ML20198H113
| ML20198H113 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 12/08/1997 |
| From: | Toelle S UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Horn M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| GDP-97-0205, GDP-97-205, NUDOCS 9801130201 | |
| Download: ML20198H113 (11) | |
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, A Globel Energy Company Decemoer 8,1997 Ms. Marti llorn SERIAL: GDP 97-0205 Proh./. Manager, Enrichment Section Special Projects Branch Division of Fuel Cycle Safety and Safeguards, NMSS United States Nuclear Regulatory Commission Washington, D.C. 20555-0001 Paducah Gaseous Diffusion Plant (PGDP)
- Docket No. 70-7001 Rer.ponse to Request for Information - Paducah Updates to Certification Application
Dear Ms. lloro:
By letter dated November 7, 1997, you requested additional information regarding the appropriateness ofchangec made to the certification application under 10 CFR 76.68. Enclosure 1 to this letter provides the USEC.esponse to your request for additionalinformation.
n Should you have any questions related to this subject, please contact Steve Routh at (301) 564-3251.
Cormiitments contained in this submittal are identified in Enclosure 2.
Sincerely, S.A.
I Steven A. Toelle Nuclear Regulatory Assurance and Policy Manager
Enclosures:
1.
United States Enrichment Corporation, Paducah Gaseous Diffusion Plant, Docket No. 70-7001, Response to November 7,1997 NRC Reques' for Additiorial Information 2.
Commitments Contained in this Submittal 9001130201 97120e ~
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GDP 9-0205 Page1of9 United States Enrichment Corporation Paducah Gaseous Diffusion Plant Docket Nos. 70-7001 Response to November 7,1997 NRC Request for Additional Information Safety Analysis Reggtt
- 1. On page 3.3-20, Rev. 8, you deleted the commitment to ANSI B-31.3, " Chemical Plant and Petroleum Refining Piping" for inbncation involving welded joints. Please provide additionalinformation as to why USEC has concluded that deletion of the ANSI standard commitment is an allowed change under g 76.68.
USEC Resnonse SAR Section 3.3.4.5.1, " Piping and Weld Joints," specifically address the Van Stone flanges : hat connect cascade piping and process equipment. These flanges were originally designed for a cascade system which was expected to operate at all times belcw atmospheric pressure. During the Cascade Uprating Project (CUP), process changes were made which resulted in some portions of the cascade now being subject to a positive internal (i.e., above atmospheric) pressure. For Van Stone flanges at some locations in the cascade now subject to positiu pressures, clamps were installed to ensure the flanges were capable of withstanding the internal pressure.
As part of USEC's efforts in response to Compliance Plan Issue 45, the extent of compliance to industry codes, standards, and other regulatory guidance documents was rev;ewed, in reviewing the extent of compliance with ANSI Standard B31.3, it was determined that neither the original design of the Van Stone fhnges nor the addition of cit.mps during CUP were designed in accordance with ANSI B31.3. Consequently, the reference to ANSI B31.3 was corrected in SAR Section 3.3.4.5.1.
Deletion of *he reference to ANSI B31.3 has no adverse atTect on safety since the original and modified Van Stone flange designs have been shown to withstand the relatively low operating
- pressures experienced in the cascade. There is no change in the ability of the Van Stone flar.ges to perform their design function. No physical char.ges were made to the plant as a result of the deletion 5
of the referena to ANSI B31.3 for the Van Stone flanges. A safety evaluation was performed in accordance with plant procedures which concluded that this change did not result in an unrev ewed safety question.
For these reasons, and based on the results of the 10 CFR 76.68 Plant Change Review (PCR) and safety evaluation performed for the change, the Revision 8 changes to SAR Section 3.3.4.5.1 were deterndned to be acceptable under 10 CFR 76.68(a) and did not require prior NRC approval. Copies of the PCR and safety evaluation performed for the change are available at the site for NRC review.
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t GDP 97-0205 Page 2 of 9
- 2. On page 3.3-35, Rev. 8, you deleted information that dry air is less than 10 ppm moisture and added information to indicate that the moisture content of the air stream is normally less than 50 ppm. Please provide additionalinformation as to why USEC has concluded that these changes do not decrease safety and are allowed changes under Q 76.68.
USEC Responsg The basis for establishing a moisture content of" _normally less than 50 ppm.. " in the Revision 8 change to S AR Section 3.3.5.2 is as follows:
NCSA GEN 10-01 establishes a limit of 1300 ppm moisture content by volume for dry air used to purge or pressurize shutdown UF, process gas equipment. Consequently, for moderation control, the original limit of 10 ppm moisture is overly restrictive.
Engineering evaluation EV-C-dl2-96-5 was performed to evaluate the other uses for dry air at the plant and establish the level of dryness required for safe operation. The engineering evaluation concluded that the moisture tolerance requirements for important to safety applications are more than satisfied when using dry air in accordance with the industry standard found in ISA S7.3, " Quality Standard for Instrument Air." The engineering evaluation suppelted a change in the moisture content limit from 'O ppm to "normally less than 50 pgm" to reflect the actual setpoint for the instrument air system controls and to acknowledge that the actual moisture content can exceed 50 ppm slightly for a short time when the instrument setpoint is reached but before the air dryers reduce moisture to below the setpoint.
The calculation of the 50 ppm value is documented in set point calculation SPC-CSE-19352-14 which ensures that the air meets both the criterion specified in IS A S7.3 (i.e.,
dewpoint at least 18 *F below the minimum local recorded ambient temperature at the plant site) as well as the criterion of 1300 ppm specified in NCSA GEN 10-01 are met.
The NCS A specification of 1300 ppm is equivalent to a dewpoint of +27 *F at 40 psig.
Based on the NCSA and ergineering evaluation, the change in moisture content limit from 10 ppm to normally less than 50 ppm results in no adverse effect on safety. A safety evaluation was performed in accordance with plant procedures which concluded that this change did not result in an unreviewed safety question.
For these reasons, and based on the results of the 10 CFR 76.68 Pimt Change Review (PCR) and safety evaluation perfomied for the change, the Revision 8 changes to SAR Section 3.3.5.2 were determined to be acceptable under 10 CFR 76 6S(a) and did not require prior NRC approval. Copies of the NCSA, engineering evaluation, PCR, and safety evaluation performed for the change are available at the site for NRC review.
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GDP 97-0205 Page 3 of 9
- 3. On page 3.13-5, Rev. 8, you changed the commitment to ASME B31.3 to current plant practice for converter repair and retesting. Please provide additionalinformation as to why.USEC has concluded that this change is allowed under } 76.68.
USEC Resnonse As part of USEC's efforts in response to Compliance Plan Issue 45, the extent of compliance to industry codes, standards, and other regulatory guidance documents was reviewed. In reviewing the extent of compliance with ANSI Standard B31.3, it was determined that this standard is not applicable to the repair and testing of cascade converters. Cascade converters are pressure vessels.
ANSI B31.3 does not address repairs to pressure vessels and, therefore, this standard is not applicable to converters. Consequently, the reference to ANSI B31.3 wa.; deleted in SAR Section 3.13.2.8.
Deletion of the reference to ANSI B31.3 for the repair and testing of cascade coverters has no adverse efTect on the ability of the converters to perform their design function. A safety evaluation was performed in accordance with plant proccdures which concluded that this change did not result in an unreviewed safety question.
For these reasons, and based on the results of the 10 CFR 76.68 Plant Change Review (PCR) and safety evaluation performed for the change, the Revision 8 changes to SAR Section 3fl3.2.8 were determined to be acceptable under 10 CFR 76 68(a) and did not require prior NRC approval. Copies of the PCR and safety evaluation performed for the change are available at the site for NRC review.
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J GDP 97-0205 Page 4 of 9
- 4. On page 4.3-49, Rev. 8, you removed the heellimits established for the cylinder cleaning and testing facility. Please provide additionalinformation as to why USEC has concluded that this change is allowed under % 76.68.
USEC Resnonse Ilisto;ical data of cylinder tare weights indicated that the cylinders were losing a significant amount of weight over time. The tare weights are typically adjusted when the cylinders are emptied after five years from the last time the tare weight was established. Prior to washing a cylinder, the heel weight was determined to nelp ensure criticality safety. The heel weight was determined by subtracting the tare weight from the cunent cylinder weight. However, due to corrosion of the cylinder wall, the cylinder tare weight was actually seveial pounds less than that originally established. Using this incorrect (i.e., larger) tare weight which was established many years earlier, results in an inaccurately (i.e., smaller) measured heel weight. In other vords, there could be a larger heel present in the cylinder than expected based on the cylinder weight.
Because the heel weight was used as one of the criticality safety controls for complying with the double contingency principle, the criticalhy safety of the operation had to be re-evaluated. New connois were established for the purpose of complying with the double contingency principle. This change to the SAR was made to reflect the development of these new controls.
i The criticality controls originally specified in the SAR allowed cylinders which contained uranium enriched to as much as 2 wt % to be washed. This is why the amount of uranium in the cylinders had to be controlled. However, after determining that the heel weights were not accurate, the cylinder wash operation was restricted to only cylinders which contain uranium enriched to less than wt %. Since a cylinder full of moderated uranium enriched to less than 1 wt% cannot go crtical, the controls necessary for compliance with the double comingency principle were developed to ensure that only those cylinders which contain uranium enriched to less than I wt% were washed.
The SAR requires compliance with the double contingency principle as the acceptance criterion for establishing criticality safety, and the change was determined not to involve an unreviewed safety question. The requirements established for double contingency in the NCSE were adequate.
The enrichment was limited to a safe value and was required to be independently verified. The independent verifications were necessary to prevent one iadividual from selecting a cylinder in error.
Although the new controls (which ensure enrichment is less that I wt%) are difTerent than the old controls (which were intended to ensure a maximum amour + of heel material), the new controls are adequate to ensure double contingency.
i The intent of the change was to comply wkh the double contingency principle. This is a case where the controls used to ensure double contingency were changed, br; double coatingency was l
still required. The intent of the new controls was tc provide greater safety because the old controls (i e., maximum heel limits) were determined to be unreliable. The change to the S AR was consistent with our program for ensuring double contingency for NCS.
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GDP 97-0205 Pa_ge5of9 For these reasons, and based on the results of the 10 CFR 76.68 Plant Change Resiew (PCR) and
-safety evaluation performed for the change, the Revision 8 changes to SAR Section 4.3.7.1.3_ were -
- determined to be acceptable under 10 CFR 76.68(a) and did not require prior NRC approval. - Copies -
of the NCSE, PCR, and safety evaluation performed for the change are available at the site for NRC '
review.
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GDP 97-0205 Page 6 of 9
- 5. On page 5.3-19, Rev. 8, USEC changed the posting requirements for soil contamination areas from 30 pCi/g of uranium and/or 70 pCi/g Tc99 to surface contamination greater than the total cot.tamination levels in Table 5.J.2. Table 5.3-2 is the bionssay program and would not be an appropriate comparison. Please provide additional information as to why USEC has concluded that they can change the levels requiring posting without decreasing the effectiveness of the radiation safety program and why Table 5.3 2 specifically has been referenced.
USEC Resnonse The reference to SAR Table 5.3-2 is an error; the correct reference should be to SAR Table 5.3-6.
An application change is being processed to correct this error. The change to a surface
- contamination limit is consistent with other contamination limits for other material as shown in Table 5.3-6.
Volumetric contamination resulting in surface contamination consistent with the surface contaminstion limits identified in Table 5.3-6 will be detectable by a surface scan for contamination. Changing the surface contamination limit to the same value as is used for other material does not decrease the effectiveness of the radiation safety progre.m.
Application Resision SAR Section 5.3.3.1, under the heading " Soil Contamination Areas," will be revised to read as follows:
" Soil Contamination Areas If surveys of scil surfaces conducted in USEC-controlled spaces indicate surface contamination greater than the tc*al contamination levels shown in Table 5.3 6, the area is ported as required by approved procedures. Prior to and during excavation, surveys are taken of the sub-surface soil to determine extent of contarniaation These soil contamination areas are typically a legacy of past DOE operations and considered 00E waste."
This application change will be completed by January 30,1998.
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. Enclosure 1 GDP 97-0205 Page 7 of 9 Emernerny Plan
- 4. The changes made to the possession limits'in Table 1-3, Rev.14 (pages 1-9 through 1-11) do not match the possession limit table in Chapter 1 of the safety analysis report. In addition, (1) footnote fis inappropriate for material types A, B, and D, and (2) chan9ing the enrichment level up to 10 percent is the same change for which USLC received a ! tice of Violation in Inspection Report 97004. Please cc ect or explain the inconsistencies.
6 USEC Resnonse As described in SAR Section 6.3.3.1, updates to several of the programs and plans in Volume 3 o the cert ficat on app cat on must be submitted to the NRC at least every 6 months _. However, f
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li i updates to the Safety Analysis Report are on an annual basis. Revision 14 included changes to several of the Volume 3 programs and plans that occurred since the first annual update (Revision 8). Included among these changes weie the changes to the Emergency Plan that are in question.
Identical changes were also made to SAR Table 1-3 and distributed to USEC copyholders.
However, the changes to the SAR are not piecd to be included in a numbered revision to the cenification application until the next annual update m April 1998.
The changes to SAR Table 1-3 resulted in USEC receiving Notice of Violation 97004-10. As documented in the response to the violation, USEC is processing an application change that will coicect the possession limits tables. The corrective action and Application changes will apply to Table 1-3 in both the SAR and the Emergency Plan. The reference to footnote f will also be corrected.
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GDP 97-0205 Page 8 of 9
- 7. On page 5-7, Rev. 8, you have deleted the annual training commitment for escorts. Please provide additionalinformation as to why USLC has concluded that deletion of the annual retraining requirement does not decrease the effectiveness of the Emergency Plan.
USEC Resnonse Retraining of escorts is not being climinated from the plan. The requirement for biennial General Employee Training (GLT) of plant personnel, including escorts, is identified in Section 7.2.1 of the Emergency Plan (EP) and Section 6.6.5 of the SAR. The Revision 8 change to EP Section 5.4.1.3 was made to eliminate an inconsistency and ambiguity relative to the retraining requirements. The deletion of " annual training" in EP Section SA,1.3 does not reduce the efTectiveness of the Emergency Plaa since the proper training, i.e., GET, at the frequency described in EP Section 7.2.1 and SAR Section 6.6.5 is being implemented.
Annlication Revision To eliminate ambiguity in the existing language, EP Section 5.4.1.3 will be revised to read as follows:
. Escorts are trained in emergency response procedures, which includes instructions on methcds of notification and the required actions in the event of an emergency. Esarts are responsibe for accounting for visitors by name through their line organizations.
To ensure proficiency, periodic evacuation and accountability drills are conducted.
When an accountability is required, personnel report through their line organizations to Building C-300, which maintains the overall accountability status of the plant. The PGDP accountabihty is considered complete when all USEC, USEC contractor, and visitor personnel are accounted for or missing persons are identified."
This application change will be completed by January 30,1998.
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4 GDP 97-0205 Page 9 of 9
- 8. -On page 6-5, Rev.14, you have deleted the comm:tment to conduct weekly tests on the STU-Ill phcne, cellular phones, and facsimile machines.- Please provide additional information as to why USEC has concluded that deletion of the test requirements does not
- decrease the cJectiveness of the Emergency Plan.
USEC Resnonse Prior to the Emergency Plan revision, descriptions for specified communications systems included " weekly testing" of communications equipment in the following Emergency Plan sections:
Section 6.2.1.1 (EOC telephones, Cascade Coordinator's STU 111 phones, r.nd PSS and APSS response vehicle cellular telephones), Section 6.2.1.3 (800 MHZ radios in the PSS and APSS response vehicles); and Section 5 2.1.5 (EOC facsimile macianes). Contrarily, Emergency Plan, Section 7.6, " Maintenance and Inventory of Emergency Equipment, Instrumentation, and Supplies,"
states that emergency equipment in C-100 (location of the EOC) is inspected and :nventoried quarterly, which is consistent with the Nuclear Regulatory Commission's guidance provided in Regt.latory Guide 3.67, " Standard Format and Content for Emergency Plans for Fuel Cycle and Materials Facilities." Section 7.6 also states that emergency equirinent and supplies on emergency response vehicles are inspected and inventoried as required by plant procedures. Plant emergency plan procedure; implement the emergency equipment inventory and inspection commitments and are consistent with Section 7.6 of the Emergency Plan.
All references to weekly testing of on-site communications systems in Sections 6.2.1.1,6.2.1.3, and 6.2.1.5 were deleted in the Emergency Plan revision. The removal of" weekly testing" from the above stated Emergency Plan sections ensures consistency within the certification application. The quarterly inspection and inventory commitment, consistent with the guidance provided in Regulatory Guide 3.67, is implemented in plant procedures CP2-EP-EP5032, " Plant Emergency Management Program," and CP2-EP-EP5058, " Maintenance of Emergency Facilities and Equipment." PGDP has been and continues to implement the quarterly commitment ofinspecting and inventorying emergeecy equipment as described in Section 7.6 of the Emergency Plan and plant procedures.
The etauge to the Emergency Plan cr-the description of the plant's emergency management program by ensuring consistency w rnergency equipment maintenance and inspection commitments delineated in the Emergency Plan. The deletion of" weekly. testing" referer.;.ed in Sections 6.2.1.1, 6.2.1.3, and 6.2.1.5 docs not reduce the effectiveness of the plant's emergency management. program since the correct inspection frequency described in Emergency Plan Section 7.6 is being implemented.
The effectiveness of the Emergency Plan has not been decreased by the change described above.
The Emergency Plan change does not impact emergency planning regulatary requi ements described -
- in 10 CFR 76.91 and does not decrease existing plant emergency response capabilities or response cifectiveness.
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- Commitments Contained in this Submittal n
- 1. SAR Section 5.3.3.1, under the heading"Seil. Contamination Areas," uill be revised to read as
' follows:
3
" Soil Contamination Areas -
. If surveys ofsoil surface conducted in USEC-controlled spaces indicate
- surface contamination greater than the total contamination levels shown in Table 5.3-6, the area is posted as required by approved procedures. Prior to and during :
excavation,~ surveys are taken of the sub-surface soil to determine extent of contamination. These so 1 contamination areas are typically a legacy of past _
- DOE operations and considered DOE waste."
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This application change will be completed by January 30,1998.
2.iTo eliminate ambiguity in the existing language, EP Section 5.4.1.3 will be revised to read as-
. follows:
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" Escorts are trained in-emergency response procedures, which includes W
instructions on methods of notification and the required actions in the event of
- an emergencyi Escorts are respcasible for accounting for visitors by name through their lirc organizations
_ To ensure proficiency, periodic evacuation and accoun' ability drills are conducted. When an accountability is required, personnel report through their line organizations to Building C-300, which maintains the overall accountability status'of the plant. The PODP accountability is considered complete when all n
!USEC, USEC contractor, and visitor personnel are accounted for or missing persons are identified."
This application change will be completed by January 30,1998.
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