ML20217J318
| ML20217J318 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 03/27/1998 |
| 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-98-0060, GDP-98-60, NUDOCS 9804060263 | |
| Download: ML20217J318 (59) | |
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USEC A Global Energy Company JAMES H. MILLER DtR: (301)564-3309 VICE PRESIDENT, PRODUCTION fax: (301)571-8279 March 27,1998 GDP 98-0060 Dr. Carl J. Paperiello 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 Revised Request for Enforcement Discretion and Justification for Continued Operation
Dear Dr. Paperiello:
.i By letter dated February 25,1998, USEC submitted to the NRC a request for enforcement discretion and an accompanying Justification for Continued Operation (JCO) associated with the potential consequences of postulated seismically-induced failures in the liquid withdrawal facilities (i.e.,
Buildings C-310/310 A and C-315). The purpose of this letter is to provide the NRC revisions to l
the request for enforcement discretion and JCO which incorporate the following information:
l Responres to NRC requests for additional information as submitted by USEC letters dated j
l February 27,1998 (Reference 2) and March 5,1998 (Reference 3), including the specific -
action levels described in USEC's March 5,1998 letter that have been implemented to limit the amount of material that could be released as a result of the postulated failures.
NRC comments provided in the March 3,1998 NRC/USEC meeting and in phone conversations between Y. Paraz (NRC) and L. Jackson (PGDP) on March 6,1998.
USEC's March 11, 1998 letter (Reference 4) which committed to an action plan to permanently correct the seismic weaknesses.
L Copies of the revised request for enforcement discretion and JCO are provided in Enclosures 1 and 2, respectively.
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I 6903 Rockledge Dcive, Bethesda, MD 20817-1818 Telephone 301-564 3200 Fax 301-564-3201 http://www.usec.com 9004060263 900327 cah, KY Portsmouth, OH Washingten, DC PDR ADOCK 07007001 C
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.J Dr. Carl J. Paperiello 1 March 27,'1998
- GDP 98-0060, Page.2.
.Should you have any' questions on the revisions, please contact Steve Routh at (301) 564-3251.
There are no new commitments contained in this submittal.
Sincerely,-
A. l
'l James H. Miller ice President, Production j
References:
1.
Letter from James H. Miller (USEC) to Dr. Carl J. Paperiello (NRC),
" Request for Enforcement Discretion," Leiter No. GDP 98-0031, dated '
February 25,1998.
2.
Letter from Steven A. Toelle (USEC) to Dr. Carl J. Paperiello (NRC),
" Request for Enforcement Discretion - Response to NRC Request for Additional Information (TAC NO. L32057)," Letter No. GDP 98-0036, dated February 27,1998.
3.
. Letter from James H. Miller (USEC) to Dr. Carl J. Paperiello (NRC),
" Request for Enforcement Discretion - Response to NRC Request for -
Additional Information," Letter No. GDP 98-0041, dated March 5,1998.
a 4.
Letter from James H. Miller (USEC) to Dr. Carl J. Paperiello (NRC), " Action Plan for Postulated Seismic Failures in Buildings C-310/C-310A and C-315,"
j Letter No. GDP 98-0046, dated March 11,1998.
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Enclosures:
1.
Revised Justification for NRC Enforcement Discretion l
2.
. Revised Justification for Continued Operation u
cc: MriRobert C. Pierson, NRC-HQ
' NRC Region III Office.
-NRC ResidentInspector-PGDP Mr. Randall M. DeVault, DOE i
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2 to GDP 98-0060
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Revised Justincation for NRC Enforcement Discretion
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GDP 98-0060 Page 1_of 6 L
JUSTIFICATION FOR NRC ENFORCEMENT DISCRETION (Revised) l 1.
THE CERTIFICATION BASIS VIOLATED-Sections 4.6 and 4,7 of the Application Safety Analysis Pqort (SAR) summarize the.
evaluation bases, analysis methodology, and the conclusions reached from studies of the potential impact of natural phenomena events at PGDP. As part of the SAR description, the consequences of postulated seismic failures are evaluated.
j In the process ofresponding to NRC questions on USEC's October 31,1997, SAR Update (SARUP) submittal, a review of operations in the Building C-310/C310-A product and Building C-315 tails withdrawal areas has concluded that the current release assumptions made in the SAR Section 4.6 analysis of the consequcnces of postulated seismic failures are no longer valid. Specifically, the SAR analysis assumes only a limited UF release fmm the j
p C-310 withdrawal facility. However, during the normal course of operations in Buildings C-i 310/310-A and C-315, these facilities contain varying amounts ofliquid UF. depending on I
withdrawal rates and maintenance and operational activities. The amount of UF that could -
L be released from these facilities during a postulated seismic event exceeds that assumed in L
the current SAR analysis.
-2.
THE CIRCUMSTANCES SURROUNDING THE SITUATION, INCLUDING ROOT -
CAUSES, NEED FOR PROMPT ACTION AND ANY RELEVANT HISTORICAL j
FACTS.
The circumstances and causes leading up to this issue are documented in USEC letter GDP 1013, dated Februarf 80,1998.
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. Consistent with guidance in Section 4 of NRC Generic Letter 91-18, Revision 1, USEC has l
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taken the compensatory actions described in No. 6 to restrict plant operations to compensate l
-i for the increase in the amount ofliquid UF that could potentially be released from Building l
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C-310/310-A and C-315 during a postulated seismic event.
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l The actions listed in No. 6 are in addition to the compensatory measures already being Ll l
implemented in response to the postulated seismic failures in Buildings C-331 and C-335 in -
l accordance with the Justification for Continued Operation (JCO) for Compliance Plan Issue
- 36.
l USEC has concluded that a continuation of the normal, safe operation in the C-310/310-A j
and C-315 withdrawal areas, in conjunction with the above compensatory measures, j
represents the safest condition for the overall plant when compared with the postulated seismic induced failure. The compensatory measures establish a safe condition by
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L GDP 98-0060 Page 2 of 6 minimizing 6e amount of material in thi withdrawal area accumulators to such a level that the conseonences of a release are of the une order as other analyzed releases. In addition, limiting accese to the buildings limits individual exposures to physical or chemical hazards in the event of an accident.
Prompt action is requested to allow the plant to continue operating in the safest condition.
Short term recycle operation and eventual shutdown is not the safest condition for the overall plant. Inherent to any infrequently performed procass, the probability of operator errors in valving operations would be increased over normal operating conditions.
Additionally, this abnormal operation would involve complications in controlling assay and 1
light and intermediate gas accumulations. Putting the plant in recycle is an abnormal 1
operation that could cause unanticipated transients and pressure surges in the cascade that may actually increase the probability of other plant events, e.g., UF hot-metal reaction 6
and/or compressor deblading.
3.
THE SAFETY BASIS FOR THE REQUEST, INCLUDING AN EVALUATION OF THE SAFETY SIGNIFICANCE AND POTENTIAL CONSEQUENCES OF THE PROPOSED COURSE OF ACTION,INCLUDINO ANY QUALITATIVE RISK ASSESSMENT.
Calculations have been performed for the seismic failures described in the attached Justification for Continued Operation (JCO 98-01, Rev.1). The consequences associated.
l with this issue, with the compensatory actions in place, are estimated to be 113 mg U intake i
at one mile from the plant center. While this number is not directly comparable to the l
consequences identified in the current SAR, in terms of mg intake, it is comparable in terms of risk. Current risks identified in SAR Chapter 4 are all in the LOW risk category or lower.
' Using this same rationale for the current situation, the probability of an earthquake times the consequences of the resultant seismically induced releases is also LOW. This is the same risk level previously accepted for the evaluation basis seismic event.
t 4.
THE BASIS FOR THE CERTIFICATE HOLDERS CONCLUSION THAT THE NONCONFORMANCE WILL NOT BE OF FOTENTIAL DETRIMENT TO THE PUBLIC HEALTH AND SAFETY AND THAT NEITHER AN USQ NOR A DETERMINATION OF SIGNIFICANCE IS INVOLVED.
As discussed in the JCO, the increase in the amount of UF,available for release in the liquid 4
withdrawal areas during a postulated seismic event results in an increased level of consequences over those currently evaluated in SAR Sections 4.6 and 4.7. Therefore, this condition represents an Unreviewed Safety Question (USQ).
However, the differences in the source term and consequences, as shown in the JCO, are not significant when compared with those previously analyzed and accepted through the
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GDP 98-0060 Page 3 of 6 application and certification process. This is evident in the comparison presented in the JCO
. between the JCO analysis results and those described in the current SAR accident analysis and the JCO for Compliance Plan Issue 36.
The consequence increase _is minimized by the compensatory actions that have been implemented as described in the JCO; For example, current operations are directed at
- minimizing the inventory of material in the withdrawal area accumulators at any given time.
' Thus, the probability is small that an earthquake will occur during periods when substantial material is in the accumulators. The conclusion of the JCO is that, with compensatory reasures in' place, the continued operation of PGDP with seismically sumeptible failures does not result in undue risk to public health and safety.
The analyses 'contain.nany conservatisms that were assumed in such a manner to' maximize l
the consequences of a release. For example, no credit is taken for building holdup or deposition, terrain effects,' atmospheric instability, etc. If more accurate analyses were to be performed, these conservatisms would be reduced, leading to a reduction in the consequences.
5.
THE BASIS OF THE CONCLUSION THAT THE NONCOMPLIANCE WILL NOT INVOLVE ADVERSE CONSEQUENCES TO THE ENVIRONMENT.
The impact to the envirorurent is related to the impact to the public. As described above, the consequences to the public as a result of this issue are not significant when compared to those previously reviewed. Therefore, the consequences to the environment are also not -
significant when compared with those previously reviewed.
- 16. ANY PROPOSED COMPEN3ATORY-MEASURES.
- The following compensatory meuures have been implemented to minimize the consequences of the postulated seismic failures in Buildings C-310/310-A and C-315:
(1) Only one accumulator in Building C-315 will b' e used to store liquid UF, at a time. The second accumulator has been removed from service through administratively controlling the valving. The standby accumulator will be isolated at all times except in the event that switching condensers / accumulators is necessary. During switching operations, both accumulators can be on-line temporarily to maintain uninterrupted accumulator access
.while flow:, are being re-established.;This valving sequence is required to avoid condenset flooding and unnecessary challenges to the Normetex Pump High Discharge -
. Pressure System. This valving evolution typically lasts for less than one hour and will not be done while actively filling the accumulators. The off-stream accumulator has been y
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GDP 98-0060 Page 4 of 6 caution-tagged and swapping accumulators will only be done with front-line manager approval.
(2) A crew briefing was performed to provide operators with a heightened awareness of the 1-l
. potential concems with unrestrained filling of the on-line accumulator in Building C-315, l
and to emphasize that any rex==y maintenance activities are to be expedited so as to
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minimize the amount of time that liquid UF, is stored in the accumulators.
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(3) The operations staff has issued Long Term Orders for Buildings C-310 and C-315 that l
specify, that except for surveillance / maintenance activities and during cylinder changeout, an empty cylinder should be kept available at all operable withdrawal positions not currently in use to provide the maximum additional storage capacity for liquid UF and to minimize the amount of time that material is diverted to the accumulators.
(4) To minimize potential effects on local workers, access to Buildings C-310 and C-315 is l
limited to only those individuals essential to operations, inspections, or those personnel performing any modifications to fix the identified seismic failures.
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(5) During the period in which operation under this JCO is authorized, the amount of UF.
l stored in the C-310/310-A and C-315 accumulators will be kept below a nominal 2,000 lb i
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_ UF. and 5,000 lb UF. respectively during normal operation.
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- (6) In cases of abnormal operation, the levels will not be allowed to exceed.4,000 lb UF in
'l the C-310/C-310-A accumulators and 10,000 lb UF. in the C-315 accumulator. The
. l amount being' stored in the accumulators will be based on best estimates using withdrawal l
rate information since calibrated level indicators or load cells are not available.gThe l
accuracy of this method of monitoring inventory is sufficient to provide confidence that l
the calculated intakes are not exceeded. Table 1 shows the conditions and shninistrative l
. limits and controls for accumulator UF inventory for C-310/310-A and C-315.
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l (7) In the event that the UF accumulator limits are reached in either Building C-310/310-A
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. or C-315, the affected withdrawal operations will cease and be placed on recycle or.
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- l routed to surge drums and assays controlled in accordance wth established procedures.
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Also, as required by Application SAR Section 6.11, emergency response to a seismic event l
has been incorporated into plant procedures. This requires that upon detection of a seismic
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i event with the potential to cause a UF. release, immediate actions are taken to minimize the l
conscquences.
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GDP 98-0060 Page 5 of 6 Table 1. Administrative Limits and Controls for Accumulator UFsInventory I
for C-310/310-A and C-315.
' Condition Required Action Completion Time l
Diverting flow to the accumulator 1.
Notify the PSS of accumulator usage.
Immediately s
in C-310-A or C-315 for greater _
2.
Begin tracking of quantities by using calculated than one hour (nominal 2,000 and withdrawal rates.
5,000 lb UF.respectively at one 3.
PSS initiate high priority actions for timely hour) resolution of unscheduled outages.
- 4. ' Cascade Coordinator takes actions to reduce
- tails downflow and/or product or tails withdrawal rates to minimize accumulator use as appropriate.
5.
Notify NRC.
Calculated accumulator inventory 1.
Stop diveiting flow to the affected accumulator.
Immediately -
reaches 4,000 lb UF. in C-310-A or 10,000 lb UF. in C-315.
l These actions are in addition to the compensatory measures already being implemented in l'
response to the postulated seismic failures in Buildings C-331 and C-335 in accordance with the JCO for Compliance PlanIssue 36.
- 7. THE JUSTIFICATION FOR THE DURATION OF NONCONFORMANCE.
On March 11,1998, USEC submitted an action plan for addressing the postulated' seismic l
l failures in Buildings C-310/310-A and C-315 (see USEC letter GDP 98-0046). In this letter, l
- USEC committed to modifying by September 30,1998, the withdrawal systems equipment I
(Normetex pumps, condensers, accumulators and connecting piping) to increase its seismic l
capacity. The nonconformance will last until the modifications are complete.
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- 8. ' A STATEMENT THAT THE REQUEST HAS BEEN APPROVED BY THE PLANT OPERATIONS REVIEW COMMITTEE (PORC).
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The information used in this request, along with the JCO, was reviewed and recommended l
for approval by the PORC on March 26,1998.
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9.? THE REQUEST MUST ADDRESS HOW THE CRITERIA FOR REQUESTING ENFORCEMENT DISCRETION IS MET.
This request for enforcement discretion is intended to avoid undesirable transients as a result of attempting to comply with the certificate condition and, thus, minimize potential safety 1
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GDP 98-0060 Page 6 of 6 consequences and ' operational risks. As discussed in the response to Item 2 above, without
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. the enforcement discretion, the plant would be _ forced to enter the recycle mode and eventual forced shut down of the facility. Short-term shutdown could result in criticality safety.
concerns throughout the cascade. The recycle transient would also introduce the additional risk associated with complex and infrequent operating conditions. Therefore, the granting of enforcement discretion 'would prevent the introduction of additional risk.
- 10. MARKED-UP SAR AND/OR TSR PAGES SHOWING THE PROPOSED CHANGES -
SHOULD BE ATTACHED.
No changes to the SAR or TSRs are proposed at this time.
- 11. STATEMENTS THAT PRIOR ADOPTION OF APPROVED LINE-ITEM IMPROVEMENT TO THE TECH SPECS WOULD HAVE OBVIATED THE NEED FOR
N/A
- 12. ANY OTHER INFORMATION THE STAFF DEEMS NECESSARY BEFORE MAKING A.
DECISION TO EXERCISE ENFORCEMENT DISCRETION.
No other information has been requested by the Staff at this time.
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t' I to GDP 98-0060 p-Revised Justification for Continued Operation 1
l Note:, The revised JCO incorporates substantial changes to most sections of the JCO; hence.
revision bars have not been included.
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JCO 98-01 Rev.1 Justillectio2 for Ce: tired Operation Page1of49 of the Paducah Gascous Diffusion Plant with Seismically Susceptible Failures JCO Number: JCO 98-01. Rev.1 Submitted on: March 27 I998
1.0 INTRODUCTION
1.1 Executive Summary Revision 1 of die Justification for Continued Operation (JCO 98-01) was prepared to incorporate NRC comments on the Revision 0 version that were provided in a meeting on March 3,1998, between the United States Enrichment Corporation (USEC) and the Nuclear Regulatory Commission (NRC). This JCO evaluates the acceptability of continued operation of the Paducah Gaseous Diffusion Plant (PGDP) with seismically-susceptible failures.
Compensatory measures have been implemented to reduce the amount of UF. that could potentially be released. Based on these compensatory measures, the resulting consequences and associated risk to plant personnel and the offsite public are evaluated and compared to other accident analyses.
The conclusion of this JCO is that, with compensatory measures in place, the continued operation of PGDP does not result in undue risk to public health and safety.
1.2 Background
Section 4.6 of the Application Safety Analysis Repon (SAR) summarizes the evaluation bases, analysis methodology, and the conclusions reached from studies of the potential impact of natural phenomena events at the PGDP. These studies were performed by the Department of Energy (DOE) in the 1980s using an Evaluation Basis Earthquake (EBE) having an approximate 237-year recurrence interval.
The corresponding effective peak ground acceleration was determined by DOE to be 0.18g. As summarized in SAR Section 4.6.1.3, the analyses concluded that cenain structures, systems, and components were not capable of withstanding a 0.18g EBE without damage and the consequences of such failures were identified and evaluated. As a result of these analyses, various modifications were made to the plant to improve the seismic capacity of selected systems and components.
USEC submitted to the Nuclear Regulatory Commission (NRC)i.2 an update to the Application SAR as required by issue 2 of DOE /ORO-2026," Plan for Achieving Compliance With NRC Regulations at the j
Paducah Gaseous Diffusion Plant"'(the Compliance Plan). USEC's update to the Application SAR is based
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largely on the results of the upgraded site-wide SAR* prepared by DOE. As part of DOE's efforts to develop i
the upgraded site-wide SAR, the capability of PGDP to withstand postu!ated mismic events was re-assessed.
DOE's analyses in support of the upgraded tite-wide SAR were performed using an EBE having a 250-year recurrence interval. The corresponding site specific peak ground acceleration was determined by DOE to be 0.15g. The DOE analyses concluded that certain stmetures, systems, and components are not capable of withstanding a 0.15g EBE without damage. The DOE analysis predicts that seismically-induced failures could occur in Buildings C-331, C-333, C-335, C-337, C-310/310-A, C-315, and C-360.
At the time the Compliance Plan was being prepared, the DOE site-wide SAR upgrade effort had not yet completed all analyses of possible accident conditions and consequences. However, the available preliminary results were generally consistent with previous analyses forming the PGDP operating safety basis and had not identified any additional significant accidents that had not been addressed in the
JCO 98-01, Rev. I Page 2 of 49 Application SAR. The only exception identified where analysis results did not confirm previous analyses l
was in the area of seismic capability of Buildings C-331 and C-335. Seismic analysis results of these l
buildings indicated that th y fall short of the seismic risk goals established for the PGDP process facilities.
Compliance Plan Issue 3t> entitled " Seismic Capability of Buildings C-331 and C-335" and a corresponding l.
Justification for Continued Operation were developed by DOE based on the available information. The j
Compliance Plan issue requires that modifications to increase the seismic capability of the buildings be j
implemented.
By letter dated Feburary 5,19985, the NRC requested USEC to provide additional information -
l regarding the predicted seismic failures in the withdrawal areas of Buildings C-310/310-A and C-315 and a justification for continued operation, given their susceptibility to seismically-induced damage and the l
potential consequences.
By letter dated February 25,1998', USEC submitted a request for enforcement discretion and the Revision 0 version of this JCO to allow continued operation of the C-310/310-A and C-315 facilities pending final resolution of the issue.
On March 3,1998, a meeting was held between the NRC and USEC to discuss technical questions regarding Revision 0 of this JCO. Responses to NRC requests for additional information were submitted in USEC letters dated February 27,1998" and March 5,1998'.
By letter dated March 11, 1998, USEC committed to complete equipment modifications to seismically-support the Normetex pumps, condensers, accumulators, and connecting piping in the withdrawal areas of Buildings C-310/310-A and C-315. USEC also committed to revise this JCO to incorporate the NRC's comments.
2.0 ISSUE This issue of concern is the continued operation of the Paducah Gaseous Diffusion Plant with SSCs susceptible to seismically-induced damage and subsequent toxic chemical release. This JCO identifies the failures predicted to occur and assesses the consequences of those failures. The likelihood of significant consequences due to a seismic event is also evaluated to determine overall risk.
- 3. 0 DISCUSSION An analysis of the consequences of the postulated seismic failures has been performed. Section 3.1 describes the structural and equipment evaluations performed. Section 3.2 describes the source-term analysis. Section 3.3 describes the methodology, assumptions, and results of the consequence analysis and evaluates the effects on onsite personnel and the offsite public. Section 3.4 presents a risk assessment based on the predicted consequences.
i 3.1 Structural and Equipment Evaluations As part of the DOE site-wide SAR upgrade, structural and equipment evaluations were performed for all facilities that process or store significant quantities of UF.to estimate the potential damage that could
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result from a 0.15g EBE. All operations were assumed to be normal at the initiation of the event. The results of the DOE analyses are presented in Appendix A. The methodology for the DOE natural phenomena evaluations is described in Section 4.3.1.3 of the SAR Update (SARUP).
.ICO 98-01, Rev.1 Page 3 of 49 I
As shown in Table A-1, all buildings were determined to have structural capacities at least equal to a 0.15g peak ground acceleration with the exception of Buildings C-331 and C-335. Capacity is defined as no building collapse. Structural failures predicted to occur in Buildings C-331 and C-335 are identified in Table A-2.
Equipment whose failure could directly result in a release of UF. was also analyzed. This equipment includes supporting equipment not directly containing UF., such as overhead cranes, sca'e carts, and autoclaves, that if not retained in position, could impact UF. systems. This evaluation detennined that a number of components have less than the evaluation basis capacity. Potential failures were identified in the process buildings (Buildings C-331, C-335, C-333, and C-337), tie-lines, withdrawal facilities (Buildings C-310/310-A and C-315), and the toll transfer and sampling facility (Building C-360).
Tables A-3 through A-9 list the equipment, piping, and components with capacities less than the 0.15g EBE for Buildings C-331, C-335, C-333, C-337, C-310/310-A, C-315, and C-360. The seismic capacity identified in Tables A-3 through A-9 represents a high confidence of low probability of failure (HCLPF) capacity. This is the capacity for which there is 95% confidence of less than a 5% chance of failure. The annual probability of failure presented in these tables is based on the median capacity, which is about 2.5 times the HCLPF capacity. This represents the ground acceleration that would cause half of an average equipment sample to fail. Earthquake experience data suggest that damage does not occur for peak ground accelerations less than 0.05g, and the accuracy of seismic calculations does not support assigning capacities below that value. Therefore, a capacity of 0.05g was the lowest capacity assigned to any piece of equipment for determination of failure probability.
For each item, the seismic capacity, annual probability of failure, location, and comments are provided. The capacities reported in the tables are the capacities of the weakest member (s) whose failure could potentially cause a UF release in the process gas systems. These items were evaluated further to 6
determine if a loss of pressure boundary was likely and to estimate the hole size that would result if the pressure boundary was breached. Equipment, piping, and components with capacities less than the EBE but that still maintain pressure boundary integrity are noted in the tables with an asterisk (*). In addition, potential seismic interactions of the cell housings and the stage compressors were evaluated. Failure of the cell housings did not adversely impact a UF. pressure boundary.
3.2 Souree-Term Amlysis A source-term analysis has been performed based on the' structural and equipment failures descrihd in Section 3.1. All failures are assumed to occur simultaneously as a direct consequence of the postulated seismic event. Since compensatory measures are in place which regulate the pressure of some portions of the cascade to below atmospheric, no higher power levels will be discussed. The source term (Ibs UF.)
assumed for each of the failures is identified in Table 1.
"00" process buildings (C-331 and C-335)- As indicated in Table A-2, the structural response of Buildings C-331 and C-335 is predicted to result in the failure of the approximately 20-foot-wide spans which traverse each building in three locations of each building's roof. The similarly supported mezzanine and cell floor sections could also fail. The affected spans are attached at one column line and supported by l
a sliding support known as a " rocker arm." At a seismic loading above 0.05g, the building columns might
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be displaced out of phase to a distance greater than the available travel of the extension bracket support, l
causing the spans to fail. There is also some probability that the building could collapse in response to an earthquake acceleration approaching 0.15g, although the ultimate capacity of these buildings was not
I JCO 98-01, Rev.1 Page 4 of 49 specifically determined as part of the DOE analyses performed in support of the site-wide SAR upgrade.
Although several equipment failures in the "00" buildings (exclusive of the structural failures) are identified in Tables A-3 and A-4, because the operating pressures are currently restricted to subatmospheric, any pressure-driven potential releases from these failures are effectively eliminated.
The source term assumed in this JCO for the structural and equipment failures predicted for Buildings C-331 and C-335 is associated with the Case 2 analysis presented in the JCO for Compliance Plan issue 36. As described in the detailed JCO" prepared by DOE in support of Compliance Plan Issue 36, Case 2 was a conservative, best-estimate analysis that assumes total building collapse and includes an estimate of the amount of UF. that would remain in the converters following the cascade system ruptures. The amount of aerosol deposition that would occur during 'he residence time of the release cloud in the buildings was also considered. He source term assumptions made by DOE were as follows:
The source term is analyzed at an operating cascade power level of 2200 MW. This power level is representative of current cascade operations which typically range between 1100 MW and 2000 MW.
DOE concluded that the exact nature of the system breaks, if any occur, could not be predicted with
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high confidence. So, a conservative, best estimate was made by observing that the converters contain roughly 48% of the inventory of UF. below the elevation of the lowest pipe connection.
Thus, assuming all piping connections fail, the release of UO F and UF. was assumed to be 2 2 equivalent to 52% of the total UF inventory.
During the residence time withi., the building, significant deposition of UO F was estimated by 2 2 DOE. The deposition assmaed was 37% of the total released into the collapsed structure.
Based on these assumptions, approximately 13,630 lb (6,184 kg) of uranium and approximately 76%
of the HF created [5,560 lb (2,520 kg)] was estimated by DOE to be released from each building.
"000" process buildings (C-333 and C-337)-The estimated failures in each of the "000" process buildings are shown in Tables A-5 and A-6. The failures are predicted to occur where the tie lines from the "00" process building enter and connect to the "000" equipment. Each tie-line consists of four major pipes (two A lines and two B lines). One A-B pair connects the bottom "000" unit with the stripper section of the "00" building, and the other A-B pair connects the top "000" unit to the enricher section of the 00" building. Because of restrictions on "00" operating pressures, both the A and B lines of the tie-lines would be below atmospheric pressure. Failures in "000" equipment are only predicted where the operating pressures are below atmospheric. With the process operating below atmospheric pressure, air will flow into the severed lines. Past experience with large air leaks into the cascade shows that with a sizable leak, air will displace the UF. in that region of the process, creating a " bubble" of light gas. Compressors within the bubble will surge as the density of the gas they are pumping drops. The reaction between UF. and the moisture in the air takes place at the air-UF. interface and is rather limited by the lack of mixing between air and UF. inside the pro-cess. Given the large volume of the cascade, a large volume of air will flow into the process unless the leak is stopped. After the flow is halted, UF.or its reaction products (UO F and HF) 2 slowly drift back to the vicinity of the hole. Because of these characteristics, the severed ends of the below-j atmospheric-pressure tie lines would not cause any appreciable release into the process buildings, except for i
the UF. contained in the tie lines that would flow out under the influence of gravity. The source term from the process building tie-lines is addressed in the next paragraph.
f JCO 98 01, Rev i i
Page 5 of 49 l
l Process building tie-lines-An analysis of the seismic source term for completely severed tie-lines l
is described in SARUP Section 4.3.2.5.3c. As stated above, the tie-lines are operated at subatmospheric l
pressure. A completely severed tie-line will have air inleakage until the pressure stabilizes and ma*.erial I
leaks out. Based on the cascade power gradient at 2200 MW, the source term from the tie-lines was determined to be approximately 600 lb for C-331,400 lb for C-335,600 lb for C-333 and 400 lb for C-337 and is expected to be released over ten minutes.
C-310/C-310-A purge andproduct withdrawal building-Table A-7 shows the postulated seismic failures for C-310/C-310-A. The C-310/C-310-A purge and product withdrawal facility houses the purge cascade which is operated at subatmospheric pressures. Thus, no releases are expected due to postulated seismic failures in these areas.
In the withdrawal area, seismically-induced failures associated with the Normetex pump anchorage, Normetex pump discharp piping, condenser anchorage,10-ton (product) accumulator anchorage, and 2%-
ton (side) accumulator anchorage are predicted to occur which could result in a release of UF.. The Normetex pumps may fail because of support failures breaking both the suction and discharge lines. No appreciable leak from the cascade piping would result from this because the suction pressure is below atmospheric pressure. The discharge from the Normetex pumps goes into the UF. condensers, which may j
fall off their cradles, resulting in broken UF. piping.
The combined capacity of the three C-310/C-310-A condensers is about 1,500 lb (680 kg) which j
includes the amount of UF. contained in connecting piping. They are conservatively assumed to be full and release all of their contents. The product accumulator has a capacity of approximately 21,000 lb (9,525 kg),
and the side accumulator has a capacity of approximately 4,300 lb (1,950 kg). Compensatory measures currently restrict operations such that no more than a total of 4,000 lb (1814 kg) will be stored in the C-310 accumulators. Previous analysis has conservatively assumed that ruptured liquid-filled UF. cylinders would release their entire contents in five minutes (see Application SAR Section 4.7.2.4.2, the liquid UF. cylinder drop scenario). Because condensers and accumulators are similar to large UF. cylinders in size, shape, and construction, the same five minute release duration as the liquid UF cylinder drop scenario is assumed.
6 Because both accumulators fail in the same manner, no assumptions were made reFarding the combination of masses in each accumulator to obtain a source term of 4,000 lb.' This results in a combined release of 5,500 lb (2,495 kg) liquid UF at a rate of 18.3 lb/s (8.32 kg/s).
Because liquid UF. cannot exist at atmospheric pressure, the liquid flashes to a mix of UF solid and vapor at 134*F (57 C), the equilibrium temperature for UF. vapor and solid at I atm pressure. The split between vapor and solid is determined by the initial temperature of the liquid UF.. This evaluation used a liquid temperature of 180 F (82*C), which is at the high end of the operating range for this equipment. The normal operating temperature for the condensers is approximately 160 F (71 C). The warmer temperature is conservative, as it results in a larger vapor fraction after flashing, which increases the consequences downwind. When released to the atmosphere, the 180 F (82 C) liquid UF. flashes to 49 percent vapor and i
51 percent solid and the temperature falls to 134 F (57 C).
C-315 tails withdrawalbuilding-Table A-8 identifies the postulated seismic failures in Building C-315. As shown in the table, the failures in Building C-315 are si nilar in nature to those predicted to occur in Building C-310/C-310-A. Seismically-induced failures associated with the Normetex pump anchorage, the Normetex pump discharge piping, the Hortonspheres, the condenser anchorages, a.d the accumulator anchorages for both 40,000 lb tails accumulators are predicted to occur which couk' result in a release of UF..
I
100 98-01, Rev. I Page 6 of 49
.As stated for the C-310/C-310-A source term discussion, no appreciable cascade leak would result from a failed Normetex pump anchorage because the suction pressure is below atmospheric pressure. The two Hononspheres are located in a heated housing on the ground floor of Building C-315. One Hortonsphere is typically maintained at a very low vacuum while the other may contain UF at up to 10 psia. Because the Hortonspheres are subatmospheric, no significant release of material would be expected.
The C-315 accumulators and condensers are assumed to fail in the same manner as that described for the C-310/C-310-A accumulators and condensers (i.e., five minute release duration). The combined capacity of the three C-315 condensers is about 2,000 lb (907 kg) which includes the amount of UF.
contained in connecting piping. They are conservatively assumed to be full and release all of their contents.
Building C-315 has two accumulators each with a capacity of approximately 40,000 lb (18,050 kg).
Compensatory measures currently restrict operations such that only one accumulator will be in service and no more than 10,000 lb (4,536 kg) will be stored. The failures from the three C-315 condensers and the one in-service C-315 accumulator results in a combined release of 12,000 lb (5,443 kg) in five minutes. His corresponds to a release rate of 40 lb/s (18.14 kg/s) liquid UF..
C-360 roll transfer andsamplingfacility-As indicated in Table A-9, the hydraulic lines for the C-360 elevator and levelator were predicted to fail during a postulated seismic event. However, the elevator and levelator are used infrequently to transport a cylinder and are operated for only a few minutes during each use. Therefore, no release of UF is considered as a result of these postulated failures.
3.3 Consequence Analysis 3.3.1 Methodology and Assumptions HGSYSTEM/UF,-The HGSYSTEM/UF suite of codes, described in SARUP Section 4.3.1.2.3.4, was used to determine consequences of the liquid UF. releases from the withdrawal facilities and the vapor releases from the process building tie-line failures. From this suite of codes, a single model, UF. MIXER, was used to estimate the dispersion of the releases from these plant buildings. The UF. MIXER code models the initial mixing and reaction of the release within the building. If the reaction is completed within the building, the Wilson-Briggs model for enhanced dilution within the building wake cavity is employed and the subsequent downwind dispersion is estimated by using a Pasqual!Gifford Gaussian plume model. If the release has not finished reacting, the code transfers data to the HEGADAS/UF. code, which models releases of dense gases at or near the ground level and accounts for continuing reaction of the UF.. A postprocessor, POSTMIX, which accounts for spreading of the plume in the windward direction, is used to estimate the exposures at ground level.
The basic HGSYSTEM model for heavy gas dispersion, from which the HGSYSTEM/UF. model was derived, has been extensively validated." The UF. chemistry and thermodynamics within a dispersing plume have not specifically been validated. However, *he UF. chemistry and thermodynamics have been compared satisfactorily with the analysis of Rodean. Several French field tests were performed with UF.
gas releases, but the plumes were essentially passive, reacted releases and therefore of limited value in validating the HGSYSTEM/UF. model.
NUREG/CR-6481" reports the statistical analysis of HGSYSTEM/UF, simulations of theses field tests and indicates significant biases toward underprediction, primarily because of the severe underpredictions at shorter distances (associated with greater concentrations).
The NUREG states that the HGSYSTEM/UF. model is capable of providing predictions, of total uranium, that underestimate the measured concentrations by a factor of two, and overestimate them by, at most, an order of magnitude.
JCO 98-01, Rev.1 Page 7 0f 49 HGSYSTEM/UF. was not used to model the releases from the "00" buildings. The methodology and details of these assumed releases are discussed in the DOE JCO supponing Compliance Plan Issue 36 and its supporting analyses.""
Withdrawal building releases were conservatively simulated by assuming that the plume would be released to the atmosphere at ground level through the large bay doors on the downwind side of the building.
The temperature of the UF released into the process buildings was set at 80*F (26.7 C), with release durations to the atmosphere assumed to be the same as the release rates into buildings. Therefore, no retention of the released material in the building was assumed. A value offs was selected such that the plume was not fully reacted and remained a ground hovering plume. This value allows for very little dilution from the air inside the buildings-a conservative assumption that results in higher downwind consequence estimates.
Assumedrelease point-All plumes ("00" buildings, process building tie-lines, C-310/C-310-A, and C-315) were conservatively assumed to originate from the same location (the plant center) to maximize the predicted consequences. Accounting for actual building locations would reduce the calculated consequences.
Meteorological conditions - For the baseline analysis in this JCO, typical meteorological conditions were selected to estimate the consequences of the postulated seismic releases. The most frequently occurring meteorological condition at PGDP is D4 (stability ciass D, neutral, and wind speed of 4 m/s), which occurred 14.9 percent of the time on an annual basis. An ambient relative humidity of 70 percent was selected j
because this value represents a maximum relative humidity at an ambient temperature of 80*F (26.7 C). In 1992, the maximum relative humidity recorded at PGDP for ambient temperatures of 80*F and above was about 71 percent. Other meteorological conditions that occur less frequently but result in higher consequence estimates were not chosen to represent typical or expected conditions because of the relatively unlikely occurrence of an evaluation basis earthquake at the site in conjunction with worst-case wind j
conditions. A less likely meteorological condition combined with an unlikely seismic event would lead to a release scenario that is a ph less credible.
A sensitivity analysis using F1 (stability class F, neutral, and wind speed of I m/s) conditions was also performed. Note that in the puff model analysis performed by DOE for the complete collapse of the "00" buildings, the consequences using F1 conditions are negligible.
Wake effects and surface roughness - The effects of the air streaming past the withdrawal buildings-wake effects-were considered for this analysis. The site contains many large buildings and the area surrounding the plant site is mix of farmland and forest. These terrain effects would act to disturb the passage of the contaminated plume and cause enhanced dilution. However, this analysis conservatively assumes a flat, open, rural environment beyond the building from which the release is emitted by modeling the surface roughness as 0.03 m.
Receptor locations - For the withdrawal building releases, consequences were calculated from 0 l
to 5 miles using HGSYSTEM/UF.. Because of the potential for underprediction in the near field results (i.e.,
from 0 to about 500 meters), the reported consequences may not be bounding. However, within the limitations of the model, the results provided are considered appropriate for discussion.
The DOE JCO only reported consequences at 1,2, and 5 miles for the postulated "00" building structural failures. Contributions from the failure of the "00" buildings to receptors at distances of 3 and 4
JCO 98-01, Rev. I Page 8 of 49 miles were determined using linear interpolation between the consequence values at 2 and 5 miles. Linear interpolation is conservative because atmospheric dispersion results in an exponential decay rather than a l
linear reduction. Because no consequence data was reported by DOE for receptors closer than one mile, the consequences to plant personnel are addressed for only the liquid UF. releases from the withdrawal facilities.
Total consequences for a postulated seismic event were determined by summing the consequence contributions calculated for the "00" building, tie-line, C-310/310-A, and C-315 failures. This approach is highly conservative because it does not account for building locations or the reducing effects associated with heavy gas dynamics.
3.3.2 Results Figures 1 and 2 plot the calculated uranium intakes and HF exposures assuming D4 meteorological conditions. Contributions from the C-310/310-A, C-315, "00" process buildings, and tie-lines are shown individually. A total consequence curve is also shown as the summation of the individual contributions. As discussed previously, based on the HGSYSTEM/UF. validation, there is lower confidence in the reported consequences within 500 meters. A tabulation of the offsite consequence results (at 1,2,3,4, and 5 miles) is provided in Table 2. At I mile, an intake of 113 mg U and and a 71 ppm HF exposure are estimated. By 5 miles, the predicted consequences are reduced to an intake of 21 mg U and an 8 ppm HF exposure.
]
Figures 3 and 4 plot the calculated uranium intakes and HF exposures for the sensitivity analysis based on F1 meteorological conditions. Contributions from the C-310/310-A, C-315, and tie-lines are shown individually. (As discussed previously, the consequences of the assumed "00" process building failures i
using F1 conditions are negligible.) A total consequence curve is also shown as the summation of the i
individual contributions. A tabulation of the offsite consequence results (at 1,2,3,4, and 5 miles) is provided in Table 3. At I mile, an intake of 136 mg U and and a 56 ppm HF exposure are estimated. By 5 miles, the predicted consequences are reduced to an intake of 16 mg U and a 5 ppm HF exposure.
3.3.3 Effects on Onsite Personnel of Uranium Dose and/or HF Exposure Table 4 identifies the typical onsite population by building and area during normal daytime operation. It is estimated that approximately 320 other personnel (e.g., construction subcontractors and service contract personnel) are scattered throughout the site. This information is used to assess the impact to plant personnel of the postulated seismically-induced UF. releases.
Local workers in the immediate area-Workers in the immediate area of a UF release could be exposed to a significant uranium dose and/or HF exposure. For the failures predicted to occur in Buildings C-310/310-A and C-315, the exposure concentration in the immediate vicinity of the UF. release could be lethal.
The immediate area surrounding the condensers and accumulators in Buildings C-310/310-A and C-315 is not normally occupied, but the withdrawal area (the location where the plume is assumed to exit the building) may be occupied by operations or maintenance personnel. In the event of a release, the plant "see and flee" policy requires personnel to immediately evacuate the area for their own protection. The method of detection for local workers is (1) visual indication of a " white smoke"(i.e., reaction products of UF. and moisture) or (2) the odor of HF, which is a product of the reaction of UF. and moisture. Based on the compensatory measure of restricting personnel access to these buildings, approximately 5 to 10 persons would typically be expected in each building to support routine operations and maintenance activities. It is l
I
]
JCO 98-01, Rev. I Page 9 of 49 j
l
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l estimated that an additional five to ten workers (approximately) in each building will be involved in completing the seismic fixes.
l The potential impacts of the predicted failures in Buildings C-331 and C-335 have been previously
)
evaluated by DOE in Compliance Plan Issue 36. Based on an assumed 5 percent chance of building collapse j
and a 50 percent chance of being present in the building (i.e., on shift), the injury rate to individual workers i
was estimated at approximately lE-04/yr with a total injury rate risk estimated at 2.6E-03 injuries per year (for an operating staff of 26). This was judged to be acceptable and is no greater than the risk of general office work onsite. Injury from structures may even be higher in the office buildings, although the probability of exposure to HF and UO F would be greater in the process buildings.
2 2 Workers in the afected building's ACR-Similar to workers in the immediate vicinity of a release, personnel in the ACRs for Buildings C-310/C-310-A and C-315 and the "00" process buildings could be exposed to a significant uranium dose and/or HF exposure. In the event of a release, the plant "see and flee" l
policy requires personnel to immediately evacuate the area for their own protection. The method of detection for local workers is (1) visual indication of a " white smoke"(i.e., reaction products of UF. and moisture) or (2) the odor of HF, which is a product of the reaction of UF. and moisture. Also, the process gas leak detection system may afford some indication of a UF. release for personnel in the ACR. Typically during the day, the C-310 ACR has two to four personnel, the C-315 ACR has three to five personnel, and the "00" process building ACRs each have ten to fifteen personnel.
Downwind workers outside the afected buildings - Workers located in downwind areas outside the affected buildings could be exposed to a potentially harmful uranium dose and/or HF exposure. There is potentially a significant number of personnel working outside during normal daytime operation as many as 200 personnel.
The controls for protecting onsite personnel outside the process and withdrawal buildings are (1) detection of the event, (2) minimization of the release by tripping applicable equipment, (3) temporary holdup of the release by the existing building structure, and (4) training of onsite personnel to evacuate areas upon detection of a release by sight or by odor.
l The first control is to detect a seismic event. Seismic activity of the magnitude required to induce i
structural or equipment failures would be feh h personnel. Also, earthquake instrumentation is available l
which would serve to warn the Central Control Facility (CCF) operator of ground accelerations greater than l
0.05g that could result in unacceptable damage and necessitate cascade shutdown. The earthquake i
instrumentation is located in the individual process buildings and includes seismic switch alarms and seismic displacement transmitters. Two seismic switch alarms located in both the C-331 and C-335 process buildings are set to detect and alarm a seismic event with a peak ground acceleration of 0.05g. Seismic displacement transmitters located in the C-333 and C-337 process buildings detect and alarm displacements
..above the capacity of process line expansion joints. The seismic switch alarms and seismic displacement transmitters provide alarra indication in Building C-300 (which has been determined to be capable of withstanding a 0.15g seismic event). Through these measures, personnel would be warned of the potential for a toxic meterhil release as a result of the postulated seismic failures.
I Seismic accelerographs are also located in various plant buildings and alarm in the nearest control room. These instruments provide a post-event indication to the plant shift superintendent of the extent of a seismic event. Accelerographs in Buildings C-300 and C-320 are set to record at 0.005g while the setpoint for those in other locations is 0.0lg.
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I JCO 98-01, Rev.1 Page 10 of 49 i
The second control is for operators to trip the appropriate equipment to reduce pressures and i
minimize the release of UF. Consistent with the discussion in Application SAR Secticn 4.6.1.4 for the process buildings, cell shutdown would be initiated within 2 minutes and cascade shutdown would occur
{
within 8 minutes. Shutdown capability can be provided by the cell remote manual shutdown system. This system manually shuts down tbell operation in case of emergencies. Emergency shutdown of equipment I
is also possible from the C-300 CCF. The shutdown of affected cells, pumps, or buildings will bring equipment to atmospheric pressure or below. Pressure at an interbuilding booster compressor can be reduced, if needed, by tripping the compressor motor or by tripping adjacent enrichment cell compressor motors. Once the pressure has dropped to atmospheric pressure or below, the release of material is effectively terminated for any potential exposure outside the process building.
The third control, building holdup, is provided by the existing building structures. The building structures would reduce potential hazardous material concentrations to downwind receptors outside of the i
building by holdup of a portion of the UF released.
The final control is the training of onsite personnel to evacuate areas upon detection of a release by sight or by odor. The onsite warning / evacuation systems would be used to provide evacuation instructions or notification in the event of an incident. If workers outside of the affected buildings received no other instructicns for action to be taken (i.e., shelter in place or take cover), then the control for these receptors would be to evacuate their areas if a release is detected by sight or by odor.
The release takes five to ten minutes to develop. The estimated exposure time is also on the order of five to ten minutes. Because the plume moves at only 4 m/s, personnel working outside and downwind would have adequate time to take protective actions from a UF. release.
Workers in downwind buildings including Building C-300 - SimiIat to workers Iocated outside in downwind areas, personnel in downwind buildings could be exposed to a potentially harmful uranium dose and/or HF exposure.
The controls for protecting workers in downwind buildings are the same as for workers located outside in downwind areas. As described in Section 5.4.1 of the Emergency Plan, during a UF. release, the incident commander or the crisis manager prescribe protective actions which may include alerting, evacuation and assembly, or sheltering in place. Sheltering in place would afford considerable protection because the expected exposure times are of short duration (5-10 minutes). From the data presented in Table 4 and Application SAR Figure 2.4-1, a significant portion of the plant population (including Building C-300) is located in buildings to the west of Buildings C-310/C-310A and C-315. Approximately 1,300 personnel typically occupy the buildings to the west of Buildings C-310/C-310-A and C-315. Based on SARUP Figure 2.1-3a, the predominant wind directions are to the north and northeast.
Building C-300 is located approximately 270 feet west of Building C-310 and 1550 feet west of Building C-315. The prevailing wind direction for the plant per SARUP Figure 2.3-1 is towards the north and northeast. Easterly winds, directly from Buildings C-315 and C-310 toward Building C-300 occur approximately three percent of the time. C-300 operating personnel would normally be sheltered in Building C-300 by the building structure during the performance of their required actions. However, there are no specific habitability requirements for Building C-300. Building C-300 is the backup facility for the ACRs for the shut down of equipment. Should Building C-300 become uninhabitable, the cascade facilities can be shutdown from alternate locations.
1 JCO 98-01, Rev. I Page1Iof49 3.3.4 Effects on Onsite Personnel of Potential Fire and Inadvertant Criticality Potentialforprocess buildingfire - The evaluation basis seismic event may cause a release of lubricating oil used to service the compressor motors in the process buildings. The tanks and lines connecting to the compressors have been evaluated as part of the equipment evaluations discussed in Section 3.1. The tube oil storage ttnk located on the roof has weak anchors. Failure of this anchorage would not result in complete loss of restraint of the tube oil tanks. Failure of the attached piping is possible, however.
Failure of this piping could allow oil to leak onto the roof or down around the lines that run to the individual compressors. Some of this material could spread out on the operating floor. Failure of equipment and i
nonstructural support components could lead to electrical shorting, creating potential ignition sources. In the absence of power, however, either as a direct result of the event or through operator action to shut down the power in the switchyard, the potential for a ready ignition source is significantly reduced. The only possible source would then be heat from mechanical components. Note that the lube oil is a low-flammability blend with a high flash point and is therefore hard to ignite. Further, the potential for water system breaks is present, and if they do occur, such breaks would also serve to abate any fire potential from failure of the lube oil system. Therefore, a large fire in the process building following a seismic event is unlikely.
Potentialfor inadvertant criticality - With uncontrolled releases of enriched UF., there is the potential for inadvertent criticality in the process buildings and the C-310/C-310-A product withdrawal building. Because tails withdrawal is less than 1.0 wt % 2"U, a criticality in Building C-315 would not be expected. With PGDP's maximum assay limited to 2.75 wt %, considerable dilution and spread of gaseous material would serve to prevent accumulation of material in an unfavorable geomet y. With an unfavorable geometry, a minimum solution depth of a few inches is needed to cause a criticality. Potential accumulation points include the scale pits at the withdrawal station and the lube oil pit in the basement of C-310-A.
Because of the uncertainty regarding other failures, such as siding, other accumulation points may be created.
Water systems are not designed for seismic loads and could present a ready moderator if they failed.
The size of the process buildings, the leakage area between floors, and the barriers between the UF. and the fire suppression systems make criticality a remote possibility unless complete building collapse ensues. In the event of a complete building collapse, significant quantities of water from the RCW and fire suppression systems would be available for mixing with the UF. into a fissile solution and accumulating in unfavorable geometries. In the C-310/C-310-A withdrawal area, the scale carts and scale pits are designed to minimize the amount of water / fissile solution that could enter the scale pit. The scale carts have a skirt which diverts water from the scale pits, and the scale pits are surrounded by a barrier to minimize water flow into the scale pit.
The consequences from an inadvertent criticality would be similar to the consequences described in SARUP Section 4.3.2.6.
The effects associated with a seismically-induced criticality would pertain to individuals in the immediate area. As shown in Figure 2.1-4 of the Application SAR, Building C-331 is the only building within 200 feet of Building C-310/C-310-A. He west edge of Building C-331 isjust within 200 feet of the east edge of Building C-310/C-310A. Table 4 shows that no populations are within 200 feet of Building C-310/C-310A. (The C-331 ACR is located on the eastern side of C-331 and is well beyond 200 feet from Building C-310/C-310A.) One of the primary contributors to risk reduction during a criticality event is l
personnel notification. However, the criticality accident alarm system is not seismically qualified.
f Nevertheless, during a seismically induced UF. release, the event itself acts as an alarm to personnel. As
i JCO 98-01, Rev. I j
Page 12 of 49 stated previously, the site "see and flee" policy requires personnel to immediately evacuate the area of a toxic material release. One of the requirements of the evacuation route taken by personnel is that it is greater than l
200 feet from a building with fissile operations. Therefore, only rescue or emergency response personnel i
would be expected to enter an area after a significant UF. release. To protect these personnel from the effects of both a toxic material release and a criticality, emergency procedures require that appropriate conditions be established for reentry to an evacuated facility. If a criticality has occured prior to entry, the entering personnel would be made aware ofit due to hand held instmmentation. If one were to occur at the 4
time of entry or while in the building, entering personnel would have to be in the immediate area (30-40 feet) to receive a lethal dose.
3.3.5 Effects on Offsite Public of Uranium Dose and/or HF Exposure i
Offsite population estimates are provided in Application SAR Table 2.1-3 and Figure 2.1-7. Per Application SAR Table 2.1-3, there are no permanent residents located within 1 mile from the center of the plant. The nearest permanent resident is located at the east-southeast site boundary.
3.3.5.1 Toxicological Effects of Uranium and HF Exposure According to NUREG-1391", persons exposed to an atmospheric release of UF inhale an aerosol of UO F2 Particulates and HF vapor. The uranium in the uranyl complexes acts as a heavy metal poison to 2
the kidneys, the HF is a strong irritant that can cause acid burns on the skin and in the lining of the respiratory system, and the fluorides, UO F and HF can cause fluoride poisoning if the intakes are large.
2 2 The toxicology of each is well established, but little is known about consequences of mixed or combined exposure.
NUREG-1391 reports the following health effects for a standard man (70 kg) due to uranium intakes:
LD for uranium is an intake of 230 mg;
+
3 Permanent (irreversible) renal injury occurs at intakes of 40 mg or greater; Transient renal injury can occur at intakes between 8.3 and 40 mg; The No Effects Level (NOEL)is 4.3 mg.
For HF exposures, NUREG-1391 reports the following:
The NIOSH IDLH level for HF is 30 ppm (25 mg/m').
Humans are reported as able to tolerate exposure of approximately 137 mg/m' for one minute.
Animal studies suggest that animals exposed to 1,000 ppm HF for exposures of 30 minutes or less did not die, but suffered tissue damage. Animals exposed to 500 ppm for 15 minutes showed signs of"ill health", and 100 hundred parts per million were tolerated for up to 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> with out death but there was a strong irritant effect. The " dangerous toxic load" (DTL) for HF, based on data from the most suspectable ar.imai to HF effects is 2,400,000 ppm -min (1,720,000 (mg/m )2-min). The DTL is an exposure hvel below the threshold of 2
3 death for humans.
JCO 98-01, Rev.1 Page 13 of 49 3.3.5.2 Consequemee Analysis I The uranium intake and HF exposures for unprotected persons under D4 atmospheric conditions are estimated in Table 2 and Figures 1 and 2. Based on these estimated consequences and the anticipated toxicological effects discussed in Section 3.3.5.1:
Permanent (irreversible) kidney damage would be anticipated in unprotected exposed populations,' but no fatalities would be expected in healthy members of this population.
. Permanent renal injury in the unprotected exposed population would be anticipated out to 4 miles. Beyond 4 miles, no irreversible health effects would be expected due to uranium intakes.
De DTL for HF at one mile is computed to be 174,960 (mg/m')2-min which is 10% of the observed threshold of death for the most sensitive animal tested. Some irritation of the skin, eyes, and nasal passages would be anticipated lin the exposed populations. The consequences of the HF exposures lessen with distance but would remain noticeable to.
unprotected persons past 5 miles from the release point.
. As previously stated, after the seismic event occurs, material is released for five to ten minutes. The plume travels at near the ambient wind speed of 9 mph (4 m/s). This provides adequate time for a message to b: broadcast via the public warning system regarding the appropriate protective actions (e.g., sheltering in place) for the offsite public. The required response time to notify the offsite public is similar to cther accidents already di scussed in the Application SAR (e.g., seismic scenario and liquid cylinder drop scenario).
De public warning system is of rugged design and would be expected to alarm.
If sheltering is taken into consideration and a protective factor of 2 is assumed, some permanent renal injury damage due to uranium intakes would be anticipated in populations out to approximately 2 miles. :The response from the HF exposure would be less severe, but would still be noticeable out to approximately 5 miles.
3.4 Risk Assessment The Application SAR and Compliance Plan Issue 36 contain accident scenarios with significant offsite impacts. By comparing the risks associated with the postulated seismic failures evaluated in this JCO
- with accident scenarios previously evaluated, it is evident that the offsite impacts predicted as a result of the postulated seismic failures are commensurate with those previously analyzed.
3.4.1 Appliention SAR Methodology
' A risk assessment of the postulated seismic failures was performed using the methodology presented in Application SAR Section 4.2. The Application SAR defines risk as probability x consequences and uses
- a "binning" technique to apply a risk matrix. In accordance with this methodology, the probability and consequence " bins" for the postulated seismically-induced failures can be assigned as follows:
From Appendix A, the. annual probability of a seismic event which produces UF. releases is approximately lE-02. Using Application SAR Table 4.2-1, the probability rating scale for this event would be medium or "C."
JCO 98-01, Rev. I Page 14 of 49 Based on Table 2 and the consequence analysis described in Section 3.3, the toxicological effects are similar to those for a " medium" hazard level as defined in Application SAR Table 4.2-2.
Using the risk matrix in Application SAR Figure 4.2-1 for a probability level of"C" and a " medium" hazard level, the resultant risk is within the " low" category.
In comparison, Section 4.7.3.2.1 of the Application SAR identifies significant consequences as a result of two postulated accidents:
Seismic event-For the seismic event, the potential health effeca predicted range from " smell" to
" renal injury" type health effects. " Irritation and possible mild health effects" range from approximately 600 ft (183 m) from source initiation to approximately 24,000 ft (7,315 m) downwind. The " renal injury" effect within this band ranges from approximately 3,500 ft (1,067 m) to 15,000 ft (4,572 m) with a bandwidth of approximately 1,000 ft (305 m). " Smell" and "possible irritation" type health effects range from 400 ft (122 m) from source initiation to 23,000 ft (7,010 m) downwind at the periphery of the more serious regions J
described. Total plume width is approximately 4,500 ft (1,372 m) at approximately 25,00011(7,620 m).
Using the methodology in Section 4.2.1, Table 4.9-1 of the Application SAR concludes that the probability of an evaluation basis seismic event is " low" or category "B." The source term identified for subatmospheric operations is 9,150 lb (4,150 kg) UF., and for full power operations is 64,000 lb (29,030 kg)
UF.. The hazard levels associated with these power levels are " low" and " medium," respectively. This corresponds to a risk of" low" for both power levels, which is the same risk level as described for the postulated seismic failures in this JCO.
Liquid cylinder drop - For the liquid cylinder drop scenario," lethality" begins approximately 100 ft (30.5 m) from the cylinder rupture and extends 1,250 ft (381 m) downwind. Immediately beyond the 1,250 ft (381 m), " renal injury" and "possible lethality" effects are found to 2,000 ft (610 m) downwind. From this serious health effect zone, renal injury health effects continue 25,000 ft (7,620 m) downwind. At the periphery," smell" to "possible irritation" type health effects exist. The total plume width with health effects is approximately 4,000 ft (1,220 m) wide.
Again, Table 4.9-1 of the Application SAR identifies the risk for this accident scenario. It states thct the probability is " low" or category "B" and the associated hazard level for the 28,000 lb liquid UF. source term is " medium." This corresponds to a " low" risk level. This is also the same risk level as described for the postulated seismic failures in this JCO.
3.4.2 Compliance Plan Issue 36 Methodology A risk assessment was performed using a methodology similar to that described in the JCO for Compliance Plan Issue 36. Using site-specific wind frequency information from SARUP Table 2.3-3a and by considering the frequency of exposure (conservatively assumed to be equal to the frequency of the seismic event), a conditional frequency of exposure was determined. First, the population data by radius and sector from Application SAR Figure 2.1-7 was multiplied by the frequency of wind blowing in that sector. This is then multiplied by the frequency of the seismic event (1.42E-02). The result is a conditional frequency of exposure by radius and sector.
l l
I JCO 98-01, Rev. !
Page 15 of 49 I
Next, the frequency ofinjury was determined. This was performed by first binning the centerline consequence data into hazard categories (e.g., low renal injury, moderate renal injury, and/or fatality). These categories are consistent with those established in the DOE JCO. Then an assessment of what hazard category applies at each radial distance (i.e., each mile). Note that this does not take into account the reduction in consequences in the crosswind direction, but assumes that the centerline concentration affects
]
100% of the population in that sector. Where the consequences change from one hazard category to the next i
between the radial distances, linear interpolation of the consequences was used to find the downwind distance affected. In this instance, only the population out to that radial distance was used for that hazard category.
The frequency ofinjury for all radial directions was then summed to determine the risk by hazard category. Table 6 shows the incremental and total frequency ofinjury from all directions from the postulated seismic event. A sheltering effectiveness factor of 2 decreases the incremental and total frequency ofinjury.
Table 7 shows the incremental and total frequency ofinjury with a sheltering effectiveness of 2.
The analysis presented in Compliance Plan issue 36 shows that, for all except the boundma case, the structural failure of Buildings C-331 and C-335 results in the potential for only "a mild exposure." The estimated intake for the bounding case of complete building collapse results in 139 mg uranium at one mile distant from the assumed point of release, indicating the potential for irreversible renal injury. This could be potentially life threatening depending upon the age, sex and existing health status of the receptor. The l
prediction ofpotential health effects is further complicated by the presence of an HF exposure estimated to be 38 ppm (29 mg/m') when averaged over one hour. The estimated toxic load for HF,50,460 (mg/m')2 min) is approximately 3 % of the DTL for unprotected persons. Based on the toxic load, fatalities due to HF exposure would not be expected. Some irritation of the skin, eyes and nasal passages should be expected."
The uranium intake of unprotected persons located 5 miles from the point of release is estimated to be 70 mg U, with a one hour average HF exposure of 19 ppm. The Compliance Plan also states that, for both cases, if emergency response is considered and credited with a reduction factor of two due to sheltering in place, then the predicted consequences are reduced to some non-disabling permanent renal injuries with the chance of excess deaths in sensitive population members becoming very remote.
The following assumptions were made for the risk identified in the DOE JCO supporting Compliance Plan Issue 36:
The probability of the offsite population being present was 0.67.
The distribution of wind was only for those for wind speeds of 4 m/s or less.
The frequency of the seismic event is 4E-03/yr.
+
As described above, the reported risk is broken into three hazard levels: 150-200 mg U intake,100-150 mg U intake, and 50-100 mg U intake. Note that no hazard level from 30-50 mg U intake was defined.
Using the assumptions from above, the moderate renal injury level (100-150 mg U intake) was identified as 0.15 injuries /yr. The low renal injury level (50-100 mg U intake) was 0.78 injuries /yr. If a sheltering effectiveness of two is assumed, the risk of moderate renal injury is identified as zero, while the risk oflow renal injury is identified as 0.15 injuries /yr.
As shown in Table 6, the risk described for the seismic failures evaluated in this JCO, for the same hazard levels as reported in the DOE JCO, is 0.07 injuries /yr and 0.70 injuries /yr for moderate and low renal injury levels, respectively. Again, this comparison does not include the range from 30-50 mg U intake since
)
l JCO 98-01. Rev. I j
Page 16 of 49 t
l f
that was not reported in the DOE JCO, nor does it include the 0.67 population scaling factor. Assuming a sheltering effectiveness of two, the risk of moderate renal injury is zero and the risk oflow renal injury is t
l 0.07 injuries /yr. In both instances, the risk is less than the reported values identified in the DOE JCO supporting Compliance Plan issue 36.
Based on Application SAR Table 2.1-3 and Figure 2.1-7, significant offsite population centers surrounding the plant are as follows:
l Approximate l
population Radius Location in these sectors I to 2 miles From E Sector to SSE Sector 300 2 to 3 miles From ENE Sector to SSE Sector 650 3 to 4 miles From E Sector to WSW Sector 1,000 4 to 5 miles NE & ENE Sectors, WSW Sector 4,500 As shown on Table 2, the consequences may exceed 30 mg U out to over four miles. Depending on the wind direction, this could impact the significant population centers in the sectors described above. Note that the consequences will only affect a single sector, and it is not expected that the entire population in any one sector would be affected due to the downwind and cross wind reduction in consequences. Notification of these populations can be made by several means. As necessary, the Emergency Broadcast System radio or TV stations and/or the National Oceanic and Atmospheric Association Weather Radio are notified of releases which could impact the offsite public. All permanent residents within two miles of the plant are given a booklet containing emergency prepardness information every two years.
1
(
4.0 OPERABILITY
SUMMARY
4.1 Availability of Redundant or Backup Equipment There is no equipment available to preclude a natural phenomenon. However, mitigation of a seismically-induced UF. release can be afforded by shutdown capability. Because of the various methods i
l available to shut down equipment in the cascade and withdrawal areas, the backup equipe..ent to the Area Control Rooms (ACRs) are the C-300 Central Control Facility (CCF), the local panels, and the switchyard power controls. Also, as discussed in SARUP Section 4.3.2.5.3, it is anticipated that any cascade releases will be self-limiting in ten minutes since as air continues to flow in through the broken A lines, the l
concentration of UF in the B line drops to essentially zero after ten minutes.
6 4.2 Compensatory Measures Including Administrative Controls l
The following compensatory measures have been implemented to minimize the consequences of the postulated seismic failures:
Failures in Buildings C-331 and C-335 (from JCO for Compliance Plan Issue 36)
(1)
Operations are limited to subatmospheric pressure within the enrichment cascade equipment.
\\
JCO 98-01, Rev.1 Page 17 of 49 i
j (2)
Operations personnel have been instructed on the specific emergency procedures for shutting down the affected enrichment cascade equipment and building ventilation systems following a seismic event.
(3)
To minimize effects on local workers, building access is limited to only those individuals essential to operations, inspections, or those personnel performing any modifications to fix the identified seismic failures.
Failures in Buildings C-310/310-A and C 315 (4)
Only one accumulator in Building C-315 will be used to store liquid UF at a time. The 3
second accumulator has been removed from service through administratively controlling the valving. The standby accumulator will be isolated at all times except in the event that switching condensers / accumulators is necessary. During switching operations, both 1
accumulators can be on-line temporarily to maintain uninterrupted accumulator access while i
flows are being re-established. This valving sequence is required to avoid condenser flooding and unnecessary challenges to the Normetex Pump High Discharge Pressure System. This valving evolution typically lasts for less than one hour and will not be done while actively filling the accumulators. The off-stream accumulator has been caution-tagged and swapping accumulators will only be done with front-line manager approval.
(5)
A crew briefing was performed to provide operators with a heightened awareness of the potential concerns with unrestrained filling of the on-line accumulator in Building C-315, and to emphasize that any necessary maintenance activities are to be expedited so as to minimize the amount of time that liquid UF. is stored in the accumulators.
(6)
The operations staff has issued Long Term Orders for Buildings C-310 and C-315 that specify, that except for surveillance / maintenance activities and during cylinder changeout, an empty cylinder should be kept available at all operable withdrawal positions not currently in use to provide the maximum additional storage capacity for liquid UF. and to minimize the amount of time that material is diverted.a the accumulators.
(7)
To minimize effects on local workers, access to Buildings C-310 and C-315 is limited to only those individuals essential to operations, inspections, or those personnel performing any modifications to fix the identified seismic failures.
(8)
During the period in which operation under this JCO is authorized, the amount of UF. stored in the C-310/310-A and C-315 accumulators will be kept below a nominal 2,000 lb UF.and 5,000 lb UF. respectively during normal operation. In cases of abnormal operation, the levels will not be allowed to exceed 4,000 lb UF. in the C-310/C-310-A accumulators and 10,000 lb UF in the C-315 accumulator. Table 5 shows the conditions and administrative limits and controls for UF inventory in C-310/310-A and C-315 withdrawal areas.
l The amount being stored in the accumulators will be based on best estimates using l
withdrawal rate information since calibrated level indicators or load cells are not available.
The accuracy of this method of monitoring inventory is sufficient to provide confidence that the calculated intakes are not exceeded.
1 I
1 JCO 98-01, Rev. I Page 18 of 49 (9)
In the event that the UF. accumulator limits are reached in either Building C-310/310-A or C-315, the affected withdrawal operations will cease and be placed on recycle or routed to surge drums and assays controlled in accordance with established procedures.
Also, as required by Application SAR Section 6.11, emergency response to a seismic event has been incorporated into plant procedures. This requires that upon detection of a seismic event with the potential to cause a UF release, immediate actions are taken to minimize the consequences.
4.3 Safety Functions and Events Proteeted Against The safety functions of SSCs associated with this issue are (1) to maintain primary containment of UF., (2) to provide shutdown capability (3) to maintain structural integrity (i.e., not collapse) during a seismic event, and (4) to provide evacuation instructions or notification in the event of an incident requiring evacuation or sheltering of the on-site personnel or the off-site public.
The UF. condensers, accumulators, and associated piping and valves in Buildings C-310/310-A and C-315 were designed to safely contain liquid UF. and to provide the means to withdraw UF. from the cascade. During a seismic event, primary containment is assumed to be lost due to predicted failures in the condensers, accumulators, or connecting piping. Also, the enrichment cascade tie-lines are predicted to fail and not perform their required ftmetion of providing UF. containment. The enrichment cascade process piping in buildings C-331 and C-335 is assumed to fail completely. Some process piping failures are predicted in C-333 and C-337, but these failures are expected to be in areas that are below atmospheric pressure, resulting in no significant release.
Earthquake instrumentation is located in individual process buildings and Building C-300 consisting of accelerographs, seismic switch alarms, and seismic displacement transmitters. Two seismic switch alarms located in both the C-331 and C-335 process buildings are set to detect and alarm a seismic event with a peak ground acceleration of 0.05g. Seismic displacement transmitters located in the C-333 and C-337 process buildings detect and alarm displacements above the capacity of process line expansion joints. The seismic switch alarms and seismic displacement transmitters provide alarm indication in Building C-300 (which has been determined to be capable of withstanding a 0.15g seismic event). Through these measures, personnel would be warned of the potential for a toxic material release as a result of the postulated seismic failures.
Seismic accelerographs are also located in various plant buildings and alarm in the nearest control room.
These instmments provide a post-event indication to the plant shift superintendent of the extent of a seismic event. Accelerographs in Buildings C-300 and C-320 are set to record at 0.005g while the setpoint for those in other locations is 0.0lg.
Shutdown capability can be provided by the cell remote manual shutdown system. This system manually shuts down the cell operation in case of emergencies. Emergency shutdown of equipment is also possible from the C-300 CCF. The shutdown of affected cells, pumps, or buildings will bring equipment to atmospheric pressure or below. Pressure at an interbuilding booster compressor can be reduced, if needed, by tripping the compressor motor or by tripping adjacent enrichment cell compressor motors. Once the pressure has dropped to atmospheric pressure or below, the release of material is effectively terminated for any potential exposure outside the process building.
There exists the possibility that Buildings C-331 and C-335 may collapse, thus defeating the ability to maintain structural integrity during a seismic event. However, no other buildings are predicted to undergo structural failure during an evaluation basis earthquake. Maintaining structural integrity of the buildings i
l
t JCO 98-01, Rev.1 Page 19 of 49 l
during a scismic event assists in preserving the primary containment boundary, thus preventing additional
}-
UF. releases.
L L
He public warning system provides warning to the public within an approximate two mile radius of the plant in the event of an incident requiring evacuation or sheltering of the public. Also, the onsite l
warning / evacuation systems provide evacuation instructions or notification in the event of an incident requiring evacuation or sheltering of the plant personnel. Although not seismically qualified, these systems are of rugged design and would be expected to provide warning to onsite personnel and the offsite public.
4.4 Conservatisms and Margias l
The following conservatisms and margins exist in the analyses performed for this JCO:
The likelihood of a seismic event is low. It is further unlikely to postulate a seismic event in conjunction with the assumed amount of material in the liquid withdrawal areas of Buildings C-310/310-A and C-315.
Margins and conservatisms exist in the structural analysis. The analysis conservatively assumes total b'uilding collapse for Buildings C-331 and C-335.
There will be a significant reduction in reaction products available for release due to hold-up.
in the process buildings. However, due to modeling capabilities and time constraints, hold.
'j up has not been accounted for in the analysis of the C-310/C-310-A and C-315 releases.
The atmospheric dispersion modeling does not account for deposition of material as a i
a mechanism to remove material from the plume. As the UF reacts with' atmospheric t
moisture, the UO F will begin to deposit on the ground. The conservatism of the model 2 2 does not account for this phenomenon.
The atmospheric dispersion modeling does not account for terrain effects.' The dispersion i
is simulated as a dense, ground-hovering plume under common meteorological conditions
)
- (neutral atmosphere and moderate to light wind speeds). Such a plume would flow much
-l like water, seeking low spots and being deflected around rises. The plume would tend to pool in low-lying areas, capturing a significant fraction of the plume mass and leading to j
the formation of small local areas of high concentrations. Pooling would tend to occur at downwind distances close to the release point where the plume is most dense and could possibly limit concentrations further downwind. A dense plume would tend to flow into and pool in low areas near the release point, which would essentially act as retaining basias for j
the released UF. and reaction products.. Pooling would act to effectively reduce the uranium concentrations in the plume and extend the releasc time. As a result, uranium exposures would be reduced. Also, the site contains many large buikFngs and the area surrounding the plant site is mix of farmland and forest. These' terrain effects would act to disturb the passage of the contaminated plume'and cause enhanced dilution. However, this analysis conservatively assumes a flat, open, rural environment beyond the building from i-which the release is emitted by modeling the surface roughness as 0.03 m.
i
JCO 98-01, Rev. I Page 20 of 49 l
The atmospheric conditions modeled are not the most favorable that could exist. Therefore, an additional reduction in offsite consequences could exist due to different wind speeds or atmospheric stabilities.
The atmospheric dispersion modeling does not account for changes in wind direction or varying atmospheric stability. This would further reduce the impact of the plume to a receptor by shifting the concentration available for intake.
~ All plumes ("00" buildings, process building tie-lines, C-310/C 310-A, and C-315) were conservatively assumed to originate from the same location (the plant cemer) to maximize the predicted consequences. Accounting for actual building locations would reduce the calculated consequences.
Due to the low population density of the area immediately surrounding the plant, there exists some margin in toxic effects to the general public.
As described in Section 3.3.5.2, if emergency response is considered and credited with a
+
reduction factor of 2 due to sheltering in place, the predicted consequences would be decreased.
Loss of power to compression sources (e.g., Normetex pumps, axial and centerifugal compressors) is anticipated but not modeled. No pressure-driven releases due to an operating compression source would be expected.
4.5 Probability of Needing the Safety Function.
j l
The probability ofineeding the safety functions described in Section 4.3 is determined by the likelihood of an earthquake which will cause seismically induced failures and the likelihood that there exists l
UF.to be released due to those failures. As stated in the accident analysis, the return period for an evaluation j
basis earthquake is 250 years. This corresponds to an annual frequency of 4.0E-03. However, the structural evaluations described in Appendix A concluded that failures could occur as a result of earthquakes with 70-year return periods. This corresponds to an annual frequency of 1.42E-02.
4.6 Probabilistic Risk Analysis or Plant Safety Operational Analysis Results that Determine How Operating the Facility in the Manner Proposed in the JCO Will Impact the Probability of the Design Basis Accident -
No probabilistic risk analysis has been performed. However, the probability of a seismic event is not affected by the controls presented in this JCO.
j i
JCO 98-01. Rev.1 Page 21 of 49
5.0 CONCLUSION
S 1
With the compensatory actions in place, and considering the conservative nature of the analysis, the J
. potential impacts of seismically susceptable failures to onsite personnel and the offsite public are minimized.
The analyzed risk is similar to those previously presented in the Application SAR (" low") and the DOE JCO
(<0.15 injuries /yr). Note that none of the scenarios analyzed in the Application SAR exceed the low risk category. It is apparent that the risk associated with continuing operation in the manner described in this JCO does not increase beyond that currently accepted.
Therefore, the continued operation of PGDP with compensatory measures in place will not present
- an undue risk to public health and safety.
6.0 REFERENCES
4 8
Letter fom James H. Miller (USEC) to Dr. Carl J. Paperiello (NRC), " Certificate Amendment Request -
Update the Application Safety Analysis Report," Letter No. GDP 97-0147, dated August 18,1997.
2 Letter from James H. Miller (USEC) to Dr. Carl J. Paperiello (NRC), " Certificate Amendment Request -
Update the Application Safety Analysis Report," Letter No. GDP 97-0188, dated October 31,1997.
. J 8
DOE /ORO-2026, " Plan for Achieving Compliance with NRC Regulations at the Paducah Gaseous Diffusion Plant," U.S. Department of Energy.
' Letter from Joe W. Parks (DOE) to Mr. George P. Rifakes (USEC), "Paducah and Portsmouth Final Safety Analysis Reports," dated February 14,1997, transmitting a copy of KY/EM-174," Safety Analysis Report, Paducah Gaseous Diffusion Plant, Paducah, Kentucky," Revision R0-A.
5 Letter from Robert C. Pierson (NRC) to Mr. James H. Miller (USEC), "Paducah Certificate Amendment Request - Update of the Application Safety Analysis Report -(TAC No. L32043)," dated February 5, 1908.
Letter from James H. Miller (USEC) to Dr. Carl J. Paperiello (NRC), " Request for Enforcement Discretion," Letter No. GDP 98-0031, dated February 25,1998.
1 Letter from Steven A. Toelle (USEC) to Dr. Carl J. Paperiello (NRC), " Response to NRC Request for Additional Information'(TAC NO. L32043)," Letter No. GDP 98-0019, dated February 27,1998.
Letter from Steven A. Toelle (USEC) to Dr. Carl J. Paperiello (NRC), " Request for Enforcement Discretion - Response to NRC Request for Additional Information (TAC No. L32057)," Letter No. GDP 98-0036, dated February 27,1998, o
Letter from James H. Miller (USEC) to Dr. Carl J. Paperiello (NRC), " Request for Enforcement Discretion - Response to NRC Request for Additional Information," Letter No. GDP 98-0041, dated March 5,1998.
Letter from James H. Miller (USEC) to Dr. Carl J. Paperiello (NRC), " Action Plan for Postulated Seismic Failures in Buildings C-310/310-A and C-315," Letter No. GDP 98-0046, dated March 11,1998.
" Letter from Joe W. Parks (DOE) to Ms. Elizabeth Q. Ten Eyck (NRC)," Seismic Capacity Improvement Justification for Continued Operation at the Paducah Gaseous Diffusion Plant," dated May 17,1996,
JCO 98-01. Rev.1 Pagi22 of 49 transmitting a copy of" Justification for Continued Operation, Temporary Operations of Buildings C-331 and C-335 with Potentially Severe Structural Damage Due to Evaluation Basis Earthquake Loads," May 17,1996.
" K/SUB/93-XJ947, Tech'ical Documentation of HGSYSTEM/UF, Model, The Earth Technology Corporation for Lockheed Martin Energy Systems, January 1996.
" NUREGICR-6481, Review ofModels Usedfor Determining Consequences of UF, Releases, Otilce of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Commission, November 1997.
" White Paper by D. A. Lombardi, Dispersion analysisfor a Seismic Event at the Paducah Gaseous Di[ fusion Plant: Complete Collapse ofthe 00 Buildings, dated April 30,1996.
" NUREG-1391, Chemical Toxicity of Uranium Hexafluoride Compared to Acute Efects ofRadiation.
Division ofRegulatory Application, Office of Nuclear Research, U.S. Nuclear Regulatory Commission, February 1991.
" Patty, F. A. (Ed), Industrial Hygiene and Toxicology, Revised Second Edition, Volume II, Toxicology, Interscience Publishers, New York,1967, pp 841-843.
JCO 98-01. Rev. I i
Page 23 of 49 l
Table 1. Summary of Seismic Source Terms.
UF.
Duration Temp Release Building Function Source (Ib)
(min)
(*F) type C-337 Upper Cascade "000" Tie Line 400 10 290 Vapor C-335 Upper Cascade "00" Building Collapse 13,630' 5
233 Vapor Tie Line 400 10 290 Vapor C-333 Lower Cascade "000" Tie Line 600 10 290 Vapor C-331 Lower Cascade "00" Building Collapse 13,630' 5
233 Vapor Tie Line 600 10 290 Vapor J
i C-310/
Purge Cascade and Condensers (3) -
1,500 5
180 Liquid C-310-A Product Withdrawal Accumulators (2) 4,000 5
isG Liquid C-315 Tails Withdrawal
. Condensers (3) 2,000 5
180 Ligdd :
Accumulator (1) 10,000 -
5 180 LiquM
]
- Reported values are in Ib uranium.
I l
l l
l ll-I l
l
JCO 98-01, Rev. I Page 24 of 49 J
l Table 2. OKsite Consequence Results with D4 Conditions.
I j
. I Mile 2 Miles 3 Miles 4 Miles 5 Miles j
(
Intake HF Intake HF Intake HF Intake HF Intake HF
]
(mg (ppm)
(mg (ppm)
-(mg (ppm)
(mg (ppm)
(mg (ppm)
U)
U)
U)
U)
U)
"W P ume l
45 15 39 11 32' 9'
24'.
7' 16 5
centerime l
Tie-line plume 3
2 1
1 1
0 0
0 0
0 centerline l
C-310/C-310,A 22 18 7
5 4
3 2
1 2
1 plume centerime 43 36 14 11 8
6 5
3 3
2 enteri e Totals 113 71' 61 28 45' 17 31 11 21 8
- Interpolated.
)
I l
l l
l
-l
JCO 98-01, Rev.1 Page 25 of 49 Table 3. Offsite Consequence Results with F1 Conditions.
1 Mile 2 Miles 3 Miles 4 Miles 5 Miles intake HF Intake HF Intake HF Intake HF Intake HF (mg U)
(ppm)
(mg U)
(ppm)
(mg U)
(ppm)
(mg U)
(ppm) -
(mg U)
(ppm)
"00" plume 0
0 0
0 0
0 0
0 0
0 centerline Tie-line plume 4
2 0
2 3
1 2
1 1
0 centerime C-310/C-310,A 53 22
- 23 9
14 6
9 3
6-2 plume centerlme C-315 niume 79 32 32 13 20 8
12 5
.9 3
centerline Totals 136 56 58 24 37 15 23 9
16 5
l
JCO 98-01. Rev. l Page 26 or49 i-l I
Table 4.. Significant Onsite Day-shift Population Estinistes by Building.
Building / Population Building / Population Building / Population l
C-100 Building Complex 349 C-331 l 35 C-600 l 15 C-200 46 C-333 l 49 C-604 13 C-212 and C-212-U l 23 C-333A l
2 C-710 127 C-300 l 21 C-335 34 C-720 Building Complex 428 C-302
! 48 C-337 50 C743 Building Complex 113 C-304 and C-304-T-01 f'L3 C-337A 4
C-744 26 C-310/C-310A l
5 C-360 15 Other Buildings (<10 assigned) 100 C-315 l
4 C-400 52 Misc. subcontractors 220 l
l
i JCO 98-01, Rev.1 Page 27 cf 49 1
l 1
Table 5. Administrative Limits and Controls for Accumulator UF. Inventory for Buildings C-310/310-A and C-315.
Condition Required Action Completion Time Diverting flow to the accumulator 1.
Notify the PSS of accumulator usage.
Immediately in C-310-A or C-315 for greater 2.
Begin tracking of quantities by using than one hour (nominal 2,000 and calculated withdrawal rates, i
5,000 lb UF.respectively at one 3.
PSS initiate high priority actions for timely hour) resolution of unscheduled outages.
4.
Cascade Coordinator takes actions to reduce tails downflow and/or product or tails withdrawalrates to minimize accumulator use as appropriate.
5.
Notify NRC.
Calculated accumulator inventory 1.
Stop diverting flow to the affected immediately -
I reaches 4,000 lb UF. in C-310-A accumulator, or 10,000 lb UF. in C-315.
i I
j
JCO 98-01, Rev. I Page 28 of 49 Table 6. Off-Site Risk Assessment Summary (injuries /yr).
mg U Intake 0-1 miles 1-2 miles 2-3 miles 3-4 miles 4-5 miles Total
>150 0.000 0.000 0.000 0.000 0.000 0.000 100-150 0.000 -
0.067 0.000 0.000 0.000 0.067 50-100 0.000 0.220 0.480 0.000 0.000 0.700 30-50 0.000 0.000 0.254 0.841 0.349 1.444 TotalInjury Rate 0.000 0.287' O.734 0.841 0.349 2.210 l
JCO 98-01. Rev.1 Page 29 of 49 Table 7. OK-Site Risk Assessment Summary with Sheltering (injuries /yr).
mg U Intake 0-1 miles 1-2 miles 2-3 miles 3-4 miles 4-5 miles Total
>150 0.000 0.000 0.000 0.000 0.000 0.000 i.
l 100-150 0.000 0.000 0.000 0.000 0.000 0.000 l
50-100 0 000 0.067 0.000 0.000 0.000 0%7 30-50 0.000 0.220 0.048 0.000 0.000 0.268 TotalInjury Rate 0.000 0.287 0.048 0.000 0.000 0.335 l
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JCO 98-01, Rev.1 Page 34 of 49 Appendix A
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i i
Appendix A - Summary of Seismic Capacities and Postulated Failures
JCO 98-01, Rrv. I Page 35 of 49 Appendix A Table A-1. Natural Phenomena Capacities of Building, Seismic (note 1)
Structure OK>0.15g C-300 OK C-310/310-A 0.1 -+ 0.15 C-315 0.06 - 0.15 i
C-331/335 0.05 C-333/337 0.1 -+ 0.15 C-333-A/337-A 0.1 - 0.15 C-360 OK C-400 0.05 -+ 0.15 C-409 OK C-710 OK C-720 0.12 - 0.15 C-746-Q OK Tie lines 0.12 - 0.15 Notes 1.
Range indicates onset of yield with structural integrity to at least the high value i
Source: SARUP Section 3.15.
I
l JCO 98-01, Rev. I Page 36 of 49 Appendix A Table A-2. Seismic Structural Failures la C-331 and C-335 Peak ground acceleration (g)
Damage summany 0.05 No significant structural damage is expected at or below this level.
- 0.10 Damage occurs between 0.0$g and 0.10g involving failure of approximately 20 foot wide spans which traverse each building in three locations at the roof, mezzanine, and cell floor levels. The affected spans are attached at one column end and supported by a sliding support known as a eccker arm -
' at the other end. Relative displacements exceed the available travel of the rocker arms, allowing the spans to fall. Failures will occur first at the roof, then the mezzanine, and finally at the cell floor. Column anchorage fails, allowing column uplift. Some cross bracing fails. No building collapse is predicted.
0.15 Between 0.10g and 0.15g, permanent deformations and member overloading increase. The probability of building collapse given a 0.15 earthquake is estimated to be 0.05.
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i Source: SARUP Section 3.15.
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