ML20202G326
| ML20202G326 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 02/01/1999 |
| From: | Toelle S UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Pederson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 70-7002-98-208, GDP-99-0020, GDP-99-20, NUDOCS 9902050114 | |
| Download: ML20202G326 (10) | |
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r USEC A Global En ergy Comparty
. February 1,1999 GDP 99-0020 i
Ms. Cynthia Pederson Director, Division of Nuclear Material Safety l
U. S. Nuclear Regulatory Commission m
Region III 801.Warrenville Road -
Lisle, Illinois 60532-4351 Portsmouth Gaseous Diffusion Plant (PORTS)
Docket No. 70-7002 Portsmouth Nuclear Criticality Safety Program - Quarterly Status Report
Dear Ms. Pederson:
1 contains the quarterly status report for the Portsmouth Nuclear Criticality Safety (NCS)
Program Corrective Action Plan (CAP) for the period October 30,1998, through January 20,1999.
In United States Nuclear Regulatory Commission (NRC) Inspection Report 98-208, dated December 18,1998, NRC identified an Inspector Followup Item (IFI) 98-208-01 concerning the NCS CAP.
. Specifically, the NRC noted that some of the completed tasks (e.g., I and 2) are related to
' " completion of other tasks and that this information is not adequately represented in status reports."
Enclosure I has been revised to address this IFI.
A' meeting to discuss revisions to the NCS CAP was conducted on January 25,1999. At this meeting, the United States Enriclunent Corporation (USEC) informed the NRC that the primary focus 'of the NCS CAP is completion of Tasks 3 and 5, which involve the upgrading of Nuclear Criticality Safety Approvals and ~ raluations (NCSA/Es), monitoring the implementation of the
. NCS A/Es in the field by the Safety, Safeguards and Quality organization, and completion of the AQ-j
- NCS Classification.' USEC also informed the NRC that the 54 existing Priority 1 NCSA/Es are being developed into 40 upgraded NCSA/Es. Therefore, USEC will submit Revision 5 of the NCS j
CAP to NRC by March 26,1999, to reflect the current ongoing work, provide an updated list of Priority 1 NCSA/Es, and delete those tasks which have been completed.
Additionally, at the meeting on January 25,1999, USEC infonned the NRC of USEC's determination that certain shutdown and abandoned equipment at PORTS was not addressed in an NCSA/E. USEC informed the NRC that we are preparing a plant site NCSA/E for this equipment, but that the NCSA/E has not been included within the scope of the NCS CAP. USEC recognizes that the current NCS CAP is not clear on the process for handling emergent work and the criteria for determining whether revised or new NCSA/Es should be covered under the NCS CAP. Thi: will be clarified in
/ the revision to the NCS CAP.
6903 Rockledge Drive Bethesda. MD 20817-1818 050005 Telephone 301-564 3200 Fax 301-564-3201 http1/www.usec.com
.Y902r)50114 N Dfg{ 7
.th, KY Portsmouth, OH Washington, DC PDR 4 DOCK 07007002h C
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Ms. Cynthia Pederson -
February '1,1999 GDP 99-0020, Page 2 i contains the regulatory commitments in this submittal. If you have any questions concerning this submittal, please contact Peter J. Miner at (740) 897-2710.
Sincerely, 5, k l
Steven A. Toelle ~
-Nuclear Regulatory Assurance and Policy Manager E
Enclosures:
As stated
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NRC Document Control Desk /
NRC Resident Inspector-PGDP & PORTS NRC Project Manager-PORTS
- NRC Special Projects Branch DOE Regulatory Oversight Manager k ;.
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GDP 99-0020 Page 1 of 7 January 1999 Quarterly Status Report of the PORTS Nuclear Criticality Safety Program Corrective Action Plan i ~
I.
Purpose To convey the status of the tasks in the Nuclear Criticality Safety (NCS) Corrective Action Plan (CAP).
II.
Scope This report documents the results of a review of the NCS CAP. This review evaluated the adequacy and effectiveness of the Plan and the products of the Plan with respect to scope, implementation, prioritization, and. scheduling. Also considered and incorporated are the findings from Safety, Safeguards and Quality (SS&Q) assessments of the CAP (refer to Task i
17 of the Plan).Section IV," Details," describes the subject, status and the results of USEC's review.
III.
Executive Summary Two tasks in the NCS CAP were scheduled to be completed during this reporting period (i.e.,
Tasks 12 and 25). These tasks were completed on schedule. A total of twenty-four tasks have been completed, as scheduled, and four tasks remain to be completed. Of the tasks outstanding, only one (Task 3, NCSA/E Upgrade Project) involves physical v..tk. Three tasks (i.e.,5,17, and 18) are assessments and evaluations.
All Task 3 Priority 1 NCSA'E documents have been developed and nearly all are peer
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reviewedi The remaining work on Task 3 regarding Priority 1 NCSA/Es is predominately i
focused on the NCS Subcommittee reviews of NCSA/E documents and the development of their associated procedures.
- IV..
Details i
The following information is grouped according to the tasks listed on Table 2 of the NCS CAP, Revision 4. The cut-off date for this report is January 20,1999.
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GDP 99-0020 Page 2 of 7 Task 1 Facility Review of Nuclear Criticality Safety Target Date: 12/24/97 Assessments / Evaluations (NCSA/E)
I Complete. The intent of this task was to review the implementation status of NCSAs and then document problems and develop corrective actions in accordance with the Problem Report process. Corrective action (Subtark 1.8) was to be accomplished in accordance with Task 3, NCSA Upgrade Project. The intent of Task I was achiems j
Task 2 Review of NCSA/Es Regarding Qualifications Target Date: 4/30/98 Complete. The intent of this task was to reevaluate the NCSA/Es, authored by engineers that were not properly q nlified. Corrective action (Subtask 2.7) was to be accomplished in accordance with Task 3, NCSA Upgrade Project.. Also Task 26, NCSA/E Calculation Review was performed to ensure that the proper calculations were flowed into and referenced in the NCSEs. The intent of Task 2 was achieved.
Task 3 NCSA/Es Upgrade Project TargetDate:See Below The following revised schedule was submitted to NRC in USEC letter GDP 98-0255, z.
dated November 13,1998:
Priority 1 NCSA/Es Complete PORC approval of Priority 1 NCSA/Es 03/19/99 Complete AQ-NCS classification 04/09/99 Complete procedures, training, and implementation 09/30/99 Priority 2 NCSA/Es Complete PORC approval of Priority 2 NCSA/Es 07/30/99 Complete A-Q-NCS classification 08/20/99
. Complete procedures, training, and implementation 03/03/09 Additional Reviews l
Complete AQ-NCS classification 05/19/00 Complete procedures, training, and implementation 05/18/01
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h GDP 99-0020 Page 3 of 7 L The foHowing table reflects the progress in completing this task:
m PRIPt[TYlNCSA/Es Activity Status as of Status as of t
1029/98 1a0/99 Approved andImplemented 7
8 Approved by PORC andawaiting 3
13 implementation ScheduledforPORCreview 20 4
Reviewed by NCSSubcommittee and 3
4 Being Preparedfor PORCReview Scheduledfor NCSSubcommittee 10 9
In Peer Review 8
2 StartedNCSEngineering Review 3
0 Total 54 40 The 54 existing Priority 1 NCSA/Es are being developed into 40 upgraded NCSA/Es i
to provide consistency across the plantsite. These have been combined as follows:
I 330_005 includes 330_006; PLANT 004 includes 342A001 and 343_001; PLANT 076 includes 342A004,342A005,343_003, and 344A003; PLANT 085 includes 342A002, 343_002, 344A001, 344A0ll, and PLANT 080; 710_009 includes 710_026; and PLANT 082 includes 343_005.
In addition, as resources which are working on the Priority 1 NCSA/Es become available, NCS engineering reviews are starting on the Priority 2 NCSA/Es. Of the 22 Priority 2 NCSA/Es, one has been PO.RC approved, one is scheduled for NCS Subcommittee review, and nine have started NCS engineering review. The
" Additional Reviews" committed to be performed under this task have not yet started. There are presently 125 NCSA/Es in this category.
Emergent work to revise existing or develop new NCSA/Es to support daily plant operations has not been included in the scope of this CAP (this includes the NCSA/E
- which is being written to address shutdown or abandoned equipment). There are
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numerous other NCSA/Es which have been revised or created outside the scope of r
the CAP.
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GDP 99-0020 Page 4 of 7
' Task 4 Enhance NCSA/E Training (Interim Process)
Target Date: 2/28/98 Complete.
Task 5 SS&Q Review ofImplementation Target Date:See Below Priority 1 NCSA/Es 12/15/99 Complete SS&Q review ofimplementation Priority 2 NCSA/Es 05/20/00 Complete SS&Q review ofimplementation On-going: Of the eight Priority 1 NCSA/Es upgrades that are completed and implemented, one had no changes and is in the process of being walked down. The other seven have been walked down and found to be properly implemented.
Completion of this task is dependent on prior completion of Task 3 above.
Task 6 Complete Comprehensive Root Cause Analysis Target Date: 2/28/98 Complete.
Task 7 Compare Applicable Industry Standards Target Date: 1/31/98 Complete. Long term programmatic enhancements, were completed under Task 12, Policy / Procedure Revision and Training. Subtask 7.5, Take any necessary immediate actions, and Subtask 7.6, Evaluate discrepancies for need for interim action, were e
- previously determined to be complete. However, based on the NRC observation discussed in IR 98-208, these subtasks were again reviewed and it was verified that no immediate nor interim actions were needed.
. Task 8 Vertical Slice Review Target Date: 5/31/98 Complete.
Task 9 Continuous Improvement Program Target Date: 1/31/98 Complete. The lessons learned program is ongoing.
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- l GDP 99-0020 Page 5 of 7 Task 10 Personnel Qualification Verification Target Date: 7/27/98 4j!
Complete. Subtasks 10.8 (upgrade procedures) and 10.9 (train and qualify NCS personnel) were performed in accordance with Task 12, Policy / Procedure Revision and Training.
Task 11 Outside/ Independent Assessments Target Date: 4/30/98 Complete. Lessons learned were processed as part of Task 9, Continuous
, Improvement Program. Two deficiencies were corrected as part of Task 7, Compare
' Applicable Industry Standards. Four procedure changes were processed as part of Task 12, Policy / Procedure Revision and Training.
Task 12 Policy / Procedure Revision and Training Target Date: 12/31/98 Complete: Procedure changes included:
XP2-EG-NS1031, Nuclear Criticality Safety XP2-EG-NS1032, NCS, Subcommittee to the PORC XP2-EG-NS 1033, NCS Murder Board Committee XP2-TR-TR1030, Conduct ofTraining XP4-EG-NS1001, NCS Evaluation and Approval XP4-EG-NS1025, NCS Response to Anomalous Conditions XP4-EG-NS 1035, Peer Technical Reviews of NCS A/Es XP4-EG-NSI 100, Nuclear Criticality Safety Calculations
. XP4-EG-NS I 102, NCS Personnel Qualifications (canceled)
POEF-LMUS-109, Training Development Administrative Guide for NCS Engineer Training Program Task 13 Revise Training Program for Site Personnel Target Date: 4/30/98 (Subtask 13.5)
Complete through subtask 13.5. The portion outstanding is the routine development of training modules and conducting the required training following the revision of each NCSA/E and implementing procedures. This is being tracked by the NCSA/E Implementation Team under Task 3, NCSA/E Upgrade Project.
Task 14
~ Corrective Action Program Enhancements Target Date: 6/30/98 Complete.
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GDP 99-0020 Page 6 of 7 Task 15 Configuration Management Program Target Date: 2/28/98 Enhancements 1
Complete.
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Task 16 Revise Assessment Programs Target Date: 10/30/98 9
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Task 17 -
Oversight of Plan' Implementation Target Date:' 4/30/99
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(Bi-monthly)
On schedule: The observations in the latest SS&Q bimonthly assessment, dated l'
November 30,1998, of the activities in the NCS Corrective Action Plan were considered as input to the discussions of specific tasks in this report.
. Task 18 Evaluation and Feedback Target Date:
Quarterly starting on 1/31/98 On schedule: This quarterly evaluation was performed and the results are included, as applicable,in this report.
Task 19 Evaluate Continued Use of Murder Board Target Date:
Not before 5/31/98 Complete.
Activity D.7 Response to Anomalous NCS Conditions Target Date: 2/11/98 Complete. Procedure changes were completed under Task' 12, Policy / Procedure Revision and Training.
! Activity D.8 NCS Oversight on the Operating Floors Target Date: 2/2/98 Complete.
Task 20 -
NCS Field Operational Assistants (FOA)
Target Date: 6/15/98 Complete. -
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GDP 99-0020 Page 7 of 7 I
Task 21 Fissile Material Operation (FMO) Identification Target Date: 10/23/98 Complete. Recent problem reports have identified a concern about the completeness of abandoned equipment FMO identification. To resolve this concern, a plantwide NCSA/E is being prepared to cover equipment that is abandoned in place.
Task 22 Compare SAR Chapter 5.2 to Applicable Target Date: 6/15/98 Industry Standards and the NCS program Complete. Long term programmatic enhancements were completed under Task 12, Policy / Procedure Revision and Training.
Task 23 NCS Short-Term Corrective Actions Target Date: Ongoing Complete.
Task 24 PEH Deposit Surveillance Tracking Target Date: 5/11/98 Complete.
Task 25 '
Compliance Plan Review -
Target Date: 11/30/98 Complete: The results of this review were provided to NRC in USEC letter GDP 98-0214 dated Octe:ber 9,1998. Addidonally, in USEC letter GDP 99-0002 dated January 19,1999, USEC committed to reopen Complicace Plan issues 8,9, and that portion of 23 which related to. AQ-NCS systems, and to submit Certificate Amendment Requests to NRC by February 25,1999.
Task 26 NCSA/E Calculation Review Target Date: TBD Complete. This task was completed before a target was established.
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~ GDP 99-0020 Page1of1 List of Commitments USEC will submit Revision 5 of the NCS CAP to NRC by March 26,1999, to reflect the current
- ongoing work, provide an updated list of Priority 1 NCSA/Es, and delete those tasks which have been completed. The revised NCS CAP will also address the process for handling emergent work
- h and the criteria for determining whether revised or new NCSA/Es should be covered under the NCS j
CAP.
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