ML20211G974

Informs That on 990812,NMSS Completed three-day Licensing Review of Activities Associated with Usec 990526,certificate Amend Request (CAR) to Reopen Compliance Plan Issues 8,9 & 23 Dealing with Nuclear Criticality Safety Program

ML20211G974
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant, 07007001
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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[ f og UNITED STATES l

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5 E NUCLEAR REGULATORY COMMISSION  !

4E WASHINGTON, D.C. 20555-0001

%, p August 26, 1999 l

• • • • • j i

MEMORANDUM TO: Robert C. Pierson, Chief )

Special Projects Branch Division of Fuel Cycle Safety and Safeguards, NMSS '

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THROUGH: Melanie A. Galloway, Chief l Enrichment Section Y,f( , N~*

• l Special Projects Branch /l I  !

Division of Fuel Cycle Safety l and Safeguards, NMSS j FROM: Lawrence J. Berg W' gp Christopher S. Tripp Enrichment Section

[1M M 0

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) l 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) {

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.  !

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" /

equipment that is different from the assumed design. /g

'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. \ '

of nno  !

n ,o1oo., m a r%C FRF P~gRR r;ttpt PDR ADOCK 07007001 C PDR l

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2 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 l NCSAs/Es, or into the existing plant NCSA for abandoned in place equipment, NCSA l 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 I 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. l 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 I requirement which appeared to be optional. Upon further review of the NCSA, we found that I 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 I 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 i superseded postings remain in place. l l

Also in Building X-710, we discovered that Operations had posted a sign which provided )

. 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: I Dockets: 70-7001,70-7002 NRC File Center PUBLIC Y.Chen l SPB r/f K. O'Brien, Rlil P. Hiland, Rill l G:\SPB\LBJ2\ Ports 899triprpt.wpd (*See previous concurrence)

OFC SPB SPB SPB b NAME *LBerg:al *DHoadley DATE 8/26/99 8/26/99 8/ h /99 C = COVER E = COVER & ENCLOSURE N = NO COPY OFFICIAL RECORD COPY

go i

. 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 I I

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: I 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 () SPB NAME LBeh D y MGalloway DATE 8/ /99 8/ 24 /99 8/ /99 C = COVER E = COVER & ENCLOSURE N = NO COPY I OFFICIAL RECORD COPY l