ML20207E876
| ML20207E876 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 02/25/1999 |
| From: | Toelle S UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Devault R ENERGY, DEPT. OF |
| References | |
| DOE-99-0002, DOE-99-2, NUDOCS 9903110098 | |
| Download: ML20207E876 (27) | |
Text
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d USEC A Global Energy Company February 25,1999 i
DOE 99-0002
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Mr. Randall M. DeVault Regulatory Oversight Manager Oak Ridge Operations j
U. S. Department of Energy Oak Ridge, Tennessee 37831-8651 United States Enrichment Corporation (USEC)
Portsmouth Gaseous Diffusion Plant (PORTS)'
Docket No.70-7002 Review and Approval of Reopening Compliance Plan Issues 8,9 and 23
Dear Mr. DeVault:
The United States Enrichment Corporation (USEC) hereby submits a request to the Department of Energy (DOE) for review and approval of a revision to the Plan for Achieving Compliance with NRC Regulations at the Portsmouth Gaseous Diffusion Plant (Compliance Plan). This revision involves l
changes to the following Compliance Plan Issues:
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Issue 8, Description ofNoncompliance, Justification for Continued Operation, and Plan of Action and Schedule, regarding development of Nuclear Criticality Safety Approvals / Nuclear Criticality Safety Evaluations (NCSAs/NCSEs), in accordance with NRC requirements, for all Fissile Material 7
Operations (FMOs);
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Issue 9, Description ofNoncompliance, Justification for Continued Operation, and Plan of A Schedule, regarding implementation of the NCSAs/NCSEs for Fissile Material Operations; Portions ofIssue 23, Description of Noncompliance, Justification for Continued Operation, and Plan of Action and Schedule, reguding: 1) review of all NCSAs/NCSEs to identify AQ-NCS items (items l
which support the nuclear c;iticality double contingency principle), identification and documentation l
of the designated design requirements and system boundaries, including support systems required for l
performance of the intended safety function, and verification of the implementation of these l
requirements; and 2) implementation of flowdown of commitments from the Technical Safety I
Requirements, the Safety Analysis Report, and other plans and programs to procedures and training.
i 9903110098 990225 F PDR ADOCK 07007002' C
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6903 Rockledge Drive, Bethesda, MD 20817 1818 Telephone 301-564-3200 Fax 301-564-3201 http://www.usec.com Ig Offices in Livermore, CA Paducah. KY Portsmouth, OH washington, DC
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7.5 Mr. Randall M. DeVault February 25,1999 DOE 99-0002, Page 2 USEC committed to provide these Compliance Plan revisions in USEC letters GDP 99-0002 dated January 19,1999 and GDP 99-0004 dated January 21,1999. These issues are being reopened to address deficiencies that were identified during the implementation of these issues.
3 In accordance with the NRC letter from Robert Pierson to Steven Toelle of USEC dated October 23, 1997, DOE approval of Compliance Plan changes is required prior to submittal to NRC. Therefore, the subject compliance Plan changes are provided in this submittal for DOE review and approval. Once DOE ay roval is obtained, the changes will be submitted to NRC.
Enclosures 1,2 and 3 to this letter provide a detailed description and justification for the proposed changes. Enclosure 4 is a copy of the revised Compliance Plan pages and removal / insertion instructions associated with this request. In order to support the schedule for submittal of the Certificate Amendment Request (CAR) to NRC and obtain their approval of the CAR, USEC mquests DOE review and approval of the Compliance Plan change by March 12,1999.
There are no new commitments contained in this submittal. If you have any questions regarding this matter please contact Mark Smith at (301) 564-3244.
Sincerely, 0
S. 9.
I Steven A.Toelle Nuclear Regulatory Assurance and Policy Manager
Enclosures:
1.
United States Enrichment Corporation (USEC), Certificate Amendmem Request, Compliance Plan Issue 8, Detail Description of Change 2.
United States Enrichment Corporation (USEC), Certificate Amendment Request, Compliance Plan issue 9, Detail Description of Change 3.
United States Enrichment Corporation (USEC), Certificate Amendment Request, Compliance Plan Issue 23, Detail Description of Change 4.
Cenificate Amendment Request, Portsmouth Gaseous Diffusion Plant, Letter GDP 99-0002, Removal / Insertion Instructions.
cc: Mr. Robert C. Pierson (NR)C NRC Region III Office V NRC Resident Inspector, PGDP NRC Resident inspector, PORTS
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DOE 99-0002 l
Page 1 of 3 United States Enrichment Corporation (USEC) i Certificate Amendment Request Compliance Plan Issue 8 Detailed Description of Change s
Compliance Plan Issue 8, Plan of Action and Schedule, committed USEC to complete formal NCSAs and NCSEs for all current operations (including handling, storage, processing'and transportation) involving uranium enriched to I wt % or higher 23'U and 15 grams or more 235U, and properly document and approve the NCSAs/NCSEs in accordance with the Nuclear Criticality Safety (NCS) program requirements contained in the approved Certificate. The procedural changes to resolve administrative noncompliances in the NCS program were also to be completed. This submittal proposes to reopen Compliance Plan Issue 8 to address deficiencies in the documentation of NCSAs/NCSEs and NCS program noncompliances that existed as a result ofinadequate completion of the Plan of Action and Schedule.
Justification of the Change i
NRC Inspection Report 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 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 suppon 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 and January 30,1998 (References 2,3 and 4). Additional revisions were made to add tasks in References 5 and 6.
Additional discrepancies with the PORTS NCS Program were also documented in Inspection Report 97-
'013, which identified a cited violation involving noncompliances in the NCS program. Additionally, NRC Inspection Report 98-204 reviewed closure evidence for Compliance Plan Issue 8 and concluded that the Issue was not adequately completed by USEC. Subsequently, per References 3 through 7 (of the cover letter), USEC agreed to reopen this CP issue.
To date, USEC has completed physical work on all but one task of the NCS CAP (i.e., Task 3, deals with the upgrade of the NCSAs and flowdown into plant implementing procedures). USEC is currently l
committed to complete this Task by March 3,2000, for the NCSAs covered by the NCS CAP (i.e.,
I Priority I and 2 NCSA/Es). 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 upgrade effort, and AQ-NCS reclassification (this is discussed in further detail in USEC letter to NRC dated November i
13,1998, see USEC letter GDP 98-0255). In the area of availability of expertise, USEC found that staff l
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l DOE 99-0002 i
Page 2 of 3 United States Enrichment Corporation (USEC)
Certificate Amendment Request r
Compliance Plan Issue 8 Detailed Description of Change augmentation required to perform NCSNNCSE 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 3
Violation 98-206-02, wherein USEC committed to review new or upgraded NCS As/NCSEs and reclassify i
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 through PORC.
Portions of the Desc-iption of Noncompliance, Justification for Continued Operation, and the hu of Action and Schedule have been deleted or revised from the original Compliance Plan Issue. These deletions and 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 j
have been confirmed as complete during the self-assessment of Compliance Plan issues conducted by USEC.
The extended schedule for completion of this Compliance Plan Issue is justified by the completion of all of the progranunatic Tasks of the NCS CAP. In addition, Senior-qualified NCS personnel conducted peer i
reviews of existing NCSAs/NCSEs, and confirmed 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 conducted to improve personnel awareness and compliance with NCS controls. As a result, a significant reduction in l
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l DOE 99-0002 Page 3 of 3 United States Enrichment Corporation (USEC)
Certificate Amendment Request i
Compliance Plan Issue 8 L.
Detailed Description of Change l
l l-event reports was realized. Other high-priority NCSAs were reviewed by teams of NCS and plant
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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 i
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 l
Corrective Action Plan for the Portsmouth Nuclear Criticality Safety Program," USEC Letter GDP-97-0216 dated December 22,1997 i
4.
Letter from Steven A. Toelle (USEC) to Cynthia Pederson (NRC), "Portsmouth Nuclear j
' Criticality Safety Program Revised Corrective Action Plan - Quarterly Status Report," USEC 1
Letter GDP-98-0013 dated January 30,1998 5.
Letter from' Steven A. Toelle (USEC) to Cynthia Pederson (NRC), "Portsmouth Nuclear j
Criticality Safety Program Revised Corrective Action Plan - Quarterly Status Report," USEC Letter GDP-98-0094 dated April 30,1998 6.
Letter from Steven A. Toelle (USEC) to Cynthia Pederson (NRC), "Portsmouth Nuclear Criticality Safety Program - Quarterly Status Report," USEC Letter GDP-98-0147 dated July 31, 1998 f.
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DOE 99-0002 Page1of3 United States Enrichment Corporation (USEC)
Certificate Amendment Request Compliance Plan Issue 9 Detailed Description of Change Compliance Plan Issue 9, Plan of Action and Schedule, committed USEC to review all NCSAs in order to identify and track the designated Nuclear Criticality Safety (NCS) conditions, specifications, and l
controls and to verify the full implementation of administrative requirements for double contingency l
controls in plant operating procedures by February 28,1997. This submittal proposes to reopen Compliance Plan Issue 9 to address deficiencies in the implementation ofNCSAs that existed as a result ofinadequate completion of the Plan of Action and Schedule.
Justification of the Change i
NRC Inspection Report 97-203 identified a violation where multiple failures to comply with i
admhdstrative criticality controls specified in various NCSAs were found. NRC Inspection Report 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 97-206 (reference USEC letter GDP-97-2026, October 29,1997), inadequacies in NCSAs/NCSEs and failures to properly flow NCSA/NCSF 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 and January 30,1998 (References 2,3 and 4). Additional revisions were made to add tasks in References 5 and 6. Key eiements 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 Inspection Report 97-013, which identified a cited violation involving noncompliances in the NCS program. Additionally, NRC Inspection Report 98-204 reviewed closure evidence fer Compliance Plan Issue 9 and concluded that the issue was not adequately completed by USEC. Subsequently, per References 3 through 7 (of the cover letter), USEC agreed to reopen this CP issue.
To date, USEC has completed physical work on all but one task of the NCS CAP (i.e., Task 3, deals with the upgrade of the NCSAs and flowdown into plant implementing procedures). USEC is currently committed to complete this Task by March 3,2000, for the NCSAs covered by the NCS CAP (i.e.,
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'. 4 DOE 99-0002 Page 2 of 3 United States Enrichment Corporation (USEC)
Certificate Amendment Request Compliance Plan Issue 9 Detailed Description of Change Priority I and 2 NCSA/Es). 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 upgrade effort, and AQ-NCS reclassification (this is discussed in further detail in USEC letter to NRC dated November 13,1998, see USEC letter GDP 98-0255). In the area of availability of expertise, USEC found that staff augmentation required to perform 'NCSA/NCSE reviews, walkdowns, and revisions took longer than expected due to an initial shortage of qualified contract personnel that was subsequently 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 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 i
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.
j 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 reclassiried AQ-NCS SSCs. Reclassification cannot be completed until each new or revised NCSA has been completed and approved through PORC.
Portions of the Description of Noncompliance, Justification for Continued Operation, and the Plan of Action and Schedule have been deleted or revised from the original Compliance Plan Issue. These deletions and 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.
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 confirmed the technical adequacy of the documents. USEC also i
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l DOE 99-0002 Page 3 of 3 United States Enrichment Corporation (USEC)
Certificate Amendment Request Compliance Plan Issue 9 Detailed Description of Change 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 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.
1
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 -
i Attention: Administrator, Region Ill, "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 i
Corrective Action Plan for the Portsmouth Nuclear Criticality Safet 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 Steven A. Toelle (USEC) to Cynthia Pederson (NRC), "Portsmouth Nuclear Criticality Safety Program - Quarterly Status Report," USEC Letter GDP-98-0147 dated July 31, 1998 1
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DOE 99-0002 Page1of3 United States Enrichment Corporation (USEC)
Certificate Amend nent Request Compliance Plan Issue 23 Detailed Description of Change Compliance Plan Issue 23, Plan of Action and Schedule, committed USEC 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 suppon the nuclear criticality double contingency principle) and identify, document, and implement design l
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. The due date for these elements to be completed was February 28, 1997 for AQ-NCS items, and June 30,1998, for flowdown implementation. This submittal proposes to i
reopen Compliance Plan Issue 23 to address deficiencies in the identification and implementation ofAQ-
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NCS items and deficiencies in the establishment and maintenance of flowdown of commitments to procedures and training that existed as a result ofinadequate completion of the Plan of Action and l
Schedule.
l Justification of the Change
- 1. AQ-NCS Items l
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 Inspection Report 98-204 also identified SSCs being relied upon for NCS control that were 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 l
the Issue dealing with AQ-NCS items was not adequately completed with appropriate rigor and formality. NRC Inspection Report 98-206 identified a violation wherein SSCs relied on in NCSAs for double contingency were not identified as components relied on for criticality safety in the Boundary Definition Manual or classified as AQ-NCS items.
l USEC responded to the violation cited in IR 98-206 (reference USEC letter GDP-98-2027) by revising the procedural guidance for classifying SSCs required to meet the double contingency principle as AQ-NCS and committing to review new or upgraded NCSAs/NCSEs resulting from Task 3 of the NCS Corrective Action Plan (CAP) and reclassifying SSCs that need to be classified as AQ-NCS.
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c DOE 99-0002 Page 2 0f 3 United States Enrichment Corporation (USEC)
Certificate Amendment Request Compliance Plan Issue 23 Detailed Description of Change 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-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 ofcommitments 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 flowdowm documents was accomplished. The database of commitments has been rnaintained current with changes made to the Certification Application in accordance with 10 CFR 76.68.
During the phased flowdown process, the Procedures Upgrade Program was being conducted m i
accordance with Issue 30 Plan of Action and Schedule. Problem Report PR-PTS-97-4304 was
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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 le.er half of 1997. However, revisions to NRA and Training and Procedures procedures that institutionalized and integrated the flowdown process in a more rigorous manner was not accomplished until the latter half of 1998.
During a SSQ audit of the Environmental Protection program, PR-QA-98-04090, initiated on June 24, 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 j
from the procedure change process to update linkages between commitments and procedures.
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DOE 99-0002 Page 3 of 3 United States Enrichment Corporation (USEC)
Certificate Amendment Request Compliance Plan Issue 23 Detailed Description of Change USEC letter GDP 99-0002 dated January 19,1999, subsequently informed NRC of this 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 based on the extensive procedure upgrade program and incorporation of commitments that was realized during the initial flowdown effort. The flowdown confirmation effort to date has confirmed that the predominant findings have been related to lack of annotation of commitments in flowdown documents. If deficiencies are found where the commitment was 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 flowdown documents, and ensure that commitments are not inadvertently deleted from procedures.
Portions of the Description of Noncompliance, Justification for Continued Operation, and the Plan of Action and Schedule have been deleted or revised from the original Compliance Plan Issue. These deletions and 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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DOE 99-0002 16 Pages Proposed Certificate Amendment Request Portsmouth Gaseous Diffusion Plant Letter DOE 99-0002 Removal / Insertion Instructions Remove Pages Insert Pages Plan for Achieving Compliance with NRC Regulations at the Portsmouth Gaseous Diffusion Plant Table of Contents Table of Contents Pages iii/iv Pages lii/ iv Issue 8(R)
Pages 1-4 Issue 9(R)
Pages 1-5 Issue 23(R)
Pages 1-4 l
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111 CONTENTS Ease PORTS COMPLIANCE PLAN ISSUES AND NONCOMPLIANCES CITED IN TH E APPLICATION....................................... y PORTS MATRIX OF COMPLIANCE ISSUES,10 CFR REQUIREMENTS, AND APPLICATION DOCUMENTS......
ix ABBREVI ATIONS............................................. xxi G LOS S ARY.................................................. xxy INTRODUCTION...
...... xxix 1
COMPLIANCE PLAN ISSUES l
Isme i
Transition from DOE Regulation to NRC Regulation......................
1 Update the Application Safety Analysis Report *
.........................2 Autoclave Upgrades * '...................
......................3 1
X-705 Evaporator Heat Exchanger Modificationst
.4 4
X-705 Isolation Valve Testingt (completed)........................... 5 X-705 Microfiltration influent pH Shutdown System Replacement *t (completed).
6 H EPA Filter Systems Testing *..................................... 7 Nuclear Criticality Safety Approval Documents.......................... 8 Nuclear Criticality Safety Approval Documents (Reopened)t............... 8R l
Nuclear Criticality Safety Approval Implementation....................... 9 Nuclear Criticality Safety Approval Implementation (Reopened)t............ 9R l
Nuclear Criticality Safety Training for Managerst (completed)..............
10 Exceptions for Criticality Accident Alarm System.......................
11 Radiation Protection Procedures 12 Posting of Radioactive Materials *.................................
13 NVLAP Certification * (completed)................................ 14 Fire Protection Compensatory Measurest (completed)...................
15 Fire Protection Sprinider Testing *t (closed) 16 Fire Protection Procedures and Hot Work Permit Prograni.................
17 Emergency Packetst..........................................
18
- These issues may not be fully reimbursable by the U.S. Department of Energy.
j tThese issues are unique to the PORTS facility.
PROPOSED RAC 99-X0015,2/25/99 i
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Packaging and Transportation (completed)...........................
19 DOE Chemical Safety and Third-Party Use of Hazardous Chemicals *.........
20 Management Controls.........................................
21 j
Safety Committees............................................
22 i
i Plant Changes and Configuration Management.........................
23 l
Plant Changes and Configuration Management (Reopened)t............... 23R i
Maintenance Program.........................................
24 1
Operations Program...........................................
25 I
I Systems Approach to Training....................................
26 i
Assessmentst.............................................
27 l
Event Investigations and Reporting Program...........................
28 Records Management and Document Control Program....................
29 Procedures Program *..................
.......................30 Q List (deleted)............................................
31 Quality Assurance Program Implementation...........................
32 Emergency Plan Support Documents (completed).......................
33 Training for Emergency Preparednesst............................
34 Quality Control Program for Low-1.evel Waste Disposal (completed)..........
35 Depleted Uranium Management Plan *...............................
36 Administrative Controls on Overtime *....................,..........
37 Decommissioning Funding Programt 38 Chemical Safety Mechanical Integrity Program * (new issue)
.......,,.....39 Operational / Safety System Trip Redundancy (new issue)..................
40 Codes and Standards (new issue).................................
41 UF Leak Detector Sensitivity Testing * (new issue)....................
42 10 CFR 21 Implementing Procedures (deleted)........................
43 Criticality Accident Alarms for Nearby Buildings (new issue)............... 44 i
- These issues may not be fully reimbursable by the U.S. Department of Energy.
tThese issues are unique to the PORTS facility.
$The U.S. Department of Energy has no financial obligation related to this issue.
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I RAC 99-X0015,2/25/99 PROPOSED i
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Issue 8(R), Page 1 I
Nuclear Criticality Safety Approval Documents (Reopened) l REQUIREMENTS l
l 10 CFR 76.35(a)(5), (6), and (7) "The application for an initial certificate of compliance must l
include the information identified in this section. (a) A safety analysis report which must include l
the following information:... (5) A training program that meets the requirements of f 76.95; (6) l A description of equipment and facilities which will be used by the Corporation to protect health l
and minimize danger to life or property (such as handling devices, working areas, shields, l
measuring and monitoring instruments, devices for the treatment and disposal of radioactive l
effluent and wastes, storage facilities, provisions for protection against natural phenomena, fire l
pratection systems, criticality accident alarm systems, etc.); (7) A description of the management l
controls and oversight program to ensure that activities directly relevant to nuclear safety and l
safeguards and security are conducted in an appropriately controlled manner that ensures protection j
of employee and public health and safety and protection of the national security interests."
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10 CFR 76.85 "The Corporation shall perform an analysis of potential accidents and l
consequences to establish the basis for limiting conditions for operation of the plant."
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10 CFR 76.87(c)(3) "(c) Appropriate references to established procedures and/or equipment to l
address each of the following safety topics must be included in technical safety requirements:...
l (3) Criticality prevention."
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l COMMITMENTS l
l Source: Safety Analysis Report j
- 5. Nuclear Safety Programs 1
5.2 Nuclear Criticality Safety [NCS]
l 5.2.2 Program Elements l
5.2.2.3 Process Evaluation and Approval [Rev. 3, 5/31/96]
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"Each operation involving uranium enriched to I wt. percent or higher "U and 15 g or more l
of"U is evaluated for NCS prior to initiation. The operation and related NCS requirements are l
documented in Part A and Part B of a NCSA [ Nuclear Criticality Safety Approval). The evaluation l
is documented in a NCSE [ Nuclear Criticality Safety Evaluation). The evaluation and approval l
process is governed by written procedures....
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Part A of the NCSA documents the operating organizations *s request for NCS evaluation and l
the description of the operation....
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Part B of the NCSA is prepared based on the results of the NCSE, and it documents the l
conditions of approval (i.e., NCS requirements) for the operation. The conditions of approval l
include the process conditions which must be mairdained to meet the double contingency principle l
or preserve the documented basis for criticality safety and restrict the modes of operation to those l
PROPOSED RAC99-X0015,2/25/99
Issue 8(R), Page 2 Nuclear Criticality Safety Approval Documcats l
l l which have been analyzed in the NCSE..
. The requirements to be included in operating l procedures and postings are identified..
l l
The NCSA/NCSE process provides assurance that operations will remain suberitical under l both normal and credible abnormal conditions."
l l
l DESCRIPTION OF NONCOSIPLLiNCE I
l There are operations at PORTS for which either (1) the nuclear criticality safety evaluations l (NCSEs) are incomplete or formal documentation is unavailable or (2) double-contingency or other l basis for acceptance has not been fully documented in an NCSE. Current lists of complete and l incomplete NCSEs are available at the site for NRC inspection.
I I
I l JUSTIFICATION FOR CONTINUED OPERATION I
l PORTS is currently operating with effective specifications and controls for NCS developed l by the professional staff over a period of more than 40 years. These specifications and controls l have resulted from extensive analysis, years of operating experience at each of the gaseous l diffusion plants, and numerous internal and external assessments and audits. The documentation l of the bases for these specifications and controls have been upgraded to be consistent with current l NRC expectations for content and format. Evaluations performed in response to NRC inspection l activities since the transition to NRC oversight have identified several controls that should be l updated (e.g., procedures and postings) and other opportunities for safety improvements (e.g.,
l replacement of administrative controls with engineered system controls). The improvements are l being made as they are identified and developed as part of the NCS Corrective Action Program.
l l
The areas of greatest concern to NCS, such as the decontamination areas, were designed for l handling fully enricl'ed uranium. !n such areas, substantial increases in the criticality safety margin l are provided by limiting USEC enriched production to 10 wt % "U and the purge gas section to l 20 wt % *U.
l l
PORTS will continue to operate safely, using NCS conditions, controls, and specifications that l have been established as a result of previous activities conducted under this Compliance Plan issue l and corrective actions taken under the NCS Corrective Action Plan, while the NCS staff continues l to upgrade the NCSE and NCSA documentation to meet NRC requirements. Corrective actions
] in response to NCS deficiencies and assessment findings also continue to strengthen the NCS l controls. Each new operation (including handling, storage, processing and transportation)
S l involving I wt % or higher U and 15 grams or more *U will be evaluated, including an l evaluation for double contingency, and will have complete NCSA and NCSE documentation s
l prepared before commencing the new operation.
l l Continued safe operation until the actions under the Plan of Action and Schedule are completed l is assured by the following:
l l
Review of Priority 1 NCSA/Es was completed and all discrepancies and issues were resolved.
l l
An example of one of the issues resolved concerned NCSA/E PLANT 006, Small Diameter l
l Containers. It was found that the calculation assumption on aisle spacing did not carry over RAC 99-X0015,2/25/99 PROPOSED 4
l
. ~ _... _ _ _
.m,
.w Nuclear Criticality Safety Approval Documents Issue 8(R), Page 3 to controls. As a result, two storage areas were tagged-out until they were evaluated to be l
safe.
l I
NCSA problems causing the majority of event reports have been resolved. An example is l
l NCSA/E PLANT 018, Dry Active Waste. Improved evaluations resulted in fewer spacing l
requirements which, in turn, resulted in reduction in NCS violations.
l I
e The majority of problems found were implementation related. PORTS has made significant l
[
improvements in field implementation.
l I
I PLAN OF ACTION AND SCHEDULE l
l 1
l All new operations (including handiing, storage, processing and transportation) that require l
l NCS approval will have properly documented and implemented NCSAs and NCSEs that have been l
approved in accordance with the NCS program requirements contained in the approved Certificate l
prior to startup. Formal NCSAs and NCSEs will be completed for all current operations involving l
uranium enriched to I wt % or higher "U and 15 grams or more "U by March 3,2000 and will l
be properly documented and approved in accordance with the NCS program requirements l
l contained in the approved Certificate.
l i
l l
1 l
i PROPOSED RAC99-X0015,2/25/99
Issue 8(R), Pag 3 4 Nuclear Criticality Safety Approval Documents l
SUMMARY
OF REQUIREMENTS, COMMITMENTS, AND NONCOMPLIANCES l
.l Issue: Nuclear Criticality Safety Approval Documents l
Code of Federal Regulations Part J
l Title 10 76.35(a)(5), (6), and (7); 76.85; 76.87(c)(3) l Application Conunitment Section l
Safety Analysis Report 5.2.2.3 i
l Technical Safety Requirements 3.9.1.c 3.11 l
Application Noncompliance Statement Section l
Safety Analysis Report 5.2.4.1, 5.2.4.2, 5.2.4.6, 5.2.4.9, 5.2.4.10, l
5.2.4.11 l
NRC Commitments Letter l
Portsmouth NCS Program Revised GDP 98-0255 l
Schedule l
Proposed Criteria for Reopening-GDP 98-02M l
Compliance l
Plan Issues (Revised) l Reopening of Compliance Plan Issues GDP 99-0002 l
Compliance Plan Status Report GDP 99-0004 l
Portsmouth Nuclear Criticality Safety GDP 99-0020 l
Program l
Quarterly Status Report l
RAC 99-X0015,2/25/99 PROPOSED
1 Issue 9(R), Page 1 l
l l
Nuclear Criticality Safety ApprovalImplementation (Reopened) i l
REQUIREMENTS l
i l
10 CFR 76.35(a)(5), (6), and (7) "The application for an initial certificate of compliance must l
include the information identified in this section. (a) A safety analysis report which must include l
the following information:.. (5) A training program that meets the requirements of Q 76.95; l
(6) A description of equipment and facilities which will be used by the Corporation to protect l
health and minimize danger to life or property (such as handling devices, working areas, shields, l
measuring and monitoring instruments, devices for the treatment and disposal of radioactive l
effluent and wastes, storage facilities, provisions for protection against natural phenomena, fire l
protection systems, criticality accident alarm systems, etc.); (7) A description of the management l
controls and oversi;St program to ensure that activities directly relevant to nuclear safety and l
safeguards and security are conducted in an appropriately controlled manner that ensures protection l
of employee and public health and safety and protection of the national security interests."
l l
10 CFR 76.87(c)(3) "(c) Appropriate references to established procedures and/or equipment to l
l address each of the following safety topics must be included in technical safety requirements:...
l (3) Criticality prevention."
l
]
l 10 CFR 76 (in general)-A number of sections (including those related to safety analysis, TSRs, l
1 and emergency planning) have implications for nuclear criticality safety to the extent that they l
address such issues as safety limits and controls.
l l
I COMMITMENTS l
l Source: Safety Analysis Report l
S. Nuclear Safety Programs l
5.2 Nuclear Criticality Safety [NCS]
l 5.2.2 Program Elements l
5.2.2.3 Process Evaluation and Approval [Rev. 3, 5/31/96]
l l
"The requirements to be included in operating procedures and postings are identified [in l Part B of the nuclear criticality safety approval (NCSA)].... Once approved by the General l
1 Manager, the NCS controls, limits, evaluation assumptions, and safety items are verified to be l
fully implemented in the field. This verification process is performed by the operations l
organization and Criticality Safety personnel. The documentation of this verification process is j
maintained as a quality record along with the NCSE [ nuclear criticality safety evaluation]. The l
j manager or designee of the operating group then signs part B, indicating acknowledgment and l
l agreement with the limits and controls specified. The NCSA is then issued as a permanent or l
l temporary document l
(
l-First-line management of the operating organization is responsible for implementing, through l
training and procedures, the conditions delineated in the NCSA. Operational aids such as postings, l
l labels, boundaries for fissile material operations, and fissile material movement guidelines are l
PROPOSED RAC 99-XOO15,2/25/99
Issue 9(R), Page 2 Nuclear Criticality Safety Approval Implementation l provided as specified in the NCSA. First-line management ensures postings and labels are prepared l and verifies that they are properly installed as required by the NCSA. The procedures are prepared 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 l begins."
I l
5.2.2.6 Procedure Requirements [Rev. 3, S/31/96]
i I
l
" Operations to which NCS pertains shall be governed by written procedures or job task l checklists. These procedures or checklists contain the appropriate NCS controls for processing, l storing, and handling of fissile material. The NCSA requirements which require employee actions l shall be incorporated into the procedure.... The NCSA requirements are incorporated into the l appropriate procedures or job task checklists as required by the NCS evaluation and approval l procedure."
l l
5.2.2.7 Posting and Labeling Requirements (Rev. 3,5/31/%]
l l
"NCS limits and controls for areas, equipment, and containers are presented through the use l of postings and labels as specified in the approved NCS As and procedures. Postings and labels are l proposed, reviewed, and approved during the NCSA review and approval process.... Approved l NCSAs specify the wording for the postings. Labels are prepared in accordance with the plant l NCS procedures and used as required by NCSAs."
l l
5.2.2.8 Change Control [Rev. 3,5/31/96]
l l
"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....
l l
Functional and physical characteristics of operations controlled for NCS are described in l NCSAs and NCSEs..,. If an item is relied on for the criticality safety of an operation, it will be j identified through the work control process as an NCS SSC [ structure, system, or component], and l Criticality Safety approval is required before implementing the change.... [M]odifications to l controlled operations are evaluated and approved prior to implementation."
l l
5.2.2.9 Operation Surveillance and Assessment [Rev. 3,5/31/96]
l l
"In order to ensure that the NCS program is properly established and implemented, USEC l utilizes walk-throughs, assessments, and audits.
I l
NCS walk-throughs are performed by Criticality Safety personnel to determine the adequacy l of implementation of NCS requirements and to verify that conditions have not been altered to l adversely affect NCS....
l l
[A]ssessments include the inspection of facility modifications and changes, operating l procedures, and compliance with NCSAs.
.l l
Identified deficiencies are documented and corrected according to the problem reporting l system described in Section 6.9 of this SAR and Section 2.18 of the Quality Assurance Plan."
l RAC 99-X0015,2/25/99 PROPOSED
Nucicar Criticality Safety Approval Implementction Issue 9(R), Page 3 DESCRIPTION OF NONCOMPL!ANCE l
1 There are inconsistencies between the specifications in NCSAs and the supporting l
implementation procedures and work-site postings. The known inconsistencies are minor I
ambiguities, small discrepancies in dimensions, and variances in format or location of postings.
l l
I JUSTIFICATION FOR CONTINUED OPERATION l
l The plant's 40-year history of safe operation with fully enriched uranium demonstrates the l
safety of the nuclear criticality controls for uranium in the physical and chemical forms employed l
in the facility. Corrective actions in response to the NCS violations and assessment findings have l
continued to strengthen the NCS controls. With USEC production at a reduced maximum l
235 2
enrichment of 10 wt %
U (and the purge gas section limited to 20 wt % 35U), operations j
designed for fully enriched :35U now have increased criticality safety margins.
l l
Some inconsistencies exist between the NCSA specifications, the implementing procedures, l
and the work-site postings as a legacy from earlier times when the format, content, and update l
practices were less formal than currently required by either DOE or NRC for NCS documentation l
and controls. These deviations have been and are being corrected whenever they are discovered l
during operations, maintenance, or walk-through and other inspections. For example, in late 1994 l
a verbatim-compliance walkdown review was performed of the existing NCS documentation to l
verify the flowdown of the NCS requirements into plant postings. The identified deviations in NCS l
controls (including unspecified tolerances on separation distances; missing or unclear specification l
limits; and missing, inconsistently worded, or out-of-date postings) were investigated, l
characterized, and resolved to upgrade the NCS controls. Resolution of remaining documentation l
deficiencies will coincide with the ongoing Nuclear Safety Upgrade initiative (and with the l
compliance plan issue " Nuclear Criticality Safety Approval Documents").
l l
Some other implementation inconsistencies resulted from the process of upgrading the overall l
NCS posting system. After developing and revising NCSA and NCSE documentation, the l
procedures and postings are upgraded before the new or revised NCSAs and NCSEs are put into l
effect.
l I
The results of the 1994 verbatim-compliance walkdown showed that the identified deviations l
between NCSA specifications and postings were minor ambiguities, small-discrepancies in l
dimensions, or variances in format or location of postings. Based on this sampling of represeritative l
NCSAs, the risks associated with any unidentified deviations are extremely low for operations l
meeting the double-contingency principle because at least two independent and concurrent process l
changes can be accommodated before a criticality accident is possible. The operations that do not I
meet the double contingency principle have a similar level of assurance of safety through l
moderation controls and associated Technical Safety Requirements as discussed in Application j
section 5.2.2.3.
l l
The NCSAs being revised mder NCS document upgrade programs cover operations existing l
prior to July 1,1993. The rt "ty of the requirements are already in the procedures for the l
existing process operations. In December 1997, an NCS Corrective Action Plan was established, l
in part, to upgrade NCSA/Es and improve implementation. Verification of the NCS requirements l
will be completed by March 3, 2000, for NCSA/Es upgraded as part of the NCS CAP.
l PROPOSED RAC 99-X0015,2/25/99
Issue 9(R), Page 4 Nuclear Criticality Safety Approv.11 Implementation l Implementation improvements for all NCSA/Es, which consist of SSC reclassification, procedure l revision and implementation, and training, will be completed by May 18,2001.
i l
l Continued safe operation until the actions under the Plan of Action and Schedule are completed l is assured by the following:
I l
Review of Priority 1 NCSA/Es was completed and all discrepancies and issues were resolved.
l An example of one of the issues resolved concerned NCSA/h PLANT 006, Small Diameter j
l Containers. It was found that the calculation assumption on aisle spacing did not carry over l
to controls. As a result, two storage areas were tagged-out until they were evaluated to be l
safe.
l l
NCSA problems causing the majority of event reports have been resolved. An example is l
NCSA/E PLANT 018, Dry Active Waste. Improved evaluations resulted in fewer spacing l
requirements which, in turn, resulted in reduction in NCS violations.
l l
The majority of problems found were implementation related. PORTS has made significant l
improvements in field implementation.
l I
l PLAN OF ACTION AND SCHEDULE l
\\
l A program is in place to review all NCSAs in order to identify and track the designated NCS l conditions, specifications, and controls and to verify their full imple entation. Particular attention l is being focused on ensuring consistency between each NCSA and the operation including l implementing procedures and work-site postings. The verification program will be completed by l March 3,2000, for NCSA/Es upgraded as pan of the NCS CAP. Implementation improvements i
l for all NCSA/Es, which consist of SSC reclassification, procedure revision and implementation, l and training, will be completed by May 18,2001.
l l
If a new or revised NCSE ident;fies the need for modifications to the existing plant l configuration, affected activities will be cunailed and will not be restarted until either (1) the plant l configuration is modified or (2) the activity is modified so that it can be performed safely in the l current configuration. If the plant configuration or activity is modified, the Plant Operations l Review Committee will review the proposed modification prior to its resumption to verify that the l activity, as modified, can be performed safely.
4 RAC 99-X0015,2/25/99 PROPOSED
Nuclear Criticality Safety Approval implementation Issue 9(R), Page 5
SUMMARY
OF REQUIREMENTS, COMMITMENTS, AND NONCOMPLIANCES l
l Issue: Nuclear Criticality Safety Approval Implementation l
Code of Federal Regulations Part l
L Title 10 76.35(a)(5), (6), and (7); 76.87(c)(3);
l 76 (general) l Application Commitment Section l
Safety Analysis Report 5.2.2.3, 5.2.2.6, 5.2.2.7, 5.2.2.8, 5.2.2.9, l
6.9 l
Technical Safety Requirements 3.9.1.c 3.11 l
Quality Assurance Program Appendix A-Section 1 l
Application Noncompliance Statement
. Section l
Safety Analysis Report 5.2.4.1, 5.2.4.2, 5.2.4.3, 5.2.4.4, 5.2.4.5, l
5.2.4.7, 5.2.4.11, 5.2.4.12 l
NRC Commitments Letter l
Portsmouth NCS Program Revised GDP 98-0255 l
Schedule l
Proposed Criteria for Reopening GDP 98-0264 l
Compliance Plan issues (Revised) l Reopening of Compliance Plan Issues GDP 99-0002 l
Compliance Plan Status Report GDP 99-0004 l
Portsmouth Nuclear Criticality Safety GDP 99-0020 l
Program Quarterly Status Report l
l l
I-
'i PROPOSED RAC 99-X0015,2/25/99 L
a i
Issue 23(R), Page 1
_ l l
Plant Changes and Configuration Management (Reopened) i l
REQUIREMENTS l
l
\\
10 CFR 76.68(a) "(a) The Corporanon may make changes to the plant or to the plant's l
)
operations as described in the safety analysis report without prior Commission approval provided l
l all the provisions of this section are met:
l 1
I (1) The Corporation shall conduct a written safety analysis which demonstrates that the l
changes would not result in undue risk to public health and safety, the common defense and l
security, or to the environment.
l (2) The changes must be authorized by responsible management and approved by a safety l
review committee.
l (3) The changes may not decrease effectiveness of the plant's safety, safeguards, and security l
programs.
l (4) The changes may not involve a change in any condition to the certificate of compliance.
l (5) The changes may not involve a change to any condition to the approved compliance plan.
l (6) The changes may not involve an unreviewed safety question."
l 1
i 10 CFR 76.93 "The Corporation shall establish, maintain, and execute a quality assurance l
program satisfying each of the applicable requirements of ASME NQA-1-1989, ' Quality Assurance l
Program Requirements for Nuclear Facilities,' or satisfying acceptable alternatives to the l
applicable requirements. The Corporation shall execute the criteria in a graded approach to an l
extent that is commensurate with the importance to safety."
l l
l COMMITMENT l
l Source: Safety Analysis Report l
- 6. Organization and Operating Programs l
6.3 Plant Changes and Configuration Management (Rev. 3,5/31/%)
j l
USEC has committed to ensuring that the review and approval of changes to the plant or l
plant's operation are accomplished in a controlled manner. This commitment includes the use of j a plant Configuration Management Program to control changes and to maintain the plant l
configuration as described in the application, including the Safety Analysis Report and the 1
Technical Safety Requirements.
l l
l DESCRIPTION OF NONCOMPLIANCE l
l The development and implementation of the Configuration Management Program for AQ-NCS {
items, as described in the application, has not been completed. The extent of noncompliance for l
this Configuration Management Program element is given here.
l i
i PROPOSED RAC 99-X0015,2/25/99
~.
q.
Issue 23(R), Page 2 Plant Changes and Configuration Management i
1 l
1.
Program Management. All augmented quality-nuclear criticality safety (AQ-NCS) items to l
l
~
be included in the scope of the Configuration Management Program have not been idcatified l
and documented.
l l
2.
Design Requirements. The review of the Nuclear Criticality Safety Approvals (NCSA) to l
identify AQ-NCS items (items which support the nuclear criticality double contingency L
l principle); identify and document the designated design requirements and the system l
boundaries, including support systems required for performance of the intended safety j
functions; and verify the implementation of these requirements has not been con'pleted.
t l
\\
l t
l JUSTIFICATION FOR CONTINUED OPERATION l
l 1.
Program Management. In recent years, plant management has become increasingly aware l
of the need for a Configuration Management Program. PORTS has maintained aspects of I
configuration management since initial plant startup. Efforts to develop and implement a l
Configuration Management Program are ongoing. A Configuration Management Program l
procedure has been developed and issued. This procedure provides management direction.
l establishes consistent concepts and terminology, and defines the scope of the program.
l identifies key roles and responsibilities, identifies organizational and programmatic interfaces, j
and provides a foundation for lower level implementing procedures.
l l
l The definition of the baseline for safety starting with the Safety Analysis Report, Process l
Hazards Analysis, Nuclear Criticality Safety Approvals, and other regulatory assessments to l
identify structures, systems, components, and design features for safety has been completed l
utilizing the process described in Application Section 6.3.5.3, with the exceptien of additional l
items required to support the double contingency principle as identified in NCSAs that will l
be upgraded and implemented as a result of the NCS CAP. This means that AQ-NCS items l
are identified; as-built configurations are verified with applicable technical and vendor data, l
or operability is verified; and safety functions are verified and documented. Section 3.8 of the
{
Application contains a current listing of the Q, AQ-NCS, and AQ systems and the associated l
boundary definitions. As additional AQ-NCS items are identified, Section 3.8 will be revised l
accordingly.
I l
2.
Design Requirements. The liquid UF, systems and cranes and associated equipment, which l
handle liquid UF., described in FSAR-GAT /GDP-1073 and all remaining Q items described 1
l in FSAR-GAT /GDP-1073, have been identified, ficld verified, and documented. The items l
within the system bedary required for these systems to operate as designed and to perform l
their safety functions have also been identified, field verified, and documented. Efforts are l
ongoing to identify, verify, and document the baseline for the AQ-NCS items resulting from l
the NCSA\\E upgrade project. All requests for engineering services involving plant changes l
are reviewed and approved by the Change Control Board (CCB). The CCB determines if l
PORC review and approval is required. Until the necessary design requirements are j
identified, verified, and documented, design requirements will be recovered and/or l
reconstituted on a case-by-case basis as reeded to support the review and approval of plant l
changes.
l l
l The above discussion regarding the ongoing efforts to develop and implement the l Configuration Management Program; and the identification, field verification. and documentation RAC 99-X0015,2/25/99 PROPOSED
=
l.
j I
\\
Plant Changes and Configuration Management Issue 23(R), Page 3 of the additional AQ-NCS items within the system boundaries provides justification that the plant l
can continue to operate safely until the Configuration Management Program is in place.
l I
l PLAN OF ACTION AND SCIIEDULE l
1 The additional actions required to complete the development and irrn* mentation of the l
Configuration Management Program and the schedule for completion of the. actions are given l
here.
l l
1.
Program Management l
l Identify and document all additional AQ-NCS items resulting from the NCSA/E Upgrade l
Program, including system boundaries and support systems required for performance of l the intended safety function, to be included in the scope of the Configuration l
{
Management Program. The scheduled completion date for these actions is May 19, 2000.
l l
Reverify and correct deficiencies in the flowdown of commitments from the Technical l
Safety Requirements, the Safety Analysis Report, and other plans and programs to l
procedures and training. The scheduled completion date for this action is March 15, l
2000.
l l
2.
Design Requirements l
l Review all Nuclear Criticality Safety Approvals and Nuclear Criticality Safety l
Evaluations to identify additional AQ-NCS items (items which support the nuclear l
criticality double contingency principle); to identify and document the designated design l
requirements and system boundaries, including support systems required for performance l
of the intended safety function; and to verify the implementation of these requirements.
l The scheduled completion date for this action is May 18,2001.
l l
PROPOSED RAC 99-X0015,2/25/99
- b Issue 23(R), Page 4 Plant Changes and Configuration Management l
SUMMARY
OF REQUIREMENTS, COMMITMENTS, AND NONCOMPLIANCES l
l Issue: Plant Changes and Configuration Management l
Code of Federal Regulations Part l
Title 10 76.35 (a)(4) and (6), 76.51, 76.68, 76.85, I
l 76.87(a), 76.87(c), 76.93, 76.95 l
l Application Commitment Section l
Safety Analysis Report 5.2.2.4, 5.2.2.6, 5.2.2.8, 5.4.6.2, 5.6.6, l
6.1.1.18, 6.2, 6.3, 6.4, 6.5, 6.6, 6.7, 6.8, 6.10, 6.11 l
Quality Assurance Program 2.3, 2.4, 2.6, 2.7, 2.8, 2.9, 2.10, 2.I1, 2.13, l
2.15, 2.17 I
l Appendix A-2.3, 2.4, 2.6, 2.7, 2.8, 2.9, i
l 2.10. 2.11. 2.13. 2.15, 2.17 l
Application Noncompliance Statement Section l
Safety Analysis Report 6.3.6.1, 6.3.6.2, 6.3.6.3, 6.3.6.4, 6.3.6.5, l
6.3.64 l
NRC Commitments Letter l
Portsmouth NCS Program Revised GDP 98-0255 l
Schedule l
Proposed Criteria for Reopening GDP 98-0264 l
Compliance Plan issues (Revised) l Reopening of Compliance Plan issues GDP 99-0002 l
l l
Compliance Phn Status Report GDP 99-0004 l
Portsmouth Nuclear Criticality Safety GDP 99-0020 l
Program Quarterly Status Report l
RAC 99-X0015,2/25/99 PROPOSED
,