ML20247N539
| ML20247N539 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 05/13/1998 |
| From: | John Miller UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Paperiello C NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| GDP-98-0039, GDP-98-39, NUDOCS 9805270177 | |
| Download: ML20247N539 (12) | |
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r USEC A Global Energy Company JAMES H. MILLER Dir: (301) 564-3309 j
VICE PRESIDENT, Pr<ODUCTION Fax: (301) 571-8279 May 13.1998 GDP 98-0039 i
Dr. Carl J. Paperiello Director, Office of Nuclear Material Safety and Safe 3uards Attention: Document Control Desk U.S. Nuclear. Regulatory Commission Washington, D.C. 20555-0001 Paducah Gaseous Diffusion Plant (PGDP)
Docket No. 70-7001 Certificate Amendment Request - CAAS Cluster Addition to TSR 2.6.4.1; CAAS Surveillance i
Frequency Revision for TSR 2.3.4.7; Cross Reference Revision for TSR 2.2.4.4
Dear Dr. Paperiello:
In accordance with 10 CFR Part 76.45, the United States Enrichment Corporation (USEC or Corporation) hereby submits a request for amendment to the certificate of compliance for the Paducah, Kentucky Gaseous Diffusion Plant (GDP). This certificate amendment request revises Technical Safety Requirements (TSRs) 2.3.4.7 and 2.6.4.1, Criticality Accident Alarm Systems, and TSR 2.2.4.4, Cylinder Heating-Cylinder Accountability Weight.
t The current surveillance frequency associated with Surveillance Requirement 2.3.4.7a-1 requires a quarterly surveillance for the calibration of the Criticality Accident Alarm System (CAAS) equipment
- hich is more frequent than the surveillance frequency associated with the identical CAAS surveillance j
w requirernent in other PGDP facilities. This amendment request revises the current feed facility CAAS surveillance frequency to agree with the CAAS surveillance frequency in the other PGDP facilities.
TSR 2.6.4.1 provides requirements for the CAAS in non-cascade facilities. Currently, two CAAS clusters, designated AC and AD, are located within C-746-Q-1. Cluster AC was not addressed in the current TSR since this cluster was originally under the control of DOE. USEC has reached an agreement with DOE to operate and maintain cluster AC. This certificate amendment request revises the applicability table of TSR 2.6.4.1 to include CAAS cluster AC.
TSR Section 2.2 provides specific TSRs associatehith the UF Feed Facilities. TSR 2.2.4.4, Cylinder 6
Heating-Cylinder Accountability Weight, Required Action A.2.1, currently contains an incorrect cross,,
reference to the Toll Transfer and Sampling Facility TSRs. The revisinn to TSR 2.2.4.4 contained in this certificate amendment request revises this TSR to reference the appropriate Feed Facility TSR.
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6903 Rockledge Drive, P>ethesda, MD 208174 818 7.,,.,
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9905270177 955513'
~ 'ucah, KY Pommouth. OH Washington, DC
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Dr. Carl J. Paperiello May_13,1998 '
GDP 98-0039, Page 2 to this letter provides a detailed description and justification for the proposed changes. contains the revised TSR pages associated with this request which are provided for your review and approval. Enclosure 4 contains the basis for USEC's determinatica that the proposed changt.s associated with this certificate amendment request are not significant.
There is currendy no immediate plant operational impact requiring prompt review of this certificate}
amendment request. Therefmt, USEC requests NRC review and approval of this certificate amendment request as soon as actical.- The amendment should become effective 30 days from issuance.
Any questions related E this subject should be directed to Mark Smith at (301) 564-3244. There are no new commitments contained within this submittal.
~ Sincerely, Jam -
- 1. Miller Vi resident, Production -
Enclosures:
- 1. Affidavit
- 2. United States Enrichment Corporation (USEC), Proposed Certificate Amendment Request, CAAS Cluster Addition to TSR 2.6.4.1; CAAS Surveillance Frequency Revision for TSR 2.3.4.7; Cross Reference Revision for TSR 2.2.4.4, Detailed Description of Change
- 3. Proposed Certificate Amendment Request, Paducah Gaseous DitTusion Plant, Letter GDP 98-0039, Removal / Insertion Instructions
- 4. United States Enrichment Corporation (USEC), Proposed Certificate Amendment Request, CAAS Cluster Addition to TSR 2.6.4.1; CAAS Surveillance Frequency Revision for TSR 2.3.4.7; Crcss Reference Revision for TSR 2.2.4.4, Significance
' Determination ec: Mr. Robert C. Pierson, NRC NRC Region III Office NRC Resident Inspector-PGDP 2
NRC Resident Inspector - PORTS Mr. Randail M. DeVault, DOE i
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OATH AND AFFIRMATION I, James II. Miller, swear and aflirm that I am Vice President, Production, of the United States Enrichment Corporation (USEC), that I am authorized by USEC to sign and file with the Nuclear Regulatory Commission this Certificate Amendment Request for the Paducah Gaseous Diffusion Plant, addressing revisions to the Criticality Accident Alarm System and Cylinder Heating-Cylinder Accountability Weight Technical Safety Requirements as contained in USEC Letter GDP 98-0039, that I am familiar with the contents thereof, and that the statements made and matters set forth therein are true and correct to the best cf my knowledge, information, and belief.
James H. Miller On this 13th day of May,1998, the officer signing above personally appeared before me, is known by me to be the person whose name is subscribed to within the instrument, and acknowledged that he executed the same for the purposes therein contained.
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In witness hereofI hereunto set my hand and official seal.
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Wut b]-
udLeib 1)turie M. Knisley, Notary Public[/
State of Maryland, Montgomery Co6nty My commission expires March 1,2002 l
GDP 98-0039 Page 1 of 3 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request CAAS Cluster Addition to TSR 2.6.4.1 CAAS Surveillance Frequency Revision for TSR 2.3.4.7 Cross Reference Revision for TSR 2.2.4.4 Detailed Description of Change A.
TSR Surveillance Requirement (SR) 2.3.4.7a-1 surveillance frequency is being changed from quarterly to annually.
The detection portion ofeach Criticality Accident Alarm System (CAAS) TSR (2.1.4.5,2.2.4.3, 2.3.4.7,2.4.4.2, and 2.6.4.1) includes a surveillance requirement to cahbrate the CAAS system equipment. Revision 4 of the Application for certification correctly listed the surveillance frequency for all five Surveillance Requirements as " annually." At the time that revision 5 of the Application was submitted, all five of the CA AS TSRs noted above were revised to resolve NRC comments. None of the comments o: issues addressed in the Revision 5 submittal related to the surveillance frequency for the CAAS system equipment calibration. Therefore, USEC did not propose any change to this surveillance frequency in Revision 5 of the Application.
However, c ue to an editorial error in the Revision 5 submittal, the TSR for the Product and Tails Withdrawal Facilities (2.3.4.7) inadvertently specified the surveillance frequency for calibration of the CAAS system equipment as quarterly. All of the other CAAS TSRs correctly specified the corresponding surveillance frequency as annually. This change request proposes to correct this editorial error to restore consistency between the CAAS TSRs for all of the facilities with respect to the frequency associated with performance of the CAAS equipment calibration.
B.
TSR Limiting Condition for Operation (LCO) 2.6.4.1 is being revised to add cluster "AC" to l
the applicability table for building C-746-Q-1.
i For C-746-Q-1, TSR 2.6.4.1 currently applies only to cluster "AD." The "AC" cluster has been l
under the control of DOE. Recently, USEC reached an agreement with DOE to operate and l
maintain the "AC" cluster. In order for USEC to operate the equipment under NRC regulation, l
the TSR scope needs to be revised to add this cluster to the applicability table of TSR 2.6.4.1.
C.
TSR 2.2.4 4, Required Action A.2.1 is being revised to correct the cross reference within this l
required action from TSR 2.1.3.3 to TSR 2.2.3.3.
l Feed Facilities 1 SR 2.2.4.4, Cylinder Heating-Cylinder AccountabilityWeight, Required Action A.2.1, currently contains a cross reference to TSR 2.1.3.3, which is a TSR for the Toll Transfer and Sampling Facility. As opposed to cross referencing th: Toll Transfer and Sampling Facility, the appropriate cross reference for TSR 2.2.4.4, should be to the Feed Facility TSRs.
Therefore, TSR 2.2.4.4, Required Action A.2.1 has been revised to cross reference TSR 2.2.3.3, which is the appropriate Feed Facility TSR for this required action.
Enclocure 3 GDP 98-0039 4 Pages Proposed Certificate Amendment Request Paducah Gaseous Diffusion Plant Letter GDP98-0039 Removal /Incertinn Instructinne Remove Page Inserthe Volumc 4 Section 2.2 Section 2.2 Page 2.2-19 Page 2.2-19 Section 2.3 Section 2.3 i
Page 2.3-20 Page 2.3-20
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i Section 2.6 Section 2.6 Page 2.6-3 Page 2.6-3 i
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'TSR-I DP PROPOSED May 13,1998 RAC 98C006 (RO) j SECTION 2.2 SPECIFIC TSRs FOR UF FEED FACILITIES (C-333-A AND C-337-A) i 2.2.4 GENERAL LIMITING CONDITIONS FOR OPERATION 2.2.4.4 CYLINDER IIEATING - CYLINDER ACCOUNTABILITY WEIGIIT LCO 2.2.4.4:
Cylinder accountability (net) weight shall be verified less than or equal to the
" Max. Fill Limit for Shipment" for cylinders other than tails cylinders and " Max.
3 Fill Limit for In-Plant Tails Storage" for tails cylinders stated m TSR Section 2.2, Appendix A prior to heating the cylinder.
APPLICABILITY: Modes: 5 ACTIONS:
Condition Required Action Completion i
Time A.
Accountability A.1 Calculate the cylinder void volume (ullage) at a Prior to entering weight exceeds temperature of 230*F and/or 235*F. Use the stamped mode 5 the Maximum water weight as the basis of the actual volume of Fill Limit for cylinders with certified volumes, or use the minimum Shipment for design volume (based on all minimum design cylmders other tolerances) for cylinders without certified valumes in than tails the calculation. Determine the category of the cylinder cylinders, or based on the following criteria:
the Maximum 11 Limit for Cat. A Void volume 25% at 235'F Plan * ' ai'.
9 or S age.ar Void volume 23% at 235"F for cylinders filled with tais cylinders.
high purity tails Cat. B Void volume 25% at 230*F or Void volume 23% at 230*F for cylinders filled with high purity tails Cat. C Void volume <5% at 230*F old volume <3% at 230"F for cylinders filled,with high purity tails AND A.2.1 Set the Autoclave Steam Pressure Control System setpoint consistent with the cylinder category per TSR i
2.2.3.3 for a Category A or B cylinder. The autoclave l
temperature / pressure controller setpoint shall not be set less than 219.9*F.
DE A.2.2 Administratively conhol the Catego7d/controlledC cylinder to l
prevent heating until such time as co feeding is re-instituted as an operating mode, t
2.2-19
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TSR-PGDP PROPOSED May 13,1998 RAC 97C?A5 (RO)
,SECTION 2.3 SPECIFIC TSRs FOR PRODUCT AND TAILS WITHDRAWAL FACILITIES 2.3.4 GENERAL LIMITING CONDITIONS FOR OPERATION 2.3A.7 CRITICALITY ACCIDENT ALARM SYSTEM (continued)
SURVEILLANCE REQUIREMENTS:
Surveillance Frequency SR 2.3.4.7a-1 Calibrate CAAS system equipment.
Annually l
1 BASIS:
The CAAS is used to warn plant personnel of a criticality or radiation accident. This system is designed to detect radiation and provide a distinctive, audible signal which will alert personnel to move from those work areas which are potentially affected. The design of the system, three detector modules per cluster, provides protection for criticality events even with partial losses of required equipment. The CAAS also provides detection coverage in most areas by using an overlapping pattern ofindividual cluster units. Criticality concerns with tre product withdrawal facility are associated with the movement of fissionable materials. The action items maintain the facility in steady state operations to limit the potential for these concerns to the extent possible.
Providing another means of coverage (i.e., portable detector / alarm, personal alarm device),
restricting operations, or restricting access to the area in the event of the loss of detection will establish protection. [SAR Chapter 4, Appendix A, Section 2.5.1.1.2, SAR 5.2, ANSI /ANS 8.3]
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TSR-PGDP PROPOSED May 13,1998 RAC 97C245 (RO)
SECTION 2.6 SPECIFIC TSRs FOR CAAS (NON-CASCADE FACILITIES) 2.6.4 GENERAL LIMITING CONDITIONS FOR OPERATION 2.6.4.1 CRITICALITY ACCIDENT ALARM SYSTEM i
LCO 2.6.4.la:
Criticality accident detection shall be operable.
APPLICABILITY: In areas, equipment, or processes in the facilities listed in the table below 235 which contain greater than 700 grams of U at an enrichment greater than 2
or equal to 1.0 wt % 35U.
Building / Facility Number Building / Facility Name CAAS Cluster and/or Function F
C-400 Cleaning Building D. E C-409 Stabilization Building P.AE C-710 Technical Services Building AG. AH. Port 1*, Port 2**
C-720, C-720M, C-720K, Maintenance and Stores AL C-720R, C-720S Buildings C-720-C Converter Shop Addition AL C-728 Motor Cleaning Facility AL C-746-Q-1 High Assay Waste Storage AC,AD l
- Until replaced by a permanent cluster.
- Until Port 1 is connected to the building alarm system.
2.6-3 l
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GDP98-0039 Page1of4 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request CAAS Cluster Addition to TSR 2.6.4.1 CAAS Surveillance Frequency Revision for TSR 2.3.4.7 Cross Reference Revision for TSR 2.2.4.4 Significance Determination The United States Enrichment Corporation (USEC) has reviewed the proposed changes associated with this certificate amendment request and provides the following Significance Determination for consideration.
- 1. No Overall Decrease in the EtTectiveness of the Plant's Safety. Safecuards or Security Procrams The Technical Safety Requirements (TSRs) are not addressed in plant safety, safeguards or security programs contained in Volume 3 of the Application for United States Nuclear Regulatory Commission Certification for the Paducah Gaseous Diffusion Plant. Therefore, the effectiveness of these programs is unafTected by these changes.
- 2. No Significant Change to Any Conditions to the Certificate of Compliance Nene of the Conditions to the Certificate of Compliance for operation of the Paducah Gaseous Diffusion Plants specifically address the Technical Safety Requirements sections affected by this certificate amendment request. Thus, the proposed changes have no impact on any C ndition to the Certificate of Compliance.
- 3. No Significant Change to Any Condition of the Approved Comnliance Plan The changes requested in TSRs 2.2.4.4, 2.3.4.7, or 2.6.4.1 are not addressed in any issue described in the Compliance Plan. The proposed changes do not involve any commitments contained in the Compliance Plan and do not change or invalidate any of the approved compensatory measures described in the approved Compliance Plan. Therefore, there is no significant change to any condition of the approved compliance plan.
- 4. No Significant Increase in the Probability of Occurrence or Consequences of Previousiv Eyaluated Accidents The proposed change to TSR 2.3.4.7 revises the surveillance frequency for calibration of the CA AS system equipment to be consistent with the CAAS surveillance frequency for other PGDP l-facilities. This change corrects an inadvertent editorial error contained in Revision 5 of the Application for Certification. In addition, an additional cluster is being added to the applicability table of TSR 2.6.4.1 which increases the amount of CAAS coverage for the C-746-Q-1 facility.
Finally, TSR 2.2.4.4 is being revised to reflect the appropriate cross reference for the required
a GDi@8-0039 Page 2 0f 4 i
United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request CAAS Cluster Addition to TSR 2.6.4.1 CAAS Surveillance Frequency Revision for TSR 2.3.4.7 4
Cross Reference Revision for TSR 2.2.4.4
- Significance Determination action associated with this TSR. These proposed changes enhance the current TSRs. Therefore, I
these changes do not increase the probability or consequences of an evaluated accident.
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- 5. No New or Different Tyne of Accident j
The proposed change to TSR 2.3.4.7 corrects the surveillance frequency for calibration of the CAAS system equipment to be consistent with the other CAAS TSRs. This change corrects an inadvertent editorial error contained in Revision 5 of the Application for Certification. In addition, an additional cluster is being added to the applicability table of TSR 2.6.4.1. This increases the amount of CAAS coverage for the C-746-Q-1 facility. Finally, TSR 2.2.4.4 is being i
revised to reflect the appropriate cross reference for the required action associated with this TSR.
l Therefore, these proposed changes enhance the current TSRs and do not result in a new or different type of accident.
- 6. No Significant Reduction in Margins of Safety The proposed change to TSR 2.3.4.7 corrects the surveillance frequency for calibration of the CAAS system equipment to be consistent with the other CAAS TSRs. This change corrects an inadvertent editorial error contained in Revision 5 of the Application for Certification. In addition, an additional cluster is being added to the applicability table of TSR 2.6.4.1. This increases the amount of CAAS coverage for the C-746-Q-1 facility. Finally, TSR 2.2.4.4 is being revised to reflect the appropriate cross reference for the required action associated with this TSR.
These changes enhance the curreat TSR. As such, there is no significant reduction in the Margins of Safety associated with these TSRs.
- 7. No Significant Decrease in the Effectiveness of Any Program or Plan Contained in the Certificate Annlication TSRs 2.2.4.4,2.3.4.7 and 2.6.4.1 are not specifically addressed in any of the programs or plans coraained in Volume 3 of the Certification Application. Therefore, the changes to these TSRs discussed above do not reduce the effectiveness of any program or plan contained in the Certification Application.
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GDP98-0039 Page 3 of 4 United States Enrichment Corporation (USEC)
Proposed Certificate Amcudment Request CAAS Cluster Addition to TSR 2.6.4.1 CAAS Surveil';,ue Frequency Revision for TSR 2.3.4.7 Cross Reference Revision for TSR 2.2.4.4 Significance Determination
- 8. The Proposed Changes do not Result in Undue Risk to 1) Public Health and Safety. 2) Common Defense and Security. and 3) the Environment.
The proposed TSR change corrects the surveillance fiequency for calibration of the CAAS system equipment to be consistent with the other CAAS TSRs and the basis statement. This change corrects an inadvertent editorial error contained in Revision 5 of the Application for Certification. In addition, an additional cluster is being added to the applicability table of TSR 2.6.4.1. This increases the amount of CAAS coverage for the C-746-Q facility. These changes enhance the CAAS system. TSR 2.2.4.4 is revised to provide a cross reference to the appropriate Feed Facility TSR as opposed to the current cross reference to the Toll Transfer and Sampling TSR. As such, these changes do not result in undue risk to public health and safety. In addition, these changes have no impact on plant effluents or on the programs and plans in place to implement physical security. Consequently, these proposed changes only enhance safety and pose no undue risk to the environment or to common defense and security.
- 9. No Change in the Types or Significant Increase in the Amounts of Any Effluents that May be Released Offsite This change has no affect on the generation or disposition of effluents. Therefore, this change does not change the type or amounts of effluents that may be released offsite.
- 10. No Significant Increase in Individual or Cumulative Occupational Radiation Exnosure The proposed changes involve revision of the existing CAAS and Cylinder Accountability Weight TSRs. The CAAS is not used to control or minimize occupational radiation exposures or to comply with 10 CFR 20 requirements. The change to TSR 2.3.4.7 revises the surveillance frequency, consistent with the CAAS surveillance frequency for other facilities, to an annual basis. This change may, in fact, decrease the occupational exposure by reducing the number of surveillance required to be performed on the Feed Facility CAAS. Therefore, this change does not result in a significant increase in individual or cumulative occupational radiation exposure.
11 No Significant Construction Impact This TSR change does not involve a plant modification. Therefore, there is no significant construction impact.
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GDP98-0039 Page 4 of 4 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request CAAS Cluster Addition to TSR 2.6.4.1 CAAS Surveillance Frequency Revision for TSR 2.3.4.7 Cross Reference Revision for TSR 2.2.4.4 Significance Determination l
- 12. No Significant Increase in the Potential for. or Radiological or Chemical Consequences from.
l Previously Analyzed Accidents i
The proposed change to TSR 2.3.4.7 corrects the surveillance frequency for calibration of the CAAS system equipment to be consistent with the other CAAS TSRs. This change corrects an
. inadvertent editorial error contained in Revision 5 of the Application for Certification. In addition, an additional cluster is being added to the applicability table of TSR 2.6.4.1. This increases the amount of CAAS coverage for the C-746-Q-1 facility. Finally, TSR 2.2.4.4 is being revised to reflect the appropriate cross reference for the required action associated with this TSR. The changes to the CAAS proposed in this certificate amendment request enhance the CAAS function. The CAAS is used to mitigate the consequences of an accident by notifying workers of the need to evacuate, and has no impact on the potential for occurrence of an j
accident. The revision to TSR 2.2.4.4 corrects the cross reference in the current TSRs and has no impact upon either the potential for an accident or the resulting consequences. Therefore, these changes do not increase the potential far, or radiological or chemical consequences from, previously analyzed accidents.
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