ML20203B987
| ML20203B987 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 02/04/1998 |
| From: | Yawar Faraz NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | John Miller UNITED STATES ENRICHMENT CORP. (USEC) |
| Shared Package | |
| ML20203B990 | List: |
| References | |
| TAC-L32051, NUDOCS 9802250027 | |
| Download: ML20203B987 (4) | |
Text
I o
' February 4 '1998 l
1 Mr James H. Miller
. Vice President, Production U. S. Enrichment Corporation 2 Democracy Center 8903 Rockledge Driva Bethesda, MD 20817 I
SUBJECT:
CERTIFICATE AMENDMENT REQUEST - PORTSMOUTH GASEOUS DIFFUSION PLANT CLARIFICATION AND COMPLIANCE PLAN COMPLETION DATE EXTENS!ON RELATED TO MEASURING AND TEST EQUIPMENT (TAC NO.
L32051)
Dear Mr. Miller:
Enclosed is a copy of the Compliance Evaluation Report prepared to support the amendment of Certificate of Compliance GDP-2. A copy of the Notice of Amendment, which has been forwarded to the Of fice of the Federal Register for publication, is also encirsed. This notice provides the opportunity for the public to petition tot review of the decision in accordance with 10 CFR Part 76, Subpart C. Final action on your amendment req'40st will not be taken until af ter the time allowed fot requesting review of the Director's Decision is over. If fou have any questions regarding this action, I can be reached at (301) 41 ti 8113.
Sincerely, Original Signed By Yawar H. Paraz, Project Manager Enrichment Section Special Projects Branch Division of Fuel Cycle Safety hO and Safeguards, NMSS h
Dockat 70-7002 Certificate GDP-2 hhh h
cc:
Mr. Steven A. Toelle, USEC Mr. Randall M. DeVault, DOE
Enclosures:
- 1. Compliance Evaluation Report il H l' W H E H
- 2. Notice of Amendment
' DISTRLBMTION: (Control No. 2005)
Docket 70 7002 N"*8 PU8tte KO'Bnen, Ritt -
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NUCLEAR REGULATORY COMMISSION t
WASHINoToN. o.C. 20$55-0001 February 4, 1908 DOCKET:
70 7002 CERTIFICATE HOLDER:
Unitad States Enrichment Corporation Portsmouth Gaseous Diffusion Plant Portsmouth, Ohio
SUBJECT:
COMPLIANCE EVALUATION REPORT: APPLICATION DATED OCTOBER 21,1997, CLARIFICATION AND COMPLIANCE PLAN COMPLET!ON D ATE EXTENS!ON RELATED TO MEASURING AND TEST EQUIPMENT (M&TE)
BACKGROUND On Octobe 21,1997, United States Enrichment Corporation (USEC) submitted a certificate amendment request for the Portsmouth Geseous Diffusion Plant (PORTS) to extend a completion date and to clarify commitments related to M&TE made in issue 24 entitled
" Maintenance Program" of the " Plan for Achieving Compliance w;th Nuclear Regulatory Commission Regulations at the Portsmouth Gaseous Diffusion Plant" DOE /ORO 2027/R3 (Compliance Plan).
The PORTS Quality Assurance Program (QAP) requires safety related structures, systems and components (SSCs) to be designated as Q, AQ and AQ NCS according to their area of application and degree of importance to safety. The PORTS OAP and the Safety Analysis Report designate SSCs as O and AQ, and AQ-NCS, which are relied upon for non-criticality safety and criticality safety, respectively. The PORTS QAP requires USEC to apply almost all of the quality assuiance (QA) requirements contained in ASME NOA 1-1989 entitled
" Quality Assurance Program Requirements for Nuclear Facilities" to Q and AQ-NCS SSCs.
For AQ SSCs, which in comparison to Q and AQ-NCS SSCs, are less important from a safety stand point, only a portion of the ASME NOA-1-1989 requirements are applicable.
USEC designates non.=afety related SSCs as NS.
K Currently, the Plan of Action and Schedule (POAS) section of Issue 24 of the Compliance Plan implies that M&TE used for Q, AQ and AQ-NCS SSCs are also designated as Q, AQ and AQ-NCS, respectively. The clarification contained in USEC's amendment request, deletes this implication, in addition to the clarificatiom USEC has also included a request to extend the completion date for revising the calibration program to meet the more formal o
requirements for AQ SSCs from December 31,1997, to June 30,1998. According to USEC, the existinC December 31.1997, date in the POAS of Compliance Plan issue 24 is inconsistent with two other actions contained elsewhere in the same POAS. In addition, according to USEC, Issue 22 entitled " Maintenance Program" of the Paducah Gaseous Diffusion Plant (PGDP) ComplianM Plan identifies June 30,1998, as the date for enmpleting similar corrective actions which address similar noncompliances.
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The fif th bullet in the POAS Section of the PORTS Compliance Plan currently states:
"... Revise the measuring and test equipmert calibration program to meet the more formal requirements. The scheduled completion dates for these actions are December 31,1996, for Q measuring and test equipment, February 28,1997, for AQ NCS measuring and test equipment; and December 31,1997, for other AQ measuring and test equipment...
Develop and implemer.t individual calibration procedures for Q, AQ NCS, and other AQ SSCs.. "
USEC has proposed to change these cornmitments to state:
.. Revise the measuring and test equipment and process equipment caliL.stion programs to meet the more formal requirements. The schedu'ed completion dates for these actions are December 31,1996, for Q SSCs, February 28,1997, for AQ.
NCS SS':s; and June 30,1998, for other AQ SSCs...
Develop and implement individual calibration procedures for Q, AQ NCS, and other AQ SSCs and for M&TE...."
The PORTS Compliance Plan was prepared by the Department of Energy (DOE) and approved by DOE and NRC. A Memorandum of Understanding between the NRC and DOE, which appeared in the E:tdenti Bnmster on November 5,1997, requires DOE's review for approval of changes made by USEC to conditions and commitments of the Compliance Plan prior to NRC's review for approval. As such, the NRC forwarded USEC's certificate amendment request to DOE on November 7,1997, for their soview and approval. By letter dated Decanber 8,1997. DOE recommended unconditional approval of USEC's request.
For USEC to be in verbatim compience with their certificate, the NHC would have had to grant the amendment before December 31,1997. Recognizing the time consuming administrative constrainta involved in NRC's review of PORTS certificate amendment requests, by letter dated December 17,1907, USEC requested the NRC to exercise enforcement discretion frcm January 1,1998, until the NRC staff issues its final decision concerning the request. By letter dated December 30,1997, the NRC informed USEC that even though a literal violation would exist from January 1,1998, until the NRC staff issues its final decision, the NRC will not cite the violmion.
DISCUSSION USEC's certificate amendment request involves two changes; a clarification that M&TE should not be designated as Q, AQ arid AQ-NCS, and an extsnsion of the completion date for revising the calibration program for M&TE used for AQ SSCs from December 31,1997, to June 30,1998.
The PORTS QAP requires USEC to control M&TE used for Q, AQ-NCS and AQ SSCs in recordance with Basic Requirr. ent 12 and Supplement 12S-1 of ASME NOA-1,1989. The NRC staff has determined tha6 shese QA requirements are sufficient to ensure the required
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3 accuracy and reliability for M&TE and that identifying M&TE as Q, AQ NCS and AQ is not warranted.
As stated above, the POAS of Issuo 24 of the PORTS Compliance Plan requires USEC to revise the calibration program for M&TE used for AQ SSCr by De <: ember 31,1996. The same POAS in two other locations requires USEC to revise the calibration procedures, and develop and conduct instrument calibration training for AQ SSCs by June 30,1998. In addition, the PGDP Compliance Plan Issue 22 entitled ' Maintenance Program /* which addresses maintenance noncompliances similar to those for PORTS, requires USEC to develop and implement calibration procedures for AQ SSCs and for the associatM M&TE and to provide the associated training by Ju'. 30,1998. Recognizing that the existing calibration procedures cod training for AQ SS, and the associated M&TE will have less formclity and rigor than specified in the PORTS Safety Analysis Report, DOE, who initially developed and approved the PORTS and PGDP Compliance Plans, recommended unconditional approval of USEC's request. Also, considering that the completion date for issue 23 of the PORTS Complianco Plan involving identification of AQ SSCs was October 1, 1997, the NRC staff concludes that for USEC to adequately upgrade the existing procedures and training for calibration of AQ SSCs and for the associated M&TE, a completion date of June 30,1998, is reasonable as long as all related interim regulatory commitments contained in the Justification for Continued Operation section of Issue 24 are maintained.
ENVIRONMENTAL REVIEW lssuance of the requested amendment to the Portsmouth Certificate of Compliance (GDP-2),
to amend the POAS of issue 24 of the Compliance Plan, is subject to the categorical exclusion provided in 10 CFR 51.22(c)(19) and wil! not have a significant impact on the human environment. Therefore, in accordance with 10 CFR 51.22(b), neither an environmental assessment nor an environmentalimpact statement is required for the proposed action.
CONCLUS10R Based on the discusion provided above, the NRC staff has datermined that identifying M&TE as 0, AQ-NCS and AQ is not warranted. In addition, the NRC staff has determined that the requested extension of the completion date for upgrading the existing procedures and training for calibration of AQ SSCs and associated M&TE, from December 31,1997, to June 30,1998, is appropriate and consistent with the completion dates provided elsewhere in the POAS sections of the PORTS and PGDP Compliance Plan issues concerning the Maintenance Program and, therefore, acceptable. The NRC staff recommends approval of this amendment. Region ill staff have no objection to this proposed action.
Princioal Contributor Yawar Faraz DISTRIBUTION-Docket 704002 NRC FILE CENTER PU8uC NMSS r/t NMSS Dr. Off. r/f FCSS r!f SP8 r/f K'08nen. Rm CCon WSchwenk. FCO8 PHaand. Rm DHartland. Am JJacobson. Rm GTAMD12CER POR b
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