ML20195E143

Describes Progress to Date in Completing Tasks Re Nuclear Criticality Safety Corrective Action Program & Provides Revised Schedule

ML20195E143
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant
Issue date:	11/13/1998
From:	Toelle S UNITED STATES ENRICHMENT CORP. (USEC)
To:	Caniano R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
GDP-98-0255, GDP-98-255, NUDOCS 9811180251
Download: ML20195E143 (8)

Text

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USEC

. A Global Energy Company November 13,1998 GDP 98-0255 Mr. Roy J. Omiano, Acting Director Division of MW Material Safety U. S. Nuclear Regulatory Commission Region 111 801 Warrenville Road Lisle, Illinois 60532-4351 i

Portsmouth Gaseous Diffusion Plant (PORTS)

- Docket No. 70-7002 Portsmouth Nuclear Criticality Safety (NCS) Corrective Action Program (CAP) Revised Schedule

Dear Mr. Caniano:

On October 30,1998, the United States Enrichment Corporation (USEC) submitted to the United States Nuclear Regulatory Commission (NRC) the quarterly status report for the PORTS NCS CAP (reference USEC letter GDP 98-0236). In this letter, USEC informed the NRC that USEC would be unable to meet the current target dates for Task 3, "NCSA/Es Upgrade Project," and for Task 5, "SS&Q Review of Implementation," since completion of this task is dependent upon Task 3.

Additionally, USEC stated that the revision to the completion dates for these tasks would be provided in separate correspondence to NRC by November 13,1998. Accordingly, the purpose of this letter is to describe the progress to date in completing these tasks, and to provide the revised schedule for these tasks and the reasons for the change.

Progress to date in completing Task 3 demonstrates that the extension of the schedule for this task, and consequently Task 5 (see Enclosure 1), will not result in any adverse impact to safe plant operations as evidenced by the following:

All Priority 1 NCSA/Es are either in or have completed the NCS team review process.

These reviews have not identified any significant safety deficiencies in the NCSA/Es.

Although some relatively minor deficiencies were identified and corrected, these reviews demonstrate that the current NCSAs are adequate with respect to safety. These reviews, plus p

peer review and review by the NCS subconunittee to the PORC, are expected to be 1

completed by December 31,1998. The focus of Task 3 is on improving the ease of implementing the NCSA/Es (e.g., simplified NCS controls), and thereby making it easier for the operating staff to ensure compliance with the NCSAs.

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Mr. Roy J. Caniano November 13,1998 l

GDP 98-0255, Page 2 l

The review of NCSA/Es was prioritized so that problem areas were identified and corrected i

first. Initially, USEC analyzed the event report data to determine which NCSAs were l

causing the majority of the noncompliances. Those NCSAs were revised with significant l

changes in these controls.

Plant personnel are more focused on compliance with existing NCSAs. As a result, self-assessment programs have been enhanced and line ownership of NCS has increased.

Additionally, training has been improved, and physical changes (e.g., reducing the amount

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of waste being stored in the process buildings) have been completed. The effectiveness of these actions is demonstrated by the dramatically reduced number of NCS Events (see ).

The SS&Q review ofimplemented NCSA/Es (i.e., Task 5) has shown no implementation problems.

In late August 1998, PORTS assigned two senior managers to oversee the actions of the NCS CAP team. This effort led to performance improvements as indicated in Enclosures 3 and 4. However, during the past year, two activities requiring significant additional resources have emerged which have resulted in the need to extend the completion date for Task 3 and, consequently, Task 5 as described below:

In reviewing the results of the Priority 1 NCSA upgrades, USEC determined that required procedure flow-down and implementation deficiencies were the primary contributor to past NCSA noncompliances rather than deficiencies in the NCSA/Es themselves. Although procedure flow-down had been performed, sufficient details were not placed in the action steps of procedures. The effort to improve the details in procedure action steps, after each NCSA/E has completed the upgrade process, and to complete the procedure review, validation and approval process, requires about eight to ten weeks. An additional three to four weeks is also required for training. Although our original schedule estimates included time for procedure revisions, the magnitude of this effort was not realized until recently.

In response to NRC Notice of Violation 98-206-02 (reference USEC letter GDP 98-2027, dated June 30,1998), USEC committed that, concurrent with Task 3 of the NCS CAP, new or upgraded NCSA/Es will be reviewed and Structures, Systems, and Components (SSCs) would be reclassified, as appropriate, in accordance with the revised criteria for the classification of AQ-NCS SSCs. This reclassification of SSCs requires activities such as preventative maintenance and instrument calibrations to be conducted in accordance with I

approved procedures which, in some cases, have not yet been developed. The resources to l

accomplish this effort are, in most cases, the same personnel being used to revise the NCSA/Es, develop training on the revisions to both the NCSA/Es and procedures, and l

Mr. Roy J. Caniano November 13,1998 GDP 98-0255, Page 3 implement the NCSA/Es. Additionally, the approved suppliers list and the stores system have to be upgraded for the reclassified AQ-NCS SSCs.

j Based on the above information, the completion dates for Tasks 3 and 5 have been extended as shown in Enclosure 1. Additionally, based on USEC's reanalysis of the focus of the NCS CAP, the Priority 2 and 3 NCSAs have been combined and are listed in Enclosure 5.

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USEC believes significant work and positive results have been achieved under.he NCS Corrective Action Program and that NCS safety at PORTS has been confirmed. A meeting to discuss the details of this correspondence may be appropriate. We are prepared and would welcome the opportunity to provide additional details in a meeting with you at your convenience.

The information contained in Enclosure 1 contains the regulatory commitments in this submittal.

If you have any questions conceming this submittal, please contact Peter Miner at (740) 897-2710.

Sincerely,

/3 S. A.

I Steven A.Toelle Nuclear Regulatory Assurance and Policy Manager

Enclosures:

As Stated cc: NRC Document Control Desk i

NRC Resident Inspector - PGDP & PORTS NRC Project Manager - PORTS NRC Special Projects Branch DOE Regulatory Oversight Manager l

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I t-GDP 98-0255 Page1of1 Portsmouth NCS Program Revised Schedule Activity Target Date Priority 1 NCSA/Es Complete PORC approval of Priority 1 NCSA/Es (task 3) 03/19/99 Complete AQ-NCS classification (task 3) 04/09/99 Complete procedures, training, and implementation (task 3) 09/30/99 Complete SS&Q review ofimplementation (task 5) 12/15/99 Priority 2 NCSA/Es (see Enclosure 5)

Complete PORC approval of Priority 2 NCSA/Es (task 3) 07/30/99 Complete AQ-NCS classification (task 3) 08/20/99 Complete procedures, tn.ining, and implementation (task 3) 03/03/00 Complete SS&Q review ofimplementation (task 5) 05/20/00 Additional Reviews' Complete AQ-NCS Classification 05/19/00 Complete procedures, training, and implementation revisions 05/18/01 L

'This is the schedule for completing the reviews of the remaining NCSA/Es (i.e., those that l

USEC has determined do not require revision).

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NCSA PROCEDURES UPDATE l

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NUMBER OF PROCEDURES 143 228 IDENTIFIED i

i MARKUPS COMPLETED 71 202 i

1 REVIEWS COMPLETED 4

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l GDP 98-0255 Page1of1 Priority 2 NCSAs to be Revised

- NCSA/E Number /Rev.

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PLAN _T025.A01 General Use of Small Diameter Containers for Storin;; up to 10%

~ Fariched Material PL~ ANT 044.A00.

t 'Id Recovery-Cold Traps PLANT 045.A01 L tited Safe Vohune Containers PLANT 048.A03 Contaminated Metal PLANT 051.A00

. Cold Recovery Chemical Traps PLANT 052.A00 Cold Recovery - Holding Drums PLANT 053.A01 Uranium Analysis and Sampling PLANT 063.A01 Building Decontamination Activities PLANT 064.A00 Handling and Storage of Seals in X-326, X-330, X-333 (includes 0326_028 and 0330_003)

' 0326_001.A02 Nuclear Criticality Safety of Shutdown and Standby X-326 Cells 0700_007.A00 Cleaning Tank #3/ Converter Flushing Station 07051002.A02 -

2.5 Ton,10-Ton, and 14-Ton Cylinder Cleaning 0705_027.A03 Heavy Metals Precipitation y

0705_031.A00 Equipment Disassembly in the North Teardown Area 0705_033.1C4 South Annex Operations-Cascade Equipment 0705_035.A05 Wmd Storage :

0705_040.A00 6veruead Storage

- 0705_076.A00 Inadvertent Containers 0710_006.A01 Uranium Sampling Laboratory

0710_011.A00 Mass Spectrometry Laboratory l

0710_012.A01 Uranium Analysis Laboratory

. 0847_001.A03 General Storage of Uranium-Bearing Waste, XT-847 l

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