ML20236Q688
| ML20236Q688 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 07/16/1998 |
| From: | Toelle S UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Knapp M NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| GDP-98-0129, GDP-98-129, TAC-L32066, NUDOCS 9807200409 | |
| Download: ML20236Q688 (5) | |
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h USEC A Global Energy Company July 16,1998 GDP 98-0129 Dr. Malcolm R. Knapp Acting Director, Office of Nuclear Material Safety and Safeguards Attention: Document Control Desk U.S. Nuclear Regi atory Commission d
Washington, D.C. 20555-0001 Paducah Gaseous Diffusion Plant (PGDP)
Docket No. 70-7001 Response to Request for AdditionalInformation - Certificate Amendment Request - Cylinder Crane Upgrades, TSRs 2.1.5.2 and 2.3.5.2 (TAC No. L32066)
Dear Dr. Knapp:
The purpose of this letter is to provide a response to the NRC's request (TAC No. L32066) for additional information on the Certificate Amendment Request (CAR) dealing with revision of Technical Safety Requirements (TSRs) 2.1.5.2 and 2.3.5.2 which specify the C-310, C-315 and C-360 facilities crane design features credited for safety. The request for additional information was provided to USEC in Reference I and identified additional information required by NRC to allow final action to be taken on the subject Certificate Amendment Request. Enclosure 1 to this letter provides USEC's response to the request for additional information.
Should you have any questions related to this subject, please contact Mark Smith at (301) 564-3244.
There are no new commitments contained in this submittal.
Sincerely, f'
S.CL M h-(f
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Steven A.Toelle Nuclear Regulatory Assurance and Policy Manager M
Enclosures:
1.
Response to Request for Additional Information, Cylinder Crane Upgrades, TSRs 2.1.5.2 and 2.3.5.2 cc:
Mr. Robert C. Pierson, NRC NRC Region 111 Office NRC Resident Inspector-PGDP NRC Resident Inspector.. PORTS Mr. Randall M. DeVault, DOE 9007200409 900716 PDR ADOCK 07007001 1
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6903 Rockledge Drive, Bethesda, MD 20817-1818 gg il M Telephone 301-564-3200 Fax 301-564-3201 http://www.usec.com Offices in Livermore, CA Paducah, KY Portsmouth. OH Washington. DC E-
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Dr. Malcolm R. Knapp July 16,1998 >
~ GDP 98-0129, Page 2 i
References L
. 1 Letter from Merri Hom (NRC) to James H. Miller (USEC), Paducah Certificate Amendment i
Request - Cylinder Crane Upgrades, TSRs 2.1.5.2 and 2.3.5.2 (TAC No, L32066), dated May 20,1998.
- 2. -
Letter from James H. Miller (USEC) to Dr. Carl Paperiello (NRC), Certificate Amendment Request - Cylinder Crane Upgrades - TSRs 2.1.5.2 and 2.3.5.2, USEC Letter GDP 98-0086, April 24,1998.
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GDP 98-0129 Page1of3 Response to Request for Additional Information (TAC No. L32066)
Cylinder Crane Upgrades TSRs 2.1.5.2 and 2.3.5.2 Question _1.
What is the reference code or standard to which the new cranes will be designed, operated, and maintained? The proposed revision to the TSRs only commits to having two hoist brakes that meet the requirements of ANSI B30.2,1990 edition. The TSR does not address other portions of the standard. Chapter 1, Appendix A of the Safety Analysis Report only lists portions of the standard whic Paducah satisfies, however, there is no clear commitment to the standard. Since two new cranes are being installed, USEC should commit to the entire standard for the new cranes. If USEC is unwilling to commit to the complete standard for the new cranes, please explain why not, providing an explanation for each section/ subsection to which you are not willing to commit.
Response
For the new C-310 and C-315 cylinder handling cranes, USEC commits to the specific sections of Chapter 2-2, " Inspection, Testing and Maintenance" of ANSI /ASME B30.2 currently specified in SAR Chapter 1, Appendix A, for liquid UF cylinder handling cranes at PGDP.
6 In addition to the current commitment as defined in SAR Chapter 1, Appendix A, the design and operating guidance contained within ANSI /ASME B30.2-1990, " Overhead and Gantry Cranes,"
including Addendum A,1991, has also been considered and applied to the new C-310 and C-315 cylinder handling cranes, with the following exceptions:
1)
Section 2-1.3.l(d): This section requires the installation of wind speed indicators.
PGDP provides this functionality via the C-300 Central Control Facility. When excessive wind conditions exist, cylinder handling operations are terminated.
2)
Section 2-2.2.2 (b2 and b3): These paragraphs relate to techniques used to perform load tests of the cranes. In particular, they require that the test load (125 % of rated load) travel the entire trolley length (b2) and that the bridge travel its entire length with the trolley located at both the extreme right and extreme left positions (b3) At Paducah, this would entail traveling the test load over autoclaves and UF cylinders.
6 The risk of dropping the test load onto safety related equipment or on UF cylinders 6
(causing a UF release) does not warrant the use of this technique. Paducah performs 6
this load test using approved test procedures which include precautions to protect the autoclaves and UF cylinders against such risks.
6 USEC's commitment to ANSI /ASME B30.2, however, remains as specified in SAR Chapter 1,
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Appendix A for the new C-310 and C-315 cylinder handling cranes.
In addition, USEC is unaware of a regulatory requirement to commit to additional industry codes and standards other than the requirements contained in the Plan of Action and Schedule associated with Compliance Plan Issue 45.
1 GDP 98-0129 Page 2 of 3 Response to Request for Additional Information (TAC No. L32066)
Cylinder Crane Upgrades TSRs 2.1.5.2 and 2.3.5.2 I
Ouestion 2 l
The issue of code commitment in relation to the cranes was originally raised during the review of Amendment 2 on the feed facilities crane design features. During the review, the staff asked USEC to explain why the commitment to the standard was limited to specific portions. Although USEC did not provide the explanation, the staff deferred resolution of the issue because of the pending Compliance Plan Issue 45 on codes and standards. This Compliance Plan issue has yet to be resolved, therefore the staff believes it appropriate to reopen the discussion on code commitment for the existing cranes. Please provide an explanation for each section/ subsection fer which USEC is not willing to commit for the existing cranes at the facility.
Response
USEC is unaware of a regulatory requirement to commit to additional industry codes and standards other than the requirements contained in the Plan of Action and Schedule associated with Compliance Plan Issue 45.
Chapter 1, Appendix A of the Safety Analysis Report identifies USEC's commitment to ANSI /ASME B30.2. As identified in Chapter 1, Appendix A, USEC has committed to the Inspection, Testing and Maintenance f,ections of ANSI /ASME B30.2-1990, including Addenda A.
1991.
The Plan of Action and Schedule for Compliance Plan Issue 45 required USEC to review SAR
. Chapter 1, Appendix A and compile a listing of specific sections of the codes, standards and NRC regulatory guidance documents to which PGDP is committed. SAR Chapter 1, Appendix A, was revised to identify USEC's commitments to industry codes and standards and was submitted in l
accordance with the Compliance Plan schedule. SAR Section 3.7.3.1, specifies that equipment is inspected, as required, in accordance with ANSI /ASME B30.2. Therefore, as required by Compliance Plan Issue 45, Chapter 1, Appendix A, was revised to reflect the existing SAR commitment for crane inspections by specifically identifying the applicable portions of ANSI /ASME B30.2, Chapter 2-2, Inspection, Testing and Maintenance, which apply at PGDP.
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GDP 98-0129 Page 3 of 3 Response to Request for Additional Information (TAC No. L32066)
Cylinder Crane Upgrades TSRs 2.1.5.2 and 2.3.5.2 Question 3 As part of the March 10,1997, response for additional information on Amendment 2, USEC informed the staff that it was undertaking an initiative to determine if further application of industry codes and standards at the GDPs was warranted. What is the status of this review?
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Response
The codes and standards initiative, which will determine if further application ofindustry codes and standards at the GDPs is warranted, is ongoing and currently scheduled to be completed by September 1998. Based upon the conclusions of this initiative, USEC will determine if SAR revisions, to include Chapter 1, Appendix A, are required.
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