ML20247B334
| ML20247B334 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant, Paducah Gaseous Diffusion Plant |
| Issue date: | 05/01/1998 |
| 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) |
| References | |
| GDP-98-0088, GDP-98-88, NUDOCS 9805080004 | |
| Download: ML20247B334 (57) | |
Text
NeP d
/1 c CSEC V
A Global Energy Company
/
May 1,1998 GDP 98-0088 l
i Dr. Carl J. Paperiello Director, Office of Nuclear Material Safety and Safeguards Attention: Document Control Desk United States Nuclear Regulatory Commission Washington, DC 20555-0001 Paducah Gaseous Diffusion Plant (PGDP)
Portsmouth Gaseous Diffusion Plant (PORTS)
Docket Nos. 70-7001 & 70-7002 Response to NRC Request for AdditionalInformation (TAC NOS. L32043 & L32044)
I
Dear Dr. Paperiello:
By letter dated February 25,1998 (ce the reference), the U.S. Nuclear Regulatory Commission (NRC) fonvarded to the United States F.irichment Corporation (USEC) various questions on the certificate amendment requests to Update the Application Safety Analysis Reports (SARUP) for the Paducah, Kentucky and Portsmouth, Ohio gaseous diffusion plants. provide USEC's response to question 17 from the referenced NRC letter.
If you have any que 1 ions on USEC's response, please call me at (301) 564-3250 or Steve Routh at (301)564-3251. There are no new commitments identified in this submitta!.
Sincerely, 5.0 RoJ%-f,c Steven A. Toelle Nuclear Regulatory Assurance and Policy Manager
Reference:
Letter from Charles Cox (NRC) to Mr. James H. Miller (USEC), Paducah and
)
Portsmouth Certificate Amendment Requests-Update the Application Safety Analysis I
(TAC Nos. L32043 & L32044), dated February 25,1998.
//
9805000004 9805o1 PDR ADOCK 07007001 C
ppg 6903 Rockledge Drive, Bethesda, MD 20817-1818 Telephone 301-564-3200 Fax 301-564-3201 http://www.usec.com O& ices in Livermore, CA Paducah, KY Porumouth, OH Washington, DC WAY o 4192 m
I 1
l 1
Dr. Carl J. Paperiello May 1,1998 i
GDP 98-0088, Page 2
Enclosure:
Response to NRC Request for Additional Information Concerning Paducah and Portsmouth Safety Analysis Report Update (TAC Nos. L32043 & L32044), United States Enrichment Corporation, Paducah and Portsmouth Gaseous Diffusion Plants, Docket Nos. 70-7001 and 70-7002, Responw to Question 17 i
l cc: Mr. Robert C. Pierson, NRC NRC RegionIII NRC Resident Inspector-PGDP NRC ResidentInspector-PORTS Mr. Randall M. DeVault, DOE l
Enclosure to GDP 98-0088 (55 pages total)
Response to NRC Request for Additional Information Concerning Paducah & Portsmouth Safety Analysis Report Update (TAC Nos. L32043 & L32044)
United States Enrichment Corporation Paducah and Portsmouth Gaseous Diffusion Plants Docket Nos. 70-7001 and 70-7002 4
Response to Question 17
)
SARUP Q&R 'rGDP/ PORTS May 1,1998 SARUPQ17 PGDP/ PORTS - General Comment l
TSRs - many Certification TSR limits (safety limits, limiting control setting, limiting condition for operation, surveillance) have been deleted in the SARUP purportedly based on the new accident analysis. Specifically identify each TSR that was deleted in the PORTS and Paducah SARUP from USEC-01 and USEC-02 and the basis for deleting them. (Question 4 and 5 are examples of questions arising from such deletions without adequate bases provided).
Response
Tables 1 and 2 provide " maps" between the existing TSRs and the SARUP TSRs for PGDP and PORTS, respectively. Where an existing TSR Safety Limit, Limiting '.ondition for Operation, Surveillance Requirement, or Design Feature is not included in the SARUP TSRs, a specific basis is provided.
As indicated in Tables 1 and 2, current TSRs that involve only administrative controls or requirements and not controls on active SSCs were typically not incorporated into the SARUP TSRs. Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO (see SARUP Section 4.2.3).
l However, many of these administrative controls are identified in other sections of the SAR and certification application, and, thus, are required to be implemented through written procedures.
SARUP Revision:
1 No revisions required.
l Page 1 of 54
SARUP Q&R - PGDP/ PORTS May 1,1998 Table 1. " Map" Between Existag PGDP TSRs and SARUP TSRs USEC-01 TSR Subject Location of TSR in SARUP or Basis for Not Including Section System / Control in SARUP TSRs 1.0 Definitions Addressed in SARUP TSR Section 1.0.
2.1 Specific TSRs for Addressed in SARUP TSR Section 2.6.
Toll Transfer and Sampling Facility (C-360) 2.1.1 Operational Modes Addressed in SARUP TSR Section 2.6.1.
)
2.1.2.1 Autoclave Shell This requirement is a passive design feature with no special Pressure surveillance requirement (the autoclave pressure decay test is (Safety Limit) included in SARUP TSR 2.6.3.1-2). Passive design features were only included in the SARUP TSRs if a specific surveillance requirement was applicable (i.e., it was not considered appropriate to include a design feature in the SARUP TSRs if there was no accompanying surveillance requirement).
Furthermore, according to the limiting accident scenario for cylinder failure inside an autoclave (SARUP Section 4.3.2.2.14),
1 this control does not prevent an EBE which could exceed the offsite EGs (reference SARUP Section 4.3.1.1.4, fourth.
i paragraph, last sentence: Only controls selected to prevent an EBE, which could exceed the offsite EGs were considered for establishing a Safety Limit or Limiting Control Setting).
Therefore, this existing safety limit was not included in the SARUP TSRs.
2.1.2.2 UF. Cylinder Addressed in SARUP TSR Section 2.6.2.1.
Temperature (Safety Limit) 2.1.3.1 Autoclave High LCO and SRs are addressed in SARUP TSR Section 2.6.3.1.
Pressure Isolation System Page 2 of 54
SARUP Q&R - PGDP/ PORTS May 1,1998 Table 1. " Map" Between Existing PGDP TSRs and SARUP TSRs USEC-01 TSR Subject Location of TSR in SARUP or Basis for Not including Section System / Control in SARUP TSRs 2.1.3.2 Autoclave Pressure SARUP Section 4.3.2.2.14 (which provides for the worst case Relief System pressure rise inside the autoclave) concluded that the pressure inside the autoclave would not reach the maximum allowable l
working pressure (MAWP) for any of the autoclaves for any of the autoclase/ cylinder configurations. The auioclave pressure relief system was not considered an essential control in this L
analysis and, therefore, this system does not qualify under the SARUP TSR selection criteria (SARUP Section 4.2.3) and is not included as a SARUP TSR LCO.
2.1.3.3 Autoclave Steam LCO and SRs are addressed in SARUP TSR Section 2.6.3.7.
Pressure Control System 2.1.4.1 UF. Release LCO and SRs are addressed in SARUP TSR Section 2.6.3.6.
Detection System -
Laboratory (Zone 1) 2.1.4.2a UF Release LCO and SRs are addressed in SARUP TSR Section 2.6.3.6.
6 Detection System-Basement Transfer Room (a portion of Zone 4) 2.1.4.2b UF Release Zone 1 and 4 of this system provide automatic isolation upon a 6
Detection System -
relcase of UF. SARUP Section 4.3.2.2 docs not rely on the 6
Autoclave Heated Zones 5-8 smoke detectors for detection of a UF releases; 6
Housings (Zones 5-8) rather, facility operators are relied upon to detect and isolate the release. Therefore, this system was not identified as an essential control, does not meet the SARUP TSR selection criteria, and was not included as a SARUP TSR LCO.
2.1.4.3 Autoclave Water LCO and SRs are addressed in SARUP TSR Section 2.6.3.4.
Inventory Corarol System 2.1.4.4 Cylinder Scale Cart This TSR is an administrative control that was not identified as Movement an essential control in the SARUP analyses and does not meet Me Prevention System SARUP TSR LCO selection criteria. Therefore, this TSR was not included as a SARUP TSR LCO.
Page 3 of 54 l
SARUP Q&R - PGDP/ PORTS May 1,1998 Table 1. " Map" Between Existing PGDP TSRs and SARUP TSRs USEC-01 TSR Subject Location of TSR in SARUP or Basis for Not Including Section System / Control in SARUP TSRs 2.1.4.5 Criticality Accident LCO and SRs are addressed in SARUP TSR Section 2.6.3.5.
Alarm System 2.1.4.6 Cylinder Heating -
This TSR is an administrative control and does not satisfy the Cylinder SARUP TSR LCO selection criteria. The weight and void Accountability volume requirements, as well as the heating allowances, under Weight this TSR are included in SARUP TSR 1.2.7 and in the Basis statements for SARUP TSRs 2.6.2.1,2.6.3.7 and 2.6.4.1. For 2
these reasons, this TSR was not included as a " stand-alone" LCO in the SARUP TSRs.
2.1.4.7 Cylinder Heating -
This TSR is an administrative control and does not meet the List of Cylinders Not SARUP TSR LCO selection criteria. The specific cylinders that to be Heated can be heated are delineated in SARUP TSR 1.2.7. For these reasons, this TSR was not included as a " stand-alone" LCO in the SARUP TSRs.
2.1.4.8 Cylinder Heating and This TSR is an administrative control and does not meet the Filling: Cylinder SARUP TSR LCO selection criteria. Therefore, this TSR was Pre-Heat and Pre-fill not included as a SARUP TSR LCO. This control is identified Inspection in SARUP Section 4.3.2.2.15. SARUP TSR 3.9.1.b (revised from the existing TSR 3.9.1.b) requires implementation of SAR Chapter 4 administrative controls through written procedures.
Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO.
2.1.4.9 Cylinder Heating -
This TSR is an administrative control and does not meet the Cylinder Cold SARUP TSR LCO selection criteria. Therefore, this TSR was Pressure not included as a SARUP TSR LCO. This control is identified in SARUP Section 4.3.2.2.7. SARUP TSR 3.9.1.b (revised from ie existing TSR 3.9.1.b) requires implementation of SAR Chapter 4 administrative controls through written procedures.
Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO.
I I
Page 4 of 54 l
SARUP Q&R - PGDP/ PORTS May 1,1998 Table 1. " Map" Between Existing PGDP TSRs and SARUP TSRs USEC-01 TSR Subject Location of TSR in SARUP or Basis for Not Including Section System / Control in SARUP TSRs I
2.1.4.10 Cylinder Filling -
This TSR is an administrative control and does not meet the -
Pre-fill Weight SARUP TSR LCO selection criteria. Therefore, this TSR was not included as a SARUP TSR LCO. This control is identified in SARUP Section 4.3.2.2.10. SARUP TSR 3.9.1.b (revised from the existing TSR 3.9.1.b) requires implementation of SAR Chapter 4 administrative controls through written procedures.
Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO.
2.1.4.11 Cylinder Filling -
This TSR is an administrative control that was not identifed as an Limiting Number of essential control in the SARUP analyses and does not meet the Autoclaves in Mode SARUP TSR LCO selection criteria. Therefore, this TSR was 6B not included as a SARUP TSR LCO. Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO.
2.1.4.12 Cylinder Filling -
This TSR is an administrative control and does not meet the Cylinder Fill Limit SARUP TSR LCO selection criteria. Therefore, this TSR was not included as a SARUP TSR LCO. The cylinder is only a concern if it is heated following overfilling, which is controlled by cylinder category. This centrol is identified in SARUP Section 4.3.2.2.2. SARUP TSR 3.9.1.b (revised from the existing TSR 3.9.1.b) requires implementation of SAR Chapter 4 administrative controls through written procedures.
Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO Cylinder void volume requirements are included in the SARUP TSR 1.2.7 and in the Basis statements for SARUP TSRs 2.6.2.1 and 2.6.3.7.
2.1.4.13 Cylinder Handling -
This TSR is an administrative control and does not meet the Cylinder Rolling and SARUP TSR LCO selection criteria. Therefore, this TSR was Tilting not included as a SARUP TSR LCO. This control is identified in SARUP Section 4.3.2.2.10. SARUP TSR 3.9.1.b (revised from the existing TSR 3.9.1.b) requires implementation of SAR Chapter 4 ada inistrative controls through written procedures.
Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO.
l Page 5 of 54
l SARUP Q&R - PGDP/ PORTS May 1,1998 l
Table 1. " Map" Between Existing PGDP TSRs and SARUP TSRs USEC-01 TSR Subject Location of TSR in SARUP or Basis for Not Including L
Section System / Control in SARUP TSRs l
2.1.4.14 Cylinder Handling -
This TSR is an administrative control and does not meet the Cylinder
'RUP TSR LCO selection criteria. Therefore, this TSR was Disconnection riot meluded as a SARUP TSR LCO. The requirement to purge and evacuate UF. lines prior to opening the primary system is a
L identified in SARUR Section 4.3.2.2.10. SARUP TSR 3.9.1.b (revised from the existing TSR 3.9.1.b) requires implementation of SAR Chapter 4 administrative controls through written procedures. Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO.
2.1.4.15 Cylinder Handling -
This TSR is an administrative control that was not identified as Cylinder Valve an essential control in the SARUP analyses and does not meet the Covers SARUP TSR LCO selection criteria. Therefore, this TSR was not included as a SARUP TSR LCO. Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO.
2.1.4.16 Cylinder Handling -
This TSR is an administrative control and does not meet the Approved Cranes for SARUP TSR LCO selection criteria. Therefore, this TSR was Liquid Cylinders not included as a SARUP TSR LCO. This control is identified in SARUP Section 4.3.2.2.15. SARUP TSR 3.9.1.b (revised from the existing TSR 3,9.1.b) requires implementation of SAR Chapter 4 administrative controls through written procedures.
Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO.
2.1.4.17 Cylinder Lifting This TSR is an administrative control and does not meet the Restriction SARUP TSR LCO selection criteria. Therefore, this TSR was not included as a SARUP TSR LCO. This control is identified in SARUP Section 4.3.2.2.15. SARUP TSR 3.9.1.b (revised from the existing TSR 3.9.1.b) requires implementation of SAR Chapter 4 administrative controls through written procedures.
Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO.
2.1.4.18 Heating UF, Plugs This TSR is an administrative control that was not identified as an essential control in the SARUP analyses and does not meet the SARUP TSR LCO selection criteria. Therefore, this TSR was not included as a SARUP TSR LCO. Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO.
Page 6 of 54
i f
i SARUP Q&R - PGDP/ PORTS May 1,1998 Table 1. " Map" Between Existing PGDP TSRs and SARUP TSRs USEC TSR Subject Location of TSR in SARUP or Basis for Not including Section System / Control in SARUP TSRs 2.1.4.19 Cylinder Heating -
As described in SARUP Table 4.2-11, the event, " Plugged i
Valve Clarity Valve / Pigtail" was analyzed by SARUP as having only limited consequences. This conclusion is based on the use of administrative controls that were not identified as essential controls in the SARUP analyses and do not meet the SARUP l
TSR LCO selection criteria. Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO.
2.1.4.20 Cylinder Heating -
As described in SARUP Table 4.2-11, the events, " Plugged Valve Valve / Pigtail" and ' Plugged / Blocked Process Line" was Clarity / Heating analyzed as havir'; only limited consequences. This conclusion Cycle In'erruptions is based on the use of administrative controls that were not identified as essential controls in the SARUP analyses and do not meet the SARUP TSR LCO selection criteria. Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO.
2.1.4.21 Scales This TSR is an administrative control that was not identified as an essential control in the SARUP analyses and does not meet the SARUP TSR LCO selection criteria. Therefore, this TSR was not included as a SARUP TSR LCO. Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO.
'2.1.5.1 UP. Cylinder Slings These d-sign feature requirements and SRs are addressed in and Lifting Fixtures SARUP TSR Section 2.6.4.2.
(Design Feature) 2.1.5.2 Crane Design Design feature requirements are addressed in SARUP TSR (Design Feature)
Section 2.6.4.2. This SARUP TSR and SARUP TSR Section 1.6.3.1, require this system to be operable prior to lifting any liquid UF cylinders. This system does not meet the SARUP 6
TSR selection criteria for an LCO. SRs in the existing TSRs that require performance of OSHA inspections (SRs 2.1.5.2-1, -2 and j
-3) were not included as SARUP TSR surveillance because they I
are not credited in the SARUP analyses. Rather, the Basis j
statement in the SARUP TSR requires that the cranes must meet the applicable codes and standards described in SAR Chapter 1, Appendix A.
Page 7 of 54 J
\\
l SARUP Q&R - PGDP/ PORTS May 1,1998 Table 1. " Map" Between Existing PGDP TSRs and SARUP TSRs USEC-01 TSR Subject Location of TSR in SARUP or Basis for Not Including
.)
Section System / Control in SARUP TSRs l
1 2.1.5.3 UF. Cylinders Design feature requirements are included in SARUP TSR Section (Design Feature) 2.6.4.1. Existing SR 2.1.5.3-1 that requires cylinder inspections prior to filling or heating is not included in SARUP TSR 2.6.4.1.
Instead, a statement was added to the Basis that requires cylind:rs containing liquid UF to meet the ANSI N14.1 requirements described in SAR Chapter 1, Appendix A. This addition to the Basis is more accurate and broader in scope.
Cylinder design requirements are described in SARUP Section 3.15.6.1.
2.1.5.4 UF Cylinder Pigtails This requirement is a passive design feature with no ongoing 6
(Design Feature) surveillance requirement. Passive design features were only included in the SARUP TSRs if a specific surveillance requirement was applicable (i.e., it was not considered appropriate to include a Design feature in the SARUP TSRs if there was no accompanying surveillance requirement).
Therefore, this TSR is not included as a SARUP TSR LCO or design feature. The requirement for initial pigtail inspections is addressed in SARUP Sections 4.3.2.2.10 and 4.3.2.2.11, as an administrative control. SARUP TSR 3.9.1.b (revised from the existing TSR 3.9.1.b) requires implementation of SAR Chapter 4 administrative controls through written procedures. Pigtail design requirements are described in SARUP Section 3.15.5.4.
2.1.5.5 Scale Cart Design Design feature requirements are included in SARUP TSR Section (Design Feature) 2.6.4.5.
2.1.5.6 Hydraulic Lifts - Lift Design feature requirements are included in SARUP TSR Section Capacity 2.6.4.4.
(Design Feature) 2.1.5.7 Hydraulic Lifts -
Design feature requirements included in SARUP TSR Section Interlock With Scale 2.6.4.4.
Cart Air Supply (Design Feature)
Page 8 of 54
~
SARUP Q&R - PGDP/ PORTS May 1,1998 Table 1. " Map" Between N=2 PGDP TSRs and SARUP TSRs
- w USEC4)1 TSR Subject Location of TSR in SARUP or Basis for Not Including a
Section System / Control in SARUP TSRs 2.1.5.8 Hydraulic Lifts - Rail This requirement is a passive design feature with no ongoing Stops surveillance requirement. Passive design features were only (Design Feature) included in the SARUP TSRs if a specific surveillance requirement was applicable (i.e., it was not considered apropriate to include a design feature in the SARUP TSRs if there was no accompanying surveillance requirement).
l Therefore, this TSR was not included as a SARUP TSR LCO.
1 l
This design feature is identified in SARUP Section 4.3.2.2.4.
2.2 Specific TSRs for Addressed in SARUP TSR Section 2.2.
UF Facilities 6
(C-333-A and C-337-A) 2.2.1 Operational Alodes Addressed in SARUP TSR Section 2.2.1.
2.2.2.1 Autoclave Shell This requirement is a passive design feature with no special Pressure (Safety surveillance requirement (the autoclave pressure decay test is Limit) conducted under SARUP TSR 2.2.3.1-2). Passive design features were only included in the SARUP TSRs if a specific surveillance requirement was applicable (i.e., it was not considered appropriate to include a design feature in the SARUP TSRs if there was no accompanying SR). Furthermore, according to the limiting accident scenario for cylinder failure inside an autoclave (SARUP Section 4.3.2.2.14), this control does not prevent an EBE which could exceed the offsite EGs (Reference SARUP Section 4.3.1.1.4, fourth paragraph, last sentence: Only controls selected to prevent an EBE, which could exceed the off-site EGs were considered fcr establishing a Safety Limit or Limiting Control Setting). Therefore, this existing safety limit was not included in the SARUP TSRs.
2.2.2.2 UF Cylinder Addressed in SARUP TSR Section 2.2.2.1. No surveillance 6
Temperature (Safety requirement is applicable.
Limit) 2.2.3.1 Autoclave High LCO and SRs are addressed in SARUP TSR Section 2.2.3.1.
Pressure Isolation System I
1 Page 9 of 54 j
l m
SARUP Q&R - PGDP/ PORTS May 1,1998 i
Table 1. " Map" Between Fridi== NGDP TSRs and SARUP TSRs USEC-01 TSR Subject Location of TSR in SARUP or Basis for Not Including Section System / Control in SARUP TSRs 2.2.3.2 Autoclave Pressure SARUP Section 4.3.2.2.14 (which grovides for the worst case l
Relief System pressure rise inside the autoclave) concluded that the pressure inside the autoclave would not reach the maximum allowable 1
.I working pressure (MAWP) for any of the autoclaves for any of the autoclave / cylinder configurations. The autoclave pressure relief system was not considered an essential control in this analysis and, therefore, this system does not qualify under the SARUP TSR selection criteria (SARUP Section 4.2.3) and was not included as a SARUP TSR LCO.
2.2.3.3 Autoclave Steam LCO and SRs are addressed in SARUP TSR Section 2.2.3.7.
l Pressure Control l
System 2.2.4.1 UF. Release SARUP Section 4.3.2.2 does not rely on autoclave smoke Detection System -
detectors for detection of a UF. releases outside of the autoclave; Autoclave Heated rather, facility operators are relied upon to detect and isolate the Housings, Piping release. Therefore, this system was not identified as an essential Trench, Jet Station, control, does not meet the SARUP TSR selection criteria, and West Walt Detectors was not included as a SARUP TSR LCO. A description of this (C-337-A ONLY) system is provided in SARUP Section 3.15.7.3.
2.2.4.2 Autoclave Water LCO and SRs are addressed in SARUP TSR Section 2.2.3.5.
Inventory Control l
System 2.2.4.3 Criticality Accident LCO and SRs are addressed in SARUP TSR Section 2.2.3.6.
Alarm System 2.2.4.4 Cylinder Heating -
This TSR is an administrative control and does not satisfy the Cylinder SARUP TSR LCO selection criteria. The weight and void Accountability volume requirements, as well as the heating allowances, under Weight this TSR are included in SARUP TSR 1.2.7 and in the Basis statements for SARUP TSRs 2.2.2.1 and 2.2.3.7. For these L
reasons, this TSR was not included as a " stand-alone" LCO in I
the SARUP TSRs. Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO.
1 l
Page 10 of 54
SARUP Q&R - PGDP/ PORTS May 1,1998 Table 1. " Map" Between Existing PGDP TSRs and SARUP TSRs l
USEC-01
~
TSR Subject Location of TSR in SARUP or Basis for Not Including Section System / Control in SARUP TSRs 2.2.4.5 Cylinder Heating -
This TSR is an administrative control and does not meet the j
List of Cylinders Not SARUP TSR LCO selection criteria. The specific cylinders that 1
to be Heated can be heated is delineated in SARUP TSR 1.2.7. For these
)
reasons, this TSR was not included as a " stand-alone" LCO in j
the SARUP TSRs. Administrative controls do not normally meet
?
the SARUP TSR selection criteria for an LCO.
2.2.4.6 Cylinder Heating -
This TSR is an administrative control and does not meet the 4
Cylinder Pre-Heat SARUP TSR LCO selection criteria. Therefore, this TSR was Inspection not included as a SARUP TSR LCO. This control is identified in SARUP Section 4.3.2.2.15. SARUP TSR 3.9.1.b (revised from the existing TSR 3.9.1.b) requires implementation of SAR Chapter 4 administrative controls through written procedures.
1 Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO.
2.2.4.7 Cylinder Heating -
This TSR is an administrative control and does not meet the Cylinder Cold SARUP TSR LCO selection criteria. Therefore, this TSR was Pressure not included as a SARUP TSR LCO. This requirement is identified in SARUP Section 4.3.2.2.7. SARUP TSR 3.9.1.b (revised from the existing TSR 3.9.1.b) requires implementation of SAR Chapter 4 administrative controls through written procedures. Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO.
l 2.2.4.8 Cylinder Handling -
This TSR is an administrative control and does not meet the Cylinder SARUP TSR LCO selection criteria. Therefore, this TSR was Disconnection not included as a SARUP TSR LCO. The requirement to purge and evacuate UF lines prior to opening the primary system is 6
identified in SARUP Section 4.3.2.2.10. SARUP TSR 3.9.1.b (revised from the existing TSR 3.9.1.b) requires implementatmn of SAR Chapter 4 administrative controls through written procedures. Administrative controls do not normally meet the j
SARUP TSR selection criteria for an LCO.
2.2.4.9 Heating UF Plugs This TSR is an administrative control that was not identified as 6
an essential control in the SARUP analyses and does not meet the j
SARUP TSR LCO selection criteria. Therefore, this TSR was
]
not included as a SARUP TSR LCO. Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO.
Page 11 of 54 a
SARUP Q&R - PGDP/ PORTS May 1,1998 Table 1. " Map" Between Existing PGDP TSRs and SARUP TSRs USEC-01 TSR Subject Location of TSR in SARUP or Basis for Not Including Section System / Control in SARUP TSRs 2.2.4.10 Cylinder Heating -
As described in SARUP Table 4.2-11, the event, " Plugged Valve Clarity Valve / Pigtail" was analyzed by SARUP as having only limited -
consequences. This conclusion is based on the use of administrative controls that were not identified as essential controls in the SARUP analyses and do not meet the SARUP TSR LCO selcction criteria. Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO.
2.2.4.11 Cylinder Heating -
As described in SARUP Table 4.2-11, the event, " Plugged Valve Valve / Pigtail" was analyzed by SARUP as having only limited Clarity / Heating consequences. This conclusion is based on the use of Cycle Interruptions administrative controls that were not identified as essential controls in the SARUP analyses and do not meet the SARUP TSR LCO selection criteria. Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO.
2.2.4.12 Scales This TSR is an administrative control that was not identified in the SARUP analyses and does not meet the SARUP TSR LCO
)
selection criteria. Therefore, this TSR was not included as a
{
SARUP TSR LCO. Administrative controls do not normally j
meet the SARUP TSR selection criteria for an LCO.
2.2.5.1 UF Cylinder Slings These design feature requirements and SRs are addressed in 6
and Lifting Fixtures SARUP TSR Section 2.2.4.1.
(Design Feature) 2.2.5.2 Crane Design Design feature requirements are addressed in SARUP TSR (Design Feature) 2.2.4.1. This SARUP TSR and SARUP TSR 1.6.3.1, require i
this system to be operable prior to lifting any liquid UF.
cylinders. This system does not meet the SARUP TSR selection criteria for an LCO. SRs in the existing TSRs that require performance of OSHA inspections (SRs 2.2.5.2-1, -2 and -3) were not included as SARUP TSR surveillance because they are l
not credited in the SARUP analyses. Rather, the Basis statement in the SARUP TSR requires that the cranes must meet the applicable codes and standards described in SAR Chapter 1, Appendix A.
i i
Page 12 of 54 i
SARUP Q&R - PGDP/ PORTS May 1,1998 Table 1. " Map" Between Existing PGDP TSRs and SARUP TSRs USEC-01 TSR Subject Location of TSR in SARUP or Basis for Not Including Section System / Control in SARUP TSRs 2.2.5.3 UF Cylinders The control provided by cylinders during heating is a passive 6
(Design Feature) design feature with no ongoing surveillance requirement.
Passive design features were only included in the TSRs if a specific surveillance requirement was applicable (i.e., it was not considered appropriate to include a design feature in the SARUP TSRs if there was no accompanying surveillance requirement).
Therefore, this TSR is not included as a SARUP TSR LCO.
This control is identified in SARUP Sections 4.3.2.2.2,.4,.6,
.7,.9,.10, and.14.
SARUP TSR 3.9.1.b (revised from the existing TSR 3.9.1.b) requires implementation of SAR Chapter 4 administrative controls through written procedures. SARUP TSRs 2.6.4.1,2.3.4.1, or 2.5.4.1 identify additional requirements prior to filling. Cylinder design requirements are described in SARUP Section 3.15.6.1.
2.2.5 UF Cylinder Pigtails This requirement is a passive design feature with no ongoing 6
(Design Feature) surveillance requirement. Passive design features were only included in the TSRs if a specific surveillance requirement was applicable (i.e., it was not considered appropriate to include a design feature in the SARUP TSRs if there was no accompanying surveillance requirement). Therefore, this TSR is not included as a SARUP TSR LCO or design feature. The requirement for initial pigtail inspections is addressed in SARUP Sections 4.3.2.2.10 and 4.3.2.2.11, as an administrative control.
SARUP TSR 3.9.1.b (revised from the existing TSR 3.9.1.b) requires implementation of SAR Chapter 4 administrative controls through written procedures. Pigtail design requirements are described in SARUP Section 3.15.5.4.
2.3 Specific TSRs for Addressed in SARUP TSR Sections 2.3 and 2.5.
Product and Tails Withdrawal Facilities 2.3.1 Operational Modes Addressed in SARUP TSR Sections 2.3.1 and 2.5.1.
Page 13 of 54
1 SARUP Q&R - PGDP/ PORTS May 1,1998 Table 1. " Map" Between Existing PGDP TSRs and SARUP TSRs j
USEC-01 TSR Subject Location of TSR in SARUP or Basis for Not Including Section System / Control in SARUP TSRs i
2.3.2.1 Normetex Pump SARUP Section 4.3.2.2 analyzed withdrawal facility accidents.
Discharge Pressure In no scenario was normetex pump pressure considered a control 1
(Safety Limit) necessary to prevent an EBE which could exceed the ooffsitesite EGs. Therefore, the normetex system pressure requirements are not identified as essential controls and do not satisfy the criteria for a SARUP TSR safety limit (reference SARUP Section 4.3.1.1.4, fourth paragraph, last sentence: Only controls selected to prevent an EBE, which could exceed the off-site EGs were considered for establishing a Safety Limit or Limiting Control
)
Setting).
1 2.3.2.2 UF Cordenser As described in SARUP Table 4.2-11, the event " Coolant Tube 6
Coolan+ vessure Rupture into Primary System" (for the withdrawal facilities) was
{
(Safet mit) analyzed as having only limited consequences. Consequently, these limits are not controls necessary to prevent an EBE which could exceed the offsite EGs. Additionally, this system (a rupture disk) is not an active SSC. Therefore, these j
requirements are not identified as essential controls and do not satisfy the criteria for a SARUP TSR safety limit (reference SARUP Section 4.3.1.1.4, fourth paragraph, last sentence: Only active controls selected to prevent an EBE, which could exceed the off-site EGs were considered for establishing a Safety Limit or Limiting Control Setting).
2.3.3.1 Normetex Pump LCO and SRs are addressed in SARUP TSR Section 2.3.3.4 High Discharge Pressure System 2.3.3.2 Coolant SARUP Section 4.3.2.2 analyzed withdrawal facility accidents.
Overpressure Control In no scenario was UF. condenser coolant pressure determined to System be a control necessary to prevent an EBE which could exceed the offsite EGs. Additionally, this system (a rupture disk) is not an active SSC. Therefore, the UF. condenser system pressure requirements are not identified as essential controls ano. do not satisfy the criteria for a SARUP TSR safety limit (reference SARUP Section 4.3.1.1.4, fourth paragraph, last sentence: Only active controls selected to prevent an EBE, which could exceed the off-site EGs were considered for establishing a Safety Limit or Limiting Control Setting).
Page 14 of 54
SARUP Q&R - PGDP/ PORTS May 1,1998 Table 1.. " Map" Between Existing PGDP TSRs and SARUP TSRs USEC-01 TSR Subject Location of TSR in SARUP or Basis ter Not Including
' Section System /Controlin SARUP TSRs 2.3.4.1 UF. Release LCO and SRs are addressed in SARUP TSR Sections 2.3.3.1 Detection and and 2.5.3.1.
Isolation System -
Low Voltage
("New") System at the UF. Withdrawal 2.3.4.2 UF. Release LCO and SRs are addressed in SARUP TSR Sections 2.3.3.1 Detection System -
and 2.5.3.1 Low Voltage System at the UF.
Withdrawal Room Ceiling 2.3.4.3 UF Re '.,e LCO and SRs are addressed in SARUP TSR Sections 2.3.3.5 Detection System -
and 2.5.3.6.
Normetex Pump 2.3.4.4 UF Release The SARUP accident analysis of the withdrawal facilities, 6
Detection System -
Section 4.3.2.2, does not rely on these smoke detectors for High Voltage detection of a UF releases in this area; rather, facility operators 6
("Old") System for are relied upon to detect and if possible isolate the release.
UF. Condensers etc.
Therefore, this system was not identified as an essential control, does not meet the SARUP TSR selection criteria, and was not included as a SARUP TSR LCO. A description of this system is provided in SARUP Section 3.15.7.3. The UF. release detection and isolation low voltage systems did meet the SARUP TSR selection criteria and are addressed in SARUP TSR Sections 2.3.3.1 and 2.5.3.1.
2.3.4.5 UF. Release As discussed in the response to Question 19 (NRC 2/25/98 Detection System -
Letter), failures in smaller enrichment and purge compressors 1
High Speed would not meet SARUP TSR criterion 3 because the amount of Centrifugal Pumps UF material at risk is small, and this equipment operates below atmospheric pressure. The exposure of workers within the building from any releases would be minimized by evacuation and would preclude exceeding the PSOA onsite thresholds.
Therefore, this system was not identified as an essential control in the SARUP analyses and was not included as a SARUP TSR LCO.
Page 15 of 54
SARUP Q&R - PGDP/ PORTS May 1,1998 Table 1. " Map" Between Existing PGDP TSRs and SARUP TSRs USEC-01 TSR Subject Location of TSR in SARUP or Basis for Not Including Section System /Controlin SARUP TSRs 2.3.4.6 Facility' Assay Limits LCOs are provided in the SARUP TSRs for those fissile material operations where double coningency could not be met (consistent with current TSR 3.11.5). Where double contingency exists, respective NCS controls are described in the specific Nuclear Criticality Safety Approval (NCSA) and not in individual TSRs. The NCSAs are controlled by TSR 3.11. This is consistent with the SARUP TSR selection criteria (SARUP Section 4.2.3, item 4). For these reasons, this TSR was not included as a SARUP TSR LCO.
2.3.4.7 Criticality Accident LCO and SRs are addressed in SARUP TSR Section 2.3.3.3 Alarm System 2.3.4.8 Fire Protection LCO and SRs are addressed in SARUP TSR Sections 2.3.3.2 System - Building and 2.5.3.2.
Sprinider System l
2.3.4.9 Fire Protection LCO and SRs are addressed in SARUP TSR Section 2.3.3.2 and System - High 2.5.3.2. SAR TSRs 2.3.4.8 and 2.3.4.9 were combined into a Pressure Fire Water single TSR for each facility.
Distribution Mains 2.3.4.10 Fire Protection LCO and SRs are addressed in SARUP TSR Section 2.4.3.1.
System-Water SAR TSRs 2.3.4.10 and 2.3.4.11 were combined into a single i
Supply Basin TSR.
Page 16 of 54
SARUP Q&R - PGDP/ PORTS May 1,1998 Table 1. " Map" Between Existing PGDP TSRs and SARUP TSRs USEC-01 TSR Subject Location of TSR in SARUP or Basis for Not Including Section System / Control in SARUP TSRs 2.3.4.11 Fire Protection LCO and SRs are addressed in SARUP TSR Section 2.4.3.1.
System-High The SRs were modified as follows:
Pressure Fire Water Pumps The annual automatic start test of the electric high pressure fire water pumps was deleted and replaced with a monthly requirement to manually start the high pressure fire water pump.s locally and from C-300. The automatic start feature is not relied on in the SARUP accident analysis. Furthermore, the addition of a monthly start test from C-300 provides assurance that if the fire water storage tank falls to the point where fire pumps are needed, a C-300 operator action can start the operable pumps.
2.3.4.12 Fire Protection LCO and SRs are addressed in SARUP TSR Section 2.4.3.2.
System - High Pressure Fire Water Storage Tank 2.3.4.13 Fire Protection This TSR is an administrative control that was not identified as System - Hot Work an essential control in the SARUP analyses and does not meet the Limitations SARUP TSR LCO selection criteria. Therefore, this TSR was not included as a SARUP TSR LCO. Administrative controls do not normally meet the SARUP TSR selection cr':ria for an LCO.
2.3.4.14 Cylinder Scale Cart This TSR is an administrative control that was not identified as Movement an essential control in the SARUP analyses and does not meet the Prevention System SARUP TSR LCO selection criteria. Therefore, this TSR was not included as a SARUP TSR LCO. Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO.
i Page 17 of 54
E SARUP Q&R - PGDP/ PORTS May 1,1998 Table 1. " Map" Between Existing PGDP TSRs and SARUP TSRs USEC-01 TSR Subject Location of TSR in SARUP or Basis for Not Including Section System / Control in SARUP TSRs 2.3.4.15 Cylinder Filling -
This TSR is an administrative control and does not meet the Pre-Fill Weight SARUP TSR LCO selection criteria. Therefore, this TSR was not included as a SARUP TSR LC9. This control is identified in SARUP Section 4.3.2.2.10. SARUP TSR 3.9.1.b (revised from the existing TSR 3.9.1.b) requires implementation of SAR Chapter 4 administrative controls through written procedures.
Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO.
2.3.4.16 Cylinder Filling -
This TSR is an administrative control and does not meet the Cylinder Pre-Fill SARUP TSR LCO selection criteria. Therefore, this TSR was Inspection not included as a SARUP TSR LCO. This control is identified in SARUP Section 4.3.2.2.15. SARUP TSR 3.9.1.b (revised from the existing TSR 3.9.1.b) requires implementation of SAR Chapter 4 administrative controls through written procedures.
Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO.
2.3.4.17 Cylinder Filling -
This TSR is an administrative control and does not meet the Cylinder Fill Limit SARUP TSR LCO selection criteria. Therefore, this TSR was not included as a SARUP TSR LCO. The cylinder is only a concern if it is heated following overfilling, which is controlled by cylinder category. This control is identified in SARUP Section 4.3.2.2.2. SARUP TSR 3.9.1.b (revised from the existing TSR 3.9.1.b) requires implementation of SAR Chapter 4 administrative controls through written procedures.
2.3.4.18 Cylinder Handling -
This TSR is an administrative control and does not meet the Cylinder SARUP TSR LCO selection criteria. Therefore, this TSR was Disconnection not included as a SARUP TSR LCO. The requirement to purge and evacuate UF lines prior to opening the primary system is identified in SARUP Section 4.3.2.2.11. SARUP TSR 3.9.1.b (revised from the existing TSR 3.9.1.b) requires implementation of SAR Chapter 4 administrative controls through written procedures. Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO.
Page 18 of 54
SARUP Q&R - PGDP/ PORTS May 1,1998 Table 1. " Map" Between Existing PGDP TSRs and SARUP TSRs USEC-01 TSR Subject Location of TSR in SARUP or Basis for Not Including Section System /Controlin SARUP TSRs 2.3.4.19 Cylinder Handling -
This TSR is an administrative control that was not identified as Cylinder Valve an essential control in the SARUP analyses and does not meet the Covers SARUP TSR LCO selection criteria. Therefore, this TSR was not included as a SARUP TSR LCO. Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO.
2.3.4.20 Cylinder Handling -
This TSR is an administrative control and does not meet the Approved Cranes for SARUP TSR LCO selection criteria. Therefore, this TSR was Liquid Cylinders not included as a SARUP TSR LCO. This control is identified in SARUP Section 4.3.2.2.15. SARUP TSR 3.9.1.b (revised from the existing TSR 3.9.1.b) requires implementation of SAR Chapter 4 administrative controls through written procedures.
Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO.
2.3.4.21 Cylinder Lifting This TSR is an administrative control and does not meet the Restriction SARUP TSR LCO selection criteria. Therefore, this TSR was not included as a SARUP TSR LCO. This control is identified in SARUP Section 4.3.2.2.15. SARUP TSR 3.9.1.b (revised from the existing TSR 3.9.1.b) requires implementation of SAR Chapter 4 administrative controls through written procedures.
Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO.
2.3.4.22 Heating UF Plugs This TSR is an administrative control that was not identified as 6
an essential control in the SARUP analyses and does not meet the SARUP TSR LCG selection criteria. Therefore, this TSR was not included as a SARUP TSR LCO. Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO.
2.3.4.23 Scales This TSR is an administrative control that was not identified as an essential control in the SARUP analyses and does not meet the SARUP TSR LCO selection criteria. Therefore, this TSR was not included as a SARUP TSR LCO. Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO.
Page 19 of 54
1 t
l
-SARUP Q&R DGDP/ PORTS May 1,1998 Table 1. " Map" Between Existing PGDP TSRs and SARUP TSRs USEC-Oi TSR Subject -
Location of TSR in SARUP or Basis'for Not Including Section System / Control in SARUP TSRs 2.3.5.1 UF Cylinder Slings These design feature requirements and SRs are addressed in 6
and Lifting Fixtures SARUP TSR Sections 2.3.4.2 and 2.5.4.2.'
wy (Design Feature)
~
- 2.3.5.2 Crane Design Design feature requirements are addressed in SARUP TSRs (Design Feature) 2.3.4.2 and 2.5.4.2. This SARUP TSR and SARUP TSR 1.6.3.1, require this system to be operable prior to lifting any liquid UF. cylinders. This system does not meet the SARUP TSR selection criteria for an LCO. SRs in the existing TSRs that require performance of OSHA inspections (SRs 2.3.5.2-1, -2 and
-3) were not included as SARUP TSR surveillance because they are not credited in the SARUP analyses. Rather, the Basis statement in the SARUP TSR requires that the cranes must meet the applicable codes and standards described in SAR Chapter 1, Appendix A.
2.3.5.3 UF. Cylinders Design feature requirements are included in SARUP TSRs (Design Feature) 2.3.4.1 and 2.5.4.1. Existing SR 2.3.5.3-1 that requires cylinder inspections prior to filling or heating is not included in i
SARUP TSRs 2.3.4.1 and 2.5.4.1. Instead, a statement was added to the Basis that requires cylinders containing liquid UF6 to meet the ANSI N14.1 requirements described in SAR Chapter 1, Appendix A. This addition to the Basis is more accurate and broader in scope. Cylinder design requirements are described in SARUP Section 3.15.6.1.
2.3.5.4 UF. Cylinder This requirement is a passive design feature with no ongoing Pigtails surveillance requirement. Passive design features were only (Design Feature) included in the TSRs if a specific surveillance requirement was applicable (i.e., it was not considered appropriate to include a design feature in the SARUP TSRs if there was no accompanying surveillance requirement). Therefore, this TSR is not included as a SARUP TSR LCO or design feature. The requirement for initial pigtail inspections is addressed in SARUP Sections 4.3.2.2.10 and 4.3.2.2.11, as an administrative control.
SARUP TSR 3.9.1.b (revised from the existing TSR 3.9.1.b) requires implementation of SAR Chapter 4 administrative controls through written procedures. Pigtail design requirements are described in SARUP Section 3.15.5.4.
Page 20 of 54
SARUP Q&R - PGDP/ PORTS May 1,1998 j
Table 1. " Map" Between Existing PGDP TSRs and SARUP TSRs l
USEC-01 TSR Subject Location of TSR in SARUP or Basis for Not Including Section System / Control in SARUP TSRs l
2.3.5.5 Scale Cart Design Design feature requirements included in SARUP TSR Sections (Design Feature) 2.3.4.3 and 2.5.4.3.
2.3.5.6 UF Condenser This requirement is a passive design feature with an Accumulator administratively controlled inspection requirement to determine Minimum Wall estimated remaining life and verify tk veasel wall hr.. act been Thickness reduced below minimum required metal thickness per te current version of the National Boiler Inspection Code. This requirement was not identified as an essential control in the SARUP analyses. Therefore, this TSR is not included as a SARUP TSR LCO or design feature.
2.4 Specific TSRs for Enrichment Cascade Addressed in SARUP TSR Section 2.1.
Facilities 2.4.1 Operational Modes Addressed in SARUP TSR Section 2.1.1 2.4.2.1 Freezer /Submlimer As discussed in the hazard analysis for the " Rupture of F/S UF. Weight Limit Vessel" event, the failure of the F/S vessel is unlikely given the (Safety Limit) multiple failures and operator errors required to take place.
However, even if the yessel did fail, the analysis concludes that the consequences would be only local and would be minimized by the low pressures associated with the "A" line when in the sublime mode. These consequences would not significantly impact workers ability to "see and flee." Consequently, it is not a control necessary to prevent an EBE which could exceed the offsite EGs. Therefore, these requirements are not identified as essential controls and do not satisfy the criteria for a SARUP TSR safety limit (reference SARUP Section 4.3.1.1.4, fourth paragraph, last sentence: Only controls selected to prevent an EBE, which could exceed the off-site EGs were considered for establishing ti Safety Limit or Limiting Control Settingh Page 21 of 54
SARUP Q&R - PGDP/ PORTS May 1,1998 Table 1. " Map" Between Existing PGDP TSRs and SARUP TSRs USEC-01 TSR Subject Location of TSR in SARUP or Basis for Not Including Section System / Control in SARUP TSRs 2.4.2.2 Coolant (R-114)
SARUP Section 4.3.2.1.61nalyzed the accident addressed by Overpressure this TSR. If left unmitigated, this event does not exceed offsite Protection Systems EGs. Additionally, this system (a rupture disk) is not an " active (Safety Limit)
SSC." Therefore, the coolant system pressure requirements are not identified as essential controls and do not satisfy the criteria for a SARUP TSR safety limit (reference SARUP Section 4.3.1.1.4, fourth p nwh, last sentence: Ort controls selected to prevent an EBE, whn.h ould exceed the off-site EGs were considered for establishing a Safety Limit or Limiting Control Setting).
2.4.2.3 Cascade Pressure SARUP Section 4.3.2.1 analyzed cascade facility accidents, in Limit no scenario was cascade pressure detennined to be a control (Safety Limit) necessary to prevent an EBE which could exceed the offsite EGs.
Therefore, the cascade system pressure requirements are not identified as essential controls and do not satisfy the criteria for a SARUP TSR safety limit (reference SARUP Section 4.3.1.1.4, fourth paragrapt last sentence: Only controls selected to prevent an EBE, which could exceed the off-site EGs were considered for establishing a Safety Limit or Limiting Control Setting).
2.4.3.1 Freezer / Sublimer As discussed in the hazard analysis for the " Rupture of F/S High-High Weight Vessel" event _ the failure of the F/S vessel is unlikely given the Trip System multiple failures and operator errors required to take place.
However, even if the vessel did fail, the analysis concludes that the consequences would be only local and would be minimized by the low pressures associated with the "A" line when in the sublime mode. These consequences would not significantly impact workers ability to "see and flee." This system was not identified as an essential control in the SARUP analyses, does not satisfy the SARUP TSR LCO selection criteria, and was not included as a SARUP TSR LCO. This system, including weight limits, is described in SARUP Section 3.15.3.5.
2.4.3.2 Freezer / Sublimer As described in SARUP Table 4.2-11, the event " Stress Rupture UF, Vent Line of F/S Vessel" was analyzed as having only limited Manual Block Valve consequences. This system was not identified as an essential control in the SARUP analyses, does not satisfy the SARUP TSR LCO selection criteria, and was not included as a SARUP TSR LCO. This control is identified in SARUP Section 3.15.3.4.
Page 22 of 54
I SARUP Q&R - PGDP/ PORTS May 1,1998 Table 1. " Map" Between Existing PGDP TSRs and SARUP TSRs
-i '
USEC-01 TSR Subject Location of TSR in SARUP or Basis for Not Including Section System / Control in SARUP TSRs 2.4.3.3 Freezer / Sublimer R-As described in SARUP Table 4.2-11, the event " Coolant Tube 114 Vent Line Rupture into Primary System" for the freezer / sublimer process Manual Block Valve was analyzed as having only limited consequences. This system was not identified as an essential control in the SARUP analyses, does not satisfy the SARUF TSR LCO selection criteria, and therefore, was not included as a SARUP TSR LCO.
2.4.3.4 R-il4 Coolant SARUP Section 4.3.2.1.6 analyzed the accident addressed by Overpressure Control this TSR. The coolant high pressure relief system is not System identified as an essential control for this accident. Additionally, this system (a rupture disk) is not an active SSC. For these reasons, this system does not satisfy the SARUP TSR LCO selection criteria. This system is described in SARUP Section 3.15.3.4.
2.4.3.5 Intermediate Gas SARUP did not analyze any hazards associated with this system Removal High because it has never operated and there are currently no plans to Temperature Control operate it. Further analysis would be required to support System operation. Therefore, this system was not included in the SARUP TSRs. The current TSR specifies that the system shall not be operated.
2.4.4.1 UF. Release LCO and 5 As are addressed in SARUP TSR Section 2.1.3.4.
Detection System 2.4.4.2 Criticality Accident LCO and SRs are addressed in SARUP TSR Section 2.1.3.3.
1 Alarm System 2.4.4.3 Cascade Equipment LCOs are provided in the SARUP TSRs for those fissile material Assay Limitations operations where double contingency could not be met (consistent with current TSR 3.11.5). Where double contingency exists, respective NCS controls are described in the specific Nuclear Criticality Safety Approval (NCSA) and not in individual TSRs. The NCSAs are controlled by TSR 3.11. As discussed in SARUP Section 4.3.1.1.4, a TSR surveillance requirement was included in the SARUP TSRs if it was necessary to ensure that the control (i.e., the LCO or Design Feature) is functioning within the constraints assumed in the 3
accident analysis. For these reasons, this TSR was not i'icluded as a SARUP TSR LCO.
Page 23 of 54
SARUP Q&R - PGDP/ PORTS May 1,1998 s
Table 1. " Map" Between Existing PGDP TSRs and SARUP TSRs USEC-01 TSR Subject Location of TSR in SARUP or Basis for Not Including Section System / Control in SARUP TSRs 2.4.4.4 Cascade Wet Air LCO and SRs are addressed in SARUP TSR Section 2.1.3.6.
Inleakage 2.4.4.3 Fire Protection LCO and SRs are addressed in SARUP TSR Section 2.1.3.5.
System - Building Sprinkler System 2.4.4.6 Fire Protection LCO and SRs are addressed in SAROP TSR Section 2.1.3.5.
System - High SAR TSR 2.4.4.5 and 2.4.4.6 were combined into a single TSR.
Pressure Fire Water Distribution Mains 2.4.4.7 Fire Protection LCO and SRs are addressed in SARUP TSR Section 2.4.3.1.
System - Water SAR TSR 2.4.4.7 and 2.4.4.8 were combined inn a single TSR.
Supply Basin 2.4.4.8 Fire Protection LCO and SRs are addressed in SARUP TSR Section 2.4.3.1.
System - High The SRs were modified as follows:
Pressure Fire Water Pumps The annual automatic start test of the electric high pressure fire water pumps was deleted and replaced with a monthly requirement to manually start the high pressure fire water pumps locally and from C-300. The automatic start feature is not relied on in the accident analysis. Furthermore, the addition of a monthly start test from C-300 provides assurance that if the fire water storage tank falls to the point where fire pumps are needed, a C-300 operator action can start the operable pumps.
2.4.4.9 Fire Protection LCO and SRs are addressed in SARUP TSR Section 2.4.3.2 System - High Pressure Fire Water Storage Tank Page 24 of 54
SARUP Q&R - PGDP/ PORTS May 1,1998 Table 1. " Map" Between Existing PGDP TSRs and SARUP TSRs USEC-01 TSR Subject Location of TSR in SARUP or Basis for Not Including Section System / Control in SARUP TSRs 2.4.4.10 Fire Protection This TSR is an administrative control that was not identified as System - Hot Work an essential control in the SARUP analyses and does not meet the Limitations SARUP TSR LCO selection criteria. Therefore, this TSR was not included as a SARUP TSR LCO. Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO.
2.4.4.11 Cascade Pressure SARUP Section 4.3.2,1 analyzed cascade facility accidents. In j
Limitation no scenario was cascade pressure determined to be an essential control or an operating restriction that meets any of the SARUP TSR LCO selection criteria. Therefore, the cascade system pressure requirements were not included as a SARUP TSR LCO.
2.4.4.12 Cascade Cell Trip LCO and SRs are ad:iressed in SARUP-TSR Section 2.1.3.1.
Function 2.4.4.13 Heavy Equipment This TSR is an administrative control and does not meet the Handling SARUP TSR LCO selection criteria. Therefore, this TSR was not included as a SARUP TSR LCO. This control is identified in SARUP Section 4.3.2.1.8. SARUP TSR 3.9.1.b (revised from the existing TSR 3.9.1.b) requires implementation of SAR Chapter 4 administrative controls through written procedures.
Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO.
2.4.4.14 Heating UF. Plugs This TSR is an administrative' control that was not identified as an essential control in the SARUP analyses and does not meet the SARUP TSR LCO selection criteria. Therefore, this TSR was not included as a SARUP TSR LCO. Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO.
2.5 Equipment Removal Addressed in SARUP TSR Sections 2.1,2.3, and 2.4.
Activities 2.5.4.1 Pre-Removal LCO and SRs are addressed in SARUP TSR Sections 2.1.3.7, Examination 2.3.3.7 and 2.4.3.4.
2.5.4.2 Post-Removal LCO and SRs are addressed in'SARUP TSR Sections 2.1.3.7, Examination 2.3.3.7, and 2.4.3.4.
2.5.4.3 PEH Equipment LCO and SRs are addressed in SARUP TSR Sections 2.1.3.6 Openings and 2.3.3.6.
Page 25 of 54
SARUP Q&R - PGDP/ PORTS May 1,1998 Table 1. " Map" Between FMag PGDP TSRs and SARUP TSRs USEC-01 TSR Subject Location of TSR in SARUP or Basis for Not Including Section System / Control in SARUP TSRs 2.5.4.4 PEH LCO and SRs are addressed in SARUP TSR Sections 2.1.3.6 and 2.3.3.6.
2.6 CAAS Addressed in SARUP TSR Section 2.4.
(Non-Cascade Facilities 2.6.4.1 Criticality Accident LCO and SRs are addressed in SARUP TSR, Section 2.4.3.3.
Alarm System 3.0 Administrative Addressed in SARUP TSR Section 3.0.
Controls Page 26 of 54
SARUP Q&R - PGDP/ PORTS May 1,1998 Table 2. " Map" Between Existing PORTS TSRs and SARUP TSRs USEC-02 TSR Subject Location of TSR in SARUP or Basis for Not Including Section System /Controlin SARUP TSRs 1.0 Definitions Addressed in SARUP TSR Section 1.0. Current TSR Definition 1.2.4 was deleted because this term is not used in the SARUP TSRs.
2.1 Specific TSRs for Addressed in SARUP TSR Section 2.2.
X-342, X-343, and X-344 Facilities 2.1.1 X-342, X-343, X-Addressed in SARUP TSR Section 2.2.1.
344 Autoclave Operational Modes 2.1.2.1 Autoclave Pressure This requirement is a passive design feature with no special (Safety Limit) surveillance requirement (the autoclave pressure decay test is conducted under SARUP TSR 2.2.3.1-2). Passive design features were only included in the SARUP TSRs if a specific surveillance requirement was applicable (i.e., it was not considered appropriate to include a design feature in the SARUP TSRs if there was no accompanying surveillance requirement).
Furthermore, according to the limiting accident scenario for a cylinder failure inside an autoclave (SARUP Section 4.3.2.2.14),
this control does not prevent an EBE, which could exceed the offsite EGs (reference SARUP Section 4.3.1.1.4, fourth paragraph, last sentence: Only controls selected to prevent an EBE, which could exceed the off-site EGs were considered for establishing a Safety Limit or Limiting Control Setting).
Therefore, this existing safety limit is not included in the SARUP TSRs.
2.1.2.2 Cylinder Heating Addressed in SARUP TSR Section 2.2.2.1. No surveillance requirement is applicable.
l 2.1.3.1 Criticality Accident LCO and SRs are addressed in SARUP TSR Section 2.2.3.6.
Alarm Sysh (CAAS) 2.1.3.2 UF. Cylinder High LCO and SRs are addressed in SARUP TSR Section 2.2.3.4.
Pressure Autoclave Steam Shutoff Page 27 of 54
SARUP Q&R - PGDP/ PORTS -
May 1,1998 Table 2. " Map" Between Fri=*1== PORTS TSRs and SARUP TSRs
{
USEC-02 TSR Subject Location of TSR in SARUP or Basis for Not Including j
L Section System / Control in SARUP TSRs 2.1.3.3 UF. Cylinder High LCO and SRs are addressed in SARUP TSR Section 2.2.3.8.
l Temperature j
Autoclave Steam Shutoff 2.1.3.4 Autoclave Shell This system was determined in the SARUP to provide " defense-High Steam indepth" and, thus, does not meet the SARUP TSR selection Pressure Shutdown criteria. SARUP Sections 4.3.2.2.4,4.3.2.2.9, and 4.3.2.2.14 support this position. Therefore, this control was not included as a SARUP TSR LCO.
2.1.3.5 Autoclave Shell LCO and SRs are addressed in SARUP TSR Section 2.2.3.1.
i High Pressure Containment Shutdown 2.1.3.6 Autoclave Shell SARUP Section 4.3.2.2.14 (which provides for the worst case High Pressure pressure rise inside the autoclave) concluded that the pressure Relief System inside the autoclave would not reach the maximum allowable working pressure (MAWP) for any of the autoclaves for any of the autoclave / cylinder configurations. The autoclave shell high pressure relief system was not considered an essential control in -
this analysis and, therefore, this system does not qualify under the SARUP TSR selection criteria (SARUP Section 4.2.3) and is not included as a SARUP TSR LCO.
2.1.3.7 High Condensate LCO and SRs are addressed in SARUP TSR Section 2.2.3.5.
Level Shutoff 2.1.3.8 Cylinder Heating This TSR is an administrative control and does not satisfy the SARUP TSR LCO selection criteria. The weight and void volume requirements, as well as the heating allowances, under this TSR were included in SARUP TSR 1.2.7, and in the Basis statements for SARUP TSRs 2.2.2.1,2.2.3.8, and 2.2.4.1. For these reasons, this TSR was not included as a " stand-alone" l
LCO in the SARUP TSRs.
j 1
i Page 28 of 54
SARUP Q&R - PGDP/ PORTS May 1,1998
]
Table 2. " Map" Between Existing PORTS TSRs and SARUP TSRs 1
USEC-02 TSR Subject Location of TSR in SARUP or Basis for Not Including Section System /Controlin SARUP TSRs I
2.1.3.9 Low Cylinder As described in SARUP Table 4.2-11, the event for which this Pressure Shutoff system was intended to provide protection, a plugged cylinder valve / pigtail, was analyzed by SARUP as having only limited consequences. This conclusion is based on the use of admini.etrative controls that do not meet the SARUP TSR LCO selection criteria.
2.1.3.10 Cylinder Assay LCOs are provided in the SARUP TSRs for those fissile material Limitations operations where double contingency could not be met (censistent with current TSR 3.11.5). Where double contingency exists, respective NCS controls are described in the specific Nuclear Criticality Safety Approval (NCSA) and not in j
individual TSRs. The NCSAs are controlled by TSR 3.11. This is consistent with the SARUP TSR selection criteria (SARUP Section 4.2.3, item 4). For these reasons, this TSR was not included as a SARUP TSR LCO.
2.1.3.11 Autoclave Smoke SARUP Section 4.3.2.2, does not rely on autoclave smoke Detection System detectors for detection of a UF. releases outside of the autoclave; rather, facility operators are relied upon to detect and if possible isolate the release. Therefore, this system was not identified as an esseraisi control, does not meet the SARUP TSR selection criteria, and was not included as a SARUP TSR LCO. A description of this system is provided in SARUP Section 3.8.7.3.
2.1.3.12 Liquid UF.
The LCO requirements are addressed in SARUP TSR Section Handling Cranes 2.2.4.2. This SARUP TSR and SARUP TSR 1.6.3.1, require this system to be operable prior to lifting any liquid UF6 cylinders. This system does not meet the SARUP TSR selection criteria for an LCO. SRs in le existing TSRs that require performance of OSHA inspections (SRs 2.1.3.12.3 and 2.1.3.12.4) were not included as SARUP TSR surveillance because they are not credited in the SARUP analyses. Rather, the Basis statement in the SARUP TSR requires that the cranes must meet the applicable codes and standards described in SAR Chapter 1. Appendix A.
2.1.3.13 Pigtail Line LCO and SRs are addressed in SARUP TSR Sections 2.2.3.2 Isolation (for X-342-A and X-343) and 2.2.3.7 (for X-344-A).
Page 29 of 54
I SARUP Q&R - PGDP/ PORTS May 1,1998 Table 2. " Map" Between Existing PORTS TSRs and SARUP TSRs I
USEC-02 TSR Subject Leontion of TSR in SARUP or Basis for Not Including Section System / Control in SARUP TSRs 2.1.3.14 Liquid UF.
This TSR is an administrative control and does not meet the Movement SARUP TSR LCO selection criteria. Therefore, this TSR was not included as a SARUP TSR LCO. This control is identified in SARUP Section 4.3.2.2.15. SARUP TSR 3.9.1.b (revised from the existing TSR 3.9.1.b) requires implementation of SAR Chapter 4 administrative controls through written procedures.
Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO.
2.1.3.15 Receiving Cylinder This TSR is an administrative control and does not meet the Fill Weights SARUP TSR LCO selection criteria. Therefore, this TSR was not included as a SARUP TSR LCO. The cylinder is only a concern if it is heated following overfilling, which is controlled by cylinder category. This control is identified in SARUP Section 4.3.2.2.2. SARUP TSR 3.9.1.b (revised from the existing TSR 3.9.1.b) requires implementation of SAR Chapter 4 administrative controls through written procedures.
Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO. Cylinder void volume requirements are included in the SARUP TSR 1.2.7 and in the Basis statements for SARUP TSRs 2.2.2.1 and 2.2.3.8.
2.1.3.16 UF. Cylinder Crane This TSR is an administrative control and does not meet the i
Movement SARUP TSR LCO selection criteria. Therefore, this TSR was not included as a SARUP FSR LCO. This control is identified in SARUP Section 4.3.2.2.15. SARUP TSR 3.9.1.b (revised from the existing TSR 3.9.1.b) requires implementation of SAR Chapter 4 administrative controls through written procedures.
Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO.
l 2.1.3.17 UF. Cylinder This TSR is an administrative control and does not meet the Weight Discrepancy SARUP TSR LCO selection criteria. Therefore, this TSR was not included as a SARUP TSR LCO. This control is identified in SARUP Section 4.3.2.2.10. SARUP TSR 3.9.1.b (revised from the existing TSR 3.9.1.b) requires implementation of SAR Chapter 4 administrative controls through written procedures.
Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO.
Page 30 of 54
SARUP Q&R - PGDP/ PORTS May 1,1998 Table 2. " Map" Between Wag PORTS TSRs and SARUP TSRs USEC-02 l
TSR Subject Location of TSR in SARUP or Basis for Not Including Section System / Control in SARUP TSRs 2.1.3.18 UF. Plugs This TSR is an administrative control that was not identified as an essential control in the SARUP analyses and does not meet the SARUP TSR LCO selection criteria.
erefore, this TSR was not included as a SARUP TSR LCO.p' 2.1.4.1 UF. Cylinder These design feature requirements and SRs are addressed in Lifting Fixtures SARUP TSR Section 2.2.4.2.
(Design Feature) 4 2.1.4.2 UF. Cylinders Design feature requirements are included in SARUP TSR (Design Feature) 2.2.4.1. Existing SR 2.1.4.2.2 that requires cylinder inspections prior to filling or heating is not included in SARUP TSR 2.2.4.1. Instead, a statement was added to the Basis that required cylinders containing liquid UF. to meet the ANSI N14.1 requirements described in SAR Chapter 1, Appendix A.
This addition to the Basis is more accurate and broader in scope.
Cylinder design requirements are described in SARUP Section 3.8.6.1.
2.1.4.3 UF Cylinder This requirement is a passive design feature with no ongoing Pigtails (Design surveillance requirement. Passive design features were only Feature) included in the TSRs if a specific surveillance requirement was applicable (i.e., it was not considered appropriate to include a design feature in the SARUP TSRs if there was no accompanying surveillance requirement). Therefore, this TSR is not included as a SARUP TSR LCO or design feature. The requirement for initial pigtail inspections is addressed in SARUP Sections 4.3.2.2.10 and 4.3.2.2.11, as an administrative control.
SARUP TSR 3.9.1.b (revised from the existing TSR 3.9.1.b) requires implementation of SAR Chapter 4 administrative controls through written procedures. Pigtail design requirements are included in SARUP Section 3.8.5.4.
Page 31 of 54
(
l SARUP Q&R - PGDP/ PORTS May 1,1998 Table 2. " Map" Between Existing PORTS TSRs and SARUP TSRs USEC-02 L
TSR Subject tocation of TSR in SARUP or Basis for Not Including s
Section System / Control in SARUP TSRs 2.1.4.4 X-342 Condensate LCOs are provided in the SARUP TSRs for those fissile material Sump and Oil operations where double contingency could not be met Interceptor (Design (consistent with current TSR 3.11.5). Where double Feature) contingency exists, respective NCS controls are described in the specific Nuclear Criticality Safety Approval (NCSA) and not in individual TSRs. The NCSAs are controlled by TSR 3.11. This is consistent with the SARUP TSR selection criteria (SARUP Section 4.2.3, item 4). For these reasons, this TSR was not included as a SARUP TSR LCO or Design Feature.
2.1.4.5 Autoclave Shell The pressure test requirement for the autoclave shell are (Design Feature) addressed under SARUP TSR 2.2.3.1-2. Other than this test, this existing TSR requirement represents a passive design feature. Passive design features were only included in the TSRs if a specific surveillance requirement was applicable (i.e., it was not considered appropriate to include a DF in the TSR if there was no accompanying surveillance requirement). Therefore, this existing design feature was not included in the SARUP TSRs.
The National Board Inspection Code inspection covered by the existing TSR continues to be required under the SAR Chapter 1, Appendix A.
2.1.4.6 Overhead Crane The requirement to test cranes that carry liquid UF cylinders at Capacity (Design 100% rated load is included in SARUP TSR 2.2.4.2. Other than Feature) this test, this existing TSR requirement represems a passive design feature. Passive design features were only included in the TSRs if a specific surveillance requirement was applicable (i.e.,
it was not considered appropriate to include a design feature in the SARUP TSRs if there was no accompanying surveillance requirement). Therefore, this existing design feature was not included as a " stand-alone" design feature in the SARUP TSRs.
These cranes are described in SARUP Section 3.8.6.2.
l
'1 Specific TSRs for Addressed in SARUP TSR Section 2.1.
X-330 and X-333 Cascade Facilities l
2.2.1 X-330/X-333 Addressed in SARUP TSR Section 2.1.1.
l Cascade Operational Modes Page 32 of 54
SARUP Q&R - PGDP/ PORTS M g 1,1998 Table 2. " Map" Between Friding PORTS TSRs and SARUP TSRs USEC-02 TSR Subject Location of TSR in SARUP or Basis for Not Including Section System / Control in SARUP TSRs 2.2.2.1 Coolant Pressures SARUP Section 4.3.2.1.6 analyzed the accident addressed by (Safety Limit) this TSR. Ifleft unmitigated, this event does not exceed cffsite EGs. Therefore, the coolant system pressure requirements are not identified as essential controls and do not satisfy the criteria for a SARUP TSR safety limit (reference SARUP Section 4.3.1.1.4, fourth paragraph, last sentence: Only controls selected to prevent an EBE, which could exceed the off-site EGs were considered for establishing a Safety Limit or Limiting Control Setting).
2.2.2.2 Cascade Pressures SARUP Section 4.3.2.1 analyzed cascade facility accidents. In (Safety Limit) no scenario was cascade pressure determined to be a control necessary to p event an EBE which could exceed the offsite EGs. Therefore, the cascade system pressure requirements are not identified as essential controls and do not satisfy the criteria for a SARUP 1SR safety limit (reference SARUP Section 4.3.1.1.4, fourtit paragraph, last sentence: Only controls selected to prevent an EBS, which could exceed the off-site EGs were considered for establishing a Safety Limit or Limiting Control Setting).
2.2.3.1 Coolant High SARUP Section 4.3.2.1.6 analyzed the accident addressed by Pressure Relief this TSR. The coolant high pressure relief system is not System identified as an essential control for this accident. Additionally, this system (a ruptu,e disk) is not an active SSC. For these reasons, this system does not satisfy the SARUP TSR LCO selection criteria. This system is described in SARUP Section 3.8.3.4.
2.2.3.2 Criticality Accident LCO and SRs are addhessed in SARUP TSR Section 2.1.3.3.
Alarm System 2.2.3.3 CADP UFg Smoke LCO and SRs are addressed in SARUP TSR Section 2.1.3.4.
Detection System i
Page 33 of 54
I.
)
SARUP Q&R - PGDP/ PORTS May 1,1998 Table 1. " Map" Between Existing PORTS TSRs and SARUP TSRs USEC-02 TSR Subject Location of TSR in SARUP or Basis for Not Including Section System / Control in SARUP TSRs 2.2.3.4 High Pressure Fire LCO and SRs are addressed in SARUP TSRs 2.1.3.5 Water System (Sptinklers), 2.4.3.1 (Fire Water Pumps), and 2.4.3.2 (Fire Water Storage Tanks). SARUP TSR SRs were revised from the existing TSR SRs. SRs were added from the existing TSRs l
while several SRs were deleted as follows:
(a)
The annual verification of supervisory alarms (USEC-02 TSR 2.2.3.4.7) was replaced with the monthly l
verification of control and sectionalizing valve alignment l
(SARUP TSR 2.1.3.5-1) because the monthly check is considered more reliable than the annual check of the supervisory alarm system.
(b)
The annual automatic start test of the electric high pressure fire water pumps was deleted and replaced with a monthly requirement to manually start the high pressure fire water pumps locally and from the X-300, The automatic start feature does not exist for diesel fire pumps and this pump feature is not relied upon in the accident analysis. Furthermore, the addition of a monthly start test from the X-300 building provides added assurance that if the fire water storage tank level falls to the point where fire pumps are needed, a PCF operator action can start the operable pumps.
(c)
A SR was added to verify on a monthly basis that the water supply tanks for the pumps contain sufficient inventory.
2.2.3.5 Coolant Removal Explosive concentration limits and other related operational restrictions for preventing coolant / oxidant exothermic reactions l
are administrative controls and not active SSCs. The SARUP I
TSR selection criteria (SARUP Section 4.2.3, item 3) requires an LCO for active SSCs that prevent or mitigate an event that could result in life threatening or serious health effects to onsite I
personnel from the release of radioactive materials. Therefore,
)
this TSR was not included as a SARUP TSR LCO.
l j
Page 34 of 54
i-3 l
SARUP Q&R - PGDP/ PORTS May 1,1998 Table 2. " Map" Between RwMag PORTS TSRs and SARUP TSRs USEC-02 TSR Subject Location of TSR in SARUP or Basis for Not Including Section System /Controlin SARUP TSRs I
2.2.3.6 Cell Treatment Explosive concentration limits and oth= operational restrictions Monitoring for preventing coolant / oxidant exothermic reactions are administrative controls and not active SSCs. The SARUP TSR selection criteria (SARUP Section 4.2.3, item 3) requires an LCO for active SSCs that prevent or mitigate an event that could result in life threatening or serious health effects to onsite personnel from the release of radioactive materials. Therefore, l
this TSR was not included as a SARUP TSR LCO.
l l
2.2.3.7 Cell Inverse Explosive concentration limits and other related operational Recycle Treatment restrictions for preventing coolant / oxidant exothermic reactions are administrative controls and not active SSCs. The SARUP TSR selection criteria (SARUP Section 4.2.3, item 3) requires an LCO for active SSCs that prevent or mitigate an event that could result in life threatening or serious health effects to onsite personnel from the release of radioactive materials. Therefore, this TSR was not imluded as a SARUP TSR LCO.
l 2.2.3.8 Seal Exhaust LCOs are provided 1 the SARUP TSRs for those fissile material Station Enrichment operations where double contingency could not be met (consistent with current TSR 3.11.5). Where double contingency exists, respective NCS controls are described in the specific Nuclear Criticality Safety Approval (NCSA) and not in individual TSRs. The NCSAs are controlled by TSR 3.11. This is consistent with the SARUP TSR selection criteria (SARUP Section 4.2.3, item 4). For these reasons, this TSR was not included as a SARUP TSR LCO.
2.2.3.9 Evacuation Booster LCOs are provided in the SARUP TSRs for those fissile material Station (EBS) operations where double contingency could not be met Enrichment (consistent with current TSR 3.11.5). Where double contingency exists, respective NCS controls are described in the specific Nuclear Criticality Safety Approval (NCSA) and not in individual TSRs. The NCSAs are controlled by TSR 3.11. This is consistent with the SARUP TSR selection criteria (SARUP L
Section 4.2.3, item 4). For these reasons, this TSR was not included as a SARUP TSR LCO.
Page 35 of 54 i
l 1
SARUP Q&R - PGDP/ PORTS May 1,1998 Table 2. " Map" Between Existing PORTS TSRs and SARUP TSRs USEC-02 TSR Subject Location of TSR in SARUP or Basis for Not Including Section System / Control in SARUP TSRs 2.2.3.10 Crane Movement of This TSR is an administrative contro! and does not meet the Cascade Equipment SARUP TSR LCO selection criteria. Therefore, this TSR was not included as a SARUP TSR LCO. This control is identified l
in SARUP Section 4.3.2.1.8. SARUP TSR 3.9.1.b (revised l
from the existing TSR 3.9.1.b) requires implementation of SAR Chapter 4 administrative controls through written procedures.
Administrative controls do not normally meet the SARUP TSR l
selection criteria for an LCO.
1 2.2.3.11 Evacuation Booster Explosive concentration limits and other operational restrictions l
Station Oxidant for preventing coolant / oxidant exothermic reactions are Limit administrative controls and not active SSCs. The SARUP TSR selection criteria (SARUP Section 4.2.3, item 3) requires an LCO for active SSCs that prevent or mitigate an event that could result in life threatening or serious health effects to onsite personnel from the release of radioactive materials. Therefore, this TSR was not included as a SARUP TSR LCO.
2.2.3.12 UF Plugs This TSR is an administrative control and does not meet the 6
SARUP TSR LCO selection criteria. Therefore, this TSR was not included as a SARUP TSR LCO.
2.2.3.13 Cascade Pressure SARUP Section 4.3.2.1 analyzed cascade facility accidents. In l
Limitations no scenario was cascade pressure determined to be an essential I
control or an operating restriction that meets any of the SARUP TSR LCO selection criteria. Therefore, the cascade system l
pressure requirements were not included as a SARUP TSR LCO.
2.2.3.14 Cascade DC LCO and SRs are addressed in SARUP TSR Section 2.1.3.1.
I Control Power L
2.2.3.15 Moderation Control LCO and SRs are addressed in SARUP TSR Section 2.1.3.6.
2.2.3.16 Removed LCO and SRs are addressed in SARUP TSR Section 2.1.3.7.
Equipment with Deposits i
I 1
Page 36 of 54 1
a
SARUP Q&R - PGDP/ PORTS May 1,1998 Table 2. " Map" Between Existing PORTS TSRs and SARUP TSRs USEC-02 TSR Subject Location of TSR in SARUP or Basis for Not Including"~
- Section System / Control in SARUP TSRs 2.2.4.1 Seal Exhaust Pump LCOs are provided in the SARUP TSRs for those fissile material Overflows (Design operations where double contingency could not be met Feature)
(consistent with current TSR 3.11.5). Where double contingency exists, respective NCS controls are described in the specific Nuclear Criticality Safety Approval (NCSA) and riot in individual TSRs. The NCSAs are controlled by TSR 3.11. This l
is consistent with the SARUP TSR selection criteria (SARUP Section 4.2.3, item 4). For these reasons, this TSR was not included as a SARUP TSR LCO or Design Feature.
2.3 Specific TSRs for Not included in SARUP TSRs. See below.
X-333 Freezer Sublimers 2.3.1 Freezer Sublimer As discussed below, there were no controls specifically Operational Modes involving the freezer sublimers that satisfied the SARUP TSR LCO selection criteria. Therefore, these operating modes were not included in the SARUP TSRs.
2.3.2.1 UF. Weight Limit As discussed in the hazard analysis for the " Rupture of F/S for Freezer Vessel" event, the failure of the F/S vessel is unlikely given the Sublimers (Safety multiple failures and operator errors required to take place.
Limit)
However, even if the vessel did fail, the analysis concludes that j
the consequences would be only local and would be minimized by the low pressures associated with the "A" Line when in the sublime mode. These consequences would not significantly impact workers' ability to "see and flee." Consequently, it is not a control necessary to prevent an EBE which could exceed the offsite EGs. Therefore, these requirements are not identified as essential controls and do not satisfy the criteria for a SARUP TSR safety limit (Reference SARUP Section 4.3.1.1.4, fourth paragraph, last sentence: Only controls selected to prevent an EBE, which could exceed the off-site EGs were considered for establishing a Safety Limit or Limiting Control Setting).
Page 37 of 54
i SARUP Q&R - PGDP/ PORTS May 1,1998 Table 2. " Map" Between Existing PORTS TSRs and SARUP TSRs USEC-02 TSR Subject Location of TSR in SARUP or Basis for Not Including Section System /Controlin SARUP TSRs 2.3.3.1 Freezer / Sublimer As discussed in the hazard analysis for the " Rupture of F/S UF. High-High Vessel" event, the failure of the F/S vessel is unlikely given the Weight Trip System multiple failures and operator errors required to take place.
i However, even if the vessel did fail, the analysis concludes that the consequences would be only local and would be minimized by the low pressures associated with the "A" Line when in the sublime mode. These consequences would not significantly impact workers' ability to "see and flee." This system was not identified as an essential control in the SARUP analysis, does not satisfy the SARUP TSR LCO selection criteria, and was not included as a SARUP TSR LCO. This system, including weight limits, is described in SARUP Section 3.8.3.5.
2.3.3.'
Assay Limitations LCOs are provided in the SARUP TSRs for those fissile material operations where double contingency could not be met (consistent with current TSR 3.11.5). Where double contingency exists, respective NCS controls are described in the specific Nuclear Criticality Safety Approval (NCSA) and not in individual TSRs. The NCSAs are controlled by TSR 3.11. This is consistent with the SARUP TSR selection criteria (SARUP Section 4.2.3, item 4). For these reasons, this TSR was not
]
included as a SARUP TSR LCO.
j
'2.3.3.3 Freezer / Sublimer This TSR is an administrative control and not an active SSC-Venting TSR selection criteria (SARUP Section 4.2.3, item 3) requires 1
an LCO for active SSCs that prevent or mitigate an event that 1
could result in life threatening or serious health effects to onsite personnel from the release of radioactive materials. Therefore, this control does not satisfy any SARUP TSR selection criteria and is not included as a SARUP TSR LCO. This control is identified in SARUP Section 3.8.3.4.
2.4 Specific TSRs for Not included in SARUP TSRs. See below.
X-330 and X-333
)
Cold Recovery 4
l 2.4.1 Cold Recovery As discussed below, there were no controls specifically Operational Modes involving the cold recovery system that satisfied the SARUP TSR LCO selection criteria. Therefore, these operating modes were not considered necessary for the SARUP TSRs.
Page 38 of 54 1
l
1 SARUP Q&R - PGDP/ PORTS May 1,1998 Table 2. " Map" Between Existing PORTS TSRs and SARUP TSRs USEC-02 j
TSR Subject Location of TSR in SARUP or Basis for Not Including Section System /Controlin SARUP TSRs 2.4.3.1 Criticality Accident LCO and SRs are addressed in SARUP TSR Section 2.1.3.3.
Alarm System 2.4.3.2 Cold Trap Pressure As oiscussed in SARUP Section 4.2.6.4.4.4, the primary Relief System admimstrative controls identified for the cold recovery process are to limit operating pressures to below atmospheric pressure.
These controls minimize any release of UF. should a failure in the primary system occur. Only two initiating events involving the cold recovery system potentially exceeded the PSOA threshold, criticality and evacuation (refer to SARUP Table 4.2-11). The criticality event is not applicable to this TSR. The evacuation event was analyzed in SARUP Section 4.3.2.1.5.
The conclusion for the cold recovery system was that even if the system ruptured only local effects would result (but because of the evacuation, no workers would be in the area). No essential controls were identified for cold recovery in this SARUP scenario. Therefore, this system does not satisfy the SARUP TSR LCO selection criteria and was not included as a SARUP TSR LCO.
2.4.3.3 Cold Recovery LCOs are provided in the SARUP TSRs for those fissile material Enrichment operations where double contingency could not be met (consistent with current TSR 3.11.5). Where double contingency exists, respective NCS controls are described in the specific Nuclear Criticality Safety Approval (NCSA) and not in individual TSRs. The NCSAs are controlled by TSR 3.11. This is consistent with the SARUP TSR selection criteria (SARUP Section 4.2.3, item 4). For these reasons, this TSR was not included as a SARUP TSR LCO.
2.4.3.4 X-333 Wet Air LCOs are provided in the SARUP TSRs for those fissile material Evacuation operations where double contingency could not be met Enrichment (consistent with current TSR 3.11.5). Where double contingency exists, respective NCS controls are described in the specific Nuclear Criticality Safety Approval (NCSA) and not in individual TSRs. The NCSAs are controlled by TSR 3.11. This is consistent with the SARUP TSR selection criteria (SARUP Section 4.2.3, item 4). For these reasons, this TSR was not included as a SARUP TSR LCO.
Page 39 of 54
SARUP Q&R - PGDP/ PORTS May 1,1998 Table 2. " Map" Between Existing PORTS TSRs and SARUP TSRs USEC-02 TSR Subject Location of TSR in SARUP or Basis for Not Including Section System / Control in SARUP TSRs 2.4.3.5 Reaction Products Explosive concentration limits and operating restrictions for preventing coolant / oxidant exothermic reactions are administrative controls and not active SSCs. The SARUP TSR selection criteria (SARUP Section 4.2.3, item 3) requires an LCO for active SSCs that prevent or mitigate an event that could result in life threatening or serious health effects to onsite personnel from the release of radioactive materials. Therefore, j
this TSR was not included as a SARUP TSR LCO.
2.5 Specific TSRs for Addressed in SARUP TSR Section 2.3.
X-326 ERP, X-333 l
LAW, and X-330 Tails Withdrawal Stations 2.5.1 Withdrawal Station Addressed in SARUP TSR Section 2.3.1.
Operating Modes 2.5.2.1
' aolant Pressure As described in SARUP Table 4.2-11, the event " Coolant Tube J
(Safety Limit.s)
Rupture into Primary System" (for the withdrawal facilities) does not have consequences that exceeded the PSOA threshold.
Consequently, these limits are not controls necessary to prevent an EBE which could exceed the offsite EGs. Therefore, these requirements are not identified as essential controls and do not satisfy the criteria for a SARUP TSR safety limit (reference SARUP Section 4.3.1.1.4, fourth paragraph, last sentence: Only controls selected to prevent an EBE, which could exceed the off-site EGs were considered for establishing a Safety Limit or Limiting Control Setting).
2.5.3.1 Criticality Accident LCO and SRs are addressed in SARUP TSR Section 2.3.3.3.
Alarm System Page 40 of 54
SARUP Q&R - PGDP/ PORTS May 1,1998 Table 2. " Map" Between Existing PORTS TSRs and SARUP TSRs 4
USEC-02 TSR Subject Location of TSR in SARUP or Basis for Not Including i
Section System / Control in SARUP TSRs 2.5.3.2 Coolant High As described in SARUP Table 4.2-11, the event " Coolant Tube Pressure Relief Rupture into Primary System" (for the withdrawal facilities)
System does not have consequences that exceeded the PSOA threshold.
Additionally, this system (a rupture disk) is not an active SSC.
1 The SARUP TSR selection criteria (SARUP Section 4.2.3, item
- 3) requires an LCO for active SSCs that prevent or mitigate an event that could result in life threatening or serious health effects to onsite personnel from the release of radioactive materials.
For these reasons, the coolant high pressure relief system does not satisfy the SARUP TSR LCO selection criteria. This system and operating restrictions are described in SARUP Section 3.8.3.4.
2.5.3.3 UF. Smoke LCO and SRs addressed in SARUP TSR Section 2.3.3.6.
Detectors 2.5.3.4 Pigtail Line LCO and SRs addressed in SARUP TSR Section 2.3.3.1.
Isolation System 2.5.3.5 Assay Monitoring LCOs are provided in the SARUP TSRs for those fissile material operations where double contingency could not be met (consistent with current TSR 3.11.5). Where double contingency exists, respective NCS controls are described in the specific Nuclear Criticality Safety Approval (NCSA) and not in individual TSRs. The NCSAs are controlled by TSR 3.11. This is consistent with the SARUP TSR selection criteria (SARUP Section 4.2.3, item 4). For these reasons, this TSR was not included as a SARUP TSR LCO.
2.5.3.6 Withdrawal LCOs are provided in the SARUP TSRs for those fissile material Accumulator operations where double contingency could not be met Enrichment (consistent with current TSR 3.11.5). Where double,
contingency exists, respective NCS controls are described in the specific Nuclear Criticality Safety Approval (NCSA) and not in individual TSRs. The NCSAs are controlled by TSR 3.11. This is consistent with the SARUP TSR selection criteria (SARUP Section 4.2.3, item 4). For these reasons, this TSR was not included as a SARUP TSR LCO.
Page 41 of 54
4 SARUP Q&R - PGDP/ PORTS May 1,1998 Table 2. " Map" Between Existing PORTS TSRs and SARUP TSRs USEC-02 TSR Subject Locaten of TSR in SARUP or Basis for Not Including Section System / Control in SARUP TSRs 2.5.3.7 UF. Cylinder LCOs are provided in the SARUP TSRs for those fissile material Enrichment operations where double contingency could not be met (consistent with current TSR 3.11.5). Where double contingency exists, respective NCS controls are described in the specific Nuclear Criticality Safety Approval (NCSA) and not in individual TSRs. The NCSAs are controlled by TSR 3.11. This is consistent with the SARUP TSR selection criteria (SARUP Section 4.2.3, item 4). For these reasons, this TSR was not included as a SARUP TSR LCO.
2.5.3.8 UF Cylinder Cart.
This TSR is an administrative control and does not meet the Movement SARUP TSR LCO selection criteria. Therefore, this TSR was not included as a SARUP TSR LCO. This control is identified in SARUP Section 4.3.2.2.11. SARUP TSR 3.9.1.b (revised from the existing TSR 3.9.1.b) requires implementation of SAR Chapter 4 administrative controls through written procedures.
Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO.
2.5.3.9 Liquid UF.
This TSR is an administrative control and does not meet the Cylinder Movement SARUP TSR LCO selection criteria. Therefore, this TSR was not included as a SARUP TSR LCO. This control is identified in SARUP Section 4.3.2.2.15. SARUP TSR 3.9.1.b (revised from the existing TSR 3.9.1.b) requires implementation of SAR Chapter 4 administrative controls through written procedures.
Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO.
2.5.3.10 Liquid UF.
The LCO requirements are addressed in SARUP TSR 2.3.4.2 Handling Cranes (Design Feature). This SARUP TSR and SARUP TSR 1.6.3.1, require this system to be operable prior to lifting any liquid UF.
cylinders. This system does not meet the SARUP TSR selection criteria for an LCO. SRs in the existing TSRs that require performance of OSHA inspections (SRs 2.5.3.10.3 and 2.5.3.10.4) were not included as SARUP TSR surveillance because they are not credited in the SARUP analyses. Rather, the Basis statement in the SARUP TSR requires that the cranes must meet the applicable codes and standards described in SAR l
Chapter 1, Appendix A.
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l SARUP Q&R - PGDP/ PORTS May 1,1998 Table 2. " Map" Between Existing PORTS TSRs and SARUP TSRs j
USEC-02 i
r3R Subject Location of TSR in SARUP or Basis for Not Including Section System /Controlin SARUP TSRs 2.5.3.11 Cylinder Fill This TSR is an administrative control and does not meet the Weights SARUP TSR LCO selection criteria. Therefore, this TSR was i
not included as a SARUP TSR LCO. The cylinder is only a concern if it is heated following overfilling, which is controlled by cylinder category. This control is identified in SARUP Section 4.3.2.2.2. SARUP TSR 3.9.1.b (revised from the existing TSR 3.9.1.b) requires implementation of SAR Chapter 4 administrative controls through written procedures.
Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO. Cylinder void volume requirements are included in the SARUP TSR 1.2.7 and in the Basis statements for SARUP TSRs 2.2.2.1 and 2.2.3.8.
2.5.3.12 UF Cylinder Crane This TSR is an administrative control and does not meet the 6
Movement SARUP TSR LCO selection criteria. Therefore, this TSR was not included as a SARUP TSR LCO. This control is identified in SARUP Section 4.3.2.2.15. SARUP TSR 3.9.1.b (revised from the existing TSR 3.9.1.b) requires implementation of SAR Chapter 4 administrative controls through written procedures.
Administrative controls do not normally meet the SARUP TSR selection criteria for an LCO.
2.5.3.13 UF Plugs This TSR is an administrative control that was not identified as 6
an essential control in the SARUP analyses and does not meet the SARUP TSR LCO selection criteria. Therefore, this TSR was not included as a SARUP TSR LCO.
2.5.4.1 UF Cylinder These design feature requirements and SRs are addressed in 6
Lifting Fixtures SARUP TSR Section 2.3.4.2.
(Design Feature) 2.5.4.2 UF Cylinders Design feature requirements are included in SARUP TSR 6
(Design Feature) 2.3.4.1. Existing SR 2.5.4.2.2 that requires cylinder inspections prior to fillmg or heating is not included in SARUP TSR 2.3.4.1. Instead, a statement was added to the Basis that requires cylinders containing liquid UF to meet the ANSI N14.1 6
requirements described in SAR Chapter 1, Appendix A. This addition to the Basis is more accurate and broader in scope.
Cylinder design requirements are described in SARUP Section 3.8.6.1.
Page 43 of 54
SARUP Q&R - PGDP/ PORTS May 1,1998 Table 2. " Map" Between N== PORTS TSRs and SARUP TSRs USEC-02 TSR Subject Location of TSR in SARUP or Basis for Not Including Section System / Control in SARUP TSRs 2.5.4.3 UF. Cylinder This requirement is a passive design feature with no ongoing Pigtails (Design -
surveillance requirement. Passive design features were only Feature) included in the TSRs if a specific surveillance requirement was applicable (i.e., it was not considered appropriate to include a DF in the TSR if there was no accompanying surveillance requirement). Therefore, this TSR is not included as a SARUP TSR LCO or design feature. The requirement for initial pigtail inspections is addressed in SARUP Sections 4.3.2.2.10 and 4.3.2.2.11, as an administrative control. SARUP TSR 3.9.1.b (revised from the existing TSR 3.9.1.b) requires implementation of SAR Chapter 4 administrative controls through written procedures. Pigtail design requirements are described in SARUP Section 3.8.5.4.
1 2.5.4.4 Scale Pit Raschig LCOs are provided in the SARUP TSRs for those fissile material Rings (Design operations where double contingency could not be met Feature)
(consistent with current TSR 3.11.5). Where double contingency exists, respective NCS controls are described in the specific Nuclear Criticality Safety Approval (NCSA) and not in individual TSRs. The NCSAs are controlled by TSR 3.11. This is consistent with the SARUP TSR selection criteria (SARUP Section 4.2.3, item 4). For these reasons, this TSR was not included as a SARUP TSR LCO.
2.5.4.5 Overhead Crane The requirement to test cranes that carry liquid UF. cylinders at Capacity 100% rated load is included in SARUP TSR 2.3.4.2. Other than this test, this existing TSR is a passive design feature. Passive design features were only included in the TSRs if a specific surveillance requirement was applicable (i.e., it was not considered appropriate to include a DF in the TSR if there was no accompanying surveillance requirement). Therefore, this existing design feature was not included as a " stand-alone" design feature in the SARUP TSRs.
2.6 Specific TSRs for Not included in SARUP TSRs. See below.
X-705 Facility Page 44 of 54
i SARUP Q&R - PGDP/ PORTS May 1,1998 Table 2. " Map" Between Existing PORTS TSRs and SARUP TSRs USEC-02 TSR Subject Location of TSR in SARUP or Basis for Not Including Section System /Controlin SARUP TSRs 2.6.1 X-705 Operational As discussed below, the were no controls specifically involving Modes X-705 (except CAAS) that satisfied the TSR LCO selection criteria. Therefore, these operating modes were not considered necessary for the SARUP TSRs.
2.6.2.1 Calciner Internal LCOs are provided in the SARUP TSRs for those fissile material Temperature operations where double contingency could not be met (Safety Limit)
(consistent with current TSR 3.11.5). Where double contingency exists, respective NCS controls are described in the specific Nuclear Criticality Safety Approval (NCSA) and not in individual TSRs. The NCSAs are controlled by TSR 3.11. This is consistent with the SARUP TSR selection criteria (SARUP Section 4.2.3, item 4). For these reasons, this TSR was not included as a SARUP TSR LCO.
2.6.2.2 Microfiltration LCOs are provided in the SARUP TSRs for those tissile material Effluent (Safety operations where double contingency could not be met Limit)
(consistent with current TSR 3.11.5). Where double contingency exists, respective NCS controls are described in the specific Nuclear Criticality Safety Approval (NCSA) and not in individual TSRs. The NCSAs are controlled by TSR 3.11. This is consistent with the S ARUP TSR selection criteria (SARUP Section 4.2.3, item 4). For these reasons, this TSR was not included as a SARUP TSR LCO.
2.6.2.3 Microfiltration LCOs are provided in the SARUP TSRs for those fissile material Effluent Bag Filter operations where double contingency could not be met Pressure (consistent with current TSR 3.11.5). Where double Differential (Safety contingency exists, respective NCS controls are described in the Limit) specific Nuclear Criticality Safety Appros al(NCSA) and not in individual TSRs. The NCSAs are controlied by TSR 3.11. This is consistent with the SARUP TSR selection criteria (SARUP Section 4.2.3, item 4). For these reasons, this TSR was not included as a SARUP TSR LCO.
Page 45 of 54
SARUP Q&R - PGDP/ PORTS May 1,1998 Table 2. " Map" Between Evi=*i== PORTS TSRs and SARUP TSRs USEC-02 TSR Subject Location of TSR in SARUP or Basis for Not Including Section System / Control in SARUP TSRs 2.6.3.1 Calciner High High LCOs are provided in the SARUP TSRs for those fissile material Temperature operations where double contingency could not be met Shutoff System (consistent with current TSR 3.11.5). Where double J
contingency exists, respective NCS controls are described in the specific Nuclear Criticality Safety Approval (NCSA) and not in individual TSRs. The NCSAs are controlled by TSR 3.11. This is consistent with the SARUP TSR selection criteria (SARUP Section 4.2.3, item 4). For these reasons, this TSR was not included as a SARUP TSR LCO.
2.6.3.2 Calciner Discharge LCOs are provided in the SARUP TSRs for those fissile material Collector Probe operations where double contingency could not be met Detection (consistent with current TSR 3.11.5). Where double contingency exists, respective NCS controls are described in the specific Nuclear Criticality Safety Approval (NCSA) and not in individual TSRs. The NCSAs are controlled by TSR 3.11. This j
is consistent with the SARUP TSR selection criteria (SARUP Section 4.2.3, item 4). For these reasons, this TSR was not included as a SARUP TSR LCO.
2.6.3.3 Calciner Can Level LCOs are provided in the SARUP TSRs for those fissile material Probe Detection operations where double contingency could not be met (consistent with current TSR 3.11.5). Where double contingency exists, respective NCS controls are described in the specific Nuclear Criticality Safety Approval (NCSA) and not in individual TSRs. The NCSAs are controlled by TSR 3.11. This is consistent with the SARUP TSR selection criteria (SARUP Section 4.2.3, item 4). For these reasons, this TSR was not included as a SARUP TSR LCO.
2.6.3.4 Criticality Accident LCO and SRs are addressed in SARUP TSR Section 2.4.3.3.
Alarm System Page 46 of 54 4
w
SARUP Q&R - PGDP/ PORTS May 1,1998 Table 2. " Map" Between Fri=*ing PORTS TSRs and SARUP TSRs USEC-02 TSR Subject Location of TSR in SARUP or Basis for Not including Section System /Controlin SARUP TSRs 2.6.3.5 Microfiltration pH LCOs are provided in the SARUP TSRs for those fissile material Shutdown System operations where double contingency could not be met (consistent with current TSR 3.11.5). Where double contingency exists, respective NCS controls are described in the specific Nuclear Criticality Safety Approval (NCSA) and not in 4
individual TSRs. The NCSAs are controlled by TSR 3.11. This is consistent with the SARUP TSR selection criteria (SARUP Section 4.2.3, item 4). For these reasons, this TSR was not included as a SARUP TSR LCO.
2.6.3.6 Microfiltration LCOs are provided in the SARUP TSRs for those fissile material Permeate Effluent operations where double contingency could not be met Bag Filter System (consistent with current TSR 3.11.5). Where double contingency exists, respective NCS controls are described in the specific Nuclear Criticality Safety Approval (NCSA) and not in individual TSRs. The NCSAs are controlled by TSR 3.11. This is consistent with the SARUP TSR selection criteria (SARUP Section 4.2.3, item 4). For these reasons, this TSR was not included as a SARUP TSR LCO.
2.6.3.7 Calciner Tube LCOs are provided in the SARUP TSRs for those fissile material Rotation Interlock operations where double contingency could not be met (consistent with current TSR 3.11.5). Where double contingency exists, respective NCS controls are described in the specific Nuclear Criticality Safety Approval (NCSA) and not in individual TSRs. The NCSAs are controlled by TSR 3.11. This is consistent with the SARUP TSR selection criteria (SARUP Section 4.2.3, item 4). For these reasons, this TSR was not included as a SARUP TSR LCO.
2.6.3.8 Truck Alley Oil and LCOs are provided in the SARUP TSRs for those fissile material Grease Removal operations where double contingency could not be met Unit (OGRU)
(consistent with current TSR 3.11.5). Where double contingency exists, respective NCS controls are described in the specific Nuclear Criticality Safety Approval (NCSA) and not in individual TSRs. The NCSAs are controlled by TSR 3.11. This is consistent with the SARUP TSR selection criteria (SARUP Section 4.2.3, item 4). For these reasons, this TSR was not included as a SARUP TSR LCO.
Page 47 of 54
SARUP Q&R - PGDP/ PORTS May 1,1998 Table 2. " Map" Between Existing PORTS TSRs and SARUP TSRs USEC-02 TSR Subject Location of TSR in SARUP or Basis for Not including Section System /Controlin SARUP TSRs 2.6.3.9 Microfiltration LCOs are provided in the SARUP TSRs for those fissile material Effluent Filter Press operations where double contingency could not be met Operation (consistent with current TSR 3.11.5). Where double contingency exists, respective NCS controls are described in the specific Nuclear Criticality Safety Approval (NCSA) and not in individual TSRs. The NCSAs are controlled by TSR 3.11. This is consistent with the SARUP TSR selection criteria (SARUP Section 4.2.3, item 4). For these reasons, this TSR was not included as a SARUP TSR LCO.
2.6.3.10 Moderation Control LCO and SRs addressed in SARUP TSRs, Section 2.4.3.4.
2.6.4.1 Handtable LCOs and Design Features are provided in the SARUP TSRs for Overflows (Design those fissile material operations where double contingency could Feature) not be met (consistent with current TSR 3.11.5). Where double contingency exists, respective NCS controls are described in the specific Nuclear Criticality Safety Approval (NCSA) and not in individual TSRs. The NCSAs are controlled by TSR 3.11. This is consistent with the SARUP TSR selection criteria (SARUP Section 4.2.3, item 4). For these reasons, this TSR was not included as a SARUP TSR Design Feature.
2.6.4.2 Air Gaps (Design LCOs and Design Features are provided in the SARUP TSRs for Feature) those fissile material operations where double contingency could not be met (consistent with current TSR 3.11.5). Where double contingency exists, respective NCS controls are described in the specific Nuclear Criticality Safety Approval (NCSA) and not in individual TSRs. The NCSAs are controlled by TSR 3.11. This is consistent with the SARUP TSR selection criteria (SARUP Section 4.2.3, item 4). For these reasons, this TSR was not included as a SARUP TSR Design Feature.
Page 48 of 54
SARUP Q&R - PGDP/ PORTS May 1,1998 Table 2. " Map" Between Existing PORTS TSRs and SARUP TSRs USEC-02 TSR Subject Location of TSR in SARUP or Basis for Not including Section System /Controlin SARUP TSRs 2.6.4.3 Diked Areas LCOs and Design Features are provided in the SARUP TSRs for (Design Feature) those fissile material operations where double contingency could not be met (consistent with current TSR 3.11.5). Where double contingency exists, respective NCS controls are described in the specific Nuclear Criticality Safety Approval (NCSA) and not in individual TSRs. The NCSAs are controlled by TSR 3.11. This is consistent with the SARUP TSR selection criteria (SARUP Section 4.2.3, item 4). For these reasons, this TSR was not included as a SARUP TSR Design Feature.
2.6.4.4 Tank Covers LCOs and Design Features are provided in the SARUP TSRs for (Design Feature) those fissile material operations where double contingency could not be met (consistent with current TSR 3.11.5). Where double contingency exists, respective NCS controls are described in the specific Nuclear Criticality Safety Approval (NCSA) and not in individual TSRs. The NCSAs are controlled by TSR 3.11. This is consistent with the SARUP TSR selection criteria (SARUP Section 4.2.3, item 4). For these reasons, this TSR was not included as a SARUP TSR Design Feature.
2.7 Specific TSRs for Addressed in SARUP TSR Section 2.1.
X-326 Cascade Facility 2.7.1 X-326 Cascade Addressed in SARUP TSR Section 2.1.1, Operational Modes 2.7.2.1 Cell Coolant SARUP Section 4.3.2.1.6 analyzed the accident addressed by Pressure (Safety this TSR. If left unmitigated, this event does not exceed offsite Limit)
EGs. Therefore, the coolant system pressure requirements are not identified as essential controls and do not satisfy the criteria for a SARUP TSR safety limit (reference SARUP Section 4.3.1.1.4, founh paragraph, last sentence: Only controls selected to prevent an EBE, which could exceed the off-site EGs were considered for establishing a Safety Limit or Limiting Control Setting).
Page 49 of 54
T SARUP Q&R - PGDP/ PORTS May 1,1998 Table 2. " Map" Between Frida= PORTS TSRs and SARUP TSRs USEC-02 TSR Subject Location of TSR in SARUP or Basis for Not Including Section System /Controlin SARUP TSRs 2.7.2.2 Cascade Pressure SARUP Section 4.3.2.1 analyzed cascade facility accidents. In (Safety Limit) no scenario was cascade pressure determined to be a control
]
necessary to prevent an EBE which could exceed the offsite EGs. Therefore, the cascade system pressure requirements are not identified as essential controls and do not satisfy the criteria for a SARUP TSR safety limit (reference SARUP Section 4.3.1.1.4, fourth paragraph, last sentence: Only controls selected to prevent an EBE, which could exceed the off-site EGs were considered for establishing a Safety Limit or Limiting Control Setting).
2.7.3.1 Coolant High SARUP Section 4.3.2.1.6 analyzed the accident addressed by Pressure Relief this TSR. The coolant high pressure relief system is not System identified as an essential control for this accident. Additionally, this system (a rupture disk) is not an active SSC. For these reasons, this system does not satisfy the SARUP TSR LCO selection criteria. This system is described in SARUP Section 3.8.3.4.
2.7.3.2 Criticality Accident LCO and SRS are addressed in SARUP TSR Section 2.1.3.3.
Alarm System Page 50 of 54
SARUP Q&R - PGDP/ PORTS May 1,1998 Table 2. " Map" Between Existing PORTS TSRs and SARUP TSRs I USEC-02 TSR Subject Location of TSR in SARUP or Basis for Not Including Section System / Control in SARUP TSRs 2.7.3.3 High Pressure Fire LCO and SRs are address.ed in SARUP TSRs 2.1.3.5 Water System (Sprinklers),2.4.3.1 (Fire Water Pumps), and 2.4.3.2 (Fire Water Storage Tanks). SARUP TSR SRs were revised from the existing TSR SRs. SRs were added from the existing TSRs t
.vhile several SRs were deleted as follows:
(a)
The annual verification of supervisory alarms (USEC-02 TSR 2.7.3.3.7) was replaced with the monthly verification of control and sectionalizing valve alignment
)
(SARUP TSR 2.1.3.5-1) because the monthly check is j
considered more reliable than the annual check of the supervisory alarm system.
)
(b)
The arnual automrtic start test of the electric high pressure fire 3r pumps was deleted and replaced with a monthly requirement to manually start the high i
pressure fire water pumps locally and from the X-300.
i The automatic start feature does not exist for diesel fire pumps and this pump feature is not relied upon in the accident analysis. Furthermore, the addition of a monthly start test from the X-300 building provides added assurance that if the fire water storage tank level falls to the point where fire pumps are needed, a PCF i
operator action can start the operable pumps.
(c)
A SR was added to verify on a monthly basis that the water supply tanks for the pumps contain sufficient inventory.
2.7.3.4 Coolant Removal Explosive concentration limits and operating restrictions for preventing coolant / oxidant exothermic reactions are administrative controls and not active SSCs. The SARUP TSR selection criteria (SARUP Section 4.2.3, item 3) requires an LCO for active SSCs that prevent or mitigate an event that could result in life threatening or serious health effects to onsite personnel from the release of ndicactive materials. Therefore, this TSR was not included as a SARUP TSR LCO.
\\
Page 51 of 54 c
4.c.
SARUP Q&R - PGDP/ PORTS -
May 1,1998 Table 2. " Map" Between Exishg PORTS TSRs and SARUP TSRs USEC-02 TSR Subject Location of TSR in SARUP or Basis for Not Including Section System / Control in SARUP TSRs 2.7.3.5 Cell Treatment Explosive concentration limits and operating restrictions for Monitoring preventing coolant / oxidant exothermic reactions are administrative controls and not active SSCs. The SARUP TSR selection criteria (SARUP Section 4.2.3, item 3) requires an LCO for active SSCs that prevent or mitigate an event that could result n life threatening or serious health effects to onsite i
personnel from the release of radioactive materials. Tiserefore, this TSR was not included as a SARUP TSR LCO.
2.7.3.6 Cell Inverse Explosive concentration limits and operating restrictions for Recycle Treatment preventing coolant / oxidant exothermic reactions are j
administrative controls and not active SSCs. The SARUP TSR selection criteria (SARUP Section 4.2.3, item 3) requires an j
LCO for active SSCs that prevent or mitigate an event that could result in life threatening or serious health effects to onsite personnel from the release of radioactive materials. Therefore, this TSR was not included as a SARUP TSR LCO.
2.7.3.7 Oxidant Control Explosive concentration limits and operating restrictions for preventing coolant / oxidant exothermic reactions are administrative controls and not active SSC The SARUP TSR selection criteria (SARUP Section 4.2.3, i.am 3) requires an LCO for active SSCs that prevent or mitigate an event that could result in life threatening or serious health effects to onsite personnel from the release of radioactive materials. Therefore, j
this TSR was not included as a SARUP TSR LCO.
2.7.3.8 Freon Degrader Explosive concentration limits and operating restrir.tions for preventing coolant / oxidant exothermic reactions are administrative controls and not sc ive SSCs. The SARUP TSR selection criteria (SARUP Section 4.2.3, item 3) requires an LCO for active SSCs that prevent or mitigate an event that could result in life threatening or serious health effects to onsite personnel from the release of radioactive mate-ials. Therefore,
)
this TSR was not included as a SARUP TSR LCO.
1 l
Page 52 of 54 4
I c
SARUP Q&R - PGDP/ PORTS May 1,1998 Table 2. " Map" Between Existing PORTS TSRs and SARUP TSRs t.
F USEC-02 TSR Subject Location of TSR in SARUP or Basis for Not Including Section System / Control in SARUP TSRs 2.7.3.9 Freon Degrader Explosive concentration limits for preventing coolant / oxidant Fluorine Flow exothermic reactions are administrative controls and not active SSCs. The SARUP TSR selection criteria (SARUP Section 4.2.3, item 3) requires an LCO for active SSCs that prevent or mitigate an event that could result in life threatening or serious health effects to onsite personnel from the release of radioactive materials. Therefore, this TSR was not included as a SARUP TSR LCO.
2.7.3.10 Side Feed Cylinders As discussed in SARUP Section 3.8.6, small cylinders (those with capacities of less than or equal to 500 lb) do not have the capacity to cause significant offsite effects in the event of a release of UF from the cylinder. The cylinders addressed by 6
this existing TSR have capacities of less than 500 lb.
Furthermore, this TSR is an administrative control and does not meet the SARUP TSR LCO selection criteria. For these reasons, this TSR is not included as a SARUP TSR LCO.
2.7.3.11 UF Plugs This TSR is an administrative control that was not identified as 6
an essential control in the SARUP analyses and does not meet the S ARUP TSP. LCO selection criteria. Therefore, this TSR was not included as a SARUP TSR LCO.
2.7.3.12 Cascade Pressure SARUP Section 4.3.2.1 analyzed cascade facility accidents. In Limitation no scenario was cascade pressure determined to be an essential control or an operating restriction that meets any of the SARUP TSR LCO selection criteria. Therefore, the cascade system pressure requirements were not included as a SARUP TSR LCO.
2.7.3.13 Cascade DC LCO and SRs are addressed in SARUP TSR Section 2.1.3.1.
Control Power 2.7.3.14 Moderation Control LCO and SRs are addressed in SARUP TSR Section 2.1.3.6.
2.7.3.15 Removed I CO and SRs are addressed in SARUP TSR Section 2.1.3.7.
Equipment with Deposits Page 53 of 54 il
SARUP Q&R - PGDP/ PORTS May 1,1998 Table 2. " Map" Between N== PORTS TSRs and SARUP TSRs USEC-02 TSR Subject Location of TSR in SARUP or Basis for Not Including Section System / Control in SARUP TSRs 2.7.4.1 Seal Exhaust Pump LCOs and Design Features are provided in the SARUP TSRs for Overflows (Design those fissile material operations where double contingency could Feature) not be met (consistent with current TSR 3.11,5). Where double contingency exists, respective NCS controls are described in the specifa Nuclear Criticality Safety Approval (NCSA) and not in individual TSRs. The NCSAs are controlled by TSR 3.11. This is consistent with the SARUP TSR selection criteria (SARUP Section 4.2.3, item 4). For these reasons, this TSR was not included as a SARUP TSR Design Feature.
2.8 Specific TSRs for Not included in SARUP TSRs. See below.
X-710 Laboratory 2.8.1 X-710 Laboratory There were no controls specifically involving X-710 (except Operational Modes CAAS) that satisfied the TSR LCO selection criteria. Therefore, these operating modes were not considered necessary for the SARUP TSRs.
2.8.3.1 Criticality Accident LCO and SRs addressed in SARUP TSR Section 2.4.3.3.
Alarm System 3.0 Administrative Addressed in SARUP TS'R Section 3.0. Cold recovery was Controls deleted from current TSR Table 3.2.2-1 because cold recovery is not addressed in the SARUP TSRs.
i l
l Page 54 of 54 i