ML20211N185

Revised Sar,Comprised of Rev 32 to Application for NRC Certification,Portsmouth GDP

ML20211N185
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant
Issue date:	08/04/1999
From:	UNITED STATES ENRICHMENT CORP. (USEC)
To:
Shared Package
ML20211N178	List: ML20211N172 ML20211N185 ML20211N192
References
NUDOCS 9909100090
Download: ML20211N185 (59)

Text

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APPLICATION FOi! UNITED STATES NUCLEAR REGULATORY COMidSSION CERTIFICATION PORTSMOUTII GASEOUS DIFFUSION PLAhT USEC-02 REMOVE / INSERT INSTRUCTU;NS REVISION 32 Remove Insert VOLUME 1 LOEP i/ii LOEP ilil LOEP xi/xii LOEP xl/xii LOEP xxiii to xxviil LOEP xxiil to xxviii SAR Introduction Pages 3/4 Pages 3/4 i

Section 2.1 Pages 2.1-11/2.1-12 Pages 2.1-11/2.1-12 Section 3,3 Pages 3.3-91/3.3-92 3.3-91/3.3-92 Section 3.4 1

Pages 3.4-67/3.4-68 Pages 3.4-67/3.4-68 Pages 3.4-77 to 3.4-78a Pages 3.4-77 to 3.4-78a l

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9909100090 990004 PDR ADOCK 07007002 PDR C

APPLICATION FOR UNITED STATES l

NUCLEAR REGULATORY COhfMISSION CERTIFICATION i

PORTSMOUTH GASEOUS DIFFUSION PLANT USEC-02 1

REMOVE / INSERT INSTRUCTIONS l

REVISION 32 l

l VOLUME 2 i

Section 5.1 l

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Pages 5.121/5.1-22 Pages 5.1-21/5.1-22 Pages 5.1-25/5.1-26 Pages 5.125/5.1-26 l

l Pages 5.1-43/5.1-44 Pages 5.1-43/5.1-44 Pages 5.1-47/5.1-48 Pages 5.1-47/5.1-48 Pages 5.1-59/5.1-60 Pages 5.1-59/5.1-60 Section 5.3 Pages 5.3-1/5.3-2 Pages 5.3-1/5.3-2 Section 6.1 Pages 6.1-1 to 6.1-10 Pages 6.1-1 to 6.1-10 l

Pages 6.1-15/# l-16 Pages 6.1-15/6.1-16 Section 6.5 Pages 6.5-11/6.5-12 6.5-11/6.5-12 Section 6.8 Pages 6.8-1/6.8-2 Pages 6.8-1/6.8-2 O

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l APPLICATION FOR UNITED STATES NUCLEAR REGULATORY COMMISSION CERTIFICATION PORTSMOUTII GASEOUS DIFFUSION PLANT USEC-02 l

REMOVE / INSERT INSTRUCTIONS 1

REVISION 32 VOLUME 3 Quality Assurance Plan LOEP I/ii LOEP llli Pages 5/6 Pages 5/6 Emergency Plan Section 4 LOEP I/ii LOEP I/ii Pages 4-1/4-2 Pages 4-1/4-2 Fundamental Nuclear Materials Control Plan Section 2 LOEP I/ii LOEP illi Pages 21/2-2 Pages 2-1/2-2 Pages 2-7/2-8 Pages 2-7/2-8 Section 9 Pages 9-3 to 9-6 Pages 9-3 to 9-6 Pages 9-11/9-12 Pages 9-11/9-12 Transportation Security Plan LOEP1 LOEP1 Page 14 Page 14 Page 33 Page 33 0

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O SAR-PORTS June 30,1999

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Rev.32 Princinni OfHegn Mr. William H. Timbers President and Chief Executive Officer Mr. James H. Miller Executive Vice President Mr. James N. Adkins, Jr.

l Vice President - Production 1

I Format and Content of the USEC Certification Application The Application contains a Safety Analysis Report (SAR), Technical Safety Requirements (TSRs),

and programs, plans and other documents as described above. In accordance with 10 CFR 76.35(b), the Application also includes a plan prepared and approved by DOE for achieving compliance with respect to any areas of nonnunplinnm with the NRC's regulations identified by USEC as of the date of this Application. The Compliance Plan provides an expanded description of the O

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SAR-PORTS April 15,1998 Rev.19 1

areas of noncompliance, a justification for continued operation, a description of the plan of action to achieve compliance, and the schedule for completion of those actions, as applicable.

The Application is written in the present tense. The physical description of installed structures, l systems and components (SSCs) in the Application is current as of June 1,1995, except as described in Section j

3.8, " Items Addressed by Compliance Plan." The programs, plans, procedures and other aspects of the facility's operations other than the SSCs are described as they will be when all Compliance Plan items are j

completed. Each section of the Application contains a subsection entitled " Items Addressed by Compliance Plan". This subsection describes those aspects of the program, plan or section topic that are not in full compliance with the Application. This subsection also contains a brief description of what is currently in place. Any section which does not have any related Compliance Plan states "None identified."

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5.3 RADIATION PROTECTION As a condition of certification,10 CFR 76.60(d) requires that USEC " comply with the applicable

- provisions of 10 CFR Part 20, " Standards For Protection Against Radiation" not later than the date of the Directors decision on the initial application and/or as specified in an approved plan for achieving compliance.

This section describes USEC's Radiation Protection (RP) Program for keeping occupational radiation exposures and radioactive contamination as low as is reasonably achievable.

5.3.1 Radiation Protection Program 5.3.1.1 ALARA Policy In accordance with 10 CFR 20.1101, USEC has established an RP program designed to protect personnel entenng the USEC-leased spaces from unnecessary exposure to ionizing radiation and radioactive materials.

Management has adopted the following principles:

1.

Personnel radiation exposures and the release of radioactive effluents shall be maintained in accordance with the As Low As Reasonably Achievable (ALARA) principle.

2.

No individual shall receive a radiation dose in excess of any regulatory limit.

Responsibility for establishing and ensuring adherence to this policy rests with the USEC Executive Vice President.' ne General Manager has the overall responsibility and authority for the ALARA program l at PORTS. De PORTS Radiation Protection Manager is responsible for implementing the ALARA policy.

5.3.1.2 ALARA Conimittee The ALARA Committee (a subcommittee of the PORC) functions to: 1) communicate management's commitment to the ALARA Program; 2) monitor the implementation of the ALARA Program and serve as advisor to plant management for maintaining occupational dose and environmental dose in accordance with ALARA principles; and 3) review, for the purpose of occupational dose and environmental dose reduction, proposed designs, practices, selected suggestions, and selected project schedules.

. Memharshin and Structure he membership, and any change to the membership, is designated by the PORC chair and provides a M-@r= of members who have the necessary qualifications, competence, and experience to perform the responsibilities of the subcommittee. ney also represent various functional disciplines of the plant. He ALARA Committee chair reports to and is appointed by the PORC Chair (see Section 6.2 for PORC). He

- Radiation Protection Manager currently serves as the chair, and the Production Support Manager currently serves as the vice-chair. Current membership of the ALARA Committee includes representatives from:

Radiation Protection -

s 5.3-1

SAR-PORTS May 31,1996 Rev.3 Environmental, Safety and Health Cascade Operatio.r Chemical Operations

=

Feed and Transfer Operations Production Support Maintenance Nuclear Regulatory Affairs Training and Procedures Engineering Site and Facilities Support United Plant Guard Workers of America (UPGWA) Bargaining Unit Representative Oil, Chemical, Atomic Workers (OCAW) Bargaining Unit Representative Committee members may delegate alternates to attend meetings in their place but may not delegate an l alternate to vote in their absence.

Quorum A quorum consists of the chair or vice-chair and five (5) members.

Authorities

. The committee authority is limited to reviews and recommendations only. The committee has no approval, stop, or start work authorities. The ALARA Committee may also establish other temporary l subcommittees or assign individuals to undertake special studies or conduct reviews that will be documented and presented to the ALARA Committee with any recommendations.

Meeting Freauency The committee meets at least semiannually and as directed by the chair.

l Resnonsibilities I

ne ALARA Committee chair ensures that the functions of the committee as designated in its procedure and tasks assigned by the PORC chair are properly executed. Minutes are provided to the PORC, and special reports are made upon request of the PORC chair, or when the ALARA Committee chair believes issues require the attention of the PORC.

He ALARA Committee reviews matters that have or may have a significant impact on occupational dose and environmental dose. Rese include but are not limited to: 1) completed tasks which exceed 1 man-rem collective dose; 2) proposed design changes with a projected occupational dose impact of 1 man-rem or greater per year or a projected implementation dose of I man-rem or greater; 3) annual evaluations of the ALARA Program implementation, which assess its effectiveness and ensure that it reflects current industry philosophies and practices; 4) radiation exposure and airborne activity trends and resulting impacts on ALARA Program goals; and 5) revisions to the ALARA Procedures.

5.3-2

n-SAR-PORTS July 28,1998 Rev.22

6. ORGANIZATION AND OPERATING PROGRAMS 6.1 ORGANIZATION AND RESPONSIBILITY l-l Under the Energy Policy Act of 1992, the Nuclear Regulatory Commission (NRC) was required to establish a certification process to ensure that USEC complies with the standards established by NRC for the l

GDPs under 10 CFR Part 76. The Energy Policy Act provides that the requirement for a certificate of l

compliance shall be in lieu of any requirement for a license for the GDPs and that USEC shall apply for a certificate of cou,pliance. 'Ihe Act also requires that USEC and any contractor operating the GDPs for USEC provide the NRC with ready access to the facilities, personnel, and information that the NRC considers necessary to carry out its responsibilities for certification.

i USEC is committed to conducting operations 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. In order to meet

(

these commitments, as well as others required for operation of the uranium enrichment enterprise, USEC has l

issued an operations policy manual which contains statements of policy and procedures to guide the day-to-day l business and provide direction to USEC employees. The USEC policy with respect to nuclear safety, safeguards and security states in part:

i r

I i

USEC is ultimately responsible for, and is committed to, safe operation, maintenance, modification, i

l design, fabrication, and testmg of the Portsmouth Gaseous Diffusion Plant...and the Paducah Gaseous l

Diffusion Plant...and is committed to conducting operations in a manner that protects the health and safety of workers and the public, protects the environment and provides for the common defense and j

l l

security...USEC has provided the management structure to ensure that the safety / safeguards policy is effectively implemented.

1 The line organization is responsible for the safe operadon of the GDP. Programs and staff

' organizations are established for safety, safeguards, and quality (SS& Q) and environmental and health (E&H) l_

areas and are provided with sufficient resources to support the line organization in safe operation of the GDP.

USEC and its operating contractor, Lockheed Martin Utility Services, Inc. (LMUS), have established l management systems with associated policies, administrative procedures, and management controls to ensure:

- the GDP equipment, facilities and procedures; the staff (including training and qualifications), and the E&H and SS&Q programs provide for the protection of the health and safety of workers and the public, protection of the environment, and for the common defense and security. Management controls have been established to maintain.the safety / safeguards basis of the GDP as described in this application. E&H and SS&Q organizations have been established with a reportmg chain, independent from the line organizations, to a senior manager l

O l

6.1 -1 l

i

SAR-PORTS June 30,1999 Rev.32 (Executive Vice President, for Corporate Headquarters and General Manager for plant organizations).

l

'Ihe integration of the plant operations and the various E&H and SS&Q programs and requirements is currently accomplished through a variety of management practices. Where frequencies are identified below, they represent current normal business practice but can be adjusted by the manager responsible for the meeting.

Executive Vice President, daily officers meeting.

Executive Vice President, weekly staff meetings.

Vice President, Production, phone call with General Managers to discuss the overall status of the plants, problem and event reports, the daily production report, future plans, and other pertinent subjects.

General Manager meets weekly with Enrichment Plant Manager and Organization Managers to discuss issues and policy implementation Monthly review of plant performance indicators.

The Plant review and approva! systems [particularly the function of the Plant Operations Review Committee (PORC)] for procedures, training, modifications / changes to the physical plant and/or plant pmgrams as described in this application, provide for the integration of the various SS&Q and E&H requirements and controls.

Plant work perrnit systems provide the integration in the field of various health, safety, and environmental program requirements and hazard evaluations.

Figure 6.1-1 shows the USEC organization for operation of the GDPs. Managerial positions that have responsibilities important to safety and safeguards are described in this chapter; other managerial positions are described in those prtions of the application where applicable, particularly in the Quality Assurance Program Description, Radioactive Waste Management Program Description, Emergency Plan, Fundamental Nuclear Material Control Plan, Security Plan for the Transportation of Special Nuclear Material of Low Strategic Significance, and the Security Plan for Classified Matter (Commitment Management, Administrative Support, Customer Service and Product Scheduling, and Emergency Management are not described in this chapter).

" Organization Managers" report to either the Enrichment Plant Manager or General Manager; " Group Managers" report to Organization Managers; and "Section Managers" report to Group Managers.

Section 6.1.1 describes the organizational commitments, relationships, responsibilities and authorities for the overall management system to assure the protection of the health and safety of the workers and the public, protection of the environment, and provide for the common defense. This section includes the qualifications, functions, responsibilities, and authorities of the positions in the organization assigned functions related to SS&Q and E&H.

Section 6.1.2 describes the management controls for maintaining the E&H and SS&Q programs and the administrative systems to control relationships and interfaces between programs.

O 6.1-2

m

- SAR-PORTS June 30,1999 Rev.32 6.1.1 Organizational Commitments, Relationships, Responsibilities, and Authorities USEC is committed to the safe operation of the GDP and has provided the management structure to ensure that the safety / safeguards policy is effectively implemented. He Corporation and Plant management systems provide for line responsibility for safe operations with sufficient staff support to develop, communicate, and provide edmical programs for various E&H and SS&Q areas. h organization of various support staff are provided in the description of the E&H and SS&Q areas.

USEC pmvides diidm and managenent of GDP operations from the President and Chief Executive Officer (CEO) through the Executive Vice President, the Vice President, Production, and the General l Managers. Additionally, policy and program direction of E&H programs is provided through the Safety and Health Assurance and Policy Manager, and the Environmental Assurance and Policy Manager for their respective areas. These managers are independent'from day-to< lay production, plant operating cost, and pWiaa hiiv %;ici,tions. Also, the Safety, Safeguards and Quality Manager (located onsite) who reports to the Executive Vice President, provides USEC oversight and assurance that corporate policies and l procedures are being followed in operation of the plant.

The General Manager directs and oversees site activities to ensure safe, reliable, and efficient operations. De Enrichment Plant Manager reports to the General Manager and directs and coordinates the production plant operation in accordance with USEC policies as reflected in plant procedures and practices.

O-h production line organizations (Operations, Production Support, Maintenance and Work Control) report to the Enrichment Plant Manager and have responsibilities for implementation of USEC safety and safeguards policies and procedures in daily operations. The on<luty PSS reports to the Shift Operations Manager and provides direction and coordination for shift operations. He Shift Operations Manager reports to the Operations Manager. The staff and support organizations (Engineering, Training and Procedures, Environmental, Safety and Health, Site and Facilities Support, Materials Management, Commitment Management, and Nuclear Regulatory Affairs) report to the General Manager and provide program direction and support to the production line in knplementing safety and safeguards requirements. Finally, administrative organizations (Administrative Support, and Special Programs and Planning) report to the General Manager and provide the services required to support the overall plant operations.

i USEC is responsible for safe operation of the GDPs. He operating and maintenance contract between USEC and LMUS affirms the authorities necessary to ensure continued safe operation of the GDPs. USEC approves the management structure and key positions, the assignment of individuals to key positions, qualifications for key positions, and responsibilities and authorities for key positions. Through its onsite presence, contractual authorities, organization and personnel, and management controls, USEC ensures that activities at the GDPs are adequately controlled, that applicable NRC regulatory requirements are met, that the public and worker health and safety are protected, that the environment is protected, and that the common defense ~ provided for.

Personnel minimum qualifications, functions and responsibilities for key staff positions are described below:

O 6.1-3

SAR-PORTS June 30,1999 Rev.32 6.1.1.1 Executive Vice President The Executive Vice President reports to the President and Chief Executive Officer (CEO).

l The Executive Vice President has overall responsibility for safe operations of the GDPs, including packaging and transportation of radioactive material. The Executive Vice President is authorized to direct the General Manager to take any specific action, including but not limited to, placing all or any portion of one or both GDPs in a safe condition, in order to ensure health and safety of workers and the public, protection of the environment, safeguards and security, and to achieve or maintain compliance with applicable regulatory requirements. 'Ibe Executive Vice President is responsible for both the Quality Assurance Program (QAP) and the Packaging and Transportation Quality Assurance Program (PTQAP), and for determining the status, adequacy, and effectiveness of the QAP as described in section 2.2.5 of the QAP and the PTQAP. In addition, the Executive Vice President must concur with the decision of the General Manager to restart any operation that was directed to be shut down by the Executive Vice President or by the Safety, Safeguards and Quality Manager.

The Executive Vice President shall have as a minimum a bachelors degree or equivalent technical l experience',10 years of management experience, and 6 years of nuclear experience (which may be concurrent with the management experience).

The Executive Vice President is appointed by the USEC Board of Directors.

l 6.1.1.2 Vice President, Production The Vice President, Production, reports to the Executive Vice President.

l The Vice President, Production, has overall responsibility for all activities within the production organization, including the functions of operations, maintenance, plant support, engineering, transportation, materials handling and storage, and industrial, radiological, and nuclear safety.

He Vice President, Production, has overall responsibility for packaging and transportation activities within USEC. The Vice President, Production, is responsible for final approval of the design of packaging and design changes to packaging used for radioactive material shipments. The Vice President, Production, is also responsible for review of the PTQAP and oversight of radioactive material packaging and transportation activities.

He Vice President, Production, shall have shut down authority for any aspect of operation at either plant.' In addition, the Vice President, Production must concur with the decision of the General Manager to restart any operation that was directed to be shut down by the Vice President, Production.

Throughout this section, equivalent technical experience means the substitution of 2 years of nuclear industry experience for each year of college up to a total of 3 years. Additionally, 30 semester hours or 60 quarter hours from an accredited college or university may be substituted for 1 year of baccalaureate education.

6.1-4

SAR-PORTS June 30,1999 Rev.32 L

The Vice President, Production, shall have as a minimum a bachelors degree in engineering or the physical sciences or equivalent technical experience, 6 years nuclear experience, and 6 years management experience (which may be concurrent with the nuclear experience).

The Vice President, Production, is appointed by the USEC Board of Directors.

6.1.1.3 Nuclear Regulatory Assurance and Policy Manager The Nuclear Regulatory Assurance and Policy Manager, located at headquarters, reports to the Executive Vice President.

l The Nuclear Regulatory Assurance and Policy Manager has responsibility for the management of nuclear regulatory assurance functions. The Nuclear Regulatory Assurance and Policy Manager is the prunary day-to< lay interface with the NRC Office of Nuclear Materials Safety and Safeguards (NMSS) and has overall responsibility for management of activities related to certification of the GDPs. Although the Nuclear Regulatory Assurance and Policy Manager works closely with the General Manager and key plant personnel, he/she is independent from production, plant operating cost, and production schedule concerns, and

- has the authority to stop work if there is a failure to adhere to regulatory or quality requirements. The Plant Nuclear Regulatory Affairs Manager reports to the General Manager, but is governed by and must adhere to policies established by the Nuclear Regulatory Assurance and Policy Manager.

p The Nuclear Regulatory Assurance and Policy Manager shall have as a minimum a bachelors degree or equivalent technical experience, and 4 years of nuclear experience.

s The Nuclear Regulatory Assurance and Policy Manager is appointed by the Executive Vice President. l 6.1.1.4 Safety and Health Assurance and Policy Manager The Safety and Health Assurance and Policy Manager, located at headquarters, reports to the Executive Vice President.

l

'Ihe Safety and Health Assurance and Policy Manager is responsible for plant fire and police services, nuclear material control and accountability, security, safety and health, radiation protection, and emergency management activities, and for the development and management of comoration-wide policies concerning these matters. The Safety and Health Assurance and Policy Manager is independent from production, plant operating costs, and production schedule concerns, and has the authority to stop work if there is a failure to adhere to applicable regulatory requirements concerning safeguards, security, material control and accountability, and emergency services.

The Safety and Health Assurance and Policy Manager shall have as a minimum a bachelors degree or equivalent technical experience, and 4 years of safety and health and/or nuclear experience.

The Safety and Health Assurance and Policy Manager is appointed by the Executive Vice President. l O

v 6.1-5

i l

SAR-PORTS June 30,1999 Rev.32 6.1.1.5 Environmental Assurance and Policy Manager The Environmental Assurance and Policy Manager, located at headquarters, reports to the Executive Vice President.

l The Environmental Assurance and Policy Manager is responsible for the development and j

management of wrporation-wide environmental and waste management policies and for these activities at the plants. 'Ihis manager is indeperxlent from production, plant operating costs, and production schedule concerns, and has the authority to stop work if there is a failure to adhere to applicable regulatory requirements in environmental and waste management areas.

The Environmental Assurance and Policy Manager shall have as a minimum a bachelors degree or equivalent technical experience, and 4 years of environmental management experience.

The Environmental Assurance and Policy Manager is appointed by the Executive Vice President.

l 6.1.1.6 Safety, Safeguards and Quality Manager The Safety, Safeguards and Quality Manager, located at the plant, reports to the Executive Vice President.

l j

The Safety, Safeguards and Quality Manager has the responsibility to exercise oversight of plant operations to ensure that the health and safety of the public and workers are adequately protected, to ensure compliance with safety, safeguards, and quality requirements and to ensure implementation of policies, procedures and management expectations. The Safety, Safeguards and Quality Manager is also responsible for nuclear material control and accountability.

The Safety, Safeguards and Quality Manager is independent from production, plant operating cost, and production schedule concerns, and has authority to shut down operations and/or stop work when necessary to ensure protection of public and worker health and safety and provide for common defense and security and to ensure regulatory and quality compliance. This manager has access to all information at the site related to safety, safeguards and quality. This manager interacts directly with the General Manager, other managers, and key plant personnel and participates, as desired, in any evaluations or discussion safeguards and quality. This manager informs the Executive Vice President, Vice President, Production, and the General Manager about safety, safeguards, and quality issues and compliance. This manager manages the Safety, Safeguards and Quality Office and directs plant quality assurance functions involving audits and oversight of plant operations as well as a nuclear safety assurance function.

The Safety, Safeguards a.'x! Quality Manager primarily works the office shift but periodically observes plant operations performed on backshifts. This manager is on-call and is notified by the Plant Shift Superintendent's office of reportable events, per plant procedures. This notification occurs on all shifts.

6.1-6

SAR-PORTS June 30,1999 Rev.32 he Safety, Safeguards and Quality Manager shall have as a minimum a technical degree and 15 years nuclear experience with 3 years of management experience in quality assurance, nuclear safety oversight, engineering and technical support, or regulatory affairs. Either the Safety, Safeguards and Quality Manager, or a management position responsible, for quality assurance that reports to the Safety, Safeguards and Quality Manager, shall have a minimum of 1 year quality assurance experience or 1 year experience implementing quality assurance program requirements.

De Safety, Safeguards and Quality Manager is appointed by the Executive Vice President.

l 6.1.1.7 President, IMhaani Martin Utility Services, Inc.

He President, LMUS, has corporate responsibility within LMUS for the USEC/LMUS operating

& maintenance contract for the GDPs. De President, LMUS is responsible for providing the services described by the contract to USEC, through the Vice President, Production.

De President, LMUS, is appointed by the President of Lockheed Martin Energy and Environmental i

with concurrence by the President and CEO, USEC.

6.1.1.8 General Manager

%e General Manager reports to the Vice President, Production, and administratively to the President, O

The General Manager is responsible for the safe operation of the plant, for compliance with all applicable NRC regulatory requirements, and for adherence to applicable policies. De General Manager is responsible for production, training and procedures, site and facilities support, engineering, transportation, materials handling and storage, and occupational, environmental and nuclear safety. Day-to-day authority and accountability for production and production support activities is assigned to the Enrichment Plant Manager.

De General Manager has responsibility for the primary day-to-day interface with NRC on matters of adequate safety / safeguards and regulatory compliance, and may delegate responsibility for that interface to the Nuclear Regulatory Affairs Manager.

De General Manager has shut down and stop work authority for all or any portion of the plant (leased facilities). The General Manager shall be responsible to authorize restart of shut down operations and must obtain concurrence of(1) the Vice President, Production, for any operations that were directed to be shut down by the Vice President, Production; and (2) the Executive Vice President, for any operations that were directed to be shut down by the Executive Vice President, or by the Safety, Safeguards and Quality Manager.

The General Manager shall have as a minimum a bachelors degree in engineering or the physical sciences or equivalent technical experience,6 years of nuclear experience, and 6 years of management experience (which may be concurrent with the nuclear experience).

The General Manager is appointed by the President, LMUS with concurrence by the Vice President, Production, and the Executive Vice President.

l bv 6.1-7

SAR-PORTS June 30,1999 Rev.32 O

6.1.1.9 Enrichment Plant Manager The Enrichment Plant Manager reports to the General Manager.

The Enrichment Plant Manager is responsible for the day-today production activities at the site Idvhg operations, maintenance, work control, and production support (which includes radiation protection, quality control, laboratory analysis, and waste management). The Enrichment Plant Manager shall be responsible for authorization of restart of shutdown operations but must seek concurrence from the General Manager for any operation that was shutdown by the General Manager, the Vice President, Production, the Executive Vice President, or the Safety, Safeguards and Quality Manager.

l The Enrichment Plant Manager shall have as a minimum a bachelors degree in engineering or the physical sciences or equivalent technical experience, 6 years of nuclear experience, and 6 years of management experience (which may be concurrent with the nuclear experience).

The Enucament Plant Manager is appointed by the General Manager, with concurrence by the President, LMUS and the Vice President, Production.

6.1.1.10 Operations Manager he Operations Manager reporta to the Enrichment Plant Manager.

The Operations Manager is responsible for the operations of the enrichment cascade, plant utilities, chemical services, feed and product facilities and shift operations. This includes activities such as ensuring the correct and safe operation of the UF.pr%; proper receipt, storage, handling and onsite transportation of UF6; pmviding electric power, steam, compressed air, nitrogen, plant and sanitary water, and waste water treatment for the cascade and support facilities; and providmg chemical cleaning and decontamination services.

In the absence of the General Manager and Enrichment Plant Manager, the Operations Manager may be delegated the responsibilities and authorities of the General Manager and/or the Enrichment Plant Manager.

His manager shall have the authority to stop work and/or shut down operations in any part of the operation for which he/she has responsibility.

The Operations Manager shall have as a minimum a bachelors degree in engineering or the physical sciences or equivalent technical experience, and 4 years of nuclear experience with at least 6 months in a gaseous diffusion plant.

The Operations Manager is appointed by the Enrichment Plant Manager with concurrence by the General Manager and the Vice President, Production.

6.1.1.11 Maintenance Manager The Maintenance Manager reports to the Enrichment Plant Manager.

The Maintenance Manager is responsible for safe, reliable, and cost-effective performance of preventive, predictive, and corrective maintenance on production facilities and equipment. This includes troubleshooting, maintenance of logs and records, interfacing with work control to initiate, screen, 6.1-8

l SAR-PORTS May 31,1996 g

Rev.3 evaluate, prioritize, and plan maintenance work, and coordinating shop maintenance in direct support of production equipment and buildings. De manager shall have the authority to stop work and/or shut down operations in any part of the operation for which he/she has responsibility.

l ne Maintenance Manager shall have as a minimum a bachelors degree in engineering or the physical l

sciences or equivalent technical experience, and 4 years of nuclear experience with at least 6 monis in a l

gaseous diffusion plant.

The Maintenance Manager is appointed by the Enrichment Plant Manager with concurrence by the General Manager and by the Vice President, Production.

6.1.1.12 Production Support Manager l

l De Production Support Manager reports to the Enrichment Plant Manager.

The' Production Support Manager is responsible for the technical functions in direct support of pr4+ activities. This includes the radiation protection program, laboratory operations, quality control, l l

and waste management services. Quality control in this case means the inspection of modifications, new construction, and maintenance tasks as well as receipt inspection of material and inspection of plant equipment for conformance with applicable codes as described in procedures. This manager shall have the authority to I

stop work and/or shutdown operations in any part of the operation for which he/she has responsibility.

The Production Support Manager shall have as a minimum a bachelors degree in engineering or the physical sciences or equivalent technical experience, and 4 years of nuclear experience with at least 6 months in a gaseous diffusion plant.

he Production Support Manager is appointed by the Enrichment Plant Manager with concurrence l

by the General Manager and the Vice President, Production.

l 6.1.1.13 Radiation Protection Manager l

Be Radiation Protection Manager reports to the Production Support Manager.

l j

l The Radiation Protection Manager is responsible for the implementation, maintenance, and l effectiveness of the health physics and radiation protection programs. These duties include training personnel in the use of radiological program support equipment, controlhng radiation exposure of personnel, determining l

the radiological status of the facility, determining the need for issuing and closing out radiation work permits, and conducting the radiological occupational monitoring program. %e Radiation Protection Manager has l l

direct access to the General Manager and the Enrichment Plant Manager concerning radiation protection l

matters and has stop work authority for activities not being conducted in accordance with radiation protection requirements and policies.

1 De Radiation Protection Manager shall have as a minimum a bachelors degree in engineering, health l physics, radiation protection, or'the physical sciences or equivalent technical experience, and 4 years l

experience in radiation protection including 6 months at e uranium processing facility.

O i

V 6.1-9

1 l

l SAR-PORTS June 30,1999 Rev.32

\\

O l

ne Radiation Protection Manager is appointed by the Production Support Manager with concurrence by the Enrichment Plant Manager and General Manager.

6.1.1.14 Work Control Manager The Work Control Manager reports to the Enrichment Plant Manager.

De Work Control Manager is responc,ible for production maintenance work planning and scheduling.

His includes managing daily work control activities, developing an integrated work schedule, and coordinating development of work control guidelines.

De Work Control Manager shall have as a mimmum a bachelors degree in engmeering or the physical sciences or equivalent technical experience, and 4 years of nuclear experience with at least 6 months in a gaseous diffusion plant.

He Work Control Manager is appointed by the Enrichment Plant Manager with concurrence by the General Manager and the Vice President, Production.

6.1.1.15 Shift Operations Manager The Shift Operations Manager reports to the Operations Manager.

The Shift Operations manager coordinates the activities of the Plant Shift Superintendents and provides technical and administrative support.

The Shift Operations Manager shall have as a minimum a bachelors degree or equivalent technical

' experience, and 4 years nuclear experience with at least 6 months at a GDP.

The Shift Operations Manager is appointed by the Operations Manager with concurrence by the Enrichment Plant Manager, General Manager and the Vice President, Production.

6.1.1.16 Plant Shift Superintendent s

The Plant Shift Superintendent reports to the Shift Operations Manager.

As the senior manager on shift, the Plant Shift Superintendent represents the General Manager and has the authority and responsibility to make decisions as necessary to ensure safe operations, including stopping work and placing the plant in a safe condition. De Plant Shift Superintendent is responsible for accumulation and diwmimtion ofinformation regarding plant activities, serving as or designating an incident commander during plant emergencies, and making notification of events.

%e PSS is authorized to stop operations when system operability or the overall safety of operations is in question. The PSS is also authorized to initiate restart after shut down for non-routine reasons. For shutdowns that are directed by the Executive Vice President; Vice President, Production; Safety, Safeguards l and Quality Manager; the General Manager, or the Enrichment Plant O

6.1-10

SAR-PORTS April 14,1999 Rev.31 Management systems and programs are described in Chapters 5 and 6, the Technical Safety Regidos;;s, and in several program plans and descriptions (notably, the Emergency Plan, Quality Assurance Program, Radioactive Wase Management Program, Faadamenal Nuclear Material Control Plan, and Security Plans). The commitment tracking and corrective action management systems are integrated to prioritize plant actions consistent with their safety and safeguards significance. Where safety or safeguards might be adversely impacted by cost or schedule considerations, it is the policy of USEC to subordinate cost and schedular considerations to ensure adequate treatment of safety nad safeguards. The interface and coordination of the elements of safety and safeguards programs are accomplished through the management systems described in this chaper and are manifest in the line duection of plant operations. Additionally, oversight of the integration ofvarious program elements is provided by the Safety, Safeguards and Quality Manager. From a technical perspective, the Plant Operations Review Committee (PORC) and its associated subcommittees provide the mechamsm for evaluating and inegrating E&H and SS&Q program elements from a plant design and program,

change perspective.

6.1.3 Section Deleted O

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SAR-PORTS April 14,1999 '

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Rev.31 6.5.5.3 IAskeeping

. Operator logs provide a means of documenting the information on activities occurring during shift.

i Logbooks are maintained in the ACRs, shift /first-line managers' offices, CC's desk, and in the PSS office and in other designated areas.

l EngM*= maintained in ACRs record chronological operations of the shift and equipment realignments and problems encountered.- Supervisors' logs are often the summation of activities from different operating areas under their supervision. Therefore, the chronology of events is not as rigorously followed except under emergency conditions. Entries in all logs are in black ink with corrections lined out, initialed, and dated. legs are essential in completing shift turnover, and turnover is documented by signatures in logs by the outgoing and incoming m.veJ. 'Ihis formal turnover is done to assure the information necessary for smooth activity transition is exchanged. Iog books are also routinely reviewed by day shift personnel, individual building managers (called facility coordinators), gmup heads, and others. 'Ihese reviews are indicated by the reviewer's initials in the logbook.

6.5.6 Operations Procedures and Operator Aids and System Labeling Operating procedures are prepared, reviewed, and approved as outlined in Section 6.11. Shift operations peacnnel follow and use procedures as described in Section 6.11. Actions required by emergency and alarm response procedures may be completed before referring to the procedure if conditions warrant.

Another valuable tool for support of operator duties are the operator aids. These aids consist of posted j

sketches, notes, graphs, instmetions, and drawings. A formal program is in place to control and account for these aids and ensure they are correct in all respects. Operating information is also disseminated using organization memos, daily instructions, ami long-term shift orders. 'Ihese communications provide information not included in procedures which is required for a special short-term period by the opnations personnel.

Major equipment and piping systems are labehd Lse labels and personnel in identifying specific equipment and systems in the field. In the large cascade buildings, the gnuping of equipment into units and cells is clearly marked so that the possibility for operator error is minimized. In addition, equipment location can be identi6ed by a column grid system (alpha-numeric) which can be used to direct operators or emergency responders to the proper location.

6.5.7 Permits and Tagging A lockout /tagout permit system is in place which provides controls for ensuring safe isolation of systems for maintenance or testing. Lockout /tagout activities are performed by authorized personnel and l placement is independently verified. A " Caution Tagging" system has been implemented as a warning to operators to stop and seek assurance of proper action before proceeding. Section 6.4 discusses this in more

- detail.

.h i.

a 6.5-11

1 SAR-PORTS June 30,1999 Rev.32 i

O 6.5.8 Management Monitoring of Operations A management assessment program is used by management to provide oversight of plant operations.

De program includes managers at all levels and is described in procedures. The results of the program are disseminated to appropriate management for evaluation.

6.5.9 Control of Equipment ne Cascade Operations controller provides overall coordination of operational activities including removing / returning of cascade equipment to service, increasing / decreasing power levels, radiological protection, maintenance, and instrumentation to accomplish the operating objectives for the shift and to maintain safe and efficient operations. Communications between the controller and the first-line managers who authorize the removal and return of equipment and systems from service for maintenance, testing, or operational activities is conducted using the communications methods described above.

Qualified operators are capable of diagnosing facility and equipment conditions and are authorized to perform tasks during normal, off-normal, and emergency conditions which may include the shutdown of equipment. Restart of equipment from routine shutdowns is authorized by the first-line manager. He PSS is authorized to stop operations when system operability or the overall safety of operations is in question. The PSS is also authorized to initiate restart after shut down for non-routine reasons. For shutdowns that are directed by the Executive Vice President; Vice President, Production; Safety, Safeguards and Quality l Manager; General Manager or the Enrichment Plant Manager; the PSS may authorize restart only after obtaining the approval of the Enrichment Plant Manager (who will in turn obtain the necessary concurrence as described in Section 6.1.1.9).

For the purposes of ensuring the ongoing operability of TSR-required equipment, Operations utilizes procedural requirements which include the following activities:

Day-to-day operation of the facility Plant walkdowns or tours Operator observations Inspections, assessments, and audits Engineering evaluations and design reviews TSR-required surveillance tests The above activities combine to provide continuing assurance that TSR-required equipment will perform as required, when needed.

To regain operability of equipment which has failed, been taken out of service, or had maintenance performed on it, each of the following elements must be satisfied:

Applicable surveillance test (s) must be successfully performed Any involved technical support organizations, such as engineering or criticality safety, must approve restart or return to service PSS gives authorization O

6.5-12

SAR-PORTS June 30,1999 Rev.32 6.8 AUDITS AND ASSESSMENTS A system of audits and assessments is implemented at the Portsmouth Gaseous Diffusion Plant (PORTS) to ensure that the health, safety, and enviromnental programs, as described in this application, are adequate and effectively implemented. He system is designed to ensure comprehensive program oversight at least once every three years. He system is comprised of two distinct levels of activities. These are audits and asser.sments.

6.8.1 Audits l

Audits are madam by the USEC plant independent Safety, Safeguards and Quality organization in 1

accordance with procedures and checidists by qualified auditors. Audits verify the effectiveness of health, safety and environmental programs and their implementation and determine the effectiveness of the assessment process.

These audits and their associated frequencies are conducted in accordance with Section 2.18 and Appendix A of the Quality Assurance Program and use written plans and checidists. Audits are performed under the direction of a Lead Auditor, qualified in accordance with the American Society of Mechanical Engineers (ASME) NQA-1 Supplement 2S-3. Iead auditors and staff auditors are functionally and organizationally independent of the programs and activities examined. Where appropriate, audit teams are supplemented with on site and/or off site technical specialists.

Audit results are documented and reported as specified in plant procedures. Provisions are made for immediate reporting and corrective action where warranted, as described in Section 6.9. A plant corrective action program is administered to ensure proper control of corrective actions as defined in Section 2.16 of the Quality Assurance Program (QAP).

C*at with Section 2.2.5 of the QAP, the Executive Vice President is responsible for determining l the status, adequacy, and effectiveness of the QAP at least once every 24 months through review and audit of each of the GDPs in accordance with applicable procedures.

j 6.8.2 Assessments Assessments are performed by management responsible for implementing portions of the QAP to assess the adequacy of the part of the QAP for which they are responsible and to assure its effective

- implementation, as required by NQA-1 Basic Requirement 2. Personnel from the area being na*=ad may l

perform the assessment, provided that they do not have direct responsibility for the specific area being neaa-i. Results of smeaments shall be documented. Any observations from the program assessments are resolved by the responsible organization manager.

1 A-= ants performed include:

6.8-1

r w

SAR-PORTS May 31,1996 Rev.3 6.8.2.1 Program Assessments The managers responsible for several major programs assure assessments are performed of their particular programs:

Nuclear Criticality Safety activities related to assessments are addressed in Section 5.2.2.9,

" Operation Surveillance and Assessments."

Assessments are conducted of the fire protection program in Organizational Self Assessment (Section 6.8.2.2) and Management Self Assessments Activities (Section 6.8.2.3). These assessments include the Testing and Impection program as addressed in Section 5.4.4 and the hazard evaluations of Section 5.4.1.2.

A-ments of environmental programs are performed to assess compliance with environmental laws and regulations and to verify completion of corrective actions for environmental noncompliances.

Assessments of health and safety programs are performed on a regular basis (typically one to two program areas per month, with all major program areas, as determined by the Organization Manager, assessed every 3 years) by Safety and Health professionals to verify that programs are effectively achieving their designed purposes. Industrial Safety, Radiation Safety and Chemical Safety are the major programs asseaa?

Assessments of the accuracy of nuclear materials accounting records are performed by Nuclear Material Control and Accountability (NMC&A) Group personnel. These assessments are required as part of the item monitoring activities associated with the item control program, as described in Section 8 of the Fundamental Nuclear Material Control Plan (FNMCP).

6.8.2.2 Organizational Self Assessments Managers of Operations, Maintenance, Work Control, Production Support, Engineering, Site and Facilities Support, and Training and Procedures maintain a management assessment process within their organization to assess the adequacy of and effectiveness of the implementation of the programs under their cognizarrn 'Ihe Safety, Safeguards, and Quality organization will monitor the organizational self-assessment process.

6.8.2.3 Management Self Assessment Activities Managers evaluate findmgs from audits, assessments and problem reports to determine their significance to plant safety and to ensure proper resolution. In addition, a program titled Management by Walking Around (MBWA) describes how senior managers evaluate plant facilities in the areas of Occupational Safety and Health, Nuclear Criticality Safety, Radiological Protection, Environmental Compliance, Safety Requirements, Conduct of Operations, and Conduct of Maintenance. Issues relating to Training, Quality Assurance, Maintenance, Configuration Management, etc., are also assessed during these assessments. Problem Reports (as described in Section 6.8.2.4) are generated for nonconforming conditions.

O 6.8 2 2

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