ML20151Y132
| ML20151Y132 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant, Paducah Gaseous Diffusion Plant |
| Issue date: | 09/15/1998 |
| From: | Toelle S 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-98-0192, GDP-98-192, TAC-L21175, NUDOCS 9809180118 | |
| Download: ML20151Y132 (9) | |
Text
..
(.
LSEC A Global Energy Company September 15,1998 GDP 98-0192 Dr. Carl J. Paperiello Director, Office of Nuclear Material Safety and Safeguards Attention: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 1
Paducah Gaseous Diffusion Plant (PGDP)
Portsmouth Gaseous Diffusion Plant (PORTS)
Docket Nos. 70-7001 and 70-7002 USEC Response to Request for Information for Annual Report to Congress on the Gaseous Diffusion Plants (TAC No. L21175)
Dear Dr. Paperiello:
In response to the Commission's letter dated July 10,1998, TAC No. L21175, requesting information on the status of health, safety, and environmental programs at the Paducah and Portsmouth Gaseous Diffusion Plants, I am pleased to submit the enclosed information.
The enclosed information is volunterily provided for your use in preparing the annual report to Congress on the GDPs. There are no new commitments contained in this correspondence.
I would be pleased to discuss these responses with you. Please contact me at (301) 564-3250 or Ms. Lisamarie Jarriel at (301) 564-3247.
Sincerely, n
s. A.
I C
Steven A.Toelle
,gg Nuclear Regulatory Assurance and Policy Manager whLh
Enclosure:
Information for NRC's Annual Report to Congress
- f., 4 g ptv I
oo m u:
cc: NRC Document Control Desk
]O<
NRC Region III Office NRC Resident Inspector, PGDP 5
NRC Resident Inspector, PORTS E
$a.u Mr. Randall M. DeVault, DOE
]'
6903 Rockledge Drive, Bethesda. MD 20817-1818 Telephone 301-564-3200 Fax 301-564-3201 http://www.usec.com O&es in Liverrnore, CA Paducah. KY Portsmouth. OH Washington. DC
Enclosure GDP 98-0192 Page 1 of 8 USEC Response to Request for Information for the NRC Annual Report to Congress on the GDPs Portsmouth, Ohio and Paducah, Kentucky NRC Request 1.
One section ofthe annual report will discuss the status ofhealth, safety, and environment. In this section, personnel dose and environmental radioactive releases will be discussed, including whether requirements governing these areas were met.
The most recent information on personnel exposures, direct off-site radiation levels including sky shine, public exposure, and radioactive efluents would be useful. It would also be usefid to obtain a discussion ofwhether dose limits specyled in Part 20 were metfor the period October 1,1997 through September 30,1998, whether there were any overexposures/ contamination incidents, and whether there were any planned special exposures.
USEC Response Both PORTS and PGDP monitor air and water releases and maintain a network of environmental thermoluminescent dosimeters (TLDs) to monitor ambient gamma radiation levels both on-site and off-site. Both direct offsite radiation and sky shine or scattered radiation are collectively measured using the TLDs. Typically, scattered radiation is minimal; less than one percent of direct radiation.
The most recent available data from the Environmental TLD networks is consistent with past experience. Ambient gamma exposure at the boundary of the PORTS and PGDP reservations is not statistically different than at monitoring locations remote from the facility (i.e., background locations).
Neither direct radiation from the plants nor from plant radioactive releases result in any detectable contribution to the total external gamma exposure as measured by TLDs at the boundary of the unrestricted areas.
Radioactive releases from PGDP have been within historical levels and PORTS releases have been noticeably lower than the historical average during this period. Based on measured and estimated releases, the maximum annual public radiation dose for all of calendar year 1998 is presently projected to be approximately 0.06 mrem / year at PORTS and less than 0.05 mrem / year at PGDP. Estimated doses at both GDPs are far below the applicable regulatory limits in 10 CFR 20, which limits the annual dose to any member of the public to 100 mrem / year (10 CFR 20.1301).
10 CFR 20 (Subpart C) specifies occupational doses be limited to 5000 mrem / year. USEC's Radiological Protection Program has established an Administrative Control Level (ACL) for occupational exposure at one-tenth of the Part 20 limit, or 500 mrem / year. Historically, both plants have been below the required monitoring limits in Part 20, and as a result the monitoring frequencies changed in January 1998. Personnel who have the potential to exceed the Administrative Control e
~
a.
Enclosure GDP 98-0192 Page 2 of 8 USEC Response to Request for Information for the NRC Annual Report to Congress on the GDPs Portsmouth, Ohio and Paducah, Kentucky J
Level of 500 mrem / year are on a quarterly monitoring frequency, as required by Part 20. All other monitored personnel are on an annual monitoring frequency.
Exposure data for the plants are provided below. The data reflects a minimum reportable dose of 10 mrern and only includes the first two calendar quarters of 1998. Dose is measured in mrem. Average Measurable Total Effective Dose Equivalent (TEDE) is the average dose for only those incidents that
' involved exposures greater than or equal to 10 mrem.
f(( hk f
k,h h
jf;ff (Ifs {h NUMBER NUMBER -
AVERAGE --
YEAR PERSONS MEASURABLE COLLECTIVE AVERAGE MEASURABLE MAXIMUM MONITORED EXPOSURES TEDE TEDE-TEDE' TEDE 1997 3433 222 13,264 4.0 60.0 292.0 1998*
729 132 2,700 3.7 20.5 75.0
- Includes all 1998 processed personnel TLDs and is for external exposure only as internal exposure data not available at time of report.
khlh&&k
- NUMBER.-
L NUMBER' AVERAGE YEAR' PERSONS ^
MEASURABLE COLLECTIVE AVERAGE
' MEASURABLE MAXIMUM MONITORED EXPOSURES -
TEDE:
,TEDE sTEDE TEDE 2837 379 16,719 l
l1997l 5.9 44.1 365.0 542 85 5,169 l
l1998*l 9.5 60.8 221.0
- Includes all 1998 processed personnel TLDs and is for external exposure only as internal exposure data not available at time of report.
As reflected in the above data, both GDPs continue to meet the requirements of 10 CFR 20 for occupational exposure.
a
~
e Enclosure GDP 98-0192 Page 3 of 8 USEC Response to Request for Information for the NRC Annual Report to Congress on the GDPs Portsmouth, Ohio and Paducah, Kentucky EORTS Dosimetry Summarv A review of 1997 dosimetry data indicates no personnel exceeded the 500 mrem TEDE Administrative Control Level (maximum recorded dose of 292 mrem). The 1998 data indicates no personnel are expected to exceed the ACL, This indicates monitoring is not required at PORTS under the conditions stated in 10 CFR 20.1502(a)(1).
A review of 1997 internal dosimetry data indicated exposure to soluble uranium resulted in intakes of less than 1 mg/ week (10% of the 10 CFR 20.1201(e) weekly limit). In 1997, the maximum recorded acute intake was 0.418 mg and the maximum internal dose was 28 mrem CEDE. Through August, the maximum acute intake of soluble uranium in 1998 was 0.445 mg.
There has been one personnel contamination event in 1998 (January through August). This compares to 13 events in Calendar year 1997. The resulting dose in each case was insignificant in terms of skin dose.
There have been no planned special exposures at PORTS during this period.
PGDP Dosimetry Summary A review of 1997 dosimetry data indicates no personnel exceeded the 500 mrem TEDE Administrative Control Level (maximum recorded dose of 365 mrem).1998 data indicates no personnel are expected to exceed the ACL. This indicates monitoring is not required at PGDP under conditions stated in 10 CFR 20.1502(a)(1).
A review of 1997 internal dosimetry data indicated exposure to soluble uranium resulted in average intakes ofless than 1 mg/ week which is 10% of the limit. The maximum recorded acute intake was 1.3 mg and the maximum internal dose was 3 mrem CEDE. For 1998 to date, the maximum intake was 0.922 mg and the maximum dose was 2 mrem.
There have been three personnel contamination events in 1998 (January - August). The resulting dose in each case was insignificant in terms of skin dose. This compares to only one event in 1997.
There have been no planned special exposures at PGDP during this period.
Enclosure GDP 98-0192 Page 4 of 8 USEC Response to Request for Information for the NRC Annual Report to Congress on the GDPs Portsmouth, Ohio and Paducah, Kentucky NRC Request i
2.
A description ofany improvement initiatives that you have started or are in progressfor the period October 1,1997 through September 30,1998 to improve environment, safety and health issues would be usefid. These could include safety and health improvements in arcas such as fire protection, nuclear safety (criticality, seismic upgrades, equipment upgrades, quality assurance, training, SAR reviews), packaging and transportation, emergencypreparedness, radiation protection, and worker safety.
USEC Response 1
PGDP Imnrovement Initiative Summarv There were numerous projects in FY 1997 to improve environmental, safety, and health for the public and employees at the Paducah Plant. Key actions were:
)
The SAR Upgrade was completed, after receipt from DO, and submitted as a Certificate Amendment Request for NRC review. The SAR Upgrade features an enhanced accident analysis described in the " Plan for Achieving Compliance with NRC Regulations at the Paducah Gaseous Diffusion Plant."
Extensive efforts to identify freon leaks and to repair those leaks identified were initiated.
Improvements were also made in the control and security of freon stored on the site.
A wide range ofimprovements were made related to industrial safety, such as covering exposed electrical contacts in the back ofinstrument panels, upgrading ladders, handrails, machine guarding, platform guarding, safer access to cranes, and improvernents in fire protection systems.
A major project for seismic upgrade to the C-331 and C-335 process buildings was initiated.
New steel is being installed in the buildings to decrease the potential for a release of UF6 in the l
event of a seismic occurrence.
l A combustible loading analysis was completed for Buildings C-333A, C-337A, and C-360; the l
analysis showed that combustible loadings are very low and are not a threat to uranium i
processes in these buildings.
8
Enclosure GDP 98-0192 Page 5 of 8 USEC Response to Request for Information for the NRC Annual Report to Congress on the GDPs Portsmouth, Ohio and Paducah, Kentucky Asbestos abatement in the C-600 steam plant is a significant improvement that was made to protect the workforce.
Improvements in corrosive gas leak detection and evacuation systems were made to provide increased safety for the workforce.
The preventive maintenance standards were upgraded for cranes and haulers that are used to handle UF. cylinders.
Improvements were made in the development and use of Training Development and Administrative Guides used to define qualifications for engineers, operators and maintenance personnel. The plant initiated an innovative Nuclear Criticality Safety error lab for detailed training for employees in handling fissile materials.
Many improvements were made to the Criticality Accident Alarm System (CAAS), including installation and expansion of systems in the plant laboratory, the maintenance shops, and for buildings that are located close to the process buildings.
Fire Services implemented, trained and certified Emergency Medical Technicians to use defibulators in the event of medical emergencies.
Radiation Protection Program upgrades included: HP Technician continuing training (completed first year); continued to train plant workers to allow self survey of tools and developed tool. control program; decontaminated the cell housings and condenser platforms to allow work with less personnel protective equipment; completed site characterization surveys and corresponding postings; and performed prospective evaluation for personnel monitoring program.
PORTS Improvement Initiative Summarv There were numerous projects and activities completed in FY-1997 to improve environmental, safety, and health for the public and employees at the Portsmouth Plant. Key actions were:
The SAR Upgrade was completed, after receipt from DOE, and submitted as a Certificate Amendment Request for NRC review. The SAR Upgrade features an enhanced accident analysis meeting the standards agreed to in the " Plan for Achieving Compliance with NRC Regulations at the Portsmouth Gaseous Diffusion Plant."
l
44 Enclosure GDP 98-0192 Page 6 of 8 USEC Response to Request for Information for the NRC Annual Report to Congress on the GDPs Portsmouth, Ohio and Paducah, Kentucky i
A number of commitments contained in the SARUP application submittal were completed that have enhanced the margin of safety, these include:
- Installation of additional remote feed isolation handswitches in the X-342A facility.
- Completion of physical modifications increasing the structural capacity of Building XT-847 to satisfy evaluation basis natural phenomena events.
- Completion of a combustible loading analysis for Buildings X-342A and X-344A; the analysis showed that combustible loadings are very low and are not a threat to uranium processes in these buildings. The buildings are protected with sprinkler systems.
- Completion of an hydraulic analysis of sprinkler system demand in the event of a fire in the process buildings; the analysis confirmed the adequacy of current and proposed TSRs.
- Walkdowns of the withdrawal stations were completed to determine whether seismic capacity deficiencies existed in piping that was not completely analyzed by the SARUP due to lack of accessibility. The walkdowns were completed and the systems have adequate seismic capacity to withstand the evaluation basis seismic event.
- An analysis of the railcars used for cooling cylinders for seismic performance during an evaluation basis seismic event was completed. The railcars, cylinder holders and reaction ofloaded cylinders was determined to withstand an evaluation basis seismic event without any loss of cylinder containment.
Improvements were made in the development and use of Training Development and Administrative Guides, used to define qualifications for engineers, operators and maintenance personnel. The plant initiated an innovative Nuclear Criticality Safety error lab for detailed training for employees in certain fissile material operations.
Many improvements were made to the Criticality Accident Alarm System (CAAS) particularly with respect to providing enhanced alarm coverage in buildings near fissile material operations.
A wide range ofimprovements related to industrial safety such as covering exposed electrical contacts, upgrading ladders and handrails, machine guarding, crane access and improvements to fire protection systems were completed.
Improved the control of HF exposure to personnel involved in cascade maintenance activities
)
utilizing engineered controls and formalizing purging to reduce HF concentrations into procedures.
i l
l i
i L.
.. g.
Enclosure GDP 98-0192 Page 7 of 8 USEC Response to Request for Information for the NRC Annual Report to Congress on the GDPs Portsmouth, Ohio and Paducah, Kentucky Completed efforts to eliminate the use of chlorine as a biocide in the recirculating water system pumphouses by replacement with a less hazardous biocide.
Extensive efforts to identify freon leaks using innovative technology (e.g., infrared monitoring) and to repair those leaks identified were initiated. Improvements were also made in the control and security of freon stored on the site.
Radiation Protection Program upgrades included: Implemented Dry-Ice (CO ) blasting i
2 decontamination of parts in process building; evaluated shielding for Technetium Traps; designed and constructed containment hood for cylinder disconnects; evaluated X-705 containment for dry buffing area; reached agreement with OCAW for union employees to begin surveying equipment out of contamination areas; evaluated and implemented reduced use of respiratory protection during entries to appropriately characterized cell housings; performed evaluation of uranium material handling work activities in an effort to reduce personnel doses; performed prospective evaluation for personnel monitoring requirements.
i h
Enclosure a
GDP 98-0192 Page 8 of 8 USEC Response to Request for Information for the NRC Annual Report to Congress on the GDPs Portsmouth, Ohio and Paducah, Kentucky NRC Request 3.
Please provide any additional information that you would suggest be included in the annual report that pertains to the status ofhealth, safety, and environmental conditions at the GDPs, or compliance with the standards established by the NRC.
i USEC Response i
' USEC has initiated the following programs and process tools to promote a dynamic safety culture at the plants:
Both plants continued to benchmark SALP 1 rated nuclear facilities and to bring back new ideas for improving nuclear safety. Resulting initiatives included the revision and improve of i
I the Assessment and Tracking and Problem Report systems at both GDPs, and the development of System Description Documents at PGDP to provide detailed descriptions of how process safety systems work, j
i The refeed of HEU material at PORTS was completed without any injury to personnel or impact to the public or the environment. This effort eliminated the presence of about 13,000 pounds of HEU as uranium hexafluoride from the site.
Approximately 26,500 OSHA nonconformances have been abated at both GDPs since July i
1993. Through FY 98, nearly $28M has been spent for the abatement of these nonconformances. An estimated $6M will be spent during the next two fiscal years to successfully abate OSHA nonconformances discovered during inspections, audits, and the assessment tracking report and problem report processes.
The Lost Workday Case (LWC) rate at the GDP complex averages 1.23 for the period in question. This is below the industry average LWC rate of 1.80. In addition, the Recordable injuries / Illnesses (RIIs) rates at the complex averages 2.91 for the period in question. This, too, is below the industry rate of 3.60.
Both PORTS and PGDP have a Pollution Prevention and Waste Minimization program that have been implemented since the creation of USEC. Initiatives in this area have focused on reducing the generation of mixed waste. As a result of these programs, the generation of mixed waste has been reduced by 15% in 1997 at PGDP and by 11% at PORTS.
O
_,