Comparison Evaluation of the PFP FSAR and NRC Regulatory Guide 3.39 with DOE-STD-3009-94

One of the Plutonium Finishing Plant's (PFP) current Authorization Basis (AB) documents is the Final Safety Analysis Report (FSAR). This FSAR (HNF-SD-CP-SAR-02 1) was prepared to the format and content guidance specified in U.S. Nuclear Regulatory Commission (NRC) Regulatory Guide 3.39, Standard Format and Content of License Applications for Plutonium Processing and Fuel Fabrication Plants (RG 3.39). In April 1992, the US Department of Energy (DOE) issued DOE Order 5480.23 which established the FSAR requirements for DOE nonreactor nuclear facilities. In 1994, DOE issued DOE-STD-3009-94, Preparation Guide for US. Department of Energy Nonreactor Nuclear Facility Safety Analysis Reports, which is a format and content guide addressing the preparation of FSARs in accordance with DOE Order 5480.23. During the initial preparation and issuance of the PFP FSAR the format and content guidance contained in NRC Regulatory Guide 3.39 was utilized, since it was the most applicable guidance at the time for the preparation of Safety Analysis Reports for plutonium processing plants. With the adoption of DOE Order 5480.23 and DOE-STD-3009-94, DOE required the preparation of SARs to meet the format and content of those DOE documents. The PFP was granted an exemption to continue with RG 3.39 format for future FSAR revisions. PFP modifications and additions have required PFP FSAR modifications that have typically been prepared to the same NRC Regulatory Guide 3.39 format and content, to provide consistency with the PFP FSAR. This document provides a table comparison between the 3009 and RG 3.39 formats to validate the extent of PFP FSAR compliance with the intent of DOE Order 5480.23 and DOE-STD-3009-94. This evaluation was initially performed on Revisions 1 and 1A of the PFP FSAR. With the preparation of a Revision 2 draft to the FSAR, sections with significant changes were reevaluated for compliance and the tables were updated, as appropriate. The tables resulting from this comparison provide a ''road map'' between the RG 3.39 format of the PFP FSAR and the requirements of 3009, to verify compliance with 3009 and identify any discrepancies. Because of the format differences between the RG 3.39 and 3009 guidance, the extent to which the PFP FSAR complies with 3009 is not entirely clear. No comparative evaluation of the existing PFP OSRs to the requirements contained in Chapter 5 of 3009 was performed