ML20217N357
| ML20217N357 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 08/19/1997 |
| From: | Toelle S UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Pierson R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| GDP-97-0144, GDP-97-144, NUDOCS 9708260130 | |
| Download: ML20217N357 (4) | |
Text
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United St: tis En1chment Corporation 2 Democracy Center
- EM 6903 Rockledge Dnve Bethesda, MD 20817 Tel, (301) $64 3200 Far (301) 564-3201 United States f.nrirlunent Cor]mratiott August 19,1997 Mr. Robert C. Pierson SERIAL: OCr' 97-0144 Chief, Special Projects Branch Division of Fuel Cycle Safety and Safeguards, NMSS United States Nuclear Regulatory Commission Washington, D.C. 20555-0001 Paducah Gaseous Diffusion Plant (PGDP)
Docket No. 70-7001 Application of Facility Staffing Technical Safety Requirements to the Site Secunty Force
Dear Mr. Pierson:
The purpose of this letter is to inform you of our actions to apply the TSR hours of work limitations to security services personnel, in Reference 1, USEC provided plans for implementing the facility staffing requirements dealing with overtime restrictions for the Site Security Force. In that letter USEC stated that PORTS was applying the TSR hour of work limitations by realigning job duties and responsibilities among existing security personnel. At PGDP, USEC committed to evaluate the options for applying the hour of work limitations in TSR 3.2.2.b to security personnel and to identify these options by August 7,1997. It was also noted in Reference I that it was USEC's intention to submit a Certificate Amendment Request to revise the PGDP Compliance Plan, Issue 42, Administrative Controls on Overtime, to outline the plan of action and schedule to bring fmal resolution of this issue.
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USEC has evaluated the options to allow application of the TSR hours of work limitations to the security services personnel at PGDP. The results of this evaluation determined that, by curtailing the g hours ofoperation of certain posts, closing posts, reducing the number of site protection officers utilized g',
for CAAS outages and limiting off-shift support to non-essential projects, USEC will be able to apply g, the hours of work limitations to the security services personnel noted in TSR Table 3.2.2.1 without the M.
routine use of deviations to the TSR guidelines. We currently anticipate that these actions will be
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3 implemented by October 31,1997, which will result in the application of the TSR hour of work limitations to security personnel at PGDP, without the routine use ofdeviation requests. However, we will continue to evaluate this schedule and expedite this schedule as reasonably achievable.
9708260130 970819 PDR ADOCK 07007001 I
C PDR l
l Offices in Paducah, Kentucky Portsmouth, Ohio Washington. DC
Mr. Robert C. Pierson August 19,1997 GDP 97-0144 Page 2 Until this date,- USEC will attempt to aggresively reduce the deviation requests, to the extent practical, but anticipates further use of deviations until PGDP can fully apply the hours of work limitations to security services personnel.
Based on the receipt of your letter (Reference 2) and an evaluation of the options which will allow USEC to apply the hours of work limitation to security personnel, USEC has concluded that a revision to the Compliance Plan to address the application of the TSR hours of work limitations to site security personnel is not required.
Should you have any questions related to this subject, please contact me at (301) S64-3413 or Mark Smith at (301) 564-3244. Commitments contained within this letter are noted in Enclosure 1.
- Sinenely,
/)
S. A.
I Steven A.Toelle Nuclear Regulatory Assurance and Policy Manager cc:
NRC Region Ill Office NRC Resident inspector-PGDP NRC Resident Inspector-PORTS s
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Mr. Robert C. Pierson.
. August 19,*1997:
GDP 97-0144 Page 3 References
- 1. NSEC Letter GDP 97-0127, Steven A. Toelle to Roben C. Pierson, " Application of Facility Stafling Technical Safety Requirements to the Site Security Force, " dated July 31,1997,
- 2. NRC letter, Robert C, Pierson to Steven A. Toelle," Application of the Facility Staffing Technical Safety Requirement to the Site Security Force," dated August 8,1997.
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4 GDP 97-0144-Page1of1 1 ist of Commitments
- 1. USEC currently anticipates that the actions which will result in the application of the TSR hour of work limitations to security personnel at PGDP, without the routine use of deviation requests, will be implemented by October 31,1997, llowever, we will continue to evaluate this schedule and expedite this schedule as reasonably achievable, 4
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