ML20205R398
| ML20205R398 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 04/16/1999 |
| From: | Toelle S UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Paperiello C NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| GDP-99-0056, GDP-99-56, TAC-L32108, NUDOCS 9904220323 | |
| Download: ML20205R398 (11) | |
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USEC A ciod.: energy company April 16,1999 GDP 99-0056 Dr. Carl J. Paperiello Director, Office of Nuclear Material Safety and Safeguards Attention: Document Control Desk U.S. Nuclear Regulatory Commission Washington, I).C. 20555-0001 Paducah Gaseous Diffusion Plant (PGDP)
Doeket No. 70-7001 Certificate Amendment Request - Proposed Changes to the Quality Assurance Program Description - Response to NRC pequest for Additional Information (TAC.No. L32108)
Dear Dr. Paperiello:
The purpose of this letter is to respond to the NRC's March 18,1999 request for additional information (Reference 1) on USEC's February 12,1999 Certificate Amendment Request (CAR) regarding proposed changes to the Quality Assurance Program (QAP) Description (Reference 2).
USEC's response to the NRC information request is provided in Enclosure 1 to this letter. The
. proposed QAP pages have been revised as described in our question responses and are included in j. These revised QAP pages are replacement pages for those previously provided in Reference 2.
USEC has reviewed Enclosure 1 (Detailed Description of Change) and Enclosure 3 (Significa Determination) in our February 12,1999 CAR and has determined that the conclusions of these enclosures remain valid.
Any questions related to this subject should be directed to Steve Routh at (301) 564-3251. There are no new commitments contained in this submittal.
Sincerely, s.n.I.SA Steven A.Toelle Nuclear Regulatory Assurance and Policy Manager 9904220323 990416 7
i PDR ADOCK 07007001 C
PDR _
6903 Rockledge Drive, Bethesda, MD 208t7-1818 Telephone 301564-3200 Fax 301-564-3201 http://www.usec.com Offices in 1.ivermore, CA Paducah, KY Portsmouth. OH Washington, DC
Dr. Carl J. Paperiello April 16,1.999 GDP 99-0056, Page 2
References:
- 1. Letter from Yawar Faraz(NRC) to Mr. James N. Adkins (USEC),"Paducah and Portsmouth Gaseous Diffusion Plant: Quality Assurance Program Change--
Request for Additional Information (TAC Nos. L32108 and L32109)," March 18, 1999.
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- 2. Letter from Steven A. Toelle (USEC), to Dr. Carl J. Paperiello (NRC),"Paducah Gaseous DifTusion Plant (PORTS), Docket No. 70-7001, Certificate Amendment Request - Proposed Changes to the Quality Assurance Program Description,"
USEC Letter No. GDP 99-0008, February 12,1999.
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Enclosures:
- 1. United States Enrichment Corporation, Paducah Gaseous Diffusion Plant, Certificate Amendment Request, Proposed Changes to the Quality Assurance L
Program Description, Response to March 18,1999 NRC Request for Additional Information (TAC No. L32108)
- 2. Oath and Affirmation, Revised Quality Assurance Program Description Pages cc: Mr. Robert C. Pierson (NRC)
NRC Region 111 Office NRC Resident Inspector - PGDP NRC Resident Inspector-PORTS i
T Enclosure i GDP 99-0056 Page1of3 United States Enrichment Corporation Paducah Gaseous Diffusion Plant Certificate Amendment Request Proposed Changes to the Quality Assurance Program Description Response to March 18,1999 NRC Request for Additional Information l
(TAC No. L32108) j 1.
The first sentence in Section 2.4.3.1, item 2 has a proposed change that adds the words "or alternatives as described in Section 2.7.3.2" at the end of the sentence that addresses NQA-I-1989. Basic Requirement 4 of NQA-1-1989 requires: "To the extent necessary, procurement documents shall require Suppliers to have a quality assurance program consistent with the applicable requirements of this Standard."
j Section 2.7.3.2, items 3 through 6 provide acceptable alternatives. Ilowever,it ir not clear that the reference to Section 2.7.3.2 in Section 2.4.3.1, item 2 does not include Section 2.7.3.2, items 1 and 2 that are not acceptable alternatives. Clarify.
Resnonse i
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I The proposed change to QAP Section 2.4.3.1.3 has been revised to read as follows:
"3.
Procurement documents, for non-commercial grade items, require that the supplier q
implement a documented quality assurance program that is equivalent to the requirements of ASME-NQA-1-1989 or alternatives as described in Sections I
2.7.3.2.3 through 2.7.3.2.6. The procurement documents..."
2.
The proposed changes to Section 2.18.3.2, item 3.b of the QA Program and Section 2.18.3.2, item 4.b of the Appendix of the QA Program, which delete the term "onsite,"is acceptable. Ilowever,it is not clear how "USEC supervision" will be provided for services performed both on-site and off-site. Clarify.
Response
A contracted supplier may provide nuclear (Q, AQ, and AQ-NCS) services to USEC under either the supplier's USEC-approved quality assurance (QA) program or the USEC QA program.
When a supplier is contracted to perform work under the USEC QA program. USEC ensures that supplier personnel are adequately trained to perform the v>ork. As a minimum, supplier personnel are trained to the USEC QA program and the USEC implementing procedures that 1
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r G DP 99-0056 Page 2 of 3 are applicable to the scope of work. Training on other USEC procedures such as security, safety and health, work control, etc. is also provided as necessary for performing the work.
When a supplier is contracted to perfonn work under the USEC QA program and USEC implementing procedures, that work will normally be conducted at either the Paducah or Portsmouth site or at USEC headquarters. In these cases, USEC personnel will control the supplier's work using the same methods used to control USEC employees.
In some circumstances, the particular capabilities of a supplier can best be utilized at their own facilities or at a combination of their facilities and USEC's facilities. When this is the case and the work is being performed under the USEC QA program and implementing procedures, specific controls are provided in procurement documents (specifically, the Statement of Work) that describe how the contracted work will be controlled by USEC personnel. I)epending on the nature and duration of the work, these controls will include one or more of the fbilowing:
Pedodic visits to the supplier's site by USEC personnel to assess progress made and conforreance of the supplier to the USEC QA program and procedures.
Visits by scoplier personnel to USEC's facilities to demonstrate progress achieved at key milestones in the work.
Periodic conununications between supplier personnel and USEC personnel using phones, fax machines, electciic mail, or other methods as appropriate for the intended purpose.
Periodic surveillances of supplier activities by the USEC quality assurance organization to ensure compliance with the USEC QA program and procedures.
In addition to the above methods used during the performance of work, formal methods are also required for accepting supplier wmk products and documenting that acceptance.
As part of the implementation of this Certificate Amendment Request, the applicable USEC procedures will be revised to include the above supervisory / oversight controls.
GDP 99-0056 i
Page 3 of 3 El. Section 2.7.3.2, items 1 and 2 have changed " potential supplier's" to " supplier's." Section 2.7.3.2, Item 3 has the same change in the second line but not in the first line. For consistency, consider making the same change in the first line.
Resnonse The proposed change to QAP Section 2.7.3.2.3 has been revised to read as follows:
"3.
The supplier's technical and quality capability is determined by a direct.. "
E2. The organization referred to as "NIAC" in Section 2.7.3.2, item 4 should he better identified.
Response
The proposed change to QAP Section 2.7.3.2.4 has been revised to read as fbliows:
"4.
USEC reviews... audits (i.e., third party audits such as the Nuclear Industry Assessment Committee (NIAC), etc.). The review..."
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GDP 99-0056 Oath and Affirmation and Revised Quality Assurance Progam Description Pages (4 pages total)
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.,o DATil AND AFFIRMATION 1, Steven A. Toelle, swear and allirm that I am the Nuclear Regulatory Assurance and Policy Manager of the United States Enrichment Corporation (USEC), that I am authorized by USEC to sign and file with the Nuclear Regulatory Commission these revised Quality Assurance Program Description pages in support of a Certificate Amendment Request for the Paducah Gaseous Diffusion Plant, as described in USEC Letter GDP 99-0056, that I am familiar with the contents thereof, and that the statements made and matters set forth therein are true and correct to the best of my knowledge, information, and belief.
A S. 6.
If Steven A.Toelle t
on this 16th day of April,1999, the person signing above personally appeared before me,is known by me to be the person whose name is subscribed to within the instrument, and acknowledged that he executed the same for the purposes therein contained, in witness hereofI hereunto set my hand and official seal.
Rphin D. Johnson, Ng> Public
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State of Maryland, Nfontgomery County My commission expires June 1,2002
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l Quality Assurance Program - GDPs December 13,1998 Rev: 33 2.3.3.5 Design Changes Procedures for design change control are established to ensure the following:
1 1.
Changes to final designs, field changes, modifications, and nonconforming items dispositioned "use-as-is" or " repair" are justified, documented, and evaluated against criteria established by the Engineering Manager; 2.
Design documents, including changes thereto, are controlled in accordance vith Section 5 of Supplement 3 S-1 to NQA-1,1989 and Section 2.6 of this QAP. When a significant design change is found to be necessary because of an incorrect design, the design process and verification procedure are reviewed and modified as necessary; and 3.
Changes to the plant are evaluated and processed in accordance with the provisions of 10 CFR 76.68.
2.3.3.6 Design Interfaces Procedures for design interface control are established to ensure the following:
1.
Internal and external design interfaces are identified and controlled and design efforts are coordinated among participating organizations; 2.
The responsibilities for the preparation, review, approval, release, distribution, and revision of documents involving design interfaces are defined; and 3.
Design information transmitted across interfaces is documented and controlled in accordance with Supplement 3S-1. Section 6 of NQA-1,1989.
2.3.3.7 Design Documentation and Records Design documentation and records that provide evidence that the design and design verification processes were performed in accordance with this section are collected, stored, and maintained in accordance with Supplement 3S-1, Section 7 of NQA-1,1989 and Section 2.17 of this QAP.
l 2.4 PROCUREMENT DOCUMENT CONTROL 2.4.1 General A procurement document control system is established for Q items and related activities and services within the scope of this QAP as identified in Section 2.2. The procurement document control system is in accordance with ASME NQA-1,1989, Basic Requirement 4, and Supplement 4S-1. The procurement document control system ensures that applicable regulatory requirements, technical requirements, and QAP requirements are included or referenced in procurement documents for the 9
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l Quality Assurance Program - GDPs PROPOSED February 12,1999 RAC 98C075 (RO) evaluations of the suppliers technical and quality capabilities or history of satisfactory performance or the evaluation of the suppliers current quality records as determined and approved by the Engineering Manager and the Safety, Safeguards and Quality Manager. The Safety, Safeguards and Quality Manager is also responsible for developing and implementing procedures which meet the requirements of this section of the QAP.
The Production Support Manager provides support functions such as source verification or surveillance, receipt inspections, installation inspections, and review of procurement documents during receipt inspections. This manager is also responsible for developing and implementing procedures which meet the requirements of this section of the QAP.
The Engineering Manager is responsible for evaluation of suppliers' technical capabilities and for determining the methods of acceptance to be applied to purchased items and services. The Engineering Manager is also responsible for the approval of dispositions and technical evaluations for 1
supplier-generated nonconformances for items and services. The Engineering Manager is also responsible for providing measures which ensure the proper selection, application, methods of acceptance, and use of items.
The Central Procurement Director is responsible for purchasing activities and ensuring that items are procured from approved suppliers on the approved suppliers list when required.
l 2.7.3 Requirements The requirements of Sections 2.7.3.1 through 2.7.3.8 apply to services and non-commercial grade items. For commercial grade items, the requirements of Section 2.7.3.9 apply.
2.7.3.1 Procurement Planning Procedures are established to ensure the following:
1.
Procurement activities are planned and documented to assure a systematic approach to tLe procurement process.
2.
Procurement planning results in the documented identification of procurement methods and organizational responsibilities.
3.
Planning activities meet the requirements of Section 2 of Supplement 7S-1 to ASME NQA-1,1989.
2.7.3.2 Supplier Selection Procedores are established for the selection of suppliers. This selection shall be based on the i
evaluation of their capability to provide items or services in accordance with the requirements of procurement documents. Measures for evaluation and selection of procurement sources, and the results therefrom, shall be documented and shall include one or more of the following:
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