ML20206T430
| ML20206T430 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 05/14/1999 |
| 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) |
| Shared Package | |
| ML20206T438 | List: |
| References | |
| GDP-99-0039, GDP-99-39, NUDOCS 9905240155 | |
| Download: ML20206T430 (12) | |
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,USEC A Global Energy Co'mpany May 14,1999 GDP 99-0039 Dr. Carl J. Paperiello Director, Office of Nuclear Material Safety and Safeguards Attention: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Portsmouth Gaseous Diffusion Plant (PORTS)
Docket No. 70-7002 Certificate Amendment Request - Reopening Compliance Plan Issues 8,9 and 23
Dear Dr. Paperiello:
In accordance with 10 CFR Part 76.45, and as committed to in References 5 and 6, the United States l
Enrichment Corporation (USEC) hereby submits a request to the Nuclear Regulatory Commission (NRC) for amendment to the certificate of compliance for the Portsmouth, Ohio Gaseous Diffusion T
Plant. This certificate amendment request involves a change to The Plan for Achieving Compliance with NRC Regulations at the Portsmouth Gaseous Diffusion Plant (Compliance Plan) for the following issues:
Issue 8, Description of Noncompliance, Justification for Continued Operation, and Plan of Action and Schedule, regarding development ofNuclear Criticality Safety Approvals / Nuclear J
Criticality Safety Evaluations (NCSAs/NCSEs), in accordance with NRC requirements, for j
all Fissile Material Operations (FMOs);
Issue 9, Description of Noncompliance, Justification for Continued Operation, and Plan of Action and Schedule, regarding implementation of the NCSAs/NCSEs for FMOs; Portions ofIssue 23, Description ofNoncompliance, Justification for Continued Operation, and Plan of Action and Schedule, regarding: 1) review of all NCSAs/NCSEs to identify AQ-ij NCS items (items which support the nuclear criticality double contingency principle),
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identification and documentation of the designated design requirements and system boundaries, including support systems required for performance of the intended safety function,' and verification of the implementation of these requirements; and 2)
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implementation of flowdown of commitments from the Technical Safety Requirements, the Safety Analysis Report, and other plans and programs to procedures and training.
O 9905240155 990514 PDR ADOCK 07007002 C
- PDR, 6903 Rockledge Drive. Bethesda, MD 20817-1818 Telephone 301-564-3200 Fax 301-564-3201 http://www.usec.com Offices in Livermore. CA Paducah. KY Ponsmouth, OH Washington. DC M I8
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- May 14,1999 j
GDP 99-0039, Page 2 As discussed in References 1 through 6, these issues are being reopened to address deficiencies that were identified during the implementation of these issues.
The proposed Compliance Plan changes have been reviewed and approved by the Department of
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Energy (DOE) as documented in References 7,9 and 10.
Enclosures 2,3 and 4 to this letter provide a detailed description and justification for the proposed changes. Enclosure 5 is a copy of the revised Compliance Plan pages and removal / insertion
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instructions associated with this request. Enclosure 6 contains the basis for USEC's determination that the proposed changes associated with this certificate amendment request are not significant. This I
amendment should become effective seven days from issuance.
In GDP 98-0264, USEC indicated that we would provide the subject CAR to NRC within two weeks following receipt of DOE's approval of the proposed CP changes necessary to reopen CP issues 8, 9 and 23. Based on the April 14,1999 date of the DOE letter approving the CP changes, the CAR was scheduled to be submitted to NRC by April 28. 'USEC notified Mr. Yawar Faraz, NRC Project Manager for PORTS, on April 27 and again on May 6 that submittal of the subject CAR to NRC would be delayed until May 14,1999. Mr. Faraz was informed that the delay was necessary to ensure consistency between the subject CAR and Revision 5 of the NCS CAP (Reference 8), which was submitted to NRC on April 30,1999, and to resolve internal comments.
There are no new commitments made in this submittal. Any questions related to this subject should be directed to Mark Smith at (301) 564-3244 or Russ Wells at (301) 564-3245.
i Sincerely, s.9.
1' Steven A.Toelle Nuclear Regulatory Assurance and Policy Manager
Enclosures:
- 1. Oath and Affirmation
- 2. Compliance Plan Issue 8 - Detailed Description of Change
- 3. Compliance Plan Issue 9 - Detailed Description of Change
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- 4. - Compliance Plan Issue 23 - Detailed Description of Change
- 5. Removal /InsertionInstructions
- 6. SignificanceDetermination
- cc: Robert C. Pierson (NRC)f NRC Region III Office 7
' NRC Resident Inspector-PGDP NRC ResidentInspector-PORTS i
Randall M. DeVault(DOE) i l
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GDP 99-0039 Page1of1 OATH AND AFFIRMATION I, Steven A. Toelle, swear and affirm that I am 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 this Certificate Amendment Request for the Portsmouth Gaseous Diffusion Plant addressing revisions to Compliance Plan Issues 3,9 and 23 contained in USEC Letter GDP 99-0039, 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.
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I Steven A.Toelle l
On this 14th day of May,1999, the authorized individual 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.
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J Pp6in D. Johnson,No Public State of Maryland, tgomery County My commission expires June 1,2002 L
t GDP 99-0039 Page1of3 United States Enrichment Corporation (USEC)
Certificate Amendment Request 3
Compliance Plan Issue 8 Detailed Description of Change Compliance Plan Issue 8 contained commitments to complete formal NCSAs and NCSEs for all current operations (including handling, storage, processing and transportation) involving uranium enriched to I wt % or higher 2nU and 15 grams or more "U, and properly document and approve 2
the NCSAs/NCSEs in accordance with the Nuclear Criticality Safety (NCS) program requirements contained in the approved Certificate. Procedural changes to resolve administrative noncompliances in the NCS program were also to be completed. This submittal proposes to reopen Compliance Plan Issue 8 due to reviews conducted after the transition from Department of Energy regulatory oversight to Nuclear Regulatory Commission (NRC) oversight, which found deficiencies in NCSEs and operations at PORTS for which either (1) the nuclear criticality safety evaluations (NCSEs) are incomplete or formal documentation is unavailable or (2) double-contingency or other basis for acceptance has not been fully documente.d in an NCSE. These reviews also found that abandoned equipment remaining in leased areas was not included in the NCS program.
- Justification of the Change NRC Inspection Report (IR)97-206 identified several non-cited violations and program weaknesses in the' area of NCS documentation and compliance with administrative controls.
USEC acknowledged, in the response to IR 97-206 (Reference 1), inadequacies in NCSAs/NCSEs and i
failures to properly flow NCSA/NCSE requirements into implementing procedures, and committed to develop a corrective action plan to improve the performance of the NCS Program and its support
'l to the operation of PORTS. The NCS Corrective Action Program (CAP) was submitted to NRC on November 10,1997, and subsequently revised on December 22,1997, January 30,1998, April 30, 1998, and April 30,1999 (References 2 through 6).
Additional discrepancies with the PORTS NCS Program were also documented in IR 97-013, which I:
identified a cited violation involving noncompliances in the NCS program. Additionally, NRC IR
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98-204 reviewed closure evidence for Compliance Plan Issue 8 and concluded that the Issue was not adequately completed by USEC. Subsequently, per References 2 through 6 of the cover letter, USEC agreed to reopen this CP issue.
To date, USEC has completed most of the tasks of the NCS CAP. Task 3 deals with the upgrade of the NCSAs, completion of the AQ-NCS Classification, and flowdown into plant implementing procedures. USEC is currently committed to complete this task by May 18,2001. The reasons for
' the length of time to complete this effort result from three major areas; availability of expertise, j
inadequate understanding of the full scope of the upgrade effort, and AQ-NCS reclassification. This is discussed in further detail in USEC letter to NRC dated November 13,1998, GDP 98-0255. In i
the area of availability of expertise, USEC found that staff augmentation required to perform i
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GDP 99-0039 Page 2 of 3 United States Enrichment Corporation (USEC)
Certificate Amendment Request Compliance Plan Issue 8 Detailed Description of Change NCSA/NCSE reviews, walkdowns, and revisions took longer than expected due to an initial shortage
- of qualified contract personnel that was subsequently rectified.
The area related to understanding the scope of the upgrade effort was investigated more fully, and it was found that there is a high degree of complexity to the upgrade of NCSAs and subsequent flowdown to implementing procedures. There are over 1800 approved procedures for operations and maintenance, of which approximately 425 implement controls from NCSAs. Currently, those 425 procedures have over 4000 specific references to NCS controls. It was found that a NCSA revision typically results in over 13 procedure revisions, making the configuration management of the process complex, difficult, and time consuming, since individual NCSAs are approved at different points in time. The level of detail needed to clearly implement NCSA controls into action steps of procedures was found to be a time-consuming yet important process to ensure proper and consistent field implementation of the controls.
The third area of AQ-NCS reclassification resulted from the action plan to address NRC Notice of Violation 98-206-02, wherein USEC committed to review new or upgraded NCSAs/NCSEs and reclassify SSCs in accordance with revised criteria for classification of AQ-NCS SSCs. This reclassification of SSCs requires activities such as preventative maintenance and instrument calibrations to be conducted in accordance with approved procedures which, in some cases, have not yet been developed. Additionally, the approved suppliers list and the stores system have to be upgraded for the reclassified AQ-NCS SSCs. Reclassification cannot be completed until each new or revised NCSA has been completed and approved by PORC.
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' Abandoned equipment has been identified and placed under management control while the 1
associated NCSA and NCSE documentation is completed to define the controls necessary for this
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equipment and to formally implement these controls.
The Description of Noncompliance, Justification for Continued Operation, and the Plan of Action and Schedule in the reopened Compliance Plan Issue 8 have been revised from the original Compliance Plan Issue. These revisions result from updating the information contained in the Issue to better reflect the current status of noncompliance and actions required to restore compliance, and removal ofitems that have been confirmed as complete during the self-assessment of Compliance j
Plan issues conducted by USEC.
The extended schedule for completion of this Compliance Plan Issue isjustified by the completion f
of all of the programmatic Tasks of the NCS CAP. In addition, Senior-qualified NCS personnel j
conducted peer reviews of existing NCSAs/NCSEs, and confirmed the technical adequacy of the j
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i' GDP 99-0039 Page 3 of 3 United States Enrichment Corporation (USEC)
Certificate Amendment Request Compliance Plan Issue 8 Detailed Description of Change documents. USEC also identified the NCSAs that resulted in the majority of NRC Bulletin 91-01
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event reports, reviewed and corrected them, and conducted site training. Additionally, a "NCS Stand-down" was conducted to improve personnel awareness and compliance with NCS controls.
As a result, a significant reduction in event reports was realized. Other high-priority NCSAs were reviewed by teams of NCS and plant personnel, who confirmed the adequacy of existing NCSA controls.
References:
j 1.
Letter from James B. Morgan (USEC) to United States Nuclear Regulatory Commission -
Attention: Document Control Desk, " Response to inspection Report (IR) 70-7002/97206 Notice of Violation (NOV)," USEC Letter GDP-97-2026 dated October 29,1997 2.
Letter from James B. Morgan (USEC) to United States Nuclear Regulatory Commission -
Attention: Administrator, Region III, "Portsmouth Gaseous Diffusion Plant (PORTS),
Docket No. 70-7002, Completion of a Regulatory Commitment," USEC Letter GDP-97-2030 dated November 10,1997 3.
Letter from George P. Rifakes (USEC) to Cynthia Pederson (NRC), " Transmittal of the l
Revised Corrective Action Plan for the Portsmouth Nuclear Criticality Safety Program,"
l USEC Letter GDP-97-0216 dated December 22,1997 I
4.'
Letter from Steven A. Toelle (USEC) to Cynthia Pederson (NRC), "Portsmouth Nuclear Criticality Safety Program Revised Corrective Action Plan - Quarterly Status Report," USEC Letter GDP-98-0013 dated January 30,1998 5.
Letter from Steven A. Toelle (USEC) to Cynthia Pederson (NRC), "Portsmouth Nuclear Criticality Safety Program Revised Corrective Action Plan - Quarterly Status Report," USEC Letter GDP-98-0094 dated April 30,1998 6.
Letter from J. Morris Brown to Cynthia D. Pederson, " Submittal of Revision 5 of the PORTS Nuclear Criticality Safety (NCS) Corrective Action Plan (CAP) and NCS Program Quarterly Status Report," GDP 99-2020 dated April 30,1999.
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GDP 99-0039 Page 1 of 3 United States Enrichment Corporation (USEC)
Certificate Amendment Request
. Compliance Plan Issue 9 Detailed Description of Change Compliance Plan Issue 9 contained commitments to review all NCSAs in order to identify and track the designated Nuclear Criticality Safety (NCS) conditions, specifications, and controls and to verify the full implementation of requirements for double contingency controls in plant operating procedures by February 28,1997. This submittal proposes to reopen Compliance Plan Issue 9 due to reviews which found that implementation ofNCS conditions, specifications, and controls in plant operating procedures is deficient.
Justification of the Change NRC Inspection Report (IR)97-203 identified a violation where multiple failures to comply with administrative criticality controls specified in various NCSAs were found. NRC IR 97-206 also identified a violation related to a failure to establish a Technical Safety Requirement for singly contingent operations, and several non-cited violations and program weaknesses in the area of NCS documentation and compliance with administrative controls. USEC acknowledged, in the response to IR 97-206 (Reference 1), inadequacies in NCSAs/NCSEs and failures to properly flow NCSA/NCSE requirements into implementing procedures, and committed to develop a corrective action plan to improve the performance of the NCS Program and its support to the operation of PORTS.
The NCS Corrective Action Program (CAP) was submitted to NRC on November 10,1997, and subsequently revised on December 22,1997, January 30,1998, April 30,1998, and April 30,1999 (References 2 through 6).
Key elements of the NCS CAP related to CP Issue 9 consisted of walkdowns of existing NCSAs in each building where fissile material operations are performed to identify and correct deficiencies; a prioritized NCSA/NCSE upgrade project which included revisions to implementing procedures, and an upgraded training program for site personnel who implement NCSAs/NCSEs.
Additional discrepancies with the PORTS NCS Program were also documented in IR 97-013, which identified a cited violation involving noncompliances in the NCS program. Additionally, NRC IR 98-204 reviewed closure evidence for Compliance Plan Issue 9 and concluded that the Issue was not adequately completed by USEC. Subsequently, per References 2 through 6 of the cover letter, USEC agreed to reopen this CP issue.
To date, USEC has completed most of the tasks of the NCS CAP. Task 3 deals with the upgrade of the NCSAs and flowdown into plant implementing procedures. USEC is currently committed to
- complete this Task by May 18,2001. The reasons for the length of time to complete this effort result from three major areas; availability of expertise, inadequate understanding of the full scope of the 1
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GDP 99-0039 Page 2 0f 3 United States Enrichment Corporation (USEC)
Certificate Amendment Request Compliance Plan Issue 9 Detailed Description of Change upgrade effort, and AQ-NCS reclassification. This is discussed in further detail in USEC letter to NRC dated November 13,1998, GDP 98-0255. In the area of availability of expertise, USEC found -
I that staff augmentation required to perform NCSA/NCSE reviews, walkdowns, and revisions took
- longer than expected due to an initial shortage of qualified contract personne
- that was subsequently
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rectified.
i The area related to understanding the scope of the upgrade effort was investigated more fully, and it was found that there is a high degree of compicxity to the upgrade of NCSAs and subsequent flowdown to implementing procedures. There are over 1800 approved procedures for operations and maintenance, of which approximately 425 implement controls from NCSAs. Currently, those 425 procedures have over 4000 specific references to NCS controls. It was found that a NCSA revision typically results in over 13 procedure revisions, making the configuration management of the process complex, difficult, and time consuming, since individual NCSAs are approved at different points in time. The level of detail needed to clearly implement NCSA controls into action steps of procedures was found to be a time-consuming yet important proce:s to ensure proper and consistent field implementation of the controls.
The third area of AQ-NCS reclassification resulted from the action plan to address NRC Notice of Violation 98-206-02, wherein USEC committed to review new or upgraded NCSAs/NCSEs and i
reclassify SSCs in accordance with revised criteria for classification of AQ-NCS SSCs. This reclassification of SSCs requires activities such as preventative maintenance and instrument calibrations to be conducted in accordance with approved procedures which, in some cases, have not yet been developed. Additionally, the approved suppliers list and the stores system have to be upgraded for the reclassified AQ-NCS SSCs. Reclassification cannot be completed until each new or revised NCSA has been completed and approved by PORC.
Abandoned equipment has been identified and placed under management control while the associated NCSA and NCSE documentation is completed to defme the controls necessary for this equipment and to formally implement these controls. The as-found condition will exist for a significantly shorter period of time than the remainder of the noncompliance identified in this issue.
The Description of Noncompliance, Justification for Continued Operation, and the Plan of Action and Schedule in the reopened Compliance Plan Issue 9 have been revised from the original Compliance Plan Issue. These revisions result from updating the information contained in the Issue L
to better reflect the current status of noncompliance and actions required to restore co.mpliance, and removal ofitems that have been confirmed as complete during the self-assessment of Compliance Plan issues conducted by USEC.
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GDP 99-0039 Page 3 of 3 i
United States Enrichment Corporation (USEC)
Certificate Amendment Request Compliance Plan Issue 9 Detailed Description of Change The extended schedule for completion of this Compliance Plan Issue is justified by the activities completed under other tasks of the NCS CAP. Senior-qualified NCS personnel conducted peer reviews of existing NCSAs/NCSEs, and confumed the technical adequacy of the documents. USEC also identified the NCSAs that resulted in the majority of NRC Bulletin 91-01 event reports, reviewed and corrected them, and conducted site training. Additionally, a "NCS Stand-down" was I
conducted to improve personnel awareness and compliance with NCS controls. As a result, a significant reduction in event reports was realized. _ Other high-priority NCSAs were reviewed by i
teams of NCS and plant personnel, who confirmed the adequacy of existing NCSA controls.
References:
1.
Letter from James B. Morgan (USEC) to United States Nuclear Regulatory Commission -
Attention: Document Control Desk, " Response to Inspection Report (IR) 70-7002/97206 Notice of Violation (NOV)," USEC Letter GDP-97-2026 dated October 29,1997 2.
Letter from James B. Morgan (USEC) to United States Nuclear Regulatory Commission -
Attention: Administrator, Region III, "Portsmouth Gaseous Diffusion Plant (PORTS),
- Docket No. 70-7002, Completion of a Regulatory Commitment," USEC Letter GDP-97-2030 dated November 10,1997 3.
Letter from George P. Rifakes (USEC) to Cynthia Pederson (NRC), " Transmittal of the Revised Corrective Action Plan for the Portsmouth Nuclear Criticality Safety Program,"
USEC Letter GDP-97-0216 dated December 22,1997 4.
Letter from Steven A. Toelle (USEC) to Cynthia Pederson (NRC), "Portsmouth Nuclear Criticality Safety Program Revised Corrective Action Plan - Quarterly Status Report," USEC Letter GDP-98-0013 dated January 30,1998 5.'
Letter from Steven A. Toelle (USEC) to Cynthia Pederson (NRC), "Portsmouth Nuclear Criticality Safety Program Revised Corrective Action Plan - Quarterly Status Report," USEC Letter GDP-98-0094 dated April 30,1998 6.
Letter from J. Morris Brown to Cynthia D. Pederson, " Submittal of Revision 5 of the PORTS
- Nuclear Criticality Safety (NCS) Corrective Action Plan (CAP) and NCS Program Quarterly Status Report," GDP 99-2020 dated April 30,1999.
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GDP 99-0039 L
Page1of3 United States Enrichment Corporation (USEC) 1 l
Certificate Amendment Request 7
Compliance Plan Issue 23 L
Detailed Description of Change -
I Compliance Plan Issue 23 contained commitments to complete the development and implementation of the Configuration Management Program. Elements of the program to be developed and implemented included identification and documentation of augmented quality-nuclear criticality safety (AQ-NCS) items to be included in the Configuration Management Program; review of the Nuclear Criticality Safety Approvals (NCSAs) to identify AQ-NCS items (items which support the nuclear criticality double contingency principle) and identify,' document, and implement design requirements and system boundaries (including support systems); and implementation of flowdown of commitments from the Technical Safety Requirements, the Safety Analysis Report, and other -
plans and programs to procedures and training. This submittal proposes to reopen Compliance Plan Issue 23 due to reviews conducted following the transition from Department of Energy regulatory oversight to Nuclear Regulatory Commission (NRC) oversight, which noted deficiencies in the identification of safety boundaries for AQ-NCS items. These reviews also identified that the flowdown of commitments from TSRs, the Safety Analysis Report, and other plans and programs of the PORTS Certification Application into procedures and training was incomplete.
Justification of the Change
- 1. AQ-NCS Items NRC Inspection Report (IR)97-203 identified a violation involving a failure to identify NCS safety boundary components and systems needed to assure criticality safety as AQ-NCS items. NRC IR 98-204 also identified SSCs being relied upon for NCS control that wem not adequately identified as AQ-NCS, and concluded that the corrective action taken by USEC in response to the IR 97-203 violation was ineffective to prevent recurrence, and the portion of the Issue dealing was AQ-NCS items was not adequately completed with appropriate
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rigor and formality. NRC IR 98-206 identified a violation wherein SSCs relied on in NCSAs p
for double contingency were not identified as components relied on for criticality safety in the Boundary Definition Manual or classified as AQ-NCS items.
- USEC responded to the violation cited in IR 98-2% (reference USEC letter GDP-98-2027)
. by revising' the procedural guidance for classifying SSCs required to meet the double j
contingency principle as AQ-NCS and committing to review new or upgraded r
NCSAs/NCSEs resulting from Task 3 of the NCS Corrective Action Plan (CAP) and t
reclassifying SSCs that need to be classified as AQ-NCS.
4 This commitment was integrated into Task 3 of the NCS CAP. Specifically, Task 3 of the NCS CAP requires that all NCSA/Es be reviewed to determine they have the proper AQ-
GDP 99-0039 l
Page 2 of 3 United States Enrichment Corporation (USEC)
Certificate Amendment Request Compliance Plan Issue 23 Detailed Description of Change NCS classification. Where reclassification of SSCs is required as a result of this effort, this task will require that the associated procedures be revised, training completed, and the revised procedures implemented. This effort is currently scheduled to be completed for all NCSA/Es by May 18,2001.
- 2. Flowdown of Commitments to Procedures and Training Flowdown of commitments from the TSRs, SAR, Programs and Plans of the PORTS Certification Application into procedure and training was initiated in June 1996 and was accomplished in phases according to the schedules identified in Compliance Plan Issues 21 and 30, with completion of the bulk of the flowdown effort by December 31,1997, and completion of the last phase for maintenance procedures on June 30,1998. Over 8000 commitments were identified and flowed down into one or more site procedures or controlled documents. An electronic database containing the commitments was established and linkage of commitments to flowdown documents was accomplished. The database of commitments has been maintained current with changes made to the Certification Application in accordance with 10 CTR 76.68.
During the phased flowdown process, the Procedures Upgrade Program was being conducted in accordance with Issue 30 Plan of Action and Schedule. Problem Report PR-PTS-97-4304 was initiated on April 30,1997, and identified that commitment flowdown was not properly transferred from the old procedure to its upgraded version due to a lack of guidance governing procedure initiation or procedure revision that ensured review of commitments and update of linkage to flowdown documents. Corrective actions included guidance to procedure preparers to ensure identification of commitments in new or revised procedures, which was effective for procedures upgraded in the latter half of 1997. However, revisions to Nuclear Regulatory Affairs and Training and Procedures procedures that institutionalized and integrated the flowdown process in a more rigorous manner was not accomplished until the latter half of1998.
.A Safety, Safeguards and Quality audit of the Environmental Protection Program in June 1998 identified inconsistencies between the commitment database and the flowdown documents. The root cause for the inconsistencies was inadequate procedural guidance for identifying and maintaining commitments in flowdown documents and relaying changes resulting from the procedure change process to update linkages between commitments and procedures.
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GDP 99-0039 Page 3 of 3 L
United States Enrichment Corporation (USEC)
Certificate Amendment Request Compliance Plan Issue 23 j
Detailed Description of Change
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Flowdown program deficiencies have also impacted the procedures program, in that some
- procedures were identified as containing commitments, but were not classified as regulatory in accordance with SAR Section 6.11.4.1. The periodic review of these procedures was also not conducted in a timely manner, USEC letter GDP 99-0002 dated January 19,1999, subsequently informed NRC of this -
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- deficiency and committed to reopen this portion of Compliance Plan Issue 23.
The extended schedule for completion of this portion of Compliance Plan Issue 23 isjustified
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based on the extensive procedure upgrade program and incorporation of commitments that i
was realized during the initial flowdown effort. The flowdown confirmation effort to date has confirmed that the predominant fmdings have been related to lack of annotation of commitments in flowdown documents. If deficiencies are found where the commitment was l
not flowed to an applicable document, a problem report will be issued and the impact on '
operability will be determined. Thus, the flowdown confirmation effort will result in a more comprehensive and complete linkage between Certification Application commitments and l
flowdown documents, ensure that commitments are not inadvertently deleted from procedures, and ensure that flowdown documents are properly categorized as regulatory domments if they contain Certification Application commitments. This effort is currently scheduled to be' completed by March 30,2001.
The Description of None'ompliance, Justification for Continued Operation, and the Plan of Action and Schedule for the reopened Compliance Plan Issue 23 have been revised from the original 3
Compliance Plan Issue. These revisions result from updating the information contained in the Issue to better reflect the current status of noncompliance and actions required to restore compliance, and removal ofitems that have been confirmed as complete during the self-assessment of Compliance Plan issues conducted by USEC.
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