ML20217G173
| ML20217G173 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant, 07007001 |
| Issue date: | 10/14/1999 |
| From: | Yawar Faraz NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Adkins J UNITED STATES ENRICHMENT CORP. (USEC) |
| References | |
| TAC-L32129, TAC-L32130, NUDOCS 9910210211 | |
| Download: ML20217G173 (14) | |
Text
'v October 14, 1999
.,, Mr. Jam:s N. Adkins Vice President, Production U. S. Enrichment Corporation 2 Democracy Center 6903 Rockledge Drive Bethesda, MD 20817
SUBJECT:
PADUCAH AND PORTSMOUTH GASEOUS DIFFUSION PLANT: QUALITY ASSURANCE PROGRAM CHANGE - REQUEST FOR ADDITIONAL INFORMATION (TAC NOS. L32129 AND L32130)
This refers to your applications dated September 24,1999, requesting amendments to the Certificates of Compliance for the Paducah and Portsmouth Gaseous Diffusion Plants for the ;
revised Quclity Assurance Programs.
Our review of your applications has identified additional information that is needed before final action can be taken on your requests. The additional information, specified in the enclosure, i should be provided within 30 days of this letter. Please reference the above TAC Nos. in future correspondence related to this request.
If you have questions regarding this request, please contact Charlie Cox for Paducah at (301) 415-6755 or me for Portsmouth at (301) 415-8113.
Sincerely, signed by Y. Faraz Yawar Faraz, Project Manager Enrichment Section Special Projects Branch ,
Division of Fuel Cycle Safety )
and Safeguards, NMSS ]
Dockets 70-7001,70-7002 Certificates GDP-1, GDP-2
Enclosure:
Request for Additional Information cc: Mr. Steven Toelle, USEC Mr. Randall DeVault, DOE go-#- jg{Ngipyggpede',
a U
e F ti R R.li I , gg Mr. Howard Pulley, PGDP Mr. Morris Brown, PORTS DISTRIBUTION: (Control Nos. 630S and 550S, Docket Nos. 70-7001 and 70-7002)
PUBLIC NBCFHeCen A NMSS r/f FCSS r/f SPB r/f Rlli KO'Brien, Rill DHartland, Rlli PHiland, Rlli WSchwinki, FCOB RPierson MTekar DOCUMENT NAME: G:\SPBLIGS1\GDP.RAl.wpd (*see previous con:urrence) k To receive a copy.of this document, indicate in the oox: C = copy without enclosure E = Copy with enclosure N = No cop'r OFC . WIP E SPB E sPB E sPB E SPB E SPB NAME\ spraut al *DAHoadley ' Y JChen(N/A) *CCox YHFaraz di ay DATE I 10/6&14/99 10/6/99 10/- /99 10/13/99 10/13/99 10 9
~l OFFICIAL RECORD COPY 9910210211 991014 PDR ADOCK 07007001 C PDR
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," Mr. Jim::s N. Adkins Vice President, Productioa U. S. Enrichment Corporation
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2 Democracy Center 6903 Rockledge Drive-Bethesda, MD 20817
/
SUBJECT:
PADUCAH AND PORTSMOUTH GASEOUS DIFFUSION PLANT. QUALITY ASSURANCE PROGRAM CHANGE - REQUEST FOR AD ITIONAL INFORMATION (TAC NOS. L32129 AND L32130) l This refers to your applications dated September 24,1999, reque ing amendments to the Certificates of Compliance for the Paducah and Portsmouth G eous Diffusion Plants for the l revised Quality Assurance Programs.
J l
Our review of your applications has identified additional i ormation that is needed before final action can be taken on your requests. The additional ' ormation, specified in the enclosure, should be provided within 30 days of this letter. Ple e reference the above TAC Nos. in future correspondence related to this request.
If you have questions regarding this request, ase contact Charlie Cox for Paducah at (301) 415-6755 or me for Portsmouth at (30 415-8113.
Sincerely, Yawar Faraz, Project Manager ;
Enrichment Section ;
Special Projects Branch Division of Fuel Cycle Safety and Safeguards, NMSS Dockets 70-7001,70-7 2-Certificates GDP-1, ,
P2 .
Enclosure:
Request for Additional Information cc: Mr. Steven Toelle, USEC Mr. Randall DeVault, DOE _
Mrc -Le,1 i'6vn, 5P6 Mrr.2cTchar,SP9 DISTRIBUTION: (Control Nos. 630S and 5508, D et Nos. 70-70 11,and 70-7002)
PUBLIC KO'Brien, Rill t'RC File Center UHartland, Rill NMSS r/f PHiland, lil FQf
- ^/. ,,000 "'E(
- g SPg/ .
40B Rlli DOCUMENT NAME: G:\SPBklGS1\GDP.RAl.wpd To receive a copy of this document, Indicate in the box: C = copy . " andnsue My with enclosure N = No cop'r OFc _ SP& E SPB E sPB E SPB E sPB E sPB NAME praul.a! ' oadley Y hen x YHFara MAGalloway DATE 10/6/09 10/h /99 10/ /99 10 0 /99 10/f)/99 10/ /99 OFFICIAL RECORD COPY w
. casou k UNITED STATES
'j{ j NUCLEAR REGULATORY COMMISSION
.g g WA8HINGTON, D.C. 20656-0001
- October 14, 1999.
Mr. James N. Adkins Vice President, Production
. U. S. Enrichment Corporation 2 Democracy Center '
- 6903.Rockledge Drive Bethesda, MD 20817
SUBJECT:
PADUCAH AND PORTSMOUTH GASEOUS DIFFUSION PLANT: QUALITY ASSURANCE PROGRAM CHANGE - REQUEST FOR ADDITIONAL INFORMATION (TAC NOS. L32129 AND L32130)
This refers to your applications dated September 24,1999, requesting amendments to the Certificates of Compliance for the Paducah and Portsmouth Gaseous Diffusion Plants for the revised Quality Assurance Programs.
Our review of your applications has identified additional information that is needed before final action can be taken on your requests. The additional information, specified in the enclosure, should be provided within 30 days cf this letter. Please reference the above TAC Nos. In future correspondence related to this request.
If you have questions regarding this request, please contact Charlie Cox for Paducah at
-(301) 415-6755 or me for Portsmouth at (301) 415-8113.
Sincerely,
~
[ L Ya ar Faraz, Project Manager Enrichment Section Special Projects Branch Division of Fuel Cycle Safety and Safeguards, NMSS Dockets 70-7001,- 70-7002
- Certificates GDP-1, GDP-2
Enclosure:
. Request for Additional Information
. cc: Mr. Stever Toelle, USEC Mr. Randall DeVault, DOE -
.._Mr. Howard Pulley, PGDP -
Mr. Morris Brown, PORTS
4 Request for AdditionalInformation l
Application dated September 24,1999 Quality Assurance Program United States Enrichment Corporation Paducah and Portsmouth Gaseous Diffusion Plants Dockets 70-7001 and 70-7002 l . .
Note that each requeet for aMitional information shown below is applicable to both plants and
. should be addressed accordingly.
Please provide the following information:
- 1. USEC proposes to revise the first sentence of QAP Section 2.4.3 to state: 'The l requirements of Section 2.4.3.1 apply only to non-commercial grade items and services."
While Paragraphs 3 and 4 of Section 2.4.3.1 Indicate that they are for non-commercial procurements, Paragraphs 1,2, and 5 of Section 2.4.3.1 do not include this limitation, it appears that these paragraphs (1,2, and 5) should not be so limited. Clarify the applicability of Paragraphs 1,2, and 5 of Section 2.4.3.1 or justify not doing so.
- 2. USEC proposes to revise the first sentence of QAP Section 2.7.3 to state: " Sections 2.7.3.1 through 2.7.3.8 apply to non-commercial grade items and services." It seems that some of the commitments in these sections should also apply to commercial grade procurements, for example, Procurement Planning (2.7.3.1) and Supplier Selection (2.7.3.2). These examples do not appear to be addressed in Sections 2.7.3.9 or 2.7.3.10 either. Clarify the applicability of Sections 2.7.3.1 through 2.7.3.8 orjustify not doing so.
- 3. QAP Sections 2.7.3.10 (1.c) and 2.7.3.10 (9) both refer to "the manufacturer's published l product description or other appropriate documents.". Since these sections are for services I rather than items, " manufacturer's" does not appear to be appropriate and should be !
replaced by " service provider's" or some other more appropriate term. Also, provide
- examples of what USEC would consider to be "other appropriate documents" or justify not doing so.
- 4. QAP Section 2.7.3.10 (2) refers to obtaining reasonable assurance that the commercial grade service meets specified requirements. Clarify what organization is responsible for specifying the requirements that must be met and where these requirements will be documented or justify not doing so.
- 5. Editorially, QAP Section 2.7.3.10 (4) is not a sentence, and it appears that words such as "shall be applied" should be added or that some other change should be made to make it a sentence.
- 6. QAP Section 2.7.3.10 (5) indicates that either a commercial grade survey or an acceptable supplier service performance record can be used as the method of acceptance of a commercial grade service. Either of these activities, in and of itself, does not appear to be capable of ensuring the acceptability of a service. Clarify the commitment in this regard or justify not doing so.
Enclosure 1:
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- 7. QAP Section 2.7.3.9 (5) describes the basis for selecting the method or combination of methods used to accept commercial grade items.~ Describe the basis for selecting the method or combination of methods used to accept commercial grade services or justify not doing so.
- 8. Regarding source evaluation and selection, QAP Section 2.7.3.9 (7) for procurement of l commercial grade items refers to Section 3.1 of Supplement 7S-1 of ASME NOA-1,1989.
!- ' QAP Section 2.7.3.10 (7) for procurement of commercial grade services refers to QAP Section 2.7.3.2. These two references are comparable except that NOA-1 requires that supplier history must reflect current capability. Include this requirement for services or justify not doing so.
- 9. QAP Section 2.7.3.9 (7)' specifies that commercial grade items are receipt inspected "to ensure that required documentation is received and is acceptable." Specify in QAP
.Section 2.7.3.10 how USEC ensures that required documentation for commercial grade services is received and is acceptable or justify not doing so.
- 10. USEC proposes to revise the second sentence of Section 2.7.3 of QAP Appendix A to state:"AQ services shall be in accordance with the requirements of Section 2.7.3.10 of the !
- - O program." This indicates that all AQ services will be precured as commercial grade. l While this sounds like a reasonable approach, it is not obvious that all AQ services can be l
" ordered from the manufacturer / supplier on the basis of a specification set forth in the l
- manufacturer's published product description (e.g., catalog) or other appropriate l'
documents _" aa specified in the proposed QAP Section 2.7.3.10 (1.c). Clarify USEC ,
commitments regarding the procurement of AQ services orjustify not dcing so. (Also refer to Request for Additional Information 3 above.) i l
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i Enclosure o
1 1
Request for Additional Information Application dated September 24,1999
- Quality Assurance Program
'_ United States Enrichment Corporation Paducah and Portsmouth Gaseous Diffusion Plants Dockets 70-7001 and 70-7002 Note that each request for additional information shown below is applicable to both plants and
'should be addressed accordingly. I Please provide the following information: j
- 1. USEC proposes to revise the first sentence of QAP Section 2.4.3 to state:"The . j requirements of Section 2.4.3.1 apply only to non-commercial grade items and services." ;
While Paragraphs 3 and 4 of Section 2.4.3.1 indicate that they are for non-commercial l procurements, Paragraphs 1,2, and 5 of Section 2.4.3.1 do not include this limitation. It '
appears that these paragraphs (1,2, and 5) should not be so limited. Clarify the applicability of Paragraphs 1,2, and 5 of Section 2.4.3.1 or justify not doing so.
- 2. USEC proposes to revise the first sentence of QAP Section 2.7.3 to state:" Sections 2.7.3.1 through 2.7.3.8 apply to non-commercial grade items and services." It seems that
- some of the commitments in these sections should also apply to commercial grade 1 procurements, for example, Procurement Planning (2.7.3.1) and Supplier Selection ,
(2.7.3.2). These examples do not appear to be addressed in Sections 2.7.3.9 or 2.7.3.10 )
- either. Clarify the applicability of Sections 2.7.3.1 through 2.7.3.8 or justify not doing so.
' 3. QAP Sections 2.7.3.10 (1.c) and 2.7.3.10 (9) both refer to "the manufacturer's published product description or other appropriate documents." Since these sections are for services ,
rather than items, " manufacturer's" does not appear to be appropriate and should be l
< replaced by " service provider's" or some other more appropriate term. Also, provide l examples of what USEC would consider to be "other appropriate documenic" or justify not doing so.
- 4. QAP Section 2.7.3.10 (2) refers to obtaining reasonable assurance that the commercial grade service meets specified requirements. Clarify what organization is responsible fc?
specifying the requirements that must be met and where these requirements will be documented or justify not doing so.-
- 5. ~ Editorially, QAP Section 2.7.3.10 (4) is not a sentence, and it appears that words such as "shall be applied" should be added or that some other change should be made to maKO it a sentence.
- 6. QAP Section'2.7'3.10 (5) indicates that either a commercial grade survey or an acceptable -
- supplier service performance record can be used as the method of acceptance of a commercial grade service. Either of these activities, in and of itself, does not appear to be apable of ensuring the acceptability of a service. Clarify the commitment in this regard or just3y not doing so.
Enclosure
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l 7 QAP Section 2.7.3.9 (5) describes the basis for selecting the method or combination of
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l' methods used to accept commercial grade items. Describe the basis for s deting the 1 l ~ method or combination of methods used to accept commercial grade servir or justify not doing so.
- 8. Regarding source evalu'ation and selection, QAP Section 2.7.3.9 (7) for procurement of commercial grade items refers to Section 3.1 of Supplement 7S-1 of ASME NOA-1,1989.
QAP Section 2.7.3.10 (7) for procurement of commercial grade services refers to QAP Section 2.7.3.2. These two references are comparable except that NOA-1 requires th;t supplier history must reflect current capability. Include this requirement for services or justify not doing so.-
- 9. - QAP Section' 2.7.3.9 (7) specifies that commercial grade items are receipt inspected "to ensure that required documentation is received and is acceptable." Specify in OAP Section 2.7.3.10 how USEC ensures that required documentation for commercial grade services .ls received and is acceptable or justify not doing so.
- 10. , USEC proposes to revise the second sentence of Section 2.7.3 of_QAP Appendix A to
- state:."AQ services shall be in accordance with the requirements of Section 2.7.3.10 of the Q program." This indicates that all AQ services will be procured as commercial grade.
While this sounds like a reasonable approach, it is not obvious that all AQ services can be
'" ordered from the manufacturer / supplier on the basis of a specification set forth in the manufacturer's published product description (e.g., catalog) or other appropriate documents" as specified in the proposed QAP Section 2.7.3.10 (1.c). Clarify USEC commitments regarding the procurement of AQ services or justify not doing so. (Also refer to Request for Additional Information 3 above.) j i
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PADUCAH & PORTSMOUTH COMMERCIAL GRADE ITEMS COMMERCIAL GRADE SERVICES (2.7.3.9) (2.7.3.10)
Procedures are established goveming the application OK and use of commercial grade items
- 1. Methods for determining whether an item can be 1. Methods for determining whether a service can be OK ,
purchased as commercial grade and dedicated for use purchased as commercial grade and dedicated for use I in a O application. A commercial grade item is an item in a O application are established and implemented. A satisfying all of the following: commercial grade service is a service satisfying all of l the following: l
- a. Not subject to design or specification requirements a. Not subject to design or specification requirements OK that are unique to the nuclear facility. that are unique to GDP facilities or activities;
- b. Used in applications other than nuclear facilities. b. Used in applications other than GDP facilities or OK activities; and
- c. Is to be ordered from the manufacturer / supplier on c. Is to be ordered from the manufacturer / supplier on O-3 the basis of a specification set forth in the the basis of a specification set fortt 'n the 1 manufacturer's published product description (e.g., manufacturer's published product description (e.g , '
cataloq). catalog) or other appropriate documents. l
- 2. The criteria and methods for identifying the critical 2. The criteria and methods for identifying the critical Q-4 characteristics that are essential to ensure that the characteristics (critical controls) for acceptance are item will perform its intended O function. established. The critical characteristics (critical l controls), which once selected to be verified, provide reasonable assurance that the service provided meets specified requirements.
- 3. The criteria for determining the type and depth of 3. In selecting the critical controls, the impact of the OK product acceptance and the criteria for determining the activities associated with the service on the safety point of dedication at which time USEC assumes the function of plant equipment is considered.
responsibility for rqnortability.
Dedication of a cv . ..e.cial grao hem occurs after 4. If there are no critical controls that impact the safety Q-5 receipt when that dem is designated for use in a O function of the plant equipment that can be applied to (Edit) application. (See ' service
- item 6.) the service, then administrative controls for the service such as controls over the process or qualification of personnel shall be applied (7).
- 4. Methods used to accept (dedicate) commercial 5. Methods of acceptance of commercial grade OK grade items are receipt inspection as required by services are established and include any one or l 2.7.3.9.10 or one or more of the following as combination of the following:
! determined by engineering:
- a. Special test a. Special test and inspections OK
- b. Commercial grade survey of supplier b. Commercial grade survey Q-6
- c. Source verification c. Source verification OK
- d. Acceptable supplier and item performance record d. Acceptable supplier service performance record Q-6
- 5. The selection of the method or combination of Q-7 methods in 4.above is based on the following:
- a. Selected critical characteristics
- b. Available supplier information
- c. Quality history
- d. Degree of standardization
- e. Importance to safeiy and complexity of the item
- 6. Dedication of a commercial grade service occurs OK when that service is accepted in accordance with 2.7.3.10.5 above.
- 7. Source evaluation and selection, where deemed 7. Source evaluation and selection, where deemed Q-8 necessary by the engineering based on complexity and necessary by engineering based on complexity and importance to safety, shall be in accordance with the importance to safety, is in accordance with the requirements of Section 3.1 of Supplement 7S-1 of requirements of Section 2.7.3.2. i ASME NOA-1,1989.
- 8. Procurement documents are issued and controlled 8. Procurement documents are issued and controlled OK in accordance with the requirements of Sections in accordance with the requirements of Sections -
2.4.3.2 and 2.4.3.3 of this OAP. 2.4.3.2 and 2.4.3.3 of this OAP. !
1
- 9. Commercial grade items are identified in the 9. Commercial grade services are identified in the Q-3 l pdase order by the manufacturer's published purchase order by the manufacturer's published i product description. product description or other appropriate documents.
- 10. Receipt inspections are performed . . and to OK except as highligb94 O-9 ensure that required documentation is received and is acceptable.
- 11. The requirements of other sections of this OAP OK !
apply once a commercial grade item is dedicated and determined acceptable for use in a O application. l
- 3. CAP Sections 2.7.3.10 (1.c) and 2.7.3.10(9) both refer to "the manufacturer's published product description or other appropriate documents." Since these sections are for services rather than items, " manufacturer's" doe not appear to be appropriate and should be replaced by " service provider's" or sc- ior more appropriate term. Also, provide examples of what USEC would cons- be "other appropriate documents" or justify not
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doing so. ;
- 4. QAP Section 2.7.3.10 (2) refers to obtaining reasonable assurance that the commercial grade service meets specified requirements. Clarify what organization is responsible for specifying the requirements that must be met and where these requirements will be documented or justify not doing so.
- 5. Editorially, OAP Section 2.7.3.10 (4) is not a sentence, and it appears that words such as i "shall be applied" should be added or that some other change should be made to make it a sentence.
- 6. CAP Section 2.7.3.10 (5) indicates that either a commercial grade survey or an acceptable supplier service performance record can be used as the method of acceptance of a commercial grade service. Either of these activities, in and of itself, does not appear to be capable of ensuring the ace- .bility of a service. Clarify the commitment in this regard or justify not doing so.
- 7. OAP Section 2.7.3.9 (5) describes the basis for selecting the method or combination of methods used to accept commercial grade items. Describe the basis for selecting the method or combination of methods used to accept commercial grade services or justify not doing so.
- 8. Regarding source evaluation and selection, OAP Section 2.7.3.9 (7) for procurement of commercial grade items refers to Section 3.1 of Supplement 7S-1 of ASME NOA-1,1989.
QAP Section 2.7.3.10 (7) for procurement of commercial grade services refers to QAP Section 2.7.3.2. These two references are comparable except that NOA-1 requires that supplier history must reflect current capability. Include this requirement for services or justify not doing so.
- 9. QAP Section 2.7.3.9 (7) specifies that commercial grade items are receipt inspected "to
- = ensure that required documentation is received and is acceptable." Specify in OAP Section 2.7.3.9 how USEC ensures that required documentation for commercial grade services is
- l. received and is acceptable or justify not doing so.
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2.7.3.9 Commercial Grade Items Procedures are established governing the application and use of commercial grade items: 1
- 1. Methods for determining whether an item can be purchased as commercial grade and dedicated for 4 use in a Q application. A commercial grade item is an item satisfying all of the following:
- a. Not subject to design or specification regvirements that are unique to the nuclear facility.
- b. Used in applications other than nuclear facilities,
- c. Is to be ordered from the manufacturer / supplier on the basis of a specification set forth in the manufacturer's published product description (e.g., catalog).
- 2. De criteria and methods for identifying the critical characteristics that are essential to ensure that the item will perform its intended Q function.
- 3. The criteria for determining the type and depth of product acceptance and the criteria for determining the point of dedication at which time USEC assumes the responsibility for reportability.
Dedication of a commercial grade item occurs after receipt when that item is designated for use in a Q application.
- 4. Methods used to accept (dedicate) commercial grade items are receipt inspection as required by 2.7.3.9.10 or one or more of the following as determined by engineering:
- a. Special test
- b. Commercial grade survey of supplier
- c. Source verification
- d. Acceptable supplier and item performance record
- 5. The selection of the method or combination of methods in 4. above is based on the following:
- a. Selected critical characteristics
- b. Available supplier informction c, . Quality history
(
- d. Degree of standardization
- e. Importance to safety and complexity of the item-
- 6. Attemate commercial grade items are allowed provided the Engineering Manager provides verification that the altemate commercial grade item will perfonn its intended Q function.
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- 7. Source evaluation and selection, where determined necessary by the engineering based on complexity .
and importance to safety, shall be in xcordance with the requirements of Section 3.1 of Supplement )
7S.1 of ASME NQA-1.1989.
i
- 8. Procurement documents are issued and controlled in accordance with the requirements of (
Sections 2.4.3.2 and 2.4.3 3 of this QAP. j
- 9. Commercial grade items are identified in the purchase order by the manufacturer's published product description.
- 10. Receipt inspections are performed to determine that damage was not sustained during shipment, that the item received is the item ordered, and that inspection and testing are performed as required, to j ensure conformance with manufacturer's published requirements; and to ensure that required i documentation is received and is acceptable.
I 1. The requirements of other sections of this QAP apply once a commercial grade item is dedicated and ,
determined acceptable for use in a Q application.
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2.7.3.10 COMMERICAL GRADE SERVICES I
- 1. Methods for determining whether a service can be purchased as commercial grade and dedicated for use in a Q application are established and implemented. A commercial grade service is a service satisfying all of the following:
- a. No; subject to design or specification requirements that are unique to GDP facilities or icdvities- .
- b. Used in applications other than GDP facilities or activities; and
- c. Is to be ordered from the manufacturer / supplier on the basis of a specifica: ion set forth in the manufacturer 's published product description (e.g., catalog) or other appropriate documents.
- 2. The criteria and methods for identifying the critical characteristics (critical controls) for acceptance are established. The critical characteristics (critical controls), which once selected to be verifie 3, provide reasonable assurance that the service provided meets specified requirements.
- 3. In selecting the critical controls, the impact of the activities associated with the service on the safety function of plant equipment is considered
- 4. If there are no critical controls that impact the safety function of the plant ;quipment that can be applied to the service, then administrative controls for the service may be applied such as controls over the process or qualification of personnel.
- 5. Methods of acceptance of commercial grade services are established and include any one or combination of the foliawing:
- a. Special tests and inspections
- b. Commercial grade survey
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- c. Source verification
'd. ~ Acceptable supplier service performance history
- 6. Dedication of a commercial grade service occurs when that service is accepted in accordance with
. 2.7.3.10.5 above.
' 7.-
. Source evaluation and selection, where deemed necessary by engineering based on complexity and importance to safety, is in accordance with the requirements of Section 2.7.3.2.
8.- Procurement documents are issued and controlled in accordance with the requirements of Sections 2.4.3.2 and 2.4.3.3 of this QAP.
- 9. Commercial grade services are identified in the purchase order by the manufacturer's published product description or other appropriate documents.
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