ML20204C745
| ML20204C745 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 03/16/1999 |
| 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-99-0029, GDP-99-29, NUDOCS 9903230258 | |
| Download: ML20204C745 (11) | |
Text
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, A Globb r.nngy Company March 16,1999 GDP 99-0029 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 Paducah Gaseous Diffusion Plant (PGDP)
Docket No. 70-7001 Certificate Amendment Request - Executive Vice President Title Change
Dear Dr. Paperiello:
In accordance with 10 CFR Part 76.45, the United States Enrichment Corporation (USEC) hereby submits a request for amendment to the Certificate of Compliance for the Paducah, Kentucky, Gaseous Diffusion Plant (PGDP). This Certificate Amendment Request (CAR) proposes to revise Technical Safety Requirements (TSRs) Sections 3.1.1 and 3.10.4.d to reflect a change in the title of the Executive Vice President, Operations. It is proposed that the title be changed to Executive Vice President. to this letter provides a detailed description and justification for the proposed changes. is a copy of the revised TSRs which are provided for your review and approval. contains the basis fbr USEC's determination that the proposed changes associated with this Certificate Amendment Request are not significant.
Similar 6hanges to reflect this title change are necessary to the Safety Analysis Report (SAR), and the Programs, Plans and other documents contained in Application Volume 3. Enclosure 5 provides a list of the affected SAR and Program and Plan pages associated with this CAR. Due to the simplicity and the magnitude of changed pages, the associated SAR and Program and Plan changes have not been provided as an enclosure to this CAR. These SAR and Program and Plan changes have been evaluated in accordance with 10 CFR 76. With the exception of the Radioactive Material
{l Packaging and Transportation Quality Assurance Program (PTQAP), the changes to the SAR and
- Program and Plan pages noted in Enclosure 5 have been determined not to require prior NRC review and approval. The PTQAP changes were submitted by USEC letter GDP 99-0033 dated March 11, 1999.
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yo The amendment should become effective no later than 30 days from issuance. Because there is no immediate plant operational impact requiring prompt review of this certificate amendment request, USEC reauests NRC review as soon as oractical.
9903230258 990316 PDR ADOCK 07007001
- u,u., mmup unve, Bethesda, MD 20817-1818 Telephone 301-564-3200 Fax 301-564-3201 http://www.usec.com Offices in Livermore, CA Paducah, KY Portsmouth, OH Washington, DC E...<
- Dr. Carl J. Paperiello
- March 16,1999 GDP 99-0029, Page 2 4
- There are no new commitments contained within this submittal. Any questions related to this subject should be directed to Mark Smith at (301) 564-3244.
Sincerely,-
A
- s. R.
i Steven A. Toelle Nuclear Regulatory Assurance and Policy Manager
Enclosures:
- 1. Oath and Affirmation
- 2. United States Enrichment Corporation (USEC), Certificate Amendment Request, Executive Vice President Title Change - Detailed Description of Change i
- 3. Certificate Amendment Request, Paducah Gaseous Diffusion Plant, Letter GDP 99-0029, Removal / Insertion Instructions
- 4. United States Enrichment Corporation (USEC), Certificate Amendment Request, Executive Vice President Title Change - Significance Determination
- 5. Certificate Amendment Request, Paducah Gaseous Diffusion Plant, Letter GDP 99-0029, List of Associated SAR and Program and Plan Changes cc: Mr. Robert C. Pierson (NRC)
NRC Region III Office 4
NRC Resident Inspector - PGDP NRC Resident Inspector-PORTS Mr. Randall M. DeVault (DOE) 2 -
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l OATH AND AFFIRMATION I, Steven A. Toelle, swear and affirm that I am the Nuclear Regulatory Assurance and Policy Manager, of the United States Enrichment Corporation (USEC), that I am authorized by USEC to sign and file with the Nuclear Regulatory Commission this Certificate Amendment Request i
for the Paducah Gaseous Diffusion Plant addressing revision to the Technical Safety Requirements, l
as described in GDP 99-0029, that I am familiar with the contents thereof, and that the statements
-l made and matters set forth therein are true and correct to the best of my knowledge, information, and i
belief.
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Steven A. Toelle
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On this 16th day of March,1999, the individual signing above personally appeared before me, is known by me to be the person.whose name is subscribed to within the instrument, and acknowledged that he executed the same for the purposes therein contained.
In witness hereofI hereunto set my hand and officia' seal.
f M'X/
WWY Rollin D. Johnson,81ontgomery County -
Ndtary Public State of Maryland My commission expires June 1,2002.
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g GDP 99-0029 Page1of1 United States Enrichment Corporation (USEC)
Certificate Amendment Request Executive Vice President Title Change Detailed Description of Change Description of Change This certificate amendment request revises Section 3.1.1 and 3.10.4.d of the Technical Safety Requirements (TSRs) to reflect a change in the title of the Executive Vice President, Operations.
Currently, TSR Section 3.1.1 reads: "The Executive Vice President, Operations shall have corporate responsibility for..."
It is proposed that this section be revised to read: "The Executive Vice President shall have corporate responsibility for..." In addition, TSR Section 3.10.4.d currently reads: " Notify the Executive Vice President, Operations of any safety significant..." It is proposed that this section be revised to read" " Notify the Executive Vice President of any safety significant..."
Justification for the Chance l
This change in the title of the Executive Vice President, Operations to Executive Vice President is solely an administrative change to reflect a restructuring of USEC, Inc., intended to streamline operations. The functional responsibilities, reporting relationships and qualifications currently described in the Application are not affected by this proposed change.
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GDP 99-0029 4
3 Pages Total Certificate Amendment Request Paducah Gaseous Diffusion Plant Letter GDP 99-0029 Removal /Insertinn Instructions Remove Page Insert Page Volume 4 TSR Section 3 TSR Section 3 3.0-2, 3.0-9 3.0-2, 3.0-9 i
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TSR-PGDP PROPOSED March 16,1999 RAC 98C144 (RO)
SECTION 3.0 ADMINISTRATIVE CONTROLS 3.1 RESPONSIBILITY 3.1.1 The Executive Vice President shall have corpmate responsibility for overall gaseous l
diffusion plant safety and shall have authority to take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety.
3.1.2 The General Manager shall be responsible for the overall safe operations of the plant and shall take any measures required to ensure the plant remains in a safe condition. The General Manager or his/her designee shall approve, prior to implementation, each proposed test, experiment, or modification to systems or equipment that affect nuclear safety.
The General Manager shall delegate in writing the succession to this responsibility during his/her absence from plant site.
3.1.3 The Plant Shift Superintendent (PSS) shall be responsible for the operational aspects of the plant, and for the central control room command function. During any absence from the central control room while the plant is operational, an authorized designee shall be named and be present in the central control room. The term designee means a person who has been trained to execute plant emergency procedures. The designee shall have the capability to be in contact with the PSS using the plant communication systems when the PSS is absent from the central control facility.
3.1.4 The Organization Manager shall be responsible for the operations conducted within the facilities affected by this TSR for which he/she is responsile, and shall delegate in writing the succession of responsibility during absence from plant site.
3.2 ONSITE AND OFFSITE ORGANIZATION 3.2.1 Onsite and Offsite Onsite and offsite organizations shall be established for facility operation and corporate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting the nuclear safety of the gaseous diffusion plant and are described in Section 6.1 of the SAR.
- a. Lines of authority, responsibility, and communications shall be established and
' defined for the highest management levels through intermediate levels to include operating organization positions. These relationships shall be documented and updated, as appropriate, in the form of organizational charts, functional descriptions of organization responsibilities and relationships, and job descriptions fcr positions
~ down to and including first-line managers.
3.0-2
o TSR-PGDP PROPOSED March 16,1999 RAC 98C144 (RO)
SECTION 3.0 ADMINISTRATIVE CONTROLS 3.10.4 -FUNCTIONS 1
The PORC shall, as a minimum, incorporate functions that:
- a. Advise the General Manager on matters related to nuclear safety;
- b. Recommend to the General Manager approval or disapproval of items considered underTSR 3.10.5 prior to their implementation except as provided in TSR 1.6.4.1 l
and TSR 3.9.3;
- c. Determine whether each item considered under TSR 3.10.5 requires prior NRC approval before implementation per 10 CFR 76.68 and 76.45.
- d. Notify the Executive Vice President of any safety significant disagreement between l
the PORC and the General Manager within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. However, the General Manager shall have responsibility for resolution of such disagreements pursuant to TSR 3.1.2.
3.10.5 RESPONSIBILITIES The PORC shall be used to conduct, as a minimum, reviews of the following:
- a. All proposed procedures and procedure changes as required by TSR 3.9.2;
- b.~
All proposed changes to the Safety Analysis Report; c.~ All proposed changes to the Emergency Plan, Quality Assurance Program Description, Physical Security Plan for the Protection of Special Nuclear Material of Low Strategic Significance, Security Plan for the Transportation of Special Nuclear Material of Low Strategic Significance, Security Plan for the Protection of Classified Matter, ' Fundamental Nuclear - Materials Control Plan, Radioactive Waste Management Program, Depleted Uranium Management Plan, Decommissioning Funding Program Description, Environmental Compliance Status Report, and Supplemental Environmental Information Related to Compliance Plan that are
- included in the certification application.
- d. All proposed changes to the TSRs, the TSR basis statements, the Certificate cf Compliance, or the Compliance Plan;
- e. All proposed changes to the plant or the plant's operations, including tests and experiments, that require a written safety analysis in accordance with 10 CFR 76.68.
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GDP 99-0029 Page1of3
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' United States Enrichment Corporation (USEC)
Certificate Amendment Request Executive Vice President Title Change Significance Determination The United States Enrichment Corporation (USEC) has reviewed the proposed changes associated with this certificate amendment request and provides the following Significance Determination for consideration.
1.
No Significant Decrease in the Effectiveness of the Plant's Safety. Safeguards or Security Programs The Executive Vice President, Operatio ts, function is not changed in plant safety, safeguards or security programs contained in Volume 3 of the Application for United States Nuclear Regulatory Commission Certification for the Paducah Gaseous Diffusion Plant (PGDP).
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Therefore, the effectiveness of these programs is unaffected by this change.
2.
Najignificant Change to Any Conditions to the Certificate gf Comnliance None of the Conditions to the Certificate of Compliance for operation of the Paducah Gascous Diffusion Plant specifically address the corporate position of Executive Vice President, j
Operations. Thus, the proposed changes have no impact on any Condition to the Certificate i
ofCompliance.
3.
No Significant Change to Any Condition of the Annroved Compliance Plan None of the conditions of the approv.:d Compliance plan involve the corporate position of Executive Vice President, Operations. Therefore, no change to any condition of the approved Cornpliance Plan is involved.
4.
No Significant Increase in the Probability of Occurrence or Conseauences of Previqusly Evaluated Accidents The change in title for the Executive Vice President, Operations, will not increase the probability or consequences of an accident. The functional responsibilities, reportin, relat onships and qualifications are not affected by this proposed change.
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GDP 99-0029 Page 2 of 3 i
United States Enrichment Corporation (USEC)
Certificate Amendment Request Executive Vice President Title Change Significance Determination 5.
No New or Different Type of Accident The change in title for the Executive Vice President, Operations, will not increase de probability of an accident of any kind. The functional responsibilities, reporting relationships and qualifications are not affected by this proposed change.
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No Sienificant Reduction in Marcins of Safets There is not a Safety Limit or a margin of safety defined in the TSRs or supporting basis documents associated with organizational titles. The change in title for the Executive Vice President, Operations, will not cause a reduction in any margin of safety.
7.'
No Significant Decrease in the Effectiveness of any Program or Plan Contained in the Certificate Apnlication The Executive Vice President, Operations, function is not changed in plant safety, safeguards or security programs contained in Volume 3 of the Application for United States Nuclear Regulatory Commission Certification for the Paducah Gaseous Diffusion Plant (PGDP).
Therefore, the effectiveness of these programs is unaffected by this change.
8.
The Proposed Charps do not Result in Undue Risk to 1) Public Health and Safety. 2)
Common Defense and Security. and 3) the Environment.
The change in title for the Executive Vice President, Operations, will not restiit in undue risk to public health and safety, common defense and security, or the environment. The functional responsibilities, reporting relationships and qualifications are not affected by this proposed change.
9.
No Change in the Tvoes or Significant Increase in the Amounts of Anv Effluerts that May be Released Offsite This change has no affect on the generation or disposition of effluents. Therefore, this change does not change the type or amounts of effluents that may be released offsite.
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e s GDP 99-0029 Page 3 of 3 United States Enrichment Corporation (USEC)
Certificate Amendment Request l
i Executive Vice President Title Change Significance Determination
- 10. No Significant Increase in Individual or Cumulative Occupational Radiation Exnosur:
The proposed TSR change does not change or increase maintenance, testing, or operational requirements for the plant. This change does not relate to controls used to minimize j
occupational radiation exposures. Therefore, there is no significant increase in individual or cumulative occupational radiation exposure.
- 11. No Significant Construction Imnact The change in title for the Executive Vice President, Operations, is an administrative change which does not invo'.
- nificant construction impact.
- 12. No Significant Irierease in the Potential for. or Radiological or Chemical Consequences from.
heviousiv Analyzed Accidents The change in title for the Executive Vice President will not result in a significant increase in the potential for radiological or chemical consequences from previously evaluated accidents.
No responsibilities or qualifications are affected by this proposed change.
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GDP 99-0029 Page1of1 Proposed Certificate Amendment Request Paducah Gaseous Diffusion Plant j
Letter GDP 99-0029 List of Associated SAR and Program and Plan Channes Volume 1 Introduction Introduction 3/4 3/4 Volume 2 Section 5.3 Section 5.3 5.3-1/5.32 5.3-1/5.3-2 Section 6.1 Section 6.1 6.1 - 1/6.1 -2, 6.1 -3/6.1 -4, 6.1 -5/6.1 -6, 6.1 - 1/6.1 -2, 6.1 -3/6.1 -4, 6.1 -5/6.1 -6, 6.1-7/6.1-8, 6.1-11/6.1-12,6.1-l7/6.1-l8 6.1-7/6.1-8,6.1-11/6.1-12,6.1-l7/6.1-l8 Section 6.5 Section 6.5
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6.5-9/6.5-10 6.5-9/6.5-10 Section 6.8 Section 6.8 6.8-1/6.8-2 6.8-1/6.8-2 Volume 3 Quality Assurance Program Quality Assurance Program
.5/6 5/6 Emergency Plan Emergency Plan 4-1/4-2 4-1/4-2
' FNMCP FNMCP 2-1/2-2,2-11/2-12 2-1/2-2,2-11/2-12