ML20198S626
| ML20198S626 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 11/10/1997 |
| From: | Morgan J UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| GDP-97-2030, NUDOCS 9711140076 | |
| Download: ML20198S626 (6) | |
Text
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November 10,1997 United States Nuclear Regulatory Commission SERIAL:GDP 97 2030 Attention: Administrator, Region 111 801 Warrenville Road Lisle, Illinois 60532-4351 Portsmouth Gaseous Diffusion Plant (PORTS), Docket No. 70-7002, Completion of a Regulatory Commitment Pursuant to a discussion between Patrick liiland, NRC Region ill, and Ron Gaston, PORTS Nuclear Regulatory AfTairs Manager, on November 7,1997, this letter documents the completion of a commitment described io USEC letter GDP 97 2028, dated November 7,1997, to provide NRC with the NCS corrective action plan by November 10,1997.
A copy of the NCS corrective action plan is enclosed.
A list of NCSAs and their priority classifications was provided in USEC letter GDP 97 2028, dated November 7,1997, implementation of the NCSA review, field walkdown, verification and the review board is described in the NCS Corrective Action Plan in the section entitled, Short-Term Implementation Activities.
If you have any questions regarding this submittal, please contact Ron Gaston at (614) 897 2710.
/
l-Sincerely, l
N Ulm Morgan Acting Genera fanager Portsmouth Gaseous Diffusion Plant 9711140076 97111 '
PDR ADOCK 07007 2
lllljgl ll ll C
p O&ces m Paducah. Kentuc Av Portsmouth. Ohio Washington DC
United States Nuclear Regulatory Commi:sion
' November 10,1997 Page2 J
Enclosure cc:
- NRC Document Control Desk NRC Resident inspector - PORTS NRC Special Projects Branch
i United States Nuclear Regalatory Commission
' November 10,1997 Page 3 4
Distribution:
bec:
{
J. Adkins,ilQ J. Dietrich, LMUS -
R. Gaston, PORTS J. Miller,ilQ S. Polston, PODP A. Rebuck Main,ilQ
. D. Sykes, PODP S. Toelle, IlQ R. Wells, llQ Concurrence line CRS / /97 l
l 1
El-1 1
+
f CORRECTIVE ACTION PI,AN
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- NUCLEAR CRITICALITY SAFETY PURPOSE:
f The purpose of this plan is to identify and derme the steps to increase the effectiveness of the NCS l
T :ogram and its support for the operatien of the plant.
l This plan will cover all aspects of the NCS Program and its function from the identification of fissile material _ operations through the implementation of the controls to ensure criticality safety. The plan i
is developed into short term and long term activities and objectives. The short term objectives are
- put in place to correct currently identified deficiencies and strengthen weaker areas of the NCS Program. The long term vbjeuives are developed to ensure continuous improvement in the NCS -
operations and to identify activitie-that must be implemented over the next two years to ensure that l
the NCS Program arid its operation are continuously improving in technical excellence to support the Portsmouth Oaseous Diffusion Plant.
+
S110RT-TERM IMPLEMENTATION ACTIVITIES j
1.
Review and Deld walkdown of all NCSAs will be performed. Prior to any walkdowns of the l
NCSAs, there will be a team review of the NCSA to ensure accuracy and completeness. The team review will consist of an NCS Engineer, the NCSA Owner, a representative from the labor union with " hands on" knowledge of the process / equipment, and a System Engineer.
NCSA Owners will review each NCSA/NCSE in the respective buildings for compliance with the NCS requirements and for accurate and complete description of the fisalle material operation (i.e., a description in the NCSA). The NCSA Owner's walkdowns should be done by teams in order to ensure higher quality walkdowns. Where possible, the team should be comprised at a minimum of an individual who is very familiar with the operation and may have been involved in the initial walkdown, and an individual who is independent of the specific operation and therefore can look at things with a fresh point of view.
The walkdowns shall be done in a documented fashion with a complete list of deficiencies identified and supplied to the NCS Organization. An NCS Engineer will accompany the team on the walkdown of the area.
2.
Verification of NCS requirement implementation in procedures and field acti"ities shall be done. The Quality Systems Group will conduct a sample review of NCS A requirements and l
the subsequent verification'of those requirements in the implementing procedures. This sampling shall be done in accordance with mil standards (or other standards) to ensure a high accuracy and a high confidence factor for successful implementation of the requirements.
i Failure to meet the criteria for acceptance will result in increasing the sample review size and in revisions to the NCSA and implementing procedures. The verification activities shall take l
place on selected NCSAs requested by the Nuclear Safety Manager. Thes: NCSAs will be selected to check the effectiveness of the corrective actions, r
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. 3.
- Conununication of stop work notifications shall be checked for effectiveness. The Quality Systems Group shall review the effectiveness of the notifications made by Operations to shut down various opentions due to cancellation of the Engineering Notices associated with the NCSAs. A complete review of all canceled Engineering Notices shall be done to enstde that the Document Control organization and functions worked properly in make each controlled copy holder and each effected organization aware of the canceled Engineering Notice and therefore the cancellation of that specific operation as defined by the Engineering Notice.
4.
A review board has been established by Nuclear Criticality Safety with representation from Operations, Work Control, Quality Assurance, and hiaintenance. This review board will function to review each new and revised NCSA/NCSE along with the implementing procedures arid the necessary eccessories to ensure proper implementation of all NCS requirements. Review board representative (s) will selectively accompany NCS Engineers and NCSA Owners on the field walkdowns, as well as have the NCS Engineers, NCSA Ov ners, and Procedure Writers present to the review board a step by-step, detailed explanation of each NCS requirement and how that requirement is being met in the field.
The review board will also ensure, through preseatation from the NCS Engineer. NCSA Owner, and Procedure Writers that each contingency is required and not redundant. This review will be done prior to submittal of the NCSA/NCSE and the implementing procedures to the PORC. This review will be done before signature approval of the NCSA/NCSE by the Nuclear Safety hianager.
Tiu xview board will be used for new NCSAs but may also be used to review the existing NCSAs with the same rigorous process. This review board will continue to exist until such time as the board believes that the technical quality of the NCSAs/NCSEs and accompanied procedures is adequate to allow the review process to be discontinued and reassigned to the NCS Subcommittee.
LONG-TE101 ACTIVITIES 1.
A vertical slice review of the NCS program will be done. This will be done by an outside NCS expert, a representative of the Portsmouth hianagement Team, and a representative of the Paducah hianagement Team. The review will select several NCSAs and review each and every aspect of the development through final implementation and use in the field. This review will identify deficiencies or areas of concem that need to be addressed for the long term. Once any deficiencies or areas of concern are addressed, the team will also do an extent of condition review or a horizontal slice to identify other NCSAs/how many other NCSAs may be affected by similar problems. The results of this review will be used to prepare, develop, and implement other long term activities to strengthen the NCS Program at PORTS.
t
The vertical slice review will cover at k ast the following aspects of the NCS program.
Effectiveness of the NCS Subcommittee Effectiveness of methodolog" for determining and documenting the fissile miterial e
operations that require an NCSA.
Effectiveness of training for making NCSAs effective.
e Effectiveness of NCS ownership training and NCS staff training.
implementation /Justifict. tion of differences in the CM programs at both sites.
e Effectivenes's of our lessons leamed program for NCS issues in the industry and at both plants.
implementation of a standards document for both sites so that the basis for criticality e
safety requirements are the same, Effectiveness of the periodic walkdowns by NCS and the building personnel, o
Effectiveness of the self assessment program for NCS.
o Development of a trending program for NCS pioblems.
EfTectiveness of NCS/0PS communications during drafting of NCS As.
2.
A review of PORTS NCSAs and PGDP NCSAs will be done t^ ens.. that there is consistency for similar fissile operations. In cases where there is not complete consistency, the basis for the difference will be documented.
Approval:2%
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a Nuclear Safety 6Mnager Date
/$ s obelO Engineering Manager #
Date