ML20135D850
| ML20135D850 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 02/28/1997 |
| From: | John Miller UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Paperiello C NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| GDP-97-0020, GDP-97-20, TAC-L32015, NUDOCS 9703060040 | |
| Download: ML20135D850 (23) | |
Text
LBlod 70- 7e /
United Stitis Enrichm:nt Corporttion
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2 Democracy Center 6903 Rockledge Drive Bethesd l. MD 20817 j
Tel. (301) 564-3200 Unite 91 Sales IUnichtnent Corporation JAMES H. MILLER Dir: (301) 564-3309 VICE PRESIDENT, PRODUCTION Fax: (301) 571-8279 February 28,1997 Dr. Carl J. Paperiello SERIAL: GDP 97-0020 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 Certificate Amendment Request-Definition of Completion Times
Dear Dr. Paperiello:
In accordance with 10 CFR 76.45, the United States Enrichment Corporation (USEC or Corporation) hereby submits a request for amendment to the certificate of compliance for the Paducah, Kentucky Gaseaus Diffusion Plant (GDP). This certificate amendment request revises Technical Safety Requirements (TSR), sections 1.2, " Definition of Terms," and 1.6, " General Application."
The proposed change is to provide a definition for " Completion Time" and to define the maximum interval between repetitive LCO action completion times. A 25% extension would be established for repetitive intervals in LCO actions. This change would make the interpretation of hourly intervals applicable to fire watches consistent with the interpretation of other repetitive intervals defined in the SAR and TSRs.
970306004o 970228 ADOCK0700g1 PDR a
N FON i
c 050113 IEl.ERHppi.1,E,EJIEp Off ces in Paducah. Kentucky Portsmouth. Ohio Washington DC
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Dr. Carl J. Paperiello February 28,1997 GDP 97-0020, Page 2 Enclosure I to this letter provides a detailed description and justification for the proposed changes i
to the PGDP TSRs. Enclosure 2 is a copy of the revised TSR and SAR pages. Enclosures 3 contains the basis for USEC's determination that the proposed changes associated with this certificate amendment request are not significant.
Since this pmposed certificate amendment request is an enhancement to the Technical Safety Requirements and is not required to support continued operation, USEC requests NRC review and approval at your earliest convenience. The amendment should become effective 30 days from issuance.
Any questions related to this subject should be directed to Mr. Mark Smith at (301) 564-3244.
Sine ly,.
t d
es H. Miller ice President, Production
Enclosures:
As Stated cc:
NRC Region 11I Office NRC Resident Inspector-PGDP NRC Resident inspector-PORTS Mr. Randall M. DeVault (DOE) t
P 4
0 f
i OATH AND AFFIRMATION I, James II. Miller, swear and affirm that I am Vice President, Production, of the United i
States Enrichment Corporation (USEC), that I am authorized by USEC to sign and file with the Nuclear Regulatory Commission this Certificate Amendment Request for the Paducah Gaseous Diffusion Plant, that I am familiar with the contents thereof, and that the statements made and matters set forth therein are true and correct to the best of my knowledge, information, and belief.
1 James filler r
l
.2N day of
/
,1997.
Subscribed to before me on this LINDA ANDEPSON
/
SL Notary Public l
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'l GDP97-0020 Page 1 of 2
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United States Enrichment Corporation (USEC)
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Proposed Certificate Amendment Rcquest i
Definition of Completion Times Detailed Description of Change i
Specific TSR Sections Affected 1.
A new definition is added to Section 1.2, as follows:
1.2.4 Completion Time - The Completion Time is the amount of time allowed for completmg a Required Action. It is referenced to the time ofdiscovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the system / component is in a MODE or specified condition stated in the Applicability of the LCO.
Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the system / component is not within the LCO Applicability.
2.
The other definitions shown in Section 1.2, beginning with the old definition number 1.2.4,
" Cylinder Categories", through old number 1.2.17, " Uncomplicated Handling", are renumbered to accotmt for the insertion of the above new definition.
3.
A second paragraph is added to Section 1.6.2, " Operating Limits", subsection 1.6.2.2.e, "LCO Completion Times", as follows:
If a Completion Time requires periodic performance on a "once per..." or "every hour thereafter..." basis, the 25% time interval extension specified in the Note to TSR USE AND APPLICATION, Section 1.3 applies to each performance after the initial performance. For Completion Times specified as "once," the 25% time interval extension does not apply.
Reason for Change The PGDP Technical Safety Requirements (TSRs) require that fire protection sprinkler systems and High Pressure Fire Water System (HPFWS) distribution mains be operable for the cascade facilities and the product and tails withdrawal facilities. When these systems are determined to be inoperable, TSRs 2.3.4.8,2.3.4.9,2.4.4.5, and 2.4.4.6 specify that a fire patrol be conducted within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and every hour thereafter. For hourly repetitive actions, such as this, the TSRs do not define the time
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i GDP97-0020 Page 2 of 2 j
i interval nor specify if an actension is permitted. The proposed change will provide a definition for
" Completion Time" and define the maximum time interval between repetitive action completion times (25% extension for maximum time interval). The proposed application of extensions to j
repetitive actions is consistent with nuclear industry practice as evicient in NUREG-1431, Standard Technical Specifications, Westinghouse Plants, April 1995, Section 1.3 and Surveillance Requirement SR 3.0.2.
Justification of the Change The proposed additions to Sections 1.2 and 1.6 will establish a consistent understanding of the interval requirements. The information added to Section 1.2 clarifies the meaning of Completion Time for plant personnel applying TSRs to their daily work. At present the term " Completion Time" is not formally defined in the TSRs and is, therefore, subject to various interpretations. NRC clearly recognized the potential problems posed by varying interpretations of Completion Time and addressed this in Use and Application section of the reactor standard technical specifications. (See for example Section 1.3 of NUREG-1431, Standard Technical Specifications for Westinghouse Plants, dated April 1995.)
The information added to Section 1.6.2.2 would make the interpretation of" hourly" consistent with that of other intervals specified in Section 1.3, " Time Intervals for Surveillance." At times circumstances arise in which the fire patrol is performed within 60 minutes but additional time is needed to reach the location in which logs are kept and make log entries necessary to consider the watch " complete". Shortening fire patrol schedules to ensure the patrol and associated log entries are completed within 60 minutes would significantly add to the work load on operators without comparably increasing the safety of the plant.
The proposed revision is consistent with standard nuclear power industry practice for repetitive action completion times and consistent with the Westinghouse Standard Technical Specifications, NUREG-1431, Standard Technical Specifications, Westinghouse Plants, April 1995, Section 1.3 and Surveillance Requirement SR 3.0.2.
GDP97-0020 14 Pages i
l Proposed Certificate Amendment Request Paducah Gaseous Diffusion Plant Letter GDP97-0020 Removal / Insertion Instructions j
Remove Pages Insert Pages VOLUME 1 Definitions Definitions i
I through 4 1 through 4 VOLUME 4 l
t Table of Contents Table of Contents V
V Section 1.2.4 Section 1.2.4 l
1.0-2 through 1.0-9 1.0-2 through 1.0-9 f
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1 l
4 I
1 A
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l TSR-PGDP PROPOSED February 28,1997 RAC 96C165 TABLE OF CONTENTS
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hen SECTION 1.0 USE AND APPLICATION..
1.0-1
1.1 INTRODUCTION
1.0-2 1.2 DEFINITION OF TERMS.......
1.0-2 1.2.1 ACTIONS.....
1.0-2 1.2.2 ADMINISTRATIVE CONTROLS....
1.0-2 1.2.3 CHANNEL CIIECK..
1.0-2 l
1.2.4 COMPLETION TIME........
1.0-2 l
1.2.5 CYLINDER CATEGORIES...
1.0-3 l
1.2.6 DESIGN FEATURES (DF) 1.0-3 l
1.2.7 FIRE PATROL..
1.0-3 l
1.2.8 FUNCTIONAL TEST.......
1.0-3 l
1.2.9 IMMEDIATELY..............
1.0-3 l.
1.2.10 LIMITING CONDITIONS FOR OPERATION (LCO)......... 1.0-3 l
1.2.11 LIMITING CONTROL SETTING (LCS) 1.0-3 l
1.2.12 OPERATING CYCLE (AUTOCLAVE)..
1.0-4 l
1.2-13 OPERABLE......
1.0-4 l
1.2.14 PLANNED EXPEDITIOUS IIANDLING (PEH) 1.0-4 l
1.2.15 SAFETY LIMIT (SL) 1.0-4 l
1.2.16 SURVEILLANCE REQUIREMENTS (SRs)...
1.0-4 i
l 1.2.17 UF. CYLINDER (OR CYLINDER).
1.0-4 l
1.2.18 UNCOMPLICATED HANDLING.
1.0-4 l
1.3 TIME INTERVALS FOR SURVEILLANCE.
1.0-5 l
1.4 LIST OF ACRONYMS...............
1.0-6 l
1.5 INTENT OF TERMS 1.0-6 l
1.6 GENERAL APPLICATION............
1.0-6 l
1.6.1 SAFETY LIMIT.....
1.0-6 l
1.6.2 OPERATING LIMITS.
1.0-7 l
1.6.2.1 LIMITING CONTROL SETTINGS 1.0-7 l
1.6.2.2 LIMITING CONDITIONS FOR OPERATION....... 1.0-7 l
1.6.3 SURVEILLANCE REQUIREMENTS.........
1.0-8 l
1.6.4 CONDITIONS OUTSIDE TSR,........
1.0-9 SECTION 2.0 FACILITY-SPECIFIC TECHNICAL SAFETY REQUIREMENTS.
2.0-1 2.1 SPECIFIC TSRs FOR TOLL TRANSFER AND SAMPLING FACILITY............
2.1-1 2.1.1 OPERATIONAL MODES.....
2.1-2 2.1.2 SAFETY LIMITS 2.1-4 2.1.2.1 AUTOCLAVE SHELL PRESSURE 2.1-4 2.1.2.2 UF. CYLINDER TEMPERATURE 2.1-4 v
TSR-PGDP PROPOSED February 28,1997 RAC 96C165
1.1 INTRODUCTION
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j 10 CFR 76.87(a) states that "The Corporation shall establish technical safety requirements.
In establishing the requirements, the Corporation shall consider the analyses and results of the safety analysis report submitted pursuant to 10 CFR 76.35." These Technical l
Safety Requirements (TSRs) are intended to fulfill the requirements of 76.87 and set forth approved limitations for operation of the Paducah Gaseous Diffusion Plant (PGDP). The TSRs define the conditions, safe boundaries and the management or administrative controls necessary to ensure safe operation of the facility and are based on the accidents analyzed in the Safety Analysis Report (SAR).
1.2 DEFINITION OF TERMS I
1.2.1 Actions - That part of a TSR that prescribes required actions to be taken under designated -
conditions within specified completion times.
1.2.2 Administrative Controls - The provisions relating to organization and management, procedures, recordkeeping, reviews and audit, and reporting necessary to ensure operation of the plant in a safe manner.
1.2.3 Channel Check - The qualitative assessment of channel behavior during operation.' This determination shall be based on observation and shall include, where possible, a comparison of the channel indication and status with other indications and the status derived from independent instrument channels measuring the same parameter.
l 1.2.4 Completion Time - The Completion Time is the amount of time allowed for completing l
l a Required Action. It is referenced to the time of discovery of a situation (e.g., inoperable l
equipment or variable not within limits) that requires entering an ACTIONS Condition l
l unless otherwise specified, providing the system / component is in a MODE or specified j
l condition stated in the Applicability of the LCO. Required Actions must be completed l'
prior to the expiration of the specified Completion Time. An ACTIONS Condition l
remains in effect and the Required Actions apply until the Condition no longer exists or l
the system / component is not within ths LCO Applicability.
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I 1.0-2 t
TSR-PGDP PROPOSED Febmary 28,1997 RAC 96C165 l 1.2.5 ' Cylinder Categories - Cylinders are categorized as follows:
Categorv UF Cylinder Model Number A
Cylinders with certified volumes containing less UF than the maximum 6
fill limit for shipment or less UF than the maximum fill limit for in-6 plant tails storage (if filled with high purity tails), or cylinders which if heated to 235*F would have void volumes 25% or void volumes 23% if filled with high purity tails, according to TSR 2.1.4.6 or 2.2.4.4.
B Cylinders filled beyond the Category A limits, which if heated to 230*F would have void volumes 25% or void volumes 23% if filled with high purity tails, according to TSR 2.1.4.6 or 2.2.4.4.
C Damaged cylinders or cylinders filled beyond the limits of Categories A or B.
l 1.2.6 Design Features (DF) - Those design attributes of structures, systems, and components that passively prevent or mitigate the consequences of radiological accidents that could cause significant consequences.
l 1.2.7 Fire Patrol - Required to perform monitoring of an area for fire due to a fire suppression or detection system being impaired / inoperable. This monitoring shall be performed at regular intervals not to exceed the interval specified in the facility-specific TSR. The person performing the fire patrol must be instructed on the following:
(1) specifically what system is inoperable and the area to be patrolled, (2) actions to take upon discovering a fire, and (3) procedures for reporting a fire.
l 1.2.8 Functional T4t - The irJecdon of a simulated or actual signal into the channel as close to the sensor as practicable to verify Operability, including required alarms, interlocks, trip functions, and channel failure trips. The Functional Test may be performed by any series of sequential, overlapping, or total channel steps such that the entire channel is tested.
l 1.2.9 Immediately - Required action s'all be pursued without delay and in a controlled manner.
l 1.2.10 Limiting Conditions for Operation (LCO) - The lowest functional capability or i
performance levels of structures, systems, components and their support systems required for normal safe operation of the plant.
l l 1.2.11 Limiting Control Setting (LCS) - Settings for automatic alarm or protective devices related to those variables having significant safety functions.
1.0-3
- TSR-PGDP PROPOSED February 28,1997 RAC %C165
'l l '1.2.12 ' Operating Cycle (Autoclave) - The time between the initial entrance into the heating mode and the completion of the intended task (sample or transfer in C-360 or feeding and heeling in C-333-A and C-337-A) inclusive of mode changes allowed by the LCOs and their action statements which might occur during the course of the evolution.
l 1.2.13 Operable - An SSC shall be operable or have operability when it is capable of performing its specified function (s), and when all necessary attendant instrumentation, controls, l
electrical power, cooling or seal water, lubrication, or other auxiliary equipment that are required for the SSC to perform its specified function (s) are also capable of performing their related support func: ion (s).
l 1.2.14 Planned Expeditious Handling (PEH) - The process of handling equipment that contains more than a safe mass of uranium (relative to "U assay) as determined by TSR 2.5, 2
Appendix B.
l 1.2.15 Safety Limit (SL) - Those bounds within which the process variables must be maintained for adequate control of the operation and that must not be exceeded in order to protect the 1
integrity of the physical system that is designed to guard against the uncontrolled release of radioactivity.
l l 1.2.16 Surveillance Requirements (SRs) - Requirements relating to test, calibration, or inspection to ensure that the necessary quality of systems and components is maintained, j
that plant operation will be within the safety limits, and that the limiting conditions for operation will be met.
l 1.2.17 UF Cylinder (or cylinder) - Unless otherwise specified, UF cylinder (or cylinder) is 6
6 intended to be limited to large (2%-ton and larger) UF cylinders.
6 l 1.2.18 Uncomplicated Handling - The process of handling equipment that contair 3eposit of less than or equal to an always safe mass.
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1.0-4
3 TSR-PGDP PROPOSED February 28,1997 RAC 96C165
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1.3 TIME INTERVALS FOR SURVEILLANCE 4
I Interval Interval Between Consecutive Maximum Interval Between j
Designation Surveillances Consecutive Surveillances Five-year 5 years to the day 5 years to the day (unless j
j specifically stated otherwise)
Biennially 2 years 2 years 6 months j
Annually 365 days 456 days Semiannually 184 days 245 days I
Quarterly 92 days 123 days i
Monthly 31 days 39 days Daily 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 30 hours Shiftly 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 15 hours Twice Each Shift 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 8 hours NOTE:
The extension between the standard and maximum surveillance intervals is intended to be used to accommodate operational and maintenance scheduling.
The time interval between surveillances on in-service equipment should not routinely extend to the maximum allowable interval.
The extension between the standard and maximum surveillance intervals is 25% of the standard value with the exception of twice each shift, quarterly and semiannual items. The extension on these intervals is 33% consistent with past plant practice which has been in accordance with DOE 5481.1B.
1.0-5
TSR-PGDP PROPOSED February 28,1997 RAC 96C165
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1.4 LIST OF ACRONYMS ANSI American National Standards Institute DF Design Feature LCO Limiting Conditions for Operation LCS Limiting Control Setting l
MAWP Maximum Allowable Working Pressure NRC Nuclear Regulatory Commission j
PEH Planned Expeditious Handling TSR Technical Safety Requirements SAR Safety Analysis Report SL Safety Limit
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l SR Surveillance Requirement SSC Structure, System, or Component l
UH Uncomplicated Handling 1.5 INTENT OF TERMS I
Shall Requirement Should Recommendation May Permission
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1.6 GENERAL APPLICATION l
1.6.1 SAFETY LIMIT 1.6.1.1 Coupliance with SAFETY LIMIT requirements is required during OPERATIONAL MODES specified in the Applicability statement.
1.6.1.2 If the SAFETY LIMIT is exceeded, immediately perform the following:
a.
If the conditions do not require evacuation, attempt to bring the affected parameter within the SAFETY LIMIT in a manner that leaves the facility / system in an operational mode for which the safety limit is not applicable.
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b.
If appropriate, notify plant emergency personnel and initiate building evacuation.
I c.
Conduct a technical evaluation to determine if any damage has occurred and to evaluate the ability of the system to be restarted.
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l 1.0-6
TSR-PGDP PROPOSED February 28,1997 RAC 96C165 1.6.2 OPERATING LIMITS i
1.6.2.1 LIMITING CONTROL SETTINGS a.
Compliance with the LIMITING CONTROL SETTING requirement is required during the OPERATIONAL MODES l
specified in the Applicability statement.
1.6.2.2 LIMITING CONDITIONS FOR OPERATION a.
Compliance with the LIMITING CONDITIONS for OPERATION contained in these requirements is required during the OPERATIONAL MODES specified in the Applicability statement, except as provided in 1.6.2.2.b.
b.
Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, c.
When a LIMITING CONDITION for OPERATION is not met, complete the attendant action steps within the required time interval.
If the action steps are not met within the specified time interval, or l
if none are provided, place the equipment / system in an operating mode for which the LCO does not apply. Action shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
Exceptions to this TSR (1.6.2.2.c.) are stated in individual requirements.
Where corrective measures are completed that permit operation in j
accordance with the LCO or ACTIONS, completion of the actions required by this TSR (1.6.2.2.c.) is not required.
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j d.
Entry into an OPERATIONAL MODE that is applicable to a particular LCO shall not be made unless the conditions for the LIMITING CONDITIONS for OPERATION are met without reliance on provisions contained in the ACTION statement.
Exceptions to this rule are stated in the individual requirements.
Additionally, this provision shall not prevent passage through or to l
OPERATIONAL MODES required or allowed by ACTION statements.
e.
LCO Completion Times. The completion times for LCO required actions begin when that specific condition is discovered, regardless of how long that condition may have previously existed. All i
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1.0-7
TSR-PGDP PROPOSED February 28,1997 RAC 96C165 completion times within a single row of an LCO table are measured fmm the point of discovery of that condition.
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If a Completion Time requires periodic performance on a "once l
per..." or "every hour thereafter..." basis, the 25% time interval l
extension specified in the Note to TSR USE and APPLICATION l
Section 1.3 applies to each perfo'rmance after the initial l
performance. For Completion Times specified as "once," the 25%
l time interval extension does not apply.
f.
Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to 1.6.2.2.b. for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.
1.6.3 SURVEILLANCE REQUIREMENTS 1.6.3.1 SURVEILLANCE REQUIREMENTS shall be met prior tu entering the OPERATIONAL MODES or other conditions specified in the Applicability statement for individual LCS and LCOs unless otherwise i
stated in an individual SURVEILLANCE REQUIREMENT.
1.6.3.2 Each SURVEILLANCE REQUIREMENT shall be performed in accordance with Section 2 and within the maximum time interval defined in Section I.3. Surveillances do not have to be performed on SSCs which are not in, or being prepared to enter, the applicable operating mode (s).
1.6.3.3 Failure to perform a SURVEILLANCE REQUIREMENT within the maximum acceptable time interval constitutes a failure to meet the OPERABILITY requirements for a LIMITING CONDITION for OPERATION. Exceptions are stated in the individual requirements.
When it is discovered that a surveillance has not been performed within the maximum acceptable time interval for the frequency specified in Section 2, perform the following within either 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified frequency (whichever is less) of discovery:
a.
Perform the required surveillance, or l
b.
Place the equipment in an operating mode for which the system is not required.
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i 1.0-8
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TSR-PGDP PROPOSED February 28,1997 RAC 96CI65 In instances where inoperability is declared due to missed surveillances, this general usage action statement takes precedence over the facility-specific LCO action statement. In the event that the missed surveillance is not performed within the interval provided by this general LCO, the action steps associated with system inoperability shall be immediately initiated in accordance with the facility-specific LCO.
1.6.3.4 Entry into an OPF9 ATIONAL MODE or other specified condition shall not be made t. -. s the SURVEILLANCE REQUIREMENT (s) associated with the LIMITING CONDITION for OPERATION has been performed within the stated surveillance interval or as otherwise specified in the individual surveillance requirements. This provision shall not prevent passage through or to OPERATIONAL MODES as required or allowed by ACTION statements.
Exceptions are stated in the individual requirements.
1.6.4 CONDITIONS OUTSIDE TSR In an emergency, if a situation develops that is not addressed by the TSR, operations personnel should use their training and expertise to take actions to correct or mitigate the situation. Also, operations personnel may take actions that depart from a requirement in the TSR provided that: (a) an emergency situation exists; (b) these actions are needed immediately to protect the public and employee health and safety; and (c) no action consistent with the TSR can provide adequate or equivalent protection. Such actions must be approved by the Incident Commander as defined in the Emergency Plan. If emergency action is taken, both a verbal and written notification shall be made in accordance with 10 CFR 76.120.
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i 1.0-9
'SAR-PGDP PROPOSED February 28,1997 RAC 96C165
'I.0 DEFINITIONS Assay - As used in the uranium enrichment industry, the "U isotopic concentration relative to total 2
uranium in a uranium-bearing material, typically stated in wt % (e.g.,2.75% assay) l Completion Thne - The Completier. Time is the amount of time allowed for completing a Required Action.
l It is referenced to the time of discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the system / component is in a MODE or specified condition stated in the Applicability of the LCO. Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS l Condition remains in effect and the Required Acdons apply until the Condition no longer exists or the system / component is not within the LCO Applicability.
If a Completion Time requires periodic performance on a "once per..." or "every hour thereafter..."
basis, the 25 % time interval extension specified in the Note to Section 3.0 applies to each performance after the initial performance. For Completion Times specified as "once," the 25% time interval extension does not apply.
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independent Assessment - A determination of the capabilities, performance and overall effectiveness of the a program performed by persons not associated with the program or topic being assessed.
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'l Nuclear materials (NMs)- Materials such as uranium, uranium bearing material, thorium, neptunium, 2
or "U for which accountability is required by NRC.
Safeguards - An integrated system of physical protection, accountability, and material control measures designed to deter, prevent, detect, and respond to unauthorized possession and/or use of SNM.
1 Tails - Depleted UF below normal assay, which is withdrawn from the
- bottom" of the cascade and placed into long-term storage.
Inspect - Inspect, unless specifically stated otherwise, is intended in the standard usage of the word, i.e.,
i visual evaluation for acceptability.
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UF, Cylinder (or cylinder) - Unless otherwise specified. UF. cylinder (or cylinder) is intended to be limited to large (2 %- ton and larger) UF. cylinders.
2.0 LIST OF ACRONYMS The following is a list of acronyms used throughout the USEC Application.
ACL Administrative Control Level ADP Automatic Date Processing ALARA -
As Imw As Reasonably Achievable American Society of Mechanical Engineers ASME ANSI American National Standards Institute AQ Augmented Quality ARA Airborne Radioactivity Area CCF Central Control Facility CAAS Critical Accident Alarm System CCB Change Control Board CCZ Contamination Control Zone I
i SAR-PGDP PROPOSED February 28,1997 RAC 96C165 CFR Code of Federal Regulations CM Configuration Management CM Crisis Manager CUP Cascade Uprating Program DOE United States Department of Energy EAL Emergency Action Level ECSR Environmental Compliance Status Report EOC Emergency Operations Center EPA Environmental Protection Agency EPIP Emergency Plan Implementing Procedure ERO Emergency Response Organization FNMCP -
Fundamental Nuclear Materials Control Plan GERT -
General Employee Radiological Training GET General Employee Training
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IIP IIealth Physics
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IIRA liigh Radiation Area IIS&E liealth, Safety and Environmental JCO Justification for Continued Operations LAW Low Assay Withdrawal LEU Low Enriched Uranium LMES -
lackheed Martin Energy Systems LMUS -
Lockheed Martin Utility Services MBA Material Balance Area NBS National Bureau of Standards i
NCS Nuclear Criticality Safety NDA Nondestructive Assay NIST National Institute of Standards and Technology NM Nuclear Material NMSS NRC Office of Nuclear Materials Safety and Sai.pards NRC Nuclear Regt:'atory Commission OSHA Occupational Safety and liealth Administration PGDP Paducah Gaseous Diffusion Plant PM Preventive Maintenance PORC Plant Operations Review Committee PORTS -
Portsmouth Gaseous Diffusion Plant PRB Procedures Review Board PSS Plant Shift Superintendent PW Product Withdrawal QAP Quality Assurance Program RA Radiation Area RMA Radioactive Material Area RP Radiation Protection RWMP -
Radioactive Waste Management Program RWP Radiological Work Permit S&S Safeguards and Security j
SAE Site Area Emergency SAR Safety Analysis Report SM Source Material SNM Special Nuclear Material SOP Standard Operating Procedure i
SPP Standard Practice Procedure 2
._m.___._
_. _ _ _. _ _.. - _. ~... _. _ _
.m.
FROM sUSEC 301-564-3210 1997.C2-29 iSI37 llOEWD P.14/30 4
4 2
' SAR-PODP FROPOSED i
RAC 96C165 F;bruary 28,1997 1
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SWU Separative Work Unit TSR Tehaient Safety Requirements UE Uranturn MM-2
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UF, Uranium Hexafloudde USEC United States Enrichment Corporadon j
3.4 FREQUENCES
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Interval Designation Interval Between Consecutive Mari== Interval Between l
(Psgsy)
Survailla-M Conm*ive Siuveillances i
Pive-year 5 years to the day 5 years to the day (unless specifically stated otherwise) i Biennially 2 years 2 years 6 Inonths i
.i Annually 365 days 456 days
.i M =n=11y 184 days 245 days 3
Quarterly 92 days 123 days Monthly 31 days 39 days 1
3 Daily 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 30 hours
+
Per Shift 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 15 hours 1
Twice Each Shift 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 8 hours i
i NOTE:
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'Ibe extausion between the standard and rnarimum surveiiance intervals is intended to be to accomrunodate operewmm1 and snaintenance scheduling. 'Ibe extension between the standard i
and Inaxitnum surveillance intervals is 25% of the standard value with the exception of twice sadt shift, quarterly, and setniannual items. The extension on these intervals is 33 %, which is j.
consisteot with past plant practice.
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ram iusee sei-ss4-2219 iss7.e2-2s icise asse P.i m e
- SAR-PGDP i
i Rev.1 September 15,1995 I
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o United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Definition of Completion Times Significance Determination The United States Enrichment Corporation (USEC) has reviewed the proposed changes associated with this certificate amendment request and provides the following Significance Determination for consideration.
1.
No Overall Decrease in the Effectiveness of the Plant's Safetv. Safeguards. or Security Programs.
l The addition of a definition for " Completion Time" and the maximum time interval for repetitive actions provides more formality in the conduct of plant operations. This term has not been formally defined in the past and was left open to varying interpretation. The inclusion of the definition will ensure interpretation of" Completion Time" and that the maximum interval between repetitive actions is consistently applied. " Completion Time" and repetitive actions is not mentioned in any program or plan contained in the Certification Application. Therefore, the proposed changes will not result in an overall decrease in the effectiveness of the plant's safety, safeguards, or security programs.
2.
No Significant Change to Any Conditions to the Certificate of Comnliance The proposed TSR changes involve the addition of a definition for " Completion Time" and the maximum time interval for repetitive actions. None of the Conditions to the Certificate of Compliance for Operation of Gaseous Diffusion Plants (GDP-1) specifically address a definition for " Completion Time" or the maximum time interval for repetitive actions.
Thus, the proposed changes have no impact on any of the Conditions to the Certificate of Compliance.
3.
No Sienificant Change to Any Condition of the Annroved Comnliance Plan The proposed TSR changes involve the addition of a dermition for "Corapletion Time" and the maximum time interval for repetitive actions. The proposed changes do not involve any condition related to the Compliance Plan and causes no significant changes to any conditions of the Compliance Plan,
GDP97-0020 Page 2 of 4 4.-
No Significant Increace in the Probability of Occurrence or Concenuences of Previousiv Evaluated Accidents The addition of a definition for " Completion Time" and the maximum time interval for repetitive actions provides more formality in the conduct of plant operations. This term has pt been formally defined in the past and was left open to varying interpretation. The inclusion of the definition will ensure interpretation of" Completion Time" and that the maximum interval between repetitive actions is consistently applied. This change would not increase the probability of occurrence or consequence of an accident previously evaluated.
5.
No New or Different Tvoe of Accident The addition of a definition for " Completion Time" and the maximum time interval for repetitive actions provides more formality in the conduct of plant operations.- This term has not been formally defined in the past and was left open to varying interpretation. The inclusion of the definition will ensure interpretation of" Completion Time" and that the maximum interval between repetitive actions is consistently applied. This change would not create the possibility of a new or different type of accident than any previously evaluated.
6.
No Significant Reduction in Margins of Safety I
The addition of a definition for " Completion Time" and the maximum time interval for repetitive actions provides more formality in the conduct of plant operations. This term has not been formally defined in the past and was left open to varying interpretation. The inclusion of the definition will ensure interpretation of" Completion Time" and that the maximum interval between repetitive actions is consistently applied. The proposed changes cause no reductions in the margins of safety.
7.
No Significant Decrease in the Effectiveness of any Programs or Plans Contained in the Certificate Application The addition of a definition for " Completion Time" and the maximum time interval for repetitive actions provides more formality in the conduct of plant operations. This term has not been formally defined in the past and was left open to varying interpretation. The inclusion of the definition will ensure interpretation of" Completion Time" and that the maximum interval between repetitive actions is consistently applied. " Completion Time" and repetitive actions is not mentioned in any program or plan contained in the Certification Application. Therefore, the proposed changes have no impact on the effectiveness of these programs or plans.
GDP97-0020 Page 3 of 4
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8.
The Procosed Changes do not Result in Undue Risk to 1) Public Health and Safety. 2)
Common Defense and Security. nnd 3) the Environment.
The addition of a defmition for " Completion Time" and the maximum time interval for repetitive actions provides more formality in the conduct of plant operations. This term has not been formally defined in the past and was len open to varying interpretation. The inclusion of the defmition will ensure interpretation of" Completion Time" and that the maximum interval between repetitive actions is consistently applied. As such, these changes do not represent an undue risk to public health and safety. In addition, these revisions have no impact on plant efnuents or on the programs and plans in place to implement physical security. Consequently, these proposed changes only enhance safety and pose no undue risk to the environment or the common defense and security.
9.
No Change in the Tynes or Significant Increase in the Amounts of Anv Effluents That May Be Released Offsite.
The addition of a defmition for " Completion Time" and the maximum time interval for repetitive actions provides more formality in the conduct of plant operations. This term has not been formally dermed in the past and was left open to varying interpretation. The inclusion of the definition will ensure interpretation of" Completion Time" and that the maximum interval between repetitive actions is consistently applied. As such, these changes have no impact on plant effluents.
10.
No Sienificant Increase in Individual or Cumulative Occuoational Radiation Exposure.
The addition of a dermition for " Completion Time" and the maximum time interval for repetitive actions provides more formality in the conduct of plant operations. This term has not been formally dermed in the past and was left open to varying interpretation. The inclusion of the definition will ensure interpretation of" Completion Time" and that the maximum interval between repetitive actions is consistently applied. The proposed changes might actually reduce individual or cumulative occupational radiation exposures by eliminating the potential for fire patrols conducted more often than necessary to ensure -
the hourly requirement is met.
I 1.
No Significant Construction Imoact.
The proposed changes do not involve a plant modification. Therefore, there is no construction impact.
12.
No Significant Increase in the Potential For. or Radiological or Chemical Conseauences From. Previousiv Analyzed Accidents.
The addition of a defmition for " Completion Time" and the maximum time interval for repetitive actions provides more formality in the conduct of plant operations. This term has not been formally defined in the past and was left open to varying interpretation. The inclusion of the definition will ensure interpretation of" Completion Time" and that the
GDP97-0020 Page 4 of 4 maximum interval between repetitive actions is consistently applied. The proposed changes do not affect the potential for or radiological or chemical consequences from previously analyzed accidents, i
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