ML20133C518

Provides Addl Info Re Explanation as to Why Delay in Ncsa/E Project Was Unavoidable,Assurance That Level of Mgt Attention to Issue Is Adequate & Assurance That Requested Dates Will Be Met,Per Request

ML20133C518
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant
Issue date:	12/23/1996
From:	John Miller UNITED STATES ENRICHMENT CORP. (USEC)
To:	Ten Eyck E NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
GDP-96-0205, GDP-96-205, NUDOCS 9701070207
Download: ML20133C518 (6)

Text

.-.

-~

-~

United Stat:s Enrichment Corpor; tion

~ 2 Democracy Center L.,,.

6903 Rockledge Drive Bethesda, MD 20817 Tel: (301)S64-3200 Fax:(301) 564-3201 JAMES H. MU.ER Dir- (301) 564-3309 VICE PRESIDENT, PRODUCTION Fax- (301) 571-8279 December 23,1996 Ms. Elizabeth Q. Ten Eyck SERIAL: GDP 96-0205 Director, Division of Fuel Cycle Safety and Safeguards Attention: Document Control Desk U.S. Nuclear Regulatory Ccmmission Washington, D.C. 20555-0001 Portsmouth Gaseous Diffusion Plant (PORTS)

Docket No. 70-7002 Certificate Amendment Request - Supplemental Information - Changes to Compliance Plan Due Dates for NCS Related issues

Dear Ms. Ten Eyck:

USEC letter dated October 31,1996 (GDP 96-0190), submitted a Certificate Amendment Request (CAR) to several completion dates specified in DOE /ORO-2027, Plan for Achieving Compliance with NRC Regulation at the Portsmouth Gaseous Diffusion Plant, regarding the completion and implementation of Nuclear Criticality Safety Approvals (Issues 8,9,23,24,30, and 32). Specifically, this CAR proposed that the completion date for the Nuclear Criticality Safety Approvals / Evaluations (NCSAs/Es) be extended from November 30,1996 to January 31,1997, and the completion dates for associated NCS activities be extended to February 28,1997. NRC letter to USEC dated December 10, 1996 submitted a request for additional information concerning this CAR. The purpose of this letter is to provide the additional information you requested.

}f l Your letter requested that USEC provide information regarding the following: (1) an explanation as

[

to why the delay in the NCSA/E project was unavoidable; (2) assurance that the level of management's ll l

attention to this issue is adequate; and (3) assurance that the requested dates will be met.

The NCSA/E project represents a significant increase in the quality of the NCS documentation with specific concentration on establishing and implementing defined double contingency protection. In order to achieve this level of quality and rigor, significant changes have been necessary in the NCSA/E 9701070207 961223 l#

$d PDR ADOCK 0700 0 L q g g 7 e g '3 5 7

~

N QQc: j,g Offices in Uvermore, Califomia Paducah, Kentucky Portsmouth, ohio Washington, DC l

3 Ms. Elizabeth Q. Ten Eyck December 23,1996 GDP 96-0205 Page 2 l

~ development and approval process, the management of the project, and especially in the associated facility operations. These changes caused project delays that resulted in our request to extend the project

_ completion dates. For example, NCSA writers, many of whom were initially subcontractors, had difficulty determining the proper balance between administrative and engineering controls that would satisfy the ever increasing level of quality and rigor demanded by management, while at the same time not significantly impeding plant operations. The time required to attain the knowledge and experience

]

necessary to accomplish this balancing effort took longer than originally anticipated. Significant changes.

in administrative controls and plant modifications were, in some cases, ultimately determined to be j

i necessary which caused further delays in the NCSA/E approval process. Other factors that contributed to the delay included fragmented responsibility between various organizations during the earlier NCSA/E development period; the level of effort required to develop a single NCSA/E document was j

underestimated; and management's expectations regarding the content in the final products evolved and significantly increased over time. Furthermore given the complexity of the project, the impact of these l

I

. problems on the schedule was not recognized as soon as it should have been, thereby delaying our request to amend our commitment dates. In hindsight, many of these problems could have been foreseen, and therefore possibly avoided. However, some of these impediments were unavoidable, e.g., the facility

.]

administrative control changes and plant modifications mandated by the new NCSAs/Es.

I

I Many of the problems noted above have been corrected by an increase in the level of knowledge and experience of the NCSA/E writers. To correct other' problems we have discontinued the use of poor performing subcontractors, reduced overall reliance on subcontractors to develop the NCSAs/Es, and j

,i assigned increased NCSA/E development responsibility to plant staff. Additionally, plant management, through the Plant Operations Review Committee (PORC), established protocols for the content of the NCSAs/Es. These efforts have dramatically increased the quality of the NCSA/E documents as well as increased the efficiency of the review and approval process.

As the scope and complexity of the NCSA/E project intensified, so too did the level of management's attention. In May/ June 1996, a highly experienced " coach" was assigned to the Criticality Safety Manager to manage the NCSA project exclusively. In August 1996, in recognition that the NCSA/E i

project was larger and more complex than originally anticipated, management began to conduct twice-weekly senior manager briefings regarding the project to remove impending barriers, many of which are discussed above. In October 1996, management realized that the original completion dates in the Compliance Plan for the NCSA/E project could not realistically be met and our October 31,1996 amendment request was submitted. Based on these changes, the level and quality of management attention is in place to ensure that this project is completed satisfactorily.

3 Our current schedule for completing the NCSA/E project addresses the development and approval 4

of the NCSA/E documents as well as the implementation of activities to ensure that proper flowdown of i

the associated NCS controls. The following information is pmvided regarding our current schedule and i

progress to date.

l

+

Ms. Elizabeth Q. Ten Eyck December 23,1996 GDP 96-0205 Page 3

1. NCSA/E development and aporoval (Issues 8 and 9): The total number of MCSA/E documents identified in the scope of this project is 180. To date, 51 are active (i.e., field implemented) and an additional 115 are PORC approved. Only 14 NCSAs/Es remain to be approved by the PORC. These 14 documents have been developed and are either in the peer review, multi-discipline review or the PORC review stages. Based on our current forecast, all NCSAs/Es will be approved by December 31,1996.

The extension date in our amendment request is January 31,1997 for this part of the project. The month of January is built into our schedule to allow for unforeseen technical issues and any required revisions to the NCSAs/Es resulting from self-assessments, field walk-downs, or additional operations feedback.

2. Identification of AO-NCS systems. structures. and components (SSCs)(Issue 23): Of the 180 NCSAs/Es within the project,160 have been reviewed by the Configuration Management group for identification of AQ-NCS SSCs. Our current schedule for completion of this review is January 3,1997 (three days after approval of the last NCSA/E). This activity is part ofIssue 23, and the requested completion date for all of the Configuration Management actions in this area is February 28,1997.

However, because several" downstream" activities in the flowdown sequence are dependent on this step, this action is being tracked separately by our management from the remaining Issue 23 actions. The remaining actions under Issue 23 are discussed in item 8 below.

3. Identification of maintenance nrocedure requirements (Issues 9 and 24): The SSCs identified as AQ-NCS by Configuration Management are forwarded to Maintenance.

Maintenance uses this information to identify required maintenance procedure changes. To date, Maintenance has identified the need for ten (10) procedures that need to be developed or revised based on the 160 NCSAs/Es reviewed by Configuration Management. These requests for procedure changes are forwarded to the Procedures Group. The scheduled completion date for the identification of required procedure changes is January 7,1997, two working days after the scheduled completion for item 2 above. The extension date in our amendment request for the identification of required maintenance procedure changes is January 31,1997. As discussed above, the time between our current internal schedule and the extension date is to account for unforeseen issues and self-assessment activities which may identify the need for additional procedure changes.

4. Identification of nrocedure changes for NCS controls (Issues 9 and 30): To date, Operations and Procedures have identified the need for 205 new or revised operations procedures resulting from NCSAs/Es, of which 129 are completed. As discussed abc,ve, Maintenance has identified ten (10) procedure changes, none of which are complete. Based on our current procedure work-off rate and estimating a number of additional procedure changes from the remaining unapproved NCSAs/Es, our internal completion schedule for completing these procedure changes is approximately January 15,1997 for the cascade facilities and February 20 for the remaining facilities (primarily the X-705). The extension date in our amendment request is February 28,1997.

5. Imnlementation ofinfrastructure procedure changes (Issues 9. 24. 30. and 32): The administrative procedures required for the NCS program are completed. Seven additional procedures that flowdown AQ-NCS requirements from the Quality Assurance Program are scheduled to be completed by December l

l l

l

(-

,e i

I L

Ms. Elizabeth Q. Ten Eyck l

December 23,1996 GDP 96-0205 Page 4 31,1996. The remaining infrastructure procedures required to implement NCS controls for AQ-NCS SSCs (e.g., configuration management for safety system maintenance and testing, setpoint calibration, etc.) are under development and are scheduled to be completed by February 28,1997, the extension date -

l l

in our amendment request.

6. Training of operations and maintenance nersonnel (Issues 24 and 32k Training has determined that 25 new or revised modules are necessary to implement the required NCS training. Ten (10) of these l

modules are approved. The remaining modules will be completed by approximately January 15,1997.

L The current estimate of site personnel required to receive some or all of this training is 720, of which 311 -

l have been trained to date. Cascade and X-340 complex operations and maintenance personnel (approximately 500 workers) are scheduled to complete their NCS training by January 3,1997. It is anticipated that all remaining NCS training will be completed by February 28,1997, the date requested in our extension letter.

7. Identification and scheduline of NCS driven surveillance and calibration reauirements (Issue 9h A site-wide procedure has been developed to address the tracking and scheduling of TSR and other safety system surveillances. Surveillances required by NCSAs/Es with a periodicity of one month or greater will be tracked under this program. More frequent NCS related tests will be implemented through plant procedures (such as rounds) or work packages. To date, 34 surveillances have been identified from L

NCSAs/Es. Surveillance and calibration requirements for AQ-NCS SSCs that are identified in l

NCS As/Es will be current by February 28,1997, the date requested in our extension letter.-

8. Incorooration of AO-NCS items into Confieration Management prouram (Issue 23t Engineering l

l has identified the activities necessary to implement AQ-NCS SSCs into the Configuration Management l

program for the 160 NCSAs/Es reviewed to date. In addition to item 2 above, these activities include:

developing boundary definitions for each AQ-NCS SSC (65 are completed ' scheduled completion date January 31,1997); creating or updating drawings to depict AQ-NCS SSC boundaries (40 drawings identified, changes ongoing - scheduled completion date February 15,1997); developing procurement specifications (86 identified as needed - scheduled completion date is February 15,1997); establishing stores stock as needed (scheduled completion date is February 28,1997); calculating setpoints for AQ-NCS instrumentation (scheduled completion date is consistent with the corresponding procedure L

development schedule); issuing boundary definitions to the plant (scheduled completion date is February 28,1997).

9. Verification of above-listed flowdown areas (Issue 91 Our program provides for review of

- NCSAs/Es in order to identify and track the designated NCS conditions, specifications, and controls and to verify their full implementation. Our current scheduled date for the verification is Febmary 28,1997, the same date as the extension date in our amendment request.

l In summary, the delays in the NCSA/E project were caused in large part by impediments, such as i

determining the appropriate controls to meet management's rising expectations and unforeseen facility l

changes, as well as inadequate initial attempts to remove the impediments. Many of these problems m-m

J Ms. Elizabeth Q. Ten Eyck i

December 23,1996 GDP 96-0205 Page 5 -

could have been avoided had we foreseen the complexity and scope of the project. However, based on the steps taken to correct these problems, the progress noted to date, and the level and quality of the in-l place management team currently overseeing this project, we fully anticipate that the NCSA/E program will be implemented by February 28,1997.

Based on your December 18,1996 letter regarding changes to Compliance Plan dates prior to March f

3,1997, we intend to implement the completion date revisions requested in our October 31,1996 letter.

Any questions related to this subject should be directed to Mr. Robert L. Woolley, USEC's Manager of Nuclear Regulatory Assurance and Policy, at (301) 564-3413.

t Sincerely, s H. Miller i

ce President, Production t

cc: NRC Region III Office NRC Resident Inspector - PGDP NRC Resident Inspector - PORTS DOE Regulatory Oversight Manager

i i

OATH AND AFFIRMATION I, James H. Miller, swear and aflirm that I am Vice President, Production, of the United States Enrichment Corporation (USEC), that I am authorized by USEC to sign and file with the.

Nuclear Regulatory Commission this Certificate Amendment Request for the Portsmouth Gaseous Diffusion Plant, that I am familiar with the contents thereof, and that the statements made and l

matters set forth therein are true and correct to the best of my knowledge, information, and belief.

j I

~

James H er Subscribed to before me on this hday of 996.

_)

Notary Public t

g.

. ~ 7. / TK TN'i, E. KE3.

C

. c,,;rpj,Nn l

~

,;.j C.......:.a 2, x i : a tA*19/I f

l l

i