ML20155K299
| ML20155K299 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 11/06/1998 |
| From: | UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | |
| Shared Package | |
| ML20155K296 | List: |
| References | |
| GDP-98-0235, GDP-98-235, NUDOCS 9811130176 | |
| Download: ML20155K299 (67) | |
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O GDP 98-0235 Page1of4 United States Enrichment Corporation (USEC)
Proposed Changes Certificate Amendment Request Update the Application Safety Analysis Report Detailed Description of Change l.0 Purpose The purpose of this submittal is to provided revised pages to the Safety Analysis Report Update (SARUP) previously transmitted in USEC letters GDP 97-0188, dated October 31,1997
. (Reference 1); GDP 98-0064, dated March 31,1998 (Reference 2); and GDP 98-0219, dated i
October 19,1998 (Reference 3); for NRC review and approval.
2.0 Description of Submittal and Basis for Changes The following changes are included in this submittal which modify the latest version of the SAR Update certificate amendment request. The revised pages are included in Enclosure 3.
A.
The Revision Log has been updated to reflect the changes included in this revision.
B.
The List ofEffective Pages has been updated to reflect the changes included in this revision.
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C.
SARUP Chapter 1, Appendix A has been updated to delete the reference to the Packaging and Transportation Quality Assurance Program (UEO-1041) from the description of 1
compliance with ANSI N14.1 and to correct the spelling of"hexafluoride." This change corrects an inappropriate cross reference and a typographical error. The Packaging and i
Transportation Quality Assurance Program (UEO-1041) does not contain any information related to compliance with ANSI N14.1.
D.
The Table of Contents has been updated to reflect the deletion of SAR Figure 2.1-3,
" Building Directory of PGDP." This figure has been deleted because it is redundant to the latest version of SAR Figure 2.1-4,"PGDP building lease status."
E.
SARUP Section 2.1.2.4 has been updated to indicate that posts other than the main guard post may be opened for shift changes or other operational needs during off-shifts, holidays, and weekends. An additional change to this section has been made to indicate that selected areas of the CAA perimeter may be operated in a flexible manner. Operational needs require more flexibility in the way guard posts and the CAA boundary are operated. The changes proposed still provide the same level of protection and access control as is currently described in the SAR. Security personnel man all posts when they are open for personnel access.
Security personnel also throughly inspect areas located outside the CAA to ensure 9811130176 981106 PDR ADOCK 07007001 l=
C PDR
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GDP 98-0235 Page 2 of 4 unauthorized personnel are not left in the security boundary prior to brining the area back into the CAA.
F.
SARUP Section 3.15.3.7.2.1 has been revised to delete reference to the cascade pressure TSR limit. The reference to the cascade pressure TSR limit has been deleted since the TSRs proposed as a part of the SARUP CAR do not include a cascade pressure TSR limit.
G.
SARUP Section 3.15.6.2.3 has been updated to add discussion of administrative controls used to prevent simultaneous loading or operating both bridge cranes in Buildings C-310 and C-315 located on the same runway. SARUP Table 3.15-1 has been updated to correct the description of the liquid UF cylinder handling crane brakes. Changed "D.C. rectified shoe 6
brakes" to "two hoist brakes." SARUP Section 4.3.2.2.15 has been updated to add a discussion of administrative controls used to prevent simultaneous loading or operating both bridge cranes in Buildings C-310 and C-315 located on the same runway.
The proposed changes revise the description of the safety features on the cranes in the withdrawal and toll transfer and sampling facilities (C-310 and C-315). These changes are required to reflect the configuration of the cranes used in these facilities. The brake designs comply with the requirements of ANSI B30.2-1990 and will continue to perform their safety function.
H.
SARUP Section 3.15.7.7.3 has been updated to change the description of seismic instmmentation from " seismic accelerographs" to " seismic switches." SARUP Table 3.15-2 has been updated to delete reference to "accelerographs" from the boundary definition of seismic instrenentation. The seismic switches and displacement alarms credited in the accident analysis are triaxial seismic switches. The accelerometers are not credited in the accident analysis because of the lack of correlation between ground acceleration, which the accelerometers measure, and displacement, which actually results in damage to the cascade.
I.
SARUP Section 3.15.10.1.3.1 has been updated to change the setpoint for the Freezer / Sublimer DPCS R-114/RCW Low Differential Pressure Trip from 2.5 psi to 2.0 psi.
This change has been made to comport with the Nuclear Criticality Safety Approval (NCSA) limit. This setpoint is more conservative and within the analyzed boundaiy limit.
J.
SARUP Table 3.15-2 boundary definition for the Chlorine System has been changed to define the AQ boundary as the piping up to and including the vacuum regulator and the chlorine leak detectors. The components that are no longer within the AQ boundary operate at a vacuum.
Should a release occur in this part of the system, the ability to maintain a vacuum would be lost and the vacuum regulator would close, thus isolating the container from the system breach. There is no analyzed accident in the SARUP associated with a breach of the system piping.
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GDP 98-0235 Page 3 of 4 K.
SARUP Table 3.15-2 boundary definition for the Criticality Accident Alarm System (CAAS) and related TSR 2.4.3.3 have been revised to reflect new configuation for buildings C-710 and C-709. The CAAS for C-710 has been upgraded to satisfy Compliance Issues 8 and 50.
As part of the upgrade, C-709 has been slaved to the C-710 system and C-302 has been removed from the C-710 boundary since it is outside of the 12 rad exposure boundary.
L.
SARUP Table 4.2-7, Facilities Included in the SAR Review has been updated to include facility C-304-T-01, Temporary Office and to delete facility C-616-E, Sludge Lagoon.
Facility C-304-T-01 is a temporary office trailer that was inadvertently omitted in the original SARUP submittal. The C-616-E Sludge Lagoon facility has been removed from the SARUP submittal since it is a facility retained by the Department of Energy (DOE).
M.
SARUP TSR 2.1.3.6 and 2.3.3.6 Basis statements have been updatea to reflect that moderation control can be maintained by draining the Raw Cooling Water (RCW) from the coolant condenser in the event that the R-114 pressure cannot be maintained greater than the RCW pressure. The update to the Basis statement is necessary to reflect the current SARUP TSR action statement and does not introduce any new operation or control.
N.
S ARUP TSR 2.4.3.1.a Surveillance Requirements and Basis statements have been updated to correct have been updated to correctly identify High Pressure Fire Water System diesel fire water pump house facility designations. The facility number designations were specified incorrectly in 4 locations in SARUP TSR 2.4.3.1.a.
O.
The SARUP sections identified below have been updated to reflect the C-310/310A and C-315 seismic modifications that upgraded component capability to withstand a proposed evaluation basis eanhquake (EBE) having a site specific spectra anchored to a zero period i
acceleration of 0.165g. Sections updated: 3.15.3.3.3, 3.15.4.5.3, Table 3.15-2, Table 3.15-8, Table 3.15-9, Table 3.15-10,4.3.2.5.3, Table 4.3-11, Table 4.3-12, Table 4.3-13, Table 4.3-14, Table 4.3-15, Figure 4.3-38, Figure 4.3-39, Figure 4.3-40, Figure 4.3-41, Figure 4.3-42, Figure 4.3-43, and Figure 4.3-44.
References 1.
Letter from James H. Miller (USEC) to Dr. Carl J. Paperiello (NRC), Certificate Amendment l
Request - Update the Application Safety Analysis Report, USEC ' Letter GDP 97-0188, l
October 31,1997.
l 2.
Letter from George P. Rifakes (USEC) to Dr. Carl J. Paperiello (NRC), Certificate Amendment Request - Update the Application Safety Analysis Report - Proposed Changes, USEC Letter GDP 98-0064, March 31,1998.
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GDP 98-0235 Page 4 of 4 3.
Letter from Steven A. Toelle (USEC).to Dr. Carl J. Paperiello (NRC), Certificate Amendment Request - Update the Application Safety Analysis Report - Proposed Changes, USEC Letter GDP 98-0219, October 19,1998.
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Enclosure.
GDP 98-0235
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63 Pages Total PROPOSED CHANGES CERTIFICATE AMENDMENT REQUEST SAFETY ANALYSIS REPORT UPDATE INSERTION / REMOVAL INSTRUCTIONS NOVEMBER 6,1998 Remove Pages Insert Pages SARUP Revision Log SARUE Cevision Log i
i SARUP List of Effective Pages SARUP List of Effective Pages SARUF-1 through SARUP-12 SARUP-1 through SARUP-12 SARUP Section 1.0 SARUP Section 1.0 Appendix A. Page A 1 Appendix A, Page A 1 SARUP Section 2 SARUP Section 2 6,2.1 -3 6, 2.1-3 SARUP Section 3.15 SARUP Section 3.15 f-- s 3.15-20,3.15-27,3.15-32,3.15-51,3.15-61,3.15-72, 3.15-20,3.15-27,3.15-32,3.15-51,3.15-61,3.15-72,
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Table 3.15-1 page 6, Table 3.15-2 pages 12,13,21,22 Table 3.15-1 page 6, Table 3.15-2 pages 12,13,21,22 and 23, Table 3.15-8, Table 3.15-9, Table 3.15-10 and 23, Table 3.15-8, Table 3.15-9, Table 3.15-10 SARUP43 SARUP43 Table 43-7 pages 2 and 9 Table 43-7 pages 2 and 9 SARUP Section 4.3 SARUP Section 43 43-116,43-117,4-3-126,43-138,43-139,43-141,43-116,43-117,4-3-126,43-138,4 3-139,43-141,43-142,43-143,43-144,43-145, Table 43-11,43-142,43-143,43-144,43-145, Table 43-11 Table 43-12, Table 43-13, Table 43-14, Table 43-15, Table 43-12, Table 43-13, Table 43-14, Table 43-15, Figure 43-38, Figure 43-39, Figure 43 40, Figure 43-38, Figure 43-39, Figure 43-40, Figure 43-41, Figure 43-42, Figure 4.3-43, and Figure 43-41, Figure 43-42, Figure 43-43, and Figure 43-44, Figure 43-44, SARUP TSR 2.1 SARUP TSR 2.1 2.1-23 2.1-23 SARUP TSR 2.3 SARUP TSR 2.3 23-19 23-19 SARUP TSR 2.4 SARUP TSR 2.4 2.4-3,2.4-4,2.4-9,2.4-11,2.4-12 2.4-3.2.4-4.2.4-9.2.4.I1.2.4-12 9
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November 6,1998
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! V United States Enrichment Corporation Paducah Gaseous Diffusion Plant l
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l Safety Analysis Report Update 4
I REVISION LOG Date Description 8/18/97 Initial Issue. Included: changes to SAR Chapter 2 (changed pages only); new SARUP Sections 4.1,4.2.1 through 4.2.5, 4.3.1, 4.4.
10/31/97 Submittal of completely SARUP (including 8/18/97 sections unchanged), with the exception of changes to Application SAR Chapter 3 Included: changes to SAR Chapters 1 and 2 and Sections 5.2,5.4, and 5.6 (changed pages only); complete replacement of Section 3.15, Chapter 4, and the TSRs; new Section 5.2, Appendix A.
3/31/98 Submittal to remove the fixed fire suppression sprinider systems within the C-333-A, C-337-A, and C-360 facilities and the sanitary and fire water system (SFWS), including i
it's distribution and elevated storage tank as safety (AQ) systems. Sections revised include: Section 3.15.7.2, Table 3.15-2, Table 4.2-5, Table 4.2-11, Section 4.3.2.2.16,
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TSR Table of Contents, TSR 2.2.3.3, TSR 2.4.3.1.a. TSR 2.4.3.1.b, TSR 2.4.3.2.a,
'd TSR 2.4.3.2.b, and TSR 2.6.3.2. SARUP List of Effective Pages added.
1 10/19/98 Submittal to define the codes and standards applied to the process building cranes.
Sections revised include: Chapter 1, Appendix A, Sections 3.15.6.2.2, 3.15.6.2.3, 3.15.9.2.2, 3.15.9.2.3 and TSRs 2.2.4.1, 2.3.4.2, 2.5.4.2, and 2.6.4.2, 11/6/98 Submittel to incorporate miscellaneous SARUP revisions. SARUP Sections affected are:
1.1 of Chapter'1 Appendix A, Chapter 2 Table of Contents, 2.1.2.4, 3.15.3.3.3, 3.15.3,7.2.1, 3.15.4.5.3, 3.15.6.2.3, 3.15.7.7.3, 3.15.10.1.3.1, Table 3.15-1, Table 3.15-2, Table'3.15-8, Table 3.15-9, Table 3.15-10, Table 4.2-7, 4.3.2.2.15, 4.3.2.2.16, 4.3.2.5.3, Table 4.3-11, Table 4.3-12, able 4.3-13, Table 4.3-14, Table 4.3-15, Figure 4.3-38, Figure 4.3-39, Figure 4.3-40, Figure 4.3-41, Figure 4.3-42, Figure 4.3-43, Figure 4.3-44, TSR 2.1.3.6 Basis, TSR 2.3.3.6 Basis, TSR SR 2.4.3.1.a-2, TSR 2.4.3.1 Basis, TSR 2.4.3.3 Title, TSR 2.4.3.3.b Applicability, and TSR 2.4.3.3.b Basis.
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l SARUP-PGDP November 6,1998 SARUP LIST OF EFFECTIVE PAGES SARUP Pane RAC/Date/ Revision SARUP Pane RAC/Date/ Revision l
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_RAC/Date/ Revision SARUP Pane RAC/Date/ Revision Technical Safety Reauirements 2.1-27 97C237(R2)
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SAR-PGDP PROPOSED November 6,1998 n
RAC 97C238 (R1), 97C207 (RO)
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Appendix A Applicable Codes, Standards, and Regulatory Guidance This Appendix lists the various industry codes, standards, and regulatory guidance documents which have been referenced in certification correspondence. The extent to which PGDP satisfies each code, standard, and guidance document is identified below, subject to the completion of applicable actions required by the Compliance Plan.
1.0 American National Standards Institute (ANSI) l 1.1 ANSI N14.1, Uranium Hexafluoride - Packaging for Transport,1990 Edition PGDP satisfies the requirements of this standard, except for those portions superseded by Federal Regulations, with the following clarifications:
New cylinders and associated valves - Entire standard Cylinders and valves already owned and operated by PGDP that were not purchased to meet this edition of the standard - Satisfy only Sections 4, 5, 6.2.2 - 6.3.5, 7, and 8 of the standard.
Cylinders purchased prior to 1990 were manufactured to meet the version of the ANSI standard or specification in effect at the time of the placement of the purchase order.
U Section 5.2.1 - For U.S. Department of Transportation 7A Type A packaging, satisfy U.S.
Depanment of Energy (DOE) evaluation document DOE /RL-96-57, Revision 0, Volume 1, which supersedes DOE /00053-H1.
l See SAR Sections 3.7.1 and 4.3.2 and the basis statements for TSR Sections 2.2.3.7,2.3.4.1, l
2.5.4.1, 2.6.3.7, and 2.6.4.1.
1.2 ANSI /ANS 2.8, Determining Design Basis Flooding at Power Reactor Sites,1981 Edition The extent to which PGDP sat'isfies the requirements of this standard will be determined as part of the SAR Upgrade activity.
For references to this standard, see SAR Section 2.4.3.
1.3 ANSI /ANS 3.1, Selection, Qualification, and Training of Personnel for Nuclear Power Plants, 1987 Edition PGDP satisfies only the following section of this standard:
Section 4.3.3 - The qualifications of the Radiation Protection Manager identified in SAR Section 6.1 satisfy the requirements of this section of the standard.
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l SAR-PGDP PROPOSED November 6.1998 RAC 97C100 (RO), 97C255 (RO)
P_. age CHAPTER 2 1.ist of Fieures 2.1-1 ' The location of PGDP........
2.1-22 2.1-2 PGDP and the surrounding region, showing the DOE property boundarv, nearby communities, roads, and bodies of water....................
2.1-23
. l 2.1-3 Figure Deleted 2.1-4 PGDP building lease status............
2.1-27 2.1-5 PGDP site boundary and plant boundary........................... 2.1-29 2.1-6 Shortest distances to the PGDP boundary from effluent release points...
2.1-30 2.1-7 The 1990 population, by sectors, within 1,2,3,4 and 5 miles of PGDP....... 2.1-31 2.1-8 Schools in the e W of PGDP,................................ 2.1-32 2.1-9 ~ Public recreath ; aM racilities in the vicinity of PGDP.
2.1-33 2.1-10 General land use within 5 miles of PGDP......................
2.1-34 2.3-la Comparison of wind roses at 33 ft and 197 ft levels at PGDP for 1992....
2.3-11 2.3-1b Average wind rose at 33 ft level at PGDP for 1988-1992................ 2.3-11a 2.3-Ic Average wind rose at 33 ft level at PGDP for 1988-1992................ 2.3-11b 2.3-2. Monthly mean temperatures averaged over the period from 19951 to 1980 at Paducah, Kentucky..............
2.3-12 2.3-3 ' Monthly mean precipitation averaged over the period from 19951 to 1980 at Paducah, Kentucky 2.3-13 O
. 2.4-1 Regional area primary surface hydrology....................
2.4-9 V
2,4-2 PGDP site surface hydrology systems 2.4-10 2.4-3 Efiluent outfall locations at PGDP
.............................. 2.4-11 z 2.4 The 10,000-year precipitation intensity-versus-duration graph for PGDP,,.... 2.4-12 2.5-1 Schematic north-south section showing regional stratigraphic relationships (not to scale)..
2.5-14 2.5-2 Potentiometric surface map of RGA...............
2.5-15 2.5-3 Water level elevations and geologic components of the local flow system 2.5-16 2.5-41 Potentiometric surface and thickness map of the McNairy aquifer in the Jackson Purchase region...................................... 2.5-17 2.5-5 ' Calculated potentiometric surface in the shallow sand................... 2.5-18 2.5-6 Calculated potentiometric surface in the upper clay...........
2.5-19 2.5-7 Calculated potentiometric surface in the RGA........................ 2.5-20 2.5-8 Calculated northwest plume in the RGA at the end of the 10th year....
2.5-21
-2.5-9 Calculated northwest plume in the RGA at the end of the 20th year......... 2.5-22 2.5-10 Calculated northwest plume in the RGA at the end of the 30th year......... 2.5-23 2.5-11 Calculated northwest plume in the shallow sand at the end of the 30th year.... 2.5-24
-2.6-1 Regi:nal physiographic map................................... 2.6-11 2.6-la Geologic time scale
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2.6-2 Regional geo'.ogic setting....................
2.6-12 6
SAR-PGDP PROPOSED November 6,1998 RAC 97C100 (RO), 97C206 (RO) n
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The PGDP rail system, consisting of slightly more than 17 miles of track, is the primary means of transporting materials such as cylinders and coal. The rail spur enters the site west of Building C-720 and branches out within the fenced area.
PGDP utility systems include communications, electricity, water supply, high-pressure fire water, wastewater treatment, miscellaneous energy, and industrial gases. A Bell system, power dispatching network, and an emergency system constitute the plant's telephone system. PGDP's electrical power is supplied at 161-kV; switchyards are connected with the Tennessee Valley Authority (TVA), Kentucky Utilities Company (KU), and Electric Energy, Inc. (EEI).
PGDP's water supply system includes a DOE-owned pumping station at the Shawnee Steam Plant, two 36-in. raw water lines, the Building C-611 treatment plant, and separate distribution networks for process and sanitary water. Storm water is collected by the storm drainage network, industrial wastewater is pumped to the C-616 treatment plant, and sewage is pumped to C-615.
2.1.2.4 Site Boundary The north, east, and west boundaries of PGDP are defined by the West Kentucky Wildlife Management Game Reserve. Also adjoining the northern boundary is the Shawnee Steam Plant owned and operated by TVA. Figure 2.1-5 chows the site boundary and the plant boundary.
The plant protection section monitors about 3,000 acres in and around PGDP. Within the fenced area is a limited access area, and security personnel staff all plant entry points. During off-shifts, l
holidays, and weekends, access to the plant is limited to the main guard post, which is staffed continuously by security personnel. Other posts may be opened during shift changes or as needed by l
Os operational requirements. Special work areas in C-720 are edsica creas whhin the plant fence.
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Additionally, the area around the Building C-611 water treatment plant is a controlled area to which access is regulated administratively.
Selected areas located on the CAA perimeter / boundary are configured in such a way as to allow the areas to be operated in a flexible manner (moved in/out of the CAA) as operational needs dictate. The dual CAA perimeters / boundaries of areas which are flexed shall afford appropriate level of protection l
to deter unauthorized access to the CAA Areas containing SNM and/or classified matter are prohibited from being moved outside the CAA by procedures. Areas located outside the CAA are throughly inspected to ensure unauthorized persons are not left in the security area prior to bringing the area back into the CAA.
2.1.2.5 Boundaries for Esteblishing Efiluent Release Limits The controlled area is as defined in 10 CFR Part 20 and is the area outside the restricted area but inside the site (reservation) boundary, access to which can be limited by USEC for the purposes of plant protection, security, emergency preparedness and radiation protection. Adequate measures to limit access to the controlled area, such as utilizing existing gates, can be implemented as directed in site procedures.
Figure 2.1-6 shows distances from potential effluent release points to the boundary of the controlled area.
2.1.3 Population 2.1.3.1 On-Site Population Current Lockheed Martin Utility Services (LMUS) employment on-site at PGDP totals approximately 1,800. Employees work different shift cycles. There are four rotating,12-hr shifts (A, (n) 2.1-3 v
l l
t
l j
SAR-PGDP PROPOSED November 6,1998 l
RAC 97C238 (RI), 98C068 (RI)
- t l
The UF, primary system is required to provide integrity for the cascades and the supporting l
processes that handle UF.. This safety function is accomplished by retaining UF, primary system integrity t
'during normal operating temperatures / pressures.
l The UF. primary system in the enrichment cascade which is intended to operate above
[
atmospheric pressure is also required to maintain UF primary system integrity during evaluation basis l
natural phenomena events. The effects of evaluation basis natural phenomena events on the UF primary l
- system of the enrichment cascade in C-310, C-331, C-333, C 335, C-337, and the tie lines were evaluated. The results indicate that the UF primary system integrity is maintained in evaluation basis high wind and flood events. As indicated in the flood and high wind event scenarios in Section 4.3.2.5.1 and 4.3.2.5.2, the UF primary system will not have any significant UF, release during these evaluation basis 6
events. Some of the equipment and piping in the cascade facilities does not meet the performance criteria for the 250-yr return evaluation basis earthquake (EBE) (see Section 4.3.2.5.3). Tables 3.15-4 through 3.15-9 list the equipment, piping, and components with capacities less than the EBE for buildings C-310, C-315, C-331, C-333, C-335, and C-337. For each item, the seismic capacity, annual probability of failute, location, and comments are provided. The capacities reported in the tables are the capacities of i
the weakest member (s) whose failure could potentially cause a UF, release in the process gas systems.
These items were evaluated further to determine if a loss of pressure boundary was likely and to estimate the hole size that would result, if the pressure boundary was breached. Equipment, piping, and components with capacities less than the evaluation basis earthquake but that still maintain pressure boundary integrity are noted in the tables with an asterisk (*). In addition, potential seismic interactions of the cell housings and the stage compressors were evaluated. Failure of the cell housings did not adversely impact a UF pressure boundary.
The analysis of the ear:hquake event in Sectica 4.3.2.5.3 assumed fa!!ure cf the remaining components listed in the tables (i.e., those without an asterisk). The portions of the enrichment cascade operating above atmospheric pressure may release some UF, whi!e the p rtions cpera:ing at subatmospheric pressure will result in inleakage with a negligible loss of UF., The most significant failures associated with this event are failures at the booster stations that supply the tie line between the l "000" and "00" buildings. These failures were evaluated in the earthquake event scenario in Section 4.3.2.5.3, and the' potential consequences were assessed. With the exception of the failures l
identified and evaluated, the portions of the enrichment cascade that are intended to operate above atmospheric pressure will accomplish the safety function of not having gross failures of the UF. primary system integrity in evaluation basis natural phenomena events. For the portions of the enrichment cascade l that are operated only at subatmospheric pressure, the purge cascade, and the Hortonspheres, the capacity to retain their UF pnmaty system integrity is not required in evaluation basis natural phenomena events.
This is based on the subatmospheric pressure and minimal releases should the UF. primary system fail.
Based on these evaluations, the UF. primary system can accomplish the required safety functions with the exceptions noted.
3.15-20 f
I
- - -....~
SAR-PGDP PROPOSED November 6,1998
! p RAC 97C238 (RI), 98C102 (RO)-
3.15.3.7.2' High Pressure Datum System 3.15.3.7.2.1 Safety Function l
The high pressure datum system provides precise control of cascade pressure and provides the pressure information necessary to calculate the inventory of the cascade when necessary.
3.15.3.7.2.2 Functional Reauirements e
See Sections 3.3.3.2 and 3.3.5.9, and the Fundamental Nuclear Materials Control Plan.
3.15.3.7.2.3 System Evaluation The high pressure datum system consists of three parts which provide the same function. The part of the datum system to be used is determined by the valving at the cell panel. The high side cell datum pressure indicators are at the cell panel for each individual cell. The unit high datum system has analog gages in the datum room and is not used if the freezer / sublimer datum system is operational. The freezer / sublimer high datum system pressure indicators are read at the freezer / sublimer datum panels.
3.15.3.7.2.4 System Classification This system is classified as AQ.
..n r!
~
3.15.3.7.2.5 Boundarv The AQ boundaries for the low datum pressure system are defined in Table 3.15-2.
3.15.4 Withdrawal Facilities 3.15.4.1 Withdrawal Station Isolation System -
3.15.4.1.1 Safety Function The withdrawal station isolation system shall be capable of isolating the withdrawal station to prevent exceeding the radiological /nonradiological EGs for the EBE category.
3.15.4.1.2 Functional Reauirements l
The withdrawal station isolation system includes (1) automatic UF. detection and isolation and (2) manual isolation. The system shall be designed in accordance with the following functional requirements to ensure the capability to accomplish the required safety functions:
g The system shall be capable of accomplishing the required safety function independent of the plant air supply.
l f
,i 3.15-27 i
l l
SAR-PGDP PROPOSED November 6,1998 q
RAC 97C238 (RI), 98C068 (RI)
In addition, the system is required to maintain UF primary system integrity during an evaluation basis earthquake and evaluation basis wind loading. The UF primary system was evaluated to assess its ability to withstand high wind and earthquake events. The results of this evaluation indicated that the UF.
primary system piping could withstand the wind loadings and any potential impacts from debris. The UF6 primary system was also evaluated to assess its ability to withstand an evaluation basis earthquake event.
l This evaluation showed that the system is capable of performing its safety function following an l evaluation basis earthquake.
Tables 3.15-8 and 3.15-9 address the seismic capabilities of the UF. primary system in the l withdrawal facilities. All capabilities less than the EBE occur in portions of the system containing l gaseous UF operating at subatmospheric pressure. As evaluated in Section 4.3.2.5.3, these do not j contribute to any source term from the withdrawal facilities.
3.15.4.5.4 System Classification The UF. primary system is required to:
Prevent a large release of UF to the atmosphere during normal operations; and Prevent a large release of UF. to the atmosphere during upset conditions not specifically related to failure of the UF. primary system.
A large release ofliquid UF has the potential to exceed off-site EGs if the UF primary system
[]
integrity fails. Therefore, the portions of the UF primary system that cou:d cennin !! qaid UF (e.g.,
V' condensers, accumulators, and piping downstream of the condensers) meet the criteria for classification asQ.
The process line failure at compression discharge event was evaluated in Section 4.3.2.2.11. The results indicate that consequences would remain below the off-site EBE EGs with only the building holdup function. Therefore, the portions of the UF primary system that contain only gaseous UF (e.g., piping upstream of the condensers, compressors, etc.) are required for on-site protection, not off-site protection, and are classified as AQ systems.
3.15.4.5.5 Boundarv The Q and AQ boundaries for the UF primary system for the withdrawal processes are defined 6
in Tables 3.15-1 and 3.15-2, respectively.
3.15.4.6 High Pressure Relief Systems See Section 3.15.3.4 for information on the safety function, functional requirements, system description, system evaluation, justification for system classification, and boundaries for this system for the withdrawal compression-loop coolant high pressure relief system for the withdrawal facilities.
l s
i s
V 3.15-32 l
1 l
SAR-PGDP PROPOSED November 6,1998 i
n RAC 97C238 (R1), 97C200 (RO), 98C116 (RO)
U 3.15.6.2.3 System Evnluation i
The required safety function is to not fail in a manner that causes UF primary system failure 6
(i.e., dropped cylinder) during normal operation, an evacuation of facility event, or natural phenomena j events. The cranes are designed for the loads they will handle during normal operation of these facilities.
Administrative controls require inspections of the cables, brakes, and other critical items to ensure that l the crane can operate correctly. (Refer to Chapter 1, Appendix A for commitments to ANSI standard l inspection and testing requirements). In addition, the cranes are designed so that when the controls are released (e.g., evacuation of facility event), only small compensatory movements occur due to momentum after the crane drive mechanism stops and brakes are applied but these movements have no safety significance. The cranes were evaluated to assess their ability to withstand natural phenomena events.
The analyses indicated that the cranes will not have any structural damage, will remain in place, and will not release their loads during an evaluation basis eanhquake and wind. Floods do not reach the elevation of the facility to threaten crane integrity.
Failure of the crane lifting components or load braking system while lifting a liquid-filled UF6 cylinder could result in dropping the cylinder and rupturing the cylinder. Therefore, a load test is performed periodically.
Engineering (i.e. limit switches, etc.) and administrative controls are also used with liquid UF6 cylinder handling cranes to minimize the risk of the cranes dropping a liquid cylinder, or similar weight load, on operating process equipment. The engineering controls for liquid handling cranes used in the various process buildings are discussed in Section 3.7.3.1.2. The administrative zone controls (such as
/3 for the feed facilities) are incorporated in the applicable procedures.
V The withdrawal facilities in C-310 and C-315 are each equipped with two bridge crances located on one runway. Both cranes in each facility are qualified for handling liquid-filled cylinders. However, administrative controls prevent simultaneous loading or operating of both cranes located on the same runway.
Based on the analysis, the cranes can accomplish the required safety function.
3.15.6.2.4 System Classification The liquid UF cylinder handling cranes are required to perform the following safety function:
6 Prevent dropping a liquid-filled UF cylinder that could result in a cylinder failure event.
6 The cylinder failure event is classified as an EBE whose consequences could exceed the off-site EGs if the cranes were to fail in a manner that resulted in the drop and failure of a liquid-filled cylinder.
Therefore, the liquid UF cylinder handling cranes meet the criteria for classification as a Q system.
6 3.15.6.2.5 Boundary The Q bandaries for the liquid UF cylinder handling cranes, including associated lifting 6
fixtures, are defined in Table 3.15-1.
p)
(
3.15-51 l
l
SAR-PGDP PROPOSED November 6,1998 RAC 97C238 (RI), RAC 97C236 (RO) 3.15.7.6 Onsite Warning / Evacuation Systems 3.15.7.6.1 Safetv Function The onsite warning /evt.cutation systems provide evacuation instructions or notification in the event of an incident requiring evacuation or sheltering of the plant personnel.
3.15.7.6.2 Functional Reauirements See Sections 3.12.3 and 3.12.5 and the Emergency Plan, Sections 5.4 and 6.2.
3.15.7.6.3 System Evaluation See Sections 3.12.3 and 3.12.5 and the Emergency Plan, Sections 5.4 and 6.2.
3.15.7.6.4 System Classification This system is classified as AQ.
3.15.7.6.5 Boundarv The AQ boundaries for the onsite warning / evacuation systems are defined in Table 3.15-2.
O V
3.15.7.7 Seisade Instrumentation 3.15.7.7.1 Safety Function The function of the system is to detect a seismic event and alarm, thereby alerting personnel as to the severity of the earthquake.
3.15.7.7.2 Functional Reauirements The displacement transmitters and seismic switches shall provide alarms in the C-300 central control facility during a seismic event.
3.15.7.7.3 System Evaluation l
Seismic switches and displacement transmitters provide information which is used to determine the ground acceleration and displacement during a seismic event. The displacement transmitters and seismic switches provide alarms in the C-300 central control facility.
3.15.7.7.4 System Classification This system is classified as AQ.
s) 3.15-61 t'
.1
SAR-PGDP PROPOSED November 6,1998 G
RAC 97C238 (RI), RAC 98C037 (RO) b 3.15.10.1.2 Freezer /Sublimers (F/S) DPCS High UF, Pressure Trip 3.15.10.1.2.1 Safety Function The DPCS high UF. pressure trip ensures that the fre.er/sublimers are not operated at pressures above a maximum limit of 18 psia. The maximum pressur ;gnit is one contingency against potential HF condensation (a source of moderation) and potential criticality.
3.15.10.1.2.2 Functional Reauirements The DPCS high UF. pressure trip shall place the F/S into cold standby, except that the UE vent valve is open, to reduce pressure.
3.15.10.1.2.3 System Evaluation See Section 5.2, Appendix A.
3.15.10.1.2.4 System Classification The DPCS high UF. pressure trip is classified as AQ-NCS.
3.15.10.1.2.5 poundarv The AQ-NCS boundaries for the DPCS high UF. pressure trip are defined in Table 3.15-3. The boundary applies to all the F/Ss in the cascade including Buildings C-331, C-333, C-335, and C-337 exposed to greater than or equal to 1.0 wt.%2"U.
3.15.10.1.3 Freezer /Sublimers (F/S) DPCS R-114/RCW Low Differential Pressure Trip 3.15.10.1.3.1 Safety Function The DPCS R-114/RCW low differential pressure trip ensures that water or UF is not introduced 6
l into the R-114 loop in the F/Ss. The R-il4 pressure is operated at least 2.0 psi greater than the RCW pressure. The introduction of water or UF, into the R-114 loop is one contingency against potential criticality.
3.15.10.1.3.2 Functional Reauirements The DPCS R-114/RCW low dinu caual pressure trip shall place the F/S into hot standby and alert the operator.
3.15.10.1.3.3 System Evaluation See Section 5.2, Appendix A.
?(
3.15-72 i
Table 3.18-1. Boundary Definition for Q Structieres, Systems, and Components (continued).
$>m nx
~,
. System Facility lloundary Definition Support Systems
,,n Liquid UF. Cylinder C-310 1.
Crane structure and structural supports, the crane -
No support systems are required. The h
IIandling Cranes (Sec: ion C-315
- rails, the bridge, the enechanical rail stops :st the end '
crane brake fails safe on loss of power.
L *O 3.15.6.2) of the bridge, the trolley rails, the trolley, and the 0
reeving.
W l
2 Two hoist brakes E
- 3. - Relays for boist brake control y
4.
Iloist motor contacts
'g L
5.
Geared up/down limit switch 6.
Two paddle-type limia switches 4
7.
Emergency stop button O-8.
Proximity switches 8
9.
Associated circuitry g
l 9.
Lifting fixture assemlity.
o
~
m
- 10. Wire rope legs
'If Liquid UF. Cylinder C-360 1.
Crane structure and suuctural supports, the crane No support systems are required. The W
IIandling Cranes (Section rails, the bridge runway, mechanical rail stops at the crane brake fails safe on loss of power.
k w
3.15.6.2) end of the bridge, and trolley rails. Each bridge crane O
is equipped with one polar trolley hoist, with redundant reeving and a double-block design.
U l
l 2.
Two hoist brakes 3.
Caliper brake j
4.
Geared up/down limit switch j
5.
Two paddle-type limit switches 6.
Emergency stop button 7.
Mechanical Continuity Monitor '
8.
Lifting fixture assembly.
9.
Wire rope legs 6
l Z
.E 1
9
?
I t
[
g 00 6
I i
I P
m.
m m
m m
O O
O Table 3.15-2. Boundary Definition for AQ Structures, Systems, and Components (continued).
$m>
ax
~
System Facility Boundary Definition Support Systems
,.e Criticality Accident Alarm C-710 The Criticality Accident Alarm System boundary includes c
l System (Section 3.15.7.1)
C-709 the following:
w
- O 120 VAC power - Required for the
- 1. Radiation detector cluster units consisting of -
cluster's power and the CAAS horns to W
- a. Three gamma detector modules, function. The cluster upon loss of 120 9
- b. Cluster logic module, VAC power is provided with battery 3
- c. Cluster housing, backup and is therefore fail-safe. Also g
8
- d. Backup battery for the cluster, required for the C-709 and C-710 uO
- e. Associated wiring between the clusters and alarm building horns power. - Power is horns, and; provided by an uninterruptible power 3
f.
120 VAC power to and including the supply supply and is therefore considered fail.
O breaker safe. -
N i
O
-e O
en (T!
O r
L k
b Eo9?
,O 00 12
j'+ -
l x;..
s T
TaNe 3.15-2. Boundary Definition for AQ Structures, Systents, and Consponents (continued).
'ox System -
1:acility lloundary Definition Support Systems e
Criticality Accident Alarm.
- 2. Alarm horn unit (buikling evacuation including slaved 48 VDC power - for supervisory a
System
- buiklings) circuits inonitoring CAAS status and b
_ 'O --
1 (Section 3.15.7.1)
- a. C-710 Buikling horns including:
powered by the C-300 48 VDC circuit.
1 (Continued).
e i electronic horns,
'M 24 VDC power to and including the supply 24 VDC power - Required as backup -
~E a
- breaker, support for actuation of the building.
3
- '120 VAC power for the horns including the horns and is provided in C-710.' Loss g
t supply breaker, and; of 24 VDC power is annunciated in C-x l
uninterruptible power supply for the alarm horns 300 CAAS console.
f
'f
- h. C-709 electronic horns.
_C W
i
- 3. Radiation Alarm Cabinet in each buikling consisting of
- a. Relay from the clusters, and; f
l
- b.. Relay to actuate the building / slave horns.
I
- u
- 4. C-300 annunciation system including N
- a. 48 vok power supply from the radiation alarm
.o.
n annunciator cabinets to the first breaker, O
- b. less of power relays,
- c. Loss of power indication on the C-300 console, O
and; I
- d. Building horn control switch 1
.i E
2:
E i
o I
3 i
a".
I 0
~
t Ch t
w-1
~
t f
13 t
r i-i t
,m
,m m
I i
(V
[U
\\
i v
Table 3.15-2. Boundary Definition for AQ Structures, Systerns, and Cotuponents (continued).
N>g an System Facility lloundary Definition Support Systems e4 4O Onsite Warning / Evacuation The plant PA system boundary includes:
120 VAC supphes the internal PA Og Systems (Section 3.15.7.6) amplifiers and the external pole I$*U
- l. Speakers mounted PA systems battery charging j
- 2. Control consoles circuit and the non-process building W
- 3. Amplifiers evacuation horns. Loss of 120 VAC E
- 4. Power sources power renders the internal PA system
- 5. Wiring included in the plant wide PA system and the non-process building evacuation g
6 120 VAC power supply back to the first breaker horns in-operable ar.d prevents charging the external PA system batteries.
4 The building evacuation alarm system boundary includes O
125 VDC power supplies power for the
- l. Ilm m building horn solenoid valves for the g
- 2. Concret cabinets process buildings.
O
- 3. Control e usoles
- 4. Power and utility supplies and wiring necessary to Plant air supplies the building provide an evacuation alatm to the cascade buildings evacuation horns. Loss of air renders O
and other facilities where the PA system is not the system inoperable. The air system 3
effective.
is supplied from a plant air header with y
5.125 VDC supply back to the first breaker multiple compressors.
p
- 6. Plant air back to the accumulator
- 7. 24 VDC supply back to the first breaker 24 VDC power from the batteries supplies power for the external PA system amplifiers, circuits and speakers. If the batteries fail, these is no powei Mr the external PA system.
Seismic Instrumentation C-300 (Section 3.15.7.7)
C-335
- 1. Displacement transmitters C-335
- 2. Associated circuitry, readouts / alarms located in the
- Z ACRs, and the alarm in C-300 125 VDC (Illdg. Battery bank or g
l
- 3. Two triaxial seismic switches located in each "00" rectified AC) powers the displacement 3
building and associated alarm circuitry to C-300 transm tters T
- 4. Power supplies and relay panels
[
5.120 VAC power back to the first breaker 6.125 VDC supp!y back to the first breaker G$
21
,m
\\b Table 3.15-2, Boundary Definition for AQ Sintctures, Systems, and Components (continued).
hm>n System Facility lloundaiy Definition Support Systems a%
e Chlorine System (Section C-611-B, The vacuum regulator and chlorine leak detectors and 120 VAC power for the chlorine Oh 3.15.8)
C-611-S, associated alarms.
release detection system ti T and C-615 C
3 C 631-1, All piping components including flexible connections, pipe, 9
C-633-3, valves up to and including the vacuum regulator and y
C-635-1, chlorine Icak detectors, and associated alarms.
and O
e C-637-1 120 VAC power from the release detection system back to os the first breaker.
O e
CIF, System (Section 3.15.8)
C-350 The distribution piping from the chlorine trifluoride storage
??O VAC power for the CIF alarm W
3 tank including the flexible connection, pipe and valves.
system 38 The instrumentation that controls the tank pressures to less Air for the CIF detection system.
3 y
than atmospheric pressure.
M Steam for the Condensate Tank and the O
y The chlorine trifluoride leak detectors and associated Condensate Tank Cooling Water O
alarms.
(Sanitary & Fire Water System) is part of the CIF, detection system. The O
120 VAC power from the alarm system back to the first steam is condensed in the Condensate breaker.
Tank to fill the tnixing chamber, and mixed with the air samples. l.oss of Air from the CIF3 detection system back to the first steam and cooling water results in a accumulator.
non fail-safe condition.
Steam supply back to the first isolation valve.
Cooling water supply back to the first isolatirm valve.
F System (Section 3.15.8)
C-410-D The fluorine storage tanks and distribution piping including 120 VAC power for the fluorine release
[
3 the flexible connection, pipe, valves, and relief devices.
detection and alarm systems N9 o~
Fluorine leak detectors and associated alarms.
g 120 VAC power from the release detection system back to
~as the first breaker.
8 oo 22
-e.
~
(
(
(
1 GI
\\_,)
L' Table 3.15-2. Boundary Definition for AQ Structures, Systems, and Cotuponents (continued).
Nm>
nN System Facility Boundary Definition Support Systems ey L*h Enrichment and Purge C-310
- 1. Foundations No support systems are required.
Cascade and Product anct C-310-A
- 2. Base plates c
Tails Withdrawal Facility C-315
- 3. Building frames Structures (Section 3.15.9.1)
C-331
- 4. Column anchorage N
C-333
- 5. lead bearing walls 9
C-335
- 6. Reinforcing tees e
C-337
- 7. Bracing 8
- 8. Seismic expansion joints (gaps between floor sections) 8
- 9. Connections
- 10. Supports foi important to safety piping 3
- 11. Transite siding at the cell floor and O
above l
- 12. Roof Feed and Toll Transfer and C-333-A
- 1. Foundations No support systems are required.
.e Sampling Facility Structures C-337-A
- 2. Base plates N
(Section 3.15.9.1)
C-360
- 3. Building frames
- 4. Column anchorage O
- 5. Load bearing walls
- 6. Reinforcing tecs C
- 7. Bracing l
- 8. Supports for important to safety piping Cell Floor Process Building C-310
- 1. Bridge crane rails and structural supports for the C-No support systems are required.
Cranes (Section 3.15.9.2)
C-315 310. C-315. C-333 and C-337 cranes parked over unit C-333 bypass piping or Normetex pumps C-337 Cascade Equipment C-310 For housings over cells or interhuilding booster stations No support systems are required.
Ilousings (Section 3.15.9.3)
C-331 that are intended to be operated above atmospheric C-333 pressure:
7 C-335 9
C-337
- 1. Steel frame surrounding UF. primary systems.
g
- 2. Transite or sheet metal panels attached to the framing.
g n
O 00 23
.b)
V-U C5 a=
3o
'O o wm Table 3.15-8. Seismic Capacities of Buil-8ings C-310/C-310-A Piping, Equipment and Components.
Equipment, piping and Seismic Annual probability of Y
f components capacity, g failure Location Comments o
Piping between cells
<0.05g
> 5.4 x 10 '
C-310 cell Weak or missing support g
Cell bellows
<0.05g
> 5.4 x 10~'
C-310 cell Building relative movements may tear bellows N
Bellows SX-5/9/10/12
<0.05g
> 5.4 x 10 '
C-310 bypass Bellows may tear due to unrestrained piping Bellows SX-6*
0.12g 1.3 x 10.s C-310 bypass Same as above Be!!aws OX-2/4/5/6
<0.05g
> 5.4 x 10 '
C-310 bypass Same as above T
C-310 bypass Duilding relative movements may tear bellows Wo Anchor types 90 & %
<0.05g
> 5.4 x 10 '
C-310 bypass Weld deficiency I
I M
i U
1 I
I I
E i
I i
I I
- Pressure boundary is not likely to be adversely effected.
i All other equipment, piping, and components had capacities equal to or greater than the E13E.
Z Sn 5
wk 9,
b t
. /~y
-p ry A) d b
. n >v1
>(
] o.
Table 3.15-9. Seismic Capacities of Building C-315 Piping, Eqisipment and Components wOo.
44 Annual
-g*
Equipment, piping, and Seismic
. probability of g
components Location capacity, g failure Comments p
i No I
8 co I
9
~
1 l
i TW O
T I
o tn m
Process piping Ilortonspheres
<0.10g
< l.9 x 10 8 Ilortonsphere rmi fails and attached piping l>reaks or o
sphere ruptures All other equipment, piping, and components had capacities equal to or greater than the EBE.
t i
e r,
9
?
i
~
?
f N
i t
[
f i
i
.'p)..
(J d-q.
5's Table 3.15-10. Natural Phenomena Capacities of Buildings.
]Y
. O 'a o
Wind to c
Seismic (note 1)
OK>70 mph (113 km/hr)
Structure-OK > 0.15g Structure Components Flood p
C-300 OK OK OK OK-2 h
l_
C-310/310-A 0.1
- 0.15' OK' 50 OK l. C-315 0.06
- 0.15 65 50 OK' f:c C-331/335 OK (note 3)
OK 50 (note 2)
Inicakage (note 4)
O l
C-333/337 0.1
- 0.15 OK
' 50 Inicakage (note 4) '
l.
C-333-A/337-A 0.1 -+ 0.15 OK 50 OK C-360 OK OK 45 (note 5)
OK y
C-44'X) 0.05
- 0.15 OK OK-CK h
C-409 OK OK OK OK C-710 OK OK OK OK C-720 0.12 -+ 0.15 OK OK OK C-746-Q OK OK OK OK Tie lines 0.12
- 0.15 OK OK OK Notes 1.
Range indicates onset of yield with structural integrity to at least the high value 2.
Structural modifications specified by CP Issue 36 assumed to be completed 3.
Siding pulled off 4.
Roof ponding 5.
Roof decking pulled off b
a
?
E
[
-$5 ne a Table 4.2-7. Facilities Included in the SAR Review.-
-33 n o Nuclear hazard PrIIA PSOA -
UN-Facility Name Screen in?
= category '
required?
required?
a -
so C-203 Emergency Vehicle Shcher No N/A.
No No.
y
.C-205 Respirator Issue Building -
No N/A No..
No C-2%
Pump Draflor Pit No N/A
.No-No ia -
1 C-206-A Storage Trailer -
No N/A No No g-C-206-B Smoke Training Facility No N/A No No O
P C-207 Fire Training Facility No N/A No No C-212 Office Building No N/A-No No C-212-A Main Guard Post (Gate 15)
No N/A No No y:c C-215 Portals 18 & 19 No.
N/A.
No' No O
C-216 Post 47 No N/A
. No No I
C-217 Post 43 No N/A No No o ~
C-300 Central Control Building No N/A No No C-300-531 Instrumentation Tunnel Yes Radiological No No' C-300-533 Instrumentation Tunnel Yes Radiological No No' C-300-535 Instrumentation Tunnel
- Yes Radiological No.
No C-300-537 Instrumentation Tunnel Yes.
- Radiological No No C-302 Cascade Operations Data Center No N/A No No-C-303 Supervisory Control and Data Acquisition Systems Building No N/A No No 7
C-304
. Training and Cascade Offlee Building No N/A No No-h f
j C-304-T-01 Temporary Oflice No
-N/A No No C-310 Purge & Product Building Yes.
Category 2 Yes Yes h
C-310-331 Enclosed Bridge Yes Radiological No No i
C-310-33 I Tie Line Yes Category 2 Yes Yes 00 i
C-310-410 Tie Line Yes Category 2 Yes Yes l
Continued.
t t
2 i
}
. ~
v h
-t oP-1-
Table'4.2-7. Facilities Included in the SAR Review.
.$3' o e i
.. Nuclear hazard -
PrHA
. PSOA -
i35 Fac.lity.'
Name Screen. ?
i.
m w.
category :
required?
required?
t
--W i
C-615-G.
Sewage 1.iR Station No N/A -
No Na-
. F.
l-C-615-Il Sewage LiR Station No N/A~
No No 2
I C-615-Ill Sewage Lift Station.
No N/A No' No-w.
C-615-II2
. Sewage 1,in Station -
No-N/A No No.
g l
C-615-J Chromate Lift Station (Abandoned)
No N/A No-No
'8 C-615-K
- Chromate Lift Station (Abandoned)
' No N/A
.No-
. No' C-615-L Oil Control Monitoring Station -
No N/A No-No 9
C-615-M Oil Control Structure No N/A No.
No-7 m
W C-615-N Oil Contaminated Lagoon No N/A No
. No O
-i C-615-0 Oil Control Duilding No N/A ~
No No m
C-616 Liquid Pollution Abatement and Appurtenant Structures Yes N/A No No O
C-616-A Chemical Feed Building Yes N/A No No j
C-616-Il Clarifier Yes N/A No No C-616-C Lin Station Yes N/A -
No No C-616-D Studge Lagoon and Valve Pit Yes Radiological No No I
C-616-F Full Flow I.agoon Yes N/A
. No No
?
C-616-G Sulfuric Acid Tank Yes N/A Yes Yes 7-h l
C-616-Ill FeSO4 Storage Tank (East)
Yes N/A No No C-616-II2 FeSO4 Storage Tank (West)
Yes N/A No No h,
[
4 C-616-J Reduction Tank Yes N/A No No p
7 C-616-K Service Building Yes' N/A No No i
8 i
Continued.
Co k
9'
. ~. - ~
. - -... -. - - - - - - = - - - - - - - - - - - - - - - - - - - - - - - - ' - - - - - - - - - - - - - - -
SAR-PGDP PROPOSED November 6,1998 p
RAC 97Cl24 (RO), RAC 97C200 (RO) s Based on the above essential controls, the resulting important to safety SSCs and TSRs are as follows:
The UF, cylinders, autoclave steam pressure control system, autoclave water inventory control system, autoclave high pressure isolation system, and the autoclave shell and associated isolation valves are identified as important to safety SSCs. See Section 3.15 for details including safety classification.
TSRs are provided for the UF, cylinders, autoclave steam pressure control system, autoclave high pressure isolation system, autoclave water inventory control system, and administrative requirements for procedures and training of workers for evacuation actions.
4.3.2.2.15 Cylinder Failure Outside Autoclave (Primary System Integrity) a.
Scenario Description During feed, transfer, sampling, and withdrawal operations, handling and moving liquid-and solid-filled cylinders is a nonnal operation. During cylinder moving operations outside of the autoclaves, it is possible that the cylinder could suffer a physical integrity failure that could result in a large UF.
release. The physical integrity failure can be caused by initiators such as dropping a liquid-filled cylinder, dropping a heavy component onto a liquid-filled cylinder, filling a cylinder contaminated with hydrocarbons, or impact from a vehicle. After an accidental drop of a liquid-filled cylinder at PORTS (see Section 4.3.1.2.3.1.2), various preventive controls (operator training, crane design and inspections, etc.) were instituted at both GDPs to reduce the probability of occurrence for this event. Based upon these preventive controls, an integrity failure event of a liquid-filled cylinder (i.e., liquid cylinder drop) occurring outside of an autoclave is classified in the EBE frequency category.
This scenario evaluates a physical integrity failure of a liquid-filled cylinder outside of an autoclave (specifically dropping a liquid-filled cylinder). The initial conditions assumed in the analysis of this event are as follows:
Initial temperature in the cylinder is conservatively 240*F (116*C), which is controlled by the autoclave steam pressure control system for autoclave facilities (withdrawal facilities operate at much lower temperatures and no control is required);
The following administrative controls are in place:
1.
Liquid UF cylinder handling cranes are inspected daily (prior to first use) for obvious 6
defects associated with the lifting system; 2.
The dual liquid UF handling cranes located in each of the withdrawal facilities are not 6
loaded or operated at the same time; 3.
No cylinder or similar weight load is moved over a cylinder containing liquid UF, (toll transfer and sampling facility and withdrawal facilities only);
l 4.
No liquid-filled cylinder is moved over a closed autoclave housing a cylinder containing liquid UF (feed facilities only);
[
5.
No cylinder or similar weight load is moved over the heated housings and common UF, primary system piping between the autoclaves (feed facilities only);
l 6.
Only approved cylinder handling equipment is used by qualified operators for maneuvering cylinders and other heavy loads; l
7.
Cylinder cleaning requirements conform to ANSI N14.1 for cylinder cleaning; i
l l
,V 4.3-116 i
i i
SAR-PGDP PROPOSED November 6,1998 fs RAC 97Cl24 (RO), RAC 97C200 (R0) l 8.
Cylinders to be filled with UF are verified as passing a current (within 5 years) 6 hydrostatic pressure test; l
9.
Cylinders containing liquid UF are staged in a designated area until solidified (this area 6
is restricted so that routine vehicle traffic is not allowed-vehicles are required to support certain maintenance evolutions); and l
10.
UF cylinders to be filled or heated are inspected for obvious damage that could threaten 6
their ability to withstand normal filling, heating and moving.
The physical integrity failure even of a liquid-filled cylinder outside of an autoclave was evaluated for the withdrawal facilities, the feed facilities, and the toll transfer and sampling facility.
These evaluations determined that a significant release of UF could occur if the administrative 6
controls / design controls fail to prevent a failun of the cylinder's primary system integrity. The liquid-filled cylinder drop scenario is considered a limiting event for the primary system integrity failure and the EBE frequency category.
The primary concern associated with this event is the release of liquid UF. The applicable EGs 6
(see Table 4.2-2) associated with this event are EF. and 2, as well as EG 6 in the EBE frequency range. EG 3 would not apply since the cylinder's i 1 '.ty is defined to fail in the scenario description and no other contamment is provided for this type of event. The essential safety actions associated with meeting these EGs for a cylinder failure outside an autoclave include detection of the release and emergency response to evacuate the immediate vicinity and downwind locations to minimize on-site /off-site personnel exposure.
/
V b.
Source-Term Analysis A source-term analysis simulated dropping of a type 48G thin-wall tails cylinder containing the maximum permissible quantity of 28,000 lb (12,700 kg) of liquid UF at 240*F (ll6*C) [as specified in 6
ANSI N14.1]. The cylinder is assumed to be dropped as it is being moved outdoors which results in a physical integrity breach developing at the bottom of the cylinder. The liquid UF inside the cylinder is 6
assumed to be at 240*F (116*C) with an associated vapor pressure about 6 times atmospheric [88 psia (0.61 MPa)]. The release duration is assumed to be fixed at 5 min (300 s). The average liquid UF6 release rate is approximately 93.3 pounds per second (42.3 kg/s). To obtain this release rate with 88 psia (0.61 MPa) internal pressure, the breach would have an effective diameter of 2.75 in. (0.07 m). The presence or absence of noncondensable gases is not significant in this case because the breach diameter is calculated from a fixed release duration (i.e.,300 s), not vice versa.
As the liquid UF is released, 62.5 percent [17,500 lb (7900 kg)] would be flashed to vapor and 6
the remaining 37.5 percent [10,500 lb (4800 kg)) is assumed to become entrained solid UF. Both the 6
vapor and the solid are approximated to be at the equilibrium temperature of 134*F (56.6*C) at I atm (0.101 MPa). The release is assumed to be just above ground level and pointed directly toward the ground (i.e., the released UF would have no net horizontal velocity). The released UF is assumed to 6
be 1.0 percent SU, by weight, the maximum enrichment allowed in a type 48G tails cylinder.
f O) 4.3-117 (v
SAR-PGDP PROPOSED November 6,1998 RAC 97Cl24 (RI), 97C200 (RO)
(n) w/
2.
The dual liquid UF. handling cranes located in each of the withdrawal facilities are not loaded or operated at the same time; 3.
No cylinder or similar weight load is moved over a cylinder containing liquid UF6 (toll transfer and sampling facility and withdrawal facilities only);
l 4.
No liquid-filled cylinder is moved over a closed autoclave housing a cylinder containing liquid UF6 (feed facilities only);
}
5.
No cylinder or similar weight load is moved over the heated housings and common UF6 primary system piping between the autoclaves (feed facilities only);
j 6.
Only approved cylinder handling equipment is used by qualified operators for maneuvering cylinders and other heavy loads; 7.
Cylinder cleaning requirements conform to ANSI N14.1 for cylinder cleaning; 8.
Cylinders to be filled with UF6 are verified as passing a current (within 5 years) hydrostatic pressure test; l
9.
Cylinders containing liquid UF6 are staged in a designated area until solidified (this area is restricted so that routine vehicle traffic is not allowed-vehicles are required to support certain maintenance evolutions); and l
10.
UF. cylinders to be filled or heated are inspected for obvious damage that could threaten their ability to withstand normal filling, heating and moving.
Autoclave steam pressure control system - maintain initial condition (normal operation, EG 5 only);
Liquid UF6 handling cranes - maintain primary system integrity (EGs 1 and 2);
Operator training for required actions - evacuate area of releases (EGs 1 and 2 only).
Based on the above essential controls, the resulting important to safety SSCs and TSRs are as l
)
ff.'ows:
L/
The autoclave steam pressure control system and liquid UF handling equipment (cranes, scale 6
carts, C-360 elevator and levelator) are identified as important to safety SSCs. See Section 3.15 for details including safety classification.
TSRs are provided for the autoclave steam pressure control system, liquid UF6 handling cranes, scale carts, C-360 elevator and levelator, and administrative requirements for procedures and training of workers for cylinder handling requirements and evacuation actions.
4.3.2.2.16 Large Fire (External Event) a.
Scenario Descrintion During operations associated with withdrawal, feed, toll transfer, sampling, and cylinder handling and storage operntions, the potential exists for fires to oNur. Small fires can be caused by welding and burning operations, electrical failures, vehicle acciderr.s, etc. The withdrawal operations are performed in the process buildings that house lube oil and the associated fire-related concerns are addressed in the large fire event for the cascade facilities (see Section 4.3.2.1.9).
The feed and toll transfer facilities do not contain any significant quantities of flammable or combustible materials. An assessment of these facilities concluded that an unmitigated fire would not compromise pnmary systems integrity or result in a release of UF6. In addition, an unmitigated fire will not threaten the structural steel or the steel roof decking to cause collapse of these buildings. The assessment did not credit the sprinkler systems or manual fire fighting capabilities for the feed and toll G
4.3-126
()
l
_ _ _ ~ _ _ _ _ _ _. _..
i SAR-PGDP PROPOSED November 6,1998 RAC 97Cl25 (RO), 98C068 (RI)
All facilities that process or store significant quantities of UF. were analyzed for seismic effects up to the evaluation basis earthquake. All facilities have structural capacities at least equal to this peak ground acceleration.' Capacity is defined as no building collapse.
Equipment whose failure could directly result in a release of UF. was also analyzed. This equipment includes supporting equipment not directly containing UF., such as overhead cranes, scale carts, and autoclaves, that if not retained in position, could impact UF systems. This evaluation 6
determined that a number of components have less than the evaluation basis capacity. Weak links were identified only in the process buildings and the withdrawal facilities. These areas are considered below.
b.
Cascade Process System Confinement Failure i
Two cases were analyzed for this event: (1) maximum cascade power of 3040 MW and (2) operating cascade power of 2200 MW. Case 1' evaluated cascade operations with an extensive portion of
'l the cascade running above atmospheric pressure, which would produce the largest releases. This power level is the maximum design power level for the cascade but is no longer possible without a major upgrade of equipment. Operation at significantly above 2200-MW would require capital improvements to the plant. Current demand does not justify these expenditures, and operation above this level is currently considered unlikely. Case 2 evaluated cascade operations at 2200 MW with most of the cascade running below atmospheric pressure. This power level is more representative of current cascade operations, which typically range between 1100 MW and 2000 MW.
Depending on operating pressures and power level, the main process buildings contain as much as 650,000 lb (295,000 kg) of UF in each "000" building and as much as 150,000 lb (68,000 kg) of UE 3
in each "00" building at 3040 MW. The pressure gradient varies throughout the cascade and directly impacts any potential response to a seismic event. The equipment evaluations cited above included location-specific considerations as they relate to system operating pressures.
In general, the weak links in the cascade piping are the expansion joints. The typical seismic failure mechanism for these components is displacements in excess of capacity. For the "00" cascade buildings, the potential equipment failure locations based on engineering evaluations are indicated in Figure 4.3-33. In the "000" buildings, all failures occur near the B stream booster pump stations.
l The failures predicted at the withdrawal facilities either do not involve UF (i.e., fire protection ll piping) or else occur in piping and equipment that contains gaseous UF operating at subatmospher 6
pressure. Therefore, no UF release is postulated for the withdrawal facilities.
6 l-l l
!~
'The modifications to Buildings C-331 and C-335 that are described in DOE /ORO-2026, Plan for Achieving Compliance with NRC Regulations at the Paducah Gaseous Diffusion Plant, Issue 36, Seismic Capa Buildings C-331 and C-335, have been credited in this analysis.
(V 4.3-138 l
o 4
SAR-PGDP PROPOSED November 6,1998
. /]
RAC 97C125 (RO),98C068 (RI) l L!
l I
I All failures were assumed to occur simultaneously as a direct consequence of the seismic event.
l Because release conditions are maximized through the operating power assumption, the consequences are l
judged to be conservative from a complete site perspective.
c.
Source-Term Analvsis The source-term analysis of these cases was based on the structural and equipment evaluations of the main process and auxiliary buildings described above. Potentially significant UF. source terms are associated with estimated damage to the enrichment cascade, located in the "00" and "000" process l buildings (Buildings C-331 and C-335 and Buildings C-333 and C-337, respectively).
The source-term analysis is presented for both 3040-MW and 2200-MW operating power levels.
l The pressure gradients used were based on typical operation at these power levels, using a reason l
combination of product, feed, and tails flow rates and assays. The actual gradients in use at any specific power level depend on cascade conditions such as recent and projected power levels, available eq and the current product, feed, and tails streams. For most operating conditions, the 2200-MW power leve l
would limit above-atmospheric pressure to the "000" buildings, while at the 3040-MW level, above-atmospheric pressure would occur in both the "00" and "000" buildings. Typical cascade pressure profiles for these two power levels are included in Figures 4.3-34 and 4.3-35 (3040 MW) and Figu g
4.3-36 and 4.3-37 (2200 MW).
(v)
The remainder of this source-term discussion describes estimated source terms that l
in the (1) 3040-MW case and (2) 2200-MW case.
Source-Term Analysis-3040-MW Case. Source-term parameters for the 3040-MW case are listed in Table 4.3-11. The source-term analysis discussion for the 3040-MW case identifies failures from l
, the process buildings.
The estimated failures in each of the "000" process buildings occur where the tie lines from the l
"00" process building enter and connect to the "000" equipment. Each tie line consists of four pipes (two A lines and two B lines). One A-B pair connects the bottom "000" unit with the st section of the "00" building, and the other A-B pair connects the top "000" unit to the enricher section of the "00" building. For the 3040-MW case, both of the B lines would be above atmospheric pressure.
Seismic evaluations indicate that breaches of both an above-atmospheric-pressure B line and a belo atmospheric-pressure A line may occur in approximately the same location. Because the A are simultaneously severed, UF would flow from the B lines while air flows into the A lines. Withi few seconds, the stages feeding the holes in the B lines would partially fill with air, and the supply i
breach would become a mixture of UF and air.
.a i 4.3-139
- V
I' SAR-PGDP
- PROPOSED November 6,1998 RAC 97C125 (RO),98C068 (RI)
Additional failures in the."00" buildings include the cell-bypass A line between Cells 7 and 9 and Cells 10 and 8 in each of the four units in each building. These A-line failures are below atmospheric pressure and would result in no release. One specific stage in Building C-331 has also been identified as a possible damage site, Stage 1 located in Cell 3 of Unit 4 in Building C-331 could lose the compressor discharge expansion joint. This cell is located near the top of the enricher and would be below l
atmospheric pressure even at 3040 MW and, therefore, would not result in a release into Building C-331.
1 I
1 i-l l
I-f%
! \\ -
p
[
L i
j.
l l
l.
j a
4.3 141 Is i'
1
. _ _ _ _ - _. ~ _. _ - _ _ _ _ _ _ _. _ _. _ _ _ _ _
l SAR-PGDP PROPOSED November 6,1998 RAC 97Cl25 (RO),98C068 (RI)-
I l
I l
Source-Term Analysis-2200-MW Case. Source-term parameters for the 2200-MW case are listed in Table 4.3-12. The source-term analysis discussion for the 2200-MW case identifies failures from L
the process buildings.
.l-
' The identified failures in the process building would be the same as those described for the'3040-MW release scenario, except that both the A and B lines would be below atmospheric pressure. With the process operating below atmospheric pressure, air will flow into the severed lines. Past experience with large air leaks into the cascade shows that with a sizable leak, air will displace the UF. in that region of the process, creating a " bubble" oflight gas. Compressors within the bubble will surge as the density of the gas they are pumping drops. The reaction between UF, and the moisture in the air takes place at the air-UF. interface and is rather limited by the lack of mixing between air and UE inside the process.
l' Given the large volume of the cascade, a large volume of air will flow into the process unless the leak l
is stopped. After the flow is halted, UF or its reaction products (UO F and HF) slowly drift back to the 2
l-vicinity of the hole. Because of these characteristics, the severed ends of the below-atmospheric-pressure tie lines would not cause any appreciable release into the process buildings, except for the UF, contained j
l-in the tie lines that would flow out under the influence of gravity.
For the 2200 MW case, the amount of UF. in the tie lines is less than that for the 3040-MW case because of the lower operating pressures in the cascade. Approximately 1200 lb (545 kg) of UF. vapor
/
would be contained in the tie line connecting Building C-331 to Building C-333, half of which [600 lb (273 kg)] would flow into each building. The release would occur over a 10-min period, yielding an average release rate into each building of 60 lb/ min (0.46 kg/s). The release rates of the reaction products from Buildings C-331 and C-333 would be 41 lb/ min (0.31 kg/s) for uranium and 14 lb/ min (0.10 kg/s) for HF.
About 800 lb (363 kg) of UF vapor would be contained in the tie line connecting Building C-335 6
to Building C-337, half [400 lb (182 kg)] of which would flow into each building. The release would occur over a 10-min period, yielding an average release rate into each building of 40 lb/ min (0.3 kg/s).
The atmospheric release rates of the reaction products from Buildings C-335 and C-337 would be 27 l
^ lb/ min (0.21 kg/s) for uranium and 9.1 lb/ min (0.068 kg/s) for HF.
.l l
d.
Consequence Analvsis l
l L
Figure 4.3-38 shows the building locations where UF releases are postulated to occur after an l
evaluation basis seismic event. Also shown in this figure is the wind direction used to estimate
[
consequences. The southerly wind direction was selected for several reasons. It is the predominant direction at the site and would be the most likely wind direction in a seismic event. Also, the nearest site boundary is almost due north of the buildings (i.e., in the direction a southerly wind would carry
'I 4.3-142 v
F
_~
SAR-PGDP PROPOSED November 6,1998 m
RAC 97C125 (RO),98C068 (RI) contaminants). Finally, the buildings from which the releases would occur are roughly aligned along a north-south axis With a southerly wind, releases occurring simultaneously from these buildings would appear as a single plume from the viewpoint of a downwind receptor. Therefore, consequence estimates for a southerly wind would be higher than for an easterly or westerly wind, for which the plumes would initially be separated so that their near-centerline concentrations would not be additive. For this analysis, all the releases were conservatively assumed to occur precisely along the same north-south axis (i.e.,
absolutely no spreading of the source locations in the crosswind (east-west) direction, even though the individual sources are not so neatly aligned]. This assumption results in slightly higher consequence estimates because some initial plume spread in the crosswind direction is ignored.
Dispersion parameters used to derme the baseline scenario are listed in Table 4.3-13. For the seismic release event, typical meteorological conditions were selected to estimate consequences for the baseline scenario. The most frequently occurring meteorological condition at PGDP is D4 (stability class D, neutral, and wind speed of 4 m/s), which occurred 14.9 percent of the time on an annual basis. Other meteorological conditions that occur less frequently but result in higher consequence estimates were not chosen to represent baseline conditions because of the relatively unlikely occurrence of an evaluation basis earthquake at the site in conjunction with worst-case wind conditions. A less likely meteorological condition combined with an unlikely seismic event would lead to a release scenaric that is much less credible. However, for the purposes of comparison, consequence estimates for a much less favorable meteorological condition (F3) are presented later in this section for comparison.
A typical summer daytime temperature of 80*F (26.7'C) under stability class D was used for the Q
baseline scenario. An ambient relative humidity of 70 percent was selected for the baseline scenario b
because this value represents a maximum relative humidity at an ambient temperature of 80'F (26.7 C).
In 1992, the maxunum relative humidity recorded at PGDP for ambient temperatures of 80*F and above was about 71 percent.
The process building releases were conservatively simulated using the UF MIXER model (see 6
Section 4.3.1.2.3.4) and assuming that the plume would be released to the atmosphere at ground level through a hole in the building side created by a seismic event. The temperature of the UF released into 6
the process buildings was set at 290*F (143'C), with release durations to the atmosphere assumed to be the same as the release rates into buildings. Therefore, no retention of the released material in the building was assumed. Prior to release to the atmosphere, the UF in the plume was assumed to 6
completely react to form UO F and HF inside the process building based on the results of the MELCOR 22 modeling performed for the large release of UF to atmosphere (see Section 4.3.2.1.7). A value offa (the 6
UF MIXER model uses fa to take into account dilution of the plume with in-building air; see Section 6
4.3.1.2.3.4) equal to 0.002 was used for each process building to achieve the mixing necessary for the UF in the plume to completely react just prior to release to the atmosphere. Model simulations show that 6
the plumes exiting the process buildings would be buoyant and would rise.
l l
l I
n()
4.3-143
. - - ~
SAR-PGDP PROPOSED November 6,'1998 RAC 97Cl25 (RO), 98C068 (RI)
O 1
l l
For the process buildings, values of initial uranium deposition (0%) and surface roughness [1 in.
.(0.03 m)] were selected to provide maximum downwind consequence estimates. The selection of these
'l parameters is discussed in more detail in Section 4.3.2.2.15. The results from the process building simulations were superimposed at selected downwind distances. All downwind distances were referenced l.
from the northem edge of Building C-337. The remainder of this section divides the consequence estimate
. discussion into (1) the 3040-MW case and (2) the 2200-MW case.
' Consequence estimates-3040-MW case. Figures 4.3-39 through 4.3-41 show estimated downwind consequences associated with the baseline scenario. Note that the baseline scenario (D4) is '
represented by the bottom curve in these figures; the top curve is for a more adverse meteorological condition (F3), as discussed below. Calculations of specific consequence parameters (amount of inhaled
. uranium,. radioactive dose, and HF exposure) were made. Calculated values of the consequence parameters were compared to EBE guideline values for uranium (25 rem for U radiological toxicity and l
30 mg U intake for U chemical toxicity) and to the Emergency Response Planning Guidelines (ERPG-2) i for HF (20 ppm for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />).
lL Q D
Table 4.3-14 lists specific consequence estimates at the site boundary and at I'mi (1600 m)
L and 5 mi (8050 m) directly downwind (nonh) of Building C-337. The site boundary is about 0.56 mi (900 m) north of Building C-337. The consequence guideline for uranium chemical toxicity would be exceeded
. l to about 1.1 mi (1700 m). The radioactive dose guideline value would not be exceeded at the site boundary. The HF exposure comparison value would also be exceeded to a downwind distance of about 1.1 mi (1700 m).
Figures 4.3-39 through 4.3-41 show consequence estimates for D4 and F3. The highest
[. consequence estimates for this multisource release occur with F3 meteorological conditions. Plumes exiting the process buildings would ris'e because of buoyancy, with Faher wind speeds resulting in lower final plume heights and higher downwind ground-level concentrations. Under F3 meteorological conditions, the uranium chemical toxicity guideline value would be exceeded to a downwind distance of about 3.4 mi (5400 m), and the HF exposure comparison value would be exceeded to a downwind -
distance of about 2.3 mi (3700 m).
Consequence esthnates-2200-MW case. Table 4.3-15 lists specific consequence estimates at the site boundary and at 1 mi (1600 m) and 5 mi (8050 m) directly downwind (north) of Building C-337.
- Figures 4.3-42 through 4.3-44 show estimated downwind consequences associated with the baseline l J scenario. The consequence guideline for uranium chemical toxicity and the HF exposure comparison value l would be exceeded to about 0.12 mi (200 m). These figures also show a comparison of the consequence estimates for the baseline scenario (D4 meteorological conditions) and F3 meteorological conditions.
[
4.3 144
~-
c.,-
r-,
~
-r
SAR-PGDP PROPOSED November 6,1998 9
RAC 97Cl25 (RO), 98C068 (RI)
U Under F3 conditions, the uranium chemical toxicity guideline value and the HF exposure comparison value would be exceeded to a downwind distance of about 0.12 mi (200 m).
Potential for Inadvertent Criticality. With uncontrolled releases of enriched UF., there is the potential for inadvertent criticality With PGDP's maximum assay limited to 5.5 wt %, considerable dilution and spread of the material would probably prevent accumulation of material in an unfavorable geometry. With an unfavorable geometry, a minimum solution depth of a few inches is needed to cause a criticality. Water systems are not designed for seismic loads and could present a ready moderator.
However, the size of the buildings, the leakage area between floors, and the barriers between the UF.
and the fire suppression systems make criticality a remote possibility. Nevertheless, emergency procedures require that appropriate conditions be established for reentry to an evacuated facility.
Consequences from an inadvertent criticality would be similar to the consequences described in the criticality event scenario (see Section 4.3.2.6).
Lube OilImpact. The evaluation basis seismic event may cause a release of lubricating oil used to service the compressor motors. The tanks and lines connecting to the compressors have been evaluated as part of the equipment evaluations. The storage tank located on the roof has weak anchors. Failure of this anchorage would not result in complete loss of restraint of the lube oil tanks. Failure of the attached piping is possible, however. Failure of this piping could allow oil to leak onto the roof or down around the lines that run to the individual compressors. Some of this material could spread out on the operating floor. Failure of equipment and nonstructural support components could lead to electrical shorting, creating potential ignition sources. In the absence of power, however, either as a direct result of the event (V) or through operator action to shut down the power in the switchyard, the potential for a ready ignition source is significantly reduced. The only possible source would then be heat from mechanical components. Note that the lube oil is a low-flammability blend with a high flash point and is therefore hard to ignite. Further, the potential for water system breaks is present, and if they do occur, such breaks would also serve to abate any fire potential from failure of the lube oil system. Therefore, a large fire in the process building following a seismic event is unlikely.
Overall Seismic Conclusions. The results of the 3040-MW and 2200-MW cases show that the l evaluation guidelines are exceeded beyond the site boundary for the 3040 MW case. Therefore, safety actions are required to control the potential releases from a seismic event.
The applicable EGs associated with this event are all the EGs for the EBE frequency range and any initial conditions assumed (i.e., normal operation, EG 5). The essential safety actions associated with meeting these EGs include (1) primary system pressure control to prevent, mitigate, or minimize any UF6 release and (2) emergency response to evacuate the immediate vicinity so that the exposure of on-site personnel to UF., its reaction products, or ionizing radiation is minimized.
The consequences of this event are significantly overstated when the plant operates at typical l
power conditions. At lower power levels, significantly more of the cascade will be below atmospheric pressure. In all cases, the most important action is to control cascade system pressure.
/~~)N i
4.3-145 s
l
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s.
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Table 4.3-11. Source Terms Defining a UF, Release Associated with a Postulated Seismic Event:
$a 5
3040-MW Case.
g 8
UF.(a) Properties go Building Failed Equipment Resulting in Mass Released, Ib Release Temperature Release Duration Facility Type Number Release (kg)
Initial State
- F (*C) s (min) 00
-3 B line 0
~
Unit B bypass (Units 1-2) 320 (146) vapor 290 (t43) 600 (10)
Severed sie line 1.000 (455)
Total 1.320 (601)
B line 17,500 (7950)
C-333 Severed tie line 1,000 (455) y Total IR,500 (8,400)
W Process Imildm.es O
B line 0
- U Unit B bypass (Units 1-2) 0 vapor 290 (143) 600 (10)
C-335 rr1 Severed tie line 600 (273) c Total 600 (77')
H Ime 17,500 (7,945)
C-337 Severed tie line 600 (273)
Total 18.100 (R,218) i
?
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- a. All the released UF. is assumed to be enriched to 5.5% '"U.
Z S.0
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=
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-( x i
[
v n:P-33 oa 13 m i
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Table 4.3-12. Source Terna Defining UF, Release Associated with a Postulated S-Seismic Event: 2200-MW Case.
gn 8'
m UF.(a) Properties 9
I Release O
Failed Equipment Mass Released Temperature Release Duration Facility Type Building Number. Resulting in Release Ib (kg)
Initial State
- F (*C) s (min)
C-331 Severed tie lines 600 (273) vapor 290 (143) 600 (10)
(
C-333 Severed tie lines 600 (273) vapor 290 (143) 600 (10) m Wo Process Buildings C-335 Severed tie lines 400 (182)'
vapor 290 (143) 600 (10) y O
C-337 Severed tie lines 400 (182) vapor 290 (143) 600 (10) yc 1
1 I
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SAR-PGDP PROPOSED November 6,1998 RAC 97Cl25 (RO), 98C068 (RI) s
'y Table 4.3-13. Dispersion Parameters Defining the Baseline Scenario for a UF.
Release Associated with a Postulated Seismic Event:
3040-MW Case and 2200-MW Case.
Parameter Value General parameten common to process buildlings and withdrawal buildings Atmospheric stability Neutral (Pasquill-Gifford stability class D)
Wind speed 9 mph (4 m/s) l Ambient air temperature 80'F (26.7'C)
Ambient relative humidity 70 %
Surface roughness 1 in. (0.03 m)
Parameters specific to the process building releases fa (fraction of the leeward side of building that is 0.002 covered by the plume cross-sectional area)
Duration of release to the outside atmosphere 600 s (10 min)
(_
. Uranium deposition inside the process buildings 0%
l; l
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l 1
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rx r~
s
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Table 4.3-14. Estimated Consequences for a UF, Release Associated with a O C i
Postulated Seismic Event: 3040-MW Case, Base Scenario.
M. '
l 9
c3 Uranium Chemical Toxicity Radiological Toxicity Dose IIP Chemical Exposure F~
Estimated Estimated a
Consequence Guideline Consequence Guideline Value Estimated Value Comparison Value S
l Receptor Location Value (mg)
. Value (mg) '
. Value (rem)
(rem)
(ppm)
(ppm) 1 W
'l Site boundary
- 59 30 0.37 25 38 20 O
l 1 mi(1,600 m) downwind 31 30~
0.19 25 20 20 l
l 5 mi (8050 m) downwind 3
30 0.02 25 2
20
- a. Consequence estimates were made at the site boundary north of C-337 (0.56 mi [900 m]).
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em Table 4.3-15. Estimated Consequences for a UF, Release Associated with a nO Postulated Seismic Event: 2200-MW Case, Base Scenario.
_QT g.-
Uranium Chemical Toxicity Radiological Toxicity Dose IIF Chemical Exposure 8
e Estinured Estimated 8
Consequence Guideline Consequence.
Guideline Value Estimated Value Comparison Value R
l Receptor Location Value (mg)
Value (mg)
Value (rem)
(rem)
(ppm)
(ppm)
W l
Site boundary
- 4 30 0.022 25 2
20 0
l 1 mi (1,600 m) downwind 2
30 0.011 25 1
20 l
5 mi (8.050 m) downwind 0.2 30 -
0.000 25 0.1 20
- a. Consequence estimates were made at the site boundary north of C-337 (0.56 mi [900 m]).
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l SAR-PGDP -
PROPOSED November 6,1998 RAC 97C125 (RO),98C068 (RI) 1000.00.
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Doumwinal distance, m F3 = F Stability,3 meters per second wind speed D4 = D Stability,4 meters per second wind speed (base case) l
- Figure 4.3-39. Estimated uranium chemical toxicity vs. downwind distance for two meteorological conditions for a UF release associated with a postulated seismic 6
event: 3040 MW case. (See Tables 4.3-11 and 4.3-13 for release conditions and Table 4.3-14 for a summary of consequences.)
P l
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PROPOSED November 6,1998 RAC 97Cl25 (RO),98C068 (RI)
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Figure 4.3-40. Estimated radioactive dose vs. downwind distance for two meteorological conditions for a UF release associated with a postulated seismic event: 3040 MW 6
case. (See Tables 4.3-11 and 4.3-13 for release conditions and Table 4.3-14 for a summary ofconsequences.)
l' 1
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1 SAR-PGDP PROPOSED November 6,1998
'^N RAC 97Cl25 (RO),98C068 (R1) s_f l
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Figure 4.3-41. Estimated hydrogen flouride dose vs. downwind distance for two meteorological conditions for a UF release associated with a postulated seismic event: 3040 MW 6
case. (See Tables 4.3-11 and 4.3-13 for release conditions and Table 4.3-14 for a summary of consequences.)
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L SAR-PGDP PROPOSED November 6,1998 RAC 97Cl25 (RO), 98C068 (RI) jq
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F3 = F Stability,3 meters per second wind speed i
D4 = D Stability,4 meters per second wind speed l
l Figure 4.3-42. Estimated uranium chemical toxicity vs. downwind distance for two l
meteorological conditions for a UF release associated with a postulated seismic 6
l event: 2200 MW case. (See Tables 4.3-12 and 4.3-13 for release conditions and Table 4.3-15 for a summary of consequences.)
g i-:x 4
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SAR-PGDP PROPOSED November 6,1998 l ~'
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Downwind dietance, m I t F3 = F stability,3 meters per second wind speed D4 = D stability,4 meters per second wind speed Figure 4.3-43. Estimated radioactive dose vs. downwind distance for two meteorological conditions for a UF release associated with a postulated seismic event: 2200 MW 6
case. (See Tables 4.3-12 and 4.3-13 for release conditions and Table 4.3-15 for a summary ofconsequences.)
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SAR-PGDP PROPOSED November 6,1998
,l O RAC 97Cl25 (RO), 98C068 (RI)
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l F3 = F stability,3 meters per second wind speed D4 = D stability,4 meters per second wind speed Figure 4.3-44. Estimated hydrogen flouride toxicity vs. downwind distance for two meteorological conditions for a UF release associated with a postulated seismic 6
event: 2200 MW case. (See Tables 4.3-12 and 4.3-13 for release conditions and l
Table 4.3-15 for a summary of cons.:quences.)
1
TSR-PGDP PROPOSED November 6,1998 RAC 97C237 (R2), 97C269 (RO) l The fact that a UO:F deposit in an operating cell is not a nuclear criticality safety concern also explains 2
r3 the limited scope of and frequency for the SURVEILLANCE REQUIREMENT. Over time, wet air
- b) inleakage in an operating cell could readily announce itself (in the form of changing motor loads, compressor surging, line recorders, stage control valve positions, A-suction pressures, etc.). Since larger 1
wet air inleakages announce themselves readily, and continuously fluorinated UO:F: deposits of any magnitude pose no criticality safety concern, a quarterly surveillance for UO:F deposits is appropriate 2
for early detection of such deposits and follow up surveys for prudent remediation.
Once identified, the growth of a deposit is monitored quarterly to assure that the deposit does not become sufficiently large to become an operational problem or a cascade structural concern. The maximum allowable size of the deposit is primarily dependant on its location and will be determined as a part of the surveillance of the deposit. Operational experience suggests that quarterly surveillance by NDA methods is adequate to monitor the size of the deposit in process piping, expansion joints and valves.
NDA is of limited value (e.g., quantification of deposit size) for compressors, converters, process gas coolers and freezer sublimers. The size of a deposit in a freezer sublimer can be determined by the remaining weight when the F/S has been emptied of UF. Deposits in axial and centrifugal compressors 6
are detected by the damage the deposits cause to the impeller or by deblading. Deposits in the converters are determined by the impact of the deposit on the pressure drop across the converter. Deposits in the process gas cooler are identified by the operator as degraded performance and are located by radiation surveys.
For shutdown cells, moderation mntrol can also be provided by a dry gas (plant air or nitrogen) blanket over the deposit. Once a systern a been isolated from the cascade and filled to 2: 14 psia with a dry gas blanket, normal atmospheric pressure iluctuations will cause. minor in and out flow through any existing system leaks. Analyses have demonstrated that this " breathing" of the cell will not significantly (v) affect deposit moderation, even over a period much longer than the 180 days to which this condition is limited. The dai!y surveillance demonstrates that the gas blanket is maintained as assumed in the analyses.
Maintenance evolutions or cascade system maintenance, used in REQUIRED ACTION statements, include other related tasks such as decontamination and sampling. CONDITION C is considered to be met when the UF primary system is first breeched.
The potential for moderation from RCW system water is precluded by the two physical barriers (RCW l to coolant and coolant to cascade) and either by maintaining the coolant system pressure greater than the l RCW pressure or by draining the coolant condenser. [SAR Section 5.2, Appendix A]
l t t t(
i 1
2.1-23
TSR-PGDP PROPOSED November 6,1998 RAC 97C237 (R2), 97C269 (RO)
The fact that a UO:F deposit in an operating cell is not a nuclear criticality safety concern also explains 2
pg the limited scope of and frequency for the surveillance requirement. Over time, wet air in-leakage in an V
operating cell could readily announce itself (in the form of changing motor loads, compressor surging, line recorders, stage control valve positions, A-suction pressures, etc.). Since larger wet air in leakages announce themselves readily and continuously fluorinated UO F: deposits of any magnitude pose no criticality safety concern, a quarterly surveillance for UO:F: deposits is appropriate for early detection of such deposits and follow up surveys for prudent remediation.
Once identified, the growth of a deposit is monitored quarterly to assure that the deposit does not become sufficiently large to become an operational problem or a cascade structural concern. The maximum allowable size of the deposit is primarily dependent on its location and will be determined as a part of the surveillance of the deposit. Operational experience suggests that quarterly surveillance by NDA methods is adequate to monitor the size of the deposit in process piping, expansion joints and valves.
NDA is of limited value (e.g., quantification of deposit size) for compressors, converters, process gas coolers and freezer sublimers. The size of a deposit in a freezer sublimer can be determined by the remaining weight when the F/S has been emptied of UF.. Deposits in axial and centrifugal compressors are detected by the damage the deposits cause to the impeller or by deblading. Deposits in the converters are determined by the impact of the deposit on the pressure drop across the converter. Deposits in the process gas cooler are identified by the operator as degraded performance and are located by radiation surveys.
For shutdown cells, moderation control can also be provided by a dry gas (plant air or nitrogen) blanket over the deposit. Once a system has been isolated from the cascade and filled to 2 14 psia with a dry gas blanket, normal atmospheric pressure fluctuations will cause minor in and out flow through any existing system leaks. Analyses have demonstrated that this " breathing" of the cell will not significantly affect deposit moderation, even over a period much longer than the 180 days to which this condition is i
4 limited. The daily surveillance demonstrates that the gas blanket is maintained as assumed in the analyses.
Maintenance evolutions or cascade system maintenance, used in REQUIRED ACTION statements, include other related tasks such as decontamination and sampling. CONDITION C is considered to be met when the UF. primary system is first breeched.
The potential for moderation from RCW system water is precluded by the two physical barriers (RCW l to coolant and coolant to cascade) and either by maintaining the coolant system pressure greater than the l RCW pressure or by draining the coolant condenser. [SAR Section 5.2, Appendix A]
r
{k i
l 2.3-19
1 TSR-PGDP PROPOSED November 6,1998
' RAC 97C237 (R3), 98C101 (RO) l 2.4.3 LIMITING CONTROL SETTINGS, LIMITING CONDITIONS FOR OPERATION,
'^\\
SURVEILLANCE FEQUIREMENTS V
l 2.4.3.1 Fire Protection System - Fire Water Pumps b
2.4.3.1.a High Pressure Fire Water System Pumps
[
l APPLICABILITY:
Whenever any one of the cascade, purge and product withdrawal, or tails l.
withdrawal facility sprinkler systems is required to be OPERABLE per TSR j
2.1.3.5, 2.3.3.2, or 2.5.3.2 respectively.
l LCO:
At least two high pressure fire water system (HPFWS) pumps shall be OPERABLE.
ACTIONS: TSR 1.6.2.2.d does not apply.
l l
CONDITION REQUIRED ACTION COMPLETION TIME A. Only one HPFWS pump A.1 Initiate and continue efforts to restore a IMMEDIATELY OPERABLE.
second HPFWS pump to OPERABLE status.
B. No HPFWS pump B.1 Verify that the HPFWS C-611-R storage IMMEDIATELY OPERABLE.
tank is OPERABLE.
AND g)
B.2 Provide alternative means of fire water 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> iV supply.
SURVEILLANCE REQUIREMENTS:
I SURVE1LLANCE FREQUENCY SR 2.4.3.1.a-1 Manually start HPFWS fire water pumps locally and from Monthly C-300.
l SR 2.4.3.1.a-2 Verify adequate diesel fuel supply for HPFWS diesel fire Monthly l
water pump in C-631-1 pump house.
SR 2.4.3.1.a-3 Verify water level in the C-631-2 RCW cooling tower basin Monthly is within five feet of the top of the oasin.
SR 2.4.3.1.a-4 Verify HPFWS fire water pump flow is 2 2500 gpm at Annually i
rated pressure.
l' BASIS:
The fire protection system is provided to mitigate a lube oil fire that could cause a potential threat to
[V) pnmary system integrity with the potential for onsite and offsite consequences. The fire protection system is divided into three areas: the fire protection system pumps; the building sprinklers; and elevated water 2.4-3
~ _ _.
TSR-PGDP PROPOSED
- November 6,1998 RAC 97C237 (R3), 98C101 (RO)
' storage tanks. The HPFWS pumps are designed to provide both makeup to the high level storage tank and l
system pressure and flow if the high level tank is not available. Each HPFWS pump has a flow capacity of i--
approximately 4000 gpm which is sufficient to meet the accident analysis assumption of 2500 gpm.
i The requirement for the HPFWS pumps to supply 2500 gpm for 30 minutes is based on available discharge densities and the sprinkler operating areas determined for the evaluation basis fire. The highest average fire
}
water flow rate is assumed to be 0.30 gpm/ft x 8,400 ff = 2,500 gpm for the process building floor. The 2
l l HPFWS provides fire water to the cascade and withdrawal buildings (as well as other facilities not covered l
l by this TSR).
j.
_ PGDP has a total of 4 fire water pumps located in the C-631-1 pump house and the C-631-3 pump house.
l l There are three electric pumps (two in C 631-3 and one in C-631-1) and I diesel pump (in C-631-1).
. The electric fire pumps are normally in a standby condition, ready to start as the level in the high level storage tank decreases. The diesel powered pump also auto starts when tank level drops. The automatic l
start feature is not required for pump operability. The minimum required diesel fuel supply for the diesel backup pump to ensure that this pump can perform its required safety function is 50 gallons.
l The pumps m C-631-1 and C-631-3 pump houses take suction from the C-631-2 RCW cooling tower l
basin. Alternative flow can be accomplished by utilizing available fire trucks, hoses, hydrants, and any other means determined to be appropriate by the Authority Having Jurisdiction (AHJ). This arrangement provides adequate diversity to ensure ready availability of makeup water to the elevated tank.. [SAR l
Section 3.15.7.2]
O l V L
I l
t l
4 2.4-4 i
TSR-PGDP PROPOSED November 6,1998
' RAC 97C237(R2), 97C241 (RO) 1 - 2.4.3.3 Criticality Accident Alarm Systems [C-400, C-409, C-710, C-720, C-720-C, C-728, C-746-Q-1]
2.4.3.3.a Criticality Accident Alarm System - Detection APPLICABILITY:
In areas, equipment, or piecesses which contain greater than 700 grams of 235U at an enrichment greater than or equal to 1.0 wt '/c 235 U.
LCO:
Criticality accident detection shall be OPERABLE.
ACTIONS: TSR 1.6.2.2.d is not applicable.
CONDITION REQUIRED ACTION COMPLETION TIME A. Areas, equipment, or A.1 Implement the following for areas, processes not covered equipment, or processes applicable to by criticality accident this LCO and that are not otherwise detection.
covered by uiticality accident detection.
A.1.1 Discontinue operations with fissile IMMEDIATELY material.
bN-Q A.2.1 Restore criticality accident detection by 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> installing portable CAAS unit providing required criticality accident detection.
("%
()
A.2.2 Restore criticality accident detection to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> OPERABLE status.
B. REQUIRED ACTION B.1 Continue to comply with REQUIRED IMMEDIATELY A.2.1 and A.2.2 not ACTION A.1.1 satisfactorily AND accomplished.
B.2 Evacuate and restrict access to the area IMMEDIATELY applicable to this LCO not covered by criticality accident detection, except individuals with an alternate means of criticality detection and alarm notification, such as a device that will alarm on sensing a 10 mr/hr dose rate.
AND B.3 Continue actions to restore criticality IMMEDIATELY accident alarm system detection to OPERABLE status.
L
. SURVEILLANCE REQUIREMENTS:
SURVEILLANCE FREQUENCY SR 2.4.3.3.a-1 Calibrate Criticality Accident Alarm System equipment.
Annually q
)
2.4-9 L
TSR-PGDP PROPOSED November 6,1998 RAC 97C237 (R2), 97C241 (RO) 2.4.3.3.b Criticality Accident Alarm System - Alarm
()
V l APPLICABILITY: In areas in (or near) the facilities listed in 2.4.3.3.a where the maximum foreseeable absorbed dose in free air exceeds 12 rad.
LCO:
Criticality accident alarm shall be OPERABLE (audible).
ACTIONS: TSR 1.6.2.2.d is not applicable.
CONDITION REQUIRED ACTION COMPLETION TIME A.
Area does not have A.1 Ensure there is an alternate means of IMMEDIATELY an audible criticality criticality alarm notification in the area accident alarm.
of inaudibility, such as the Plant PA, building horns, or a radio in communication with the CCF.
AND A.2 Restore criticality accident alarm to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> OPERABLE status.
B.
REQUIRED B.1 Implement the following for areas, ACTIONS A.1 or equipment, or processes where a A.2 not satisfactorily criticality accident could result in a accomplished.
maximum foreseeable dose excceamg 12 rad in the area of inaudibility and g
LCO 2.4.3.3.a applies.
()
B.1.1 Discontinue operations with fissile IMMEDIATELY material.
AND B.2 Evacuate and restrict access to the area IMMEDIATELY of inaudibility applicable to this LCO, except individuals with an alternate means of criticality alarm notification, such as a device that will alarm on sensing a 10 mr/hr dose rate or a radio in communication with the CCF.
AND.
B.3 Continue actions to restore criticality IMMEDIATELY accident alarm system audibility to OPERABLE status.
SURVEILLANCE REQUIREMENTS:
SURVEILLANCE FREQUENCY l
SR 2.4.3.3.b-1 Test the CAAS, local cluster horns, building horns, and Semiannually C-300 alarms.
SR 2.4.3.3.b-2 Verify that the nitrogen supply pressure to each cluster Quarterly n
horn is at least 900 psig.
s 2.4-11 l
TSR PGDP PROPOSED November 6,1998
[
RAC 97C237 (R2), 97C241 (RO) l SURVEILLANCE l,,i FREQUENCY
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SR 2.4.3.3.b-3 Verify that the condition of the battery backups to the Annually electronic horns are sufficient to power the horns for at least 120 seconds.
1 BASIS:
l The CAAS is used to warn plant perscanel of a criticality or radiation accident. This system is designed to detect radiation and provide an audible signal which will alert personnel to move from those work areas which are potentially affected. Criticality concerns involve movement of fissile material and moderator introduction. The REQUIRED ACTIONS maintain steady state operations (relative to criticality control) to limit the potential for these concerns to the extent possible. Discontinuing
)
operations with fissile material stops fissile material processing activities and movement of fissile j
material. The design of the system, three detector modules per cluster, provides protection for criticality l events even with partial losses of required equipment. The alarm signal is provided by sounding building l horns which sound upon a signal from any cluster, and by sounding in some locations a local horn l associated with each individual cluster. The building horns for C-709 and C-710 are configured in two l separate networks, either of which can independently sound the required evacuation signal. The building l horn configuration in C-709 and C-710 allows the CAAS for those buildings to remain operable even l when one of the independent horn networks is temporarilly out of service. During the 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> allowed to restore audibility, an alternate means of criticality accident alarm notification is available. Providing another means of cov rage for the area in the event of inaudibility will establish protection on a temporary basis until system operability is restored.
Os
\\.j he nitrogen bottles which backup plant air for the local cluster horns provide for 120 seconds of horn j actuation when at their minimum acceptable pressure of 900 psig (where applicable).
The semiannual surveillance of the CAAS, local cluster horns and building horns consists of placing the cluster in the test mode, and manually causing two detutor modules to generate radiation readings above the alarm setpoint. The cluster electronics determines tl.at this meets the high radiation alarm criteria and propagates a high radiation alarm signal to the rest of the :ystem. This signal activates the high radiation l alarm light and bell in C-300, causes the local cluster honi to sound (where applicable) and activates the building CAAS horns and lights. Each horn and light is qualitatively verified to be operating. This test is a horn and light functional test and each module combination is tested to generate the high radiation signal. [SAR 3.15.7.1]
n (v) 2.4-12