ML20211Q785

Insp Rept 70-7002/99-205 on 990816-20.No Violations Noted. Major Areas inspected:Y2K Readiness Program

ML20211Q785
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant
Issue date:	09/10/1999
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20211Q781	List: ML20211Q776 ML20211Q785
References
70-7002-99-205, NUDOCS 9909150152
Download: ML20211Q785 (8)

Text

e U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS Docket No: 70-7002 Certificate No: GDP-2 Report No. 70-7002/99-205 Certificate Holder: United States Enrichment Corporation Location: Portsmouth Gaseous Diffusion Plant 3930 U.S. Route 23 South P.O. Box 628 Piketon, OH 45661 Inspection Dates: August 16 - 20,1999 Inspectors: D. Whaley, MC&A Physical Scientist, inspection Section D. McGowan, Technical Support, Pacific Northwest National Lab Approved by: Philip Ting, Chief Operations Branch Division of Fuel Cycle Safety and Safeguards, NMSS l

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United States Enrichment Corporation Portsmouth Gaseous Diffusion Plant inspection No. 70-7002/99-205 EXECUTIVE

SUMMARY

The NRC conducted a risk-informed, performance-based examination of Portsmouth Gaseous Diffusion Plant's (PORTS) Year 2000 (Y2K) Readiness Program. This matter requires priority attention because of limited time remaining to assess the magnitude of the problem, assess its )

associated risks, and implement programs that will achieve a satisfactory resolution of the Y2K problem.

YEAR 2000 READINESS l

• The inspectors concluded that the PORTS Y2K program had ensured that the actions taken were effective in resolving the Y2K problem and were in compliance with the terms and conditions of their certificate and NRC regulations.

• The test results and additional information provided subsequent to the inspection indicated ,

i the Dynamic Materials Control and Accountability System (DYMCAS) to be Y2K Ready.

'o The PORTS Y2K readiness program had adequately addressed the following elements which were identified in Generic Letter No.98-03: (1) management planning; i (2) implementation; (3) quality assurance; (4) regulatory considerations; and l

(5) documentation.

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1. Year 2000 Readiness (85501)

a. Inspection Scope The inspectors reviewed the PORTS Y2K program to ensure that the actions taken by the certificate holder are effective in resolving the Y2K problem and are in compliance with the terms and conditions of their certificate and NRC regulations. The following elements of the Y2K program were examined: (1) management planning; (2) implementation; (3) quality assurance; (4) regulatory considerations; and (5) documentation. The inspection was conducted after the certificate holder had completed responses to "NRC Generic Letter No. 98-03: NMSS Licensees' and Certificate Holder's Year 2000 Readiness Programs," and had acknowledged that PORTS was Y2K Ready.

b. Observations and Findinas The inspectors focused on the planning, implementation, quality assurance, regulatory considerations and the documentation for the Y2K remediation. The inspectors examined the risk significance designations of systems by PORTS. A designation of Level 1-S identified safety and safeguards systems with the greatest risk significance; Level 1-B and Level 2 did not impact safety but would impede the company operation; Level 3 were those systems whose failure would be isolated with no risk significance on safety and safeguards.

The inspectors focused on Level 1-S for readiness confirmation.

All systems that were reported in the Inventory stage were examined. Fifty-five systems were scrutinized with regard to planning, implementation, quality assurance, regulatory considerations, and the documentation. Additional information was gathered from interviewing plant personnel in the areas of Oversight, Operations, Power, Physical and Computer Security, and Material Control and Accounting.

During the examination of the work plans for the Level 1-S systems, it was noted that the Dynam;c Materials Control and Accountability System (DYMCAS) had a notation in the work plan that an integrated test would be made on the back-up system. Evaluation of the work plan by the inspectors indicated that while individual units had been tested for DYMCAS, the integrated test had not been performed. In the technicaljudgement of the inspectors, the integrated test noted in the work plan was necessary to provide adequate assurance of the performance of DYMCAS for Y2K. The incomplete test of the system as determined by the inspectors was currently of low risk significance given the time remaining before December 31,1999. Therefore, inspector Follow-up Item 70-7002/99-205-01 was opened to track the results of the integrated test of the DYMCAS system. The certificate holder felt the tests which had been completed for the DYMCAS system were adequate to ensure Y2K readiness, but agreed to complete the integrated test by September 3,1999. As a result of the determination by the inspectors that the integrated test noted in the work package had not been performed, the question was raised about the accuracy of the information provided by USEC in its July 1,1999 response to Generic Letter 98-03. The response stated, "The USEC Y2K readiness program is complete for impact Level One systems required for safe

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and compliant operation of PGDP and PORTS. As a result, PGDP and PORTS are Y2K Ready." Therefore Unresolved item 70-7002/99-205-02 was opened to further examine the issue when more information became available. An unresolved item is a matter about which more information is required to ascertain whether it is an acceptable item, a deviation, or a violation.

Readiness confirmation consisted of the examination of the initial assertion in the inventory document where systems were identified as compliant or non-compliant. Those systems that were declared compliant were further recearched for evidence supporting the compliance classification. This supporting evidence took the form of recorded tests (screen printouts and session captures) where the subject matter experts had exercised the system. At PORTS, the non-compliant items were tracked in a database and work plans contained detailed assessment and remediation information. In the context of the Y2K documentation for a given system, there were no contingency plans identified in the work plans for two Level 1-S systems at PORTS. This included the DYMCAS system and the GCEP fire system. During the inspection, information was provided that indicated specific contingency plans for the two systems existed but the information had not been included as part of the work plan.

Therefore, IFl 70-7002/99-205-03 was opened to track the certificate holder's efforts to include the contingency plan information in the work plan for ready access and reference in the event the plan was needed. Subsequent to the inspection, during the week of August 30,1999, USEC faxed information to NRC Headquarters documenting the inclusion of the contingency plan information in the work plans. The inspectors reviewed the documentation and concluded that IFl 70-7002/99-205-03 was closed.

PORTS has adequate contingency planning specific to a Y2K power loss scenario in addition to system specific contingency plans which were documented in the work plans as part of the Y2K documentation cycle.

Subsequent to the inspection, on August 30,1999, USEC had a telephone conference with representatives from the Fuel Cycle Safety and Safeguards Division. During the conversation, USEC stated that during the inspection, their representatives had not completely understood the questions about the DYMCAS system. After further evaluation of the issues, USEC had concluded that the oath and affirmation had been correct based on their review of the DYMCAS work package and their belief that a complete test had been performed including an integrated test on the DYMCAS system. In addition, USEC had completed the integrated test of DYMCAS the week of August 23,1999. The inspectors examined the additional test results of the DYMCAS test conducted by USEC, and concluded that the DYMCAS system had been thoroughly tested and appeared, based on the additional test results, to be Y2K Ready. Therefore, IFl 70-7002/99-205-01 was closed.

During a subsequent telephone conference on August 30,1999, members of FCSS explained to USEC the importance of providing clear and accurate information to the NRC in replies required to be submitted under oath and affirmation. The information provided by the j certificate holder is distributed by the NRC to the public and U.S. Congress on an as needed I basis and must be clear and accurate. The inspectors evaluated the additional information provided by the telephone conference, and via express mail. Since it appears that the 1

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5 originalinformation accurately reflected USEC's technical judgement on this issue, URI 70-7002/99-205-02 was closed. The inspectors concluded that all other Level 1-S systems at PORTS were Y2K Ready.

c. Conclusions The inspectors concluded that the PORTS Y2K program had ensured that the actions taken were effective in resolving the Y2K problem and were in compliance with the terms and conditions of their certificate and NRC regulations. The test results and additional information provided subsequent to the inspection indicated the DYMCAS system to be Y2K Ready. The PORTS Y2K readiness program had adequately addressed the following elements which were identified in Generic Letter No.98-03: (1) management planning; (2) implementation; (3) quality assurance; (4) regulatory considerations; and (5) documentation.

2. EXIT MEETING The inspection scope and results were summarized during a meeting on August 20,1999, with certificate holder personnel. The inspectors identified two inspector follow-up items, and an unresolved item. The certificate holder acknowledged the results of the inspection.

Subsequent to the inspection, additionalinformation was provided to the NRC by USEC via a telephone conference on August 30,1999. The inspectors closed the two IFls and the URI after the discussions with USEC on August 30,1999, and after evaluating the documentation provided to the NRC after the telephone call.

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! - 6 PARTIAL LIST OF PERSONS CONTACTED Certificate Holder A. Allen, Senior Manager Business Systems J. Blackmon, Maintenance M. Brown, General Plant Manager W. Bruttaniti, Vice President and Chief Information Officer L. Burt, Manager, Operational Applications Support G. Englert, Y2K Coordinator L. Fink, Manager, Safety, Safeguards, and Quality S. Fout, Operations D. Gash, DYMCAS Computer Engineer S. May, Plant Shift Superintendent P. Miner, Manager, Nuclear Regulatory Affairs J. Monroe, Computer Security M. Redden, Emergency Management M. Scott, director information Technology D. Shisler, Manager, Nuclear Material Control and Accounting R. Stein, Engineer J. Snodgrass, Section Manager, Protective Services NRC D. Hartland, PORTS Senior Resident inspector Exit Meeting Attendees INSPECTION PROCEDURES USED IP 85501 MC&A Management Structure I

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l ITEMS OPENED, CLOSED, AND DISCUSSED Opened 70-7002/99-205-01 IFl The certificate holder had not completed an integrated test of the DYMCAS system in preparation for Y2K.

70-7002/99-205-02 URI This item was open to examine the accuracy of USEC's oath and affirmation statement with regard to Y2K readiness.

l 70-7002/99-205-03 IFl The certificate holder had not included the contingency plans for DYMCAS and the GCEP fire system as part of the work plan for l ready access in the event the plan was needed.

1 Closed 70-7002/99-205-01 IFl The certificate holder had not completed an integrated test of the DYMCAS system in preparation for Y2K. Subsequent to the inspection, but prior to the final report, additional information was provided to the NRC which closed this item.

70-7002/99-205-02 URI This item was opened to examine the accuracy of USEC's oath and affirmation statement with regard to Y2K readiness.

Subsequent to the inspection, but prior to the final report, l additional information was provided to the NRC which closed l this item.

70-7002/99-205-03 IFI The certificate holder had not included the contingency plans for DYMCAS and the GCEP fire system as part of the work plan for ready access in the event the plan was needed. Subsequent to the inspection, but prior to the final report, additional information was provided to the NRC which closed this item.

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8 LIST OF ACRONYMS AND ABBREVIATIONS CFR Code of Federal Regulations DYMCAS Dynamic Materials Control and Accountability System GCEP Gaseous Centrifuge Enrichment Plant IFl Inspector Followup Item MC&A Material Control and Accounting Pl Physical Inventory PORTS Portsmouth Gaseous Diffusion Plant USEC United States Enrichment Corporation URI Unresolved item l

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