ML20198A284
| ML20198A284 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 12/29/1997 |
| From: | Polston S UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-7001-97-208, NUDOCS 9801050332 | |
| Download: ML20198A284 (15) | |
Text
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USEC A ow an.ru omp.ar c
December 29,1997 United States Nuclear Regulatory Commission SERIAL: GDP 97-1056 Attention: i>ocument Control Desk Washington, D.C. 20555 Paducah Gaseous Diffusion Plant (PGDP)
Docket No. 70-7001 Response to Inspection Report (IR) 70-7001/97208 Notices of Violations (NOVs) and Devhtion (NOD)
The Nuclear Regulatory Commission (NRC) letter dated November 28,1997, transmitted the subject IR which centained three NOVs and one NOD, respectively. United States Enrichment Corporation's (USEC) response to these issues is provided in Enclosures 1-4. Enclosure 5 lists the commitments made in this report. Unless speciGeally noted, the corrective actions specined in each enclosure apply solely te PGDP.
USEC does not agree with the NOD. USEC believes the process used to notify NRC of the change in commitment was consistent with NRC requirements, the Commission's guidance and applicable USEC procedures. USEC acknowledges that we did not communicate our intention to the PGDP NRC Senior Resident inspector to revise this commitment prior to submitting the change letter to NRC Additionally, vre acknowledge that our formal notincation to NRC regarding this change should have been timelier. Further discussion regarding the basis for the USEC's denial of this NOD is provided in Enclosure 4.
If you have any questions regarding this submittal, please contact Bill Sykes at (502) 441-6796.
Sincerely, Steve Polston 9801050332 971229 Ceneral Manager PDR ADOCK 07007001 Paducah Gaseous Diffusion Plant C
PDR SP:SRC:mic Enclosures (5) cc:
NRC Region'Ill O
/r
-NRC Senior Resident Inspector, PGDP
!!O. Box 1410. Paducah, KY 42001
- Telephone 502 4415803 Fax 502-441-5801 http://www.usec.com
. OfHces in Livermore, CA Paducah, KY Portsmouth, OH Washington, DC
ENCLOSURE 1 UNITED STATES ENRICllMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 97-208-03 TSR Section 3.11.1 requires, in part, that "A Criticality Safety Prognun shall be established, implemented and maintained as described in the Safety Analysis Report..."
SAR Section 5.2.3.2 requires, in part, that " Statistical analysis is employed to estimate the calculational bias, which includes the uncertainty in the bias and uncertainties due to extensions of the area of applicability, as well as the effective margin of suberiticality... The margin of suberificality used at PGDP shall result in a k,y upper safety limit which will ensure that there is 95 percent confidence that 99.9 percent of all future k,g values less than this value will be suberiticality... controls and limits are established to ensure that the maximum k,ycomplies with the applicable code validation for that type of system being evaluate (."
Violation Cited Contrary to the above, as of November 7,1997, the calculations in Nuclear Criticality Safety Evaluations (NCSEs) were observed to be based on an enrichment of 5.5 wt% even though the experimental data only extended to 4.98 wt%. The validation report did not demonstrate that the data was nonnally distributed, as required by the method which determines the USL with 95%
confidence that 99.9% of all future calculations with k,y<USL will be suberitical. The valiaation did not rigorously demonstrate that the above conditions could be met for enrichments of 5.5 wt%.
USEC Response 1.
Background Information In support of the Ilicher Assay Upgrading Project, the PGDP code validation range for enrichment has been extended to 5.5 wt%. KY/S-221. Rev.1, did not utilize critical benchmark experiments with enrichmen?s greater than 5.0 wt%. The area of applicability was extended from 5.0 wt% to 5.5 wt% using qualitative arguments based on the trending of data provided in the validation report. Since no adverse trends in data from critical ber.cl.; nark experiments and validation report results were observed as enrichment approached 5.0 wt%, it was determined that linear extrapolation of the bias from the data oflower enrichments would be acceptable over the relatively small enrichment change to 5.5 wt%. Since the bias was not expected to change adversely from 5.0 to 5.5 wt%, it was determined that all the SAR requirements would be met in the extended range of applicability.
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. Indu'stry standardized techniques for performing validation extensions beyond areas supported by critical benchmark experiments, have not been established, other than the general guidance given in ANSI /ANS 8.1-1983," Nuclear Criticality Safety (NCS) in Operation with Fissionable Materials Outside Reactors." Knowing that no criteria existed for extending the area of validation applicability and no s. udards or policies had been established to implement extensions, the qualitative arguments were deemed to be sufficient. In developing the validation report PGDP util; zed the services of an NCS and validation expert from Oak Ridge National Laboratory (ORNL). The validation expert was consulted in performing the validation and he approved the validation and techniques applied therein during the review process.
11.
Reasons for Violation The reason for the violation was a lack of standards and guidance regarding the proper methodology for extending validation applicability. ANSI /ANS 8.1-1983 contains guidance that when extending the area of applicability, any uncertainties due to the extension need to be included in the estimate of the bias, llowever, no industry and plant standards exist to ensure that a sufficiently rigorous method is adopted and utilized consistently.
111.
Corrective A@ns Taken and Results Achieved NCS has performed a preliminary review cf PGDP operations ar.d NCSAs to determine the scope of operations which could be performed at assays between 5.0 and 5.5 wt%.
Only a few operations are currently being performed at assays greater than 2.75 wt%,
due to current plant authorization limits (TSRs and SAR limit most operations to less than 2.75 wt% assay). Those operations with greater than 2.75 wt% assay include a few processes in the laboratory and storage of offsite equipment (with assay less than 5.5 wt%) under the controls of NCSA GEN-10. The common physical characteristics of those activities, (i.e. limited mass, high leakage geometries, and the presence of metal in most equipment) ensure that any potential change in bias will not significantly affect nuclear criticality safety. Significant safety margin for equipment characterized for storage and handling under NCSA GEN-10 is included in the NCSA GEN-10 safe mass curve. The safe mass curve establishes maximum safe mass values that are on the order of 43 percent of the actual critical mass value. Therefore the preliminary reviews ensure that no immediate safety concern exists.
IV.
Corrective St2ns to be Taken 1.
Procedure CP2-EG-NS1032," Software Configuration Control Program for the Nuclear Criticality Safety Code System (SCALE)," will be revised to be centistent with SAR Section 5.2.3.2. This action will be completed by April 30, 1998.
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2.
The code vali e.(ion, KY/S-221, will be revised using benchmark experiments with enrichments greater than 5.0 wt%. The resulting validation will then bound assays through 5.5 wt%, at a minimum. This action will be completed by July 20, 1998.
3.
If needed, a request will be submitted to NRC by August 4,1998, for a change to TSR requirement 3.11.4.
V.
Date of Full Comnliance Full compliance will be achieved upon the revision to the code validation report and, if needed, any subsequent TSR changes.
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ENCLOSURE 2 UNITED STATES ENRICllMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7001/97208-08 SAR Section 5.2.2 requires, in part, that "The nuclear criticality safety (NCS) program, as defined in this section is implemented by the plant NCS procedures."
Procedure CP4 EG NSI104, Rev. O," Nuclear Criticality Safety Engineer Response to Emergency, Off Nonnal, and Process Upset Conditions," requires, in part, that the NCS Engineer " Evaluates potential criticality safety violations... responds and provides guidance during emergencies, off-nonnal, and process upset conditions with NCS significance.. " and also must " Complete incident Report within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ofincident..."
Violation Cited Contrary to the above, as of September 19,1997, threc criticality control violations were identified in which the NCS Section was not notified or consulted, and thus did not provide the required guidance or issue the Audit / Incident Reports within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
1.
Background Information The " Nuclear Criticality Safety" procedure CP2-EG-NS1031 describes and establishes the NCS program requirements and responsibilities and applies to all personnel who process, handle, store, or transport fissile or potentially fissile material. fhis procedure defines the organizations responsible for fissile niaterial operations and their management as being responsible for the safety of operations. The First-line Manager is responsible for the safety of operations under his/her control, including implementation of the requirements given in approved NCSAs. The procedure goes on to state that if an NCSA requirement is violated, or appears to have been violated, the responsible manager immediately notifies Plant Shill Superintendent (PSS) and NCS and reports the incident according to the " Problem Reporting" procedure Following notification, the NCS Engineer prepares an incident report.
11.
Reasons for Violation 1.
The reason fer the violation was e failure to follow procedures and inadequate training. Specifically, plant procedures, CP2-EG NS1031, required fissile material operations managers to notify both the PSS and NCS upon discovery of a condition which could adversely affect Criticality Safety. This procedurt also requires the PSS to notify NCS as appropriate if an NCS-related problem report is submitted. Individuals failed to contact NCS because they believed the PSS would do so based on training they had received. The training organization also E2-1
incorrectly assumed that the person identifying an NCS problem did not need to contact both the PSS and NCS, si' ice the PSS would always contact NCS for NCS issues.
2.
Additionally, CP4-EG NSI104 requires NCS eng'aeers to evaluate events aficcting criticality safety and complete a Criticality Safety Audit / Incident Report within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the incident. In one of the examples cited in the violation, NCS had been notified ano failed to follow procedure and complete and file the
- incident report documentation within the 24-hour tiu period.
III.
Corrective Actions Taken and Results Achieved USEC has campleted crew briefings with NCS personnel and the general plant population to heighten awareness to procedural requirements concerning this issue.
1.
In October 1997, a crew briefing was performed with all NCS personnel on communications with the PSS. The crew briefing identified NCS management's expectation concerning the responsibility of personnel to identify problems and fully communicate concerns in a timely and accurate manner to the PSS.
2.
By December 4,1997, a site-wide crew briefing was perfomied on "NCS Program Failures and NRC Violations." The plant-wide briefing specifically addressed Problem Report PR-EN-97-5242, identifying plant personnel's failure to notify NCS concerning violations of NCS controls.
IV.
Corrective Stens to be Taker 1.
Training management (or designees) will briefinstructors for modules 501.02.02SS and 501.02.02CR of the need to clarify to trainees that both the PSS and NCS must be contacted for any NCS related problem. This action will be completed by January 30,1998.
2.
NCS Management (or designees) will perfomi a crew briefing emphasizing the requirements of CP4-EG.NS I 104, regarding completion of the Criticality Safety Audit / Incident Repori within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the incident. This action will also be completed by January 30,1998.
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Dalp of Full Comnliance On December 4,1997, site personnel were briefed on the requirement to notify NCS of violations of NCS controls. The corrective actions to prevent recurrence will be completed by January 30,1998.
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4 ENCLOSURE 3 UNITED STATES ENRICllMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7001/97208-10 SAR Section 6.11.1 requires, in part, that "USEC is committed to the use of approved and centrolled written procedures to conduct nuclear safety, safeguards, and security activities...USEC's quality assurance commitments are described in the Quality Assurance Plan."
QAP Section 2.16.1 requires, in part, that "A corrective action system... establishes measures which ensure that conditions adverse to quality are identified and corrected as soon as practical..."
Violation Cited Contrary to the above, as of November 7,1997, inconsistencies between operating procedures that could have permitted the assay limit on the C-360 surge drums to be exceeded during 2S cylinder refeed operations had been observed. The operation was restarted without taking prompt and corrective action to resolve the inconsistency, and the corrective action was inadequate to resolve the inconsistency.
Background Information The C-360 facility is ased to receive, ship and sample UF cylinde;s and to transfer UF.
from one cylinder to another. In additian, sample contamers (2S cylinders) and laboratory spectrometer cold traps are sent to C-360 for emptying and eventual return to cwade inventory. Records indicate that none of these items that have been sampled or emptied at C-360 and they also contained an assay greater than 2%Um II.
Reason for Violation As indicated in IR 97-10. there were two concerns that !ed to the violation: 1) operators continued to use procedure CP4-CO-CN2051i," Returning 2S Sample Cylin;lers and C-710 Mass Spectrometry Metal Cold Traps to the C-360 Surge Drums," after a problem report was written to recommend revising the procedure to limit assay to a maximum of 2.75 wt' 'l235; 2) the Problem Report was closed out on the basis of a procedure change request.
The reason that Operations continued to use CP4-CO-CN2051i after the problem was identified was that Operation's personnel failed to verify that adequate controls were in place to prevent the refceding of material with an assay greater than 2 percent. The only facility at PGDP which has material greater than 2 percent assay in 2S cylinders or Mass Spectrometer Cold Traps is the C-710 Laboratory. Operations contacted C-710 upon E3-1
l discoveiy of the problem and determined that administrative centrols were in place to prevent greater than 2 pc. cent material from being shipped to C-360. These controls are that 2S cylinders r.re tagged with the assay and any cylinders greater than 2 percent have a restriction not to ship to C-360. Ilowever, these controls were not captured by procedures. In addition, the surge drum operational procedure (CP4-CO CN2007) did have a 2 percent assay limit as an NCSA control. This procedure was identified as a "Use Ref erence" in the refeed operation procedure (CP4-CO-CN2051i) and thus implied a 2 percent limit for the refeed operation. It was determined later, however, that there were steps in CP4-CO CN2051i which did not specifically require the use of the surge drum procedure and thus the 2 percem limit may r.ot always have a procedure driver.
The rea.mn for inadequate closure of the problem report and inconsistem NCSA flowdown was that there was not a specific policy or procedural requirement regarding these issues. Currently UE2 IIR-C11031, Carrective Action Process, allows Conditions Adverse to Quality (CAQ) problem reports to be closed with the issuance of a Procedure Development Form (PDF); however, the process does not provide for traceability of PDF closure / cancellation back to the initiating problem report. It should be noted that Significant Conditions Adverse to Quality (SCAQ) Problem Reports cannot be closed without a subsequent action verifying completion in addition, two different NCSAs for associated operations (i.e. refeeding operations for 2S cylinders and spectrometer cold traps and the operation of the C-360 surge drums) had inconsistent assay limits and there is not an NCSA procedural development requirement which requires that consideration to be given to contiguous systems when developing NCSAs.
111.
Corrective Actions Taken and Results Achieved 1.
CP4-CO-CN2051i, has been modified to flowdown the 2 percent assay limit required for the surge drum operation. Other pertinent facility procedures were verified to have the 2 percent limit incorporated.
2.
Commitment Management has advised Organizational Managers and Problem Report Coordinators through presentations and memorandums not to submit PDFs for closure of problem reports.
IV.
Correstby
.ons to be Taken 1.
Commitment Managemer.t will fix PDF process traceability or revise appropriate procedures by April 30,1998, to ensure that initiated PDFs are not accepted as closure for problem reports.
2.
The NCSA developmental procedures will be revised by June 17,1998,as necessary, to require the establishment of system baundaries such that multiple NCSAs will not result in inconsistent assay limits for connected systems.
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, 3.
Procedures and Training will revise procedural guidance, as necessary, to clarify th: definition and use of"Use References" by April 30,1998.
4.
Operations will issue a " Lessons Leamed" memorandum by January 15,1998, to appropriate Operations Managers and other organizational managers concerning the operation of systems without assuring that relevant NCSA requirements are in place.
V.
Date of Full Compliance USEC achieved full compliance when CP4-CO-CN2051i was revised to incorporate the correct assay limits. The corrective actions to prevent recurrence will be completed by June 17,1998.
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ENCLOSURE 4 -
UNITED STATES' ENRICHMENT CORPORATION (USEC)
REPLY TO NOTICE OF DEVIATION (NOD) 70-7001/97208-01 Restatement of Deviation USEC letter GDP-97-1013 dated June 16,1997, committed to correct violation 70 7001/97201-02 regarding flowdown of NCSA required fire fighting instructions int _o the pre-fire plans for the Negative Air Machine (NAM) filters stored in the C-335 Fissile Control Area (FCA) and into appropriate emergency response training. The date committed to was August 20,1997'.
Contrary to the above, USEC letter GDP.971027 dated August 19,1997, changed the date for correcting the violation to November 12,1997.- Change to a commitment requires the concurrence of the NRC and is expected in a tiinely manner.
4 USEC Response USEC does not agree with this deviation. There is no requirement to obtain NRC concurrence for a change to a commitment of the type referenced in the NOD.
USEC believes the process that was utilized to notify NRC regarding the change to the regulatory commitment was consistent with the applicable NRC requirements, the Commission's guidance for managing regulatory commitments, and applicable USEC procedures. USEC acknowledges that we did not communicate to the PGDP NRC Senior Resident inspector our intention to revise this commitment prior to submitting the notification letter to NRC on the
-SAR. Additionally, we acknowledge that our formal notification to NRC regarding this commitment change should have been timelier, Actions that USEC has taken to improve our communications with NRC regarding changes to regulatory commitments are described later in this response, llowever, USEC is not aware of any NRC requirement which specifies that NRC concurrence is required for a change to a regulatory commitment that is contained in a response to a Notice of Violation (NOV) when the commitment has not yet been implemented. Further
' discussion regarding the basis for USEC's denial of this NOD is provided below.
'It should be noted that the cited deviation is not factually correct. In response to NOV 97201-02, USEC committed, by August 20, I997, to update NCSE KY/S-249 to more clearly document the technical basis used to enwre the safe storage ofspent NAht! Fixed HEPAfilters. This update will include a suficient level ofdetail to clearly)ustify the spacing reqwremints and other NCS controls used to ensure double censingency in theJ1!ter.
storage area. Subsequently, USEC letter GDP-97-1027 dated August 19,1997, notified NRC that USEC had J changed the due date for this regulatory commitment to November 12,1997. Thus, although the NOD cites the wrong commitment, NRC is correct that USEC did submit correspondence to NRC on August 19,1997,e h
- provided notification of a change in a commitment that was due August 20,1997.
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e NRC Guidance on Revising Regulatory Commitments -
L NRC has recognized that there is no codified process for revising commitments that do not stem from a legally binding requirement or licensing - documents (e.g., Final Safety Analysis Report, Technical Specifications, NRC rules or regulations, etc.)2. Accordingly, on December 20,1995, the NRC Executive Director for Operations issued SECY-95 300, Nuclear Energy Institute's -
(NEI) Guidance Document, "Guidelinefor Managing NRC Commitments. " The purpose of this document was to inform the Commission that the NRC staff udended to notify the NE! by letter that its guidance document "Guidelinefor Managing NRC Commitments"is an acceptable guide for licensees to follow for managing and changing their commitments to the NRC. Subsequently by letter dated January 24,1996, NRC notified NEl that their guidance document for managing hRC commitments is an " acceptable method for licensees to follow for managing and changing
. their NRC commitments."2 in SECY-95-300, NRC states that " Regulatory commitments are specific actions that have been
- voluntarily agreed to or that have been offered by a licensee in docketed correspondence to the Commission on a voluntary basis. Unlike regulatory requirements contained in regulations, licenses, and orders, regulatory commitments are not legally binding... Many regulatory
. commitments are not contained in the FSAR but in other docketed 'correspndence such as licensee event reports (LERs), responses to notices of violation (NOVs), and responses to generic letters. Those com nitments not contained in the FSAR are not controlled by a defined regulatory process such as 10CFR50.59. Therefore, licensees have the ability to change docketed commitments not contained in the FSAR without informing the Commiss%."4
~
- Additionally,in SECY-97-036, dated February 12,1997, Millstone Lessons Learned Report.
Part 2: Policy Issues, NRC states: "The agency has no requirements that govern commitments found outside of the operating license or FSAR, other than Section 50.9, which requires the information to be complete and accurate. at the time that it is given to the NRC,. Currently, commitments are defined only in an industry guideline that the agency endarsed in January
~ l 996."5 -
4 8 in USEC 's case this would also apply to Conditions in the Certification Application and also the Compliance Plans.
a See NRC letter dated January 24; 1996, Dennis M. Crutchfield to Joe F. Colvin, NEl's "Guidelinefor Afanaging NRC Commitments " Revision 2, December 20,1995
- See page 3, Regulatory Sigmficance ofL ommitments.
- See page 2l, Commitments in SERs. Event Reports, and Responses to Generic Communicatiam, in the
~
Atillstone Lessons !.carned Report Part 2' Policy issues.
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Therclore, the NEI guidelines provide NRC-accepted guidance with respect to changing regulatory commitments that are not described in the FSAR or other licensing-basis (or in USEC's case, certification-basis) documents. The NEI guidelines contain a five-step process for evaluating changes to commitments. This process is summarized below:
The first step captures commitments that are already subject to codified processes,
+
such as 10CFR50.59 or 10CFR50.54 (a),(p), and (q).
The second step asks the licensee to evaluate the safety sigmficance of the change to the commitment to verify that the change would not negatively impact the ability of a structure, system or component (SSC) to perform its intended safety function.
The third step applies to commitments which were made to achieve and maintain compliance with NRC requirements if the changed commitment does not preserve compliance, the licensee would have the option of not proceeding with the change, or formally requesting regulatory relief (e.g., license amendment, exemption).
The fourth step involves commitments (exclusive of those made in confirmatory action letters)in which the NRC either reviewed and approved the action volunteered; or agreed to by the licensee; er relied upon the commitment in lieu of taking other action, such as issuiag an order. Comraitments included in this step are specific statements in NRC safety evaluation reports; commitments made in respouse to bulletins, generic letters, and 10CFR50.54(f) letters; and commitments identified as long-term corrective actions in response to an NOV.
The fifth and final step in the NEl guidance involves commitments made to minimize recurrence of adverse conditions, such a those described in some LERs.
As noted above, the fourth step of the NEl p:ocess specifically addresses commitments identified as long-term corrective actions in response to an NOV. The NEl guidance states: "If the original commitments have not yet been implemented, the licensee can proceed with the change.
Ilo vever, the NRC would be notified as soon as practicable after the change is approved by licensee management, but befc;e any committed completion date."
USEC's Pweess for Revising Regulatory Commitments USEC 's process for revising a regulatory commitment. similar to the one cited in the NOD, is described in procedure UE2-OP-RA1032,"USEC Nuclear Regulatory Commitment Management System," and is summarized as follows:
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When the need to revise a regulatory co nmitment is identified, the responsible person completes an Action Response Status Form, with accompanying justification, and submits it to the Nuclear Regulatory Affairs (NRA) organization for approval.
Upon NRA approval of the i:gulatory commitment change request, written notification is required to be submitted to the regulator, prior to the regulatory commitment due date.
Ilasis for USEC's Denial of the Notice of Deviation In response to NOV 70-7001/97201-02, USEC committed to a long term corrective action as follows: "By August 20,1997, NCS will update NCSE KY/S-249 to more clearly doc iment the technical basis used to ensure the safe storage of spent NAM / Fixed llEPA filters. This update will include a sufTicient level of detail to clearly justify the spacing requirements and other NCS controls used to ensure double contingency in the filter storage area."
On August 19,1997, the NDP NRA Manager approwd a request to change the due date for this Subsequenti,on August 19,1997, commitment from August 20,1997, to November 12,1997.
f USEC submitted a letter to NRC advising NRC of the change in the due date for this regulatory commitment and thejustification for this change. This method fer notifying the NRC of this change in a regulatory commitment is proceduralized (i.e., UE2-OP-RA1032) and is consistent with the NRC guidsnee in SECY-95-300 in that:
Tir original commitment had not yet been implemented; USEC notified NRC of the change as soon as practical after the change was approved by the NRA Manager: and NRC was notified of this change via docketed correspondence.
Additionally, there is no NRC regulation that would have required NRC concurrence with this commitment change prior to the commitment due date.
The NRC Enforcement Manual defines a deviation as,"a licensee's failure to satisfy a written commitment, such as a commitment to conform to the provisions of applicable codes, standards, guides, or accepted industry practices when the commitment, code, standard, guide, or practice involved has not been made a requirement by the Commission." Based on the above, it is USEC's belief that we did not deviate from the NRC requirements and guidelines and accepted l
industry practices for revising a regulatory commitment.
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Enhancements to the USEC Process for Notifying NRC of Changes in Regulatory Commitments USEC acknowledges that it is a good practice to communicate to the NRC Resident inspector our intention to revise commitments prior to submitting notification lett.r to NRC. Additicnally, we acknowledge that our formal notification tc NRC regarding commitment changes should be timelier. - Accordingly, the General Managers have communicated to their staffs the need to ensure that NRC receives more timely notification of changes in regulatory commitments.
Additionally, the NRA Managers et both GDPs have initia*ed the practice of verbally notifying the NRC Resident inspector (s) of changes in regulatory commitments prior to submitting any docketed correspondence to NRC.
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ENCLOSURES LIST OF COMMITMENTS.
1.
Procedure CP2 EG-NS1032," Software Configuration Control Program for the Nuclear Criticality Safety Code System (SCALE)," will be revised to be consistent with SAR Section 5.2.3.2. This action will be completed by April 30,1998.
2.
The code validation, KY/S-221, will be revised using benchmark experiments with enrichments greater than 5.0 wt%. The resulting validation will then bound assays through 5.5 wt%, at a minimum. This action will be completed by July 20,1998.
3.
If needed, a request will be submitted to NRC by August 4,1998, for a change to TSR requirement 3.11.4.
6 1.
Training management (or designees) will briefinstructors for modules 501.02.02SS and 501.02.02CR of the need to clarify to trainees that both the PSS and NCS must be contacted for any NCS related problem. This action will be completed by January,,30, 1998.
2.
NCS Management (or designees) will perform a crew briefing emphasizing the requirements of CP4-EG NSI 104, regarding completion of the Criticality Safety Audit / Incident Report within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the incident. This action will also be completed by January 30,1998.
1.
- Commitment Management will fix PDF process traceability or revise appropriate procedures by April 30,1998, to ensure that initiated PDFs are not accepted as closure for problem reports.
2.
The NCSA developmental procederes will be revised by June 17,1998, as necessary, to require the establishment of system boundaries such that multiple NCSAs will not result in inconsistent assay limits for connected systems.
3.
Procedures and Training will revise procedural guidance, as necessary, to clarify the definition and use of"Use References" by April 30,1998.
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Opefations will issue a " Lessons Learned" memorandum by January 15,1998, to J
' appropriate Operations Managers and other organizational managers conceming the -
operation of systems without asseing that relevant NCSA requirements are in place.
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