ML20199F491
| ML20199F491 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 01/12/1999 |
| From: | Toelle S 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-99-0012, GDP-99-12, NUDOCS 9901210329 | |
| Download: ML20199F491 (14) | |
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4 USEC A Global Energy Company January 12,1999 GDP 99-0012 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 Paducah Gaseous Diffusion Plant (PGDP)
Docket No. 70-7001 Certificate Amendment Request - Buildings C-331 and C-335 Seismic Upgrades
Dear Dr. Paperiello:
1 In accordance with 10 CFR 76.45, the United States Enrichment Corporation (USEC) hereby submits a request for amendment to the certificate of compliance for the Paducah, Kentucky Gaseous Diffusion Plant (PGDP). This Certificate Amendment Request (CAR) propotes to revise the Plan of Action and Schedule for Issue 36 described in DOE /ORO-2026, Plan for Achieving Compliance with NRC Regulations at the Paducah Gaseous Diffusion Plant (Compliance Plan).
Compliance Plan Issue 36 requires that modifications to increase the seismic capability for floor and roof sections in Buildings C-331 and C-335 be completed by June 30,1999. This CAR proposes to change the Compliance Plan scheduled date for this issue to June 30,2000. As previously identified in USEC's recent monthly status reports (References 1,2, and 3), construction activities in these buildings have proven to be substantially more difficult than originally anticipated. In numerous locations, a significantly greater than expected effort has been required to remove and relocate interferences, remove existing steel, and install new steel. These unanticipated difficulties, coupled with the reduced worker productivity experienced in the high heat conditions of the process buildings, are projected to more than double the original estimated cost of the project with a resultant delay of 12 months in the overall construction schedule. to this letter provides a detailed description and justification for the proposed change. is a copy of the revised Compliance Plan pages associated with this request. Enclosure 4 contains USEC's determination that the proposed changes associated with this Certificate Amendment Request are not significant. Enclosure 5 contains DOE's approval of the proposed change. Enclosure 6 identifies new commitments contained in this submittal.
9901210329 990112 PDR ADOCK 07007001 7
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PDR 6903 Rockledge Drive, Bethesda. MD 20817-1818 Telephone 301564 3200 Fax 301-564-3201 http://ww.usec.com Offices in Livermore, CA Paducah, KY Portsmouth, OH Washington. DC
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Dr. Carl J. Paperiello January 12,1999
.GDP 99-0012, Page 2 Since this CAR affects Compliance Plan actions which are currently required to be completed by l
June 30,1999, a timely review of this request is desired. The amendment should become effective immediately upon issuance.
i Any questions related to this subject should be directed to Mr. Steve Routh at (301) 564-3251.
Sincerely,
{1 S.A.
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Steven A.Toelle Nuclear Regulatory Assurance and Policy Manager
References:
- 1. Letter from Steven A. Toelle (USEC) to Mr. Robert C. Pierson (NRC),"Paducah Gaseous Diffusion Plant, Docket No. 70-7001, Monthly Update on Progress of Seismic Upgrades to Buildings C-331 and C-335," Letter No. GDP 98-0217, dated October 15,1998.
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- 2. Letter from Steven A. Teelle (USEC) to Mr. Robert C. Pierson (NRC),"Paducah Gaseous Diffusion Plant, Docket No. 70-7001, Monthly Update on Progress of Seismic Upgrades to Buildings C-331 and C-335," Letter No. GDP 98-0217, dated November 16,1998.
- 3. Letter from Steven A. Toelle (USEC) to Mr. Robert C. Pierson (NRC), "Paducah Gaseous Diffusion Plant, Docket No. 70-7001, Monthly Update on Progress of Seismic Upgrades to Buildings C-331 and C-335," Letter No. GDP 98-0269,
- dated December 15,1998.
Enclosures:
- 1. Affidavit j
- 2. United States Enrichment Corporation (USEC), Certificate Amendment Request, Buildings C-331 and C-335 Seismic Upgrades, Detailed Description of Change
- 3. Certificate Amendment Request, Paducah Gaseous Diffusion Plant, Letter GDP 99-0012, Removal / Insertion Instructions
- 4. United States Enrichment Corporation (USEC), Certificate Amendment Request, Buildings C-331 and C-335 Seismic Upgrades, Significance Determination i
Dr. Carl J. Paperiello January 12,1999 GDP 59-0012, Page 3 Enclosures (continued):
Paducah Gaseous Diffusion Plant - Docket No. 70-7001 - Department of Energy Approval of Change to Compliance Plan Issue 36, dated January 8,1999.
- 6. Commitments Contained in this Submittal cc:
Mr. Robert C. Pierson (NRC)
NRC Region Ill Office NRC Resident Inspector-PGDP NRC Resident inspector-PORTS Mr. Randall M. DeVault (DOE)
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GDP 99-0012 Page1of1 OATil AND AFFIRMATION 1, Steven A. Toelle, swear and affirm that I am the Nuclear Regulatory Assurance and Policy Manager of the United States Enrichment Corporation (USEC), that I am authorized by USEC to sign and file with the Nuclear Regulatory Commission this Certificate Amendment Request for the Paducah Gaseous Diffusion Plant addressing revisions to Compliance Plan issue 36 described in USEC letter GDP 99-0012, 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.
S. M. /
Steven A.Toelle On this 12th day of January,1999, the individual 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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VLaGrie M. Knisley, Notary Public
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State of Maryland, Montgomery County My commission expires March 1,2002 1
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GDP 99-0012 Page 1 of 2 United States Enrichment Corporation (USEC)
Certificate Amendment Request Buildings C-331 and C-335 Seismic Upgrades Detailed Description of Change Description of Change The Plan of Action and Schedule for Compliance Plan Issue 36 states :
Modifications to increase the seismic capability for floor and roof sections in Buildings C-331 and C-335 will be completed by June 30,1999.
This Certificate Amendment Request proposes that the Plan of Action and Schedule for Compliance Plan Issue 36 be revised as follows:
Modifications to increase the seismic capability for floor and roof sections in Buildings C-331 and C-335 will be completed by June 30,2000.
Justification for the Change As required by Compliance Plan Issue 36, modifications to upgrade the seismic capability of Buildings C-331 and C-335 are in progress. However, the construction activities to complete the seismic upgrades are proceeding slower than originally anticipated. Construction experience to date has revealed several unanticipated problems that have caused delays in construction:
Removal and subsequent installation ofreplacement steel in an individual bay cannot a
be accomplished in two shifts as originally estimated. High ambient temperatures at the work sites severely curtail the amount of time that heavy labor can be performed.
Laborers spend a good percentage of each shift simply cooling down.
Demolition of existing bracing and gusset plates is taking more time than initially projected. Great care must be taken to ensure the remaining structures, systems and components (SSC) are not damaged by construction activities. Erection of protective structures, guards, drop nets, etc. in congested quarters is taking more time than initially projected.
As performance of the work progresses, more interferences have been discovered than were accounted for in the initial design, requiring increased engineering, drafting, planning, scheduling, procuring, and construction time. Additionally, plant maintenance personnel were originally identified as the work force which would
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GDP 99-0012 Page 2 of 2 move SSCs interfering with installation of the additional steel. "In plant" relocation resources are insufficient to support the expanded work load.
In order to recover some of the original installation schedule, two commitments regarding the construction sequence for performing these upgrades were revised to provide greater flexibility in managing the available construction resources (Reference 1).
In addition, other process improvements have been implemented which are reducing the amount of time required to complete work at each construction location. However, these improvements will not reduce task completion times to meet the initial estimates, and the delays experienced to date cannot be fully recovered.
Therefore, an extension of the June 30,1999 scheduled completion date is being requested.
References 1.
Letter from Steven A. Toelle (USEC) to Dr. Carl J. Paperiello (NRC), " Notification of Changes in Regulatory Commitments - Compliance Plan Issue 36 - Seismic Upgrades to Buildings C-331 and C-335," Letter No. GDP 98-0198, November 25,1998.
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d GDP 99-0012 2 Pages Total Certificate Amendment Request Paducah Gaseous Diffusion Plant Letter GDP 99-0012 Removal / Insertion Instructions Remove Pages Insert Pages PLAN FOR ACllIEVING COMPLIANCE WITH NRC REGULATION AT THE PADUCAH GASEOUS DIFFUSION PLANT (DOE /ORO-2026)
Issue 36, Seismic Capability of Buildings Issue 36, Seismic Capability of Buildings C-331 and C-335 C-331 and C-335 Pages 5/6 Pages 5/6 I
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_ = _ _ _ _ _ _ _ _
e 6-Seismic Capability of Buildings C-331 and C-335 PROPOSED Issue 36, Page 5
, RAC 98C0143 i
i the injury rate to individual workers was estimated at approximately 1 x 10" per year with a total i
injury rate risk estimated at 2.6 x 10-2 injudes per year (for an operating staff of 26). This is judged to be acceptable and is no greater than the risk of general office work on-site. Injury from 1
structures may even be higher in the office buildings, although the probability of exposure to HF and UO F releases would be greater in the process buildings.
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Therefore, it is concluded that the risk to the rsublic and the on-site workers from the unmitigated response of Buildings C-331 and C-335 2 not extreme and can be accepted without I
undue harm with the compensatory measures imposed on operations remaining in effect until the modifications are complete while the structural weaknesses are being corrected.
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RAN OF ACTION AND SCHEDULF The actions to upgrade the seismic capabilities of Buildings C-331 and C-335 are as follows:
1.
Based on a Directive for Information provided to USEC by DOE on September 22,1995, tb:
j USEC evaluation of the currently available information from the DOE safety analysis upgrade, j
effort related to seismic capabilities at the facility completed on October 23,1995, the DOE evaluation of the USEC response dated October 31,1995, and USEC's proposed resolution documented on January 9,1996, the following actions are being implemented to ensure the 4
protection of the workers and public health and safety:
4 Until the completion of modifications discussed below, operations in Buildings C-331 and C-335 will be limited to subatmospheric pressure within the enrichment cascade l
equipment.
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Operations personnel will be instructed on the specific emergency procedures for shutting down the affected enrichment cascade equipment and building ventilation systems l
following a seismic event.
I Building access will be limited to only those individuals essential to operations, j
inspections, or those personnel performing the modifications until they are complete.
l Modifications to increase the seismic capability for floor and roof sections in Buildings C-331 and C-335 will be completed by June 30,2000.
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At the time of transition from DOE regulatory oversight to NRC tegulatory oversight, USEC will inform NRC of the interim measures still in effect for the affected buildings and equipment and the current status of upgrading the seismic capabilities of the affected buildings and equipment.
3.
Documentation prepared for the design of the modification and other relevant information concerning implementation will be provided to the NRC, upon issue, for information and review.
PGDP January 12,1999
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Issue 36, Page 6 Seismic Capability of Buildings'C-331 and C-335 1
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By December 1,1997, USEC shall submit for NRC approval an updated seismic risk analysis for the Paducah plant site. The analysis shall:
i Consider all available regional and site-specific data published by the U.S. Geological 4
Survey.
Provide an estimate of the peak ground acceleration for a seismic event with a 250-year return period. If the estimate is greater than 0.15g, then the return period for a 0.15g event shall also be estim-d.
3 Any proposed modifications that may result from this analysis shall be subject to a backfit analysis pursuant to 10 CFR 76.76(b).
SUMMARY
OF REQUIREMENTS, COMMITMENTS, AND NONCONIPLIANCES Issue: Seismic Capability of Buildings C-331 ar,d C-335 Code of Federal Regulations Part Title 10 76.35(a)(4), 76.35(a)(6), 76.35(a)(8), 76.85 Application Commitment Section Safety Analysis Report 2.1.1, 2.6, 3.1, 3.3, 3.4, 4.2.2.6, 4.6.1, 4.7, Table 4.9-1 Application Not. compliance Statement Section Safety Analysis Report 2.7, 3.16.1, 4.10 PGDP Rev. 7,3/20/98 i
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GDP 99-0012 Page 1 of 3 l
United States Enrichment Corporation (USEC)
Certificate Amendment Request Buildings C-331 and C-335 Seismic Upgrades Significance Determination The United States Enrichment Corporation (USEC) has reviewed the proposed changes associated with this certificate amendment request and provides the following Significance Determination for consideration.
1 1.
No Significant Decrease in the Effectiveness of the Plant's Safety. Safeguards. or Security Programs This Certificate Amendment Request proposes a change in the schedule for completing the i
seismic modifications to Buildings C-331 and C-335 required by Compliance Plan Issue 36.
The seismic / structural capacity of Buildirgs C-331 and C-335 is not addressed in the plant safety, safeguards, or security programs contained in Volume 3 of the Application for United States Nuclear Regulatory Commission Certification for the Paducah Gaseous Diffusion Plant.
The current JCO, including required compensatory measures, for this Compliance Plan Issue will remain in effect until the modifications are completed. As a result, the effectiveness of the plant's safety, safeguards, and security programs is unaffected by this certificate amendment.
2.
No Significant Change to Any Conditions to the Certificate of Compliance j
None of the Conditions to the Certificate of Compliance address the schedule for completing the seismic upgrades to Buildings C-331 and C-335. Thus, the proposed changes have no impact on any of the Conditions to the Certificate of Compliance.
3.
No Significant Change to Any Condition of the Aporoved Comnliance Plan Issue 36 is the only portion of the Compliance Plan affected by the proposed changes.
Extending the completion date for the modifications is not a significant change because the JCO for Compliance Plan Issue 36 will remain in effect until the modifications are completed, including the required compensatory measures.
4.
No Sienificant Increase in the Probability of Occurrence or_Conseouences of Previousiv
. Evaluated Accidents Extending the completion date for the seismic upgrades has no effect on the probability of a seismic event. Althcugh Buildings C-331 and C-335 will remain in a weakened condition for a longer time, the consequences of postulated seismic failures of these buildings will be no
GDP 99-0012 Page 2 of 3 greater than those previously evaluated in the JCO for Compliance Plan Issue 36. The compensatory measures will also remain in effect until completion of the modifications.
Therefore, there will be no significant increase in the probability of occurrence or the consequences of previously evaluated accidents.
5.
No New or Different Tyne of Accident The accident scenario related to this certificate amendent is a seismic event that results in a release of UF from Buildings C-331 and C-335. No new or different type of accident has been 6
identified.
6.
No Significant Reduction in Margins of Safety This certificate amendment request has no impact on the margins of safety as defined in the basis for any Technical Safety Requirement. Therefore, no significant reductions in margins of safety will result.
7.
No Significant Decrease in the Effectiveness of any Program or Plans Contained in the Certificate Application For the reasons discussed in the response to Item 1 above, there will be no significant decrease in the effectiveness of any program or plan contained in Volume 3 of the Certification Application.
8.
The Pronosed changes do not Result in Undue Risk to 1) Public Health and Safety. 2) Commor*
Defense and Security. and 3) the Environment As discussed in the response to Item 4, the extension of the completion date for the seismic upgrades to Buildings C-331 and C-335 will not result in a significant increase in the probability of occurrence of previously evaluated accidents. Also, there will be no increase in the consequences of previously evaluated accidents and no new accidents have been identified.
Thus, there will be no undue risk to public health and safety, the common defense and security, or the environment.
9.
No Change in the Tynes or Significant Increase in the Amounts of Anv Effluents that Mav be Released Offsite_
As discussed in the response to Item 4, there will be no increase in the consequences of a postulated seismic event. Therefore, there will be no change it. Se types or significant increase in the amounts of any effluents that may be released offsite.
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i GDP 99-0012 Page 3 of 3 i
- 10. No Significant Increase in Individual or Cumulative Occuoational Radiation Exoosure i
The extensioa of the completion date for the seismic upgrades is related to an existing plan for a plant modification that is required by Compliance Plan Issue 36. No increases in individual or cumulative occupational radiation exposures are involved.
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- 11. No Significant Construction Imnact This change involves an existing plan for a plant modification and only changes the completion 3
date of the project. Therefore, there is no significant construction impact.
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- 12. No' Significant Increase in the Poten6.al for Radiological or Chemical Consequences froin
' Previously Analyzed Accidents 1
As discussed in the response to Item 4, there is no significant increase in the probability of
' occurrence ofpreviously evaluated accidents. Therefore, there is no significant increase in the
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. potential for radiological or chemical consequences from previously analyzed accidents.
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4.
. to GDP 99-0012 (3 pages total)
Letter to Mr. Steven A. Toelle (USr' i from Randall M.
DeVault (DOE), Paducah Gaseous D sion Plant - Docket No. 70-7001 - Department of Energy approval of Change to Compliance Plan Issue 36, dated January 8,1999.
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C Department of Energy Oak Ridge Operations Post Office Box 62 Oak Ridge, Tennessee 37831 -8651 January 8, 1999 Mr. Steven A. Toelle Nuclear Regulatory Anurance and Policy Manager!
United States Enrichment Corporation 2 Democracy Center 6903 Rockledge Drive Bethesda, Maryland 20817
Dear Mr. Toelle:
PADUCAH GASESOUS DIFFUSION PLANT - DOCKET NO. 70-7001 - DEPARTMENT OF ElvERGY APPROVAL OF CHANGE TO COMPLIANCE PLAN ISSUE 36 In a letter dated December 11, 1998, the United States Enrichment Corporation (USEC) requested the Department of Energy's (00E) approval of a USEC-proposed revision to the Paducah Gareous Diffusion Plant (PGDP) Compliance Plan Issue 36, " Seismic Capability of Buildings C-331 and C-335."
The proposed revision to Issue 36 would extend the schedule for completion of seismic modifications in PGDP Buildings C-331 and C-335 from the present date of June 30, 1999, to June 30, 2000.
DOE has reviewed and considered USEC's request for an extension in the schedule to implement structural reinforcevnts in PGDP Buildies C-331 and C-335.
Based on the current status of the modifications, the Uzards to personnel performing the work, and the projected improvement in building seismic capacity that can be anticipated by the present scheduled completion date, DOE finds the proposed Compliance Plan revision acceptable. Therefore, DOE approves amending the PGDP Compliance Plan Issue 36 to extend the completion date for implementing these structural reinforcements to June 30, 2000, This change does not affect any agreements between DOE and USEC related to assignment of costs for nuclear safety upgrades.
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Mr. Steven A. Toelle January 8, 1999 If there are any questions or comments concerning this approval, please contact me at (423) 576-0802.
Sincerely,
.A y
Randall M. DeVault Regulatory Oversight Manager Office of Assistant Manager for Enrichment Facilities 1
cc:
R. C. Pierson, NRC, Wnite Flint W. S. Schwink, NRC, White flint j
T. J. Reidinger, NRC, Region III i
R. M. George, NE-40, GTN G. G. Pennington, Bechtel Jacobs, MS-8551, K-1550V J. C. Hodges, EF-22, PAD E. W. Gillespie, EF-21, PORTS A. L. Takacs, EF-21, PORTS J. W. Parks, EF-20 T. T. Slack, CC-10 W. M. Yoder, DP-821, 2714-J i
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GDP 99-0012 l
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COMMITMENTS CONTAINED IN THIS SUBMITTAL i
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Modifications to increase the seismic capability for floor and roof sections in Buildings C-331 and C-335 will be completed by June 30,2000.
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