ML20203H430
| ML20203H430 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 12/10/1997 |
| 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-97-0192, GDP-97-192, NUDOCS 9712180406 | |
| Download: ML20203H430 (10) | |
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V~USEC m A Gleal Enwgy Compas,y j
JAMES H. MILLER Dir: (301) $64 3309 VICE PRE &tDENT, PaoouctioN rex:( A1) 5 18279 December 10,1997 Dr. Carl J. Paperiello SERIAL: GDP 97-0192 Director, Office of Nucuar hinterial Safety and Safeguards Attention: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555 0001 Portsmouth Gaseous Diffusion Plant (PORTS)
Docket No. 70 7002 Certificate Amendment Request -Title of Shift Operations Manager
Dear Dr. Paperiello:
In accordance witi 10 CFR Part 76.45, the United States Enrichment Corporation (USEC or Corporation) hereby submits a request for amendmen..o the cenificate of compliance for the Pousmouth, Ohio Gaseous Diffusion Plant (GDP). This certificate amendment request revises the " Description of Noncompliance" in Complhmce Plan, Issue 21, to change the title of Plant Shift Superintendent hianager to Shift Operations hinnager.
Revision 4 of the Plan for Achieving Compliance with NRC Regulations at the Portsmouth Gascous Diffusion Plant (Compliance Plan), issued on April 15, 1997, revised the " Description of Noncampliance" for Issue 21, to change the title of Plant Shift Superintendent hianager to Shift Operations hianager. This Compliance Plan change was implemented in accordance with Reference 1, which documents that changes to the "Descr'ption of Noncompliance" section would no* require NRC appmval prior to implementation provided the change meets the criteria of 10 CFR 76.68 (a)(1), (2), (3),
(4), and (6) and does not result in a change to the Technical Safety Requirements. The change to Issue 21 was evaluated and detennined to satisfy the above criteria. As such, the change to issue 21 was approved and issued with Revision 4 of the Compliance Plan.
Reference 2, issued subsequent to issuance of Compliance Plan, Revision 4, established NRC's position on changes to the Compliance Plan. As stated in Reference 2, changes to the " Description of Noncompliance" section require NRC review and approval prior to implementation. Reference 2 also Z HE emTm eenv ill!.ll!lllll illl!Illlll 6903 Rockledge Diive, Bethesda, MD 20817181e Telephone 301-564 3200 l~as 301564 3201 hup://www.mec.com 97th1904069710IO-
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t Dr. Carl J. Paperie.Ilo December 10,1997 GDP 97-0192 Page 2 requirca that any changes that h'.ve tren made to the " Description of Noncompliance" section be submitted to the NRC for review and approval through an amendment to the Certificate of Compliance.
This Certificate Amendn:ent Request is provided in response to this reqmrement.
The Compliance Plan thange enclosed within this Certificate Amendment Request has been coordinated with the Departmee. of Energy (DOE) and found t.o be accephble. Documentation for DOE's acceptance is contained in Reference 3.
Enclosure I to this letter provides a detailed description and justification for the proposed change to Compliance Plan, Issue 21. Enclosure 2 includes the " Removal / Insertion Instructions" and a copy of the revised complianc: plan page. The compliance plan page is provided for your review and approval. contal is the basis for USEC's detennination that the proposed change associated with this Certificate Amendment Request is not significant.
Since this Certificate Amendment Request is not required to support continued plant operation, USEC requests NRC review and approval of this certificate ame idment request at your earliest convenience.
The amendment should become effective immediately upon issuance.
There are no new commitments contained in this submittal. If you have any questions regarding this matter, please contact hiark Smith at (301) 564 3244.
Sincerely, P
Cn [I J mes 11. hiiller Vice President., Production cc:
NRC Region 111 Ollice HRC Resident inspector - PORTS NRC Resident inspector - PGDP DOE Regulatory Oversight hianager
Enclosures:
As stated I
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i Dr. Carl J. Paperiello Deceml er 10,1997 GDP 97-0192 Page 3 lteferences
- 1. USl!C Letter, Mr. Itobert L. Woolley 'o Mr. Itobert C. Pierson, "10 CFit 76.68 Itequirements for Changes to the Compliance Plans", ODP 96-0200, dated December 11,1996.
- 2. NltC Letter, Mr. Itobert C. Pierson to Mr. Itobert 1. Woolley, "Itequirements for Changes to the Compliance Plans", dated July 15,1997.
- 3. dol! l.etter, Mr. Itandall M. DeVault to Mr. Steven A. Toelle, " Department oflinergy llevHv of Change to Compliance Phm Portsmouth issue 21; Your 1.etter: DOII97 0003" dated November 25, 1997.
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OATil AND AFFIRhiATION 1, James 11. hiiller, swear and affirm that I am Vice President, Production, of the United States Enrichment Corporation (USliC), that I am authorized by USlic to sign and file with the Nuclear Regulatory Commission this Certificate Amendment Request for the Portsmouth Gaseous Dif fusion Plant, that I am familiar with the enntents thereof, and that the statements made and matters set forth therein are true and correct to the best of my knowledge,information, and belief.
O E '?
James 11. hiiller On this loth day of December 1997, the ollicer signing above personally appeared befbre me, is known by me to be the person whose name is subscribed to within the instrument, and acknowled he executed the same for the purposes therein contained.
in witness hereofI hereunto set my hand and official seal,
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[ llaurie bl. Knisley, Notary Public d
State of hiaryland, hiontgomery County hiy commission expires hiarch 17,1998
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GDP 97 0192 Page1ofI onited States Enrichnient Corporation (USEC)
Proposed Certificate Amendment Request Title of Shift Operations Manager Detailed Description of Change Specific Compliance Plan Sections Affected This proposal provides a change to the " Description of Noncompliance" of Compliance Plan, Issue i
21.
in this section, under item 2, change the title of" Plant Shift Superintendent Manager" to " Shift Operat!ons Manager".
,lustification of the Change The change is made to reflect the cunrnt manager to whom the Plant Shift Superintendents (PSS) reports. The change simply reflects a revised management structure at PORTS wherein the PSS reports t
through the operations organization, via the Shift Operations Manager, rather than directly through the PSS Manager. No changes have been made in PSS responsibilities or duties. Therefore, the change provides a more direct link between the PSS and Plant Operations.
The change to the Compliance Plan presented in Enclosure 2, which was implemented in Revision 4 of the Compliance Plan, was evaluated and approved in hicordance with the understanding between USEC and NRC documented in USEC's letter from Mr. Robert I., Woolley to Mr. Robert C. Pierson, "10 CFR 76.68 Requirements for Changes to the Compliance Plans", GDP 96 0200, dated December 11, 1996. This USEC letter states that changes to the " Description of Noncompliance" section would not require NRC approval prior to implementation provided the changc meets the criteria of 10 CFR 76.68 (a)(1),(2),(3), (4), and (6) and does not result in a change to tL Technical Safety Requirements. The change to issue 21 was evaluated and determined to satisfy the above criteria. As such, the change to issue 21 was r.pproved and issued with Revision 4 of the Compilanc: Plan.
This change to the Compliance Plan is provided in response to the NRC's letter from Mr. Robert C.
Pierson to Mr. Robert I., Woolley, " Requirements for Changes to the Compliance Plan", dated July 15, 1997. This NRC letter requires that changes to the " Description of Noncompliance" section of the compliance Plan, not previously reviewed and approved by NRC, should be submitted for NRC approval through an amendment to the Certificate of Compliance.
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GDP 97 0192 3 Pages l
Proposed Certificate Amendment Request Portsmouth Gascons Diffusion Plant 1.etter GDP 97 0192 12emavnl/Interflan Innf rucilana Remove Page insert Page DOFJORO 2027, Plan for Achieving Compliance with NRC R gulations at the Portsmouth Gaseous Diffusion Plant Inue 21 issue 21 l
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Manager'nent Controls REQUIREMENTS 10 CFR 76,35(a)(3) and 0) "'ihe application for ar initial cenificate of compliance must include the information identified in this sectien. (a) A safety analysis report which must include the following information:... (3) The qualifications requirements, including training anal experience, of the Corporation's management organization and key individuals responsible for safety in accordance with the regulatiom in this chapter:.. (7) A description of the management controls,nd oversight program to ensure that activities directly relevant to nuclear safety and safeguards and security are conducted in an appropriately controlled manner that ensures protection of employee and public health and safety and protection of the national security interests."
- the Corporation shall establish, malatain, and execute a quahty assurance program satisfying each of the applicable requirements of ASME NQA t 1989, ' Quality Assurance Program Requirements for Nuclear Facilities,' or satisfying acceptable alternatives to the applicable requirements.
Th; Corporation shall execute the criteria in a graded approach to an extent that is commensurate with the importance to safety."
COMMITMENTS Source: Safety Analysis Report
- 6. Oiganization and Operating Programs 6.1 Organization and Responsibility [Rev. 3, 5/31/96]
l USEC conunits to conducting operations at PORTS in a manner that protects the health and safety of workers and the public, protects the environment, and provides for the common defense and security of the United States. USEC intends to achieve this commitment by establishing an organizational structure such that responsibility aivt authority for safe operations is clearly (lefined, and that critical safety, safeguards, security, and quality functions are established with a re,norting chain to a senior manager who is independent of the production function. Further, a series of ir.anagement controls and oversight have been established to ensure that activities directly relevant to nuclear safety and safeguards and security are conducted in a controlled manner that ensures the protection of employees and public health and safety and protection of national security interetts.
DESCRIPTION OF NONCOMPLIANCE USEC has not completed development and implementation of programmatic controls to ensure effective oversight and compliance with applicable NRC regulatory requirem:nts. Those management controls that require further developmen' and implementation include policies and directives, management systems, and administrative p4,vedores, which have been specifically described in Chapters 5.0 and 6.0 of the Safety Analysis Report (SAR), in the Technical Safety Requirements (TSR), and in several program plans and descriptions (notably, the Emergency Plan, Quality Assurance Program, Radioactive Waste Management Program, Fundamental Nuclear Material Control Plan, and Security Plans). Specific to Section 6.1 of the Application, USEC has identified that the integration of all health, I
PORTS Rev. 3,7/0'96
luue 21 Page 2 Atanagement contmis safety, and emironment and of all safeguards and security program elements can be fully evaluated, revised, and/or updated to ensure that compliance will exist upon NRC assuming regulatory oversight of the facility through the resolution of the following two compliance issues:
1.
QAP and Regulatory Requirements Flow Down-Not all applicable NRC approvet application t
conunitments that fulfill the 10 CFR 76 regulatory requirements have been " flowed-down" to policies and procedures that are approved and implemented at USEC headquarters and PORTS to ensure that full compliance with these documents has been achieved. Specific NRC requirements that have not been satisfied when USEC submitted its application to the NRC have been identified by the issues submitted in this DOE Compliance Plan document.
2.
Organizational Roles, Resp (msibilities, Relationships, and Authorities Flow Down-The reporting relationships, and the qualifications, functions, responsibilities, and authorities for the i
following positions defined in Safety Analysis Report Sections 6.1.1.1 through 6.1.1.25 and Figure 6.1 1 have not been " flowed-down" to position desca;ptions:
Executive Vice President, Operations Vice President, Production Nuclear Regulatory Assurance and Policy Manager Safety and llealth Assurance and Policy Manager Environmental Assurance and Policy hbnager Safety, Safeguards, and Quality Managu General Manager Enriclunent Plant Manager Operations Manager Maintenance Manager Production Support Manager Radiation Protection Manager Work Control Manager Shift Operations Manager l
Plant Shift Superintendent Environmental, Safety and I!ealth Manager Engineering Manager Nuclear Safety Manager Site and Facilities Support Manager Security Manager Fire Services Manager Training and Procedures Manager Nuclear Regulatory Affairs Manager Operations and Maintenance First-Line Managers Customer Service and Product Scheduling Manager i
e Emergency Management Manager Materials Management Manager Administrative Support Manager PORTS Rev. 4. 4/1$/97 m
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l GDP 97-0192 Page1of3 United States Enrichment Corporation (USEC)
Proposed Certificate Amendment Itequest Title of Shift Operations Manager Significance Determination Tlie United Siates Enrichment F arporation (USEC) has reviewed the proposed changes associated with ibis certificate amendment request and provides the following Significance Determination for consideration.
1, No Overall Declease in the I!!Tectiveness of the Plant's S.itfety. Safeguards. or Security Programs.
This Certificme Amendment Request reflects the current manager to whom the Plant Shill Superintendents (PSS) report. The reponing relationship of the PSS is described in the plant safety, safeguards and security programs. Ilowever, this change is an administative change which does not affect the duties or responsibilities of the PSS. Therefore, the proposed change does not represent an overall decrease in the effectiveness of the plant's safety, safeguards, or security programs, 2
No Significant Chance to Any Conditiens to the Certificate of Comnliance.
No aspect o. h ; Certificate of Compliance (COC) is afTected by these changes. Therefore, no significant change to any conditions to the COC will result, 3.
No Significant Change to Any Condition of the Annroved Co,npliance Plan.
The proposed change involves revision ofissue 21 of the Description of Noncompliarse section of the Compliance Plan to reflect the reporting relationship of the Plant Shift Superintendents. The proposed change has no impact on the Justification for Continued Operation in the Compliance Plan This change is an administrative change which does not afTect the duties or responsibilities of the PSS. Therefore, the proposed change does not represent a significant change to any condition of the approved Compliance Plan, 4,
No Significant increase in the Probability of Occurrence of Consequences of Prevituily Es alualedAccidents The proposed change is an administrative change to tellect the current reporting relationship ofib Phmt SNO Superintendents (PSSL The d1 ties and responsibilities of the PSS are not alTected. Therefore, the proposed changes do not represent any increase in the probability of occurrence of consequences o previously evaluated accidents.
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i GDP97-0192 Page 2 of 3 United States Enrichment Corporation (USEC) 1 Proposed Certificate Amendment Request Title of Shift Operations Manager Significance Determination S.
No New or Different Kind of Accident.
This change does not introduce any new or different equipment or processes, nor do they involve a modification to existing equipinent or operations. The change is an administrative c
change to reflect the reporting relationship of the Plant Shift Superintendents. Therefoie, this change will not result in the possibility of a new or different kind of accident.
l 6.
No Signincant Iteduction in Margins of Safety.
The proposed change is an administrative change to reficct the reporting relationship of the PSS. The duties and responsibilities of the PSS are not affected by this change. Therefore, the proposed change does not represent a reduction in any margin of safety.
7.
No Sienificant Decrease in the liffectiveness of Any Program or Plan Contained in the t
Cn11Hcation Anplication.
This Certificate Amendment itequest reflects the current manager to whom the Plant Shill Superintendents (PSS) report. The reporting relationship of the PSS is described in the programs and plans contained in the certification application, llowever, this change is an administrative change which does not affect the duties or responsibilities of the PSS.
Therefore, the proposed change does not represent a decrease in the effectiveness on any program or plan contained in the certification application.
8.
The Pronosed Changes do not Result in Undue Risk To 11 Public Ilealth and Safety. 2)
Common Defense and Security. and 31 the linvironment This change is an administrative change which does not alter the function or responsibilities required for plant operations. The proposed changes do not increase the consequence or probability of an accident and, therefore, do not present an undue risk to the public. The proposed changes do not afTect any common defense or security operations, therefore, no undue rist to common defense and security is presented. No undue risk to the environment is presented by the proposed changes because they do not alTect accident scenarios or operations that could alTect the environment. No additional environmental risk is presented because the changes have no impact on plant efiluents or postulated accidents which might atTeet the enstronmem. 'Iherefore, the proposed changes do not result in undue risk to the public health and safety, common defense and security, or the environment.
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GDP97-Ol92 Page 3 of 3 United States Enrichment Corporation (USEC)
Proposed Certifbeate Amendment Request Title of Shift Operations Manager Significance Determination 9.
No change in the Tynes or Significant increase in the Amounts of Any lifilucats That May 4
Ile Released Offsite.
The proposed change does not involve any process which would change or increase ellluents that may be released by the plant. Therefore, there is no change in the types or any increase in the amounts of any ellluents that may be released offsite.
10.
No Significant increase in Individual or Cumulative Oc.cunational Radiation IIxnosure.
The proposed change does not modify any process or equipment which would affect radiation exposure. Therefore, no increase in individual or cumulative occupational radiation exposure would occur.
I 1.
No Significant Construction Impact.
This change does not involve construction of any plant structure or system, nor will this i
change affect any planned or existing construction project. Therefore, there is no construction impact.
1..
No Significant increase in the Potential for. or Radiological or Chemical Conscauences from.
Presiottsiv Analyzed Accidents.
The proposed changes do not involve any new or modified operation which would increase the potential for an accident or any associated consequences. Therefore, these changes will-not increase the potential for, or radiological or chemical consequences from, previously analyzed accidents.
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