ML20199K488

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Rev 20 to Paducah Certification Application,Incorporating Changes to Compliance Plan Issue 3 & to Sar.Rev 6 to Paducah Compliance Plan Also Encl
ML20199K488
Person / Time
Site: Paducah Gaseous Diffusion Plant
Issue date: 11/20/1997
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-97-0199, GDP-97-199, NUDOCS 9712010138
Download: ML20199K488 (22)


Text

United St:tes 4

Enrichment Corpor lion e

2 Democracy Center 6903 Rockledge Drive i

Bethesda. MD 20817 Tel: (301)564-3200 Fax:(301) 564-3201 (I iileil Sitity t

Etuirlarneint Corpontliott JAMES H. MILLER Dir; (301) 564-3309 VICE PRESIDENT, PRODUCTION Far (301) 571-8279 November 20,1997 Dr. Carl J. Paperiello SERIAL: GDP 97-0199 Director, Office of Nuclear Material Safety and Safeguards Attention: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Paducah Gascous Diffusion Plant (PGDP)

Docket No 70-7001 Transmittal of Revision 20 to Paducah Certification Application and Revision 6 to Paducah Compliance Plan

Dear Dr. Paperiello:

In accordance with 10 CFR Part 76, the United States Enrichment Corporation (USEC) hereby submits twenty (20) copies of Revision 20 (November 20,1997) to USEC-01, Application for United States Nuclear Regulatory Commission Certification, Paducah Gaseous Diffusion Plant and of Revision 6 (November 20,1997) to DOE /ORO-2026, Plan for Achieving Compliance with NRC Regulations at the Paducah Gaseous Diffusion Plant, Revisions 6 and 20 incorporate changes to Compliance Plan issue 3 and to the Safety Analysis Report, respectively. NRC acknowledgment of these changes was provided in the NRC letter from Mr.

Robert C. Pierson to Mr. Steven A. Toelle, " Modification of the Autoclave Interlock Controls-Compliance Plan issue 3, Action 8", dated October 21,1997. Revision bars are provided in the right-hand margin to identify the changes. Revisions 6 and 20 will be implemented on November 20,1997.

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9712010138 971120 "

i PDR ADOCK 07007001 C

PDR-141418It!!NOl!!Ill.El Offices in Paducah, Kentucky Portsmouth, Ohio Washington, DC

Dr; Carl J. Paperiello.

November 20,1997 GDP 97-0199 Page 2 Should you have any questions or comments on the subject revisior.s, please call me at (301) 564-3309 or Mark Smith at (301) 564 3244. There are no new commitments made in this submittaic Since 'ly, A

J' es 11. Miller ice President, Production i

Attachments:

1.

USEC-01, Application for United States Nuclear Regulatory Commission Certification, Paducah Gaseous Diffusion Plant, Revision 19, Copy Numbers 567 through 586 2.

DOE /ORO-2026, Plan for Achieving Compliance with NRC Regulations at the Paducah Gaseous Diffusion Plant, Revision 6,20 copies

Enclosure:

Atlidavit cc:

NRC Region 111 Office Copy Numbers 442,664 NRC Resident inspector - PGDP Copy Number 697 NRC Resident inspector - PORTS Copy Number 665 Mr. Joe W. Parks (DOE)

Copy Numbers 641 through 644 b

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c, OATII AND AFFIRhiATION j

1, Jame 11. hiiller, swear and affirm that I am Vice Presidem, Production, s f the United States Enrichment Corpo ation (USEC), that I am authorized by USEC to sign and file eith the Nuclear Regulatory Commission this Revision 20 of the USEC Application for United Sta'es Nuclear Regulatory Commission Certification, Paducah Gaseous Diffusion Plant (USEC-01) and this Revision 6 of the Plan for Achieving Compliance with NRC Regulations at the Paducah Gaseous Diffusion Plant (DOFJORO-2026), that I am familiar with the contents thereof, and that the statements made mw matters se' forth therein are true and correct to the best of my knowledge, infenation, and belief,

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l J-s 11. hiiller On this 20th day of November,1997, the ollicer 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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IUaleuo "ilurie hi. Knisley, Notary Public g

State of Maryland, Montgomery County My commission expires March 17,1998

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APPLICATION FOR UNITED STATES -

NUCLEAR REGULATORY COMMISSION CERTIFICATION PADUCAH GASEOUS DIFFUSION PLANT REMOVFANSERTINSTRUCTIONS REVISION 20 NOVEMBER 20,1997 ~

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=SAR PODP May 31,1996 R$3 As a resuk, high conductivity will be detected which will operste an interlock system to put the autoclave 8ato containment.

- 3.6.7.2 UF, D=**

Each =maclave, the laboratory room, and the basement area in C-360 are equipped _with general aren UP. detectors. 'Ihe UF. release detection systems are arranged in zones. Zone 1 is the laboratory area, Zones 2 and 3 are the autoclave heads, Zone 4 is the basement area, and Zone: 5-8 are the autoclave heated housings. Figure 3.6-5 provides a simplified schematic of the UP. relettse detection systems.-

The laboratory area (Zone 1) contains two UF. detectors. When either detector is activated, the associated circuitry initiates closing the UF. sample line isolation valves, XV *51 and XV *48, closing -

the UP. transfer line sample isolation valves, XV *49 and XV *52, and sounding of alarms. This isolates all sample cabinets from their corresponding autoclave. The alarms sound at the local autoclave panel,

._. the C-360 supervisor's office, and in the CCF in C-300. The Zone 1 detection system does not initiate building containment.

Detector heads in the basenza wes (Zone 4) are located above the receiving cylinder pigtail, cold trap, the relief tanks, surge drums and on the ceiling in the transfer room. WMn any of these detector howls is actuated, the associated circuitry initiate closing the UF transfer li.:c block valves on all autoclaves (XV *52 and XV *50), closing the transfer line block valve WV-041, :osing the receiving cylinder valve, actuating building containment which allows the automatic door closures on the drain station enclosure to close, providing confinement, and sounding alarms. The Zone 1 and po:tions of the Zone 4 detection systems are identified as systems required to be incicded hi the TSR. The portion of the Zone 4 system includes only those detector heads located within the transfer room.

The Zones 2 and 3 UF, detection systems are located above the autoclave head <. Zone 2 consists of the awenrs over autoclaves 1 and 2, and Zone 1 consists of the detector heads over autoclaves 3 and 4.

If either detector head in a zone actuates, automatic transfer isolation valves close on the two autoclaves associated with that zone only. Actuation of the Zone 2 or 3 detection system also initiates building containment and initiates alarms sounding in the C-360 suriervisor's office, and in the CCF in C-300.

Zones 5-8 consists of the detector heads sampling the heated housing of each autoclave. Alarms and the closure of the steam supply isolation valves are initiated. The alarins sound in the C-360 supervisor's office, and in the CCF in C-300.

I There is a time delay of 45 seconds between actuation of a PGLD head sending the building into contamment and the closure of the overhead doors. Alarms sound to alert operators that the doors will

- close. The time delay allows the continued movement of the crane or scale carts to get out of the path of the closing doors.

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  • Ihe cylinder valve closer is alt operated with a nitrogen backup. On loss of plant air or low plant air pressure, a pressure switch on the air supply line (set at or above 75 psig) actuates to open a solenoid valve which makes nitrogen available to the air supply line. The cylinder valce can be closed by the 3.6-9

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i SAR-PGDP November 20,1997 Rev. 20 nitrogen in 30 secorxh. De nitrogen cor.nection to the air supply line is made downstream from a check valve in the line which prevents loss of nitrogen pressure. The nitrogen bottle which supplies the system with backup nitrogen is a 1.55 ft' tank and must have an indicated pressure of at least 1200 psig. The nitrogen is regulated to an indicated 80 psig.

Check valve operability is verified during quanerly testing by monitorin;; for detectable flow from tubing located upstream from the check valve that is open to atmosphere open to atmosphere (no detectable flow after nitrogen has been supplied to the supply header down stream from the check valve indt the valve has seated pwperly). Another indication of proper check valve performance is closing a cylinder valve using tne nitrogen backup (also part cf the quarterly test). If the cylinder valve will close within the required 30 seconds using nitrogen, then the check valve is providing sufficient resistance to backflow for the system to function properly if called upon to do so.

3.6.7.3 Water Inventory Control As mentioned in Section 4.2.3, the maximum pressure generat x1 in an autoclave from an accidental UF. release and subsequent reaction with the available water is be, t controlled by limiting the water in the autoclave. Redundant condensate level probes LE *07 and LE *08 are mot'nted in the 3-in. drain pipe slightly below the autoclave level. A strainer basket is placed over the drain p*pe to prevent trash from blocking the drain line. If the ultrarunic probes detect a high water level, the steam supply isolation valves XV *53 and FV *05 and the thermovent line block valve FV *34 close to limit the total water in the autoclave. This system has been designated a system required to be included in the TSR (see Figure 3.6-3).

3.6.7.4 Autoclave Steam Pressure Control The autoclave steam pressure control system is used to stop the steam flow to the autoclave while heating a cylinder p'ar to reaching temperatures which could result in reaching the maximum allowable working pressure of the cylinder. This system is identified as a system required to be included in the TSR 'line steam piessure control system closes the steam isolation valves and sounds an alarm if the autoclave steam pressure reaches the set point of a maximum of 8 psig. The components of this system are the pressure transmitter 17T *15 and associated pressure switch PSH *15A, pressure switch PSH *15B, steam supply isolation valves XV *53 and FV *05, associated relays, solenoids and switches (see Figures 3.6-3 and 3.6-4).

3.6.7.5 Autoclave IIigh Pressure Isolation Systern ne autoclave high pressure isolation system causes the autoclave to go into the contahment mode and sound an alarm if the internal pressure of the autoclave reaches 15 psig. In addition, the system disables the hydraulic system required to open the autoclave shell preventing the autoclave from opening until the alarm condition has been cleared. This system is identified as a system required to be included in the TSR. The system components include the autoclave shell, head, and locking ring, pressure transmitter PT *15 and associated pressure switch PSHH *15A, pressure blind switch PSHH *15B, 3.6-10

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Autoclave Upgrades REQUIREMENTS f-10 CFR 76.35(a)(6) "The application for an initial certificate of compliance must include the information identified in this section. (a) A safety analysis report which must include the following information:... (6) A description of equipment and facilities which will be used by the Corporation to protect health and minimize danger to life or property..."

10 CFR 76.85 "The Corporation shall perform an analysis of potential accidents and consequences to establish the basis for limiting conditions for operation of the plant with respect to the potential for releases of radioactive material. Special attention must be directed to assurance that plant operation will be conducted in a manner to prevent or to mitigate the consequences from a reasonable spectrum of postulated accidents which include internal and external events and natural phenomena in order to ensure adequate protection of the public health and safety."

10 CFR 76.87(c)(5) "(c) Appropriate references to establish:d procedures and/or equipment to address each of the following safety topics must be included in technical safety requirements:... (5) Radiation protection."

COMMITMENT Source: Safety Analysis Report

3. Facility and Process Description 3.2 UP. Feed Facilities 3.2.5 Instrumentation 3.2.5.4 Autoclave High Pressure Isolation System [Rev. 3, 5/31/96)

"The autoclave high pressure isolation system causes the autoclave to go into the containment mode and sound an alarm if the internal pressure of the autoclave reaches 15 psig.

In addition, the system disables the hydraulle system required to open the autoclave shell preventing the autoclave from opening until the alarm condition has been cleared: This system is identified as a system required to be included in the TSR [ Technical Safety Requirements)."

3.2.5.7 Autoclave Manual isolation System [Rev. 3,5/31/%)

"The autoclave manual isolation sptem contains three manual push buttons, one at the Operations Monitoring Room [OMR) door, one at the crane bay exit near the local cylinder yard, and one in the ACR [ Area Control Room). When one of these buttons is pressed, each facility autoclave is placed into containment (at least one isolation valve on each isolable autoclave penetration closed). The buttons are used upon confirmed UF, outleakage to mitigate the release."

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3.4 UP. Product Withdrawal Facility V

3.4.7 Instrumentation [Rev. 3, 5/31/96) 3.5 UF. Tails Withdrawal Facilny 3.5.7 Instrumentation [Rev. 3, 5/31/96]

"'lhe cylinbr valve closer is air operated with a nitrogen backup. On loss of plant air or low plant air precure, a pressure switch on the air supply line (set at or above 75 psig) actuates to open a solenoid valve which makes nitrogen avMlable to the air supply line. The cylinder val /c can be closed by the nitrogen in 30 secorxis. The nitrogen connection to the air supply line is inade downstream from a check vahe in the line which prevents loss of nitrogen pressure. We nitrogen bottle which supplies tie system with backup nitrogen is a 1.55 ft' tank and must have an indicated pressure of at least 1200 psig. The nitrogen is regulated to an indicated 80 psig.

Check valve operability is verified during quarterly testing by monitoring for detectable flow from tubing located upstream from the check valve that is open to atmosphere (no detectable flow after nitrogen has been supp!!cd to the supply header down stream from the check valve indicates the valve has seated properly). Another indication of proper check valve performance is closing a cylinder valve using the nitrogen backup (also part of the quarterly test). If the cylinder valve will close within the required 30 seconds using nitrogen, then the check valve is providing sufficir~ bq.ime to backflow for the system to function properly if called upon to do so."

3.6 Uranium llexafluoride Saapling and Transfer Facility O

3.6.7 Instrumentation [Rev.1, f/31/%)

" Instrumentation for the UF. sampling and transfer facility is designed to monitor and control those operations involved in the heating, sampling, and transferring of UF.."

3.6.7.2 UF. Detection [Rev. 3, 5/31/96]

"The laboratory area (Zone 1) contains two UF. detectors. When either detector is activated, the associated circuitry initiates closing the UF, sample line isolation valves, XV *51 and XV *48, closing the UF. transfer line sample isolation valves, XV *49 and XV *5pjmd sounding of alarms. This isolates all sample cabhets from their corresponding autoclave. The alarms sound at the local autoclave panel, the C-360 supervisor's office, and in the CCF [ Central Control Facility) in C 300. The Zone 1 detection system does not initiate building containment.

Detector heads in the basement area (Zone 4) are located above the receiving cylinder pigtail, cold trap, the relief tanks, surge drums and on the ceiling in the transfer room. When any of these detector heads is actuated, the associated circuitry initiate closing the UF. transfer line block valves on all autoclaves (XV *52 and XV *50), closing the transfer line block valve WV-(M2, closing the receiving cylinder valve, actuating building containment which allows the automatic door closures on the drain station enclosure to close, providing confinenent, and sounding alarms. The Zone 1 and portions of the Zone 4 detection systems are identified as systems required to be included in the TSR....

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h Awodm Upgrds issue 3 Page 3 i

O De cylirder valve closer is air operated with a nitrogen backup. On loss of plant air or low plant air pressure, a pressure switch on the air supply line (set at or above 75 psig) actuates to open a solenoid valve which makes nitrogen available to the air supply line. The cylirder valve can be clo6ed by the nitrogen in 30 seconds. The nitrogen connection to the air supply line is made downstream from a check valve in the line which prevents loss of nitrogen pressure. The nitrogen bottle which supplies the system with backup nitrogen is a 1.55 ft' tank and must have an indicated pressure of at least 1200 psig. The nitrogen is regulated to an indicated 80 psig, Check valve operability is verified during quarterly testing by monitoring for detectable flow from tubing located upstream from the check valve that is open to atmosphere (no detectable flow after nitrogen has been supp11ed to the supply header down stream from the check valve indicates the valve has wated properly). Another indication of proper check valve performance is closing a cylinder valve using the nitrogen backup (also part of the quarterly test), if the cylinder valve will close within th: required 30 secord using nitrogen, then the check valve is providing sufficient resistance to backflow for the system to function properly if called upon to do so."

l 3.6.7.5 Autoclave liigh Pressure isolation System ['Rev. 3,5/31/%)

"The autoclave high pressure isointion system causes the autoclave to go into the containment mode and sound an alarm if the internal pressure of the autoclave reaches 15 psig, in addition, the system disables the hydraulle system required to open the autoclave shell preventing the autoclave from opening until the alarm condition has been cleared. This system is identified as a system required to be included in the TSR."

3.6.7.7 Operational Systems [Rev. 3,5/31/%)

t "The cylinder pressure relief system relieves pressum; in excess of 100 psig from the feed cyltrder to the cylinder relief tanks, and closes the steam supply isolation valves and the thermovent line block valve....

De autoclave opening prevention system is used to prevent the opening of an autoclave when the internal pressure exceeds 1.25 psig and gives a visual indication....

The cylinder roll interlock prevents the rolling of a cylinder while the pigtail is pressurized."

DESCRIITION OF NONCOMPLIANCE This issue involves a total of twen.y-two autoclaves. There are eight autoclaves in C-333A, ten autoclaves in C-337A, and four autoclaves in C-360. There are no autoclaves in C-310 or C-315, but liquid UF. is transferred to product withdrawal cylinders there.

1.

The three manual push buttons for the C-333A and C-337A autoclave containment system, one at the OMR door, one at the crane bay exit near the local cylirder yard, and one in the ACR used to place the autoclaves into containment upon confirmation of a UF.

O release, are not installed.

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The reset function for the C 333A and C 337A Autoclaves Iligh Pressure Isolation J.

System initiates the opening of certain containment valves. This could result in the opening of valves that are not intended to be opened.

3. The indicating range for the pressure transmitters on the autoclave opening prevention and cylinder roll interlock systems in C-360 is so much larger than normal ' crating pressures that calibration and instrument accuracies cannot be assured.

4.

The present pressure monitoring instrumentation does not have the capacity, accuracy, and resolution to reliably measure the vacuum required by UF. piping test procedure to verify integrity of piping connections. In addition, the present pressure monhoring instrumentation on the autoclaves in C 333A, C-337A, and C-360 has too large of a pressure range to accurately measure the small difference between the operating and the steam shutoff (8 psig) pressure.

5. "Ihe SAR Upgrade activities have identified transfer and sampling piping in C-360 wh:re the UP. detection systems located in Zones 1 and 4 initiate closure of only one containment isolation valve on the transfer / sampling piping.

6.

The performance criteria and test plan for determining plant air isolation check valve operability on loss of plant air and for allowing the bottled nitrogen system to operate the emergency valve closing for C 310, C-315, and C-360 has not been developed.

7.

For the autoclaves in C-360, one of the channels telled upon for initiating containment on a high-pressure indication would be disabled upon loss of instrument air.

8.

The relay logic for the autoclaves in C-360 does not lock out the hydraulics to prevent the autoclaves from being inadvertently opened when an Autoclave liigh Pressure isolation System containment signal is present.

9.

The transfer manifold for the parent-daughter transfer operation in C-3N) is not provided with pressure relief protection.

10. The capability to perform s. pressure decay test separately for the inner and outer containment valves, and essting that backpressure does not mask leaks, does not exist for all autoclaves in C-333A, C-337A, and C-360.

JUSTIFICATION FOR CONTINUED OPERATION 1.

In the event of a release of UP. in C 333A or C-337A, the UE detection system will actuate an annunciator in the OMR, the ACR, and the CCF. In response to such an alarm where more than ne e indication of UF. release has occurred, the following actions will be required:

  • Personnel wili immediately evacuate the local area of the feed facility except for the OMR in accordance with the "see and flee" policy, b')

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Auustave Upgrades issue 3, Page 5

  • The OMR operator will place the operating autoclaves into containment by placing the O.

conductivity cell meters in the check calibration mode (simulating a high high conductivity signal). To ensure that the conductivity cell meters will adequately perform this function, quartedy channel functional surveillance tests are performed.

Following initial evacuation and placement of the autoclaves into conta'nment, the alarm response procedure requires that an operator don protective clothing and respiratory protection and investigate the alarm. The operator will use HF detection equipment to deter.nine the presence of HF, indicating a release of UF.,

Also, until the autoclave manual isolation pushbuttons are installed, quarterly system channel functional tests to verify containment valves closure and quarterly tests of each UF. detection head will be performed.

2.

The Autoclave liigh-Pressure Isolation System cannot be reset until the autoclave pressure is below 15 psig, the limiting safety system setting. Until the control logic is modified so that the containment valves temain closed after reset of the containment signal, the operating procedure requires the operator to manually close these valves immediately after resetting the Autoclave High-Pressure Isolation System.

3.

The autoclaves in C-360 are not currently in operation and will not be placed into operation until the pressure transmitters on the autoclave opening prevention and cylinder roll interlock systems are replaced.

O 4.

Until replaced, the present pressure monitoring instrumentation for the C-333A, C-337A, and C-360 autoclaves is adequate to provide marginally acceptable capacity, accuracy, and resolution for autoclave operation. Also, the steam shutoff pressure trip is set sufficiently low to ensure that the desired 8 psig is not exceeded.

5.

Until the UF detection systems for Zones 1 and 4 are modified, sampling will not be allowed during transfer operations. Also, the operating procedure requires the operator to ensure that the drain valves remain shut when sampling operations are conducted.

6.

The bottled nitrogen backup system for C-310, C-315, and C-360 is currently out of service. In C-310 and C-315, the plant air supply to the cylinder valve is being periodically verified by operator surveillance to ensure operability. Upon identification of a loss of the plant air supply, administrative controls require manual closure of the cylinder valve (s). This surveill.mee is not currently being performed in C-360 as the cylinder valve closer system is out of service.

7.

For the autoclaves in C-360, there is redundant instrumentation to initiate containment upon a high-pressure indication. One channel of this instrumentation is a pressure switch which is not dependent on instrument air to perform its containment initiation function.

This is sufficient for safe operation until a second channel which is not dependent on in:trument air is added, 8.

The alarm and emergency response procedures for the autoclaves in C-360 only allow the operator to open the autoc!nes after clearing the alarm condition via an administratively O

controlled key switch. Also, the autoclave opening prevention system locks out the hydraulics to prevent the autoclaves from being opened when the pressure is greater than PODP Rev. 6. I1/20/97

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1.25 psig. 'Ihe autoclave opening prevention system is tested quarterly to verify its ability V

to perform this function.

9.

The design of the liquid transfer for the parent-daughter transfer of UF. In C-360 was constrained by the need to protect against a catastrophic release of liquid UF. to the work or general environment. This constraint was addressed by providing a set of administrative procedures, four independent controls on the source of heat, and two sets of doubly redundant steam cutoffs.

10. Until the capability to perform a pressure decay test separately for the inner and outer containment valves, and assuring that backpressure does not mask leaks, is provided for all autoclaves in C-333A, C-337A, and C-360, the following surveillance tests will be performed: (1) quarterly channel functional tests to verify containment valve closure and (2) quarterly overall autoclave containment pressure decay or leak rate.

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The above discussion provides justification that the plant can continue to operate safely until the autoclave upgrades are installed as discussed in the Plan of Action and Schedule.

PLAN OF ACTION AND SCIIEDULE 1.

The C-333A and C-337A autoclave containment systems will be modified by installhig three manual push buttons, one at the OMR door, one at the crane bay exit near the local cylinder yard, and one in the ACR which can be used to place the autoclaves into (V

containment upon confimiation of a UF. release. The scheduled completion date for these actions (with the exception of NRC approval of the associated TSR) is [ completed]. The scheduled date for submittal of the TSR to the NRC is [ completed].

2.

The control logic for the C-333A and C 337A Autoclave High-Pressure Isolation System will be modified such that upon reset of the containment signal, the valves will remain closed, but the valves can be opened by subsequent operator action. [ Complete]

3.

The pressure transmitters for the autoclave opening prevention and cylinder roll interlock systems in C-360 will be replaced. [ Complete]

4.

The pressure monitoring instrumentation serving the autoclave safety systems and defense-in-depth systems for C-333A C-3337A, and C-360 autoclaves will be replaced.

The scheduled completion date for this action is October 31,1997.

5.

The UF. detection systems for Zones 1 and 4 will be modified such that upon detection of a UF. release, multiple valves (FV *50, *S2, and '47 from Zone 1 and FV *47 and

  • 49 from Zone 4) will be closed on the transfer and/or sampling piping. The scheduled completion date for this action is (completed).

6.

Performance criteria and a test plau will be developed to demonstrate whether the nitrogen backup can close the cylinder valve in 30 secords in C 310, C-315, and C-360.

Further design requirements will be completed pending the outcome of this testing. The p

scheduled completion date for this action is [ completed].

O PODP Rev. 6 11/20/97

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. 7.

Add a second channel, which is not dependent upon instrument alt, to the autoclaves in b,

C 360 to initiate containment upon a high-pressure indication. The scheduled completion date for this action is October 31,1997.

8.

Modify the controls for the autoclaves in C-360 to prevent them from being inadvertently opened when an Autoclave liigh-Pressure isolation System containment signal is present.

The scheduled completion date for this action is October 31,1997.

9.

A code interpretation from the ASME Code Committee will be obtained regarding the C-360 parent-daughter transfer system and the need for pressure relief on the transfer manifold. Based on this interpretation, the need for modifications to the system or operations will be assessed. Both the ASME Code interpretation and the assessment results will be submitted to NRC for review and approval. The scheduled completion date for these actions is [ completed).

10. Modifications to allow a pressure decay test to be performed separately for the inner and outer containment valves, and assurance that backpressure does not mask leaks, for all autoclaves in C-333A, C-337A, and C-360 will be complete by [ completed). A revised TSR to reflect the new configuration will be submitted to NRC by [ completed).

SUMMARY

OF REQUIREMENTS, COMMITMENTS, AND NONCOMPLIANCES p

lasue: Autoclave Upgrades Code of Federal Regulations Part Title 10 76.35(a)(6), 76.85, 76.87(c)(5)

Application Commitment Section Safety Analysis Report 3.2.5.4, 3.2.5.7, 3.4.7, 3.5.7, 3.6.7, 4.3.1.1.1, 4.3.5.4.3 Tecimical Safety Requirements 2.1,2.2,2.3

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Application Noncompliance Stdf ement Section Safety Analysis Report 3.16.2, 3.16.5, 3.16.10, 4.3.1.1.1, 4.10 PGDP Rev. 6, It/2a97

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