ML20199G623
| ML20199G623 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 01/08/1999 |
| From: | UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | |
| Shared Package | |
| ML20199F252 | List: |
| References | |
| DOE-ORO-2026, NUDOCS 9901220353 | |
| Download: ML20199G623 (10) | |
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1 GDP 99-0005 I
DOE /ORO-2026 Plan for Achieving Compliance with NRC Regulations at the Paducah Gaseous Diffusion Plant Revision 8 i
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9901220353 990108 PDR ADOCK 07007001 C
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DOE /ORO-2026, PLAN FOR ACHIEVING COMPLIANCE WITH NRC REGULATIONS AT THE PADUCAH GASEOUS DIFFUSION PLANT REMOVAL / INSERTION INSTRUCTIONS REVISION 8 JANUARY 8,1999 Remove Page Insert Page Issue 46, Criticality Accident Alarm Issue 46, Criticality Accident Alarm System-Horn Audibility System-Horn Audibility Pages 1/2,3 Pages 1/2,3/4 Issue 50, Criticality Accident Alarms for Issue 50, Criticality Accident Alarms for Nearby Buildings Nearby Buildings Paces 1/2. 3 Pages 1/2. 3/4 O
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i Issue 46, Page 1 f
l Criticality Accident Alarm System-Horn Audibility (new issue)
REQUIREMENT 10 CFR 76.89 "(a) The Corporation must maintain and operate a criticality monitoring and audible alarm system meeting the requirements of paragraph (b) of this section in all areas of the facility. The Corporation may describe for the approval of the Commission defm' ed areas to be excluded from the monitoring requirement. This submittal must describe the measures that will be used to ensure against criticality, including kinds and quantities of material that will be permitted and measures that will be used to control those kinds and quantities of material. (b) The system must detect and annunciate a criticality that produces an aFrorbed dose in soft tissue of 20 rads of combined neutron and gamma radiation at an unshielded 6istance of 2 meters from the reacting material within 1 minute. Coverage of all monitored areas must be provided by two detectors."
COMMITMENTS Source: Safety Analysis Report
- 5. Nuclear Safety Programs 5.2 Nuclear Criticality Safety i
5.2.2 Program Elements i
5.2.2.5 Criticality Accident Alarm System Coverage [Rev. 3, 5/31/96]
"The [ criticality accident alarm] system utilizes a distinctive audible signal to notify personnel in the affected area and initiates evacuation, thereby reducing personnel exposure to emitted radiation."
DESCRIPTION OF NONCOMPLIANCE There are areas in process buildings C ' 31, C-335, and C-337 where the criticality accident alarm system (CAAS) homs are not audible to personnel due to high ambient noise levels. A full sound survey of all buildings with CAAS horns is being conducted. The inaudibility does not affect the capability of the CAAS to detect a criticality accident.
JUSTIFICATION FOR CONTLNUED OPERATION The CAAS provides an automatic alarm to initiate the evacuation of areas potentially affected i
by a criticality accident. Although the CAAS cannot prevent a criticality accident, its alarm will reduce the exposure time of affected personnel.
The process buildings are also equipped with other evacuation alarm systems. The building howlers are used to initiate evacuations for events other than a criticality accident. A continuous blast on the building howlers is the " alert signal," which directs personnel to evacuate the building (V']
immediately and to listen to the plant public address system for further instructions. The operability of the howlers will be verified at least semiannually. The same evacuation routes are designated 1
PGDP Rev. 8.1/8/99
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Issue 46, Page 2 Criticality Accider.t Alarm System-Horn Audibility i
for the CAAS and building alert signals; in both situations the requirement is to evacuate the building by the nearest route.
Sound level surveys conducted with both the CAAS and building howlers sounding demonstrated that the building howler signals could be heard throughout the process buildings.
Thus, as a compensatory measure for the inaudible CAAS alarms, the building howlers will be sounded within approximately 10 seconds following actuation of any CAAS detection / alarm cluster. An auxiliary control room operator will activate the howlers by a switch in the control room. The applicable procedure has been changed to include this step.
Walkthroughs were conducted to measure the time necessary for an operator walking at a normal pace to reach the building howler switch from the most remote location in the control room. The time delay was less than 10 seconds for Buildings C-331, C-335, and C-337 under these conservative conditions.
The areas of Buildings C-331 and C-335 where the alarm cannot be heard are not areas with a potential for a criticality accident. The area of Building C-337 where a criticality accident could most conceivably occur has an additional local horn, which would sound and provide an audible warning. A criticality accident elsewhere in Building C-337 would be remote from the areas where the CAAS is inaudible. Thus, the 10-second time delay for a building howler actuation would not have a significant impact on evacuating the areas of the process buildings where the CAAS alanns cannot be heard.
Following a CAAS activation, procedures require that a public address announcement be made by personnel in Building C-300, Central Control Building. The announcement will inform all plant personnel of the need for a building evacuation due to a CAAS activation and will direct them to proceed to their ppropriate assembly point.
PLAN OF ACTION AND SCIEDULE Plant modifications will be initiated to ensure that the CAAS alarm horns are capable of being heard throughout the affected areas of the process buildings. The modifications will be l complete by January 18,2000.
O PGDP Rev. 8. !/8/99
Criticality Accident Alarm System-Horn Audibility Issue 46, Page 3
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SUnihiARY OF REQUIREnfENTS, CO3131IThfENTS, AND NONCO3fPLIANCES v.
Issue: Criticality Accide:ii Alarm System-Horn Audibility Code of Fadini Regulations Part Title 10 76.89(a)
Application Conunitment Section Safety Analysis Report 5.2.2.5 Technical Safety Requirements 2.1.4.5, 2.2.4.3, 2.3.4.7, 2.4.4.2, 2.6 Application Noncompliance Statement Section Safety Analysis Report 3.16.9
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,.i Issue 46, Page 4 Criticality Accident Alarm System-Horn Audibility i
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Irsue 50, Page 1 O
Criticality Accident Alarms for Nearby Buildings (new issue)
REQUIREMENT 10 CFR 76.89 "(a) The Corporation must maintain and operate a criticality monitoring and audible alarm system meeting the requirements of paragraph (b) of this section in all areas of the facility. The Corporation may describe for the approval of the Commission defined areas to be excluded from the monitoring requirement. This submittal must describe the measures that will be used to ensure against criticality, including kinds and quantities of material that will be permitted and measures that will be used to control those kinds and quantities of material. (b) The system must detect and annunciate a criticality that produces an absorbed dose in soft tissue of 20 rad:, of combined neutron and gamma radiation at an unshielded distance of 2 meters from the reacting material within 1 minute. Coverage of all monitored areas must be provided by two detectors."
COMhilTMENTS Source: Safety Analysis Repon
- 3. Facility and Process Description 3.12 Communications and Alarm Systems 3.12.6 Criticality Accident Alarm System [Rev. 3, 5/31/96]
OQ "A building which.. would be affected by a criticality occurring in an alarmed building is provided with alarms which are slaved to the alarmed building... Slaved buildings are buildings located within the 12 Rad radius from a CAAS [ criticality accident alarm system) alarmed building cr area and that are equipped with a plant air or nitrogen operated hom unit similar to the unit described above, or an electronic evacuation hom that produces a similar sourxi."
DESCRIPTION OF NONCOMPLIANCE The evacuation area around the CAAS clusters (" clustered" buildings) was determined based on a 12 rad exposure from a postulated criticality accident within these buildings. Several leased buildings that are located within the evacuation area do not have evacuation horns and lights activated by these clusters. Furthermore, the criticality alarm horns from adjacent alarmed buildings cannot be heard within most of these unalarmed buildings. Therefore, the requirements that a criticality accident be annunciated into all areas requiring evacuation is not met.
The following is a list of the unalarmed buildings within the evacuation area of clustered buildings as of June 19, 1996.
Manned Facilities:
C-331Q-T-01, Health Physics Office C-333-T-06, Health Physics Office C-333-T-07, Health Physics Office
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C-337-T-01, Health Physics Office PGDP Rev. 8.1/8/99
i Issue 50, Page 2 Criticality Accident Alarms for Nearby Buildings C-337-T-02, Health Physics Office C-360-T1, Health Physics Office C-400-T-01, Health Physics Office C-400-T-02 Health Physics Office C-410-K, Fluorine Building C-604, Utilities Maintenance Building C-720-N1, Office Trailer C-720-N2, Office Trailer C-720-01, Office Trailer C-727 Waste Accumulation Area C-746Q-T-01, Office Miscellaneous Trailers Post 47 Guard Station Unmanned Facilities:
C-310, Burp Station C-350, Drying Agent Building C-360-T2, Health Physics Office C-400-A, Emergency Power Building C-408, Truck Scale C-409-A, Storage Trailer C-409-B, Storage Trailer C-409-C, Storage Trailer C-409-D, Storage Trailer C-409-E, Storage Trailer C-410-D, Fluorine Storage Building C-605, Substation Building C-710-10, Boundary Control Station C-721 Gas Manifold C-729, Acetylene Building C-754, Low-Level Waste Storage Miscellaneous Portable Toilets Miscellaneous Semi-Trailers j
This list is subject to change as buildings are removed from or relocated into the evacuation area or reanalyses to redefine the evacuation area are performed. An up-to-date listing of leased, unalarmed facilities within evacuation areas of clustered buildings is maintained on-site.
Additional unalarmed facilities that may be relocated into the evacuation area after June 19, 1996, will be administratively controlled to comply with the compensatory actions described in the Justification for Continued Operations until the facility is modified to achieve compliance with alarms activated by the nearby CAAS or relocated to outside the evacuation area.
JUSTIFICATION FOR CONTINUED OPERATION As a comprsatory aaion, postings wdl be installed to identify each unalanned building within the evacuation area of an alarmed facility. Additionally, personnel entering those un*larmed PGDP Rev. 8.1/8/99
Ornicality Accident Alarms for Nearby Buildings Issue 50, Page 3 O.
buildings where the nearby criticality alarm horns cannot be adequately heard are required to have a radio capable of receiving emergency information and are required to monitor the radio continuously while inside. Prior to entry into these unalarmed buildings, personnel are required to verify that their radios are receiving transm ssions. For continuously manned unalarmed buildings, personnel are required to perform ttis check once a shift. In, ti,e event of an clarm sounding (e.g., due to a criticality acciden; or false alarm), a page delivered over all rad +
frequencies will provide notification to personnel in the affected buildings and facil.5 ate evacuation or other appropriate protective action (e.g., continued -heltering).
As descri%d in the Safety Analysis Repon, the probability of a criticality event is extremely low because of design safety features and administrative controls specified in nuchar criticality safety appros als for fissile-material facilities and activities. Additionally, because a majority of the unalarmed buildings are not continuously manned, the probability of a cri.icality event occurring at the time these buildings are occupied is very low. Notification of individuals in these buildings to evacuate or take other protective measures will further mitigate the risk associated
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with an unlikely c.riticality accident.
PLAN OF ACTION AND SCHEDULE Evacuation horns (for those unalarmed buildings where nearby CAAS horns cannot be adequately heard) and/or lights will be installed in the unalarmed buildings located within the evacuation area of CAAS-clustered buildings, or the unalarmed buildings will be removed from the evacuation area. These horns and/or lights will be activated from a nearby clustered building or other alarmed building. Unalarmed facilities that have been identified as of June 19,1996, will be modified with the required homs and/or lights, as appropriate, or relocated to locations outside of the evacuation area in accordance with the plan of action and schedule of the Compliance Plan l
issue entitled " Criticality Accident Alarm System - Horn Audibility."
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SUMMARY
OF REQUIREMENTS, COMMITMENTS, AND NONCOMPLIANCES lssue: Criticality Accident Alarms for Nearby Buildings Code of Federal Regulations Part Title 10 76.89(a) and (b)
Application Commitment Section Safety Analysis Report 3.12.6, 5.2.2.5 Technical Safety Requirements 2.6.4.1 Application Noncompliance Statement Section None I-PGDP Rev. 8,1/8/99
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