ML20210C647
| ML20210C647 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 07/20/1999 |
| From: | Toelle S UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Paperiello C NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| GDP-99-0090, NUDOCS 9907270001 | |
| Download: ML20210C647 (16) | |
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.USEC l
A Globat Energy Company July 20,1999
{
GDP 99-0090 Dr. Carl J. Paperiello Director, Office ofNuclear Material Safety and Safeguards Attention: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Paducah Gaseous Diffusion Plant (PGDP)
Docket No. 70-7001 Certificate Amendment Request -Mode Applicability Revision for Cylinder Lifting Restrictions in C-360 and Other Editorial and Formatting TSR Revisions - TSR 2.1.4.8, I
2.1.4.17,2.3.4.1,2.3.4.4,2.3.4.16, and 3.10.4.b
Dear Dr. Paperiello:
In accordance with 10 CFR Part 76.45, the United States Enrichment Corporation (USEC) hereby submits a request for amendment to the certificate ofcompliance for the Paducah Gaseous Diffusion Plant (PGDP). This certificate amendment request revises Technical Safety Requirement (TSR) 2.1.4.17, Cylinder Lifling Restrictions, by including operational Mode Ib in the applicability statement. TSRs 2.1.4.8,2.3.4.1,2.3.4.4. 2.3.4.16, and 3.10.4.b are also revised to correct minor editorial or formatting concerns.
TSR 2.1.4.17 restricts the lifting of one UF cylinder over another when either cylinder contains 6
liquid UF. Ilowever, the TSR as currently written only applies in operational Mode la which 6
applies to the movement of cylinders containing liquid UF. Ilowever, the TSR Limiting Condition 6
for Operation (LCO) and Condition A implies the cylinder lifting restriction should also apply to prevent the movement of empty cylinders or solid UF cylinders over a cylinder containing 6
liquid UF. To clarify this needed restriction TSR 2.1.4.17 should be revised to specifically apply 6
to both operational Mode la and Ib, when the cylinder being lifted has not been acceptably heeled.
\\[ to this letter provides a detailed description and justification for the proposed changes.
' is a copy of the revised TSR pages. The TSR pages are provided for your review and approval. Enclosure 4 contains the basis for USEC's determination that the proposed change associated with this certificate amendment request is not significant.
Current PGDP operating procedures and practices already restrict the movement of empty cylinders l
or solid UF cylinders over a cylinder containing liquid UF.. As such, USEC requests NRC review
/ O 6
of this certificate amendment as soon as practical. The amendment should become efTective 30 days from issuance.
9907270001 990720 PDR ADOCK 0700 1
3esda, MD 20817 1818
""P"""* '"os-uuo rax 301-564-3 1 http://www.usec.com UU'M OMces in Livermore. CA Paducah, KY Portsmouth, OH Washington DC
~ '
o D'r. Carl J. Paperiello
. July 20,1999 GDP 99-0090, Page 2 Any questions related to this subject should be directed to Mr. Mark Smith at (301) 564-3244.
There are no new commitments contained within this submittal.
Sincerely, n_
S. 9.
I Steven A.Toelle Nuclear Regulatory Assurance & Policy Manager
Enclosures:
- 1. Oath and Affirmation
- 2. United States Enrichment Corporation (USEC), Proposed Certificate Amendment Request, Mode Applicability Revision for Cylinder Lifling Restrictions in C-360 and Other Editorial and Formatting TSR Revisions - TSR 2.1.4.8, 2.1.4.17, 2.3.4.1,2.3.4.4,2.3.4.16, and 3.10.4.b, Detailed Description of Change
- 3. Proposed Certificate Amendment Request, Paducah Gaseous Diffusion Plant, Letter GDP 99-0090, Removal / Insertion Instructions
' 4. United States Enrichment Corporation (USEC), Proposed Certificate Amendment Request, Mode Applicability Revision for Cylinder Lifling Restrictions in C-360 and Other Editorialand Formatting TSR Revisions - TSR 2.1.4.8, 2.1.4.17, 2.3.4.1,2.3.4.4,2.3.4.16, and 3.10.4.b, Significance Determination cc: Robert Pierson, NRC Special Projects Branch Patrick Ililand, NRC Region ill Ken O'Brien, NRC Resident Inspector - PGDP David liartland, NRC Resident Inspector - PORTS Randall M. DeVault, DOE Regulatory Oversight Manager
o OATII AND AFFIRMATION i, Steven A. Toelle, swear and affimi that I am the Nuclear Regulatory Assurance and Policy Manager, of the United States Enrichment Corporation (USEC), that I am authorized by USEC to sign and file with the Nuclear Regulatory Commission this Certificate Amendment Request for the Paducah Gaseous Diffusion Plant addressing revision to TSR 2.1.4.8, Cylinder lieating and Filling: Cylinder Pre-lieat and Pre-Fill Inspection, TSR 2.1.4.17, Cylinder Lifting Restriction, TSR 2.3.4.1, UF Release Detection and Isolation System - Low Voltage ("New") System at the UF 6
6 Withdrawal Stations. TSR 2.3.4.4, UF Release Detection System - Iligh Voltage ("Old") System for UF Condensers, Accumulators, and Piping Heated liousings, TSR 2.3.4.16, Cylinder Filling -
6 Cylinder Pre-Fill Inspection, and 3.10.4.b, Plant Operations Review Committee - Functions, as described in GDP 99-0090, that I am familiar with the contents thereof, and that the statements made and matters set forth therein are true and correct to the best of my knowledge, information, and belief.'
/1 S. A.
I Steven A.Toelle On this 20th day of July,1999, the individual signing above personally appeared before me, is known by me to be the person whose name is subscribed to within the instrument, and acknowledged that he executed the same for the purposes therein contained.
in witness hereofI hereunto set my hand and official seal.
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J eDil. Bodth'e', Notary 'PuMic
~
L te of Maryland, Montgomery County fy commission expires June 23,2003 L
GDP 99-0090 Page1of3 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Mode Applicability Revision for Cylinder Lifting Restrictions in C-360 and Other Editorial and Formatting TSR Revisions - TSR 2.1.4.8,2.1.4.17,2.3.4.1,2.3.4.4,2.3.4.16, and 3.10.4.b Detailed Description of Change
]
J This Certificate Amendment Request (CAR) includes proposed revisions to 6 separate Technical Safety Requirements (TSRs). Five of the requested revisions are limited to editorial /fo~ matting r
changes to TSRs 2.1.4.8,2.3.4.1,2.3.4.4,2.3.4.16, and 3.10.4.b. The proposed revision to TSR 2.1.4.17 provides for an Applicability Stetement revision. A description of each of the proposed revisions is provided in the following:
TSR 2.1.4.8 - Cylinder Heating and Filling: Cylinder Pre-IIcat and Pre-Fiil Inspection The PGDP TSR fonnatting convention is such that each Required Action is numbered to provide a link to the associated Condition Statement. The Required Action under this TSR is not numbered.
The proposed revision will designated the Required Action as A.l. Upon approval of the proposed Certificate Amendment, Action Statement A for the TSR will read as follows:
A.
Unacceptable cylinster A.1 Repair and test (if Prior to entering mode 5 l
damage identified by necessary) the or mode 6B with the cylinder pre-heat or pre-fill cylinder in subject cylinder.
visual inspection.
accordance with SAR Section 3.7.1 and SAR Figure 3.7-1.
=
TSR 2.1.4.17 - Cylinder Lifting Restriction TSR 2.1.4.17 restricts the lifting of one UF cylinder over another when either cylinder contains 6
liquid UF. Ilowever, the TSR as currently written only applies in operational Mode la wl'ich 6
applies to the novement of cylinders containing liquid UF. However, the TSR Limiting Condition 6
for Operation (LCO) and Action Condition A implies the cylinder lifting restriction should also apply to prevent the movement of empty cylinders (vihen the cylinder has not been acceptably heeled) or solid UF cylinders over a cylinder containing liquid UF. To clarify this additional 6
6 needed restriction, TSR 2.1.4.17 should be revised to specify applicability to both Modes la and Ib (when the cylinder has not been acceptably heeled). This will also make the applicability consistent with that for the Cylinder Lifling Restriction for the Tails & Product Withdrawal Facilities (TSR
]
i GDP 99-0090 Page 2 of 3 l
United States Enrichment Cc.rporation (USEC)
Proposed Certificate Amendment Request Moe'e Applicability Revision for Cylinder Lifting Restrictkns in C-360 and Other Editorial and Formatting TSR Revisions - TSR 2.1.4.8, 2.1.4.17, 2.3.4.1, 2.3.4.4, 2.3.4.16, a nd 3.10.4.b Detailed Description of Change APPLICABILITY: Modes:
la and Ib when the cylinder being lifted has not been acceptably heeled.
TSR 2.3.4.1 - UF Release Detection and Isolation System - Low Voltage ("New") System at the 6
UF Withdrawal Stations 6
The Action associated with Condition D is currently labeled C.I. The proposed revision will correct the Action designated to D.! Upon approval of the proposed Certificate Amendment, Action Statement D for the TSR will read as follows:
D.
Action Item A or C not D.1 Place the affected Ihour l
satisfactorily accomplished.
withdrawal station in mode 3.
TSR 2.3.4.4 - UF Release Detection System - Iligh Voltage ("Old") System for UF.
6 Condensers, Accumulators, and Piping IIcated Ilousings The Actim associated with Condition B is currently labeled A.2. The proposed revision will correct the Action designated to B.1 Upon approval of the proposed Certificate Amendment, Action Statement B for the TSR will read as follows:
- b. Action item A not B.1 Place the affected portion of Ihour l
satisfactorily accomplished.
the withdrawal process in mode 3.
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GDP 99-0090 J
Page 3 of 3 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Mode Applicability Revision for Cylinder Lifting Restrictions in C-360 and Other Editarial and Formatting TSR Revisions - TSR 2.1.4.8, 2.1.4.17, 2.3.4.1, 2.3.4.4, 2.3.4.16, and 3.10.4.b Detailed Description of Change TSR 2.3.4.16 - Cylinder Filling - Cylinder Pre-Fill Inspection The PGDP TSR formatting convention is such that each Required Action is numNred to provide a link to the associated Condition Statement. The Required Action under this TSL is not numbered.
The proposed revision will designated the Required Action as "A.I." Upon approval of the proposed Certificate Amendment, the Action Statements for the TSR will read as fe!!ows:
A.
Unacceptable cylinder damage A.1 Repair and test (if Prior to entering mode 2 l
identified by cylinder pre-fill necessary) the cylinder with the subject cylinder.
visual inspection.
in accordance with SAR Section 3.7.1 and SAR Figure 3.7-1.
1 i
TSR 3.10.4.b - Plant Operations Review Committee - Functions This TSR includes an erroneous cross-reference to TSR 1.6.4.1. There is not a TSR Section 1.6.4.1.
The correct reference should be to TSR Section 1.6.4. Upon approval of the proposed Certificate Amendment, this TSR will read as follows;
- b. Recommund to the General Manager appro ' or disapproval ofitems considered under TSR 3.10.5 prior to their implementahua except as provided in TSR 1.6.4 and l
TSR 3.9.3; l
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t GDP 99-0090 7 Pages Total Proposed Certificate Amendment Request Paducah Gaseous Diffusion Plant Letter GDP 99-0090 Memnval/Intertian Instructions Remove Page Insert Page Volume 4 Section 2.1 Section 2.1 2.1-31,2.1-40 2.1-31,2.1-40 Section 2.3 Section 2.3 2.3-8,2.3-14,2.3-39 2.3-8.2.3-14,2.3-39 Section 3.1 Section 3.1 3.0-9 3.0-9 "i
. TSR-PGDP PROPOSED July 20,1999 RAC 99C034 (RO)
SECTibN 2.1 SPECIFIC TSRs FOR TOLL TRANSFER AND SAMPLING FACILITY (C-360) 2.1.4 GENERAL LIMITING CONDITIONS FOR OPERATION 2.1.4.8 CYLINDER IIEATING AND FILLING: CYLINDER PRE-IIEAT AND PRE-FILL INSPECTION LCO 2.1.4.8: Damaged UF cylinders shall not be heated or filled with UF.
6 6
APPLICABILITY: Modes: 5 and 6B ACTIONS:
)
Condition Required Action Completion Time A.
Unacceptable cylinder A.1 Repair and test (if Prior to entering mode 5 or l
damage identified by cylinder necessary) the cylinder mode 6B with the subject pre-heat or pre-fill visual in accordance with cylinder.
inspection.
SAR Section 3.7.1 and SAR Figure 3.7-1.
=
SURVEILLANCE REQUIREMENTS:
Surveillance Frequency SR 2.1.4.8-1 Cylinder visual inspection for damage.
Prior to initial entry into mode 5 and/or 6B of each operating cycle.
BASIS:
Depending upon the degree of damage (detected during the pre-use inspection), a cylinder may or may not be capable of withstanding its hydropressure. A UF. cylinder is removed from service for repair or replacement when it has leaks, excessive corrosion, cracks, bulges, dents, gouges, defective valves, damaged stifTening rings or skirts, or other conditions that, in thejudgement of the inspector, renders it unsafe or unserviceable (see Figure 3.7-1 which is taken from USEC-651 and is based upon the requirements of ANSI N14.1,1990, Section 6.3.1). As described in SAR 3.7.1, some types of cylinder damage and/or deformities are acceptable as-is or after repair as specified in SAR Figure 3.7-1.
2.1-31 1
. TSR-PGDP PROPOSED July 20,1999 RAC 99CO'.4 (RO) t SECTION 2.1 SPECIFIC TSRs FOR TOLL TRANSFER AND SAMPLING FACILITY (C-360) 2.1.4 GENERAL LIMITING CONDITIONS FOR OPERATION 2.1.4.17 CYLINDER LIFTING RESTRICTION LCO 2.1.4.17 No UF. cylinder shall be moved over another cylinder when either cylinder contains liquid UF..
APPLICABILITY: Modes: la and Ib when the cylinder being lifted has not been acceptably heeled.
ACTIONS:
Condition Required Action Completion Time A.
UF cylinders suspended one A.1 Move the suspended Immediately over the other when at least cylinder such that the one of the cylinders contains LCO statement is j
liquid UF.
satisfied.
s BASIS:
The cylinder drop and puncture scenarios in the accident analysis involving liquid UF cylinders (SAR Sections 4.3.3.1.5,4.3.4.1.5, and 4.3.5.1.2) assume a release source term of 28,000 pounds of j
UF.. The prohibition oflifting one cylinder over another if one of the cylinders contains liquid UF 6 preserves the accident analysis assumption of only one cylinder contributing to the release source term (even though the contribution from a solid UF. cylinder would be negligible).
A cylinder that has been acceptably heeled will contain no liquid UF. SAR Section 3.2.1 describes the process of heeling a cylinder. A cylinder will be considered acceptably heeled when its vapor pressure falls below 20 psia for more than 5 minutes during the heeling process.
i s
2.1-40
, TSR-PGDP PROPOSED July 20,1999 o
RAC 99C034 (RO)
SECTION 2.3 SPECIFIC TSRs FOR PRODUCT AND TAILS WITIIDRAWAL FACILITIES t
2.3.4 GENERAL LIMITING CONDITIONS FOR OPERATION 2.3.4.1 UF RELEASE DETECTION AND ISOLATION SYSTEM - LOW VOLTAGE
("NEW") SYSTEM AT TIIE UF WITIIDRAWAL STATIONS LCO 2.3.4.1:
The low voltage ("New") withdrawal station UF release detection and isolation system shall be operable.
APPLICABILITY: Modes: When the applicable withdrawal station is in mode 2.
A__CTIONS:
Condition Action Completion Time A.
The low voltage detector A.1 Perfonn UF smoke watch Initiate within I hour head at the withdrawal on area affected by PGLD and maintain station is inoperable.
detection head continuously.
inoperability.
AND A.2 Restore operability to the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> low voltage detector head.
TSR 1.6.2.2(d) is not applicable.
I B.
The low voltage detector B.1 Place the affected Ihour i
head at the withdrawal withdrawal station in station is inoperable and the mode 3.
ACR manual isolation button is inoperable.
C.
Either the liquid block valve C.1 Restore operability.
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />
. or the emergency liquid block valve is inoperable.
D.
Action Item A or C not D.1 Place the affected Ihour l
satisfactorily accomplished.
withdrawal station in mode 3.
E.
Both the liquid block valve L.1 Place the affected Ihour and the emergency liquid withdrawal station in block valve are inoperable.
mode 3.
F.
The cylinder valve closer F.1 Place the affected Ihour mechanism is inoperable.
withdrawal station in mode 3, closing the cylinder valve manually (valve closer me. be removed).
.m-2.3-8
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. TSR-PGDP PROPOSED July 20,1999 RAC 99C034 (RO) dECTION 2.3 SPECIFIC TSRs FOR PRODUCT AND TAILS WITIIDRAWAL l
FACILITIES 2.3.4 GENERAL LIMITING CONDITIONS FOR OPERATION 2.3.4.4 UF RELEASE DETECTION SYSTEM - IIIGli VOLTAGE ("OLD") SYSTEM FOR UF CONDENSERS, ACCUMULATORS, AND PIPING IIEATED IIOUSINGS l
LCO 2.3.4.4:
The high voltage ("old") UF. release detection heads monitoring the subject equipment shall be operable.
APPLICABILITY:
Modes: When the applicable equipment is in mode 2* or 3* (*When UF6 pressure is above atmospheric pressure.)
ACTIONS:
Condition Action Comnletion Time A.
One or more of the A.1 Establish a UF. smoke Initiate within I hour and detector heads is watch in th'e area affected maintain continuously, inoperable.
by PGLD head inoperability(but outside any housings) to watch for
" smoke" escaping from rny UF containing system.
TSR 1.6.2.2(d) is not i
applicable.
B.
Action item A not B.1 Place the affected portion Ihour l
satisfactorily of the withdrawal process accomplished.
in mode 3.
SURVEILLANCE REOUIREMENTS:
Surveillance Frequency SR 2.3.4.4 1
" Test fire" the UF release detection system Twice each shift onlyif heads operating in a mode specified in the applicability statement.
SR 2.3.4.4-2 Functional test by actuating the det:ctor head Quarterly with " smoke."
2.3-14 i
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, TSR-PGDP PROPOSED June 20,1999 RAC 99C034 (RO)
SECTIbN 2.3 SPECIFIC TSRs FOR PRODUCT AND TAILS WITHDRAWAL FACILITIES 2.3.4 GENERAL LIMITING CONDITIONS FOR OPERATION 2.3.4.16 CYLINDER FILLING - CYLINDER PRE-FILL INSPECTION LCO 2.3.4.I6: Damaged UF cylinders shall not be filled with UF.
6 6
APPLICABILITY: Modes: I and 2 ACTIONS:
Condition Required Action Completion Time A.
Unacceptable cylinder A.1 Repair and test (if Prior to entering mode 2 l
damage identified by necessary) the cylinder with the subject cylinder.
cylinderpre-fill visual in accoidance with SAR inspection.
Section 3.7.1 and SAR Figure 3.7-1.
SURVEILLANCE REQUIRI'MENTS:
Surveillance Frequency SR 2.3.4.16-1 Cylinder visual inspection for damage.
Prior to initial entry into mode 2 of each cylinder filling cycle.
. BASIS:
Depending upon the degree of damage (detected during the pre-use inspection), a cylinder may er may not be capable of withstanding its hydropressure. A UF cylinder is removed from service for 6
repair or replacement when it has leaks, excessive corrosion, cracks, bulges, dents, gouges, defective valves, damaged stiffening rings or skirts, or other conditions that, in thejudgement of the inspector, renders it unsafe or unserviceable (see Figure 3.7-1 which is taken from USEC-651 and is based upon the mquituments of ANSI N14.1,1990, Section 6.3.1). As described in SAR 3.7.1, some types of cylinder damage and/or deformities are acceptable as-is or after repair as specified in SAR
)
Figure 3.7-1.
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2.3-39 i
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, TSR-PGDP PROPOSED June 20,1999 RAC 99C034 (RO)
S'ECTION 3.0 ADMINISTRATIVE CONTROLS l
3.10.4 FUNCTIONS 1
l The PORC shall, as a minimum, incorporate functions that:
i Advise the General Manager on matters related to nuclear safety; a.
b.
Recommend to the General Manager approval or disapproval ofitems considered under TSR 3.10.5 prior to their implementation except as provided in TSR 1.6.4 and l
TSR 3.9.3; Determine whether each item considered under TSR 3.10.5 requires prior NRC c.
approval before implementation per 10 CFR 76.68 and 76.45.
d.
Notify the Executive Vice President, Operations 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 />.
Ilowever, the General Manager shall have responsibility for resolution of such disagreements pursuant to TSR 3.1.2.
3.10.5 RESPONSIBILITIES The PORC shall be used to conduct, as a minimum, reviews of the following:
All proposed procedures and procedure changes as required by TSR 3.9.2; a.
b.
All proposed changes to the Safety Analysis Report; All proposed changes to the Emergency Plan, Quality Assurance Program c.
Description, Physical Security Plan for the Protection of Special Nuclear Material of Low Strategic Significance, Security Plan for the Transportation of Special Nuclear 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 Environmental Infonnation Related to Compliance Plan that are included in the certification application.
d.
All proposed changes to the TSRs, the TSR basis statements, the Certificate of Compliance, or the Compliance Plan; All proposed changes to the plant or the plant's operations, including tests and e.
experiments, that require a written safety analysis in accordance with 10 CFR 76.68.
3.0-9
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GDP 99-0090 l
l Page1of3 l
United States Enrichment Corporation (USEC)
{
Proposed Certificate Amendment Request j
Mode Applicability Revision for Cylinder Lifting Restrictions in C-360 and Other Editorial and Formatting TSR Revisions - TSR 2.1.4.8, 2.1.4.17, 2.3.4.1, 2.3.4.4, 2.3.4.16, a nd 3.10.4.b Significance Determination The United States Enrichment Corporation (USEC) has reviewed the proposed changes associated with this certificate amendment request and provides the following Significance Detennination for consideration.
1.
No Sienificant Decrease in the Effectiveness of the Plant's Safety. Safeguards or Security Programs The Technical Safety Requirements (TSRs) for the handling ofliquid filled UF cylinders are 6
)
not addressed in plant safety, safeguards or security programs contained in Volume 3 of the Application for United States Nuclear Regulatory Commission Certification for the Paducah Gaseous Diffusion Plant (PGDP). Therefore, the effectiveness of these programs is unaffected by these changes.
2.
No Significant Change to Anv Conditions to the Certificate of Comnliance None of the Conditions to the Certificate of Compliance for operation of the Paducah Gaseous Diffusion Plant specifically address TSR applicability, required actions in the TSRs, Plant Operations Review Committee (PORC) functions or the handling ofliquid filled UF cylinders.
6 Thus, the proposed changes have no impact on any Condition to the Certificate of Compliance.
3.
No Significant Change to Anv Condition of the Annroved Comnliance Plan The proposed changes establish additional TSR applicability restrictions related to the handling of the UF cylinders and provide for minor editorial or formatting corrections to the TSRs and 6
result in no change to any condition of the Compliance Plan.
4.
No Significant Increase in the Probability of Occurrence or Conseauences of Previousiv Evaluated Accidents The proposed revision to TSR 2.1.4.17 will provide additional restrictions on the movement of UF cylinders so that no solid UF cylinder, or empty cylinder that has not been acceptably 6
6 heeled, may be moved over another cylinder containing liquid UF and provides consistency 6
with the currently described TSR Action and Basis Statements. As such, the proposed change will not increase the probability or consequences of an accident. The. minor editorial and formatting corrections to the TSRs have no bearing on the safe operation of the gasecus diffusion plant.
GDP 99-0090 Page 2 of 3 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Mode Applicability Revision for Cylinder Lifting Restrictions in C-360 and Other Editorial and Formatting TSR Revisions - TSR 2.1.4.8, 2.1.4.17, 2.3.4.1, 2.3.4.4, 2.3.4.16, and 3.10.4.b Significance Determination 5.
No New or Different Tyne of Accident The proposed revision to TSR 2.1.4.17 will provide additional restrictions on the movement of UF cylinders so that no solid UF cylinder, or empty cylinder that has not been acceptably 6
6 heeled, may be moved over another cylinder containing liquid UF and provides consistency 6
with the described TSR Action and Basis Statements. As such, the proposed change will not result in a new or different type of accident.
6.
No Significant Reduction in Margins of Safety The extension ofTSR 2.1.4.17 applicability to restrict the movement of any solid UF cylinder, 6
or empty cylinder that has not been acceptably heeled, over a cylinder filled with liquid UF6 provides consistency with the described TSR Action and Basis Statements. As such, the proposed change does not cause a reduction in any margin of safety.
7.
No Sienificant Decrease in the Effectiveness of any Program or Plan Contained in the Certificate Apolicatinn The TSRs prope d for revision are not discussed in any of the programs or plans contained in the application, nor do the any of the programs or plans rely on these TSRs for program / plan implementation. Therefore, these proposed changes do not reduce the effectiveness of any program or plan contained in the Certification Applicatian.
S.
The Pronosed Changes do not Result in Undue Risk to 1) Public Health and Safety. 2)
Common Defense and Security. and 3) the Environment.
The extension ofTSR 2.1.4.17 applicability to restrict the movement of any solid UF cylinder, 6
or empty cylindct that has not been acceptably heeled, over a cylinder filled with liquid UF6 provides consistency with the described TSR Action and Basis Statements. As result, the proposed changes do not result in undue risk to public health and safety, common defense and security, or the environment.. In addition, the minor editorial and formatting corrections to the TSRs have no bearing on public health and safety, common defense and security, or the environment.
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GDP 99-0090 Page 3 of 3 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Mode Applicability Revision for Cylinder Lifting Restrictions in C-360 and Other Editorial and Formatting
]
TSR Revisions - TSR 2.1.4.8, 2.1.4.17, 2.3.4.1, 2.3.4.4, 2.3.4.16, an d 3.10.4.b Significance Determination 9.
No Change in the Tynes or Significant Increase in the Amounts of Anv Effluents that May be Released Offsite This change has no affect on the generation or disposition of effluents. Therefore, this change l
i does not change the type or amounts of effluents that may be released offsite.
j
- 10. No Significant Increase in Individual or Cumulative Occunational Radiation Exnosure The proposed TSR change does not change or increase maintenance, testing, or operational requirements for the affected equipment. This change does not relate to controls used to minimize occupational radiation exposures. Therefore, there is no significant increase in individual or cumulative occupational radiation exposure.
I1. No Significant Construction Imnact There is no construction impact associated with the proposed changes.
- 12. No Significant Increase in the Potential for. or Radiological or Chemical Consecuences from.
j Previousiv Analyzed Accidents The extension ofTSR 2.1.4.17 applicability to restrict the movement of any solid UF cylinder, 6
or empty cylinder that has not been acceptably heeled, over a cylinder filled with liquid UF.
provides consistency with the described TSR Action and Basis Statements. The proposed change will not result in an increase in the potential for radiological or chemical consequences from previously evaluated accidents.
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