ML20155F076
| ML20155F076 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 10/19/1998 |
| From: | Toelle S 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-98-0211, GDP-98-211, NUDOCS 9811050292 | |
| Download: ML20155F076 (3) | |
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-t-o cs USEC A Global Energy Company October 19,1998 GDP 98-0211 Dr. Carl J. Paperiello Director, Office of Nuclear Material Safety and Safeguards Attention: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Paducah Gascous Diffusion Plant (PGDP)
Docket No. 70-7001 Request for 10 CFR 76.89(a) Exclusion for Criticality Accident Alarm System Audibility in Confined Spaces and Cell Housings
Dear Dr. Paperiello:
Pursuant to 10 CFR 76.89(a), the purpose of this letter is to request Nuclear Regulatory Commission (NRC) approval of an exclusion for Criticality Accident Alarm System (CAAS) audibility in permit-required confined spaces and cell housings associated with cells that are running. The details of the exclusion request are provided below.
Background
10 CFR 76.89(a) requires that a criticality monitoring and audible alarm system be maintained and operated for all areas of the facility except for approved exclusions. Issue 46 of DOE /ORO-2026, D
' " Plan for Achieving Compliance with NRC Regulations at the Paducah Gaseous Diffusion Plant" (the Compliance Plan) identifies that there are areas in the cascade process buildings where the CAAS horns are not audible to personnel due to high ambient noise levels. The Plan of Action and Schedule for this Compliance Plan issue requires that modifications be implemented to ensure that the CAAS alarm horns are capable of being heard throughout the affected areas of the process buildings.
Alf in performing the detailed design of modifications to upgrade the CAAS, it has been determined that a safe and reliable means of providing CAAS audibility coverage in permit-required confmed spaces
- and cell housings associated with cells that are running may not be achievable. Should enough CAAS
- horns be installed to compensate for the typically high noise levels in these areas, the resulting sound levels upon actuation of the horns could result in hearing damage to personnel that might be working in these areas. Furthermore, it has been determined that placing visual warning devices inside the cell housinas may not be reliable due to the heat and vibration that can be experienced. Currently, the 9011050292 991019 P
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~Dr. Carl J. Paperiello
. October 19,1998 GDP 98-0211, Page 2 devices inside the cell housings may not be reliable due to the heat and vibration that can be experienced. Currently, the compensatory actions required by the Justification for Continued Operation (JCO) for Compliance Plan Issue 46 (i.e., the sounding of the building howlers following actuation of any CAAS detection / alarm cluster) provide an adequate means of notification to personnel that may be working in these areas. However, upon completion of the CAAS upgrades, i
the building howlers will no longer be relied upon for CAAS notification and CAAS audibility in
- permit-required confined spaces and cell housings associated with cells that are running cannot be assured by solely relying on the CAAS horns themselves.
Statement of Reouested Exclusion
. USEC requests approval of the following exclusion to the requirements of 10 CFR 76.89(a):
1 In lieu of an audible criticality accident monitoring system in permit-required confined spaces and cell housings associated with cells that are running, a buddy system shall be used. This buddy system shall require that one person remain outside the area (confined space or cell housind in contact with personnel inside the area to notify them of a CAAS alarm.
)
Justification for Requested Exclusion The " buddy system" proposed will provide an attemative means of notifying personnel within these areas of a CAAS alarm. The buddy system will require that one person (an attendant) remain outside the area in contact with personnel (entrants) inside the area to notify them if a CAAS alarm occurs.
The buddy system will be consistent with the current phmt practice required by OSHA for confined i
space entries. The appropriate method of contact between the attendant and entrant (s) [e.g., visual, voice, radio, physical (via tether)] will be determined considering the work to be performed, the location of the work, and the personnel performing the work.
For the following reasons, the use of a buddy system in permit-required confined spaces and cell housings associated with cells that are running will pmvide adequate protection of personnel in these areast The probability of an inadvertant criticality event is low based on the design features and administrative controls that have been implemented for activities involving fissile material. These design features and administrative controls are specified in E
Nuclear Criticality Safety Evaluations performed for all fissile material operations, as required by the nuclear criticality safety program.
The probability of personnel being in these areas coincident with the occurrence of an inadvertant criticality is exceedingly low.
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Dr. Carl J. Paperiello
. October 19,1998 GDP 98-0211, Page 3 Previous analyses of hypothetical criticality incidents reveal that both a fast-burst a
type reaction and a low-power incident have little effect on personnel beyond the immediate vicinity of the accident.
The attendant is in contact with entrants into these areas and would be directed to notify the entrants if a CAAS alarm occurs and to initiate evacuation. The delay in notification introduced by the buddy system versus hearing a CAAS horn directly would be on the order of seconds. This delay would not result in an appreciable increase in the dnse that would potentially be received by the attendant or the entrants in the unlikely event of an inadveitant criticality.
Upon NRC approval of this exclusion request, USEC will revise the Safety Analysis Report and the related Technical Safety Requirements (TSRs) to identify the buddy system requirement. As discussed in the October 1,1998 Senior Management meeting, a certificate amendment request is being prepared to change the Compliance Plan completion dates for the CAAS upgrades. Until the CAAS upgrades are completed, the sounding of the building howlers provides adequate protection in these areas and a buddy system is not needed. However, when the upgraded CAAS is placed into operation, the buddy system will be needed in these areas to replace the capability of the building howlers. The TSR changes necessary to implement the transition from the current CAAS and building howler system to the upgraded CAAS and the buddy system are currently being evaluated -
and will be submitted for NRC review and approval at a later date.
j
- Should you have any questions or require additional information, please contact Marc Klasky at (301) 564-3408. There are no new commitments contained in this submittal.
Sincerely,
- s, B.
I b Steven A.Toelle Nuclear Regulatory Assurance and Policy Manager cc: NRC Region Ill Office
- NRC Resident inspector, PGDP NRC Resident inspector, PORTS Mr. Randall M. DeVault, DOE -
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