ML20217J356

Forwards Proposed Rev to Shared Site Issues Agreement (Ssia) Modifying Section 13, Access to Deleased Outside Areas, as Listed

ML20217J356
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant, Paducah Gaseous Diffusion Plant
Issue date:	03/26/1998
From:	Rifakes G UNITED STATES ENRICHMENT CORP. (USEC)
To:	Jazel Parks ENERGY, DEPT. OF
References
DOE-98-0006, DOE-98-6, NUDOCS 9804060274
Download: ML20217J356 (9)

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GEORGE P. RIFAMES Dir: (301) 564-3301 EXECUTIVE VicE PRESIDENT, OPERATIONS Fax: (301) 564-3208 March 26,1998 DOE 98-0006 Mr, Joe W. Parks Assistant Manager for Enrichment Facilities U. S. Department of Energy Oak Ridge Operations P. O. Box 2001 Oak Ridge,iennessee 37831-8651 United States Enrichment Corporation (USEC)

Paducah Caseous Diffusion Plant (PGDP)

Portsmouth Gaseous Diffusion Plant (PORTS)

Docket Nos. 70-7001 & 70-7002 Proposed Revision to Shared Site Issues Agreement (SSIA)

De tr Mr. Parks:

i i SEC letter DOE 97-0004 dated November 14,1997, requested the Department of Energy's (DOE) concurrence to delease certain GDP acreage back to the DOE effective April 1,1998. This submittal also contained a proposed revision to the Shared Site Issues Agreement (SSIA) to reflect the controls that will become effective when the proposed acres are deleased. Pursuant to your letter to James l

Adkins of USEC dated March 9,1998, and based on a conversation between you and Mr. Adkins on March 18,1997, it is my understanding that we are in agreement that proposed Section 13, " Access to Deleased Outside Areas," of the SSIA be modified to state:

"All activities in non-leased areas will be executed consistent with DOE requirements.

USEC procedures _which comply with NRC requirements may be utilized provided they meet or exceed equivalent DOE requirements. Subject to DOE approval, USEC may be

permitted to run additional or new utilities over and/or under these outside areas to serve additional needs of USEC and DOE. USEC will' contact DOE prior to work in these areas and will not violate any requirements imposed on the DOE by other regulatory agencies (e.g. EPA, OSHA). In cases where prior rotification would deter USEC's ability to respond to an' exigent situation (e.g., emergerc; respon situations, water main breaks, etc.), notification will occur as soon as nracticai."

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6903 Rockledge Drive. Bethesda. MD 20817-1818 Telephone 301-564-3200 Fax 301564-3201 http://www.usec.com 9804060274 980326

ah, KY Portsmouth, OH Washington, DC PDR ADOCK 07007001 C

PDR

/ Mr. Joe W. Parks -

' o March 26,1998

' DOE 98-0006, Page 2.

Accordingly, USEC is resubmitting the proposed revision to the SSIA for your approval. Please indicate your concurrence with the proposed revision to the SSIA by signing the' concurrence page in the

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enclosure to this submittal and retunung it to USEC. Ifyou have eny questions regarding this submittal please feel free to contact Jim Adkins at (301)564-3417 or Russ Wells at (301) 564-3245 regarding this submittal. There are no new commitments contained in this submittal.-

Sincerely,

,fip)

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/

George P. Rifakes Executive Vice President, Operations

Enclosure -

cc:.NRC Special Projects Branch NRC Region III Office.

NRC Resident Inspectors, PGDP and PORTS i

PGDP and PORTS DOE Site Office

' DOE Regulatory Ovnsight Manager i

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ENCLOSURE TO GDP 95-0018 '-

I USEC AND DOE RESOLUTION OF SHARED SITE ISSUES' L-AT THE I

GASEOUS DIFFUSION PLANTS o

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USEC AND DOE RESOLUTION OF L

SHARED SITE ISSUES AT THE l

l GASEOUS DIFFUSION PLANTS l-(Revision 1)

. Background

Once the NRC assumes nuclear regulatory oversight for USEC activities at the GDPs, there will be a need to coordinate DOE and USEC activities at the GDPs to ensure that:

1.

USEC and DOE activities at the GDPs do not adversely affect the operations of the other party in terms of health and safety, environmental protection, safeguards and l

security, and nuclear regulatory compliance, i

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Situations with the potential to affect both DOE and USEC operations and personnel, such as emergencies and threats directed toward site activities, are managed in a l

coordinated manner that protects the safety and health of DOE and USEC personnel, including their respective contractors / subcontractors, and the public.

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. Premises The following premises support the proposed resolution of shared site issues:

1.

This joint USEC and DOE approach to shared site issues does not modify, amend, or alter in any way the leare' between USEC and DOE for the GDPs, or any memoranda of agreement, or any other agreements between USEC and DOE.

2.

The site can be divided into three types of areas: 1) DOE areas (generally non. leased) in which DOE managed or overseen activities, which are exempt from NRC regulation under Section 110.a of the Atomic Energy Act of 1954, as amended, are conducted; 2) USEC leased areas in which USEC activities subject to NRC l

regulation are conducted; and 3) common areas (e.g., site roads) which are used for USEC and DOE activities.

'The term " lease" refers to the Lease Agreement between the United States Department of

' Energy and the United States Enrichment Corporation dated as of July 1,1993.

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DOE will self-regulate DOE activities conducted in DOE areas and common areas in accordance with applicable DOE requirements. This includes DOE personnel and their contractors / subcontractors. DOE assumes full responsibility for the safety, safeguards, and security of DOE activities.

4.

USEC activities conducted in USEC areas and common areas are subject to NRC

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regulation ur. der terms of the certification application. This includes USEC personnel, their contractors, and subcontractors. USEC assumes full responsibility

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for the safety, safeguards, and security of USEC activities.

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. Shared Site Issues 1.

Shared Systems and Continuity of Essential Services USEC provides certain services and utilities (e.g., lighting, heat) to DOE that are i

necessary for the safety, safeguards, or conduct of DOE activities. Similarly, USEC and DOE activities are protected or supported by shared systems (e.g., nuclear i

criticality and security alarm systems, fire protection sprinklers) that are important to the safety and safeguards of USEC and DOE activities.

USEC and DOE will work together to ensure that interruptions to services necessary for the safety, safeguards and security of the GDPs are minimized and that shared systems remain operable. Additionally, USEC will apply configuration management controis to these systems, in a manner commensurate with that applied to equivalent USEC systems, to ensure that the safety, safeguards and security systems, and conduct of USEC and DOE activities are not adversely affected. Similarly, USEC and DOE will work together to establish a process for controlling the scheduling of interruptions to essential services to ensure that the safety, safeguards, and security i

of the GDPs are not adversely affected.

2.

Control of Work Activities DOE and USEC agree that activities in leased spaces must be conducted in i

accordance with USEC commitments to NRC. Accordingly, DOE (including their contractors / subcontractors) will obtain USEC's approval prior to conducting work in leased spaces. Similarly, prior to conducting work in non-leased spaces, USEC (including their contractors / subcontractors) will obtain DOE's approval. Both parties wi!! strive to ensure that such approvals do not impede the schedule for the work activities of either party. Additionally, both parties will ensure that work activities that affect either party are conducted in accoraance with the appropriate procedures. -

3.

Plant Changes DOE and USEC agree to establish procedural controls to ensure that each party is promptly notified, and appropriate approvals obtained, prior to conducting activities that affect the design, constmetion, operation or maintenance of facilities and systems on their respective portions of the GDP sites. This process will allow the other party to evaluate the potential safety impact of such a change on its own facilities, systems, and activities at the site.

USEC will provide DOE with a copy ofeach approved written Safety Analysis issued in accordance with 10 CFR i 76.68 with respect to any changes to the leased premises or the operation of the leased premises at either GDP site. Similarly, DOE will provide USEC with a copy of each Unreviewed Safety Question Determination (USQD) or Safety Analysis prepared by or for DOE with respect to any changes to DOE's facilities, systems, or operations at either GDP site. Each party will provide the other with pertinent information concerning any Unreviewed Safety Question (USQ) identified in connection with its operations and activitics at either GDP site, including any Justification for Continued Operation (JCO) or similar document prepared in connection with such USQ. In the event that either party has a concern about the potential impact of any plant changes by the other party on the safety ofits own operation: and activities at either GDP site, the appropriate USEC and DOE representatives for that site shall jointly review the change and take appropriate action to resolve the concem (including any required plant modifications) in a prompt manner.

i4.. Emergency Management Coordination In accordance with Exhibit F of the lease, USEC will provide emergency response training to

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DOE personnel, DOE contractors, and personnel of third party tenants of DOE at each of the

. GDPs. In accordance with the lease, DOE will reimburse ~USEC for the cost of this service.

DOE will make the necessary arrangements to assure that these personnel attend such training and be responsible for tracking their participation to assure they receive the required initial and periodic training.

1 The Emergency Plan for both GDPs describes the roles and responsibilities of USEC and DOE

' in the event of an emergency. For a declared emergency, USEC has the lead in responding to j

the emergency and DOE serves as an onsite member of the Emergency Operations Center. This relationship will continue to be maintained when NRC assumes regulatory oversight of the GDPs.

1 In the event of an emergency, in coordination with the USEC emergency management team,

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DOE will take the appropiate actions to control activities in the reservation area surrounding each of the GDP sites, as den ~xi in the current Emergency Plan for each GDP. This includes the exclusion or evacuation of personnel from such area during an emergency. Additionally, USEC has ample authority to restrict ao::ess to the controlled area of the GDPs for the purposes 2

of plant protection, security, emergency preparedness, and radiation protection.'

5.

Third Party Activities on GDP Sites DOE and USEC agree to promptly provide each other with pertinent information concerning any operations or activities being conducted on their respective portions of each of the GDP sites, and the surrounding DOE-owned reservation on which that site is located, by or on behalf of third parties (e.g., the National Guard and other DOE tenants or lessees) that could have a i

potential impact on the operations or activities of the other party at that site. Specifically, DOE l

will provide USEC (and vice versa) with a written description of each existing third party lease agreement for each GDP site, including a detailed description of(a) any hazardous materials used or stored on site in connection with such lease, (b) any operations or activities being conducted under such lease that could pose a hazard to USEC's operatiens on the leased premises or act as an initiating event for an accident on the leased premises, and (c) any transportation or other access requirements on the leased premises or common areas of the site associated with such lease, particularly with respect to the transportation or storage of hazardous materials or equipment. Such descriptions shall be updated promptly to reflect changes in third party activities. In the event that either party has a concern about the potential impact that third party activities could have on the safe operation of either GDP site, the appropriate USEC and DOE representatives for that site shalljointly review the issue and take appropriate action to resolve the concern in a prompt and cost-effective manner.

6.

Physical Protection Coordination Effective access control and response to threats against site activities and facilities requires integrated access control for USEC and DOE activities and coordinated command and control in responding to threats against site facilities and activities. USEC will continue to maintain a physical security protection plan for the GDPs which defines the roles and responsibilities of the site security organizations. In the event of a security threat at the GDPs (including both leased and non-leased areas), USEC's security force has the responsibility to initially respond to the threat and determine the appropriate course of action. Depending on the significance of the security threat, the Emergency Operations Center at the affected site will be activated and, l

as discussed in Item 4 of this enclosure, USEC and DOE will respond accordingly. This relationship will continue to be maintained when NRC assumes regulatory oversight of the GDPs.

2The controlled area is defined as an area osside the renricted area but inside the site (reservation) boundary.

'See USEC letter to NRC dated December 13,1995, in response to Question 2.0Q5 of the application for PGDP anc PORTS. L

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i E. vent Notification 1USEC will promptly notify DOE of any reportable events required by 10 CFR 76 or other j

japplicable NRC regulations. - This notification will normally be made by' the Plant Shift p

- Superintendent's (PSS) office. However, this notification will not take precedence over the L prompt notification of the NRC as required by NRC regulations. Similarly DOE will promptly

_ inform USEC of any reportable events, under DOE's occurrence reporting system, for which -

DOE is responsible. Such notification will normally be made to the PSS's office.

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Helipad USEC' will establish written controls for helicopter access to the ODP ' sites, and the air space l

m over the sites for use by USEC, DOE, or other DOE tenant organizations at the sites and to -

assist state or local law enforcement or emergency response personnel. Once established, DOE agrees to abide by these controls. 'As part of these' controls, DOE will obtain USEC's L

concurrence from the PSS prior to utilizing the site helipad.

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Communiention ofIncident Information and Media Coordination j

DOE and USEC will coordinate information releases to the media in the following manner:

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DOE has the lead role m providing information relating to DOE activities and USEC

-j will refer the media to DOE in such cases; and -

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USEC has the lead role in providing information relating to USEC activities and L

DOE will refer the media to USEC in such cases unless there is a need for DOE to L

provide informati6a in its role as site landlord.

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- DOE and USEC will promptly provide each other with information copies of news releases of events that occur at the GDPs.

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10. Radiation Protection i

Radiation Protection (e.g., exposure monitoring) of employees is the responsibility of the j

employer (USEC or DOE) and is independent of the activities upon which they are working.

Titat is, radiation protection for DOE personnel and their contractors / subcontractors is q

performed umier the DOE radiation protection program. Similarly, radiation protection for j

USEC perso_nnel and their contractors /subcontactors is performed under the USEC radiation L

program. In addition:

L Radiation exposure infomadon ibt individuals who work on both DOE and USEC

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activities will be shared to permit DOE and USEC to satisfy their radiation exposure reporting requirements; and

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DOE will provide NRC with the radiation exposure information for DOE employees i

and their contractors / subcontractors, as requested, in order to meet NRC's reporting requirements.

In accordance with Exhibit F of the lease, USEC will provide radiatica protection training to I

DOE personnel, DOE contractors, and personnel of third party tenants of DOE at each of the GDPs. In accordance with the lease, DOE will reimburse USEC for the cost of this service.

DOE will make the necessary arrangements to assure that these personnel attend such training and be responsible for tracking their participation to assure they receive the required initial and periodic training.

I1. International Atomic Energy Agency (IAEA) Safeguards Agreement Implementation DOE and USEC will cooperate with the NRC in the development, review, and revision of Subsidiary Arrangements and Facility Attachments for DOE and USEC activities at the sites which are applicable to the safeguards requirements of the IAEA.

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12. Unclassified Controlled Nuclear Information (UCNI) l DOE is developing guidelines with consultation and technical support from USEC for the identification of UCNI at the GDPs and will provide these guidelines to NRC.

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Access to Deleased Outside Areas l

l All activities in non-leased areas will be executed censistent with DOE requirements. USEC l

procedures which comply with NRC requirements may be utilized provided they meet or exceed j equivalent DOE requirements. Subject to DOE approval, USEC may be permitted to run l

additional or new utilities over and/or under these outside areas to serve additional needs of l USEC and DOE. USEC will contact DOE prior to work in these areas and will not violate any l

requirements imposed on the DOE by other regulatory agencies (e.g. EPA, OSHA). In cases l

where prior notification would deter USEC's ability to respond to an exigent situation (e.g.,

l emergency response situations, water main breaks, etc.), notification will occur as soon as l

practical.

l CONCURRED BY:

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%^ hh Joe W. Parks Date

/ George P. IJifakes Date Departnient of Energy.

United States Enrichment Corporation Asst. Manager for Enrichment Facilities Executive Vice President