ML20210G051

Compliance Evaluation Rept Accepting QAP Descriptions

ML20210G051
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant, 07007001
Issue date:	07/26/1999
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20210G042	List: ML20210G039 ML20210G051 ML20210G058
References
NUDOCS 9908020278
Download: ML20210G051 (6)

Text

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44 9 p -t UNITED STATES j

.s NUCLEAR REGULATORY COMMISSION

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2 WASHINGTON. D.C. 20066-0001

! , , g . ,o July 26, 1999 l

l DOCKETS: 70-7001 and 70-7002 i

CERTIFICATE HOLDER: United States Enrichment Corporation Paducah and Portsmouth Gaseous Diffusion Plants Paducah, Kentucky and Portsmouth, Ohio l

SUBJECT:

COMPLIANCE EVALUATION REPORT: APPLICATIONS l

DATED FEBRUARY 12,1999, QUALITY ASSURANCE PROGRAM CHANGE ACCEPTANCE BACKGROUND By letters dated February 12,1999, the United States Enrichment Corporation (USEC) l submitted certificate amendment requests (CARS) regarding the Certificates of Compliance for

.the Paducah Gaseous Diffusion Plant (Paducah) and the Portsmouth Gaseous Diffusion Plant (PORTS). By letter dated March 18,1999, the Nuclear Regulatory Commission (NRC) staff requested additional information to further evaluate the amendment requests. By letter dated l April 16,1999, USEC staff provided the additional information. The amendment requested a revision to the Paducah and PORTS Quality Assurance Program (OAP) descriptions to include additional ways to approve suppliers for inclusion on the Approved Suppliers List and to clarify

! the audit requirements applied to suppliers conducting work under the USEC OAP.

DISCUSSION The specific QAP revisions requested by USEC and the staff's evaluations are Jiscussed below.

1. Revise Section 2.4.3.1-3 (Paducah) and Section 2.4.3.1.2 (PORTS) so that l each section recognizes the alternatives to ASME-NOA-1-1989 that are

! requested for Section 2.7.3.2 regarding supplier qualification.

I This is an editorial change that clearly shows that the USEC requests involve an alternative to ASME-NOA-1-1989. It was not clear, however, that the references to Section 2.7.3.2 did not include some alternatives that are not acceptable; and i the NRC requested clarification. The USEC response clarified the proposed change to Section 2.4.3.1-3 (Paducah) and Section 2.4.3.1.2 (PORTS) to show that only the acceptable alternatives to ASME-NOA-1-1989 were proposed. As clarified, and since the proposed alternatives do not contradict the requirements of ASME-NOA-1-1989, the proposed revisions to Section 2.4.3.1-3 (Paducah) and Section 2.4.3.1.2 (PORTS) are acceptable to the NRC staff. l t

2. For both Paducah and PORTS, revise Sections 2.7.3.2 and 2.7.3.2-2 to clarify the meaning of the current wording.

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The changes make it more clear that the commitments are in agreement with the requirements of ASME-NOA-1-1989. For example, the revisions indicate that  ;

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supplier evaluations will be documented. The NRC staff understood that this has been done in the past, but now there is a specific commitment. These revised sections are acceptable to the NRC staff.

3. For both Paducah and PORTS, revise Section 2.7.3.2-1 to clarify that the evaluation of a supplier's history must also consider whether the supplier is currently capable of performing to the level indicated by the historical performance.

USEC noted that this makes the commitment more conservative. The NRC staff agrees and finds the proposed revision to Section 2.7.3.2-1 acceptable for both Paducah and PORTS.

4. For both Paducah and PORTS, revise Section 2.7.3.2-3 to specify that the OA program of a Paducah and/or PORTS supplier that satisfies the applicable requirements of Appendix B to 10 CFR Part 50 also satisfies the applicable requirements of ASME-NOA-1-1989.

The NRC staff does not disagree and finds the proposed change acceptable.

5. For both Paducah and PORTS, add Sections 2.7.3.2-4,2.7.3.2-5, and 2.7.3.2-6 to the OAP Descriptions.

Section 2.7.3.2-4 will allow USEC to use the results of third-party nuclear QA audits in its supplier selection process. USEC has committed to perform over-checks that will ensure that the results of the third-party nuclear QA audits will provide the same level of selectivity for suppliers as would be present if USEC conducted its own audits. Section 2.7.3.2-5 is an extension of Section 2.7.3.2-4 in that it allows USEC to use a supplier of calibration services based on the supplier's valid " certificate of accreditation" from the National Institute of Standards and Technology. Section 2.7.3.2-6 is also an extension of Section 2.7.3.2-4 in that it allows USEC to use a supplier whose OAP has been accepted by the NRC. Both Sections 2.7.3.2-5 and 2.7.3.2-6 require an implementation  ;

audit once the supplier has started work for USEC. The addition of these l sections is acceptable to the NRC staff, for both Paducah and PORTS, as i providing acceptable alternatives to the requirements of ASME-NOA-1-1998 in that they do not contradict the standard and they will result in a comparable level )

l of OA. -

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6. For both Paducah and PORTS, revise Section 2.18.3.2-3b (and the corresponding commitment in Section 2.18.3.2-4b of each OAP Appendix A) to delete "onsite" and " direct" from: " Suppliers of services do not require external audit if they perform work onsite using the USEC OAP and procedures under direct USEC Supervision."

These limitations are not part of the ASME-NOA-1-1989 requirements. In response to an NRC request, USEC acceptably described how it would provide supervision for supplier services and committed to include these controls in the i

,o July 26, 1999

. applicable USEC procedures as part of its implementation of the CARS. Therefor , the indicated deletions are acceptable to the NRC staff.

The NRC staff included two editorial comments in its request for additional information regarding the USEC CARS. USEC addressed the editorial comments acceptably in its responses.

ENVIRONMENTAL REVIEW lssuance of amendments to the Certificates of Compliance GDP-1and GDP-2 revising the Quality Assurance Program (OAP) descriptions to include additional ways to approve suppliers for inclusion on the Approved Suppliers List and to clarify the audit requirements :pplied to suppliers conducting work under the USEC QAP is subject to the categorical exclusion provided in 10 CFR 51.22(c)(19). Therefore, neither an environmental assessment nor an environmental impact statement is required for the proposed action.

CONCLUSION Based on the NRC staff's review of the information provided by USEC in its CARS and in .

response to the staff's request for additional information, the staff concludes that the USEC OAP descriptions will continue to meet the NRC OA requirements specified for Paducah and PORTS in 10 CFR Part 76, specifically 76.93," Quality Assurance." Therefore, the staff concludes that USEC can implement its proposed QAP description changes at Paducah and PORTS.

The Region lil Inspection staff has no objection to tnis proposed action.

Principal Contributor John G. Spraul DISTRIBUTION: (Control Nos. 470S and 540S)

Dockets 70-7001 and 70 7002 O

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