ML20136G006

Forwards Response to RAI Re Certificate Amend Request to Correct Discrepancy Between Actual Plant Configuration & Design Feature Specified in Tsr

ML20136G006
Person / Time
Site:	Paducah Gaseous Diffusion Plant
Issue date:	03/10/1997
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-97-0034, GDP-97-34, TAC-L32013, NUDOCS 9703170154
Download: ML20136G006 (17)

Text

,

Y.

~

,'. g.

United States Enrichment Corporation

~

2 Democracy Center 6903 Rockledge Drive Bethesda, MD 20817 Tel. (301) 564-3200 Fax: (301) 564-3201 Un.ited b,lates Enrichment Corporation JAMES H. MILLER Dir; (301) 564-3309 VICE PRESIDENT, PRODUCTION Fax: (301) 571-8279 March 10,1997 Dr. Carl J. Paperiello SERIAL: GDP 97-0034 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 Response to Request for Additional Information Certificate Amendment Request-Feed Facilities Crane Design Features

Dear Dr. Paperiello:

This purpose of this letter is to provide a response to the NRC's request for additional information (TAC No. L32013) on the subject Certificate Amendment Request. This amendment would revise Technical Safety Requirement (TSR) 2.2.5.2, Crane Design, to correct a discrepancy between the actual plant configuration and the design features specified in the TSR. provides a response to each of your staffs questions or requests. Enclosure 2 provides the new pages for the TSR and SAR that are changed as a result of this response. USEC has reviewed the Enclosure 2 (Detail Description of Change) and Enclosure 4 (Significance Determination) which were previously transmitted in our Febmary 14,1997 Cedificate Amendment Request (Reference 1) and has determined that the conclusions of these enclosures are still valid. As such, only the enclosed TSR replacement page (TSR page 2.2-31) and SAR pages (A-3, 3.2-10a, 3.2-10b, 3.7-4a, 3.7-5, 3.7-5a, 3.7-5b, 3.15-7,3.15-7a,3.15-7b) are provided with this response.

In letter GDP 97-0009 dated January 31,1997, USEC provided the NRC a copy of the revised Appendix A to SAR Chapter 1 for both the PGDP and PORTS plants. The revised Appendix A identifies the extent of USEC's current commitment to various industry codes, standards, and regulatory guidance documents originally identified in the certification application and related correspondence.

I 9703170154 970310 L

h!E,E % lE,E,E,E % E j

R ADOCK 0700 1

Offices in Paducah. Kentucky Portsmouth. Ohio Washington. DC

t' W"

.y Dr. Ca-D. Paperiello March 10,'1997 GDP 97-0034 Page 2 USEC is undertaking an initiative to determine if further application ofindustry codes and standards at the GDPs is warranted. This initiative encompasses the following tasks:

-(a)

Review the codes and standards in SAR Chapter 1, Appendix A, to determine if any additional documents, different editions, or additional sections of documents should be applied to the GDPs. As part of this review, determine what structures, systems, components, analyses, and operations would be subject to each document. It is anticipated that current e

practices at fuel cycle, reacto., and related chemical facilities (as applicable to the design and operation of the GDPs) will be useful benchmarks in conducting these reviews.

(b).

Review the design, supporting analyses, and operations of the GDPs and determine what hardware, analysis, or operational changes would be required to meet the identified codes and standards.

(c)

Evaluate the benefits and costs of the identified hardware, analysis, and operational changes and decide which changes are worthwhile.

(d)

Implement the chwips.

USEC will keep the NRC informed of our progress, as plans are developed and finalized.

This additionalinformation should enable you to corg,wte the review and approval of our Certificate Amendr;ent Request. Any questions related to this subject should be directed to Mark Smith at (301) 564-3244.

Sin

ely,

^A 7

es H. Miller ice President, Production

- Enclosures cc:. RC Region III Office N

. NRC Resident Inspector - PGDP NRC Resident Inspector - PORTS Mr. R. DeVault-COE I

i

l*

1 j

Dr. Carl J. Paperiello j-March 10,1997 i

GDP 97-0034 Page 3 References 1.

USEC Letter GDP 97-0018, James H. Miller to Dr. Carl J.. Paperiello, " Certificate Amendment Request-Feed Facilities Crane Design Features", dated February 14,1997.

i 4

4 R

I I

i 4

e 4

k d

e f

_-y n

e-l i

GDP 97-0034 i

Page1of2 1.

The text in the SARUSR does not irulicate that thefeedfacility cranes meet any aspect ofANSI B30.2. However, both the sigmficance determination and thejustificationfor enforcement discretion imlicate that the brakes meet the requirements ofANSI B30.2.0-1967.- There is also no discussion of whether the brakes have been maintained in accordance with the ANSI i

starulard. Compliance Plan issue 45 was intended to resolve the issue of commitm?nt to standards, however, it is noted that USEC has not committed to any standardfor thefeed l^

cranes in the January 31,1997, s"' ~uittalrelated to this compliance plan issue. Please clarify

}

what standard, or portion of s

ndard, USEC is committed tofor thefeed cranes. The SA10TSR should clearly indicate any commitment to a standard. If USEC is unwilling to commit to any standard, please explain why not, or, if the commitment is limited to aportion ofa standard, explain why.

L USEC Resoonse l

USEC is committing at PGDP to the following Sections of ANSI B30.2 - 1990 Edition (including Addenda A,1991) as the applicable standard for the liquid UF and feed facility 6

handling cranes.

Section 2-2.1.1-all 4

i Section 2-2.1.2-all Section 2-2.1.3-all except for paragraphs (6), (8) and (9) 3 Section 2-2.2.2-only paragraphs (a), (b)(1), and (b)(4)

Section 2 ?.3.1-all Section 2-2.4.1-all includes a change to Section 1.11 of Appendix A to Chapter 1 of the SAR.

l 2.

DF 2.2.S.2, 2nd bullet. fruticate what type of brakes are inplace; use of the term hoist brakes is not clear.

4 i

USEC Resoonse i' includes a revision to our proposed change of TSR 2.2.5.2. The second bullet is being revised to read:

f Two hoist brakes that meet the requirements of ANSI B30.2,1990 Edition (including a

Addenda A,1991).

The specific type of brakes are specified on page 3.15-7 of the SAR under Section 3.15.1.1.7.

.~--.---... - - -..

e o

w GDP 97-0034 Page 2 of 2 3.

SARpg 3.2-10a, 3.2.6.1,1stparagraph, 6th sentence. Clarify in the text whether each crane has a geared up/down switch or if the discussion only applies to the C-337A north crane.

USEC Resoonse A " geared up/down switch" applies to each of the feed facility cranes. Enclosure 2 contains a revision to page 3.2-10a of the SAR to clarify the section to minimize any confusion.

l, 4.

SARpg 3.2-10a, 3.2.6.1,1stparagraph. A discussion of the C-333A east crane should also be included.

USEC Response A description of the C-333-A East crane is included in the change to SAR 3.2.6.1, which is included in Enclosure 2.

5.

SARpg 3.7-Ja. Is ityour intention to delete the 3 paragraphs ofexisting textfrom thispage?

Either reinsert the text or explain why it has been deleted.

USEC Resoonse 1

2 It was not USEC's intent to delete the three paragraphs. The deleted paragraphs were automatically shifted to a different page (by the word processing program) when sentences that referred to pending construction, which had already been completed, were deleted. It was our error in not including this additional page for your information. Pages 3.7-4a and 3.7-5 are j

included in Enclosure 2.

i 6

SAR pg 3.15-7. The list shouhlindicate the type of brake inplace and not merely state hoist brakes.

USEC Response 1

" Hoist brakes" have been specified in a revised SAR page 3.15-7 (see Enclosure 2). The revision of SAR page 3.15-7 specifies the type of brakes utilized for each feed facility crane.

a

)

w _

1 GDP 97-0034 Page1of12 Technical Safety Requirement and Safety Analysis Report Pages

a.

TSR-PGDP PROPOSED March 10,1997 RAC 96C224 (RI)

SECTION 2.2 SPECIFIC TSRs FOR UF. FEED FACILITIES (C-333-A AND C-337-A) 2.2.5 GENERAL DESIGN FEATURES 2.2.5.1 UF, CYLINDER SLINGS AND LIFTING FIXTURES DF 2.2.5.1:

UF cylinder slings and lifting fixtures are designed with a stnictural factor of safety of 5 to 1 based upon the material's ultimate tensile strength.

SURVEILLANCE REQUIREMENTS:

Surveillance Frequency SR 2.2.5.1-1 Visual inspection for defects Prior to first use of shift SR 2.2.5.1-2 Hands-on Inspection (no disassembly required)

Monthly SR 2.2.5.1-3 Load test at a minimum of 100% of rated Biennially capacity.

BASIS:

Slings, H-frames, etc used to handle liquid filled UF cylinders are credited for prevention of the 6

liquid cylinder drop and rupture accident scenario. Visual inspection will detect obvious defects which could cause the cylinder drop accident scenario. Surveillance requirements 1 and 2 are performed to meet the requirements of OSHA 1910.184. [SAR Section 4.3.1.1.2]

2.2.5.2 CRANE DESIGN DF 2.2.5.2: The following aspects of the feed facility cranes are credited for safety:

20-ton overhead bridge crane Two hoist brakes that meet the requirements of ANSI B30.2,1990 Edition l

(including Addenda A,1991) l Geared up/down limit switch on cable d um

• Paddle-type limit switch to prevent blocking

• Crane travellimit switch protecting C-337-A Jet Station 2.2-31

i, -

SAR-PGDP PROPOSED March 10,1997 4

RAC 96C224 (RI)/97C006 1.7 ANSI /ANS 8.7 (N16.5), Guide for Nuclear Criticality Safety in the Storage of Fissile Material, 1975 Edition PGDP satisfies the requirements of this standard with the following exceptions / clarifications:

Section 4.2.6 - Fire protection systems are installed throughout the process buildings where flammable liquids are used in operating equipment Individual cell housings do not contain fire protection systems.

Section 5.1 - PGDP does not implement the unit mass limits described in this section.

Mass limits are defined in Nuclear Criticality Safety Approvals (NCSAs) and Nuclear Criticality Safety Evaluations (NCSEs).

For references to this staadard, see SAR Section 5.2.2.1.

I 1.8 ANSl/ANS 8.19, Administrative Practices for Nuclear Criticality Safety,1984 Edition PGDP satisfies the requirements of this standard.

For references to this standard, see SAR Section 5.2.2.1.

i 1.9 ANSI /ANS 8.20, American National Standard for Nuclear Criticality Safety Training,1991 Edition f

PGDP satisfies the requirements of this standard.

For references to this standard, see SAR Sections 6.6.5.2 and 6.6.6.1.

i

]

1.10 ANSI A17.1, Safety Codes for Elevators,1974 Edition i

PGDP satisfies only the following section of this standard as clarified below:

Section 1005.4 - The building C-360 hydraulic lifts (elevator and levelator) are designed and tested to the requirements of this section of the standard for direct-plunger type elevators.

For references to this standard, see the TSR Section 2.1.

1.11.-

ANSI B30.2, Overhead and Gantry Crane Design & Inspection,1990 Edition (including Addenda A,1991)

PGDP satisifies the requirements of the following sections of this standard for liquid UF.

handling and Feed Facility cranes:

l A-3

a..

' SAR-PGDP -

PROPOSED March 10,1997 RAC 96C224 (RI)/96C151 The components of this system are the 100 psig relief discs, PSE-506 and PSE-508, on the feed line, pressure i

I element PE-507, pressure transmitter PT-507, pressure switches PSH 507 and PSI 507, steam supply l

isolation valves PV-520, XV-524, and thermovent line block valve XV-565, and associated relays, solenoids, and switches. The pressure between the rupture discs is maintained between 9.5 and 19.5 psia.

i The autoclave opening prevention system is used to prevent the opening of an autoclave when the pressure exceeds 1.25 psig and gives a visual indication. System components are the pressure j

elements PE-514 and PE-515, pressure transmitters PT-514 and PT-515, pressure swiwhes PSL-514' l and PSL-515, and associated relays and switches.

3.2.6 UF Cylinder Handling UF, feed is delivered to the feed facilities and stored in an interim storage yard until a particular cylinder assay is needed for feed. Cylinders are weighed and checked against fill limits. Each cylinder is inspected externally for any damage prior to storing in the yard or placing in an autoclave for feed. All feed cylinders handled are normally :mpty or contain solid UF, and administrative controls prohibit the handling ofliquid UF, in these areas except in emergency conditions.

3.2.6.1 Cranes The C-333-A and C-337-A overhead bridge cranes handle only cylinders that are empty or contain l

solid UF6. The two cranes in C 333 A and the north crane in C-337-A are 20-ton single hook, pendant-l controlled crancs. The C-333-A west crane hoist has a direct current (de) rectified shoe brake and an eddy l

current brake. The (dc) rectified shoe brake is spring actuated in the event of a power loss. The C-333-A cast l

crane hoist and C-337-A north crane hoist utilize a (de) rectified shoe brake and a mechanical ratchet and pawl backup brake in the case of shoc brake failure. All of the feed facility crancs have a geared up/down limit switch designed to prevent exceeding the limits for lowering or hoisting the load. When activated, the limit switch circuit will stop the motor and actDate the shoe brake. To prevent the lifting hook from colliding with the upper cranc structure, each crane uses a swivel bar attached to wire hanging from a paddle-type limit switch on the crane trolley. When the hook comes in contact with the swivel bar, the tension in the wire is released and the crane hoist motor is de-energized. Each of these crancs uses an H-frame type lifting sling l

to lift the cylinder with its single hook.

l The south crane at C 337-A is a 20 ton double block, radio / pendant controlled crane with a lifting beam specially designed for UF6 cylinders. The crane hoist has two direct current (dc) shoc brakes and one eddy current brake. One hoist shoe brake is used as a holding brake, and the other shoe brake serves as an emergency brake. These brakes are spring actuated in the event of a power loss. A geared up/down limit switch is connected to the cable drum for use in lowering or hoisting the load. When activated, the geared limit switch circuit will stop the motor and activate the brakes. This switch will reset automatically once the motor is reversed. Each crane is equipped with two paddle-type limit switches that serve to prevent a lifting beam to upper cranc structure collision. Each paddle-type limit switch has a weight that hangs on a wire from the crane trolley. If the lifting beam comes in contact with one of these weights, the tension in'the wire is released and the crane hoist motor is de-energized.

l 3.2-10a

SAR-PGDP PROPOSED March 10,1997 RAC 96C224 (RI)

J j

3.2.6.2 Short-Term Storage Both facilities contain cylinder yards for the short-term storage of both full and empty cylinders. The yards are equipped with saddles that prevent the rolling of cylinders and subsequent damage that could result

' from improper spacing of cylinders. Storage yards are discussed in Section 3./.

1 1

\\

i 1

1 7

h a

J d

j 3.2-10b

- ~.. - - -..-.. --... -.. ~...

SAR-PGDP PROPOSED February 13, 1997 RhC 96C224 The carts in C-333A, C-337A, C-310, and C-315 are a new, low-profile design. The low-profile design will not allow a fall of greater than 2 in., so there is no need to rely on safety legs. The carts are made of stainless steel to reduce corrosion. Saddles are provided on the carts to prevent the cylinders from rolling. As in the older system, the carts are air operated and will brake upon the loss of air.

3.7.3.1.2 Cranes and Lifting Fixtures Nine different cranes can be used to move UF. filled cylinders. Of these nine, four cranes are l

designed to move solid and liquid UF filled cylinders and five to move solid UF. cylinders. One liquid l

6 UF handling crane is located at the product withdrawal facility at C-310, one at the tails withdrawal facility at C-315, and two liquid UF. handling cranes are located at the toll sample and transfer facility at C-360. The feed facilities in C-333-A and C-337-A have two cranes each for moving empty and solid UF. filled cylinders. The south C-337A crane is designed to lift liquid UF filled cylinders but is 6

currently used only for empty and solid UF. cylinders. The chemical operations facility in C-400 uses a semi-gantry crane to move solid UF. filled 10-ton product cylinders.

The product withdrawal area has one 20-ton overhead bridge crane which is used to move solid or liquid-filled cylinders from the scale cart to the storage area. The tails withdrawal facility has a similar 20-ton semi-gantry bridge crane. Each of these cranes is a double-block crane equipped with a special lifting beam, which is specifically designed for lifting liquid UF. filled cylinders.

.1 1

3.7-4a

7.

~

- SAR-PGQP PROPOSED March 10,1997 RAC 96C224 (RI)

. The C-310 and C-315 Product and Tails withdrawal facilities cylinder handling bridge cranes are designed with several safety features. Each crane hoist has two direct current (de) shoe brakes. One of the brakes is used as a holding brake, and the other is on a timer which acts within one second as an emergency brake should the holding brake fail. A geared up/down limit switch is connccted to the cable drum for use in lowering or hoisting the load. When activated, the limit switch circuit will stop the motor and activate the hoist shoe brake. This geared limit switch will reset automatically once the motor is reversed. Two paddle-type limit switches prevent a collision between the lifting beam and C "nper crane structure. Each paddle switch has a weight that hangs on a wire from the crane tre he lifting beam comes in contact with one of these weights, the tension in the wire is released, a.

.ane hoist motor is de-energized end the hoist holding brake is activated. Once activated the paddle-type limit 1

switches require a manual reset to resume crane operation. The C-310 product withdrawal facility crane has been installed with a zone control to prevent the crane from carrying a load into the piping associated with the C-310-A burp station. The C-310 and C-315 crancs are equipped with proximity sensors and mechanical rail stops located at the end of the bridge and trolley rails. These devices are designed to prevent the crane from running off the end of the track.

The Toll Transfer and Sampling Facility at C-360 has two functionally identical 20-ton overhead bridge cranes. One crane can serve the high-bay work area over the autoclaves; the other crane can serve the cylinder storage area on the east side of the building. By opening the building crane door, both cranes can enter or exit the building. During normal operations the two cranes are not used together on a single load. Each bridge crane is equipped with one 20-ton capacity polar trolley, controlled by push-button pendant or radio transmitter. Crane control can be interchanged from push-button pendant or radio transmitter. Operation of the trolley and hoist individually or simultaneously are alle, ed as needed for lifting a liquid UF6 filled cylinder.

Each C-360 crane hoist has one de rectified shoe brake and one electro-hydraulic mechanical caliper brake. Both are spring actuated in the event of a power loss. The hoist shoe brake is used as a holding brake, and the electro-hydraulic mechanical caliper brake serves as an emergency brake should the holding brake fail. If brake slippage, mechanical discontinuity or overspeed is detected, the electro-hydraulic mechanical caliper brake will engage and act as an emergency brake. A geared up/down limit switch is connected to the cable drum to prevent lowering or hoisting the load too far. When activated, the limit switch circuit will stop the motor and activate the hoist holding shoe brake Paddle-type limit switches prevent the lifting assembly from colliding with the upper crane structure. The limit switch assembly has a w@ that hangs on a wire from the crane trolley. If the lifting block comes in contact with this weight a tension in the wire is released and the crane hoist motor is de-energized.

Mechanical rail sups are located at the end of the bridge and trolley rails to prevent the crane from running off the end of its tracks.

The C-333-A and C-337-A overhead bridge cranes handle only cylinders that are empty or l

contain solid UF.. The two cranes in C-333-A and the north crane in C-337-A are 20-ton single-hook, pendant-controlled crenes. The C-333-A west crane hoist has a direct current (de) rectified shoe brake and an eddy current brake. The hoist shoe brake is spring actuated in the event of a power loss. The C-333-A east and C-337-A north crane hoists utilize a shoe brake with a ratchet and pawl backup in case of shoe brake failure. All of the feed facility crancs have a geared up/down limit switch connected to the cable drum for use in lowering or hoisting the load. When activated, the limit switch circuit will stop the motor and activate the shoe brake. To prevent the lifting hook from colliding with the upper crane structure, each crane uses a swivel bar attached to a wire hanging from a paddle-type limit switch on the crane trolley. When the lifting hook comes in contact with the swivel bar, the tension in the wire is l

3.7 5

. _ -. ~.. -. - -. ~.,..... ~.

_. ~

4.:

i i

SAR-PGDP PROPOSED March 10,1997 RAC %C224 (RI) released and the crane hoist motor is de-energized. Each of these cranes uses an H-frame-type sling to l

lift the cylinders with its single hook. The C-337-A south crane hoist utilizes two snoe brakes and an eddy current brake.

l 3.7-Sa

o.n SAR-PGDP PROPOSED March 10,1997 RAC 96C224 (RI)

Blank Page l

3.7-5b

i e

.e

,a SAR-PGDP PROPOSED March 10,1997 R'AC 96C224 (RI)

Boundary The system boundaries for the portable CAAS unit include:

1.

Gamma detector channel 2.

Cluster logic module 3.

Cluster housing 4.

Associated circuitry 5.

Local electric horn 6.

Backup battery for the cluster and horn 7.

Connecting cable to connect to the building system 3.15.1.1.7 C-333-A and C-337-A Overhead BrM?.e Cranes O Function The function ~of these cranes is to safely handle UF, cylinders over/near the autoclaves. These cranes handle only cylinders which are empty or contam solid UF.

6 See Section 3.2.6.1 and 3,7.3.1.2 for a description of this system.

Boundarv The system boundary includes:

J 1.

Crane structure and structural supports, the crane rails, the bridge, the mechanical rail stops at the end of the bridge, the trolley rails, the trolley, the reeving, the cable, lifting fixture (C-337A South) and the hooks (C-333A and C-337A North).

2.

Iloist brakes:

l C-333-A East and C-337-A North - One DC rectified shoe brake and one mechanical ratchet and l

pawl brake.

l C-333-A West - One DC rectified shoe brake and one eddy current brake.

C-337-A South - Two DC rectified shoe brakes 3.

Emergency stop button 4.

Geared up/down limit switch 3.15-7

8 SAR-PGDP PROPOSED March 10,1997 R'AC 96C224 (RI) 5.

Swivel bar/ paddle-type limit switch 6.

Relays for hoist brake control 7.

Automatic zone controls for C-337A crane, including the paddle switches and PLC.

1 i

1 3.15-7a

r S,AR-PODP PROPOSED March 10,1997 RAC 96C224 (RJ)

Blank Page 3.15-7b