ML20217N477
| ML20217N477 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 08/18/1997 |
| From: | John Miller UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Paperiello C NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| GDP-97-0133, GDP-97-133, TAC-L32027, NUDOCS 9708260188 | |
| Download: ML20217N477 (8) | |
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United St:t:s Entschm:nt Corrottion P Demncracy Center 0903 Rockledge Dnve nethesda, MD ?0817 Tel (30t1664 3200 rar (300 664 3201 l'intnl Staten f.euirlunctit Ostpitatioli JAldES H. MILLER Dir: (301) 664 3309 VICE PRESIDENT, PnooucTioN Far (301) $710279 1
I August 18,1997 1
Dr. Carl J. Paperiello SERIAL: GDP 97-0133 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 Additional Information Request - Cascade Cell Trip Function Requirements
Dear Dr. Paperic!!a:
The purpose of this letter is to provide a response to the NRC's request (TAC. No. L32027) for additional information on the Certificate Amendment Request dealing with cascade cell trip function requirements. This additional information request was provided to USEC in Reference 1 and identifies additional issues associated with the above noted Certificate Amendment Request which require resolution so that final action can be taken on our request.
USEC's response to these additional issues is provided in Enclosure I to this letter. Based upon the additional issues provided in Reference 1, USEC has revised the proposed Technical Safety Requirement (TSR) for the Cascade Cell Trip Function. This revised TSR is provided in Enclosure 2 for your review and approval. As noted in your letter (Reference 1), the staff has questians related to the 5-year frequency for shutting down the operating cells, llowever, you conclude that it is possible to separate this issue from the remainder of the amendment request. USEC is in agreement with separation of the 5 year frequency issue from the remainder of the amendment request. Therefore, USEC requests that NRC proceed with review of our amendment request and defer action on the issue of the 5 year testing frequency at this time.
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C PDft Offices in Paducah. Kentucky Portsmouth. Ohio Washington, DC
Dr., Carl J. Paperiello August 18,1997 GDP 97 0133 Page 2 USlic has reviewed the Enclosure 3 (Significance Detennination) which was previously provided in our Certificate Amendment Request (iteference 2) and has detennined that the additional changes proposed in this letter do not afTect the conclusion of this enclosure.
Any questions related to this subject should be directed to hir. hiark Smith at (301) 564 3244.
There are no new commitments contained in this submittal.
Sincerely, Jar
- 11. hiiller President, Production i
l
Enclosures:
As Stated 1
cc:
NitC Region 111 Ollice NRC Residentinspector PGDP NRC Resident inspector PORTS DOE Regulatory Oversight hianager
Dr. Carl J. Paperiello August 18,1997 ODP 97 0133 Page 3 Referente 1)
NitC Letter from Merri llorn to Mr. James 11. Miller,"Paducah Certificate Amendment Request -
Cascade Cell Trip Function Requirements (TAC L32027)" dated July 18,1997.
2)
USEC Letter ODP 97 0047, Mr. James 11. Miller to Dr. Carl J. Paperiello, "Paducah Gaseous Diffusion Plant (PODP) Docket No. 70-7001 Cenificate Amendment llequest-Cascade Cell Trip Function Requirementa," dated April 14,1997.
GDP 97 0133 Page1of1 Response to AdditionalInformation Request (TAC No. L32027)
Issue:
NRC letter to James 11. Miller from Merri llorn, "Paducah Certificate Amendment Request Cascade Cell Trip Function Requirements (TAC No. L32027), dated July 18,1997, identified additional issues related to the subject amendment request. Specifically, this letter stated:
We have reviewed the information provided on the proposed attemative test and have concluded that the alternative test is acceptable and can be used to demonstrate the functionality of the cell trip mechanism. Use of either test will be acceptable to meet the surveillance requirement. Therefore, USEC can delete NOTE 2 of Surveillance Requirement (SR) 2.4.4.12 8, since the note is no longer necessary. The alternative test does need to be added to the surveillance language; it was added to the Hasis. SR 2.4.4.12 8 should have two surveillance ftmetional tests connected by an "OR" statement.
Additionally, we recommend the removal of NOTE 1. As worded, NOTE 1 implies that the 5 year frequency will not be met. Deletion of this note will enable us to separate the addition of the alternative test to the TSR surveillance from the issue of the 5 year test frequency.
Response
To support separation of the 5 year test frequency from the remainder of the certificate amendment request, USEC has revised the TSR previously submitted for NRC review and approval in USEC Letter ODP 97 0096, dated June 13,1997. Based on your above noted letter, the proposed TSR has been revised to specifically include the attemate test in the surveillance language. Due to inclusion of the alternate test in the surveillance language, NOTE 2, which previously indicated that all planned cell shutdowns shouH be accomplished using the ACR motor stop buttoWmotor breaker pistol grip, has been deleted. Additionally, NOTE 1 has been deleted, so that the issue of the 5 year testing frequency can be separated from this amendment request. The revised TSR, in its entiretv, is provided in Enclosure 2.
- -. - _ -. - ~ _. - - -.
GDl' 97 0133 Page1of4 l
Proposed Cert lRente Amendment Request i
Paducah Gaseous Diffusion Plant j
Letter GDP97 0133 Hemoval/ Insertion Instructions Remove Pages insert Pages l
VOLUME 4 Section 2.4.4 Section 2.4.4 2.4-41 2.4-41 2,4-42 2.4 42 2.4-43 2.4-43 P
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I p..,.
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TSR PGDP PROPOSED April 14.1997 RAC 96C212 (RO)
SECTION 2.4 SPECIFIC TSRS FOR ENRICllMENT CASCADE FACILITIES 2.4.4 GENERAL LIMITING CONIHTIONS FOR OPERATION 2.4.4.12 CASCADE CELL TRIP FUNCTION 1,CO 2.4.4.12 DC control power and air pressure for cell trip of UP stage motors shall be S
APPL >CAHILITY: Modes: Cascade 1 and 2 when stage motors are energized.
ACTIONS:
Condition Required Action Completion Time A. DC voltage < 210 volts A.1 Notify Cascade immediately Coordinator of potential need to utillre alternate means of cell shutdown.
M A.2 Restore DC voltage to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> a 210 volts B. Required action A. not satisfactorily B.1 Shutdown affected 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> accomplished.
cascade cell (s).
M B.2 Verify cell isolation.
C. Air header pressure feeding a group C.1 Notify Cascade immediately of "000" air circuit breakers is less Coordinator of potential tL.n the minimum required to actuate need to utilize alternate those breakers.
means of cell shutdown.
M C.2 Restore air pressure to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> greater than the
- minimum required breaker actuation pressure.
D. Required action C. not satisfactorily D.1 Shutdown affected 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> accomplished, cascade cell (s).
M D.2 Verify cell isolation.
E. Individual battery (cell) parameters E.1 Restore the individual 90 days (other than voltage) for any connected battery (cell) parameters cell are outside limits established in to within limits, surveillance requirements.
TSR 1.6.2.2(d)is not applicable.
2.4-41
~
TSR.PGDP PROPOSED August 18,1997 RAC 97C191 (RO)
SECTION 2.4 SPECIFIC TSRS FOR FNRICllMENT CASCADE FACILITIES 2.4.4 GENERAL LIMITING CONDITIONS FOR OPERATION 2.4.4.12 CASCADE CELL TRIP FUNCTION (continucti)
SURVEILLANCE REQUIREMENTS:
Surveillance Frequency SR 2.4.4.121 Verify DC voltage a 210 volts at the battery DC Daily charger.
SR 2.4.4.12 2 Verify "000" air circuit breaker air header pressure Daily is greater than the minimum required actuation pressure.
SR 2.4.4.12 3 Inspect battery tenninals a.4 racks for ev'ience of Quarterly corrosion and for leakage of electrolyte.
SR 2.4.4.12-4 Check that the specific gravity of the pilot cell is Quarterly a 1.180 corrected to 77" F.
SR 2.4.4.12 5 Verify the battery charger output is > 0 DC amps Quarterly SR 2,4.4.12-6 Visually check the cell electrolyte levels to verify Quarterly j
that tne level is above the low level indication and no more than 0.25 inches above the high indication line.
SR 2. e.4.12 7 Check that the specific gravity of the cells is =1.180 Annually corrected to 77" F.
SR 2.4.4.12-8 Perform functional test of the manual cell shutdown function by either:
a.
Utilizing the ACI' " motor stop" button for "00" Each planned cell shutdown and "000" cells or the motor breaker pistol grip at the local cell panel for C-310 cells at the time of the planned cell shutdown.
OR b,1 Verifying, with the process substation Prior to restart after each transformer secondary breaker open and the planned cell shutdown.
motor breakers clorcd. actuation of the ACR
" motor stop" buttor, for the "00" cells opens the motor breakers.
DR b.2 Verifying, with the 15kV Air Circuit Breaker (ACB) disconnects open, the process motor breakers open, and switch house 15kV ACB closed, actuation of the ACR " motor stop" button for the "000" cells opens the switch house 15kV ACB.
SR 2,4.4.12-9 Verify expected block valve closure and recycle Each planned cell isolation.
valve opening for the planned cell isolation and initiate corrective actions for any unexpected valve
- operation.
2.4-42
TSR PGDP PROPOSED August 18,1997
+
RAC 97Cl91 (RO)
SECTION 2.4 SPECIFIC TSRS FOR ENRICllMENT CASCADE FACILITIES 2.4.4 GENERAL 1 lMITING CONI)lTIONS FOR OPERATION 2.4.4,12 CASCADE CELL TRIP FUNCTION @ontinued)
HASISt The accident analysis presented in SAR chapter 4 discusses numerous cascade cell related scenarios (e.g., 4.3.2.1.2, 4.3.2.1.5, 4.3.2.1.6, 4.3.2.2.2, 4.3.2.3.2., and 4.3.2.4.1) in which operating personnel respond to certain process conditions and alanns by de-energizing the process motors (" tripping the cell"), thus bringing the cell below atmospheric pressure. In order to initiate a cell shutdown, the DC control and trip power circuit must be functional.
Two methods can be used to demonstrate the reliability of the cell trip function. The first, for both the "00" and the "000" cell motors, is at the time of planned cell shutdown. Use of the ACR cell motor stop button for the "00" or "000" cells or the motor breaker pistol grip for the C-310 cells at the time of planned cell shutdown demonstrates cell trip reliability. Note that Planned Cell Shutdown is defined as the process of manually de-energizing the process motors in accordance with approved procedures. Unplanned Cell Shutdown is therefore any automatic trip of the process motors.
The second method of testing depends upon the type of cell, "00" or "000", being tested.
The rellat ility of the cell trip function for *00" cell motors can also be demonstrated using the ACR " motor stop" button with the process substation transformer secondary breaker open and the motor breakers closed. Actua:Ing the ACR push button will open the motor breakers thereby verifying the ACR trip circuit functions correctly.
The reliability of the cell trip function for "000" cell motors can also be demonstrated using the ACR " motor stop" button with the 15kV Air Circuit Breaker (ACB) disconnects open, process motor breakers open, and switch house 15kV ACB closed. Actuating the ACR push button will open the 15 kV ACB thereby verifying the cell trip function.
Planned cell shutdowns must be initiated at the kical control panel for C-310 cells bec, an ACR trip button is not provided for C-310 celk The minimum air pressure required to trip the "J00" breakers varies with the breaker type. The minimum required breaker actuation pressure foc the "000" breaker groups and the bases for those values are identified in SAR Section 3.9.1.3.2.
The alternate means of cell shutdown referred to in required action A.1 are discussed in SAR Table 4.3 2 for the "00" cells and includes alternate means of shutdown from the ACR. For the "000" cells, alternate shutdown is manually accomplished from the switch house if DC power is unavailable; or, from either the switch house, relay house, or C-300, depending on the status of individual breaker air tank pressure.
2.4-43