ML20198B693
| ML20198B693 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 12/15/1998 |
| From: | Toelle S UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Paperiello C NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| GDP-98-0277, GDP-98-277, NUDOCS 9812210077 | |
| Download: ML20198B693 (11) | |
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i USEC
. A Globas Energy Company I
December 15,1998 GDP 98-0277 Dr. Carl J. Paperiello I
Director, Office of Nuclear Material Safety and Safeguards Attention: Document Control Desk '
. U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Paducah Gaseous Diffusion Plant (PGDP)
Docket No. 70-7001 Request for Enforcement Discretion
Dear Dr. Paperiello:
The purpose of this letter is to request enforcement discretion to allow continued plant operations beyond the existing schedule date for completing the Plan of Action and Schedule for Issues 46 and 50 described in DOE /ORO-2026, Plan for Achieving Compliance with NRC Regulations at the Paducah Gaseous Diffusion Plant (Compliance Plan). The enforcement discretion is necessary to allow plant operations to continue pending NRC issuance of the Certificate Amendment which was requested by USEC on November 5,1998 (Reference 1), which revises the completion dates associated with these Compliance Plan Issues. Although the NRC staff has recommended approval of the schedule change in their Compliance Evaluation Report issued on December 7,1998 (Reference 2), insufficient time is available to allow the amendment to be issued prior to the December 15,1998 completion date.
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Compliance Plan Issues 46 and 50 require plant modifications to ensure that the Criticality Accident Alarm System (CAAS) alarm homs are capable of being heard throughout the affected areas of the process buildings and to provide CAAS alarm homs for those unalarmed facilities within the &
evacuation area of CAAS-clustered buildings, respectively. The existing Compliance Plan schedule date associated with Issues 46 and 50 is December 15,1998. These Compliance Plan issues contain Justifications for Continued Operation (JCOs) which establish the basis for continuing normal plant operations without entering the Technical Safety Requirements (TSR) action statements for the Limiting Conditions for Operation (LCOs) for areas with an inaudible CAAS, which would otherwise be required.
i The JCOs associated with Compliance Plan Issues 46 and 50 will no longer be in effect after 1
December 15,1998, which is the required completion date for these Compliance Plan issues.
Without the benefit of the Compliance Plan JCOs, USEC would be required to enter the action statements associated with the CAAS audibility TSRs. The action steps associated with TSR l-6903 Rockledge Drive, Bethesda, MD 20817-1818 l'<>j9 Telephone 301-564-3200 Fax 301-564-3201 http:#www.usec.com i
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' Dr. Carl J. Paperiello December.15,1998
. GDP 98-0277, Page 2
.2.4.4.2(b), Criticality Accident Alarm System for the Enrichment Cascade Facilities and TSR 2.3.4.7(b), Criticality Accident Alarm System for the Product and Tails Withdrawal Facilities, require CAAS audibility to be restored within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of entering the LCO action steps. This cannot be accomplished until the modifications required by Compliance Plan Issues 46 and 50 are completed. -As a result, PGDP would no longer be able to comply with the TSRs requiring an audible CAAS. The action steps associated with the remaining affected CAAS audibility TSRs require CAAS audibility to be restored prior to reinitiating normal plant activities. Entering the LCO action steps associated with the remaining affected CAAS audibility TSRs would significantly i
curtail plant operations without a corresponding safety, safeguards, security or environmental benefit.
i Therefore, USEC is seeking enforcement discretion to continue normal plant operations as explained in the Enclosure. Specifically, USEC is requesting discretion to operate without entering the LCO action statements of the TSRs requiring CAAS audibility, for those areas which are currently covered by the JCOs for Compliance Plan Issues 46 and 50, until the NRC issues the certificate l
amendment. During this period of time, USEC will continue to implement the compensatory actions required by the JCOs for these two issues. The Enclosure provides the technicaljustification for this request in accordance with NRC Inspection Manual Chapter 9900.
Should you have. any questions regarding this matter, please contact Mr. Mark Smith at (301)564-3244. There are no new commitments contained in this submittal.
Sincerely, S.A
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Steven A.Toelle Nuclear Regulatory Assurance and Policy Manager l
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- d Dr. Carl J. Paperiello December.15,1998 GDP 98-0277, Page 3
References:
1.
Letter to Dr. Carl J. Paperiello (NRC) from Steven A. Toelle (USEC),
Certificate Amendment Request--Criticality Accident. Alarm System Upgrades--Compliance Plan Issue 46 and 50, dated November 5,1998.
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Letter to James H. Miller (USEC) from Merri Horn (NRC), Paducah
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Certificate Amendment Request: Criticality Alarm System Audibility Upgrades, Compliance Plan Issues 46 and 50 (TAC No. L32103), dated December 7,1998.
Enclosure:
Justification for Request for Enforcement Discretion ec: NRC Document Control Desk NRC Region III OfTice NRC Resident Inspector - PGDP Mr. Robert C. Pierson, NRC IIQ Mr. Randall M. DeVault, DOE I'
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1 ENCLOSURE GDP 98-0277 Justification for Request for Enforcement Discretion s,.
4 Enclosure to GDP 98-0277 Page1 of7 l
JUSTIFICATION FOR REQUEST FOR ENFORCEMENT DISCRETION 1.
THE TSR VIOLATED.
TSRs 2.3.4.7 and 2.4.4.2, Criticality Accident Alarm System, will be violated. The CAAS alarm is not audible (LCO 2.3.4.7b and 2.4.4.2b) in all areas where the maximum foreseeable absorbed dose in free air exceeds 12 rad. As identified in the NRC's letter to USEC on February 28,1997 (See Reference), this condition is not a violation while the JCOs and associated compensatory actions for Compliance Plan issues 46 and 50 remain in effect.
Ilowever, these JCOs will no longer be in effect after December 15,1998, the current scheduled completion date for these issues. Once the December 15,1998, completion date has passed, and until the NRC approves the certificate amendment request submitted on November 5,1998, to extend the completion date for these issues to January 18,2000, USEC will be unable to comply with the LCO action statement requiring CAAS audibility to be restored within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
Although the remaining alTected CAAS TSRs (TSRs 2.1.4.5 and 2.6.4.1) would not be violated, entering the current LCO action statements after December 15,1998, would curtail operations within the facilities covered by the TSRs without a corresponding increased safety, safeguards, security or environmental benefits. The CAAS Audibility TSR for the C-333 A and C-337A feed facilities would not be affected as there are no audibility concerns for these facilities.
2.
THE CIRCUMSTANCES SURROUNDING TiiE SITUATION, INCLUDING ROOT CAUSES, NEED FOR PROMPT ACTION AND IDENTIFICATION OF ANY RELEVANT HISTORICAL EVENTS.
As described in the Plan of Action and Schedule for Compliance Plan Issue 46, plant modifications to ensure that CAAS alarm horns are audible throughout the affected areas of process buildings C-331, C-335 and C-337 are required to be completed by December 15, 1998. To accomplish this Compliance Plan requirement, a CAAS Modification Project was initiated to design and install additional CAAS horns to ensure adequate audibility throughout the process buildings. The conceptual design to satisfy the requirements of this Compliance Plan action originally required installation of additional air powered CAAS horns and upgrading the existing air system to supply the air necessary to power these new horns. During the detailed design process, further reliance on the existing plant air system to support the CAAS system was questioned and determined to be undesirable. As a result, a new design concept to improve CAAS reliability v'hich utilizes a dedicated air system and air accumulators to supply the new CAAS horr was developed. Although only the process buildings were addressed in issue 46, to further enhance the reliability of the site wide CAAS system, this same design l
concept (i.e., a dedicated air system with air accumulators) is being applied to all CAAS ait i
horns at PGDP.
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o Enclosure to I
GDP 98-0277 Page 2 of 7 -
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The Plan of Action and Schedule for Compliance Plan Issta 50 requires modification of the
- CAAS to provide horns and/or lights for those unalarmed facilities, identified as of June 19, i
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L 1996, where nearby CAAS homs cannot be adequately heard or relocate the facilities to location outside the evacuation area of CAAS-clustered buildings. All facilities which were planned to be relocated outside of the evacuation area of CAAS-clustered buildings have been relocated.
The remaining scope of the Plan of Action and Schedule will be accomplished as part of the
- CAAS Modification Project described above.
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As noted'in the certificate amendment request submitted on November 5,1998, the modifications necessary to satisfy the requirements of Compliance Plan Issues 46 and 50 will not be completed until January 18,2000. This change in the scheduled completion date is required to allow sufficient time to perform the following activities:
Completion of the final design activities associated with CAAS Modification Project.
' Procurement of materials to support construction.
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Completion of construction activities.
Preparation, review and approval of anticipated Technical Safety Requirements changes to support operation of the improved CAAS.
l Preparation, review and approval of necessary implementing procedutes and training j
on these procedures to allow facility transition to the improved CAAS.
l Prompt action is required since, after December 15,1998, and until NRC completes their action to approve the above mentioned certificate amendment request, USEC will not be able to meet the audibility requirements of the CAAS TSRs until.the above noted modifications are completed and the existing JCOs for Compliance Plan Issues 46 and 50 will no longer be in l
effect.
- 3. ' THE SAFETY BASIS FOR THE REQUEST, INCLUDING AN EVALUATION OF THE SAFETY SIGNIFICANCE AND POTENTIAL CONSEQUENCES OF THE PROPOSED COURSE OF ACTION, INCLUDING ANY QUALITATIVE RISK ASSESSMENT.
The accident of concern associated with this request is an inadvertent criticality. As described L
in SAR Section 4.4, the probability of a criticality accident at PGDP is very low because of the L
design safety features and administrative controls specified in nuclear criticality safety L
approvals for fissile material facilities and activities. Continuing to operate in accordance with L
Compliance Plan Issues 46 and 50 JCOs cannot increase the probability of occurrence of a l-criticality accident at PGDP. In addition, the ability of the CAAS system to detect a criticality accident is not affected by the delay in completing the audibility upgrades.
Furthermore, the compensatory actions required by the JCOs for Compliance Plan Issues 46 and i
50 will continue to provide adequate notification to affected personnel of the need to evacuate
l Enclosure to e
GDP 98-0277 Page 3 of 7 in the event of a criticality accident. Therefore, the potential consequences of continuing to operate under the JCOs and associated compensatory actions for Compliance Plan Issues 46 and 50 after December 15,1998, is unchanged.
The NRC issued " Compliance Evaluation Report: Application Dated November 5,1998, Criticality Accident Alarm System Audibility Upgrades, Compliance Plan Issues 46 and 50,"
on December 7,1998. This CER was in response to USEC's request for amendment to the Compliance Plan completion dates. In the conclusion of the CER, the NRC staff recommends that the Compliance Plan be revised to reflect the new completion date for Issues 46 and 50.
4.
TIIE BASIS FOR Ti1E CERTIFICATE HOLDERS CONCLUSION TIIAT TliE NONCOMPLIANCE WILL NOT BE OF POTENTIAL DETRIMENT TO TIIE PUBLIC HEALTII AND SAFETY, T11E ENVIRONMENT, SAFEGUARDS, OR SECURITY, AND THAT NEITHER AN USQ NOR A SIGNIFICANT HAZARD CONSIDERATION IS INVOLVED.
The response in Question 3 shows that neither the probability nor the consequences of a criticality accident will be affected by this operation. The consequences for all credible criticality accident scenarios are presented in SAR Section 4.4 and are shown to be limited to on-site consequences. Therefore, there is no potential detriment to the public or worker health and safety.
The CAAS is only used to mitigate the efTects of a criticality accident by detecting a criticality and providing prompt notification to affected personnel of the need to evacuate the area. The certificate amendment request submitted on November 5,1998, stated that the compensatory actions required by the JCOs for Compliance Plan Issues 46 and 50 will remain in effect to provide an adequate means of notification in the event of actuation of the criticality accident monitoring system. The ability of the CAAS to detect a criticality is not affected and the compensatory actions required by the JCOs for Compliance Plan Issues 46 and 50 will continue to provide prompt notification to affected personnel.
Based on the following conclusions, there is no Unreviewed Safety Question:
1.
The proposed operation will not increase the probability of occurrence of an accident previously evaluated in the SAR. Continuing to operate in accordance with Compliance Plan Issues 46 and 50 JCOs cannot increase the probability of occurrence of a criticality l
l accident at PGDP.
2.
The proposed operation will not increase the consequences of an accident previously evaluated in the SAR. The ability of the CAAS system to detect a criticality accident is not affected by the delay in completing the audibility upgrades. In addition, the
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l Enclosure to l
GDP 98-0277 Page 4 of 7 compensatory actions required by the JCOs for Compliance Plan issues 46 and 50 will continue to provide prompt notification to affected personnel.
3.
The proposed operation will not increase the probability of occurrence of a malfunction of equipment important to safety previously evaluated in the SAR. The CAAS is only used l
to mitigate the consequences of a criticality accident. Continuing to operate under the JCOs for Compliance Plan Issues 46 and 50 will not effect the operation of the CAAS system.
4.
The proposed operation will not increase the consequences of a malfunction of equipment important to safety previously evaluated in the SAR. The CAAS is only used to mitigate the consequences of a criticality accident. Continuing to operate under the JCOs for Compliance Plan Issues 46 and 50 will not effect the operation of the CAAS system. In addition, the compensatory actions required by tne JCOs for Compliance Plan issues 46 and 50 will continue to provide prompt notification to affected personnel.
5.
The proposed operation will not create the possibility of an accident of a different type than any previously evaluated in the SAR. The CAAS is not used to prevent an accident.
Continuing to operate under the JCOs for Compliance Plan Issues 46 and 50 will not create the possibility of any new or different type of accident.
6.
The proposed operation will not create the possibility of a different type of malfunction of equipment important to safety than any previously evaluated in the SAR. The CAAS is only used to mitigate the consequences of a criticality accident. Continuing to operate under the JCOs for Compliance Plan Issues 46 and 50 will not create the possibility of a different type of malfunction of equipment important to safety.
7.
The proposed operation does not reduce the margin of safety as defined in the supporting bases documents for any TSR. The CAAS is only used to mitigate the consequences of a criticality accident which has already been evaluated in the Safety Analysis Report. No margins of safety associated with these mitigating actions are impacted by continued operation under the JCOs for Compliance Plan Issues 46 and 50.
Based on the following conclusions, there is no Significant Hazard Consideration:
- 1. The proposed operation has no impact on any effluents released offsite. Plant operations will continue under the JCOs for Compliance Plan Issues 46 and 50 such that there is no change in the effluents emitted from these operations.
- 2. The proposed operation will not result in an increase in individual or cumulative occupational radiation exposure. As discussed in the response to Question 3, neither the probability nor the consequences of a criticality accident will be affected by this operation.
- 3. The proposed operation will not result in a significant construction impact.
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- 4. The CAAS is only used to mitigate the consequences of a criticality accident which has already been evaluated in the Safety Analysis Report. As discussed in the response to Question 3, neither the probability nor the consequences of a criticality accident will be l
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s Enclosure to GDP 98-0277 Page 5 of 7 affected by this operation. Therefore, there is no increase in the potential for, or radiological or chemical consequences from, previously analyzed accidents.
- 5. The CAAS is only used to mitigate the consequences of a criticality accident which has already been evaluated in the Safety Analysis Report. There is no possibility of a new or different kind of accident arising from continued operation under the JCOs for Compliance Plan Issues 46 and 50.
- 6. No margins of safety associated with these mitigating actions are impacted by continued operation under the JCOs for Compliance Plan Issues 46 and 50.
- 7. The CAAS is only used to mitigate the consequences of a criticality accident which has already been evaluated in the Safety Analysis Report. Therefore, the proposed operations will not result in an overall decrease in the effectiveness of the plant's safety, safeguards or security programs.
The Notice of Amendment dated December 7,1998, concluded that the change in completion date is not significant in accordance with 10 CFR 76.45, and that the change provides reasonable assurance of adequate safety, safeguards and security.
5.
TIIE BASIS OF THE CONCLUSION THAT THE NONCOMPLIANCE WILL NOT INVOLVE ADVERSE CONSEQUENCES TO THE ENVIRONMENT.
The proposed operation has no impact on any effluents released offsite. Plant operations will continue under the JCOs for Compliance Plan Issues 46 and 50 such that there is no change in the effluents emitted from these operations. The Notice of Amendment dated December 7, 1998, also concludes that the change will not result in different types or a significant increase in the amounts of any effluents.
6.
ANY PROPOSED COMPENSATORY MEASURES.
As previously stated, this request proposes to continue operation under the compensatory measures already implemented to meet the requirements of the JCOs for Compliance Plan Issues 46 and 50. No additional compensatory measures are necessary.
7.
THE JUSTIFICATION FOR THE DURATION OF NONCONFORMANCE.
On November 5,1998, USEC submitted an amendment request to extend the scheduled completion date for actions required by Compliance Plan Issues 46 and 50. The duration of this nonconformance will last until the NRC completes their action to approve the proposed amendment.
l-Enclosure to GDP 98-0277 Page 6 of 7 8.
A STATEMENT THAT THE REQUEST HAS BEEN APPROVED BY THE PLANT l
OPERATIONS REVIEW COMMITTEE (PORC).
L The PGDP PORC approved this request for enforcement discretion on December 15,1998.
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THE REQUEST MUST ADDRESS HOW ONE OF THE NOED CRITERIA FOR l
APPROPRIATE PLANT CONDITIONS SPECIFIED IN SECTION B IS SATISFIED.
Criteria B.3 in Manual 9900, NOEDs for GDPs states: "For all operating conditions at the GDP, the NOED is intended to avoid total plant shutdown, without considering the full implication and without corresponding safety, safeguards, security or environmental benefit."
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Therefore, for LCOs 2.3.4.7b and 2.4.4.2b, dealing with CAAS Audibility, the granting of i
enforcement discretion would prevent a total plant shutdown without corresponding safety, safeguards, security or environmental benefits.
l Certain activities, such as maintenance, sampling, waste management and other support l
activities are necessary if operation is to continue beyond the December 15,1998. Criteria B.l(a) in Manual 9900, NOEDs for GDPs, states that "... the NOED is intended to: (a) avoid unnecessary transients as a result of forcing compliance with the TSR/ certificate condition and, I
thus, minimize potential safety, environmental, safeguards or security consequence and l
operational risks;..." Components such as seals, seal exhaust pumps, wet air pumps, compressors, square to round fittings, etc., are frequently removed from service and either repaired or replaced with rebuilt components. Interruption of these activities, even for a short time, could result in the interruption of stable process operations and produce undesirable
. process equipment shutdowns due to a lack of replacement components and the inability, due i
to TSR restrictions, to open the system for maintenance, process waste and move fissile or potentially fissile material.
j In addition, entry into the LCO required actions for all facilities, except for those covered by i
LCOs 2.3.4.7b and 2.4.4.2b, requires fissile material operations to cease, resulting in site wide transitory activities to stop these operations. Therefore, for LCOs 2.1.4.5b and 2.6.4.1b, dealing L
with CAAS Audibility, the granting of enforcement discretion would avoid unnecessary l
transients as a result of forcing compliance with the TSR/ certificate condition and, thus, minimize potential safety, environmental, safeguards or security consequence and operational risks. The CAAS Audibility TSR for the C-333A and C-337A feed facilities would not be affected as there are no audibility concerns for these facilities.
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Enclosure to GDP 98-0277 Page 7 of 7
- 10. IF A. FOLLOW-UP TSR/ CERTIFICATE AMENDMENT IS REQUIRED, THE NOED
, REQUEST MUST INCLUDE MARKED-UP TSR PAGES.
THE ACTUAL TSR/ CERTIFICATE AMENDMENT REQUEST.MUST FOLLOW WITHIN 48 HOURS.
The proposed certificate amendment request was submitted on November 5,1998. This additional enforcement discretion is requested while the NRC completes their action to approve this amendment request.
I1. ANY OTHER INFORMATION THE STAFF DEEMS NECESSARY BEFORE MAKING A DECISION TO EXERCISE ENFORCEMENT DISCRETION.
No other information has been requested by the StafTat this time.
REFERENCE:
Letter from Robert C. Pierson (NRC) to Mr. James H. Miller (USEC), Linkage of Criticality Accident Alann System (CAAS) Technical Safety Requirements (TSRs) and Compliance Plan Requirements for Portsmouth (PORTS) and Paducah (PGDP) Gaseous Diffusion Plants, dated February 28,1997.
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