ML20210H247
| ML20210H247 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 07/22/1999 |
| 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) |
| Shared Package | |
| ML20210H251 | List: |
| References | |
| GDP-99-0120, NUDOCS 9908030313 | |
| Download: ML20210H247 (7) | |
Text
I USEC A Gobal Energy Company July 22,1999 GDP 99-0120 Dr. Carl J. Paperiello Director, Office of Nuclear Material Safety and Safeguards Attention: Document Control Desk U.S. ' Nuclear Regulatory Commission Washington, D.C. 20555-0001 Portsmouth Gascous Diffusion Plant (PORTS)
Docket No. 70-7002 Certificate Amendment Request - Update the Application Safety Analysis Report - Proposed Changes
Dear Dr. Paperiello:
By letter dated October 31,1997 (Reference 1), USEC submitted a certificate amendment request (CAR) containing the Safety Analysis Report Update (SARUP) required by Issue 2 of DOE /ORO-2027, " Plan for Achieving Compliance with NRC Regulations at the Portsmouth Gaseous Diffusion Plant" (the Compliance Plan), for NRC review and approval. By letters dated April 30,1998 (Reference 2), October 19,1998 (Reference 3), Novembcr 20,1998 (Reference 4), May 10,1999 (Reference 5), and June 1,1999 (Reference 6) USEC submitted proposed changes to the SARUP certificate amendment request. This letter provides additional changes to the SARUP certificate amendment request. These changes to the SARUP certificate amendment comprise the third set of SARUP Technical Safety Requirement (TSR) changes, changes to SARUP Section 3.8, and S ARUP Chapter 4 that were discussed in USEC's letter to NRC dated February 25,1999 (Reference 7).
The proposed changes in References 5,6, and herein replace the original SARUP TSRs wth revisions to current TSRs that are included in Volume 4 of USEC's Certification Application (USEC-02). This third set also inciudes TSR Limiting Conditions for Operation (LCOs) and Design Features which were not in USEC-02 but were included in the original SARUP TSR submittal.
These changes were made to provide consistency with the safety basis established in the SARUP analysis.
9900030313 990722 1 / O l.
PDR ADOCK 07007002 Qf \\/
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PDR 6903 Rocidedge Drive, Bethesda, MD 20817-1818 Telephone 301-564-3200 Fax 301564-3201 http://www.usec.com Offices in Uvermore, CA Paducah, KY Portsmouth, OH Washington, DC
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Q Dr. Carl J. Paperiello July 22,1999 GDP 99-0120, Page 2
)
The changes to Section 3.8 and Chapter 4 include:
.(1) -
changes to operating mode terminology and system names (to provide consistency with USEC-02 system names);
(2) changes resulting from proposed responses to NRC questions; (3)'
changes necessary for consistency with the integration of USEC-02 and SARUP
}
TSRs;
-(4) changes made in accordance with item 5.c of the Plan of Action and Sched mr Compliance Plan Issue 2. to this letter provides a detailed description of the proposed changes. Revised SARUP
)
pages, dated July 9,1999, are provided in Enclosure 3. Revisions are noted (TSRs from current USEC-02 TSRs and SARUP text from previous SARUP text) by a revision bar in the right-hand page margin for the TSRs, and by a revision bar in the left-hand margin for Chapters 3 and 4. The conclusions stated in Enclosure 2 to Reference 1, that the proposed changes associated with the CAR are significant, are not affected by this revision and thus no significance determination is provided.
Any questions regarding this matter should be directed to Mark Smith at (301) 564-3244. There are no new commitments contained in this submittal.
' Sincerely, 0
S. #,
6 Steven A.Toelle Nuclear Regulatory Assurance and Policy Manager
References:
- 1. Letter from James H. Miller (USEC) to Dr. Carl J. Paperiello (NRC), Certificate Amendment Request - Update the Application Safety Analysis Report, USEC j
Letter GDP 97-0189, October 31,1997.
- 2. Letter from James H. Miller (USEC) to Dr. Carl J. Paperiello (NRC), Certificate i-Amendment Request - Update the Application Safety Analysis Report - Proposed i
Changes, USEC Letter GDP 98-0096, April 30,1998.
i l
)
- 3. Letter from Steven A. Toelle (USEC) to Dr. Carl J. Paperiello (NRC), Certificate I
l' Amendment Request - Update the Application Safety Analysis Report - Proposed Changes, USEC Letter GDP 98-0212, October 19,1998.
i i:
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L Dr. Carl J. Paperiello July 22,1999 GDP 99-0120, Page 3 References (continued) l
_4.
Letter from Steven A. Toelle (USEC) to Dr. Carl J. Paperiello (NRC), Certificate Amendment Request - Update the Application Safety Analysis Report - Proposed l
Changes, USEC Letter GDP 98-0251, November 20,1998.
- 5. Letter from Steven A. Toelle (USEC) to Dr. Carl J. Paperiello (NRC), Certificate Amendment Request - Update the Application Safety Analysis Report - Proposed Changes, USEC Letter GDP 99-0076, May 10,1999.
- 6. Letter from Steven A. Toelle (USEC) to Dr. Carl J. Paperiello (NRC), Certificate Amendment Request. Update the Application Safety Analysis Report - Proposed Changes, USEC Letter GDP 99-0084, June 1,1999.
l l
- 7. Letter from Steven A. Toelle (USEC) to Dr. Carl J. Paperiello (NRC), Certificate l
Amendment Request - Update the Application Safety Analysis Report - Adoption of Current Application Technical Safety Requirements, USEC Letter GDP 99-0042, February 26,1999.
Enclosures:
- 1. Oath and Affirmation
- 2. United States Enrichment Corporation (USEC), Proposed Changes, Certificate Amendment Request, Update the Application Safety Analysis Report, Detailed Description of Change
- 3. Proposed Changes, Certificate Amendment Request, Safety Analysis Report Update, Insertion / Removal Instructions, July 9,1999 l
cc: Robert Pierson, NRC Special Projects Branch Patrick Hiland, NRC Region III David Hartland. NRC Resident Inspector - PORTS Ken O'Brien, NRC Resident Inspector - PGDP Randall DeVault, DOE Regulatory Oversigh't Manager l
l' L
i I,,
l
o OATH AND AFFIRMATION I, Steven A. Toelle, swear and affirm 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 these proposed changes to the Safety Analysis Report Update for the Portsmouth Gaseous Difrusion Plant, as described in GDP 99-0120, 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.
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- 5. B.
/J Steven A.Toelle On this 22nd 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 1
that he executed the same for the purposes therein contained.
in witness hereofI hereunto set my hand and official seal.
f ikD /7?
8 o,
a'ne't hUooth'e, Notary Public
' tate of Maryland, Montgomery County My commission expires June 23,2003 6
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GDP 99-01:'.0 Page1af3 United States Enrichment Corporation (USEC)
Proposed Changes Certificate Amendment Request Update the Application Safety Analysis Report Detailed Description of Change 1.0 Purpose The purpose of this submittal is to provide revised pages, dated July 9,1999, to the Safety Analysis Report Update (SARUP) previously transmitted in USEC letters GDP 97-0189, dated October 31, 1997 (Reference 1), GDP 98-0096, dated April 30,1998 (Reference 2), GDP 98-0212, dated October 19,1998 (Reference 3), GDP 98-0251, dated November 20,1998 (Reference 4), GDP 99-0076, dated May 10,1999 (Reference 5), and GDP 99-0084, dated June 1,1999 (Reference 6) for NRC review and approval.
2.0 Description of Submittal The following changes are included in this submittal which modify the latest version of the SAR Update certincate amendment request. The revised pages are included in Enclosure 3.
A.
The Revision Log has been updated to reflect the changes included in this revision.
B.
The List of Effective Pages has been updated to reflect the changes included in this revision.
C.
The proposed changes in Reference 5,6, and herein replace the original SARUP TSRs with revisions ofcurrent TSRs that are included in Volume 4 of USEC's Certification Application (USEC-02). This third set also includes TSR Limiting Conditions for Operation (LCOs) and Design Features for systems which did not have a USEC-02 TSR but were included in the original SARUP TSR submittal such as: motor load indicators (cascade and withdrawal station); autoclave locking ring interlock; high pressure fire water sprinklers in X-343; liquid cylinder handling scale carts and railcars; process building cranes; and compressor motor trips for certain withdrawal station compressors. These changes were made to provide consistency with the safety basis established in the SARUP analysis. In some cases, minor changes have been made to the original SARUP TSR wording as a result of further plant consideration.
D.
The changes to SARUP Section 3.8 include:
(1) changes to operating mode terminology and system names (to provide consistency with USEC-02 system names);
(2) changes resulting from proposed responses to NRC questions; L
l GDP 99-0120 Page 2 of 3 (3) changes necessary for consistency with the integration of USEC-02 and SARUP TSRs; (4) changes made in accordance with item 5.e of the Plan of Action and Schedule for Compliance Plan Issue 2. This latter set includes: changes to remove references to inadequacies in supported piping at ERP, LAW and Tails withdrawal facilities (refer to Reference 1, Table 1, item 13); changes to remove references to structural j
deficiencies in the XT-847 Waste Management Storage Facility that were corrected as committed in Reference 1, Table 1, Item 9; and changes to boundary definitions for Q, AQ, and AQ-NCS SSCs to provide consistency with changes to plant boundary manuals.
E.
The changes to SARUP Chapter 4 include:
)
(1) changes to operating mode terminology and system names (to provide consistency with USEC-02 system names);
(2) changes resulting from proposed responses to NRC questions; and (3) changes made in accordance with item 5.c of the Plan of Action and Schedule for Compliance Plan Issue 2. This latter set includes: changes to remove references to inadequacies in supported piping at ERP, LAW and Tails withdrawal facilities (refer to Reference 1, Table 1, Item 13); changes to clarify what is encompassed by the term " pigtail connection"in the accident analysis; changes to remove references to HEU refeed process and include the side feed process; and changes to remove references to structural deficiencies in the XT-847 Waste Management Storage Facility that were corrected as committed in Reference 1, Table 1, item 9.
3.0 Basis for the Revision
[ Items A, B, C, D(1), D(3), E(1)] As discussed iu Reference 7, USEC presented in a February 12.
1999 meeting between USEC and NRC, USEC's intention to delete the original SARUP TSRs and adopt a revised version of the current TSRs. The TSRs in this third set of"new" SARUP TSRs include TSRs not submitted in References 5 and 6 that were changed or added to provide consistency 1
with the safety basis established in the SARUP analysis.
[ltems D(2) and E(2)] Changes were made to address questions raised by the NRC during the review of SARUP.
[ Items D(4) and E(3)] Two of the items (changes to correct inadequacies in supported piping at ERP.
]
LAW and Tails withdrawal facilities and changes to remove references to structural deficiencies in the XT-847 Waste Management Storage Facility that were corrected as committed in Reference 1, Table 1, Item 9) were made to satisfy previous commitments. The changes to boundary definitions were made to clarify system boundariec as part of efforts to improve the boundary definitions.
Changes to clarify the term " pigtail connection" were made to more accurately reflect passible j
l
g t-GDP 99-0120 Page 3 of 3 fhilure mechanisms. The change to remove the reference to IIEU refeed process and replace it with a reference to the side feed process addresses the completion ofIIEU refeed and the existence of the side feed process which is already discussed in the USEC-02 application. All of these changes were determined to have negligible safety impact.
References 1.
Letter from James II. Miller (USEC) to Dr. Carl J. Paperiello (NRC), Certificate Amendment Request - Update the Application Safety Analysis Report, USEC Letter GDP 97-0189, October 31,1997.
2.
Letter from James H. Miller (USEC) to Dr. Carl J. Paperiello (NRC), Certificate Amendment Request - Update the Application Safety Analysis Report - Proposed Changes, USEC Letter GDP 98-0096, April 30,1998.
3.
Letter from Steven A. Toelle (USEC) to Dr. Carl J. Paperiello (NRC), Certificate Amendment Request - Update the Application Safety Analysis Report - Proposed Changes,
)
USEC Letter GDP 98-0212, October 19,1998.
1 4.
Letter from Steven A. Toelle (USEC) to Dr. Carl J. Paperiello (NRC), Certificate Amendment Request - Update the Application Safety Analysis Report - Proposed Changes,
'USEC Letter GDP 98-0251, November 20,1998.
5.
Letter from Steven A. Toelle (USEC) to Dr. Carl J. Paperiello (NRC), Certificate Amendment Request - Update the Application Safety Analysis Report - Proposed Changes, USEC Letter GDP 99-0076, May 10,1999.
6.
Letter from Steven A. Toelle (USEC) to Dr. Carl J. Paperiello (NRC), Certificate Amendment Request - Update the Application Safety Analysis Report - Proposed Changes, USEC Letter GDP 99-0084, June 1,1999.
7.
Letter from Steven A. Toelle (USEC) to Dr. Carl J. Paperiello (NRC), Certificate Amendment Request - Update the Application Safety Analysis Report - Adoption of Current Application Technical Safety Requirements, USEC Letter GDP 99-0042, February 26,1999.