ML20137H658
| ML20137H658 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 03/31/1997 |
| 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-97-0044, GDP-97-44, NUDOCS 9704030011 | |
| Download: ML20137H658 (11) | |
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United States Enrichment Corporation
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2 Democracy Center 6903 Rockledge Dnve Bethesda. MD 20817 Tel. (301) S64-3200 Unital States Enrichtnent Coriw> ration JAMES H. MILLER Dir: (301) 564-3309 VicE PRESIDENT, PRODUCTION Fax: (301) 571-8279 March 31,1997 Dr. Carl J. Paperiello SERI AL: GDP 97-0044 Director, Office of Nuclear Material Safety and Safeguards Attention: Document Control Desk j
U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Paducah Gaseous Diffusion Plant (PGDP)
Docket No. 70-7001 Certificate Amendment Request - Changes to TSRs 2.1.4.4 and 2.3.4.8
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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 proposed certificate of compliance for the Paducah, Kentucky Gaseous Diffusion Plant (GDP). This certificate amendment request revises j
two TSR sections: (1) TSR 2.3.4.8, Fire Protection System-Building Sprinkler System and (2) TSR 2.1.4.4, Cylinder Scale Cart Movement Prevention System. The proposed changes are summarized below.
The change to TSR 2.3.4.8 would broaden the applicability statement from Modes 1 through 3 to "At all times" This change would ensure the applicability statement is entirely consistent with the SAR accident analysis. The current applicability statement could be interpreted erroneously to permit outage of the sprinkler system when the facility is outside of Modes 1 through 3.
The change to TSR 2.1.4.4 would correct an erroneous mention of the " withdrawal" cylinder's pigtailin Action Condition B. This Condition should refer to the " receiving" cylinder's pigtail. The mention of" withdrawal" rather than " receiving" is an obvious editorial error in this TSR.
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I 9704030011 970331 PDR ADOCK 07007001 Offices in Paducah, Kentucky Portsmouth. Ohio Washington. DC
m Dr. Carl J. Paperiello March 31,1997 GDP 97-0044 Page 2 to this letter provides a detailed description and justification for the proposed
. changes. Enclosure 2 is a copy of the revised TSR pages. Enclosure 3 contains the basis for USEC's determination that the proposed changes associated with this certificate amendment request are not significant.
Since this proposed certificate amendment request 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 Mark Smith at (301) 564-3244.
Sinc y,
es H. Miller ice President, Production
Enclosures:
As Stated cc:
NRC Region III Office NRC Resident Inspector - PGDP NRC Resident Inspector - PORTS Mr."Randall M. DeVault (DOE)
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OATH AND AFFIRMATION I, James H. Miller, swear and aflirm that I am Vice President, Production, of the United 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.
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James I iiller Subscribed to before me on this S/
day of 24tch,1997.
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$ +a w 'k b am n u Notary Public BERNICE R. LAWSON NOTARY PUBUC STATE OF MAkYLAND Certificate f;'ed in Montgomuy County Commisston Expires August 1,1997
GDP97-0044 Page 1 of 2 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Revised Applicability Statement for TSR 2.3.4.8 Correction of Condition B for TSR 2.1.4.4 Detailed Description of Changes Specific TSR Sections Affected TSR 2.3.4.8. Fire Protection System-Buildine Sprinkler System The Applicability portion of Technical Safety Requirement (TSR) Limiting Condition for Operation (LCO) 2.3.4.8 currently reads as follows:
" Modes: Product and tails withdrawal modes 1 through 3 except when the lube oil is valved off or removed from the equipment covered by a specific sprinkler system."
USEC proposes to replace the phrase " Modes: Product and tails withdrawal modes 1 through 3" with "At all times" so the Applicability statement will read:
"At all times except when the lube oil is valved off or removed from the equipment covered by a specific sprinkler system."
TSR 2.1.4.4. Cylinder Scale Cart Movement Prevention System Technical Safety Requirement LCO 2.1.4.4, Condition B, currently reads as follows:
" Scale cart movement prevention system key is discovered not hanging from the withdrawal cylinder's pigtail without entry into condition A."
USEC proposes to change Technical Safety Requirement LCO 2.1.4.4, Condition B, to read as follows:
" Scale cart movement prevention system key is discovered not hanging from the receiving cylinder's pigtail without entry into condition A."
Reasons for Change TSR 2.3.4.8. Fire Protection System-Buildina Sprinkler System The proposed change is intended to eliminate a potential misinterpretation of the current TSR.
GDP97-0044 Page 2 of 2 TSR 2.1.4.4. Cylinder Scale Cart Movement Prevention System The proposed change corrects an obvious error in the TSR and would reduce the potential for confusion.
Justifications for Change TSR 2.3.4.8. Fire Protection System-Buildinn Sprinkler System The boundary for dividing the enriclunent cascade systems located in C-310 from the withdrawal systems is defined to be at the suction of the Normetex pump. The TSRs were organized according to facility type with TSR section 2.4 covering the enrichment cascade facilities (which include C-331, C-333, C-335, C-337 and C-310 up to the Normetex pump suction) and TSR section 2.3 covering the withdrawal facilities (which, for C-310, begin at the Nonnetex pump suction and include all other equipment out to and including the drain stations.)
However, the fire protection systems were designed to cover entire buildings. This creates an administrative difficulty for Building C-310 because both enrichment cascade and withdrawal systems are contained in this building. It is not desirable to have duplicate TSR coverage in each of TSR sections 2.3 and 2.4.
The selected approach was to include all of the C-310 fire protection TSR requirements in section 2.3 of the TSR.
The applicability statement as written does not cover all of the operating conditions under which the fire protection system is required (as taken credit for in the SAR accident analysis.) The applicability statement indicates that the C-310 sprinkler is only required in withdrawal modes 1 through 3.
This is almost ahvays the case, since the plant is almost always withdrawing product. However, in the rare circumstance in which the plant is not withdrawing product, the SAR accident analysis (SAR Section 4.3.2.5.1) would still require sprinkler coverage for those cascade cells in C-310 that do not have lube oil valved off. The language of the TSR applicability statement would technically allow the sprinklers to be out of service. It was the intent of the accident analysis to require sprinkler coverage at all times except when the lube oil is valved off or removed from the equipment covered by a specific sprinkler system. The proposed change would ensure this intent is expressed clearly.
TSR 2.1.4.4. Cylinder Scale Cart Movement Prevention System Technical Safety Requirement LCO 2.1.4.4, Condition B, currently reads as follows:
" Scale cart movement prevention system key is discovered not hanging from withdrawal cylinder's pigtail without entry into condition A."
Reference to " withdrawal cylinder's pigtail" is an error. The TSR is for the C-360 Toll Transfer and Sampling Facility. The correct terminology should be "..the receiving cylinder's pigtail..."
The proposed change would correct this editorial error.
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GDP 97-0044 3 Pages Proposed Certificate Amendment Request Paducah Gaseous Diffusion Plant Letter GDP97-0044 Removal / Insertion Instructions Remove Pages Insert Pages VOLUME 4 Section 2.1 Section 2.1 Page 2.1-20 Page 2.1-20 Section 2.3 Section 2.3 Page 2.3-23 Page 2.3-23 1
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TSR-PGDP PRC) POSED March 31,1997 RAC96C216 1
SECTION 2.1 SPECIFIC TSRs FOR TOLL TRANSFER AND SAMPLING FACILITY (C-360) 2.1.4 GENERAL LIMITING CONDITIONS FOR OPERATION l
2.1.4.4 CYLINDER SCALE CART MOVEMENT PREVENTION SYSTEM l
l LCO 2.1.4.4: The cylinder scale cart movement prevention system shall be operable.
APPLICABILITY: Modes: 6B ACTIONS:
Condition Required Action Completion Time A.
Cylinder scale cart A.1 Verify that the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> movement prevention system's key is system inoperable.
hanging from the receiving cylinder's pigtail.
AND A.2 Tag out the air 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> connector on the supply for the scale cart motor.
NOTE: Current operating cycle may be completed.
B. Scale cart movement B.1.1 Tag out the air 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> prevention system key is connector on the air discovered not hanging from supply for the scale the receiving cylinder's pigtail cart motor.
l without entry into QR condition A.
B.1.2 Stop operations in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> mode 6B AND Purge and evacuate the receiving cylinder's pigtail, disconnect the pigtail, and hang the system's key on the pigtail.
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2.1-20
TSR-PGDP PROPOSED March 31,1997 RAC 96C234 SECTION 2.3 SPECIFIC TSRs FOR PRODUCT AND TAILS WITIIDRAWAL FACILITIES t
2.3.4 GENERAL LIMITING CONDITIONS FOR OPERATION 2.3.4.8 FIRE PROTECTION SYSTEM - BUILDING SPRINKLER SYSTEM LCO 2.3.4.8: The fire protection sprinkler systems in process buildings C-310 and C-315 (exclusions: the dry pipe sprinkler system in C-310 and the deluge system for the exterior transformer located adjacent to C-315) shall be operable.
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APPLICABILITY:
At all times except when the lube oil is valved off or removed from the I
equipment covered by a specific sprinkler system.
ACTIONS:
Condition Required Action Completion Time A. A control valve (i.e., shutoff A.1 Restore to the open 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> valve) in the feed main to the position.
j sprinkler system is not in the open position.
B.
Action item A not B.1 Conduct a fire patrol for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and every hour satisfactorily accomplished.
the affected area (s) of the thereafter, affected building (s).
AND B.2 Confirm at least one 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> HPFW hydrant adjacent to the affected building (s) is operable.
TSR 1.6.2.2(d) is not applicable.
C. The sprinkler system fails one C.1 Restore to oper:ble status.
2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or both functional tests. (See Basis for description of functional tests.)
D. Action item C not D.1 If a fire alarm fails to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and every hour satisfactorily accomplished.
sound in C-300 within 90 thereafter.
seconds after opening the inspectors test valve (ITV), conduct a fire patrol for the affected area (s).
AND D.2 If no water flows from 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> the ITV or main drain, confirm at least one HPFW hydrant adjacent to the affected building (s) is operable.
TSR 1.6.2.2(d) is not applicable.
2.3-23
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GDP97-0044 Page 1 of 3 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Revised Applicability Statement for TSR 2.3.4.8 Correction of Condition B for TSR 2.1.4.4 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 EfTectiveness of the Plant's Safety. Safeguards. or Security Programs.
TSR. s.4.8. Fire Protection System-Building Snrinkler System The proposed TSR change ensures operability requirements for the sprinkler system are consistent with the existing SAR accident analysis. This would not decrease the effectiveness of the plant's safety, safeguards, or security programs.
TSR 2.1.4.4. Cylinder Scale Cart Movement Prevention System The proposed correction to Condition B of TSR 2.1.4.4 is not addressed in plant safety, safeguards or security programs. Therefore, the effectiveness of these programs is unafrected by this change.
2.
No Significant Change to Any Conditions to the Certificate of Comoliance None of the Conditions to the Certificate of Compliance for Operation of Gaseous Diffusion Plants (GDP-1) specifically address operating modes for the C-310 fire protection system or required actions in TSR 2.1.4.4. Thus, the proposed changes have no impact on any of the Conditions to the Certificate of Compliance.
3.
No Significant Change to Any Condition of the Annroved Comnliance Plan The TSRs affected by the proposed changes are not addressed in the Compliance Plan.-
The proposed changes do not involve any commitment contained in the Compliance Plan and do not affect any Justification for Continued Operation contained in the Compliance Plan. Therefore, the changes do not present a significant change to any condition of the approved Ccmpliance Plea.
4.
No Significant Increase in the Probability of Occurrence or Conseauences of Previousiv Evaluated Accidents The proposed change to TSR 2.3.4.8 involves a change to the applicability statement for the C-310 fire protection system in order to be consistent with the SAR accident analysis.
The proposed change in TSR 2.1.4.4 corrects one word and does not change the intent of the TSR. None of the proposed changes would increase the probability of occurrence or consequence of an accident previously evaluated.
o GDP97-0044 Page 2 of 3 5.
No New or DifTerent Tyne of Accident The proposed change to TSR 2.3.4.8 involves a change to the applicability statement for the C-310 fire protection system in order to be consistent with the S AR accident analysis.
The proposed change in TSR 2.1.4.4 corrects one word and does not change the intent of the TSR. None of the proposed changes would increase the probability of occurrence or consequence of an accident previously evaluated.
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No Significant Reduction in Margins of Safety The proposed change to TSR 2.3.4.8 involves a change to the applicability statement for the C-310 fire protection system in order to be consistent with the SAR accident analysis.
The proposed change in TSR 2.1.4.4 corrects one word and does not change the intent of the TSR. The proposed changes would increase, not decrease the margins of safety by eliminating potential misunderstandings about TSR requirements.
7.
No Significant Decrease in the Effectiveness of any Programs or Plans Contained in the Certificate Annlication The proposed change to TSR 2.3.4.8 involves a change to the applicability statement for the C-310 fire protection system in order to be consistent with the SAR accident analysis.
The proposed change in TSR 2.1.4.4 corrects one word and does not change the intent of the TSR. None of the proposed changes decrease the effectiveness of any programs or plans contained in the Application.
8.
The Pronosed Changes do not Result in Undue Risk to D Public Health and Safety. 2)
Common Defense and Security. and 3) the Environment.
The proposed change to TSR 2.3.4.8 involves a change to the applicability statement for the C-310 fire protection system in order to be consistent with the SAR accident analysis.
The proposed change in TSR 2.1.4.4 corrects one word and does not change the intent of the TSR. The proposed changes only enhance safety and pose no undue risk to public health and safety, the common defense and security, and the environment.
9.
No Change in the Tynes or Significant Increase in the Amounts of Any Efiluents That May Be Released Offsite.
The proposed change to TSR 2.3.4.8 involves a change to the applicability statement for the C-310 fire protection system in order to be consistent with the SAR accident analysis.
The proposed change in TSR 2.1.4.4 corrects one word and does not change the intent of the TSR. None of the proposed changes affect efiluents.
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GDP97-0044 Page 3 of 3 10.
No Significant Increase in Individual or Cumulative Occuoational Radiation Exnosure.
The proposed change to TSR 2.3.4.8 involves a change to the applicability statement for the C-310 fire protection system in order to be consistent with the SAR accident analysis.
The proposed change in TSR 2.1.4.4 corrects one word and does not change the intent of I
the TSR. The changes do not relate to controls used to minimize occupational radiation exposures.
j 11.
No Significant Construction Impact.
None of the proposed TSR changes involve a plant modification. Therefore, there is no construction impact.
12.
No Significant Increase in the Potential For. or Radiolonical or Chemical Consecuences j
From. Previously Analyzed Accidents.
The proposed change to TSR 2.3.4.8 involves a change to the applicability statement for the C-310 fire protection system in order to be consistent with the SAR accident analysis.
The proposed change in TSR 2.1.4.4 corrects one word and does not change the intent of the TSR. None of the proposed changes would alter anything related to consequences of previously analyzed accidents.
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