ML20196J077
| ML20196J077 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 12/04/1998 |
| From: | Paperiello C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Toelle S UNITED STATES ENRICHMENT CORP. (USEC) |
| References | |
| TAC-L32100, NUDOCS 9812090256 | |
| Download: ML20196J077 (3) | |
Text
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Mr. Steven A. Toelle Manager, Nuclear Regulatory Assurance and Policy U. S. Enrichment Corporation 2 Democracy Center 6903 Rockledge Drive Bethesda, MD 20817
SUBJECT:
PADUCAH REQUEST FOR APPROVAL OF AN EXCLUSION FROM 10 CFR 76.89(a) FOR CRITICALITY ACCIDENT ALARM SYSTEM AUDIBILITY IN CONFINED SPACES AND CELL HOUSINGS (TAC NO. L32100)
Dear Mr. Toelle:
i By letter dated October 19,1998, the U. S. Nuclear Regulatory Commission (NRC) received your request for an exclusion from the Criticality Accident Alarm System (CAAS) audibility requirements of 10 CFR 76.89(a) for the Paducah Gaseous Diffusion Plant.
Specifically, you have requested that the U. S. Enrichment Corporation (USEC) be allowed an exclusion from the requirements to have an audible CAAS alarm in permit-required confined spaces and cell housings associated with cells that are running. It is required by 10 CFR 76.89(a) that a criticality monitoring and audible alarm system be maintained and operated for all areas of the plant. The regulations allow USEC to describe for the approval of NRC defined areas to be excluded from the monitoring requirement. USEC is only re@esting relief from the audibility requirements and not the detection function.
There are some areas of the facility where the CAAS horns cannot be heard above the background noise. USEC has an upgrade program to address audibility issues for most areas of the plant. The modifications are required by Compliance Plan Issues 46 and 50. As part of the upgrade project, USEC has determined that a safe and reliable means of providing CAAS audibility coverage in permit-required confined spaces and cell housings associated with cells that are running may not be achievable. The addition of enough horns to compensate for ihe high noise le./el could result in hearing damage to personnel working in those areas. The heat and vibration that can be experienced inside the cell housings can also cause problems with the reliability of any devices (visual or horn) that may be placed insido the housing. Permit-required confined spaces covered by this exclusion request include such areas as work inside vessels for vessel inspection, work inside piping, and work in trenches.
ANSl/ANS 8.3-1997," Criticality Accident Alarm System" provides that for areas with high O
background noise or mandatory hearing protection, visual signals or other alarm means should be considered. USEC is proposing to use a buddy system to provide an alternate means of notifying personnel of a CAAS alarm. The buddy system requires that one person (an
\\p2 attendant) remain outside the area in contact with personnel (entrants) inside the area to notify them if a CAAS alarm occurs. The method of contact between the attendant and entrant is determined considering the work to be performed, the location of the work, and the personnel performing the work. The buddy system is current plant practice required by OSHA for confined space entries. Entry into permit-required confined spaces already requires use of the
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S. A. Totila, USEC 2
December 4, 1998 buddy syst:m, no changa to plant proc:duras will be n:c:ssary. For the cell housings, USEC will revise the procedures to require use of the buddy system. Staff will be trained on the revised procedures prior to implementation to ensure that the new requirements are understood. The delay in notification introduced by use of the buddy system versus hearing a CAAS horn directly should be on the order of seconds. This delay would not result in an appreciable increase in the dose that would potentially ba received by either the attandant or the entrants in the unlikely event of an inadvertent criticality. In addition, the probability of an inadvertent criticality event is low based on the design features and administrative controls that have been implemented for activities involving fissile material.
Although the CAAS alarms can probably be heard in most of the areas covered by the permit-required confined spaces and in some of the cell housings, audibility cannot be assured.
Therefore, an alternate means of notification is necessary. The staff finds the use of the buddy system to be an acceptable alternative.
USEC is hereby granted an exclusion from the audibility requirements of 10 CFR 76.89(a) for permit-required confined spaces and cell housings associated with cells that are running at the Paducah Gaseous Diffusion Plant. USEC shall use a buddy system when entering permit-j required confined spaces and cell housings associated with cells that are running. TI,is buddy system shall require that one person remain outside the area (confined space or cell housing) in contact with personnel inside the area to notify them of a CAAS alarm.
If you have any questions, please contact Ms. Merri Horn of my staff at (301) 415-8126.
Sincerely, (Original signed by)
Carl J. Paperiello, Director Office of Nuclear Material Safety and Safeguards Docket 70-7001 Certificate GDP-1 cc: Mr. Howard Pulley, PGDP Mr. Randall DeVault, DOE DISTRIBUTION:(ControlNo. 500S)
Docket 70-7001 NRC File Center PUBLIC Rlli KO'Brien, Rlli NMSS r/f FCSS r/f SPB r/l PHiland,Rll!
DHartland, Rlli p:padexaud.wpd
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S. A. To lla, USEC 2
d:r of s:conds. This d lay would not result in an appreciabla increase in tha dose that would potentially be received by either the attendant or the entrants in the unlikely event of an inadvertent criticality. In addition, the probability of an inadvertent criticality event is low based on thh4esign features and administrative controls that have been implemented for activities involvin'g\\
fissile material.
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Although the(CAAS alarms can probably be heard in most of the areas covered by the permit-required confir(ed spaces and in some of the cell housings, audibility cannot be assured.
Therefore, an ah rnate means of notification is necessary. The staff finds the use of the buddy system to be an a eptable alternative.
USEC is hereby granted an exclusion from the audibility requirements of 10 CFR 76.89(a) for s
permit-required confined s es and cell housings associated with cells that are running at the Paducah Gaseous Diffusion ant. USEC shall use a buddy system when entering permit-required confined spaces and housings associated with cells that are running. This buddy contact with personnelinside the are(a4o notify them of a CAAS alarm. system shall req N
If you have any questions, please contact M6. Merri Horn of my staff at (301) 415-8126.
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Sincer,ely, Carl J. Pape llo, Director..
Office of Nucle Material Safety and Safeguards Docket 70-7001 Certificate GDP-1 cc: Mr. Howard Pulley, PGDP Mr. Randall DeVault, DOE DISTRIBUTION:(Control No. 500S)
Docket 70-7001 NRC File Center PUBLIC Rlli KO'Brien, Rlli NMSS r/f FCSS r/l SPB ri!
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