ML20195B802
| ML20195B802 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 11/05/1998 |
| From: | Toelle S UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Paperiello C NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20195B810 | List: |
| References | |
| GDP-98-0215, GDP-98-215, NUDOCS 9811160286 | |
| Download: ML20195B802 (8) | |
Text
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. A GMal Enugy Company November 5,1998 GDP 98-0215 Dr. Carl J. Paperiello Director, Office of Nuclear Material Safety and Safeguards
. Attention: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Paducah Gaseous Diffusion Plant (PGDP)
Docket No. 70-7001 Certificate Amendment Request - Criticality Accident Alarm System Audibility Upgrades -
Compliance Plan Issues 46 and 50
Dear Dr. Paperiello:
In accordauce with 10 CFR 76.45, the United States Enrichment Corporation (USEC) hereby submits a request for amendment to the certificate of compliance for the Paducah, Kentucky, Gaseous Diffusion Plant (PGDP). This Certificate Amendment Request (CAR) proposes to revise the Plan of Action and Schedule for Issues 46 and 50 described in DOE /ORO-2026, Plan for Achieving Compliance with NRC Regulation at the Paducah Gaseous Diffusion Plant (Compliance Plan). This CAR also requests approval of a revision to a related section of the Safety Analysis Report (SAR).
Compliance Plan Issues 46 and 50 require plant modifications to ensure that the CAAS alann horns are capable of being heard throughout the affected areas of the process building and to provide CAAS alarm horns for those unalarmed facilities within the evacuation area of CAAS-clustered buildings, respectively.
This CAR proposes to change the Compliance Plan due date associated with Issues 46 and 50 from December 15,1998, to January 18,2000. In addition, this CAR requests approval of alternate SAR criteria for determining CAAS audibility.
To accomplish the Plan of Action associated with Compliance Plan Issues 46 and 50, a CAAS Modification Project was initiated to design and install additional CAAS horns to ensure adequate audibility throughout the process buildings and for unalarmed facilities within the evacuation area of CAAS-clustered buildings i The conceptual design to satisfy the requirements of these Compliance Plan actions originally required I installation of additional air powered CAAS horns and upgrading the existing air system to supply the air necessary to power these new horns. During the detailed design process, further reliance on the existing plant air system to support the CAAS system was questioned and determined to be undesirable. As a result, g
a new design concept to improve CAAS reliability which utilizes a dedicated air system and air p 1 accumulators to supply the new CAAS horns was developed. To further enhance the reliability of the siteh wide CAAS, this same design concept (i.e., a dedicated air system with air accumulators) is being applied to all CAAS air horns at PGDP. This change in design and the application of this design to all CAAS systems utilizing air horns at PGDP, in addition to the subsequent site activitie 9811160286 981105" YMf f"h-h gt!
dw PDR ADOCK 07007001 EJ C
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, Bethesda, MD 20817-1818 Telepho7E 301-564-3200 Fax 301-564-3201 http:#www.usec.com OfTices in Livermore, CA Paducah, KY Portsmouth, OH Washington. DC
o Dr. Carl J. Paperiello No'vember 5,1998 GDP 98-0215, Page 2 implementation of the design, necessitates the change in Compliance Plan due date. The change in the audibility criteria allows the application of additional criteria to be applied to ensure CAAS audibility.
' to this letter provides a detailed description and justification for the proposed changes. is a copy of the revised Compliance Plan and SAR pages associated with this request. The Compliance Plan pages and SAR pages 2-6 and 2-15 are provided for NRC review and approval. The remaining pages contained in Enclosure 3 are provided for information only. Enclosure 4 contains USEC's determination that the proposed changes associated with this Certificate Amendment Request are not significant. Enclosure 5 contains DOE approval of the Compliance Plan changes. Enclosure 6 contains new commitments contained in this submittal.
Since this CAR affects Compliance Plan actions which are required to be completed by December 15,1998, I
a prompt review of this CAR is desired. The amendment should become effective immediately upon
~ issuance.
Any questions related to this submittal should be directed to Marc Klasky at (301) 564-3408.
Sincerely,
/1 S. A.
ll Steven A.Toelle Nuclear Regulatory Assurance and Policy Manager
Enclosures:
- 1. Affidavit
- 2. United States Enrichment Corporation (USEC), Certificate Amendment Request, Criticality Accident Alarm System Audibility Upgrades, Detailed Description of Change
- 3. Certificate Amendment Request, Paducah Gaseous Diffusion Plant, Letter GDP 98-215, Removal / Insertion Instructions
- 4. United States Enrichment Corporation (USEC), Certificate Amendment Request, Criticality Accident Alarm System Audibility Upgrades, Significance Determination
Gaseous Diffusion Plant - Docket No. 70-7001 - Department of Energy Approval of Change to Compliance Plan Issues 46 and 50, dated October 29,1998.
- 6. New Commitments Contained in this Submittal.
cc: Mr. Robert C. Pierson (NRC)
NRC Region 111 Office NRC Resident Inspector-PGDP NRC Resident Inspector - PORTS p
. Mr. Randall M. DeVault (DOE)
OATil AND AFFIRMATION I, Steven A. Toelle, swear and affirm that I am the Nuclear Regulatory Assurance and Policy Manager of the United States Enrichment Corporation (USEC), that I am authorized by USEC to sign and file with the Nuclear Regulatory Commission this Certificate Amendment Request for the Paducah Gaseous Diffusion Plant addressing revisions to the Safety Analysis Report and Compliance Plan Issues 46 and 50 described in USEC letter GDP 98-0215, that I am familiar with the contents thereof, and that the statements made and matters set forth therein are true and correct to the best of my knowledge, information, and belief.
/)
S. A.
/
/
Steven A. Toelle On this 5th day of November,1998, the individual signing above personally appeared before me, is known by me to be the person whose name is subscribed to within the instrument, and acknowledged that he executed the same for the purposes therein contained.
In witness hereofI hereunto set my hand and official seal.
I Il fl/, --
Jurie M. Knisley, Notary Pu'blic State of Maryland, Montgomery County My commission expires March 1,2002
O o
GDP 98-0215 Page 1 of 5 United States Enrichment Corporation (USEC)
Certificate Amendment Request CAAS Audibility Upgrades-Compliance Plan Issues 46 and 50 Detailed Description of Change -
1.0 Change in Scheduled Completion Date Descriotion of Change The Paducah Gaseous Diffusion Plant currently has two open Compliance Plan issues regarding audibility of the Criticality Accident Alarm System (CAAS) Compliance Plan Issue 46 involves a lack of audibility of the CAAS alarm horns in certain areas of the plant process buildings due to high ambient noise levels. The Plan of Action and Schedule for Compliance Plan Issue 46 states that:
" Plant modifications will be initiated to ensure that the CAAS alann horns are capable of being heard throughout the affected areas of the process buildings. The modifications will be complete by December 15,1998."
Compliance Plan Issue 50 involves the lack of alarm horns and lights in buildings located within the evacuation area of clustered buildings. The Plan of Action and Schedule for Compliance Plan Issue 50 states that.
l
" Evacuation horns (for those unalarmed buildings where nearby CAAS horns cannot be adequately heard) and/or lights will be installed in the unalarmed buildings located within the evacuation area of CAAS-clustered buildings, or the unalarmed buildings will be removed from the evacuation area. These horns and/or lights will be activated from a i
neart.v clustered building or other alarmed building. Unalarmed facilities that have been identified as of June 19,1996, will be modified with the required horns and/or lights, as appropriate, or relocated to locations outside of the evacuation area by December 15, 1998."
Justification of Change This Certificate Amendment Request proposes that the Plan of Action and Schedule for Compliance Plan Issues 46 and 50 be revised as follows:
6' P
GDP 98-0215 Page 2 0f 5 United States Enrichment Corporation (USEC)
Certificate Amendment Request CAAS Audibility Upgrades-Compliance Plan Issues 46 and 50 Detailed Description of Change Comoliance Plan Issue 46 Plant modifications will be initiated to ensure that the CAAS alarm horns are capable of being heard throughout the affected areas of the process buildings. The modifications will be complete by January 18,2000.
Compliance Plan Issue 50 Evacuation horns (for those unalarmed buildings where nearby CAAS homs cannot be adequately heard) and/or lights will be installed in the unalarmed buildings located within the evacuation area of CAAS-clustered buildings, or the unalarmed buildings will be removed from the evacuation area. These homs and/or lights will be activated from a nearby clustered building or other alarmed building. Unalarmed facilities that have been identified as of June 19,1996, will be modified with the required horns and/or lights, as appropriate, or relocated to locations outside of the evacuation area in accordance with the plan of action and schedule of the Compliance Plan issue entitled " Criticality Accident Alarm System - Horn Audibility."
l Justification for the Change:
)
As described in the Plan of Action and Schedule for Compliance Plan Issue 46, plant modifications to ensure that CAAS alarm homs are audible throughout the alTected areas of process buildings C-331, C-335 and C-337 are required to be completed by December 15,1998. To accomplish this Compliance Plan action, a CAAS Modification Project was initiated to design and install additional i
CAAS horns to ensure adequate audibility throughout the process buildings. The conceptual design l
to satisfy the requirements of this Compliance Plan action originally required installation of additional air powered CAAS homs and upgrading the existing air system to supply the air necessary to power these new homs. During the detailed design process, further reliance on the existing plant air system to support the CAAS system was questioned and determined to be undesirable. As a result, a new design concept to improve CAAS reliability which utilizes a dedicated air system and air accumulators to supply the new CAAS horns was developed. Although only the process buildings were addressed in Issue 46, to further enhance the reliability of the site wide CAAS system, l
this same design concept (i.e., a dedicated air system with air accumulators) is being applied to all l
CAAS air horns at PGDP.
]
The Plan of Action and Schedule fbr Compliance Plan Issue 50 requires modification of CAAS to l
provide horns and/or lights for those unalarmed facilities, identified as of June 19,1996, where i
nearby CAAS homs cannot be adequately heard or relocate the facilities to location outside the j
i
-l i
GDP 98-0215 Page 3 of 5 United States Enrichment Corporation (USEC)
Certificate Amendment Request CAAS Audibility Upgrades-Compliance Plan Issues 46 and 50 Detailed Description of Change evacuation area of CAAS-clustered buildings. All facilities which were planned to be relocated outside of the evacuation area of CAAS-clustered buildings have been relocated. The remaining scope of the Plan of Action and Schedule will be accomplished as part of the CAAS Modification Project described above.
As noted in the above proposed changes to the Plan of Action and Schedule, the modifications necessary to satisfy the requirements of Compliance Plan issues 46 and 50 will not be completed until January 18,2000.
This change in the scheduled completion date is required to allow sufficient time to perform the following activities:
Completion of the final design activities associated with CAAS Modification Project.
Procurement of materials to support construction.
Completion of construction activities.
Preparation, review and approval of anticipated Technical Safety Requirements changes to support operation of the improved CAAS.
Preparation, review and approval of necessary implementing procedures and training on these procedures to allow facility transition to the improved CAAS.
Until the CAAS upgrades are completed and the requirements of Plan of Action and Schedule for Compliance Plan Issues 46 and 50 are satisfied, the compensatory actions required by the Justification for Continued Operation (JCO) for Compliance Plan Issues 46 and 50 will remain in effect to provide an adequate means of notification in the event of actuation of the criticality accident monitoring system.
Furthermore, in performing the detailed design of modifications to upgrade the CAAS, it has been determined that a safe and reliable means ofproviding CAAS audibility coverage in pennit-required confined spaces and cell housings associated with cells that are running may not be achievable. To address this issue, a request for exclusion from the requirements 10 CFR 76.89 (a) has been provided in USEC's letter from Steven A. Toelle to Dr. Carl J. Paperiello (NRC), " Request for 10 CFR 76.89(a) Exclusion for Criticality Accident Alarm System Audibility in Confined Spaces and Cell Housings," GDP 98-0211, dated October 19,1998. Contingent on NRC approval of the exclusion request, revised TSR requirements for the new system which address both cell housings associated with cells that are running and permit-required confined areas of the plant and the CAAS system surveillance requirements will be submitted for NRC review and approval by February 26,1999.
i
GDP 98-0215 Page 4 of 5 United States Enrichment Corporation (USEC)
Certificate Amendment Request CAAS Audibility Upgrades-Compliance Plan Issues 46 and 50 Detailed Description of Change Pending approval of these TSR changes, transition of plant facilities to the new system is scheduled to begin in the third quarter of 1999.
2.0 Modification of the Field Determination of CAAS Audibility Criterion Description of Changs To support the upgrade associated with the CAAS modification project, this Certificate Amendment Request proposes to modify the criterion for establishing the audibility of the CAAS system.
Currently, CAAS audibility is established based on recommendations in ANSI /ANS 8.3, 1986 Edition, which states that signals generated by the evacuation alann system should be capable of producing an overall sound pressure level which is not less than 10dB above the overall maximum typical ambient noise level, and in any case not less than 75dB nor greater than 115dB (reference j
20 N/m2) at the ear of the individual at every location from which immediate evacuation is deemed essential. To allow for additional system design flexibility, it is proposed that the following criteria be utilized to verify compliance with the ANSI /ANS 8.3,1986 Edition audibility requirement:
- 1) Ensure the broadband CAAS alarm signal is at least 10dB above the maximum expected broadband background noise. If this criterion cannot be met, proceed to step 2.
- 2) Ensure the 1/3 octave 500 Hz CAAS alarm signal is at least 13dB above the maximum expected 1/3 octave 500 Hz effective masked threshold. If this criterion cannot be met, proceed to step 3.
- 3) Expose a minimum of ten people, rep wenting a cross section of the plant population's age and hearing capability, to the alarm signal and ensure each of the test subjects can hear the alarm signal. This test is repeated five times and the results are satisfactory if each of the test subjects hear the signal each time they are exposed.
If any of the above criteria are met, the CAAS meets the CAAS audibility requirement of ANSI /ANS 8.3, 1986. Criteria 2 and 3 have been taken from the International Standard ISO-7731 " Danger Signals for Work Places-Auditory Danger Signals."
l Justification of Change Criteria 1 and 2 are stipulations of sound intensity that are expected, by national and international standards, to provide for audibility whereas Criterion 3 is a direct determination of audibility.
Criterion 3 directly determines that the CAAS system is audible by sampling a representative sample 5
GDP 98-0215 Page 5 of 5 United States Enrichment Corporation (USEC)
Certificate Amendment Request CAAS Audibility Upgrades-Compliance Plan Issues 46 and 50 Detailed Description of Change of the plant's population. Because the ANSI /ANS standard requirement stipulates only that audibility be ensured at the ear of the individual at every location from which immediate evacuatico Jeemed essential, any of the three criterion are sufficient to fulfill the audibility requirement. T'
. ore, the change in the CAAS audibility criteria will not diminish the effectiveness of the CA/. system in alerting personnel to evacuate the area.
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