ML20237F048

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Forwards Request for Amend to Technical Safety Requirements 2.1.3.1.5,correcting Improper Conversions from Pounds (Lbs) to Kilogram (Kgs) & Ensuring That Approved Shipping Weight for 5-inch Cylinders Is Consistent W/Ansi N14.1-1995
ML20237F048
Person / Time
Site: Portsmouth Gaseous Diffusion Plant
Issue date: 08/24/1998
From: Toelle S
UNITED STATES ENRICHMENT CORP. (USEC)
To: Paperiello C
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
Shared Package
ML20237F049 List:
References
GDP-98-0176, GDP-98-176, NUDOCS 9809020020
Download: ML20237F048 (5)


Text

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4 ESEC A Global Energy Company August 24,1998 GDP 98-0176 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 Portsmouth Gaseous Diffusion Plant (PORTS)

Docket No. 70-7002 Certificate Amendment Request - Technical Safety Requirement 2.1.3.15 Receiving Cylinder Fill Weights

Dear Dr. Paperiello:

In accordance with 10 CFR Part 76.45, the United States Enrichment Corporation (USEC or Corporation) hereby submits a request for amendment to the Technical Safety Requirements (TSRs) for the Portsmouth Gaseous Diffusion Plant. This certificate amendment request involves a change to TSR 2.1.3.15 that addresses Receiving Cylinder Fill Weights.

Technical Safety Requirement (TSR) 2.1.3.15 is being changed for the purpose of correcting improper conversions from pounds (Ibs) to kilograms (Kgs) and to ensure that the approved shipping weight for 5-inch cylinders is consistent with ANSI N14.1-1995, Uranium Hexafluoride Packaging for Transport. In all cases, the changes promote a more conservative position in that the cylinder void volume is increased, thereby reducing the potential for hydraulic rupture in the event these cylinders were to be heated in an autoclave. to this letter provides a detailed description andjustification for the proposed changes to TSR 2.1.3.15. Enclosure 3 provides a copy of the revised TSR Ind SAR pages. The TSR page is provided for your review and approval. 'Ihe revised SAR pages have been evaluated in accordance with 10 CFR 76.68. Based on the resuits of the 10 CFR 76.68 evaluation, the enclosed SAR pages do not require prior NRC review and ap1,.v; val and are provided for information only.

The revised SAR pages reflect revisions associated with this Certificate Amendment Request and may not reflect other approved changes to these Si R pages. Enclosure 4 contains the basis for USEC's determination that the proposed change associnted with this certificate amendment request is not significant. Since this Certificate Amendment dequest is not required to support continued plant operations, USEC requests NRC review and approval of this Certificate Amendment Request at your earliest convenience. This amendment should become effective no later than 60 days from

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issuance.

9809020020 980824 PDR ADOCK 07007002' C

PDR 6903 Rockledge Drive, Bethesda. MD 20817-1818

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Telephone 301-564 3200 Fax 301-564-3201 http://www.usec.com f

Offices in Livermore. CA Paducah, IW Portsmouth. OH Washington, DC j

Dr. Carl J. Paperiello

. August 24,1998 GDP 98-0176, Page 2 Any questions related to this subject should be directed to Mark Smith at (301) 564-3244. There are no new/ revised commitments contained in this submittal.

l Sincerely, S. A.

I Steven A.Toelle Nuclear Regulatory Assurance and Policy Manager

Enclosures:

1. Affidavit
2. United States Enrichment Corporation (USEC), Proposed Certificate Amendment Request, Technical Safety Requirement 2.1.3.15 Receiving Cylinder Fill Weights, Detailed Description of Change
3. Proposed Certificate Amendment Request, Portsmouth Gaseous Diffusion Plant, Letter GDP 98-0176, Removal / Insertion Instructions
4. United States Enrichment Corporation (USEC), Proposed Certificate Amendment Request, Technical Safety Requirement 2.1.3.15 Receiving Cylinder Fill Weights, Significance Determination ec: Robert C. Pierson, NRC -

NRC Region III Office NRC Resident Inspector-PGDP NRC Resident Inspector-PORTS Randall M. DeVault, DOE y

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OATII'AND AFFIRMATION 1, Steven A. Toelle, swear and aflirm that I am Manager, Nuclear Regulatory Assurance and '

Policy, of the United States Enrichment Corporation (USEC), that I am authorized by USEC to sign and file with the Nuclear Regulatory Commission this Certificate Amendment Request for the Portsmouth Gaseous Diffusion Plant addressing revision to Technical Safety Requirement 2.1.3.15 I

contained in USEC Letter GDP 98-0176, that I am familiar with the contents thereof, and that the statements made and matters set forth therein are true and correct to the best of my knowledge, information, and belief.'

S. R.

I Steven A.Toelle On this 24th day of August,1998, the manager signing above personally appeared before me, is known by me to be the person whose name is subscribed to within the instrument, and 1

acknowledged that he executed the same for the purposes therein contained.

l In witness hereofI hereunto set my hand and official seal.

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[1xlm La/rie M. Knisley, Notary Public f/

l State of Maryland, Montgomery County My commission expires March 1,2002 l

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GDP 98-0176 Page 1 of 2 United States Enrichment Corporation (USEC)

Proposed Certificate Amendment Request TSR 2.1.3.15 Receiving Cylinder Fill Limits Detailed Description of Change This certificate amendment request changes Technical Safety Requirement (TSR) 2J.3.15 for the purpose of correcting improper conversions from pounds (lbs) to kilograms (kgs) and to ensure that the approved shipping weight for 5-inch cylinders is consistent with ANSI N14.1-1995, Uranium Hexafiuoride Packaging for Transport. The specific changes to the TSR are as follows:

1. Fill limit for 5A & 5B 5-inch cylinders is being changed from 55.671bs(25250 g) to 54.91bs(24902 g).
2. Fill limit for 8A 8-inch cylinders is being changed from 2551bs(155.665 kg) to 2551bs(115.665 kg).
3. Fill limit for 10-inch cylinders is being changed from 370lbs(158.756 kg) to 350lbs(158.756 kg).

Justification of the Change The fill weight for 8-inch cylinders as expressed in kgs is not correct in the TSR. Based on the 8-inch cylinder fill limit values (lbs & kgs) given in both ANSI N 14.1-1995 and USEC-651, Rev. 7 it has been determined that the 155.665 kg value given in the TSR is the result of a typographical error in which two fives were typed verses two ones and as such the correct value is 255 lbs (115.665 kg). No change to the pound value is required. A Dynamic Nuclear Materials Control and Accountability System (DYMCAS) review of all 8-inch Monel cylinders on plantsite indicated that all of the cylinders contained less than the approved fill weight of 255 pounds.

The fill weight value for 10-inch cylinders as expressed in kgs is not correct in the TSR. The kg value presented corresponds to a 350 lb limit instead of the 370 lb limit. A review of the USEC inventory obtained off of DYMCAS for 10-inch cylinders determined that there are no 10-inch cylinders on site that are owned by USEC which contain greater than 350 lbs ofmaterial. Therefore, since the 10-inch cylinders are not addressed in ANSI N-14.1, to be conservative the fill limit for 10-inch cylinders will be reduced to the 350 lb value instead of raising the kg value to equal the 370 lb value. The 10-inch cylinders on plantsite have been declared inoperable pending approval of this CAR.

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GDP 98-0176 Page 2 of 2 United States Enrichment Corporation (USEC)

Proposed Certificate Amendment Request TSR 2.1.3.15 Receiving Cylinder Fill Limits Detailed Description of Change In addition, the review of the TSR fill table as part of developing this request, revealed that the fill limit for SA & 5B cylinders which also can be used to determine shipping weight limits was higher than the value allowed by ANSI N 14.1-1995. Therefore, to ensure that the fill weight values listed do not indirectly contribute to a DOT violation the fill limit for these cylinders will be reduced to the ANSI N 14.1-1995 value of 54.9 lbs (24902 kg).

In all cases, the changes promote a more conservative position in that the minimum cylinder void volume is theoretically increased, thereby reducing the potential for hydraulic rupture in the event these cylinders were to be heated in an autoclave.

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