ML20135D860
| ML20135D860 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth 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-97-0021, GDP-97-21, TAC-L32016, NUDOCS 9703060053 | |
| Download: ML20135D860 (24) | |
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'h United Stitis Enrichmint Corporation
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2 Democracy Center 6903 Rockledge Drive Bethesda, MD 20817 Tel. (301) 564-3200 ad304 564-3201 linited States Enrichment Corpiration JAMES H: MILLER Dir (301)56443309 VICE PRESIDENT, PRODUCTION Fax:(301) 571-8279 February 28,1997 Dr. Carl J. Paperiello SERIAL: GDP 97-0021 Director, Office of Nuclear Material Safety and Safeguards Attention: Docmnent Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Portsmouth Gaseous Diffusion Plant (PORTS)
Docket No. 70-7002 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 Portsmouth, Ohio Gaseous 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 intern! 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 repetitive intervals consistent with the interpretation of other repetitive intervals defined in the SAR and TSRs.
9703060053 970220 ADOCK0700g2
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PDR Offices in Paducah, Kentucky Portsmouth, Ohio WasNngton, DC
. -. -. - ~... - -. -. _ - - =
.-- l Dr. Cstl J. Paperiello i
February 28,1997 GDP 97-0021, Page 2 i
Enclosure I to this letter provides a detailed description and justification for the proposed changes to the PORTS 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.
i Since this proposed certificate amendment request is an enhancement to the existing Technical Safety 1
Requirements and is not required to support continued operation, USEC requests NRC review and i
approval at your earliest convenience. The amendment should become effective 30 days from issuance.
M Any questions related to this subject should be directed to Mr. Mark Smith at (301) 564-3244.
Si
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l' es II. Miller ice President. Production
Enclosures:
As Stated cc:
NRC Region III Office NRC Resident Inspector-PORTS NRC Resident Inspector-PORTS Mr. Randall M. DeVault (DOE) i I
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I OATH AND AFFIRMATION i
I, James H. Miller, swear and affirm that I am Vice President,-Production, of the United l
States Enrichment Corporation (USEC), that I am authorized by USEC to sign and file with the _
,'i Nuclear Regulatory Commission this Certificate Amendment Request for the Portsmouth Gaseous -
Diffusion Plant, that I am familiar with the contents thereof, and that the statements made and.
i matters set forth therein are true and correct to the best of my knowledge, information, and belief.
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l J 1e I. Miller l
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Subscribed to before me on this ' d b day of /$4
,1997, i
LINDA ANDERSON-
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939 Notary Public J
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GDP97-0021 j
Page 1 of 2
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United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Definition of Completion Times Detailed Description of Change Specific TSR Sections Affected 1.
A new definition is added to Section 1.2, as follows:
1.2.7 Completion Time - The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time ofdiscovery of a situation (e.g., inoperable equirment or variable not within limits) that requires entering an ACTIONS Condition anless otherwise specified, providing the system / component is in a MODE or speified condition stated in the Applicability of the LCO.
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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 1.2.8,
" Cylinder Categories", through old number 1.2.20, " Uncomplicated IIandling", are renumbered to account 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
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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 perfonnance. For Completion Times specified as "once," the 25% time interval extension does not apply.
Reason for Change The PORTS Technical Safety Requirements (TSRs) require that fire protection sprinkler systems and High Pressure Fire Water System (11PFWS) distribution mains be operable for the cascade facilities. When these systems are determined to be inoperable, TSRs 2.2.3.4 and 2.7.3.3 specify that a fire patrol be conducted within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> thereafter. For repetitive actions, such as this, the TSRs do not define the time interval nor specify if an extension is permitted. The
0 GDP97-0021 Page 2 of 2
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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 repetitive actions is consistent with nuclear industry practice as evident in NUREG-1431, Standard TechnicalSpecifications, Westinghouse Plants, April 1995, Section 1.3 and Surveillance Requirement SR 3.0.2.
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Justification of the Change j
l The proposed additions to Sections 1.2 and 1.6 will establish'a consistent understanding of the j
interval requirements. The information added to Section 1.2 clarifies the meaning of Completion j
- 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 i
. Plants, dated April 1995.)
1 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 TechnicalSpecifications, Westinghouse Plants, April 1995, Section 1.3 and Surveillance Requirement SR 3.0.2.
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FROM (FRI)02. 28' 9712:25/ST,12:20/N0. 3561571482 P 2/16 GDP97-0021 15 Pages a
Proposed Certificate Amendment Request Portsmouth Gaseous Diffusion Plant Letter GDP97-0021 Removal / Insertion Instructions Remove Pages Insert Pages VOLUME 1 Definitions Definitions I through 4 1 through 4 VOLUME 4 Table of Contents Table of Contents y and vi v and vi Section 1.2.4 Section 1.2.4 1,0-2 through 1.0-9 1.0-2 through 1.0-9 l
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i-Jn (al)02. 28'9712:25/ST.12:20/N0. 3561571482 P 3/16 TSR-PORTS PROPOSED RAC 97X0061 (RO)
February 28,1997 I
CONTENTS 1
SECTION 1.0 USE AND APPLICATION......
. 1.0 1 i
1.1 INTRODUCTION
1.0-2 1.2 DEFINITION OF TERMS...........
1.0-2 i
1.2.1 ACTIONS..............
i 1.2.2 1.0-2 ADMINISTRATIVE CONTROLS............
1.0-2 1.2.3 ALLOWABLE VALUE.
1 1.0-2 1.2.4 CASCADE MINIMUM SUCTION PRESSURE.........
1.0-2 1.2.5 CHANNEL CHECK.......
i 1.2.6 CHANNEL FUNCTIONAL TEST.
1.0-2 1.0 2 1.2.7 COMPLETION TIME.
1.0-3 l
1.2.8 CYLINDER CATEGORIES..............
1.2.9
............... 1.0-3 l
i DESIGN FEATURES (DF).......
3 1.0-3 1.2.10 FIRE PATROL.
1.0-3 1.2.11 IMMEDIATELY.......
i 1.2.12 1.0-3 LIMITING CONDmONS FOR OPERATION (LCO) 1.2.13 1.0-3 LIMmNG CONTROL SETTING (LCS).....
j 1.2.14 OPERABLE
............... 1.0-4 i
1.2.15 OPERATING CYCLE (AUTOCLAVE) 1.04 i
1.2.16 1.04 PLANNED EXPEDMOUS HANDLING (PEH).
1.04 1.2.17 SAFETY LIMIT (SL)........
1.04 1.2.18 SURVEILLANCE REQUIREMENTS (SRs) 1.0-4 1.2.19 UF, CYLINDER (OR CYLINDER)........................
l 1.2.20 1.04 UNCOMPIJCATED HANDLING (UH).
1.0-4 1.3 TIME INTERVALS FOR SURVEILLANCE....
4 1.4 LIST OF ACRONYMS........................
1.0-5 1.0-6 1.5 INTENT OF TERMS..
LO-6 1.6 GENERAL APPLICATION...................................
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.............. 1.0-6 1.6.1 SAFETY LIMIT...................
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1.6.2 OPERATING LIMITS 1.0-6 1.0-7 1.6.2.1 U=l**a= Control Settings 1.0-7 1.6.2.2 U=iting Conditions for Operation.....
s 1.0-7 i
1.6.3 SURVEILLANCE REQUIREMENTS I.6.4 CONDmONS OUTSIDE TSR..........
1.0-8 1.0-9 SECTION 2.0 FACILITY SPECIFIC TECHNICAL SAFETY REQUIREMENTS.
.................. 2.0-1 i
i 2.1 SPECIFIC TSRs FOR X-342, X-343, AND X-344 FACILMES..
2.1-1 1
2.1.1 X-342, X-343, X-344 AUTOCLAVE OPERATIONAL MODES l
2.1.2 SAFETY LIMITS................
2.1-2 4
2.1-3 2.1.3 i
LIMITING CONTROL SETI'INGS, LIMITING CONDmONS FOR OPERATION, SURVEILLANCES 2.1-4 2.1.3.1 Criticality Accident (Radiation) Alann Systems...
2.1-4 2.1.3.2 UF, Cylinder High Pnesure Autoclave Samam Shutoff
. 2.1-5 2.1.3.3 UF, Cylinder High Temperature Autoclave Steam Shutoff...
2.1-7 v
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TSR-PORTS PROPOSED RAC 97X0061 (RO)
February 28,1997 CONTENTS (Condnued) 2.1.3.4 Autodave SheH High Staaet Pressure Shutdpwn.........
2.19 2.1.3.5 Autodave 8hdi High Pressure Can#=in==nt Outdown.....
2.1-11 2.1.3.6 Autodate Shell High Pressure Reuef Sysica...
l 2.1.3.7 High Condannah Imd Shutdf.
2.1-13 2.1-15 2.1.3.8 Cylinder Headng 2.1-16 2.1.3.9 Low Cylinder Pressure Shutoff'...........
2.1 18 2.1.3.10 Cylinder Assay I Amitation 2.1 -19 2.1.3.11 Autoclave Smoke Detection System...
.............. 2.1 20 2.1.3.12 Liquid UF, Handling Cranes........
2.1-21 2.1.3.13 Pistall line Isoladen...
2.1-23 2.1.3.14 Liquid UF, Movement.......................... 2.1-24 2.1.3.15 Receiving Cylinder Fui Weights................
2.1-25 2.1.3.16 UF, Cylinder Crane Movernest 2.1-28 2.1.3.17 UF, Cylinder Weight Discrepancy 2.1-29 2.1.3.18 UF, Plugs.
2.1-30 2.1.4 GENERAL DESIGN FEATURES...........
2.1-31 2.1.4.1 UF, Cylinder Lifting Fistures 2.1-31 2.1.4.2 UF, Cylinders..........
2.1-31 2.1.4.3 UF, Cylinder Pagtails........
2.1-32 2.1.4.4 X-342 Condensat* Sump and Oil Interce 2.1-32 Autoclave Shell................ ptor...
2.1.4.5 2.1-33 2.1.4.6 Overhand Crane Capadty..............
2.1-33 2.2 SPECIFIC TSRs FOR X-330 AND X-333 CASCADE FACILITIES 2.2-1 1
2.2.1 X-330/X-333 CASCADE OPERATIONAL MODES 2.2-2 2.2.2 SAFETY LIMITS..............
2.2-3 2.2.3 LIMITING CONTROL SETI1NGS, LIMITING CONDITIONS FOR OPERATION, SURVEILLANCES 2.24 2.2.3.1 Coolant High Pressure Rdief System...
2.2-4 2.2.3.2 Criticauty Aeddent (Radiation) Alarm System.
2.2-6 2.2.3.3 CADP UF, Smoke Detection System 2.2-8 2.2.3.4 High Pressure Fire Water System......
2.2-9 2.2.3.5 Coolant Removal 2.2-12 2.2.3.6 Cell Treatment Monitoring......
2.2-13 2.2.3.7 CellInverse Recyde Treatment.....
2.2-14 2.2.3.8 Seal Erhanet Station Enrichment...
2.2-15 2.2.3.9 Evacuation Booster Station (EBS) Enrichment 2.2-17 2.2.3.10 Crane Movement of Cascade Equipinent...
2.2-19 2.2.3.11 Evacuation Booster Station Oxidant Ihnit.........
2.2-20 2.2.3.12 UF, Plugs 2.2-21 2.2.3.13 Cascade Pttssure limitadon............
2.2-22 2.2.3.14 Cascade DC Control Power.........
2.2-24 2.2.3.15 Moderation Control.....
2.2-27 2.2.3.16 Resnoved Equipment with Deposits..
2.2-31 2.2.4 GENERAL DESIGN FEATURES,.........
2.2-33 2.2.4.1 Seal Erhaust Pump Overflows 2.2-33 i
M (FRI)02. 28' 9712:26/ST.12:20/N0. 3561571482 P 5/16 4
4 TSR-PORTS PROPOSED l
RAC 97X0061 (RO)
Fabruary 28,1997 4
SECTION 1.0 USE AND APPLICATION I
1.1 INTRODUCTION
i 10 CFR 76.87(a) mates "'Ihe Corporation shall establish technical safety requirement In establishing the requirements, the Capoi.iion shall consider the analyses and result of the safety analysis report oubmitted pursuant to 10 CFR 76.35." These Technical i
Safety Requirements (TSRs) are intended to fulfill the requirements of 76.87 and set 2
forth approved limitations for operation of the Portsmouth Gaseous Diffusion Plant (PORTS). The TSRs derme the conditions, safe boundaries, and the management or i
administrative comrols necessary to ensure safe operation of the facility and are based on the accidents analyzed in the Safety Analysis Report (SAR).
4 1.2 DEFINITION OF TERMS 1.2.1 Actions - That part of a TSR that prescribes required actions to be taken under
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designated conditions within specified completion times.
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1.2.2 A4ministrative Controls - The provisions relating to orgamzation and management, procedures, recordkeeping, reviews and audit, and reporting narruary to ensure j
operation of the plant in a safe manner.
i 1.2.3 Allowable Value - The limiting value that the trip setpoint can have when tested i
periodically, beyond which the instrument channel is declared inoperable and corrective action must be taken.
j 1.2.4 Caernde Mininuun Surtlan Pressure - The "A" suction pressure of any operating cell
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which is being used to reduce another cell's UF, inventory.
i 1.2.5 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 stams derived from independent instrument channels measuring the same parameter.
s 1.2.6 Channel Functional Test - The injection of a sirrulated or actual signal into the i
channel as close to the sensor as practicabic to verify operability, including required
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alarms, interlocks, trip functions, and channel failure trips. The Channel Functional j
Test may be performed by any series of sequential, overlapping, or total channel step such that the entire channel is tested.
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(FRl)02. 28' 9712:27/ST.12:20/N0. 3561571482 P 6/16 t
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TSR-PORTS t
PROPOSED RAC 97X0061 (RO)
February 28,1997 l
SECTION 1.0 USE AND APPLICATION i.
1.2.7 Completion 'thne 'Ihe Completion Time is the amount of tinie allowed for completing l
i a Required Action. It is refs,.iiisd to the time of discovery of a situation (e.g.,
l inoperable equipment or variable not within limits) that requires entering an ACTIONS l
l Condihon unless otherwise specified, providing the system / component is in a MODE or l
j specified condition stated in the Applicability of the 1f0.' Required Actions must be l
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completed prior to the expiration of the specified Completion Time. An ACTIONS l
4 C*itiewt remains in effect and the Required Actions apply until the Condition no longer l
l exists or the system / component is not within the LCO Applicability.
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1.2.8 Cylinder Categories - Cylinders are categorized as follows:
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'Catemory
- UF, CvlirvL e Mrviel Nn=M i
A Cylinders with the following model numbers can be heated to a limit i
of 235 'F and still meet the applicable void volume criteria: IS, 2S, j
5 (A, B, S, L), 8 (A & S),12 (A & B), 30 (A Ac B), 48A, 480 (Serial Nos. 111821 and above), 48X, 48H, 48HX, 48Y.
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B Cylinders with the followmg model numbers can be heatM to a limit' j
of 220F and still meet the applicable void volume criteria: 480 &
480M (Senal Nos.111820 and below), 48B (48B cylinders may also be known as 48T),48F.
C Damaged or everfilled cylinders that are fed by Controlled Feeding 1.2.9 Design Festores (DF) - Those daign attributes of structures, systems, and components I
that pasively prevent or mitigr.e the consequences of radiological accidents that could cause significant consequences.
1.2.10 Fire Pa$rol - Required to perform monitoring of an area for fire due to a fire j
suppression or detect'on system being impaired / inoperable. This monitoring shall be performed at reguhr imervals not to exceed the interval specified in the facility-specific TSR. The person performing the fire patrol must be mstmeted on the following:
(1) specifically what system is ingerable and the area to be patrolled, (2) actions to take upon discovering a fire, and (3) procedures for reporting a fire.
1.2.11. Immediately - Required action sho'11d be pursued without delay and in a controlled l
manner.
1.2.12 Limiting Conditions for Operation (140) - The lowest functional capability or I
performance levels of structures, systems, components and their support systems required for normal safe operation of the plant.
I 1.0-3
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TSR-PORTS PROPOSED RAC 97X0061 (RO)
February 28,1997 SEUTION 1.0 USE AND APPLICATION
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1.2.13 Limiting Control Setting (LCS) - Settings for automatic alarm or protect related to those variables having significant safety functions.
l 1.2.14 Operable - An SSC shall be operable or have opentbility when it is c performmg its specified function (s), and when all necessary attendant ins l
t controls, electrical power, cooling or seal water, lubrication, or other auxiliary i
equipment that are required for the SSC to perform its specified function (s) are capable of performing their related support function (s).
1.2.15 Operating Cycle (Autoclave) 'Ihe time between the initial entrance l
mode (Mode II) and completion of the intended task (feeding, sampling, tran inclusive of mode changes which might be required during the course of the evolutio 1.2.16 Plannad Expedidous Handling (PEH) - Handling of equipment containing j
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a safe mass of uranium.
l 1.2.17 Safety Limit (SL) - Those bounds within which the process variables must be i
maintained for adequate control of the operation and that must not be exceeded in ord l
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to protect the integrity of any physical system that is designed to guard against the uncontrolled release of radioactivity.
1.2.18 Surveinance Requirements (SRs);- Requirements telating to test, calibration, l
mspection to ensure that the necessary quality of systems and components is mainta that the plant operation will be within the safety limits, and that the limiting conditio for operation will be met.
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1.2.19 UF, CyL.As (or cylinder) - Unless otherwise specified, UF, cylinder (or cyl l
intended to be limited to large (2 %- ton and larger) UF cylinders.
l 1.2.20 Un=npucatad Handling (UH) - Ifandling of equipment that contains a depos an always safe mass.
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ic.22 (FRI)02. 28' 9712:28/ST.12:20/N0. 3561571482 P 8/16
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TSR-PORTS '
PROPOSED RAC 97X0061 (RO)
February 28,1997 i
SECTION 1.0 USE AND APPLICATION i
1.3.
TIME INTERVAIE FOR SURVEILLANCE d
Interval Interval Between Consecutive Maximum Interval Between Designation Surveillantes Consecutive Surveillances Five-year 5 years to the day 5 years to the day (unless l
4 specifically stated otherwise)
Biennially 2 years 2 years 6 months 4
Annually 365 days 456 days Semiannually 184 days
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245 days Quarterly 92 days 123 days 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
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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 in 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.
i The extension between the standard and maximum surveillance inte i
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 ha been in accordance with DOE 5481.1B.
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(FRI)02. 28' 9712:28/ST.12:20/N0. 3561571482 P TSR-PORTS PROPOSED Pebruary 28,1997 RAC 97X0061 (RO) s SECTION 1.0 USE AND APPLICATION 1.4 LIST OF ACRONYMS i
ANSI American National Standards Institute DF Design Feature LCO Limiting Conditions for Operation LCS Limiting Control Setting MAWP Maximum Allowable Working Pressure NKC Nuclear Regulatory Commission i
PEH Planned Expeditious Handling TSR Technical Safety Requirements SAR Safety Analysis Report SL Safety Limit SR Surveillance Requirement SSC System, Structure or Component j
UII Uncomplicated Handling i
4 1.5 INTENT OF TERMS Shall Requirement Should Recommendation May Permission l
1.6 GENERAL APPLICATION 1.6.1 SAFETY LIMIT 1.6.1.1 Compliarse 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 perfonn the following:
If the conditions do not require evacuation, attempt to bring the a.
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.
b.
If appropriate, notify plant emergency personnel and initiate building evacuation.
Conduct a technical evaluation to determine if any damage has c.
occurred and to evaluate the ability of the system to be restarted.
1.0-6
TSR-PORTS
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PROPOSED RAC 97X0061 (RO)
February 28,1997 SECTION 1.0 USE AND APPLICATION 1.6.2 OPERATING LIMITS 1.6.2.1 LIMITING CONTROL SETTINGS Compliance with the LIMITING CONTROL smsNG requirement a.
is required durmg the OPERATIONAL MODES specified in the Applicability Statement.
1.6.2.2 LIMITING CONDITIONS FOR OPERATION Compliance with the LIMITING CONDITIONS for OPERATION a.
contained in these requirements is required during the OPERATIONAL MODES specified within the Applicability statement, except as provided in 1.6.2.2 b.
b.
1 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions diall be met.
When a LIMITING CONDITION for OPERATION is not met, c.
complete the attendant action steps within the required time interval.
If the action steps are not met within the specified time interval, or 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 accordance with the LCO or ACTIONS, completion of the actions required by this TSR (1.6.2.2 c.) is not required.
d.
Entry into an OPERATIONAL MODE that is applicable to a particular ILO shall not be made tmless 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 OPERATIONAL MODES as required or allowed by. ACTION statements.
1.0-7
FROM (FRI) 02. 28' 97 12: 29/ST.12:20/N0. 3561571482 P 11/16 a
TSR-PORTS PROPOSED RAC 97X0061 (RO)
February 28,1997 SECTION 1.0 USE AND APPLICATION LCO Completion Times. The completiori times for ILO required e.
actions begin when that specific condition is discovered, regardless of how long that condition may have previously existed. All completion times within a single row of an LCO table are measured from the l
point of discovery of that condition.
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
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Section 1.3 applies to each performance after the initial performance.1 i
For Completion Times specified as "once," the 25% time interval 2
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extension does not apply.
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Equipment removed from service or declared inoperable to comply
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with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABLITY or the OPERABILITY of other equipment. This is an exception to 1.6.2.2 b. for the system returned to service under i
administrative control to perform the testing required to demonstrate OPERABILITY.
1.6.3 SURVEILLANCE REQUIREMENTS I
1.6.3.1 SURVEILLANCE REQUIREMENTS shall be met prior to entering the OPERATIONAL MODES or other conditions specified for individual LCS and ILOs unless otherwise stated in an individual SURVEILLANCE REQUIREMENT.
1.6.3.2 Each SURVEILLANCE REQUIREMENT shall be performed in accordance with section 2 and within the maximtun time interval defined in Section 1.3. Surveillances do not have to be performed on SSCs which are not in, or being prepared to enter, the applicable operating mode (s).
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i 1.6.3.3 Failure to perform a SURVEILLANCE REQUIREMENT within the i
j maximum acceptable time interval constitutes a failure to meet the 3
OPERABIllTY reqmrements for a LIMITING CONDITION for OPERATION. Exceptions are stated in the individual requirements.
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When it is discovered that a surveillance has not been performed within the maximum acceptable time interval for 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 4
specified frequency (whichever is less) of discovery:
i 1.0-8 4
TSR-PORTS PROPOSED RAC 97X0061 (RO)
February 28,1997 SECTION 1.0 USE AND APPLICATION i
1 Perfonn the required surveillance, or a.
b.
Place the equipment in an cpadug mode for which the system is not required.
In instances where inoperability is declared due to missed surveillances.
this general usage action statement takes preference 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 i
action steps associated with system inoperability shall be immediately initiated in accordance with the facility specific LCO.
1.6.3.4 Entry into an OPERATIONAL MODE or other specified condition shall be made unless the SURVEILLANCE REQUIREMENT (
not associated with the LIMITING CONDITION for OPERATION hasi been performed within the stated surveillance interval or as otherwise
[
specified in the individual surveillance requirements. This provision shall
)
not prevent passage through 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 TSRs, operatio personnel should use their training and expertise to take actions to correct or mitigate the situation.
Also, operations penonnel 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 safe 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 verbal and written notifications shall be made in accordance with 10CFR76.120.
1.0-9
m (R1102. 28' 97 12:30/ST.12 :20/N0. 3561571482 P 13/16 SAR-PORTS RAC 97 X0061 R(0)
PROPOSED February 28,199}
1.0' DEFINITIONS Assay - As used in the uranlurn carichment industry, the "U isotopic tencontrati uranium in a uranium-bearing material,' typically stated in wt 'A (e.g.,2.75% assay)
Completion Thne - The Completion Time is the amount of time 410wed fo t
Action. It is referenced to the time of discovery of a situadon (e.g., inoperable equi l
not within linuts) that requires entenng an ACTIONS Condition unless otherw l
system / component is in a MODE or pas condition stated in the Applicability of I
Actions must be completed prior to the expiration of the specified Completion Time.
Condition remains in effect and the Required Actions apply until the Condition no l; system / component is not within the LCO Applicability.
If a Completion Time requires periodic performance on a "once per..." or "every h I
basis, the 25% time interval extension specified in the Note to Section 3.0 appli l
after the initial perfonnance. For Completion Tunes specified as "once," the 25 % tim l
does not apply.
l 1% Assessment - A determination of the capabilities, performance and overall effec the a program performed by persons not associated with the program or topic being as or "U for which accoumabilky is required by NRC.Nedseramateri Safeguards - An integrated system of physical protection, accountability, and mate designed to deter, prevent, detect, and respond to unauthorized possession and/or use o Tails - Depleted UF. below normal assay, which is withdrawn from tlw "bouom" of the placed into long-term storage.
Inspect -Inspect, unless specifically stated otherwise, is intended in the standard visual evaluation for acceptability.
UF, Cylinder (or cylinder) - Unless otherwise specified UF, cylinder (or cylinder) is inte limited to large (21/2-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 I.evel ALARA -
As I.ow As Reasonably Achievable ANSI American National Standards Institute
)
AQ Augmented Quality 1
ARA Airbome Radioactivity Area CCB Change Control Board CCZ Contamination Control Zone CFR Code of Federal Regulations 1
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'E2 (FRI)02. 28' 9712:31/ST.12:20/N0. 3561571482 P 14/16 SAR-PORTS RAC 97 X006) R(0)
PROPOSED Pcbruary 28,1997 i
CM Corrective Mainumance 1
DOE United States Department of Energy EAL Emergency Action Level EC8R Environmental Compliance Status Report i
E&H Environmental and Health i
EOC Emergency Operadons Center EPA Environmental Protection Agency EPIP Emergency Plan Implernanting Procedure ERO Emergency Response Organization FNMCP -
Pundamental Nuclear Materials Control Plan GERT General Employee Radiological Training GET General Employee Training I
HP Heahh Physics l
HRA High Radiation Area JCO Justification for Continued Operations j
LAW Low Assay Withdrawal i
LEU Low Enriched Uranium LMES Lockheed Martin Energy Systems LMUS Lockheed Martin Utility Services MBA Material Balance Area NBS National Bureau of Standards NCS Nuclear Crideality Safety 1
NDA Nondestructive Assay NIST National Institute of Standards and Technology NM Nuclear Material NMSS NRC Office of Nuclear Materials Safety and Safeguards NRC Nuclear Regulatory Commission PDGP Paducah Oaseous Diffusion Plant j
PM Preventive Maintenance PORC Plant Operations Review Committee PORTS -
Portsmouth Gaseous Diffusion Plant PRB Procedures Review Board PSS Plant Shift Superintendent PW Product Withdrawai QAP Quality Assurance Program RA Radiation Area RMA Radioactive Material Area RP Radiation Protecdon RWMP -
Radioactive Waste Management Program RWP Radiological Work Permit S&S Safeguards and Security SAE Site Area Emergency SAR Safety Analysis Report SM
- Source Material SNM Special Nuclear Material SOP Standard Operating Procedure 4
l SPP Standard Practice Procedure 4
2 j
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pgog (FRl)02.28'9712:31/ST.12:20/N0.3561571482P15/16 SAR-PORTS RAC 97 X0061 R(0)
PR3 POSED February 28,1997 SS&Q Safety, safeguants, & Quality sac structures, systerns and components SWU Separativ'e Work Unit
-TSR Technical Safety Requirements UE Uranium Enrichmem UF.
Uranium Hexaflouride USEC United States Enrichment Corporation l-
-3.0 FREQUENCIES i
i imerval Designation Incarval Between Consecutive Marl =nm Interval Between (Frequency)
Actions Cnnsecutive Actions -
a Five-yr i 5 years to the day 5 years to the day (unless -
L specifically stated othesise) i j
Bic..kily 2 years 2 years 6 months 1
Annually 365 days 456 days Semimaa"=11y 184 days 245 days Quarterly 92 days 123 days 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
]
Per Shift 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 k a the standard and maxunum surveillance intervals is intended to be used to accommodate operational and maintenance schedul The extension between the scandard and n:aximum surveillance interva 25% of the standard value with the exception of twice each shift, quarterly, and semlannual items. The extension on these intervals is 33% which i consistent with past plant practice.
4 h
3
FROM (FRI)02. 28' 9712:32/ST.12:20/N0. 3561571482 P 16/16
-PORTS j
September 15,1995 Blank Page 4
(
SAR-PORTS September 15,1995 Rev.1 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 Safety. Safeguards. or Security Programs.
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 interpretatio 1.
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-2) specifically address a definition for " Completion Time" or 6e maximum time interval for repetitive actions. Thus, the proposed changes have to isra ! on any of the Conditions to the Certificate of Compliance.
3.
No Significant Chance to Any Condition of thclpproved Compliance Plan The proposed TSR changes involve the addition of a definition for " Completion 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.
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% 4 GDP97-0021 Page 2 of 4 j
4.
No Significant increase in the Probability of Occurrence or Consecuences of Previously Evaluated Accidents j
~ 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.'
j 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.
1 5.
No New or Different Tvoe of Accident 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. This change would not create the possibility of a new or different type of accident than any previously evaluated.
6.
No Significant ReductioliaMargins of Safety The addition of a definition for " Completion Time" and the maximum time interval for repetitive actions provides more formality in the conduct of plant operat!ons. This term has not been formally defined in the past and was left open to varying, interpretation.
j The inclusion of the definition will ensure interpretation of" Completion Time" and that the maimum 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 Anolication.
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.
. ~
Y,a I
GDP97-0021 J-i Page 3 of 4 8.-
The Pronosed Changes do not Result in Undue Risk to 1) Public Health and Safety. 2)
Common Defense and Security. and 3) the Environment.
]
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. As such, these changes do not represent an undue risk to public health and safety. In addition, these revisions have no impact on plant effluents or on the programs and plans in place to j
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 Types or Significant Increase in the Amounts of Any Effluents That May Be Released Offsite.
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. As such, these
- changes have no impact on plant effluents.
i l
10.
No Significant increase in Individual or Cumulative Occupational Radiation Exposure.
1
[
The addition of a definition for " Completion Time" and the maximum time interval for 3.
repetitive actions provides more formality in the conduct of plant operations. This term j
has not been formally defined in the past and was left open to varying interpretation.
j The inclusion of the definition will ensure interpretation of" Completion Time" and that
.j
'the maximum interval between repetitive actions is consistently applied. The proposed changes might actually reduce individual or cumulative occupational radiation j
exposures by eliminating the potential for fire _ patrols conducted more often than j
i necessary to ensure the requirement is met.
4 I1.
No Significant Construction Impact.
1 I
The proposed changes do not involve a plant modification. Therefore, there is no j
construction impact.
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-4,,~
,c,.
GDP97-0021 i
j Page 4 of 4 j
i 12.
No Significant Increase in the Potential For. or Radiological or Chemical Conseauences i
From. Previousiv Analyzed 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 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 do not affect the potential for or radiological or chemical consequences from previously analyzed accidents.
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