ML20198L721
| ML20198L721 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 01/13/1998 |
| From: | John Miller UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Pederson C NRC |
| References | |
| GDP-98-0004, GDP-98-4, NUDOCS 9801160102 | |
| Download: ML20198L721 (6) | |
Text
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s USEC A Global Enhgy Company.
- JAMES H, MILLER -
- Dir. (301) 564-3309
' VICE PRESIDENT, PRODUCTION Fax:(301) 571-8279 January 13,1998 Ms. Cynthia Pederson, Director SERIAL: GDP-98-0004 Director of Division of Nuclear Materials Safety United States Nuclear Regulatory Commission 801 Warrenville Road -
- Lisle, Illinois 60532-4351 P5rtsmouth Gaseous Diffusion Plant (PORTS)
- Docket No. 70-7002 Response to NRC Questioaa Regarding the Revised Corrective Action Plan for the Portsmouth Nuclear Criticality Safety P ogram
Dear Ms,
Pederson:
USEC letter GDP-97-0217 dated December 22. 1997, provided to the Nuclear Regulatory Commission (NRC) a revised Corrective Action Plan for the Portsmouth Nuclear Criticality Safety (NCS)
Program. On January 7,1998, NRC verbally provided USEC with questions regarding the information in the revised Corrective Action Plan. A teleconference between NRC and USEC was conducted on January 9,1998, in which USEC responded to the NRC's questions. As committed to in the teleconference, USEC is providing this letter to document the verbal responses provided to the NRC. to this !ctter restates each NRC question and provides USEC's response. Enclosure 2 lists the commitments made in this submittal, if you have questions regarding this stiomittal, please contact Ron Gaston at (614) 897-2710.
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' Enclosure 1 Response to NRC Questions e
Revised PORTS Nuclear Criticality Safety (NCS) Program Corrective Action Plan -
NRC Question #1 What actions do plant personnel take in response to anomalous conditions regarding NCS controls?
USEC Response
. To ensure consistency between the GDPS, PORTS is providing the following guidance to plant personnel as to the actions to take in response to anomalous conditiens regarding NCS controls:
Activities in the immediate area will be stopped.
.The area will be secured.
. ' The supervisor of the person discovering the condition will be notified.
. The Plant Sh!fl Superintendent (PSS )will be notitied and will subsequently notify the NCS Manager -
or the Duty NCS Engineer.
An NCS Engineer will direct the recovery operation.
These actions have been communicated via a standing order and will also be implemented through training of all FMO personnel and incorporation into the appropriate procedure (s). These actions will serve to futu.e che requirements of paraernph 7.6.4 of ANSI 8.20 1991 and of paragraph 5.2.2.2 of the Safety Analysis Report.
Expected Comp!ction Date: February 11,1998' NRC Question #2 Where the CAP discusses Nuclear Criticality Safety Assessments (NCSAs), do the corrective actions apply to the corresponding Nuclear Criticality Safety Evaluation (NCSE)?
USEC Response References to NCSAs in the revised CAP also include the corresponding NCSEs.
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^'b NRC Question #3 c
c Wlut interim actions are being taken to correct inadequacies in the NCS program and other program -
Edeficiencies (e.g., corrective' action program)?
USEC Response Interim measures that have been put in pk iwill remain in place until the NCS Corrective Action E
Plan has been fully implemc. J are listed..ow:
a.
Two person" rule on NCS support of the PSS for NCS related Problem Reports (prs).
! b.
Daily review of prs to ensure actions are being taken especially for those that are NCS.
related deficiencies.
c.:
' Changes to the applicable procedures and process for NCS related problems as described in USEC 's response to NRC Question #1.
d.
New NCSA/Es and revisions to existing NCSA/Es are being developed using a team approach
. involving the NCS Engineer, the System Engineer, and representation from the implementing organization in the form of a management person and a hands on user.
e.
NCS ove sight on the operating floors to ensure continued heightened awareness of the importance of NCS controls. This is a temporary measure which will remain in effect until USEC is assured that proper awareness has been achieved regarding NCS controls, f.
Review of new NCSA/Es and revisions to existing NCSA/Es by the " Murder Board" to ensure the required level ofinterface exists between the operations personnel and the NCS personnel throughout the NCSA/E and procedure development.
' Expected Completion Date: All of the interim measures, with the exception ofitem "e" are currently in effect. Item "e" (i.e., NCS oversight on the operating floor) will be implemented by February 2,1998.
NRC Question #4 How are generic aspects (i.e., lessons learned) from the NCS e trective actions being applied and what is the process that will be used to accomplish these?
USEC Response Task 9, Contimsons Improvement Program, of the revised Corrective Action Plan describes the actions that USEC is taking to ensure that lessons learned are documented. disseminated to the appropriate personnel, and incorporated into procedures, as applicable. The lessons leamed progran will ensure that the NCS program and implementation continue to improve over time. Another major part of the lessons learned program is ensuring that previously approved products are sufficient to ensure safety in light of the new lesson teamed. Each lesson leamed will be reviewed to identify the affect on related El-2 i
NCSA/Es'whether not yet reviewed or already reviewed under the Corrective Action Plan. Lessons leamed that affect the safety of approved Fissile Material Operations (FMOs) will be documented in a -
' PR. The'PR will then be used as the method to document the specific actions taken to ensure safety.
NRC Questions #5
. In light of the NCS deficiencies, what is the basis for USEC concluding that PORTS is being operated -
safely?
USEC Response The following actions provide the basis and assurance that the PORTS facility is being operated in a safe manner with regard..o NCS controls pending the completion of the actions in the revised NCS Corrective Action Plan:
Compliance with existing NCS A/Es has been verified thrt gh a recent review of ai: NC3A/Es in each facility. This review resulted in the generation of 242 prs,29 of which were reportable to NRC. The remainder of the prs documented issues that did not involve a loss of control or an FMO that was not properly documented.
NCSA/Es that were prepared or reviewed by NCS Engineers that did not meet qualification standards ara being reviewed. This review is on-going but samples of each engineer's work have been reviewed. One engineer's work was found to be below acceptable standards. Based on the review of the NCSA/Es prepared or reviewed by this individual, two activities were stopped (i.e., cylinder valve changes and the L705 Small Parts Pit).
Surveillances for NCS and Tahnical Safety Requirements (TSRs) were verified to be current.
Cancellation of Engineering Notices (ens) that modified NCS program requirements and shutdown of the affected FMOs. All FMOs are being performed in accordance with Plant Operations Review Committee (PORC) approved NCSA/Es.
Daily review of prs has not identified any immediate safety concerns.
The conservatisms used in doing NCS evaluations provide added assurance of safety (e.g., assumption
-(.. optimum geometry, full moderation and reflection. higher assay levels).
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List of Commitments
- 1. To ensure consistency between the GDPS, PORTS is providing the following guidance to plant personnel as to the actions to take in response to anomalous conditions regarding NCS controls:
Activities in the immediate area will be stopped.
.The area will be secured.
The supervisor of the person discovering the condition will be notified.
The Plant Shift Superintendent (PSS )will be notified and will subsequently notify the NCS Manager or the Duty NCS Engineer.
An NCS Engineer will direct the recovery operation.
These actions have been communicated via a standing order and will also be implemented through training of all FMO personnel and incorporation into the appropriate procedure (s). These actions will be completed by February 11,1998.
- 2. NCS oversight on the operating floors to ensure continued heightened awareness of the importance of NCS controls will be implemented by February 2,1998.
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