ML20248J207
| ML20248J207 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 05/29/1998 |
| 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-98-0115, GDP-98-115, TAC-L32045, NUDOCS 9806090027 | |
| Download: ML20248J207 (9) | |
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janes H. MILLER Dir- (301) 564-3309 Vice PRESIDENT, PRODUCTION Fax:(301) 571-8279 i
i May 29,1998 I
l GDP 98-0115 l
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Dr. Carl J. Paperiello Director, Office of Nuclear Material Safety and Safeguards Attention: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Portsmouth Gaseous Diffusion Plant (PORTS)
Docket No. 70-7002 Response to Request for AdditionalInformation Certificate Amendment Request - TSR Section 2.1.3.11 - Autoclave Smoke Detection System J
Dear Dr. Paperiello:
i The purpose of this letter is to provide the final response to the NRC's request (TAC No. L32045) for l
additional information regarding the Certificate Amendment Request (CAR) for Technical Safety Requirement (TSR) 2.1.3.11, involving the mimmum number of autoclave area smoke detectors required )
to be operable. The original CAR was submitted in Reference 1. The request for additional information was provided to United States Enrichment Corporation (USEC or Corporation) in Reference 2. An initial /
response to this request for additional information was provided in Reference 3. This initial response l
stated that a revision to the proposed TSR 2.1.3.11 would be submitted to the NRC that addresse l
l situations where there are fewer than four (4) smoke detector heads (total) operable in X-343 i
Accordingly, USEC hereby submits a revised Technical Safety Requirement for the Portsmouth, Ohio l
Gaseous Diffusion Plant (GDP). This revised TSR incorporates the aforementioned information into the l
proposed TSR 2.1.3.11 and are replacement pcges for those pages previously submitted in Reference 1.
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h 9806090027 980529 PDR ADOCK 07007002 C
PDR l
6903 Rockledge Drive. Bethesda. MD 20817 1818 l
Telephone 301-564-3200 Fax 301-564-3201 http://www.usec.com u80029 flices in Liverm re, CA Paducah, KY Portsmouth. OH Washington. DC
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Dr. Carl J. Paperiello May 29,1998 GDP 98-0115, Page 2
,. provides a detailed description andjustification for the proposed change. Enclosure 3 is a L
copy of the revised TSR pages. The conclusions stated in Enclosure 3 to the original CAR (Reference 1), that the proposed changes associated with the CAR are not significant, are not affected by this revision.
'Any questions related to this subject should be ud to Mr. Mark Smith at (301) 564-3244. There are l
no new commitments contained in this submittal.
Sincerely, b
J H. Miller
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President, Production
Enclosures:
- 1. Affidavit
- 2. United States Enrichment Corporation (USEC), Proposed Changes, Certificate Amendment Request, TSR section 2.1.3.11, Autoclave Smoke Detector System
- 3. Proposed Certificate Amendment Request, Portsmouth Gaseous Diffusion Plant, Letier GDP 98-0115, Removal / Insertion Instructions cc: Mr. Robert C. Pierson (NRC)
NRC RegionIII Office NRC Resident Inspector-PORTS NRC ResidentInspector-PGDP Mr. Randall M. DeVault (DOE)
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I Dr. Carl J. Paperiello
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May 29,1998 GDP 98-0115, Page 3 REFERENCES l-
- 1. Letter from James H. Miller (USEC) to Dr. Carl J. Paperiello (NRC), Certificate Amendment Request -TSR Section 2.1.3.11 - Autoclave Smoke Detection System, USEC Letter GDP 97-0128, July 30,1997.
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- 2. Letter from R. Pierson (NRC) to J. Miller (USEC), Certificate Amendment Request - Minimum Number of Autoclave Area Smoke Detector Alarm Circuits Required to be Operable - Request for Additional Information (TAC No. L32045), March 19,1998.
- 3. Letter from S. Toelle (USEC) to C. Paperiello (NRC), Response to Request for Additional Information - Certificate Amendment Request - TSR 2.1.3.11, Autoclave Smoke Detection System, April 17,1998.
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OATH AND AFFIRMATION I, James H. Miller, swear and afErm 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 Portsmouth Gaseous Diffusion Plant addressing revisions to TSR 2.1.3.11, Autoclave Smoke Detection System, es described in GDP 98-0115, that I am familiar with the contents thereof, and that the statements made and matters set forth therein are true and correct to the best of my knowledge, information and belief.
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James H. Miller On this 29th day of May 1998, the ofBcer signing above personally appeared before me, is known by l
me to be the person whose name is subscribed to within the instrument, and acknowledged that he l
l 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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Labe M. Knisley,1Jotary Public f State of Maryland, Montgomery County My commission expires March 1,2002 y
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1 GDP98-0115 Page 1 of 2 United States Enrichment Corporation (USEC)
Proposed Changes
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Certi6cate Amendment Request I
TSR Section 2.1.3.11 Detailed Description of Change Description of the Chance:
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By letter dated April 17,1998 (Reference 1), USEC submitted a response to the NRC's request for
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additional inforraation related to the Certificate Amendment Request (CAR) regardmg Technical Safety i
Requirement 2.1.3.11, Autoclave Smoke Detection System. USEC's April 17,1998 submittal contained the following commitment:
USEC will submit a revision to proposed TSR 2.1.3.11 to include a Condition in the Limiting Condition for Operation (LCO) Action statement that addresses situations where there are fewer than four (4) smoke detectors (total) opemble in X-343. This requirement will supplement the proposed requirement in the June 30,1997 CAR that at least one detector (of the four required) shall be operable above any operable autoclave in X-343. The revision to TSR 2.1.3.11 will be submitted to the NRC by May 30,1998.
In accordance with this commitment, USEC proposes the following revisions to TSR 2.1.3.11 previously submitted for NRC review and approval in Reference 2.
Add an additional requirement in Condition B to address the situation where fewer than four smoke detectors are operable in X-343.
< 4 operable smoke detector heads (total).
Add a description to the Basis which addresses the additional requirement added to Condition B Additionally, a minimum of four (4) smoke detector heads (total) mounted on the
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ceiling are required to be operable in X-343 to alleviate any potential adverse effects on the smoke detector heads from wind inside the building when one or both crane doors are open. If this Condition is not satisfied, the "affected autoclaves" referenced in Action B.2 encompasses all autoclaves in X-343.
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GDP98-Oll5 Page 2 of 2 United States Enrichment Corporation (USEC)
Proposed Changes Certi5cate Amendment Request TSR Section 2.1.3.11 Detailed Description of Change JimHHcation for the Chance i
A minimum of four (4) smoke detector heads mounted in the ceiling are required to be operable to ensure adequate coverage of the facility. This requirement alleviates the potential adverse effects on the ability I
of the smoke detectors to sense a release which may be caused by wind conditions in X-343 building I
when one or both of the X-343 facility crane doors are open. In addition, requiring a minimum of four detectors to be operable in the X-343 facility retains the same level of detector coverage as required by 4
the existing X-343 autoclave smoke detection TSR.
l REFERENCES l
- 1. Letter from S. Toelle (USEC) to C. Paperiello (NRC), Response to Request for Additional
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Information - Certificate Amendment Request - TSR 2.1.3.11, Autoclave Smoke Detection System, April 17,1998.
- 2. Letter from James H. Miller (USEC) to Dr. Carl J. Paperiello (NRC), Certificate Amendment Request
-TSR Section 2.1.3.11 - Autoclave Smoke Detection System, USEC Letter GDP 97-0128, July 30, 1997.
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GDP98-0115 3 Pages Proposed Changes Certificate Amendment Request Portsmouth Gaseous Diffusion Plant Letter GDP 98-0115 Removal / Insertion Instructions Remove Page Insert Page VOLUME 4 Section 2.13.11 Section 2.13.11 Page 2.1-20 Pages 2.1-20 and 2.1-20a 1
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TSR-PORTS PROPOSED May 29,1998 RAC 97X0095 (RI)
SECTION 2.1 SPECIFIC TSRs FOR X-342, X-343, AND X-344 FACILITIES 2.1.3 LIMITING CONTROL SETTINGS, LIMrrING CONDITIONS FOR OPERATION, SURVEILLANCE 2.1.3.11 Autoclave Smoke Detection System APPLICABILITY:
All Autoclave Operational Modes LCO:
Autoclave UF smoke detection systems shall be operable.
ACTIONS: Note:
TSR 1.6.2.2(d) does not apply Condition Required Actions Completion Time A. For the X-342 and X-344 A.1 Provide Immediately buildings:
continuous smoke watch at affected
< 1 operable smoke detector alarm area circuit covering the area above the
.OR autoclaves A.2 Place all 1 Hour autoclaves in the affected building
.in Mode VII B. For the X-343 building:
B.1 Provide Inunediately continuous smoke
< 1 ope able smoke detector alarm watch at affected circuit covering the area above area each autoclave pair (i.e., No. I and OR 2; 3 and 4; 5 and 6)and autoclave B.2 Place affected 1 Hour
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< 4 operable smoke detector heads l
(total) l 2.1-20 l
N' TSR-PORTS PROPOSED May 29,1998
~ RAC 97X0095 (RI)
SECTION 2.1 SPECIFIC TSRs FOR X-342, X-343, AND X-344 FACILITIES 2.1.3 LIMITING CONTROL SETTINGS, LIMITING CONDITIONS FOR OPERATION, SURVEILLANCE 2.1.3.11 Autoclave Smoke Detection System (continued)
SURVEILLANCE REQUIREMENTS:
Frequency Surveillance Semiannually SR 2.1.3.11.1 Test active smoke heads to ensure alarm indication will occur when smoke head is exposed to a simulated smoke condition.
I BASIS:
h In the event of a UF. release in the autoclave area a local indicator will sound notifying operating personnel that immediate investigation and action must occur. The smoke detection system and subsequent personnel actions will mitigate the consequences of any UF. release. The detection y
components used are ionization type fire detectors designed to detect not only smoke but invisible l'
combustion products. Due to their operating principle these detectors will also actuate in the -
L presence of steam and vehicle exhaust, etc. Therefore prompt investigation of the actuation source is required. This LCO ensures that at least one smoke detector alarm circuit, covering the area above -
each autoclave that is not shutdown, is operable. For autoclaves in the X-343 building, an autoclave f
smoke detector alarm circuit is required to have at least one operable smoke detector head above each respective autoclave pair (i.e., autoclave No. I and 2; 3 and 4; 5 and 6) and above autoclave No. 7, in order to be considered operable.
' Additionally, a minimum of four (4) smoke detector heads (total) mounted on the ceiling are required p
- to be operable in X-343 to allevir,te any potential adverse effects on the smoke detector heads from L
wind inside the building when one or both crane doors are open. If this Condition is not satisfied, the L
"affected autoclaves" referenced in Action B.2 encompasses all autoclaves in X-343.
Furthermore, a single smoke watch is adequate to implement Action B.1 regardless of how many autoclaves may be affected. Because of the physical layout of the autoclaves and the smoke detector heads in the X-342 and X-344 buildings, an autoclave smoke detector alarm circuit in either of these j
two buildings is required to have both smoke detector heads operable in order to be considered operable. Other smoke detectors (and their associated alarm circuits) located in these facilities but not physically above the autoclaves are not covered by this TSR and shall not be used to satisfy the LCO requirements [SAR Sections 3.2.1.1.6,3.2.1.2.6, and 3.2.1.3.6].
2.1-20a
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