ML20137H647

Application for Amend to Coc for Paducah Gasous Diffusion Plant,Revising Technical Safety Requirement 3.2.2 b.2 Which Defines Guidelines for Use of Overtime at Plant

ML20137H647
Person / Time
Site:	Paducah Gaseous Diffusion Plant
Issue date:	03/31/1997
From:	John Miller UNITED STATES ENRICHMENT CORP. (USEC)
To:	Paperiello C NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
GDP-97-0042, GDP-97-42, NUDOCS 9704030008
Download: ML20137H647 (11)

Text

United Stites v

Enrichrntnt Corporation 2 Democracy Center Isk.

6903 Rockledge Drive Bethesda, MD 20817 Tel: (301)S64-3200 Fax- (301) 564-3201 Unitt1] States 15nrichtnent Corporation JAMES H. MILLER Dir; (301) 564-3309 VicE PRESIDENT, PRODUCTION Fax: (301) 571-8279 i

March 31,1997 l

Dr. Carl J. Paperiello SERIAL: GDP 97-0042 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-Change to Technical Safety Requirements for Administrative Controls on Overtime

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 Paducah Gaseous Diffusion Plant (PGDP). This certificate amendment request revises TSR 3.2.2 b.2 which defines the guidelines for the use of overtime at PGDP.

Issue 42 of the Plan for Achieving Compliance with NRC Regulations at the Paducah Gaseous DifTusion Plant, requires USEC to supplement current stafrmg allocations to meet proposed woA%g hour guidelines and to submit a revised TSR to add these guidelines to TSR 3.2.2 b.2. PGD' i ;

3 provided the resources and management controls necessary to comply with the proposed work.<. r guidelines. The revised TSR will implement the proposed requirements that an individual should not be permitted to work more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period and no more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7 day period exclusive of shift turnover time.

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{DR Offices in Paducah, Kentucky Portsmouth. Ohio Washington, DC

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-. Dr. Carl J. Paperiello -

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. March 31,1997 q

L GDP 97-0042 Page 2 -

I to this letter provides a detailed description an justification for the proposed change.

Enclosure:

2 contains a copy.of the revised TSR page and the associated SAR page revisions. The revised _SAR pages reflect revisions required as a result of this certificate amendment request and may; l not reflect other approved changes to these SAR pages. Enclosure 3 contains the basis for USEC's

,l determination that the proposed changes associated with this certificate amendment request are not

' significant.

Since this proposed certificate amendment request is not required to support continued operation, 5 USEC requests NRC review and approval at your earliest convenience. This amendment should t

become effective 30 days from issuance.

Any questions related to this subject should be directed to Mark Smith at (301) 564-3244.

I Sincerely,

- l a

J II. Miller

'l e President, Production

Enclosures:

As Stated l

cc:

NRC Region 111 Office NRC Resident inspector - PGDP NRC Resident Inspector - PORTS Mr. Randall M. DeVault (DOE) l i

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OATII AND AFFIRMATION I, James H. Miller, swear and affirm that I am Vice President, Production, of the United States Enrichment Corporation (USEC), that I am authorized by USEC to sign and file with the; l

Nuclear l Regulatory Commission this Certificate Amendment Request for the Paducah Gaseous i

DitTusion Plant, that I am familiar with the contents thereof, and that the statements made and matters -

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set forth therein are true and correct to the best of my knowledge, information, and belief..

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- es H. Miller i

Subscribed to before me on this 3/

day of 7//2td,1997.

b Wld Y,yk/lkfDU Notary Public BERNICE R. LAWSON I

NOTARY PUBUC STATE OF MAkYLAND Certificolo I::4d in Montgomery County Commission Expires August 1,1997 i

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GDP97-0042 Page1 of1 United States Enrichment Corporation (USEC)

Proposed Certificate Amendment Request Paducah Gaseous Diffusion Plant Administrative Controls on Overtime Detailed Description of Change The Plan for' Achieving Compliance with NRC Regulations at the Paducah Gaseous Diffusion Plant (Compliance Plan), Issue 42, requires USEC to supplement current staffing allocations to meet proposed working hour guidelines and to submit a revised TSR to add these guidelines to TSR 3.2.2 b.2.

In accordance with this Compliance Plan Issue, the Paducah Gaseous Diffusion Plant has provided the resources and management controls necessary to comply with the proposed work hour guidelines.

Existing TSR 3.2.2 b.2 reads as follows:

An individual should not be pennitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, nor 1

more tha 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> in any 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period, nor more than 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> in any 7 day period, all excluding shift turnover time; The proposed revision to TSR 3.2.2 b.2 reads as follows:

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An individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period, nor more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7 day period, all excluding shift turnover time The revised TSR 3.2.2 b.2 implements the proposed requirements that an individual should not be permitted to work more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period and no more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7 day perioci exclusive of shift tumover time as committed to in the Action Plan for Compliance Plan Issue 42. Revised TSR 3.2.2 b.2 is included in Enclosure 2. In addition, SAR Section 6.5.9.3 has been revised to reflect this change to the working hour guidelines and is also included in Enclosure I

2. The implementation of these overtime controls satisfies the Compliance Plan commitment and will enhance safe facility operation by minimizing any adverse effects of excessive work hours.

GDP97-00042 4 Pages Proposed Certificate Amendment Request Paducah Gaseous Diffusion Plant Letter GDP97-0042 Removal / Insertion Instructions Remove Pages Insert Pages VOLUME 2 Section 6.5 Section 6.5 Page 6.5-9 Through 6.5-12 Page 6.5-9/6.5-10 VOLUME 4 Section 3.0 Section 3.0 Page 3.0-3 Page 3.0-3 9

i TSR-PGDP PROPOSED

' March 31,1997 i

RAC 97C031 (RO) j SECTION 3.0 ADMINISTRATIVE CONTROLS

b. Individuals who perform training, health physics, quality assurance, nuclear criticality safety, and/or other safety functions shall have sufficient organizational freedom to ensure their independence from operating pressures.

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3.2.2 FACILITY STAFF

a. Minimum staffing requirements for each facility are shown in Table 3.2.2-1. These i

staffing levels do not apply under conditions requiring facility evacuation.

b. Administrative procedures shall be developed, implemented, and maintained to limit i

the working hours of facility staff who perform safety functions (e.g., operators, i

health physics personnel, maintenance personnel), in accordance with the following i

guidelines.

Adequate shift coverage shall be maintained without routine heavy use of overtime.

The objective shall be to have personnel work an 8-hour or 12-hour workday [i.e.,

a nominal 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> (can be as much as 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />) work week]. In the event that overtime must be used on a temporary basis, the following guidelines shall be used:

1. An individual should not be permitted to work more than 16 straight hours, j

excluding shift turnover;

2. An individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period, nor more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in l

any 7 day period, all excluding shift turnover time;

3. A break of at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> should be allowed between work periods; the 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> may include shift turnover;

4. Except during outage periods, the use of overtime should be considered on an individual basis and not for the entire staff on a shift.

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Any deviation from the above guidelines shall be authorized in advance by the General l

Manager or his designee, in accordance with approved administrative procedures and with documentation of the basis for granting the deviation. Routine deviation from the above guidelines is not authorized.

Management will assess on a monthly basis the application of overtime for facility staff who perform safety functions to ensure consistency with the overtime guidelines stated above.

3.0-3

SAR-PGDP May 31,1996 Rev. 3 Major equipment and piping systems are labeled. These labels aid personnel in identifying specific equipment and systems in the field. In the large cascade buildings, the grouping of equipment into units and cells is clearly marked so that the possibility for operator error is minimized. In addition, equipment location can be identified by a column grid system (alpha-numeric) which can be used to direct operators or emergency responders to the proper location.

6.5.6 Permits and Tagging A lockout /tagout pennit system is in place which provides controls for ensuring safe isolation of systems for maintenance or testing. For maintenance activities, the tagout request is initiated by maintenance personnel. Operations personnel write and approve the tagout, isolate (lock / tag) the system, perform concurrent verification with independent verification being performed by the service organization. A " Caution Tagging" system has been implemented as a warning to operators to stop and seek assurance of proper action before proceeding.

6.5.7 Management Monitoring of Operations A management assessment program is used by management to provide oversight of plant operations.

The program includes managers at all levels and is described in procedures. The results of the program are disseminated to appropriate management for evaluation.

6.5.8 Control of Equipment The Cascade Coordinator provides overall coordination of operational activities including

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removing / returning of cascade equipment to service, increasing / decreasing power levels, radiological i

protection, maintenance, and instrumentation to accomplish the operating objectives for the shift and to maintain safe and efficient operations. Communications between the coordinator and the first-line managers who authorize the removal and return of equipment and systems from service for maintenance, testing, or operational activities is conducted using the communications methods described above.

Qualified operators are capable of diagnosing facility and equipment conditions and are authorized to perform tasks during nomial, off-normal, and emergency conditions which may include the shutdown of equipment. Restan of equipment from routine shutdowns is authorized by the first-line manager. The PSS is authorized to stop operations when system operability or the overall safety of operations is in question. The PSS is also authorized to initiate restart after shutdown for non-routine reasons. For j

shutdowns that are directed by the Executive Vice President, Operations; Vice President, Production; Safety, Safeguards and Quality Manager, the General Manager or the Enrichment Plant Manager; the PSS may authorize restart only after obtaining the approval of the Enrichment Plant Manager and the General Manager (who will in turn obtain the concurrence of the Executive Vice President, Operations, or the Vice President, Production, as described in Section 6.1.1.8).

For the purposes of ensuring the ongoing operability of TSR-required equipment, Operations utilizes procedural requirements which include the following activities:

Day-to-day operation of the facility Plant walkdowns or tours 6.5-9

SAR-PODP PROPOSED March 31,1997 i

RAC 97C031 (RO)

Operator observations Inspections, assessments, and audits Engineering evaluations and design reviews TSR-required surveillance tests l

The above activities combine to provide continuing assurance that TSR-required equipment will perform f

as required, when needed.

To regain operability of equipment which has failed, been taken out of service, or had maintenance performed on it, each of the following elements must be satisfied:

Applicable surveillance test (s) must be successfully performed Any involved technical support organizations, such as engineering or criticality safety.

must approve restart or return to service PSS gives authorization j

When all of the above elements have been satisfied, the first-line manager can return the equipment to service.

i 6.5.9 Items Addressed by Compliance Plan This section is' implemented as described with exception (s) as listed below. The listing of the exception (s) also contains a brief description of what is currently in place at the plant. The Compliance Plan pmvides a description of the exceptions (noncompliance), a justification for continued operation, a description of the actions to be taken to achieve compliance and the schedule for completion of those actions.

6.5.9.1 Procedure Upgrades An upgrade of operations procedures is part of the nuclear safety upgrade program.

6.5.9.2 Training Program Upgrades Training will be required on upgraded procedures. In addition, training and qualification for some of the positions noted in this section are included in the nuclear safety upgrades for systems approach to 4

training. Plant Shift Superintendent qualification training needs to be accomplished according to Section r

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6.6.16.

6.5.9.3 Overtime Section Deleted l

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6.5-10 i

GDP97-0042 Page1of3 United States Enrichment Corporation (USEC)

Proposed Certificate Amendment Request Paducah Gaseous Diffusion Plant Administrative Control on Overtime Significance Determination The United States Enrichment Corporation (USEC) has reviewed the proposed changes associated with this certiGcate amendment request and provides the following Significance Determination for consideration.

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No Overall Decrease in the Effectiveness of the Plant's Safety. Safeauards. or Security Procrams The specific Administrative Controls Technical Safety Requirement (TSR) regarding overtime limitations are not addressed in 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. Therefore, the effectiveness of these programs is unaffected by these changes.

2.

No Sienincant Chance to Any Conditions to the Certincate of Comoliance None of the Conditions to the CertiGcate of Compliance for operation of the Paducah Gaseous Diffusion Plant address Administrative TSRs regarding overtime limitations. Thus, the proposed changes have no impact on any of the Conditions to the Certincate of Compliance.

3.

No Sieni0 cant Chance to Any Condition of the Annroved Compliance Plan The Plan of Action and Schedule for Issue 42 of the Compliance Plan, requires USEC to

. supplement current staf0ng allocations to meet working hour guidelines and to submit a revised TSR to add these guidelines. The proposed TSR change is submitted to satisfy a Compliance Plan conunitment and creates no significant change to the Compliance Plan nor to any conditions of the Compliance Plan. The SAR section has also been revised accordingly to reflect the completion of the Compliance Plan action.

4.

No Sienificant increase in the Probability of Occurrence or Conseauences of Previousiv Evaluated Accidents There is no accident scenario of concern for hours of work limitations. The proposed revision establishes more restrictive controls on overtime use by plant staff than the curreret

GDP97-0042 Page 2 of 3 United States Enrichment Corporation (USEC)

Proposed Certificate Amendment Request Paducah Gaseous Diffusion Plant Administrative Control on Overtime Significance Determination TSR.

Therefore, this change would not increase the probability of occurrence or consequence of an accident previously evaluated.

5.

No New or Different Tyne of Accident Changing the TSR requirements for hours of work limitations does not have the potential of creating a new type of accident. The proposed revision establishes more restrictive controls on overtime use by plant staff than the current TSR. Therefore, no new or different type of accident could result from this change.

6.

No Sienificant Reduction in Marcins of Safety The implementation of more restrictive work hour controls as identified in Compliance Plan issue 42 will not reduce the margin of safety as defined in the Technical Safety Requirements. This change is intended to minimize the potential for adverse effects which may be associated with excessive work hours.

7.

No SieniUcant Decrease in the Effectiveness of any Procram or Plans Contained in the Certificate Annlication The implementation of more restrictive work hour controls as identified in Issue 42 will not significantly decrease the effectiveness of any program or plan contained in the Application

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for United States Nuclear Regulatory Commission Certification for the Paducah Gaseous Diffusion Plant. Work hour guidelines are not specifically addressed in any of the Programs or Plans contained within the Certification Application. The change to the work hour guidelines contained with TSR 3.2.2.b.2 is intended to restrict overtime expended so as to minimize adverse affects of excessive overtime. Therefore, this change does not decrease the effectiveness of any programs or plans contained in the Certificate Application.

8.

The Pronosed Chances Do Not Result in Undue Risk to 1) Public Health and Safety. 2) l Common Defense and Security. and 3) the Environment The proposed change involves revision of the. hours of work TSR to establish more j

restrictive limitations than the current TSR. As such, this change does not represent an undue risk to public health and safety. In addition, these revisions have no impact on plant effluents or on the programs and plans in place to implement physical security.

GDP97-0042 Page 3 of 3 United States Enrichment Corporation (USEC)

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Proposed Certificate Amendment Request Paducah Gaseous Diffusion Plant Administrative Control on Overtime Significance Determination Consequently, these proposed changes only enhance safety and pose no undue risk to the environment or the common defense and security.

9.

No Chance in the Types or Sienificant Increase in the Amounts of Any Effluents that May be Released Offsite The proposed change involves revision of the hours of work TSR to establish more restrictive limitations than the current TSR. There are no effluent releases associated with this change.

10. No Sienificant increase in Individual or Cumulative Occupational Radiation Exposure The proposed change involves revision of the hours of work TSR to establish more restrictive limitations than the current TSR. As such, these changes do not represent an increase in individual or cumulative occupational radiation exposure.

I1. No Siunificant Construction impact This TSR change does not involve a plant modification. Therefore, there is no significant construction impact.

12. No Sienificant increase in the Potential for. or Radiolonical or Chemical Conscauences from. Previously Analyzed Accidents The proposed change involves revision of the hours of work TSR to establish more restrictive limitations than the current TSR. As such, these changes do not represent an increase in the potential for, or radiological or chemical consequences from, previously analyzed accidents.

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