ML20217G536
| ML20217G536 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant, Paducah Gaseous Diffusion Plant |
| Issue date: | 10/06/1997 |
| From: | John Miller UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Pierson R NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| GDP-97-0175, GDP-97-175, TAC-L32042, NUDOCS 9710100313 | |
| Download: ML20217G536 (8) | |
Text
United St:l's Enrichment Corpor: tion
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2 Democr:cy C:nt:r 6903 nocMedge Drive Bethesda, Mo 20817 Tel (301)564 3200 ram:(301) 564 3201 JAfAEs H. MILLER Dir. (301) 564 3309 VicE PRESIDENT, PRODUCTION Far (301) 571-8279 October 6,1997 Mr. Robert C. Pierson, Chief SERIAL: GDP 97-0175 Special Projects Dranch Division of Fuel Cycle Safety and Safeguards, NMSS Attention: Document Control Desk U S. Nuclear Regulatory Commission Washington, D C. 20555 0001 Paducah Gaseous DitTusion Plant (PGDP)
Portsmouth Gascous DilTusion Plant (PORTS)
Docket Nos. 70-7001 and 70-7002 USEC Response to Request for Additional Information (RAI)- NRC Annual Report to Congress on the Gr -ous Diffusion Plants (TAC No. IJ2042)
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Dear Mr.
>on' In respense to your letter dated September 11, 1997, TAC No L32042, requesting additional 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 voluntarily provided for your use in preparing the annual report to Congrets on the GDPs. There are no new commitments contained in this correspondence.
9710100313 971006 PDR ADOCK 07007L01 C
PDR 1 y, lllb !$ fl,[l[l blhlll Offices in Uvermore.Cahfomia Paducah, Kentucky Portsmouth. Ohio Washington, UC
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NRC Document Control Desk October 6,1997
- GDP 97-0175 Page 2.
-I would be pleased to discuss these responses with you. Please contact me at (301) 564-3309 or Ms.
Lisamarie Jarriel at (301) 564-3247, Si erely, i.
a es H. Miller lee Presidetit, Production Enclosure cc: NRC Region III Office
- NRC Resident _ Inspector - PGDP NRC Resident Inspector - PORTS DOE Regulatory Oversight Manager W
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i Enclosure USEC Response to Request for Additional Information for the Annual Report to Congress on the GDPs Portsmouth, Ohio and Paducah, Kentucky l
NRC Regunt l.
One section of the annual report will discuss the status ofheahh, safety, and environment. In this section, personnel dose and environmental radioactive releases will be discussed, inchtding whether requirements governing these areas were met.
10 CFR Part 20 specifies dose limits to be metfor members of thepublic (Subpart D) as wellas occupational dose limits (Subpart C). Information thatyou couldprovide on personnel exposures, direct off-site radiation levels including sky shine and radioactive effluents would be usefid. It would also be useftd to obtain a discussion of whether dose limits specified in Part 20 were metfor the period in question, whether there were any i
overexposure / contamination incidents, and whether there were anyplanned special exposures.
USEC Resnonse 10 CFR 76.60(d) requires that the United States Enrichment Corporation (USEC) comply with the applicable provisions of 10 CFR Part 20, Standards For Pr.,tection /. gainst Radiation, not later than the date of the Director's decision on the initial application and/or as specified in an approved plan for achieving compliance. Sectic,n 5.1 of both the PGDP and PORTS Certification Application addresses the management ofradiological environmental protection and Section 5.3 describes the Radiation Protection (RP) Program for keeping occupational radiation exposures and radioactive contamination as low as is reasonably achievable in accordance with the requirements set forth in 10 CFR 20.
Both PORTS and PGDP monitor air and water emissions and maintain a network of environmental thermoluminescent dosimeters ('1 LDs) to monitor ambient gamma radiation levels both on-site and oft site. Both direct offsite radiation and sky shine or scattered radiation dre CoIIeClively 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 are 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 efIluents result in any detectable contribution to the total external gamma exposure as measured by TLDs at the boundary of the unrestricted areas.
US[ C lleshnse to ital, Annucl Itcport to Congess on GDPs Enclosure to GDP 97-0175 October 6,1997 Page 2 of 6 Radioactive ellluents from both PORTS and PGDP (measured as activity) have been within historical levels during this period (hlarch 3-Sept 30,1997). Ilased on measured data to date, the maximum annual public radiation dose for all of calendar year 1997 is presently projected to be 0.05 mrem at PORTS and less than 0.05 mrem at PGDP. Estimated doses at both GDPs are far below the applicable regulatory limits in 10 CFR 20. Part 20 specifies doses to members of the public be limited to 100 mrem /yr (Subpart D).
Part 20 specifies occupational doses be limited to 5 renVyr (Subpart C). In fact, USEC's RP Program has established an administrative control limit for occupational exposure at one-tenth of the Part 20 limit, or 500 mrem /yr.
Exposure data for the plants are provided below. Data for 1997 only includes the external exposure for tht first two calendar quarters of the year and does not include any of the internal radiation exposure for the year because that data was not available at the time of this report:
PGDP PORTS 1 Exposure.
Data /yr.
Maximum TEDE Average TEDE Maximum TEDE Average TEDE (mrem)
(mrem)
(mrem)
(mrem) 1995 285 2.07 636 5.94 1996 367 4.89 317 4.39 1997 160 2.28 164 2.29 As illustrated by the above data, occupational dose limits have been met historically and for the period in question.
Contamination incidents are tracked and monitored for treno; using performance indicators.
There were 1.5 personnel skin contaminations on average each month at PORTS and none at PGDP during the period in question.
There have been no planned special exposurc; at the GDPs during this time period.
Improvement initiatives in the areas of environmental safety and radiological protection are included in the following section.
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tJSEC Response to RAI, Annuct Report to Congress on ODPs Enclosure to GDP 97 0175 Octol>cr 6,1997 Page 3 of 6 NRC Request 2.
A description of any improvement initiatives that)vu have started or are in progressfor theperiodMarch 3,1997, through Septemb;r 30,1997 to improve environment, safety 1
and heahh issues would also be usefod. These wouldinchide safety and heahh improvements in areas such asfire protection, nuclear safety (criticality, seismic upgrades, equip:nent upgrades, quality assurance, training, SAR reviews), packaging and transportation, emergency preparedness, radiation protection, and worker safety.
USEC Response USEC and the plants have undertaken a number ofimprovement initiatives to increase the margin of safety at the plants. The ongoing Nuclear Safety Upgrades (NSU) Program includes the bulk of the initiatives This $200 Million program includes both functional upgrades and physical modification of the facilities. The following summarizes some of the key elements of that program as well as other initiatives outside of the NSU program:
f Nuclear Criticality Safety Program upgrades:
- quality reviews of nuclear criticality safety evaluations (NCSE) and approvals (NCS A) to verify their technical basis, related Technical Safety Requirements (TSRs), and implementing pro.edures and training modules;
- field verification of revised NCSE/NCSAs;
- (PORTS) prevent / mitigate possibility ofliquid from breeched cylinder entering scale pit and causing criticality by installing geometrically favorable sumps in scale pits, geometrically favorable storal;e reservoirs, and moisture detectors in sumps;
- (PGDP) Criticality Accident Alarm System (CAAS) upgrade.
Seismic upgrades:
- increase the structural capacity of the roof supports on certain process buildings at PGDP to withstand a 250-year recurrence interval earthquake.
Equipment upgrades:
- (PORTS) Autoclave modifications to improve the operability of safety systems;
- (PORTS) HEPA Filter upgrades to meet ANSI /ASME standards;
- (PGDP) Replaced cranes that handle liquid cylinder UF cylinders in C-360; 6
- (PGDP) Autoclave containment system push buttons to place autoclaves in containment upon confirmatica of a UF, release;
- replace outleakage detection system with smoke detectors.
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USJ C llesponse to RAI, Annual Report to Congress on ODPs Enclosure to GDP 97-0175 October 6,1997 Page 4 of 6 Procedures /fraining upgrades:
- develop and implement accurate, human factored procedures (1500 new and 1800 upgraded procedures);
- Systematic Approach to Training methodology adopted (245,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of training / training development);
- Procedures for oiT-normal operations.
Safety Analysis Report upgrade: An upgraded safety analysis for the GDPs was completed by DOE in February 1997. USEC is in the process of verifying DOE's update of the plants' safety analysis to provide the necessary basis for establishing the safe operating parameters of the facilities. The new information includes supporting documentation for scenario identification, source term analysis, and consequence analysis.
Packaging / Transportation QA upgrade:
- develop and implement a quality assurance program to ensure safe shipping of enriched uranium products.
I Emergency Preparedness upgrades:
- develop a hazards and consequences assessment;
- upgrade the existing emergency plan and implementing procedures to address hazards assessment;
- develop training program for those called upon to respond to emergencies, including drills, and exercises;
- proside dedicated emergency response equipment;
- (PGDP) replace existing public warning sirens with new siren system to enhance reliability and ensure better coverage ofimmediate notification areas.
Radiation Protection Program upgrades:
- ventilation units for control of airborne radioactive material (gulpers, HEPA units, negative air machines, ventilation units);
- developed training course module for "ALARA for Emergency Responders" detailing practical use of ALARA principles in emergencies;
- expanded use of Continuous Air Monitors and breathing zone air sampling (new label air samplers) to assure exposures are being maintained below regulatory limits;
- (PGDP) increased use of high-volume air samplers which employ an annular icinetic impaction head reducing the amount of radon interference associated with filtered samplers.- As a result, personnel can evaluate airborne concentrations more timely.
- new computer system to maintain internal and external dosimetry personnel exposure data, and maintain and track radiation instrumentation and radioactive sources on site.
The database is accessible to all areas of the plant;
- site characterization and survey;
- posting based on the results of the site characterization and survey;
- improved radiation work permit system to reduce the risk of skin contaminations.
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USI, C Res;bnse to RAI, Annual Report to Congress on GDPs Enclosure to GDP 97 0175 October 6.1997 Page 5 of 6 Worker Safety upgrades: Each of the process and equipment upgrade activities described above to improve the GDPs ubility to protect the health and safety of the public also improve the protection of the health and safety of the worker. Improvements in the areas l
of safety systems, procedures, training, NCS controls, fire protection, radiation work permits, etc. all address worker safety. For instance, Fire Protection Program upgrades included new and improved procedures and training; upgrades to the Fire Alarm System; refurbishment of electric fire water pumps, verification of the maximum acceptable combustible loading in the process buildings; and verification of the adequacy of sprinkler systems.
In addition, approximately 26,000 potential industrial safety hazards have been corrected at the plants since July 1993 at a cost of $22 hiillion. A further $8 hiillion is budgeted to achieve acceptable OSHA compliance by the year 2000. This work is ongoing.
The Lost Workday Case (LWC) rate at the GDP complex averages 1.27 for the period in question. This is below the industry' average LWC rate of 2.0. Similarly, the Recordable Injuries / Illnesses (RIls) rate at the complex averages 2.98 for the period in question. This is below the industry' average for Rlls of 4.4.
Configuration Management Program upgrades: Developed to 1) ensure configurations of systems credited as providing a nuclear safety function are maintained consistent with the safety basis, and 2) ensure hardware modifications and procedure changes are reviewed to ensure adequate safeguards are maintained. Improvements include; l) identify and achieve configuration control of Q and AQ SSCs,2) establish a program to control vendor manuals for Q and selected AQ items, and 3) establish an instrument setpoint control program.
Instrument Calibration Program upgrades: Establish calibration settings for variables on which safety limits have been placed and calibrate other control instrumentat on in the i
plants.
Environmental Program upgrades: Both PORTS and PGDP have a Pollution Prevention and Waste hiinimization program that have been implemented since the creation of USEC.
Initiatives in this area since hiarch 3,1997 have focused on reducing the generation of mixed waste. The PGDP olant has upgraded a number of ambient emironmental air monitors The new monitors use a high-volume air pump instead oflow-volume samplers and pull a larger volume of air over a larger filter which allows for a lower level of detection for some types of radiation. They also now allow for analysis of uramum.
' Industrial Chemical Industry.
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USflCReshnse to RAl Annual Report to Congress nn ODPs Enclosure to GDP 97-0175 October 6,1997 Page 6 of 6 NRC Recuen 3.
Please provide any additional information that you would suggest be inchided in the annual report that pertains to the status ofhealth, safety, and environmenta! conditions at the GDPs, or compliance with the standards established by the NRC.
USEC Response USEC has initiated the following programs and process tools designed to promote a dy'iamic safety culture at the plants:
Plant Operations Review Committee: The PORC is a multi-disciplined senior comraittee responsible for reviewing day-to-day and proposed plant activities to ensure ti ese activities are/will be conducted in a safe manner.
Plant Performance Review Committee: The objectives of the PPRC are to identify areas of improvement for plant performance; provide guidance to facilitate improvement; assess overall progmss toward improvement; and report fmdings and/or concerns to executive /line management. The core of this committee consists of senior industry and former NRC executives (both NMSS and NRR). Both plants and the local communities are also represented on the committee. The PPRC conducts an annualindependent assessment of the performance of the GDPs in the following areas: Operations, Maintenance, Engineering, Administration (CAP, PORC, Safety Culture, etc.), Radiation Protection, Chemistry / Radiochemistry, SS&Q, Regulatory Compliance, Training, and Nuclear Safety. The assessment is available for review at the plants and USEC Corporate lieadquarters.
Problem Reporting System: The Problem Reporting System has been effective in promoting the self-identification of problems by plant personnel. The success of the program is indicative of a staff with a safety conscience state of mind.
Coaching Program: Senior individuals experienced and knowledgeable in the nuclear safety culture expected by the NRC were employed as coaches and deployed throughout the plant's organization to show, coach, evaluate, counsel, and advise plant personnel.
Operating Experience Review Program: Operating experience between plants and from outside the GDPs is assessed for its applicability to the GDPs and lessons learned applied to operations.
Performance Indicators: Performance indicators are used throughout the plants and by management to facilitate self assessment and graphically depict operating trends.
Employee Concerns Program: Employee concerns programs were developed to encourage employees to raise safety or compliar.ce issues by providing an additional avenue for employees to raise such concerns that is independent ofline organizations.
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