ML20155J000
| ML20155J000 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant, Paducah Gaseous Diffusion Plant |
| Issue date: | 11/05/1998 |
| From: | Toelle S UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Pierson R NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| GDP-98-0237, GDP-98-237, NUDOCS 9811100382 | |
| Download: ML20155J000 (4) | |
Text
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USEC A ciod.:4.rsy comp.ny November 5,1998 1
GDP 98-0237 Mr. Robert C. Pierson Chief. Special Projects Branch Office of Nuclear Material Safety and Safeguards Attention: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Paducah Gaseous Diffusion Plant (PGDP)
Portsmouth Gaseous Diffusion Plant (PORTS)
Docket Nos. 70-7001 & 70-7002 Proposed Criteria for Reopening Compliance Plan Issues
Dear Mr. Pierson:
On October 15,1998, a meeting was held between the Nuclear Regulatory Commission (NRC) and the United States Enrichment Corporation (USEC) to discuss the closure of Compliance Plan issues.
At this meeting, NRC requested that USEC develop criteria to determine when a completed Compliance Plan issue should be reoper.ed. Accordingly, the following information is being provided for NRC consideration: contains criteria that USEC proposes to use to determine whether the completion of a Compliance Plan action was deficient and warrants further action. This enclosure also describes the process by which USEC would voluntarily notify NRC of the deficiency when it would not otherwise meet the criteria for reportability. is proposed criteria which could be used to determine if an improperly completed Compliance Plan Issue should be considered for reopening.
The assessment and actions described in Enclosures 1 and 2 would be in addition to actions USEC has already been taking to respond to noncompliances in accordance with existing NRC requirements and guidance.
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i 9811100302 981105 7 PDR ADOCK 070070011 C
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b y'[.$'~'IL 6903 Rockledge Drive. Bethesda, MD 20817-1818 4
Telephone 301-564-3200 Fax 301-564-3201 http://www.ur,ec.com OfDces in Livermore, CA Paducah, KY Portsmouth, OH Tchington, DC L
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Dr. Carl J. Paperiello
. November 5,1998 L
dDP 98'-0237, Page 2 l
USEC is prepared to discuss the enclosed criteria with NRC at your earliest convenience. Any questions regarding this matter should be directed to me at (301) 564-3250, There are no new l
' commitments contained in this submittal.
Sincerely, A
.s.A.
I Steven A.Toelle Nuclear Regulatory Assurance and Policy Manager
Enclosures:
(as stated)
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NRC Project Managers - PGDP and PORTS l
NRC Region III Office NRC Resident Inspector - PORTS NRC Resident Inspector - PGDP l
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GDP 98-0237 Page1of1 Pronosed Criteria for Determining if a Completed Compliance Plan (CP) Action is Deficient
-USEC proposes that the completion of a CP action be considered deficient ifit meets the following criteria:
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'l.
The completion evidence for the CP action does not demonstrate that the issue or action was completed by the required due date (i.e., the issue or action was completed after the due date, L
or the issue or action was never completed); or, L
2.
' Problem Reports (prs), Assessment and Tracking Reports (ATRs), or other indicators (e.g.,
self-assessments) indicate that deficiencies (other than minor isolated deficiencies) exist in the completeness of actions stated in the CP Plan of Action and Schedule (POAS).
. Ifit is determined that a completed CP action is deficient, a PR or ATR will be written documenting l.
the deficiency, if one does not already exist. The deficiency will be evaluated for operability, in l
accordance with the guidance in NRC Gene:ic Letter 91-18, Rev.1, and reportability. If the t
deficiency does not meet the criteria for reportability as described in Section 6.9 of the Safety Analysis Report (SAR), then the Nuclear Regulatory Affairs (NRA) Manager at the affected site (s) will verbally inform the NRC Resident Inspector of the deficiency and keep the Resident Inspector informed of actions being taken to resolve the deficiency.
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GDP 98-0237 l
Page1of1
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~ Pronosed Criteria for Re-coening a CP Issue Following the determination that the completion of a CP action is deficient, an evaluation will be l
performed to determine if the affected CP issue should be reopened using the following criteria:
l.
The time to complete any necessary corrective actions to resolve the deficiency will exceed L
nine (9) months from the date of the evaluation; and, t
l 2.
The deficient CP action is related to a Q or AQ-NCS structure, system, or component; and,
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3.
The non-compliant condition addressed by the deficient action has not been corrected by some other action (e.g., if the SAR or TSR had been revised such that the deficient CP action does not result in a non-compliant condition, then the affected CP issue would not have to l
be reopened).
Unless otherwise directed by the NRC, if USEC determines that an imptoperly completed CP issue l
satisfies all of the above proposed criteria, a Certificate Amendment Request would be submitted
- to NRC to revise the affected CP POAS and, if necessary, the Justification for Continued Operation.
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