ML20210U699
| ML20210U699 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 09/15/1997 |
| 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-97-0061, GDP-97-61, NUDOCS 9709220035 | |
| Download: ML20210U699 (11) | |
Text
United States a
Enitchment Corporation 2 Democracy Center 0903 Rockledge DrWe Betheada. MD 20817 Tol; (301)564 3200 Fax:(301)504 3201 JAMES H. MILLER Dir: (301) 564 3300 VicE PREhlDf;NT, PRODUCTION Fax: (301) 5718279 September 15,1997 Dr. Carl J. Paperiello SERIAL: GDP 97 0061 Director, Office of Nuclear Material Safety and Safeguards Attention: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20$55 0001 Paducah Gaseous Diffusion Plant (PGDP)
Docket No. 70-7001 Certificate Amendment Request - Product and Tails Withdrawal Facilities Criticality Accident Alarm System
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. This cenificate amendment request revises the Technical Safety Requirement (TSR) 2.3.4.7, Criticality Accident Alarm System, Required Action A 1.5, to provide additional time to operate the withdrawal station in normal steady state operation should the CAAS be declared inoperable and the required actions entered.
In the event of CAAS inoperability, TSR 2.3.4.7, Required Action A. I.5, currently allows completion of the current withdrawal cycle and then discontinuing withdrawal of UF.. Discontinuing withdrawal, j
once the current withdrawal cycle is completed, requires isolation of the withdrawal pumps, compressors and the accumulators. This mode of operation would eliminate all withdrawal from the cascade, requiring the cascade to be placed in recycle. In recycle, the cascade assay will begin to rise and will soon exceed the assay limitation of TSR 2.4.4.3, without operator intervention. Although assay can be {
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Dr. Carl J. Paperiello September 15,1997 GDP 97-0061 Page 2 l
corttelled during recycle, the necessary actions to prevent exceeding assay limits are complex and p4ce the plant in a rarely used configuration that poses signincant control challenges and increases the likelihood of exceeding assay limits.
To minimize the impact associated with CAAS inoperability in the Product and Tails Withdrawal Facility, USEC proposes to change the TSR to allow additional time for operation of the plant in its normal, steady state con 0guration. This is accomplished by allowing the plant to continue withdrawing product aner the current cylinder 011 cyr e is complete by filling the accumulators as is normally done during a cylinder change-out. to this letter provides a detailed description and justi0 cation for the proposed changes to the Criticality Accident Alarm System TSR for the Product and Tails Withdrawal Facilities. Enclosure 2 is a copy of the revised TSR pages associated with this request. Enclosure 3 contains the basis for USEC's determination that the proposed changes associated with this certi0cate amendment request are not significant.
Although there is currently no immediate plant operational impact requiring prompt review of this certificate amendment request, should the CAAF, become inoperable in the future, USEC is concerned with placing the plant in such a rarely used configuration with such complex control challenges.
Therefore, USEC requests NRC review of this certificate amendment request as soon as possible. The amendment should become efTective no later than 15 days from issuance.
Any questions related to this subject should be directed to Mark Smith at (301) 564 3244, Sinc ely, l
JDW$
)m es II. Miller LA ice President, Production
Enclosures:
As Stated cc:
NRC Region 111 Ofuce NRC Resident inspector PGDP NRC Resident inspector - PORTS DOE Regulatory Oversight Manager
t OATil AND AFFIRh1ATION 1, James 11. hiiller, swear and amrm 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 the statements made and matters set forth therein are true and correct to the best of my knowledge, information, and belief.
L
~
James 11. hiiller On tlis ISth day of September,1997, the oflicer signing above personally appeared before me, is known by n.c 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 oflicial seal.
J klGLLL L(
((, j -
}4.aurie hl. Knisley, Notary Public
/
State of hiaryland, hiontgomery County My commission expires h1 arch 17,1998
GDP 97 0061 Page 1 of 2 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Product and Tails Withdrawal Facilities Criticality Accident Alarm System Detailed Description of Change LCO 2.3.4.7a, Action A.l.5 and LCO 2.3.4.7b, Action A.I.5, state:
" Complete current cycle and then discontinue withdrawal of UF, enriched to a 1 wt % 2"U."
This change provides more precise language so that the statement will read:
" Cylinder filling with UF. enriched to a I wt %2"U will be discontinued. [In progress cylinder filling cycle (s) may be completed, stopped, and/or re started as necessary. Normal operation of withdrawal compressors, condensers, and accumulators is not restricted by this action.]"
The proposed change alleviates a safety concem associated with the existing language of Required Action A. l.5.
The current TSR 2.3.4.7a&b, Required Action A.1.5, requires the following two actions (in order).
1.
Complete the current (cylinder filling) cycle. This action is the safest, steady state operational configuration since it minimizes any operational changes that could introduce suflicient moderator into the system, thereby creating a circumstance favorable to a criticality event.
Therefore, PGDP is to continue withdrawal while, at the same time, preventing the movement of fissionable material (TSR 2.3.4.7, Action A.I.1). This means, however, that when cylinder filling is completed, the filled cylinder cannot be moved.
2.
When the cylinder filling cycle has been completed. TSR 2.3.4.7,-Required Action A.l.5, as currently written, requires PGDP to discontinue withdrawal. In its most literal technical sense, this means that the Nomietex pumps, the compressors, the condensers and the accumulators are to be isolated thereby eliminating the ability to withdraw product from the cascade stream and the Paducah Cascade must therefore be placed in recycle. In recycle, the cascade assay will begin to rise and will soon exceed the assay limitation of TSR 2.4.4.3, without operator intervention.
Although assay can be controlled during recy cle, the necessary actions to prevent exceeding assay limits are complex and place the plant in a rarely used configuration that poses significant control challenges and increases the likelihood of exceeding assay limits.
b linclosure1 GDP 97.0061 Page 2 of 2 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Product and Tails Withdrawal Facilities Criticality Accident Alarm System I)ctailed Description of Change To minimize this circumstance, USEC proposes to change the TSR to clearly allow additional time for operation of the plant in its normal, steady state configuration. This is accomplished by allowing the plant to continue withdrawing product from the cascade after the current cylinder filling is complete as -
is normally done during a cylinder change out. This maintains the plant in its safe, steady state mode of operation.
The original intent of this TSR action for the withdrawal facility was to discontinue cylinder filling and not to immediately place the cascade on recycle. The safety conc ^rn being addressed by this required action is the potential introduction of UF. into an " empty" cylinder that inadvertently contains water
- (moderator) By disallowing further filling of cptnders, with the exception of cylinders currently being filled, this possible cause of an inadvertent criticality is avoided during the period that the CAAS is inoperable. The absence of water in cylinders that are in a fill cycle at the time of a CAAS outage has already been demonstrated by the :ack of UF,/ water reaction.
GDP 97 0061 3 Pages Proposed Certificate Amendment Request Paducah Gascous Diffusion Plant Letter GDP97-0061 Removal / Insertion Instructions 1(emove Page Insert Page Volume 4 Section 2.3 Section 2.3 Page 2.3 I9 Page 2.3 19 Page 2.3 21 Page 2.3 21
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TSR PGDP PROPOSED September 12.1997
' CAR #97-C-0093 SECTION 2.3 SPECIFIC TSRs FOR PRODUCT AND TAILS WITilDRAWAL FACil.lTIES 2.3.4 GENERAL LihllTING CONDITIONS FOR OPERATION 2.3.4.7 CRITICALITY ACCIDENT ALARM SYSTEM LCO 2.3.4.7al Criticality accident detection shall be operabic.
APPLICAlllLITY:
In areas, equipment, or processes which contain greater than 700 grams of 2"U at an enrichment greater than or equal to 1.0 wt % 2"U.
ACTIONSI Condition Required Action Completion Time 4.
Areas, equipment, or A.l
!mplement the following for areas, equipnwnt, or proccsses immediately pnwesses rut coseted by apphcaNe to this LCO arnt that are not otherwise covered by critwahty accident crincality accident detectum.
detecuon.
A.l.1 Discontinue etwsettient of c)ltralers coritaining UF. enriched to al 0 wt 5 3"U.
M A. l.2 NaF trals containmr varuum enriched to al.0 wt % *"U shall swit be handled.
M A.I.3 Waste wntamma urentum enriched to al 0 wt % 2"U shall fut be tamed.
M A 1.4 Dacontinue mamtenaiwe actnities that require breach of contammem of equpment contaming uranium ennched to a i wt % 4"U.
M A I,5 C)hnder fdlms with UF. ennched to a I wt % 8"U wtil be dacontmued. lin progress cyhrsler filhng cycle (s) may be completeA stopped, assi'or re. started as necenary. Normal operanon of widwirawal compressors, condemers, and accumulators is tut restncted by thn action 1 M
A.2.1 I!vacuate area withm die area tot smered by criticahty accident detection.
Immediately M
A.2.2 Restrict access to area cucuated in A.2.1 M
A.)
Provide personnel allowed into the area that woukt be restncted urkler Actum A 2.1 with an alternate means of enticahty alarm Immediately futi6 cation such as a desice that will alarm on sensmg a 10mr/hr d ne rate.
Areas, equipnwns, or B. I.1 Restare snucahty accklem detection by installmg portabts 44 hours5.092593e-4 days <br />0.0122 hours <br />7.275132e-5 weeks <br />1.6742e-5 months <br /> procesws not covered by CAAS unit prmidmg *equired entwahty accident detection and (effectne when NRC cnucahty accident same alarms a 0 sed umt, assumes regulatory detectkm.
.QR
=
authority)
B.1.2 Restore criticahty accident detecuon to operable status.
l T!.R 16.2 2d is not apphcaNe.
2.3-19 l
TSR PGDP June 7.1997
' RAC #97 C-0093 SECTION 2.3 SPECIFIC TSRs FOR PRODUCT AND TAILS WITilDRAWAL FACILITIES 2.3.4 GENERAL LIMITING CONDITIONS FOR OPERATION 2.3.4.7 CRITICALITY ACCIDENT ALARM SYSTEM (continued)
LCO 2.3.4.7b:
Criticality accident alarm shall be operable (audible).
APPLICABILITY:
In areas where the maximum foreseeable absorbed dose in free air exceeds 12 rad.
ACTIONS:
Condition Required Action Completion Time A.
Area does not have an A.1 Implement the following for areas, equipment, or praenes immediately audible criucahty acsdent where a cnticahty accident could result in a maximurr, alarm.
foreseeable dose exceedmg 12 rad in the area of inaudibihty ard LCO 2.3.4.7a apphes.
A. I.1 Discontmue snovement of cyhrulers contaming UF, entkhed to el wt % 2"U.
E A. I.2 NaF traps containing uraruum enriched to a! wt 4 8"U shall not te handled.
E A.I.3 Waste containing uratuum enriched to at wt % 2"U shall not be transported.
G A. I.4 Discontinue maintenance activities that require breach of containment of equipment contatrung uranium ennched to a I wt%8"U.
M A.I.5 Cyhrder filling with UF enriched to a I wt % *"U will be discontinued. [In-progress c)hnder filling cycle (s) may be completed, sit 33ed, ard/or re. started as necessary Normal operation of withdrawal compressors, condensers, ard accumulators is not restricted by this actkm ]
M A.2.1 Evacuate area of inaudibihty M
immediately A.2.2 Restrict access to the area of inaudibihty, M
A.3 Provide personnel allowed to enter the area of inaudibihty with an altenute means of criticahty alarm touricatitm such as a immediately device that will alarm on sensing a 10mr/hr dose rate, or a radio in constant communication with the Central Control Facility.
II.
Area does not have an 11.1 Restore entkahty accdent alarm L opetable status.
48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> suddde cnucahty accident (effectne when NRC alarm.
TSR I.6.6.2d is tot apphcable, assumes regulatory authorirvi 2.3 21 l
GDP97 0061 Page 1 of 3 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Product and Tails Withdrawal Facilities Criticality Accident Alarm System Significance Determination The United States Enrichment Corporation (USEC) has reviewed the proposed changes associated with this certificate amendment request and provides the following Signl0cance Determination for consid: ration.
1.
No Overall Decrease in the IIfTectiveness of the Plant's Safety. Safeguards or Security Prograrns The proposed specific required actions of TSR 2.3.4.7 are not arldressed in plant safety, safeguards or security programs contained in the Application for United States Nuclear Regulatory Commission Certification for the Paducah Gaseous Difrusion Plant. Therefore, the cfTectiveness of these programs is unaffected by these enanges.
2.
No Significant Change to Any Conditions to the Certificate of Compliance None of the Conditions to the Certificate of Compliance for operation of the Paducah Gaseous Diffusion Plants specifically address required actions in Technical Safety Requirements. Thus, the proposed changes have no impact on any Condition to the Certificate of Compliance.
3.
No Significant Change to Any Candition of the Anproved Cnmpliance Plan The actions required in A.I.5 of TSR 2.3.4.7 are not addressed in any issue described in the Compliance Plan. The proposed change does not involve any commitment contained in the Compliance Plan and does not change or invalidate any of the approved compensatory measures described in the approved Compliance Plan.
4.
No Significant Increase in the nrobability of Occurrence or Consequences of Previoush Eyaluated Accidents The proposed TSR change involva a change to Required Action A.l.5 for Criticality Accident Alarm System. The proposed change provides precise language describing the required actions to take in the event of CAAS inoperability. This assures that the safety requirement of maintaining the withdrawal facility in safe, steady state operation with to movement of fissionable material is not compromised.
This does not increase the probability or consequences of an evaluated accident.
O linclosure 3 GDp97 0061 Page 2 0f 3 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Product and Tails Withdrawal Facilities Criticality Accident Alarm System Significance Detennination 5.
No New or Different Tyne of Aesident The proposed TSR change involves a change to Required Action A.l.5 for Criticality Accident Alarm System. The proposed change provides precise language describing the required actions to take in the event of CAAS inoperability. This assures that the safety requirement 3
of maintaining the withdrawal facility in a safe steady state operation with no movement of fissionable material is not compromised. This does not create the possibility for a new or different type of accident.
6.
No Sienificant Reduction in Marcins of Safety The proposed TSR change involves a change to Required Action A.I.5 for Criticality Acc! dent Alarm System. The proposed change provides precise language describing the required actions to take in the event of CAAS inoperability. This assures that the safety requirement of maintaining the withdrawal facility in a safe steady state operation with no movement of fissionable material is not compromised. This change does not reduce the margin of safety.
7.
No Significant Decrease in the Effectiveness of any Program or Plan Contained in the Certificate AoplientinD The proposed TSR change involves a change to Required Action A.I.5 for Criticality Accident Alarm System. The proposed change provides 1.;;cise language describing the required actions to take in the event of CAAS inoperability. The proposed change has no impact on any of the programs or plans described in the Certificate Application. This change does not reduce the effectiveness of any program or plan contained in the Certification Application.
8, The Proposed Chances do not Result in Undue Risk to 1) Public Ilealth and Safety. 21 Common Defense and Security. and 3) the Environment.
111e proposed TSR change involves a change to Required Action A.I.5 for Criticality Accident Alarm System. The proposed change provides precise language describing the required actions to take in the event of CAAS inoperability. This assures that the safety requirement of maintaining the withdrawal facility in a safe steady state operation with no movement of fissionable material is not compromised, in addition this change has no impact on plant ellluents or on the programs or plans in place to implement physical security. This change does not result in undue risk to public health and safety, the common defense and security, or the environment.
.4 GDp97 0061 Page 3 of 3 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Product and Tails Withdrawal Facilities Criticality Accident Alarm System Significance 1)etermination 9.
No Change in the Tynes or Sigtilficant increase in the Amounts of Any Efiluents that May be Released Offsite This change has no afrect on the generation or disposition of effluents. Therefore, this change does ciot change the type or amounts of effluents that may be released offsite.
10.
No Significant increase in Individual or Cumulative Occunational Radiation Exnosure The proposed TSR change involves a change to Required Action A.I.5 for Criticality Accident Alarm System. The CAAS is not used to control or minimize occupational radiation exposures or to comply with 10 CFR 20 requirements. Therefore, this change does not relate to controls used to minimize occupational radiation exposures.
11.
No Significant Construction Imnact This TSR change does not involve a plant modification. Therefore, there is no significant construction impact.
12.
No Significant increase in the Potential for. or Radiological or Chemical Consequences from.
Previousiv Analyzed Accidents The proposed TSR change involves a change to Required Action A.l.5 for Criticality Accident Alarm System. The proposed change provides precise' language describing the required actions to take in the event of CAAS inoperability. This assures that the safety requirement of maintaining the withdrawal facility in a safe steady state operation with no movement of fissionable material is not compromised. Therefore, this change does not increase the potential for, or radiological or chemical consequences from, previously analyzed accidents.
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