ML20137K319
| ML20137K319 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 03/27/1997 |
| From: | Horn M NRC |
| To: | NRC |
| Shared Package | |
| ML20137K317 | List: |
| References | |
| TAC-L32013, NUDOCS 9704070008 | |
| Download: ML20137K319 (4) | |
Text
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+4 UNITED STATES s
j NUCLEAR REGULATORY COMMISSION 4"
WASHINGTON. D.C. 20665-0001 l
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March 27,.1997 DOCKET:
70-7001 CERTIFICATE HOLDER:
United States Enrichment Corporation Paducah Gaseous Diffusion Plant Paducah, KY
SUBJECT:
- COMPLIANCE EVALUATION REPORT: APPLICATION DATED FEBRUARY 14,1997, FEED FACILITIES CRANE DESIGN FEATURES BACKGROUND By letter dated February 14,1997, the United States Enrichment Corporation (USEC) requested an amendment to the certificate of compliance for the Paducah Gaseous Diffusion Plant (PGDP). The amendment request was resubmitted by letter dated February 25,1997, because the notary seal had expired prior to the date the Oath and Affirmation was executed. There was no change to the technical content. The request is to revise Technical Safety Requirement (TSR) 2.2.5.2, Crane Design, to correct a discrepancy between the field configuration and the design feature specified in the TSR.
By letter dated February 28,1997, the staff requested additional information. USEC responded to the request by letter dated March 10,1997.
1 As part of the request, USEC also asked to be granted enforcement discretion in the event i
the NRC could not issue the amendment prior to transition on March 3,1997. The Department of Energy had granted enforcement discretion that expired at midnight on l
i March 2,1997. The NRC assumed regulatory jurisdiction over the facility at 12:01 a.m.
on March 3,1997. The NRC issued a Notice of Enforcement Discretion (NOED) No.
GDP971 on February 28,1997. This allowed USEC to continue using the cranes until the NRC took final action on the amendment request. Without enforcement discretion, USEC would have needed to declare the cranes inoperable because the cranes did not meet the design feature specified in the TSR. Without use of the feed facility cranes, USEC would a
have needed to place the enrichment cascade into a recycle mode. Issuance of this amendment will terminate NOED No. GDP97-1.
DISCUSSlQN TSR 2.2.5.2 credits the feed facility cranes with having two DC rectified shoe brakes, Two of the cranes in the feed facilities (C 333A and C-337A) do not meet this l
requirement; the C-337A South crane does meet the requirement. The C-333A East and the C-337A North cranes have one DC rectified and one ratchet and pawl brake. The C-333A West crana has one DC rectified and one eddy current brake. The safety function of the brakes is to stop and hold or control the load. The safety function is unaffected by the design of the brake. These cranes are used to lift empty cylinders and cylinders f
containing solid uranium hexafluoride into and out of the autoclaves at the feed facilities.
The cylinders provide the feed material for operations.
9704070008 970327 PDR ADOCK 07007001 C
PDR 1
2 1
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The field configuration is the Department of Energy approved design. USEC failed to ensure that the TSR incorporated the approved as-built condition of the cranes when originally submitting the TSRs. Revising the TSR to reflect the correct configuration does not result in an unreviewed safety question or cause any impact to the public health and safety. Each crane does have two independent brake systems that meet the requirements 1
of ANSI B30.2-1990," Overhead and Gantry Cranes." The TSR is being revised to reflect the requirement that the feed facility cranes shall have two hoist brakes that meet the requirements of ANSI B30.2,'1990 Edition (including Addenda A,1991).
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The SAR has been revised to clearly describe the braking system for the cranes in the feed facilities. In the response to Question 1, USEC committed to several sections of ANSI l
B30.2-1990as being applicable to the feed facility handling cranes. However, USEC did not explain why the commitment was limited to specific portions of the standard as t
requested in the question. The issue of commitment to standards is part of a larger issue for the entire plant and is covered by Compliance Plan issue 45. Because the TSR modification covers only the hoist brakes and USEC has committed that the hoist brakes will meet the ANSI standard, the staff will defer resolution of the extent of the commitment to the standard. This issue will be considered as part of our review of USEC's January 31,1997, response to Compliance Plan issue 45. The section on brakes was not listed in the response to Question 1, however, the TSR clearly commits to the brake portion of ANSI B30.2-1990,therefore, the addition of the brake section to the list of commitments will also be addressed during the review of the Compliance Plan response.
The staff notes that in their letter, USEC has committed to taking a second look at the codes and standards to determine if any additional documents, different editions, or additional sections of documents should be applied to the GDPs.
ENVIRONMENTAL REVIEW issuance of an amendment to Certificate of Compliance GDP-1 to revise the TSR on crane design is subject to the categorical exclusion provided in 10 CFR 51.22(c)(19). Therefore, neither an environmental assessment nor an environmental impact statement is required for the proposed action.
l CONCLUSION The staff concludes that the TSR revision to rettect the actual configuration of the crane brakes will not adversely impact the safety of the facility. USEC has committed to meeting the requirements of ANSI B30.21990 for the crane hoist brake.i. The staff recommends that the revised TSR be approved.
The Region lil Inspection staff has no objection to this proposed action.
Princioal Contributor Merri Horn DISTRIBUTION: (Control No. o6os) TAC No. L32013 Docket 7o-7oot NRC Filo Center PuBUC Rtil Ko'Bnen, Rill NMSs r/f NMss Dir off. r/f FCss r/f FCoB sPB r/f GShear, Rlli
' 'See previous concurrence CP/ PROOFED / MARCH 27,1997 5
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DATE 3/20/97 3/la/97 3/2o/97 3/21/97 C=CMYR E = GOVER En ENCloslJRE N = No COPY OFFICIAL. RECORD COPY
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The field configuration is the Department of Energy approved design. USEC failed to ensure that the TSR incorporated the approved as-built condition of the cranes whe origirially submitting the TSRs. Revising the TSR to reflect the correct configuratip does not res' ult in an unreviewed safety question or cause any impact to the public h 10th and safety. Ehch crane does have 'wo independent brake systems that meet the r quirements t
of ANSI B30,2-1990, " Overhead and Gantry Cranes." The TSR is being rev' ed to reflect the requireme'n(that the feed facility cranes shall have two hoist brakes t t meet the requirements of NSI B30.2,1990 Edition (including Addenda A,1991 The SAR has been rev(sed to clearly describe the braking system fo the cranes in the fead facilities. In the respon to Question 1, USEC committed to sev al sections of ANSI B30.2-1990 as being app ' able to the feed facility handling cr es. However, USEC did not explain why the commit ent was limited to specific porti s of the standard as requested in the question. Th 'ssue of commitment to sta ards is pe.:t of a larger issue for the entire plant and is covere by Compliance Plan Iss
- 45. Because the TSR modification covers only the hoist i kes and USEC ha ommitted that the hoist brakes will meet the ANSI standard, the staf ill defer resol ion of the extent of the commitment to the standard. This issue ill be co idered as part of our review of USEC's January 31,1997, response to Coi plian Plan Issue 45. The section on brakes I
was not listed in the response to Question 1, ever, the TSR clearly commits to the brake portion of ANSI B30.2-1990, therefore e addition of the brake section to the list of commitments will also be addressed dur' g th review of the Compliance Plan response.
i The staff notes that in your letter, USEC as comrt ' ted to taking a second look at the codes and standards to determine if a9 additional d uments, different editions, or additional sections of documents should be applied to t e GDPs.
1 ENVIRONMENTAL REVIEW 7
/
Issuance of an amendmentjt' Certificate of Compliance GDP-13o revise the TSR on crane design is subject to the cjitegorical exclusion provided in 10 CFR31.22(c)(19). Therefore, neither an environmenft assessment nor an environmental impact tatement is required fos the proposed acti n.
l CONCLUSION The staff cortcludes that the TSR revision to reflect the actual configuration kthe crane brakes wifnot adversely impact the safety of the facility. USEC has committed to meetin[he requirements of ANSI B30.2-1990 for the crane huist brakes. The st'a f reco tnends that the revised TSR be approved.
T e Region lli inspection staff has no objection to this proposed action.
Princioal Contributor
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Merri Horn DISTRIBUTION: (Control No. 000s) TAC No. L32013 Docket 70-70o1 NRC File Center PUBLIC Rlli Ko'Bnen, Rlli NMss r/f NMss dir. ofc. r/f FCss r/f FCoB SPB r/f GShear, Riti i
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I The field configuration is the Department of Energy approved design. USEC failed to ensure that the TSR incorporated the approved as-built condition of the cranes whpn
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originally submitting the TSRs. Revising the TSR to reflect the correct configura 'on does not result in an unreviewed safety question or cause any impact to the public alth and safety. Each crane does have two independent brake systems that meet th9 requiiaments i
of ANSI B30.2-1990, " Overhead and Gentry Cranes." The TSR is being rpdised to reflect the requirement that the feed facility cranes shall have two hoist brakesJhat meet the requirements of ANSI B30.2,1990 Edition (including Addenda A,1991.
The SAR has been revised to clearly describe the braking system f the cranes in the feed facilities. In the response to Question 1, USEC committed to sev ral sections of ANSI B3C.2-1990 as being applicable to the feed facility handling cr es. However, USEC did not explain why the commitment was limited to specific porti ns of the standard as requested in the question. The issue of commitment to sta ards is part of a larger issue for the entire plant and is covered by Compliance Plan Iss
- 45. Because the TSR modification covers only the hoist brakes and USEC has ommitted that the hoist brakes will meet the ANSI standard, the staff will defer resolu on of the extent of the commitment to the standard. This issue will be conpdered as part of cur review of your January 31,1997, response to Compliance Plan iss'ue 45. The section on brak.es was not listed in the response to Question 1, however, tp[TSR clearly commits to the brake portion of ANSI B30.2-1990, therefore, the addition of the brake section to the list of commitments will also be addressed during JHe' review of the Compliance Plan response.
The staff notes that in your letter, USEC tyis committed to taking a second look at the codes and standards to determine if any4dditional documents, different editions, or additional sections of documents shoufd be applied to the GDPs.
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ENVIRONMENTAL REVIEW lssuance of an amendment to Certificate of Compliance GDP-1 to revise the TSR on crane design is subject to the cprdgorical exclusion provided in 10 CFR 51.22(c)(19).
Therefore, r:either an environmenta) assessment nor an environmental impact statement is required for the proposed actiorf.
CONC.LUSION The staff co udes that the TSR revision to reflect the actual configuration of the crane brakes wil[ dot adversely impact the safety of the facility. USEC has committed to meeting,the requirements of ANSI B30.2-1990 for the crane hoist brakes. The staff rec niends that the revised TSR be approved.
The Region ll1 Inspection staff has no objection to this proposed action.
Princioal Contributor Merri Horn DISTRIBUTION: (Control No, oSoS) TAC No. L32013 Docket 70 70o1 NRC File Center PUBLIC Alli Ko'Brien, Rill NMsS r/f NMSS dir ofc. r/t FCss r/f FCoB SPB r/f Gsheer, Riti Il I
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