ML20151L482
| ML20151L482 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant, Paducah Gaseous Diffusion Plant |
| Issue date: | 07/31/1997 |
| From: | Toelle S UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Pierson R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| GDP-97-0127, GDP-97-127, NUDOCS 9708070014 | |
| Download: ML20151L482 (4) | |
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United St't;s Enrichment Corporation
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2 Democracy C:nt:r 6903 Rockledge Drive Bethesda. MD 20817 Tel. (301) 564-3200 Fax: (301) 564-3201 July 31,1997 Mr. Robert C. Pierson SERIAL: GDP 97-0127 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 Facility Stafrmg Technical Safety Requirements to the Site Security Force
Dear Mr. Pierson:
Reference 1 provided NRC's position regarding the application of the TSR hours of work limitations to site security personnel. In this reference, it is stated that the NRC would expect the hours of work limitations in TSR 3.2.2.b to apply to at least some of the security forces at each site. The purpose of this letter is to provide USEC's response to Reference 1 as well as USEC's intended actions to address the application of TSR hours of work limitations to security personnel at the Portsmouth and Paducah Gaseous Diffusion plants.
Reference 2 provided USEC's understanding of the application of the TSR hours of work limitations to security personnel. As stated in Reference 2, it was USEC's understanding that those limitations did not apply to site security perscnnel. Since March 3,1997, USEC has been opet ating on the basis that the limitations were not a requirement for security personnel. USEC believes this action is consistent with the action plan established to implement the Plan of Action and Schedule for the Compliance Plan Issues on Administrative Controls on Overtime. It also appears to be consistent with the NRC's requirement for similar overtime controls in reactor licensee technical specifications, as reflected in Generic Letter 82-12 (June 15,1982) and Generic Letter 83-14 (March 7,1933). Nevertheless, USEC intends to move forward l
to meet NRC expectations with regard to the application of the TSR hours of work limitations to site security personnel.
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PDR ADOCK 07007001 C
PDR Offices in Livermore Cahfornia Paducah, Kentucky Portsmouth, Ohio Washington, DC I
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Mr. Robert C. Pierson I
July 31,1997 i
GDP 97-0127 Page 2 '
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1 To meet NRC expectations at PORTS, USEC is realigning thejob duties and responsibilities among i
existing personnel assigned to DOE and USEC activities to ensure that those security personnel assigned
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to perfonn USEC activities remain within the TSR hours of work limitations. At PGDP,' existing security L
. staffing levels do not permit the flexiHT.ty to realign job duties and responsibilities to achieve the ovenime l
limits at this time. USEC is currently investigating the options available to allow PGDP to meet the NRC's i
expectations. Until such time as these options are evaluated, USEC intends to apply, to the extent possible, the TSR hours of work limitations at PGDP. However, to apply those limitations to security personnel at PGDP, deviations from the requirements of the TSR hours of work limitations are required.
L These deviations are being authorized by the General Manager, or his designee, in accordance with the requirements of TSR 3.2.2.b. USEC will identify and evaluate the available options by August 7,1997, to allow PGDP to fully meet NRC expectations and apply the TSR hours of work limitations to security personnel, without relying on deviations to the TSR hour ofwork limitations.
l To obtain final closure of this issue, USEC believes that a change to Compliance Plan Issue 42, Administrative Controls on Overtime, is necessary to specifically identify the necessary actions and associated completion dates required to fully meet NRC expectations at PGDP. Once the options l
described above are evaluated and an appropriate course of action is identified, USEC will submit a Certificate Amendment Request (CAR) to NRC to revise the Compliance Plan, Issue 42.' USEC anticipates submittal of this CAR by August 21,1997J Until such time as final closure is achieved through j
i successful completion of the actions to be noted in the Certificate Amendment Request, USEC requests
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that enforcement action not be taken on this issue.
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Should you have any questions related to this subject, please contact me at (301) 564-3413 or Mark Smith at (301) 564-3244. Commitments contained within this letter are noted in Enclosure 1.
Sincerely,
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- 5. B. L Steven A. Toelle Nuclear Regulatory Assurance and Policy Manager l
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NRC Region III Office NRC Resident Inspector-PGDP l
NRC Resident Inspector-PORTS j
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Mr. Robert C. Pierson July 31,1997 GDP 97-0127 Page 3
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References
- 1. NRC letter, Roben C. Pierson to Robert L. Woolley, " Application of the Facility Staffing Technical i
Safety Requirement to the Site Security Force," dated July 18,1997.
- 2. USEC letter GDP 97-0109, Robert L. Woolley to Robert C. Pierson, " Application of the Facility Stafling Technical Safety Requirements to the Site Security Force," date June 26,1997.
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i GDP 97-0127 l
Page1 of1 l
List of Commitments i
- 1. USEC willidentify and evaluate the available options. by August 7,1997, to allow PGDP to fully meet NRC expectations and apply the TSR hours ofwork limitations to security personnel, without relying l
on deviations to the TSR hour of work limitations.
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- 2. Once the options to allow PGDP to fully meet NRC expectations and apply the TSR hours of work l
limitations to security personnel are evaluated and an appropriate course of action is identified, USEC i
will submit a Certificate Amendment Request (CAR) to NRC to revise the Compliance Plan, Issue 42.
l USEC anticipates submittal of this CAR by August 21,1997.
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