ML20210T354
| ML20210T354 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 08/29/1997 |
| From: | Rifakes G 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-97-0151, GDP-97-151, NUDOCS 9709150065 | |
| Download: ML20210T354 (20) | |
Text
___
A United States
(
Enrichment Corpor: lion 2 C;mocr:cy C:nt;r 6903 Rockledge Drive Bethesda, MD 20817 k
Tel: (301)S64 3200 Faa:(301) 564 3201 GEoRoE P. RFAKES Dir; (301) 564 3301 EXECUTNE VicE PRESIDENT, OPERATIONS Fax: (301) 5713208 August 29,1997 Dr. Carl 1 Paperiello SERIAL: GDP 97-0151 Director, Office 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 - Closure of C-360 Autoclave Isolation Valves Following Zone 1 or Zone 4 UF, Detection
Dear Dr. Paperiello:
In.accordance with 10 CFR Part 76.45, the United States Enrichment Corporation (USEC or Corporation) hereby submits a request for amendment to the certificate of compliance for the Paducah, Kentucky Gaseous Diffusion Plant (GDP). This certificate amendment request revises Technical Safety Requirement (TSR) Sections 2.1.4.1 and 2.1.4.2a to include operability and surveillance requirements for additional valves required to close upon C-360 Zone 1 or 4 UF detection.
6 Compliance Plan Issue 3, item 5, identified a deficiency with the transfer and sampling piping in C-360 where the UF, detection system located in Zones 1 and 4 initiate closure of only one containment isolation valve on the transfer / sampling piping. The Plan of Action and Schedule for this item required system modification such that upon detection of a UF release, multiple valves (XV *50, XV *52 and /
FV *47 from Zone 1 and FV *47 and XV *49 from Zone 4) will be closed on the transfer and/or sampling piping. (NOTE: * = 1,2,3 or 4 for autoclave numbers 1,2,3 and 4 respectively.) Upo completion of the modifications associated with this Compliance Plan action, the following valves will isolate upon detection of a UF6 release. For Zone 1, valves FV *47, XV *48, XV *49, XV *50, XV *51 and XV *52 will close upon UF, detection. For Zone 4, valves FV *47, XV *49, XV *50, XV *52 and WV-042 will close upon UF. detection. The facility modifications associated with this Compliance Plan 1
- action will be completed in accordance with the Plan of Action and Schedule contained in the Compliance Plan.
9709150065 970829 itintimlinlig!IllllulEIIHittilPOp)jlg l% Q PDR ADOCK 07007001 li C
PDR Offices in Uvermore.Califomia Paducah. Kentucky Portsmouth. Ohio Washington. oC
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Dr. Carl J. Paperiello August 29,1997 GDP-97-0151, Page 2 to this letter provides a detailed description and justification for the proposed changes. is a copy of the revised TSR and SAR pages._ The TSR pages are provided for your review and approval. The SAR pages have been evaluated in accordance with 10 CFR 76.68. Based on the results of the 10 CFR 76.68 evaluation, the enclosed SAR pages do not require prior NRC review and approval and are provided for information only. These revised SAR pages reflect revisions associated with this certificate amendment request and may not reflect other approved changes to these SAR pages. contains the basis for USEC's determination that the proposed change associated with this certificate amendment request is not significant.
The Compliance Plan Issue associated with this modification (Issue 3, item 5) did not specifically identify that a revision to the TSRs was required to complete this action. As part of the modification process, it was identified that a change to the TSRs was required and is provided in Enclosure 2. Until the enclosed TSR is approved by NRC and implemented at PGDP, USEC will implement the current TSRs and continue to operate the C-360 facility under the Justification for Continued Operation (JCO) associated with Compliance Plan issue 3, Item 5 This JCO requires that sampling not be performed during transfer operations and that operators ensure that drain valves remain shut when sampling operations are conducted. This amendment should become effective 30 days from issuance.
Any questions related to this subject should be directed to lur. Steve Toelle at (301) 564-3250 or Mr.
Mark Smith at (301) 564-3244. Commitments contained within this submittal are provided in.
Sincerely,
/
George. Rifakes Executive Vice President, Operations
Enclosures:
As Stated cc:
.NRC Region Ill Oflice
' NRC Resident Inspector - PGDP NRC Resident Inspector - PORTS DOE Regulatory Oversight Manager j
9 OATil AND AFFIRMATION I, George P. Rifakes, swear and afGrm that I am Executive Vice President, Operations, of the United States Enrichment Corporation (USEC), that I am authorized by USEC to sign and file with the Nuclear Regulatory Commission this Certincate Amendment Request for the Paducah Gaseous Diffusion Plant, 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.
/5)
/
deorge P. Rifakes On this 29th 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.
l L'24ut b [ 7, La/ct b Laurie M. Knisley, Notary Public State of Maryland, Montgomery County My commission expires March 17,1998 a
I s
GDP 97-0151 Page 1 of 2 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Closure of C-360 Isolation Valves Following a Zone 1 or Zone 4 UF. Detection Detailed Description of Change Compliance Plan Issue 3, Item 5 identified a deficiency with the transfer and sampling piping in C-360 where the UF. detection system located in Zones I and 4 does not initiate closure of two containment isolation valves on each of the affected transfer / sampling pathways. The Plan of Action and Schedule for this item required system modification such that upon detection of a UF release, multiple valves (XV *50, XV *S2 and FV *47 from Zone 1 and FV *47 and XV *49 from Zone
- 4) will close on the transfer and/or sampling piping. (Note: * = 1,2,3, or 4 for autoclave numbers 1,2,3, and 4 respectively.) Upon completion of the modifications associated with this Compliance Plan Issue, the following valves will isolate upon detection of a UF6 release. For Zone 1, valves FV *47, XV *48, XV *49, XV *50, XV *51 and XV *52 will close upon UF detection. For Zone 4, valves FV *47, XV *49, XV *50, XV *S2 and WV-042 will close upon UF. detection. This will provide for the closure of at least two containment isolation valves for each possible UF. pathway.
This Certificate Amendment Request revises TSR 2.1.4.1 and 2.1.4.2a to estabiish TSR limiting conditions of operation and surveillance requirements for the above noted valves. Revisions to TSRs 2.1.4.1 and 2.1.4.2a are provided in Enclosure 2.
The specific changes proposed are as follows:
TSR Condition /
Current TSR Proposed TSR Surveillance Statement TSR 2.1.4.1, Condition D.
Valve XV *49 inoperable Valve FV *47, XV *49, OR XV *50, or XV *52 Either or both XV *50 and inoperable.
XV *S2 inoperable TSR 2.1.4.1, Condition F.
Valve XV *49 inoperable Valve XV *49 inoperable AND AND Either valve XV *50 or Either valve FV *47, XV-XV *52 inoperable.
- 50 or XV *52 inoperable.
TSR 2.1.4.1, SR 2.1.4.1-1 Test each Zone 1 UF release Test each Zone 1 UF release detection head to verify it detection head to verify it will detect " smoke" and close will detect " smoke" and close the appropriate UF. manifold the appropriate UF mamfold isolation valves (XV *48, isolation valves (FV *47, XV *49, XV *50, XV *51, XV *48, XV *49, XV *50, and XV *52).
XV *51, and XV *52).
TSR 2.1.4.2a, Condition C.
Valve XV *50 or XV *52 Valve FV *47, XV *49, inoperable.
XV *50 or XV *52 inoperable.
_ ~ ~. -
GDP 97-0151 Page 2 of 2 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Closure of C-%0 Isolation Valves Following a Zone 1 or Zone 4 UF, Detection Detailed Description of Change TSR Condition / '
Current TSR Proposed TSR Surveillance Statement TSR 2.1.4.2a, Condition D.
Valves XV *50 and XV *S2 Valve XV *52 inoperable.
AND Either valve FV *47, XV *49, or XV *50 inoperable.
TSR 2.1.4.2a,SR 2.1.4.2a-1 Test each Zone 4 (basement Test each Zone 4 (basement transfer room) UF. release transfer room) UF. release detection head to verify it detection head to verify it will detect " smoke" and will detect " smoke" and close the appropriate UF.
close the appropriate UF.
manifold isolation valves and manifold isolation valves the receiving cylinder valve.
(FV *47, XV *49, XV *SO The receiving cylinder valve and XV *S2), the transfer must close within 30 seconds line block valve (WV-ofdetection.
042)and the receiving cylinder valve. The receiving cylinder valve must close within 30 seconds of I
detection.
The proposed TSR changes ensure that the TSRs adequately address the modi 6ed plant -
configuration required by the Compliance Plan by establishing limiting conditions for operation and associated surveillance requirements to demonstrate the operability of the associated containment isolation valves. These TSR changes enhance the overall plant safety.
i
GDP 97-0151 9 Pages Total Proposed Certificate Amendment Request Paducah Gaseous Diffusion Plant Letter GDP 97-0151 Removal / Insertion Instructions Remove Pages Insert Pages Volume 1 Section 3.6 Section 3.6 Page 3,6-9/10, 3.6 17/18, 3.15-25/26 Page 3.6-9/9a, 3.6 10/10a, 3.6-17/18, 3.15 25/26 Volume 4 i
Section 2.1 Section 2,1 Page 2.1-13 through 2.1-16 Page 2.1-13 through 2.1-16
l SAR PGDP August 15, 1997 RAC 97Cl21 (RO)
As a result, high conductivity will be detected which will operate an interlock system to put the autoclave into containment.
3,6.7.2 UF. Detection Each autoclave, the 1sboratory room, and the basement area in C 360 are equipped with general nea UF detectors. The UF. release detection systems are uranged in snes. Zone 1 is the laboratory area, Zones 2 and 3 are the autoclave heads, Zone 4 is the basement area, and Zones 5 8 are the autoclave heated housings. Figure 3.6 5 provides a simplified schematic of the UF. release detection systems.
The laboratory area (Zone 1) contains two UF, detectors. When either detector is activated, the l
associated circuitry initiates closing the UF. sample line isolation valves, XV-?48 and XV *51, closing i
the UT.transferline isolation valves, FV '47, XV *49, XV *$0 2nd XV *52, and sounding of alarms.
This isolates all sample cabinets from their corresponding autodave. The alarms sound at the local autoclave panel, the C 360 supervisor's office, and in the CCF in C-300. The Zone 1 detection system does not initiate building containment.
Detector heads in the basement area (Zone 4) are located above the receiving cylinder pigtail, cold trap, the relief tanks, surge drums and on the ceiling in the transfer room. When any of these detector heads is actuated, the associated circuitry initiate closing the UF, transfer sample line and transfer line block valves on all autoclaves (FV *47,;XV;*49, XV *50 and XV *52), closing the transfer line blocid valve WV-042, closing the receiving cyllnder valve, actuating building containment which allows the automatic door closures on the drain station enclosure to close, providing confinement, and sounding alarms. The Zone 1 and portions of the Zone 4 detection systems are identified as systems required to be included in the TSR. The ponion of the Zone 4 system includes only those detector heads located within the transfer room.
The Zones 2 and 3 UF. detection systems are located above the autoclave heads. Zone 2 consists of the detectors over autoclaves 1 and 2, and Zone 3 consists of the detector heads over autoclaves 3 and 4.
If either detector head in a zone actuates, automatic transfer isolation valves close on the two autoclaves associated with that zone only. Actuation of the Zone 2 or 3 detection system also initiates building containment and initiates alarms sounding in the C 360 supervisor's office, and in the CCF in C 300.
Zones 5-8 consists of the detector heads sampling the heated housing of each autoclave. Alarms and the closure of the steam supply isolation valves are laitiated. The alarms sound in the C 360 supervisor's office, and in the CCF in C-300.
There is a time delay of 45 seconds between actuation of a PGLD head sending the building into containment and the closure of the overhead doors. Alanns sound to alert operators that the doors will close. The time delay allows the continued movement of the crane or scale cans to get out of the path of the closing doors.
3.6-9
SAR PGDP August 15, 1997 f
RAC 97C121 (RO)
The cylinder valve closer is air operated with a nitrogen backup, On loss of plant air or low l
plant air preasure, a pressure switch on the air supply line (set at or above 75 psig) actuates to open a solenoid valve which makes nitrogen available to the alt supply line. The cyllader valve can be closed by the i
4 4
3.6-9a
SAR PGDP May 31,19%
Rev. 3 niuogen in 30 seconds, ne d rogen connection to the air supply line is made downstream from a check t
valve in the line which prevents loss of nitrogen pressure. The nitrogen bottle which supplies the system 8
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.
Check valve operability is verified during quanerly testing by monitoring for detectable flow from tubing located upstream from the check valve that is open to atmosphere 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 performance is closing a cylinder valve using the nitrogen backup (also part of the quarterly test). If the cylinder valve will close within the required 30 seconds using nitrogen then the check valve is providing sufficient resistance to backflow for the system to function properly if called upon to do so.
3.6.7.3 Water Inventory Control As mentioned in Section 4.2.3, the maximum pressure generated in an autoclave from an accidental UF. release and subsequent reaction with the available water is best controlled by limiting the water in the autoclave. Redundant condensate !cvel probes LE *07 and LE *08 are mounted in the 3 in. drain pipe slightly below the autoclave level. A strainer basket is placed over the drain pipe to prevent trash from blocking the drain line, if the ultrasonic probes detect a high water level, the steam supply isolation valves X%*53 and FW*05 and the thermovent line block valve FV *34 close to limit the total water in the autoclave. his system has been designated a system required to be included in the TSR (see Figure 3.6-3).
3.6.7.4 Autoclave Steam Pressure Control The autoclave steam pressure control system is used to stop the steam flow to the autoclave while heating a :ylinder prior to reaching temperatures which could result in reaching the maximum allowable working pressure of the cylinder. This system is identified as a system required to be included in the TSR. The steam pressure control system closes the steam isolation valves and sounds an alarm if the autoclave steam pressure reaches the set point of a muimum of 8 psig. The components of this system are the pressure transmitter PT *15 and associated pressure switch PSH *15A, pressure switch PSH *15B, steam supply isolation valves X%*53 and FW'05, associated relays, solenoids and switches (see Figures 3.6 3 and 3.6-4),
3.6.7.5 Autoclave High Pressure Isolation System The autoclave high pressure isolation system causes the autoclave to go into the containment mode and sound an alarm if the internal pressure of the autoclave reaches 15 psig. The relay logic does not currently lock out the autoclave hydraulics upon autoclave high pressure isolation system actuation.
However, the alarm response procedure and emergency response procedure do not direct autoclave opemng until the alarm condition is cleared. His system is identified as a system required to be included in the TSR. The system components include the autoclave shell, head, and locking ring, pressure l
transmitter PT *15 and associated pressure switch PSHH *15A, pressure blind switch PSHH *15B, 3.6-10
SAR PGDP August 15, 1997 RAC 97C121 (RO)
BlankPage 3.610a
SAR PGDP August 15, 1997 RAC 97Cl21 (RO)
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- Some Room Cedng XV'49
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i Figure 3.6-5. Simplifted whamatic of the C 360 UF, detection system (Zones 1 & 4).
3.6-17 l
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SAR PGDP Av---- <.- 15,1995 Rev.1 N
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3.6 18
4 SAR PGDP -
August 15, 1997 RAC 97C121 (RO) 3.15.1.4.5 UF. Release Detection System Laboratory Area (Zone 1)
O Funetlog The UF release detection system provides the means to detect a UF. release in the sampling laboratory area. De system function is to isolate the sampling manifold from the parent cylinder by closing the sampling valves and end the release.
See Section 3.6.7.2 for a description of this system.
B.oundary ne system boundaries include:
a l
l 1.
Two UF. detector heads located in the laboratory area, YE 00$A and YE 00$B 2.
UF, detector control panel 3.
Sample liniisolation valves and transfer;line isolatioWalves 4.
Solenoid valves, and associated circuitry to close the valves.
5.
Alarms and associated alarm circuitry 3.15.1.4.6 UF Release Detection System Transfer Room (Portions of Zone 4)
QhvKil9A ne UF. release detection system provides the means to detect a UF. release in the transfer room when either of the two heads detect UF.. He system function is to automatically isolate the drain manifold from the parent cy!!nder by closing the block valves and automatically isolate the cylinder by closing the cylinder valve. (Building containment is also actuated but is not.1 credited Q function.)
See Section 3.6.7.2 for a description of this system.
Andary The system boundaries include:
1.
UF. detector heads located in the transfer room 2.
Autoclave drain line block valves 3.
Transfer tidbidifij valves siid'trshifei"Miiip'le;lisQQgg 4.
Cylinder valve closer 3.15-25 M
i SAR PGDP May 31,1996
^
Rev.3-
~
5.
Bacimp N supply l
6.
Aasociated solenoid valves and circuitry to close the valves.
l, 7.
Alarms and associated alarm circuitry l
The Q systems in those areas are described in Section 3.6.7.
I 3.15.1.4.7 UF Release Detection Systesa Heated Housings (Zones 54)
[
i t
- the UF. release detection system provides the means to detect a UF release in the heated housing.
The system function la to detect a UF. release and alarm. (The system also closes the steam supply isolation valves, but this is not part of its Q function.)
-l See Section 3.6.7.2 for a description of this system.
i Boundary The system boundaries include:
1.
UF detector heads located near the heated housing 2.
Alarms in the C 360 supervisor's office and C 300
(
+
3.
Associated alarm circuitry 3.15.1.4.8 Scale Cast Movement Prevention Systems O Function
.The scale cart movement prevention system prevent moving a scale cart with a pressurized pigtail attached.-
t See Section 3.6.9.1 for a description of this system.
Beisidur The system boundary includes:
1, Differendal pressure sensors
- 2. - Solenoid valves 4
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TSR PGDP PROPOSED August 29,1997 RAC 97C194 (RO)
SECTION 2.1 SPECIFIC TSRs FOR TOLL TRANSFER AND SAh!PLING FACILITY (C 360) 2.1.4 GENERAL LIhtITING CONDITIONS FOR OPERATION 2.1.4.1 UF, RELEASE DETECTION SYSTEh! LABORATORY (ZONE 1)
LCO 2.1.4.1: Zone 1 (Laboratory) of the UFe release detection system shall be operable.
APPLICABILITY: Modes: 7 ACTIONS:
Condition Required Action Completion Time A.
One Zone i detector head A.! Restore operability.
Prior to entering mode 7 on a inoperable, new operating cycle.
NOTE: The existing operating cycle may be completed.
B.
Both Zone 1 detector heads B.1 Stop operations in mode 7. Ihout inoperable.
M B.2 Evacuate sample manifold I hour (place the sample cabinet in mode 8 and the autoclave in mode 4).
C.
Valve XV.*48 or XV *51 C.1 Restore operability.
Prior to entering mode 7 on a inoperable, new operating cycle.
NOTE: The existing operating cycle may be completed.
4 D.
. Valve FV *47 XV *49 XV *50, D.1 Restore operability. See Prior to ent: ring mode 7 on a or XV *52 inoperable section 2.1.3.1 for impact new operating cycle on the autoclave.
NOTE: The existing operating cycle may be completed.
E.
Valves XV *48 and XV *51 E.1 Stop operations in mode 7 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> inoperable.
M E.2 Evacuate sample manifold Ihour (place the sample cabinet in mode 8). See section 2.1.3.1 for impact on the autoclave.
F.
Valve XV *49 inoperable F.1 Stop operations in mode 7 1 hout AND M
Either valve FV *47, XV *50 or F.2 Evacuate sample manifold I hour l
XV *52 inoperable.
(place the sample cabinet in mode 8). See section 2.1.3.1 for impact on the autoclave.
2.1-13
...w
.. - = - -
TSR PGDP PROPOSED August 29, 1997 RAC 97C194 (RO)
SECTION 2.1 SPECIFIC TSRs FOR TOLL TRANSFER AND SAA1PLING FACILITY (C 360) 2.1.4 GENERAL LIMITING CONDITIONS FOR OPERATION 2.1.4.1 UF. RELEASE DETECTION SYSTEM LABORATORY (ZONE 1)
(continued)
SURVEILLANCE REQUIREMENTS:
Surveillance Frequency SR 2.1.4.1-1 Test each Zone 1 UF. release detection head to Quarterly verify it will detect " smoke" and close the appropriate UF. manifold isolation valves (FV *47, l
XV *48, XV *49, XV *SO, XV *S1, and XV *52).
BASIS:
The reaction of UF. and water (free atmospheric humidity) in the case of a UF. release produces uranyl fluoride (UO:F ) as particulates and hydrogen fluoride (HF) as a gas which will hydrate.
The UO:F and HF*x(H O) are highly visible as " smoke." This system detects the presence of 2
2 this " smoke" in the laboratory area and isolates the parent cylinder from the release point.
[SAR Section 4.3.5.1.11 The functional test surveillance requirement associated with TSR 2.1.3.1 verifies valve closure times are within accident analysis assumptions on a quarterly basis. SAR Section 4.3.5.1.1 assumes the manifold valves will close in 10 seconds.
2.1-14
TSR PGDP PROPOSED August 29. 1997 RAC 97C194 (RO)
\\
SECTION 2.1 SPECIFIC TSRs FOR TOLL TRANSFER AND SAMPLING FACILITY (C 360) 2.1.4 GENERAL LIMITING CONDITIONS FOR OPERATION 2.1.4.2a UF RELEASE DETECTION SYSTEM BASEMENT TRANSFER ROOM (A PORTION OF ZONE 4)
LCO 2.1.4.2a: Zone 4 (Basement transfer room) of the UF, release detection system shall be operable.
APPLICABILITY: Modes: 6B ACTIONS:
Condition Required Action Completion Time A., One basement transfer A.! Restore operability.
Prior to entering mode 6B room detector head on a new operating cycle inoperable.
NOTE: The existing operating cycle may be with a new parent or completed.
daughter cylinder.
B.
Both basement transfer B.! Stop operations in mode 6B 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> room detector heads M
B.2 Evacuate transfer manifold (place the Ihour transfer station in mode 8).
B.3 Place the autoclave in mode 4.
I hour C.
Valve FV *4,
C.1 Restore operability.
Prior to entering mode 6B XV *49, XV *50 or on a new operating cycle XV *52 inoperable.
NOTE: The existing operating cycle may be with a new parent or -
completed.
daughter cylinder.
D.
Valve XV *$2 D.1 Stop operations in mode 6B 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> inoperable M
AND D.2 Evacuate transfer manifold (place the 1bour Either valve FV *47, transfer station in mode 8). See XV *49, or XV *50 2.1.3.1 for impact on the autoclave, inoperable.
E.
Valve WV 042 E.1 Stop operations in mode 6B 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> inoperable, M
E.2 Evacuate transfer manifold (place the Ihour transfer station in mode 8)
M E.3 Place the autoclave in mode 4.
Ihour F.
Receiving cylinder F.! Stop operations in mode 6B 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> vaWe emergency valve M closer inoperable.
F.2 Close the cylinder valve manually Ibour (valve closer may be removed)
M F.3 Evacuate transfer manifold (place the Ihout transfer station in mode 8)
M F.4 Place the autoclave in mode 4.
I hour 2.1-15
. -. -. -. =
TSRlPGDP PROPOSED August 29,1997
' RAC 97C194 (RO)
SECTION 2.1 SPECIFIC TSRs FOR TOLL TRANSFER AND SAMPLING FACILITY (C 360) 2.1.4 GENERAL LISIITING CONDITIONS FOR OPERATION 2.1.4.2a UF. RELEASE DETECTION SYSTEM - BASEMENT TRANSFER ROOM (A PORTION OF ZONE 4) (continued)
SURVEILLANCE REQUIREMENTS:
Surveillance Frequency SR 2.1.4.2a 1 Test each Zone 4 (basement transfer room)
Quarterly UF. release detection head to verify it will detect " smoke" and close the appropriate UF.
manifold isolation valves (FV *47, XV *49, XV *SO and XV *S2), the transfer line block valve (WV-042) and the receiving cylinder valve. The receiving cylinder valve must close withir. 30 seconds of detection.
SR 2.1.4.2a-2 Verify that nitrogen is available to power the Quanerly receiving cylinder valve closer air motor in order to close the cylinder valve (pressure check).
SR 2.1.4.2a-3 Verify that the automatic transfer from plant Quarterly air to nitrogen is operable for the receiving j
cylinder valve closer.
SR 2.1.4.2a-4 Verify that the check valve on the air supply Quarterly line to the transfer cylinder valve closer air motor just upstream of the nitrogen supply interface is operable.
BASIS:
The reaction of UF and water (free atmospheric humidity) in the case of a UF. release produces uranyl fluoride (UO F ) as particulates and hydrogen fluoride (HF) as a gas which will hydrate.
2 2 The UO F and HF*x(H 0) are highly visible as " smoke." This system detects the presence of 22 this " smoke" in the basement transfer room and isolates the parent and receiving cylinders from the release point, [SAR Section 4.3.5.1.1]
The receiving cylinder valve closer motor is driven by plant air and is backed up by bottled nitrogen in the event plant air header pressure is low concurrent with a demand for receiving cylinder valve closure.
The functional test surveillance requirement associated with TSR 2.1.3.1 verifies valve closure times are within accident analysis assumptions on a quarterly basis. SAR Section 4.3.5.1.1 assumes the manifold valves will close in 10 seconds.
2.1 16
- - - ~
l GDP 97 0151 Page1of3 United States Enrichment Corporation (USEC)
Proposed CertlGcate Amendment Request 3
Closure of C-360 Isolation Valves Following a Zone 1 or Zone 4 UF. Detection Significance Determination The United States Enrichment Corporation (USEC) has reviewed the proposed changes associated I
with this certificate amendment request and provides the following Significance Determination for consideration.
- 1. No Significant Decrease in the Effectiveness of the Plant's Safety. Safeguards. or Security Pronrams a
The requirements of TSR 2.1.4.1 and 2.1.4.2a for closure of valves upon UF release detection are not addressed in plant safety, safeguards, or security programs contained in Volume 3 of the Application for Uruted States Nuclear Regulatory Commission Certification for the Paducah Gaseous Diffusion Plant. Therefore, the effectiveness of these programs is unaffected by this
- change,
- 2. No Significant Change to Any Conditions to the Certificate of Comoliance None of the Conditions to the Certificate of Compliance for operation of the Paducah Gaseous Diffusion Plant specifically address requirements for closure of valves upon UF. release detection. Thus, the proposed change has no impact on any of the Conditions to the Certificate ofCompliance.
- 3. No Sinnificant Change to Any Condition of the Anoroved Comoliance Plan Compliance Plan Issue 3, Item 5 requires modification of C-360 Zone 1 and Zone 4 UF.
detection system such that multiple "alves on the autoclave transfer and sampling piping will isolate upon detection of UF..
The proposed TSR changes modify the conditions and surveillance requirements of the TSRs to address the multiple valves required to close upon detection of UF in Zones 1 and 4. Until the proposed change is approved, the Justification for Continued Operation conditions of the Compliance Plan will remain in effect. However, upon approval of the proposed change, there is no impact on any condition of the approved Compliance Plan.
- 4. No Significant Increase in the Probability of Occurrence or Conseauences of Previously Evaluated Accidents Accidents of concem involve the release of UF. in the C 360 laboratory area (Zone 1) and the C-360 basement transfer room (Zone 4). The proposed TSR changes ensure that the TSRs adequately address the modified plant configuration required by the Compliance Plan by establishing limiting conditions for operation and associated surveillance requirements to demonstrate the operability of the associated containment isolation valves. These TSR changes enhance the overall plant safety. Therefore, the addition of new requirements will not increase the probability of occurrence or consequences of previously analyzed accidents.
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GDP 97-0151 Page 2 of 3 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Closure of C-360 Isolation Valves Following a Zone 1 or Zone 4 UF Detection Signifleance Determination S. No New or Different Tvoc of Accident Compliance Plan issue 3, item 5 requires modification of C 360 Zone 1 and Zone 4 UF.
detection system such that multiple valves on the autoclave transfer and sampling piping will isolate upon detection of UF.. The proposed TSR changes ensure that the TSRs adequately address the modified plant configuration required by the Compliance Plan by establishing limiting conditions for operation and associated surveillance requirements to demonstrate the operability of the associated containment isolation valves. This change will not create the possibility of a different type of equipment malfunction or a different type of accident.
- 6. No Siunificant Reduction in Marcins of Safety The proposed TSR changes ensure that the TSRs adequately address the modified plant conGguration required by the Compliance Plan by establishing limiting conditions for operation and associated surveillance requirement.: to demonstrate the operability of the associated containment isolation valves. Therefore, this modification does not reduce the margin of safety as defined in the supporting bases documents for the TSRs.
- 7. No Siunificant Decrease in the Effectivenest of any Procram or Plans Contained in the Certificate Aeolication The proposed TSR changes ensure that the TSRs adequately address the modified plant configuration required by the Compliance Plan by establishing limiting conditions for operation and associated surveillance requirements to demonstrate the operability of the associated containment isolation valves. The requirements of TSR 2.1.4.1 and 2.1.4.2a for closure of valves upon UF, release detection are not addressed in program or plans contained in Volume 3 of the Application for United States Nuclear Regulatory Commission Certification for the Paducah Gaseous DifTusion Plant. Therefore, the effectiveness of these programs and plans is unaffected by this change.
- 8. The orocosed chances do not result in undue risk to 11 oublic health and safety. 2) common defense and security. and 3) the environment The proposed TSR changes ensure that the TSRs adequately address the modified plant configuration required by the Compliance Plan by establishing limiting conditions for operation and associated surveillance requirements to demonstrate the operability of the associated containment isolation valves. The addition of these new requirements does not increase the probability or consequence of any previously analyzed accident. As such, this change does not represent an undue risk to public health and safety. This change will enhance safety and will have no adverse impact on the environment or the common defense and security.
s GDP 97-0151 Page 3 of 3 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Closure of C-360 Isolation Yalves Following a Zone 1 or Zone 4 UF. Detection Significance Determination
- 9. No Change in the Tvoes or Significant increase in the Amounts of Anv Emuents that May be Released OfTsitg.
The proposed TSR changes ensure that the TSRs adequately address the modified plant configuration required by the Compliance Plan by establishing limiting conditions for operation and associated surveillance requirements to demonstrate the operability of the associated containment isolation valves. This change has no effect on the generation or disposition of efIluents, therefore it does not change the types or amounts of efiluents that may be released offsite.
- 10. No Significant Increase in Individual or Cumulative Occuoational Radiation Exoosure The pro};osed TSR changes ensure that the TSRs adequately address the modified plant configuration required by the Compliance Plan by establishing limiting conditions for operation and associated surveillance requirements to demonstrate the operability of the associated containment isolation valves and will not increase the probability of occurrence or consequences of any postulated accident currently identified in the SAR. Therefore, there is no significant increase in individual or cumulative occupational radiation exposure.
- 11. No Siunificant Construction Imoact The proposed change only involves changes in operation procedures and has no construction requirement. Therefore, this modification does not represent a significant construction impact.
- 12. No Significant Increase in the Potential for. or Radiclogical or Chemical Consequences from.
Etsyitysly Analyzed Accidents The proposed TSR changes ensure that the TSRs adequately address the modified plant conSguration required by the Compliance Plan by establishing limiting conditions for operation and associated surveillance requirements to demonstrate the operability of the associated containment isolation valves and will not increase the probability of occurrence or consequences of any postulated accident currently identified in the SAR. Therefore, there is no significant increase in the potential for radiological or chemical consequences from previously analyzed accidents.
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j GDP 97-0151 Page1of1 i
i COMMITMENTS CONTAINED IN THIS SUBMrITAL 4
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Until the enclosed TSR is approved by NRC and implemented at PGDP, USEC will implement the current TSRs and continue to operate the C 360 facility under the Justification for Continued Operation (JCO) associated with Compliance Plan Issue 3, Item 5 This JC0 requires that sampling not be performed during transfer operations and that operators ensure that drain valves remain shut when sampling operations are conducted.
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