ML20217A648

Forwards Amend 15 to Coc GDP-1,revising Compliance Plan Issue 36 on Seismic Mods of Buildings C-331 & C-335. Condition 8 Has Been Revised to Include Date of 970731.Copy of Edited Proposed Compliance Plan Issue 36 Included

ML20217A648
Person / Time
Site:	07007001
Issue date:	03/20/1998
From:	Paperiello C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	John Miller UNITED STATES ENRICHMENT CORP. (USEC)
Shared Package
ML20217A652	List: ML20217A648 ML20217A658
References
TAC-L32028, NUDOCS 9803250151
Download: ML20217A648 (9)

Text

.

. March 200 1998 1

Mr. James N. Miller Vice President, Production U. S. Enrichment Corporation 2 Democracy Center 6903 Rockledge Drive Bethesda, MD 20817 '

SUBJECT:

PADUCAH CERTIFICATE AMENDMENT REQUEST - BUILDINGS C-331 AND C-335 SEISMIC UPGRADES (TAC NO. L32028)

Dear Mr. Miller:

In accordance with the portions of your application dated April 23,1997, as revised July 31, 1997, that were granted in the Director's Decision and became effective upon the Commission Denial of United States Enrichment Corporation's petition for review, and pursuant to Part 76 to Title 10 of the Code of Federal Regulations, Certificate of Compliance GDP-1 is hereby amended to revise Compliance Plan lasue 36 on the seismic modifications of buildings C-331 and C-335.

Accordingly, Condition 8 has been revised to include the date of July 31,1997 (as modified by the Director's Decision on December 8,1997, and affirmed by the Commission decision on March 19,1998). This amendment becomes effective immediately.

Please note that the enclosed proposed pages for the Compliance Plan issue 36 have been edited to state only the portions of the amendment request that were granted in the Director's Decision and upheld by the Commission's decision. Please resubmit these pages with the indicated edits made.

All other conditions of this certificate shall remain the same.

Enclosed is a copy of the revised Certificate of Compliance.

Sincerely, (0RIGINAL SIGNED BY)

Carl J. Paperiello, Director Office of Nuclear Material Safety p}g and Safeguards Docket 70 7001 C Certmcate GDP-1 Amendment 15 II N )/

rtif to f pla ce d P cc: Mr. Steve Polston, PGDP Mr. Randall DeVault. doe Mr. Steven Toolle, uSEC DISTRlBUTION: (Control No.240S)

NRC File Center PUBLIC R!ll KO'Brien, Rlli NMSS Dir. Off. r/f NMSS r/f FCSS r/f FCOB SPB r/f PHiland, Rill MHorn

• See previous concurrence op/enoormo/maanon so, ssee .

OFC SPB* 'SPB SPB* SPB SPB OGC FCSS NEji NAM PPatel:ij DPersinko Hoadley DMartin RPierson phone ETenEyck CPap llo E

DATE 3/12/98 3/18/98 3/12/98 3/18/98 3/18/98 3/19/98 3/19/98 '6/ )$ /98 C = COVER E = COVER & ENCLOSURE N = NO COPY 9903250151"i80320 y "" "MORD CW PDR ADOCK 07007001 C

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NUCLEAR REGULATORY COMMISSION WASHINGTON. D.C. 2055H21 t, / March 20, 1998 Mr. Jarnes H. Miller Vice President, Production U. S. Enrichment Corporation 2 Democracy Center 6903 Rockledge Drive Bethesda, MD 20817

SUBJECT:

PADUCAH CERTIFICATE AMENDMENT REQUEST - BUILDINGS C-331 AND C-335 SElSMIC UPGRADES (TAC NO. L32028)

Dear Mr. Miller:

In accordance with the portions of your application dated April 23,1997, as revised July 31, 1997, that were granted in the Director's Decision and became effective upon the Commission Denial of United States Enrichment Corporation's petition for review, and pursuant to Part 76 to Title 10 of the Code of Federal Regulations, Certificate of Compliance GDP-1 is hereby amended to revise Compliance Plan Issue 36 on the seismic modifications of buildings C-331 and C-335.

Accordingly, Condition 8 has been revised to include the date of July 31,1997 (as modified by the Director's Decision on December 8,1997, and affirmed by the Commission decision on March 19,1998). This amendment becomes effective immediately.

Please note that the enclosed proposed pages for the Compliance Plan issue 36 have been edited to state only the portions of the amendment request that were granted in the Director's Decision and upheld by the Commission's decision. Please resubmit these pages with the indicated edits made.

All other conditions of this certificate shall remain the same.

Enclosed is a copy of the revised Certificate of Compliance.

Sincerely, tt Carl J. Paperiel , Director Office of Nuclear Material Safety and Safeguards Docket 70-7001 Certificate GDP-1 Amendment 15

Enclosure:

Compliance Plan issue 36, pages 1-7 Certificate of Compliance GDP-1 cc: Mr. Steve Polston, PGDP Mr. Randall DeVault, DOE Mr. Steven Toelle, USEC

.y

.. 1 1

J Issue 36. Page 1 Seismic Capability of Buildings C-331 and C-335 (new issue)

REQUIREN!ENTS 10 CFR 76.35(a)(4), (6), and (8) "The application for an initial certificate of compliance must include the information identified in this section (a) A safety analysis report which must include the following information: , . . (4) An assessment of accidents based on the requirements o f 76.85; . . . (6) A description of equipment and facilities which will be used by the Corporat

. . provisions for protection to protect health and minimize danger to life or property (such as. . (8) A against natural phenomena; principal structures, systems, and components of the plant."

10 CFR 76.88 The Corporation shall perform an analysis of potential accidents and consequences to establish the basis for limiting ccnditions for operation of the plant with r to the potential for releases of radioactive material. Special attention must be directed to assu that plant operation will be conducted in a manner to prevent or to mitigate the consequences natural phenomena in from a reasonable spectrum of postulated accidents which include order to ensure adequate protection of the public health and safety. Plant operating history relevant to the assessment should be included. In performing this assessment, the full ran operations should be considered including, but not necessarily limited to, operation at maximum capacity contemplated. The assessment must be performed using an expected. re rate resulting from anticipated operational occurrences and accidents with existing system procedures intended to mitigate the release consequences, along with site character meteorology, to evaluate the offsite radiological consequences."

COSf3flThfENTS Source: Safety Analysis Report

2. Site Characteristics [Rev. 3, 5/31/96]

• This chapter provides information on he location and site characteristics of the facility to address 40 CFR 76.35(a)(0, including the historical basis for site characteristics in geology and seismology. This infomution is needed to support the assumptions that were used in determ the impacts of normal operation, the hazard and accident analysis as described in Chap the application, and emergency operations, particularly with regard to the contribution o seismic phenomena to the initiation of events and the site related assumptions that were evaluating accident consequences.

3. Facility and Process Description [Rev. 3. 5/31/961 This chapter provides information on the principal structures, systems, and componen the plant as well as information on the equipment and facilities that are used to protect

- minimize danger to life or property to address 10 CFR 76.35(a)(6) and 10 CFR 76.35(a)(8),

including (1) properties of uranium and uranium hexafluoride (UF.) and the process and facilities used for enriching UF. in the SU isotope; (2) UF, feed facilities and processes; (3) UF. enrichment facilities and processes; and (4) UF. product withdrawal facility and PODP, July 31,1997 PROPOSED

PROPOSED Seismic Capability ot Buildings C 331 and C-335 Issue,36 Page 2 RAC 97C192 processes. This information is needed to support the assumptions that were used the impacts of normal operation, emergency planning, and the hazard and accident a described in Chapter 4 of the application regarding the contribwnn of facility and process to initiation of events and the design-related assumptions that were used in evaluating accid consequences."

4. Accident Analysis [Rev. 3, 5/31/96]

This chapter provides a description of the accident analyses that were performed to 10 CFR 76.35(a)(4) and 10 CFR 76.85. The accident analyses consisted of (1) review of operations including the history of failures ar;i accidents; (2) discussion of the me in determining the risk associated with hypothetical accidents; (3) identification of accide scenarios: (4) consequences of accidents; and (5) determination of residual risk. The accid analyses considered natural phenomena including earthquakes.

DESCRHTION OF NONCONIPLIANCE in 1985. the PGDP was analyzed for a 0.18g peak ground acceleration earthquake loadi corresponding to an approximate 250-year earthquake return interval, the Evaluation Earthquake (EDE) established in the 1985 Safety Analysis Report (SAR). Building capacit shown to be less than this earthquake demand but only minor structural damage was estim and structural integrity was maintained. liowever, certain cascade piping attachments known as expansion joints or bellows were judged to fail in significant numbers within the bui resulting in a substantial combined release of uranyl fluoride (UO:F,) and hydrogen f from the cascade facilities. Operations were limited to moderate power levels to keep the enrichment process sub-atmospheric until these expansion joints were improved.

Recently, structural seismic loading capacity analyses, performed as part of the ge safety analyses update of the Paducah Gaseous Diffusion Plant (PGDP), have iden significant plant damage could occur in two of the main cascade buildings, C-331 below the Evaluation Basis Earthquake. This damage could involve the failure of the

,approximately 20-foot wide spans which traverse each building in three locations o building's roof. The similarly supported men nine and cell floor sections could also fail affected spans are attached at one column line and supported by a sliding support known as a

" rocker arm." At a seismic loading above 0.05g, the building columns might be displaced out of phase to a distance greater than the available travel of the extension bracket sup the spans to fall. Previous acceptance by DOE of the facility's seismic capability relie integrity of the buildings for events up to the Evaluation Basis Earthquake. This poten of the building integrity has been determined to be an unreviewed safety question and o e

plant's authorization basis.

JUSTIFICATION FOR CONTINUED OPERATION In response to the Unreviewed Safety Question, structural modifications to impro bracing in the affected buildings have been developed and are in progress. Specific cross bracing will be added at specific column locations in the north-south and east-west l directions in Buildings C-331 and C-335 as identified in the detailed design whic PGDP, July 31, 1997 PROPOSED

PROPONED issue 36. Page 3 Seismic Capability of Buildinp C-331.md C-335 RAC 97C192 prepared to raise the capacity of the structures to a 0.15g magnitude earthquake as SAR Upgrade Program site specific hazard curve. These modifications will reduce displa thus ensuring the overall building integrity. Completion of the modifications will bring the P process building structures into compliance within the interpretation of the 1985 SAR seismic requirements for GDP hazardous facilities.

PGDP plans to continue operation with two process buildings, C-331 and C-335, in a l

seismically weak condition until the completion of building reinforcement modifications.

Continued operation of the processes in these buildings is justified in the interim since the increased nsk to the general public and on-site workers is within an acceptable level. The ris increase to the public is a small increase in the chance of an exposure 2 2 to UO F and HF ca minor to moderate renal injuries. The risk increase to some on-site workers is a moderate (fa of 2 to 3) increase in the chance of both exposure to toxic releases and physical injury. (See "Paducah Gaseous Diffusion Plant Justification 13r Continued Operation: Temporary Operat of Buildings C-331 and C-335 with Potentially Severe Structural Damage Due to Evalua Earthquake Loads," nrepared by the Department of Energy Regulatory Oversight, Oak TN, dated May I 7. i996.) Compensatory measures were initiated upon recognition of the structural deficiency and will remain in place until the corrective modifications are complete.

These measures minimize the number of shift personnel in the affected buildings during the interim period, and the allowed power level in the two buildings is limited to maintain the cascade subatmospheric thereby minimizing the release after a seismic event.

The conclusion that the risk level is acceptable during the interim operating period is supponed by evaluations of the consequences to the public and on-site workers from release scenarios based on the projected and bounding building failures that are possible up evaluation basis earthquake. Physical effects such as the impact of a seismically induced fire a were examined as part of these scenarios.

The projected structural response of the two buildings up to an Evaluation Basis Eart (250-year return interval, peak ground acceleration equivalent: 0.15 g) is the inward c three areas of each building's roof, mezzanines, and cell floor. These areas are about 20 feet w and run the length of each building in the direction of the structural expansion joint between internal structural urdt s. The collapse could cause the release of UF., UO 2 2 F , and ilF. In addition, there is some probability that the buildings could collapse in response to the loadin earthquakes that pn. duce accelerations approaching 0.15g. Based on the possible str response, four exposure cases were evaluated. A bounding case (Case 1) assumed th building collapsed (i.e., the building fell over onto its side) and the entire contents of the c system was released into the collapsed structures. It should be noted that the load bea of the converters located throughout the building on the cell floor would prevent the complete flattening of the structure and provide a vertical air space approximately S feet high. The analyzed quantity of the2 UO;F and HF released was not reduced by physical considera as the material that would remain in the cascade piping and equipment or may deposit in the building or the vicinity of the building due to aerosol deposition. However, the effects o thermodynamics and the mixing of fluids (water vapor and R-il4 Freon) in the building were considered. Case 2 used a conservative, but more realistic, engineering analysis basis that included an estimate of the UF. that would remain in the converters following the cascade system ruptures. The amount of aerosol deposition that would occur during the residence time release cloud in the buildings was also considered. This release care is a conservative but defendable estimate of the bounding physical state of the building. Cases 3 and 4 are similar cases PGDP. July 31,1997 MOPOSED

i I

PROPosFD Seismic Capability of Iluildmps C-331 and C-335 Issue 36, Page 4 RAC 97C192 of the buildings' expected actual structural response to an Evaluation Basis Earthquake event (including the failure of areas of the buildings at the structural expansion joints). Case 3 is bas on a highly conservative estimate of the cascade damage that would be sustained if the roo mezzanine, and cell floor failed as predicted and no aerosol deposition occurred. Case 4 is the same as case 3 with consideration given to aerosol deposition.

The resuhs of the four evaluation cases are summarized in the following table:

Table 1. Uranium Uptake and liF exposure

• to Individuals IIF Exposure if F Exposure Meteorology Maumum Maximum Evaluation Case Concentration Concentration Cl.iss Wind Uramum Inhaled Uranium Inhaled Mass (mg) at 5 (ppm)-1 mile (ppm)-5 mdes speed (m!sec) Mass (mg) at i mile miles

f. Iluildmg Collapse-No 38 19 139 70 retention in D.4 Cascade illoundmg Casei

11. Iluildmg Collapse-15 5 Conservatn e D-4 45 16 estimate of retention m Cascade 111. Partial g7 y Huildmg Fadure p,3 yy 7 with No Aerosol Deposnion IV. Partul 2

Buildmg Failure F.3 20 4 11 with Aerosol Deposition

• III exposures are based on I hour aserage concentrations.

The results of all but the bounding case (Case 1) show the potential for only a mild exposure, nearly within the accident evaluation guidelines. The bounding case consequences indicate the potential for significant renal injury, that would not be potentially life threatening at one mile distance from the release point. One mile is essentially the distance to the site boundary from the buildings in question. The risk of exposure to the general public of moderate (uptake of 100-150 mg of uranium) and low (50-100 mg uptake) renal injuries was estimated to be 0.15 injuries and 0.78 injuries / year, respectively, assuming no benefit from an emergency response.

If emergency response is considered and credited with a factor of 2 benefit due to sheltering, then the risk is essentially zero, at 0,15 low level renal injuries / year. Given the highly conservative nature of the evaluation of the release and the low consequences, continued operation does not pose a significant undue risk to the public during the period of operations until building modifications are completed.

The risk to workers in the buildings was estimated as well. Based on an assumed 5 percent chance of building collapse and a 50 percent chance of being present in the building (i.e., on PGDP, July 31, 1997 PROPOSED

. I<

PROPOSED Issue 36 Page 5 Seismic Capability of Buildings C-331 and C-335 rad 97C192 shift), the injury rate to individual workers was estimated at approximately 1 x 10" per year with a total injury rate risk estimated at 2.6x 104 injuries per year ifor an operating staff of 26). This is judged to be acceptable and is no greater than the risk of general office work on-site. Injury from structures may even be higher in the office buildings, although the probability of exposure to liF and UO;F: releases would be greater in the process buildings. Thh. unin .. . fur hr

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Therefore, it is concluded that the risk to the public and the on-site workers from the unmitigated responsero '3uildings C-331 and C-335 is not extreme and can be .septed "ithout undue harm rim the comper a iry measures imposed on operations remaining in effect until the modifications are complete while the structural weaknesses are being corrected.

PLAN OF ACTION AND SCIIEDULE The actions to upgrade the seismic capabilities of Buildings C-331 and C-335 are as follows:

1. Based on a Directive for Information provided to USEC by DOE on September 22,1995.

the USEC evaluation of the currently available information from the DOE safety analysis upgrade effort related to seismic capabilities at the facility completed on October 23,1995, j

the DOE evaluation of the USEC response dated October 31, 1995, USEC's proposed resolution documented on January 9,1996, and USEC's certificate amendment request dated [

July 31,1997, the following actions are being impt.emented to ensure the protection of the l workers and public health and safety:

• Until the completion of modifications discussed below, operations in Buildings C-331 and C-335 will be limited to subatmospheric pressure within the enrichment cascade

. equipment. , ,

• Operations personnel will be instructed on the specific emergency procedures for shutting down the affected enrichment cascade equipment and building ventilation systems following a seismic event.

• Building access will be limited to only those individuals essential to operations.

inspections, or those personnel performing the modifications until they are complete.

l

• Modifications to increase the seismic capability for floor and roof sections in Buildings C-331 and C-335 will be completed am : ding . h; fc!! ..., .,i;dulc hTunt30, iiii.

(a) USEC p;;p. .... and :.;E.... i: 'inal Jc:,;g:. cf 6: C ?? ? nd C ? ?.* 'ruumi-

.nodTa ..< .m ,q uired by ha. 3 bim. ,

I PGDP, July 31, 1997 PROPOSED

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2. At the time of transition from DOE regulatory oversight to NRC regulatory oversight, USEC will inform NRC of the interim measures still in effect for the affected buildings and equipment and the current status of upgrading the seismic capabilities of the affected buildings and equipment.

3. Documentation prepared for the design of the modification and other relevant information concerning implementation will be provided to the NRC, upon issue, for information and review. .

4. By December 1,1997. USEC shall submit for NRC approval an updated seismic risk analysis for the Paducah plant site. The analysis shall:

• Consider all available regional and site-specific data published by the U.S. Geological Survey.

PGDP, July 31,1997 PROPOSED

Seismic Capability of fluildings C-331 and C-335 , PROPOSED issue 36. Page 7 RAC 97C192

• Provide an estimate of the peak ground acceleration for a seismic event with a 250-year return period. If the estimate is greater than 0.15g, then the return period for a 0.15g event shall also be estimated.

Any proposed modifications that may result from this analysis shall be subject to a backfit analysis pursuant to 10 CFR 76.76(b).

SUMMARY

OF REQUIRE 5fENTS, C0515f!TafENTS, AND NONCOSIPLIANCES Issue: Seismic Capability of Buildings C-331 and C-335 Code of Federal Regulations Part Title 10 76.35(a)(4), 76.35(a)(6). 76.35(a)(8). 76.85 Application Commitment Section Safety Analysis Report 2.1.1. 2.6. 3.1. 3.3. 3.4. 4.2.2.6, 4.6.1.

4.7, Table 4.9-1 Application Noncompliance Stetement Section Safety Analysis Report 2.7. 3.16.1, 4.10 PGDP. July 31,1997 PROPOSED