ML20141F580
| ML20141F580 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant, Paducah Gaseous Diffusion Plant |
| Issue date: | 06/26/1997 |
| From: | Woolley R UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Pierson R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| GDP-97-0109, GDP-97-109, NUDOCS 9707030079 | |
| Download: ML20141F580 (2) | |
Text
-
i United Stit:s
' ~,
Enrichtnint Corporation 2 Dernocracy Center 6903 Rockledge Drive Bethesda. MD 20817 Tel. (301) 564-3200 Fax:(301) 564-3201 Unitetl ates Enrichment Coqmration June 26,1997 Mr. Robert C. Pierson SERIAL: GDP 97-0109 Chief, Special Projects Branch Division of Fuel Cycle Safety and Safeguards, NMSS United States Nuclear Regulatory Commission Washington, D.C. 20555-0001 Paducah Gaseous Diffusion Plant (PGDP)
Portsmouth Gaseous Diffusion Plant (PORTS)
Docket No. 70-7001 and 70-7002 Application of the Facility Staffing Technical Safety Requirement to the Site Security Force The purpose of this letter is to provide USEC's understanding of the applicability of the Facility Staffing requirements dealing with overtime restrictions for the Site Security Force. The question of the applicability of the overtime restrictions contained in Technical Safety Requirement (TSR) 3.2.2.b to the Site Security Force has been raised at the Gaseous Diffusion Plants. This letter documents USEC's understanding of the applicability of TSR 3.2.2.b to these individuals. A response to this letter is requested if this understanding is inconsistent with NRC's understanding of this isme.
Technical Safety Requirement 3.2.2.b stipulates the requirements which " limit the working hours of facility stafT who perform safety functions (e.g. operators, health physics personnel, maintenance
{
personnel)". Security personnel perform a site protection function which is not directly related to i
ensuring safe operation of the facility as described in the Safety Analysis Report and the Technical Safety
{
Requirements. Therefore, security personnel at the GDPs have not been considered to perform " safety functions" and the requirements of the TSR 3.2.2.b have not been applied to security personnel at the l
GDPs.' However, the Security Services personnel are included in TSR Table 3.2.2.1, Minimum Staffmg i
Requirements, so that appropriate administrative controls are in place to ensure a minimum complement of security personnel are available onsite at all times to perform their physical protection function.
j In addition, USEC is unaware of the application of the limitation on working hours, similar to the j
requirements contained in TSR 3.2.2.b, to security personnel at nuclear power facilities. Based on a
{
limited survey ofoperating nuclear power facilities, the technical specification requirements on overtime j
at these facilities are not applied to security personnel. Overtime restrictions for security personnel at these nuclear power facilities are specified in plant procedures.
,**h
/d M g
9707030079 970626 PDR ADOCK 07007001 C
PDR Por+smouth. ohio washington. DC
l,.
b l
Mr. Robert C. Pierson l
June 26,1997 GDP 97-0109 Page 2 Therefore, USEC has not applied the hours of work limitations addressed in Technical Safety Requirement 3.2.2.b to GDP security personnel, which is, to the best of our knowledge, consistent with the treatment of security personnel at nuclear power facilities. However, USEC does recognize the importance oflimiting overtime for security personnel so that these personnel can adequately perform their site protection function. These overtime limitations for security personnel are noted in site specific procedures.
If you have any questions, please contact Mark Smith at (301) 564-3244. There are no new commitments contained in this submittal.
Sincerely, Y
J Robert L. Woolley Nuclear Regulatory Assurance and Policy Manager CC:
NRC Region III Office NRC Resident Inspector - PGDP NRC Resident Inspector - PORTS l
,