ML20211M363
| ML20211M363 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 10/06/1997 |
| 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-97-0172, GDP-97-172, NUDOCS 9710140165 | |
| Download: ML20211M363 (12) | |
Text
0"l00l United Stat:s EnnchmInt Corporation
..S.
2 Democracy Center 6903 Rockledge D ive Bethesda, MD 20817 Tel: (301)564-3200 Fam: (301) 564-3201 0 dleil Sales Enrichment Girp> ration i
JAMES H. MILLER Dir: (301) 564-3309 VICE PRESIDENT, PRODUCTION Fax:(301) 571-8279 i
l October 6,1997 r
Dr. Carl J. Paperiello SERIAL: GDP 97-0172 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 - Product and Tails Withdrawal and Cascade Facilities Criticality Accident Alarm System Cross Reference
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 DifTusion Plant (GDP). This certificate amendment request revises Technical Safety Requirement (TSR) 2.3.4.7 and TSR 2.4.4.2, Criticality Accident Alarm System, to add a new Required Action under Condition A which provides a cmss reference to assure that all necessary Required Actions are performed when the C-310 CAAS is inoperable. This TSR change does not change, add to, or delete, any actions currently required by the TSRs. This change is proposed as a human factors improvement to help ensure that all required actions for TSR 2.3.4.7 and 2.4.4.2 are performed whenever required. to this letter provides a detailed description and justification for the proposed changes to the Criticality Accident Alarm System TSRs. Enclosure 2 is a copy of the revised TSR pages t
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9710140165 971006
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ADOCK 0700 0 1 Offices in Paducah. Kentucky Portsmouth. Ohio Washington, DC
Dr. Carl J. Paperiello -
' Octoher 6,1997 GDP 97-0172 Page 2
- associated with this request. Enclosure 3 contains the basis for USEC's determination that the proposed -
changes associated with 'his certificate amendment request are not significant.
There is currently no immediate plant operational impact requiring prompt review of this certificate amendment request. Therefore, USEC requests NRC review of this certificate amendment request as soon as practical. The amendment should become efTective 30 days from issuance.
- Any questions related to this subject should be directed to Mark Smith at (301) 564-3244. There are -
no new commitments contained within this submittal.
- Sincerely, I
es 11. Miller Vice President, Production
Enclosures:
As Stated cc:
NRC Region Ill Office NRC Resident inspector-PGDP NRC Resident Inspector - PORTS DOE Regulatory Oversight Manager
DATil AND AFrilGiATION 1, James 11. Miller, 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 Gle 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 l
true and correct to the best of my knowledge, information, and belief.
i hh James 11. Miller On this 6th day of October,1997, the ofncer signing above personally appeared before me, is known by me to be the person whose name is subscribed to within the instrument, and acknowledged that he executed the same for the purposes therein contained, in witness hereofI hereunto set my hand and ofUcial seal, b-ll h.
lf_b Notary Public State of Maryland, Montgomery County
GDP 97-0172 Page1of1 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Product and Tails Withdrawal Facilities Criticrih* Accident Alarm System Cross Reference Detailed Description of Change USEC proposes to add the following new Required Action to each of the four LCOs as show below:
LCO 2.3.4.7a "AND A.l.6 Perform Required Actions A.l.1, A.l.2, A.I.3, A.I.4, A.2.1, A.2.2, A.3, B.1.1, and B.I.2, of TSR 2.4.4.2a."
LCO 2.3.4.7b "AND l
A.I.6 Perform Required Actions A.l.1, A.I.2, A.I.3, A.I.4, A.2.1, A.2.2, A.3, and B.1, of TSR 2.4.4.2b."
4 LCO 2.4.4.2a "AND A.I.7 When implementing these actions in C-310, perfonn Required Actions A.I.1, A.l.2, A.I.3, A.I.4, A.I.5, A.2.1, A.2.2, A.3, B.1,I and B.I.2 of TSR 2.3.4.7a."
LCO 2.4.4.2b "AND A.I.8 When implementing these actions in C-310, perform Required Actions A.I.1, A. I.2, A.l.3, A.l.4, A. I.5, A.2.1, A.2.2, A.3, and B.1 of TSR 2.3.4.7b."
This proposed change does not change, edd to, or delete, any Required Actions currently in the TSRs.
This change is being proposed to enhance the understanding and effective implementation of the TSRs.
Currently, TSR's 2.4.4.2a&b and TSR's 2.3.4.7a&b must be implemented when the C-310 CAAS is inoperable. This is because the C-310 building, all of which is covered by the same CAAS equipment, contains both cascade equipment (TSR 2.4.4.2) and product withdrawal equipment (TSR 2.3.4.7). PGDP has experienced difficulties in implementing these TSR's during CAAS inoperabilities in C-310 in that TSR 2.3.4.7 has been correctly implemented, but it was not recognized that TSR 2.4.4.2 also applied.
This proposed change will provide a cross reference within the Required Actions of TSRs 2.3.4.7 and 2.4.4.2 to explicitly reference the applicable actions of the other TSR which must be accomplished in the event of CAAS inoperability in the cascade or product withdrawal facilities.
1
GDP 97-0172 5 Pages Proposed Certificate Amendment Request Paducah Gaseous Diffusion Plant Letter GDP97-0172 Removal / Insertion lustructions Remove Page Insert Page Volume 4 l
Section 2.3 Section 2.3 Page 2.3-19 and 2.3-21 Page 2.3-19 and 2.3-21 i
Section 2.4 Section 2.4 Page 2.4-17 and 2.4-19 Page 2.4-17 and Page 2.4-19 c
TSR-PGDP PROPOSED October 6,1997 RAC 97C0193 (RO)
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 LCO 2.3.4.7a: Criticality accident detection shall be operable.
APPLICABILITY: 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 % 235U.
ACTIONS:
Condition Required Action Completion Time 1
A.
Areas, equipment, A.1 Implement the following for areas, equipment, or immediately or processes not processes applicable to this LCO and that are not covered by otherwise covered by criticality accideat detection.
criticality accident A.l.1 Discontinue movement of cyline containing UF.
detection.
enriched to a1.0 wt % 2"U.
M A.I.2 NaF traps containing uranium enriched to a1.0 wt
% 2"U shall not be handled.
I e
A.I.3 Waste containing uranium enriched to a1,0 wt %
2"U shall not be moved.
M A.I.4 Discontinue maintenance activities that require breach of containment of equipment containing uranium enriched to a I wt % 2"U.
M A.I.5 Complete current cycle and then discontinue withdrawal of UF. enriched to a I wt % 2"U.
M A.1,6 Perform Required Actions A.I.1, A.I.2, A.I.3, A. I.4, A.2.1. A.2.2, A.3, B.I.1, and B. I.2 of TSR 2.4.4.2a.
M A.2.1 Evacuate area within the area not covered by Immediately criticality accident detection.
M A.2.2 Restrict access to area evacuated in A.2.1.
M A.3 Provide personnel allowed into the area that would immediately be restricted under Action A.2.1 with an alternate means of criticality alarm notification such as a device that will alarm on sensing a 10mr/hr dose rate.
B.
Areas, equipment, B.l.1 Restore criticality accident detection by installing 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or processes not portable CAAS unit providing required criticality (effective when NRC covered by accident detection and same alarms as fixed unit.
assumes regulatory criticality accident OR authority) detection.
B.I.2 Restore criticality accident detection to operable status.
TSR 1.6.2.2d is not applicable.
2.3-19
TSR PGDP PROPOSED October 6,1997 RAC 97C0193 (RO)
SECTION 2.3 SPECIFIC TSRs FOR PRODUCT AND TAILS WITIIDRAWAL 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 A.1 Implement the following for areas, equipment, or immediately an audible processes where a criticality accident could result criticality accident in a maximum foreseeable dose exceeding 12 rad alarm.
in the area of inaudibility and LCO 2.3.4.7a applies.
l A. I.1 Discontinue movement of cylinders containing UF.
enriched to aI wt % 2"U.
M A.I.2 NaF traps containing uranium enriched to aI wt %
2"U shall not be handled.
M A.I.3 Waste containing uranium enriched to a I wt %
2"U shall not be transported.
M A.I 4 Discontinue maintenance activities that require breach of containment of equipment containing uranium enriched to a I wt % 2"U.
M A.I.5 Complete current cycle and then discontinue withdrawal of UF. enriched to a I wt % 2"U M
A.I.6 Perform Required Actions A.I.1, A,1.2, A.I.3, A. I.4, A.2.1, A.2.2, A.3, and B. ! of TSR 2.4.4.2b.
E A.2.1 Evacuate area of inaudibility immediately M
A.2.2 Restrict access to the area ofinaudibility.
M A.3 Provide personnel allowed to enter the area of immediately inaudibility with an alternate means of criticality alarm notification such as a deviae that will alarm on sensing a 10mr/hr dose rate, or a radio in constant communication with the Central Control Facility.
B.
Arca does not have B.1 Restore criticality accident alarm to operable 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> an audible status.
(effective when NRC criticality accident assumes regulatory alarm.
TSR 1.6.6.2d is not applicable.
authority) 2.3-21
TSR-PGDP PROPOSED October 6,1997 RAC 97C0193 (RO)
SECTION 2.4 SPECIFIC TSRS FOR ENRICil51ENT CASCADE FACILITIES 2.4.4 GENERAL L1511 TING CONDITIONS FOR OPERATION 4
2,4.4.2 CRITICALITY ACCIDENT ALAR 51 SYSTEh!
LCO 2,4.4.2a: Criticality accident detection shall be operable, s
APPLICAlllLITY:
In areas, equipment, or processes which contain greater than 700 grams of 2"U at an enrichment a 1.0 wt 4 2"U.
ACTIONS:
Condition Required Action Completion Time A.
- Areas, A.1 Implement the following for areas, equipment, or immediately equipment, processes applicable to this LCO and that are not or processes otherwise covered by criticality accident detection, not covered A. I. ! Discontinue cell maintenance activities that require breach by criticality of the containment boundary of cells containing UF.
accident enriched to a I wt % 2"U.
l detection.
M A.I.2 Monitor temperatures / pressures in the cascade cells containing UF. enriched to a I wt % 2"U hourly to maintain UF. in the gaseous state.
M A.I.3 Waste containing uranium enriched to a I wt % 2"U shall not be handled.
M A.I.4 Wet air pumps shall not be used for evacuation of cells containing UF. enriched to a I wt % 2"U.
M A.I.5 Monitor temperature and pressure of surge drums containing UF. enriched to a I wt % 2"U hourly to maintain inventory in gaseous state.
M A.I.6 Place freezer /sublimers containing UF. enriched to a I wt
% 2"U in mode F/S 3, F/S 4 F/S 5 or F/S 6.
-M A.I.7 When implementing these actions in C-310, perform Required Actions A. I.1, A. I.2, A. I.3, A. I.4, A. I.5, A.2.1 A.2.2, A.3, B.I.1 and B.I.2, of TSR 2.3.4.7a.
M A.2.1 Evacuate area within the area not covered by detection Immediately capability.
E A.2.2 Restrict access to area evacuated in A.2.1.
M A.3 Provide persotmel allowed into the area that would be immediately restricted under Action A.2.1 with an alternate means of criticality alarm notification such as a device that will alarm on sensing a 10mr/hr dose rate.
B. Areas, B.l.1 Restore criticality accident detection by installing portable 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> equipment, or CAAS unit providing required criticality accident (effective when NRC processes not detection and same alarms as fixed unit.
assumes regulatory covered by QR authority) criticality B.I.2. Restore criticality accident detection to operable status.
accident detection.
TSR 1.6.2.2(d) is not applicable.
2.4-17
TSR PGDP PROPOSED October 6.1997 RAC 97C0193 (RO)
~ SECTION 2.4 SPECIFIC TSRS FOR ENRICllMENT CASCADE FACILITIES 2.4.4 GENERAL L1511 TING CONDITIONS FOR OPERATION 2.4.4.2 CRITICALITY ACCIDENT ALARM SYSTE.1 LCO 2.4.4.2h:
Criticality accident alarm shall be operable (audible).
APPLICAHILITY: 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 A.1 Implement the following for aie equipment, or immediately an audible processes where a criticality accide t could result in a criticality accident maximum foreseeable dose exceedin 12 rad in the area of inaudibility and LCO 2.4.4.2a or 3'.2.4.3a applies.
- alarm, A.l.1 Discontinue cell maintenance activities that require breach of the containment boundary of cells containing UF.
enriched to a I wt % 2"U.
AhD A,l.2 Monitor temperatures / pressures in the cascade cells containing UF, enriched to a I wt % 2"U hourly to maintain UF. tn the gaseous state.
AND A.I.3 Waste containing uranium enriched to a 1 wt % "U shall not be handled.
AND A.I.4 Wet air pumps shall not be used for evacuation of cells containing UF. enriched to a I wt % 2"U.
AND A.I.5 Monitor temperature and pressure of surge drums containing UF. enrict.ed to a I wt % 2"U hourly to maintain mventory m gaseous state.
AND A.I.6 Place freezer /sublimers conta!ning UF.F/S 6.
enriched to a I wt
% "U in mode F/S 3, F/S 4, F/S 5 or AND A.I.7 Perform Required Actions A.I I and A.I.2 of TSR 2.2.4.3b.
AND A.I.8 When implementing these actions in C-310, perform Required Actions A.I.1, A.I.2, A.I.3, A.I.4, A.I.5, A.2.1, A.2.2, A.3, and B.1 of TSR 2.3.4.7b.
AND A.2.1 Evacuate area of inaudibility.
Immediately AND A.2.2 Restrict access to area evacuated in A.2.1.
AND A.3 Provide personnel allowed into the are,. that would be immediately restricted under Action A.2.1 with an alternate means of criticality alarm notification such as a device that will alarm on sensing a 10mr/hr dose rate, or a radio in constant communication with the Central Control Facility.
B.
Area does not have B.I Restore criticality accident alarm to operable status.
48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> an audible (effective when criticality accident TSR 1.6.2.2(d) is not applicable.
NRC assumes alarm.
regulatory authority) 2.4-19
9 GDP97-0172 Page1of3 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Product and Tails Withdrawal Facilities Criticality Accident Alarm System Cross Reference Significance Determination The United States Enrichment Corporation (USEC) has reviewed the proposed changes associated with this certincate amendment request and provides the following Signincance Determination for consideration.
j 1.
No Overall Decrease in the Effectiveness of the Plant's Safety. Safecuards or Security Procrams The proposed specine Required Actions of TSR 2.3.4.7 and 2.4.4.2 are not addressed in plant safety, safeguards or security programs contained in Volume 3 of the Application for United States Nuclear Regulatory Commission CertiGeation for the Paducah Gaseous Diffusion Plant.
Therefore, the effectiveness of these programs is unaffected by these changes.
2, No Significant Changt. to Any Conditions to the Certificate of Comnliance None of the Conditions o the Certincate of Compliance for operation of the Paducah Gaseous Diffusion Plants specif cally address required actions in the Technical Safety Requirements.
Thus, the proposed changes have no impact on any Condition to the Certincate of Compliance.
3.
No Significant Change to Any Condition of the Annroved Comnliance Plan The actions required in TSR 2.3.4.7 and 2.4.4.2 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 probability of Occurrence or Consecuences of Previously Evaluated Accidents The proposed TSR change does not change, add to, or delete any Required Action in the current
~ TSR. It does provide a cross reference to assure that all of the current TSR Required Actions are performed when required. This does not increase the probability or consequences of an evaluated accident.
5.
No New or Different Tyne of Accident The proposed TSR change does not change, add to, or delete any Required Action in the current TSR. It does provide a cross reference to assure that all of the current TSR Required Actions are performed when required. This does not create the possibility for a new or different type of accident.
GDP97-0172 Page 2 0f 3 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Product and Tails Withdrawal Facilities Criticality Accident Alarm System Cross Reference Significance Determination 6.
No Significant Reduction in Margins of Safety The proposed TSR change does not change, add to, or delete any Required Action in the current TSR. It does provide a cross reference to assure that all of the current TSR Required Actions are performed when required. 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 Application l
The proposed TSR change does not change, add to, or delete any Required Action in the current TSR. It does provide a cross reference to assure that all of the current TSR Required Actions are performed when required. The specific actions required in TSR 2.3.4.7 and 2.4.4.2 are not addressed in the Programs and Plans contained in the Certificate Application. Therefore, this change does not reduce the effectiveness of any program or plan contained in the Certification l
Application.
8, The Pronosed Changes do not Result in Undue Risk to 1) Public Ilealth and Safety. 2) Common Defense and Security. and 3) the Environment.
The proposed TSR change does not change, add to, or delete any Required Action in the current TSR. It doer provide a cross reference to assure that all of the current TSR Required Actions are performed when required. This change does not result in undue risk to public health and safety, the common defense and security, or the environment.
9.
No Change in the Tynes or Significant increase in the Amounts of Anv Effluents that May be Released OfTsite This change has no affect on the generation or disposition of effluents. Therefore, this change does not change the type or amounts ofeffluents that may be released offsite.
- 10. No Significant increase in Individual or Cumulative Occunational Radiation Exoosure The proposed TSR change does not change, add to, or delete any Required Action in the current TSR. It does provide a cross reference to assure that all of the current TSR Required Actions are performed when required. 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.
1
.)
GDP97-0172 Page 3 of 3 United States Enrichment Corporation (USEC)
Proposed Certincate Amendment Request Product and Tails Withdrawal Facilities Criticality Accident Alarm System Cross Reference Significance Determination i1. No SigniGeant Construction Imnact This TSR change does not involve a plant modincation. Therefore, there is no signincant construction impact.
l 12, No Significant increase in the Potential for. or Radiological or Chemical Consecuences from.
Previousiv Analyzed Accidents The proposed TSR change does not change, add to, or delete any Required Action in the current TSR it does provide a cross reference to assure that all of the current TSR Required Actions are performed when required. Therefore, this change does not increase the potential for, or radiological or chemical consequences from, previously analyzed accidents.
r
)