ML20195B813
| ML20195B813 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 11/05/1998 |
| From: | UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | |
| Shared Package | |
| ML20195B810 | List: |
| References | |
| NUDOCS 9811160287 | |
| Download: ML20195B813 (19) | |
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l GDP 98-0215 Page1of11 l
I Certificate Amendment Request Paducah Gaseous Diffusion Plant l
Letter GDP 98-0215 Removal / Insertion Instructions Remove Pages Insert Pages
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PLAN FOR ACHIEVING COMPLIANCE WITH NRC REGULATION AT THE PADUCAH GASEOUS DIFFUSION PLANT (DOE /ORO-2026)
Issue 46, Criticality Accident Alarm Issue 46, Criticality Accident Alarm System - Horn Audibility System - Horn Audibility Pages 1/2 Pages 1/2 Issue 50, Criticality Accident Alarms for Issue 50, Criticality Accident Alarms for L
Nearby Buildings Nearby Buildings i
Page 3 Pages 3/4 APPLICATION FOR UNITED STATES NUCLEAR REGULATORY COMMISSION CERTIFICATION VOLUME 2 SAR Section 1, Appendix A SAR Section 1, Appendix A A-1/A-2 A-1/A-2 SAR Section 4, Appendix A SAR Section 4, Appendix A 2-5/2-6 and 2-15/2-16 2-5/2-6,2-15/2-16 r
9811160287 9911051 PDR ADOCK 07007001 C
t Issue 46, Page I Criticality Accident Alarm System-Horn Audibility (new issue) l REQUIREMENT 10 CFR 76.89 "(a) The Corporation must maintain and operate a criticality truoring and audible alarm system meeting the requirements of paragraph (b) of this section in all areas of the facility.
The Corporation may describe for the approval of the Commission defm' ed areas to be excluded from the monitoring requirement. This submittal must describe the measures that will be used to l
ensure against criticality, including kinds and quantities of material that will be permitted and measures that will be used to control those kinds and quantities of material. (b) The system must detect and annunciate a criticality that produces an absorbed dose in soft tissue of 20 rads of combined neutron and gamma radiation at an unshielded distance of 2 meters from the reacting material within 1 minute. Coverage of all monitored areas must be provided by two detectors."
COMMITMENTS Source: Safety Analysis Report
- 5. Nuclear Safety Programs 5.2 Nuclear Criticality Safety 5.2.2 Program Elements 5.2.2.5 Criticality Accident Alarm System Coverage [Rev. 3, 5/31/96]
I "The [ criticality accident alarm] system utilizes a distinctive audib.e signal to notify personnel in the affected area and initiates evacuation, thereby reducing pe:sonnel exposure to emitted radiation."
DESCRIPTION OF NONCOMPLIANCE There are areas in process buildings C-331, C-335, and C-337 where the criticality accident alarm system (CAAS) horns are not r.udible to personnel due to high ambient noise levels. A full sound survey of all buildings with CAAS horns is being conducted. The inaudibility does not affect i
the capability of the CAAS to detect a criticality accident.
JUSTIFICATION FOR CONTINUED OPERATION The CAAS provides an automatic alarm to initiate the evacuation of areas potentially affected by a criticality accident. Although the CAAS cannot prevent a criticality accident, its alarm will reduce the exposure time of affected personnel.
The process buildings are also equipped with other evacuation alarm systems. The building howlers are used to initiate evacuations for events other than a criticality accident. A continuous blast on the building howlers is the " alert signal," which directs personnel to evacuate the building immediately and to listen to the plant public address system for further instructions. The operability l.
of the howlers will be verified at least semiannually. The same evacuation routes are designated for l'
l PGDP RAC 98C096, dated 11/5/98
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Issue 46, Page 2 PROPOSED Criticality Accident Alarm System-Ilorn Audibility l
l the GAAS and building alert signals; in both situations the requirement is to evacuate the building i
by the nearest route.
Sound level surveys conducted with both the CAAS and building howlers sounding demonstrated that the building howler signals could be heard throughout the process buildings. Thus, as a compensatory measure for the inaudible CAAS alarms, the building howlers will be sounded within approximately 10 seconds following actuation of any CAAS detection / alarm cluster. An auxiliary control team operator will activate the howlers by a switch in tne control room. The l
applicable procedure has been changed to include this step, i
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Walkthroughs were conducted to measure the time necessary for an operator walking at a normal pace to reach the building howler switch from the most remote location in the control room.
l The time delay was less than 10 seconds for Buildings C-331, C-335, and C-337 under these l
conservative conditions.
The areas of Buildings C-331 and C-335 where the alarm cannot be heard are not areas with a potential for a criticality accident. The area of Building C-337 where a criticality accident could most conceivably occur has an additional local horn, which would sound and provide an audible warning. A criticality accident elsewhere in Building C-337 would be remote from the areas where the CAAS is inaudible. Thus, the 10-second time delay for a building howler actuation would not have a significant impact on evacuating the areas of the process buildings where the CAAS alarms cannot be heard.
Following a CAAS activation, procedures require that a public address announcement be made by personnel in Building C-300, Central Control Building. The announcement will inform all plant personnel of the need for a building evacuation due to a CAAS activation and will direct them to proceed to their appropriate assembly point.
PLAN OF ACTION AND SCHEDULE 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.
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l PGDP RAC 98C096 dated 11/5/98
Criticality Acciden: Alarms for Nearby Buildings PROPOSED Issue 50, Page 3 buildings where the nearby criticality alarm horns cannot be adequately heard are required to have a radio capable of receiving emergency information and are required to monitor the radio continuously while inside. Prior to entry into these unalarmed buildings, personnel are required to verify that their radios are receiving transmissions. For continuously manned unalarmed buildings, personnel are required to perfonn this check once a shift. In the event of an alarm sounding (e.g.,
due to a criticality accident or false alarm), a page delivered over all radio frequencies will provide notification to personnel in the affected buildings and facilitate evacuation or other appropriate protective action (e.g., continued sheltering).
1 As described in the Safety Analysis Report, the probability of a criticality event is extremely low because of design safety features and administrative controls specified in nuclear criticality safety approvals for fissile-material facilities and activities. Additionally, because a majority of the unalarmed buildings are not continuously manned, the probability of a criticality event occurring at the time these buildings are occupied is very low. Notification of individuals in these buildings to evacuate or take other protective measures will further mitigate the risk associated with an unlikely criticality accident.
PLAN OF ACTION AND SCIIEDULE 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 nearby clustered building or other alarmed building.
Unalarmed facilities that have been identified as ofJune 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 Alann System -llorn Audibility."
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SUMMARY
OF REQUIREMENTS, COMMITMENTS, AND NONCOMPLIANCES Issue: Criticality Accident Alarms for Nearby Buildings Code of Federal Regulations Part Title 10 76.89(a) and (b)
Application Commitment Section Safety Analysis Report 3.12.6,5.2.2.5 Technical Safety Requirements 2.64.1 l
Application Noncompliance Statement Section None i
PGDP RAC 98C096, dated i 1/5/98
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Issue 50, Page 4 PROPOSED Criticalny Accident Alarms for Nearby Buildings i
Blank Page PGDP RAC 98C096 dated 11/5/98
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SAR-PGDP April 15,1998 Ret.24.
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Appendix A Applicable Codes, Standards, and Regulatory Guidance l
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) 1.1 ANSI N14.1, Uranium Hexaflouride - Packaging for Transport,1990 Edition PGDP satisfies the requirements of this standard, except for those portions superseded by Federal Regulations, with the following clarifications:
L New cylinders and associated valves - Entire standard i,
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.
L 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.
Section 5.2.1 - For U.S. Department of Transportation 7A Type A packaging, satisfy U.S.
p Department of Energy (DOE) evaluation document DOE /RL-96-57, Revision 0, Volume 1, which supersedes DOE /00053-Hl.
Tinning of cylinder valve and plug threads: ANSI N14.1 - 1990 requires the use of ASTM B32 50A, a 50/50 tin / lead solder alloy described in the 1976 and previous editions of the ASTM standard. Cylinder valve and plug threads are tinned with solder alloys meeting the requirements of ASTM B32. Tinning is performed with nominal 50% tin alloy or with a mixture of alloys with nominal tin content from 40% to 50%, with a lower limit of 46% tin in the mix.
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See SAR Sections 3.7.1 and 4.3.1.5 and the basis statements for TSR Sections 2.1.4.8,2.2.4.6, and l
2.3.4,16.
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1.2 ANSI /ANS 2.8, Determining Design Basis Flooding at Power Reactor Sites,1981 Edition The extent to which PGDP satisfies 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 i<
PGDP satisfies only the following section of this standard:
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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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SAR-PGDP November 5,1998 Rev. 8 / RAC 98C106 (RO) 1.4 ANSI /ANS 3.2, Administrative Controls and Quality Assurance for the' Operational Phase of Nuclear
- Power Plants,1994 Edition 4
The extent to which.PGDP satisfies the requirements of this standard'is outlined in SAR
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Section 6.11.1 and Appendix B to SAR Section 6.11.
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1.5. ANSI /ANS 8.1, Nuclear Criticality Safety in Operations With Fissionable Materials Outside Reactors,1983 Edition PGDP satisfies the requirements of this standard.
For reference's to this standard, see SAR Sections 5.2.2.1,5.2.2.3,5.2.3.2,5.2.4.1, and Table 6.9--
1.
1.6 _ ANSI /ANS 8.3, Criticality Accident Alarm System,1986 Edition
- The recommendations of this standard were used as guidance only for the design of the CAAS.
PGDP satisfies the requirements of this standard with the following exceptions:
Section 4.4.2 - An alarm signal with a complex sound wave or modulation is not provided.
l Section 4.5.3 - Emergency power supplies for AQ and NS alarm systems are not provided.
A battery backup serves as the backup power supply for the cluster and local nitrogen horn.
Section 5.3 - The CAAS is not designed to withstand seismic stresses.
- For references to this standard, see SAR Section 3.12.6, Section 2.5.1 of Appendix A to Chapter 4, and the basis statements for TSR Sections 2.1.4.5,2.2.4.3,2.3.4.7,2.4.4.2 and 2.6.4.1.
1.7. ANSI /ANS 8.7 (N16.5), Guide for Nuclear Criticality Safety in the Storage of Fissile Material,1975 Edition PGDP satisfies the requirements of this standard with the following exceptions / clarifications:
Section 4.2.6 - Fire protection systems are installed throughout the process buildings where flammable liquids are used in operating equipment. hidividual cell housings do not contain fire protection systems.
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1 SAR-PGDP Chapter 4, Appendix A April 15,1998 Rev.*24 2.5 INSTRUMENTATION AND CONTROL SYSTEMS / FEATURES 2.5.1 Criticality Accident Alarm System l
The Criticality Accident Alarm System (CAAS) is used for warning plant personnel of a criticality incident.
j The system is designed to detect gamma radiation and provide a distinctive, audible signal that will alert l
personnel to evacuate the areas that are potentially affected.
A block diagram of the overall system configuration is depicted in Fig. 2.5-1. In addition to the devices described in the figure, one other type of detector is associated with the system. This detector is identified as the argon gammagraph detector. This detector and its logic was not changed or affected by the changes for the HAUP and will not be discussed. For more information on these devices and their functions, refer to Sect.
3.12.7 of the PGDP SAR.
l The CAAS was significantly affected by the HAUP due to the additional areas requiring criticality alarm coverage. The entire system will be described and reviewed for acceptability.
l 2.5.1.1 Principal Design Basis and Criteria The primary input (i.e., principal design criteria) for the CAAS is ANSI /ANS 8.3. The following design criteria support the present bases for CAAS at PGDP.
2.5.1.1.1 Text Deleted l
2.5.1.1.2 ANSI /ANS 8.3 1.
Gamma radiation detectors shall be capable of detecting a criticality that produces an absorbed dose in free l
air of 20 rads of combined neutron and gamma radiation at an unshielded distance of 2 m from the fissionable material within 60 seconds. Areas where this requirement is not met must have adequate justification for not providing alarm coverage. It should be noted that this requirement is not applicable to areas containing material less than I wt % "U.
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2.
The system shall automatically initiate an evacuation alarm signal within one half second of the alarm l
setpoint being exceeded. The building evacuation alarm system shall be capable of being manually activated from a central remote location.
3.
Text Deleted l
4.
The system shall remain in an alarm condition after initiation regardless of radiation levels returning to normal until a manual reset of the alarm has been accomplished. Reset capability shall be limited in access to preclude inadvertent reset and shall be located outside the area to be evacuated.
5.
The local evacuation alarm system shall be able to perform its function without the aid of off-site alternating current (ac) electrical power or the plant air system.
6.
The system shall be designed to preclude inadvertent initiation signals to the extent practical to provide system credibility.
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SAR-PGDP Chapter 4, Appendix A November 5,1998 Rev.'29 / RAC 98C106 (RO)
PROPOSED i
7.
The system shall be designed to provide an indication of system malfunctions for alerting personnel of maintenance requirements.
8.
A means shall be provided to test the response and performance of the system (excluding the sounding of the alarm) without causing an evacuation alarm. In addition, the ponions of the system not affected by the test shall still remain functional.
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- 9. LThe system shall provide sufficient information to the Central Control Facility (CCF) to allow implementation of site emergency response procedures for criticality accidents; this information shall be provided independent of off-site ac power for a minimum of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
1 110. The alarm signal shall be for immediate evacuation purposes sly and of sufficient volume and coverage to be heard in all areas that are to be evacuated.
- 11. The CAAS shall remain operable in the event of seismic shock equivalent to the site-specific design basis earthquake or the equivalent value specified by the Uniform Building Code.
Each of these criteria will be addressed in Sect. 2.5.1.3 by illustrating how the system meets the requirements.
2.5.1.2 System Description The CAAS is primarily divided into three categories for description. These three areas are the local alarm system, building alarm system, and the Building C-300 CCF alarms and controls. The local alarm system includes the individual cluster unit detectors that provide detection capability for the entire system.
The cluster unit detection system actuates both visual and audible alarms in the affected area (s). The personnel alarms that would be activated consist of:
a local horn (continuous high pitched blast) actuated by plant air or by nitrogen or an electronic horn, e
building horns (air or electric),
. red rotating or strobe beacons located on the outside of buildings, and an audible and visible alarm on the Building C-300 CAAS control panel.
I The local and building horns produce a loud, distinctive sound and are used as an emergency signal for immediate evacuation of all personnel from the building or area.
Due to the significant number of changes in this system, the local and building alarm system will be described first. Once the basic concept has been established, each building or area will be discussed in detail to provide information on the specific configuration and how the system is arranged.
2.5.1.2.1 Local alarm system The local alarm system consists of three major devices: the cluster unit, the localjunction/ horn control box, and the alarm horn. The cluster unit sends the required input to the building alarm system and to the CCF. The
' individual local alarm units are located throughout the plant as indicated on Fig. 2.5-2. C-710 and C-720 do not have a specific local horn.
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SAR-PGDP Chapter 4, Appendix A November 5,1998 Rev.'29 / RAC 98C106 (RO)
PROPOSED from the detector circuit to the building alarm system could cause spurious operation of the system. liowever, past operational history has shown this portion of the system to be reliable in preventing spurious alarms within the system. Therefore, based upon the detection logic and past operational experience, the system configuration meets the applicable criterion.
Section 2.5.1.2.1 previously described the self-testing capability of the individual detector channel by the function of the LED light source within the assemblics. This meets the requirements for indication of system malfunctions for the detector channels (Criterion 7). In addition to this capability, the power supply circuits are monitored with appropriate alarm indication within C-300 as well as the local horn control boxes as described previously. In addition to the self-monitoring of the system, periodic testing of the system is also performed as described in Sect. 5 to verify proper system operability.
Test circuits and switches are located throughout the system to allow for system verification as described in Sect. 5. In addition, local alarms will remain operational as long as the individual alarm is not being tested.
These local alarms will still send input to the building alarms during these conditions unless the building alarms have been disabled before the test. The individual detector channels have their own test circuit along with the cluster logic module. The building alarm system can be tested by the IIORN CONTROL SWITCil as previously described Therefore, the system meets the testability requirement specified in Criterion 8.
As described in Sect. 2.5.2, all of the alarms and fault conditions are displayed in C-300. Section 2.5.2 gives a detailed evaluation of this requirement (Criterion 9) for the CAAS.
Criterion 10 is one of the most difficult portions of the system to verify by analysis. ANSI /ANS 8.3-1986, Sect. 4.4.1, requires that the alarm signal shall be for immediate evacuation purposes nnly and of sufficient volume and coverage to be heard in all areas that are to be evacuated. Those areas that do not have sufficient volume to be audible are being addressed under the PGDP Compliance Plan.
The following acceptance criteria were developed using approved industry standards and are used by PGDP to verify compliance with ANSI /ANS 8.3,1986 CAAS audibility requirements:
- 1) Ensure the broadband CAAS alarm signal is at least 10 dB above the maximum expected bioadband background noise. If this criterion cannot be met, go to step 2,
- 2) Ensure the 1/3 octave 500 liz CAAS alarm signal is at least 13 dB above the maximum expected 1/3 octave 500 Hz effective masked threshold. If this criterion cannot be met, go to step 3.
- 3) Expose a minimum of ten people, representing 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.
Pl? report number PIP:45-89-0043, Improve Maintenance and Monitoring of Radiation Alarm System",
documented that the present system could not be proven to meet Criterion 11. This section requires that the system remain operable in the event of a seismic shock equivalent to the site specific design basis earthquake or the equivalent value specified by the Uniform Building Code. The CAAS does not meet seismic qualifications. Specific exceptions to ANSI /ANS 8.3 criteria are listed in SAR Section 1.6.
2.5.1.4 CAAS Safety Class Equipment and Instrumentation The CAAS is designated a safety system. The core of the CAAS is the radiation detection cluster unit, the alarm horn control box, and the local alarm horn which are installed throughout PGDP where fissionable material is handled and a non-trivial risk of a criticality exists. These devices must function in order to initiate a prompt evacuation of personnel from the area of detection in the event of an inadvertent criticality.
Tne following are the components of the CAAS which are identified as safety system components:
building CAAS horns and lights (lights are not safety system components in C-710 and associated facilities) gamma criticality monitors (cluster):
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l SAR-PGDP Chapter 4, Appendix A October 31,1998 Rev.'29
{
three detectors, one common control panel; i
alarm horn control box (where applicable):
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- one nitrogen regulator (where applicable),
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two pressure switches (where applicable),
one air to nitrogen control valve (where applicable),
alarm cabinet (relay matrix):
e
' control relays (W, Y, and Z relays),
l local alarm horns.
2.5.2 Central Control Facility Provisions and Features 2.5.2.1 System Description At the radiation alarm system console, the operator can identify cluster units in an " ALARM" or
" TROUBLE" state, silence alanns, test and turn on building horns, and disable alarms.
The radiation alarm system console is located in C-300 (CCF). Portions of the radiation alarm system console front panel are shown in Fig. 2.5-15. Portion " A" of Fig. 2.5-15 is a plot plan that depicts the alarm
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indicators and controls associated with each cluster unit. Figure 2.5-16 shows a grouping of indicator lights and control switches, all of which are common to the radiation alarm system console. The functions of the i
components shown in Fig. 2.5-15, portions "A, " "B," and "C," are discussed below.
A group of indicators and switches provide indications and controls for one cluster unit. This cluster unit plot plan is shown in portion "A" of Fig. 2.5 '5.
1, 10-mR Alarm Light The red 10-mR light comes on, along with the console horn, when a criticality alarm signal is received from the related cluster unit. After the alarm condition is over, this light is reset by pushing the CL 1
RESET (cluster reset) switch, which turns off the 10-mR light and resets the logic in the cluster unit (see Sect.-2.5.1).
2.
Memory Light This light is part of the MEMORY /CL RESET combination as shown in Fig. 2.515, portion "A."
When a criticality event signal is received, the red 10-mR and blue MEMORY lights come on and the red 2-R light comes on if conditions so warrant. Reset of the 10-mR light is discussed in item 1; however, after the criticality event is over and no alarm signal is being received from the cluster unit, the MEMORY light will remain ON until the console operator actuates the MEMORY RESET switch located in the common indicators and controls section (see Fig. 2.5-15, portion "B").
3.-
CL (Cluster) Reset Switch i
The CL RESET switch is pushed to reset the logic in the cluster unit and turn off the 10-mR light at the L
. radiation alarm system console when a criticality event is over.
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GDP 98-0215 Page1of4 l
United States Enrichment Corporation (USEC)
Certificate Amendment Request CAAS Audibility Upgrades-Compliance Plan Issues 46 and 50 Significance Determination The United States Enrichment Corporation (USEC) has reviewed the proposed changes associated with this Certificate Amendment Request and provides the following Significance Determination for consideration.
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1.
No Significant Decrease in the Effectiveness of the Plant's Safety. Safeguards. or Security Programs i
This Certificate Amendment requests NRC review of a modification to the CAAS system audibility criteria and a change in the schedule for completing Compliance Plan Issues 46 and 50. Neither the CAAS system audibility criteria nor the schedule for completing Compliance Plan Issues 46 and 50 are addressed in the plant safeguards or security programs contained in Volume 3 of the Application for United States Nuclear Regulatory Commission Certification for the Paducah Gaseous DifTusion Plant. With regard to the criticality safety program, the current JCOs, including the required compensatory measures, for both Compliance Plan issues will remain in effect to provide adequate i
evacuation notification until the upgrades are completed. As a result, the effectiveness of the plant's safety, safeguards, and security programs is unaffected by this certificate amendment. The modifications to the CAAS system audibility criteria have been shown not to diminish the l
efTectiveness of the CAAS system.
2.
No Significant Change to Any Conditions to the Certificate of Comnliance None of the Conditions to the Certificate of Compliance address the modification of the CAAS system audibility criteria, or the schedule for completing the Compliance Plan issues associated with CAAS audibility. Thus, the proposed changes have no impact on any of the Conditions to the Certificate of Compliance.
3.
No Significant Change to Any Condition of the Annroved Comnliance Plan The proposed changes involve a change to the schedule for completing Compliance Plan Issues 46 and 50 and a modification of the CAAS system audibility criteria. Extending the completion date for the modifications is not a significant change because the JCOs for Compliance Plan Irsues 46 and 50 will remain in effect until the modifications are completed, including the e quired compensatory measures. The CAAS system audibility criteria are not addressed in the compliance l
plan.
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GDP 98-0215 Page 2 of 4 United States Enrichment Corporation (USEC)
Certificate Amendment Request CAAS Audibility Upgrades-Compliance Plan Issues 46 and 50 Significance Determination 4.
No Siunificant Increase in the Probability of Occurrence or Conseauences of Previousiv Evaluated Accidgnis The proposed changes involve a change to the schedule for completing Compliance Plan Issues 46 and 50 and a modification to the CAAS system audibility criteria. Extending the completion date for the modifications to improve CAAS audibility has no effect on the probability of occurrence of a criticality accident. The consequences of a criticality accident will not be significantly increased since the ability of the CAAS to detect a criticality will not be affected and the compensatory measures for CAAS audibility required by the JCOs for Compliance Phm Issues 46 and 50 will remain in effect until the modifications are completed.
The modification of the CAAS system audibility criteria for verifying field audibility does not to diminish the effectiveness of the CAAS system in alerting personnel to evacuate the area. Therefore,-
the consequences associated with' an inadvertent criticality will not increase. Finally, the modification of the CAAS system audibility criteria have no effect on the probability of a criticality, j-5.
No New or Different Tyne of Accident The CAAS is only used to mitigate the consequences of a criticality accident which has been j
l previously evaluated in the Safety Analysis Report. No new or different type of accident has been l
identified.
6.
No Significant Reduction in Margins of Safety The proposed changes involve a change to the schedule for completing Compliance Plan issues 46 l
and 50 and a modification of the CAAS system audibility criteria. Extending the completion date for the modifications does not reduce the margin of safety because the JCOs for Compliance Plan Issues 46 and 50 will remain in effect until the modifications are completed, including the required L
. compensatory measures. Likewise, modifying the CAAS audibility acceptance criteria does not L
reduce the margin of safety because the additional criteria that have been proposed are at least as effective in ensuring audibility as the previous audibility criterion.
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GDP 98-0215 Page 3 of 4 United States Enrichment Corporation (USEC) i Certificate Amendment Request
. CAAS Audibility Upgrades-Compliance Plan Issues 46 and 50 Significance Determination 7.
No Significant Decrease in the Effectiveness of any Program or Plans Contained in the Certificate Application For the reasons discussed in the response to Item 1 above, there will be no significant decrease in the effectiveness of any program or plan contained in Volume 3 of the Certification Application.
8.
The Proposed Changes do not Result in Undue Risk to 1) Public Health and Safety. 2) Common Defense and Security. and 3) the Environment The proposed changes involve a change to the schedule for completing Compliance Plan Issues 46 and 50 and a modification of the CAAS system audibility criteria. As discussed in the response to Item 4, neither of these changes will result in a significant increase in the probability of occurrence or the consequences ofpreviously evaluated accidents. In addition, no new accidents associated with this change have been identified. Thus, there will be no undue risk to public health and safety or to the environment. The proposed changes will have no impact on common defense and security because the proposed changes do not modify the plant safeguards or security program.
' 9.
No Change in the Tynes or Significant Increase in the Amounts of Any Effluents that May be Beleased Offsite The proposed changes involve a change to the schedule for completing Compliance Plan Issues 46 and 50 and a modification of the CAAS system audibility criteria. As discussed in the response to Item 4, neither of these changes will result in a significant increase in the probability of occurrence or the consequences of a criticality accident. Therefore, there will be no change in the types or significant increase in the amounts of any effluents that may be released offsite.
- 10. No Significant increase in Individual or Cumulative Occunational Radiation Exposure The CAAS is only used to mitigate the consequences of a criticality accident which has already been evaluated in the Safety Analysis Report. As discussed in the response to item 4, neither of these changes will result in a significant increase in the probability of occurrence or the consequences of a criticality accident. As a result, the proposed changes will not cause a significant increase in individual or cumulative occupational radiation exposure.
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GDP 98-0215 Page 4 of 4 United States Enrichment Corporation (USEC)
Certificate Amendment Request i
CAAS Audibility Upgrades-Compliance Plan Issues 46 and 50 Significance Determination
- 11. No Significant Construction Imoact This change involves an exiaing plan for a plant modification and only changes the completion date of the project. Therefore, there is no significant construction impact.
- 12. No Significant Increase in the Potential for Radiological or Chemical Consequences from Previousiv Analyzed Accidents The proposed changes involve a change to the schedule for completing Compliance Plan Issues 46 and 50 and a modification of the CAAS system audibility criteria. As discussed in the response to Item 4, neither of these changes will result in a significant increase in the probability of occurrence or the consequences of previously evaluated accidents. In addition, no new accidents associated with this change have been identified. Therefore, there is no significant increase in the potential for radiological or chemical consequences from previously analyzed accidents.
- o GDP 98-0215 3 Pages l
Letter to Mr. Steven A. Toelle (USEC) from Randall M. DeVault (DOE),
Paducah Gaseous Diffusion Plant - Docket No. 70-7001 -
Department of Energy Approval of Change to Compliance Plan Issue 46 and 50, dated October 29,1998 f
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Department cf Energy i
'I Oak Ridge Operations Post Office Box 62 Oak Ridge, Tennessee 37831 -8651
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October 29, 1998 Mr. Steven A. Toelle Nuclear Regulatory Assurance
- and Policy Manager United States Enrichment Corporation 2 Democracy Center 6903 Rockledge Drive Bethesda, Maryland 20817
Dear Mr. Toelle:
PADUCAN GASEOUS DIFFUSION PLANT - DOCKET NO. 70-7001 - DEPARTMENT OF ENERGY APPROVAL OF CHANGE TO COMPLIANCE PLAN ISSUES 46 AND 50 The United States Enrichment Corporation (USEC) in a letter dated October _19, 1998, requested Department of Energy (D0E) approval of changes in the schedule for the completion of the Paducah Gaseous Diffusion Plant (PGDP)
Compliance Plan Issue 46, " Criticality Accident Alarm System - Horn Audibility," and Issue 50, " Criticality Accident Alarms for Nearby Buildings."
This change in schedule extends the completion date for modifications to the Criticality Accident Alarm System (CAAS) from December 15, 1998, to January 18, 2000.
DOE has reviewed USEC's request for this change and finds the PGDP Compliance Plan changes acceptable. The USEC requested changes to the PGDP Compliance Plan are therefore approved by DOE. We note that the revision to Compliance Plan Issue 50 contains a statement referring to the relocation of facilities to locations outside the evacuation area. However,.in your " Justification for the Change," a statement is made that all facilities that were planned to be removed have been relocated. DOE reconnends deletion of the relocation statement from the proposed revision to Issue 50.
If there are any questions or coments on this approval, please contact me at i
(423) 576-0802.
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Sincerely,
[ Randa 1 M. DeVault Regulatory Oversight Manager Office of Assistant Manager for Enrichment Facilities l
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Steven A. Toelle October 29, 1998 1
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.T. D. Reidinger, NRC, Region III R. M. George, NE-40,'.GTN G. G. Pennington, Bechtel Ja. cobs, NS-8651, K-1550V
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l GDP 98-0215 Page1of1 New Commitments Contained in this Submittal 1.
Plant modifications will be initiated to ensure that the CAAS alarm homs are capable of being heard throughout the affected areas of the process buildings, except areas in permit required confined spaces and cell housings associated with cells that are running. The revised TSR applicability statements and surveillance requirements for the new system will be submitted fer NRC review and approval by February 26, 1999. All modifications necessary to meet the requirements of Compliance Plan Issues 46 and 50 will be completed by January 18,2000.
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