ML20195H477
| ML20195H477 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant, Paducah Gaseous Diffusion Plant |
| Issue date: | 03/31/1997 |
| From: | Jeremy Dean, Hurrell S, Resnir V External (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20195H463 | List: |
| References | |
| KY-S-267, KY-S-267-R02, KY-S-267-R2, NUDOCS 9906170058 | |
| Download: ML20195H477 (69) | |
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KYi3-267 l
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TECHNICAL JUSTIFICATION FOR THE t
EXEMPTION OF C-146-A, C-733, C-754, C-754-A, C-333, AND C-757 WASTE STORAGE FACILITIES ji FROM CRITICALITY ALARM REQUIREMENTS I
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March 1997
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Report Prepared by
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Name Date CAUTION This document has not been given final patent clearance and is for intemal use only If this e
document is to be ghen puNic release, it must be cleared through the site Technical Information Office which will see that the pmper patent and Icchnical information reviews are completed in
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accordance with L'tility Settices Policy.
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l 9906170058 990301 ADOCK 0700 001 P.DR
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Paducah Gaseous Difrusion Plant I
TECHNICAL JUSTIFICATION FOR THE EXEMPTION OF C-746-A, C-733, C-754, C-754-A, C-333, AND C-757 WASTE STORAGE FACILITIES FROM CRITICALITY ALARM REQUIREMENTS g
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March 1997 1
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Report Prepared by i
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11645 South Monticello Drive Knoxville, Tennessee 37922 under i.
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LOCKHEED MARTIN UTILITY SERVICES,INC.
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i, United States Enrichment Corporation under contract USECHQ 93-C-0001
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L DISCLAIMER 1,
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This report was prepared as an account of work sponsored by an egency of the Unrted States Govemment. Neither the Urvted States Govemment nor any agency r
thereof, not any of their emptcyees, makes any warranty, empress or impEed, or assumes any legal Esbilrty or responsibility for the accuracy, completeness, or usefulness of any informa' ion, apparatus, product, or process disclosed, or represents that its use would not intnnge pnvately owned rights. Reference herein to soy specific commercial product, process, or service by trade name, trademark,
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manufacture, or otherwise, does not necessenty constitute or imply ets endorsement, recommendation, or favoring by the Uruted States Govemment or any agency 1
thereof. The views and opwwons of authors expressed herein do not neesssardy state y
or reflect those of the Uruted States Government or any agency thereof.
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KY/S 267 L.
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Revision 2 l
Approvals f
TechnicalJustifiention for Exemption from Criticality Alarm Requirements for C-746-A, C-733, C-754, C-754-A, C-333, sad C-757 Waste Storage Facilities Paducah Gaseous Diffusion Plant l^
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NCS Analyst Date r
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CONTENTS l 9 4
List of Tables................................................................. v i
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i L i st of Figures.............................................................. v i 1..
Acronym s................................................................... v i i i
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- 1. INTRO DUCTI ON........................................................
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i 1.1 B UI LDING C-74 6-A..................................................
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' t 1.2 B UILDING C-73 3....................................................
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' b i.3 B ui tDiNG C-75 4..................................................... 4
- ,r l.4 B UILDING C-754-A................................................... 5 l 0 ll 1.5. B UI LDING C-3 3 3................................................
... 5 l.6 B UI L DING C-7 5 7..................................................... 5 t
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1.7 G ENERAL CONTROLS................................................ 6 i>
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- 2. M ETHO DO LOGY........................................................
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- 3. AS S U M PTI ON S.......................................................... 20 t
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- 4. RES U LTS.............................................................
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4.1 B UILDING C 74 6-A.................................................
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4.2 B UI LDING C-73 3...................................................
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4.3 B UI LDING C-754.................................................... 24 l(
4.4 B UI LD ING C-7 5 4. A.................................................. 2 6 l<
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- 4. 5 B UI LDING C-3 3 3.................................................... 2 7
- a 1 t4 4.6 B UI LDING C-7 5 7.................................................... 29 1-l n.
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j CONTENTS (contissed) l.
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CONC L U SI ON S........................................................ 31 e
- 6. RE FE RENCES.........................................................
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!I Ar-;endix A FACILITY LAYOUTS........................................... A 1 1
' Appendix B FACILITY WALKDOWN SHEETS AND DATA SUMMARIES........... B-1 I
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TABLES T
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Summary of changes in waste generation and storage.......................... 9 2.
Facility walkdown sheet................................................ I1 s
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Building C 746-A walkdown sheet....................................... B 1 B2 Building C-746-A data summary........................................ B-4 B-3 Building C-733 walkdown sheet.......................................... B 5 B-4 Building C-73 3 data sum mary........................................... B.8 B-5 B6ilding C 754 walkdown sheet.......................................... B-9 B-6 Building C-754-A walkdown sheet...................................... B 12 B-7 Building C-3 3 3 walkdown sheet......................................... B-15
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B-8 Building C-757 walkdown sheet......................................... B-18 t
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FIGURES i
1 N CS XPT e v ent tree................................................... 14 2
IN ADFIS event tree................................................... 17 A-1.
Building C-746-A general layout......................................... A-1 A-2.
General area around Buildings C-746-A and C-746.B........................ A 2 A-3.
Building C-733 general layout........................................... A-3 A 4.
Building C-754 general layout........................................... A-4 a
A-5.
Building C-754-A general layout........................................ A-5 A-6 Building C-757 general layout........................................... A-6 Y-6 1
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l' ACRONYMS AEC Atomic Energy Commission '
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ANSI
- American National Standards Institute li
'CAAS Criticality Accident and Alarm System J
DOE Department of Energy i
DOT Department of Transportation a
HAUP Higher Assay Upgrading Project l!
LLW Low Level Waste LMUS -
Lockheed Martin Utility Systems, Inc.
,.j MORT Management Oversight Risk Tree l;
NCS Nuclear Criticality Safety -
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NCSA Nuclear Criticality Safety Approval
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NCSE Nuclear Criticality Safety Evaluation 4
~ National Fire Protection Association NRC Nuclear Regulatory Commission OSHA Occupational Safety and Health Administration PCB polychlorinated biphenyt PGDP Paducah Gaseous Diffusion Plant RCRA
. Resource Conversation and Recovery Act TSCA' Toxic Substances Control Act UN.
. United Nations USEC United States Enrichment Corporation i
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CHANGELOG l
Rev Affected Pages Reason for Change Employee No initials 1
5,26, C 15 Added storage area in C-333 SJH 2
1.4,5,6,18,20,29-Added Building C-757 description and SJH 30, A-6 B 18 analysis t
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- 1. INTRODUCTION f
i There are several areas on the Paducah Gaseous DifTusion Plant (PGDP) site used to store waste generated by United States Enrichment Coiporation (USEC) operations. Some of these areas are owned by USEC and some are owned by the Department of Energy (DOE). Since they are storing USEC waste, all of these areas must comply with Nuclear Regulatory Commission (NRC) requirements regarding criticality monitoring and alarm systems (CAAS). A CAAS that complies with the guidance provided in ANSI /ANS 8.3 is generally considered acceptable by the NRC.' 10 CFR Part 76.89 requires a criticality monitoring and alarm system for all areas of the facility except for approved exclusions. An area is excluded from these requirements by obtaining approval of the measures that will be uwd to protect against criticality, including the kinds and quantities of material j
that will be permitted and measures that will be used to control those kinds and quantities of material. Waste generated from USEC operations is stored in C-746-A, C-733 C 754 C 754-A,
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and C-757. Waste owned by DOE is stored in space leased from USEC in C-333. These areas are l
not covered by a CAAS. The purpose of this evaluation is to determine the effectiveness of the measures and controls that prevent criticality in these areas by estimating the frequency of criticality I
due to the nssociated storage operations. This document describes the controls that will be itsed to ensure against criticality and tojustify the exemption from 10 CFR Part 76.89 for waste storage locations C-746-A, C-733 C-754, C-754 A, C 333, and C 757.
l The Energy Policy Act of 1992 transferred responsibility for PGDP from DOE to USEC effective July 1,19o3. With the transfer of responsibility for plant operations, the ownership of waste at the plant was divided between DOE and USEC. Waste containing polychlorinated biphenyl (PCB) or asbestos are the responsibility of DOE. In addition, all wastes generated before bly 1, 1993, and wastes generated after July 1,1993, resulting from operations and cleanup of spills, etc.,
that occurred when DOE and its predecessor, the Atomic Energy Commission (AEC), held exclusive responsibility for the site, belong to DOE. The enrichments of waste stored in facilities exclusively used by DOE, therefore, are constrained to 2% or less. All process waste generated after July 1 1993, which does not contain PCB or asbestos. but may contain up to 5.5% "'U, belongs to USEC.
Waste resulting from spills etc.. that occur during USEC ownership belong to USEC.
PGDP procedures require that minimum criticality spacing controls be used for waste with enrichments of greater than or equal to I wt*' "'U isotope and in quantities greater than or equal to the "always safe mass' for each container size. The basis for excluding wastes that are less than I l
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st% *"U is TechnicalJustifcation: Uranium Enriched to I.ess Than one Weight Percent :"U. Safe
)6r Operations at the Paducah Gaseous Dfusion Plant. KY/S-N8*. De basis for excluding wastes that are less than the "always safe mass"(120 g "U for a 5 gal container) from criticality spacing 2
requirements is Five Gallon Drum Waste OdStorage at 3.5% "Uat the Paducah Gaseous Dfusion Plant'. His Nuclear Criticality Safety Evaluation (NCSE), which considers double batching.
3 defines the "always safe mass" for a 5 gal container to be 120 g of"'U.
From its initial operation, PGDP has operated at enrichments below 2*'. 2"U. Current plans call h
for this product enrichment to increase to 2.75%:"U and then to a nominal 5.0% "U. A slight increase in assay, as much as 0.25 wt % :"U. may occur in the purge cascade and the product i
withdrawal system to ensure the correct product assay in the withdrawal cylinder. As a result of this i.
increase in the product enrichment, the assay of waste generated by process operations is expected
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to increase accordingly. To support operations at a nominal 5.0% "'U product assay, the criticality I
analyses associated with the Higher Assay Upgrading Project (HAUP) were performed at 5.5% 2"U i
t to bound this increase and for a degree of conservatism.
De storage locations evaluated in this justification may be used to store the following USEC-and DOE-ov.ned wastes:
B poly-chlorinated biphenyl(PCB) waste, t
t hazardous and mixed waste regulated by the Resource Conservation and Recovery Act (RCRA)
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Iow-level radioactive waste (LLW).
L lt should be noted that in addition to the wastes described abos c. Buildings C-716 A and C 733 are used to store wastes contaminated with detectable levels of PCDs. The waste containers stored in theses areas have been determined to be exempt from Nuclear Criticality Safety (NCS) spacing controls (NCS exempt) based on the above criteria. Waste is characterited in accordance with requirements provided in Nuclear Critically Safey Assessment of Waste Ressdtingpom Higher Assav Operations KY/S 253*.
The primary storage containers currently approved for use at the PGDP site are Department of Transportation (DOT) 17-C (for solids) and 17 E (for liquids) 55 gal metal drums. (Note that the e
new designation for these containers is a United Nations (UN) designation: :, UN embossed 1 A l\\X 16 Y
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corresponds to a 17 E and UN embossed I A2\\X corresponds to a 17-C.) Some of the other more commonly used containers include 5 gal and 30-gal metal drums, the 85 gal overpack (used to store a damaged or breached metal drum), and the B 25 metal box (approximately 4 ft x 4 ft x 6 ft)and roll-ofTbins which are used to store bulky solid waste. A maximum of four standard 55 gal drums are stored on a 4-x 4 fi wooden pallet. For waste considered to be NCS exempt (i.e., all waste stored in these facilities), fully loaded pallets may be stacked. RCRA and Toxic Substances Control i
Act (TSCA) wastes require 2-ft aisles between rows of pallets loaded with drums to enable proper drum inspection.
f He SS gal DOT 17-C and 17-E containers used at PGDP for waste storage are designed to the requirements of DOT-7A (49 CFR 178.350). Type A packages are designed to withstand the tests described in 49 CFR 173.465 and 173.466. Section 49 of CFR 173.465 requires that a package designed for solid materials maintain its integrity following a free drop test from a height of 4 ft.
Container integrity is considered breached if the centents of the packaging are dispersed outside of the container. It should be noted that while most of the waste storage containers in use at PGDP are designed to these DOT requirements, the low radiological content of the LLW does not require compliance with these requirements.
PGDP has formal procedures for handling, storing, and routinely inspecting waste containers to ensure that the containers continue to maintain their integrity. The frequency of container inspection depends on the type of waste stored. PGDP inspection procedures meet and in general exceed the requirements established by RCRA and TSCA. TSCA requires PCD waste containers i.
so be inspecad every 30 days; PGDP performs this inspection every 14 days. RCRA requires hazardous and mixed waste containers to be inspected weekly: PGDP performs this inspection daily.
PGDP inspects LLW containers every month.
Equipment used for handling drums is routinely inspected. Forklift trucks used to move pallets I
containing waste containcrs are required to meet American National Standards Institute (ANSI).
Occupational Safety and Health Act (OSHA), and National Fire Protection Association (NFPA) requirements.
PGDP maintains a data base that characterizes the waste stored at various locations on the plant site. This data is representative of the waste generated under DOE and AEC operations. However, this data is not representatise of hazardous waste that uill be generated by USEC during high assay operations. Conservative extrapolation of the current hazardous waste data was required to estimate
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the mass and enrichment of hazardous waste generated by future operations. LLW generated by h
future operations will differ from current data in that an effort will be made to maximize the "U r
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content cf NCS exempt waste containers to the alwsys safe mass for each contain:r size in erder is I
more efficiently use storage space.
Storage locations in Buildings C-733 and C 746-A will receise waste owned by both DOE and i
USEC. The enrichment of the USEC waste is expected to increase with the change to a higher plant l
production enrichment. As z result, the risk of criticality from future storage operations at these storage areas will be different from the risk of criticality from current storage operations.
f The new storage locations for LLW, Buildings C-754, C-754 A and C-757, both owned by l
USEC. will receive waste generated from production at 2% and higher enrichments.
1.1 Building C-746 A l
Building C-746-A is a RCRA-permitted facility used for storage of PCB, PCB/R, hazardous, and
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hazardous mixed waste. The building walls and roof are metal with a concrete floor that is fully diked and enclosed by a metal pan with 8 in. sides. Current storage areas inside the. building are shown in Fig. A l. Site features in the area of Building C-746-A are shown in Fig. A 2. The facility is provided with a dry piped sprinkler sy stem for fire protection. Fire water risers are located at each corner of the building. The operational capacity of this storage facility is 7440 55-gal drums.
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Wastes stored in this area may be solid, liquid, or sludges.
1.2 Building C-733 j
Building C-733 is a fully diked and roofed area used to store flammable hazardous and mixed wastes. As shown in Fig. A 3, Building C 733 is protected from the elements on two sides by Plexiglas pancis, and a chain link fence encloses the entire facility. The facility is permitted to store 700 55-gal drums plus four 3000 gal tanks. The tanks may be used to consolidate wastes which are later transferred to a tank truck for oft-site disposal. Nuclear Criticality Safety Evahoationjir Liquid Waste Tanker and Tanks at the Paducah Gaseous Difusion Mant' specifies the nuclear criticality safety controls for this operation. Wastes stored in this area may be solids, liquids, or sludges.
1.3 Building C-754 As shown in Fig. A-4, Building C 754 is a concrete pad covered by an aluminum framed canvas structure, called a clam shell building. Diked areas will be constructed as n. assary on the pad for
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drums with liquid contents. This facility will be used to house NCS exempt LLW generated by USEC. The facility is also used for the soning and sampling of the LLW. Waste materials that are excluded from NCS controls according to Nuclear Criticality Safety Approval (NCSA) GEN-07 are consolidated and repackaged in Building C-754 for shipment off site. The storage capacity is I
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spproximately 10,000 ft2 or 135155. gal drums
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!.4 Building C-754-A lf As shown in Fig. A 5, Building C-754 A is a gravel area covered by an aluminum framed y
canvas structure, called a clam shell building. This facility will be used to house NCS exempt LLW 1h generated by USEC. The storage capacity is approximately half of Building C-754. This facility i
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Is currently used to store roofing material that is slightly contaminated. De waste containers stored 1
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in this facility are roll-off bins.
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I 5 Building C-333 Building C-333 is a gaseous diffusion process building. Due to the locations of the criticality
- h, accident alarm detectors in this building some peripheral portions of the building are not provided l;
with CAAS coverage. Ground Goor areas on the periphery of the building, leased from USEC, are used to store DOE-owned waste that is exemp from NCS spacing controls. Since these storage
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areas are not equipped with CAAS coverage, they are included in thisjustiGcation. De DOE owned waste is PCB and LLW that is stored in 30, SS, and 85 gal containers on wooden pallets stacked
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two high. These wastes were produced during PGDP operations at an assay of s2 wt % 8"U lE operations. Therefore, the assay of this waste does not exceed 2 wt % 2"U. The various storage l[
areas within Building C-333 are provided with Gre sprinklers. The Building C 333 structure protects 1t[
the stored waste from external damage. Data used in the analysis of C 333 was current as of ll: '
February 1996.
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1.6 Building C-757 l
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Q, As shown in Fig. A-6. Building C-757 is a metal frame building on a concrete foundation. The l
,al' concrete area surrounds the building structure facilitating access by trucks to the many roll up doors.
l The facility is heated by natural gas heaters, but does not have a Gre sprinkler system. The facility l
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is divided into two areas by a wall. One area is currently used for the handling and compaction of l
non. radiological tnsh. The other area. designated as a radiological area will be used to store mixed l
waste containing both radiological and har.ardous contaminants.
l Solid waste will be stored on wooden pallets with four drums to a pallet. Liquid waste is stored l
on top of a metal containment pallet designed to accommodate any liquid releases.
l Waste that is currently stored in Building C-727 will be relocated to Building C-757. Storage l
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practices currently in place in Building C-727 will be used in Building C 757. At the time of the l
walk down. Building C-757 did not contain any radiological waste.
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1.7 GENERALCONTROLS L
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Each storage location discussed in thisjusti6 cation is limited in the type ofw aste it can accept.
The handling and storage of Lockheed Mar:in Utility Services. Inc.,(LMUS) wastes at PGDP is l,
strictly controlled by the following plant and departmental procedures:
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Plant Procedures:
f CP2 EW-WM1035 implements requirements for handling oflow-level radioactive waste.
CP2 EW.WM1036 -implements re ;uirements for handling and storing Gssile and potentially 6ssile waste.
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CP2 EW.WM1038 implements the requirements for handling and temporary staging of Gssile and potentially Gssile waste as provided in NCSA GEN 05. Departmental Procedures.
1 CP4 EW.WM2100 provides requirements for handling and temporarily storing 6ssile and potentially Gssile waste and repackaging waste.
l CP4-EW.WM2106 -implements requirements for handling and storing 6ssile and potentially Gssile waste in the C-333 Nuclear Criticality Storage Area.
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y CP4-EW.WM2107 - implements requirements for transferring and placing LLW in storage i
areas.
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Adh'erence to the procedures ensures that the correct waste type is stored in each facility lf
- 2. METHODOLOGY In order to assess the likelihood of a criticality in the waste storage ids the contents of i:
each storage location were evaluated to obtain a reasonable estimate of the type of waste stored, the
"'U assay of the waste, and the mass of "'U present in the facility. One difficulty in evaluating ij these parameters is that often the assay of the waste in a specific container is not available.
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However, numerous containers have been sampled and these containers are representative of the
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waste generated during operations in which the highest product enrichment was 2%. This sampling data is extrapolated, as discussed below, to estimate the n'U content of waste drums generated by future operations.
Reference 2 indicates that wastes with assays ofless than 1% will not cause a criticality. The significant content of 2"U in these wastes will tend to prevent a criticality accident. Based on this information, the contribution to a critical mass from "U in wastes with assays ofless than 1% was 2
t not considered in this analysis.
Available analytical data is used to estimate the number of drums in a facility that contain waste
!j with al% :"U. The characterization of the waste stored in each facility using the available analytical data is considered to be conservative since the drum sampling process is not truly random.
f The selection of a drum for sampling is biased based on the source of the waste. Waste that is likely r
P to be greater than or equal to 1% "'U and to contain relatively large quantities of"'U is more likely
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to be sampled because of NCS guidelines than, for example, waste known to be less than 1% "'U.
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Therefore, the percentage of drums sampled that are a 1% assay is higher than the percentage of 1
h, drums sampled that are <l% assay. The percentage of sampled drums that are al% is k'l conservatively considered to be representative of the total percentage of drums in the facility that 3f are a 1% assay, f*-
Waste management data was evaluated to determine, from a criticality standpoint, the " worst-(+,
case drum" for Buildings C 733 and C.746-A which will receive USEC RCRA waste. The current
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waste management data was extrapolated to encompass wastes that will be generated when PGDP
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operations increase to 5.5% enrichment. First, the data was reviewed and outliers (i.e., one time shipments of high uranium mass materials with assays less than 1% or similar wastes that are eenerated at a very low rate, for example, one drum per year) were eliminated from further consideration. The drum with the greatest mass of uranium was then selected as the worst case
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drum. Rather than its sampled enrichment, this drum was assumed to contain uranium waste with b
an enrichment of 5.5% "'U. The extrapolated value for "'U content was then calculated. For instance, the worst case drum in Building C-746-A (RFD 05536) contains 358 lb of waste at a total e
j uranium concentration of 2396 ppm at an assay of 0.90%. Based on this information, the content ll of this container is:
f 358 lb of waste x 2396 parts U/10' parts waste = 0.858 lb U 0.858 lb U = 0.009 "SU/U = 454 g/lb = 3.5 g "'U.
For the purposes of this analysis, the assay of the waste was assumed to be 5 5% such that the
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worst-case drum has an extrapolated "*U content of:
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0.858 lb U = 0.055 2"U/U = 454 g/lb = 21.4 g "'U.
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Buildings C 754 and C-754-A will receive LLW from current operations and, potentially, LLW from higher assay operations. The exact "'U mass of LLW generated in the future is unknown; this analysis conservatively assumes that the worst-case drum holds the always safe mass for each container size (120 g "SU for a 5 gal container). This is the highest "U content at which a waste 2
drum can be considered NCS exempt and the highest mass per container that will be placed in thew areas.
I With the exception < ; i: silding C-333 waste data, the waste data used to determine the credibility of a criticality m.olving waste containers veas collected in 1993. '(The Building C 333
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waste data was collected in February 1996.) Waste management personnel from USEC and DOE were interviewed to determine if any significant changes in the nature of the waste stored that would j
affect the calculation of the worst-case drum had occurred since 1993. The results of these
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interviews are summarized for each facility in Table 1. No changes in the worst case drum or assumptions were identified since plant operations have not significantly changed since the I
collection of data in 1993. In addition, the requirements for waste segregation and storage have not 2.
changed.
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l Table 1. Summary of changes la waste generation and storage Facility Summary of changes q
C-733 No significant changes in the nature of the waste stored.
Waste in Building C-733 dependent on plant operations which hase not changed significantly L4 C-746-A No significcat changes in the nature of the waste stored C-754 Functional change from waste storage only to waste sorting and storage will not affect the anal) sis. Worst-case drum is based on maximum NCS-exempt 5-gal drum (120 g "U)*
C-754-A Worst case drum is based on maximum NCS-exempt drum (120 g "U)*
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- Current sample data of waste currently stored in Buildings C-754 and C-754-A and waste typical of that which would be stored in these facilities indicates :"U content of each drum well below the 120 g assumed worst-case 5-gal container.
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After determining the worst-case drum for each facility. it was necessary to determine the number of worst-case drums required to achieve a criticality. As previously discussed. it is unlikely that a waste container's assay would exceed 5.5% ;"U. Subcritical Dimemi<ms)br Water Refected UOf, aml Water Systems at L3 Weight Percent Enrichment KYiS-:::' indicates that for an assay of 5.5%. more than 22.3 kg of uranium (i.e.,1.23 kg of SU) in a single container would be required FV to form a critical mass. This analysis makes the conservative assumption that every accident would involve drurns with contents equivalent to the facility worst-case drum. It follows that the number of worst-case drums equivaient to a total of 1.23 kg *U must be released in an accident to cause a criticality.
Walkdowns were performed to identify the types of accidents likely to occur in each facility.
Before the walkdowns, a table of potential accident initiators was developed to facilitate the evaluation of each facility. This table was developed using the DOE Management Oversight Risk Tree (MORT) list of hazards as a guide. Accident initiators (resulting from a failure to control a hazard)'that are applicable to the storage and handling of containerized waste were. selected for inclusion in the table. Accident initiators were grouped according to the release mechanism involved. Table 2 was used as a starting point for the evaluation of each facility. During the walkdowns, each facility was evaluated to qualitatively determine the potential for each initiator on the list to occur. If an initiator was determined to be relevant and applicable to a particular facility, an estimate of how many containers might be impacted by the initiator was made. The potential for the accumulatior of released material due to gravitational settling. sprinkler actuation, etc., was also evaluatei In t4ddition to the potential initiator information. other information pertinent to the impact of accidents at adjacent facilities on the storage area was considered.
The accident scenarios were then screened to determine which accidents could result in a criticality. The screening process involved a detennination of how many worst case drums in each facility would be required to accumulate sufficient material for a critical mass. This number was compared to the estimated number of drums involved in each accident scenario.
If the number of drums necessary to form a critical mass was greater than the number of drum s potentially involved in an accident scenario, a criticality due to that accident scenario was not considered credible (i.e., frequency <10*/ year). If the number of drums necessary to form a e
criticality was less than or equal to the number of drums involved in the accident scenario, further evaluation of the accident scenario was performed.
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I Pallet dropped during transport (human error, hardware) i I
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6.,
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hardware)
P Corrosion internal human error in loading container (e.g. material L
incompatibilitv)
V Esternal exposure to air, sun.
moisture, etc.
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12 Release Mechanism Potential Initiators Dalmate of Amoest of Material Releswd (drums) f Extemal undetected caustic spill 1
f Containen impacted by fire Containen impacted by extemal vehicles 1
~
Containers impacted by adjacent facility operations Containers impacted by roof snow load collapse due to:
t high wind / tornado earthquake Containers impacted by tornado missiles generated from:
Containers impacted by fall earthquake and'or fa!!ing objects due to:
1.1 If. nem ems;4etiem of the wreenmg andysis an xcident wenano was fouest to hase the pcocessa! no caaw a enticality, a qui tatne esatutam was perfmned to justify elimmatmg the acodent scenario frem fwther emuderstmr The qulitaine esaluations usually consider more realistic physical emwquences of the xciJent wenano that would preclude the critical c=figuret If qualitatise argumen:s ens!d not be uwd to eliminate the accident wenano from further consideration, a quantitatne analysis of the acendent scenano using esent trees was performed to estimate the frequency of the accident scenarios that rewlt in a criticality.
Two types of criticality accident scenarios pertinent to these storage locations are identilled.
i The first accident scenano, modeled by es ent tree NCSXPT. ins ois es the release and accumulation of NCS exempt material into a critical configuration. The second accident scenario modeled by event tree INADFli involses the placement of two NCS controlled containers at optimum conditions into an NCS exempt storage array. It should be noted that the addition of one NCS controlled container into the NCS exempt storage array was determined to be suberitical by a
i Reference 4 I
i 1
NCSXPT EVENT TREE l
The NCSXPT event tree, shown in Fig.1. models criticality sequences that result from the accumulation of NCS exempt material released from containers breached by different initiating events. A generic initiating event was used in this event tree so that the various accident initiators identified in the walkdowns could be modeled with the same event tree. Conditions necessary for the released material to accumulate such that a critical configuration results were modeled as lines I
of as'urance. The initiating event and the lines of assurance are described below.
s j
NCSXFT Initiating Event i
5 I
The NCSXPT initiating event is generic in that any accident scenario that would breach drums containing a minimum critical mass of fissile material may be substituted in this event tree. In Sect.
- 3. the most frequent initiating event for each storage location that could release a critical mass is substituted into this event tree and quantified.
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MATREL Basic Event 1
1 De event tree event htATREL is modeled as a single basic es ent. This event models the release l
of all the material from the container such that it is available for accumulation into a critical mass.
If the material in the breached container is in a liquid form, all the material is considered to be released from the container. If the material in the breached container is in a solid form, only a small
,l portion would be released outside the container such that it could accumulate in a critical configuration. It should be noted that with the exception of material stored in Building C-733 most i
i-of the waste containers stored by USEC are in a solid form. The probability that all the material in the breached containers is released from the container is conservatively considered to be 1.0.
l:
MATMOVE Basic Event 1
il 1
The event tree event NIAThlOVE is modeled as a single basic event. This event models the movement of the released material from the point at which the breach occurs. The storage areas are all on a level grade such that movement of material is, for the most part, minimized. While liquids I,
may flow from the point of a breach, no credible mechanism exists to dissolve and transport this waste from the point of release. A sprinkler system actuation may cause released material to move, but the actuation of a sprinkler system coincident with most accidents that release a critical mass of o
It material is not considered credible. It should be noted that only one of the storage areas (Building 1
C-716 A) has a sprinkler system. It should also be noted that fires that would actuate a sprinkler are unlikely to release critical mass quantities of waste. Although only a small portian of the waste stored by USEC is in a form that supports tr.ovement, the probability that the released material moves from the breach point is conservativel considered to be 1.0.
f MATACUM Basic Event The event tree event h1ATACUhl is modeled as a single basic event. This event models the accumulation of material released from multiple containers into a critical mass. As previously discussed, most of the USEC waste stored in these facilities is in a solid form. Although the waste material in a liquid form has the greatest potential to move and accumulate into a critical mass, this waste is stored in areas provided with dikes that prevent the accumulation of material from other i
l
16 storage areas. Based on this information the probability of released material accumulating in a critical masi is conservatively considered to be 0.1, I
GEOOPTM Basic Event The event tree event GEOOPTM is modeled as a single basic event. "This event models the accumulation of the rekased material in a geometry that is near optimal from a criticality standpoint.
The optima! conditions for this situation as analyzed in Reference 6 is a sphere. While released liquid waste may accumulate in low points inside the diked areas, the geometry of the accumulation is likely to be a slab which is less reactive than the sphere used to calculate the maximum suberitical I
mass of 1.23 kg "U. Based on this information, the probability of the accumulation occurring at 2
near optimal conditions is conservatively considered to be 0.1.
CONDOPT Basic Event The event tree event CONDOPT is modeled as a single basic event. This event models optimal conditions for criticality consistent with the determination of the maximum subcritical mass in Reference 6. This event models the probability of achieving a set of conditions including a homogeneous solution of UO:F: and water surrounded by 30-cm of water reflector. Much of the waste stored by USEC is not homogeneous in nature. The non homogeneous waste may be contaminated metal, boundary control station waste consisting of personnel protective equipment, plastic, or rags that is not subject to accumulation in a homogeneous form. Even the USEC homogeneous waste (trap mix and waste oils) would require considerable mixing with water to form a homogeneous solution of UO:F and water. No mechanism exists for mixing the released material into a homogeneous solution. Accumulating a 30 cm layer of water reflector around the homcgeneous solution is not plausible given the absence of water sources in these facilities. Based on this information the probability of the accumulation of released material occurring at near optimal conditions for a criticality is considered to be 0.01.
j INADFIS EVENT TREE i
The INADFIS event tree, showa in Fig. 2 models the inadvenent placement of two NCS controlled waste storage containers into an NCS exempt storage array under optimum conditions.
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I, I8 The frequency with which a single NCS controlled container is accidentally placed in one of the NCS exempt storage areas is evaluated in Reference 4. A generic initiating event was used in this event tree so that the credible sequences for the inadsertent placement of one NCS controlled container in the storage array from Reference 4 could be analyzed. Conditions necessary for this p.
erroneous handling of waste containers to result in a criticality were modeled as lines of assurance.
The initiating event and the lines of assurance are described below.
INADFIS Initiating Event The INADFIS initiating event is generic in that any accident sequence from Reference 4 that would result in a NCS controlled drum being placed in an NCS exempt array may be substituted in the event tree. In Sect. 4 the most frequent sequence that involves the placement of a NCS l'
controlled drum in an NCS exempt storage array is substituted into this esent tree and quantified.
The most' frequent sequence identified for a single NCS controlled container to be inadvertently placed ia an NCS exempt storage area is calculated in Reference 4 to be 2E 0.%r.
This initiating event may also be used to analyze the placement of SCS exempt containers that l
are less than 5.0 gal (i.e. 2 gal) in volume in an array of NCS-ex:mpt containers. The analysis l
which determined that drums containing s120 g "U can be stored safely without NCS spacing l
3 controls only addressed 5 gal containers. While the extension of the 120 g limit to include larger l
volume containers can easily be made, the 120 g limit does not apply to containers smaller than 5.0 l
gal (e.g.,2 gal drums)in volume. However, the frequency of an error involving placement of a 2 l
gal container with s 120 g "U in an NCS exempt storage arra) is considered to be bounded by the l
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error which results in an NCS controlled container being placed in an NCS exempt storage snay.
l The basis for this statement is:
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Tuo-gal containers are only used for storage of slugged oil.
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Slugged oil in a 2 gal container will exceed 120 g "U, requiring NCS spacing controls.
l 2
l A 2 gal waste drum, containing s 120 g "U. that was inadvertently used to collect waste other l
2
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than slugged oil would most likely be consolidated with waste from other containers into a l
larger container.
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19 l
FISDRUM Basic Event The event tree event FISDRUM is model.d as a basic esent. This esent models the placement of a second NCS controlled waste drum into an NCS exempt storage array. The production of NCS lq contmiled waste drums (i.e. drums that exceed the alwa>s safe mass) at PGDP is extremely limited.
The nature of the waste generated at PGDP is generally of such low U concentration that it is
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unlikely that a 5-gal drum of the waste would contain >l20 g "U. During the approximately two 2
i j
years since initiation of HAUP NCS controls. there hase been no S. gal drums generated with >l20 l
g "U.
As discussed in Reference 4, the controls applied to these containers minimize the potential 2
y for a NCS controlled container to be placed in a LLW storage area. As previously discussed, the
[
most frequent sequence identified for a single NCS controlled container to be inadvertently placed l
in an NCS exempt storage area is 2E 03/yr. Considering the limited quantity of NCS controlled l'
containers produced each year and the potential for a common cause error, the probability that a 1
second NCS controlled container is placed in any NCS exempt array gisen the emmeous placement of the first container was conservatively estimated to be 0.1.
t,l SAMELOC Basic Event
'l j
The event tree event SAMELOC is modeled as a basic esent. This event models the placement I
of the second NCS controlled container in the same storage array as that modeled by the initiating esent. Since the production of NCS controlled waste drums is limited to on!) a few different plant locations. the probability that two separate waste generators would produce NCS controlled drums that would be analyzed at the same time such that the drums are shipped at the same time to the same erroneous storage array is negligible. The more realistic scenario involves the two drums being mislabeled by the same generator and shipped to the same NCS exempt storage location. The probability that a second NCS controlled container would be erroneously sent to the ume storage array is conservatively considered to be 0.1.
1 DRUMOIT Basic Event The event tree event DRUMOPT is modeled as a basic event. This event models the probability that the NCS controlled containers added to the NCS exempt storage area are near the near optimal conditions modeled in Reference 4. The analysis documented in Reference 4 uses the optimal l
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loading density for a 5 gal drum of 1500 gU/l. The probability that esen a single NCS controlled waste drum would have such a high loading of Gssile material is negligible. Iloweser for the purposes of this analysis, the probability of two waste containers having this near optimal loading was conservatively considered to be 0.1.
)
l OPTCOND Basic Event The event tree event OPTCOND is modeled as a basic event. This event models optimal conditions for criticality consistent with the analysis for the placement of a 5 gal NCS controlled drum in a LLW storage area that is documented in Reference 4. Reference 4 analyzed a single NCS controlled drum in a LLW storage array with full density water placed in between the drums and 30-cm of full density water reGector surrounding the array on the bottom and four sides. The probability that the optimal conditions of water between waste containers and water surrounding the array is considered to be 0.01 given the absence of water sources in the storage locations.
- 3. ASSUMPTIONS
- 1. This analysis assumes that the types of waste placed in each storage area are limited to those types modeled. This assumption is required to perform the analysis.
- 2. This analysis assumes that the worst-case drums stored in the new storage locations (C-754. C.
754-A. and C-757) contain the always safe mass for each speciGe container site (120 g "U for l
a 5-gal drum). This is a conservative assumption in that it minimizes the number of drums that must be breached in the analysis to result in a criticality.
- 3. This analysis assumes that requirements denned in Reference 4 for preventing the placement of an NCS controlled container in an NCS exempt storage area are implemented and controlled to maintain the validity of this analysis.
21 4.RESULTS The results of this anal) sis are in the form of the completed walkdown shests in Appendix B and the facility-specific discussions of the quantification of event trees NCSXPT and INADFIS r
'I presented below.
- i 4.1 BUILDING C-746-A The accident scenarios identined for this location are no difTerent from those likely to be encountered in any waste storage facility. A completed walkdown report for facility-specific accidents is"provided in Table B-l. Extrapolation of the waste management data, summarized in Table B-2, indicates that the worst-case drum in this facility would contain approximately 21 g of mU in the form of solid waste. In order to achieve a critical mass (i.e.. l.23 kg "U), approximately 58 drums with a fissile content of the worst case drum would have to be damaged. The only accident initiators identified for this facility that could possibly damage such a larFe number of containers is a tornado or an earthquake. A tornado strike that could result in a criticality is not considered credible since, rather than accumulating the released waste, a tornado would tend to distribute the waste, precluding a criticality. While it is considered credible that an earthquake could damage 58 drums (approximately 1% of the operational capacity of the building, 7440 drums) it is not very likely that 58 drums of released material could accumulate in a critical conGguration due to a number of factors discussed below.
The primary initiator of a release during an earthquake would be structural components impacting the containers. The only structural components capable of causing significant damage to the containers are the beams, which limits the number of drums impacted (i.e., the surface area under the beams is relatively small compared to the area covered by the drums). 'Ihe number of drums impacted by the structural beam depends on the failure mode. The greatest relesw occurs when a smaller number of drums are impacted because the force of the impact of the beam is concentrated on a few drums as opposed to being distributed among a number of drums. A secondary initiator of a release during an earthquake would be the waste containers falling from a stacked position to the floor. However, the SS-gal waste storage drums in use at PGDP are designed to sustain a 4 ft drop, precluding a significant release of material.
22 The higher uranium concentration wastes in Building C-746 A are primarily solids and sludges.
As a result, the quantity of material released from a damaged container will be limited. The phy sical form of the waste also makes transport and accumulation of any released material unlikely.
There are a variety of mechanisms that will preclude the accumulation of released material. The floors in the storage area of Building C-746-A are flat and are not conducise to' material mosement.
Other barriers to nnterial accumulation include a large number of drums containing, l'. enriched material and diked structures. Drums containing :1% "U may present the mosement of material without contributing fissile material to a critical mass. The numerous diked structures present in Building C-746-A would also prevent material movement.
Based on evaluation of Building C 746-A. an earthquake is the only accident that could damage more than 58 drums of material. Given the low probability of an earthquake, the I m probability that an earthquake would release more than 58 drums of material, and the extremely low probability that the released material would accumulate in a critical configuration. a criticality in C 746 A is not considered credible. Quantification of the NCSXPT esent tree in Fig. I with a 1000 year retum period earthquake results :n a conservative estimate of the critical enn11puration sequence frequency of I E-07/ year.
As previously discussed, Reference 4 addresses criticality scenarios that do not require the release and accumulation of material (e.g., placement of NCS controlled waste into an array of NCS j
exempt containers). Since the worst-case drum in this area has such a low fissile loading (21 g "U).
it is not considered credible for the accidental placement of a single NCS controlled drum in the Building C-746-A storage array to result in a criticality. Quantification of the INADFIS es ent trec in Fig. 2 using the most frequent pertinent accident sequence from Reference 4 (2E 03/> ear) as the initiating esent results in a conservative estimate of the critical configuration sequence frequency of 2E-08/yr.
4.2 BUILDING C-733 Evaluation of the storage facility in Building C 733 was made using the completed walkdown report and the listing of sampled waste containers provided in Tables B-3 and B-4. respectively.
Extrapolation of waste management data indicates that the worst-case drum in this facility contains approximately 12 g of 2"U in liquid waste. The storage capacity of Building C 733 is 700 55 gal drums and four 3000-gal tanks. In order to achies e a critical mass (i.e.,1.23 kg :"U in this facility, approximately 102 drums with a fissile content of the worst-case drum would has e to be damaged.
e
,h 23 lt Fire is a hazard in this facilitv since the wastes stored are considered ignitable. Potential overpressure events ccatribute to this concern since the sielent relief of excessive drum pressure could initiate a fire. The open structure of Building C-733 minimires overpressure events by maintaining the drums at ambient temperatures and limiting the accumulation of released gases.
t 1
Daily inspection of the drums in Building C-733 reduces the frequency of an os erpressure es ent by
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facilitating early detection of bulging drums. The facility is presided with a fire sprinkler s> stem
!i that would'quickly extinguish a fire thus minimizing the number of drums involsed. Moderation (e.g., by the water used for fire suppression) is accounted for in the models used to calculate the critical mass.
The only accideni initiators identified for this facility that could conceivably damage this many containers would be a tomado or an earthquake. A tornado strike was ruled out for the reasons stated previously.
It is not considered credible for an earthquake to rupture 102 drums. Since the $5 gal drums that are stacked are designed to sustain a 4 fi drop. falling of the stacked drums is not considered to result in a significant release. Another damage mechanism to the storage containers is impact from a structural beam. The beams in Building C-733 appear stronger and the dead loads are significantly less than those in Building C-746 A. In order to accumulate a critical mass, approximately 14% of the storage area drum capacity (700 drums) would have to be released. It is unlikely that a failure of the beams would occur and ifit did,it is unlikely that damage to 102 drums would occur. See Sect. 4.1 for the event tree quantification of the earthquake scenario.
An earthquake might also impact the four 3000 gal storage tanks located at C 733 and release the contents of the tanks. Although each storage tank holds approximately 216 55 Fal drums, the material stored in these tanks is DOE-owned waste. As previously discussed, the enrichment of this DOE-owned waste is unlikely to change. Samples from the last three shipments from these tanks indicate that material stored in these tanks is not NCS controlled. Storage of wante in these tanks will be controlled by a separate NCS evaluation and approsal to ensure that the total :"U content 3
of the tanks is maintained at an acceptable level. Based on these considerations, the release from these tanks caused by an earthquake is not considered a credible criticality initiator.
As previously di:; cussed. Reference 4 addresses criticality scenarios that do not require the release and accumulation of material (e.g placement of NCS controlled waste into an array of NCS
]
exempt containers). Since the worst case drum in this area has such a low fissile loading (12 g "U).
1 2
it is not considered credible for the accidental placement of a single NCS controlled drum in the C-I J
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'~
24 733 storage array to result in a criticality. See Sect. 4.1 for the esent tree quantification of this accident scenario.~
!l l1 4J BUILDING C-754 l5 l
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The storage facility in Building C 754 was evaluated using the walkdown sheets prosided in Table B-5. His facility will be used to store USEC LLW including high uranium density wastes such as trap mix and seal exhaust oil. Since the drums stored in this facility could include waste a
from 5.5% operations, it is assumed that the worst case drum contains 120 g of 2"U. In order to q
form a critical mass, at least 10 worst case drums of material uould have to be released in an accident. There are several accidents identified by the completed w alkdowti sheets that could impact more than 10 drums. These include forklin accidents, high wind vtornadoes, earthquake, and fire.
Although it is possible that a forkliR accident could impact more than 10 drums, it is unlikely that 10 drums would be breached. It is highly unlikely that if 10 drums were breached..the breacted drums would all have the fissile content of the worst-case drum. As presiously noted. wastes with 6
high uranium concentrations are, as a rule, solids or sludges. Therefore, when the drum is breached, i
it is likely that a significant portion of the material uould remain inside the drum. This means that
'i more than 10 drums with the fissile content of the worst-case drum would have to be breached by the accident to release 1.23 kg "U. The 55 gal drums are designed to sustain a 4 A drop. In 7
addition, the presence of waste management personnel will ensure rapid response and mitigation.
While it is credible that more than 10 drums could be impacted by high winds, a tornado, or
. f. '
tornado-generated missiles, it is highly unlikely that conditions would be conducive to criticality.
The dispersive effects of the v inds woutri prevent the accumulation of the released material in a critical configuration.
The LLW storage facility was evaluated for impacts from an earthquake. While the drums will fall onto the concrete pad. it is likely that many will maintain their integrity since they are designed to sustain at least a 4 A drop. The structural materials are relatively light, canvas and aluminum, and should not cause significant damage to many drums if they should fall. However, since containers may be triple stacked it is considered credible that ten could be breached during an earthquake. See Sect. 4.1 for the event tree quantification of the earthquake scenario.
L Several types ofcombustibles and flammables were identified in Building C-754. including the structural canvas, oil stored in drums, wooden pallets, and the wood flooring used for the diked areas. Ignition sources are limited to gasoline. powered fork trucks. lightning, and lighting panels.
I, l
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Due to the relatively small quantitin of the above combustibles and ignitian sources, the potential j
for fire is minimal. In additiot, the potential fire initiators are all associated with building occupancy (i.e., the fork trucks and generator are used during material handling and inspection). A fire extinguisher is prosided at the ; ad so that personnel could limit the spread of a fire should one occur. If a fire did ves, i is unlikely that a significant number, if any, of the drums would be t
involved. The amount of gasoline is limited to the small gas tanks on the fork trucks and the generator. Only a small portion of the structural canvas is within five feet of the drums. It is likely i
that a fire would not significantly impact more than a few drums in the immediate vicinity of the source. In addition, there are no mechanisms associated with a fire in Building C-754 that would be conducive to the accumulation of any released material. In the event of a fire, the temporary dikes that accumulate released material would more than likely be destroyed by the fire, further i
reducing the likelihood of a criticality.
There are physical factors that would significantly limit the movement and accumulation of the material. As previously discussed, wastes with a high uranium concentration are primarily solids or sludges that are less likely than liquids to move from the point of release. The concrete pad in L
C-754 is flat which limits material movement. The dike structures and any drums that may hase I
fallen onto the pad will also limit mosement and accumulation of the material.
Based on evaluation of C-754, an earthquake is the only accident that could damage more than 10 drums of material except for a tomado which would disperse material rather than accumulate it.
Given the low probability of an ear hquake, the low probability that a critical mass would be released, and the extremely low probability that the released material would accumulate in a critical configuration, a criticality in Building C-754 is not considered credible. Quantification of the NCSXPT event tree in Fig. I with a 1000 year return period earthquake results in a critical configuration sequence frequency of IE 07/ year.
As previously discussed, Reference 4 addresses criticality scenarios that do not require the release and accumulation of material (e.g., placement of NCS controlled waste into an array of NCS exempt containers). Since wastes resulting from HAUP operations may be stored in this area (i.e..
drums may contain up to 120 g mU) the accident anal) sis documented in Reference 4 is relesant to this facility. See Sect. 4.1 for the event tree quantification of this accident scenario.
t l
l
g 26 i
4.4 BUILDING C-754-A i
11g j
The storage facility in Building C-754-A was evaluated using the walkdown sheets pros ided in I
j Table B-6. Although this facility contains s!,ghtly contaminated roonng material. in the future it may be used to store USEC LLW including high uranium density wastes such as trap mis and seal exhaust oil. Since the LLW drums that may be stored in this facility could include waste from 5.5%
operations, it is assumed that the worst case drum contains 120 g of:"U. In order to form a critical mass, at least 10 worst-case drums of material would hase to be released in an accident. There are several accidents identified by the completed walkdown sheets that could impact more than 10 tl drums. These include forklift accidents, high winds / tornadoes, earthquake, and fire.
Although it is possible that a forklift accident could impact more than 10 drums, it is highly i i unlikely that 10 drums would be breached. It is highly unlikely that if 10 drums were breached, the breached drums would have the fissile content of the worst-case drum. As previously noted. wastes with high uranium concentrations are, as a rule. solids or sludges. Therefore, when the drum is breached, it is likely that a signi5 cant portion of the material uould remain inside the drum. This means that more thin 10 drums would have to be impacted by the accident to release 1.23 kg :"U.
Many of the drums impacted will maintain their integrity since they are certined for at least a 4 fi drop.. In addition, the presence of waste management personnel will ensure rapid response and mitigation.
While it is credible that more than 10 drums could be impacted by high winds a tornado, or
[
tornado generated missiles, it is highly unlikely that conditions would be conducive to criticality.
j The dispersive efTects of the winds would prevent the accumulation of the released material in a I
critical conGguration.
De LLW storage facility was evaluated for impacts from an earthquake. While the drums will fall onto the gravel pad it is likely that many will maintain their integrity since they are designed to sustain a 4 fi drop. The structural materials are relatively light, canvas and aluminum. and should not cause signiScant damage to many drums if they should fall. Iloweser. since containers may be stacked, it is considered credible that ten could be breached during an earthquake. See Sect. 4.1 for the event tree quanti 6 cation of the earthquake scenario.
Seseral types of combustibles and flammables were identiGed as present or assumed to be present during future Building C-754-A operations, including the structural canvas and wooden pallets. Ignition sources are limited to gasoline powered fork trucks. Due to the relatiscly small quantities of the above combustibles and ignition sources, the potential for Arc is minimal. In
27 addition, the potential fire initiators are all associated with building occupancy (i.e., the fork trucks are used during material handling and inspection). If a fire did occur. it is unlikely that a significant number. if any, of the drums would be involved. The amount of gasoline is limited to the small gas tanks on the fork trucks. Only a small portbn of the structural camas is within five feet of the drums. Due to the small amount of combustibles, it is likely that 4 fire would not significantly j
q impact more than a few drums in the immediate vicinity of the source. In addition, there are no mechanisms associated with a fire in Bailding C 754-A that would be conducive to the accumulation of any released material.
There are physical factors that would significantly limit the movement and accumulation of the material. As previously discussed, wastes with a high uranium concentration are primarily solids or sludges that are less likely than liquids to move from the point of release. In addition the gravel pad will limit material movement.
Based on evaluation of Building C-754-A. an earthquake is the only accident that could dama;:e more th'an 10 drums of material except for a tornado which would disperse material rather than accumulate it. Given the low probability of an earthquake, the low probability that a critical mass uould be released, and the extremely low probability that the released r wrial would accumulate in a critical configuration, a critical y in Building C-754 A is not considered credible.
Quantification of the NCSXPT event tree in Fg. I with a 1000 year retum period earthquake results in a critical configuration sequence frequency of IE-07/ year.
As previously discussed, Reference 4 addresses criticality scenarios that do not require the i
release and accumulation of material (e.g., placement of NCS controlled waste into an array of NCS I
exempt containers). Since wastes resulting from HAUP operations may be stored in this area (i.e..
drums may contain up to 120 g "U) the accident analysis documented in Reference 4 is relevant to this facility. See Sect. 4.1 for the event tree quantification of this accident scenario.
[
4.5 BUILDING C-333 i
Building C-333 waste storage areas were evaluated using the walkdown sheets located in Table 1
B-7. Most of the waste stored outside the CAAS is asbestos insulation which has historically been extremely low in "U content (<l g "U in a 55 gal drum). However, since the waste stored in this area is exempt from NCS spacing controls, the worst case drum was assumed to contain 120 g of
- mU. In order to form a critical mass, at least 10 worst case drums of material would has e to be
7, l
28 released in an accident. Seseral accidents identified by the completed walkdown sheets that could impact more than 10 drums were es aluated. These include forkliti accidents, fire, and earthquake.
Although it is possible that a forklift accident could impact more than 10 drums, it is highly unlikely that 10 drums would be breached. It is also unlikely that if 10 drums were breached the breached drums would have the fissile content of the worst case drum. As previously noted, wastes l
with high uranium concentrations are, as a rule, solids or sludges. Derefore, when the drum is breached, it is likely that a significant ponion of the material would remain inside the drum. This means that more than 10 drums would have to be impacted by the accident to release 1.23 kg :"U.
Many of the drums impacted will maintain their integrity since they are certified for at least a 4 ti drop. In addition, the presence of waste management personnel during a forklift accident will ensure rapid response and mitigation.
The C-333 storage areas were evaluated for impacts from an earthquake. While the drums will fall onto the concrete floor. it is likely that many will maintain their integrity sir:ce they are designed
~
to sustain a 4 ft drop. However, since containers are stacked, it is considered credible that 10 could be breached during an earthquake. See Sect. 4.1 for the event tree quantification of the earthquake scenario. The earthquake is unlikely to damage the building structure in a manner that would cause damage to the stored containers.
Several types of combustibles and Hammables were identified in the Building C-333 waste storage operations. The wooden pallets contribute to the combustible loading of the stored waste.
However, all waste storage areas are equipped with sprinkler protection; therefore, fires are not considered a credible criticality initiator.
Dere are physical factors that would significantly limit the mosement and accumulation of the material. As previously discussed, wastes with a high uranium concentration are primaril) solids or sludges that are less likely than liquids to move from the point of release. Since the floor is level concrete and the waste is not provided with dikes, no mechanism for accumulating released waste was identified.
Based on the walkdown of Building C 333, an earthquake is the only accident that could breach more than 10 drums of material. Given the low probability of an earthquake. the low probability that a critical mass would be released, and the extremely low probability that the released material would accumulate in a critical configuration, a criticality in C-333 due to the release of stored DOE waste l
is not considered credible. Quantification of the NCSXPT event tree in Fig. I with a 1000 year return period earthquake results in a critical configuration sequence frequency of I E.07 y ear.
L.
s.
I e
29 As pres iously discussed. Reference 4 addresses criticality scenarios that do not requb the release and accumulation of material (e.g., placement of NCS controlled waste into an array of NCS i
exempt containers). Since wastes drums my contain up to 120 g "U. the accident analysis documented in Reference 4 is relevant to this facility. See Sect. 4.1 for the event tree quanti 6 cation f
of this accident scenario.
't 4.6 BUILDING C-757 l
l i
Building C-757 waste store area was evaluated using the walkdoun sheets provided in Table B.
l
[
- 8. This facility will be used to store USEC mixed waste m a 90-day storage area. The waste stored l
in this area is not expected to be high uranium density wastes such as trap mix and seal eshaust oil.
l l
Since the drums stored in this facility could include waste from 5.5 wt % 2"U operations, it is l
i assumed that the worst-case drum contains 120 g "U. In order to form a critical mass, at least 10 l
2 worst-case drums of material would have to be released in an accident. There are several acciden l
identified by the completed walkdown sheets that could impact more than 10 drums. These includel forklift accidents, high winds / tornadoes, earthquake, and Gre.
l Although it is possible that a forklift accident could impact more than 10 drums, it is unlikely l
that 10 drums would be breached. It is highly unlikely that if 10 drums were breached, the breachedl drums would all have the fissile content of the worst-case drum. This means that more th l
drw..s with the fissile content of the worst case drum would have to be breached by the accident to l
B
.[
release 1.23 kg SU. De 55-gal drums are designed to sustain a 4 !t drop. In addition the presence l
r of waste management personnel will ensure rapid respense and mitigation.
l t
While it is credible that more than 10 drums could be impacted by high winds, a tornado, orl tornado-generated missiles, it is highly unlikely that conditions would be conducive to criticality.
l The dispersive effects of the winds would prevent the accumulation of the released material in s l criticalcoaliguration.
l De LLW storage facility was evaluated for impacts from an earthquake. While the drums will l
fall onto the concrete floor, it is likely that many will maintain their integrity since they are designed l
to sustain at least a 4 ft drop. He structural materials are relatively light. sheet metal and should l
not cause significant demage to many drums if they should fall, llowever, it is considered credible l
that more than ten centainers could be breached during an earthquake. See Sect. 4.1 for the event l
l:
tree quantification of the earthquake scenario.
l l
1 30 Several types of combustibles and flammables were identified in Building CJ57, including l
natural gas for heating and wooden pallets. It should be noted that natural gas heaters are located l
at the ceiling level where they are unlikely to be damaged by operational actis ities. Ignition sources l
are limited to gasoline powered fork trucks lightning, and lighting panels. Due to the relativel) l small quantities of the above combustibles and ignition sources, the potent:al for fire is minimal.
l In addition, the potential fire initiators are primarily associated with building occupancy (i.e., the l
fork trucks are used during material handling). Fire extinguishers are prosided in the building so l
that personnel could limit the spread of a fire should one occur. If a fire did occur, it is unlikely that l
a significant number, if any, of the drums would be invoh ed. The amount of gasoline is limited to l
the small gas tanks on the fork trucks. The building structure is also not combustible it is likely l
l that a fire would not significantly impact more than a few drums in the immediate vicinity cf the fire l
source. In addition, there are no mechanisms associated with a fire in Building C 757 that would l
be conducive to the accumulation of any released material. In the event of a fire, the containment l
c systems that accumulate released material would not be destroy ed by the fire, further reducing ihe l
t likelihood of a criticality.
l There are physical factors that would significantly limit the mos ement and accumulation of the l
material. As previously discussed, wastes with a high uranium concentration are primarily solids l
{
or sludges that are less likely than liquids to mos e from the point of release. The floor in C-757 is l
flat which limits the accumulation of released material. The containment pallets, based on their l
design, will also limit movement and accumulation of released material to safe les els.
l Based on evaluation of C-757, an earthquake is the only accident that could damage more than l
f 10 drums ofmaterial except for a tomado which would disperse material rather than accumulate it.
l Given the low probability of an earthquake, the low probability that a critical mass would be l
l released, and the extremely low probability that the released material would accumul.ite in a critical l
configuration, a criticality in Building C 757 is not considered credible. Quantification of the l
NCSXPT event tree in Fig. I with a 1000 year return period earthquake results in a critical l
configuration sequence frequency of IE 07/ year.
l As previously discussed. Reference 4 addresses criticality scenarios that do not require the l
release and accumulation of material (e.g., placement of NCS controlled waste into an array of NCS l
exempt containers). Since wastes resulting from HAUP operations may be stored in this area (i.e.,
l drums may contain up to 120 g '"U). the accident analysis documented in Reference 4 is relevant l
to this facility. See Sect. 4.1 for the event tree quantification of this accident scenario.
l l
l
31 r
- 5. CONCLUSIONS
't Although the mass of 2"U exceeds a minimum critical mass in C *i46-A and is espected to ii exceed a minimum critical mass in C-733. C-754. C 754.A. and C 757 under 5.5*. operations, no credible criticality accident scenarios were identified.
F The primary uncertainty of this analysis is associated with the use of available sampling dits as representative of all the drums stored in a particular facility. The impact of this uncertainty on the final results was minimized by the anal) sis. Although as ailabic sampling data for enrichment from some storage locations is somew hat limited, the total uranium content of almost all drums is known.
The extrapolation of this total uranium content data to estimate waste from 5.5% operations, such that waste which is less than 2% assay is assumed to be 5.5% mU. is an extremely consenatise approach to the analysis. Even with these conservatise assumptions, sriticality in any of the analyzed facilities is not considered credible. Therefore, a criticality monitoring system is not required f'or any of the facilities esaluated.
l l!l l
- 6. REFERENCES i
1:
- l. American NationalStandardfor Cruicality Accident Alarm Sprem. ANSilANS.8.3 1986 American Nuclear Society La Grange Park. Illinois. August 29.1986.
I 3
- 2. TechnicalJustification: Urantum Enriched to less Than One Weight Percent U SafeJhr 4
Operations at the Paducah Gasema Diffusion Plant. KY!S-248. Martin Marietta UtiIity sen ices.
Inc.. Paducah. Kentucky, March 31.1995.
- 3. Five Galhm Drum Waste Oil Storage at 3.3% at the Paducah Gaseous Defusion Plant.
NCSE 207. Martin Marietta Utility Services. Inc.. Paducah, Kentucky. August 1993.
- 4. Nuclear Criticality Safen Assessment of Waste Resu'tingJVom liigher Anas Operathms.
KY/S-253. Revision 2. Martin Marietta Utility Services. Inc.. Paducah. Kentucky. May 1996
(
- 5. Nuclear Criticatin Safen Evaluationfor Liquid Taste Tanker and Tanks at the Paducah Gasecus Difusion Plant. NCSA Number WM 209. Manin Marietta Utility Senices. Inc., Paducah.
Kentucky. May 1995.
- 6. Subcritical Dimensionsfor Water-Reflected C0f and Water Spiems at 3.3 Weighs Percent Enrichment KY/S 222. Martin Marietta Utility Services. Inc. Paducah, Kentucky. October 1993.
~.
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FACILITY LAYOUTS i
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Fig. A-2. General ares around buildings C.746-A and C.74(, D.
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C 733 Hazardoes Weste g
i Drums Wante oil accumulatlee 2
l tasks poet
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j gel esch) g N
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Electrical panels hg Semp Plesiglas wall l
Pump.
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supplies p
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C 732 Not to scale Heavy hnes denote diked stess i
Fig. A-3. Building C-733 generallayout.
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Fig. A-4. Building C-754 layout.
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Fig. A-5. Building C-754-A layout.
I L
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A-6 Concrete N
'l Pers w:
Roll up
'l door door 1
Crane railg d
i g
x Covered gg,,\\
area r
L 1
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.k Mixed waste stored Walllouwrs
~
i in this area
- J t
j Electrical cabinets Radiological area 1
Personnel Building g
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/ Partition W
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Non-radiological area p
Trash j
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Roll up Personnel door door Concrete Fig. A-6. Building C-757 generallayout.
7,f I
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.5, 9
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.y Appendix B FACILITY WALKDOWN SHEETS AND DATA SUMMARIES i
f.
i
'l 4
4 i
' ?.
-a 4
i t
i.
e f
j 1
I l
f Bl 1
Table B-l. C-746-A walkdown sheet Bldg # / Pad #: C 746-A Size: 71.100 sq ft (including Storage capacity: 7440 trash sorting area) drums Distance to street: >100 9 Distance to closest bide: apprm. 20 R (C 746 B)
Personnel occupation: Only during drum inspection and mos entent and actisities associated with trash sorting and compaction Sprinklers: Yes, dry Structural components of building combustible? No Other operations in storage facility? Yes. bos compaction
" Worst case" drum in facility: 21 g SU Number of drums for critical mass: $8 Potential for material accumulation: floor divided into multiple diked areas (8 in.) diked areas are relatively large - material could accumulate in low spots l
Release Mechanism Potential Initiators Estimate of Amount of Material Relessed (drums)
Container breach due to ForkliR runs into array (human Max 4 drums (I pallet) fall error hardware) 1 l
j' Pallet fails Mat 4 drums (1 pallet) l I
Pallet dropped during transport Max 4 drums (I pallet)
(human error, hardware) 1
)
i Container breach due to Forklift runs into array Mas 8 solid drums or pouibly impact 10 12 liquid drums (damage to drums on lower ps!!et could cause upper drums to fall) i l
Oserhead equipment falls onto Oserhead equipment is drums relatively light (e g.. roof panels, lighting, piping, heaters). Damage to individual containers due to impact is possible
)
B2 Table B l. C-746 A wcikd:wa sheet (cantiated) t Release Mechanism Potential Initiators Estimate of Amount of i
Material Released (drums) t
,(;
Overpressure Pressure generated by contents 7 drums (overpressure might not vented (human error, impact I drum deep). Note:
)
hardware) there did not appear to be any drums that were vented or
- y marked as gas (e.g., hydrogen) generators stored in the facility. PGDPhas 4
y esperienced bulgmg drums; however, pressure was relieved. No explosion I
occurred
)
I.
Corrosion Intemal human error in Possible - could impact i
loading container (e.g., material multiple drums ifinspection or incompatibilityl repacking mechanisms fail i
Extemal exposure to air, sun.
N/A moisture, etc.
l Extemal undetected caustic Possibility ofimpacting spill multiple drums within the i
i diked area containing the spill. Diked areas are relatively large. Most likely t
impact uould be to adjacent drums i
Containers impacted by Possible impact to multiple i
fire drums. Fire sources include small amounts of gasoline (in pump tanks), some flammable i
RCRA materialin drum, and combustible spillcleanup materials. Limited ignition sources (electric panels for fans. lighting and fork trucks).
Note: natural gas lines have I
been isolated Containers impacted by N/A - minimal trame around extemal vehicles building i
D3 Tcble B-1. C-746-A nalkdswo sheet (ce:titued)
Release Mechanism Potential Initiaton Estimate of Amount of 3
Material Released (drome l
l Containers impacted by Other operations in C 7J6 A.
adjacent facility box compaction, and in C.746-b' operations B. waste handling and storage.
are relatisely innocuous i
Containers impacted by snow load Possible impact to multiple
{
roof collapse due to:
pallets i
I high wind' tornado Possible impact to large e
t numberofpallets. Dispenion due to high winds.1ornado would limit xcumulation of released drum contents -
earthquake Possible impact to large i
number of pallets i
l Containers impacted by tornado Likely to impact large number l
missiles generated from:
of pallets; however, dispersion due to winds would limit the accumulation of released drum contents
.f Containers impacted by earthquake Individual containers could fall and/or falling objects fall from pa!! cts onto concrete due to:
floor, Structuralcomponents cooid damage large number of pallets 1
l.
r:
f.'
l B-4 I
Table B-2. C-746-A data seminary l
Total drums: 3987 solids: 348I liquids:506 l
l PCB waste l
Total drums with analytical data: 1121 solids: 960 l
liquids: 161 l
Hmedous wate Total drums with analytical data: 52 solids: 18 liquids: 34 worst-ene drums 10 content)*
t i
RFD #
U Concentration (ppm)
Mass (th)
Waste Type 05536 23 %
358 general salvage (PCD) 10520 3823 163 absorbents (PCB) 05446 700 480 waste oil (PCB) 16548 430 152 U contaminated oil (Hazardovs)
' Outliers (i.e., one time shipments of high uranium mass materials with assays less than 1%) were investigated and eliminated from consideration as appropriate.
l l
l lc
f-B-5 Table B-3. C-733 walkdown sheet l
Bids # / Pad #: C 733 Size: 3560 sq R Storage capacity: 544 drums and four 3000 al S
i tanks Distance to street: approx. 20 Distance to closest bldg: appros. 50 A a
h Personnel occupation: Only during drum inspection and movement and activities associated with l
filling and emptying the tanks
_ Sprinklers: No Sevetural components of building combustible? No
{
Other opvations in storage facility? No
" Worst-case" drum in facility: 12 g SU Number of drums for critical mass: 102 Potential for material accumuhtion: good - dams are mostl liquids, stored on diked concrete pad L
f
~
Release Mechanism PotentialInitiators Estimate of Amount of Material Released (drums)
Container breach due to ForkliA runs into array (human Max 4 drums (I pallet) i fall error, hardware)
Pallet fails Mas 4 drums (1 pallet)
[
f Pallet dropped during transport Max 4 drums (I pallet)
(human error, hardware) ii l
Container breach dt.e to ForkliA runs into array Max 8 solid drums or possibly
[
impact 10 12 liquid drums (damage to drums on lower pellet could i
cause upper drums to fall) k1 Overhead equipment falls onto N/A drums 4
e Bc6 Table B-3. C-733 walkdown sheet (continued) i i
h Release Mechanism Potential Initiators Estimate of Amount of i
Material Released (drums)
I Overpressure Pressure generated by contents (overpressure might impact I not vented (human error, drum deep). If overpressure I,.
hardware) resulted in a fire, many drums
,. g could be involved. Note: there did not appear to be any drums I
that were vented or marked as gas (e g., hydrogen) generators i
stored in the facility. PGDP f
has experienced bulging j
drums; howes er. pressure was relieved. No explosion I
occurred v
Corrosion Intemal-human error in Possible couldimpact i
loading container (e g.. material multiple drums ifinspection or incorr~stibilitvt repacking mechanisms fait s
f Extemal exposure to air, sun, Possibility minimized by roof moisture, etc.
and Plexiglas side enclosures.
I could impact multiple diums if i
inspection or repacking i
mechanisms fail h
Extemal undetected caustic Possibility ofimpacting all
{
spill drums within the diked area containing the spill. Most likely impact would be to adjacent drums
}
t Containers impacted by Possible impact to multiple l
fire drums. Large quantity of ignitables stored in facility, e
i Limited ignition sources.
[
Dispersement effects of fire p
and explosions would limit i
accumulation Containers impacted by Possible impact to multiple extemal vehicles pallets due to trame from Tennessee Ave.
i f
l B-7 i,
Table B-3. C-733 walkdown sheet (continued)
Release Meehanism PotentialInitiators Estimate of Amount of Maternal Released (drums)
Containers impacted by Operations in adjacent facility adjacent facility (C 723)are fairly innocuous operations Containers impacted by snS2 load Possible impact to multiple roof collapse due to:
pallets. Roofpanels relatively light high wind /tomado Possible impact to large numberofpallets. Dispersion due to high winds tornado would limit accumulation of released drum contents earthquake Possible impact to large number of pallets Containers impacted by tornado Likely; however, dispersion missiles generated from'.
due to winds would limit the accumulation of released drum contents Containers impacted by earthquake Individual containers could fall and/or falling objects fall from pallets onto concrete due to:
floor. Structuralcomponenta could damage large number of containers
Fi q,.
\\
B-8 1
I l.
Table B-4. C 733 dets summary l#
li!!
Total drums: 795
[
selids: 327 liquids: 468 t
hl PCB waste
- t.
Total drums with analpical data: 19 i
l!
liquids: 18 solids: I
['
[
Hmrdous waste L.
Total drums with analytical data: 50
'i solids and sludges: 18 1
liquids: 32 l'
Worst-case drums (U content)*
'?
- RFD #
U Concentration (ppm)
Mass (Ib)
Waste Type j
3675 9000 55 contaminated trichlorethylene l
(harmdous) 05982 190 585 sludge' water (PCB) i
~I
' Outliers were investigated and eliminated from consideration as approp iat r
e.
.t I
f i
s 9
B9 Table B 5. C 754 *alkdown sheet Bldg # / Pad #:C 754 Size: 10.000 sq R Storage capacity: 1351 drums Distance to street: >50 A Distance to clo se bldg. C-415 is immediately adjacent to the ditches between main roads pad and pad Personnel occupation: Only during container inspection and mos ement Sprinklers: No Structural components of building combustible' 3es (canvas)
Other operations in storsee facility? No
" Worst case" drum in facility: <l20 g :"U Number ofdrums for critical mass 10 Potential for material accumulation: minimal-flat concrete pad with multiple diked areas j
1 Release Mechanism Potential Initiators Estimate of Amount of Material Released (desme)
Container breach due to Forklin runs into array (human Mas 4 drums (I pallet) fall error, hardware)
Pallet fails Mat 4 drums (1 pallet) f Pallet dropped during transport Mat 4 drums (I pallet)
Ihuman error, hardware)
Container breach due to Forklin runs into array Mat 8 solid drums or possibly impact to - 12 liquid drums (damage to drums on lower pa!!ct could cause upper drums'to fall)
Overhead equipment falls onto Oserhead equipment is drums relatively light (e g. lighting)
J Damage to individual containers due to impact is possible
T B-10 j
Tchte B-5. C-754 walkdswa sheet (co: tinted) j t
l, Release Mechanism Potential Initiators Estimate of Amount of Material Released (drums)
Overpressure Pressure generated by contents 7 drums (overpressure might f
not vented (humin error, impact I drum deep). Note:
hardware)
PGDP has experienced bulging drums; however.
pressure was relieved. No 1
esplosion occurred I
e t
Corrosion Intmal-human error in Possible - could impact loading r.ontainer(e g., material multiple drums ifinspection or incompatibilitv) repacking mechanisms fail External exposure to air, sun.
N/A moisture. etc.
External-undetected caustic Possibility ofimpacting spill multiple drums withm the diked area containmg the spill. Most likely impact would be to adjacent drums i
Containers impacted by Possible impact to multiple fire drums. Fire sources include gasoline from fork trucks and electric generator, canvas, wood pallets, and wood diked areas. Limited ignition raurces (electric panels for lighting, fork trucks, e
e-nerator)
Containers impacted by Minimal,other than trucks external vehicles bringing in drums or remosing drums. Main roads are not close to the pad 1
L Containers impacted by C-815 (Feed Plant Storage j
adjacent facility Building) Innocuous - Feed operations Plant no longer in use.
Possible decontamination l
activities in the future I
j
e *. }.
, q},;.,
s}
y.
~.s /.... <
+,
- ^ * '..
- J ',;
, ' e r..
_ = '
i B Il Table B-5. C-754 walkdown sheet (continued)
Release Mechanism Potential Initiators Estimate of Amount of Material Released (drums)
Containers impacted by snow load Snow load. ifit could roof collapse due to:
accumulate (doubtful) would most likely rip canvas or bend frame high wind tomado Possible impact to large number of pallets. Dispersion due to high windtomado would limit accumulation of released drum contents earthquake Negligible impact from canvas or frame Containers impacted by tomado Likely to impact large number missiles generated from:
ofpallets; however, dispersion due to winds would limit the accumulation of released drum contents Containers impacted by earthquake Individual containers could fall ancor falling objects fall from pa!!ets onto concrete due to:
floor. Structuralcomponents relatively light, minimal damage anticipated
?
,o
[
B 12 i
Table B-6. C-754-A walkdown sheet f
Bldg 8 / Pad #:C 754 A Size. 5000 sq ti Storage capacity: varies depending on type of container (cunently stores roll-oft bins)
)
Distance to street: >$0 ft Distance to closest bldg: > $0 ft between C 754 and C 754 A ditches between main roads and pad Personnel occupation: Or.ly during contamer inspection and mos ement Sprinklers: No Structural components of building combustible? yes (canvas)
Other operations in storage facility? No j
" Worst-case" drum in facilitv: <!20 g "U Number of drums for critical mass: 10
~
Potential for material accumulation: minimal due to flat gravel pad th cre.',1cchan sm Potential laisiaturs Estimate of Amount of Material Released (drums)
Container breach due to Forklift runs into array (human Mas 4 drums (1 p.11tet) fall error, hardware)
Pa!!et fails Mat 4 drums (I pallet)
Pallet dropped during transport Mas J drums (I pallet)
(human error, hardware) r Container breach due to Forklifi runs into array Mas 8 solid drums or possibly impact 10 12 liquid drums (damage to drums on lower pallet could cause upper drums to fall)
Overhead equipment falls onto Oserhead equipment is drums relatisely light (e.g., lighting).
Damage to individual containers due to impact is possib'e
'j l
~'
}
B 13
{
Table B-6. C-754-A walkdown sheet (continued) i Release Mechanism PotentialInitiators Estimate of Amount of t
l Material Released (drums)
Overpressure Pressure generated by contents 7 drums (overpressure might not vented (human error, impact I drum deep) Note:
hardware)
PGDP has experienced bulging drums; however.
[
pressure was relieved. No I
explosion occurred Corrosion Internal-human error in Possible could impact loading container (e.g.. material multiple drums ifinspection or incompatibilitv) repacking mechanisms fail i
(
Extemal exposure to air. sun.
N/A
~
moisture, etc.
l f
J External undetected caustic Possibility ofimpacting g,
spill multiple drums within the diked area containing the spill. Most likely impact would be to adjacent dr Ans t
i Containers impacted by Possible impact to multiple fire drums. Fire sources include gasoline from fork trucks and electric generator, canvas.
7 wood pallets, and wood diked i
areas. (Electric generator I
present only during use.)
i j
l.imited ignition sources
)
(electric panels for lighting.
fork trucks. generator)
Containers impacted by Minimal, other than trucks external vehicles bringing in drums or removing drums. Main roads are not close to the pad
7 I*
1 B 14 Table B-6. C-754-A walkdown sheet (continued) lIlf Release Mechanism Potentist feitiators Estimate of Amoest of
-I Mateelal Released (drums)
L)
!l Containers impacted by C 415 (Feed Plant Storag; Q
adjacent facility Building) Innocuous Feed E
operations Plant no longer in use.
[
Possible decontamination lj activities in the future
'r I
t i
Containers impacted by snow load Snow load,ifit could roofcollapse due to:
accumulate (doubtful) would i
most likely rip canvas or bend I!
frame f
high wind'tomado Possible impact to large
,r number of pallets. Dispersion
!~
due to high wind tomado would limit accumulatida of
}
released drum contents earthquake Negligible impact from canvas f
i or frame
'i c
- t. ;.
Containers impacted by tomado Likely to impact large number l
missiles generated from:
of pallets: however. dispersion l.
due to winds would limit the l[
accumulation of released drum contents I
i l
f[-
Containers impacted by earthquake Individual containers could falland/or falling objects fall from pallets onto concrete r
due to:
floor. Structural components l'
relatively light, minimal damage anticipated
- Walkdown sheet completed for worst case 55 gal drum storage.
B l
B 15
\\\\
Table B-7. C-333 walkdown sheet Dids 8 C 333.various storage Size: 1.02E+06 sq A Storage capacity: drum i
areas on ground noor storage constrained to specific areas
)
l 'I Distance to street N'A Distance to closest bldg: N/A l
i
{
hi Penennel occupation: > to ; 24 hr per day
)
Spinklen: Yes J
1 Structurst components ofl>Jilding combustible No
>}
Other operations in storage fxility? Yes: support to gaseous difTusion operations l
l J
? I i
" Worst eme* drum in facilitv <l:0 g "U Number of drums for critical mass: 10 2
1 if
!I Potential for material s,ccumulation: stored waste materials are solid precluding accumulation; no i
!i i
diked areas provided I
i 1 Relesee Mechanism Potentiallnitiators Estimate of Amount of Material Released (drums) l l
Contamer breach due to fork! A runs into array (human Max 4 drums (1 pallet)
[
fall etTor hardwarei li
!s l
Pallet fails Mat 4 drums (1 pallet) l l
Palles dropped during transport Max 4 drums (I pallet) thuman error, hardware) i!
+
l-Container breach due to Ferklin runs into array Mat 8 solid drums (damage to unpact drums on lower pallet could cause upper drums to fall) l Osesend equipment fa!!s onto Overhead equipment is drums relatively light (e.g., lighting and piping). Minor damage to individual containers due to impact is possible ll l
I
l B 16
[
Table 7. C 333 walkdown sheet (continued)
Relesw Meenanism PotentialInitiators Estimate of Amount of Material Released (drums)
L Oserpressurt Pressure generated by contents 7 drums (overpressure might not sented thuman error.
impact I drum deep). Note:
hardware)
PGDP has experienced bulging drums; however.
pressure was relieved. No explosion occurred Corrmkm Intemal human error in Possible couldimpact loadmg container (e.g., material multiple drums ifinspection or incompatibility) repacking mechanisms fail Extemal exposure to air, sun.
N/A moisture. etc.
i External undetected caustic N/A i
l spill i
i Containers impacted by Sprinklers provide fire fire protection f
l Contamm impacted k Only forklift and light vehicles i
ettemal vehicles are present. Speed limit in building is extremelv slow Containers impacted by Adjacent facility operations abscem facdity are relatively innocuous operations l
Cretamers impacted by snow load N 'A conf coltarse due to-high wind tornado Structure of building expected to protect against high wind I
?
f.-
Bol7 Table 7. C 333 walkdown sheet (continued)
Releen Mechanism Potentiallnitiators Estimate of Amount of I
Material Released (drums)
[
earthquake Structure of building is expected to survive EBE
,}
(
i I
Containers impacted by tomado Structure of building expected f
missiles generated hom:
to stop tornado missiles i
Contamers impacted by earthquake Individual containers could fall and'oc fWiing objeca fall from pallets onto concrete due to:
floor. Structural components are expected to survive EBE i
i i
?
?
I I
i F
6 e
e-l B-18 Table B-8. C-757 walkdown sneet Bldg s757 90 day storage area Size: <10.000 sq A; only h.ilf Storage capacity: drum on ground floor of building used for storage constrained to radiological s orage specific areas Distance to street: >$0 A Distance to closest bldg: >300A
~'
Pmonneloccupation: <5 Sprinklm No Structural components of building combustible? No Othee operations in storage facility? Yes; waste compaction of non radiological waste
- Worst-ca:e" drum in facility: <120 g "U. Number of drums for critical mass: 10 Potential for material accumulation; stored waste materials that are liquid are stored in containment devices that provide containment; solid waste stored on pallets Release Mechanism Potential Initiators Estimate of Amount of Material Released (drums)
Container breach due to Forklia runs into array (human Max 4 drums (I pa!!ct) fall error hardware)
Pallet fails Max 4 drums (I pallet)
Pallet dropped during transport Max 4 drums (1 pa!!ct)
(human error. harda are)
B Contamer breach due to Forklia runs into array Max 8 solid drums (damage to impact drums on lower pallet could cause upper drums to fall) s e
Overhead equipment falls onto Overhead equipment is drums relatively light (e.g., lighting and piping). Minor damage to individual containers due to impact is possible a
i
.,e B 19 Table B-8. C-757 walkdown sheet (continued) i Releen Mechanism Potential Initiators Estimate of Amount of Material Released (drums)
C...,, w ure Pressure gener ted by contents 7 drums (overpressure might not vented thuman error, impact I drum deep). Note:
hardware)
PGDP has experienced i
bulging drums; however, pressure was relieved. No explosion occurred i
Conotion Intemal human error in Possible - could impact loading container (e.g., material multiple drums ifinspection inu ;oatibility) fails External exposure to air, sun, N/A moisture. etc.
Extemal undetected caustic N/A spill l
Containe impacted by Potential for sirborne release fire since no sprinkler protection is provided. Not a criticality concern e
Containers impacted by Only forklift and light vehicles estemal vehicles are present in the vicinity of the building
+
i Containm impacted by Adjacent facility operations adjacent facility are relatively innocuous and a operations wall separates the two operations t
I Containers impacted by snow load Possible impact to multiple roof collapse due to:
pallets
1
, A *.r*
t B 20 Table B-8. C-757 walkdown sheet (continued)
Release Mechanism Potential Initiators Estimate of Amount of Material Released (drums) high wind /tomado Possible impact to large number of containers.
Dispersion due to high winds would limit accumulation of released material earthquake Possible damage to multiple containers
)
Containers impacted by tomado Likely to impact large number missiles generated from; of containers; however, dispersion due to winds would limit the accumulation of released drum contents Containers impacted by earthquake Individual containers could fall ansor falling objects fall from pallets onto concrete due to:
floor. Structural components are light causing minimal damage
\\
i Unclassified
POEF-LMUS-10 Revision 3 l
2 I
L o c u n u u n m a n r i ng Criticality Accident Alarm System PORTSMOUTH-Coverage and Exclusions GASEOUS DIFFUSION iPLANT December 1998 l
l By 1
J. A. Rapp, Jr.
l LOCKHEED MARTIN UTILITY SERVICES, INC.
PORTSMOUTH GASEOUS DIFFUSION PLANT P.O. Box 628 Piketon, Ohio 45661 Under Contract USEC-96-C-0001 to the U.S. ENRICHMENT CORPORATION l
-L HEE.AAR SERVICES,INC.
- : ?l%
~
Ts"!88eiU88%t B
a POEF-LMUS-10 Revision 3 Criticality Accident Alarm System Coverage and Exclusions pecember 1998 Page 1 of 30 l
l l
1 DISTRIBUTION l
LOCKHEED MARTIN UTILITY SERVICES, INC.
I I
PORTSMOUTH
- Bahney, B.
- Lemming, R.
l
- Belford, J.
- Rapp, J.(5) l
- Bolling, J.
Van Volkinburg, S l
- Corzine, G.
Central Files (2) l D'Aquila D.
X-710 Technical Library (2) l
- Demeglio, R.
NRA (5) l
- Hone, M.
USEC (5) l J
POEF-LMUS-10 Revision 3 Criticality Accident Alarm System Coverage and Exclusions December 1998 Page 2 of 30 l
l N TRO D U CTI O N........ -............................................
3 l*
I Section 1.
AREAS COVERED BY CRITICALITY ACCIDENT ALARM SYSTEM.
4 l.
I Section 2.
NON-PROCESS BUILDINGS NOT COVERED BY A CAAS FOR WHICH l
AN EXCLUSION IS REQUESTED..........................
7 l
l Section 3.
EXCLUSION OF ROADWAYS FOR CERTAIN MATERIALS......
21 l
l Section 4.
EXCLUSION FOR LARGE CYLINDERS OF UF. IN STORAGE YARDS 22 l
1 Section 5.
EXCLUSION FOR THE BUILDING XT-847 OUTSIDE STORAGE PAD 27 l
l RE FERE N C E S.....................................................
28 l
l L
POEF-LMUS-10 Revision 3 Criticality Accident Alarm System Coverage and Exclusions December 1998 Page 3 of 30 INTRODUCTION l
1 Federal regulation,10 CFR 76.89', requires criticality monitoring and alarm system l
coverage for all areas of a facility except approved exclusions. The national standard, l
ANSI /ANS-8.32, also addresses alarm systems. ANSI /ANS-8.3 Section 4.2.1, requires that the need for a criticality monitoring and alarm system shall be evaluated for all activities in individual unrelated areas for which the inventory of fissionable materials involved exceeds 700 grams of 23sU.
This report is divided into five sections. Section 1 discusses areas of PORTS that are covered by the Criticality Accident Alarm System (CAAS). Section 2 discusses non-process buildings not covered by a CAAS for which an exclusion is requested Section 3 discusses an exclusion from CAAS coverage of roadways for certain materials.
Section 4 requests an exclusion from CAAS coverage for cylinder storage yards.
l Sectron 5 requests an exclusion from CASS coverage for the outside storsge pad west l
of Building XT-847.
l l
l l
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I I
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POEF-LMUS-10 Revision 3 Criticality Accident Alarm System Coverage and Exclusions December 1998 Page 4 of 30 Section 1.
AREAS COVERED BY CRITICALITY ACCIDENT ALARM SYSTEM l
l I~
The following buildings / areas are covered by the Oriticality Accident Alarm System l
(CAAS) in accordance with 10 CFR 76.89.
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POEF-LMUS-10 Revision 3 Criticality Accident Alarm System Coverage and Exclusions December 1998 Page 7 of 30 Section 2.
NON-PROCESS BUILDINGS NOT COVERED BY A CAAS FOR WHICH l
AN EXCLUSION IS REQUESTED The purpose of this section is to request an exclusion from 10 CFR Part 76.89 for all PORTS buildings / areas that do not contain operations involving uranium enriched to 1 wt% or higher 23sU, and 15 grams or more of 23sU. LMUS is requesting an exclusion for the buildings / areas listed in the following table. This list was generated using revision l
26 (November 6,1998) of the Application for the Portsmouth Gaseous Diffusion Plant.
l Historically these buildings / areas have not had uranium operations. Thus, there is no need for a Criticality Accident Alarm System (CAAS) in them. Areas will be added to or deleted from this section per the Lease Agreement between the United States Department of Energy and the United States Enrichment Corporation.
There are two buildings in this list that have greater than 1% uranium enrichment and more than 15 grams uranium. The two buildings are X-744H and X-744L. These two buildings are warehouses that store contaminated equipment. Both buildings have an areal density ofless than 50 g 23sU/m. Access to both building are controlled ensuring l
2 that the areal density of material in these buildings is not exceeded. Since both l
buildings have an areal density of less than 50 g 23sU/m, a CAAS is not required and 2
an exclusion from 10 CFR Part 76.89 is requested for these buildings.
There are two depleted uranium cylinder storage yards listed in this table. They are X-745G and X-745H. These areas are used to store uranium hexifluoride filled cylinders.
The uranium in them contains less than 1% 23sU. Since uranium with less than 1% 23sU can not go critical a CAAS is not required and an exclusion from 10 CFR Part 76.89 is requested for these areas.
POEF-LMUS-10 Revision 3 1
Criticality Accident Alarm System Coverage and Exclusions l
December 1998 Page 8 of 30 l
Facility Requires Coverage Number Facility Name and/or Function by CAAS X-100 Administration Building no X-100B Air Conditioning Equipment Building no X-100L Environmental Control Trailer no X-101 Health Service Center no X-102 Cafeteria no X-103 Auxiliary Office Building no X-104 Guard Headquarters no X-104A indoor Firing Range no X-105 Electronic Maintenance Building no X-106 Tactical Response Station no X-106B Fire Training Building no X-108A South Portal and Shelter no X-1088 North Portal and Shelter no X-108E Construction Portal no X-108H Pike Avenue Portal no X-109A Personnel Monitoring Building no X-109B Personnel Monitoring Building no X-109C Personnel Monitoring Trailer no X-111 A SNM Monitoring Portal (X-326) no X-111B SNM Monitoring Portal (NW X-326) no X-112 Data Processing no X-114A Outdoor Firing Range no
POEF-LMUS-10 Revision 3 Criticality Accident Alarm System Coverage and Exclusions December 1998 Page 9 of 30 Facility Requires Coverage Number Facility Name and/or Function by CAAS i
X-120H Meteorological Tower no X-200 Site Prep, Grading, Landscaping no X-201 Land and Land Rights no X-204 Railroad and Railroad Overpass no X-206A _
Main Parking Lot (N) no X-206B Main Parking Lot (S) no X-206E Construction Parking no X-206H Pike Avenue Parking Lot no X-206J South Office Parking Lot no X-208 Security Fence no X-210 '
Sidewalks no X-215A Electrical Distribution to Process Buildings no X-2158 -
Electrical Distribution to Other Areas no X-215C Exterior Lighting no X-215D Electric Power Tunnel.
no X-220A Instrumentation Tunnels no X-220B1
' Process Instrumentation Lines no X-220B2 Carrier Communication Systems no X-220B3 Water Supply Telemetering Lines no X-220C Superior American Alarm System no X-220D1 General Telephone no X-220D2 Process Telephone no ig._
___a
POEF-LMUS-10 Revision 3 Criticality Accident Alarm System Coverage and Exclusions December 1998 Page 10 of 30 Facility Requires Coverage Number Facility Name and/or Function by CAAS X-220D3 Emergency Telephone System no X-220E1 Evacuation Public Address System no X-220E2 Process Public Address System no X-220E3 Power Public Address System no X-220F Plant Radio System no X-220G Pneumatic Dispatch System no X-220H MuCulloh Alarm System no X-220J Radiation Alarm System no X-220K Cascade Automatic Data Processing System no X-220L Cascade Automatic Data Processing System no X-220N Security Alarm and Surveillance System no X-220P Maintenance Work Authorization and Control no System X-220R Public Warning Siren System no X-220S Power Operations SCADA System no X-230 Water Supply Line no X-230A Sanitary and Fire Water Distribution System no X-230A-3 Ambient Air Monitoring Station A-3 (South Access no Road)
X-230-A-6 Ambient Air Monitoring Station A-6 (at Power Pole no 6 in Piketon)
X-230A-8 Ambient Air Monitoring Station A-8 (at Power Pole no 74 Near X-735)
4 POEF-LMUS-10 Revision 3 Criticality Accident Alarm System Coverage and Exclusions December 1998 Page 11 of 30 Facility Requires Coverage Number Facility Name and/or Function by CAAS X-230-A-9 Ambient Air Monitoring Station A-9 (at Wakefield no Mound Road).
X-230-A-10 Ambient Air Monitoring Station A-10 (at Don no Marquis Substation)
X-230-A-12 Ambient Air Monitoring Station A-12 (at McCorkle no Road)
X-230-A-15 Ambient Air Monitoring Station A-15 (at Loop Road) no X-230-A-23 Ambient Air Monitoring Station A-23 (at Taylor no Hollow and McCorkle Road).
X-230-A-24 Ambient Air Monitoring Sbtion A-24 (at Shyville no Road)
X-230-A-28 Ambient Air Monitoring Station A-28 (at Camp no Creek Road)
X-230-A-29 Ambient Air Monitoring Station A-29 (at West no Access Road)
X-230-A-36 Ambient Air Monitoring Station A-36 (at X-611) no X-230-A-37 Ambient Air Monitoring Station A-37 (at Mount no Hope Road)
X-230-A-40 Ambient Air Monitoring Station A-40 (at X-100 no Penthouse)
X-230B Sanitary Sewers no X-230C Storm Water Sewers no X-230D Soften Water Distribution System no X-230E Plant Water System (Makeup to Cooling Towers) no X-230F -
Raw Water Supply Lines no
+
i l
POEF-! "US-10 Revision 3 Criticality Accident Alarm System Coverage and Exclusions December 1998 Page 12 of 30 Facility Requires Coverage Number Facility Name and/or Function by CAAS X-230G RCW System no X-230H Fire Water Distribution System no X-230J1 Environmental Monitoring Station no X-230J2 South Holding Pond Effluent Monitoring Station no X-230J3 West Environmental Monitoring Building no X-230J4 Environmental Air Monitoring Station no X-230J5 West Environmental Sampling Building no X-230J6 Northeast Monitoring Facility no X-230J7 East Monitoring Facility no X-230J8 Environmental Storage Building no X-230J9 North Environmental Sampling Station no X-230K South Holding Pond no X-230L North Holding Pond no X-232A Nitrogen Distribution System no X-232B Dry Air Distribution System no X-232D Steam and Condensate System no X-232E Freon Distribution Lines no X-232F Fluorine Distribution System no X-232G Supports for Distribution Lines no X-240A RCW System (Cathodic Protection) no X-300 Plant Control Facility no
POEF-LMUS-10 Revision 3
- Criticality Accident Alarm System Coverage and Exclusions December 1998-Page 13 of 30 Facility Requires Coverage Number Facility Name and/or Function by CAAS X-300A Process Monitoring Building no X-3008 Plant Control Facility Carport no X-300C Emergency Antenna no X-334 Transformer Storage Cleaning Building no X-342B Fluorine Storage Building no X-344B Maintenance Storage Building no X-501 Substation no X-501A Substation.
no X-502 Substation no X-515 330 KV Tie Line no X-530A Switch Yard no X-530B Switch House-no X-530C Test and Repair Facility no X-530D Oil House no X-530E Valve House no X-530F Valve House no X-530G GCEP Oil Pumping Station
- no X-533 Transformer Storage Pad no X-533A' Switch Yard no X-533B Switch House no X-533C Test and Repair Facility no X-533D Oil House no
(,.....
POEF-LMUS-10 Revision 3 Criticality Accident Alarm System Coverage and Exclusions December 1998 Page 14 of 30 l
l l
Facility Requires Coverage l
Number Facility Name and/or Function by CAAS X-533E Valve House no
-l X-533F Valve House no X-533H Gas Reclaiming Cart Garage no X-540 Telephone Building no X-600 Steam Plant no X-600A Coal Pile Yard no X-6008 Steam Plant Shop no X-600C Ash Wash Treatment Building no XT-801 South Office Building no X-605 Sanitary Water Control House no X-605A Sanitary Water Wells no X-605H Booster Pump House and Appurtenance no X-6051 Chlorinator Building no X-605J Diesel Generator Building no X-608 Raw Water Pump no X-608A Raw Water Wells (1 to 4) no X-608B Raw Water Wells (5 to 15) no X-611 Water Treatment Plant and Appurtenances no X-611B Sludge Lagoons no X-611C Filter Building no X-611D Recarbonization Instrument Building no X-612 Elevated Water Tank no
POEF-LMUS-10 Revision 3 Criticality Accident Alarm System Coverage and Exclusions December 1998 Page 15 of 30 Facility Requires Coverage Number Facility Name and/or Function by CAAS X-614A Sewage Pumping Station no X-614B Sewage Lift Station no g
X-614D South Sewage Lift Station no X-614P Northeast Sewage Lift Station no X-616 Liquid Effluent Control Facility no X-617 South PH Control Facility no X-618 North Holding Pond Storage Building no X-621 Coal Pile Runoff Treatment Facility no X-626-1 Recirculating Water Pump House no X-626-2 Cooling Tower no X-630-1 Recirculating Water Pump House no X-630-2A Cooling Tower no X-630-28 Cooling Tower no X-630-3 Acid Handling Station no X-633-1 Recirculating Water Pump House no X-633-2A Cooling Tower no X-633-2B Cooling Tower no X-633-2C Cooling Tower no X-633-2D Cooling Tower no X-640-1 Firewater Pump House no X-640-2 Elevated Water Tank no lX-700A Air Conditioning Equipment Building no
1 i
1 POEF-LMUS-10 Revision 3 Criticality Accident Alarm System Coverage and Exclusions December 1998 Page 16 of 30 Facility Requires Coverage 1
Number Facility Name and/or Function by CAAS X-701A Lime House no X-701D Water Deionization Facility no X-705D Heating Booster Pump Building no X-710A Technical Services Gas Manifold Shed no X-710B Explosion Test Facility no X-720A Maintenance and Stores Building Gas Manifold no Shed X-720B Radio Base Station Building no X-720C Paint and Storage Building no X-741 Oil Drum Storage Facility no j
X-742 Gas Cylinder Storage Facility no X-743 Lumber Storage Shed no i
X-744B Salt Storage Building no i
X-744H Bulk Storage Building no, this building contains more than 15 grams of uranium, but contains an areal density ofless than 2
50 g/m,
X-744J Bulk Storage Building no X-744L Stores and Maintenance no, this building contains more than 15 grams of uranium, but contains an areal density of less than 2
50 g/m
l 1
POEF-LMUS-10 Revision 3 Criticality Accident Alarm System Coverage and Exclusions December 1998 -
Page 17 of 30 e
Facility.
Requires Coverage Number Facility Name and/or Function by CAAS -
X-744W Surplus and Salvage Warehouse no X-745G DUF6 Cylinder Storage Yard no,2"U enrichment less than 1%
X-745H DU Storage Yard no,2"U enrichment less than 1%
X-746 Materials Receiving and inspection Building no X-747A Material Storage Yard no a
X-7478 Material Storage _ Yard no X-747C -
Material Storage Yard no X-747D Material Storage Yard no X-747E Material Storage Yard no X-747F Miscellaneous Material Storage Yard no X-747J Decontamination Storage Yard no X-748 Truck Scale Facility no X-750 Mobile Equipment Maintenance Shop no X-750A Garage Storage Building no XT-847 Warehouse - Office Area no l
X-1000 Administration Building no X-1007 Fire Station no X-1020 Emergency Operations Center (EOC) no X-1107A Administrative Portal no X-1107B.
Interplant Portal no X-1107BP Admin. Portal no
1 POEF-LMUS-10 Revision 3 -
Criticality Accident Alarm System Coverage and Exclusions December 1998 Page 18 of 30 i
Facility Requires Coverage Number Facility Name and/or Function -
by CAAS X-1107D Northeast Portal no X-2200 Site Preparation, Grading and Landscaping no X-2202 Roads (GCEP) no X-2204 GCEP Railroads no X-2207A GCEP Administrative Parking Lot no X-2207D Northwest Parking Lot no X-2208 Security Fence no X-2210 Sidewalks no X-2215A Underground Electrical Distribution to Process no Buildings X-2215B Electrical Distribution to Areas Other than Process no Buildings X-2215C Exterior Light Fixtures no X-2220C Fire and Supervisory Alarm System no X-2220D Telephone System no X-2220L Classified Computer System no X-2220N Security Access Control and Alarm System no X-2230A' Sanitary Water Distribution System no X-2230B GCEP Sanitary Sewers no X-2230C Storm Sewers no X-2230F Raw Water Supply Line no X-2230G Recirculating Water System no X-2230H Fire Water Distribution System no
- m..
POEF-LMUS-10 Revision 3 Criticality Accident Alarm System Coverage and Exclusions December 1998 Page 19 of 30 Facility Requires Coverage Number Facility Name and/or Function by CAAS' X-2230J -
Liquid Effluent System no X-2230T Recirculation Heating Water System-no X-2232A Nitrogen Distribution System no X-2232B Dry Air Distribution System no X-2232D Steam and Condensate System no X-2232G Supports for Distribution Lines -
no X-3000 Electronic Maintenance Building no X-5000 GCEP Switch House no
~
X-5001 Substation no X-5001A Valve House no X-5001B Oil Pumping Station no X-5015 HV Electrical System no X-6000 GCEP Cooling Tower Pump House no X-6001 Cooling Tower no X-6001A Valve House no X-6609 Raw Water Wells no X-6613 Sanitary Water Storage Tank no X-6614E Sewage Lift Station no X-6614G Sewage Lift Station no X-6614H Sewage Lift Station no X-6614J Sewage Lift Station no X-6619 Sewage Treatment Facility no
POEF-LMUS-10 Revision 3 Criticality Accident Alarm System Coverage and Exclusions December 1998 Page 20 of 30 Facility Requires Coverage Number Facility Name and/or Function by CAAS X-6643 Fire Water Storage Tanks 1 and 2 no X-6644 Fire Water Pump House no q
X-7721 Maintenance Stores Training Building (Training) no t
0 I
h-
-m_
POEF-LMUS-10 Revision 3 Criticality Accident Alarm System Coverage and Exclusions December 1998 Page 21 of 30 Section 3.
EXCLUSION OF ROADWAYS FOR CERTAIN MATERIALS Exclusion of roadways, X-202, from Criticality Accident Alarm Coverage is requested during transport of the following four general classes of materials under the specified conditions.
Justification for the exclusion is given following the description of the specified conditions.
Class 1. Materials for which no spacing is required.
These materials will be limited to a concentration less than 5 grams U-235 in 10 liter volume (500 ppm) or all of the material being transported at a time will have less than a safe mass of U-235 at the highest enrichment in transport. Materials may be in one container or piece of equipment or several containers or pieces of equipment.
The stated concentration is given in Section 5.2 of the SAR and is consistent with the concentration given in 10CFR71.53 which exempts materials from being classified as fissile for the purposes of off-site transport.
Class 11. Materials for which spacing is required.
Materials will be secured such that the spacing will be maintained during transport. The plant speed limit will be maintained. Individually, materials will contain less than a safe mass of U-235, materials will be contained in volumetrically favorable containers, or materials will be contained in geometrically favorable containers.
The securing mechanisms will ensure spacing during norrnal transport and small transport abnormalities; e.g., bumps in roads, minor collisions. An overtuming of the transport vehicle or a major collision at speeds exceeding the plant speed limits would be required to create the potential for criticality.
Class Ill. Large UF6 Cylinders The exclusion forlarge UF cylinders of solid UF in storage is addressed in Section 4. The NCS considerations for these cylinder movements on roadways would be the same as cylinder movements in the cylinder storage yards.
Class IV. Materials Packaged for Offsite Transport Materials meeting the criteria and limits for 10CFR71 for offsite transport will not require coverage by CAAS.
Offsite shipment criteria have been established such that CAAS are not required.
Therefore, materials meeting the offsite shipment criteria should be excluded from CAAS coverage.
POEF-LMUS-10 Revision 3 Criticality Accident Alarm System Coverage and Exclusions
- December 1998 Page 22 of 30 Section 4.
EXCLUSION FOR LARGE CYLINDERS OF UF,IN STORAGE YARDS
4.1 INTRODUCTION
~
The purpose of this sectio'n is to justify an exclusion from 10 CFR Part 76.89 for all cylinder storage yards / lots (X-745B Toll Enrichment Process Gas Yard-UEA; X-745D Cylinder Storage Yard; X-745F North Process Gas Stockpile Yard) that may have UF, cylinders containing >1 wt% 23sU.but < 5 wt% 23sU, which are not covered by an existing CAAS at the Portsmouth Gaseous Diffusion Plant (PORTS). This justification is based on the Justification for Excluding UFe Cylinder Storage Yards from Criticality Accident Alarm Coverage", KY/S-27.1 (see attachment). This document evaluates the hazards associated with, and th'e controls applied to, cylinders containing >1 wt% 23sU to determine the credibility of a criticality accident. This document demonstrates that a criticality accident is not credible in the cylinder storage yards / lots at PGDP, thus an exclusion for the UF cylinder storage yards / lots from CAAS coverage is warranted.
Since the cylinder storage yards / lots at PORTS are similar to those at PGDP, the exclusion can be extended to the cylinder storage yards / lots at PORTS.
The credible accident scenarios addressed in the exclusion justification for PGDP involve the introduction of moderator into the UF, cylinder. Accident scenarios that involve the release of UFe or UO F from the cylinder to a location where the uranium 2 2 might form a critical configuration are not considered credible at either PGDP or PORTS. Periodic surveillance of the cylinders will detect the collection of UFe or UO F 2 2 from the cylinder before a sufficiently large quantity could accumulate into a critical configuration. There are no mechanisms in the immediate area of the storage yards / lots at either PGDP or PORTS that would facilitate the collection of released material into a layer that exceeds the minimum critical slab thickness.
I I
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POEF-LMUS-10 Revision 3 Criticality Accident Alarm System Coverage and Exclusions December 1998 Page 23 of 30 l
- 4.2 COMPARISON OF THE PGDP CYLINDER STORAGE YARDS / LOTS TO THE PORTS CYLINDER STORAGE YARDS / LOTS
- There is no difference in materials in the cylinder yards at PGDP and the cylinder
- yards / lots at PORTS as far as enrichment of 23sU (both a maximum of 5 wt% 23sU), type of cylinders stored, or cylinder inspection methods (both plants use the same
- procedure). The following operational differences exist between PORTS and PGDP; PORTS allows the stacking of cylinders, PORTS has an overhead crane system over some of the cylinder storage yards / lots, and the PORTS peak ground acceleration for a 1,000 year earthquake (0.17 g ) is less than PGDP. The last difference is bounded by 2
the PGDP case. The two differences not bounded by PGDP, stacking cylinders in the storage yards / lots and heavy equipment (overhead crane system) above/ adjacent to the storage yards / lots are discussed in the following two sections.
.4.2.1 STACKING CYLINDERS IN OUTSIDE CYLINDER STORAGE YARD / LOTS At PORTS cylinders are stacked a maximum of three high in cylinder storage yards / lots
_ (Reference 13). Two additional scenarios are possible due to stacking.
The first scenario is that a cylinder could be breached while stacking. The breach is due to impact, drop, or puncture. This scenario is covered in Reference 11 Section 4.1.
The second scenario is that a cylinder is damaged in such a way that the damage is not detected. This scenario is covered in Reference 11 Section 4.4.
4.2.2 OVERHEAD CRANE SYSTEM Several cylinder storage yards / lots at PORTS have overhead crane systems for moving cylinders. Six additional scenarios are possible due to the presence of the overhead crane system.
'The first scenario is that the crane drops the cylinder while transporting it. The dropped
. cylinder is breached due to impact, drop, or puncture. This scenario is covered in Reference 11 Section 4.1.
The second scenario is that the crane drops the cylinder while transporting it but it is only damaged in such away that the damage is not detected. This scenario is covered
POEF-LMUS-10 Revision 3 Criticality Accident Alarm System Coverage and Exclusions December 1998 Page 24 of 30 in Reference 11 Section 4.4.
The third scenario is that the crane drops a cylinder while transporting it onto another cylinder (s) causing either the dropped cylinder or target cylinder (s) to be breached. The breach is caused by the impact, drop, or puncture. This scenario is covered in Reference 11 Section 4.1.
The fourth scenario is that the crane drops the cylinder while transporting it onto another cylinder (s) causing either the dropped cylinder or target cylinder (s) to be damaged in such away that the damage is not detected. This scenario is covered in Reference 11 Section 4.4.
The fifth scenario is that part of the overhead crane system falls onto the cylinders breaching one. The breach is caused by an externalimpact. This scenario is not covered in Reference 11 Section 4.2 since PGDP does not have any heavy equipment l
adjacent to or over their shrage yards. There are four events that could cause the overhead crane system to fall; mechanical failure, tomado, earthquake, or flood.
Flooding is not a credible event since PORTS is 110 feet" above the 500-year flood level. The mechanical failure of the overhead crane system is not considered credible 1
since the crane is inspected every shift". The remaining initiators, tornado and earthquake are credible.
j The frequency of a tomado and earthquake are discussed in Reference 11 Section 4.2 I
for PGDP and in References 14 and 12 for PORTS. In both cases the availability of l
sufficient moderation, successful detection, and ease of repair was considered. For both the tornado and earthquake successfui detection and repair, in less than a week, is possible due to the high alerting factor of either event (see Table 4.2.2-A and 4.2.2-B).
The sixth scenario is that part of the overhead crane system falls onto the cylinders damaging one in such away that the damage is not detected. This scenario is covered in Reference 11 Section 4.4.
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1 POEF-LMUS-10 Revisic : 3 Criticality Accident Alarm System Coverage and Exclusions December 1998 Page 27 of 30 l
i Section 5.
EXCLUSION FOR THE BUILDING XT-847 OUTSIDE STORAGE PAD An exclusion is requested from criticality accident alarm systern coverage of the outside l
storage pad immediately west of XT-847.
The storage pad immediately west of XT-847 is used to store B-25 boxes containing contaminated dry waste and scrap metal. Each B-25 box stored there is limited to 5
(
100 grams U-235. All boxes have been NDA measured prior to storage. B-25 boxes can be grouped provided that there is 5 600 grams per group and each group is 12-
{
inches edge-to-edge from adjacent groups.
The material is not permitted to be transferred from one container to another stored on the outside pad.
j The stated gram limit for uranium-bearing waste material is stated in Section 5.2.2.5 of the SAR and is consistent with the gram limit given in 10CFR71.53 which exempts such
{
materials from being classified as fissile for the purposes of off-site transport (15 grams
)
U-235).
ANSI /ANS 8.3 states the need for a criticality accident alarm system is to be evaluated for all activities in which the inventory of fissionable materials in individual unrelated areas exceeds 700 grams U-235. Individual areas may be considered unrelated when the boundaries between such areas are such that there can be no interchange of materials between areas, the minimum separation between material in adjacent areas is 10 cm, and the areal density of fissile material averaged over each individual area is 2
less than 50 grams U-235/m. The limits on these operations, as described above, meet these conditions. The limit of 700 grams U-235 and the areal density of 50 grams 2
U-235/m is consistent with Section 5.2.2.5 of the SAR.
V l
POEF-LMUS-10 Revision 3 Criticality Accident Alarm System Coverage and Exclusions December 1998 Page 28 of 30 REFERENCES 1.
2.
American National Standard for Criticality Accident Alarm System, ANSI-ANS-8.3-1979, American Nuclear Society, LaGrange Park, Illinois, August 29,1986.
3.
S. B. Negron, R. W. Tayloe Jr., M. C. Dobelbower, Analysis of Criticality Alarm System Response to an Accidental Criticality outside the Cascade Process Buildings at the Portsmouth Gaseous Diffusion Plant, POEF-SH-19, Martin Marietta Utility Services, Inc., July 1994.
4.
M. C. Dobelbower, J. Woollard, B. L. Lee Jr., R. W. Tayloe Jr., Analysis of Criticality Accident Alarm System Coverage of the X-744G, X-744H, X-342/344A and X-343 Facilities at the Portsmouth Gaseous Diffusion Plant, POEF-SH-35, Lockheed Martin Utility Services, Inc., September 1995.
5.
C. W. Skapik, M. C. Dobelbower, J. E. Woollard, B. L. Lee Jr., J. A. Henkel, Analysis of Criticality Accident Alarm System Coverage in the X-700, X-705, and X-720 Facilities, POEF-SH-39, Lockheed Martin Utility Services, Inc.,
December 1995.
6.
C. W. Skapik, M. C. Dobelbower, J. Woollard, B. L. Lee Jr., An Examination of Criticality Accident Alarm Coverage of the X-710, X-760 Buildings and the North Half of the X-7745-R Storage Pad, POEc-SH-40, Lockheed Martin Utility Services Inc., January 1996.
7.
B. L. Lee Jr., M. C. Dobelbower, J. Woollard, C. W. Skapik, Examination of Criticality Accident Alarm Coverage on the Operating Floors of the X-333, X-330, and X-326 Facilities at the Portsmouth Gaseous Diffusion Plant, POEF-SH-38, Lockheed Martin Utility Services, Inc., January 1996.
8.
Letter from B. L. Lee Jr. to D. M. D'Aquila, dated March 5,1996, " Additional MCNP Calculations for X-326 NDA Laboratory - Purchase Order 426215 Item
- 2," Battelle.
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POEF-LMUS-10 Revision 3 Criticality Accident Alarm System Coverage and Exclusions December 1998 Page 29 of 30 9.
S. B. Negron, R. W. Tayloe Jr., Analysis of the Proposed Relocation of the l
Neutron criticality Clusters in the Process Buildings for the Portsmouth Gaseous Diffusion Plant, POEF-SH-12, Lockheed Martin Utility Services Inc.,
January 1994.
10.
M. C. Dobelbower, J. Woollard, B. L. Lee Jr., R. W. Tayloe Jr., Verification of Criticality Accident Alarm system Detector Locations for the X-326 Process Ce/IFloor, POEF-SH-34, Lockheed Martin Utility Services Inc., August 1995.
11.
Justification forExcluding UFe Cylinder Storage Yards from Criticality Accident Alarm Coverage, KYlS-271.
12.
Final Safety Analysis Report for Portsmouth Gaseous Diffusion Plant, GAT /GDP-1073, originally issued April 1985.
13.
Storing and Handling of Large Cylinders of Uranium Material, PORTS NCSA-PLANT 004.001.
14.
Application for United States Nuclear Regulatory Commission Certification for the Portsmouth Ohio Gaseous Diffusion Plant, originally issued September 15,1995.
15.
Design Analysis and Calculations NPH Evaluation for Stacked UFe Cylinders at Storage Yards, DAC-19045-CCA-60, Martin Marietta Energy Systems, Inc., Oak Ridge, Tennessee, June 12,1995.
16.
Deleted 17.
Deleted 4
18.
Deleted 19.
C. W. Skapik and B. L. Lee, Jr., A Comparison of Two Criticality Accident Alarm System Detector Locations for the X-700 Building at the Portsmouth Gaseous Diffusion Plant, POEF-LMUS-02, Lockheed Martin Utility Services, Inc., February 1996.
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D POEF-LMUS-10 Revision 3 Criticality Accident Alarm System Coverage and Exclusions December 1998 Page 30 of 30 20.
A. S. Brown, R. W. Tayloe Jr, M. C. Dobelbower, J. Woollard, Examination of l
Criticality Accident Alarm Coverage on the Operating Floors of the X-333, X-330, and X-326 Facilities at the Portsmouth Gaseous Diffusion Plant, POEF-SH-38 Rev.1, Lockheed Martin Utility Services, Inc., March 1997.
l-21.
NCS-CALC-98-023, Analysis of the Criticality Accident alarm System l
Coverage within the XT-847 Building.
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