ML20195E941
| ML20195E941 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant, Paducah Gaseous Diffusion Plant |
| Issue date: | 06/08/1999 |
| From: | Toelle S UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Paperiello C NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| GDP-99-0078, GDP-99-78, NUDOCS 9906140147 | |
| Download: ML20195E941 (6) | |
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. A Global Energy Company June 8,1999
.GDP.99-0078 Dr. Carl J. Paperiello Director, 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 Application ofIndustry Codes and Standards
Dear Dr. Paperiello:
USEC letter, GDP 97-0034, dated March 10,1997, addressed an initiative to determine if further application ofindustry codes and standards at the gaseous diffusion plants was warranted. The purpose of this letter is to provide the results of this initiative. In addition, the enclosure to this letter l
_is intended to resolve the NRC's unresolved item, URI 70-7001/97007-08, related to the lack of j
specificity for application of codes and standards in the Safety Analysis Report (SAR) and PGDP l
Compliance Plan Issue 45, " Codes and Standards." contains a summary of USEC's codes and standardsinitiative. USEC has reviewed the results and recommendations of the codes and standards initiative and has determined that the f
current commitments to the codes and standards identified in the Paducah and Portsmouth SARs,
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l Chapter 1, Appendix A, are adequate and appropriate for the gaseous diffusion plants. The results jl l
of the codes and standards initiative are currently being utilized in the engineering design process as described in Enclosure 1.
'O l
9906140147'990600 ~
PDR ADOCK 07007001 C
PDR 6903 Rockledge Drive,11ethesda. MD 20817-1818 Telephone 301-564-3200 Fax 301-564 3201 http://www.usec.com Gmces in Liv-tmore, CA Paducah, KY Portsmouth, OH Washington, DC J
e Dr. Carl J. Piperi:llo June 8,1999 GDP 99-0078, Page 2 Any questions related to this subject should be directed to Mark Smith at (301) 564-3244. There are no new commitments contained in this submittal.
Sincerely, b
S. A.
In' Steven A. Toelle Nuclear Regulatory Assurance and Policy Manager
Enclosure:
As stated
Reference:
Letter from James H. Miller (USEC) to Dr. Carl J. Paperiello (NRC), "Paducah Gaseous Diffusion Plant (PGDP), Docket No. 70-7001, Response to Request for Additional Information, Certificate Amendment Request-Feed Facilities Crane Design Features," GDP 97-0034, dated March 10,1997.
cc:
Mr. P. L. Hiland, NRC Region III Office NRC Resident Inspector-PGDP NRC Resident Inspector-PORTS
x, N,
7 Enclosure I c
GDP 99-0078 Page1of4 5:
Summary of Codes and Standards Initiative Project Scope Historically,the Paducah (PGDP) and Portsmouth (PORTS) Gaseous Diffusion Plants (GDPs) have carried out operations, maintenance, and modifications to the Facilities usins guidance in a broad range ofindustry codes and standards. USEC's current commitment to specific codes and standards applicable to Q, AQ-NCS and AQ items are identified in Chapter 1, Appendix A, of the Safety Analysis Report (SAR). In response to a Request for Additional Information related to the PGDP
. Certificate Amendment Request associated with Feed Facility Crane Design Features (Reference GDP 97-0034), USEC committed to an initiative to determineif further application ofindustry codes and standards was warranted at the GDPs.
The specific commitment, outlined in USEC letter GDP 97-0034, is as follows:
"In letter GDi'97-009 dated January 31,1997, USECprovidedthe NRC a copy of the revisedAppendixA to SAR Chapter 1for both the PGDP and the PORTSplants.
The revised Appendix A identifies the extent of USEC's current commitment to various industry codes, standards, and regulatory guidance documents originally identified in the certification application and related correspondence.
j USEC is undertaking an initiative to determine offurther application ofindustry codes and standards at the GDPs is warranted. This initiative encompasses the following tasks:
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!(a)
Review the codes and standards in SAR Chapter 1, Appendix A, to determine if any additional documents, diferent editions, or additionalsections ofdocumentsshouldbe applied to Ihe GDPs. As l
part ofthis review, determine what structures, systems, components, analyses, and operations would be subject to each document. It is anticipated that currentpractices atfuel cycle, reactor, and related i
chemicalfacilities (as applicable to the design and operation ofthe GDPs) will be useful benchmarks in conducting these reviews.
(b)
' Review the design, supportinganalyses, and operations ofthe GDPs and determine what hardware, analysis, or operational changes would be required to meet the identified codes and standardr.
A' (c)
Evaluate the benefits and costs ofthe identified hardware, analysis, andoperationalchanges anddecide which changes are worthwhile.
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e; i
1 GDP 99-0078 '
Page 2 of 4 I
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implement the changes (d)
USEC will keep the NRC informed of our progress, as plans are developed and
. finalized. "
In' addition, NRC Inspection Report 70-7001/97007 contained an Unresolved Item (URI 70-7001/97007-08) which was linked to the resolution of Compliance Plan Issue 45, " Codes and Standards." In opening the URI, the NRC identified potential concems with USEC's response
- provided to Compliar.cc Plan Issue 45 and with the current engineering practices for the application ofengineering specifications. With respect to USEC's response to PGDP Compliance Plan Issue 45, the NRC inspectors noted that the response did not explicitly include reference to " national standards and engineering piping specifications" found in PGDP SAR Section 3.2.4.
Project Description This project identified current codes and standards which could be applied to operation, maintenance, and modification of structures, systems and components at the PGDP and PORTS GDPs. The scope of the review was limited to items classified in the PGDP and PORTS System Boundary Definition Manuals.as quality categories Q, AQ-NCS, and AQ. A report summarizing the results of the codes and standards initiative was prepared and is available at both the PGDP and PORTS GDPs.
This project identified actions necessary to apply recommendations and ' requirements of current industry codes and standards to GDP operations and maintmance procedures as well as identifying
. considerations associated with reconstituting the as-built design standards.
Project Methodology, i
1.
Compile a list ofrelated codes and standards i
The listing of current codes and standards which could be applied to each Q, AQ-NCS and AQ
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. structure, system and component was developed from three primary references: UEO-1045," Design
. Guidelines"; interviews with plant personnel; and, other companies primarily in the petro-chemical and energy productionindustry. In addition,other documents were utilized for input, such as DOE j
Order 6430.1, United States Department of Energy General Design Criteria," manufacturer's literature and vendor. manuals. The list of codes and standards was then compiled into tables for
- PGDP and PORTS that matrix these codes. aid standards to structures, systems and components listed in the System Boundary Definition Manual.
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GDP 99-0078 Page 3 of 4 2.
Correlate Codes andStandards with Operations and Maintenance Procedures Once the list of codes and standards was established, e search of the plant procedure database was performed to identify those operations and maintenanc procedures which referenced a code or standard included in the above noted matrix prepared as pet of the codes and standards initiative.
Based on this search, a listing of procedures for each plant which referenced a code and/or a standard identified in the initiative was developed. These listings were presented to knowledgeable plant individuals for review.
3.
Evaluate the Results ofthe Correlation
' Knowledgeable plant individuals evaluated the listing of procedures, and the referenced codes or standards in these procedures,to identify 1) known deficiencies existing in the listing of procedures provided or 2) procedures which should be revised to reflect additionaluse of codes and standards.
There were no procedures identified during this evaluation which required immediate action.
However, recommendations for procedure revisions resulting from this evaluation were obtained l
from these individuals during the course of their review and will be dispositioned as stated in the l
conclusions to this letter, j
Conclusions The matrices developed in response to the codes and standards initiative are being used as reference documentationto identify the codes and standards which could be applied to Q, AQ-NCS and AQ structures, systems and components identified in the Boundary Definition Manuals. The existing design control processes utilized at the GDPs require that the original design basis be identified, or reconstituted as required,on a case by case basis for each design change associated with Q, AQ-NCS and AQ structures, systems and components. As part of this design control process requirement, current industry codes and standards are compared to the codes and standards associated with the original design basis. Differences identified in the comparison of the original design basis codes and standardsto current codes and standards are evaluated as part of the design control process. In the event this evahiation concludes that codes and standards other than the original design basis codes and standards should be utilized, consideration is given to the installed structures, systems and components to ensure that the original design basis associated with these installed structures, systems and components is not adversely impacted.
Based on USEC's review of the results and recommendations of the codes and standards initiative, the current codes and standards identified in SAR, Chapter 1, Appendix A, and the extent of USEC's commitments to these codes and standards presented in the SAR, are adequate for continued safe operation of the plant. Therefore, USEC does not intend to expand commitments to codes and standards beyond those commitments currently contained in the SAR, Chapter 1, Appendix A.
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GDP 99-0078 Page 4 of 4 Recommended procedure revisions noted during implementation of the codes and standards initiative will be evaluated for inclusion in the appropriate procedure at the next procedure revision.
With respect to URI 70-7001/97007-08, USEC has reviewed the installation documentation associated with the autoclave piping and has verified that the PGDP autoclave piping to the second isolation valve was installed in accordance with national standards and engineering piping specifications with a pressure rating of 200 psig. As such, the current statement in SAR, Section 3.2.4 relating to the installation of the autoclave piping to the second isolation valve is accurate as written. USEC is unaware of a regulatory requirement to revise the current SAR to identify these particular standards with more specificity.
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