ML20149G906

Discusses Application of Facility Staffing Technical Safety Requirements to Site Security Force & Cautions to Be Careful in Future & Check Content of Correspondence Before Mailing to Assure That It Is Complete & Accurate

ML20149G906
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant, 07007001
Issue date:	07/18/1997
From:	Pierson R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Woolley R UNITED STATES ENRICHMENT CORP. (USEC)
References
NUDOCS 9707240121
Download: ML20149G906 (2)

Text

._ _ . _ . - . _ _ __ ._.

1 July 18* 1997 i Mr. Rob:rt L. Woollsy, Man ger A Nuclxr Rsgul: tory Assurcnca and Policy

.y*

U. S. Enrichment Corporation 2 Democracy Center j 6903 Rockledge Drive Bethesda, MD 20817

SUBJECT:

APPLICATION OF THE FACILITY STAFFING TECHNICAL' SAFETY d

REQUIREMENT TO THE SITE SECURITY FORCE

Dear Mr. Woolley:

Your June 26,1997, letter informed the NRC of USEC's understanding of the applicability of the facility staffing requirements dealing with overtime restrictions for the Site Security Force. In the letter you state that USEC has not applied the hours of work limitations in Technical Safety Requirement (TSR) 3.2.2.b to the security personnel. You further state that overtime limitations for security personnel are noted in site-specific procedures.

Our understanding of the TSRs differs from USEC's view. As written, the NRC would expect the hours of work limitation in TSR 3.2.2.b to apply to at least some of the security l force at each site. We note that TSR Table 3.2.2.1, Minimum Staffing Requirements, l includes Security Services. We consider, at a minimum, that all staff specifically mentioned in the minimum staffing table are covered by the hours of work TSR. In addition, any time a member of the security force is utilized to perform a safety related j function, the worker should be covered by TSR 3.2.2.b. Examples of such utilization  !

would be using security force members to conduct fire watches or limit access to a I building due to an inoperable criticality accident alarm system or to perform any other TSR related activity, i

During a conference call on July 2,1997, your staff informed us that the statement  ;

concerning site-specific procedures was in error. We caution USEC to be carefulin the )

future and check the content of correspondence before it is mailed to assure that it is complete and accurate in all respects.

1 '

. If you have any questions, please contact Ms. Merri Horn of my staff at (301) 415-8126.

Sincerely, Robert Pier on, Chief 4>

Special Projects Branch 9707240121 970718 Division of Fuel Cycle Safety j PDR ADOCK 07007001 and Safeguards, NMSS C PDR Docket No. 70-7001,70-7002 Certificate GDP-1, GDP 2

@y DISTRIBUTION:

Docket 70-7001, 70-7002 12.MC Filo Center : PUBLIC Region lli NMSS r/f FCSS r/f SP /f . K'OBrien, Rlli CCox, Rlli FCOB PHiland, Rill f (u' jDeers em a.,a_

OFC SPB- C SPB C SPB E SPB SPB o NAME 4MHorn:ij MYFaraz IDHoadley // tfn RPihen DATE 7/9/97 7/9/97 7/10/97 7 [N7 7/\ 7 C = COVER E = COVER & ENCLOSURE N = NO COPY GAUSECSSF.MLH OFFICIAL RECORD COPY C30016 RIlllE!RHp!IR

Mr. Rob::rt L. Woollsy, Man gtr

• [A U.

cirr Regulatory Assurance and Policy

. Enrichment Corporation l 2 De ocracy Center 6903- kledge Drive Be'thesda, D 20817

SUBJECT:

A' LICATION OF THE FACILITY STAFFING TECHNICAL SAFETY RE !REMENT TO THE SITE SECURITY FORCE i l

Dear Mr. Woolley:

Your June 26,1997, let informed the NRC of USEC's understanding of the applicability of the facility staffing requi ements dea!!ng witn overtime testrictions for the Site Security Force. In the letter you stateyat USEC has not applied the hours of work limitations in Technical Safety Requirement (TCR) 3.2.2.b to the security pegopnel. You further state that overtime limitations for secur personnel are noted in sitgcific procedures.

6 A

Our understanding of the TSRs diffegfr\m the USEC view. As written, the NRC would expect the hours of work limitation in TSP 3.2.2 b to apply to at least some of the security force at eacr. site because TSR Table 3.2. , Minimum Staffing Requirements includes the l Security Services. We expect, at a minimum, hat those specifically mentioned in the minimum staffing table would be covered by th hours of work TSR. In addition, any time a member of the security force is utilized to perfo a safety related function, the worker should be covered by TSR 3.2.2.b. Examples of su gutilization would be using security force members to cenduct fire watches or limit access $ o a building due to an inoperable criticality accident alarm system or to perform any other SR related activity.

During a conference call on July 2,1997, your staff informe .s that the statement concerning site specific procedures was in error. We caution EC to be carefulin the future and check the content of correspondence before it is mail o assure that it is complete and accurate in all respects.  ;

l If you have any questions, please contact Ms. Merri Horn of my staff at 01) 415-8126. l l

Sincerely, -

l l

Robert C. Pierson, Chief Special Projects Branch i Division of Fuel Cycle Safety l and Safeguards, NMSS l Docket No. 70-7001, 70-7002 l Certificate GDP-1, GDP-2 DISTRIBUTION:

Docket 70-7001, 70-7002 NRC File Center PUBLIC Region ill i NMSS r/f FCSS r/f SPB r/f K'OBrien, Rlli i CCox, Rlli FCOB PHiland, Rlli "J:ITJ OFC SPB ( SPB d. SPB h SPB SPB NAME MHorn:ij YFar z oadley DMartin RPierson DATE ') / 'J/97 7/4/97 'l /#/97 / /97 , / /97 l C = COVER E = COVER & ENCLOSURE N = NO COPY P:\USECSSF.MLH OFFICIAL RECORD COPY l