ML20141M147

Staff Requirements Memo Re Commission Approval of Restart of Ga Sequoyah Fuels Facility

ML20141M147
Person / Time
Issue date:	03/27/1992
From:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
To:	Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
References
REF-10CFR9.7 M920317A, NUDOCS 9204020020
Download: ML20141M147 (3)

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IN RESPONSE, PLEASE REFER TO:

M920317A OFFICE OF THE March 27, 1952 SECRETARY MEMORANDUM FOR:

James M.

Taylor Executive Director for Ope"ations FROM:

Samuel J.

Chilk, Secret

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SUBJECT:

STAFF REQUIREMENTS - BRKE NG ON STATUS OF RESTART OF GENERAL ATOfflC ' SEQUOYAH FUELS FACILITY, 8:30 A.M.,

TUESDA1, MARCH 17, 1992, COMMISSIONERS' CONFERENCE ROOM, ONE WHITE FLINT NORTH, ROCKVILLE, MARYLAND (OPEN TO PUBLIC ATTENDANCE) e The Commission was briefed by the NRC staff, the licensee, and petitioners (Native Americans for a Clean Environment and the Cherokee Nation of Oklahoma) on the status of restart or the licensee's facility in Gore, Oklahoma.

The issues which were discussed fall into two categories: a.) solutions to problems identified in the October 3, 1991 order which therefore are preconditions to restart and b.) gaps in the current license which should be remealed, but not as a prccondition to restart.

Based on the discussions at that meeting the Commission directs g

the staff to undertake the following:

1.

When and if the staff is prepared to permit restart, taking into account the results of the OI investigation, a memo should be sent to the Commission before restart is permitted.

T ds memorandum should announce the staf f's intentions and the rationale behind them.

T;te staf f should consult with the solicitor about incorporating into any restart decision a " housekeeping" stay of up to eight business days.

2.

To deal with some of the concerns expressed about the depth of understanding and committant to changes emplaced at SFC, the staff should consider approving a phased start-up of the facility, rather than moving directly to full process operation.

This start-up could be based on appropriate hold points, at which the staff would observe and evaluate performance of the management and work force in terms of compliance with procedures, adequacy of training, and management awareness of overall operations.

Once the staffs finds performance at a given level of operation cc be 9204020020 920327 0.

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acceptable, approval'could be granted to move to' operation atethe next level.

SFC1has identified.the DUF4 facility as such a; hold point in its March 20, 1992 letter.

The staff Eshould explore the feasibility and advirability of this and other possibic hold points with the licensee,

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-3.

To ensure that past commitments and lessons learned have not been overlooked, the staff should:

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Beginning with the 1986 incident at Gore, examine its own reports and studies as-Hell as those conducted by theilicensee, for recommendations and lessons learned that were identified in those reports and studies;

11. Identify'tnose recoumendations or lessons uhich are important but have not been implemented, i ncluding any additional commitmente made by the licensee at the March 17 briefing (such as thone relating to quality assurance, training, etc.;; and 111. Obtain from the licensee written assurances and schedules for implementation of those recommendatjons or lessons which are important out have not been implemented. The staf f should also establish a

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mechanism for tracking such commitments.

These steps, insofar as feasible, should be completed prior to restart.

If, in evaluating.the agency's follow thrcagh on the lessons-learned from the 1986 event, the staff tidentifies issues of concern that Were overlooked at the n

L time, theLstaff should bring such issues to the Commission's attention.

l4.

The staff should pay particular attention to': (1) the development and' full implementation of a-formal internal

' quality assurance program; and (2) theEposition of a i dedicated _ full-time QA manager-within-the SFC organizational structure.

The reliance _on augmented oversight for quality assuranca by General Atomics is acknowledged to be-an interim measure'while the-internal program' matures.. Staff should ensare'that effective external and interna'l programs emerge.

This is not a precondition to restart.

Si The' staff should communicate with EPA prior to any; decision onLrestart and-should also inform the Commission of its past and present-interactions with-EPA-and OSHA regarding'SFC, including consideration of a joint inspection.

If appropriate.and feasible, such consideration should include a joint-inspectica prior to restart.

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6.

Theirole of.the Plant Operations Review Committee (PORC) needs elaboration.

What will its role be in the future?

If it has a role, what is-needed to assure it is effective?

7.a. The staff should ensure that the licensee's commitments-for monitoring ~and remediating environmental conditions made at

-the' March 17, 1992 meeting as well as appropriate requirements for r'eporti:,9 the results of such monitoring are included in the license.

b. The staff, in connection with its review of the license renewal application, should expedite completion of the environmental assessment.

'These requirements are not preconditions for.ustart.

8.-

In the paragraphs marked. "(1)" and "(2)" in its March 19, 1992 letter to the Commission, General-Atomics has made certain; financial-commitments regarding cleanup of the Gore site.,The staff-should make these commitments legally b.nding on General Atomics if it is practicable and udvisable to do so.

This is not a precondition to restart.

9.

Finally, with respect to restart issues, the staff should instruct-the licensee ts continue to make available to the petitioners documents sent

.o the NRC on the same schedule that we receive them..

10.

The actions.in. Items 3-9 above are without' prejudice to any.

matter in'the.pending license renewal proceeding.

They are included here to address any possible concerns about' potential effects of; operations, in the event restart is authorized.

cc: The Chairman.

' Commissioner Rogers Commissioner Curtiss

.-Commissioner Remick A

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. Commissioner.de Plangue-OGC.

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