ML20248G821
| ML20248G821 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 05/26/1998 |
| 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-98-0075, GDP-98-75, NUDOCS 9806050351 | |
| Download: ML20248G821 (14) | |
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p,USEC A Glehel Enery Company JAssis H. Miu.ER Dic (301) 564-3309 Vics PRassoENT, PRoouCTION Fac (301) 571-8279 May 26,1998 GDP 98-0075 Dr. Carl J. Paperiello Director, Office ofNuclear Material Safety and Safeguards Attention: Docum:nt Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Portsmeuth Gaseous DiNusion Plant (PORTS) l Docket No. 70-7002 CertiScute Amendment Request-lot Cylinder Pressure ShutoK
Dear Dr. Paperiello:
In accordance with 10 CFR 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 revises TSR Section 2.1.3.9, Low Cylinder Pressure Shutoff, to reflect an improved description of the system operation through changes to the Surveillance Requirements and the Basis Statement wording. In addition, allowable instmment system operating tolerances were incorporated into the calibration values specified in the TSR.
l l to this letter provides a detailed description and justification for the proposed changes to TSR i
2.1.3.9. Enclosure 3 provides a copy of the revised TSR and SAR page. The TSR page is provided for your review and approval. The revised SAR page has been evaluated in accordance with 10 CFR 76.68.
Based on the results of the 10 CFR 76.68 evaluation, the enclosed SAR page does not require prior NRC review and approval and is provided for information only. This revised SAR page reflects revisions associated with this Certificate Amendment Request and may not reflect other approved changes to this SAR page. Enclosure 4 contains the basis for USEC's determination that the proposed change associated with this Certificate Amendment Request is not significant.
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9806050351 980526 PDR ADOCK 07007002 C
PDR i
6903 Rockledge Drive, Bethesda. MD 20817-1818 Telephone 301-564-3200 Fax 301-564-3201 http://www.usec.com Offices in Liv:rmore, CA Paducah, KY Portsmouth. OH Washington, DC MONgy g i
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- Dr. Carl J. Paperiello May 26,.1998.
GDP 98-0075, Page 2 l
Since this Certificate Amendment Request is not required to support continued plant operation, USEC
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mquests NRC review and approval of this Certificate Amendment Request at your earliest convenience.
'Ibe amendment should become effective no later than 60 days &om issuance.
Any questions related to this subject should be directed to Mr. Mark Smith at (301) 564-3244. There are no new commitments contained within this submittal.
Sincerely, i
es H. Miller ice President, Production
Enclosures:
1.
Affidavit 2.
United States Enrichment Corporation (USEC), Proposed Certificate Amendment Request, Low Cylinder Pressure Shutoff, Detailed Description of Change 3.
Proposed Certificate Amendment Request, Portsmouth Gaseous Diffusion Plant, Letter GDP 98-0075, Removal / Insertion Instructions 4.
United States Enrichment Corporation (USEC), Proposed Certificate Amendment Request, Low Cylinder Pressure Shutoff, Significance Determination cc: Robert C. Pierson, NRC NRC RegionIII Office NRC Resident Inspector-PGDP NRC Resident Inspector-PORTS Randall M. DeVault, DOE l
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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 Co.pvi ion (USEC), that I am autbo.ized by USEC to sign and file with the Nuclear Regulatory Commissian this Certi6cate Amendma'* Reqwat for the Portsmouth Gascons Diffusion Plant, addressing revisions to the Low Cylinder Pressure Shutoff Technical Safety Requirements as contained in USEC Letter GDP 98-0075, that I ara familiar with the conwnts 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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ames H. Miller On this 26th 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 1
executed the same for the purposes therein contained.
l In witness hereofI hereunto set my hand and ofHeial seal.
L f-dftf4L 1Laurie M. Knisley, Notary Public/
State of Maryland, Montgomery County My commission expires March 1,2002 L_-_-_____
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GDP98@75 Page 1 of 3 i
United States Enricinnant Corporation (USEC)
L--g--i Certincate An=nans=* Request Low Cylinder Presumet ShutoK Detailed Descdytion of Change Specine TSR hetlana Affected The proposed change is to revise Technical Safety Requimment (TSR), Limiting Conditions for Operation (LCO) 2.1.3.9 and its Basis Statement for the purpose of improving the TSR wording that describes how the low cylinder pressure shutoff system is intended to operate and to establish coriW " Allowable Values" for the operation of the low cylinder pressure shutoff system. The specific TSR changes are as follows:
Surveillance SR 2.1.3.9.1 was revised to acknowledge that due to instrument channel uncertainties j
the cylinder low pressure system may actuate at a value (" Allowable Value") different from a l
specified setpoint and still be considered operable.
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" Perform a channel functional test to verify steam isolation to the autoclave when after the initial allowable time of cylinder heating the cylinder pressure does not exceed the allowable value."
Surveillance SR 2.1.3.9.2 was revised to specify the corresponding " Allowable Values".
" Perform calibration with allowable values of a 15.0 psia and s 65 minutes."
l The Basis Statement was revised to provide more descriptive information on the low cylinder pressum system operation and to add the basis for establishing the instrument " Allowable Value".
"The heating of a UF cylinder having a closed or plugged cylinder valve and/or pigtail 6
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would negate the protection afforded by the cylinder high pressure shutoff system due to L
the isolation of the cylinder from the high pressure instrumentation. A UF cylinder should not be heated if its pressure cannot be measured ha-excessive mternal cylinder pressures could potentially rupture the cylinder. The low cylinder pressure shutoff system will isolate the steam supply to an autoclave when after the initial nominal hour (s 65 minutes Allowable Value) of cylinder heating the cylinder pressure indication does not equal or exceed the Allowable Value of 15.0 psia. UF cylinders are not heawi unless their cold pressure is s 10 psia which provides a 5.0 psia margin to the Allowable Value for the purpose of ensuring valve and line clarity to the cylinder pressure instrumentation.
Setpoints established shall be consistent with ANSI /ISA-67.04 Part I, "Setpoints for Nuclear Safety Related Instrumentation" and ANSI /ISA-67.04 Part II, " Methodologies for the Determination of Setpoints for Nuclear Safety Related Instrumentation". The exception l
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l GDP98-0075 Page 2 of 3 I
United States Enrich =wne Corporation (USEC)
Proposed Certificate Amendment Request Low Cylinder Pressure Shutoff Detailed Description of Change is that 2S sample cylinders heated to 235 *F would have a void volume of over 9% with the cylinder valve closed. This system only provides protection during initial heating and not at any other time [SAR Section 3.2.1.1.1]."
Justification of the Change The low cylinder pressure shutoff system has been installed on all of the X-340 Complex autoclaves i
for the purpose of detecting any valve /line plug that would isolate the internal UF cylinder pressure 6
l indication from the UF cylinder high pressure autoclave steam shutdown systern. It is the basic function of the UF cylinder high pressure instruinentation to prevent a cylinder rupture (excessive internal pressure) within the autoclave due to either cylinder over filling, over heating or excessive amounts of " low molecular weight gases" in the cylinder. The operating premise of the low cylinder pressure shutoff system is based on the fact that as the UF in the cylinder is heated the corresponding UF vapor pressure will increase. Therefore, this internal UF. cylinder pressure rise over time can be monitored for the purpose of ensuring valve /line clarity between the UF cylinder and the pressure instrumentation. The low cylinder pressure shutoff system activates to stop the input of steam to the autoclave if a prec1.. coined UF internal pressure is not achieved within a specified time frame (s 65 n:inutes) after heating begins. Failure to achieve the specified pressure could indicate a plugged or closed valve.
Surveillance SR 2.1.3.9.1 was revised to reflect that due to typical instrument channel uncertainties the system may not function at the established setpoint while under test or "on demand" conditions.
l The limiting value for the actuation of the described system, which if excaadad would require the
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described system to be declared inoperable is known as the " Allowable Value". This concept is supported by ANSI /ISA-67.04 Part I, "Setpoints for Nuclear Safety Related Instnunentadon" and Part II, " Methodologies for the Determination of Setpoints for Nuclear Safety Related Instrumentation".
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Surveillance SR 2.1.3.9.2 was revised to specify the " Allowable Values" referenced in SR 2.1.3.9.1.
l The pr:ssure Allowable Value for the low cylinder pressure shutoff system is 15.0 psia. It has been
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j established that a UF, cylinder should not be heated unless it has a cold pressure of s 10 psia. The i
L sequence of procedure steps prior to determining the cylinder cold pressure provide an additional l
means for verifying the valve / lire clarity between the cylinder and the pressure instmmentation. After l:
the pigtail / cylinder hookup has been leak tested the pigtail is pressurized to approximately 110 psia and then vented into the cylinder. If the pressure in the pigtail decreases then clarity has been l
established and the final pressure reading will represent the cylinder cold pressure. Once the cold l
pressure has been determined to be s 10 psia then the cylinder is heated. From this point on the 1
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GDP98-0075 Page 3 of 3 United States Enrich==d Cw,- S-(USEC)
Proposed Certifieste Am*=dawd Request Iew Cylinder Pressure 2ndaff Detailed Description of Change cylinder pressure instrumentation should see the pressure rise as the UF vapor pressure increases and 6
therefore the minimum 5.0 psia differential or 50% rise in pressure between the cold pressure (s 10
. psia) and the Allowable Value of 15.0 psia is sufficient to ensure that valve /line clarity has been nimintained.
The proposed time Allowable Value for the low cylinder pressure shutoff system is 65 minutes. It is necessary to identify an allowable value or upper time limit parameter for two reasons. The first reason stemming from the need to clarify or quantify how long is the "after" in the portion of current SR 2.1.3.9.1 which states "...after the first hour of heating..." and the second reason being the need to address timer uncertainties, overall channel response time (i.e. microprocessor and valve closure performances), etc. that are inherent to the performance of a channel functional test. Based on the expected cylinder heating rate as previously reflected in the low cylinder pressure TSR criteria, the 5 mimite increase is considered to be a minor adjustment. The additional 5 minutes will not result in a challenge of the 100 psig minimum design pressure of a UF. cylinder nor does the increase in time alter the ability of the system to detect a pressure rise and thereby demonstrate that valve /line clarity i
has been maintained.
' In support of the changes to the LCO discussed above, TSR 2.1.3.9 Basis Statement were revised to reflect these conclusions and to improve the overall descriptive wording of the low cylinder pressure shutoff system operation. The TSR Basis changes clanfy that the purpose of the low cylinder pressure shutoff system is to detect a pressure rise in the cylinder during the initial heating period. This is accomplished by utilizing an instrument system that will respond to both a pressure and time input, in other words a rate of pressure rise.
'Ibe 20 psia and nominal I bour values currently in the SAR represent only one of many pressure / time l
combinations that exist during the cylinder heating evolution. The inclusion of allowable values mstead of what was in essence setpoints protects the intent of the SSC, i.e. pressure rise over time, while propeth acknowledging channel uncertainties and other process variables.
GDP98-0075 Page 1 of 4 Proposed Certincate Amendment Request Portsmouth Gaseous Diffhslon Plant Ider GDP98-0075 Removal / Insertion Instructions Remove Page Insert Page VOLUME 1 SAR 3.2.1.1.1 SAR 3.2.1.1.1 Pages 3.2-9/3.2-10 Pages 3.2-9/3.2-10 VOLUME 4 TSR 2.1.3.9 TSR 2.1.3.9 Page 2.1-18 Page 2.1-18 i
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SAR-PORTS May 26,1998 RAC97X0410 of 100 psig whereas, heavywall cylinders are rated for 200 psig. Normal operation at 220"F to 230'F, however, produces US pressures in the range ol80-90 psia. Thus, it is practical and safe ta keep the pressure switch set for the worst-case cylinders. UF. cylinders exhibiting an excessive cold pressure (greater than 10 psia) are cold burped to remove contammant gases that can cause excessive pressure to result upon heating.
In order to ensure that the cylinder valve and pigtail are opened to the pressure monitoring circuit, a pressure switch and timer are employed. Durmg initial beating of a Oh cylinder, if the rate of pressure rise indicates to the operator that cylinder pressure will be less than the Allowable Value of 15 psia within one hour (Allowable Value of s 65 minutes), then the steam input will be checked. If steam flow had already been established, then steam flow will be shut off, the autoclave will be shut down and opened, and the cylinder safety valve and cylinder valve will be verified open. The autoclave is then,eclosed and the heating cycle is reinitiated. A check of cylinder valve clarity is made; if valve clarity cannot be established, then the cause is investigated and corrected before further heating of the cylinder. The cylinder low pressure cutoff system serves as a backup to the operator and has been designated a Limiting Condition for Operation (LCO).
At the conclusion of a heating cycle, steam is exhausted from the autoclave through the blowdown exhaust system. This system consists of an air-jet ejector (aspirator) connected to the blowdown piping av.
is capable of exhausting steam from any one or all of the autoclaves simultaneously. A check valve located in each autoclave blowdown line prevents steam exhausted from one autoclave from entering another autoclave. A vacuum breaker is employed to allow a sweep of air through the autoclave. The Locking Ring Interlock system consists of a high and low pressure switch interlocked with the hydraulic locking ring to prevent the autoclave from being opened unless the autoclave pressure is within i0.5 psig. This feature is intended to prevent the mechanical damage and hazard to employees that would be expected to occur if the autoclave were unlocked while pressunzed with steam or UF. release products.
UF.
release detection and containment shutdown are accomplished by the steam-sampling / conductivity-monitoring system, the high autoclave pressure steam shu:down and the extreme high autoclave pressure containment shutdown. Each autoclave employs two independent steam sampling systems which withdraw steam through two small diameter lines each leading to a water-cooled condenser and reservoir. A conductivity cell is located in each reservoir to measure the conductivity of the condensate as the condensate flows through the reservoir. HF is formed by the reaction of UF with water when released inside the autoclave. HF in the condensate causes the conductivity to increase. This system is designed to detect UF. releases (as small as 2 lbs/ min) and cause the autoclave to automatically go into a containment-shutdown mode. This mode consists of appropriate alarms and closure of all the containment block valves. Additional features of the conductivity sampling system are a flow switch and a sanitary water supply tap. The flow switch will signal steam shutdown upon loss of cooling water flow to either condenser. The sanitary water tap is used to test the conductivity cells each time the autoclave is used. Sanitary water has sufficient conductivity to simulate a small UF. release. Ahhough the steam condensate conductivity system can initiate autoclave shutdown it is not considered to be necessary for autoclave operation and is not a safety system.
3.2-9
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SAR-PORTS January 4,1998 Rev.16, In the evem of a large release of UF inside an autoclave, a faster reacting system is available to effect a containment dundawn mode. That system is the Autoclave Shell High Pressure isolation system.
Durn's a large release, a massive amount cf HF gas would be rapidly produced by the reaction of UF. with water. The HF gas will increase the pressure in the autoclave and upon the autoclave internal pressure
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teachmg 15 psig, a raduadant pressure sensor will trigger corummment shutdown. De amount of HF gas produced is directly propornonal to the amount of water available to react with UF.. In order to limit the amount of water insmie the autoclave, two ind-aaadaar and rarhmdant water level probes are installed in the condensate drain line directly beneath the autoclave. Dese probes will trigger steam shutdown if the water level in the condensate drain should rise because of blockage downstream. This High Condene Level Cutoff system has been designated a safeo; rystem. An imtial water inventory test is performed on each new asoclave to A--
L he amount of water normally entrained wahin an operating autoclave.
t Past experience indicates that seven-foot feed and sampling and six-foot feed autoclaves can have' excess
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entrained water dunng normal operation. Con==iantly, these six-foot autoclaves are not full containment vessels in the event of a catastrophic cylinder rupture in a closed autoclave because the stated pressure
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vessel limits will be exceeded and the pressure relief system will vent excess material outside the X-343 l
Facility.
Each autoclave is equipped with an Autoclave Shell High Pressure Relief system to prevent the internal pressure from exceeding tiae maximum allowable working pressure (MAWP) as determined by Section VIII of the ASME Pressure Vessel Code. This system consists of a' pressure relief valve and rupture disc, each rated at or below the MAWP. The ruptura disc is aa~~=wy only to prevent constant exposure of the pressure relief valve to steam durmg normal operation. ' Such constant exposure could cause undesirable corrosion and scaling of the valve. Pressure above the rating of the pressure relief valve
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would be vented. (In the X-342A and X-343 Buildings, the safety relief valve exhaust is outside the L
tmilding. Due to the configuration of the equipment in the X-344A Budding, the PRV exhaust la inside the building.) The valve is eyad o re-seat at the MAWP to contain pressure (reaction products) up to t
that amount.
De autoclaves are =dppad with a pressure switch which is interlocked with the hydraulic system l
to prevent opening the autoclaves at greater than 0.5 psig. Only steam pressure would be present under normal conditions; however, opening the autoclave may cause enough thrust between the head and shell
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to propel the shell and cause equipment damage, ne X-342 and X-343 autoclaves have been fitted with I
an emergency hydraulic override switch. Using this switch, the shell can be opened at any time, as long as the internal pressure is below 0.5 psig.
The autoclave shells are thermally insulated. Under the insulation and against the ooter surface l
shell is tubing (tracing) through which steam or cold water can be passed Heatmg or cooling an autoclave l
may be aa~===y durmg clean-up operations following a release.
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3.2-10
TSR.-PORTS PROPOSED May 26,1998 RAC 97X0410 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 2.1.3.9 Low Cylinder Pressure Shutoff APPLICABILITY:
Autoclave Operational Mode II LCO: Low Cylinder Pressure Shutoff system shall be operable.
ACTIONS:
Condhion Required Actions Completion Time A.
Low cylinder pressure shutoff A.1 Place autoclave in 1 Hour system inoperable Mode VII SURVEILLANCE REQUIREMENTS:
Frequency Surveillance Quaiterly SR 2.1.3.9.1 Perform a channel functional test to verify steam isolation to the autoclave when after the initial allowable time of cylinder heating the cylinder pressure does not exceed the allowable value.
l Semiannually SR 2.1.3.9.2 Perform calibration with allowable values of a 15.0 psia and s 65 l
minutes.
BASIS:
'Ihe heating of a UF. cylinder having a closed or plugged cylinder valve and/or pigtail would negate the protection afforded by the cylinder high pressure shutoff system due to the isolation of the cylinder from the high pressure mstrumentation. A UF. cylinder should not be heated if its pressure cannot be measured because excessive internal cylinder pressures could potentially rupture the cylinder. The low cylinder pressure shutoff system will isolate the steam supply to an autoclave when after the initial nommal hour (s 65 minutes Allowable Value) of cylinder heating the cylinder pressure indication does not equal or exceed the Allowable Value of 15.0 psia. UF, cylinders are not heated unless their cold pressure is s 10 l
psia which provides a 5.0 psia margin to the Allowable Value for the purpose of ensuring valve and line clarity to the cylinder pressure instrumentation. Setpoints established shall be consistent with ANSI /ISA-67.04 Part I, "Setpoints for Nuclear Safety Related Instrumentation" and ANSI /ISA-67.04 Part II,
" Methodologies for the Determmation of Setpoints for Nuclear Safety Related Instrumentation".
The exception is that 2S sample cylinders heated to 235 'F would have a void volume of over 9% with the cylinder valve closed. This system only provides protection during initial heating and not at any other time l
[SAR Section 3.2.1.1.1].
3.2-11
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e GDP98-0075 Page1of4 United States Enrichment Corporation (USEC)
Proposed Certi8eate Amendment Request Low Cylinder Pressure Shutoff i
Signi8eance Detennimation De United States Enrichment Corporation (USEC) has reviewed the proposed changes associated I
with this certi6cate amendment request and provides the following Significance Determination for consideration.
1.
No Sioni6 cant hr = in the Nctivenen of the Plant's hfety hfeaumrds or Security Prnarnmm The revision of the low cylinder pressure Technical Safety Requiren nt(TSR) for the purpose ofimproving the Surveillance and Basis descriptive wording and the establishment of an instrument system allowable value are not addressed in plant safety, safeguards or security programs contained in Volume 3 of the Application for United States Nuclear i
. Regulatory Commission Certification for the Portsinouth Gaseous Diffusion Plant.
Therefore, the effectiveness of these programs is unaffected by these changes.
2.
No Rionificant Chance to Any Onnditinne to the Certinente of Cnmnliance None of the Conditions to the Certificate of Compliance for Operation of Gaseous Diffusion Plants (GDP-2) specifically address TSR Surveillance or Basis statements. Thus, the proposed change has no impact on any of the Conditions to the Certificate of Compliance.
3.
No Significant Chance to Any Canditinn of the Annroved Comnliance Plan l
The revision of the low cylinder pressure Technical Safety Requirement for the purpose of 1
improving Surveillance and Basis descriptive wording and the establishment of an instrument system allowable value is not addressed by the Compliance Plan nor in any conditions of the Compliance Plan. Herefore, revision of TSR 2.1.3.9 does not change any L
condition of the approved Compliance Plan, i
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No Rieni6 cant increme, in the Prnhahility of Occurrence or Cnneennerice= of Previously Evnlan'ad Accidaata l-SAR Section 4.2.3 discusses UF. releases involving autoclave feed, sampling and transfer operations. None of the autoclave accident scenarios discussed make any reference nor take credit for the low cylinder pressure shutoff system for consequence mitigation. Accident analysis Case R-27 Cylinder Rupture addresses the dropping ofliquid UF, filled cylinder c stside of an autoclave as being the worse case scenario. Case R-27 bounds any cylinder
GDP98-0075 Page 2 of 4 United States Enrichment Corporation (USEC)
Proposed CertiScate Anneedment Request Low Cylinder Prussere Shotoff Signi8cance Detered== Man release within a closed autoclave and as such the low cylinder pressure shutoff system has no impact. The low cylinder pressure shutoffsystem will continue to be able to perform its intended safety function and will remain con =i< tant with the original safety basis. Since the performance of the low cylinder pressure shutoff system remains unchanged and no credit is taken for this system to prevent or mitigate a UF. release there will be no significant increase in the probability or consequences of any previously evaluated accident.
5.
No New or Di& rent Tyne of Accident SAR Section 4.2.3 discusses UF. releases involving autoclave feed, sampling and transfer operations. None of the autoclave accident scenarios di=cus=ad make any reference nor take credit for the low cylinder pressure shutoff system as either an accident initiator or mitigator.
The proposed changes are primarily editorial in nature except for the establishment of instrument system Allowable Values. It has been determined that the establishment of Allowable Values of 15.0 psia and 65 minutes will not prevent the system from performing its intended safety function and is consistent with the original safety basis. The proposed changes will not create the potential for an accident that has not been previously evaluated in the SAR 6.
No Rionificant Reductinn in Marains of Rnfety The operating premise of the low cylinder pressure shutoff system is based on the fact that as the UF. in the cylinder is heated the corresponding UF. por pressure will increase.
Therefore, this internal UF. cylinder pressure rise over time can be monitored for the purpose of ensuring valve /line clarity between the UF. cylinder and the pressure instrumentation.
Under normal heating conditions the cylinder internal pressure will exceed 15 psia after 65 minutes of heating which represents a pressure rise of 50% or 5 psia, which is adequare to demonstrate valve /line clarity between the cylinder contents and the pressure ' strumentation m
required to be operable. Consequently, there is no significant reduction in the margin of safety as defined in the supporting bases documents for any TSR.
7.
No Rionificant Dem= in the Ffrectivene== of any Proarame or Planc Cnntnined in the certificate Annlientinn The TSR change that improves the descriptive wordmg and establishes an instrument system allowable value are not specifically addressed in any programs or plans contained in the
y GDP98-0075 Page 3 of 4 United States Enrichment Corporation (USEC)
Proposed Certi8cate Amendment Request Low Cylinder Pressure Shutoff Signi8cance Deter-i==*iam Certificate Application. Therefore, the revision of TSR 2.1.3.9 will not decrease the effectiveness of these programs or plans.
8.
The Prnnneed Chanoen do not Recnit in Undne Rieir to 11 Public Health and Rnfety. M Cnmman Defense and Recurity. and 3) the Envim. - =^
The proposed changes to TSR 2.1.3.9 do not change the ability of the low cylinder pressure shutoffsystem to perform its intended safety function nor do they change the probability and consequences of any accident previously analyzed. As such, these changes do not result in i.
undue risk to public health and safety. In addition, these revisions have no impact on plant emuents or on the programs and plans in place to implement physical security.
Consequently, these proposed changes only =h= + safety and pose no undue risk to the environment or the common defense and security.
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9.
There is no Chance in the Tynec or Rionificant T-in the Ammmte of any Fmnente that may be Releneed OfYmite.
The proposed changes have no effect on the generation of emuents and therefore, do not change the type of emuents that may be released offsite. Therefore, there is no change in the types or significant increase in the amounts of any emuents that may be released offsite.
10.
There is no Rionificant increa=* in Individual or Cumn1=+ive Ocennatinnnl Radiatinn Fvnnenre.
l The consequences of a UF. release associated with any postulated accident currently identified in the SAR will not increase as a result ofimproving TSR 2.1.3.9 descriptive wording and the establishment of an instrument system allowable value. This change does not increase the probability of a UF release in an autoclave. The proposed changes will not affect the mdiological protection program actions in place to minimize occupational exposures. Therefore, there is no significant increase in individu.d or cumulative l'
occupational radiation exposure as a result of this proposed change.
11.
There in no Rionificant Canatructinn Imnact This change does not involve a plant modification, therefore, there is no significant construction impact.
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GDP98-0075 Page 4 of 4 United States Enrichment Corporation (USEC)
Proposed Certiscate Amendment Regnest Low Cylinder Pressare Shatoff SigniBeance Determination 12.
There is no Rionificant increace in the Potential for Radininaical or Chemical Cnneennences frnm Previously Analv7ed Accidente
'Ihe revision ofTSR 2.1.3.9 will not increase the probability ofoccurrence or consequences (radiological and/or chemical) of any po<tulatad accident currently identified in the SAR.
The impmving of TSR 2.1.3.9 descriptive wording and the establishment of an instrument system allowable value 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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