ML20206T439

Proposed Revs to Plan for Achieving Compliance with NRC Regulations at Portsmouth Gaseous Diffusion Plant

ML20206T439
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant
Issue date:	05/14/1999
From:	UNITED STATES ENRICHMENT CORP. (USEC)
To:
Shared Package
ML20206T438	List: ML20206T430 ML20206T439
References
ZAR-990514, NUDOCS 9905240157
Download: ML20206T439 (19)

Text

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GDP 99-0039 15 Pages l

l Proposed Certificate Amendment Request Portsmouth Gaseous Diffusion Plant Letter GDP 99-0039 Removal / Insertion Instructions Remove Pages Insert Pages Plan for Achieving Compliance with NRC Regulations j

at the Portsmouth Gaseous Diffusion Plant Table of Contents Table of Contents Pages iii/ iv Pages lii/ iv Issue 8(R)

Pages 1-3 Issue 9(R)

Pages 1-5 i

Issue 23(R)

Pages 1-4 I

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i 9905240157 990514 PDR ADOCK 07007002 C

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Issue 8(R), Page 1

' Nuclear Criticality Safety Approval Documents (Reopened)

REQUIREMENTS 10 CFR 76.35(a)(5), (6), and (7) "He application for an initial certificate of compliance must include the information identified in this section. (a) A safety analysis report which must include the following information:... (5) A training program that meets the requirements of f 76.95; (6)

A description of equipment and facilities which will be used by the Corporation to protect health and minimize danger to life or property (such as handling devices, working areas, shields, measuring and monitoring instruments, devices for the treatment and disposal of radioactivs effluent and wastes, storage facilities, provisions for protection against natural phenomena, fire protection systems, criticality accident alarm systems, etc.); (7) A description of the management controls and oversight program to ensure that activities directly relevant to nuclear safety and J

safeguards and security are conducted in an appropriately controlled manner that ensures protection of employee and public health and safety and protection of the national svurity interests."

10 CFR 76.85 "The Corporation shall perform an analysis of potential accidents and consequences to establish the basis for limiting conditions for operation of the plant."

10 CFR 76.87(c)(3) "(c) Appropriate references to established procedures and/or equipment to address each of the following safety topics must be included in technical safety requirements:...

(3) Criticality prevention."

COMMITMENTS i

Source: Safety Analysis Report

5. Nuclear Safety Programs 5.2 Nuclear Criticality Safety [NCS) 5.2.2 Program Elements

' 5.2.2.3 Process Evaluation and Approval [Rev. 31,4/14/99]

"Each operation involving uranium enriched to 1 wt. percent or higher "8U and 15 g or more

' of usU is evaluated for NCS prior to initiation. The operation and related NCS requirements are documented in a NCSA [ Nuclear Criticality Safety Approval]. The evaluation is documented in a NCSE [ Nuclear Criticality Safety Evaluation). De evaluation and approval process is governed by written procedures....

When a NCSA is needed for a particular operation, the organization responsible for performing the operation completes a NCSA request form (Request for Criticality Safety Evaluation). - This documents the operating organizations's request for NCS evaluation of the operation....

The NCSA is prepared based on the results of the NCSE, and it documents the conditions of approval (i.e., NCS requirements) for the operation. The conditions of approval include the process conditions which must be maintained to meet the double contingency principle or preserve the documented basis for criticality safety and restrict the modes of operation to those which have PROPOSED RAC 99 X0015,5/14/99

Issue 8(R), Page 2 Nuclear Criticality Safety Approval Documents been analyzed in the NCSE.... The requirements to be included in operating procedures and

' posting's are identified....

l The NCSA/NCSE process provides assurance that operations will remain suberitical under both normal and credible abnormal conditions."

DESCRIPTION OF NONCOMPLIANCE Compliance Plan Issue 8 contained commitments to complete formal Nuclear Criticality Safety Approvals (NCSAs) and Nuclear Criticality Safety Evaluations (NCSEs) for all current operations (including handling, storage, processing, and transportation) involving uranium enriched to 1 wt

% or higheru5U and 15 grams or more "5U, and properly document and approve the NCSAs and NCSEs in accordance with the Nuclear Criticality Safety (NCS) program requirements contained in the approved Certificate. Procedural changes to resolve administrative noncompliances in the I

NCS program were also to be completed. Reviews conducted after the transition from Department of Energy regulatory oversight to Nuclear Regulatory Commission (NRC) oversight 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 documented in an NCSE. These reviews also found that abandoned equipment remaining in leased areas was not included in the NCS program. A comprehensive NCS Corrective Action Plan (CAP) was developed to correct NCS program weaknesses.

j Issue 8R incorporates commitments of the comprehensive NCS CAP into the PORTS Compliance Plan. The status of the NCSA and NCSE upgrades is available at the plant for NRC inspection.

l JUSTIFICATION FOR CONTINUED OPERATION Prior to the transfer of regulatory authority to the NRC, the corrective actions of Compliance Plan Issue 8 concerning the completion of NCSAs and NCSEs for the NCS Program were completed. The essential provisions of Compliance Plan Issues 8 and 9 were to complete l

formalized NCSAs and NCSEs, flow the requirements of the approvals down into operating

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procedures, and fully implement and verify the required controls. During the same interval of time, i

the facility was introducing a new procedural system that emphasized verbatim compliance with l

procedures. As the NCSAs went into practice, problems were identified with the implementation L-of some NCSA requirements. In a small number of cases there were also problems identified with

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the content of NCSA or NCSE. When problems were identified, management controls were utilized to take appropriate action, up to and including stop work, to preserve the operation within f

its analyzed safety envelope. For example, abandoned equipment has been put under management control while the associated NCSA and NCSE documentation is completed defm' ing the controls l

' necessary for this equipment.

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The core of the NCS program is the identification of the need for NCS controls and the implementation of the controls to maintain the required nuclear criticality safety. The effort to

' upgrade the NCS program was completed in late 1996 and early 1997. The deficiencies found to date have not identified problems that would invalidate the safety of operations governed by the l

RAC 99-X0015,5/12/99 PROPOSED 3

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Nuclear Criticality Safety Approval Documents Issue 8(R), Page 3 NCSAs,. On the basis of valid NCSAs and NCSEs being in place, and interim management controls

' applied where required, the facility has been, and is, maintained in a safe state. The same conditions will be maintained during the completion of the enhancements outlined in the NCS CAP l

l and Plan of Action and Schedule described below.

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PLAN OF ACTION AND SCIIEDULE All new operations (including handling, storage, processing and transportation) that require NCS approval will have properly documented and implemented NCSAs and NCSEs that have been approved in accordance with the NCS program requirements contained in the approved Certificate prior to startup. As part of the NCS CAP formal NCSAs and NCSEs will be upgraded / completed l

for all current operations involving uranium enriched to 1 wt. % or higher U and 13 grams or 235 235U by May 18,2001, and will be properly documented and approved in accordance with I

more the NCS program requirements contained in the approved Certificate.

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SUMMARY

OF REQUIREMENTS, COMMITMENTS, AND NONCOMPLIANCES l

Issue: Nuclear Criticality Safety Approval Documents l

Code of Federal Regulations Part Title 10 76.35(a)(5), (6), and (7); 76.85; 76.87(c)(3)

Application Commitment Section Safety Analysis Report 5.2.2.3 Technical Safety Reauirements 3.9.1.c 3.11 Application Noncompliance Statement Section

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Safety Analysis Report 5.2.4.1, 5.2.4.2, 5.2.4.6, 5.2.4.9, 5.2.4.10, 5.2.4.11 NRC Conunitments Letter l

Portsmouth NCS Program Revised GDP 98-0255 l

Schedule l

Proposed Criteria for Reopening GDP 98-0264 l

Compliance Plan issues (Revised)

Reopening of Compliance Plan Issues GDP 99-0002 Compliance Plan Status Report GDP 99-0004 l

l Portsmouth Nuclear Criticality Safety GDP 99-0020 Program Quarterly Status Report PROPOSED RAC 99-X0015, $/14/99

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e Issue 9(R), Page 1 l

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' Nuclear Criticality Safety ApprovalIniplementation (Reopened)

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REQUIREMENTS o-10 CFR 76.35(a)(5), (6), and (7) "The application for an initial certificate of compliance must include the information identified in this section. (a) A safety analysis report which must include the following information:... (5) A training program that meets the requirements of f 76.95; (6) A description of equipment and facilities which will be used by the Corporation to protect health and minimize danger to life or property (such as handling devices, working areas, shields, measuring and monitoring instruments, devices for the treatment and disposal of radioactive effluent and wastes, storage facilities, provisions for protection against natural phenomena, fire protection systems, criticality accident alarm systems, etc.); (7) A description of the management controls and oversight program to ensure that activities directly relevant to nuclear safety and safeguards and security are conducted in an appropriately controlled manner that ensures protection of employee and public health and safety and protection of the national security interests."

10 CFR 76.87(c)(3) "(c) Appropriate references to established procedures and/or equipment to address each of the following safety topics must be included in technical safety requirements:...

(3) Criticality prevention."

10 CFR 76 (in general)-A number of sections (including those related to safety analysis, TSRs, and emergency planning) have implications for nuclear criticality safety to the extent that they address such issues as safety limits and controls.

COMMITMENTS Source: Safety Analysis Report

5. Nuclear Safety Programs j

5.2 Nuclear Criticality Safety [NCS) 5.2.2 Program Elements 5.2.2.3 Process Evaluation and Approval [Rev. 31,4/14/99]

"The requirements to be included in operating procedures and postings are identified....

Once approved by the General Manager, the NCS controls, limits, evaluation assumptions, and safety items are verified to be fully implemented in the field. This verification process is performed by the operations organization and Criticality Safety personnel. The documentation of this verification process is maintained as a quality record along with the NCSE [ nuclear criticality safety evaluation]. The manager or designee of the operating group then signs the NCSA, indicating acknowledgment and agreement with the limits and controls specified. The NCSA is then issued as a permanent or temporary document.

First-line management of the operating organization is responsible for implementing, through training and procedures, the conditions delineated in the NCSA. Operational aids such as postings, labels, boundaries for fissile material operations, and fissile material movement guidelines are provided as specified in the NCSA. First-line management ensures postings and labels are prepared and verifies that they are properly installed as required by the'NCSA. The procedures are prepared PROPOSED RAC 99-X0015,5/14/99

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Issue 9(R), Page 2 Nuclear Criticality Safety ApprovalImplementation l

or modified to incorporate NCSA requirements. First-line management is responsible for ensuring l

the employees understand the procedures and understand the NCS requirements before the work begins."

5.2.2.6 Procedure Requirements [Rev. 2,1/19/%)

" Operations to which NCS pertains shall be governed by written procedures or job task checklists. These procedures or checklists contain the appropriate NCS con'rols for processing, storing, and handling of fissile material. The NCSA requirements which require employee actions shall be incorporated into the procedure.... The NCSA requirements are incorporated into the appropriate procedures or job task checklists as required by the NCS evaluation and approval procedure."

5.2.2.7 Posting and labeling Requirements [Rev. 2,1/19/%]

"NCS limits and controls for areas, equipment, and containers are presented through the use of postings and labels as specified in the approved NCSAs and procedures. Postings and labels are proposed, reviewed, and approved during the NCSA review and approval process.... Approved NCSAs specify the wording for the postings. Labels are prepared in accordance with the plant NCS procedures and used as required by NCSAs."

5.2.2.8 Change Control [Rev. 4, 7/26/%]

"The CM [ Configuration Management] Program applies to NCS,... because a change to a l

system, structure, or component (SSC) controlled by CM may require a NCS approval....

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' Functional and physical characteristics of operations controlled for NCS are described in NCSAs and NCSEs.... If an item is relied on for the criticality safety of an operation, it will be identified through the work control process as an NCS SSC [ structure, system, or component], and l

Cri:icality Safety approval is required before implementing the change.... [M]odifications to I

controlled operations are evaluated and approved prior to implementation."

l 5.2.2.9 Operation Surveillance and Assessment [Rev. 4,7/26/96]

I "In order to ensure that the NCS program is properly established and implemented, USEC utilizes walk-throughs, assessments, and audits.

NCS walk-throughs of facilities that may contain fissile matenal operations are performed by Criticality Safety personnel to determine the adequacy ofimalamantation of NCS requirements and to verify that conditions have not been altered to adversely affect NCS....

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[A]ssessments include the inspection of facility modifications and changes, operating

- procedures, and compliance with NCSAs....

Identified deficiencies are documented and corrected according to the problem reporting system described in Section 6.9 of this SAR and Section 2.18 of the Quality Assurance Plan."

i!II' PROPOSED

}i RAC 99-X0015,5/12/99 i i i

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Nuclear Criticality Safety Approval Implementation Issue 9(R), Page 3 DESCRIPTION OF NONCOMPLIANCE Compliance Plan Issue 9 contained commitments to review all Nuclear Criticality Safety Approvals (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 operrting procedures. Reviews have found that implementation of NCS conditions, specifications, and controls in plant operating procedures is deficient. A comprehensive NCS Corrective Action Plan (CAP) for correction of the NCS weaknesses has been developed.

Issue 9R is opened to address deficiencies in the implementation of NCSAs that exist as a result of inadequate completion of the original Issue 9 Plan of Action and Schedule and incorporates commitments of the comprehensive NCS CAP into the PORTS Compliance Plan.

JUSTIFICATION FOR CONTINUED OPERATION PORTS was originally designed and built to nuclear criticality safety requirements established for highly enriched uranium (greater than 90 percent enrichment). The emphasis was on design of equipment that would provide physical controls for safe geometry. In mid-1993, USEC took over the management and operation of PORTS under the oversight of the Department of Energy (DOE).

On March 3,1997, regulatory authority transferred to the NRC. The plant has operated under USEC for almost 6 years without a criticality incident.

During the development of the Certification Application for PORTS, the NCS program was recognized as requiring substantial upgrades including the preparation of NCSAs and Nuclear Criticality Safety Evaluations (NCSEs) containing NCS conditions, specifications, and controls.

NCSEs form the basis for NCSA requirements. Preparation of approximately 200 NCSAs and l

NCSEs was initiated when the Application was submined in 1995. Because these NCSAs and NCSEs would not be fully implemented prior to the approval of the USEC Application for Certification of PORTS, these NCSAs and NCSEs and their implementation were included in the i

Compliance Plan. The completion and implementation of the NCS program upgrades was originally scheduled for December 31,1996, and subsequently revised to February 28,1997.

l Consistent with the original schedule, PORTS completed all identified NCSAs and NCSEs and flowed the NCSA information to procedures that implemented them prior to March 3,1997.

Operations have continued with these NCSAs and supporting NCSEs. Subsequent to implementation, problems were found with operations under some of the NCSA requirements.

NRC reviews of closure documentation found instances of incomplete or poor evidence supporting closure of the Compliance Plan issues related to the NCS program. This condition resulted in the initiation of an NCS CAP to improve the quality of the NCSAs and NCSEs and provide more rigorous documentation and implementation through procedures. Reviews completed as part of the NCS CAP found no significant safety deficiencies. Where operations could not be performed under the current requirements for NCS, these operations are prohibited from being performed. The NCSAs and NCSEs put in place at the time of transition to regulation by the Nuclear Regulatory Commission establish an adequate safety basis for the nuclear criticality safety of PORTS.

. Systematic searches of the plant have been performed to ensure identification of equipment which might have had previous exposure to enriched uranium, to confirm the uranium content L

l PROPOSED RAC 99 X0015,5/14/99

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Issue 9(R), Page 4 Nuclear Criticality Safety Approval Implementation through NDA measurements, and to ascertain what controls were already applied to the equipment.

'Any as-found conditions are controlled under compensatory measures until criticality safety analyses have been completed and formal controls implemented. The as-found condition, primarily involving abandoned equipment, will exist for a significantly shorter period of time than the remainder of the noncompliance identified in this issue.

NCS issues under the Compliance Plan involve the flowdown of requirements to procedures, the implementation of the procedures on the operating floor and the completion of the identification of structures, systems and components that are to be controlled as AQ NCS. The majority of the NCS activities to be completed (upgrade of existing NCSAs and NCSEs and implementing the requirements in the field) are improvements that facilitate operations and prevent NCS violations oflow safety significance.

Therefore, continued operations are justified in the interim period on the basis that all fissile l

material operations of the plant are conducted under known, documented, and controlled criticality safe conditions that provide for adequate safety.

PLAN OF ACTION AND SCHEDULE A program is in place to review all NCSAs in order to identify and track the designated NCS conditions, specifications, and controls and to verify their full implementation. Particular attention is being focused on ensuring consistency between each NCSA and the operation including implementing procedures and work-site postings. Implementation improvements for all NCSAs and NCSEs, which consist of SSC reclassification, procedure revision and implementation, and training, will be completed by May 18,2001 as part of the NCS CAP.

If a new or revised NCSE identifies the need for modifications to the existing plant configuration, affected activities will be curtai!cd and will not be restarted until either (1) the plant configuration is modified or (2) the activity is modified so that it can be performed safely in the current configuration. If the plant configuration or activity is modified, the Plant Operations i

Review Committee will review the proposed modification prior to its resumption to verify that the i

activity, as modified, can be performed safely.

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RAC 99-X0015, $/12/99 PROPOSED s,

Nuclear Criticality Safety Approval implementation Issue 9(R), Page 5 S'UMMARY OF REQUIREMENTS, COMMITMENTS, AND NONCOMPLIANCES l

Issue: Nuclear Criticality Safety ApprovalIrnplementation 1

Code of Federal Regulations Part

)

Title 10 76.35(a)(5), (6), and (7); 76.87(c)(3);

76 (general)

Application Commitment Section Safety Analysis Report 5.2.2.3, 5.2.2.6, 5.2.2.7, 5.2.2.8, 5.2.2.9, 6.9 Technical Safety Requirements 3.9.1.c, 3.11 Quality Assurance Prograrn Appendix A-Section 1 Application Noncompliance Statement Section Safety Analysis Report 5.2.4.1, 5.2.4.2, 5.2.4.3, 5.2.4.4, 5.2.4.5, 5.2.4.7. 5.2.4.11, 5.2.4.12 NRC Commitments Letter Portsmouth NCS Program Revised GDP 98-0255 Schedule Proposed Criteria for Reopening GDP 98-0264 Compliance Plan Issues (Revised)

Reopening of Compliance Plan Issues GDP 99-0002 Compliance Plan Status Report GDP 99-0004 Portsmouth Nuclear Criticality Safety GDP 99-0020 Program Quarterly Status Report l

PROPOSED RAC 99-X0015,5/14/99 i

i Issue 23(R), Page 1

' Plant Changes and Configuration Management (Reopened) 1 REQUIREMENTS 10 CFR.76.68(a) "(a) The Corporation may make changes to the plant or to the plant'r, operations as descritxxi in the safety analysis report without prior Commission approval provlied all the provisions of this section are met:

. (1) The Corporation shall conduct a written safety analysis which demonstrates that the changes would not result in undue risk to public health and safety, the common defense and security, or to the environment.-

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(2) The changes must be authorized by responsible management and approved by a safety

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review committee.

l (3) The changes may not decrease effectiveness of the plant's safety, safeguards, and security programs.

(4) The changes may not involve a change in any condition to the certificate of compliance.

(5) The changes may not involve a change to any condition to the approved compliance plan.

)

(6) The changes may not involve an unreviewed safety question."

10 CFR 76.93 "The Corporation shall establish, maintain, and execute a quality assurance program satisfying each of the applicable requirements of ASME NQA-1-1989, ' Quality Assurance Program Requirements for Nuclear Facilities,' or satisfying acceptable alternatives to the applicable requirements. The Corporation shall execute the criteria in a graded approach to an extent that is commensurate with the importance to safety."

COMMITMENT Source: Safety Analysis Report

6. Organization and Operating Programs 6.3 Plant Changes and Configuration Management [Rev. 31,4/14/99]

USEC has committed to ensuring that the review and approval of changes to the plant'or plant's operation are accomplished in a controlled manner. This commitment includes the use of a plant Configuration Management Program to control changes and to maintain the plant configuration as described in the application, including the Safety Analysis Report and the Technical Safety Requirements.

l DESCRIPTION OF NONCOMPLIANCE I'

i Compliance Plan Issue 23 contained commitments to complete the development and I

. 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 nucear criticality double contingenc'y principle) and identify, document, PROPOSED RAC 99-X0015, $/14/99 u

Issue 23(R), Page 2 Plant Changes and Configuration Management and implement design requirements and system boundaries (including support systems); and implementation of flowdown of commitments from the Technical Safety Requirements (TSRs), the Safety Analysis Report, and other plans and programs to procedures and training. Reviews conducted following the transition from Department of Energy regulatory oversight to Nuclear l

Regulatory Commission (NRC) oversight noted deficiencies in the identification of safety l

boundaries for AQ-NCS items. These reviews also identified that the flowdown of commitments from Section 3.0, Administrative Controls, of the TSRs, the SAR, and other plans and programs of the PORTS Certification Application into procedures and training was incomplete.

Issue 23R incorporates commitments in the Nuclear Criticality Safety Corrective Action Plan (CAP) and the subsequent update of procedures and training into the PORTS Compliance Plan.

The extent of noncompliance for the Configuration Management Program elements is given below.

1.

Program Management. All augmented quality-nuclear criticality safety (AQ-NCS) items to be included in the scope of the Configuration Management Program have not been identified and documented. In addition, the flowdown of commitments from TSR Section 3.0, Administrative Controls, the SAR, and other plans and programs contained in the application to the plant procedures and training is not complete.

2.

Design Requirements. The review of the NCSAs to identify AQ-NCS items (items which support the nuclear criticality double contingency principle); identification and documentation of the designated design requirements and the system boundaries, including support systems required for performance of the intended safety functions; and verification of the implementation of these requirements has not been completed.

l JUSTIFICATION FOR CONTINUED OPERATION 1.

Program Management. A Configuration Management Program procedure has been developed and issued. This procedure provides management direction, establishes consistent concepts and terminology, and defines the scope of the program, identifie: key roles and responsibilities, identifies organizational and programmatic interfaces, and provides a foundation for lower level implementing procedures.

The plant configuration has been baselined for safety using the Application Safety Analysis I

Report, Process Hazards Analysis, existing Nuclear Criticality Safety Approvals, and other i

regulatory assessments to identify structures, systems, components, and design features for i

safety utilizing the process described in Application Section 6.3.5.3, with the exception of safety features required to support the double contingency principle. As AQ-NCS items are identified in the NCSA upgrade process through the comprehensive NCS Corrective Action Plan (CAP), as-built configurations will be updated, system walkdowns will be performed, and safety functions will be documented. The Q, AQ-NCS, and AQ system boundary definition manuals, which are maintained on-site, contain a current listing of the AQ-NCS items and the associated boundary definitions. As additional AQ-NCS items are identified, these manuals will be revised accordingly.

The flowdown of facility-specific TSR requirements to procedures has been reverified as having been accomplished satisfactorily. The flowdown of Administrative Control TSR requirements accomplished as part of the corrective action for the original Issue 23 RAC 99-X0015,542/99 PROPOSED i

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Plant Changes and Configuration Management Issue 23(R), Page 3 noncompliance is in the reverification process. A listing of existing commitments has been established. The listing of commitments is maintained current with changes made to the Certification Application in accordance with 10 CFR 76.68. Guidance has been developed and I-given' to implementing document preparers to ensure identification and flowdown of commitments in new or revised implementing documents.

2.

Design Requirements. Effons are ongoing to identify, verify, and hment the baseline for.

the AQ-NCS items resulting from the Nuclear Criticality Safety Approvals (NCSAs) and Nuclear Criticality Safety Evaluations (NCSEs) upgrade project. All requests for engineering services involving plant changes are reviewed and approved by the Change Control Board (CCB) which includes criticality safety expertise, as required. The CCB determines if PORC review and approval is required. Until the necessary AQ-NCS design requirements are identified,~ verified, and documented, design requirements will be recovered and/or reconstituted on a case-by-case basis as needed to support the review and approval of plant changes.

The above discussion regarding the ongoing effons to identify, field verify, and document additional AQ-NCS items within the system boundaries; and the verification / correction of the flowdown of commitments from the TSRs, the SAR, and other plans and programs provides justification that the plant can continue to operate safely.

PLAN OF ACTION AND SCHEDULE The additional actions required to complete the' development and implementation of the AQ-NCS portion and the flowdown of commitments portion of the Configuration Management Program and the schedule for completion of these actions are given here.

1.

Program Management Identify and document all additional AQ-NCS items resulting from the NCS CAP, including system boundaries and support systems required for performance of the intended safety function, to be included in the scope of the Configuration Management Program. The scheduled completion date for these actions is May 19, 2000.

Reverify and correct deficiencies in the flowdown of commitments from TSR Section 3.0, Administrative Controls, the SAR, and other plans and programs contained in the Application to implementing documents and trainhq. The scheduled completion date for this action is March 30,2001.

2.

Design Requirements Review all Nuclear Criticality Safety Approvals and Nuclear Criticality Safety Evaluations to identify additional AQ-NCS items (items which support the nuclear criticality double contingency principle); to identify and document the designated design requirements and system boundaries, incbding support systems required for performance of the intended safety function; and to verify the implementation of these requirements.

The scheduled completion date for this action is May 18,2001.

L PROPOSED RAC 99-X0015,544/99

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Issue 23(R), Page 4 Plant Changes and Configuration Management

SUMMARY

OF REQUIREMENTS, COMMITMENTS, AND NONCOMPLIANCES Issue: Plant Changes and Configuration Management Code of Federal Regulations Part Title 10 76.35 (a)(4) and (6), 76.51, 76.68, 76.85, 76.87(a), 76.87(c), 76.93, 76.95 Application Commitment Section Safety Analysis Report 5.2.2.4, 5.2.2.6, 5.2.2.8, 5.4.6.2, 5.6.6, 6.1.1.18, 6.2, 6.3, 6.4, 6.5, 6.6, 6.7, 6.8, 6.10, 6.11 Quality Assurance Program 2.3, 2.4, 2.6, 2.7, 2.8, 2.9, 2.10, 2.11, 2.13, 2.15, 2.17 Appendix A-2.3,2.4,2.6,2.7,2.8,2.9, 2.10. 2.11, 2.13, 2.15, 2.17 Application Noncompliance Statement Section Safety Analysis Report 6.3.6.1, 6.3.6.2, 6.3.6.3, 6.3.6.4, 6.3.6.5, j

6.3.6.6 NRC Commitments Letter Portsmouth NCS Program Revised GDP 980255 Schedule Proposed Criteria for Reopening GDP 98-0264 Compliance Plan Issues (Revised)

Reopening of Compliance Plan Issues GDP 99-0002 Compliance Plan Status Report GDP 99 0004 Portsmouth Nuclear Criticality Safety GDP 99-0020 Program Quarterly Status Report 4

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1 iii CONTENTS Ease

. PORTS COMPLIANCE PLAN ISSUES AND NONCOMPLIANCES CITED IN THE APPLICATION....................................... v L

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PORTS MATRIX OF COMPLIANCE ISSUES,10 CFR REQUIREMENTS, AND APPLICATION DOCUMENTS................................... ix l

ABBREVIATIONS............................................... xxi p

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. O LOSSARY_................................................... xxv INTRODUCTION.............................................. xxix COMPLIANCE PLAN ISSUES l

Imme Transition f.om DOE Regulation to NRC Regulation......................

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Update the Appih.stion Safety Analysis Report *

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Autoclave Upgrades *

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l X-705 Evaporator Heat Exchanger Modificationst........................ 4 X-705 Isolation Valve Testingt (completed)........................... 5 X-705 Microfiltration Influent pH Shutdown System Replacement *t (completed)... 6 HEPA Filter Systems Testing *..................................... 7 Nuclear Criticality Safety Approval Documents.......................... 8 Nuclear Criticality Safety Approval Documents (Reopened)t................ 8R Nuclear Criticality Safety ApprovalImplementation....................... 9 j

l-Nuclear Criticality Safety ApprovalImplementation (Reopened)t............. 9R 1

Nuclear Criticality Safety Training for Managerst (completed)..............

10 i

Exceptions for Criticality Accident Alarm System.......................

11 I

Radiation Protection Procedures..................................

12 Posting of Radioactive Materials *

.................................13 NVLAP Certification * (completed)................................

14 Fire Protection Compensatory Measurest (completed)

...................15 l

Fire Protection Sprinkler Testing *t (closed)..........................

16 L

Fire Protection Procedures and Hot Work Permit Program.................

17 1

Emergency Packetst............. -..............................

18

• These issues may not be fully reimbursable by the U.S. Department of Energy.

- tThese issues are unique to the PORTS facility.

PROPOSED RAC 99-X0015,5/12/99 i.

iv Packaging and Transportation (completed),.........................

19 DOE Chemical Safety and Third-Party Use of Hazardous Chemicals *........

20 Management Controls........................................... 21 Safety Committees............................................

22 Plant Changes and Configuration Management.........................

23 Plant Changes and Configuration Management (Reopened)t............... 23R Maintenance Program......................................... 24 Operations Program...........................................

25 Systems Approach to Training.................................... 26 Assessments t............................................... 27 Event Investigations and Reporting Program........................... 28 Records Management and Document Control Program....................

29 Procedures Program *........................................... - 30 Q List (deleted).............................................

31

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Quality Assurance Program Implementation...........................

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Emergency Plan Support Documents (completed)......................

33 Training for Emergency Preparednesst..............................

34 Quality Control Program for Low-Level Waste Disposal (completed)..........

35 Depleted Uranium Management Plan *...............................

36 Administrative Controls on Overtime *...............................

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Decommissioning Funding Programt 38 i

Chemical Safety Mechanical Integrity Program * - (new issue) 39 Operational / Safety System Trip Redundancy (new issue)..................

40 Codes and Standards (new issue)................................. 41 1

UF, Leak Detector Sensitivity Testing * (new issue)..................... 42 10 CFR 21 Implementing Procedures (deleted)........................ 43 Criticality Accident Alarms for Nearby Buildings (new issue)..............

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• These issues may not be fully reimbursable by the U.S. Department of Energy.

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- tThese issues are unique to the PORTS facility.

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• The U.S. Department of Energy has no financial obligation related to this issue.

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RAC 99-X0015,5/12/99 PROPOSED 1-1.

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GDP 99-0039 Page1of4 United States Enrichment Corporation (USEC)

Certificate Amendment Request i

Compliance Plan Issues 8,9 and 23 Significance Determination The United States Enrichment Corporation (USEC) has reviewed the proposed changes associated with this certificate amendment request and provides the following Significance Determination for consideration.

1.

No Sionificant Decrease in the Effectiveness of the Plant's Safety. Safecuards or Security Programs The proposed changes to the Compliance Plan do not affect any of the plant's safety, safeguards or security programs. The proposed changes revise the Plan for Achieving Compliance with NRC Regulations at the Portsmouth Gaseous Diffusion Plant (Compliance Plan), to:

Reopen Compliance Plan Issue 8 and allow additional time to address deficiencies in the documentation of Nuclear Criticality Safety Approvals / Nuclear Criticality Safety Evaluations (NCSAs/NCSEs) and NCS program noncompliances that existed as a result ofinadequate completion of the Plan of Action and Schedule.

Reopen Issue 9 and allow additional time to make needed improvements in

'NCSAs/NCSEs and to ensure that controls required to demonstrate the double contingency principle are properly flowed down to appropriate procedures; Reopen the portion ofIssue 23 dealing with AQ-NCS items and allow additional time for the identification of AQ-NCS items resulting from the improved NCSAs/NCSEs, revision to boundary manuals, and documentation of these items in procurement documents and design documents.

Reopen the portion ofIssue 23 dealing with flowdown of commitmen'.s from the Certification Application to allow additional time to identify all procedures and controlled documents that implement commitments and ensure that procedures and controlled documents are revised to incorporate commitment identification, properly reviewed to meet SAR and TSR requirements, and procedural guidance is in place to assure that commitments are not inadvertently deleted from procedures or controlled documents.

The time extensions will not require any changes to plant documentation that could reduce safety, nor will it require any changes in the Certification Application to accommodate these extensions. The applicable conditions specified in the original Compliance Plan Issues, Justification for Continued Operation (JCO),will be reinvoked during this extended period. Therefore, there is no decrease in the effectiveness in the plant's safety, safeguards, or security programs as a result of the proposed change.

GDP 99-0039 Page 2 of 4

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United States Enrichment Corporation (USEC)

[

Certificate Amendment Request t

Compliance Plan Issues 8,9 and 23 i

Significance Determination 2.

No Significant Change to Any Conditions to the Certificate of Comnliance None of the Conditions to the Certificate of Compliance for Operation of Gaseous Diffusion Plants (GDP-2) specifically address the subject Compliance Plan completion dates. Thus, the proposed change will have no impact on any of the Conditions to the Certificate of Compliance.

3.

No Significant Change to Any Condition of the Anoroved Comoliance Plan The Plan of Action and Schedule for Compliance Plan Issues 8,9 and 23 are currently statused as complete, since the due dates for completion of the Issues have been passed. As described in Enclosure 5, the proposed change extends the completion date for NCS-related actions to May 18,2001 and the completion date for flowdown-i related actions to March 30,2001. Since the actions will still be completed in accordance with the Compliance Plan requirements and there is no change in the scope of the activities, the changes in these completion ~ dates do not represent a significant change to the Compliance Plan Issues, j

4.

No Significant Increase in the Probability of Occurrence or Conseauences of Previousiv Evaluated Accidents The reopening of the Compliance Plan Issues does not increase the probability or the consequences of any previously analyzed accidents since the engineered and administrative controls currently in place will be improved by the accomplishment of the actions described in the Issues.

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. 5.

No New or Different Tvoe of Accident '

i The proposed changes do not modify plant equipment or add new operations to the facility. Upgrade of the NCSAs/NCSEs and implementation of NCS controls, identification of additional AQ-NCS items, and improvement of commitment flowdown to procedures and controlled documents will not introduce any new accident initiators or failure modes. Therefore, the change will not result in a new or different type of accident.

6.

No Significant Reduction in Margins of Safety As described in Items 4 and 5 above, continued operation until NCSAs/NCSEs are upgraded, additional or revised NCS controls are implemented, additional AQ-NCS

. items are identified and controlled, and commitment flowdown to procedures and controlled documents is improved, will not result in a reduction in the margins of safety as defined in the supporting bases documents for the TSR.i

1 GDP 99-0039 Page 3 of 4 i

United States Enrichment Corporation (USEC)

Certificate Amendment Request Compliance Plan Issues 8,9 and 23 l

Significance Determination 7.

No Significant Decrease in the Effectiveness of Any Programs or Plans Contained in J

the Certificate Application The proposed changes to Compliance Plan Issues 8,9 and 23 will not result in a change to any of the programs or plans contained in the Certificate Application.

Therefore, the proposed changes will result in no decrease in the effectiveness of any programs or plans contained in the Certificate Application.

I 8.

The Proposed Changes do r;ot Result in Undue Risk to 1) Public Health and Safety.

2) Common Defense and Security. and 3) the Environment Due to the fact there are no increases in the probability or consequences of any accident previously analyzed, there will be no undue risk to the public health and safety because of the proposed changes. In addition, the proposed changes have no impact on plant effluents or on the programs and plans in place to implement physical security. Consequently the proposed changes to Compliance Plan Issues 8,9 and 23 will not pose any undue risk to the public health and safety, common defense and security, or the environment.

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9.

No Change in the Tvoes or Significant Increase in the Amounts of Any Effluents that May be Released Offsite The proposed reopening of the Compliance Plan Issues will have no effect on the generation of effluents since the changes deal with ccmpletion of programs.

Therefore, the proposed changes do not change the type or amount of effluents that may be released offsite.

10.

No Significant Increase in Individual or Cumulative Occupational Radiation Exposure The proposed changes do not increase the probability or consequences of a postulated criticality. The proposed reopening of Compliance Plan Issues 3,9 and 23 will not affect the radiological protection program description or the actions in place to minimize occupational exposures. Therefore, there is no increase in individual or cumulative occupational radiation exposure as a result of these changes.

I 1.

No Sienificant Construction Imnact This proposed change does not involve physical plant modifications. Therefore, there are no construction impacts associated with this change proposal.

GDP 99-0039 i

Page 4 of 4 United States Enrichment Corporation (USEC)

Certificate Amendment Request Compliance Plan Issues 8,9 and 23 Significance Determination 12.

No Significant Increase in the Potential for. or Radiological or Chemical Consequences from. Previousiv Analyzed Accidents The reopening of Compliance Plan Issues 8,9 and 23 will not increase the probability f

of occurrence or consequences (radiological and/or chemical) of any postulated accidents currently identified in the PORTS Safety Analysis Report (SAR). The proposed changes do not alter the assumptions used in the accident analysis.

Therefore, there is no increase in the potential for, or radiological or chemical consequences from, previously analyzed accidents.

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