absorbed dose in free air exceeds 12 rad.

Issue 46 of the PGDP Compliance Plan (DOE /ORO-2026/R3 " Plan for Achieving Compliance with NRC Regulations at the Paducah Gaseous Diffusion Plant) recognizes that there are areas within the process buildings where CAAS horns are not audible. In addition, PGDP Compliance Plan issue 50 identifies severalleased buildings located within the 12 rad radius of the buildings with CAAS Husters, which do nut have evacuation / ,

horns and lights activated by these clusters. Y a completion date for resolution of these $

noncompliances is December 15,1998.

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1 NRC FRf CENTER COPY 9703050421 970228 PDR ADOCK 07007001 C PDR ,

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a James H. Miller .

l The USEC certification application, was required by 10 CFR Part 76.35(b) to include a plan for achieving compliance with areas of noncompliance with regulations applicable to the Gaseous Diffusion Plant. The NRC staff considers this approved Compliance Plan as a vehicle to bring USEC into compliance with NRC requirements, over an appropriate period of time, during which compensatory measures are implemented as prescribed in the Justification for Continued Operation sections of each Compliance Plan issue. Therefore, after March 3,1997, and before the respective completion deadlines for the above mentioned Compliance Plan issues, the NRC will not consider activities which are in conformance with the Compliance Plans, including any associated compensatory measures, to be violations.

If you have any questions regarding this matter, please contact Yawar Faraz for PORTS at (301) 415-8113 or Merri Horn for PGDP at (301) 415-8126.

Sincerely, Orioinal Signed By Robert C. Pierson, Chief Special Projects Branch Division of Fuel Cycle Safety and Safeguards, NMSS Dockets 70-7001 and 70-7002 Certificates GDP-1 and GDP-2 cc: Mr. Randall DeVauf t, DOE-OR Mr. Date Allen, PORTS Mr. Steve Polston, PGDP DISTRIBUTION: '

Dockets 70-7001,70-7002 NRC File Center PUBLIC GShear,Rlll KO'Brien, Rill SPB r/f FCSS r/f NMSS r/f CCox, Rill LTenEyck WBrach )

WShwink,FCOB G:\TSRCPLNY.LNK

'See previous concurrence Rfil SPB, OFC SPB E SPB 'SPB SP ,, OC)C t NAME YFarazN Ofdkrn DAHoadley hhtin Y } f. Rhrson

/ /97 2/26/97 7F//97 2 /2f/97 l/Dl97 1 N '/97 DATE ,.1 f//97 E = COVER & ENCLOSURE N = NO COPY C = COVER OFFICIAL RECORD COPY l

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l

. James H. Miller j l

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The NRC staff considers the approved Compliance Plans as vehicles to ng USEC into  ;

compliance with NRC requirements, over an appropriate period of tim , during which l compensatory measures are implemented as prescribed in the Jus)'ficationt for Continued l Operation sections of each Compliance Plan issue. Therefore, thd NRC staff requests that '

by April 3,1997, you propose amendments to the above menfoned TSRs so as to make them consistent with their respective above mentioned Co pliance Plan issues. Please be  !

advised that after March 3,1997, which is the expected ansition date of USEC leased areas from the Department of Energy regulatory jurisdi son to NRC regulatory jurisdiction,

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I and before the effective date of the amended CAAS SRs, the NRC staff will not consider  ;

PORTS and PGDP to be in violation of the existin AAS TSRs for conditions which fall within the discrepancy described above betwee the TSRs and Compliance Plan issues.

If you have any questions regarding this m er, please contact Yawar Faraz for PORTS at (301) 415-8113 or Merri Horn for PGDP - (301) 415-8126.

Sincerely, 1

1 Robert C. Pierson, Chief  ;

Special Projects Branch Division of Fuel Cycle Safety and Safeguards, NMSS Dockets 70-7001 nd 70-7002 Certificates G -1 and GDP-2 cc: Mr andall DeVault, DOE-OR

r. Dale Allen, PORTS

r. Steve Polston, PGDP ISTRIBUTION:

Dockets 70-7001, 70-7002 NRC File Center PUBLIC GShear, Rlli KO'Brien, Rlli SPB r/f FCSS r/f NMSS r/f WShwink, FCOB CCox, Rlli G:\TSRCPLN.LNK OFC SPB d. SPB b iSPB 10 SPB OGC SPB NAME YFaraz[ NHorn [dAHoadley DMartin RPierson DATE .1/ E/97 S /.n/97 j' ///97 / /97 / /97 / /97 C = COVER E = COVER & ENCLOSURE N = NO COPY OFFICIAL RECORD COPY

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