ML20211G974
| ML20211G974 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant, Paducah Gaseous Diffusion Plant |
| Issue date: | 08/26/1999 |
| From: | Berg L, Tripp C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Pierson R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9909010085 | |
| Download: ML20211G974 (3) | |
Text
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E NUCLEAR REGULATORY COMMISSION 4E WASHINGTON, D.C. 20555-0001 p
August 26, 1999 l
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MEMORANDUM TO: Robert C. Pierson, Chief
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Special Projects Branch Division of Fuel Cycle Safety and Safeguards, NMSS THROUGH:
Melanie A. Galloway, Chief l
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Enrichment Section
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Special Projects Branch Division of Fuel Cycle Safety and Safeguards, NMSS j
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FROM:
Lawrence J. Berg gp 0
Christopher S. Tripp Enrichment Section Special Projects Branch j
Division of Fuel Cycle Safety and Safeguards, NMSS l
SUBJECT:
PORTSMOUTH GASEOUS DIFFUSION PLANT ONSITE LICENSING REVIEW AUGUST 9-12,1999 i
On August 12,1999, we completed a three-day licensing review of activities associated with USEC's May 26,1999, Certificate Amendment Request (CAR) to reopen Compliance Plan issues 8,9, and 23 dealing with the nuclear criticality safety program at the Portsmouth plant.
The purpose of the onsite review was to support the Nuclear Regulatory Commission's (NRC's) assessment of USEC's CAR to reopen Compliance Plan issues 8,9, and 23 by determining the i
acceptability of !JSEC's proposal to reduce the scope of its Nuclear Criticality Safety (NCS)
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Corrective Action Plan (CAP) by performing only Augmented Quality (AO)-NCS reviews on 93 Priority 3 Nuclear Criticality Safety Approvals (NCSAs)/ Evaluations (Es) identified for additional review, and an additional 42 NCSAs/Es identified for consolidation or deletion.
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We reviewed the problem reports, completed checklists and a limited sample of Priority 3 O
i NCSAs/Es and determined that issues similar to those encountered with the Priority 1 and 2 i
NCSAs/Es existed. These issues included identification of processes not covered by l
NCSAs/Es, problems with the flowdown of criticality safety requirements into procedures and postings, administrative controls not being followed in the field, and discovery of "as-built"
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equipment that is different from the assumed design.
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'In response to NRC's issue with the adequacy of Priority 3 NCSAs/Es, USEC has committed to implementing draft procedure XP2-EG-NS1037, " Review of Non-Priority 1 and 2 NCSAs/Es."
This procedure contains a robust set of criteria for making the determination of the adequacy of n\\
the NCSA/E. The NRC requested that USEC add this commitment to NCS CAP Subtask 3.3. \\
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We also noted that 15 NCSAs/Es previously identified by USEC to be Priority 3 are on the consolidation or deletion list. Discussions with the Portsmouth nuclear criticality safety staff Indicated that several NCSAs/Es on this list are being consolidated into upgraded Priority 1 or 2 NCSAs/Es, or into the existing plant NCSA for abandoned in place equipment, NCSA PLANT 088," Storage of Abandoned Equipment." The remaining NCSAs/Es are being evaluated for deletion because they potentially cover non-fissile material operations. Because the NCSAs/Es identified on the consolidation / deletion list must undergo reviews, similar to those for the NCSAs/Es in the additional review list, prior to consolidation or deletion, and because these reviews have not been completed yet, we believe that the additional review process and list of NCSAs/Es should be broadened to include the NCSAs/Es identified for consolidation or deletion. This should ensure that all necessary Portsmouth NCSAs/Es receive a thorough review.
Additional issues identified Durino Facility Walkdown i
During a facility walk-down in Building X-333, we discovered problems with implementation of a completed Priority 1 NCSA. Specifically, we discovered a required NCS posting having a requirement which appeared to be optional. Upon further review of the NCSA, we found that the NCSA requirement in Part B of the NCSA was correctly worded but inconsistent with the wording specified for the posting. Operations posted the requirement in accordance with the NCSA but interpreted it as optional. Plant personnelissued a problem report.
During a facility walk-down in Building X-710, we discovered that temporary postings were in wide-spread use. The NRC is concerned that these postings could remain in place indefinitely.
These postings are not all readily identifiable as NCS postings, and in some cases, old or superseded postings remain in place.
Also in Building X-710, we discovered that Operations had posted a sign which provided
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interpretation or clarification of an NCS requirement. This posting had been in place since December 1997, but the NCSA has not been revised to provide the necessary clarification.
Distribution:
Dockets: 70-7001,70-7002 NRC File Center PUBLIC Y.Chen SPB r/f K. O'Brien, Rlil P. Hiland, Rill G:\\SPB\\LBJ2\\ Ports 899triprpt.wpd
(*See previous concurrence) b OFC SPB SPB SPB NAME
- LBerg:al
- DHoadley 8/ h /99 DATE 8/26/99 8/26/99 C = COVER E = COVER & ENCLOSURE N = NO COPY OFFICIAL RECORD COPY
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2 We reviewed the problem reports, completed checklists and a limited sample of Pri rity 3 NCSAs/Es and determined that issues similar to those encountered with the Pri y 1 and 2 NCSAs/Es existed. These issues included identification of processes not cov ed by NCSAs/Es, problems with the flowdown of criticality safety requirements in' procedures and postings, administrative controls not being followed in the field, and disc ery of "as-built" equipment that is different from the assumed design.
I We also noted that 15 NCSAs/Es previously identified by USEC be Priority 3 are on the consolidation or deletion list. Discussions with the Portsmouth clear criticality safety staff indicated that several NCSAs/Es on this list are being consol' ated into upgraded Priority 1 or 2 NCSAs/Es, or into the existing plant NCSA for abandoned ' place equipment, NCSA PLANT 088," Storage of Abandoned Equipment." The re aining NCSAs/Es are being evaluated for deletion because they potentially cover n -fissile material operations. Because the NCSAs/Es identified on the consolidation /deletio ist must undergo reviews, similar to those for the NCSAs/Es in the additional review list rior to consolidation or deletion, and because these reviews have not been completed et, we believe that the additional review process and list of PCSAs/Es should be broade ed to include the NCSAs/Es identified for consolidation or de.etion. This will ensure that I necessary Portsmouth NCSAs/Es receive a thorough review.
l l
During a facility walk-down in Building X-3, we discovered problems with implementation of a j
completed Priority 1 NCSA. Specifically we discovered a required NCS posting having a requirement which appeared to be opt' nal. Upon further review of the NCSA, we found that the NCSA requirement in Part B of t NCSA was correctly worded but inconsistent with the wording specified for the posting.
'perations posted the requirement in accordance with the NCSA but interpreted it as option. Plant personnel issued a problem report.
During a facility walk-down in uilding X-710, we discovered that temporary postings were in wide-spread use. The NRC js, concerned that these postings could remain in place indefinitely.
These postings are not all readily identifiable as NCS postings, and in some cases, old or superseded postings remain in place.
Also in Building X-710 e discovered that Operations had posted a sign which provided l
interpretation or clariffcation of an NCS requirement. This posting had been in place since December 1997, but the NCSA has not been revised to provide the necessary clarification.
J 1
Distribution:
Dockets: 70-7001,70-7002 NRC File Center PUBLIC Y.Chen SPB r/f K. O'Brien, Rlli P. Hiland, Rlli G:\\SPB\\LBJ2\\ Ports 899triprpt.wpd i
OFC SPB
..k SPB
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SPB LBeh D
y MGalloway NAME DATE 8/
/99 8/ 24 /99 8/
/99 C = COVER E = COVER & ENCLOSURE N = NO COPY I
OFFICIAL RECORD COPY