ML20149H890
| ML20149H890 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 07/18/1997 |
| From: | John Miller UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Paperiello C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| GDP-97-0121, GDP-97-121, NUDOCS 9707250229 | |
| Download: ML20149H890 (12) | |
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4 United States
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- EnrichmInt Corporttion 2 Democracy Center l
6903 Rockledge Drive Bethesda. MD 20817 Tel: (301)S64-3200 Fax: (301) 564-3201 United States Enrichment Corporation JAMES H. MILLER Dir; (301) 564-3309 VICE PRESIDENT, PRODUCTION Far (301) 571-8279 i
July 18,1997 Dr. Carl J. Paperiello SERIAL: GDP 97-0121 Director, Office of Nuclear Material Safety and Safeguards Attention: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Paducah Gaseous Diffusion Plant (PGDP)
Docket No. 70-7001 Certificate Amendment Request - Update th. Application Safety Analysis Report
Dear Dr. Paperiello:
In accordance with 10 CFR 76.45, the United States Enrichment Corporation (USEC) hereby submits a request for amendment to the certificate of compliance for the Paducah, Kentucky Gaseous Diffusion Plant (GDP). This certificate amendment request revises the completion date for submittal of the update to the application Safety Analysis Report (SAR) that is specified in DOE /ORO-2026, " Plan for Achieving Compliance with NRC Regulations at the Paducah Gaseous Diffusion Plant" (the Compliance Plan).
Issue 2 of the Compliance Plan requires, in part, that USEC submit an update to the application Safety Analysis Report based largely on the DOE site-wide SAR by August 17, 1997. USEC's efforts to l.
complete the SAR Update (SARUP) submittal have been underway since receipt of the DOE upgraded l
SAR in mid-February,1997 and a majority of the necessary activities have been completed. However, additional time is required to complete the resolution ofinternal comments from plant support groups, to evaluate changes to the plant and identified as-found conditions for their impact on SARUP, to review the SARUP supporting documents, and to obtain final PORC approval of the proposed application changes. Consequently, USEC requests NRC approval of a change in the submittal date from NFOLl[
August 17,1997 to October 31,1997.
9707250229 970716
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Offices in Pad Jeah. Kentucky Portsmouth. Ohio Washington, DC
4 Dr. Car,1 J. Paperiello July 18,1997-GDP 97-0121 Page 2 Enclosure I to this letter provides a detailed description and justification for the proposed change. is a copy of the new pages for Compliance Plan Issue 2. Enclosure 3 contains the basis for USEC's detennination that the proposed change associated with this certificate amendment request is not significant.
The amendment should become effective no later than 15 days from issuance.
Any questiona related to this iubject should be directed to Mr. Steve Routh at (301) 564-3251. There are no new commitments contained in this submittal.
Sin ' rely, In T
es H. Miller Vice President, Production
Enclosures:
1.
United States Enrichment Corporation (USEC), Proposed Certificate Amendment Request, Update the. Application Safety Analysis Reports, Detailed Deacription of Change i
2.
NRC Certificate Amendment Request, Padu;ah Gaseous Diffusion Plant, Letter GDP 97-0121, Removal / Insertion Instructions & Pages 3/4,9/10 of Compliance Plan Issue 2 3.
United States Enrichment Corporation (USEC), Proposed Certificate Amendment Request, Update the Application Safety Analysis Report, Significance Determination ec:
NRC Region III Oflice, w/ enclosures NRC Resident Inspector - PORTS, w/o j
NRC Resident Inspector - PGDP, w/ enclosures Mr. Randall M. DeVault, w/ enclosures
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7 OATH AND AFFIRMATION I, James H. Miller, swear and aflirm.that I am Vice President, Production, of the United States 4
- 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,
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that I am familiar with the contents thereof, and that the statements made and matters set forth therein l!
J are true and correct to the best of my knowledge, information, and belief. '
B7#4 l
U James H. Miller Subscribed to before me on this /
day of httlz/-
,1997.
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GDP 97-0121 1
Page1 of2 I
United States Enrichment Corporation (USEC) l Certificate Amendment Request Update the Application Safety Analysis Report Detailed Description of Change 1.0 Purpose The purpose of this certificate amendment is to request NRC approval of a change in the submittal date for the update to the Application Safety Analysis Report that is specified in Issue 2, " Update the Application Safety Analysis Report," of DOE /ORO-2026, Plan for Achieving Compliance with NRC Regulations at the Paducah Gaseous Diffusion Plant (Compliance Plan). Specifically, a change in the submittal date specified in Item 3 of the Plan of Action and Schedule for CP Issue 2 from August 17,1997 to October 31,1997 is requested.
2.0 Description Compliance Plan Issue 2 requires USEC to prepare and submit an update to the Application Safety Analysis Report based largely on the DOE site-wide SAR. Specifically, item 3 of the Plan of Action and Schedule for Compliance Plan Issue 2 requires that:
3.
By no later than August 17,1997, USEC shall submit an amendment to their Certification Application which includes:
a) identification of all information, fmdings, and recommendations which indicate differences between the DOE site-wide Safety Analysis Report and the USEC Application for Certification.
b) an evaluation of the effects of those differences on the safety of workers, and off-site members of the public.
c) proposed modifications to the compliance certificate and/or facility, including proposed modifications to the Application SAR and TSRs.
USEC's efforts to complete the SAR Update (SARUP) submittal have been underway since receipt of the DOE upgraded SAR (KY/EM-174, see Reference 1) in mid-February,1997 and a majority of the necessary activities have been completed. However, additional time is required to complete the following activities:
Resolve internal comments from plant support groups
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Page 2 of 2 Evaluate changes to the plant and identified as-found conditions for their impact on SARUP Review the SARUP supporting documents Obtain final PORC approval of the proposed application changes -
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, Consequently, USEC requests NRC review and approval of a change in the submittal date from l
August 17,1997 to October 31,1997.
l A review of the Justification for Continued Operation (JCO) for Compliance Plan Issue 2 has been performed to determine if any changes are required as a result of extending the SARUP submittal
. date. The conclusions of this review are that no changes to the JCO are required (other than the submittal 1
date change) and continued operation is justified during the extended period.
Reference i
KY/EM-174, Safety Analysis Report, Paducah Gaseous Diffusion Plant, Paducah, Kentucky; Prepared by Lockheed Martin Energy Systems, Inc. for the U.S. Department of Energy; Transmitted by February 14,1997 Letter from Joe W. Parks (DOE) to Mr. George P. Rifakes, USEC.
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GDP 97-0121 3 Pages Total a
NRC Certificate Amendment Request Paducah Gaseous Diffusion Plant Letter GDP 97-0121 Removal / Insertion Instructions Remove Pages Insert Pages PLAN FOR ACIIIEVING COMPLIANCE WITII NRC REGULATION AT TIIE PADUCAII GASEOUS DIFFUSION PLANT (DOE /ORO-2026)
Issue 2, Update the. Application Safety Issue 2, Update the Application Safety Analysis Report Analysis Report Pages 3/4, 9/10 Pages 3/4,9/10 l
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Updam de Applicanon Safay Analysis Rapon Issue 2, Page 3 Wadfindon, source term analysis, and consequence analysis. The DOE site-wide safety analysis upgrade effort contams site characteristic information including geology, seismology, and meteorology (including tornado and high wmds). Additionally, the facility and process descriptions
- are reqmred to be updated based on the final accident analyses resulting from the DOE site-wide safety analysis upgrade effort, as well as other program upgrades such as the Configuration Management Program. The SAR update will provide more accurate estimates of release rates and on site and off-site cowam needed to meet 10 CFR 76.85 for establishmg liminng condinnas for operations.
JUSTIFICATION FOR CONTINUED OPERATION The safety of the GDPs has been connnually confirmed through: (1) te initial Atomic Energy Commission reviews and approvals of GDP design, siting, and construction; (2) the performance, review, and approval of tmmerous additional safety analysis and assessments performed to support continued operations under increasingly stnngent standards; and (3) more than 100 combined years of operation for the 3 GDPs that has developed a generation of competent operating staff whose plant experience and knowledge continue to assure safe operations of the GDPs.
i DOE's current safety basis for authorizing the continued operation of the GDPs is based on the plants' implementation of, and adherence to, safety requirements in Operational Safety Requirements (OSRs)'and plant procedures, developed through the long operating experience of the GDPs. This safety basis will continue to be utilized by the GDPs during the interim period of noncompliance until completion'of the SAR Upgrade and knplementation of the approved amendment request addressing results of the SAR Upgrade. The Technical Safety Requirements j
(TSRs), which will take effect upon NRC assuming regulatory oversight of the GDPs, are based on the safety requirements in OSRs and additional safety requirements identified during the i
certification process. Current plant procedures that are safety related shall also remain in effect after NRC assumes regulatory oversight of the GDPs. Also, new safety procedures continue to be developed and implemented as part of the certification process. These existing and new safety procedures can be changed only in accordance with the procedure TSR which provides the necessary safety assessment and both management and technical review before a procedure is changed or replaced. TSRs cannot be changed without prior NRC approval.
The safety systems in the Certification Application contain commitments with regard to currently identified safety structures, systems, equipment, and components to assure the availability and reliability of features relied on for safety. In addition, the Certification Application also contains commitments to safety programs such as radiation protection, criticality prevention, etc.
The protection of workers, members of the public, and the environment is assured through proper implementation of the safety systems and programs described in the Application and the Compliance Plan, which includes the SAR Upgrade. From the comprehensive analysis of all credible ia&dag events based on "as-exist" plant configurations, and the consequences from these accidents, the SAR Upgrade will designate possible additional safety systems, equipment, components, and human activities and also provide descriptions of the various safety programs (based prunarily from the Certification Application).
The combinanon of the use of experienced plant personnel: implementation of, and adherence to, TSRs (which succeed the OSRs) and current as well as new GDP safety procedures; and v
commitments to compensatory measures and/or interim regulatory commitments will ensure that PGDP Rev. 3,7/15/%
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Issue 2, Page 4 PROPOSED Update the Application Safety Analysis Report
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a RAC 97C0180
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the GDPs continue to operate safely during the interim period of noncompliance untilthe SAR p
upgrade and' accompanying GDP modifications for safety are approved by the NRC and implemented at the GDPs.
The DOE site wide safety analysis upgrade (SAR Upgrade) was initiated to address the 4I.
deficiencies stated in the Description of Noncompliance, changes to_the plant configuration implemented since the previous analysis was performed, and the revised DOE safety requirements issued since the development of the 1985 FSAR. This effort involves (1) comprehensive site j
characterization for' natural and man-made phenomena (e.g., explosion off-site) evaluation; i
(2) systematic identification and analysis of hazards associated with-each of the facilities; L
(3) determination;of human actions, structures, systems, and components that are safety j
significant; (4) determinaticn of credible accidents from the possible hazards; (5) evaluation of
' facility operational states for the limiting condition within each operational mode; and (6) determination of releases from the credible accidents and consequences from the releases for i
normal, off-normal,' and accident conditions, i
The DOE site-wide safety analysis upgrade effort has not yet completed all analysis of possible accident conditions and consequences. However, the currently available preliminary results are generally consistent with previous analysis forming the GDP current operating safety basis and, to 1
i date, have not identified any additional significant accidents that have not been addressed in the submitted SAR. Although the ongoing DOE site-wide safety analysis upgrade may identify
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additional risks, insights, and measures that can be taken to further reduce risks to workers and j
public health and safety and the environment, the upgrade is not expected to identify significant l
additional or higher risks than those considered in the submined Safety Analysis Report. The only exception presently identified where the current analysis results do not confirm previous analysis
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is in the area of seismic capability of Buildings C-331 and C-335 Current seismic analysis results of these buildings indicate that they fall short of the seismic risk goals established for the GDP i
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- process facilities. This issue is described in more detail in the Compliance Plan issue entitled 8
" Seismic Capability of Buildings C-331 and C-335."
l Although the final SAR Upgrade will not be submitted to the NRC until October,1997, preliminary SAR Upgrade results concerning safety significant issues (e.g., seismic) have and shall continue to be brought to the attention of the NRC staff. Where possible, features of safety 2
j-systems and elements of safety programs that will enhance safety are being incorporated into the certification application. For those features of safety systems and remaining elements of safety-l programs which cannot be implemented by the time NRC assumes regulatory oversight of the plants, compensatory measures and/or interim regulatory commitments have been provided in the -
1 compliance plan during the interim period of noncompliance. These compensatory measures and/or interim regulatory commitments are described in compliance plan issues related to the functional areas covering the pertinent safety issue.
If the upgrade efforts identify risks more severe than those submitted in the Safety Analysis Report,~ DOE will inform USEC of the identified risk within 5 working days. If such risk is identified before NRC assumes regulatory oversight for the facility, USEC will resolve the risk in accordance with DOE Regulatory Oversight Agreement requirement 3.3.2.7. This requires that management ensure that "as found" conditions which potentially involve an unreviewed safety question or a change in the authorization basis or an operational safety requirement are reported to DOE and that appropriate engineering reviews and safety assessments of the condition are performed and submitted to DOE for review. If any of the information is identified by USEC or PGDP, July 18,1997 EROPOSED
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IJpdate the Application Safety Analysis Repon PROPOSED Issue 2, Page 9
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RAC 97C0180 l
Plant Safety Operational Analysis (PSOA), the bases for Technical Safety 3
_ Requirements will be developed for both USEC and DOE activities.
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- 2) The Technical Safety Requirements bases will include technical requirements for safety class and safety significant structures, systems, and components including I
safety limits, limiting control settings,' limiting conditions for operation, design ive
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controls required to reduce the probability of significant accident scenarios will be i
described, f)
Programmatic Controls
- 1) The programs _ discussed. in the Chapter 6 through 17 descriptions in DOE-STD-3009-94 will be described for DOE activities at the facility. These programs include prevention 'of inadvertent criticality; radiation protection:
J hazardous material protection; radioactive and hazardous waste management; initial l
testing, in-service surveillance, and maintenance; operational safety; procedures j
and training; human factors; quality assurance; emergency preparedness program; i
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provisions for decontamination and decommissioning; and management.
l organization, and institutional safety provisions.
2)- The programs described in Chapters 5 and 6 of the USEC Application for Certification, as well as the other supplemental program descriptions contained therein, will be assumed valid for USEC activities at the facility. These programs will be reviewed and evaluated'for impact on DOE activities, and areas of interdependency will be identified. Any apparent conflict between USEC and DOE l
acti',ities identified during this review will be resolved between USEC and DOE
.during the DOE site-wide Safety Analysis Report preparation, review, and approval by DOE.
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USEC will provide information required to complete the DOE site-wide Safety Analysis Report and will provide technical reviews of the ongoing analyses to ensure that the analyses accurately reflect the facility configuration.
3.
By no later than October 31; 1997, USEC shall submit an amendment to their Certification l
Application which includes:
a) identification of all information, findings, and recommendations which indicate differences between the DOE site-wide Safety Analysis Report and the USEC Application for Certification.
b) an evaluation of the effects of those differences on the safety of workers, and off-site mensbers of the public.
c) proposed modifications to the compliance certificate and/or facility, including proposed modifications to the Application SAR and TSRs.
- 4. ' At the same time the Application amendment is due, USEC shall also submit for NRC approval, its proposed resolution of matters contained in the DOE-approved site-wide Safety PGDP, July 18, th7 EEQPOSED
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Issue 2, Page 10 Update the Applicnion Safety Analysis Report Analysis Report not incorporated by USEC in its request for amendment of their Application for Certification.
5.
From September 30,1995, until NRC approves the submittals in paragraphs 3 and 4 above, changes made by USEC in accordance wi6 DOE's ROA requirement concerning Unreviewed Safety Question Determinations (USQDs) or with 10 CFR 76.68 must be addressed either in the DOE SAR Upgrade results or in te amended safety analysis report submitted by USEC based upon those results. The following will assure such changes are properly considered and addressed:
a) The plant configuration was considered to be frozen for the purpose of DOE's analysis on September 30,1995.
b) Changes made to the plants after September 30,1995, will be addressed by USEC in its amendment Application. The amendment Application will reflect the plant as it exists 6 months before the amendment submittal.
1 c) Once the snendment is submitted, USEC will inform NRC of changes that are made in accordance with 10 CFR 76.68 that 'could render the amendment to be incorrect, inaccurate, or incomplete until the amendment is approved by NRC.
d) NRC is notified of changes made in accordance with 10 CFR 76.68 as part of the annual Application for renewal required by 10 CFR 76.36.
6.
The update to the Application SAR will also reflect those commitments made by USEC to the 1
NRC during the ininal certification Application process as identified in the Application and the responses to NRC questions / comments.
SUMMARY
OF REQUIREMENTS, COMMITMENTS, AND NONCOMPLLLNCES Issue: Update the Application Safety Analysis Report Code of Federal Regulations Part Title 10 76.35(a)(4), (6), and (8),76.85 Application Commitment Section l
Safety Analysis Repott Chapters 2,3,4 Application Noncompliance Statement Section l
Safety Analysis Report 2.7, 3.16.1 PGDP Rev. 3,7/15/96
.. to GDP 97-0121 Page1of2 United States Enrichment Corporation (USEC)
Certificate Amendment Request Update the Application Safety Analysis Report 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
- 1 consideration.
1.
No Overall Decrease in the Effectiveness of the Plant's Safety. Safeguards. or Security Programs No changes to the plant's safety, safeguards, or security programs are required as a result of an extension to the SAR Update submittal date. Thus, the, effectiveness of the plant's safety, safeguards, and security programs is unatTected by this certificate amendment.
2.
No Significant Change to Any Conditions to the Cc-tificate of Comnliance i
None of the Conditions to the Certificate of Compliance specifically address the SAR Update.
Thus, the proposed changes have no impact on any of the Conditions to the Certificate of Compliance.
3.
No Significant Change to Any Cor dition of the Acoroved Comoliance Plan Issue 2 is the only portion of the Compliance Plan affected by the proposed changes. Extendmg the submittal date for the SAR Update is not a significant change because no changes to the JCO for Compliance Plan Issue 2 are required (other than the submittal date change).
4.
No Significant Increase in the Probability of Occurrence or Conseauences of Previousiv Evaluated Accidents No changes to the existing application SAR are required as a result of an extension to the SARUP submittal date. For this reason, the probabilit, of occurrence or the consequences of previously evaluated accidents will not be increased.
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5.
No New or Difr_gtent Tvoc of Accident x
No changes to the existing application SAR are required as a result of an extension to the S ARUP J
submittal da+e. For this reason, no new or different types of accidents will be created.
1 6.
No Sinnificant Reduction in Margins of Safety This certificate amendment request has no impact on the margins of safety as defined in the basis for any Technical Safety Requirement. Therefore, no significant reductions in margins of safety will result.
. i to GDP 97-0121 Page 2 of 2 7.
Np_Sjgnificant Decrease in the Effectiveness of any Program or Plans Contained in the Certificate Anotication For the reasons discussed in the response to item 1 above, there will be no significant decrease in the efTectiveness of any program or plan contained in Volume 3 of the Certification Application.
8.
The oronosed changes do not result in undue risk to 1) oublic health and safety. 2) common dsfense and security. and 3) the environment As discussed in the response to Item 4, the extension of the submittal date for the SAR Update will not result in a significant increase in the probability of occurrence or the consequences of previously evaluated accidents. As discussed in the response to Item 5, no new or different types of accidents have been identified. Thus, there will be no undue risk to public health and safety or to the environment. The change in the submittal date has no impact on common defense and security.
9.
No Change in the Tynes or Significant Increase in the Amounts of Anv Efiluents that May be Erleased Offsite As discussed in the response to Item 4, there will be no increase in the consequences of previously evaluated accidents. Therefore, there will be no change in the types or significant increase in the amounts of any efIluents that may be released ofTsite.
10.
No Siunificant Increase in Individual or Cumulative Occupational Radiation Exoosure The extension of the SARUP submittal date has no impact on plant operation. The Compliance Plan JCO will continue to remain in effect. No increases in individual or cumulative occupational radiation exposures are involved.
I 1.
No Significant Construction Imnact The extension of the SAR Update submittal date does not involve construction activities.
Therefore, there is no significant construction impact.
12.
No Sienificant increase in the Potential for Radiological or Chemical Conseauences Sm l
Previously Analyzed Accidents As discussed in the response to item 4, there is no significant incicase in the probability of occurrence of previously evaluated accidents. Therefore, there is no significant increase in the potential for radiological or chemical consequences from previously analyzed accidents.
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