ML20249A805
| ML20249A805 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 06/11/1998 |
| From: | John Miller UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Knapp M NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| GDP-98-0120, GDP-98-120, NUDOCS 9806180263 | |
| Download: ML20249A805 (13) | |
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i USEC A ciob.i kn.rgy company JAMES H. MILLER Dir: (301) 564-3309 VicE PRESIDENT, PRoouctioN Fax:(301) 571-8279 June 11,1998 GDP 98-0120 Dr. Malcolm R. Knapp Acting Director, Office of Nuclear Material Safety and Safeguards Attention: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Portsmouth Gaseous Diffusion Plant (PORTS)
Docket No. 70-7002 Certificate Amendment Request - Compliance Plan Issue 11 Revision
Dear Dr. Knapp:
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 Portsmouth, Ohio, Gaseous Diffusion Plant (GDP). This Certificate Amendment Request involves a change to The Plan for Achieving Compliance with NRC Regulations at the Portsmouth Gaseous Diffusion Plant (Compliance Plan) Issue 11. Plan of Action and Schedule, regarding the connection of evacuation homs in the X-744H
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Building to the X-744G Criticality Accident Alarm System (CAAS).
Issue 11 currently commits USEC to tie the evacuation homs in Building X-744H to the Building X-744G CAAS by July 1.1998. With the elimination of fissile operations in Building X-744H, a nuclear criticality safety evaluation has concluded that due to the absence of fissile operations in the X-74411 facility and the intrinsic nature of the residual contaminated material, which contain no visible quantities of uranium, a nuclear criticality is not credible in the X-744H warehouse. Therefore, the requested change revises issue 1I to eliminate the action to tie evacuation homs in X-744H to the X-744G CAAS.
1 to this letter provides a detailed description ai.! justification for the proposed changes. is a copy of the revised Compliance Plan page and removal / insertion instructions associated l
with this request. Enclosure 4 contains the basis for USEC's determination that the proposed change I
associated with this cenificate amendment request is not significant. Enclosure 5 contains DOE approval of the Compliance Plan change as required prior to submittal to NRC. Since this request affects a Compliance Plan action scheduled for completion by July 1,1998. USEC requests NRC review and approval as soon as possible. USEC has implemented measures to ensure that a criticality is not credible
. in the X-74411 Building. This amendment should become effective five (5) days from issuance.
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- u e Dr. Malcolm R. Knapp -
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- June 11,1998 GDP 98-0120, Page 2 -
o Any questions related to this subject should be directed to Marc Klasky at (301) 564-3408. There are no new commitments evntained in this submittal.
Si ere :
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b H. Miller e President, Production
Enclosures:
- 1. Affidavit
- 2. Detailed Description of Change
- 3. Proposed Certificate Amendment Request, Removal / Insertion Instructions
- 4. Significance Determination
- 5. DOE Approval of Change
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NRC Region 111 Office NRC R_esident Inspector-PGDP NRC Resident Inspector - PORTS Mr. Randall M. DeVault (DOE) k; E--_-
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OATH AND AFFIRMATION I, James H. Miller, swear and affirm 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 l
Nuclear Regulatory Commission this Certificate Amendment Request for the Portsmouth Gaseous Diffusion Plant addressing revisions to Compliance Plan Issue 11 contained in USEC Letter GDP 98-0120, 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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mes H. Miller
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On this lith day of June,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.
In witness hereofI hereunto set my hand and official seal.
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daujie M. Knisley, Notary Public l
State of Maryland, Montgomery County '
My commission expires March 1. 2002
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r GDP 98-0120 Page1of1 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Compliance Plan Issue 11 Revision Detailed Description of Change Compliance Plan Issue 11, Plan of Action and Schedule currently commits USEC to tie the l
l evacuation horns in Building X-744H to the Building X-744G CAAS by July 1,1998. This
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subnstal proposes the deletion of the following Compliance Plan Issue 11 action:
"The analyses already submitted identified the need to tie the evacuation horns in Building X-744H to the. Building X-744G CAAS that provides detection coverage for Building X-744H. Building X-744H contains lightly contaminate waste with a comparatively low potential for a criticality accident. The tie for the horns will be completed by July 1,1998."
Justification of the Change The X-74411 Building (Warehouse 18) is a large general type warehouse located approximately 300 ft. From the X-744G facility. The North end portion of the warehouse was utilized for sorting and batching of solid contaminated bumables which necessitated the need for CAAS coverage. As noted in Compliance Plan, Issue iI the X-744G CAAS provided the detector coverage but the evacuation hom coverage was determined to be less than adequate. Subsequently the sorting and batching of solid contaminated burnables operation was discontinued in the X-744H and transt' erred to the XT-847 facility which does have local CAAS coverage. All associated fissile materials were also removed. The X-744H warehouse will continue to be used to store routine stores items and new and refurbished process related equipment and parts. Some of these refurbished / reusable process parts have fixed contamination but no visible uranium or free liquids are present. In addition, equipment / parts from offsite (i.e. K-25, PGDP) that have not been surveyed at PORTS were inspected and packaged prior to shipment to verify compliance with 10 CFR 71.
There are no longer any fissile material operations ongoing in the X-744H facility that involve uranium bearing solutions or the handling of any materials that contain visible quantities of uranium.
Due to the intrinsic nature of the materials allowed in the warehou;e and the low fissile material density in the warehouse there is no credible risk of a criticality accident in X 44H. Therefore the action to tie the evacuation homs in X-744H to the X-744G CAAS is no longer warranted and should be deleted from Compliance Plan issue 11.
GDP 98-0120 Page1of3 Proposed Certificate Amendment Request Portsmouth Gaseous Diffusion Plant Letter GDP 98-017')
Removal / Insertion Instructions Remove Pages Insert Pages Plan for Achieving Compliance with NRC Regulations at the Portsmouth Gastrous Diffusion Plant Issue 11 Issue 11 Pages 1/2 Pages 1/2 i
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4 Issue 11 Page 1 Exceptions for Criticality Accident Alarm System REQUIREMENT 10 CFR 76.89(a) "(a) The Corporation must maintain and operate a criticality monitoring and audible alarm system meeting the requirements of paragraph (b) of this section in all areas of the facility. The Corporation may describe for the approval of the Commission defined areas to be excluded from the monitoring requirement. This submittal must describe the measures that will be used to ensure against criticality, including kinds and quantities of material that will be permitted and measures that will be used to control those kinds and quantities of material."
' COMMITMENTS
- 5. Nuclear Safety Programs 5.2 Nuclear Criticality Safety 5.2.2 Program Elements 5.2.2.5 Criticality Accident Alarm System Coverage and Nuclear Accident Dosime7 [Rev. 3, S/31/96)
"A CAAS [ criticality accident alarm system) is provided to alert personnel if a criticality accident should occur.
USEC will submit, in accordance with the Compliance Plan, the analyses for alarm settings, detector placement and the analyses required by 10 CFR 76.89(a) to demonstrate that criticality monitoring and alarm coverage is not required in certain areas of the facility."
DESCRIPTION OF NONCOMPLIANCE A crincality accident alarm system is not provided for all areas of the facility. Uranium cylinder and low-level waste storage areas and some fissile material activities have been excluded consistent with DOE guidance. NRC approval has not been received for excluding the applicable plant areas (i.e., those containing >700 grams of mU) from criticality accident alarm system coverage.
JUSTIFICATION FOR CONTINUED OPERATION.
The existing Safety Analysis Report and other documents identify plant locations where criticality accident alarm system monitoring is provided. The report and documents also recognize that the other plant areas do not have such monitoring. Areas not covered by a criticality accident alarm system (i.e., uranium cylinder storage yards, low-level waste storage areas, and some fissile material transportatics activities) were selected because of the intrinsic nature of the configurations and the materials allowed in the areas, including container integrity and/or low fissile material density. Many of these areas are not occupied on a regular basis. This approach is consistent with historical DOE requirements, which allowec' o' ant areas to be excluded from criticality accident PORTS Rev. 3,7/9/96
l Issue 11, Page 2 PROPOSED Excepuons for Cnnahrv Accident Alarm system l
l alarm system coverage because of documented analyses that there was no credible risk of a criticality accident in those areas.
PLAN OF ACTION AND SCIIEDULE 10 CFR 76.?9(a) pemiits USEC to request NRC approval for specific areas to be excluded from crincality accident alarm system coverage. USEC will provide criticality detector coverage in all areas of the plant except for those areas identified and justified by USEC and approved by NRC. Analyses that provide the technicaljustification for not providing criticality accident alarm system coverage in designated areas of the plant are being developed. Except for Buildings X-330, X-333, and X-700, analyses have been submitted to NRC tha: (1) verify the adequacy of the existing criticality accident alarm system and its detector locations for detecting a criticality accident and (2) justify that detectors are not required for monitoring other areas of the plant. The analyses for Buildings X-330, X-333, and X-700 will be completed by September 30,1996. This compliance plan issue will be modified to provide a plan and schedule for establishing adequate detector coverage if the adequacy of the current detector coverage is not verified by the NRC review.
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SUMMARY
OF REQUIREMENTS, CO3IMITMENTS, AND NONCO31PLIANCES l
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Issue: Exceptions for Criticality Accident Alarm System
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Code of Federal Regulations Part Title 10 76.89(a)
Application Commitment Section Safety Analysis Report 5.2.2.5 j
Technical Safety Requirements 2.1.3.1, 2.2.3.2, 2.4.3.1. 2.5.3.1, 2.6.3.4, 2.7.3.2, 2.8.3. I a
Application Noncompliance Statement Section Safety Analysis Report 5.2.4.8 l
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PORTS RAC97-X0540 (6/1 t /98)
GDP 98-0120 Page1of3 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Compliance Plan Issue 11 Revision Significance Determination The United States Enrichment Corporation (USEC) has reviewed the proposed changes associated with this certificate amendment request and pre rides the following Significance Determination for consideration.
1.
No Significant Decrease in the Effectiveness of the Plant's Safety. Safeguards or Security Programs The proposed change to the Compliance Plan does not affect any of the plant's safety, safeguards or security programs. The proposed change revises Issue 11 to delete the action to tie the evacuation horns in Building X-744H to the Building X-744G CAAS by July 1,1998. The action is no longer required based on the fact that the fissile material operation (sorting and batching) that requires CAAS coverage has been removed from the X-744H. Due to the intrinsic nature of the materials allowed in the warehouse and the low fissile material density (no visible uranium) in the warehouse there is no credible risk of a criticality accident in X-744H. Therefore, there is no decrease in the effectiveness in the plant's safety, safeguards, or security programs as a result of the proposed change.
1 2.
No Significant Change to Any Conditions to the Certificate of Comnlign g None of the Conditions to the Certificate of Compliance for Operation of Gaseous Diffusion Plants (GDP-2) specifically address Compliance Plan Actions and Schedules or the location of criticality accident alarm detectors. Thus, the proposed change will have no impact on any of the Conditions to the Certificate of Compliance.
3, No Significant Chance to Anv Condition of the Anoroved Comoliance Plan The Plan of Action and Schedule for Issue 11 of the Plan for Acaleving Compliance with NRC Regulations at Portsmouth Gaseous Diffusion Plant currently commits USEC to tie the evacuation horns in Building X-744H to the Building X-744G CAAS by July 1,1998. As described in. the proposed change deletes the X-744H required action. The action is no longer required based on a Nuclear Criticality Safety Evaluation which concluded that CAAS coverage is no longer required and therefoie the change to the Compliance Plan is not considered significant.
4.
No Significant increase in the Probability of Occurrence or Consequences of Previousiv Evaluated Accidents There are no longer any fissile material operations ongoing in the X-744H facility that involve uranium bearing solutions or the handling of any materials that contain visible quantities of uranium. Due to the intrinsic nature of the materials allowed in the warehouse and the low fissile material density in the warehouse there is no credible risk of a criticality accident in X-l:
744H. The proposed change does not change the consequences of any previously analyzed
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accidents since they are based on credible criticality scenarios in which CAAS coverage is required.
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GDP 98-0120 Page 2 of 3 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Compliance Plan Issue 11 Revision Significance Determination 4.
No Significant Increase in the Probability of Occurrence or Consequences of Previousiv Evaluated Accidents (continued)
Therefore, the proposed change will not cause any increase in the probability of occurrence or consequences of previously evaluated accidents.
5.
No New or Different Tvoe of Accident The proposed change does not modify plant equipment or add new operations to the facility. In fact the sorting and batching of solid contaminated burnables which necessitated the need for CAAS coverage has been discontinued in the facility. The CAAS horns are for mitigation of a criticality accident once it has occurred and are not an accident initiator. Therefore, this change will not result in a new or different type of accident.
6.
No Significant Reduction in Margins of Safety Based on the overall conclusion that there are no credible criticality accident scenarios associated with the X-744H Building, the margin of safety has been increased over that previously thought to exist when the sorting and batching of sold contaminated burnables operation existed in the facility.
7.
No Significant Decrease in the Effectiveness of Anv Procrams or Plans Contained in the Certificate Ariolication The change to Compliance Plan Issue 11 will not result in a change to any of the programs ot ; ans contained in the Certificate Application. Therefore, the proposed change will result in no decrease in the effectiveness of any programs or plans contained in the Certificate Application.
8.
The Prooosed Changes do not Result in Undue Risk to 1) Public Health and Safety. 2) Common Defense and Security. and 3) the Environment Due to the fact the consequences of a criticality have only onsite affects and the conclusion that there are no credible criticality scenarios for the X-744H operation there will be no undue risk to the public health and safety. In addition, this change has no impact on plant effluents or on the programs and plans in place to implement physical security. Consequently the elimination of the Compliance Plan Issue 11 action to tie the X-744H evacuation horns to the X-744G CAAS will not pose any undue risk to the public health and safety, common dvense and security and environment.
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i GDP 98-0120 Page 3 of 3 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Request Compliance Plan Issue 11 Revision Significance Determination 9.
No Chance in the Tvoes or Significant Increase in the Amounts of Anv Effluents that May be Released Offsite The consequences of a criticality are confined to plantsite and there will be no changes in the operation of X-744H nor in the manner in which it is maintained. The change will not increase the probability of any previously analyzed accidents. The change to the Compliance Plan issue 11 has no effect on the generation of effluents and therefore, it does not change the type or amount of effluents that may be released offsite.
10.
No Significant Increase in Individual or Cumulative Occupational Radiation Exoosure The consequent.r3 of a criticality are confined to plantsite and there will be no changes in the operation of the X-744H Building. This change does not increase the probability of a criticality but concludes that the potential for a criticality is extremely low. The proposed change will not affect the radiological protection program actions in place to minimize occupational exposures. Therefore, there is no increase in individual or cumulative occupational radiation exposure as a result of this change.
11.
No Significant Construction Imnact The proposed change eliminates the need for a plant modification. Therefore, there is no construction impact.
12.
No Significant Increase in the Potential for. or Radiological or Chemical Consequences from.
Previousiv Analyzed Accidents 1
i The elimination of the need to tie the X-714H evacuation horns to the X-744G CAAS will not j
increase the probability of occurrence or consequences (radiological and/or chemical) of any postulated accidents currently identified in the SAR. This change does not alter the assumptions used in the accident analysis. Therefore, there is no significant increase in the potential for radiological or chemical consequences from previously analyzed accidents.
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GDP 98-0120 Certificate Amendment Request Compliance Plan Issue 11 Revision DOE Approval Of Change
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Oak Ridge Operations Post Office Box 62 Oak Ridge, Tennessee 37831 -8651 May 29, 1998 Mr. Steven A. Toelle Nuclear Regulatory Assurance and Policy Manager United States Enrichment Corporation 2 Democracy Center 6903 Rockledge Drive Bethesda, Maryland 20817
Dear Mr. Toelle:
PORTSMOUTH GASEOUS DIFFUSION PLANT - DOCKET NO. 70-7002 - DEPARTMENT OF ENERGY APPROVAL OF CHANGE TO COMPLIANCE PLAN ISSUE 11 l
The United States Enrichment Corporation (VSEC) in a letter dated May 7,1998, requested Department of Energy (DOE) approval of a change to the Portsmouth Gaseous Diffusion Plant (PORTS) Complicnce Plan Issue 11, " Exceptions for Criticality Accident Alann System," regarding deletion of an action to tie the i
evacuation horns in Building X-744H to the Building X-744G Criticality Accident Alarm System that provides coverage for Building X-744H.
DOE has reviewed USEC's request for this change. After a 00E walkdown of j
Building X-744H on May 20, 1998, and review of a revised Engineering Evaluation No. EV-X-832-97-001, Revision 1, dated May 26, 1998, 00E finds the PORTS Compliance Plan change acceptable. Therefore, the USEC-requested change to the PORTS Compliance Plan is approved by 00E.
If there are any questions or comments on this approval, please contact me at (423) 576-0802.
Sincerely,/x W Randall M. DeVault Regulatory Oversight Manager Office of Assistant Manager for Enrichment Facilities l
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- Mr. Steven A. Toelle May 29, 1998
.cc:
R. C. Pierson, NRC, White Flint W. S. Schwink NRC, White Flint J. R. Knicely,- NRC, Region III R. M. George NE-40, GTN G. G. Pennington, Bechtel Jacobs, MS-8651, K-1550V T. T. Slack, CC-10, ORO A. L. Takacs, EF-21, PORTS E. W. Gillespie, EF-21, PORTS J. W. Parks, EF-20, ORO W. M. Yoder, DP-821, 2714-J, ORO