ML20207A038
| ML20207A038 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 05/10/1999 |
| From: | Devault R ENERGY, DEPT. OF |
| To: | Toelle S UNITED STATES ENRICHMENT CORP. (USEC) |
| References | |
| NUDOCS 9905260095 | |
| Download: ML20207A038 (6) | |
Text
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f I'.k Department of Energy
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j Oak Ridge Operations 1
y' Post Office Box 62
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%s Oak Ridge, Tennessee 37831 -8651 l
May 10, 1999 1
Mr. Steven A. Toelle i
Nuclear Regulatory Assurance and Policy Manager United States Enrichment Corporation 2 Democracy Center 6903 Rockledge Drive
.Bethesda, Maryland 20817' s
Dear Mr. Toelle:
PORTSM0UTH GASEOUS DIFFUSION PLANT - DOCKET NO. 70-7002 - DEPARTMENT OF ENERGY APPROVAL 0F THE REVISED OF COMPLIANCE PLAN ISSUE 23R On May 6, 1999, the Department of Energy (D0E) received a request from the United States Enrichment Corporation (USEC) to change the DOE-approved proposed Portsmouth Gaseous Diffusion Plant (PORTS) Compliance Plan Issue 23R, Plant Changes and Configuration Management. The requested change extends the completion date for verification of the flowdown of commitments from Technical Safety Requirements Section 3.0, Administrative Controls, the Safety Analysis Report, and other plans and programs contained in the PORTS Application for Certification from March 15. 2000,- to March 30, 2001.
A review of the effect of the requested date change on the approved Issue 23R, in particular the Justification for Continued Operation, was performed.
Based i
on this review and additional information received from the PORTS Nuclear Regulatory Affairs staff regarding the progress made in achieving compliance,
-the " Description of Noncompliance," " Justification for Continued Operation" (JCO), and." Plan of Action and Schedule" (P0AS) sections of Issue 23R were updated.
The enclosed revised issue is the DOE-approved Issue 23R and
)
supercedes the version transmitted to you in my April 14, 1999, letter.
The revised date contained in the P0AS is that pro)osed by USEC to the Nuclear Regulatory Commission.
Future changes extending t1e time required to complete 4
correcthe actions will require an additional evaluation of the JC0 by D0E.
If you have any questions or comments on this issue, please contact me at I
(423) 576-0802.
f Sine ly, h
h Randall M. DeVault
,i Regulatory Oversight Manager
' ', a ' i ' I Office of Assistant Manager
'J for Uranium & Engineering Services cc's on Page 2.
Enclosures.
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Issue 23(R), Page I t
Plant Changes and Configuration Management (Reopened)
REQUIREMENTS i
10 CFR 76.68(a) "(a) The Corporation may make changes to the plant or to the plant's operations as described in the safety analysis report without prior Commission approval provided 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 i
security, or to the environment.
(2) The changes must be authorized by responsible management and approved by a safety I
review committee.
(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.
i (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 i
Source: Safety Analysis Report
- 6. Organization and Operating Programs 6.3 Plant Changes and Configuration Management [Rev. 3, 5/31/96].
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.
DESCRIPTION OF NONCOMPLI ANCE Compliance Plan issue 23 contained commitments to complete the development and j
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, PORTS,5/10/99
l Issue 23(R), Page 2 Plant Changes and ConGguration Management i
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 (SAR), and other plans and programs to procedures and training. Reviews conducted following the transition from Department of Energy regulatory oversight to Nuclear Regulatory Commission (NRC) oversight noted deficiencies in the identification of safety boundaries for AQ-NCS items. These reviews also identified that the flowdown of commitments from Section 3.0, Administrative Controls, of the TSRs, the S AR, 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 S AR, 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.
JUSTIFICATION FOR CONTINUED OPERATION 1.
Program Management. A Configuration 11anagement Program procedure has been developed and issued. This procedure provides management direction, establishes consistent concepts and terminology, and defines the scope of the program, identifies 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 Report, Process Hazards Analysis, existing Nuclear Criticality Safety Approvals, and other regulatory assessments to identify structures, systems, components, and design features for safety utilizing the process described in Application Section 6.3.5.3, with the exception of safety features required to support the (louble contingency principle. As AQ-NCS items are identified in the NCS A 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 tiowdown of Administrative Control TSR requirements accomplished as part of the corrective action for the original Issue 23 PORTS,5/10/99
m-,,-
f Plant Changes and Connguration Management Issue 23(R), Page 3 l
t 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 given to implementing document preparers to ensure identification and Howdown of commitments.in new or revised implementing documents.
2.-
Design Requirements. Efforts are ongoing to identify, verify, and document 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
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(CCB) which includes criticality safety expertise. The CCB determines if PORC review and approval is required. Until the necessary AQ-NCS design requirements are identified, j
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 efforts to identify, neld 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, Administratiw Controls, the SAR, and other plans and programs contained in the Application to implementing documents and training. 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 tie nuclear criticality double contingency principle); to identify and document the designated design requirements and system boundaries, including 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.
PORTS,5/t0/99
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Issue 23(R), Page 4 Plant Changes and Configuration Management
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- 'SUMhfARY OF REQUIREMENTS, COhlMITMENTS, AND NONCOMPLIANCES l
Issue: Plant Changes and Configuration Management l
Code of Federal Regulations Part Title 10 76.35 (a)(4) and (6), 76.51, 76.68, 76.85, J
76.87(a), 76.87(c), 76.93, 76.95 Appliention Commitment Section i
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.I1, 2.13, 2.15, 2.17 I
Appendix A-2.3, 2.4, 2.6, 2.7, 2.8, 2.9, 2.10, 2.I1. 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, 6.3.6.6 NRC Commitments Letter i
Portsmouth NCS Program Revised GDP 98-0255 Schedule 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 Portsmouth Nuclear Criticality Safety GDP 99-0020 Program Quarterly Status Report l
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PORTS,5/10/99
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