ML20210K838
| ML20210K838 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 08/11/1997 |
| From: | John Miller 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-97-0140, GDP-97-140, NUDOCS 9708200131 | |
| Download: ML20210K838 (13) | |
Text
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y Enrichment Corporation 2 0emocracy Center 6903 nockledge Drive Bethe6da. MD 20817 Tel. (301) 664 3200 rer(301)664 3201 JAuts H. MILLER Dir: (301) 504 3309 Vice PRC&lDENT, PaooucTioN For (301) 6718270 l
l August 11.1997 Dr. Carl J. Paperiello SERIAL: GDP 97-0140 Director, OlTice of Nuclear 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 Compliance Plan Issue 3, Autoclave Upgrades
Dear Dr. Paperiello:
In accordance with 10 CFR 76AS, the United States Emichment Corporation (USEC or Corporation) hereby submits a request for amendment to the cenificate of compliance for the Paducah, Kentucky Gaseous DitTusion Plant. This certificate amendment request modifies one of the action items in the Description of Noncompliance, Justification for Continued Operation, and the Plan of Action and Schedule specified in the DOE /ORO-2026, Plan for Achieving Compliance with NRC Regulations at the Paducah Gaseous Diffusion Plant (Compliance Plan), Revision 3, Change A, for issue 3, Autoclave Upgrades.
This action item (Issue 3, Action item 7) provides for the modification of the C-360 autoclave controls to add a low instrument air pressure switch to initiate containment upon loss ofinstrument air.
llowever, recent evaluation of this prescribed modification has determined that providing a second channel for high pressure containment that does not rely on instrument air is an improved alternative.
In addition, this request proposes to change the implementation date for this action item from August 31, 1997 to October 31,1997, to coincide with completion of another Compliance Plan action item (Issue 3, Action item 4) which will also require shutting down C-360 operations while the modifications are made.
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Dr. Carl J..Paperiello August 11,1997 GDP 97-0140 Page 2 Enclo>ure I to this letter provides a detailed description and justification for the proposed change. Er. closure 2 contains insen and removal instructions and revised pages for Compliance Plan issue 3. Enclosure 3 contains the basis for USEC's detennination that the proposed change associated with this certificate amendment request is not significant.
This proposed certificate amendment request affects a Compliance Plan commitment due August i
31,1997. Since operation of the C 360 facility beyond the current duc date will require NRC approval, USEC requests that this Certificate Amendment Request (CAR) receive highest priority of all Paducah CARS submitted to date and that NRC review and approval of this Certificate Amendment Request occur prior to August 31,1997. In the event that review and approval does not occur prior to August 31,1997, USEC requests permission to continue operation of the C 360 facility under the existing JCO for issue 3, Action item 7 contained in the Compliance Plan until this CAR is reviewed and apl, roved. The amendment should become effective upon issuance.
Any questions related to this subject should be directed to Mr. Mark Smith at (301) 564-3244, There are no new commitments contained in this submittal.
- Sinegely, M
s art s 11. Miller
'4ce President, Production
Enclosures:
As Stated cc:
NRC Region I:1 Office NRC Resident inspector PGDP NRC Resident inspector-PORTS DOE Regulatory Oversight Manager l
l l
9 OATil AND AFFIRMATION 1 James II. Miller, swear and afflim that I am Vice President, Production, 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, that I am familiar with the contents thereof, and that ti.e statements made and matters set forth therein are true and correct to the best of my knowledge, information, and l
belief.
, As James 11. Miller On this lith day of August,1997, the officer 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 hereof I hereunto set my hand and official seal.
AblLL b -
ALO U Vn
/ 'aurie M. Knisley, Notary Public c/
I, State of Maryland, Montgomely County My commission expires March 17,1998
ODP 97 0140 Page1of2 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Compliance Plan issue 3, Autoclave Upgrades Detailed 1)escription of Change Compliance Phm issue 3, Action item 7 provides for the modification of the C 360 autoclave controls to add a low instrument air pressure switch to initiate containment upon loss ofinstrument air, llowever, recent evaluation of this prescribed modification has detennined that providing a second channel for high pressure containment that does not rely on instrument air is a better alternative, in addition, this request proposes to change the implementation date for this action item from August 31,1997 to October 31,1997 to coincide with completion of another Compliance Plan action (Issue 3, item 4) which will also require shutting down C 360 operations while the
. modifications are made, 2
One channel of the existing C 360 Autoclave liigh Pressure Isolation, Steam Pressure Control and Opening Prevention Systems would be disabled if the instrument air system failed. The pressure switches for the "A" channel of these systems (PSilli *15A, PSil *15A and PSL *15A) receive a pneumatic signal from PT
- 15A, a pneumatic pressure transmitter. The signal air to this 4
pressure transmitter is supplied by the instrument air system in C 360. If the instrument aH ystem should develop a leak, the pressure transmitter would not be capable of providing the correct output signal and the pressure switches would not be capable of performing their intended safety function.
This deficiency is documented in Compliance Plan issue 3, Action item 7. The Description of Noncompliance section states that the C 360 autoclaves do not have a low instrument air switch to initiate containment upon loss ofinstrument air. The Plan of Action and Schedule section states that low instrument air pressure switch will be added to the autoclaves in C 360 to initiate containment upon loss ofinstrument air. The scheduled completion date for this action is August 31,1997.
1 An engineering evaluation of the modification described in the Compliance Plan detemiined that it would be preferable to remove the pneumatic switches (PSilli
- 15A and PSil *15A) from the pneumatic output of PT *15A and install new mechanical-electrical pressure switches similar to PSilli
- 15B and PSil
- l5B to directly read autoclave pressure. These mechanical electrical type pressure switches do not rely upon instrument air to perform their safety functions and fall in a safe condition upon loss of electrical power. This change will provide two safety channels for this system which do not rely on instrument air. This will also preclude putting the autoclaves into containment upon a loss ofinstmment air when there would otherwise be no reason to do so. This is undesirable while a cylinder is in the 3 o' clock position and being sampled. If an autoclas e is put into containment in this situation, the UF. in the cylinder and the pigtail could solidify, making it diflicult to recover from such an unnecessary isolation.
The proposed change would revise the Description of Noncompliance to more clearly indicate that one of the channels relied upon for initiating containment would be disabled upon loss of b
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GDP 97 0140 Page 2 of 2 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Compliance Plan lasue 3 Autoclave Upgrades Detailed 1)escription of Change instrument air. The Justification for Continued Operation and the Plan of Action and Schedule l
sections would be revised to refer to the addition of a second channel for containment isolation l
which is not dependent on instrument air.
This request also proposes to change the implementation date for this action item from August 31,1997 to October 31,1997. Action item 4, which calls for the replacement of pressure monitoring instmmentation serving the autoclave safety systems and defense-in-depth systems for C 333A, C-337A, and C-360 autoclaves,is scheduled for completion by October 31,1997. That modification will also require that operations in C 360 be shut down for implementation. The work in C 360 for that modification is currently scheduled to be performed during September. The proposed change in this request would allow USEC to perfonn both modifications at the same time, therefore requiring only one shutdown and startup evolution for the autoclaves in C-360.
GDP 97 0140 Page1of5 Proposed Certificate Amendment Request Paducah Gaseous Dinslon Plant Letter GDP 97 0140 Removal / Insertion Instructions Remove Pages Insert Pages Compliance Plan lasue 3 lasue 3 Pages 3/4, S/6 Pages 3/4, S/6
Autodag e Upgrades issue 3, Page 3 downstream from a check valve in the line which prevents loss of nitrogen pressure. The nitrogen bottle which supplies the system with backup nitrogen is a 1.55 ft' tank and must have an indicated pressure of at least 1200 psig. The nitrogen is regulated to an indicated 80 psig.
1 Check valve operability is verified during quarterly testi b
3 y monitoring for detectable flow from tubing located upstream from the check valve that is open to atmosphere (no detectable flow after nitrogen has been supplied to the supply header down stream from the check valve indicates the valve has seated properly). Another indication of proper check valve perfonnance is closing l
a cylinder valve using the nitrogen backup (also part of the quanerly test). If the cylinder valve will close within the required 30 second using nitrogen, then the check valve is providing sufficient l
resistance to backflow for the system to function properly if called upon to do so."
l l
3.6.7.5 Autoclave liigh Pressure isolation System [Rev. 3, 5/31/96]
"The autoclave high pressure isolation system causes the autoclave to go into the containment mode and sound an alann if the internal pressure of the autoclave reaches 15 psig. The relay logic does not currently lock out the autoclave hydraulles upon autoclave high pressure isolation system l
l actuation. Ilowever, the alarm response procedure and emergency response procedure do not direct autoclave opening until the alann condition is cleared. This system is identified as a system required to be included in the TSR."
3.6.7.7 Operational Systems [Rev. 3, 5/31/96]
"The cylinder pressure relief system relieves pressures in excess of 100 psig from the feed cylinder to the cylinder relief tanks, and closes the steam supply isolation valves and the thennovent line block valve....
The autoclave opening prevention system is used to prevent the opening of an autoclave when the internal pressure exceeds 1.25 psig and gives a visual indication....
The cylinder roll interlack prevents the rolling of a cylinder while the pigtall is pressurized."
DESCRIPTION OF NONCOMPLIANCE This issue involves a total of twenty two autoclaves. There are eight autoclaves in C-333A, ten autoclaves in C-337A, and four autoclaves in C-360. There are no autoclaves in C 310 or C 315, but liquid UP. is transferred to product withdrawal cylinders there.
1.
The three manual push buttons for the C 333A and C 337A autoclave containment system, one at the OMR door, one at the crane bay exit near the local cylinder yard, and one in the ACR used to place the autoclaves into containment upon confinnation of a UF. release, are not installed.
2.
The reset function for the C-333A and C-337A Autoclaves liigh-Pressure isolation System initiates the opening of certain containment valves. This could result in the opening of valves that are not intended to be opened.
PGDP Rey,3,7/t7/96
Issue 3, Page 4 PROPOSI:1)
Aun tne ttomio 3.
The indicating range for the pressure transmitters on the autoclave opening prevention and cylinder roll interlock systems in C 360 is so much larger than normal operating pressures that calibration and instrument accuracies cannot be assured.
4.
The present pressure monitoring instrumentation does not have the capacity, accuracy, and resolution to reliably measure the vacuum required by UF piping test procedure to verify integrity of piping connections. In addition, the present pressure monitoring instrumentation on the autoclaves in C 333A, C 337A, and C 360 has too large of a pressure range to accurately measure the small difference between the operating and the steam shutoff (8 psig) pressure.
I 5.
'The SAR Upgrade activities have identified transfer and sampling piping in C 360 where the UF. detection systems located in Zones I and 4 initiate c'osure of only one contahunent isolation valve on the transfer / sampling piping.
l l
l 6.
The perfonnance criteria and test plan for determining plant air isolation check valve operability on loss of plant alt and for allowing the bottled nitrogen system to operate the emergency valve closing for C 310, C 315, and C-360 has not been developed.
7.
For the autoclaves in C-360, one of the channels relied upon for initiating containment on a high pressure indication would be disabled upon loss of instrument air.
8.
The relay logic for the autoclaves in C 360 does not lock out the hydraulics to prevent the autoclaves from being inadvertently opened when an Autoclave liigh Pressure Isolation System containment signal is present.
9.
The transfer manifold for the parent-daughter transfer operation in C 360 is not provided with pressure relief protection.
- 10. The capability to perform a pressure decay test separately for the inner and outer contairunent valves, and assuring that backpressure does not mask leaks, does not exist for all autoclaves in C-333A, C 337A, and C 360.
JUSTIFICATION FOR CONTINUED OPERATION 1.
In the event of a release of UF. in C-333A or C 337A, the UF. detection system will actuate an annunciator in the OMR, the ACR, and the CCF. In response to such an alann where more than one indication of UF. release has occurred, the following actions will be required:
Personnel will immediately evacuate the local area of the feed facility except for the OMR in accordance with the "see and flee" policy.
The OMR operator will place the operating autoclaves into containment by placing the conductivity cell meters in the check calibration mode (simulating a high-high conductivity signal). To ensure that the conductivity cell meters will adequately perform this function, quarterly channel functional surveillance tests are performed.
PGDP RAC # 97C177, R/l1/97
4 Autoclave Uppades PROPOSED
!ssue 3. Page 5 Following initial evacuation and placement of the autoclaves into containment, the alann response procedure requires that an operator don protective clothing and tespiratory protection and investigate the alarm. The operator will use llF detection equipment to determine the presence ofIIF, indicating a release of UF..
Also, until the autoclave manual isolation pushbuttons are installed, quarterly system channel functional tests to verify containment valves closure and quarterly tests of each UP. detection head will be performed.
2.
The Autoclave liigh-Pressure isolation System cannot be reset until the autoclave pressure is belo v 15 psig, the limiting safety system setting. Until the control logic is modified so that the corstainment valves remain closed after reset of the containment signal, the operating procedure requires the operator to manually close these valves immediately after resetting the Autoclave liigh Pressure Isolation System.
3.
The autoclaves in C 360 are not currently in operation and will not be placed into operation until the pressure transmitters on the autoclave opening prevention and cylinder toll interlock systems are replaced.
4.
Until replaced, the present pressure mon'toring instmmentation for the C 333A, C 337A, and C 360 autoclaves is adequate to provide marginally acceptable capacity, accuracy, and resolution for autoclave operation. Also, the s: cam shutoff pressure trip is set sufficiently low to ensure that the desired 8 psig is not exceeded.
5.
Until the UF. detection systems for Zones 1 and 4 are modified, sampling will not be allowed during transfer operations. Also, the operating procedure requires the operator to ensure that the drain valves remain shut when sampling operations are conducted.
6.
The bottled nitrogen backup system for C-310 C-315, and C-360 is currently out of service, in C-310 and C 315, trie plant air supply to the cylinder valve is being periodically verified by operator surveillance to ensure operability. Upon identification of a loss of the plant air supply, administrative controls require manual closure of the cylinder valve (s). This surveillance is not currently being perfomied in C-360 as tht cylinder valve closer system is out of service.
7.
For the autoclaves in C-360, there is redundant instrumentation to initiate containment upon a high-pressure indication. One channel of this instrumentation is a pressure switch which is not dependent on instrument air to perform its containment initiation function. This is sufficient for safe operation until a second channel which is not dependent on instrument air l
is added.
8.
The alarm and emergency response procedures for the autoclaves in C 360 only allow the operator to open the autoclaves after clearing the alarm condition via an administratively controlled key switch. Also, the autoclave opening prevention system locks out the hydraulics to prevent the autoclaves from being opened when the pressure is greater than 1.25 psig. The autoclave opening prevention system is tested quarterly to verify its ability to perform this function.
9.
The design of the liquid transfer for the parent-daughter transfer of UF. In C 360 was constrained by the need to protect against a catastrophic release of liquid UF, to the work or PGDP RAC# 97CI77,8/l1/97
_.___.___m.
l lesue 3, Page 6 PROPOSF.D Autoctme tyrmin general environment. This constraint was addressed by providing a set of administrative procedures, four independent controls on the source of heat, and two sets of doubly redundant steam cutoffs.
l i
- 10. Until the capability to perfonn a pressure decay test separately for the inner and outer containment valves, and assuring that backpressure does not mask leaks, is provided for all autoclaves in C 333A, C 337A, and C 360, the following surveillance tests will be perfonned:
(1) quarterly channel functional tests to verify containment valve closure and (2) quarterly overall autoclave containment pressure decay or leak rate.
ne above discussion provides justification that the plant can continue to operate safely until the autoclave upgrades are installed as discussed in the Plan of Action and Schedule.
l PLAN OF ACTION AND SCllEDULE T
1.
The C 333A and C 337A autoclave containment systems will be modified by installing three manual push buttons, one at the OMR door, one at the crane bay exit near the k> cal cylinder yard, and one in the ACR which can be used to place the autoclaves into containment upon confinnation of a UF. release. The r,cheduled completion date for these actions (with the exception of NRC approval of the associated TSR) is September 30,1996. The scheduled date for submittal of the TSR to the NRC is October 31,1996, 2.
The control logic for the C 333A and C 337A Autoclave liigh-Pressure Isolation System will be modified such that upon reset of the containment signal, the valves will remain closed, but the valves can be opened by subsequent operator action. [ Complete]
3.
The pressure transmitters for the autoclave opening prevention and cylinder roll interlock i
systems in C 360 will be replaced. [ Complete]
4.
De p; essure monitoring instrumentation serving the autoclave safety systems arxl defense-in-deptn systems for C 333A, C 3337A, arxl C-360 autoclaves will be replaced. The scheduled completion date for this action is October 31,1997, 5.
The UP. detection systems for Zones 1 and 4 will be modified such that upon detection of a UP release, multiple valves (FW'50, *52, and *47 from Zone 1 and FV *47 and '49 from Zone 4) will be closed on the transfer and/or sampling piping. The scheduled completion date for this action is August 31,1997.
6.
Performance criteria and a test plan will be developed to demonstrate whether the nitrogen backup can close the cylinder valve in 30 seconds in C 310,- C 315, and C 360. Further design requirements will be completed pending the outcome of this testing. The scheduled completion date for this action is December 31,1996.
7.
Add a second channel, which is not dependent upon instrument alt, to the autoclaves in C 360 to initiate containment upon a high-pressure indication. The scheduled completion date for this action is October 31,1997, i
I PGDP RAC # 97C177,8/11/97 l
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GDP 97 0140 Page1of3 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Compilance Plan Issue 3, Autoclave Upgrades Signifleance Determination The United States Enrichment Corporation (USEC) has reviewed the proposed changes associated with this certificate amendment request and provides the following Significance Determination for consideration.
- 1. No Signincant Decrease in the Effectiveness of the Plant's Safety. Safeguards or Security hostains l
l The proposed change to the Compliance Plan does not affect any of the plant's safety, safeguards or security programs. The proposed change is a better alternative for providing two safety channels for initiating autoclave containment in the C 360 autoclaves. Therefore, there is no significant decrease in the effectiveness of the plant's safety, safeguards or security programs.
L
- 2. No SignlHeant Change to Any Conditions to the Cgnincate of Comnliance None of the Conditions to the Certificate of Compliance for Operation of Gaseous DifTusion j
plants (GDp 1) specifically address any autoclave safety systems. The proposed change is a better alternative for providing two safety channels for initiating autoclave containment in the C-360 autoclaves. Thus, the proposed change will have no impact on any of the Conditions to the Certificate of Compliance.
- 3. No SignlHeant Change to Any Condition of the Approved Compliance Plan The proposed change is a better alternative for providing two safety channels for initiating autoclave containment in the C 360 autoclaves. Therefore, this does not represent a significant change to the approved Compliance Plan.
- 4. No Signincant Increase in the Probability of Occurrence or Consequences of Previously Evalunted Accidents The applicable accidents evaluated in the SAR are Failure of Controls, Criticality, and Seismic event. The proposed change to the Compliance Plan will not significantly increase the probability of occurrence of these accidents because it will reduce the failure modes of the liigh Pressure Isolation and Steam Pressure Control systems. Also, the request for extending the completion date for two months will not significantly increase the probability of the accidents because the existing Justification for Continued Operation will remain in efTect. The consequences of these accidents are not increased because the functions of these systems will not be changed. Therefore, the proposed change will have no effect on the probability of occurrence or consequences of previously evaluated accidents.
ODP 97 0140 Page 2 of 3 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Compilance Plan lisue 3. Autoclave Upgrades Signifleance Determination
- 5. No New or Different Type of Accident The applicable accidents evaluated in the SAR are Failure of Controls, Criticality, and Seismic event. The proposed change to the Compliance Plan will not create any new or different type of accident because it will not change the functions of the liigh Pressure Isolation and Steam Pressure Control Systems. Therefore, no new or difTerent type of accident could result from this change.
- 6. No Significant Reduction in Margins of Safety The safety limit associated with this change is the autoclave shell pressure shall not exceed 165 psig. The proposed change to the Compliance Plan will not change this safety limit and will not change the function of the liigh Pressure Isolation System. Therefore, the proposed change will not result in any reduction in margins of safety.
- 7. No Significant Decrease in the Effectiveness of any Programs or Plans Contained in the Certificate AnnlicatiDD The Autoclave liigh Pressure Isolation and Steam Pressure Control systems are not mentioned in any of the Programs or Plans contained in the ccitificate application. Therefore, the proposed change will result in no significant decrease in the effectiveness of any programs or plans contained in the certificate application,
- 8. The Proposed Changes do not Result in Undue Risk to 1) Public IIcalth and Safety. 2) Common Defense and Security. and 3) the Environment.
The proposed change to the Compliance Plan does not affect any of tlqit's safety, s+3uards or security programs. As discussed in items 4 and 5 above, the prop med s Sange On i. ' result in a significant increase in the probability of occurrence or the conquences oQ4cx ously evaluated accidents and it will not create any new or different type of accident. Therefore, the proposed change does not result in undue risk to 1) public health and safety,2) common defense and security, and 3) the environment.
- 9. No change in the Tynes or Sienificant Increase in the Amounts of Anv Ellluents that May be Released OfTsite The proposed change to the Compliance Plan will not change the types or significantly increase the amounts of any effluents because it will not change the ftmetions of the liigh Pressure Isolation and Steam Pressure Control Systems. Therefore, the proposed change will result in no J
GDP 97 0140 Page 3 of 3 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Compliance Plan lasue 3, Autoclave Upgrades Significance Determination change in the types or significant increase in the amounts of any ellluents that may be released ofTsite.
- 10. No Signincant increase in Individual or Cumulative Occupational Rndlntion Exposure The proposed change to the Compliance Plan will not significantly increase any exposure to I
radiation because it will not change the functions of the liigh Pressure Isolation and Steam
_ Pressure Control Systems. Therefore, the proposed change will result in no significant increase l
in individual or cumulative occupational radiation exposure.
- 11. No Signincant Construction Imnact l
t 1hc proposed change to the Compliance Plan proposes a different method for addressing issue 3, item 7 related to the loss ofinstrument air. The proposed change will result in no significant impact to construction because the autoclaves will also be required to be out of service to implement modifications addressing issue 3, item 4 related to replacement of pressure monitoring instrumentation. The work required for the item 4 modification is significantly more extensive than that required for item 7. The scheduled completion date for Compliance Plan issue 3, item 4 is October 31,1997. The request to extend the completion date for Compliance Plan issue 3, item 7 will allow the coordination of work required for both of the projects and minimize the impact of shutdown and startup evolutions.
12.No Signincant Increase in the Potential for Radiological or Chemical Consequences from Previousiv Annlvzed Accidents The applicable accidents evaluated in the SAR are Failure of Controls, Criticality, and Seismic event. The proposed change to the Compliance Plan will not significantly increase the potential for radiological or chemical consequences of these accidents because it will reduce the failure modes of the liigh Pressure Isolation and Steam Pressure Control systems. Also, the request for extending the completion date for two months will not significantly increase the probability of the accidents because the existing Justification for Continued Operation will remain in effect.
The consequences of these accidents are not increased because the functions of these systems will not be changed. Therefore, the proposed change will result in no significant increase in the potential for radiological or chemical consequences from previously analyzed accidents.
-