ML20141A846
| ML20141A846 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 05/06/1997 |
| 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-97-0041, GDP-97-41, NUDOCS 9705150028 | |
| Download: ML20141A846 (15) | |
Text
United Sta2s Enrichment Corpor: tion 2 Democracy Center 6903 Rockledge Drive nothestia, MD 20817 A~
Tel (301) 564 3200 Fax:(301) 564 3201 United at er*
Enrichtlictit Corlweratiott JAMES H. MILLER Dir; (301) 564-3309 Vice PRESIDENT, PRODUCTION Fax: (301) 671-8279 May 6,1997 Dr. Carl J. Paperiello SERIAL: GDP 97-0041 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 (POllTS)
Docket No. 70-7002 Certificate Amendment itequest-Deletion of Seal Exhaust Pump Overflows in llulldings X-330 and X-333
Dear Dr. Paperiello:
In accordance with 10 CFR 76.45, the United States Enrichment Corporation (USEC or Corporation) hereby submits a request ibr amendment to the proposed certificate of compliance for the Portsmouth Gaseous Diffusion Plant. This certificate amendment request deletes Section 2.2.4.1, Seal Exhaust Pump Overflows, as a required design feature for Buildings X-330 and X-333. Updated analyses have shown that the overflows are not needed to prevent accidental criticalities associated with the accumulation of potentially uranium-laden oil in the seal exhaust pumps. These updated analyses were performed based 1
on test data relating UF and oil concentrations to provide maximum 11/U ratios representing actual
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1 process conditions. Previous nuclear criticality safety (NCS) requirements were based on standard minimum critical volumes (with a safety factor incorporated) lbr different enrichments. These updated analyses resulted in calculated suberitical volumes that were greater than the minimum volumes previously used. In addition, capacity tests of the seal exhaust pump oil reservoirs have been performed to ensure that the maximum oil m tume of the reservoir is less than the quantity required to support a criticality.
uo0M jj jj! plll l'; j ij 9705150020 970506 PDR ADOCK 07007002 C
PDR Offices irt Paducah, Kentucky Portsrnouth, Ohio Washington. DC
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L L Dr. Carl J. Paperiello :
' May 6,1997-GDP 97-0041 Page 2 Enclosure I to this letter provides a_ detailed description and justification for the proposed changes.
l is a copy of the revised TSR and SAR pages. The TSR page is provided for your review andj 9
approval. The revised SAR pages have been evaluated in accordance with 10 CFR 76.68. Based on the l
results of the 10 CFR 76.68 evaluation, the enclosed SAR pages do not require prior NRC review and l
approval and are provided for information only. These revised SAR pages reflect revisions associated
'j with this certificate amendment request and may not reflect other changes to these SAR pages. Enclosure j
I 3 contains the basis for USEC's determination that the proposed changes associated with this certificate amendment request are not significant.
This proposed certificate amendment request is required to allow installation of replacement seal exhaust pumps in the X-330 and X-333 facilities to support continued operation. As such, USEC requests this certificate amendment request receive the highest priority and that NRC review and approval of this certificate amendment request occur as soon as possible. The amendment should become effective no later than 15 days from issuance.
Any questions related to this subject should be directed to Mark Smith at (301) 564-3244.
Sincerely, es II. Miller ice President, Production
Enclosures:
As Stated cc:
NRC Region 111 Office NRC Resident Inspecter-PGDP NRC Resident inspeetor-PORTS
- DOE Regulatory Oversight Manager
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- OATH AND AFFIRMATION.
l I, James H. Miller, swear and affirm that I am Vice President, Production, of the United i
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. States Enrichnsent Corporation (USEC), that I am authorized by USEC to sign and file with the
- Nuclear Regulatory Commission this Certificate Amendment Request for the Portsmouth 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.
James H. Miller g-U Subscribed to before me on this d
dayof 22/#
,1997.
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- M Notary Public tERNKI R, LAWSON NOTARY PUOUC 5IATE OF MARY 1AND
- Cerlificate IJad in Montgomery County Cornminalon Expires August 1,1997 U
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GDP97-0041 Page 1 of 2 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Deletion of the Seal Exhaust Pump Overflows in Buildings X-330 and X-333 Detailed Description of Change Specific TSR Section AfTected The proposed change would delete TSR Section 2.2.4.1, " Seal Exhaust Pump Overflows", as a required design feature in Buildings X-330 and X-333.
Reason for Change Oil limiting overflows are no longer required by Nuclear Criticality Safety documentation. The proposed TSR change would permit the plant to replace currently installed seal exhaust pumps without the burden ofinstalling oil limiting overflows which are no longer required.
Justification of the Change The change will reflect the fact that oil level overflows are no longer required for Seal Exhaust Pumps in Cascade Seal Exhaust Stations located in the X-333 Building Area 1 and the X-330 Building Areas 2 and 3.
When the TSR was originally established, oil limiting overflows were determined to be necessary to prevent the potential buildup of an unsafe uranium mass in the seal exhaust pump oil by limiting the volume of oil available to contain uranium. Recently completed Nuclear Criticality Safety Evaluations / Approvals (NCSF/As) now show much larger volumes of oil are needed to support a criticality. These updated analyses were performed based on test data relating UF and oil 4
concentrations to provide maximum II/U ratios representing actual process conditions. Previous nuclear criticality safety (NCS) requirements were based on standard minimum critical volumes (with a safety factor incorporated) for difTerent enrichments. These updated analyses resulted in calculated subcritical volumes that were greater than the minimum volumes previously used. In addition, capacity tests of the seal exhaust pump oil reservoirs have been performed to ensure that l
the maximum oil volume of the reservoir is less than the quantity required to support a criticality.
In addition, Engineering tests discussed below, which involved verifying the actual oil capacity of the seal exhaust pumps by physically filling the oil reservoir, have shown the maximum volume of oil contained in the seal exhaust pumps is limited by the physical capacity of the pumps to quantities less than that needed for an accidental criticality to occur. Therefore, the physical capacity of the pumps is sufliciently small to ensure nuclear criticality safety is maintained, without dependence on j
oil limiting overflows.
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GDP97-0041 Page 2 0f 2 The NCSE/A for the Area 1 Seal Exhaust and Wet Air Evacuation System, and the NCSE/A for Area 2 Seal Exhaust and Wet Air Evacuation System limit the volume of oil to 27 gallons. Pump capacity tests involving the KT-300c Kinney oil pump and the KD-300 Kinney oil pump indicate that the seal exhaust pumps in Areas 1 and 2 have volumes less than 27 gallons.
The NCSE/A for Area 3 Seal Exhaust and Wet Air Evacuation System limits the pump oil capacity to 9.2 gallons. Pump capacity tests involving Area 3 Stokes vacuum pump and Area 3 Kinney vacuum pump indicate that the installed pumps have volumes less than 9.2 gallons. In addition, this NCSE/A also evaluates use of the Kinney 50-cfm seal exhaust pump in Area 3. SAR Table 3.1.1.6-1 has been revised to reflect use of this pump in Area 3.
Based upon the new NCSE/As and the engineering capacity tests, the nuclear criticality safety control which required volume limiting oil overflows has been determined to be unnecessary.
Therefore, Technical Safety Requirement 2.2.4.1 is no longer needed.
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l GDP97-0041 Page1of5 i
Proposed Certificate Amendment Request Portsmouth Gaseous Diffusion Plant Letter GDPa7-0041 Removal / Insertion Instructions Remove Pages Insert Pages VOLUME 1 Section 3.1.1.6.1.1 Section 3.1.1.6.1.1 Page 3.1 61/3.1-62 Page 3.1-61/3.1-62 Table 3.1.1.6-1 Table 3.1.1.6-1 Page 3.1-171/3.1-172 Page 3.1-171/3.1-172 VOLUME 4 Table of Contents Table of Contents vi vi i
TSR 2.2.4.1 TSR 2.2.4.1 Page 2.2-33 Page 2.2-33 I
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SAR-PORTS PROPOSED May 6,1997 RAC 96X0090 Seal exhaust systems in each area are not designed to be geometrically safe for moderation conditions at all possible enrichments. In order to maintain an always-safe condition, the amount of oil prescribed for these pumps is not to be exceeded. An oil overflow line is required for the seal exhaust pumps in Cascade Areas 4,5, and 6. The seal exhaust pumps in X-333 Building and Cascade Area 2 shall have a maximum oil capacity less than or equal to 27 gallons. In Cascade Area 3 the seal exhaust pumps shall have a maximum oil capacity less than or equal to 9.2 gallons.
In case of area seal exhaust system failure, the following actions may be taken to maintain the affected system:
Start up wet air pumps.
Open boundary block valve and use adjacent area's seal exhaust station. (This does not apply to Area 1.) Also, Area 2 seal exhaust should not be used for Area 3.
Return the seal exhaust gas to the cascade. (This would be a last resort because of the possibility of wet air being present in the seal exhaust gases and would result in barrier plugging).
The seal exhaust gases in the X-326, X-330, and X-333 are sampled prior to the alumina traps for PG negative as required by procedures, or as requested.
The atmospheric vents are also sampled. All seal exhaust and wet air discharge vents, except for LAW and ACR-3 wet air station, have a continuous monitoring sampler. These units are isokinetic, proportional flow samplers that collect the uranium isotopes, technetium, and fluoride content of the gas stream using alumina traps. The trap contents are analyzed periodically, thus providing emission data for environmental reporting and uranium accountability purposes.
3.1.1.6.1.2 Change-Out of Contaminated Alumina The changeout of contaminated alumina is performed by Chemical Operations personnel when requested by Cascade Operations. Special precautions are required when handling alumina saturated with enriched uranium. The activated alumina, used in all seal exhaust and wet-air stations in the process buildings, is exposed to enriched UF.. Therefore, when this alumina becomes saturated and needs to be i
exchanged for fresh alumina, special precautions are required. The alumina is vacuumed from the geometrically safe trap into a geometrically safe can. These cans, when filled with alumina, are handled one at a time. While one can is in motion in an area, no other containers of uranium material should enter or be moved in the immediate area.
3.1.1.6.1.3 Dandling of oil from Seal Ihhaust Pumns j
Flushing and cleaning of the seal exhaust pumps is performed by Maintenance in accordance i
with plant procedures er as requested by Cascade Operations. llandling of the oils from Area 2 and above requires strict nuclear criticality control.
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f SAR-PORTS September 15,1995 Rev.1 Oil, being a good moderating material, must be handled in a nuclearly safe manner when uranium may be present in it. It is possible that the oil in the seal exhaust pumps may contain high concentrations of uranium. Therefore, when oil is drained from the seal exhaust pumps, it is placed in 5-inch polybottles. The filled polybottles are stored upright in approved holders. Handling of oil from seal exhaust pumps is discussed in detail in Section 3.1.2, Purge Cascade.
3.1.1.6.2 Datum Systems Because of the sensitivity of barrier and compressor performance to the cascade pressure level, it is desirable to maintain the operating pressures within i0.01 psi of a specified value. Pressures must therefore be sensed by instmments which have as their reference pressure either a full vacuum or a carefully controlled pressure. For low process pressures, the vacuum reference is adequate, since the range of the instrument will not have to be so large as to make it insensitive to pressure variations of the order of 0.01 psi. For most cascade pressure, however, it is necessary to supply a well-controlled datum pressure, which is fairly close to the pressure level being measured, to the instruments. Narrow-range differential pressure instruments, which have the needed sensitivity, are used.
The datum system consists of a volume of dry air, which can be fed and exhausted through pressure control instruments as required, to maintain a given pressure level controlled to i0.005 psi.
A given datum system usually services a plant unit or half unit in the isotopic cascade; except in the purge cascades where the pressures within a cell taper too rapidly. Since all of the unit pressure transmitters and controllers are referenced to the same datum system, a shift in datum pressure will produce a movement of the cascade inventory within the unit. This technique can be used when inventory shifts or new operating conditions are desired.
3.1.1.6.2.1 High Datum The high datum system is the primary pressure reference for stage control in cascade operations.
Each unit has one or more high datum systems (see Figure 3.1.1.6-4). In the X-333 Process Building, the freezer /sublimers have their own high datum system, which can be used in place of the building system, for half a unit's cells.
A pressure blind transmitter (PBM 228) with an evacuated case, senses the high-datum system pressure and converts it to a 3 to 18 psi signal pressure, which is transmitted to a PIC. The PIC, in turn, controls a device called an inverting Booster Relay. The IBR receives filtered dry instrument air which it balances with datum exhaust (datum vacuum system), to regulate the high-datum system pressure. To compensate for short-term fluctuations in pressure, a two-cubic-foot-capacity surge drum is installed in the system side of the IBR. From the surge drum the system is connected to the unit (X-330 and X-333) or half unit (X-326) high-datum headers through a pneumatic block valve.
The pneumatic block valve (CV 232) in the high datum system is part of an emergency system to protect the high datum systems in case of component failures. CV 232 is spring-loaded to close and requires air pressure to open. The valve is controlled by a three-way solenoid valve, which operates to vent the air from the pneumatic valve, allowing it to close.
3.1-62
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SAR-PORTS September 15, 1995 Rev.1 TABLE 3.1.1.51 FLOWS AND PRESSURES IN INTERBUILDING PIPING AT 2260-MW POMT.R LEVEL FEED AND UF.
WITHDRAWAL UF.
FLOW RATE RATES PRESSURES TEMP LINE DESIGNATION (Ib-mole /hr.)
(Kr U/Dav)
Igigl
{'E A. 33-8 to 313 1547 2.3 to 18.0 210 B. 313 to 33-8 1547 (Range for A&B Lines) 210 A. 31-2 to 331 1480 2.1 to 19.0 210 B. 33-1 to 31-2 1480 (Range for A&B Lines) 210 A. 29-6 to 271 194 0.6 to 3.7 200 B. 27-1 to 29 6 194 (Range for A&B Lines) 200 Tails Withdrawal 25.201 ERP/ LAW 6,197 Feed (Normat) 22.278 (Paducah) 9,120 1
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3.1-171
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t SAR-PORTS PROPOSED May 6,1997 l
_ RAC %X0090 i
TABLE 3.1.1.61 SEAL EXHAUST PUMP SIZES MAXIMUM SIZE OF
' AMOUNT OF AMOUNT OF ALUMINA -
ACTIVATED SAFE i
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NOMINAL OIL TRAP ALUMINA
. ASSAY AREA
_ SIZE OF PUMP (gal)
(in)
(Ib)
(%)
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Kinney 300-cfm 27 24 165 3.0 l
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Wet Air Traps 24 165 3.0
. LAW Kinney 100<fm 2.5 5
28 10 2
Kinney 300-cfm 27 10 75 5
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3 Stokes 100-cfm 9.2 5
28 15 l
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Kinney 50-cfm 9.2 5
28 15 l
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Kinney 100-cfm 1.125 5
28 100 j
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Kinney 100-cfm 1.125 5
28 100 6
Kinney 100-cfm 1.125 5
28 100 1
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l SAR PORTS PROPOSED May 6,1997
. RAC96X0090 CONTENTS (Continued) 2.1.3.5 Autoclave Shell High Pressure Containment Shutdown...... 2.1-11 2.1.3.6 Autoclave Shell High Pressure Relief System............. 2.1-13 2.1.3.7-High Condensate Level Shutoff...................... 2.1-15 2.1.3.8 Cylinder Heating............................... 2.1 -16 2.1.3.9 Low Cylinder Pressure Shutoff..................... 2.1-18 2.1.3.10 Cylinder Assay Limitation
. 2.1-19 2.1.3.11 Autoclave Smoke Detection System......
2.1-20 2.1.3.12 Liquid UF. Handling Cranes...............
.... 2.1-21 2.1.3.13 Pigtail Line Isolation....................
.... 2.1-23 2.1.3.14 Liquid UF Movement.....
. 2.1-24 2.1.3.15 Receiving Cylinder Fill Weights..........
....... 2.1-25 2.1.3.16 UF. Cylinder Crane Movement..................... 2.1 -2 8 2.1.3.17 UF. Cylinder We!ght Discrepancy................... 2.1 -29 2.1.3.18 UF. Plugs.............
............. 2.1 -30 2.1.4 GENERAL DESIGN FEATURES..............
. 2.1-31 2.1.4.1 UF. Cylinder Lifting Fixtures.......
.......... 2.1 -31 2.1.4.2 UF. Cylinders........
. 2.1-31 2.1.4.3 UF. Cylinder Pigtails.......
.... 2.1-32 2.1.4.4 X-342 Condensate Sump and Oil Interceptor.
2.1-32 2.1.4.5 Autoclave Shell..............,...
.... 2.1-33 2.1.4.6 Overhead Crane Capacity.........
. 2.1-33 2.2 SPECIFIC TSRs FOR X-330 AND X-333 CASCADE FACILITIES.....
2.2-1 2.2.1 X-330/X-333 CASCADE OPERATIONAL MODES 2.2-2 2.2.2 SAFETY LIMITS.
2.2-3 2.2.3 LIMITING CONTROL SETTINGS, LIMITING CONDITIONS FOR OPERATION, SURVEILLANCES..........
2.2-4 2.2.3.1 Coolant High Pressure Relief System....
2.2-4 2.2.3.2 Criticality Accident (Radiation) Alarm System 2.2-6 2.2.3.3 CADP UF. Smoke Detection System..
2.2-8 2.2.3.4 High Pressure Fire Water System 2.2-9 2.2.3.5 Coolant Removal...........
... 2.2-12 2.2.3.6 Cell Treatment Monitoring..
. 2.2-13 2.2.3.7 Cell Inverse Recycle Treatment...
... 2.2-14 2.2.3.8 Seal Exhaust Station Enrichment....
. 2.2-15 2.2.3.9 Evacuation Booster Station (EBS) Enrichment 2.2-17 2.2.3.10 Crane Movement of Cascade Equipment
... 2.2-19 2.2.3.11 Evacuation Booster Station Oxidant Limit
. 2.2-20 2.2.3.12 UF. Plugs..................
... 2.2-21 2.2.3.13 Cascade Pressure Limitation....
... 2.2-22 2.2.3.14 Cascade DC Control Power 2.2-24 2.2.3.15 Moderation Control...........
. 2.2-27 2.2.3.16 Removed Equipment with Deposits.................. 2.2-31 2.2.4 GENERAL DESIGN FEATURES.....................
.. 2.2-33 i
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TSR-PORTS PROPOSED May 6,1997 RAC %X0090 i
SECTION 2.2 SPECIFIC TSRs FOR X-330 AND X-333 FACILITIES 2.2.4 GENERAL DESIGN FEATURES NONE l
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l GDP97-0041 Page1of3 United States Enrichment Corporation (USEC) t Proposed Certificate Amendment Request Deletion of the Seal Exhaust Pump Overflows in Buildings X-330 and X-333 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 consideratMn.
- 1. No Significant Decrease in the Effectiveness of the Plant's Safety. Safeguards or Security Programs The operational aspect of the seal exhaust pumps is not affected by this change. The amount of oil contained in the pumps for normal operation remains the same. The existence of a seal exhaust pump oil overflow 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 progmms is unaffected by this change.
- 2. No Signincant Change to Any Conditions to the Certincate of Comnliance j
There are no conditions to the Certificate of Compliance for Operation of Gaseous Diffusion Plants (GDP-2) related to the seal exhaust pumps. Thus, the proposed changes have no impact on any of the conditions to the Certificate of Compliance, l
- 3. No Signi6cnnt Change to Any Condition of the Aoproved Comnliance Plan The seal exhaust pumps are not specifically addressed in any condition of the Compliance Plan.
i While there are a number of compliance plan issues related to nuclear criticality safety, none are affected by the NCSA's which support this change. There are no changes to any condition of the j
Compliance Plan associated with this change.
- 4. No Signincant Increase in the Probability of Occurrence or Consemaces of Previously Eriduaint Accidents The operation of the seal exhaust pumps is not affected by the change of not requiring seal exhaust pump oil overflows. The maximum oil capacity of these pumps, as verified by engineering tests, is less than the limit required by the NCSE/As. Therefore, there is no increase in the probability of occurrence or consequences of any previously evaluated accidents.
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GDP97-0041 l
Page 2 of 3 4
United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Deletion of the Seal Exhaust Pump Overflows in Buildings X-330 and X-333 Significance Determination (continued)
- 5. No New or Different Type of Accident Operation of the seal exhaust pumps will not be affected by this change. The amount of oil contained in the pumps for operation has not changed. This change deletes the need for oil overflow lines which are not required as documented in NCSF/As. Therefore, there will be no new or different type of accident created by this change.
- 6. No SigniGeant Reduction in Margins of Safety The operation of the pumps will remain the same. Because the seal exhaust pump oil volume capacities prohibit the accumulation of a sufficient amount of oil to support a criticality, the safety margin is increased from that previously identified in the SAR and TSR.
- 7. No Significant Decrease in the Effectiveness of any Programs or Plans Contained in the Certificate Apnlication The seal exhaust pumps do not impact any programs or plans contained in the Certificate Application. This change will not impact the effectiveness of any program or plan contained in the application.
- 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.
This change does not impact the operation of the seal exhaust pumps. The quantity of oil required to operate the seal exhaust pumps has not changed. Thus, any environmental impact associated with the seal exhaust pump oil has not been affected by the proposed change. This change has no impact on plant efiluents or on the programs and plans in place to implement physical security. Consequently, this change does not result in undue risk to public health and safety, common defense and security, or the environment.
- 9. No Change in the Types or Significant Increase in the Amounts of Any Effluents that May be Released OfTsite This change does not impact the operation of the Seal Exhaust Pumps. The volume of oil required to operate the pumps remains unchanged. Thus, any environmental impact associated with the seal exhaust pump oil has not been affected by the proposed change.
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GDP97-0041 Page 3 of 3 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request i
Deletion of the Seal Exhaust Pump Overflows in Buildings X-330 and X-333 Significance Determination (continued)
- 10. No Significant Increase in Individual or Cumulative Occunational Radiation Exnosure The operation of the seal exhaust pumps is not affected by this change. The maximum oil capacity of these pumps is less than the limit required by the NCSE/As. Consequently, there is no increase in the individual or cumulative occupational radiation exposure due to this change.
I1. No Sienificant Construction Imnact This change does require any plant modifications and therefore does not have any construction impact.
- 12. No Significant Increase in the Potential for. or Radiological or Chemical Conseauences from Previousiv Analyzed Accidents The operation of the seal exhaust pumps is not affected by deletion of the requirement for seal exhaust pump oil overflows. The maximum oil capacity of these pumps is less than the limit required by the NCSE/As. Therefore, there is no increase in the potential for, or radiological or chemical consequences of, any previously analyzed accidents.
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