ML20141A494
| ML20141A494 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 06/16/1997 |
| 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-97-0087, GDP-97-87, NUDOCS 9706230034 | |
| Download: ML20141A494 (13) | |
Text
United States
(
Enrichm:nt Corporation 2 Democracy Center 6903 Rockledge Drive Bethesda, MD 20817 Tel: (301)564-3200 Fax: (301) 564-3201 finitet! States flirichtiletit Corp)ratiott JAMES H. MILLER Dir (301) 564-3309 VICE PRESIDENT, PRODUCTION Fax: (301) 571-8279 June 16,1997 Dr. Carl J. Paperiello SERIAL: GDP 97-0087 Director, Office of Nuclear Material i
Safety and Safeguards Attention: Document Control Desk t
U.S. Nuclear Regulatory Commission i
l Washington, D.C. 20555-0001 l
Portsmouth Gascous Diffusion Plant (PORTS)
Docket No. 70-7002 Certificate Amendment Request-TSR Section 3.11.1 - Nuclear Criticality Safety Program j
Elements
Dear Dr. Paperiello:
l In accordance with 10 CFR 76.45, the United States Enrichment Corporation (USEC or l
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 Requirement (TSR) 3.11.1 to reflect the addition of a new fourth bullet that identifies the following Criticality Safety Program element, " Identification of SSCs and support systems
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necessary to meet the double contingency principle."
/p The need for a revision to TSR Section 3.11.1 was identified in SAR Section 3.9.10,
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Identification of Nuclear Criticality Safety SSCs. A list of nuclear criticality safety Structures, Systems and Component (SSCs) and the associated support systems required to meet double contingency has been developed and is included in the facility specific Q, AQ-NCS and AQ System Boundary Definition Manuals (referenced in SAR Section 3.8.2.1, Nuclear Criticality Safety SSCs).
Also, as required in SAR'Section 3.9.10, TSR 3.11.1 is being revised to state that the NCS program will address the identification of SSCs and support systems necessary to meet double contingency.
9706230034 970616 ~
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PDR ADOCK 07007002
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PDR C00043 Offices in Paducah. Kentucky Portsmouth. Ohio Washington, DC
Dr. Carl J,. Paperiello June 16,1997 GDP 97-0087 Page 2 to this letter provides a detailed description and justification for the proposed changes. is a copy of the revised TSR pages and associated SAR pages that remove the completed commitment and references where the list of SSCs for meeting double contingency can be located. contains the basis for USEC's determination that the proposed change associated with this certificate amendment request is not significant.
There are no commitments made in this letter. Any questions related to this subject should be directed to Ms. Lisamarie Jarriel at (301) 564-3247.
Sincerely,
,s Obal Jam /es H. Miller
'ce President, Production i
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Enclosures:
As Stated l
cc:
NRC Region III Office NRC Resident Inspector - PGDP NRC Resident Inspector - PORTS l
' NRC Project Manager - PORTS p
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OATH AND AFFIRMATION l
I, James H.' Miller, swear and affinn 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
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Nuclear Regulatory Commission this Certificate Amendment Request for the Portsmouth Gaseaus L
Diffusion Plant, that I am familiar with the contents thereof, and that the statements made and matters i
set forth therein are true and correct to the : :st of my knowledge, information, and belief.
ew d
,J mes H. Miller Subscribed to before me on this //
day of h/&
,1997.
X8nukuW6WAaNnu Notary Public i
EERN!CE R. LAWSON NOTARY PUBtlC STATE OF MARYLAND CertiReate filed in Mcc.;gemery County i
Commission Expires Auyst 1,1997 i
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GDP 97-0087 Page 1 of 1
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United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request j
Portsmouth Gaseous Diffusion Plant TSR Section 3.11.1 i
Detailed Description of Change SAR Section 3.9.10, Identification of Nuclear Criticality Safety SSCs, requires the development of a list now referenced in SAR Section 3.8.2.1 as being located in the facility specific Q, AQ-NCS and AQ System Boundary Def' ition Manuals, which identifies the SSCs and the associated support m
systems required to meet the double contingency principle. SAR Section 3.9.10 also requires the revision of TSR 3.11.1 to add a new Nuclear Criticality Safety (NCS) program element which states the following, " Identification of SSCs and support systems necessary to meet the double contingency principle". This added NCS program element which is inherent to the performance of Nuclear Criticality Safety Approvals and Nuclear Criticality Safety Evaluations will enhance Portsmouth's j
ability to ensure that essential SSCs to NCS are properly addressed by the plant's Quality and Configuration Management programs.
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GDP 97-0087 Page 1 of 2 l
Proposed Certificate Amendment Request Portsmouth Gaseous Diffusion Plant Letter GDP 97-0087 Removal / Insertion Instructions Remove Page Insert Page VOLUME 2 Section 3.8.2.1 Section 3.8.2.1 Pages 3.8-43/3.8-44 Pages 3.8-43/3.8-44 Section 3.9.10 Section 3.9.10 Pages 3.9-5/3.9-6 Pages 3.9-5/3.9-6 VOLUAIE 4 Section 3.11.1 Section 3.11.1 Pages 3.0-10/3.0-11 Pages 3.0-10/3.0-11
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SAR-PORTS April 15,1997 Rev. 8 3
- 5. Circuitry associated with the local alarm.
4 Note: This system is fail safe upon loss of the electrical support system.
2 3.8.1.8 X-700. X-710, X-720, X-760, and XT-847 Q Boundary Definitions i
3.8.1.8.1 Facility Criticality Accident Alann System l
0 Function The Criticality Accident Alarm System monitors the facilities for a nuclear criticality and alarms notifying personnel that immediate evacuation must occur. An electrical support system failure is backed up by rechargeable battery packs, which will support the system for a minimum of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, and the loss will result in a trouble alarm. The portion of this system which alarms notifying the general population outside the immediate vicinity is controlled as AQ under Section 3.8.2.23.
See Section 3.6.2 for a description of the system.
Boundary The Criticality Accident Alarm System boundary includes the following:
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- 1. Radiation detection cluster unit;
- 2. N Strombos horn; 2
- 3. N supply; 2
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Associated N piping and tubing; and 2
- 5. Circuitry associated with the local alarm.
l Note: This system is fail safe upon loss of the electrical support system.
j 8.1.9 Liquid UF Cylinder Q Boundary Definition l
3.8.1.9.1 UF Cylinders T
0 Function Cylinders utilized to contain UF. have been designed, built and tested to ANSI N14.1 (subject to the l
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clarifications in Chapter 1, Appendix A) and a prescribed minimum volume specified in USEC-651. This l
ensures safe containment of UF throughout the enrichment process, including transport, sampling, feeding, 6
filling, and storage and prevent a release of liquid UF.. The issue of fail safe is not applicable to this system.
3.8-43
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SAR-PORTS PROPOSED June 16,1997 l
RAC97X0096 (RO)
The IS and 2S cylinders are not included as Q due to their small size. These cylinders are classified AQ.
4 See Section 3.2.1 for a descrip'. ion of the system.
Boundary The UF cylinder boundary includes the following:
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- 1. Cylinder;
- 2. Cylinder valve; and
- 3. Cylinder plug Notes: a. The valve protector is AQ, see Section 3.8.2.20.
- b. No support systems are required.
3.8.2 AQ Boundary Definitions This section describes the AQ SSCs at PORTS. The AQ function and boundary of each of these SSCs are described in the following paragraphs.
3.8.2.1 Nuclear Criticality Safety SSCs AO Function These SSCs are those identified in NCSAs/NCSEs as required to meet the double contingency principle.
See Section 5.2.
Boundary 1
SSCs and the associated support systems required to meet the double contingency principle are maintained l
within the System Boundary Definition Manuals.
l 3.8.2.2 UF, Process Piping and Equipment AO Function UF process piping and equipment provides a containment boundary for UF during the enrichment 6
6 process.
3.8-44
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l SAR-PORTS PROPOSED June 16,1997 i
RAC 97X0096 (RO) 3.9.9 Design Modifications to Support Q and AQ Boundary Definitions l
As part of the SAR Upgrade activity, an engineering evaluation will be performed to assess the following i
issues to determine if modifications are necessary to place the plant in a fail safe configuration. if modifications are necessary, they will be initiated.
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l Currently the UF. pigtail heaters remain energized upon loss of plant air (reference Sections 3.8.1.1.4, 3.8.1.2.4 and 3.8.1.3.5).
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Currently valves located in the autoclave feed lines will fail as-is (reference Sections 3.8.1.4.4, 3.8.1.4.8,
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3.8.1.5.4 and 3.8.1.5.8).
4 Currently the daughter cylinder safety valves located between the cylinder and the pigtail at each autoclave will fail as-is on loss of air (reference Sections 3.8.1.6.4 and 3.8.1.6.8).
Currently the autoclave UF drain line valves will fail as-is on loss of electric or air (reference Sections 6
3.8.1.6.4 and 3.8.1.6.8).
j Currently the autoclave smoke detection systems do not fail to a trouble alarm (reference Section 3.8.1.6.4).
3.9.10 Identification of Nuclear Criticality Safety SSCs Section deleted.
l 3.9.11 UF, Smoke Detection Systems UF smoke detection systems (see Sections 3.8.1.2.3 and 3.8.1.3.4) in LAW and TAILS areas may not contain a sufficient number of Q smoke detectors necessary to provide adequate detector coverage. The j
associated OSR for these areas took credit for detectors that do not meet current QAP requirements for Q SSCs. As part of the SAR Upgrade activity, an engineering evaluation will be performed to assess detector coverage requirements fer these areas. This will determine if changes are necessary to improve Q detector coverage in these areas.
3.9.12 Top Purge Assay 1
As described in Section 3.7, the following Compliance Plan items are necessary to address top purge assay issues:
3.9-5
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SAR-PORTS July 26,19%
Rev.4 Additional scenarios will be developed and analyzed for unauthorized removal paths of.
material enriched above 9.99 wt % assay, and any necessary additional controls will be established and implemented to detect and deter unauthorized removal of this material from the cascade and from the X-326 facility.
Controls and procedures will be developed and implemented to detect and protect against i
l credible scenarios for unauthorized removal of significant quantities of SNM of moderate l
strategic significance.
Controls and monitoring activities will be developed and implemented to preclude and detect the presence of more than 50 kg "U contained in gaseous UF, enriched from 10.00 to 19.99 2
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wt %, within units X-25-7 and X-25-2, interconnecting piping, and the X-326 surge drums.
1 Additional controls and procedures will be developed and implemented to ensure that nuclear -
l criticality safety is addressed for all operating conditions.
Additional controls and monitoring activities will be developed and implemented to preclude l
and detect the presence of uranium enriched to > 9.99 wt % within the top purge cascade in quantities that would lead to exceeding Category III limits across all USEC-leased and certified i
spaces following completion of the HEU refeed program.
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TSR-PORTS PROPOSED-June 16,1997
- RAC 97X0096 (RO) l l
l SECTIQN 3.0 ADMINISTRATIVE CONTROLS Report, and Supplemental Environmental Information Related to Compliance f
Plan that are included in the certification application, l
d.
All proposed changes to the TSRs, the TSR basis statements, the Certificate of l
Compliance, or the Compliance Plan; l
e.
All proposed changes to the plant or the plant's operations, including tests and experiments, that require a written safety analysis in accordance with 10 CFR i
76.68.
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All nuclear criticality safety evaluations and approvals; g.
All proposed Requests for Enforcement Discretion;
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NRC-required event reports.
3.10.6 RECORDS Written records of PORC reviews shall be maintained. As a minimum, these records shall include:
a.
Results of the activities conducted under the provisions of TSR 3.10; 1
b.
Reconunended approval or disapproval of items considered under TSR 3.10.5;
)
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Determination of whether each item considered under TSR 3.10.5 requires prior NRC approval before implementation per 10 CFR 76.68 and 76.45.
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Minutes of PORC meetings, as approved by the chair or his/her designee.
e.
Appointments of PORC members and alternates.
3.11 NUCLEAR CRITICALITY SAFETY PROGRAM 3.11.1 A Criticality Safety Program shall be established, implemented, and maintained as described in the Safety Analysis Report and shall address the following elements:
Adherence with ANSI /ANS Standards Nuclear Criticality Safety Responsibilities Process Evaluation and Approval Identification of SSCs and support systems necessary to meet the double contingency principle.
Design Philosophy and Review Criticality Accident Alarm System Coverage Procedure Requirements 3.0-10
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GDP 97-0087 Page 1 of 3 r
United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request l
Portsmouth Gaseous Diffusion Plant j
TSR Section 3.11.1 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.
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- 1. No Sienificant Decrease in the Effectiveness of the Plant's Safety. Safeguards or Security Procrams The addition of a NCS program element to the TSR that involves SSCs and support systems required to meet double contingency 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 Sienificant Chance to Any Conditions to the Certificate of Compliance None of the Conditions to the Certificate of Compliance for Operation of Gaseous Diffusion Plants (GDP-2) specifically address the identification of SSCs and support systems necessary to meet the double i
contingency principle. Thus, the proposed change has no impact on any of the Conditions to the Certificate of Compliance.
- 3. N_o. Sienificant Chance to Any Condition of the Anoroved Compliance Plan The required action to revise TSR 3.11.1 to add the following, " Identification of SSCs and support systems necessary to meet the double contingency principle" is not addressed by the Compliance Plan nor to any coditions of the Compliance Plan. The revision of TSR 3.11.1 was contingent upon the preparation of the SSCs and support systems list necessary to meet the double contingency principle as noted in SAR Section 3.9.10 and as referred to in Compliance Plan issue 23, Plan Of Action And Schedule, item 2, second bullet. The Boundary Definition Manuals have been revised to include AQ-NCS items.
4.
No Sienificant Increase in the Probability of Occurrence or Conseauences of Previousiv Evaluated Accidents The revision of the TSR and the associated SAR Section 3.9.10 to add the NCS program element for the identification of SSCs and support systems necessary to meet the double contingency principle will not increase the probability of occurrence or consequences of any postulated accident currently identified in the SAR. The analysis of postulated accidents did not take credit for the double contingency principle but analyzed each event based on individual accident initiators and preventers, and the new NCS program element does no.t change any accident initiator or preventer.
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GDP 97-0087 4
Page 2 of 3 l
United States Enrichment Corporation (USEC)
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Proposed Certificate Amendment Request Portsmouth Gaseous Diffusion Plant TSR Section 3.11.1 Significance Determination
- 5. No New or Different Type of Accident The revision of TSR 3.11.1 to add another NCS program element will not create a new or different type of accident than those previously analyzed. This is due to the fact that the new NCS program element does not change or add any new accident initiator.
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6.
No Sienificant Reduction in Marcins of Safety Since there is no increase in the probability or consequence of a criticality as a result of the proposed change to the TSR, nor have there been any new accident initiators identified, there is no significant reduction in the margin of safety. The margin of safety will slightly increase due to the added emphasis on the SSCs and support systems necessary to meet the double contingency principle.
7.
No Sienificant Decrease in the Effectiveness of any Procrams or Plans Contained in the Certificate Anolication The addition of a NCS program element to the TSR that involves SSCs and support systems required to meet double contingency is not addressed in plant safety, safeguards or security programs. Therefore, the effectiveness of these programs is unaffected by these changes.
- 8. The proposed chances do not result in undue risk to 1) nublic health and safety. 2) common defense and security. and 3) the environment.
The addition of a NCS program element to the TSR that involves SSCs and support systems required to meet double contingency does not increase the probability or consequence of any previously analyzed accident. As such, this change does not represent an undue risk to public health and safety. This change due to its NCS programmatic nature will have no adverse impact on the environment or the common defense and security.
- 9. There is no chance in the types or sienificant increase in the amounts of any effluents that may be released offsite.
This change has no effect on the generation or disposition of effluents, therefore it does not change the types or amounts of effluents that may be released offsite.
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GDP 97-0087 Page 3 of 3 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Portsmouth Gaseous Diffusion Plant TSR Section 3.11.1 Significance Determination
- 10. There is no significant increase in individual or cumulative occupational radiation exnosure.
The revision of the TSR and the associated SAR Section 3.9.10 to add the NCS program element for the identification of SSCs and support systems necessary to meet the double contingency principle will not increase the probability of occurrence er consequences of any postulated accident currently identified in the SAR. Therefore, there is no significant increase in individual or cumulative occupational radiation
- exposure,
- 11. There is no significant construction impact.
This change does not involve a plant modification, therefore it will not impact construction.
- 12. There is no sienificant increase in the notential for radiolocical or chemical conseauences from nreviously analyzed accidents.
The revision of the TSR and the associated SAR Section to add the NCS program element for the identification of SSCs and support systems necessary to meet the double contingency principle will not increase the probability of occurrence or consequences of any postulated accident currently identified in the SAR. Therefore, there is no significant increase.in the potential for radiological or chemical consequences from previously analyzed accidents.