ML20209D343

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Revised Pages for SAR Update,Certificate Amend Request
ML20209D343
Person / Time
Site: Paducah Gaseous Diffusion Plant
Issue date: 06/30/1999
From:
UNITED STATES ENRICHMENT CORP. (USEC)
To:
Shared Package
ML20209D334 List:
References
NUDOCS 9907130112
Download: ML20209D343 (111)


Text

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SAFETY ANALYSIS REPORT UPDATE CERTIFICATE AMENDMENT REQUEST JUNE 30,1999 REVISION Reniove Pages Insert Pages SARUP Revision Log SARUP Revision Log i

i, ii SARUP List of Effective Pages SARUP List of Effective Pages SARUP-1 through SARUP-12 SARUP-1 through SARUP-12 SARUP Section 3.15 Table of Contents SARUP Section 3.15 Table of Contents 1

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SARUP Section 3.15 SARUP Section 3.15 3.15-2,3.15-14 through 3.15-22,3.15-25, 3.15-2,3.15-14 through 3.15-22,3.15-25, 3.15-27,3.15-56,3.15-57, Table 3.15-1 page 3.15-27, 3.15-27a, 3,15-56, 3.15-57, Table C

2, Table 3.15-2 pages 1,2,4,5,7,10,12,14, 3.15-1 page 2, Table 3.15-2 pages 1, la,2,4, and 16, Table 3.15-3 pages 1and 2 5,7,10,12,14, and 16, Table 3.15-3 pages 1, Ia,2, and 2a SARUP Section 4.3 SARUP Section 4.3 4.3-35 through 4.3-42,4.3-44 through 4.3-47, 4.3-35 through 4.3-42. 4.3-44 through 4.3-47, 4.3-49,4.3-51,4.3-54,4.3-55,4.3-56,4.3-57, 4.3-49,4.3-51,4.3-54,4.3-55,4.3-56,4.3-57, 4.3-63,4.3-64,4.3-65,4.3-67,4.3-68 4.3-63,4.3-64,4.3-65,4.3-67,4.3-68 i

SARUP TSRs SARUP TSR All Cover Page, x, 1.0-8,1.0-9, 2.4-3, 2.4-4, 2.4-7,2.4-8,2.4-9,2.4-12,2.4-15,2.4-16, 2.4-18,2.4-20a,2.4 20c,2.4-21,2.4-25, 2.4-27,2.4-28,2.4-30,2.4-32,2.4-34,2.4-35, 2.4-37, 2.4-39, 2.4-41, 2.4-41 a, 2.4-41 b, 2.4-42, 2.4-43, 2.4-44, 2.4-45, 2.4-45 a, 2.4-45 b, 2.5-3, 2.5-4, 2.5-5, 2.5-6, 2.6-5, 2.6-7, 3.0-6, 3.0-9 I

9907130112 990701 cT PDR ADOCK 07007001 iG B

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United States Enrichment Corporation Paducah Gaseous Diffusion Plant Safety Analysis Report Update REVISION LOG Dagg.

Description 8/18/97 Initial Issue. Included: changes to SAR Chapter 2 (changed pages only); new SARUP Sections 4.1, 4.2.1 through 4.2.5, 4.3.1, 4.4.

10/31/97 Submittal of completely SARUP (including 8/18/97 sections unchanged), with the exception of changes to Application SAR Chapter 3. Included: changes to SAR Chapters 1 and 2 and Sections 5.2, 5.4, and 5.6 (changed pages only); complete replacement of Section 3.15, Chapter 4, and the TSRs; new Section 5.2, Appendix A.

3/31/98 Submittal to remove the fixed fire suppression sprinider systems within the C-333-A, C-337-A, and C-360 facilities and the sanitary and fire water system (SFWS), including it's distribution and elevated storage tank as safety (AQ) systems. Sections revised inc!ude: Section 3.15.7.2, Table 3.15-2, Table 4.2-5, Table 4.2-11, Section 4.3.2.2.16, TSR Table of Contents. TSR 2.2.3.3, TSR 2.4.3.1.a, TSR 2.4.3.1.b, TSR 2.4.3.2.a, TSR 2.4.3.2.b, and TSR 2.6.3.2. SARUP List of Effective Pages added.

10/19/98 Submittal to define the codes and standards applied to the process building cranes.

Sections revised include: Chapter 1, Appendix A, Sections 3.15.6.2.2, 3.15.6.2.3, 3.15.9.2.2, 3.15.9.2.3 and TSRs 2.2.4.1, 2.3.4.2, 2.5.4.2, and 2.6.4.2.

11/6/98 Submittal to incorporate miscellaneous SARUP revisions. SARUP Sections affected are:

1.1 of Chapter 1 Appendix A, Chapter 2 Table of Contents, 2.1.2.4,3.15.3.3.3, 3.15.3.7.2.1, 3.15.4.5.3, 3.15.6.2.3, 3.15.7.7.3, 3.15.10.1.3.1, Table 3.15-1, Table 3.15-2, Table 3.15-8, Table 3.15-9, Table 3.15-10, Table 4.2-7, 4.3.2.2.15, j

4.3.2.2.16, 4.3.2.5.3, Table 4.3-11, Table 4.3-12, able 4.3-13, Table 4.314, l

Table. 4.3-15, Figure 4.3-38, Figure 4.3-39, Figure 4.340, Figure 4.3-41, Figure 4.3-42, Figure 4.3-43, Figure 4.3-44, TSR 2.1.3.6 Basis TSR 2.3.3.6 Basis, TSR SR 2.4.3.1.a-2, TSR 2.4.3.1 Basis, TSR 2.4.3.3 Title, TSR 2.4.3.3.b Applicability, and TSR 2.4.3.3 b Basis.

6/30/99 Submittal to incorporate the necessary changes for incorporation of the current USEC-01 TSRs and the associated changes to SARUP Section 3.15 and Chapter 4 for the cascade and balance of plant facilities. The following sections are affected: Section 3.15 Table of Contents, 3.15.1, 3.15.3.1, 3.15.3.1.1, 3.15.3.1.2, 3.15.3.1.3, 3.15.3.1.4, 3.15.3.1.5, 3.15.3.2, 3.15.3.2.1, 3.15.3.2.2, 3.15.3.2.3, 3.15.3.2.4, 3.15.3.3.3,,

3.15.3.3.4, 3.15.3.4.1, 3.15.3.4.3, 3.15.3.4.4, 3.15.3.6.3, 3.15.3.7.2.1, 3.15.3.7.2.5, 3.15.3.8.1, 3.15.3.8.2, 3.15.3.8.3, 3.15.7.2.1, 3.15.7.2.2, 3.15.7.2.3, 3.15.7.2.4, i

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Safety Analysis Report Update REVISION LOG (continuation) 3.15.7.2.5, Table 3.15-1, Table 3.15-2, Table 3.15-3, 4.3.2.1.1, 4.3.2.1.2, 4.3.2.1.3, 4.3.2.1.4, 4.3.2.1.5, 4.3.2.1.6, 4.3.2.1.7, 4.3.2.1.8. All SARUP TSRs are deleted by this change and replaced with the following "first set" of revised TSRs from USEC-01 Volume 4: TSR Table of Contents page x, TSR 1.6.2.2.g, TSR 2.4.2.1 Basis, TSR 2.4.2.2 Basis, TSR 2.4.3.1 Basis, TSR 2.4.3.2 Basis, TSR 2.4.3.3 Basis, TSR 2.4.3.4 Basis, TSR 2.4.4.1 Basis, TSR 2.4.4.2 Basis, TSR 2.4.4.3 Basis, TSR 2.4.4.4 Basis, TSR 2.4.4.5 Basis, TSR 2.4.4.6 Basis, TSR 2.4.4.7 Basis, TSR 2.4.4.8 Basis, TSR 2.4.4.9 Basis, TSR 2.4.4.11 Basis, TSR 2.4.4.12 Limiting Condition for Operation (LCO), Actions Surveillance Requirements (SR), and Basis, TSR 2.4.4.13 LCO, Actions, and Basis, TSR 2.4.4.14 Basis, TSR 2.4.4.15 (all new), TSR 2.5.4.1 Basis, TSR 2.5.4.2 Basis, TSR 2.5.4.3 Basis, TSR 2.5.4.4 Basis, TSR 2.6.4.1 Basis, TSR 3.9.1.b, and TSR 3.10.4.b.

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SARUP-PGDP June 30,1999 SARUP LIST OF EFFECTIVE PAGES SARUP Pane RAC/Date/ Revision SARUP Pane RAC/Date/Re51sion Technical Safety Reauirements 2.5-3 99C028 (RO) 2.5-4 99C028 (RO)

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SAR-PGDP PROPOSED f3 RAC 97C238 (RI), 99C028 (RO) -

June 30,1999

.V SECTION 3.15 TABLE OF CONTENTS 3.15 SAFETY SYSTEM CLASSIFICATION................................

1 3.15.1 Introduction

.................................................1 3.15.2 UF Feed Facilities............................................. 2 3.15.2.1 Autoclave High Pressure Isolation Remote Feed Isolation................................ 2 3.15.2.2

........ 5 3.15.2.3 Autoclave Primary Containment System...................... 6 3.15.2.4 UF Primary System.....................

6

............9 3.15.2.5 Autoclave Water Inventory Control System..................

10 3.15.2.6 High Cylinder Pressure System..........................

11 3.15.2.7 Autoclave Steam Pressure Control System

...................13 3.15.3 Enrichment Facilities...........................................

14 l

3.15.3.1 UF Compressor Motor Manual Trip Systems.................

14 3.15.3.2 DC Power Distribution System..........................

18 I

3.15.3.3 UF. Primary System...

.............................19 3.15.3.4 High-Pressure Relief Syster.u...........................

21 h'

3.15.3.5 Freezer /Sublimers High-Hig'1 Weight Trip System..............

23 3.15.3.6 Motor Load Indicators................................

24 1

3.15.3.7 Datum Systems....................................

26 I

l 3.15.3.8 Freezer /Sublimers R-114 High-Pressure Relief System............

27 3.15.4 Withdrawal Facilities...........................................

27 3.15.4.1 Withdrawal Station Isolation System.......................

27 3.15.4.2 Compressor Motor Manual Trip System.....................

30 3.15.4.3 DC Power Distribution System

..........................31 3.15.4.4 Motor Load Indicators................................

31 3.15.4.5 UF. Primary System.................................

19 3.15.4.6 High-Pressure Relief Systems...........................32 3.15.4.7 Normetex Pump High Discharge Pressure Shutdown System........

33 3.15.4.8 Normetex Pump UF6 Release Shutdown System...............

34 3.15.5 Toll Transfer and Sampling Facility 3.15.5.1 Autoclave High Pressure Isolation

........................35 3.15.5.2 UF6 Release Detection System - Zone I and Zone 4.............

39 3.15.5.3 Autoclave Primary Containment System.....................

41 3.15.5.4 UF. Primary System.....................

...........43 3.15.5.5 Autoclave Water Inventory Control System..................

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. SAR PGDP PROPOSED June 30,1999 RAC 97C238 (RI), 99C028 (RO) functional requirements are developed based on this level of detail to include trip systems associated with "00" and "000" cell compressor motors, compressor motors in the purge cascade, and interbuilding booster compressor motors. The system evaluation and system classification subsections further delineate the essential portions of the system required to meet the safety functions and functional requirements to include a justification for any exceptions. The boundaries of Q, AQ, and AQ-NCS SSCs are provided in Tables 3.15-1, 3.15-2, and 3.15-3, respectively. Support system boundaries are included in the boundaries of the supported SSCs if loss of the support system does not result in the supported SSC

' falling in a safe manner.

3.15.2 UF. Feed Facilities 3.15.2.1 Autoclave High Pressure Isolation System L

3.15.2.1.1 Safety Function The autoclave high pressure isolation system is designed to contain a release of UF. inside the autoclave. The system detects high autoclave pressure and isolates all active isolation valves to ensure that the following safety objectives are accomplished:

The UF primary system temperature for the UF cylinder being heated inside an autoclave is 6

maintained below the temperature that assures an ullage inside the cylinder is maintained.

The release of UF. and its reaction products to the atmosphere from a UF primary system

.h failure inside an autoclave is maintained below the amount that would result in exceeding either 6

the radiological or nonradiological off-site exposure EGs for the EBE category.

3.15.2.1.2 Functional Reanimat<

The autoclave high pressure isolation system shall be designed in accordance with the following functional requirements to ensure the capability to accomplish the required safety functions:

The' system shall be capable of accomplishing the required safety function independent of plant / instrument air supply to the facility.

The system shall be capable of accomplishing the required safety function independent of the normal AC power supply to the facility.

The system shall be capable of having two detectors to sense autoclave high pressure.

Isolation of the autoclave active valves shall be accomplished within 15 seconds from autoclave pressure exceeding the required actuation pressure for the system.

3.15.2.1.3 System Evah=+1on The autoclave high pressure isolation system was evaluated to assess its ability to accomplish its required safety functions. Two separate calculations were performed to analyze transient conditions involving specific limiting events associated with the safety functions. In addition, a fault tree analysis was performed to determme the system's ability to accomplish the safety functions. The results of these evaluations are provided in this section.

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SAR-PGDP PROPOSED June 30,1999 RAC 97C238 (RI), 99C028 (RO)

Once an initiating event occurs, the autoclave steam pressure control system provides no safety function to mitigate the events.

Therefore, this system's safety function, preserving the initial temperature conditions of the analysis, meets the criteria for classification as an AQ system.

This system is also identified as an NCS AEF (see Section 3.15.10.5.3). Therefore, the autoclave steam pressure control system is classified as an AQ-NCS system.

3.15.2.7.5 Boundary The AQ-NCS boundaries for the autoclave steam pressure control system are defined in Table 3.15-3.

3.15.3 Enrichment Facilities l 3.15.3.1 UF. Compressor Motor Manual Trip Systems The UF, compressor motor manual trip systems consist of the cell remote manual shutdown systems for the enrichment and purge cascades, and the trip systems for the interbuilding booster and purge and evacuation (P&E) compressor motors. The DC power distribution system is discussed in Section 3.15.3.2.

3.15.3.1.1 Safety Function Oi

. The compressor motor manual trip systems shall shut down all applicable motors connected to the trip circuit to-Reduce the operating pressure / temperature to minimize the potential for UF primary system 6

integrity failure and Reduce the operating pressure to minimize the release of UF. and its reaction products to the atmosphere after a failure in the UF primary system integrity.

3.15.3.1.2 Functional Reauirements l

The compressor motor manual trip systems shall be capable of:

Tripping the cell and booster compressor motors in the enrichment and purge cascades from the a

area control room (ACR) and Tripping the cell and interbuilding booster compressor motors in the enrichment cascade from the central control facility (CCF).

3.15.3.1.3 System Evaluation The compressor motor manual trip systems were evaluated to assess their ability to accomplish their required safety function. In addition, a fault tree analysis was performed to determine system capabilities to accomplish their safety functions. The results of these evaluations are provided in this Section.

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RAC 97C238 (RI), 99C028 (RO) l The compressor motor manual trip system are made up of various circuits associated with the

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ed.ini.ent cascade, purge cascade, interbuilding booster, and P&E booster compressor motors. Some of the systems shut down individual compressors (~i.e., interbuilding boosters and P&E boosters) and i

others shut down all compressors within a cell (i.e., the cell remote manual shutdown system for the enrichment and purge==la). The remote switch will initiate a trip signal to the trip coil of the circuit breaker (air or electrical) inside the switchgear. The trip coil will then energize via the switchgear DC control power supply and trip the associated breaker which disconnects motive power to the associated compressors, q

Safety function analysis. The hazards and accident analysis took credit for tripping operating compressors for several different transients to reduce UF primary system pressure and temperature to minimize the potential for a loss of UF. primary system integrity. In addition, tripping operating compressors was also assumed to occur for several UF release events to reduce UF. primary system pressure and minimize releases from the operating equipment. Tripping the compressors (cell or booster compressor motors) will accomplish all of these safety functions. Compressor operation provides the main source of pressurization for the UF primary system. In addition, the heat of compression is the primary source of heat input for the UF. primary system. Therefore, by tripping the compressors associated with operating equipment, both UF prunary system pressure and the need for UF. primary system cooling are significantly reduced to accomplish the required safety function. Tripping of the compressors is the only requirement needed to bring a cell or interbuilding booster below atmospheric pressure. When cell motors are stopped, the cell pressure decreases rapidly (i.e., within seconds based on operational history) due to pressure equalization between the A-line and B-line. Repressurization of the cell is inhibited by

.O ia rie-r i ta ce er ta co-gr er a eta r a ir-t itui the ceii. ^ tria er ta co-er >er-eliminates the heat input into the system generated by the compression process. The time response associated with these events could range from several seconds up to several minutes depending on the initial operating conditions of the cell (e.g., above or below atmospheric pressure) and the severity of the operational transient (e.g., B-line block valve closure, loss of recirculating cooling water [RCW]).

In case of an canhquake, all of the compressor motors in the process buildings can be manually tripped from the switchyard. An evaluation basis earthquake,will typically cause a loss of power which will stop the compressors. If the power is still available, the switchyard will still be functional, and the switchgear should still be capable of tripping the power to the process buildings and the compressor motors. Assuming that the compressors can be tripped from the switchyard eliminates the need for DC control power following an evaluation basis earthquake to trip the compressor motors (see Section 3.15.3.2).

The functional requirements associated with this system are addressed below in the qualitative fault tree analysis. Based on the analysis above, the system can accomplish the required safety functions.

Qualitative fault tree analysis. In addition to the safety function analysis, a qualitative fault tree analysis of the compressor motor manual trip system was performed in accordance with Section 4.3.1.1.3.

l The functional requirements for these systems are to have the ability to trip compressors from (1) the associated ACR for all of the equipment and (2) the CCF for the cell and interbuilding booster 3.15-15

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.V compressors within the enrichment cascade. The fault tree analysis indicates that all of the cell compressor motors, the P&E booster compressor motors, and some of the interbuilding booster compressor motors l can be tripped from the ACR (except for the compressors in C-310) and the CCF. Some of the interbuilding booster compressor motors can be tripped from the CCF but not the ACR. Therefore, with the exception of the compressors in C-310 and some of the interbuilding booster compressors, the l functional requirements for these systems are met. The amount of UF. material at risk in the purge cascade and the portion of the enrichment cascade in C-310 is small. The threshold analyses indicate that a UF. release for 30 min from a failure of the discharge piping of the Normetex withdrawal pumps in the product withdrawal facility in C-310 will not exceed 10 mg U intake at the site boundary. A UF.

release from the cascade processes in C-310 would be much smaller because these cells operate below atmospheric pressure. The exposure of workers within the building from these small releases will be minimized by evacuation. In addition, compressor motors in C-310 can be stopped by tripping the C-310 cells at the cell panels, and process gas flow to and from C-310 may be stopped by splitting the cascade between C-335 and C-310. Thus, it is not essential to trip the compressors in C-310 from the ACR l or CCF. Additional trip capabilities for all of the compressor motors are also provided at the applicable switchgear; however, these additional locations are not required to accomplish the safety function.

The interbuilding boosters are part of the enrichment process and are typically fed from an operating cell and then discharged to another operating cell. Therefore, for the purpose of accomplishing a reduction of UF. primary system pressure, tripping of cells upstream and downstream of the l

interbuilding booster compressors from the ACR can accomplish the required safety function for those

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interbuilding boosters that do not have trip capability in the ACR. In addition, if necessary, tripping of O

the boosters can be accomplished from the CCF. Additional trip capabilities are also provided at the local V

cell panel (LCP) and the applicable switchgear, if necessary, to accomplish the safety function in emergency situations. However, these additional locations are not required to accomplish the safety function.

In addition, there are several locations available to trip a cell or booster station including feeder breakers upstream of the cell or booster station feeder breakers. If a cell or booster station breaker failed to trip, the probability of the failure of the next breaker in series becomes multiplicative. Thus the probability is reduced to a low value. In addition, the probability of the failure occurring at the same time and in the same area where the UF release occurs is multiplicative. If a cell or booster station cannot be tripped, the compressor motors in the cells upstream and downstream can be tripped, which will also reduce the pressure in the area of concern.

The air circuit breakers have individual air reservoirs to provide the pneumatic force needed to open the breaker if the normal air supply provided by the compressed air stations for the switchgear is lost. If air is lost in an air reservoir for one of the air circuit breakers, other circuit breakers in that feed path may be tripped.

One specific area of concern associated with this system that could impact the system's ability to accomplish its required function is the location of some of the circuits in the tunnels from the process buildings to the CCF. These areas have the potential for some localized flooding during large storms. The electrical circuits associated with the compressor trip circuit are the control circuits that are 250 VDC and lower and the power circuits that are 2.4 kV and higher. The motive power circuits are typically routed O

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SAR-PGDP PROPOSED June 30,1999 1

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from the operating floor up to the compressors, with the exception being those fed directly from the switchyard. The switchyard power circuits are routed either underground or in overhead dedicated banks of electrical cable trays. The only cables that could be affected by localized flooding during large storms would be those routed underground. The most likely failure mode for motive power cables routed underground would be either an open circuit or a short to ground. Either case would result in tripping of the associated load, which would accomplish the required safety function. Hot shorts, associated with these cables, which are caused by water intrusion, would be unlikely due to the grounding effects of water. This is not considered credible. Spurious operation of the control trip circuits would accomplish the required safety function and is not addressed funher. An open circuit in the control cables could result in the inability to accomplish the required safety function from the ACR or CCF. However, the likelihood of several simultaneous failures (required to prevent accomplishing the required safety function) is unlikely and is not considered credible. Single circuit failures are considered credible based on past operational history. If the capability to trip one or more compressors is lost (e.g., due to a loss of DC control power), the capability to trip cells upstream and downstream of the affected areas or to trip the affected cells from an alternate location is still available to reduce overall pressure. In addition, the capability is also provided to accomplish one trip of the compressors at the applicable switchgear via a push button without the aid of DC control power or the trip circuit. If necessary, these actions could be taken to accomplish the required function. Local trip capability of switchgear is provided independent of the functional requirements on all switchgear.

Based on the diversity of the capability to trip operating compressors via various breakers, and l the low probability of failure, the compressor motor manual trip systems have the capability to meet the O

functional requirements, v

3.15.3.1.4 System Classification Trip capability from the ACR associated with the "00" and "000" enrichment cells in C-331, C-333, C-335, and C-337 is required to prevent or mitigate UF primary system failure accidents to maintain site boundary consequences within EGs. Therefore, the cell remote manual shutdown system is classified as Q.

Failures associated with the interbuilding booster and P&E booster compressors can be mitigated by tripping adjacent enrichment cell compressor motors. Therefore, the trip systems associated with the interbuilding boosters and P&E boosters are classified as NS, and the cell remote manual shutdown system in the ACR for the associated adjacent enrichment cell compressor motors are classified as Q.

Due to the low UF. pressures and mass flow rates in Building C-310, and personnel evacuation

)

action in the event of a UF. primary sysum failure, trip capability for the C-310 compressors is not essential. Although the trip capability for the C-310 compressors does not meet the Q or AQ classification criteria specified in Section 4.2.2, the LCP trip for C-310 compressors is conservatively classified as AQ.

The cell remote manual shutdown system in the CCF associated with the enrichment cells in C-331, C-333, C-335, and C-337 is required during a facility evacuation to maintain initial conditions.

Therefore, this system is classified as AQ.

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SAR-PGDP PROPOSED June 30,1999 RAC 97C238 (R1),99C028 (RO) 3.15.3.1.5 Boundary l

The Q and AQ boundaries of the cell remote manual shutdown system are defined in Tables 3.151 and 3.15-2, respectively.

3.15.3.2 DC Power Distribution System The DC power distribution system consists of the 250-VDC and 125-VDC distribution systems that are required to support the compressor motor manual trip systems described in Section 3.15.3.1.

250-VDC power is required to trip compressors motors from the LCPs, ACRs, and the CCF, and 125-VDC power is only required to trip compressor motors from the CCF.

3.15.3.2.1 Safety Function The DC power distribution system shall provide the support control power required by the l compressor motor manual trip systems to perform their safety function.

3.15.3.2.2 Functional Reauirements The DC power distribution system shall have the capability to operate the compressor motor l manual trip systems following a loss of AC power.

3.15.3.2.3 System Evaluation The safety function required of the DC control power system is to provide the support control l power required by the compressor motor manual trip systems to perform their safety function. The DC 6

power distribution system consists of standard industrial batteries, controls, and distribution circuits that supply 250-V and 125-VDC power to operate the compressor motor circuit breakers from the remote locations. Cell tripping is classified as a momentary load per IEEE Standard 485-1983 (Reference 3.15-1), and as such, it represents a small instantaneous ampere-hour load on the total battery banks Based on this, the batteries can provide sufficient DC power upon the loss of the normal AC power supply to perform a momentary trip of the compressor motors. If the DC control power systems are lost, other breakers upstream of the cell feeder breakers can be used to trip the compressor motors. For some equipment (e.g., "00" compressors), the upstream feeder breakers are served by separate DC control power systems in the switch houses that would be available if the DC control power system in the process building should fail. For other equipment (e.g., "000" compressors), the motor circuit breakers are located in the switchyard, and these use the DC control power systems in the switch houses. In all cases, the circuit breakers can be tripped manually at the switchgear if the DC control power system in the switch house should fail. The system is not required to withstand the effects of natural phenomena hazards (see Section 3.15.3.1.3). Environmental conditions for this equipment would be similar to the compressor l motor manual trip systems since they are also located on the ground floor, in the switchyard, or in the CCF. Based on the analysis above, the system can accomplish the required safety function and meet the functional requirement.

l s

3.15-18

1

. SAR PGDP.

PROPOSED June 30,1999

)

RAC 97C238 (RI), 98C068 (RI), 99C028 (RO) 3.15.3.2.4 System Classification i

The 250-VDC power distribution system is required for the operation of the Q and AQ compressor motor manual trip systems (see Section 3.15.3.1). Consequently, it is are classified as Q.

The 125-VDC power distribution system is only required for operation of the AQ compressor motor manual trip system. Therefore, it is classified as AQ.

3.15.3.2.5 Boundary l

The Q and AQ boundaries of the DC power system are defined in Tables 3.15-1 and 3.15-2, respectively.

3.15.3.3 UF. Primary System The UF, primary system is the UF. containment barrier in the enrichment cascade and associated equipment. The UF, primary system includes the enrichment cascade equipment, cascade auxiliary equipment, purge cascade equipment, freezer / sublimer (F/S) UF. process equipment, and UF./ coolant separation process equipment.

i 3.15.3.3.1 Safety Function The UF. primary system shall provide primary system integrity for the processes that contain O

gaseous UF. in the enrichment and purge cascade facilities to prevent the release of UF during normal operation, and to prevent gross failures during evaluation basis natural phenomena events.

3.15.3.3.2 Functional Requirements The UF. primary systems in the cascade facilities shall be designed to maintain primary system integrity during normal operating temperatures / pressures and to prevent gross failure following evaluation basis natural phenomena events.

3.15.3.3.3 System Evaluation The UF. primary system for the enrichment cascade handles gaseous UF. from the feed points l to the withdrawal points. The converters, vessels, piping, coolers, compressors, valve bodies, etc.,

provide the UF. primary system integrity for the enrichment cascade process. The enrichment cascade also includes the cascade auxiliary equipment connected to the cascade to provide support for cascade operations. This equipment includes booster systems, surge drums, piping, valves, seal systems, seal exhaust systems, wet air evacuation systems, etc., that handle gaseous UF. and that provide the UF.

primary system integrity for these processes. The purge cascade uses the same type of equipment as does the enrichment cascade. It extends from the withdrawal points to the vents where purged light gases are released to the atmosphere. The UF. primary systems also include the F/S and UF / coolant separation system.

O 3.15-19

SAR PGDP PROPOSED June 30,1999

~

RAC 97C238 (R1), 98C068 (R1), 99C028 (RO)

L The UF. primary system is required to provide integrity for the cascades and the supporting l

processes that handle UF.. This safety function is accomplished by retaining UF. primary system integrity during normal operating temperatures / pressures.

l The UF. primary system in the enrichment cascade which is intended to operate above atmospheric pressure is also required to maintain UF. primary system integrity during evaluation basis l

natural phenomena events. The effects of evaluation basis natural phenomena events on the UF. primary system of the enrichment cascade in C-310, C-331, C-333, C-335, C-337, and the tie lines were evaluated. The results indicate that the UF. primary system integrity is maintained in evaluation basis high wind and flood events. As indicated in the flood and high wind event scenarios in Section 4.3.2.5.1 and 4.3.2.5.2, the UF. primary system will not have any significant UF. release during these evaluation basis events. Some of the equipment and piping in the cascade facilities does not meet the performance criteria for the 250-yr return evaluation basis earthquake (EBE) (see Section 4.3.2.5.3). Tables 3.15-4 through 3.15 9 list the equipment, piping, and components with high-confidence-tow-probability-of failure (HCLPF) capacities less than the EBE for buildings C-310, C-315, C-331, C-333, C-335, and C-337.

For each item, the seismic capacity, annual probability of failure, location, and comments are provided.

' The capacities reported in the tables are the capacities of the weakest member (s) whose failure could potentially cause a UF. release in the process gas systems. These items were evaluated further using finite element analysis and empirical test data to determine if a loss of pressure boundary was likely and to estimate the hole size that would result, if the pressure boundary was breached. In some cases, this l funher analysis indicated that although some deformation could be experienced, the deformation would l not be sufficient to affect the pressure boundary. Equipment, piping, and components with capacities less Q

than the evaluation basis canhquake but that still maintain pressure boundary integrity are noted in the tables with an asterisk (*). In addition, potential seismic interactions of the cell housings and the stage compressors were evaluated. Failure of the cell housings did not adversely impact a UF. pressure i

boundary.

The analysis of the earthquake event in Section 4.3.2.5.3 assumed failure of the remaining components listed in the tables (i.e., those without an asterisk). The portions of the enrichment cascade operating above atmospheric pressure may release some UF., while the portions operating at subatmospheric pressure will result in inleakage with a negligible loss of UF. The most significant failures associated with this event are failures at the booster stations that supply the tie line between the l "000" and "00" buildings. These failures were evaluated in the earthquake event scenario in Section 4.3.2.5.3, and the potential consequences were assessed. With the exception of the failures identified and evaluated, the portions of the enrichment cascade that are intended to operate above atmospheric pressure will accomplish the safety function of not having gross failures of the UF. primary system integrity in evaluation basis natural phenomena events. For the portions of the enrichment cascade l that are operated only at subatmospheric pressure, the purge cascade, and the Hortonspheres, the capacity to retam their UF. primary system integrity is not required in evaluation basis natural phenomena events.

This is based on the subatmospheric pressure and minimal releases should the UF. primary system fail.

Based on these evaluations, the UF. primary system can accomplish the required safety functions with the exceptions noted.

3.15-20

SAR-PGDP PROPOSED June 30,1999 RAC 97C238 (R1), 99C028 (RO)

'.O 3.15.3.3.4 System Classification The essential functions of the UF. primary system are to (1) maintain UF. primary system integrity during normal operating temperatures and pressures, and (2) prevent failures in the above atmospheric portions of the enrichment cascade beyond those assumed in the evaluation basis earthquake analysis. The system provides no additional protection once a release occurs. The UF. primary system is classified as AQ in accordance with the criteria in Section 4.2.2. This classification applies to process piping 2 inches and larger, expansion joints, valves. and process equipment that provide the UF.

l containment pressure boundary. Process piping less than 2 inches is classified as NS.

l 3.15.3.3.5 Boundary The AQ boundaries for the UF. primary system for the enrichment processes are defined in Table 3.15-2.

3.15.3.4 High-Pressure Relief Systems -

3.15.3.4.1 Safety Function l

The R-114 coolant overpressure control system in the enrichment cascade and in the purge cascade, the compression loop coolant high-pressure relief systems in the withdrawal process, and the UF.

high-pressure relief system in the F/S and UF / coolant separation processes provide pressure relief to prevent overpressurizing the interfacing UF. primary system. The potential for a release of UF from an overpressure failure of the UF. primary system is minimized. This minimizes the potential for the exposure of on-site personnel.

3.15.3.4.2 Functional Reauirements Each system shall be designed in accordance with the following functional requirements to ensure the capability to accomplish the required safety functions:

Each relief system shall provide pressure relief for the primary UF. system or the coolant system l

to minimize the potential for the failure of the UF. primary system integrity of these systems.

Each relief device shall be rated at or below the design pressure rating of the equipment they are i

protecting.

Each relief system shall be capable of providing overpressure protection without control signals, AC, or DC power.

3.15.3.4.3 System Evaluation The R-114 coolant overpressure control system for each cell coolant system consists of a manual block valve, one or two rupture disks, associated piping, and diffuser (if applicable). All of the rupture disk assemblies are separated from the coolant system by the manual block valve that must be sealed in the open position when the coolant system is in operation.

f The F/S UF. high-pressure relief system for each F/S system consists of a rupture disk, a block valve, and associated piping that provides a relief path to the A-line of the cascade.

3.15-21 i

SAR-PGDP PROPOSED June 30,1999 p

RAC 97C238 (RI), 99C028 (RO)

, %.)

The UF / coolant separation UF high-pressure relief system consists of a cold trap rupture disk, 6

6 three sodium fluoride (NaF) trap rupture disks. block valves, and associated piping that provides a relief path to holding drums.

The compression-loop coolant overpressure relief system at the withdrawal facilities consists of a rupture disk on the condenser shell that relieves on high coolant pressure.

No support systems are needed for the relief systems to perform their safety functions.

l The R-ll4 coolant overpressure control system in the enrichment cascade and the purge cascade prevents excess coolant pressure from rupturing the coolant system and releasing coolant into the UF 6

primary system that could result in the subsequent loss of UF due to overpressurization of the UF 6

i 6

system. The coolant system pressure may increase following an event that results in a loss of cooling, such as a loss of RCW to the coolant system. The rupture disk, are rated at or below the MAWP of the system being protected. This rating (with its allowable tolerances) will minimize the potential for the faliure of the coolant system primary integrity. The accident analysis identified rupture of the coolant system into an off-stream cell as the only credible means for the event to progress to a failure of the UF6 system integrity. In this condition, the amount of UF is limited, and there is no potential for exceeding 6

any of the off-site EGs.

The F/S UF high-pressure relief system and the UF / coolant separation high-pressure UF relief j

6 6

6 system prevent overpressurization of the UF primary system for (1) a releass of coolant into the F/S 6

vessel or cold trap vessel or (2) overheating. These events can only threaten the integrity of the UF6 system when the F/S or UF / coolant separation systems are isolated from the cascade. These systems 6

prevent the pressure from exceeding the capabilities of the UF primary system. When the F/S or 6

UF / coolant separation systems are isolated, the systems are operating at subatmospheric pressure which 6

would minimize the mass of UF released. Thus, there is no potential for exceeding any of the off-site 6

EGs.

The compression-loop coolant overpressure relief system at the withdrawal facilities was evaluated to assess its ability to accomplish its required safety function. The safety function is to minimize the potential for failure of the UF primary system by relieving high coolant pressure before the UF primary 6

6 system integrity is threatened. To minimize the potential for failure in the coolant system and a potential UF release through the coolant system, the system is designed to relieve at or below the MAWP of the 6

coolant system.

The relief systems do not require control signals or AC or DC power to perform their functions.

Based on the analysis above, the systems can accomplish the required safety functions and functional requirements.

3.15.3.4.4 System Classification The high-pressure relief systems are used to minimize the potential overpressurization of the l primary UF or the coolant system. This prevents the potential loss of UF primary system integrity and 6

6 minimizes the potential exposure of on-site personnel to UF. Because the system operates to prevent 6

Q V

3.15-22

SAR-PGDP PROPOSED June 30,1999 7q RAC 97C238 (RI), 99C028 (RO)

,V The cell and interbuilding booster compressor motors in the enrichment and purge cascades in the ACR, l

The cell compressor motors (enrichment cascade only) in the CCF, and;

{

The C-315 high-speed compressor motor in the ACR and C-331.

3.15.3.6.3 System Evaluation The primary function of the motor load indicators is to provide an indication of abnormal compressor operation that could lead to failure. Using ammeter indications in the ACR for the individual compressor motors, operators can quickly identify various malfunctions of process equipment. Any inexplicable change in normal amp load is quickly investigated by the operators. Compressor load changes can be caused by such events as compressor failures, inadvertent B-stream block valve closure (see Section 4.3.2.1.3), stage control valve closure (see Section 4.3.2.1.2), or failures of the UF. primary system pressure boundary that cause inleakage or a release of UF. Compressor surging will produce 6

large swings in the motor loads. The load swing 3 caused by compressor surging are large enough to be seen even during plant load changes. These early indications alert the operator that one of these events may be occurring and minimize the response -

to take mitigative actions. If an ammeter should malfunction, the load changes can be seen on the.

neters for the compressor motors in stages adjacent to the stage that is experiencing the compressor surging.

Monitoring of the C-310 compressors is not considered essential. The amount of UF material 6

at risk in the purge cascade and the portion of the enrichment cascade in C-310 is very small. The O"

threshold analyses indicate that a UF release for 30 min from a failure of the discharge piping of the Nonnetex withdrawal pumps in the product withdrawal facility in C-310 will not exceed 10 mg U intake l at the site boundary (see Section 4.3.2.2.12). A UF. release from the cascade processes in C-310 would be much smaller because these cells operate below atmospheric pressure. The exposure of workers within te building from these releases will be minimized by evacuation.

Motor load indicators are provided in the ACR for interbuilding booster compressors, however they are not considered essential. Motor load indicators associated with the adjacent enrichment cell compressor motors will provide adequate indication of a booster compressor abnormality that could lead to an analyzed UF. release.

In scenarios involving evacuation of the process buildings, the motor load indicators in the CCF and the C-331 ACR are used to monitor the compressors for the enrichment cascade and the C-315 withdrawal compressors, respectively, and inform the operator to trip their motors if there is an indication oflarge load changes that could be representative of a pressure increase after the evacuation. The motor load indicators in the CCF monitor the total cell load for all of the compressors in a cell rather than for each individual stage. Although the motor load indicators in the CCF will be less sensitive than those in the ACR, they will be able to indicate significant compressor load changes.

Based on this evaluation, the system can accomplish the required safety function and functional requirements.

pd 3.15-25

SAR-PGDP PROPOSED June 30,1999 RAC 97C238 (RI). 98C102 (RO), 99C028 (RO) 3.15.3.7.2 High Pressure Datum System 3.15.3.7.2.1 Safetv Function l

The high pressure datum system provides precise control of cascade pressure and provides the pressure information necessary to calculate the inventory of the cascade when necessary.

3.15.3.7.2.2 Functional Reauirements See Sections 3.3.3.2 and 3.3.5.9, and the Fundamental Nuclear Materials Control Plan.

3.15.3.7.2.3 System Evaluation 1

The high pressure datum system consists of three parts which provide the same function. The part of the datum system to be used is determined by the valving at the cell panel. The high side cell datum pressure indicators are at the cell panel for each individual celi. The unit high datum system has i

analog gages in the datum room and is not used if the freezer / sublimer datum system is operatiotal. The freezer / sublimer high datum system pressure indicators are read at the freezer / sublimer datum panels.

3.15.3.7.2.4 System Classification This system is classified as AQ.

O 3 15 3 7.2.5 Beunda,v l

The AQ boundaries for the high datum pressure system are defined in Table 3.15-2.

3.15.3.8 Freezer /Sub1hners R-114 High-Pressure Relief System

'I 3.15.3.8.1 Safety Function The freezer /sublimers R-114 high-pressure relief system in the F/S process provide pressure relief to prevent overpressurizing the interfacing UF6 primary system. This system is included in the Section since the TSRs require that the associated manual block valve be sealed open, except for maintenance, to assure the rupture disks are exposed to system pressure.

3.15.3.8.2 System Classification Although the,tm.er/sublimers R-114 high-pressure relief system does not meet the Q or AQ classification criteria specified in Section 4.2.2, the freezer /sublimers R-114 high-pressure relief system

~

is conservatively classified as AQ.

3.15.3.8.3 Boundary The AQ boundaries of the freezer /sublimers R-114 high-pressur. relief system are defined in Table 3.15-2.

OV 3.15-27

)

er SAR-PGDP PROPOSED June 30,1999 h

RAC 97C238 (RI), 99C028 (RO)

~

3.15.4 Withdrawal Facilities 3.15.4.1 Withdrawal Station Isolation System 3.15.4.1.1 Safety Function The withdrawal station isolation system shall be capable of isolating the withdrawal station to prevent exceeding the radiological /nonradiological EGs for the EBE category.

3.15.4.1.2 Functional Reauirements The withdrawal station isolation system includes (1) automatic UF detection and isolation and 6

(2) manual isolatbn. The system shall be designed in accordance with the following functional requirements to ensure the capability to accomplish the required safety functions:

The system shall be capable of accomplishing the required safety function independent of the plant air supply.

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V 3.15-27a L

3

1 SAR-PGDP PROPOSED June 30,1999 p

RAC 97C238 (R2), 99C028 (RO)

.O l*

Provides fire suppression for the withdrawal facilities in areas associated with handling liquid UF.

to minimize the likelihood of a fire large enough to cause a breach in the UF. primary system.

3.15.7.2.2 Functional Reauirements The fire protection system accomplishes the required safety functions by satisfying the following functional requirements:

Provide an average discharge density in excess of the required sprinkler discharge density for the cell floor and operating floor sprinkler systems in Buildings C-331, C-333, C-335, C-337, C-310, and C-315; Deliver the required discharge density to only one floor of a single building at a time; Deliver the required discharge density independent of pump operability for up to 30 min; Automatically initiates from a fire in any of the required buildings; and l*

Provide automatic fire suppression capability to C-310-A to minimize the likelihood of large fires.

3.15.7.2.3 System Evaluation Automatic sprinider systems. An unmitigated lube oil fire in Buildings C-310, C-331, C-333, I

l C-335, C-337, and C-315 could lead to significant consequences for on-site personnel. Based on the credible fire scenarios and an analysis of unmitigated fire effects, operator action cannot be solely relied upon to prevent or mitigate large fires. Therefore, the automatic sprinkler systems protecting these buildings are required. The water used by the sprinkler systems is supplied by the high pressure fire

~

water system (HPFWS).

This system has a gridded distribution piping network, several fire water pumps, and an elevated storage tanks.

A hydraulic effectiveness study was performed for the existing sprinkler systems of the cell floors in the C-331 and the C-333 type buildings, and the operating floor in C-331. The calculated minimum and average available densities were identified. The existing sprinkler systems can provide an average l density greater than required by NFPA-13 (as described in Chapter 1, Appendix A). Available sprinkler discharge densities for the cell floor in Buildings C-310 and C-315, and the operating floor in Buildings C-310, C-315, C-333, C-335, and C-337 have not been reported, but analyses of the hydraulic effectiveness of the sprinkler systems in these buildings indicate that the systems are adequate.

High pressure fire water system. Buildings C-310, C-310-A, C-315, C-331, C-333, C-335, j and C-337 are on the high pressure fire water system. The system design basis considers a sprinkler 2

2 operating area slightly under 6000 ft (557 m ) for a lube oil spill fire on the cell (second) floors in the process buildings. For the operating (ground) floors, the maximum sprinkler operating area was determined to be 8400 ft (780 m'). These sprinkler operating areas for the cell and operating floors are 2

used to define the evaluation basis fire. The highest sprinkler system flow rate is estimated to be 3200 gpm (12.1 m / min) for the operating floor. A 500 gpm (1.9 m'/ min) hose stream demand is 3

added to the sprinkler system flow rate to obtain a maximum fire water flow rate of 3700 gpm 3

(14.1 m / min) for the evaluation basis. The HPFWS fire water pumps each have a capacity that exceeds 3

the 3700 gpm (14.1 m / min) maximum fire water flow rate.

(

3.15-56

SAR-PGDP PROPOSED June 30,1999 RAC 97C238 (R2), 99C028 (RO)

The C-611-R elevated storage tank has a capacity of 300,000 gal (907,400 m ). When it is 90%

2 full, the tank is capable of supplying the maximum flow rate for approximately 73 minutes with no HPFWS pumps operating. It is also capable of supplying 2250 gpm (8.6 m'/ min) with no pumps operating for a duration of two hours. This is slightly greater than 60% of the maximum flow demand.

W O

3.15.7.2.4 System Classification The fire protection system within the process buildings is required to:

Minimize the potential for a large fire that could damage the UF, primary system integrity in the enrichment cascade; the large fire event was not considered as having the potential for exceeding the off-site EBE EGs.

Minimize the likelihood of a large fire that could threaten UF primary system integrity in the 6

withdrawal facilities.

l The combustible fuel loading in these facilities is controlled in accordance with the Fire Protection Program (see Section 5.4). Based on this, the fire protection systems within the scope of this section meet the criteria for classification as an AQ system.

3.15.7.2.5 Boundary l

The AQ boundary for the high pressure fire water system is defined in Table 3.15-2.

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SAR-PGDP PROPOSED June 30,1999 RAC 97Cl23 (RI), 99C028 (RO) -

requirements is discussed in Section 3.15. Operating limits for the essential controls are presented in the TSRs.

4.3.2.1 Cascade Facilities Table 4.2-11 documents the results of the hazard analysis for each of the cascade facility processes. In addition to the processes that were evaluated directly inside the cascade facilities, various waste storage / handling operations may also be present inside the facilities. These operations and their analyses are addressed in Section 4.3.2.3.

4.3.2.1.1 Compressor Failure-UF./ Hot Metal Reaction (Temperature Increase) a.

Scenario Descrintion UF. oxidizes most metals producing a metal fluoride and solid uranium compounds, but at

. moderate temperatures the reaction is mild and the reaction rate is inhibited by the layer of reaction products formed on the surface of the metal. However, if aluminum is heated above the solidus temperature [about 1100*F (593*C)], the protective metal fluoride layer is disturbed and a more vigorous exothermic reaction can occur. The reaction will continue as long as UF and aluminum are available, and the heat generated by this reaction is sufficient to maintain the aluminum above the solidus temperature.

O Any whsm capable of heating the aluminum to temperatures above the solidus temperature when UP. is present can initiate the UF / aluminum reaction. However, the most probable and most historically common initiating mechanism is friction associated with component rubbing after axial compressor failure /deblade which generates sufficient heat to raise aluminum temperatures above the solidus temperature. While all axial compressors have aluminum blades, the "00" compressors have the greatest potential for UF./ hot metal reactions because they have aluminum rotors that tend to expand more than the "000" compressor steel rotor. This expansion results in decreased rotor blade tip clearances and a greater probability of blade rubbing and deblade. Friction or rubbing of aluminum components or fagmr s after a deblade has the potential to provide sufficient heat to reach the solidus temperature of the aluminum and create an exothermic UF./ hot metal reaction. The reaction will result in increased temperatures and decreased pressures locally as the UF is reacted to produce solid compounds. If the reaction occurs in a vulnerable location and is not mitigated, it can damage the pressure boundary and

- cause a breach of the primary system. A breach would result in a release of UF if the process pressure were above atmospheric pressure. In addition, under certain conditions, the heat from an exothermic reaction in the compressor can be transmitted to the cooler. If this occurs, and sufficient heat is provided to melt the aluminum components in the stage cooler, the R-114 coolant would leak into and pressurize the process system. If the R-114 coolant system is breached in a cell that is isolated from the cascade, this could result in overpressure and breach of the primary system due to the limited expansion volume available. Coolant system ruptures into the primary system are addressed in Section 4.3.2.1.6.

During the modes of operation for the enrichment cascade where the compressors are running, l la number of causal factors may result in compressor failure in a cell or booster station including (1) compressor flow starvation or compressor overload, (2) catastrophic seal or bearing failure that results 4.3-35

l I

1 SAR-PGDP PROPOSED June 30,1999 RAC 97Cl23 (R1), 99C028 (RO) in wet air inleakage and subsequent rotor imbalance (excessive vibration) due to uranium deposition. (3) enrichment cascade disturbances which result in compressor surging, and (4) overheating the process gas stream due to coolant system malfunctions. These factors can cause the progressive effects of (1) compressor surging or overload, (2) overheating, and (3) if unmitigated, a compressor deblade. Direct compressor failure can also be caused by (1) a foreign object in the compressor suction or (2) blade fatigue. When a compressor deblades, the possibility of heat build up exists due to rubbing / friction of aluminum components or fragments sufficient to initiate a UF./ hot metal exothermic reaction, and burn a hole in the primary system boundary and/or the R-114 coolant system boundary.

This event is an AE because a single active failure of a compressor, left unmitigated, could result in a UF./ hot metal reaction that could lead to a breach in the process system and a release Operational

' history indicates that only a small percentage of compressor failure events result in a UF./ hot metal reaction.

A UF./ hot metal reaction event was evaluated in the PrHA, and it was determined that the l consequences could include significant on-site impact in the above atmospheric pressure modes if no mitigation were provided.

The primary concerns associated with this event are (1) the primary system temperature increase, and (2) controlling the UF release if the primary system should fail. The applicable EGs (see Table 4.2-

2) associated with this event are all the EGs for the AE frequency range. EG 4 is addressed by the NCS Program (see Section 5.2). The first safety action required to meet the other ECs would be to maintain O

ine vri=>rr erste= te=rer t=re itata 80 3. This ctio= *iti vreve=< prt=>r) >v>< = r>ii"re. erotect on-site personnel, and maintain habitability of the required control area by pres enting a release of UF.

If prunary system temperature cannot be maintained within EG 3, a breach of the primary system could conceivably occur. The safety actions for above atmospheric systems of (1) primary system leakage j

detection, (2) primary system pressure control (to reduce the primary system pressure and mimmize the UF. release), (3) building holdup, and (4) emergency response by on-site personnel would be required to maintain the effects of a UF. release within EGs 1, 2, and 6. These actions protect on-site personnel and will maintain habitability of the required control area in accordance with EG 6 as well.

Primary system temperature control is required to meet EG 3. The primary means of accomplishing this safety action is to minimize the potential for the event to occur. Typically, when one of the causal factors that could lead to a compressor deblade is identified by an abnormal motor load and confirmed by enmining other process parameters, operators will initiate appropriate actions (e.g., reduce the operating pressure, take the cell off-stream, or trip the cell (s) and take off-stream) to prevent a deblade. However, once a deblade is confirmed the essential method for preventing the reaction is to trip the cell (s) from the area control room (ACR) to shut down the motors to eliminate any heat generation due to rubbing parts. If this control fails to stop the transient in sufficient time to prevent the failure of the primary system, a release is assumed to occur if the system is above atmospheric pressure. The release of UF. to the atmosphere could exceed EGs 1,2, and 6 if no mitigation is accomplished. 'Ihe compressor failure-UF / hot metal reaction produces the most limiting temperature transient event in the 6

l AE category.

4.3-36

I SAR-PGDP -

PROPOSED June 30,1999 i

1 l

RAC 97Cl23 (RI), 99C028 (RO) b.

Source-Tenn Analysis j

In order for a UF./ hot metal reaction event to produce a significant release of UF to the atmosphere, the event must be in cells or equipment operating above atmospheric pressure. Therefore, the source-term associated with the UF./ hot metal reaction event is addressed for the above atmospheric 1

pressure operating mode.

i-The potential source term due to a breach in the primary system while the cell is operating above I

1 atmospheric pressure is bounded by the source term for the B-stream block valve closure event (Section f

4.3.2.1.3). This is because UF. is consumed during the reaction, the compressor at the point of the breach will be pumping inefficiently if it is pumping at all, and the pressure would not significantly

' l increase due to the temperature increase. In addition, if the breach occurs in an operating cell, operator action would be taken to trip the cell in response to the UF release and/or the surging of compressors l-in this cell and adjacent cells. Tripping the cell compressors significantly reduces primary system pressure j

due to a loss of compression.

-l' l

c.

Consecuence Analysis 4

The consequence analysis for the UF./ hot metal reaction event is subdivided to address the on-site receptors.-

O Local workers in the immediate area - Workers in the immediate area of the release could be l

exposed to a significant uranium dose and/or HF exposure. In the event of a release, the plant see and flee policy requires personnel to evacuate the area for their own protection. The essential method of detection for workers within the ' cascade process buildings is (1) visual indication of a " white smoke" (i.e., reaction products of UF. and moisture) or (2) the odor of HF, which is a product of the reaction of UF. and moisture. The visual indication or the odor of HF will provide indication of (1) the occurrence of a release and (2) the need for the workers to evacuate the area of the release. All the cascade UF6 processing equipment and major piping are enclosed in housings to maintain normal operating temperatures. The configuration of the housings required to maintain normal operating temperatures, and

)

therefore to keep UF in the gaseous state, provides an inherent barrier against UF. releases within the L

housing. Although the housings provide the local worker with additional time to detect the release and j

evacuate the area, the housings are not considered an essential control for this receptor rather they l

- provide further assurance that workers will be able to evacuate the area in accordance with the plant see I

and flee policy. Personnel protective equipment (PPE) or other protective measures (e.g. emergency I

l egress capability) must be available for personnel operating process building cranes.

t L

Operationalpersonnelin the ACR - The analysis for the B-stream block valve closure event (Section 4.3.2.1.3) concluded that adequate time is available for operational personnel to accomplish the essential safety actions (leakage detection and mitigation). Because the UF./ hot metal reaction source term is bounded by the B-stream _ block valve closure event, adequate time would also be available for l

operational personnel to detect and mitigate this event prior to any need to evacuate the ACR. However, 1

4.3-37

!E

SAR-PGDP PROPOSED June 30,1999 RAC 97Cl23 (RI), 99C028 (RO) once these essential actions have been accomplished, the essential control to protect these personnel is evacuation, if required, upon detection of the release by sight or by odor.

Workers outside the process buildings - The essential controls for protecting on-site personnel j

outside the process buildings are (1) detection of the release, (2) minimization of the release by tripping applicable cells, (3) temporary holdup of the release by the existing process building structure, and (4) training of on-site personnel to evacuate areas upon detection of a release by sight or by odor. The first essential control is to detect the release of UF.. As stated previously, the motor load indicators provide an indication of abnormal compressor operation that could lead to failure (i.e, surging and/or loss of load). Typically, this indication will be detected, and corrective action will be taken prior to the initiation of a UF./ hot metal reaction, or prior to a UF/ hot metal reaction progressing to the point of a primary system breach. However, should a release occur, the equipment that has the potential for causing a large i

release (i.e., "00" or "000" building compressors which are intended to operate above atmospheric pressure) are equipped with UF. release detection that alarms in the applicable ACR. Other portions of the cascade do not have operating pressures or inventories sufficient to result in any significant consequences outside the building, and this receptor would not be applicable (see Section 4.2.6.4). The second essential control, is for operators to trip the appropriate cell (s) to reduce the pressure and minimize the release of UF. The shutdown of a cell (s) will decrease the cell (s) high side pressure to 6

about one-half the normal operating pressure, which will bring the cell (s) uniformly below atmospheric pressure. Pressure at an interbuilding booster compressor can be reduced, if needed, by tripping the compressor motor or by tripping adjacent enrichment cell compressor motors. Once the pressure has dropped to atmospheric pressure or below, the release of material is effectively terminated for any O

p tential exposure outside the process building. Sufficient time is then available to perform any necessary valve evolutions to isolate the cell. The third essential control, process building holdup, is provided by the existing process building structure. The process building structure is expected to reduce the potential hazardous material concentrations to receptors outside of the building by holdup of a portion of the UF 6 released, and by causing most of the UF. that escapes the building to be released via the exhaust and roof vents flush with the top of the building. If workers outside of the process building have received no other instructions for action to be taken (i.e., shelter in place or take cover), then the essential control for these receptors is to evacuate their areas if a release is detected by sight or by odor.

d.

Comnarison With Guidelines The EGs for the AE frequency category from Table 4.2-2 were compared with the consequences associated with the event scenario. The EG associated with preventing overtemperature (EG 3) cannot be ensured based on operational history. However, operational history also indicates that the source term associated with this event is typically minimal. If EG 3 is not met, the other EGs for protection against releases are applicable to the event. For workers in the immediate area, specific exposures were not calculated because of variables and uncertainties associated with the calculations and because of obvious evacuation actions that would be taken by the worker. However, the controls. identified (i.e., see and flee, and PPE or other protective measures for crane operators) will maintain exposures within EGs 1 and 2 j

to the extent practical. Actions required of operational personnel in the ACR were evaluated, and they

{

can be accomplished to meet the requirement for EG 6. In the event that the release ultimately affects habitability of the ACR, this receptor would be able to evacuate the area before EGs I and 2 are exceeded. In addition, based on the controls identified (i.e., release detection, cell trip, building holdup, d("

4.3-38

SAR-PGDP PROPOSED June 30,1999 RAC 97Cl23 (RI),99C028 (RO) and evacuation of areas upon detection of a release) and the analysis presented for the B-stream block valve closure event (bounding AE event), EGs 1 and 2 would be met for workers outside the process building.

e.

Summary of SSCs and TSR Controls The essential controls for the UF / hot metal reaction event associated with meeting EG 3 are to minimize the potential for failing the primary system due to temperature increase. These controls include detection of the compressor failure and minimizing the source of heat / friction that could lead to the elevated temperatures that allow the UF./ hot metal reaction. For equipment operating above atmospheric pressure, the essential controls for this event are summarized as follows:

Motor load indicators in ACR-indication of abnormal compressor operation (i.e., surging and/or loss of load) (EG 3 only); and Compressor motor manual trip in ACR-elimination of heat / friction (EG 3 only).

For equipment operating above atmospheric pressure, essential mitigation of any UF releases 6

associated with this event (EGs 1,2, and 6) are the same as those described for the B-stream block valve closure event (Section 4.3.2.1.3) for on-site receptors and are summarized as follows:

Compressor motor manual trip in ACR-minmuze release to workers outside the process building (EGs 1,2, and 6);

C UF. release detection system-workers outside the process building (EGs 1, 2, and 6);

Visual / odor detection of release, worker training, and evacuation of affected area-all on-site workers (EGs 1 and 2);

Admmistrative control-personal protective equipment (PPE) or other protective measures shall be avaihble to personnel operating process building cranes (EGs 1 and 2); and Process building holdup-workers outside process building (EGs 1 and 2).

Based on the above essential controls, the resulting important to safety SSCs and TSRs are as follows:

l*

The motor load indicators, compressor motor manual trip systems, UF. release detection system, and process buildings are identified as important to safety SSCs. See Section 3.15 for details including safety classification.

l*

TSRs are provided for the motor load indicators; cell trip system: UF. release detection system:

and administrative requirements for procedures and training of workers for evacuation actions, and for protective equipment / measures for crane operators.

4.3 39

~

SAR-PGDP ~

PROPOSED June 30,1999 RAC 97Cl23 (RI), 99C028 (RO) 4.3.2.1.2 Stage Control Valve Closure (Pressure Increase) a.

Scenario Descrintion l

The stage control valve is used to control the pressure in a stage automatically or manually. The

. inadvertent closure of the stage control valve in a cell will cause a pressure increase in the stages above l. the closed control valve. Inadvertent closure of a stage control valve could be caused by initiators such as (1) an operator error, (2) a failure in the valve controls, (3) a mechanical failure in the valve mechanism (e.g., valve disk failure), (4) a freeze-out of UF. in the high side instrument line, or (5) a rupture of the high-side instrument line. The valve closure (s) could cause an increase in pressure, surging, and possibly motor overload. The pressure increase is limited due to the fact that the shift in inventory l required to increase the pressure will cause the stage compressor to go into surge. Once the stage compressor goes into surge, the compressor will stop pumping additional inventory above the closed valve and the pressure will stop increasing, The pressure transient associated with closure of a stage control valve would be no higher than the pressure transient associated with the closure of a B-stream block valve when the recycle valve does not open. In a B-stream block valve closure scenario where the recycle valve does not open as designed, the maximum pressure attamed in a "000" stage initially running at maximum steady state pressure would be about 30 psia. For equipment operating at a lower initial pressure, inadvertent closure would result in a lower maximum pressure (e.g., if the starting pressure was 14.4 psia the maximum pressure would be limited to 20 psia). In addition, stage control valves equipped with trimmer vanes and stops allow a limited amount of process gas flow to pass through the valve when it is closed. In the event of a stage control valve closure, this design feature would limit the maximum Q

achievable pressure in the affected cell even further since a closed B-stream block valve allows virtually no flow through when closed.

This event is an AE because a single active failure or a single operator error could cause the inadvertent closure of a stage control valve or valves. Primary system failure is not expected at the maximum pressures associated with this event; however, it is assumed for the purpose of this evaluation that a primary system breach is possible.

Closure of a stage control valve was evaluated in the PrHA, and it was determined that the unmitigated consequences could include significant on-site impact in the above atmospheric pressure mode. The evaluation determined that no significant consequences beyond the immediate area are l expected if the event occurs in equipment operating in the below atmospheric pressure mode.

The primary concerns associated with this event are (1) the primary system pressure increase, and (2) controlling the UF. release if the primary system should fail. The applicable EGs (see Table 4.2-2) associated with this event are all the EGs for the AE frequency range. EG 4 is addressed by the NCS Program (see Section 5.2). The first safety action required to meet the other EGs would be to maintain primary system pressure control within EG 3. This action will prevent primary system failure, protect on-site personnel, and maintain habitability of the required control area by preventing a release of UF.

6 If primary system pressure cannot be maintained within EG 3, a breach of the primary system is assumed to occur. The safety actions of(1) primary system leakage detection, (2) primary system pressure control

-(to reduce the primary system pressure and minimize the UF. release), (3) building holdup, and (4) emergency response by on-site personnel would be required to maintain the effects of the UF release 4.3-40

SAR PGDP PROPOSED June 30,1999 RAC 97Cl23 (RI),99C028 (RO) within EGs 1,2, and 6. These actions protect on-site personnel and wc intain habitability of the required control area in accordance with EG 6 as well.

Primary system pressure control is required to meet EG 3. The primary method of accomplishing this safety action is to detect the pressure increase and take actions to reduce the pressure. The essential method of detecting a pressure increase in the cascade equipment is through monitoring the motor load indicators. The motor load indicators (i.e., stage ammeter indications) will indicate a rise in current for the compressor motors above the point of valve closure that is proponional to the rise in pressure. Once the increased motor loads are detected by the operator, an operator response is needed to reduce the pressure. Typically, during normal operation, operators are likely to determine the cause of the rise in loads (e.g., through observing valve position indicators and compressor loads) and this will initiate routine actions to limit the pressure increase to meet EG 3. These routine actions could include tripping the cell and/or taking off-stream, establishing a split in the cascade to isolate flow to the cell, or placing the control valve in manual operating mode to regain pressure control. However, the essential method for limiting the pressure is to trip cell (s) from the ACR. Tripping the cell (s) will eliminate the compression source and limit the pressure increase. However, should the detection and/or cell t"9 not occur soon enough, a failure of the primary system is assumed to occur. The release of UF. to the atmosphere could exceed EGs 1,2, and 6 if no mitigation is accomplished.

b.

Source-Term Analysis l

Operating experience indicates that this event has never resulted in a release of UF. due to

]

overpressure. Therefore, failure of the primary system is not expected with this event at this frequency.

However, for analysis purposes, a failure of the primary system is assumed to occur at this event l frequency. During the above atmospheric pressure operating mode, a direct failure of the primary system is assumed to result because of the pressure increase associated with a stage control valve closure event.

The maximum pressure would be significantly less than that evaluated for the B stream block valve closure event (Section 4.3.2.1.3), and is therefore bounded by that analysis.

c.

Conseauence Analysis The consequence analysis for the stage control valve closure event is subdivided to address the different receptors.

Local workers in the immediate area - Workers in the immediate area of the release could be exposed to a significant uranium dose and/or HF exposure. In the event of a release, the plant see and flee policy requires personnel to evacuate the area for their own protection. The essential method of detection for workers within the cascade process buildings is (1) visual indication of a " white smoke" (i.e., reaction products of UF. and moisture) or (2) the odor of HF, which is a product of the reaction of UF and moisture. The visual indication or the odor of HF will provide indication of (1) the occurrence of a release and (2) the need for the workers to evacuate the area of the release. All the cascade UF.

processing equipment and major piping are enclosed in housings to maintain normal operating temperatures. The configuration of the housings required to maintain normal operating temperatures, and therefore to keep UF in the gaseous state, provides an inherent barrier against UF releases within the housing. Although the housings provide the local worker with additional time to detect the release and nU 4.3-41 L

I SAR-PGDP PROPOSED June 30,1999 RAC 97C123 (R1), 99C028 (RO)

I.

evacuate the area, the housings are not considered an essential control for this receptor rather they provide further assurance that workers will be able to evacuate the area in accordance with the plant see and flee policy.

Personnel protective equipment (PPE) or other protective measures (e.g. emergency egress capability) must be available for personnel operating process building cranes.

Operationalpersonnelin the ACR - The analysis for the B-stream block valve closure event (Section 4.3.2.1.3) concluded that adequate time is available for operational personnel to accomplish the essential safety actions (leakage detection and mitigation). Because the stage control valve closure event source term is bounded by the B-stream block valve closure event source term, adequate time would also be available for operational personnel to detect and mitigate this event prior to any need to evacuate the ACR. However, once these essential actions have been accomplished, the essential control to protect snese personnel is evacuation, if required, upon detection of ? e release by sight or by odor.

Workers outside the process buildings - The essential controls for protecting on-site personnel outside the process buildings are (1) detection of the release, (2) minimization of the release by tripping applicable cells, (3) temporary holdup of the release by the existing process building structure, and (4) training of on-site personnel to evacuate areas upon detection of a release by,.d iy odor. The first essential control is to detect the release of UF.. As stated previously, the motor C 2dicators provide an indication of a pressure increase in the affected cell. Typically, this indication wl be detected, and corrective action will be taken prior to any failure in the primary system. However, should.a release occur, the equipment that has the potential for causing a large release (i.a., "00" or "000' building compressors which are intended to operate above atmospheric pressure) are equipped with UF. release Q

detection that alarms in the applicable ACR. Other portions of the cascade do not have operating pressures or inventories sufficient to result in any significant consequences outside the building, and this receptor would not be applicable (see Section 4.2.6.4). The second essential control, is for operators to trip the appropriate cell (s) to reduce the pressure and minimize the release of UF. The shutdown of a cell (s) will decrease the cell (s) high side pressure to about one-half the normal operating pressure, which will bring the cell (s) uniformly below atmospheric pressure. Pressure at an interbuilding booster compressor can be reduced, if needed, by tripping the compressor motor or by tripping adjacent enrichment cell compressor motors. Once the pressure has dropped to atmospheric pressure or below, the release of material is effectively terminated for any potential exposure outside the process bt.ilding.

l Sufficient time is then available to perform any necessary valve evolutions to isolate the cell. The third essential control, process building holdup, is provided by the existing process building structure. The process building structure is expected to reduce the potential hazardous material concentrations to receptors outside of the building by holdup of a portion of the UF, released, and by causing most of the l UF. that escapes the building to be released via the exhaust and roof vents flush with the top of the l building. If workers outside of the process building have received no other instructions for action to be taken (i.e., shelter in place or take cover), then the essential control for these receptors is to evacuate their areas if a release is detected by sight or by odor.

O 4.u2

SAR-PGDP PROPOSED June 30,1999 RAC 97Cl23 (RI),99CG28 (RO)

Based on the above essential controls, the resulting important to safety SSCs and TSRs are as follows:

]*

The motor load indicators, compressor motor manual trip systems, UF release detection system, and process buildings are identified as important to safety SSCs. See Section 3.15 for details including safety clas ification.

l*

TSRs are provided for the motor load indicators; cell trip system: UF, release detection system; and administrative requirements for procedures and training of workers for evacuation actions, and for protective equipment / measures for crane operators.

4.3.2.1.3 8-Stream Block Valve Closure (Pressure Increase) a.

Scenario Description Normal operation of the gaseous diffusion cascade requires a cantinuous A-stream (upstream) l flow, and B-stream (downstream) flow, in order to complete the enrichment process. During operation of the enrichment cascade, the B-stream block valves are generally operated only to take equipment off-stream or to establish cascade snlits. These are operations that are typically performed at the local cell panel while the operator has an established communication link with the ACR. During these operations, the potential exists for the inadvertent closure or failure to open of the B-stream block valve by initiators such as (1) failure in the valve controls, or (2) operator error. A B-stream block valve closure that is caused by one of these initiating events is considered to be in the AE frequency category. It is also O

p ssible for the valve to mechanically fail (e.g., valve disk failure), however this initiator is considered to be in the EBE frequency category. This inadvertent "B" stream blockage will result in the A-upflow remaining near normal initially, with the B-downflow decreasing to zero as the B-stream block valve 1

closes. Inventory would be pumped from stages below the closed B-stream block valve to the stages above the closed valve. If the recycle valve opens automatically as designed, the Stage 1 compressor will raise the inventory and pressure in the stage immediately above the closed B-stream valve. The inventory.

and pressures in stages above the closed valve are postulated to continue increasing until the pressure transient exceeds the rated pressure of a primary system component (e.g., expansion joint) and results in a UF. release to atmosphere. Routine actions would typically be taken by operators to mitigate the event prior to system breach (stopping or reversing the closure of the B block valve, or closing the appropriate A block valve to stop the A-stream flow if the B block valve fails to open).

There are other possible unmitigated end states associated with the B-stream block valve closure initiator, however these potential end states are not credited in this analysis. These other potential end states include:

~

Compressors are automatically shut down on overload by the motor overload trip system.

' Compressors deblade due to overload.

The expansionjoint internal to a converter that separates the A & B stream ruptures (the pressure differential between the B-stream and the A-stream is greater than the pressure differential between the B-stream and the atmosphere).

4.3-44

SAibPGDP PROPOSED June 30,1999 (3

RAC 97Cl23 (RI), 99C028 (RO)

.V An unmitigated closure of a B-stream block valve was evaluated in the PrHA and it was determined that the consequences of a release could include significant off-site and on-site impact in the l above atmospheric pressure operating mode if no mitigation were provided, or significant on-site impact l in the below atmospheric pressure operating mode.

The primary concerns associated with this event are (1) the primary system pressure increase associated with the unmitigated inadvertent blockage of the B-stream, and (2) controlling the UF release if the primary system should fail. The applicable EGs (see Table 4.2-2) associated with this event are all the EGs for the AE frequency range. EG 4 is addressed by the NCS Program (see Section 5.2). The first safety action required to meet the other EGs is to maintain primary system pressure control within EG

3. This action will prevent primary system failure, protect both on-site personnel and the off-site public, and maintain habitability of the required control area by preventing a release of UF.. If primary system i

pressure cannot be maintained within EG 3, a breach of the primary system could occur. The safety actions of (1) primary system leakage detection, (2) primary system pressure control (to reduce the primary system pressure and minimize the UF. release), (3) building /hcusing holdup, and (4) emergency response by on-site personnel would be required to maintain the effects of the UF. release within EGs 1, 2, and 6. These actions protect both on-site personnel and the off-site public and will maintain habitability of the required control area in accordance with EG 6 as well.

Primary system pressure control is required to meet EG 3. The primary method of accomplishing this safety action is to detect the pressure increase and take actions to reduce the pressure. The essential method of detecting a pressure increase in the cascade equipment is through monitoring the motor load O

indicators. The motor load indicators (i.e., stage ammeter indications) will indicate a rise in current for the compressor motors above the point of valve closure that is proportional to the rise in pressure. The pressure rise is not immediate. A bounding analysis was performed to determine the minimum time-frame to reach primary system failure. This analysis was based ca a B-stream block valve closure occurring in a "000" cell while the cascade is operating at maximum power levels and at an area operating at maximum steady state pressure and maximum interstage flow rates. This analysis indicates that from the time that valve closure is initiated, the valve will completely close in approximately 2.5 min, primar/ system pressure would begin to significantly increase approximately 1.5 min after initiation of valve closure, and primary system failure is postulated to occur after approximately 3.5 min after initiation of valve closure. Rather than taking full credit for the expected closure time of the B-stream block valve, it is conservatively assumed for this analysis that the operator has 2.5 minutes from event initiation to detect the increased motor loads and to take actions to reduce pressure and prevent rupture and thus meet EG 3 for the worst case conditions. For lower cascade power levels, lower steady-i state operating pressures, lower interstage flows, and smaller equipment, the time frame for reaction would typically be significantly longer.

Once the increased motor loads are detected by the operator, an operator response is needed to reduce the pressure. Typically, during normal operation, operators are likely to determine the cause of the rise in loads (e.g., through observing valve position indicators and compressor loads) and this will initiate routine actions to limit the pressure increase to meet EG 3. These routine actions could include stopping or reversing the closure of the B block valve, stopping or reversing the closure of the B bypass valve if the B block valve fails to open, or closing the appropriate A block valve to stop the A-stream flow. However, the essential method for limiting the pressure is to trip cell (s) from the ACR. Tripping 4.3-45

SAR-PGDP PROPOSED June 30,1999 RAC 97Cl23 (RI), 99C028 (RO) the cell (s) will eliminate the compression source and limit the pressure increase. However, based on the minimum time-frame for operator action associated with the worst case conc'itions, detection or cell trip may not be accomplished in time to prevent exceer'ing EG 3. Consequently, a failure of the primary system is addressed. The release of UF. to the atmosphere could exceed EGs 1,2, and 6 if no mitigation is accomplished.

l Should the essential preventive actions fail to stop the transient in sufficient time to prevent a failure of the primary system, a release of UF, is assumed to occur. Operating experience indicates that this event has never resulted in a release of UF due to overpressure. Therefore, failure of the primary system is not expected with this event at this frequency. However, for analysis purposes, a failure of the primary system is assumed to occur at this event frequency.

b.

Source-Term Analysis The B-stream block valve closure event is categorized as an AE because a single failure of equipment or a single operator error could initiate the event, and it is also based on operational history.

There are many variables associated with this event that must be characterized to develop a source term.

These variables include:

The duration of the event prior to operator action; The size of the potential system failure; The location of the failure in the cascade (i.e., equipment associated with "00" or "000" cascade Q

operations-other equipment is not considered credible due to lower pressures); and The initial pressures and associated flow rate of UF, at the break.

To characterize this scenario for consequence analysis, the objective was to determine the amount of material that can be released without exceeding the AE off-site EGs (i.e.,10 mg U and 5 rem) and evaluate the time frame to determine if sufficient operator time is available to mitigate the event prior to exceeding the EGs. The scenario assumes a conservative release rate equivalent to the B-stream line failure scenario release rate presented in the large UF release to atmosphere event (see Section 6

4.3.2.1.7). The release rate is 130 lb/s (59 kg/s) of UF.. Based on the analysis in Section 4.3.2.1.7, it would take approximately 90 s to release enough material [i.e.,11,700 lb (5307 kg)] to exceed.lte mg U at the nearest site boundary. Because of the various receptors of concern (i.e., personnel in the process building, operators, general on-site workers, and the off-site public), the EGs will be addressed based on these receptors.

c.

Conseauence Analysis The consequence analysis for the B-stream block valve closure event is subdivided to address the different receptors.

Local workers in the immediate area - Workers in the immediate area of the release could be exposed to a significant uranium dose and/or HF exposure. In the event of a release, the plant see and flee pclicy requires personnel to evacuate the area for their own protection. The essential method of detection f. workers w' thin the cascade process buildings is (1) visual indication of a " white smoke" (3

V 4.3-46 L

SAR-PGDP PROPOSED June 30,1999 RAC 97Cl23 (RI), 99C028 (R0)

(i.e., reaction products of UF. and moisture) or (2) the odor of HF, which is a product of the reaction of UF. and moisture. The visual ir.fication or the odor of HF will provide indication of (1) the occurrence of a release and (2) the need fcr the workers to evacuate the area of the release. All the cascade UF.

processing equipment and major piping are enclosed in housings to mamtain mrmal operating temperatures. The configuration of the housings required to maintain normal operating temperatures, and therefore to keep UF in the gaseous state, provides an inherent barrier against UF. releases within the housing. Although the housings provide the local worker with additional time to detect the release and evacuate the area, the housings are not considered an essential control for this receptor rather they provide further assurance that workers will be able to evacuate the area in accordance with the plant see and flee policy.

Personnel protective equipment (PPE) or other protective measures (e.g. emergency egress capability) must be available for personnel operating process building cranes.

Operational personnelin the ACR - Operational personnel who are required to take mitigative action are located in the ACR, which typically would not be impacted by the event. However, during cold weather periods, the air on the cell floor is recirculated inside the building to minimize heat loss and maintain building temperatures. This mode of operation could result in elevated concentrations of HF in the ACR area, which would result in evacuation of the ACR. An evaluation of this potential concern concluded that adequate time is available for operators to perform the required actions prior to evacuation should the need arise. However, once these essential actions have been accomplished, the essen'ial control to protect these personn3l is evacuation, if required, upon detection of the release by sight or by odor.

Workers outside the process buildings - The essential controls for protecting on-site personnel outside the process buildings are (1) detection of the release, (2) minimization of the release by tripping nQ applicable cells, (3) temporary holdup of the release by the existing process building structure, and (4) traimng of on-site personnel to evacuate areas upon detection of a release by sight or by odor. The first I

essential control is to detect the release cf UF. As stated previously, the motor load indicators provide 4

6 an indication of a pressure increase in the affected cell. Typically, this indication will be detected, and

}

corrective action will be taken prior to any failure in the primary system. However, should a release occur, the equipment that has the potential for causing a large release (i.e., "00" or "000" building i

compressors which are intended to operate above atmospheric pressure) are equipped with UF release detection that alarms in the applicable ACR. Other portions of the cascade do not have operating pressures or inventories sufficient to result in any significant consequences outside the building, and this i

receptor would not be applicable (see Section 4.2.6.4). The second essential control, is for operators to trip the appropriate cell (s) to reduce the pressure and minimize the release of UF.. The shutdown of a cell (s) will decrease the cell (s) high side pressure to about one-half the normal operating pressure, which will bring the cell (s) uniformly below atmospheric pressure. Pressure at an interbuilding booster compressor can be reduced, if needed, by tripping the compressor motor or by tripping adjacent I

enrichment cell compressor motors. Once the pressure has dropped to atmospheric pressure or below, the release of material is effectively terminated for any potential exposure outside the process building.

l Sufficient time is then available to perform any necessary valve evolutions to isolate the cell. The third essential control, process building holdup, is provided by the existing process building structure. The process building structure is expected to neduce the potential hazardous material concentrations to receptors outside of the building by holdup of a portion of the UF released, and by causing most of the UF. that escapes the building to be released via the exhaust and roof vents flush with the top of the i

building. If workers outside of the process building have received no other instructions for action to be taken (i.e., shelter in place Q

V 4.3-47

SAR-PGDP PROPOSED June 30,1999 RAC 97C123 (R1),99C028 (RO)

Motor load indicators in ACR-indication of pressure increase (i.e., significant increase in motor load) (EG 3 only); and Compressor motor manual trip in ACR-decrease pressure (EG 3 only).

Essential mitigation of any UF releases associated with this event (EGs 1, 2, and 6) are summarized as follows:

. Compressor motor manual trip in ACR-minimize release for all receptors except local worker (EG s 1,2, and 6);

UF. release detection system for cells operating above atmospheric pressure-all receptors except local worker (EGs 1, 2, and 6);

Equipment housing holdup for compressors operating above atmospheric pressure-off-site public (EGs 1 and 2);

- Visual / odor detection of release, worker training, and evacuation of affected area-all on-site workers (EGs 1 and 2);

Administrative control-personal protective equipment (PPE) or other protective measures shall

. be available to personnel operating process building cranes (EGs 1 and 2); and Process building holdup-workers outside process building and the off-site public (EGs 1 and 2).

- Based on the above essential controls, the resulting important to safety SSCs and TSRs are as follows:

Q l*

The motor load indicators, compressor motor manual trip systems, UF. release detection system, equipment housings, and process buildings are identified as important to safety SSCs. See Section 3.15 for details including safety classification.

-l

  • TSRs are provided for the motor load indicators; cell trip system; UF, release detection system; and administrative requirements for procedures and training of workers for evacuation actions, and for protective equipment / measures for crane operators.

4.3.2.1.4 Limited UF. Release to Atmosphere (Primary System Integrity) a.

Scenario Description l

Small passive failures in the primary system may result in limited releases of UF. Into the process buildings. These could be caused by initiators such as failures of instrument lines, expansion joints, weld joints, etc., that could be caused by vibration, fatigue, or corrosion. These types of failures are expected frequently enough to place them in the AE category.

A limited UF. release event was evaluated in the PrHA, and it was determined that the l

co==w~ could include significant on-site impact in the above atmospheric pressure operating mode

. l if no mitigation were provided.

The primary concern associated with this event is controlling the UF. release. The applicable EGs (see Table 4.2-2) associated with this event are W the EGs for the AE frequency range. EG 3 is not 4.3-49

m SAR-PGDP PROPOSED June 30,1999 p

RAC 97Cl23 (RI),99C028 (RO)

V (i.e., reaction products of UF and moisture) or (2) the odor of HF, which is a product of the reaction 6

of UF and moisture. The visual indication or the odor of HF will provide indication of (1) the occurrence 6

of a release and (2) the need for the workers to evacuate the area of the release. All the cascade UF6 processing equipment and major piping are enclosed in housings to maintain normal operating temperatures. The configuration of the housings required to maintain normal operating temperatures, and therefore to keep UF in the gaseous state, provides an inherent barrier against UF releases within the 6

6 housing. Although the housings provide the local worker with additional time to detect the release and evacuate the area, the housings are 1.ot considered an essential control for this receptor rather they provide further assurance that workers will be able to evacuate the area in accordance with the plant see and flee policy.

Personnel protective equipment (PPE) or other protective measures (e.g. emergency egress capability) must be available for personnel operating process building cranes.

Operationalpersonnelin the ACR - Because of the minimal source term associated with this event, no essential actions are required of operational personnel in the ACR. However, the essential control to protect these personnel is evacuation, if required, upon detection of the release by sight or by j

odor.

Workers outside the process buildings - The essential controls for protecting on-site personnel outside the process buildings are (1) temporary holdup of the release by the existing process building structure, and (2) training of on-site personnel to evacuate areas upon detection of a release by sight or by odor. Process building holdup is provided by the existing process building structure. The process building structure is expected to reduce the potential hazardous material co icentrations to receptors p

outside of the building by holdup of a portion of the UF released, and by causing most of the UF that 6

6 C

l escapes the building to be released via the exhaust and roof vents flush with the top of the building. If workers outside of the process building have received no other instructions for action to be taken (i.e.,

l shelter in place or take cover), then the essential control for these receptors is to evacuate their areas if a release is detected by sight or by odor.

1 1

d.

Comparison With Guidelines The EGs for the AE frequency category from Table 4.2 2 were compared with the consequences iated with the event scenario. For workers in the immediate area, specific exposures were not calculated because of variables and uncertainties associated with the calculations and because of obvious evacuation actions that would be taken by the worker. However, the controls identified (i.e., see and flee, and PPE or other protective measures for crane operators)will maintain exposures within EGs 1 and 2 to the extent practical. There are no essential actions required of operational personnel in the ACR to meet EG 6. In the event that the release ultimately affects habitability of the ACR, this receptor would be able to evacuate the area before EGs 1 and 2 are exceeded. In addition, based on the controls identified (i.e., building holdup, and evacuation of areas upon detection of a release) and the minimal source term associated with this event, EGs 1 and 2 would be met for workers outside the process building.

e.

Summary of SSCs and TSR Controls Based on the results of this analysis, the essential mitigative controls for the limited UF release j

6 to atmosphere event associated with meeting EGs 1,2, and 6 are a subset of those described for the B-2V 4.3-51 l

\\

SAR-PGDP PROPOSED June 30,1999 RAC 97Cl23 (RI), 99C028 (RO) that continued movement of the equipment is prevented when personnel are not present. The crane operator may be required to move the crane to a designated location to exit. Once the crane operator leaves the controls, no additional movement should occur. On the basis of this concern, the process building cranes are required to stay in their last position upon the operator's release of crane control. This requirement provides assurance that a heavy load will not be dropped as a result of evacuation.

The only other condition that could result in a failure of primary system integrity and in the subsequent release of UF. or another hazard in the enrichment cascade would be excessive pressures or temperatures in the operating modes where the compressors are normally operating. The essential controls for preventing overpressurization events (e.g., B-stream block valve closure event [Section 4.3.2.1.3])

and overtemperature (e.g., UF / hot metal reaction event (Section 4.3.2.1.1]) are accomplished via motor load indicators in the central control facility (CCF) (one per cell, to detect compressor operating abnormalities) and essociated manual trip capability in the CCF. This provides a comparable level of protection for controlling primary system pressure and temperature as compared to the ACR. Certain l compressors are not provided with ammeters for motor load indication in the CCF. These include all

. auxiliary compressors (e.g., boosters) except the B booster compressors in Buildings C-333 and C-337.

However, motor load indicators are provided for all cells connected to these compressors. Large changes in auxiliary compressor loads would be detectable on these adjacent cell motor load indicators so that appropriate action (e.g., tripping compressors) could be initiated to meet EG3.

e.

Summary of SSCs and TSR Controls

~

The essential controls for the evacuation of cascade process buildings event are summarized as follows:

Motor load' indicators in CCF-indication of pressure increase (i.e., ignificant increase in motor load)(EGs 3 and 6);

Compressor motor manual trip ("00" and "000" cells only) in CCF-decrease pressure and/or eliminate source of heat / friction from CCF (EGs 3 and 6);

Crane design to prevent movement upon release of controls-prevent primary system failure due to load drop (EG 3) j Based on the above essential controls, the resulting important to safety SSCs and TSRs are as follows:

l*

The motor load indicators in the CCF, compressor motor manual trip system from the CCF, and the process building cranes are identified as important to safety SSCs. See Section 3.15 for details including safety classification.

l*

TSRs are provided for the motor load indicators in the CCF and the cell trip from the CCF.

4.3 54

l PROPOSED June 30,1999 S AR-PGDP..

RAC 97Cl23 (RI),99C028 (RO) 4.3.2.1.6 Coolant Tube Rupture Into Primary System (Pressure Increase) a.

Scenario Description l

A failure of coolant tube (s) in a cascade cell gas cooler could result in a significant pressure increase in the primary system, if the coolant leak should occur when the cell is tied to the cascade, sufficient volume is available within the cascade to allow for expansion of the coolant without causing I

any significant pressurization. Coolant tube failures could be caused by initiators such as fatigue cracks i

or ruptures, joint failures, corrosion pitting, a loss of RCW cooling coupled with a failure of the coolant high-pressure relief system, or a UF./ hot metal reaction buming a hole in the gas cooler tubes. This event l

l-in an off-stream cell (limited volume for expansion) could result in a rapid pressure increase above the normal operating pressures within the primary system. The pressure transient may exceed the rated pressure of the converters and expansion joints, etc. This could lead to a UF. release regardless of whether the cell is operating above or below atmospheric pressure. This event is an AE based on operational history.

A rupture of coolant tubes into the primary system was evaluated in the PrHA, and it was determined that the consequences could include significant on-site impact in the above atmospheric pressure or below atmospheric pressure operating modes for the enrichment cascade process if no mitigation were provided. The threshold consequence analysis performed for the PrHA determined that off-site EGs would not be exceeded for this event.

The primary concern associated with this event is controlling the UF. release if the primary l

system fails. The applicable EGs (see Table 4.2-2) associated with this event are all the EGs for the AE frequency range. EG 4 is addressed by the NCS program (see Section 5.2). EG 3 cannot be ensured for this event, therefore the safety actions of (1) building holdup, and (2) emergency response by on-site personnel are required to maintain the effects of a UF. release within EGs 1 and 2. No operator action is required for this event, therefore there are no actions required to meet EG 6.

l l

b.

Source-Term Analysis The threshold source term analysis performed during the PrHA process determined that the maxunum source term for the coolant tube rupture into the primary system event is about 11,000 lb for a "000" cell.' This analysis assumes that no operator actions are taken to mitigate the event. No credit was taken for air in-leakage, nor for UF. remaining in the cell once it has reached atmospheric pressure.

l

'Iherefore, the value given is a conservative upper bound on the maximum amount of UF. which could be released from a single isolated cell.

l If an isolated cell running on recycle were breached, the' flow rate would drop as the UF is 6

exhausted. The minimum release duration for this condition is conservatively estimated at 2.5 minutes, for an average release rate of 73 lb/sec which results in a smaller release rate than postulated for the B-stream block valve closure event (Section 4.3.2.1.3). Based on the sma'ler release rate and the smaller total amount of material released, this event is bounded by the analysis performed for the B-stream block valve closure event.

4.3-55 l

l u

i.

l SAR-PGDP PROPOSED June 30,1999 RAC 97Cl23 (RI), 99C028 (RO) c.

Consecuence Analysis The consequence analysis for the coolant tube rupture into the primary system event will be l subdivided to address the different receptors.

j Local workers in the immediate area - Workers in the immediate area of the release could be exposed to a significant uranium dose and/or HF exposure. In the event of a release, the plant see and flee policy requires personnel to evacuate the area for their own protection. The essential method of detection for workers within the cascade process buildings is (1) visual indication of a " white smoke"

.(i.e., reaction products of UF. and moisture) or (2) the odor of HF, which is a product of the reaction of UF. and moisture. The visual indication or the odor of HF will provide indication of (1) the occurrence of a release and (2) the need for the workers to evacuate the area of the release. All the cascade UF 6

processing. equipment and major piping are enclosed in housings to maintain normal operating tempernires. The configuration of the housings required to maintain normal operating temperatures, and 1

therefore to keep UF in the gaseous state, provides an inherent barrier against UF. releases within the housing. Although the housings provide the local worker with additional time to detect the release and evacuate the area, the housings are not considered an essential control for this receptor rather they provide further assurance that workers will be able to evacuate the area in accordance with the plant see and flee policy.

Personnel protective equipment (PPE) or other protective measures (e.g. emergency egress capability) must be available for personnel operating process building cranes.

Operationalpersonnelin the ACR - No essential actions are required of operational personnel O

in the ACR. However, the essential control to protect these personnel is evacuation, if required, upon detection of the release by sight'or by odor.

Workers outside the process buildings - The essential controls for protecting on-site personnel outside the process buildings are (1) temporary holdup of the release by the existing process building i

structure, and (2) training of on-site personnel to evacuate areas upon detection of a release by sight or by odor. Process building holdup is provided by the existing process building structure. The process building structure is expected to reduce the potential hazardous material concentrations to receptors outside of the building by holdup of a portion of the UF. released, and by causing most of the UF.that l escapes the building to be released via the exhaust and roof vents flush with the top of the building. If j

workers outside of the process building have received no other instructions for action to be taken (i.e.,

shelter in place or take cover), then the essential control for these receptors is to evacuate their areas if a release is detected by sight or by odor.

d.

Comnarison With GnWH-The EOs for the AE frequency category from Table 4.2-2 were compared with the consequences 1

associated with the coolant tube rupture into the primary system event. The EG associated with preventing i

overpressme (EG 3) cannot be ensured if the event occurs in the cascade off-stream mode. If EG 3 is not met, the other EGs for protection against releases are applicable to the event. For workert in the immediate area, specific exposures were not calculated because of variables and uncertairties associated with the calculations and because of obvious evacuation actions that would be taken by the worker.

However, the controls identified (i.e., see and flee, and PPE or other protective measures for crane 4.3-56

SAR PGDP PROPOSED June 30,1999 RAC 97Cl23 (RI), 99C028 (RO) 1 operators) will mamtain exposures within EGs 1 and 2 to the extent practical. The operational perscnnel in the ACR were evaluated and it was determined that there are no required essential actions to meet EG

6. In the event that the release ultimately affects habitability of the ACR, this receptor would be able to evacuate the area before EGs 1 and 2 are exceeded. In addition, based on the controls identified (i.e.,

building holdup, and evacuation of areas upon detection of a release) and the analysis presented for the B-stream block valve closure event (bounding AE event), EGs 1 and 2 would be met for workers outside the process building.

e.

Summary of SSCs and TSR Controls Essential mitigation of any UF releases associated with the coolant tube rupture into primary system event (EGs 1,2, and 6) are a subset of those described for the B-stream block valve closure event (Section 4.3.2.1.3) and are summarized as follows:

Visual / odor detection of release, worker training, and evacuation of affected area-all on-site workers (EGs 1 and 2);

Administrative control-personal protective equipment (PPE) or other protective measures shall be available to personnel operating process building cranes (EGs 1 and 2); and Process building holdup-workers outside process building (EGs 1 and 2).

Based on the above essential controls, the resulting important to safety SSCs and TSRs are as follows:

O The process buildings are identified as important to safety SSCs. See Section 3.15 for details

+

including safety classification.

TSRs are provided for administrative requirements for procedures and training of workers for evacuation actions, and for protective equipment. measures for crane operators.

4.3.2.1.7 Large Release of UF, to Atmosphere (Primary System Integrity) a.

Scmario_Descristien l

During the above atmospheric pressure operating mode, various primary system failures may result in a large release of UF. within the process buildings. These failures can be initiated by a pressure increase event (see Section 4.3.2.1.3) or a primary system integrity failure event (see Section 4.3.2.1.4).

The frequency of the large UF. release to atmosphere event is an EBE. This categorization is based on cascade operatmg experience and the low frequency of an AE progressing to the point of a large release.

A large release of UF. event was evaluated in the PrHA, and it was determined that the l consequences could include significant on-site and off-site impact in the above atmospheric pressure operating mode if no mitigation were provided.

The primary concem associated with this event is controlling the UF release. The applicable EGs 6

(see Table 4.2 2) associated with this event are all the EGs for the EBE frequency range. EG 3 is not O

4.3 52 l

)

u

i SAR-PGDP PROPOSED June 30,1999 i

RAC 97Cl23 (RI), 99C028 (RO)

  • ~

applicable cells, (3) temporary holdup of the release by the existing process building structure, and (4) training of on-site personnel to evacuate areas upon detection of a release by sight or by odor. The first essential control is to detect the release of UF.. Equipment that has the potential for causing a large release (i.e., "00" or "000" building compressors which are intended to operate above atmospheric pressure) are equipped with UF. release detection that alarms in the applicable ACR. Other portions of the cascade do not have operating pressures or inventories sufficient to result in any significant consequences outside the building, and this receptor would not be applicable (see Section 4.2.6.4). The second essential control, is for_ operators to trip the appropriate cell (s) to reduce the pressure and minimize the release of UF.. The shutdown of a cell (s) will decrease the cell (s) high side pressure to about one-half the normal operating pressure, which will bring the cell (s) uniformly below atmospheric pressure. Pressure at an interbuilding booster compressor can be reduced, if needed, by tripping the compressor motor or by tripping adjacent enrichment cell compressor motors. Once the pressure has dropped to atmospheric pressure or below, the release of material is effectively terminated for any potential exposure outside the process building. Sufficient time is then available to perform any necessary valve evolutions to isolate the cell. The third essential control, process building holdup, is provided by the existing process building structure. The process building structure is expected to reduce the potential hazardous material concentrations to receptors outside of the building by holdup of a portion of the UF.

released, and by causing most of the UF that escapes the building to be released via the exhaust and roof vents flush with the top of the building. If workers outside of the process building have received no other instructions for action to be taken (i.e., shelter in place or take cover), then the essential control for these receptors is to evacuate their areas if a release is detected by sight or by odor.

O os-site Fuefic - 8ecause this event. as described. ceeid ievoive a sisnificaet UF. reiease. a scenario is presented that indicates how much material is required to be released at the assumed conservative flow rate to result in the 30 mg U exposure at the nearest site boundary. For the worst-case conditions, the results indicate that it takes about 31,200 lb (14,165 kg) of UF. to reach a 30 mg U exposure at the nearest site boundary. With the conservative release rate assumed, this would result in a release time of about 4 min. The large UF. release to atmosphere event is characterized by the B-stream block valve closure event. The large UF release to atmosphere event ignores the time required to reach a 40-psia (0.27-MPa) cascade pressure, at which the primary system is assumed to fail (about 2.5 min, see Section 4.3.2.1.3). This extra time would allow the operator even more time to react to the event (i.e., about 6.5 min to trip the compressors for the worst case assumptions). There is sufficient time for operator response based on operator presence near the controls when this event'is expected to occur. In addition, with any quicker response time, different wind conditions, ventilation system settings, or variations in the wake effects, the resulting consequences would be below the guidelines.

d.

Comnarison With Guidelines For workers in the immediate area, specific exposures were not calculated because of variables and uncertainties associated with the calculations and because of obvious evacuation actions that would be taken by the worker. However, the controls identified (i.e., see and flee, and PPE or other protective measures for crane operators) will maintain exposures within EGs 1 and 2 to the extent practical. Actions required of operational personnel in the ACR were evaluated, and they can be accomplished to meet the requirement for EG 6. In the event that the release ultimately affects habitability of the ACR, this receptor would be able to evacuate the area before EGs 1 and 2 are exceeded. In addition, based on the 4.3-63 u

SAR-PGDP PROPOSED June 30,1999 O

RAC 97C123 (RI), 99C028 (RO)

.V controls identified (i.e., release detection, cell trip, building holdup, and evacuation of areas upon detection of a release), EGs 1 and 2 would be met for workers outside the process building. Finally, an analysis was performed to determine the worst-case scenario at which an off-site exposure of 30 mg U would be reached. Results of this analysis indicated that the operator action could be accomplished within the time frame to meet the EGs.

e.

Summary of SSCs and TSR Controls Based on the results of this analysis, the essential controls for the large UF. release to atmosphere event are summarized as follows:

Compressor motor manual trip in ACR-minimize release for all receptors except local worker (EGs 1,2, and 6);

UF release detection system for cells operating above atmospheric pressure-all receptors except local worker (EGs 1,2, and 6);

Equipment housing holdup for compressors operating above atmospheric pressure-off-site public (EGs 1 and 2);

Visual / odor detection of release, worker training, and evacuation of affected area-all on-site workers (EGs I and 2);

Administrative control-personal protective equipment (PPE) or other protective measures shall be available to personnel operating process building cranes (EGs 1 and 2); and i

g Process building holdup-workers outside process building and the off-site public (EGs 1 and 2).

V Based on the above essential controls, the resulting important to safety SSCs and TSRs are as follows:

l*

The compressor motor manual trip systems, UF release detection system, equipment housings, and process buildings are identified as important to safety SSCs. See Section 3.15 for details including safety classification.

l*

TSRs are provided for the cell trip system; UF release detection system; and admirdstrative 6

requirements for procedures and training of workers for evacuation actions, and for protective equ;pment/ measures for crane operators.

4.3.2.1.8 Heavy Equipment Drop (Primary System Integrity) a.

Scenario Descriotion During process building operations, the change-out of cascade equipment for maintenance requires that heavy equipment (converters, compressors, valves, etc.) occasionally be moved over operating cells by overhead building cranes and lifting fixtures. If this equipment should be dropped because of a failure of the crane or lifting rig, the primary system could be breached, and UF released if the cell is operating above atmospheric pressure. The fall of a crane itself is not considered a credible release initiator. The cranes that are normally parked over cascade equipment have been shown to be seismically qualified in this position (see Section 3.15). The greatest potential for a UF release would be from a drop of a converter on a B-bypass line operating at the maximum operating pressure. The heavy equipment drop 4.3-64

SAR-PGDP PROPOSED June 30,1999 RAC 97Cl23 (RI), 99C028 (RO) event has been assigned to the EBE frequency category. The assignment is justified because there is no historical precedent for a release of UF. as a result of such an event, and controls such as design and inspections placed on the cranes and lifting fixtures and operating procedures are in place to prevent the event.

Dropping of heavy equipment was evaluated in the PrHA and it was determined that if no mitigation were provided, the potential consequences could include (1) significant off-site and on-site

{

. l impact in the above atmospheric pressure mode, or (2) significant on-site impact in the freeze, sublime, hot standby, or modified hot standby modes for the freezer / sublimer process.

The primary concern associated with this event is controlling the UF. release. The applicable EGs j

(see Table 4.2-2) associated with this ev:nt are all the EGs for the EBE frequency range. EG 3 is not i

addressed because a primary system breach is assumed to occur. The safety actions of (1) primary system leakage detection, (2) primary system pressure control (to reduce the primary system pressure and minimize the UF. release), and (3) building holdup would be required to maintain the effects of the UF.

release within EGs 1 and 2. These actions protect on-site personnel and the off-site public and will maintain habitability of the required control area in accordance with EG 6 as well.

The heavy equipment drop evem was chosen as a limiting event in the EBE category because of i

k Wfferent controls required to detect the potential release of UF quickly, 6

b, Source-Tarm Analisis

.O in order for a heavy equipment drop event to produce a significant release of UF. to the atmosphere, the breaches must be in cells or equipment operating above atmospheric pressure. Breaches l of this type at sub-atmospheric pressure will result in inleakage to the cascade with minimal loss of UF..

l This event has the potential to completely sever a B-line (or significantly damage other equipment), which could result in initial release rates exceeding those indicated for the large UF. release to atmosphere (Section 4.4.2.1.1.7) event. If the event were to damage a freezer / sublimer, the source term is bounded by the cascade above atmospheric operating mode case. Therefore, the remainder of the discussion will focus on the event affecting equipment operating in the cascade above atmospheric operating mode. If a B-line at maximum operating pressure were to be completely severed, the suction side of the break would initially depressurize to atmospheric pressure at which time air would be pulled into the suction l

side of the compressor. This will cause the compressors in the vicinity of the break to surge, thereby

{

reducing their pumping ability and significantly reducing the ability of the compressors to continue I

operating or to sustain the high initial release rate. Also, as long as the compressors continue to operate,

)

the air would be mixed with the UF in the cascade in the vicinity of the break, reducing the release of UF. by diluting the released stream.

Because of the potential for a large initial release rate, the following administrative controls are required to ensure early detection and mitigation of the event. In process buildings containing equipment that is operating above atmospheric pressure:

o 4.3-65 J

c SAR-PGDP h

w

-e June 30,1999 q

RAC 97Cl23 (RI), 99C028 (RO)

V Workers outside the process buildings - The essential controls for protecting on-site personnel outside the process buildings are (1) detection J the release, (2) minimization of the release by tripping applicable cells, (3) temporary holdup of the release by the exbting process building structure, and (4) l training of on-site personnel to evacuate areas upon detection of a release by sight or by odor. The first essential control is to detect the release of UF. This control will be accomplished quickly based on the 6

previously defined administrative controls. The second essential control, is for operators to trip the appropriate cell (s) to reduce the pressure and minimize the release of UF, The shutdown of a cell (s) will i

decrease the cell (s) high side pressure to about one-half the normal operating pressure, which will bring the cell (s) uniformly below atmospheric pressure. Pressure at an interbuilding booster compressor can be reduceo, if needed, by tripping the compressor motor or by tripping adjacent enrichment cell compressor motors. Once the pressure has dropped to atmospheric pressure or below, the release of l material is effectively terminated for any potential exposure outside the process building. Sufficient time l is then available to perform any necessary valve evolutions to isolate the cell. The third essential control, I

process building holdup, is provided by the existing process building structure. The process building structure is expected to reduce the potential hazardous material concentrations to receptors outside of the building by holdup of a portion of the UF released, and by causing most of the UF that escapes the 6

6 l building to be released via the exhaust and roof vents flush with the top of the building. If workers outside of the process building have received no other instructions for action to be taken (i.e., shelter in place or take cover), then the essential control for these receptors is to evacuate their areas if a release is detected by sight or by odor.

Ofsitepublic-The source term for the heavy equipment drop event is bounded by the source term for the large UF release to atmosphere event (Section 4.3.2.1.7). The essential controls for 6

mitigating the heavy equipment drop event are the same as those described for the large UF release to 6

atmosphere event, with the addition of the controls associated with crane operation / inspection, and with the exception of the UF release detection system and equipment housing hold-up. Based on these controls and the analysis presented for the large UF release to atmosphere event, operator actions can be 6

accomplished in sufficient time to preclude exceeding off-site EGs.

d.

Comparison With Guidelines 1

For workers in the immediate area, specific exposures were not calculated because of variab!"

and uncenainties associated with the calculations and because of obvious evacuation z.ctions that would be taken by the worker. However, the controls identified (i.e., see and flee, and PPE or other protective measures for crane operators)will maintain exposures within EGs 1 and 2 to the extent practical. Actions required of operational personnel in tha ACR were evaluated, and they can be accomplished to meet the requirement for EG 6. In the event that the release ultimately affects habitability of the ACR, this receptor would be able to evacuate the area before EGs 1 and 2 are exceeded. In addition, based on the controls identified (i.e., release detection, cell trip, building holdup, and evacuation of areas upon detection of a release) and the analysis presented for the large UF release to atmosphere event (Section 6

4.3.2.1.7), EGs 1 and 2 would be met for workers outside the process building. Finally, based on the analysis presented for the large UF release to atmosphere event, the essential operator actions could be 6

accomplished in sufficient time to preclude exceeding off-site EGs.

O 4.3-67

SAR-PGDP '

PROPOSED June 30,1999 RAC 97Cl23 (RI). 99C028 (RO) e.

Summary of SSCs and TSR Controls The essential controls for the heavy equipment drop event are the same as those described for the

. large UF. release to atmosphere event (Section 4.3.2.1.7), with the addition of the controls associated with crane operation / inspection, and with the exception of the UF. release detection system and equipment s

housings. The essen:ial controls for the applicable receptors are summarized as follows:

Crane equipment is inspected at appropriate intervals and for obvious defects before each use-initial condition (EG 5);

In process buildings where equipment is operating above atmospheric pressure, ACR operating personnel informed of time and travel path of equipment being moved overhead of cells prior to such movements-pre-notification of potential operational problems (EGs 1, 2, and 6);

In process buildings where equipment is operating above atmospheric pressure, perso.inel, other than the crane operator, are present during the movement, will be in visual contact with the equipment being moved, and will be able to contact ACR personnel should an event occur-notification to ACR personnel (EGs !,2 and 6);

Compressor motor manual trip in ACR-minimize release for all receptors except local worker (EGs 1,2, and 6);

l Visual / odor detection of release, worker training, and evacuation of affected area-all on-site workers (EGs I and 2);

j Administrative control-personal protective equipment (PPE) or other protective measures shall j

be available to personnel operating process building cranes (EGs 1 and 2); and O

Proc 8 iiai 8 8eidee-or* r e=rsia Proc 8#iiai=8 a the err-ite pebiic (EGs i and 2).

j Based on the above essential controls, the resulting important to safety SSCs and TSRs are as follows:

l*

The compressor motor manual trip systems, process building cranes, and process buildings are identified as important to safety SSCs. See Section 3.15 for details including safety classification.

l*

TSRs are provided for the cell trip system; and administrative requirements for procedures and i

training of workers for evacuation actions, and for protective equipment / measures for crane operators.

4.3.2.1.9 Large Fire (External Event) a.

Scenado Descrintion Durmg any of the cascade facility processes and their associated operating modes, vuious types

- of fires could occur. The hazard analysis identified the enrichment cascade and the freezer / sublimer (F/S) processes as having the most potential for significant consequences. The withdrawal facilities located in the process buildings were also considered in this event. Other processes are limited in quantity of material and pressures such that no significant impact would occur, even if primary system integrity is i

lost. Other hazards of concern in a fire would be the potential for criticality due to the loss of primary system integrity and subsequent moderation from the fire protection system. Criticality concerns are addressed in Section 5.2 and in Section 4.3.2.6. The fire protection program is described in Section 5.4.

4.3-68

i TSR-PGDP PROPOSED June 30,1999 RAC 99CO28 (RO)

O i

TECHNICAL SAFETY REQUIREMENTS FOR PADUCAH GASEOUS DNFUSION PLANT O

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UNITED STATES ENRICHMENT CORPORATION PADUCAH GASEOUS DIFFUSION PLANT

TSR-PGDP June 30,1999 O

a^c 99co28 <no)

TABLE OF CONTENTS (Continued)

Pace 2.4.2 SAFETY LBIITS...........................

2.4-3 2.4.2.1 FREEZER /SUBLBIER UF. WEIGHT LBilT..

2.4-3 2.4.2.2 COOLANT (R-114) OVERPRESSURE PROTECTION SYSTEMS.........................

2.4-3 2.4.2.3 CASCADE PRESSURE LBIIT............

2.4-5 2.4.3 LBiITING CONTROL SETTINGS, LBIITING CONDITIONS FOR OPERATION, SURVEILLANCES.............

2.4-6 2.4.3.1 FREEZER /SUBLBIER HIGH-HIGH WEIGHT TRIP SYSTEM..........................

2.4-6

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2.4.3.2 FREEZER /SUBLBIER UF, VENT LINE MANUAL BLOCK VALVE.....................

2.4-8 2.4.3.3 FREEZER /SUilLIMER R-114 VENT LINE MANUAL 1

BLOCK VALVE.....................

2.4-9 2.4.3.4 R-114 COOLANT OVERPRESSURE CONTROL S YSTEM.........................

2.4-10 2.4.3.5 INTERMEDIATE GAS REMOVAL HIGH TEMPERATURE CONTROL SYSTEM.....

2.4-13 2.4.4 GENERAL LBIITING CONDITIONS FOR OPERATION, 2.4-14 2.4.4.1 UF, RELEASE DETECTION SYSTEM......

2.4-14 O

2.4.4.2 cRITicitIrY iCC1DENr itiRM SYSTEM. 2.4 12 2.4.4.3 CASCADE EQUIPMENT ASSAY LBIITATIONS 2.4-21 2.4.4.4 CASCADE WET AIR INLEAKAGE........

2.4-22 2.4.4.5 FIRE PROTECTION SYSTEM - BUILDING SPRINKLER SYSTEM................

2.4-26 2.4.4.6 FIRE PROTECTION SYSTEM - HIGH PRESSURE FIRE WATER DISTRIBUTION MAINS.....

2.4-29 2.4.4.7 FIRE PROTECTION SYSTEM - WATER SUPPLY B ASIN............................

2.4-31 i

2.4.4.8 FIRE PROTECTION SYSTEM - HIGH PRESSURE FIRE WATER PUMPS................

2.4-33 2.4.4.9 FIRE PROTECTION SYSTEM - HIGH PRESSURE FIRE WATER STORAGE TANK.........

2.4-3 6 2.4.4.10 FIRE PROTECTION SYSTEM - HOT WORK LBIITATIONS.....................

2.4-38 2.4.4.11 CASCADE PRESSURE LBIITATION......

2.4-39 2.4.4.12 CASCADE CELL TRIP FUNCTION.......

2.4-41 2.4.4.13 HEAVY EQUIPMENT HANDLING........

2.4-44 2.4.4.14 HEATING UF, PLUGS................

2.4-45 2.4.4.15 MOTOR LOAD INDICATORS..........

2.4-45a l

2.4.5 GENERAL DESIGN FEATURES...............

2.4-45b

]

2.5 SPECIFIC TSRs FOR EQUIPMENT REMOVAL ACTIVITIES..

2.5-1 O

x

TSR-PGDP PROPOSED June 30,1999 RAC 99C028 (RO)

Q of how long that condition may have previously existed. All V

completion times within a single row of an LCO table are measured from the point of discovery of that condition.

If a Completion Time requires periodic performance on a "once per..." or "every hour thereafter..." basis, the 25 % time interval extension specified in the Note to TSR USE and APPLICATION Section 1.3 applies to each performance after the initial performance. For Completion Times specified as "once," the 25% time interval extension does not apply.

f.

Equipment removed from service or declared inoperable to comply I

with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This i

is an exception to 1.6.2.2.b. for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

g.

Verification of OPERABILITY, as mandated in ACTION statements, l

may be accomplished by reviewing surveillance records or status boards l

to ensure that applicable equipment is operable or has not been declared l

g p

inoperable. Systems and components are assumed to be operable when l

l C) the associated SURVEILLANCE REQUIREMENTS have been met.

l However, this specification is not to be constmed as implying that l

systems or components are operable when:

l (1)

The systems or components are known to be inoperable, l

although still meeting the SURVEILLANCE l

REQUIREMENTS, or l

(2)

The requirements of the surveillance (s) are known not to l

be met between required surveillance performance.

{

1.6.3 SURVEILLANCE REQUIREMENTS 1.6.3.1 SURVEILLANCE REQUIREMENTS shall be met prior to entering the OPERATIONAL MODES or other conditions specified in the Applicability statement for individual LCS and LCOs unless otherwise stated in an individual SURVEILLANCE REQUIREMENT.

1.6.3.2 Each SURVEILLANCE REQUIREMENT shall be performed in accordance with Section 2 and within the maximum time interval defined in Section 1.3. Surveillances do not have to be performed on SSCs which n

are not in, or being prepared to enter, the applicable operating mode (s).

v 1.0-8 m

TSR-PGDP PROPOSED RAC 99CO28 (RO).

June 30.1999 1.6.3.3 Failure to perform a SURVEILLANCE REQUIREMENT within the

,O-maximum acceptable time interval constitutes a failure to meet the OPERABILITY requirements for a LBIITING CONDITION for OPERATION, Exceptions are stated in the individual requirements.

I When it is discovered that a surveillance has not been performed within the maximum acceptable time interval for the frequency specified in Section 2, perform the following within either 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified frequency (whichever is less) of discovery:

a.

Perform the required surveillance, or b.

Place the equipment in an operating mode for which the system is not required.

In instances where inoperability is declared due to missed surveillances, this general usage action statement takes precedence over the facility-specific LCO action statement. In the event that the missed surveillance is not performed within the interval provided by this general LCO, the action steps associated with system inoperability shall be immediately initiated in accordance with the facility-specific LCO.

1.6.3.4 Entry into an OPERATIONAL MODE or other specified condition shall

(]

not be made unless the SURVEILLANCE REQUIREMENT (s) l associated with the LIMITING CONDITION for OPERATION has been performed within the stated surveillance interval or as otherwise specified in the individual surveillance requirements. This provision shall not prevent passage through or to OPERATIONAL MODES as required or allowed by ACTION statements.

Exceptions are stated in the individual requirements.

1.6.4 CONDITIONS OUTSIDE TSR In an emergency, if a situation develops that is not addressed by the TSR, operations personnel should use their training and expertise to take actions to correct or mitigate the situation. Also, operations personnel may take actions that depart from a requirement in the TSR provided that: (a) an emergency situation exists; (b) these actions are needed immediately to protect the public and employee health and safety; and (c) no action consistent with the TSR can provide adequate or equivalent protection. Such actions must be approved by the Incident Commander as defined in the Emergency Plan. If emergency action is taken, both a verbal and written notification shall be made in accordance with 10 CFR 76.120.

O 1.0-9

i i

l TSR-PGDP PROPOSED June 30,1999 RAC 99C028 (RO)

SECTION 2.4 SPECIFIC TSRS FOR ENRICHMENT CASCADE FACILITIES 2.4.2 SAFETY LBIITS 1

2.4.2.1 FREEZER /SUBLBIER UF WEIGHT LIMIT 6

SL 2.4.2.1:

10MW Vessel: The UF weight shall not exceed 11,900 pounds.

6 20MW Vessel: The UF weight shall not exceed 22,400 pounds.

6 l

APPLICABILITY: Modes: All F/S Modes BASIS:

The potential exists for the stress rupture of the freezer / sublimer vessel or R-114 tubes due to i

the overfilling of the freezer / sublimer vessel with UF and subsequent reheating. Studies have 6

shown that limiting freezer / sublimer UF inventory to 11,900 pounds or less for a 10MW 6

freezer / sublimer, and 22,400 pounds for a 20MW vessel, is sufficient to prevent bridging of solid UF between adjacent R-114 tubes or between R-114 tubes and the vessel during the freeze 6

j mode of operation. Absence of bridging removes the danger of stress rupture of the R-114 tubes or the freezer / sublimer vessel (due to thermal expansion of the UF ) during the sublime mode 6

of operation. [SAR Section 3.15.3.5.3]

l i

2.4.2.2 COOLANT (R-114) OVERPRESSURE PROTECTION SYSTF3fS O

SL 2.4.2.2: Coolant pressure shall not exceed the values specified in the following table:

Equipment Specification Safety Limit (psig)

C-331, C-333, C-335, and C-337 Cascade 330 (300 psig MAWP)

Cell Coolant C-337 "B" Boosters, C-331 and C-335 330 (300 psig MAWP)

Surge and Waste Boosters C-335 "A" Boosters, C-333 "B" Booster, 330 (300 psig MAWP)

C-331 #3 Low Speed P&E Pump, C-331 and C-333 High Speed P&E Pumps, C-335 and C-337 Dual Speed P&E Pumps C-310 Cascade Cell Coolant 220 (200 psig MAWP)

C-331 "A" Booster, C-331 #1&#2, C-333, 220 (200 psig MAWP) and C-337 Low Speed P&E Pumps APPLICABILITY: Modes: All Cascade Modes O

2.4-3

TSR-PGDP PROPOSED June 30,1999 RAC 99CO28 (RO)

SECTION 2.4 SPECIFIC TSRS FOR ENRICHMENT CASCADE FACILITIES 2.4.2 SAFETY LIMITS 2.4.2.2 COOLANT (R-114) OVERPRESSURE PROTECTION SYSTEMS (continued)

BASIS:

Overpressurization and rupture of the coolant system into the UF system could result in the 6

subsequent loss of UF containment due to overpressurization of the UF enrichment system.

6 6

There is reasonable assurance the integrity of the coolant system will not be breached at the ASME Boiler and Pressure Vessel (B & PV) Code,Section VIII, maximum allowable pressure during the relief transient (110 percent of the Maximum Allowable Working Pressure [MAWP])

[SAR Section 3.15.3.4.3].

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2.4-4

TSR-PGDP PROPOSED June 30,1999 RAC 99C028 (RO)

SECTION 2.4 SPECIFIC TSRS FOR ENRICHMENT CASCADE FACILITIES b

2.4.3 LBIITING CONTROL SETTINGS, LBIITING CONDITIONS FOR OPERATION, SURVEILLANCES 2.4.3.1 FREEZER / SUBLIMER HIGH-HIGH WEIGHT TRIP SYSTEM (continued)

SURVEILLANCE REQUIREMENTS:

Surveillance Frequency SR 2.4.3.1-1 10MW Vessel: Test the freezer / sublimer high-Quarterly high weight trip system to verify that each detection / initiation channel will activate and place the freezer / sublimer in the modified hot I

standby mode at or below 10,000 pounds net weight.

SR 2.4.3.1-2 20MW Vessel: Test the freezer / sublimer high-Quarterly high weight trip system to verify that each detection / initiation channel will activate and place the freezer / sublimer in the modified hot standby mode at or below 20,000 pounds net weight.

O SR 2.4.3.1-3 Calibrate the freezer / sublimer high-high weight Annually trip system detection / initiation instrumentation, j

)

BASIS:

The potential exists for the stress rupture of the R-114 tubes due to the overfilling of the freezer / sublimer vessel with UF and subsequent reheating. For this reason, the freezer / sublimer 6

systems have dual weight monitoring systems designated as safety systems. Upon activation of I

the high-high weight trip, the freezer / sublimer system will automatically be placed in the modified hot standby mode, thus precluding any additional accumulation of material. [SAR l

Section 3.15.3.5.3]

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2.4-7

TSR-PGDP PROPOSED RAC 99C028 (RO)

June 30,1999 SECTION 2.4 SPECIFIC TSRS FOR ENRICHMENT CASCADE FACILITIES O

2.4.3 LIMITING CONTROL SETTINGS, LIMITING CONDITIONS FOR OPERATION, SURVEILLANCES 2.4.3.2 FREEZER / SUBLIMER UF VENT LINE MANUAL BLOCK VALVE LCO 2.4.3.2:

The freezer / sublimer UF vent line manual block valve shall be seajed in the open position.

~

l APPLICABILITY: Modes: F/S 1, F/S 3, F/S 5 l

ACTIONS:

Condition Required Action Completion Time A.

The UF vent line manual A.1 Ensure the valve is Immediately.

block valve is discovered open.

unsealed and/or closed.

B.

Action item A satisfactorily B.1 Reseal the valve.

8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> completed.

C.

Action item A or action item C.1 Place the Immediately B not satisfactorily freezer / sublimer in b,

completed, mode F/S 6.

SURVEILLANCE REQUIREMENTS:

Surveillance Frequency SR 2.4.3.2-1 Visually inspect the UF vent line manual block Quarterly 6

valve to verify it is sealed open.

BASIS:

Any noncondensible gases are allowed to return to the cascade cell "A" bypass through one-inch automatic UF vent valve and a two-inch vent line. If *he automatic UF vent valve fails to 6

6 open, a rupture disc is provided as a means of pressure relief for the UF side of the 6

freezer / sublimer. Without the manual vent valve open to the rupture disc and the automatic vent valve, this relief protection for the freezer / sublimer is not provided.

l The block valve is sealed open, except for maintenance, to assure the rupture discs are exposed to system pressure. This assures the availability of the pressure relief system to activate in the presence of unwanted pressure [SAR Section 3.15.3.4.3].

l nV 2.4-8

)

t TSR-PGDP 5

PRO 10 SED Iune 30,1999 RAC 99C028 (RO)

~

SECTION 2.4 SPECIFIC TSRS FOR ENRICHMENT CASCADE FACILITIES n

2.4.3 LBIITING CONTROL SETTINGS, LBIITING CONDITIONS FOR OPERATION, SURVEILLANCES i

2.4.3.3 FREEZER / SUBLIMER R-114 VENT LINE MANUAL BLOCK VALVE 4

LCO 2.4.3.3: The freezer / sublimer R-114 vent hne manual block valve shall be sealed in the open, position.

APPLICABILITY: Modes: F/S 1, F/S 3 ACTIONS:

i Condition Required Action Completion Time A.

The R-114 vent line manual A.1 Ensure the valve is Immediately, block valve is discovered open.

unsealed and/or closed.

B.

Action item A satisfactorily B.1 Reseal the valve.

8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> completed.

C.

Action item A or action item C.1 Place the Immediately B not satisfactorily freezer / sublimer in df-.

completed.

mode F/S 6.

SURVEILLANCE REQUIREMENTS:

Surveillance Frequency SR 2.4.3.3-1 Visually inspect the R-114 vent line manual Quarterly block valve to verify it is sealed open.

BASIS:

The block valve is sealed open, except for maintenance, to assure the rupture discs are exposed to system pressure. This assures the availability of the pressure relief system to activate in the presence of unwanted pressure. [SAR Section 3.15.3.4.3]

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2.4-9

TSR-PGDP PROPOSED June 30,1999 RAC 99C028 (RO)

SECTION 2.4 SPECIFIC TSRS FOR ENRICHMENT CASCADE FACILITIES OV 2.4.3 LIMITING CONTROL SETTINGS, LIMITING CONDITIONS FOR OPERATION, SURVEILLANCES 2.4.3.4 R-114 COOLANT OVERPRESSURE CONTROL SYSTEM (continued)

SURVEILLANCE REQUIREMENTS:

Surveillance Frequency SR 2.4.3.41 Visually inspect the R-114 cell coolant Quarterly overpressure control system manual isolation valve to ensure it is sealed open.

SR 2.4.3.4-2 Visually inspect the cavity vent port between Quarterly tandem-mounted rupture discs to ensure it is open to atmosphere.

BASIS:

The ASME code requires that overpressure relief be provided by a device stamped at or below the MAWP and sized such that the subsequent transient pressure will be limited to a maximum of 110% of MAWP when a single relief path is used. ASME Boiler and Pressure Vessel (B &

O ev> code aiiows meture discs to have a

  • 55 durst toierance. Rugture discs stamped at MAWP will therefore burst at or below 105% of MAWP. Thus, the LCS is set at 105% of MAWP. To comply with these standards, pressure relief devices are purchased and installed on the cascade cell coolant condensers with stamped ratings at or below the MAWP. [SAR Section 3.15.3.4.2]

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2.4-12

TSR-PGDP PROPOSED June 30,1999 RAC 99C028 (RO)

SECTION 2.4 SPECIFIC TSRS FOR ENRICHMENT CASCADE FACILITIES O

j 2.4.4 GENERAL LIMITING CONDITIONS FOR OPERATION 2.4.4.1 UF RELEASE DETECTION SYSTEM (continued) 6

' SURVEILLANCE REQUIREMENTS:

Surveillance Frequency SR 2.4.4.1-1 " Test fire" the UF release detection system Twice each shift.

)

heads.

SR 2.4.4.1-2 Physically actuate (" smoke test") the UF Annually

)

6 release detector heads to verify alarms.

BASIS:

- The reaction of UF and water (free atmospheric humidity) in the case of a UF release produces 6

uranyl fluoride (UO F ) as particulates and hydrogen fluoride (HF) as a gas which will hydrate.

22 The UO:F and HF*x(H O) are highly visible as " smoke." This system detects the presence of 2

2 this " smoke" and sounds alarms in the ACR.

In the event of a failure of the UF release detection system, the stationing of an operator at the 6

affected equipment would assure monitoring of the system to determine if any outleakage of UF6 occurs and would provide the surveillance capability until the system could be repaired or the U

UF process equipment brought below atmospheric pressure. The real safety hazard is when UF l

6 6

is released into the area inhabited by plant personnel. UF released inside the heated housing is not of significant safety concern unless it leaks from the (non-air-tight) housing. Thus, a smoke watch posted outside the housing, watching for " smoke" escaping the heated housing into the occupied spaces, is capable of providing an adequate level of safety.

Firing the heads at least once in an eight-hour interval will maintain sensitivity of the heads in elevated temperatures such as that found in the cell housings. Detector heads are fired by l

supplying voltage to the head until it alarms. This can be done by suppling voltage sufficient to fire the detector head. The firing of the heads will be recorded; this action discovers heads which are failed.

. Normal operational pressure transients may temporarily take the local process pressure to a value consistent with mode Cascade 2 values. These pressure transients typically work their way through those portions of the cascade that, by the optimized gradient, operate at mode Cascade

~

1 pressures quickly. This LCO is not intended to require UF release detection operability to 6

accommodate these transients. Instead, this LCO is intended to require system operability prior to intentionally increasing cascade pressure to mode Cascade 2 values.

The cell bypass is perpendicular to cells and traverses the length of the individual unit.

" Defined section" means that portion of the cell bypass housing between any pair of opposite cells. Opposite cells are defined as 1 and 2,3 and 4,5 and 6, etc.

O 2.4-15

TSR-PGDP PROPOSED June 30,1999 RAC 99C028 (RO)

SECTION 2.4 SPECIFIC TSRS FOR ENRICIBIENT CASCADE FACILITIES 2.4.4 GENERAL LIMITING CONDITIONS FOR OPERATION 4

2.4.4.1 UF, RELEASE DETECTION SYSTEM (continued)

BASIS (continued):

The unit bypass are perpendicular to the cell bypasses. " Defined section" of the unit bypass means that portion of the unit bypass between centerlines of adjacent units or from the centerline of the first or the last unit to the end of the housing. [SAR Section 3.15.7.3, 4.3.2.1.1, 4.3.2.1.2, 4.3.2.1.3, 4.3.2.1.7)

O O

2.4-16

i TSR-PGDP PROPOSED June 30,1999 PAC 99C028 (RO)

SECTION 2.4 SPECIFIC TSRS FOR ENRICIIMENT CASCADE FACILITIES A

2.4.4 GENERAL LIMITING CONDITIONS FOR OPERATION 2.4.4.2 CRITICALITY ACCIDENT ALARM SYSTEM (continued)

SURVEILLANCE REQUIREMENTS:

Surveillance Frequency SR 254.4.2a-1 Calibrate CAAS system equipment.

Annually BASIS:

The CAAS is used to warn plant personnel of a criticality or radiation accident. This system is designed to detect radiation and provide a distinctive, audible signa! which will alert personnel to move from those work areas which are potentially affected. The design of the system, three detector modules per cluster, provides protection for criticalit,. events even with panial losses of required equipment. The CAAS also nrovides detection coverage in most areas by using an overlapping pattern of individual cluster units. Criticality concerns with the cascade involve freeze-out of UF and moderator introduction. The action items maintain the cascade in steady 6

state operations to limit the potential for these concerns to the extent possible. Ce'asing the movement of fissionable waste prevents a criticality associated with waste storage. Providing p

another means of coverage (i.e., portable detector / alarm, personal alarm device, etc.), restricting operations, or restricting access to the area in the event of the loss of detection will establish x

protection. [SAR Sections 3.15.7.1 and 4.3.2.6]

l e

/%

2.4-18

TSR-PGDP PROPOSED June 30,1999 RAC 98C149 (RO), 99C028 (RO) 9 SECTION 2.4 SPECIFIC TSRS FOR ENRICHMENT CASCADE FACILITIES 5

2.4.4 GENERAL LIMITING CONDITIONS FOR OPERATION 2.4.4.2 CRITICALITY ACCIDENT ALARM SYSTEM (continued)

BASIS (continued):

another means of coverage (i.e., portable detector / alarm, personal alarm device, etc.), restricting operations, or restricting access to the area in the event of inaudibility will establish protection.

l

[SAR Sections 3.15.7.1 and 4.3.2.6]

l The CAAS air accumulators provide for 120 seconds of horn actuation when at their minimum acceptable pressure based on the number of accumulators in service. Electronic horns are also installed in some areas. These horns have battery backup power supplies which will provide for at least 120 seconds of horn actuation even if off-site power is lost.

The quarterly surveillance of the CAAS building horns consists of placing the cluster in the test mode with a keyswitch, and m.mually causing two detector modules to generate radiation readings above the alarm setpoint. The cluster electronics determines that this mee*.s the high radiation alarm criteria and propagates a high radiation alarm signal to the rest of the system. This signal activates the high radiation alarm light and bell in C-300 and activates the building CAAS horns and lights. Each horn and light is qualitatively verified to be operating. This test is a horn and light functional test and each module combination is tested to generate the high radiation signal.

d,m 2.4-20a

I TSR-PGDP PROPOSED June 30,1999 RAC 98C149 (RO), 99C028 (RO)

SECTION 2.4 SPECIFIC TSRS FOR ENRICHMENT CASCADE FACILITIES 4

2.4.4 GENERAL LIMITING CONDITIONS FOR OPERATION

- 2.4.4.2 CRITICALITY ACCIDENT ALARM SYSTEM (continued)

SURVEILLANCE REQUIREMENTS:

Surveillance -

Frequency SR 2.4.4.2c-1 Test the CAAS, local cluster horns and building Quarterly

-horns.

SR 2.4.4.2c-2_ Verify that the nitrogen supply pressure to the cluster Quarterly horns is at least 900 psig.

BASIS:

The CAAS is used to wam plant personnel of a criticality or radiation accident. This system is designed to detect radiation and provide a distinctive, audible signal which will alert personnel to move from those work areas which are potentially affected. Evacuation of the area of inaudibility and restricting access to those areas will eliminate the potential for increased consequences due to personnel not hearing an alann. Criticality concems with the cascade involve freeze.out of UF. and moderator introduction. The action items mamtain the cascade in steady state operations to limit the potential for these concerns to the extent possible. Ceasing the movement of fissile waste prevents a criticality associated with waste storage. The design of the system, three detector modules per cluster, provides protection for criticality events even with partial losses of required equipment. The alarm signal is provided by sounding a local horn associated with each individual cluster and building horns which sound upon a signal from any cluster. Providing another means of coverage (i.e., portable detector / alarm, personal alarm device, etc.),

restricting operations, or restricting access to the area in the event of inaudibility will establish protection.

[SAR Sections 3.15.7.1 and 4.3.2.6]

l Ihe nitrogen bottles which backup plant air for the local cluster horns are standard cylinder size 1 A (1.55 5

ft, 9 x 51 inches) and provide for 120 seconds of horn actuation when at their minimum acceptable pressure of 900 psig.

- The quarterly surveillance of the CAAS, local cluster horns and building horns consists of placing the cluster in the test mode with a keyswitch, and manually causing two detector modules to generate radiation readings above the alarm setpoint. The cluster electronics determines that this meets the high radiation alarm criteria and propagates a high radiation alarm signal to the rest of the system. This signal activates the high radiation alat light and bell in C-300, causes the local cluster to sound and activates the building CAAS horns and li,.ts. Each horn and light is qualitatively verified to be operating. This test is a hom and light functionai at and each module combination is tested to generate the high radiation signal.

. O 2.4-20c

TSR-PGDP PROPOSED June 30,1999 RAC 99C028 (RO)

SECTION 2.4 SPECIFIC TSRS FOR ENRICHMENT CASCADE FACILITIES O

2.4.4 GENERAL LBIITING CONDITIONS FOR OPERATION 2.4.4.3 CASCADE EQUIPMENT ASSAY LBIITATIONS LCO 2.4.4.3: Cascade 235U assay shall not exceed the values listed in the table below:

Equipment Assay Limit (wt % 235U) 20-MW Freezer / Sublimer Vessels 2.35 UFdR-114 Separation Unit 1.30 24-inch Alumina Traps 1.80 All other equipment 2.75 or follow NCSA applicable to the facility, operation or item of equipment APPLICABILITY: Modes: All ACTIONS:

Condition Required Action Completion Time l

O

^. Assay exceeds stated itmit.

^.1 Initiate actions to i m m ediateir.

reduce assay.

J SURVEILLANCE REQUIREMENTS:

Surveillance Frequency SR 2.4.4.3-1 Measure product stream assay.

Twice per shift BASIS:

These assay limits keep plant operations within the bounds of existing approved NCS analysis.

[SAR Section 5.2, Appendix A]. Periodic measurement of the product stream assay, which has l

the greatest potential for variation with time, provides reasonable assurance that overall plant assays are within limits.

The on-line machines are point calibrated using an assay sample standard incorporated into the machine. The calibration is essentially continuous, so no periodic calibrations are specified.

2.4-21

l TSR-PGDP PROPOSED June 30,1999 RAC 99C028 (RO)

SECTION 2.4 SPECIFIC TSRS FOR ENRICHMENT CASCADE FACILITIES 2.4.4 GENERAL LIMITING CONDITIONS FOR OPERATION 2.4.4.4 CASCADE WET AIR INLEAKAGE (continued)

BASIS (continued):

" breathing" of the cell will not significantly affect deposit moderation even over a period much longer than the 180 days to which this condition is limited. The daily surveillance demonstrates that the gas blanket is maintained as assumed in the analyses.

The potential for moderation from RCW system water is precluded by the two physical barriers (RCW to coolant and coolant to cascade) and either by maintaining the coolant system pressure greater than the RCW aressure or by draining the coolant condenser.

If the cascade component (s) with the deposit are removed from the cascade, the control of the component (s) is in accordance with the provisions of TSR 2.5 [SAR Section 5.2, Appendix A]

l O

1 O

2.4-25

y TSR PGDP PROPOSED June 30,1999 RAC 99C028 (RO)

SECTION 2.4 SPECIFIC TSRS FOR ENRICHMENT CASCADE FACILITIES

  • 'g 2.4.4 GENERAL LIMITING CONDITIONS FOR OPERATION 2.4.4.5 FIRE PROTECTION SYSTEM - BUILDING SPRINKLER SYSTEM (continued) 1 SURVEILLANCE REQUIREMENTS:

Surveillance Frequency SR 2.4.4.5 Verify control valves in the required flow paths Monthly are open.

SR 2.4.4.5-2 Functionally test each sprinider system.

Annually SR 2.4.4.5-3 Cycle all control valves in the required flow Annually paths.

SR 2.4.4.5-4 Flow test at least one HPFWS fire hydrant Annually adjacent to each process building (distribution system test).

. BASIS:

-Q.

As diens=1 in the SAR accident analysis (Section 4.3.2.1.9), an unmitigated lube oil fire could l

cause failure of the structural steel followed by localized collapse of the stmeture. This collapse could damage process piping allowing a release of UF. A large fire cou:d also cause prunary l

j 6

system failure due to overtemperature. The sprinider system will minimize the potential for, and

[

mitigate the effects of a large fire.

l The high pressure fire protection system (HPFWS) required to mitigate a lube oil fire in the l

enrichment cascade facilities include the automatic wet-pipe sprinider systems in buildings l

C-331, C-333, C-335, and C-337; the HPFWS distribution mains, water storage tank and l

pumps; and the C-631-2 cooling tower basin. The dry pipe sprinkler systems in C-333-A and l

C-337-A are part of the sanitary and fire water system and are not subject to the LCO. They l

are excluded since a fire within the areas protected by these systems would have no impact upon Process piping.

l The sprinkler systems provide primary fire suppression capability for the areas in which they are installed. If a system is not functional or has a closed valve, backup fire suppression will j

be provided by hose streams supplied from fire hydrants located adjacent to the affected

- building. The sprinkler system also provides primary fire detection for the affected areas by j

supplying flow annunciation upon system actuation. Hourly fire patrols will provide backup fire detection capability.

O 2.4-27

TSR-PGDP PROPOSED June 30,1999 RAC 99C028 (RO)

SECTION 2.4 SPECIFIC TSRS FOR ENRICIDIENT CASCADE FACILITIES 2.4.4 GENERAL LIMITING CONDITIONS FOR OPERATION 2.4.4.5 FIRE PROTECTION SYSTEM - BUILDING SPRINKLER SYSTEM (continued)

BASIS (continued):

Surveillance Requirement 2.4.4.5-2 functional tests include the opening of an ITV and a main l

drain flow test. The ITV test simulates the actuation of a single sprinkler head and then verifies that an alarm in C-300 is actuated by the sprinkler system alarm valve. This valve will only alarm on sustained water flow due to a built-in 32-second time delay. The time delay feature

" filters" out flow pulses which might be caused by short-lived pressure transients in the system, and thus only alarms on tme sustained water flow. If the C-300 alarm fails to annunciate within the required time, it could be an indication of either an electrical or mechanical problem. The 90-second response criteria is consistent with NFPA 25 and 72. The ITV and main drain flow tests will also verify that upstream control talves are open and there are no line blockages in the I

system's water supply piping.

Positions ofindicating control valves and seals on non-indicating control valves will be visually verified monthly. Non-indicating valves with missing or broken seals will be cycled and new seals installed. All control valves will be cycled annually. [SAR Section 3.15.7.2]

[

O l

i 4

l t

i 8

U 2.4-28

TSR-PGDP PROPOSED.

June 30,1999

)

RAC 99C028 (RO)

SECTION 2.4 SPECIFIC TSRS FOR ENRICHMENT CASCADE FACILITIES 2.4.4 GENE!!AL LIMITING CONDITIONS FOR OPERATION 2.4.4.6 FIRE PROTECTION SYSTEM - HIGH PRESSURE FIRE WATER DISTRIBUTION MAINS (continued) l SURVEILLANCE REQUIREMENTS:

Surveillance Frequency SR 2.4.4.6-1 Verify sectional valves in the flow paths are Monthly open.

SR 2.4.4.6-2 Cycle all sectional valves in direct flow path.

Annually q

SR 2.4.4.6-3 Flow test at least 1 HPFWS fire hydrant Annually adjacent to each process building (distribution system test).

BASIS:

l All required sprinkler systems have at least two supply paths from the HPFWS pumps through the distribution mains. Hence, the closure of one of the sectional valves in Condition A of this p

TSR will not cause a loss of function of any required sprinider system. If two or more sectional V

valves are closed, the ability to supply water to the required sprinkler systems can be lost. This would be identified by Action B. A temporary water supply will be provided consisting of hoses connected between one or more fire hydrants and the fire department connection (s) on the affected sprinkler system (s). The hoses are to be in place and comiected to satisfy Condition C.

The hoses will only be pressurized with HPFWS water in the event of a fire.

Positions of indicating sectional valves and seals on non-indicating sectional valves will be visually verified monthly. Non-indicating valves with missing or broken seals will be cycled and new seals installed. All sectional valves will be cycled annually. [SAR Sections 3.15.7.2 and l

4.3.2.1.9]

l 2.4-30

TSR-PGDP PROPOSED June 30,1999 RAC 99C028 (RO)

SECTION 2.4 SPECIFIC TSRS FOR ENRICHMENT CASCADE FACILITIES 2.4.4 GENERAL LIMITING CONDITIONS FOR OPERATION 2.4.4.7 FIRE PROTECTION SYSTEM - WATER SUPPLY BASIN (continued)

)

SURVEILLANCE REQUIREMENTS:

Surveillance Frequency SR 2.4.4.7-1 Verify water level in the C-631-2 RCW Monthly cooling tower basin is within 5 feet of the top of the basin.

BASIS:

The C-631-2 RCW cooling tower basin and the wetwell under the C-631 building are connected by a fiume. Their combined volume provides the source of water to all the HPFWS pumps.

They will hold over 4 million gallons of water when the level is within 5 feet of the top of the basin. At this level, the usable volume of water available to HPFWS pumps 2 and 3, which take a suction through the side of the basin, will exceed the 825,000 gallons needed to satisfy maximum system demands of 6,875 gpm for a two hour duration. [ Note: These requirements l

()

are conservative with respect to the system evaluation presented in SAR Section 3.15.7.2].

l l

HPFWS pumps 5 and 6 take a suction from the C-631-1 wetwell. Their suction intakes are at a lower elevation than those of the other two pumps and can draw on mere than 3.5 million gallons of water. If the basin level drops to 15 feet from the top of the basin, the suctions of HPFWS pumps 2 and 3 will be uncovered. However, HPFWS pumps 5 and 6 will still have an adequate water volume to meet the maximum system demands for two hours.

Normal makeup flow to the basin is from the plant water system. If the water drops below the required level and can not be restored by normal makeup, emergency makeup will be irdtiated to dedicate all plant water system output to the basin. If needed, crossover valves can also be opened to supply up to 9,000 gpm from the C-633 basin.

Basin water level is verified by visual observation of a graduated measuring device. [SAR l

Sections 3.15.7.2 and 4.3.2.1.9]

l,

O 2.4-32

TSR-PGDP PROPOSED June 30,1999 RAC 99C028 (RO)

SECTION 2.4 SPECIFIC TSRS FOR ENRICHMENT CASCADE FACILITIES O*

2.4.4 GENERAL LIMITING CONDITIONS FOR OPERATION 2.4.4.8 FIRE PROTECTION SYSTEM - HIGH PRESSURE FIRE WATER PUMPS (continued)

SURVEILLANCE REQUIREMENTS:

Surveillance Frequency SR 2.4.4.8-1 Manually start fire water pumps.

Monthly SR 2.4.4.8 2 Automatic start of fire water pumps on simulated Annually loss of fire system pressure.

SR 2.4.4.8-3 Calibrate the switches that provide the automatic Annually start signals to the HPFWS pumps.

SR 2.4.4.8-4 Verify HPFWS pumps 2, 3,5, and 6 will flow at Annually least 90% of their rated capacity at their rated pressure.

BASIS:

. (]

The HPFWS pumps must be capable of satisfying the maximum sprinkler system and hose stream demands of 4,875 gpm and 2,000 gpm respectively. This results in a combined pumping capacity requirement of 6,875 gpm. [ Note: These requirements are conservative with respect to the system evaluation presented in SAR Section 3.15.7.2]

Pumps 2,3,5, and 6 are rated at 125 psi TDH and have rated capacities of 4,625 gpm,4,625 gpm, 4,500 gpm, and 4,500 gpm respectively. To allow for degradation of the pumps over time, only 90% of the rated pump flow is relied upon to satisfy system flow demands. The two pumps with the smallest flow capacities can supply a combined flow of 8,100 gpm under degraded conditions.

When the HPFWS storage tank is 90% full, it is capable of supplying 2,250 gpm for two hours.

This flow combined with the flow from one degraded HPFWS pump would fall short of satisfying maximum system demand by no more than 575 gpm. The short fall can be addressed by the use of a fire pumper truck taking a suction from a cooling tower basin and discharging through a fire hydrant to the system distribution mains. If such a temporary water supply is needed to satisfy Condition A, the pumper and required hoses / pipes will be pre-positioned. The hoses / pipes will not be filled with water except in the event of a fire.

When only one HPFWS pump is operable, the C-300 operators will manually start the pump upon notification of a fire. This is necessary since the automatic start of the pump would not Q

occur until after the HPFWS storage tank level drops below 40% full.

2.4-34 4

TSR-PGDP PROPOSED June 30,1999 RAC 99C028 (RO)

SECTION 2.4 SPECIFIC TSRS FOR ENRICHMENT CASCADE FACILITIES 2.4.4 GENERAL LIMITING CONDITIONS FOR OPERATION e

2.4.4.8 FIRE PROTECTION SYSTEM - HIGH PRESSURE FIRE WATER PUMPS (contmued)

BASIS (continued):

If no HPFWS pumps are operable or Condition A cannot be satisfied, the off site fire departments will be alerted so they will be ready to provide assistance if needed. Also, temporary sources of pumping capacity will be sought to restore design capacity within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

HPFWS pump 1 is a jockey pump and has a rated capacity of only 200 gpm. It cannot be used to satisfy the TSR Condition Requirements since it will be dead headed when the larger HPFWS pumps are operating. HPFWS pump 4 is not operable and has been abandoned in place.

Levelin the HPFWS storage tank is normally maintained by HPFWS pump 1. If water demand on the system exceeds the capacity of this pump, tank level and system pressure will drop.

Switches in each of the fire pump controllers will automatically start the fire pumps sequentially until the system demand is satisfied. [SAR Sections 3.15.7.2 and 4.3.2.1.9]

l O

1 V, -

2.4-35

k l

TSR-PGDP PROPOSED June 30,1999 RAC 99C028 (RO)

SECTION 2.4 SPECIFIC TSRS FOR ENRICHMENT CASCADE FACILITIES 2.4.4 GENERAL LIMITING CONDITIONS FOR OPERATION 2.4.4.9 FIRE PROTECTION SYSTEM - HIGH PRESSURE FIRE WATER STORAGE TANK (continued)

{

SURVEILLANCE REQUIREMENTS:

Surveillance Frequency SR 2.4.4.9-1 Verify that the HPFWS stonge tank contains at Monthly least 270,000 gallons of water (filled to at least 90% capacity).

SR 2.4.4.9-2 Visual inspection of exterior of HPFWS storage Annually tank.

BASIS:

The pressure in the HPFWS system is maintained by the 300,000 gallon elevated storage tank.

O When the tank is 90% full, it is capable of supplying maximum sprinkler system and hose stream demands of 6,875 gpm [ Note: These requirements are conservative with respect to the l

system evaluation provided in SAR Section 3.15.7.2] for approximately 39 minutes. It is also

[

capable of supplying 2,250 gpm for a duration of two hours which is slightly greater than 32%

of the water required for maximum fire protection demands.

Level in the tank is normally maintained by the 200 gpm capacity HPFWS pump 1. If water demand on the system exceeds the capacity of this pump, tank level and system pressure will drop. Switches in each of the fire pump controllers will automatically start the fire pumps sequentially until system demand is satisfied. [SAR Sections 3.15.7.2 and 4.3.2.1.9]

l b

2.4-37

TSR-PGDP PROPOSED June 30,1999 RAC 99CO28 (RO)

~

SECTION 2.4 SPECIFIC TSRS FOR ENRICHMENT CASCADE FACILITIES 2.4.4 GENERAL LIMITING CONDITIONS FOR OPERATION 2.4.4.11 CASCADE PRESSURE LIMITATION LCO 2.4.4.11 The cascade stage high side pressure shall be s 25 psia.

APPLICABILITY: Modes: Cascade 1,2 ACTIONS:

Condition Required Action Completion Time A.

Cascade stage high side A.1 Establish pressure s Immediately pressure discovered > 25 25 psia, psia SURVEILLANCE REQUIREMENTS j

Surveillance Frequency SR 2.4.4.11-1 Verify operating cells have high-side Daily pressures s 25 psia.

-O sR 2 4 4.11-2 Calibrate unit, cell, and freezer / sublimer Annually datum.

BASIS:

The accident analysis provided in SAR Section 4.3.2.3.2 assumes that cascade high pressure accidents proceed to their conclusion which, in many cases, results in some form of breach in the cascade system. It is at this point that the consequences are evaluated and the identification of any mitigating actions takes place. It should be noted that the cascade was not designed to l

directly measure cell pressures in the ACR or to measure pressures that approach 40 psia.

Motor load and other process indicators in the ACR alert the operator to significant cascade transients which require appropriate actions be taken, including cell shutdown, to preclude cascade pressures from exceeding 40 psia which is the postulated rupture pressure of cascade piping. The monitoring of the cell pressures from the local cell panels is sufficient to ensure that the steady state pressures do not exceed 25 psia. Due to the ability to perform a channel check across the 8 to 10 stage pressure indicating controllers (PICS) per cell and the fact that within an operating cell any stage high side pressure increase will quickly cascade throughout the cell (i.e., raise the other stage high side pressure), it is not necessary that all the PICS are functional to determine the cell pressure. The calibration of the unit, cell, and freezer / sublimer datums will ensure an adequate level of accuracy (cell averaging) and therefore the calibration of individual PICS is not necessary. As part of the cascade h

2.4-39

TSR-PGDP PROPOSED June 30,1999 RAC 99CO28 (RO)

SECTION 2.4 SPECIFIC TSRS FOR ENRICHMENT CASCADE FACILITIES 2.4.4 GENERAL LIMITING CONDITIONS FOR OPERATION 2.4.4.12 CASCADE CELL TRIP FUNCTION LCO 2.4.4.12: The cell trip system for UF stage motors shall be operable.

l l

APPLICABILITY: Modes: Cascade 1 and 2 when stage motors are energized.

ACTIONS:

Condition Required Action Completion Time A.

DC voltage < 210 volts A. ! Notify Cascade Immediately Coordinator of potential need to utilize alternate means of cell shutdowc.

AND A.2 Restore DC voltage to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> 2: 210 volts B.

Required action A. not B.1 Shutdown affected 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> satisfactorily accomplished, cascade cell (s).

M B.2 Verify cell isolation.

C.

Air header pressure feeding a C.1 Notify Cascade immediately group of "000" air circuit Coordiaator of potential breakers is less than the minimum need to utilize alternate required to actuate tLose breakers.

means of cell shutdown.

M C.2 Restore air pressure to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> greater than the minimam required breaker actuation pressure.

D.

Required action C. not D.1 Shutdown affected 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> satisfactorily accomplished.

cascade cel:(s).

M D.2 Verify cell isolation.

E.

Individual battery (cell)/ charger E.1 Restore the individual 90 days l

parameters (other than voltage) battery (cell) parameters for any connected cell are outside to within limits.

limits established in surveillance M

requirements.

E.2 If the AC battery charger 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is inoperable, verify j

applicable battery is 4

operable.

i TSR 1.6.2.2(d) is not w

applicable.

2.4-41 l

l

TSR-PGDP PROPOSED June 30,1999 RAC 99C028 (RO)

\\

r SECTION 2.4 SPECIFIC TSRS FOR ENRICIBIENT CASCADE FACILITIES

[

2.4.4 GENERAL LBilTING CONDITIONS FOR OPERATION 2.4.4.12 CASCADE CELL TRIP FUNCTION (continued) l Condition Required Action Completion Time l

F.

CCF DC bus voltage potential F.1 Verify that Condition A Immediately is< 105 volts DC is not in effect.

AND F.2 Verify that the applicable Immediately ACR compressor motor stop button is operable.

M F.3 Restore CCF DC bus 7 days voltage potential 2105 volts DC.

TSR 1.6.2.2(d) is not 3

applicable.

j G.

ACR compressor motor stop G.1 Verify that the applicable Immediately

)

button for "00" and "000*

CCF compressor motor compressors luoperable (not due stop button is operable.

l n

to loss of DC voltage or air AND d

header pressure for "000* cells).

G.2 Restore ACR compressor 7 days j

QR motor stop button to i

The C-331. C-333. C-335, or operable status.

C-337 ACR is evacuated.

1 H.

CCF compressor motor stop H.1 Verify that the applicable Immediately button for "00* and "000*

ACR compressor motor j

compressors inoperable (not due stop button is operable.

to loss of DC voltage or air M

header pressure for "000' cells).

G.2 Restore CCF compressor 7 days j

motor stop button to operable status.

TSR 1.6.2.2(d)is not applicable.

I 2,4-41a

1 TSR-PGD" PROPOSED June 30,1999 RAC 99CW8 (RO) i A

SECTION 2.4 SPECIFIC TSRS FOR ENRICHMENT CASCADE FACILITIES 2.4.4 GENERAL LIMITING CONDITIONS FOR OPERATION 2.4.4.12 CASCADE CELL TRIP FUNCTION (continued) l Condition Required Action Completion Time I.

Both Condition G. and H. apply I.1 Notify Cascade Immediately Coordinator of potential need to utilize alternate means of cell shutdown.

AND I.2 Station an operator at an 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> established alternate shutdown location with communications to the ACR or CCF.

M I.3 Shutdown affected 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> cascade cell (s).

J.

Required action F.1, F.2, F.3, J.1 Station an operator at an 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> G.2 or H.2 not satisfactorily established alternate accomplished, shutdown location with communications to the ACR or CCF.

J.2 Shutdown affected 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> cascade cell (s).

DO 2.4-41b

TSR-PGDP PROPOSED June 30,1999 RAC 99C028 (RO)

SECTION 2.4 SPECIFIC TSRS FOR ENRICHMENT CASCADE FACILITIES em 2.4.4 GENERAL LIMITING CONDITIONS FOR OPERATION 2.4.4.12 CASCADE CELL TRIP FUNCTION (continued)

SURVEILLANCE REQUIREMENTS:

Surveillance Frequency SR 2.4.4.12-1 Verify DC voltage 2 210 volts at the battery DC Daily charger.

SR 2.4.4.12-2 Verify "000" air circuit breaker air header pressure is Daily greater than the minimum required actuation pressure.

SR 2.4.4.12-3 Inspect battery terminals and racks for evidence of Quarterly corrosion and for leakage of electrolyte.

SR 2.4.4.12-4 Check that the specific gravity of the pilot cell is Quarterly 2 1.180 corrected to 77'F.

SR 2.4.4.12-5 Verify the battery charger output is > 0 DC amps Daily l

SR 2.4.4.12-6 Visually check the cell electrolyte levels to verify that Quarterly the level is above the low level indication and no more than 0.25 inches above the high indication line.

SR 2.4.4.12 7 Check that the specific gravity of the cells is 21.180 Annually corrected to 77'F.

SR 2.4.4.12-8 Perform a functional test of the ACR and CCF manual Prior to cell startup following a cell shutdown function for "00* and 000* cells. and of planned cell shutdown the LCP manual cell shutdown function for C 310 cells.

Note: Performance of this surveillance to demonstrate system operability is not required for any cell in operation until the next planned shutdown.

SR 2.4.4.12-9 Verify expected block valve closure and recycle valve Each planned cell isolation.

opening for the planned cell isolation and initiate corrective actions for any unexpected valve operation.

SR 2.4.4.12-10 Verify CCF DC bus voltage 2105 volts DC.

Daily l

[()

2.4-42

TSR-PGDP PROPOSED June 30,1999 RAC 99C028 (RO)

SECTION 2.4 SPECIFIC TSRS FOR ENRICHMENT CASCADE FACILITIES

[

2.4.4 GENERAL LIMITING CONDITIONS FOR OPERATION 2.4.4.12 CASCADE CELL TRIP FUNCTION (continued)

BASIS:

The accident analysis presented in SAR chapter 4 discusses numerous cascade cell-related scenarios (e.g., 4.3.2.1.1, 4.3.2.1.2, 4.3.2.1.3, 4.3.2.1.5, 4.3.2.1.7, and 4.3.2.1.8) in which l

operating personnel respond to certain process conditions and alarms by de-energizing the process motors (" tripping the cell"), thus bringing the cell below atmospheric pressure. In order to initiate a cell shutdown, the DC control and trip power circuit must be functional.

The functional test of the ACR and CCF manual cell shutdown function for "00" or "000" cells l

prior to cell startup may be accomplished by 1) crediting a successful function of the ACR or l

CCF trip system at the time the cell was shutdown, and 2) testing the function of the trip l

location that was not utilized during the planned cell shutdown. It is permissible to verify l

functionality via tripping the breaker on a deenergized bus, performing combinations of wiring l

and relay checks, and/or tripping the breaker from the " test" position. In determining the l

appropriate test method, credit may be taken for portions of the circuitry tested during or since l

the previous cell shutdown (e.g., the breaker mechanism does not necessarily need to be cycled l

twice to test both the ACR and the CCF trip buttons).

l

-C l

The functional test of the LCP manual cell shutdown function for C-310 cells prior to cell l

startup may be accomplished by crediting successful function of the LCP trip system at the time l

the cell was shutdown. Planned cell shutdowns must be initiated at the local control psnel for l

C-310 cells because an ACR trip button is not provided for C-310 cells.

l Note that planned cell shutdown is defined as the process of manually de-energizing the process l

motors in accordance with approved procedures. Unplanned cell shutdown is therefore any automatic trip of the process motors.

l The minimum air pressure required to trip the "000" breakers varies with the breaker type. For l

all cells in C-337 and cells C-333-2.2, C-333-5.1, C-333-5.3, C-333-6.5, and C-333-6.7,190 l

psig is the required air pressure; and for all the other cells in C-333,118 psig is the required l

air pressure.

l The alternate means of cell shutdown referred to in the required action (e.g., A.1) could include l

local cell panel trip, breaker manual trip, or C-300/ switchyard deenergization of electrical l

feeders, buses, transformer bays, main switchyard lines. Because of the number of available trip l

locations, these alternate locations are not required to be tested periodically. [SAR Section l

3.15.3.1 and 3.15.3.2]

l DJ 2.4-43

TSR PGDP PROPOSED June 30,1999

)

RAC 99C028 (RO)

SECTION 2.4 SPECIFIC TSRS FOR ENRICHMENT CASCADE FACILITIES a

O 2.4.4 GENERAL LIMITING CONDITIONS FOR OPERATION j

=

2.4.4.13 HEAVY EQUIPMENT HANDLING

\\

L LCO 2.4.4.13: In process buildings um equipment is operating above atmospheric pressure, [

movement of large p.m:'s equipment shall not occur above/around process

[

equipment that is opera.mg above atmospheric pressure and shall not occur l

without communication beween the lift location and the ACR (ACR operator and/or shift supervisor).

j APPLICABILITY: Modes:

Cascade 2 (any portion of the building) l ACTIONS:

Condition Required Action Completion Time

\\

A.

Large process equipment A.1 Establish Immediately moved over process communication equipment without OE communication between A.2 Move the Immediately lift location and the ACR.

suspended equipment to a Q

location away from operating process equipment.

B.

Large process equipment B.1 Move equipment to Immediately l

moved above/around a location that is l

process equipment that is not above/around

]

operating above process equipment l

atmospheric pressure.

operating above l

atmospheric l

pressure l

SURVEILLANCE REQUIRIGIENTS: None.

BASIS:

A fully informed ACR (ACR opeator and/or shift supervisor) will be able to take quick action in order to mitigate the consequences of an accidental equipment drop in the cascade facilities.

This administrative control assures the shift supervisor is fully informed of the nature and location of the proposed equipment movement. Heavy equipment may be transported in a l

building that contains equipment operating in cascade modes 1 or 2, however movement of l

g heavy equipment above/around cascade equipment operating in cascade mode 2 is not allowed.

l V

[SAR Sections 3.15.9.2.3, 4.3.2.1.8]

[

2.4-44

TSR-PGDP PROPOSED June 30,1999 RAC 99C028 (RO)

SECTION 2.4 SPECIFIC TSRS FOR ENRICHMENT CASCADE FACILITIES 2.4.4 GENERAL LIMITING CONDITIONS FOR OPERATION 2.4.4.14 HEATING UF, PLUGS LCO 2.4.4.14 Direct sources shall not be applied to UF plugs until flow clarity in the system has been assured.

APPLICABILITY: At all times i

l ACTIONS:

Condition Required Action Completion Time A.

Direct heat source applied A.1 Discontinue heating Immediately to a UF giug.

the plug.

6 SURVEILLANCE REQUIREMENTS: None.

BASIS:

Application of external heat to the middle portion of the plug can melt the solid and develop large hydraulic forces in the pipe and ends of the plug, creating the potential for a UF release O

due to give moture. cUSEC-651)

I l

i l

t O

2.4-45 1

TSR-PGDP PROPOSED June 30,1999 RAC 99C028 (RO)

SECTION 2.4 SPECIFIC TSRS FOR ENRICIBIENT CASCADE FACILITIES 2.4.4 GENERAL LB11 TING CONDITIONS FOR OPERATION 2.4.4.15 MOTOR LOAD INDICATORS l

1 LCO 2.4.4.15 Cascade UF stage compressor motor load indicators for "00" and "000" l

6 compressor motors shall be operable.

l l

APPLICABILITY: Modes: Cascade 1 and 2 when "00" or "000" stage motors are energized.

l

[

1 ACTIONS:

Condition Required Action Completion Time A.

ACR stage compressor.

A.1 Verify that the stage compressor 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> motor load indicator motor load indicators for the adjacent inoperable, stages are operable.

Note: If more than one ACR indicator is inoperable, perform this action for each inoperable indicator.

TSR 1.6.2.2(d) is not applicable.

B.

ACR stage compressor B.1 Verify that the applicable cell 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> O

motor load indicators compressor motor load indicator in inoperable for 2: 2 the CCF is operable.

adjacent stage motors.

AND QR B.2 Restore at least one of the adjacent 7 days The C-331, C-333, C-ACR stage compressor motor load 335, or C-337 ACR is indicators to operable status.

evacuated C.

CCF cell compressor C.1 Verify that the applicable ACR stage 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> motor load indicator compressor motor load indicator (s) inoperable are operable.

OE C.2 Verify required action A.1 is 4 hour-complete.

TSR 1.6.2.2(d) is not applicable.

D.

Required action B.1 or D.1 Station an operator at the LCC to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> B.2, or C.1 and C.2 not monitor cell parameters with satisfactorily communications to the ACR or CCF.

accomplished.

OR D.2 Shutdown affected UF. compressor 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> motor (s).

I n

2,4-45a

TSR-PGDP PROPOSED June 30,1999 RAC 99C028 (RO)

SECTION 2.4 SPECIFIC TSRS FOR ENRICHMENT CASCADE FACILITIES b

2.4.4 GENERAL LIMITING CONDITIONS FOR OPERATION 2.4.4.15 MOTOR LOAD INDICATORS (continued) l l

SURVEILLANCE REQUIREMENTS:

SURVEILLANCE FREQUENCY l

SR 2.4.4.15-1 Perform a CHANNEL CHECK of the ACR stage Following compressor l

compressor motor load indicators.

motor start l

l BASIS:

l l

The motor load indicators provide an indication of various types of failures of the l

compressor (s>[SAR Sections 4.3.2.1.1, 4.3.2.1.2, 4.3.2.1.3, and 4.3.2.1.5]. Using ammeter l

indications in the ACR for the individual compressor motors, operators can quickly identify l

various abnormalities caused by malfunctions of the process equipment. Operator training is l

relied upon to distinguish between load changes associated with normal fluctuations such as l

cascade power increases, and equipment malfunctions. Compressor load changes can be caused l

by such events as compressor failures, inadvertent closures of B-stream block valves ~ or stage l

control valves, or failures of the primary system pressure boundary that cause inleakage or a l

release of UF. Compressor surging will produce large swings in the loads. If an ammeter l

n 6

V should malfunction, the load changes can be seen on the ammeters for the compressor motors l

in stages that are adjacent to the stage that is experiencing the compressor malfunction. Motor l

indicators in the ACRs are used to detect large load changes for cell compressor motors in the l

enrichment cascade. Load indications in the CCF are used to detect large load changes for cell l

J compressor motors (i.e., CCF indicator provides total load for all of the stages in a particular l

cell). These CCF indicators are not required to satisfy the LCO unless the ACR indicator is l

inoperable. In the event of evacuation of an ACR, the ammeter indications in the CCF can be l

used to menitor for large load changes that could be representative of a pressure increase.

l Although the monitors in the CCF are less sensitive than those in the ACR, they are able to l

indicate significant compressor load changes. This indication of an event and mitigative action l

by the operator (1) controls the primary system pressure and temperature increases to minimize l

the potential for primary system integrity failures and (2) reduces the primary system pressure l

to minimize UF releases for on-site personnel. This system is not essential for off-site public l

6 protection. The surveillance requirement is provided to ensure that, after motor start, the l.

anuneter provides qualitative (or relative) indication of motor load. It is appropriate to perform l

this surveillance after sufficient UF is introduced into the cell so that a nominal reading on the l

6 ammeter can be obtained.

[SAR Section 3.15.3.6]

l 2.4.5 GENERAL DESIGN FEATURES There are no special design features associated with enrichment cascade operations.

2.4-45b

TSR-PGDP PROPOSED June 30,1999 RAC 98C028 (RO)

SECTION 2.5 SPECIFIC TSRs FOR EQUIPMENT REMOVAL ACTIVITIES O

2.5.4 GENERAL LIMITING CONDITIONS FOR OPERATION 2.5.4.1 PRE-REMOVAL EXAMINATION LCO 2.5.4.1: An analysis or Non-Destmetive Assay (NDA) survey shall be performed to determine the level of handling restrictions to be applied (PEH or UH).

APPLICABILITY: Prior to beginning removal of equipment listed in TSR 2.5 Appendix A which contains uranium enriched to 21.0 wt % 235U.

ACTIONS:

Condition Required Action Completion Time 4

A.

Applicable equipment A.1.1 Equipment openings Immediately and until removed prior to analysis shall be covered or Action A.2 completed.

{

or NDA.

closed i

AND A.1.2 Establish and Immediately and until

)

maintain a dry Action A.2 completed.

atmosphere within C

the egolpment.

Aan A.2 Establish special Prior to beginning case-specific NCSA decontamination evolution.

{

requirements for handling equipment.

SURVEILLANCE REQUIREMENTS: None.

BASIS:

Determining the mass of any uranium deposits in the equipment allows segregation and controlled handling of equipment containing amounts of 235U that require additional controls to prevent the formation of an unsafe mass / geometry. [SAR Section 5.2, Appendix A) l ~

O 2.5-3

TSR PGDP PROPOSED June 30,1999 RAC 98C028 (RO)

SECTION 2.5 SPECIFIC TSRs FOR EQUIPMENT REMOVAL ACTIVITIES

,V 2.5.4 GENERAL LIMITING CONDITIONS FOR OPERATION 2.5.4.2 POST-REMOVAL EXAMINATION LCO 2.5.4.2: Equipment categorized and removed as UH shall have the categorization verified with a post-removal visual or NDA inspection within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

j APPLICABILITY: After completion of the removal of equipment listed in TSR 2.5 Appendix A which contains uranium enriched to 2: 1.0 wt % S U.

ACTIONS:

)

Condition Required Action Completion Time h.

UH categorization not A.I.1 Equipment openings Immediately and until l

properly verified.

shall be covered or Action A.2 completed.

closed M

A.1.2 Establish and Immediately and until maintain a dry Action A.2 completed, atmosphere within the equipment.

Q AND A.2 Establish special Prior to beginning case-specific NCSA decontamination evolution.

requirements for handling equipment.

SURVEILLANCE REQUIREMENTS: None.

BASIS:

The initial inspection is verified by a second inspection to prevent mishandling of equipment containing amounts of SU that require additional controls to prevent the forruation of an unsafe mass / geometry. [SAR Section 5.2, Appendix A]

l O

2.5-4

TSR-PGDP PROPOSED June 30,1999 RAC 98C028 (RO)

SECTION 2.5 SPECIFIC TSRs FOR EQUIPMENT REMOVAL ACTIVITIES 2.5.4 GENERAL LIMITING CONDITIONS FOR OPERATION 2.5.4.3 PEll EQUIPMENT OPENINGS LCO 2.5.4.3: Equipment openings shall be covered with fireproof covers and gasket seals when the equipment is not in the process of being decontaminated or being j

visually inspected.

l APPLICABILITY: After removal of equipment categorized as PEH (equipment listed in TSR l

2.5 Appendix A which contains more than a safe mass of uranium as determined by TSR 2.5 Appendix B)

ACTIONS:

Condition Required Action Completion Time A.

Applicable PEH equipment A.1.1 Equipment openings Immediately and until discovered with uncovered shall be covered or Action A.2 completed.

l opening (s) while not being closed decontaminated or being M

visually inspected A.1.2 Establish and Immediately and until maintain a dry Action A.2 completed.

Q atmosphere within the equipment.

M A.2 Establish special Prior to resuming case-specific NCSA decontamination evolution.

requirements for

]

handling i

equipment.

l SURVEILLANCE REQUIREMENTS:

j Surveillance Frequency l

SR 2.5.4.3-1 Inspect equipment to verify openings are Daily

)

covered or closed when not being l

decontaminated.

j i

BASIS:

Covering or closing equipment openings minimizes the introduction of moderator into the l

equipment from atmospheric moisture or external sources (e.g. overhead sprinklers). [SAR Section 5.2, Appendix A]

l

)

O l

l 2.5-5 l

l

TSR-PGDP PROPOSED June 30,1999 RAC 98C0' 8 (RO)

SECTION 2.5 SPECIFIC TSRs FOR EQUIPMENT REMOVAL ACTIVITIES 2.5.4 GENERAL LIh1ITING CONDITIONS FOR OPERATION

'2.5.4.4 PEH DECONTAMINATION TIME LIhllTS LCO 2.5.4.4: Applicable equipment categorized and removed as PEH shall be decontaminated to a safe mass or below within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from the start of equipment removal or 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from the start of decontamination, whichever is sooner.

APPLICABILITY: After removal of eqt$ipment categorized as PEH (equipment listed in TSR 2.5 Appendix A which contains more than a safe mass of uranium as determined by TSR 2.5 Appendix B)

ACTIONS:

Condition Required Action Completion Time A.

Decontamination to a safe A.I.1 Equipment openings Immediately and until mass or less not achieved shall be covered or Action A.2 completed.

within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> closed AND A.1.2 Establish and -

Immediately and until maintain a dry Action A.2 completed.

O h

atm SP ere within the equipment, blLQ A.2 Establish special Prior to resuming case-specific NCSA decontamination evolution, requirements for handling equipment.

I SURVEILLANCE REQUIREMENTS: None BASIS:

This control minimizes the potential for exposure of the UF,/UO F to external moderating 22 sources, such as humid air or other external water sources (fire protection system), that could result in a critical reaction by ensuring that there exists a barrier to the external water source.

The decontamination evolution involves any actual disassembly and deposit removal that can be temporarily interrupted due to work area levels of HF but will proceed to completion once initiated. [SAR Section 5.2, Appendix A) l O

2.5-6

TSR-PGDP PROPOSED June 30,1999 RAC 99C028 (RO)

SECTION 2.6 SPECIFIC TSRs FOR CAAS (NON-CASCADE FACILITIES)

~

  • O 2.6.4 GENERAL LIMITING CONDITIONS FOR OPERATION 3

2.6.4.1 CRITICALITY ACCIDENT ALARM SYSTEM (continued)

SURVEILLANCE REQUIREMENTS:

Surveillance Frequency SR 2.6.4.la-1 Calibrate CAAS system equipment.

Annually l

i i

BASIS:

The CAAS is used to warn plant personnel of a criticality or radiation accident. This system j

is designed to detect radiation and provide a distinctive, audible signal which will alert personnel l

to move from those work areas which are potentially affected. The design of the system, three detector modules per cluster, provides protection for criticality events even with partial losses of required equipment. The CAAS also provides detection coverage in most areas by using an overlapping pattern of individual cluster units. Criticality concerns with the listed facilities are associated with the handling of fissile materials. The action items maintain the facility in steady state operations to limit the potential for these concerns to the extent possible. The alarm signal pJ-is provided by sounding building horns which sound upon a signal from any cluster, and by sounding in some locations a local horn associated with each individual cluster. The building horns for C-709 and C-710 are configured in two separate networks, either of which can independently sound the required evacuation signal. The building horn configuration in C-709 and C-710 allows the CAAS for those buildings to remain operable even when one of the independent horn networks is temporarily out of service. Providing another means of coverage (i.e., portable detector / alarm, personal alarm device, etc.), restricting operations, or restricting access to the area in the event of the loss of detection will establish protection.

[SAR Sections 3.15.7.1 and 4.3.2.6]

i Facilities containing criticality accident alarm systems (other than those covered by TSR Sections 2.1-2.4) include C-400, C-409, C-710, C-720, C-720M, C-720K, C-720R, C-720S, C-720-C, C-728, and C-746-Q-1.

J 2.6-5

TSR-PGDP PROPOSED June 30,1999 RAC 99C028 (RO)

SECTION 2.6 SPECIFIC TSRs FOR CAAS (NON-CASCADE FACILITIES)

  • O.

2.6.4 GENERAL LIMITING CONDITIONS FOR OPERATION m

2 2.6.4.1 CRITICALITY ACCIDENT ALARM SYSTEM (continued)

SURVEILLANCE REQUIREMENTS:

Surveillance Frequency SR 2.6.4.lb-1 Test the CAAS, local cluster horns and Quarterly building horns.

SR 2.6.4.lb-2 Verify that the nitrogen supply pressure to Quarterly the cluster horns is at least 900 psig.

SR 2.6.4.lb 3 Verify that the condition of the battery Annually backups to the electronic horns are sufficient to power the horns for at least 120 seconds.

BASIS:

The CAAS is used to warn plant personnel of a criticality or radiation accident. This system is designed to detect radiation and provide a distinctive, audible signal which will alert personnel-Q to move from those work areas which are potentially affected. Evacuation of the area of inaudibility and restricting access to those areas will eliminate the potential for increased consequences due to personnel not hearing an alann. - The design of the system, three detector modules per cluster, provides protection for criticality events even with partial losses of required equipment. The CAAS also provides detection coverage in most areas by using an overlapping pattern of individual cluster units. Criticality concerns with the listed facilities are associated with the handling of fissile materials. The action items maintain the facility in steady state operations to limit the potential for these concerns to the extent possible. The alarm signal is provided by sounding building horns which sound upon a signal from any cluster, and by sounding in some locations a local horn associated with each individual cluster. The building horns for C-709 and C-710 are configured in two separate networks, either of which can independently sound the required evacuation signal. The building horn configuration in C-709 and C-710 allows the CAAS for those buildings to remain operable even when one of the independent horn networks is temporarily out of service. Providing another means of coverage (i.e., portable detector / alarm, personal alarm device, etc.), restricting operations, or restricting access to the area in the event of the loss of alarms will establish protection.

Facilities containing criticality accident alarm systems (other than those covered by TSR Sections 2.1-2,4) include C-400, C-409, C-710, C-720, C-720M, C-720K, C-720R, C-720S, C-720-C, C-728, and C-746-Q-1. [SAR Sections 3.15.7.1, 4.3.2.6, 5.2.2.5]

l The nitrogen bottles which backup plant air for the local cluster horns are standard cylinder size O

1 A (1.55 ft), 9 x 51 inches) and provide for 120 seconds of horn actuation when at their minimum acceptable pressure of 900 psig.

2.6-7

TSR-PGDP PROPOSED Jane 30,1999 RAC 99C028 (RO)

SECTION 3.0 ADMINISTRATIVE CONTkOLS

'O' 3.7 EFFECTS OF NATURAL PHENOMENA

5 Emergency response procedures dfl be estabushed, implemented, and snaintained to prescribe plant response to the following natu
s phenomena events-Earthquake Tornado /High Winds Flooding / Intense Preciphation l

3.8 PROCESS VENTILATION AND OFF-GAS Control of radicactive emissions shall be established implemented and maintained as described in Section 5.1 of the SAR.

3.9 PROCEDURES 3.9.1 SCOPE Written procedures shall be prepared, reviewed, approved, implemented, and maintained (except for a limited time as specified in the Compliance Plan) to cover the following:

a. Activities described in SAR Section 6.11.4.1 and listed in Appendix A to SAR Section 6.11;
b. Operator actions and administrative conaols to prevent or mitigate the consequences l

of accidents described in SAR Chapter 4; and

c. Programs specified and described in TSRs 3.11 through 3.19, and 3.23.

3.9.2 REVIEW AND APPROVAL

a. Each new procedure required by TSR 3.9.1 shall be reviewed by the PORC in accordance with TSR 3.10.
b. Each proposed change to the procedures required by TSR 3.9.1 shall be reviewed by the PORC in accordance with TSR 3.10 if:

1.

The proposed change requires a written safety analysis in accordance with 10 CFR 76.68; or 2.

The proposed change results in a change to the documents listed in TSR 3.10.5.b, c, and d; or bc 3.0-6

1 TSR-PGDP PROPOSED June 30,1999 RAC 99C028 (R0)

+

i SECTION 3.0 ADMINISTRATIVE CONTROLS O

' )

3.10.4 FUNCTIONS i

The PORC shall, as a minimum, incorporate functions that:

a. Advise the General Manager on matters related to nuclear safety; 4

b.~ : Recommend to the General Manager approval or disapproval of items considered under TSR 3.10.5 prior to their implementation except as provided in TSR 1.6.4 l

and TSR 3.9.3;

c. Determine whether each item considered under TSR 3.10.5 requires pricr NRC approval before implementation per 10 CFR 76.68 and 76.45.

l

d. Notify the Executive Vice President of any safety significant disagreement between the PORC and the General Manager within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. However, the General Manager shall have responsibility for resolution of such disagreements pursuant to TSR 3.1.2.

3.16.5 RESPONSIBILITIES The PORC shall be used to conduct, as a minimum, reviews of the following:

i

a. All proposed procedures and procedure changes as required by TSR 3.9.2;
b. All proposed changes to the Safety Analysis Report;
c. All proposed changes to the Emergency Plan, Quality Assurance Program Description, Physical Security Plan for the Protection of Special Nuclear Material of Low Strategic Significance, Security P an for the Transportation of Special N" clear Material of Low Strategic Significance, Security Plan for the Protection of Classified Matter, Fundamental Nuclear Materials Control Plan, Radioactive Waste Management Program, Depleted Uranium Management Plan, Decommissioning Funding Program Description, Environmental Compliance Status Report, and Supplemental Enviromrantal Information Related to Compliance Plan that are included in the certification application.
d. All proposed changes to the TSRs, ti.e TSR basis statements, the Certificate of Compliance, or the Compliance Plan;
e. All proposed changes to the plant or the plant's operations, including tests and experiments, that require a written safety analysis in accordance with 10 CFR 76.68.

O 3.0-9 L