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2009

LES:

JUN 11

NEF-09-00104-NRC

Director : :

Office of Nuclear Material Safety and'safeguardsU.S. Nuclear Regulatory Commission . i

,

Attn: Document Control Desk : :

11555 Rockville PikgRockville, MD 20852

Louisiana Energy Services, LLCNational Enrichment FacilityNRC Docket No. 70=3103,

CoVer - COMMERCIAL-IN-CONFIDENCE-DSIEXPORT CONTROLLED INFORMATION (ECI)

: Withhold Under 10 CFR 2.390

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Subject: License Amendment Request for the National Enrichment Facility (NEF) to add sole

IROFS for an unanalyzed accident involving the assay:sampling rig (LAR-09-09)

Louisiana Energy Services (LES) requests an amendment to the Materials License in accordance

with Title l0 Code of Federal: Regulations Part 70 (10 CFR 70), Subpart E, $70.34, for theNational Enrichment Facility to authorize the design modification and revision of Items Reliedon for Safety (IROFS) to control chemical releases for the Assay Sampling,pit.

During an Owner Acceptance Review (OAR) in C-apenhurst, England, of ET-UK ProductSystem and associated system drawings it was discovered that the Assay Sampling Rig had notbeen fully analyzed in the National Enrichment Facility Integrated Safety Analysis (ISA)accident r"qu"n""r. A Condition Report was initiated to track completion of the analysisprocess. It has been determined that IROFS are nedessary to control chemical releases for theAssay Sampling Rig.

The criticality accident sequence specific to the use of the Assay Sampling Rig and its exhaust

,into an exhaust ventilation system is being analyzed independently and is outside the scope ofthis amendment request. The development of this analysis is ongoing and trackin$ will occurthrough the NRC corrective action program.

Enclosure 1 provides an affidavit whereby LES considers 'the information provided in thislicense amendment request as proprietary design sensitive information and export, controlledinformation and requests the information be withheld from public disclosure in accordance with10 CFR $ 2.390(a)(4).

Document.Transmitted herewithcontCins Expgrt Controlled Information .

(ECI). When separdted from enclosure,this document is decontrolled.

Cover - COMMERCIAL,.IN-CONFIDENCE-DSIEXPORT CONTROLLED INFORMATION (ECI)

LES building and operating the National EnrichmeWitHiUl&tdnadetglole$Rrql.$p0dence foi America

ruatitnatEnrichmentFacility,POBox1789,funice,NewMexicoAbZgf ,USA T: +1 575'.3944646 F:+1 5753g44545 Wiwww.nefnm.com

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.~LES Cover - COMMERCIAL .. IN-CONFIDENCE-DSI

EXPORT CONTROLLED INFORMATION (ECI)', Withhold Under 1.0 CFR 2.390

o

.0

JUN 111009' .

NEF-09-00 1 04-NRC

DirectQr 'Office Qf Nuclear Material Safe,ty and :Safeguards ' u.s. Nuclear RegulatQry CQimriissiQn

, Attn: DQcument CQntrQI Desk ,: ',11555 RQckville'Pik~:,

RQckville, :MD: 20852

LQuisiana ]~nerg'y Services,LLC NatiQnal Enrichment Facility

':NRC DQcket No.. 70"",3103,

Subject: License Amendment, RequestfQr the Nat~Qnal Enrichment Facility (NEF) to. add sQle :, ]ROFS fQr an unaIlalyzed accident inVQlving the assay 'sampling rig (LAR-09-09)

LQuisiana Energy Seryices (LES) requests an amendnient tot4e Materials License in accQrdance with Title'J OCQde Qf Federal RegulatiQns ' ,Part. 70. (10 CFR '70)~ 'Subpart E, § 70.34, fQr the NatiQnal Enrichment Facility, to' ,authQrize the designmQdificatiQn and revisiQn Qf Items Relied Qn fQr Safety (IROFS) to cQntrQI chemical releases fQr the Assay Sampling :Rig.

During an Owner Acceptance Review (OAR) in (:'apenhurst, Erighin4~.ofET-UK PrQduct , System and assQciated system drawings 'it ~as discQvered that the Assay Sampling Rig had nQt

been fully analyzed in the NatiQnal Enrichment Facility mtegrated Safety Analysis (ISA) accident sequences. A CQndition'RepQrt was initiated to. track CQmpletiQn Qf the analysis

, prQcess. It has been determined that IROFS are necessary to. cQntrQI chemical releases 'fQr the , :Assay Sampling Rig. " ,

The criticality accident sequence specific: to. the use Qfthe Ass'ay Sampling Rig ~nd its exhaust , : irito an exhaust ventilatiQn system is being analyzed independently and is 'Qutside the sCQpe Qf

'this 'amendment request. The develQpment of this :analysis' is' ongQing and trackin.'g will Qccur thrQugh the NltC cQrrective actiQn prQgram. " , , , '

Enclosure 1: provides an affidavit whereby LES CQnsiders 'the, .infQrmatiQn prQvided in this license amendment request as prQprietary design sensitive infoririation and eXPQrt: cQntrQlled­

. infQrmatiQn and requests the iilformatiQn be WIthheld frQm public disclQsure in accQrdance with , :HfCFR § 2.390(a)(4). "

Document ,Transmitted herew'ith contains J!:xport Controlled Information .

, (ECI). When separated from enclosure, this document is decontrolled.

Cover' - COMMERCIAL~IN-CONFIDENCE~DSI EXPORT CONTROLLED INFQRMATION (Eel):"

LES building and operating the National EnrichmeWitIm.ijjld:ib1iM~e1'91<@1@m@.~dence for America . . ... . . . .

:National Enrichment Facility, PO Box 1789, Eunice, New Mexico 88231, USA T: +1 575:394,4646 F: +1 575 394A545W www.nefnm.com

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frt-

q' ,. :

Cdver - COMMERCIAL-IN-CONFIDENCE-DSIEXPORT CONTROLLED TNFORMATION (ECI)

: Withlrold Under 10 CFR 2.390

Enclosurc 2 describes the Assay Sampling Rig andnew IROFS with its safety function.

identifieg the new accident sequence, and'

.': . .: : . . .': :': : : : :

,Enclosure 3 provides replacement page ghanges to the affected NEF license bagis documents.

- Enclosurd4 provides-a redacted 'rr"rrion of LAR 09j09, Brr"toru lEz,license urn"nd-erit request..:

LES ,appreciates the'efforts of the NRC staff in supporting the review,and' apprdval of..thisimportant amendment in a limely mann€r. ' ., : : j

:- -:. ... : -: :.. ...: '. .: :

If you have any questions regardin!, this license amendment request,Cowne, Director, Quality and RegUlatory Affairs, at 575.394.5253.

Chief Operating Officer a.ld,Chief Nuclear Officer' :.

. : ,l

Enclosures: Affidavit ,

'Description of Proposed Design ModificationsReplacement Page Changes to License Basis DocumentsRedacted Version of License Amendment Request

cc: .

Timothy C. Johnson, Senior Project ManagerTwo White Flint NorthMail Stqp T-8A33IIsts:Rockville PikeRockville, Mb 20852'2738 :

.:

DeborahA.Seymour : :: ', ',Chief, Construbtion Plojects'Bianch IU.S. Nuclear Regulatory Commission,Region IISam Nunn Atlanta Federal Center, 23 T85 , '

61 Forsyth Street, SW :'

Atlanta, GA 30303 893

1)2)3)4)

DbcurirentTransmittedherelvith :

contains Export Controlled Inforniation(ECI). \ilhen separated from enclosure,.,

this document is decontrolled.

Cover - COMMERCIAL-IN-CONFIDENCE-DSIEXPORT CqNTROLLED TNFORMATION (ECI)

Wittrhold Under 10 CFR 2.390

o

Cover -'- COMMERCIAL-IN-CONFIDENCE-DSI EXPORT CONTROLLED INFORMATION (ECI)'

Whhhoirl Under 10 CPR 2;390

, Enclosure' '2' 'de~crihe,s the' Assay SaII?-pling Rig and identifies the new ,accident sequence, and' new IROFS with its safety f~nction.. '. ' ,', ":

"

Enclosure 3 provides replacement page'changes to the affectecJ NEF licens.~ b~~:is documents. ,. 4 •

-Enciosu~e4 provide~·a redacted-v~r~ion'of Li\R-09-n9, Enclos~fe 2,licen~e a'mend~eritrequest.

LES :appreciates, the' efforts of the NRC staff in supporting the review: ana approval of. :this 'important aJ?endnieht in: a ~~~ely manner:' ; '" , ,

, If. you ha~~' '~yqtiesti~ns regarding th~s, .license amendment request, please contact Stepheri' ' C6wne, Director, Qualityan~,~egulatory Affairs" at 575.394.5253.: '

~:::l:b~~~ :Gregory Op Smith Chief Operating 'Officer a~d,;Chief Nuclear Officer:

Enclosures:~ 1) Affidavit, , 2) 'Description of Proposed Design Modifications 3) Replacement Page Changes to License Basis Documents 4) ~edacted Version of License Amendment Request

cc: Timothy C. Johnson, Senior Project Manager

, Two White Flint North , .' ..

Mail St~p T-8A33 ' " 11545 'Rockville Pike Rockville, MD 20852;'2738

Deborah A. Seymour Chief, Constnic~ion P~ojects '~ranch ~ ,~.S. Nuclear Regulato~y·Commission :Region II Sam Nunn Atlanta FederaJ Center, 23 T85 61 Forsyth Street, ~w. '

, 'Atlanta, GA 30303~893 ~

Document Transmitted herewith contains Export Controlled Information' '(ECI). When separated from enclosure,':

this document is decontrolled.

Cover - COMMERCIAL-IN-CONFIDENtE-DSI EXPORT ~QN:TROLLED INFOR~ATION (Eel)

Withhold Under 10 CFR 2.390

oNEF-09-000104-NRC

L'

Enclosure 4 -

(Redacted)

Description of Assay Sampling Rg, IROFS, andAccident Sequence

INTRODUCTION

Purpose

During an Owner Acceiltance Review (OAR) in Capenhurst, England; of ET-UKProduct System and associated system drawings it'was discovered that the AssaySampling Rig had'not been fully analyzed in the National Enrichment FacilityIntegrated Safety Analysis (ISA) accident sequences. A Condition Report (2008-1438-CR) was initiated to track completion of the analysis prcicess. Chemicalanalysis has now been completed, ISA team meetings have been held, and adesign change initiated.

Approval of a new IROFSC2I identified for mitigaiion against a chemicalsequence and inclusion of missing ISA information is requested. IROFSC2I isthe same IROFS proposed in LAR-09-08 submitted previously for the CascadeSampling and Tails Take-off vacuum pump and trap sets.

-A summary of the missing information is: (l) a chemic4l 4pgideni sequence, (2) acriticality accident sequence, and (3) for theAssay Sampling vacuum pump and trap set.

Scope

This License Amendment Request is to include the Assay Sampling vacuump,,11,p a'u rrap ssr r'lsslng u'smrual auurucnr sequcnuc'a'u

-

I into the license.documents along with a request for appioval of proposed newitems relied on for safety (IROFS) to control the chemical sequence.

Page I of20

L.0

1.1

1.2

a

o Enclosure 4 -

(Redacted)

NEF -09-0001 04-NRC

Description, of Assay Sampling Rig, IROFS, and Accident Sequence

1.0 INTRODU'CTION

1.1 Purpose

During an Owner Acceptance Review (OAR) in Capenliurst, England~ ofET-UK Product System and associated system drawings if Was' discovered that the Assay Sampling Rig had'not been fully analyzed in the National Enrichment Facility Integrated Safety Analysis (lSA) accident sequences, A Condition Report (2008-1438-CR) was initiated to track completion of the analysis process, Chemical analysis has n<?w been completed, ISA team meetings have been held, and a design change initiated.

Approval of a new IROFSC21 identified for mitigation against a chemical sequence and inclusion of missing ISA information is requested. IROFSC21 is the same IROFS proposed in LAR-09-08 submitted previously for the Cascade Sampling and Tails Take-off vacuum pump ~nd trap sets.

~A summary of the missing information is: V"'~""UVV' (2) a criticality accident sequence, and (3) fot: the Assay Sampling vacuum pump and trap set.

1.2 Scope

This L, icense Amendment Request is to include the Assay S~ ~p and trap set missing chemical accident sequence'and _ .. into the license ,documents along with a request for approval of proposed new items relied on for safety (lROFS) to control the chemical sequence.

Page,} of20

oEnclosure 4 (Continued)

NEF-09-000104-NRC

The criticality accident sequence specific to the use of the Assay Sampling Rigand its exhaust into an'exhaust ventilation system is being analyzedindependentlyand is outside the scope of this amendment request.

Since the develbpmerit of this analysis is ongoing, but is not yet complete,commitments and "placeholders" in the License Basis Documents are proposedhere to ensure completion of the rig criticality sequence and supportingdocumentation (see Section 3.0.be1ow). this i"s consistent with the current ISAwhere completion of certain data or design requirements are stated to occur duringthe final design stage. Formal tracking will occur through the NEF correctiveaction program

Page 2 of20

therefore, new chemical and criticality supporting documentation is required.

()

n

Enclosure 4 (Continued) NEF -09-0001 04-NRC

therefore, new chemical and criticality suppoi-tingdocumelltation is requir~d.

The criticality accident sequence spedfic to the use of the Assay Sampling Rig and its exhaust into an'exhaus't ventilation system is being analyzed.independently and is outsiqe the scope of this amendment request.

Since the developmerit of this analysis is ongoing, but is not yet complete, commitments and "placeholders" in the License Basis Documents are' proposed here to ensure completion of the rig criticality sequence and supporting documentation (see Section 3.0 ,below). This is consistent with the current ISA where completion of certain data or design requirements are stated to occur during the final design stage. Formal tracking will occur through the NEF corrective action program.

,10

Page 2 of20

2.0

2.1

Enclosdre 4 (Corltinued)NEF-09-000104-NRC

DESCRIPTIONS AIID ANALYSIS :

Current License:

A. The Assay Sampling rig'is currently described io r.rr.rul processes in theIntegrated Safety Analysis 0SA) Summary-(ISAS). Descriptions were foundin Sections:. 3.4.1.3, Product Take-off System;o 3.4.1.4, Tails Take;off System; r

. 3.4.4.2(E), Assay Sampling System;o 3.4.4.3, Design Description;o 3.4.5.2(F), Assay Sampling Subsyslem;. Table 3.4-4, Prbduct Take-off System Design;. Table 3.4-5, Product Take-off System.Codes and Standards;-o Table 3.7-2, Accident Sequence Descriptions';. Table 3.7 -7 , Product System (Safe-by-Design Components)

and in the Safety Analysis.Report (SAR) in:. SAR Table 5.1':2, Safety Criteriafor Buildings/Systems/Components,. ' SAR Sbction 5.2.1.3.5, Pump-fr"" Volume Assumptions, ando SAR Section, 5.2.1.4, Nuclear Criticality Sofety Analyses.

B. ISAS Section 3.4.1.3, Product Take-off System, and Section 3.4.1.4, TailsToke-off System, currently discuss each system.

C. ISAS Table 3.4-4, currently includes a ddscription of the Assay S

Chemical Tran Set.

ISAS Table 3.4-5, Produci Take-offSyrl"* Codes and Standards, currentlyincludes codes and standards applicable tb the Product System. The AssaySampling system is considered part of the product system.

ISAS Table 3.7-2, Accident Sequence Descriptions, Accident Identifier:"LOSS OF SAFE-BY-DESIGN ATTRIBIJTE," currently includes thb.Product system as rbquiring safe-by-design components.

_ The Assay Sampling

Rig provides a function for the Product System. The safe-by-designcomponents for the Assay Sampling Rig are identified in Tables 3.7-6 through

Page 3 of20

D.

n

Enclosure 4 (Continued) NEF-09-000104-NRC

2.0 DESCRIPTIONS AND ANALYSIS:

2.1 Current License:

A. The Assay Sampling rig·is currently described in several processes in the Integrated Safety Analysis (ISA) Summary-(ISAS). Descriptions were found in Sections: • 3.4.1.3, Product Take-off System; • 3.4.1.4, Tails Take-;:offSystem; • 3 .4.4.2(E), Assay Sampling System; • 3.4.4.3, Design Description; • 3.4.5.2(F), Assay Sampling Subsystem; • Table 3.4-4, Product Take-off System Design; • Table 3.4~5, Product Take-off System ,Codes and Standards; .• Table 3.7-2, Accident Sequence Descriptions; • Table 3.7-7, Product System (Safe-by-DesignComponents)

and in the Safety Analysis.Report (SAR) in: • SAR Table 5.1:-2, Safety Criteriafor Buildings/Systems/Components, • ,SAR Section 5.2.1.3.5, Pump free Volume Assumptions, and • SAR Section, 5.2.1.4, Nuclear Criticality Safety Analyses.

B. ISAS Section 3.4.1.3, Product Take-off System, and Section 3.4.1.4, Tails Take-off System, currently discuss each system.

C. . tion of the As

D. ISAS Table 3.4-5, Product Take-off System Codes and Standards, currently includes codes and standards apPlicable to the Product System. The Assay Sampling system is considered part of the product system.

E. ISAS Table 3.7-2, Accident Sequence Descriptions, Accident Identifier: "LOSS OF SAFE-BY -DESIGN ATTRIBUTE," currently includes the. Product system as requiring safe-by-design components. The Assay Sampling Rig provides a function for the Product System. ?The·saf~-by-design components for the Assay Sampling Rig are identified in Tables 3.7-6 through

,Page 3 of20

o

"K$5;.i[3ffi]'_i$i?

3.7.21, Product System, Criticality Assessment of Passive Safe-By.Design"Components.

F. ISAS Table 3.7-7, Product System (safe-by-design components) identifiessafe-by-design attributes of critical components on the Assay Sampling Rig.The AsSay Sampling Rig components (column A) are identified by sequenceID (column B) and critical design attributes are identified in column C forupset conditions (column D). The upset conditions analyzed for the AssaySampling Rig are: corrosions/erosion, fire,-maintenance, impact/drop/ external -

events (construction on site), external events (failure of above-ground liquidstorage tanks); external events (seismic, tornado, external fire, local intense !

precipitation); more heat, more pressure, loss of confinement or leakage.

The components or support equipment to the vacuum rigs currenqy 3qelyzg4for loss of safe-bv-design affribute for the Producf Svstem are:

The critical design attributes have been identified forall applicable HAZOP Guidewords, following the methodology described in"

the NEF ISA Summary.

credit for any materials in these components to absorb neutrons, and thusreduce. hn would have to be justified. To avoid tliis, components that maypotentially acbumulate fissile material are modeled as being filled with<iptimally water moderated uranic breakdopn material. Thus, any internalmaterial other than this already modeled, worst case fissile material isconservatively ignored in any criticality calculation.

When a criticality calculation is performed, the.three dimensional arrangementof fissile material is what determines

in a criticality

G. ISAS Accident Identifier: PT2-5, prohibiting hydrocarbon oils in vacuumpumps is currently ideritified in Table 3.7-2,'Accident Sequence Descriptions,as applicable to the Assay Sampling Systerhs. IROFS30a, IROFS30b, andIROFS3Oc will continue as controls for the Assay Sampling rig.

Page 4 of20

o

Taking

analysis, this'change has iro impact on criticality safety.

() Enclosure 4 (Continued)

NEF -09-0001 04-NRC

3. 7 ~21, Product System, Criticality Assessment of Passive Safe-By .. Design c

Components.

F. ISAS Table' 3.7';'7, Product System (safe-by-design compoIl:ents) identifies safe-by-design attributes of critical components on the Assay Sampling Rig. The Assay Sampling ·Rig components (column A) are identified by sequence ID (column B) and critical design attributes are identified in columnC for upset conditions (column D). The upset conditions analyzed for the Assay Sampling Rig are: corrosions/erosion, fire,-maintenance, impact/drop/ external·· events (construction on site), external events (failure of above-ground liquid storage tanks); external events (seismic, tornado, external fire, local intense precipitation); more heat, more pressure, loss of confinement or leakage.

The components or support equipment to the vacuum rigs 1"'111'"r""1'"lth,

for loss of . attribute for the' Product

The critical design attributes have been iden ed for all applicable HAZOP Guidewords, following the methodology described in· the NEF ISA Summary. .

Taking credit for any maieri~ls in these components to absQrbneutrons, and thus reduce. keff would have to be justified. To avoid tliis, components that may potentially accumulate fissile material are mod~led as being filled with optimally water moderated uranic breakdo~n material. Thus, any internal material other than this already modeled, worst case fissile material is conservatively ignored in any criticality calculation.

When a criticality calculation' is performed the· three dimensional <::lr1'"<::ln'''''''1'"I'"1&U,-t

of fissile material is what determines

analysis, thi~ change has no impact on criticality safety.

G. ISAS Accident Identifier: PT2-5, prohibiting hydrocarbon oils in yacuum pumps is currently identified in Table 3.7-2;Accident Sequence Descriptions, as applicable to the Assay Sampling Systems. IROFS30a, IROFS30b, and IROFS30c will continue as controls for the Assay Sampling rig.

Page 40f20

o H.

Enclosure 4 (Continued)NEF-09-000104-NRC

The Safety Analysis Repoft (SAR) Table 5.1-2, Sof".ty CriteriaforBuildings/Systems/Components, identifies UF6 pumps and their safety criteriaand shows how the safe values of Table 5..1-l are'applied to the"facility designto prbvent a nuclear criticality event.

SAR Sectioh 5.2.1.3:5, Pump Free Valhme Assumption, identifies the types ofpumps and the puTp free volume assirmptions.

Section 5.2.1.4, Nucleaz Criticality Safety Analyses, identifies criticalityanalysis is required for individual systems or components and their interaction

Missine f{om Licenspi

The following items are missing from the licensebasis documents. (Any'coffesponding license basis document page updates can be found inAttachment 3.)

A. ISAS Section 3.4.4.2(E desi description for the Assav Sam'pli Ris needsto be uodated to reflect

B. ISAS Section 3.4.5.2G). desi dbscription for the Assay Sampline'Ris needsto be uodated

ISAS Table 3.7 "-2, Accident Sequence, needs a chemical sequence added forthe Assay Sampling pump and trap set.. Based on consequence analysis, anew sole IROFSC2I is proposed to control this sequence. This C2l IROFS isthe same IROFS proposed in LAR-09-08 submitted previously for theCascade Sampling.and Tails Take-off vacuum pump and trap sets.

A"risk table is needed to identiff the chemical sequence risk factors. A new.accident sequence and risk table is propoSed for addition to Table 3.7 -l for theAssay Sampling fig chemical sequence.

A risk table is needed to identiff the critic ality sdquence risk factors.However, the criticality risk determination is outside the"scope of this LAR(see Commitment items in Section 3 below).

Page 5 of20

I.

J.

2.2

D.

E.

F.

with other.systems or components containing enriched Uranium.

ISAS Table 3.4-4 ion of the

o

2.2

n '--...-/

Enclosure 4 (Continued) NEF -09-0001 04-NRC

H. The ~afety Analysis Repoi1(SAR) Table.5.1-2, SafeJy Criteriafor Buildings/Systems/Components, identifies UF 6 pumps and their safety criteria and shows how the safe values of Table 5 .. 1-1 are' applied to the.facility design to prevent a nuclear criticality event.

I. SAR Secti<?ll 5.2.1.3:5, Pump Free Vdlume Assumption, identifies the types of pumps and the pu~p free volume assumptions.

J. Section 5.2.1.4, Nuclear Criticality Safety Analyses, identifies criticality analysis is required for individual systems or components and their interaction with othe~-systems or components containing enriched Uranium.

Missing from License:

The following items are missing from the license basis documents. (Any'· corresponding license basis document page updates can be found in Attachment J.)

D. ISAS Table 3.7-:2, Accident Sequence, needs a chem~ca! sequence added for the Assay Sampling pump and trap set." Based on consequence an~lysis, a· new sole IROFSC21 is proposed to control this sequence. This C21 IROFS is the same IROFS proposed in LAR-09-08 submitted previously for the Casca4e Sampling ,and Tails Take-off vacuum pump and trap sets.

E. A.risk table is needed t6 identify the chemical ·sequence risk factors. A new. accident sequence and risk table is proposed for addition to Table 3.7-1 for the Assay Sampling rig chemical sequence.

F. A risk table is needed to identify the criticality se'quence risk factors. However, the criticality risk determination is outside the 'scope of this LAR (see Commitment items in Section 3 below).

Page 5 0[20

o'Kf;5;-i53ffi'-i$i2

t

G. Table 3.8-l ,"Items Relied onfor S"futy (IROFS), and Table 3.8-2, Sole ltemsRelied on for Sofety (IROFS )require a change to add a new IROFSC2I forcontrol of the missing chemical sequence (new sequence PT5-l).

ISAS Table 3 .7 -7 , Froduct System (safe-by-design components) identifiessafe-bv-desisn attributes of'critical comoonents on the Assa

I. ISAS Table 3.7-2, Accident Sequence, nOeds development.of a criticalitysequence similar toEC'4-2 in the ISA Summbry. Analysis of this criticalitysequence is outside the scope of this License Amendment (see Commitmentitems in Section 3 below). i

The reqgirement to exhaust to a Safe-by-Design (SBD) GEVS will beincluded in ISAS Table 3.7 -7 Critical Attributes. for the Product System in theCriticality Assessment of Passive Sde-by-Design Compoytents table, andidentified to be analyzed during final design. Table 3,7-7 components areaddressed.by Accident Sequence "LOSS 9F SAFE-BY-DESIGNATTRIBUTE" in Table 3 .7 -2, Accident Sequence Descriptions, in the ISASummary. Inclusion here ensures the requirement to exhaust to a Safe-by-Design GEVS and establish new IROFS as required is met.

The Assay Sampling Rig will be analyzed for the missing criticality sequencesand any IROFS or credited design features will be identified during final designchanges occurring concurrently for the GEVS;systems. This concurent criticalitysequence analysis.and establishment of any associated controls is outside thescope of this License Amendment Request.

Page 6 of20

o

Enclosure 4 (Continued) NEF -09-0001 04-NRC

G. Table 3~8-1, items Relied onfor Safety (IROFS), and Table 3.8-2, Sale Items Relied on for Safety (IROFS )require a change to add a new IROFSC21 for control of the miss,ing chemical sequence (new sequencePT5-1).

IIISAS Table 3.7-7, Product System (safe-by-design components) identifies ft b d' tt 'b t f 't' 1 t th A S l' R' ! • • ! !

I. ISAS Table 3.7-2, Accident Sequence, needs development,.of a critica~ity sequence similar to .EC4-2 in the ISA Sumniary. Analysis of this criticality sequence is outside the scope of this License Amendment (s.ee Commitment items in Section 3 below).

The reql:lirement to exhaust to a Safe-by-Design (SBDYGEVS will be, included in ISAS Table 3.7-7 Critjcal Attributes, for the Product System in the Criticality Assessment of Passive Safe-by-Design Comporzents table, and identified to be analyzed during final de.sign. Table 3: 7-7 components are addressed'by Accident Sequence "LOSS 9F SAFE-BY -DESIGN ATTRIBUTE" in Table 3.7-2, Accident Sequence Descriptions, in the ISA Summary. Inclusion here ensures the requirement to exhaust to a Safe-by-Design GEVS and establish new IROFS as required is met. .

The Assay Sampling Rig will be analyzed for the missing criticality sequences and any IROFS or credited design features will be identified during final design changes occurring concurrently for the GEVS~systems. This concurrent criticality sequence analysis. and establishment of any associated controls is outside the scope of this License Amendment Request.

Page 6 0[20

n= , EKB;r;;i53ffi1'lxi?

3.0 COMMITMENTS

A. The following commitments will be"added to the Safety Analysis Report- (SAR), Section 3.4, consistent with other.commitments currently identified in.the SAR. See Attachment 3 of this amendment for a description of the pagechanges.

a. The commitment fol the Assay Sampling Rig UF6 process pump or pumpset to exhaust to a Safe-by-Design (SBD) Gaseous Effluent YentilationSystem (GEVS) will be.added to Section3.4, Compliance ltemCommitments, of the SAR. This compliance item will include completionof the criticality analysis, accident sequence, and risk.determination. Theaddition of a new commitment (Section 3 .4,41) in this section will beconsistent with the other compliance items (e.g., Section 3.4.1).

b. JSAS-Table

3.7 -2, Accident Sequence'Descriptions, Abcident Identifier'LOSS OF SAFE-BY-DESIGN ATTRIBUTE." The requirement for the

Assay Sampling Rig exhausting to a SBD GEVS will be added to thissection. This sequence includes the Product system as requiring safe-by-design components. The Assay Sampling Rig provides a function for theProduct System. The safe-by-design components"for the Assay SamplingRig are identified in the cited Tables 3 ,7 -6 through 3 .7 -21 ; specifically,Table 3.7-7, Product System, Criticality Assessment'of Passive Safe-By-Design Components.

c. ISAS Table 3.7-T"Critical AttVibutes, will be updated toinclude therequirement for the Assay Sampling Rig to-exhaust to a SBD GEVS, butwill be analyzed durfng the final design for a SBE GEVS (see

Attachnient 3,,page changes).

PageT of20

oo

o

3.0 COMMITMENTS

Enclosure 4 (Continued) NEF-09-000104-NRC

A. The following commitments will be"added to the Safety Analysis Report (SAR), Section 3.4, consistent with other. commitments currently identified in, the SAR. See Attachment 3 of this amendment for a description oft~e page changes.

a. The commitment for the Assay Sampling Rig UF 6 p,rocess pump or pump set to exhau~t to a Safe-by-Design (SBD) Gaseous Effluent Ventilation, System (GEVS) will be.added to Sect.ion 3.4, Compliance Item Commitments, of the SAR. This cOtnpliapce i!em will include completion of the criticality analysis, accident sequence, and risk-determination. The addition of a new commitment (Section 3.4:41) in this section will be consistent with the other compliance items (e.g., Section 3.4.1).

b. IS1.\S -Table 3.7-2, Accident Sequence Descriptions, Accident Identifier "LOSS OF SAFE-BY-DESIGN ATTRIBUTE." The requirement for the Assay Sampling Rig exhausting to a SBD GEVS will be added to this section. T4is sequence includes the Product system as requiring safe-by­design components. The Assay Sampling Rig provides a function for the Product System. The safe-by-design components' for the Assay Sampling Rig are identified in the cited Tables 3.7-6 through 3.7-21; specifically, Table 3.7-7, Product System, Criticality Assessment 'of Passive Safe-By­Design Compone11;ts.

c. ISAS Table 3.7-7'Critical Att'ributes, will be updated to 'include the requirement for the Assay Sampling Rig to' exhaust to' a SBD GEVS, but will be analyzed during the final design for 'a SBD GEVS (see Attachnient 3"page changes).

Page 70f20

oEnclosure- 4 (Continued)

NEF-09-000104-NRC

4.0 DESCRIPTION OF CHANGES

The Assay Sampling system is described in the ISA Summary in Section 3.4.. Forsimilar sampling and evacuation rigs, srich as thd-cascade sampling rig, IROFS for"chemical and cr4&4!i8 lq!{rol have beeq identifiqd l4lbe IsIl$ummary (ISAS).

lins Ris differs from other setS

while using the Assav Samolins Ris insimilar rations.

There are no other major design differences.

Therefore, th6conseiluences'have potential to be higher for the Assay Sampling Rig"than currentanalyses

During a classified ISA team moeting in Capenhurst, United Kingdom (UK), theProduct system was evaluated. This meeting included discussion on the Assay..Sampling vacuum pump and trap set. Additionally, a follow-up meeting rrvas heldspecific tb the Assay Sampling set. The individual components, by process areaand process parameters (e.g., type of pumps, length of piping, actual valving, etc.)were identified,.the system design was evaluated, applicable controls weredisbussed, IROFS were identified, and in-depth system operation ind"inherentdesign protective features were all reviewed. A number of proposals wereconsidered to adequately control process hazards. In depth discussions were heldregarding adequate controls for the risk of UFo leakage into the workplace duringAssay Sampling operations. Facility baseline design information was obtainedthrough controlled'facility drawings, specifi cations, calculations; and technicaldocuments for review.

The iSA procesS"employed is consislent with the NEF ISA methodology and withguidance in NUREG-1513 and NUREG-L'12}. Comp"liance with performanceiequirements of l0 CFR 70.61 is achieved. Developmeht of the accidentsequence meets the controlled risk index criteria,_.consisteirt with NUREG:-1520accident sequence evaluation criterion. This approach, as discussed in the NEFISA Sumffi?ry, Section 3.1.1 ,ISA Methods, employs a'semi-quantitative riskindex method for categorizing accident sequences in terms oitheir likelihood ofoccurrence and their consequences of concern.

Page 8 of20

n

o

o

4.0 DESCRIPTION OF CHANGES

Enclosure 4 (Continued) NEF -09-0001 04-NRC

The Assay Sampling system is described in the ISA Summary in Section 3.4., For simila~ sampling and evacuation rigs, such as the" cascade sampling rig, IROFS for" chemical and criti control have been identified in the ISA S).

There are no other major design differences.

Th~refore, the consequences'have potential to be higher for the Ass"ay Sampling Rig,than current analyses.

During a classified ISA team meeting in Capenhurst, Uni~ed Kingdom (UK), the Product system was evaluated. This meeting included discussion on the Assay, Sampling vacuum pump and trap set. Additionally, a follow-up meeting was held specific to the Assay Sampling set. The individual components, by process area and process parameters (e.g., tYpe of pumps, length of piping, actual valving, etc.) were identified,. the system design was evaluated, applicable controls were discussep., IROFS were identified, and in-depth system opera!ion fmd~inherent design protective features were all reviewea. A number of proposals were considered to adequately control process hazards. In depth discussions were held regarding adequate controls for the risk of UF6 leakage into the workplace during Assay Sampling operations. Facility baseline design information was obtained through controlled~facility drawings, specifications, calculations; and technical documents for review.

the ISA process 'employed is consis~ent with the N~F ISA methodology and with " guidance jn NUREG-1513 and NUREG-l520. Compliance with performance requirements of 10 CF~. 70,61 is achieved. Development of the accident sequence meets the controlled risk index criteria, consistent with NUREG'-1520 accident sequence evaluation criterion. This approach, as discussed in the NEF I.SA Summary, Section J.l.l, ISA Methods, employs a'semi-quantitative risk index method for categorizing accident sequences in terms of their likelihood of Qccurrence and their consequences of concern.

Page 80f20

4.1

Enclosure 4 (Contiffued)NEF-09-000104-NRC

Upon conclusion of the ISA team meetings, configuration changes were d

completed and this License Amendment was developed. l0'CFR 70.72c requiresprior NRC approv'al for new accident sequences and new sole IROFSapplicability. Permanent bhanges to the unclassified iSe wru be incorporated intothe NFF ISA documentation,and ISA Summaly upon approval of this amendmentrequest. Any classified or design sensitive changes are updated ald maintained inthe classified ISA located in Capenhurst, UK. Unclassified updates to the licensebasis documents are attached in Enclosure 3.

This license amendment request proposes control of chemical consequences byinclusion in the ISA of a new accident sequence (PT5-l) requiring a new.IROFSC2I as a flow restriction to control'consequences below 10 CFR 70.6Ithresholds. The IROFS design will be consistent with the consequencecalculations. Atty existing IROFS or SBD controls will be retained. IROFS andsafe-by-design comporients are maintained at quality level l-.

IROFS and SBD Cohtrolq

The proposed Assay Sampling Rig IROFS-are as follows:.

()

o

able I , New IROFS for Ass Sam I RiAccidentSequence

IROFS

flsafetv Fu.nction Applicabilitv Chemical /

CriticalitvAffected

Area

PT5-I c2l(.)t!A

Flow restriction to ensure in the eventof a postulated release workerconsequences of inhalation of uranic'material and HF are low. An orifice orpipe restrictiorf on the suction side ofthe vacuum pump provides flowrestriction consistent with thecorisequence analysis. .

New IROFS Chemical ProcessServicesCorridor "

Page 9 of20

o

Enclosure 4 (Continued) NEF -09-000 I 04-NRC

Upon conclusion of the ISA team meetings, configuration changes were completed and this License Amendment was developed. 1 O'CFR 70.72c requires prior NRC approval for new accident sequences and new sole IROFS applicability. Permanent changes to tht? unclassified iSA will be incorporated into the NEF ISA documentation, and ISA Summ,!ry upon approval of this amendment request. Any classified or design sensitive,chang~s are updated a~d maintained in the classified ISA located in Capenhurst, UK." Unclassified upda(es to the license basis documents are attached in Enclosure 3.

This license amendment request proposes control of chemical consequep.ces by inclusion in the ISA of a new accident sequence (:PT5-1) requiring a !lew" IROFSC21 as a flow restriction to control:consequences below 10 CFR 70.61 thresholds. Th~ IROFS design will be consistent with the consequet;tce calculations. Any existing IROFS or SBD controls will be retained. IROFS and safe-by-design components are maintained at q~ality level 1-.

4.1 IROFS and SBD Controls

The proposed Assay Sampling Rig IROFS"are as follows:.

Table 1, New IROFS for Assay Sampling Rig Accident IROFS ~' Safety Function Al!l!licabili!y Chemical I Affected Seguence Criticali!y Area

PT5-1" C21 Flow restriction to ensure in the event NewIROFS Chemical Process U of a postulated release worker Services ~ consequences, of inhalation of uranic Corridor' t:l-.

'material and HF are low. An orifice or pipe restriction on the suction side of the vacuum pump provides flow restriction consistent with the consequence analysis. "

Page 90f20

Enclosure 4 (Continued)NEF-09-000104-NRC

o

The'existing Assay Sampling Rig IROFS are as follows:

Table 2- Existins IROFS

The existing Safe-by-Design (SBD) Controls are:

Table 3. Existins SBD Control

New chemical analySes and supporting calculation"s were developed for the AssaySampling rig chemical"sequence and is located at Capenhurst in the UnitedKingdom (UK). Page markups from'the ISA Suinmary are attached (Ehclosure 3)and require inclusion of a new accident sequence PT5-1.

Section 5 below describes the Assay Sampling system and propoSed IROFS in '

greater detail than is typically included in the ISA Summary,

Page l0 of20

a ,,S

AccidentSequence

rRoFs €)l

sSafetv Function Che{nical /

QriticalitvAffected'Area

PT2-5 30a U Limit hydroiarbon oil (moderator mass) in 'enriched Uranium product by controlling thetype of oil used in process vacuum pumps

Criticality Assay.SamplingSystems"

PT2-5 30b c) Liinit hydrocarboh oil (moderator mass) inenriched Uranium product by verifyiirgthrough test pribr to addition of oil that

_

process vacuum pump oil is not hydrocarbonbil

Criticality Assay SainplingSystems

PT2.5 30c O Limit hydrocarbon oil (moderator mass) inenriched Uranium product by verifoing

' through test after oil addition and prior toplacing vacuum pumps in the processsystem, that process vacuum pump oil is nothydrocarbon oil

Criticality Assay SamplingSystems

g X n n s

AccidentSequence

IROFS

$Safetv Function Chemical /

CritiqalitvAffected Area

LOSS OFSAFE-BY-DESIGN

Safe-by-Design

oma

Passive, safe-by-design, attributes ofcomponents for the Assay Sampling pump andtrap set are identified in Tables 3.7-6 through3:7-21of the ISA Summary. The featufes dfthese components do not rely on humaninterface to perform the criticality safetyfunction.

Criticality Assay SamplingPump and Trap

Set SBDComponents

o

o

o

Accident Segu~nce

PT2-5

PT2-5

PT2-5

Accident Sequence

LOSS OF

Enclosure 4. (Continued) NEF-09-000104-NRC

The' existing Assay Sampling Rig IROFS are as follows:

T bl 2 E . . IROFS a e , xlstmg IROFS

-~ Safety Function Chemical! Affected, Area

Criticality

30a U Limit hydrocarbon oil (moderator mass) in e Criticality Assay Sampling < _ enriched Uranium product by controlling the " Systems'

type of oil ~sed in process vacuum puml:?s

30b u Limit hydrocarboh oil (moderator mass) in Criticality Assay Sat:npling < enriched Uranium product by verifying Systems

through test prior to addition of oil that process vacuum pump oil is not hydroca;bon 'oil

.-30c U Limit hydrocarbon oil (moderator mass) in Criticality Assay Sampling

< enriched Uranium product by verifying Systems ,through test after oil addition and prior to placing vacuum pumps in the process system, that process vacuum pump oil is not hydrocarbon oil

The existi~g Safe-by-Design (SBD) Controls are:

T bl 3 E . f a e , XIS lng SBD C t I on ro s .. ~

IROFS __ Safety Function Chemical! Affected Area

~- Criticality

Safe-by- 0 Passive, safe-by-design, attributes of Criticality Assay Sampling SAFE-BY- Design t!l components for the Assay Sampling pump and Pump and Trap tZl

DESIGN 0

trap set are identified in Tables 3.7-6 through Set SBD 3:7-21 ofthe ISA Summary. The features Of Components these components do not rely on human interface. to perform the criticality safety function. <

New chemical analyses and supporting calculations were developed for the Assay Sampling rig chemical.seguence and is located at Capenhurst in the United Kingdom (UK). Page markups from the ISA Suinmary are attached(Ehclosure 3) and require inclusion of a new accident sequence PTS-l.

Section S below describes the Assay Sampling system and proposed IROFS in greater detail than is typ~cal~y included in the ISA Summary.

Page 10 of20

Enclosure'4 (Continired)NEF-09-000104-NRCo

o

5.0 SYSTEM DESCRIPTION

During production it is necessary to know th" Ur*in- 235("tU)of the operational unit product or tails stream.

Page ll of20

5.0

o ""-

o

SYSTEM DESCRIPTION

During production it is necessary to know the Uranium-235 of the erational unit or tails stream.

Enclosure'4 (Continued) NEF -09-0001 04-NRC

Page 11 of20

5.1

Enclosure 4 (Continued)'NEF-09-000104-NRC

Process Hazards

The process hazards are UF6 releases to atmosphere and HF releases to'atmosphere.

Releases to atmosphere are minimizedby operating the entire pfocess'at belowirtmospheric pressure. Abnormal pressures are detected via pressure sensors andindicated by alarms. Appropriate actions"to stop UF6 flow, isolate process stepsor shut down systems happens audomatically.

Before any breaks in the procesS are carried out, the pipework is evacuated andnitrogen purge{. The pipework is all welded construction and process valves arebellows sealed: Before discharge, all gases are treated with activated'carbon andAlzO: to remove any residual traces of UFo lnd HF. The filtered gases are thendischarged into a GFVS for final filtration, chemical adsorption, and monitoringprior to release.

lroposed IROFS

IROFS3Oa, IROFS3bb, andIROFS30c are existing IROES applicable to theAssay Sampling pump and trap set and will continue to be IROFS applicable tothe Assay Samfling Rig. IROFS3Oa, IROFS30b, and IROFS30c administrativelylimit hydrocarbon oil as a moderator mass in enriched Uranium product to ensuremoderation control assumptions are maintained by cohtrolling the type of oilintroduced andused in process vacuum.pumps.

IROFSC2I is pr-oposed as a new IROFS providing flow restriction to ensure.inthe event of a postulated release worker consequences of Uranic material and HFare below regulatory threshold liinits identified in 10 CFR 70.61.

Defensq in Pgnth and Qther Safetv Features

IROFS as well as the following measures are used to reduce the likelihood ofoccurrence of an accident scenario.

Defense in depth features enable thd system, as a whole, to exhibit greatertolerance to failures ahd provide successive levels of protection such that safety isnot completely dependent upon any single element,of the design, construction,maintenance, or operations of the facility.

o Hydrocarbon lubricantS are not used. The product system pumps arelubricated with synthetic oil, Perfluorinated polyether (PFPE). (seeIROFS3Oa, IROFS3Ob, and IROFS30c)

5.2

5.3

Page 12 of20

o

o

5.1 Process Hazards

Enclosure 4 (Continued)' NEF -09-0001 04-NRC

The process hazards are UF 6 releases to atmosphere and HF releases to atmosphere.

Releases to atmosphere are minimized by operating the entire process·at belo~ atmospheric pressure. Abnormal pressure~ are· detected via pressure sensors and indicated by alarms. Appropriate actions to stop UF 6 flow, isolate process steps or shut down systems happens automatically.

Before any breaks in the process are carried out, the pipework is ,evacuated and nitrogen purgeq. The pipework is all' welded construction and process valves are bellows·sealed~ Before discharge, all gases are treated with activated'carbon ~nd Ah03 to remove any residual traces of UF 6 and HF. The filtered gases are then discharged into a GEVS for final filtration, chemical adsorption, and monitoring prior to release.

5.2 Proposed lROFS

IROFS30a, IROFS30b, and IROFS30c are existing IROES applicable to the Assay Sampling pump and trap set and will continue to be IROFS applicable to the Assay Sampling Rig. IROFS30a, IROFS30b, and IROFS30~ administratively limit hydrocarbon oil as a moderator mass in enriched Uranium product to ensure lJloderation control assumptions are maintained by controlling the type of oil introduced and used in process vacuum.,pumps.

I

IROFSC21 is proposed as 'a new IROFS providing flow restriction to ensure.in the event of a postulated release worker consequences ofUranic material and HF are below regulatory threshold limits identified in 10 CFR 70.61.

5.3 Defense in Depth and Other Safety Features

IROFS as well as the following measures are used to reduce the likelihood of occurrence of an (;lccidentscenario. .

Defense in depth features enable the' system, as a whole, to exhibit greater tolerance to failures and provide successive levels of protection such that safety is not completely dependent upon any single element of the design, construction, maintenance, or operations of the facility.

• Hydrocarbon lubricants are not used. The product system pumps are lubricated with synthetic oil, Perfluorinated polyether (PFPE). (see IROFS30a, IROFS30b, and IROFS30c)

Page 120[20

, I

I I

I

o'K$5;-iffiffi'.i$i2

.. All product take-off system components containing Ufo are safe fromcriticality by geometry. (SBD controls)

allow identification of deviations so protective actions can be taken, ifnecessary, before increased progression.)

o

5.4 Assav Sarhplirie

Stopping the pumps provides a defense-in-depth measure to the system (i.".,Without pumps running there is no forced flow:)

Page l3 of20

Enclosure 4 (Continued) NEF -09-000104-NRC

.' All product take-off system components containing ~F6 are safe from criticality by geometry. (SBD controls)

Stopping the pumps provides a defense-in'-depthmeasure to the system (i.e., without pumps running there is no forced flow;)

•

allow identification of deviations so protec:;tive actions can be taken, if .necessary, before increased progression.)

5.4 Assay Sampling

Page 13 of20

Eirclosure 4 (Continued)NEF-09-000104-NRC

o

o

Page 14 of20

o ""-

Enclosure 4 (Continued) NEF -09-0001 04-NRC

Page 14 of20

I

·1

6.0

Enclosure 4 (Contiffued)NEF-09-000104-NRC

PROPOSED CHANGES

Evaluation of a chemical sequence for the Assay Sampling Rig"or inclusion insimilar sequences w6s missed during the original license"application. Therefore, '

development of a new (PT5-1) sequence is required. The PT5-1 initial failureinitiatins event) is an. tor error that results in incorrect sarholin uence

This is an effor that shfuld be prevented by an interlock in the Process ControlSystem; however, tot prrrposes of this PT5-1 sequence, it is assumed the PCS andthis interlock also fail.

The quantities are insufficient^to affect the public beyond the site

With IROIISC 2l inplace, the workei consequences of inhalation of uranicmaterial or HF are.calculated as below 10 CFR 70.61thresholds in the,event of arelease. The"quantities are insufficient to affect the public. As a result ofIROFSC2I, the consequence analysis shows the consequences'have beenmitigated'to an acceptable level and the risk is acceptable.

Basis for Change

Page 15 of20

6.1

fence.

()

6.0

Enclosure 4 (Continued) NEF -09-0001'04-NRC

PROPOSED CHANGES

Evaluation of a chemical sequence for the Assay Sampling Rig. or inclusion in similar sequences was missed during theotiginallicense -application. Therefore,· development of a new (PT5-1) sequence is required. The PT5-1 initial failure !' • ! • e

.. This is an error that 'should be prevented by an interlock in the Process ControJ System; however, ~or purposes of this PT5-1 sequence, it is assumed the PCS and this interlock also fail.

The quantities are insufficiep.fto affect the public beyond the site fence.

With IRO FSC21 in place, the worker consequences ~f inhalation of uranic material or HF are'calculated as below 10 CFR 70.61 thresholds in the, event of a release. The -quantities are insufficient to affect the public. As a result of IROFSC21, the conseque~ce analysis shows the consequences "have been mitig~ted-to an acceptable level and the risk is accept,able.

6.1 Basis for Change

Page 15 0[20

Enclosuie 4 (Continued)NEF-09-000104-NRC

In the uncontrolled PT5-l accident it is assumed that thethe samolin

The ISA team reviewS considered a number of proposals for control of the AssaySampling System:- This included application of existing IROFS versusapplication of a"new IROFS. The existing IROFS fo1 similar sequences havebeen challenging to design where the IROFS would adequately perform itsintended function. Therefore. this was not chosen and a new IROFSC2Iwas selected.

Consequence"analysis has demonstrated with IROFSC2I inplace,

Therefore, the system, in its normaloperation will provide flow restriction and accident sequence PTs-l'results in theconsequences below l0 CFR 70.61 thresholds.

The acceptable risk associated with PT5-l is demonstrated inAccident Seauence and Risk Index (see Enclosure 3).

has been determined applicable to the Assato ensure liw Level I (OL-l) control of the restriction device.

demohstratedPT5- 1.

adequately controls the risk in

6.2 Safetv Sienificance"

The new PT5-lmembers ofthe.

s to workers andblic with IROFSC2I

IROFSC2I has been identified as a new

associated with accident seQuence PT5-l (see risk table, Enclosure 3). The Assay

Page l6 of20

accident sequence results in low

the consequences in PT5-l have been mitigated to acceptable levels.

ISA Table 3.7 -1,

o

0' ~ ....

In the uncontrolled PTS-l accident coarllna.",,,a

the C'gr1nnl'lnn

Enclosure 4 (Continued) NEF -09-0001 04-NRC

The ISA team reviews considered a number orpropos'als for control of the Assay Sampling System .... This included applicatioil of existing IROFS versus application of a·new IROFS. The existing IROFS f~r similar sequences have been challenging to design where the IROFS would adequately perform its intended function. this was not chosen and a new IROFSC21

Con~equence'analysis has demonstrated with. IROFSC21 in place, the consequences i.n,PTS-l have been mitigated to acceptable ievels.

Therefore, the system, in its normal operation will provide flow restriction and accident sequence PTS-r results in the consequences below 10 CFR 70.61 thresholds.

and in COInpJl1arlce demonstrated PTS-l.

6.2 Safety Significance'

~ T~e new PTS-l accident sequence results in low "ru",coarn .. :.n"

members of the lic with IROFSC21

.~ble to ISA accident sequence PTS-l. _ has been demonstrated sufficient to adequately control the risks associated with accident se'quence PTS-l (see risk table, Enclo~ure 3). The Assay

Page 16 of20

o

. Enclosure 4 (Continued)

NEF-09-000104-NRC

Sampling Rig procdss operations, as shown by consequence'analysis; complieswith l0 CFR 79.61performance criteria. *

The new PT5-1, Alsay Sampling Rig accident scenario complies with thecontrolled'risk index criteria consistent with NEF ISA metbodology and NUREG-1513 and complies with,NUREG-1520 accident sequence evaluation criteria.This approach, as discussed in the ISA Sumffidry, Section 3.1.1 ,ISA Methods,employb a semi-quarititative risk index method fof Categorizing accidentsequences in terms of their likelihood of occurrence and.their consequences ofconcern. The new passive engineered-control IROFSC2'l is a Quality Level-lcontrol with required Management Measures.

Page 17 of20

o

o

Enclosure 4 (Continued) NEF -09-000104-NRC

Sampling Rig process operations, as shown by consequence ;analysis:, complies with 10 CFR 70.61 performance criteria. h '

The new PT5-1, Assay Sampling Rig accident scenario ~omplies with the controlled "fisk index criteria consistent with NEF ISA metllodologyand NUREG-1513 and complies with,NUREG-1520 accident sequence evaluation criteria. This approach, as discussed in the ISA Summary, Section 3.1.1, ISA Methods, employs a semi-quantitative risk index method fof categorizing accident sequences in terms of their likelIhood of occurrence,and.their consequences· of concern. The new passive, engineered-control IROFSC2'1 is a Quality Level-l control with required Management Measures.

Page 17 of20

7.0

Enclosure 4 (Continued)NEF-09-000104-NRC

ENVIRONMENTAL C ONSIDBRATIONS

There are no new'or additional significant environmental impacts associated withthe process operations for the Assay Sampling Rig for the changes proposed inthis License Amendinent'Request. The proposed changes do not meet the criteriaspecified in l0 CFR 51.60(b)(2) since they do not involve a significant expansionof the site, a significarit change in the types of effluents, a significant increase inthe amounts of effluents, a significant increase in individual or cumulativeoccupational radiation exposure, or a significant increase jn the potential for orconsequences from radiological accidents. The'Assay Sampling Rig wasidentified in the original NEF license application and partially analyzed in theISA, however, some of the analyses were"incomplete. This was not:discovereduntil recently during a design review process for the Product System (see 2008- -1438-CR).

The proposed nQw IROFSC2I for the Assay Sampling Rig has been demonstratedas providing an adequate safety function for the postulated PT5-1 accidentsequence; and, therefore, the PT5-1 sequence remains at an acieptable risk levelwhen controlled by IROESC2l . Nb new Licensed materials,or materials thatcould affect Licensed materials have been inJroduced. As a reSult, there'is noincreased Eirvironmental impact and no additional environmental considerationsdifferent from the original ISA analyses'for similar vacuum pump and trap sets.The Environmentril. Report is not affected.

Page l8 cif 20

7.0

I.

o

ENVIRONMENTAL CONSIDERATIONS

Enclosure 4 (Continued) NEF-09-000104-NRC

There are no new'or additional significant environmental impacts associated with the process operations for the Assay Sampling Rig for the changes proposed in this License Amend~entcRequest. The proposed changes do not meet the criterla specified in 10 CFR 51.60(b )(2) since they do not involve a significant expansion of the site, a significant change in the types of effluents, a significan~ Increase in the amounts of effluents, a significant increase in individual or cumulative occupational radiation exposure, or a significant increase "in the potential for or consequences from radiological accidents. The 'Assay Sampling Rig was identified in the original NEF license application and partially analyzed in the ISA,however, some of the analyses werejncomplete. This was not:discovered until recently during a' design review process for the Product System (see 2008- -1438-CR).

The proposed new IRQFSC21 for the Assay Sampling Rig has been deinonstrated . as providing an adequate safety function for the postulated PT5-1 accident sequence; and, therefore, the PT5-1 sequence remains at an acc'eptable risk level when controlled by IROESC21. Nb new Licensed materials or materials that could affect Licensed materials have been introduced. As a result, there'is no increased Environmental impact and no, ~dditional environmental considerations different from the original ISA analyses' for similar vacuum pump and ,trap sets. The Environmental, Report is not affected. - -'

Page 18 df20

,

8.0

Enclosure 4 (Continued)NEF-09-000I04-NRC

SEISMIC CONSIDERATIONS

Cohsideration was giveri to the potential for adverse effects resulting from a

seismic event. The ISA meeting for pump and trap set's concluded that flow.-restriction (IROFSC2I), either inherent or added, would not be adversely affectedby a seismic event. Since in all cases the restriction is upstream of the vacuumpump, external leaks would result in low.consequences. No potential faults wereidentified.where the flow rate would increase as a result of the seismic event.

Seismic consideraJion for potential adversb effects resulting'from a seismic eventand results on the rig configuration or location-or effluents/safe-by-design gaseouseffluent ventilation system where the Assay Sampling rig exhausts Was notconsidered here. It is outside the scope of this license amendment.

Page l9 of20

o 8.0

()

SEISMIC CONSIDERATIONS

Enclosure 4 (Continued) NEF -09-0001 04-NRC

Consideration was given to the potential for adverse effe~t.s resulting from a seismic event. The ISA meeting for pump and trap set's concluded that flow­restriction (IROFSC21), either inherent or added, would not be adversely affected by a seismic event. Since in all cases the restriction is upstream of the vacuum pump, extemalleaks would result in low·cons~quence.s. No potential faults were identified-where the flow rate would increase as a result of the seismic event.

Seismic consider~tion for potential adverse effects resulting from a seislI}ic event and results on the rig config':lration or 10cation 'or effluents/safe-by-design gaseous effluent ventilation system where the Assay Sampling .r:ig exhausts was not considered here. It is outside the scope of this 'license amendment.

Page 19 of20

9

'Kf;:;;_i53ffi'_Ti?

CONCLUSION

A new IROFSC2I is proposed as a Class A sole IROFS passive engineeredcontrol for a new PT5-1 sequence for the Ass'ay Sampling-vacuum pump"andchemical trap set. An acceptable controlled risk has been shown for the set as

demonstrated by a Risk Index of (3) (see Enclosure 3) and inclusion ofIROFSC2I as a PEC flow restriction. Acceptable risk is'provided in the AssaySampling System. Implementation of a'new IROFSC21 ensures the new design issafe and complieswith 10 CFR 7,0.61 perforrparice criteria.

+

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CONCLUSION

Enclosure 4 (Continued) NEF -09-0001 04-NRC

A new IROFSC21 is proposed as a Class A sole IROFS passive engineered control for a new PT5-1 sequence for the Assay Sampling' vacuum pump-and chemical trap set. An acceptable controlled risk has been shown for the set as demonstrated by a Risk Index of (3) (see Enclosure 3) and inclusion of IROFSC21 as a PEC flow restriction. Acceptable risk is'provided in the Assay Sampling System. Implementation of a new IROF~C21 ensures the new desIgn is safe and complies-with 10 CFR 70.61 performance criteria.

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