ML20140F206
| ML20140F206 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 04/28/1997 |
| 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-97-0064, GDP-97-64, NUDOCS 9705020162 | |
| Download: ML20140F206 (9) | |
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Enrichment Corpor; tion 2 Democracy Center
~S 6903 Rockledge Drive Bethesda, MD 20817
.J Tel: (301)S64-3200 Fax: (301) 564-3201 Unitetl States Enriclinient Corimration JAMES H. MILLER Dir: (301)564-3309 VICE PRESIDENT, PRODUCTION Fax: (301) 571-8279 April 28,1997 Dr. Carl J. Paperiello SERIAL: GDP 97-0064 Director, Office of Nuclear Material Safety and Safeguards Attention: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Portsmouth Gaseous Diffusion Plant (PORTS)
Docket No. 70-7002 Certificate Amendment Request-Air Gap Design Feature
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 TSR Setion 2.6.4.2, Air Gaps, to correct a typographical error which involves the changing of the word " pressure" to " presence"
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Once corrected, the surveillance would read as follows: " Verify and document the presence of air gaps required by NCSAs".
The air gaps are used by design in the X-705 "B" Area for hard piping of water-to-process piping /Y connections and all drains to prevent back flow to geometrically unsafe systems. TSR Surveillance (SR) 2.6.4.2.1 supports the Air Gap Design Feature for the X-705 "B" Area drains and water-to-process connections. The intent of the surveillance is to verify that the air gaps are in place as specified by the applicable NCSAs.
9705020162 970428 PDR A30CK 07007002 l ll I.l 1.1.Ill.I!I.I I.I c
Offices in Paducah, Kentucky Portsmouth Ohio Washington, DC
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Dr. Carl J. Paperiello April 28,1997 GDP 97-0064 Page 2 j
Enclosure I to this letter provides a detailed description and justification for the proposed change.
l is a copy of the revised TSR page. Enclosure ~ 3 contains the basis for USEC's determination that the proposed change associated with this certificate amendment request is not significant.
j Since this proposed certificate amendment request is an enhancement to the Technical Safety Requirements and is not required to support continued operation, USEC requests NRC review and
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approval at your earliest convenience. The amendment should become efTective 30 days from issuance.
Any questions related to this subject should be directed to Mr. Mark Smith at (301) 564-3244.
Sincerely, A[
.N es H. Miller i
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ice President, Production 4
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Enclosures:
As Stated cc:
NRC Region III Office l
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NRC Resident Inspector-PGDP
- NRC Resident inspector - PORTS j-Mr. J. Dale Jackson (DOE) d i~
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OATil AND AFFIRMAllON I, James H. Miller, swear and affirm 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 i
- Regulatory Commission this Certificate Amendment Request for the Portsmouth Gaseous Diffusion
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. Plant, that I am familiar with the contents thereof, and that the statements made and matters set forth i
therein are true and correct to the best of my knowledge, information, and belief.
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James H. Miller i
i Subscribed to before me on this 8 day of M
,1997.
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Notary Public BERNICE R. LAWSON NOTARY PUBUC STATE OF MARYLAND
.l Certificata 1.'od in Mor.tgomery Couny Commhston Expires Augud I,1997 l
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GDP97-0064 Page1 of1 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Air Gap Design Feature Detailed Description of Change This proposed change involves the changing of TSR Surveillance (SR) 2.6.4.2.1 from " Verify and document the pressure of air gaps required by NCSAs" to " Verify and document the presence of air gaps required by NCSAs" to correct a typographical error which resulted in the use of " pressure" instead of " presence". The air gaps are used by design in the X-705 "B" Area for hard piping of water-to-process piping connections and all drains to prevent back flow to geometrically unsafe systems. TSR Surveillance (SR) 2.6.4.2.1, supports the Air Gap Design Feature for the X-705 "B" Area drains and water-to-process connections. The intent of the surveillance is to verify that the air gaps are in place as specified by the applicable NCSAs. While it is theoretically possible to measure the pressure of an air gap, i.e. atmospheric pressure, it is sufficient to visually denote that there is an
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air gap between two pipes or a pipe and a drain to satisfy the NCSA requirements. The air gaps in the X-705 "B" Area are accessible such that the existence of the air gaps can be visually ascertained.
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GDP97-0064 Page 1 of 2 Proposed Certificate Amendment Request Portsmouth Gaseous Diffusion Plant j
Letter GDP97-0064 Removal / Insertion Instructions Remove Page Insert Page VOLUME 4 Section 2.6.4.2 Section 2.6.4.2 Page 2.6-18 Page 2.6-18 l
TSR-PORTS PROPOSED April 28,1997 RAC 97X0140 (RO)
SECTION 2.6 SPECIFIC TSRs FOR X-705 DECONTAMINATION FACILITY 2.6.4 GENERAL DESIGN FEATURES 2.6.4.1 IIandtable Overflows DF:
IIandtables shall have a s 1.5 inch high overflow.
SURVEILLANCE:
Frequency Surveillance Annually SR 2.6.4.1.1 Verify that s 1.5 inch high overflow is not obstructed and that a 5 inch overflow receiving coatainer is used BASIS:
Potential solution criticality from an " unsafe" slab thickness in a handtable is prevented by overflow drains [SAR Sections 3.3.1.3.2.7 & 4.3.1.2.2.1].
2.6.4.2 Air Gaps DF:
Air gaps shall be installed at all "B" area drains and water-to-process connections that connect to geometrically unsafe systems as required by a NCSA SURVEILLANCE:
Frequency Surveillance Annually SR 2.6.4.2.1 Verify and document the presence of air l
gaps required by NCSAs.
BASIS:
Air gaps are used by design for piping to drains to prevent back. flow to geometrically unsafe systems j
[SAR Section 4.3.1.3.3]
2.6-18
GDP97-0064 Page 1 of 3 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request l
Air Gap Design Feature Significance Determination i
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 Significant Decrease in the Effectiveness of the Plant's Safety. Safecuards or Security Programs The correction of a typographical error by changing of the word " pressure" to " presence" for an air gap design feature is not addressed in plant safety, safeguards or security programs contained in Volume 3 of the Application for United States Nuclear Regulatory Commission Certification for the Portsmouth Gaseous Diffusion Plant. Therefore, the effectiveness of these programs is unaffected by these changes.
- 2. No Si_nnificant Channe to An.y Conditions to the Certificate of Comoliance None of the Conditions to the Certificate of Compliance for Operation of Gaseous Diffusion Plants (GDP-2) specifically address design features or their related surveillances. Thus, the proposed change has no impact on any of the Conditions to the Certificate of Compliance.
- 3. No Significant Change to Any Condition of the Aoproved Compliance Plan The required action to revise TSR 2.6.4.2.1 to correct a typograpMeal error is not addressed by the Compliance Plan nor in any conditions of the Compliance Plan.
- 4. No Significant Increase in the Probability of Occurrence or Conseauences of Previousiv Evaluated Accidents The revision of TSR surveillance 2.6.4.2.1 to correct a typographical error will not increase the probability of occurrence or consequences of any postulated accident currently identified in the SAR. In either case, verifying the air pressure or verifying the presence of an air gap ensures that the air gaps referred to in the design feature will remain in place and therefore satisfy the assumptions made in the accident analysis.
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GDP97-0064 Page 2 of 3 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Air Gap Design Feature Significance Determination
- 5. No New or Different Tyne of Accident The revision of TSR 2.6.4.2.1 to correct a typographical error will not create a new or different type of accident than those previously analyzed. The word change will not add any new accident initiator since the requirement to verify the air gaps will remain in the TSR.
- 6. No Signi6 cant Reduction in Margins of Safety The requirement to verify the presence of air gaps to prevent backflow to geometrically unsafe systems will not be changed as a result of this TSR revision. The air gaps will still be verified as required by TSR 2.6.4.2.1. Therefore, this change will not reduce the margin of safety associated with this TSR.
- 7. No Significant Decrease in the Effectiveness of any Programs or Plans Contained in the Certificate Apolication The air gap design feature is not addressed in plant safety, safeguards or security programs.
Therefore, the correction of a typographical error by changing of the word " pressure" to
" presence" will not decrease the effectiveness of these programs.
- 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.
The correction of a typographical error by changing of the word " pressure" to " presence" for an air gap design feature does not increase the probability or consequence of any previously analyzed accident. In addition, criticality accidents for which this design feature is intended to prevent are local events. This change has no impact on plant effluents or on the programs and plans in place to implement physical security. As such, this change does not represent an undue risk to public health and safety. Therefore, this change will have no adverse impact on the environment or the common defense and security.
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i GDP97-0064 Page 3 of 3 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request
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Air Gap Design Feature Significance Determination 1
- 9. There is No Change in the Tynes or Significant Incrence in the Amountc of any Effluents that May be Relenced Offsite.
I This change has no effect on the generation or disposition of effluents, therefore, it does not change i
the types or amounts of effluents that may be released offsite.
- 10. There is No Significant Increase in Individuni or Cumulative Occunational Radiation Exnosure.
The revision of TSR 2.6.4.2.1 to correct a typographical error will not increase the probability of occurrence or consequences of any postulated accident currently identified in the SAR. This change does not relate to controls used to minimize occupational radiation exposure. Therefore, there is no significant increase in individual or cumulative occupational radiation exposure.
i l1. There is No Significant Construction Imnact.
i This change does not involve a plant modification, therefore it will not impact construction.
- 12. There is no Significant Incrence in the Potentini for Radiological or Chemical Conseauences from Previously Analyzed Accidents.
The revision of TSR 2.6.4.2.1 will not increase the probability of occurrence or consequences of any postulated accident currently identified in the SAR. Verifying the air gap requirement remains in place to ensure the assumptions used in the accident analysis are satisfied. Therefore, there is no significant increase in the potential for radiological or chemical consequences from previously analyzed accidents.
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