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| | document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE | | | document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE |
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| | . l March 18, 1997 1 Mr. James H. Miller Vice President, Production l U. S. Enrichment Corporation 2 Democracy Center 6903 Rockledge Drive Bethesda, MD 20817 |
| | |
| | ==SUBJECT:== |
| | CERTIFICATE AMENDMENT REQUEST - PORTSMOUTH GASEOUS DIFFUSION PLANT ADMINISTRATIVE CONTROLS ON OVERTIME (TAC NO. L32010) |
| | |
| | ==Dear Mr. Miller:== |
| | |
| | Enclosed is a copy of the Compliance Evaluation Report prepared to support the amendment of Certificate of Compliance GDP-2. A copy of the Notice of Amendment, which has been forwarded to the Office of the Federal Register for publication, is also l |
| | enclosed. This notice provides the upportunity for the public to petition for review of the l decision in accordance with 10 CFR Part 76, Subpart C. Final action on your amendment 1 |
| | request will not be taken until after the time allowed for requesting review of the Director's Decision is over. If you have any questions regarding this action, I can be l 1 |
| | reached at (301) 415-8113. l l |
| | Sincerely, r+fns1 Signed By ; |
| | Yawar H. Faraz, Project Manager f Enrichment Section ' |
| | Special Projects Branch Division of Fuel Cycle Safety and Safeguards, NMSS Docket 70-7002 Certificate GDP-2 |
| | |
| | ==Enclosures:== |
| | : 1. Compliance Evaluation Report NRC FILE CENTER COPY |
| | : 2. Notice of Amendment OfSTRIBUTION- (Control No. OSOS) |
| | Docket 70-7002 NRC File Center PUBLIC KO'Brien. Riti CCox Alli NMSS r/f FCSSr/f WSchwink. FCOB SPB r/f OGC GShear. All! MHom TWenck OAOTLTRI.YHF OFC SPB b SPS h- SPB g SPB NAME YFara cadley rson DATE J d/97 ) /97 7 )/ 7 / 19 7 I /97 C = CO /ER N = 90 COPi |
| | ~ |
| | E = COVER & ENCLOSURE OFFICIAL RECORD COPY 9703200276 970318 PDR ADOCK 07007002 C PDR |
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| | AR Rio |
| | + |
| | g"e . -- UNITED STATES |
| | := |
| | j NUCLEAR REGULATORY COMMISSION WASHINGTON. D.C. 20655-0001 0 |
| | .... 9 DOCKET: 70-7002 l ' |
| | CERTIFICATE HOLDER: United States Enrichment Corporation l l |
| | Portsmouth Gaseous Diffusion Plant ! |
| | Portsmouth, Ohio i |
| | l |
| | |
| | ==SUBJECT:== |
| | COMPLIANCE EVALUATION REPORT: APPLICATION DATED DECEMBER 23,1996, ADMINISTRATIVE CONTROLS ON OVERTIME BACKGROUND On December 23,1996, United States Enrichment Corporation (USEC) submitted a request to revise the Portsmouth Gaseous Diffusion Plant (PORTS) administrative controls on overtime specified in Technical Safety Requirement (TSR) 3.2.2.b.2. The amendment reduces two limits on working hours for facility staff who perform safety functions. The amendment is in accordance with a commitment made in issue 37 of the Compliance Plan (DOE /ORO-2027 Revision 3, Plan for Achieving Compliance with NRC Regulation at the Portsmouth Gaseous Diffusion Plant), which was part of the USEC certificate application. |
| | The Plan of Action of issue 37 states, "USEC will supplement current staffing allocations ] |
| | i to meet its proposed working hour guidelines that state that an individual should not be permitted to work more than 24 hours in any 48 hour period and no more than 72 hours in any 7 day period exclusive of shift turnover time. In addition, USEC will submit a revised TSR to the NRC to add these guidelines to TSR 3.2.2.b at the time sufficient staffing is achieved to meet these guidelines. Sufficient staffing will be achieved and the revised TSR submitted to the NRC by December 31,1996." |
| | TSR 3.2.2.b.2 in the USEC certificate application states: |
| | "An individual should not be permitted to work more than 16 hours in any 24 hour period, nor more than 32 hours in any 48 hour period, nor more than 80 hours in any 7 day period, all excluding shift turnover time._ |
| | USEC has proposed to revise TSR 3.2.2.b.2 to state: |
| | i "An individual should not be permitted to work more than 16 hours in any 24 hour period, nor more than 24 hours in any 48 hour period, nor more than 72 hours in any 7 day period, all excluding shift turnover time." |
| | DISCUSSION Administrative TSR 3.2.2.blimits working hours of facility staff who perform safety functions (operators, health physics personnel, maintenance personnel, etc.). The proposed change reduces the currently authorized limits, of 32 hours in any 48 hour period |
| | |
| | 2 and 80 hours in any 7 day period, to 24 hours in any 48 hour period and 72 hours in any 7 day perMd, respectively. The staff has determined that these two 8-hour reductions in overtime limits will not adversely affect safety, in fact,it may have a positive effect on safety by reducing occupational stresses and burdens on facility staff who perform safety functions. |
| | UF6 Unconfinement and Criticality The staff has determined that the amendment will not significantly increase the risk of UF6 unconfinement or criticality accidents. On the contrary, the amendment would likely decrease such risks. The reason for this conclusion is that PORTS relies on certain facility staff to perform safety functions for preventing and/or mitigating several criticality and UF6 unconfinement accident scenarios which are analyzed in the Safety Analysis Report (SAR) and determined to be credible. Implementation of the revised overtime controls would apply to such personnel and would likely minimize any adverse effects of excessive work hours. |
| | Occuoational Radiation Exoosure Occupational radiation exposures at PORTS are generally low. Some of the reasons being that (1) occupancy factors are low, (2) distances from radioactive sources are generally high, (3) significant shielding is provided by solid and liquid UF6 (self-shielding) and by piping and equipment, (4) depleted and low enriched uranium has low specific activities and are also comparatively low gamma radiation emitters, (5) most of the uranium in process is in gaseous form (low density), (6) UF6 is confined within quality controlled cylinders, equipment and piping and (7) compliance with the 10 milligram per week soluble uranium intake limit based on its toxicity ensures that the inhalation radiological doses for depleted and low-enriched soluble uranium are small. The proposed reductions in overtime limits would not significantly affect any of these above mentioned seven reasons. |
| | Therefore, reducing overtime limits, will not significantly increase individual or cumulative occupational radiation exposures. |
| | Safeouards and Security The staf f has not identified any safeguards or security related implications from the proposed amendment. |
| | ENVIRONMENTAL REVIEW issuance of the requested amendment to the Portsmouth Certificate of Compliance (GDP-2) to amend the administrative limits on overtime,is subject to the categorical exclusion provided in 10 CFR 51.22(c)(19)and will not have a significant impact on the human environment. Therefore, in accordance with 10 CFR 51.22(b), neither an environmental assessment nor an environmentalimpact statement is required for the proposed action. |
| | CONCLUSION Based on the irformation provided in this CER, the NRC staff approves and grants this amendment. Region ill staff have no objection to this proposed action. |
| | Princioal Contributor (s) |
| | Yawar Faraz}} |
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MONTHYEARML20134D6471997-02-0303 February 1997 Informs That NMSS Anticipates Completing Review of Application for Amend of Coc GDP-2 by 970228 Project stage: Approval ML20137A3041997-03-18018 March 1997 Forwards Compliance Evaluation Rept Prepared to Support Amend of Coc GDP-2.Notice of Amend,Forwarded to Ofc of Fr for Publication Encl Also Project stage: Other ML20137T9661997-04-14014 April 1997 Amends Coc GDP-2 to Limit Facility Staff That Perform Safety Functions to Work No More than 24 H in Any 48 H Period or 72 H in Any Seven Day Period Per 10CFR76 Project stage: Other ML20141F4111997-05-12012 May 1997 Submits Rev 9 to USEC-02,application for NRC Certification, Portsmouth Gaseous Diffusion Plant.Rev Bars Provided in right-hand Margin to Identify Changes Project stage: Request 1997-03-18
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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217N5861999-10-22022 October 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7002/99-09 Issued on 990827 ML20217H6911999-10-19019 October 1999 Ack Receipt of 990928 Application to Revise Technical Safety Requirements 2.2.3.15 & 2.7.3.14.Initial Administrative Review Finds Application Acceptable.Completion of Review Is Anticipated by 991215 ML20217M2961999-10-15015 October 1999 Provides Addl Changes to Updated SAR Certificate Amend Request,Including Changes Made IAW Item 5 of Plan of Action Schedule for Compliance Plan Issue 2 & Changes That Resulted from Reevaluation of Autoclave head-to-shell O-ring ML20217N9141999-10-15015 October 1999 Forwards Rev 6 of NCS Cap,Providing Addl Details within Subtask 3.3,addl Ncsa/E Reviews & Establishes New Milestone to Conduct Addl Reviews IAW Procedure XP2=EG-NS1037, Review of Non-Priority 1 & 2 ML20217G1731999-10-14014 October 1999 Requests Addl Info Re Applications Dtd 990924,requesting Amends to Cocs for Paducah & Portsmouth GDPs for Revised QA Programs.Encl Identifies Specific Info Needed.Info Should Be Provided within 30 Days ML20217G4671999-10-14014 October 1999 Forwards Proprietary Insp Rept 70-7002/99-207 on 990920-23. No Violations Noted.Under Provisions of Section 2.790(d), Repts Containing Info Related to Licensee MC&A Program, Exempt from Public Disclosure ML20217F5481999-10-0808 October 1999 Discusses Insp Rept 70-7002/99-12 on 990810-0920 at Ports- Mouth Gaseous Diffusion Plant.No Cited Violations of NRC Requirements Were Identified During Insp ML20217B6121999-10-0606 October 1999 Forwards Copy of Security Incident Log for Month of Sept 1999 ML20217A4781999-10-0404 October 1999 Forwards Revised Event Rept 99-17,for Event Resulting from Determination That Sprinkler Sys Not Capable of Meeting Operability Requirements.Caused by Mineral Deposits.Provided Following Completion of Root Cause Evaluation ML20212H5991999-09-27027 September 1999 Responds to Violations Noted in Insp Rept 70-7002/99-09. Corrective Actions:Engineering Evaluated Site Rail Track Insp Process for Improvement ML20216J7891999-09-27027 September 1999 Provides Required 30-day Event Rept 99-19 for Event That Resulted from Failure of Cascade Automatic Data Processing Data Processing Smoke Detection Sys at Portsmouth Gaseous Diffusion Plant.Encl 2 Is List of Commitments Made in Rept ML20212H1251999-09-24024 September 1999 Notifies NRC of Change in Regulatory Commitments Associated with Submittal Date for Update of Application SAR Chapter 3.Specifics of Commitment Changes of Listed ML20212H3801999-09-24024 September 1999 Responds to 990723 RAI Re 1999 Annual Update to Certification Applications ML20212G0551999-09-23023 September 1999 Provides Revised 30-day Event Rept 99-06 for Emergency Condition That Was Declared Alert at Portsmouth Gaseous Diffusion Plant ML20212G9401999-09-23023 September 1999 Responds to 990806 Reply to NOV in Ltr with Insp Rept 70-7002/99-04.Revised Reply Reviewed & Responses to Violations 1.B & 1.C Do Not Fully Address Needs as Clarified in 990715 Telcon.Resubmit Response within 30 Days of Ltr ML20212H3721999-09-22022 September 1999 Forwards NRC Form 790 Classification Record Documents for Paducah & Portsmouth GDPs That Were Generated During Month of Aug 1999.Without Encl ML20217J1211999-09-20020 September 1999 Submits Listed Comments on NRC Proposed Rule, Reporting Requirements for Nuclear Power Reactors ML20216E6911999-09-13013 September 1999 Forwards 30-day Written Rept Er 99-18,re Actuation of Cascade ADP Smokehead in X-333 Bldg Low Assay Withdrawal Station.Caused by UF6 Release from Law A/B Compressor Shaft Seal Area.Planned C/As Will Be Provided in Revised Rept ML20211Q7761999-09-10010 September 1999 Forwards Insp Rept 70-7002/99-205 on 990816-20.No Violations Noted.Insp Consisted of Selective Exams of Computer Systems, Representative Records & Interviews with Personnel ML20211P2091999-09-0909 September 1999 Provides Staff Written Clarification of NRC Reporting Expectations of When Double Contingency Losses Should Be Reported to NRC IAW Bulletin 91-001, Reporting Loss of Criticality Safety Controls, & Suppl ML20211Q7171999-09-0808 September 1999 Forwards Required 30-day Written Event Rept 99-14,rev 1,re 990628 Event Involving Actuation of Brake Sys on Liquid U Hexafluoride Handling Crane at Plant.Revised Rept Includes Corrective Actions.Commitments in Rept Also Encl ML20211Q8041999-09-0808 September 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7002/99-05 ML20211N8951999-09-0707 September 1999 Forwards Required 30 Day Event Rept 99-17,for Event That Resulted from Determination That 13 Sprinkler Sys Associated with High Pressure Fire Water Sys in Process Buildings Were Not Capable of Meeting Operability Requirements ML20211M6401999-09-0303 September 1999 Forwards Security Incident Log for Month of Aug 1999,per Requirements of 10CFR95.57(b) ML20211P3831999-09-0303 September 1999 Forwards Coc GDP-1,amend 3 & Coc GDP-2,amend 4 for Paducah (Pgdp) & Portsmouth (Ports) Gdps,Respectively by Revising Pgdp & Ports QAPs in Vol 3 of Respective Certificate Applications ML20211M6941999-09-0202 September 1999 Forwards 30-day Written Event Rept 99-09,rev 1,for Event Involving Actuation of Brake Sys on Liquid U Hexafluoride Handling Crane at Plant.Revised Rept Includes Root Cause & Corrective Actions.List of Commitments,Included ML20211L4871999-09-0101 September 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7002/99-07 Issued on 990709 ML20211K4041999-08-31031 August 1999 Forwards Responses to Remaining NRC Questions/Comments from 980601 & 0709 NRC RAIs Re SAR Update ML20211K2081999-08-31031 August 1999 Discusses 990730 Revised Response to RAI Transmitted by NRC Re 990528 Response for Severity Level IV Violations Identified in Insp Rept 70-7002/99-06 ML20211M7031999-08-30030 August 1999 Forwards Proprietary Rev 0 to Arming & Arrest Authority Security Plan for Paducah & Portsmouth Gaseous Diffusion Plants, for Review & Approval.Encl Withheld ML20211H2741999-08-27027 August 1999 Forwards Insp Rept 70-7002/99-09 on 990629-0809 & Notice of Violations Re Involving Inadequate Corrective Actions of Concern,Due to Staff Failure to Take Actions to Prevent Recent Derailment ML20211G9891999-08-26026 August 1999 Informs That on 990812,NRC Completed three-day Licensing Review of Activities Associated with Usec 990526,certificate Amend Request (CAR) to Reopen Compliance Plan Issues 8,9 & 23 at Portsmouth Plant ML20211D9311999-08-23023 August 1999 Forwards Required 30-day Written Event Rept 99-16 Re Event Involving Autoclave High Condensate Level Shutoff Actuation at Portsmouth Gaseous Diffusion Plant.List of Commitments, Included ML20211A7011999-08-17017 August 1999 Forwards Copy of Final Amend to 10CFR76 for Info of Subcommittee.Final Rule Is Being Transmitted to Fr for Publication.Final Rule Will Amend Regulations That Apply to Paducah & Portsmouth Gaseous Diffusion Plants ML20211C5951999-08-17017 August 1999 Submits Changes to Authorized Derivative Classifier List for Portsmouth Gdp.Changes Are Current as of 990806 ML20211D2351999-08-16016 August 1999 Replaces Ltr Forwarding Proprietary Followup to Submittal Re Holdup of U Enriched Greater than or Equal to 10 Weight Percent U-235 in Process Equipment ML20211D6341999-08-16016 August 1999 Forwards Proprietary Info Containing Process That Would Be Followed Once Deposit Identified That Could Cause Usec to Exceed NRC Possession Limit.Proprietary Encl Withheld ML20211D5771999-08-16016 August 1999 Submits Rev 1 to Event Rept 99-12,to Clarify That Only One of 50 Ball Lock Pins on Packages Used in Shipment Was Unfastened When Shipment Was Received.Cause Has Not Been Determined.Usec Revised Procedure XP4-TE-UH2400 ML20211C3941999-08-13013 August 1999 Forwards Proprietary Followup to Submittal Re Holdup of U Enriched Greater than or Equal to 10 Weight Percent U-235 in Process Equipment.Encls Withheld ML20211C8031999-08-13013 August 1999 Forwards Proprietary Versions of Rev 33 Changes to Fundamental Nuclear Matls Control Plan & Transportation Security Plan.Proprietary Encl Withheld ML20210P6981999-08-10010 August 1999 Forwards Insp Rept 70-7002/99-11 on 990719-23.No Violations Noted.Insp Consisted of Selective Exam of Procedures & Representative Records,Interviews with Personnel & Observations of Activities in Progress ML20210Q5291999-08-0909 August 1999 Responds to Violations Noted in Insp Rept 70-7002/99-07. Corrective Actions:On 990622,results of Nda Surveys for G-17 Valves Moved Outside Bldg X-744H Were Obtained ML20210Q6061999-08-0909 August 1999 Forwards NRC Form 790 Classification Record Documents for Paducah & Portsmouth Gdps,Per 10CFR95.57.Records Were Generated During Month of July 1999.Without Encl ML20210P1841999-08-0606 August 1999 Revised Response to NRC NOV Re Violations Noted in Insp Rept 70-7002/99-04.Corrective actions:DOI-832-99-03 Revised & Reissued on 990729,to Include Any Document Utilized to Support Safety Basis in Ncse ML20210N8511999-08-0606 August 1999 Forwards Copy of Security Incident Log for Month of July 1999 1999-09-09
[Table view] Category:OUTGOING CORRESPONDENCE
MONTHYEARML20217N5861999-10-22022 October 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7002/99-09 Issued on 990827 ML20217H6911999-10-19019 October 1999 Ack Receipt of 990928 Application to Revise Technical Safety Requirements 2.2.3.15 & 2.7.3.14.Initial Administrative Review Finds Application Acceptable.Completion of Review Is Anticipated by 991215 ML20217G4671999-10-14014 October 1999 Forwards Proprietary Insp Rept 70-7002/99-207 on 990920-23. No Violations Noted.Under Provisions of Section 2.790(d), Repts Containing Info Related to Licensee MC&A Program, Exempt from Public Disclosure ML20217G1731999-10-14014 October 1999 Requests Addl Info Re Applications Dtd 990924,requesting Amends to Cocs for Paducah & Portsmouth GDPs for Revised QA Programs.Encl Identifies Specific Info Needed.Info Should Be Provided within 30 Days ML20217F5481999-10-0808 October 1999 Discusses Insp Rept 70-7002/99-12 on 990810-0920 at Ports- Mouth Gaseous Diffusion Plant.No Cited Violations of NRC Requirements Were Identified During Insp ML20212G9401999-09-23023 September 1999 Responds to 990806 Reply to NOV in Ltr with Insp Rept 70-7002/99-04.Revised Reply Reviewed & Responses to Violations 1.B & 1.C Do Not Fully Address Needs as Clarified in 990715 Telcon.Resubmit Response within 30 Days of Ltr ML20211Q7761999-09-10010 September 1999 Forwards Insp Rept 70-7002/99-205 on 990816-20.No Violations Noted.Insp Consisted of Selective Exams of Computer Systems, Representative Records & Interviews with Personnel ML20211P2091999-09-0909 September 1999 Provides Staff Written Clarification of NRC Reporting Expectations of When Double Contingency Losses Should Be Reported to NRC IAW Bulletin 91-001, Reporting Loss of Criticality Safety Controls, & Suppl ML20211Q8041999-09-0808 September 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7002/99-05 ML20211P3831999-09-0303 September 1999 Forwards Coc GDP-1,amend 3 & Coc GDP-2,amend 4 for Paducah (Pgdp) & Portsmouth (Ports) Gdps,Respectively by Revising Pgdp & Ports QAPs in Vol 3 of Respective Certificate Applications ML20211L4871999-09-0101 September 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7002/99-07 Issued on 990709 ML20211K2081999-08-31031 August 1999 Discusses 990730 Revised Response to RAI Transmitted by NRC Re 990528 Response for Severity Level IV Violations Identified in Insp Rept 70-7002/99-06 ML20211H2741999-08-27027 August 1999 Forwards Insp Rept 70-7002/99-09 on 990629-0809 & Notice of Violations Re Involving Inadequate Corrective Actions of Concern,Due to Staff Failure to Take Actions to Prevent Recent Derailment ML20211G9891999-08-26026 August 1999 Informs That on 990812,NRC Completed three-day Licensing Review of Activities Associated with Usec 990526,certificate Amend Request (CAR) to Reopen Compliance Plan Issues 8,9 & 23 at Portsmouth Plant ML20211A7011999-08-17017 August 1999 Forwards Copy of Final Amend to 10CFR76 for Info of Subcommittee.Final Rule Is Being Transmitted to Fr for Publication.Final Rule Will Amend Regulations That Apply to Paducah & Portsmouth Gaseous Diffusion Plants ML20210P6981999-08-10010 August 1999 Forwards Insp Rept 70-7002/99-11 on 990719-23.No Violations Noted.Insp Consisted of Selective Exam of Procedures & Representative Records,Interviews with Personnel & Observations of Activities in Progress ML20211A7901999-08-0404 August 1999 Forwards Info Requested During Briefing by NRC Staff on 990726 Re NRC Interactions with Usec ML20210G0391999-07-26026 July 1999 Forwards Compliance Evaluation Rept & Fr Notice for Revised Qaps,Per 990212 Application ML20210D8181999-07-23023 July 1999 Submits Response to SA Toelle Ltr Dtd 990614, 10CFR76.68(a)(3) Decreased Effectiveness Reviews & RAI for Paducah & Portsmouth Transmittals of 1999 Annual Update to Certification Applications ML20210V3481999-07-16016 July 1999 Informs That Staff Completed Review of New Payment Surety Bonds (Psb) for Paducah & Portsmouth Gdps,Which Were Provided in .Cancelled Psbs for Liberty Mutual Insurance Co & Safeco Insurance Co of America,Encl ML20209G2501999-07-14014 July 1999 Forwards Copy of Compliance Evaluation Rept Prepared to Support Resolution & Closure of Violation in Insp Rept 70-7002/97-203,re Failure to Have Adequate Benchmarks in Validation Rept Analysis of Models of U Sys ML20209F1031999-07-12012 July 1999 Forwards Insp Rept 70-7002/99-204 Conducted on 990614-17.No Violations Noted.Major Areas Inspected:Mc&A Safeguards Program.Rept Details Withheld,Per 10CFR2.790 ML20209E8711999-07-0909 July 1999 Discusses Insp Rept 70-7002/99-08 on 990614-17 & Forwards Notice of Violation ML20209E8551999-07-0909 July 1999 Forwards Insp Rept 70-7002/99-07 on 990517-0629 & Nov. Violation of Concern Because Staff Displayed Lack of Rigor in Failing to Ensure That Nuclear Facility Criticality Safety Controls Were Implemented as Listed ML20209D4821999-07-0707 July 1999 Discusses Licensee 990702 Request That NRC Exercise Discretion Not to Enforce Compliance with Actions Required by Tsrs 2.2.3.2,2.4.3.1,2.5.3.1 & 2.7.3.2.NRC Concluded That NOED Warranted ML20209B7911999-07-0101 July 1999 Forwards Insp Rept 70-7002/99-203 Conducted on 990607-11.No Violations Noted ML20196H8421999-06-29029 June 1999 Discusses Insp Rept 70-7002/99-06 on 990322-26 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $55,000 ML20196F1121999-06-23023 June 1999 Responds to 990528 Response to NOV Submitted by with Insp Rept 70-7002/99-06.Response Not Fully Addressing Informational Needs in Notice.Response to Notice Requested to Be Resubmitted within 30 Days of Date of Ltr ML20207H5001999-06-11011 June 1999 Discusses Insp Rept 70-7002/99-05 on 990406-0515 & Forwards Notice of Violation Re Weakness in Staff Knowledge & Implementation of Plant Procedures in Several Program Areas ML20195J2001999-06-11011 June 1999 Ack Receipt of Certificate Amend Request Re Reopening of Compliance Plan Issues 8,9 & 23.Staff Has Completed Initial Administrative Review of Application & Anticipates Completing Review by 990831 ML20207G2641999-06-0808 June 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7002/99-03 Sent on 990528.Reviewed Corrective Actions & Have No Futher Questions.Actions Will Be Examined During Future Insp ML20207F2571999-06-0202 June 1999 Informs That NRC Disagrees with Usec Conclusion for Not re-opening Issue 2 of Compliance Plan,Since Proposed Change to Sarup Submittal Constitutes Major Rev to Operating Safety Bases Contained in Technical Safety Requirements ML20207A0121999-05-21021 May 1999 Forwards Insp Rept 70-7002/99-04 on 990222-0312 & Notice of Violations Re Inadequate Knowledge & Understanding by Some Staff & Mgt of Corrective Action ML20207E5421999-05-18018 May 1999 Discusses Apparent Violation Involving Usec & Lockheed Martin Utility Svcs,Inc.(Lmus) Mgt Discriminating Against Lmus Employee at Paducah Gaseous Diffusion Plant. Violation Being Considered for Escalated Ea.W/O Encl 2 ML20206S3091999-05-17017 May 1999 Confirms Meeting Scheduled for 990610 in Lisle,Il to Discuss Failure to Classify Emergency Conditon as Alert IAW Portsmouth EP ML20206N3851999-05-12012 May 1999 Forwards Amend 1 to Coc GDP-1 & Amend 3 to Coc GDP-2 IAW 990316 Applications,Revising Paducah & Portsmouth Gaseous Diffusion Plants Technical Safety Requirement Sections 3.1.1 & 3.10.4 ML20206H5601999-05-0606 May 1999 Ack Receipt of Responding to Notice of Violation Noted During Insp 70-7002/99-202 of 990319.Corrective Actions Acceptable,Per 10CFR2.201 ML20206E9761999-05-0303 May 1999 Forwards Amend 2 to Coc GDP-2,reducing Ports Fundamental Nuclear Matl Control Plan Requirements Re Min Number of UF6 Cylinder Receipts from Russia ML20206E3781999-04-29029 April 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7002/99-01.Actions Will Be Examined During Future Insp ML20206E4281999-04-29029 April 1999 Forwards Insp Rept 70-7002/99-03 on 990222-0406 & NOV Re Failure to Understand & Implement Personnel Safety Controls During Maint Evolution ML20206B5611999-04-22022 April 1999 Forwards Insp Rept 70-7002/99-06 on 990322-26 & Nov.One Violation Identified Involving Failure of Plant Shift Superintendent,Acting as Incident Commander for Er to Fire on 981209,to Classify Emergency Condition as Alert ML20205K4251999-04-0707 April 1999 Forwards Compliance Evaluation Rept for GDP-1 & GDP-2, Supporting Change in Title of Executive Vice President, Operations.Notice of Amend,Which Has Been Forwarded to Ofc of Fr for Publication,Encl ML20205J2051999-04-0606 April 1999 Forwards Amend 1 to Coc GDP-2,revising Issue A.2 of Portsmouth Gaseous Diffusion Plant Compliance Plan.Condition 8 Revised to Include Date of 981228 ML20205F6721999-03-31031 March 1999 Forwards Proprietary Copy of Compliance Evaluation Rept Prepared to Support Amend of Coc GDP-2.Notice of Amend,Which Has Been Forwarded to Ofc of Fr for Publication,Also Encl. Proprietary Encls Withheld ML20196K3981999-03-19019 March 1999 Forwards Insp Rept 70-7002/99-202 Conducted on 990222-26. Violation Noted.Major Areas Inspected:Mc&A Safeguards Program.Rept Details Withheld,Per 10CFR2.790(d) ML20204H9611999-03-18018 March 1999 Forwards RAI Re 990212 Applications Requesting Amends to Coc for Paducah & Portsmouth Gaseous Diffusion Plants for Revised QAPs ML20204D7991999-03-17017 March 1999 Discusses Insp Rept 70-7002/99-01 on 990112-0222 & Forwards Notice of Violation.Violation Identified Involved Licensee Staff Returning Sys to Svc Following Safety Actuations Without Appropriately Documenting Safety Actuations ML20204E2341999-03-17017 March 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7002/98-18 .Reviewed C/As & Have No Further Questions.C/As Will Be Examined During Future Insps ML20207G4991999-03-0505 March 1999 Discusses Rescheduling of 1999 Portsmouth Emergency Preparedness Exercise to 990914.Date Change Acceptable to Local Officials ML20207B3361999-03-0202 March 1999 Ack Receipt of 990212 Applications for Amend to Cocs GDP-1 & GDP-2.Staff Has Completed Initial Administrative Rev of Applications & No Omissions of Deficiencies Were Identified. Staff Anticipates Completing Review by 990416 1999-09-09
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1
. l March 18, 1997 1 Mr. James H. Miller Vice President, Production l U. S. Enrichment Corporation 2 Democracy Center 6903 Rockledge Drive Bethesda, MD 20817
SUBJECT:
CERTIFICATE AMENDMENT REQUEST - PORTSMOUTH GASEOUS DIFFUSION PLANT ADMINISTRATIVE CONTROLS ON OVERTIME (TAC NO. L32010)
Dear Mr. Miller:
Enclosed is a copy of the Compliance Evaluation Report prepared to support the amendment of Certificate of Compliance GDP-2. A copy of the Notice of Amendment, which has been forwarded to the Office of the Federal Register for publication, is also l
enclosed. This notice provides the upportunity for the public to petition for review of the l decision in accordance with 10 CFR Part 76, Subpart C. Final action on your amendment 1
request will not be taken until after the time allowed for requesting review of the Director's Decision is over. If you have any questions regarding this action, I can be l 1
reached at (301) 415-8113. l l
Sincerely, r+fns1 Signed By ;
Yawar H. Faraz, Project Manager f Enrichment Section '
Special Projects Branch Division of Fuel Cycle Safety and Safeguards, NMSS Docket 70-7002 Certificate GDP-2
Enclosures:
- 1. Compliance Evaluation Report NRC FILE CENTER COPY
- 2. Notice of Amendment OfSTRIBUTION- (Control No. OSOS)
Docket 70-7002 NRC File Center PUBLIC KO'Brien. Riti CCox Alli NMSS r/f FCSSr/f WSchwink. FCOB SPB r/f OGC GShear. All! MHom TWenck OAOTLTRI.YHF OFC SPB b SPS h- SPB g SPB NAME YFara cadley rson DATE J d/97 ) /97 7 )/ 7 / 19 7 I /97 C = CO /ER N = 90 COPi
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E = COVER & ENCLOSURE OFFICIAL RECORD COPY 9703200276 970318 PDR ADOCK 07007002 C PDR
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g"e . -- UNITED STATES
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j NUCLEAR REGULATORY COMMISSION WASHINGTON. D.C. 20655-0001 0
.... 9 DOCKET: 70-7002 l '
CERTIFICATE HOLDER: United States Enrichment Corporation l l
Portsmouth Gaseous Diffusion Plant !
Portsmouth, Ohio i
l
SUBJECT:
COMPLIANCE EVALUATION REPORT: APPLICATION DATED DECEMBER 23,1996, ADMINISTRATIVE CONTROLS ON OVERTIME BACKGROUND On December 23,1996, United States Enrichment Corporation (USEC) submitted a request to revise the Portsmouth Gaseous Diffusion Plant (PORTS) administrative controls on overtime specified in Technical Safety Requirement (TSR) 3.2.2.b.2. The amendment reduces two limits on working hours for facility staff who perform safety functions. The amendment is in accordance with a commitment made in issue 37 of the Compliance Plan (DOE /ORO-2027 Revision 3, Plan for Achieving Compliance with NRC Regulation at the Portsmouth Gaseous Diffusion Plant), which was part of the USEC certificate application.
The Plan of Action of issue 37 states, "USEC will supplement current staffing allocations ]
i to meet its proposed working hour guidelines that state that an individual should not be permitted to work more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period and no more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7 day period exclusive of shift turnover time. In addition, USEC will submit a revised TSR to the NRC to add these guidelines to TSR 3.2.2.b at the time sufficient staffing is achieved to meet these guidelines. Sufficient staffing will be achieved and the revised TSR submitted to the NRC by December 31,1996."
TSR 3.2.2.b.2 in the USEC certificate application states:
"An individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, nor more than 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> in any 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period, nor more than 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> in any 7 day period, all excluding shift turnover time._
USEC has proposed to revise TSR 3.2.2.b.2 to state:
i "An individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period, nor more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7 day period, all excluding shift turnover time."
DISCUSSION Administrative TSR 3.2.2.blimits working hours of facility staff who perform safety functions (operators, health physics personnel, maintenance personnel, etc.). The proposed change reduces the currently authorized limits, of 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> in any 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period
2 and 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> in any 7 day period, to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period and 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7 day perMd, respectively. The staff has determined that these two 8-hour reductions in overtime limits will not adversely affect safety, in fact,it may have a positive effect on safety by reducing occupational stresses and burdens on facility staff who perform safety functions.
UF6 Unconfinement and Criticality The staff has determined that the amendment will not significantly increase the risk of UF6 unconfinement or criticality accidents. On the contrary, the amendment would likely decrease such risks. The reason for this conclusion is that PORTS relies on certain facility staff to perform safety functions for preventing and/or mitigating several criticality and UF6 unconfinement accident scenarios which are analyzed in the Safety Analysis Report (SAR) and determined to be credible. Implementation of the revised overtime controls would apply to such personnel and would likely minimize any adverse effects of excessive work hours.
Occuoational Radiation Exoosure Occupational radiation exposures at PORTS are generally low. Some of the reasons being that (1) occupancy factors are low, (2) distances from radioactive sources are generally high, (3) significant shielding is provided by solid and liquid UF6 (self-shielding) and by piping and equipment, (4) depleted and low enriched uranium has low specific activities and are also comparatively low gamma radiation emitters, (5) most of the uranium in process is in gaseous form (low density), (6) UF6 is confined within quality controlled cylinders, equipment and piping and (7) compliance with the 10 milligram per week soluble uranium intake limit based on its toxicity ensures that the inhalation radiological doses for depleted and low-enriched soluble uranium are small. The proposed reductions in overtime limits would not significantly affect any of these above mentioned seven reasons.
Therefore, reducing overtime limits, will not significantly increase individual or cumulative occupational radiation exposures.
Safeouards and Security The staf f has not identified any safeguards or security related implications from the proposed amendment.
ENVIRONMENTAL REVIEW issuance of the requested amendment to the Portsmouth Certificate of Compliance (GDP-2) to amend the administrative limits on overtime,is subject to the categorical exclusion provided in 10 CFR 51.22(c)(19)and will not have a significant impact on the human environment. Therefore, in accordance with 10 CFR 51.22(b), neither an environmental assessment nor an environmentalimpact statement is required for the proposed action.
CONCLUSION Based on the irformation provided in this CER, the NRC staff approves and grants this amendment. Region ill staff have no objection to this proposed action.
Princioal Contributor (s)
Yawar Faraz