ML20137A304

Forwards Compliance Evaluation Rept Prepared to Support Amend of Coc GDP-2.Notice of Amend,Forwarded to Ofc of Fr for Publication Encl Also

ML20137A304
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant
Issue date:	03/18/1997
From:	Yawar Faraz NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	John Miller UNITED STATES ENRICHMENT CORP. (USEC)
Shared Package
ML20137A308	List: ML20137A304 ML20137A333
References
TAC-L32010, NUDOCS 9703200276
Download: ML20137A304 (3)

Text

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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

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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