ML20132F256

Forwards Proprietary Quarterly Repts on Implementation Status of Compliance Plans.Encl Withheld,Per 10CFR2.790

ML20132F256
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant, Paducah Gaseous Diffusion Plant
Issue date:	12/18/1996
From:	Woolley R UNITED STATES ENRICHMENT CORP. (USEC)
To:	Pierson R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
Shared Package
ML19310E918	List: ML20132F256
References
GDP-96-0194, GDP-96-194, NUDOCS 9612240170
Download: ML20132F256 (31)

Text

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'e Unit:d St tis Enrichm;nt Corporition 2 Democracy Center L-6903 Rockledge Drive Bethesda, MD 20817 k

Tel: (301)S64-3200 CONTAINS 10 CFR 2.EU WF04JMiaN ram 3oi> SS4-320i December 18,1996 Mr. Robert C. Pierson SERIAL: GDP 96-0194 Chief, Special Projects Branch Division of Fuel Cycle Safety and Safeguards, NMSS United States Nuclear Regulatory Commission Washington, D.C. 20555-0001 Paducah Gaseous Diffusion Plant (PGDP)

Portsmouth Gaseous Diffusion Plant (PORTS)

Docket Nos. 70-7001 and 70-7002 1

Quarterly Compliance Plan Report

Dear Mr. Pierson:

i In the Introduction section of the PGDP and PORTS Compliance Plans, USEC committed to provide the NRC with quarterly reports on the implementation status of the Compliance Plans.

Accordingly, enclosed is the initial quarterly Compliance Plan Report. This initial report is required to be submitted within ninety days of the Office of Nuclear Material Safety and Safeguards (NMSS)

Director's decision on initial certification.

For purposes of reporting consistency, USEC has established a cutoff date of November 30, 1996, for this report. The cutoff date for the next Compliance Plan Report will be February 28,1997, and the report will be submitted to NRC by mid-March 1997. This pattern will be used for future quarterly Compliance Plan Reports.

As required by the Compliance Plan, enclosed is the following information: 1) an executive summary that identifies Compliance Plan issues that were completed during the past quarter, Compliance Plan issues that are scheduled to be completed during the next quarter, and a discussion of any Compliance Plan issues that are behind schedule; and 2) a detailed listing, sorted by noncompliance, of the individual commitments within each Compliance Plan issue.

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Mr. Roben C. Pierson December 18,1996 GDP 96-194, Page 2 t

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As you are aware, DOE has conducted inspections at both sites to review those Compliance Plan f

l issues and actions that USEC considers complete. DOE has informed us that they will be submitting to us a letter documenting the results of their inspection, which we plan to reflect in the next quarterly.

report. If you have any questions or require additional information, please contact Russ Wells at I

(301) 564-3245.- There are no new commitments contained in this submittal.

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Sincerely,

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S. DEA 4;c Robert L. Woolley I

i Nuclear Regulatory Assurance and Policy Manager j

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NRC Region III Office NRC Resident Inspector - PGDP and PORTS l

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DOE Regulatory Oversight Manager l

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TABLE OF CONTENTS A.

Executive Summary 1.

Introduction l

II.

Proposed Revisions to Compliance Plans for " Closed" Noncompliances III.

Completed Compliance Plan Issues IV.

Compliance Plan Issues that are Scheduled to be Completed During the Next Quarter V.

Description of any Compliance Plan Issues that are Behind Schedule VI.

Detailed Listing of the Individual Commitments within each Compliance Plan Issue B.

Tables 1.

Description of Proposed Revisions to the Compliance Plans 2.

Description of Completed Compliance Plan Issues 3.

Description of Compliance Plan Issues that are Coming Due During the Next Quarter C.

Figures

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Summary ofIndividual Compliance Plan Actions D.

Enclosures 1.

Description of Compliance Plan Issues and Actions l

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EXECUTIVE

SUMMARY

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Introduction i

On September 15,1995, USEC initially submitted the Compliance Plans for PGDP and l

PORTS to NRC as part of the Certification Application. Subsequent revisions to the -

Compliance Plans were submitted to NRC on November 7,1995 (Revision 1), February 5, 1996 (Revision 2), July 12,1996 (Revision 3), and August 1,1996 (Revision 3, Change A).

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The Compliance Plans include the following information A description of the areas of noncompliance; l

A plan of actions and schedule for achieving compliance; and A justification for continued operation with adequate safety and safeguards.

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i The Compliance Plans contains 106 individual areas of noncompliances or " issues," 57 at 4

PGDP and 49 at PORTS. Each issue includes one or more actions that must be completed in the next several years. There are approximately 450 individual actions contained in the Compliance Plans. Figure I shows graphically the Compliance Plan actions that have been i

completed and those actions that are remaining to be completed.

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The Introduction sections of the Compliance Plans state:

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" Subsequent to the Office of Nuclear Material Safety and Safeguards (NMSS) Director's decision on initial certification, USEC will provide quaderly reports to NRC on the l

implementation status of Compliance Plan commitments. These quarterly status reports will i

include, where appropriate, proposed revisions to remove the discussions of noncompliances that have been closed. The reports will also include an executive summary that identifies j

l plans of actions that were completed during the past quarter, plans of actions scheduled to completed [sicJ during the next quarter, and a discussion of any plans of actions that are behind j

schedule ( The executive summary will be supported by a detailed listing, sorted by

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noncompliance, of the individual commitments within each plan of action. The listing will include a comparison of the commitment completion date with the current projected completion i

date for each individual commitment that has not been completed. The first such report will be provided to NRC no later than 90 days after the NMSS Director's decision on initial certification. These reports will be provided until either all plans of action in the PORTS or PGDP Compliance Plan have been completed or the NRC agrees that the reports are no longer necessary."

For ease of reporting, USEC has established a cutoff date of November 30,1996, for Compliance Plan issues closed or coming due in the next ninety days. The cutoff date for subsequent quarterly Compliance Plan Reports will follow this pattern (i.e., end of February, May, August, and November) and the report will be submitted to NRC by the middle of the following month.

'The " plans of actions" in this sentence are coincident with the Compliance Plan issues.

To address and resolve each issue, the plan of action for that issue must be completed.,

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The following is a summary of information included in this quarterly Compliance Plan report:

II.

Proposed Revisions to the Compliance Plans for " Closed" Noncompliances In the Compliance Plans, USEC committed to provide NRC with " proposed revisions to remove the discussions of noncompliances that have been closed."Section III below identifies those Compliance Plan Issues which USEC has completed as of the cutoff date for this report.

2 USEC will reflect the results of DOE or NRC " closure" activities relating to Compliance Plan issues in future reports. Additionally, Table I lists the Certificate Amendment Requests (CARS) that USEC has submitted to NRC that affect Compliance Plan due dates. Updates to the Compliance Plans to reflect completed or closed Compliance Plan issues actions will be submitted to NRC as part of Certificate of Compliance amendments or renewals required by 10 CFR 76.

i III.

Completed Compliance Plan Issues Of the 106 Compliance Plan issues,28 (i.e., approximately 27%) have been completed as of November 30,1996, and are listed in Table 2. Of the approximate 450 Compliance Plan actions, about 150 (i.e.,33%) have been completed as of November 30,1996.

Future Compliance Plan reports will identify those issues that were completed during the previous quarter and also identify any issues that are considered closed by the regulator.

IV.

Compliance Plan Issues that are Scheduled to be Completed During the Next Quarter

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There are 16 Compliance Plan issues coming due between December 1,1996 and March 3,1997 (i.e., the date of NRC transition). These issues are listed in Table 3.

V.

Discussion of Any Compliance Plan Issues that are Behind Schedule Table 1 identifies those CARS that USEC has submitted to revise Compliance Plan due dates. Additionally, Table 3 identifies those Compliance Plan issues that have completion dates between December 1,1996 and March 3,1997, but are currently behind schedule.

USEC is placing additional emphasis on these issues to complete them within their required due dates. As previously noted, USEC is required to submit a CAR for NRC review and approval if we cannot complete a Compliance Plan issue within its required due dates.

I 2The term " complete" means that USEC has fulfilled all of the individual actions described in a Compliance Plan issue. A Compliance Plan issue is considered " closed" when the regulator has reviewed and concurred that all actions have been completed and documented its review in writing.

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VI.

Detailed Listing of the Individual Commitments within each Compliance Plan Issue j

i Enclosure I to this report lists each Compliance Plan Issue, a description of the commitments for each issue, the due date committed to in the Compliance Plan, and identifies if the commitment has been completed. This report also reflects any extension requests to

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Compliance Plan due dates shown in Table 1.

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Page1 TABLE 1 PROPOSED REVISIONS TO THE COMPLIANCE PLANS i

Date of Certificate USEC Letter Description ofProposed Revision Status Amendment No.

Request 10/31/96 GDP 96-0190 The proposed change will revise the duc dates for completing the NCSAs Responding to NRC comments and NCSEs as described in PORTS Compliance Plan issues 8, 9, 23, 24, l

30, and 32.

i 10/31/96 GDP-96-0191 This change proposes to revise the completion date for the first item in NRC plans to take no action on this the Plan of Action and Schedule for PGDP Compliance Plan Issue 14 and will note this in their first from October 31,1996 to November 22,1996.

Amendment approval.

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lI/04/96 GDP-96-0192 This change proposes to extend the completion date committed to in Responded to NRC comments, f

PORTS Compliance Plan issue A.4 (first action item) for removal of awaiting NRC approval IIEU from all Irwed areas (except for de minimis total quantities not to i

exceed 999 grame nf "U) from November 15,1996 to February 28, 2

1997.

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Page 1 TABLE 2 DESCRIPTION OF COMPLETED COMPLIANCE PLAN ISSUES PORTSMOUTH ISSUE NO.

DESCRIPTION OFISSUE 5

X-705 Isolation Valve Testing 6

X-705 Microfiltration Influent pH Shutdown System Replacement 10 Nuclear Criticality Safety Training for Managers 12 Radiation Protection Procedures 14 NVLAP Certification 15 Fire Protection Compensatory Measures 16 Fire Protection Sprinkler Testing i

19 Packaging and Transportation 27 Assessments 33 Emergency Plan Support Documents 34 Training for Emergency Preparedness 35 Quality Control Program for Low-Level Waste Disposal 40 Operational / Safety System Trip Redundancy

' Page 2 TABLE 2 DESCRIPTION OF COMPLETED COMPLIANCE PLAN ISSUES PADUCAH ISSUE NO.

DESCRIPTION OFISSUE 4

C-360 Crane Upgrades 6

Nuclear Criticality Safety Approval Implementation 1

7 Criticality Accident Alarm System Coverage 9

Radiation Protection Procedures 11 Radioactive Calibration Source Accuracy i

12 NVLAP Certifications I

13 Fire Alarm System Reliability 15 Fire Protection Equipment j

18 Packaging and Transportation 32 Emergency Plan Support Documents 33 Training for Emergency Response Organization 34 Quality Control Program for Low-Level Waste Disposal 48 Cascade Cell Trip Function System Requirements A.3 Receipts Based on Measured Values i

A.4 Inventory Program for Uranium Holdup 4

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Page 1 TA"LE3 COMPLIANCE PLAN ISSUES COMING DUE DURING THE NEXT QUARTER PORTSMOUTH ISSUE NO.

DESCRIPTION OFISSUE DUE DATE STATUS 1

Transition from DOE Regulation to NRC Regulation Transition On schedule 4

X-705 Evaporator Heat Exchanger Modifications 12/31/96 On schedule 8

Nuclear Criticality Safety Approval Documents Transition Behind schedule 22 Safety Committees Transition On schedule 28 Event Investigations and Reporting Program Transition On schedule 36 Depleted Uranium Management Plan 12/31/96 On schedule 37 Administrative Controls on Overtime 12/31/96 On schedule 41 Codes and Standards 2/1/97 On schedule A5 DOE Materials Stored in Leased Space 12/31/96 Behind schedule, USEC is working with DOE to complete this issue.

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COMPLIANCE PLAN ISSUES COMING DUE DURING TIIE NEXT QUARTER PADUCAH ISSUE NO.

DESCRIPTION OFISSUE DUE DATE STATUS 1

Transition from DOE Regulation to NRC Regulation Transition On Schedule 5

Nuclear Criticality Safety Approval Documents Transition Behind Schedule 20 Safety Committees Transition On schedule 25 Event Investigations and Reporting Program Transition On schedule 45 Codes and Standards 2/1/97 On schedule A2 Measurement Systems 12/31/96 On schedule A7 DOE Materials Stored in Leased Space 12/31/96 Behind schedule, USEC is working with DOE to complete this issue.

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FIGURE I

SUMMARY

OF INDIVIDUAL COMPLIANCE PLAN ACTIONS

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l ENCLOSURE 1 DESCRIPTION OF COMPLIANCE PLAN ISSUES AND ACTIONS l

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4 ENCLOSURE 1 PORTS Action Status by Issue 16-Dec-96 FACILfiT ISSUE #

TASKID DUE DATE COMMITMENT DESCRIPTION STATliS PORTS 01 CPI-POA-C01.01 Transition Some of the activities necessary for USEC to implement this phased transition are described in this Compliance Plan. USEC is currently developing additional detailed plans and schedules to implement the phased transition. Consistent with ROA requirements 312.2,33.2.6, and 3.4.23, DOE will review all proposed changes from OSRs to TSRs, and USEC will not implement any such changes without the consent I

and uvitten approval of the DOE Regulatory Oversight Manager.

CPI-POA-X01.01 Transition Some of the activities necessary for USEC to implement this phased transition are described in this Compliance Plan. USEC is currently developing additional detailed plans and schedules to implement the phased transition. Consistent with ROA requirements 3.2.2.2,33.2.6, and 3.4.23, DOE will review all proposed changes from OSRs to TSRs, and USEC will not implement any such changes without the consent and uvitten approval of the DOE Regulatory Oversight Manager.

CPI-POA-X01.02 Transition in the interest of assuring a safe, smooth transition from DOE to NRC regulatory authority, including a safe transition from OSRs to TSRs, USEC will keep the DOE Regulatory Oversight Manager and the NRC fully informed of USEC plans, schedules, and the status of activities to implement the phased transition. The information USEC will pmvide will include detailed tasks, schedules, and milestones for completing the transition; identification of areas requiring interface reviews and the schedules for performing such review-and the schedules for procedure development. personnel training, ard pional readiness evaluations.

Except as identified in this Compliance Plan, all activities required to complete the transition from compliance with DOE requirements to NRC regulations will be completed by the date NRC assumes regulatory authority. De transition to NRC regulatory oversight is scheduled to occur 120 days after the i

NMSS Di'ector's decision regarding USEC's certification.

CPI-POA-X01.03 Transition De listing of open USEC commitments to DOE will be pmvided to NRC by USEC on the date that NRC assumes regulatory authority for PGDP.

PORTS 02 CPI-POA-X02.01 2!!5/97 De approved DOE site-wide Safety Analysis Report and supporting documentation will then be forwarded to USEC by February 15,1997.

CPI-POA-X02.02 4/1/97 USEC will provide information required to complete the DOE site-wide Safety Analysis Report and will provide technical reviews of the ongoing analyses to ensure that the analyses accurately reflect the facility configuration.

CPI-POA-X02.03a 8/17/97 By no later than August 17,1997, USEC shall submit an amendment to tSeir Certification Application f

which includes:

a) identification of all information, findings, and recommendations which indicate differences between the DOE site-wide Safety Analysis Report and the USEC Application for Certification.

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FACILITY ISSITE O 7ASK ID DtIDATE COM3tlTMENT DESCRIPTION STATUS CPI-POA-X02.03b 8/17/97 By no later than August 17,1997, USEC shall submit an amendment to their Certification Application uhich includes:

b) an evaluation of the effects of those differences on the safety of workers, and off-site mernbers of the public.

CPI-POA X02.03c 8/17/97 By nolaterthan August 17,1997, USEC shall submit an amendment to their Certification Application which includes:

c) proposed modifications to the compfiance certificate and/or facility, including proposed modifications to the Appiication SAR and TSRs.

CPI-POA-X02.04 8/17/97 At the same time the Application amendment is due, USEC shall also submit for NRC approva!. its proposed resolution of matters contained in the DOE-approved site-wide Safety Analysis Report not incorporated by USEC in its request for amendment of their Application for Certification.

CPI-POA-X02.05a 9/30/97 From September 30,1995, until NRC approves the submittals in paragraphs 3 and 4 above, changes made by USEC in accordance with DOE's ROA requi ement concerning Unreviewed Safety Question Determinations (USQDs) or with 10 CFR 76.68 must be addressed either in the DOE SAR Upgrade results or in the amended safety analy sis report submitted by USEC based upon those results.1he following will assure such changes are properly considered and addressed:

CPI-POA-X02.05b 9/30/97 From September 30,1995, until NRC approves the submittals in paragraphs 3 and 4 above, changes made by USEC in accordance with DOE's ROA requirement concerning Unreviewed Safety Question Determinations (USQDs) or with id CFR 76.68 must be addressed either in the DOE SAR Upgrade results or in the amended safety analysis report submitted by USEC based upon those results. The following will assure such changes are properly considered and addressed:

- Changes made to the plants after September 30,1995, will be addressed by USEC in its amendment Application. The amendment Application will reflect the plant as it exists 6 months before the amendment submittal.

CPI-POA-X02.05c 9/30/97 From September 30,1995, until NRC approves the submittals in paragraphs 3 and 4 above, changes made by USEC in accordance with DOE's ROA requirement conceming Unreviewed Safety Question Determinations (USQDs) or with 10 CI R 76.68 must be addressed either in the DOE SAR Upgrade results or in the amended safety analysis report submitted by USEC based upon those results. The following will assure such changes are property considered and addressed:

- Once the amendment is submitted, USEC will inform NRC of changes that are made in accordance with 10 CFR 76.68 that could render the amendment to be incorrect, inaccurate, or incomplete until the amendment is approved by NRC.

CPI-POA-X02.05d 4/30/98 From September 30,1995, until NRC approves the submittals in paragraphs 3 and 4 above, changes made by USEC in accordance with DOE's ROA requirem nt conceming Unreviewed Safety Question Determinations (USQDs) or with 10 CFR 768 must be addressed either in the DOE SAR Upgrade results or in the amended safety analysis report submitici by USEC based upon those results. The following will assure such changes are properly considered and aJdressed:

- NRC is notified of changes made in accordance v ith 10 CFR 76.68 as part of the annual Application for renewal required by 10 CFR 76.36.

Enclosure I, Page 2 of22

FACILITY ISSFE #

TASKID DUE D ATE COMMfTMENT DESCRIPTION STATUS CPI-POA-X02.06 8/17N7 The update to the Application SAR uill also reflect those w,6a..c.ts made by USEC to the NRC durmg

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the initial certification Application process as identified in the Application and the responses to NRC questions / comments.

PORTS 03 CPI-POA-XO3.01a 7/IN7 Provide the capability to separately test the inner and outer loop containment valves on the autoclaves in X-342A, X-343, and X-344A.

CPI-POA-XO3.0lb 7/IN7 A revised TSR to reflect the new [ inner and outer loop comainment valve test] configuration will be submitted to NRC by July 1,1997.

CPI-POA-XO3 01c Certifcation The TSRs for all autoclaves will be revised to declare an autoclave inoperable and taken out of service when any containment valve is determined to be inoperable until the capability to perform autoclave pressure decay testing uith inner loop and outer loop containment valves is provided.

CPI-POA-X03.02a 5/IN8 Install fail-safe containment valves upstream of the UF6 feed isolation and flow control valves on the autoclaves in X-342A and X-343 and modify the programmable logic control system.

CPI-POA-X03.02b 5/1N8 Install fail-safe containment valves on the liquid UF6 drain line on autoclaves 3 and 4 in X-344A.

CPI-POA-X03.02c 5/1/98 Replace or modify the daughter cylinder isolation valves on the autoclaves in X-344A for fail-safe (i.e.,

closed) position on loss of air.

CPI-POA-X03.03 5/1/98 Add a low air pressure switch to autoclave 2 in X-344A to initiate containment upon loss of air to pressure transmitter PT-134.

CPI-POA-X03.04 5/l/98 Modify the Ifigh Pressure Containment Shutdown System controls for the autoclaves in X-342A, X-343, and X-344A to prevent them from being inadvertently opened when the pressure in the autoclave exceeds the setpoint as defined in the Technical Safety Requirements.

CPI-POA-X03.05 5/IN8 Upgrade the internal autoclave and UF6 cy linder pressure transmitters to improve their temperature compensation capability and accuracy in the operating pressure range.

CPI-POA-XO3 %

5/1/98 Provide operational alarms on the autoclave safety systems to alert operators to poiential upset conditions.

CPI-POA-X03.07 5/IM8 Modify the autoclave steam supply and condensate removal systems in X-342A. X-243, and X-344 A to minimize the back up of condensate in the autoclave.

CPI-POA-XO3 08 5/1/98 Restore the autoclave head /shell sealing surfaces for the autoclaves in X-342A, X-343, and X-344A.

CPI-POA-X03.09 5/1/98 A code interpretation fiom the ASME Code Committee will be obtained regarding the need for pressure relief for the UF6 cylinders. Based on this interpretation, the need for modifications to the affected system operations will be assessed. Both the ASME Code interpretation and the assessment results will be submitted to NRC for review and approval.

CPI-POA-XO3.10s 12/31N6 Pressure Gecay testing procedures that assure that backpressure does not mask leaks in autoclave steam admission lines will be implemented by December 31,1996.

CPI-POA-X03.10b 12/31/96 Modifications to the buffer air supply lines on nine autoclaves 'o eliminate backpressure masking and resulting changes to pressure decay testing procedures will be made.

Enciosser I, Page 3 of22

FACILITY ISSUE 8 TASKID DUE DATE COMMITMENT DESCCIPTION STATUS CPI-POA-XO3.11 3/31/98 A detailed schedule for comletion of these action will be availabic for review at PORTS.

CPI-POA-X03.12 2/1/2001 The completion schedule for the remaining twehe autoclaves will be such that the final autoclave is complete by February 1,2001.

PORTS 04 CPI-POA-XO4.01 12/31/96 Install instrumentation and system modifications in the steam condensate drain piping froa the evaporator heat exchangers to provide double contingency for nuclear criticality safety.

CPI-POA-X04.02 12/31N6 Replace the evaporator heat exchangers to climinate the unfavorable geometry expansion joint.

PORTS 05 CPI-POA-X05.01 6/30S6 Block valves, test taps, and a valve leak test cart have been installed to a!!ow leak testing of the following Complete isolation valves:

(1) the uranyl nitrate feed isolation valves to the X-705 calciners feed pumps and (2) the isolation valves between the microfiltration units bag filters and efY!uent storage tank.

The leak testing of these isolation valves will commence prior to June 30,1996.

PORTS 06 CPI-POA-XO6.01 a 6/30/06 Repipe a section of the feed system to the microfiltration process.

Complete CPI-POA-XO6.01b 6/30N6 Deactivate the microfiltration influent pII shutdown system (located between second stage pil adjust and Complete the microfiltration feed tank).

CPI-POA-XO6.01c 6/30N6 Instalt a microfiltration effluent pil shutdown system (located between the microfiltration modules ad the Complete efiluent tank).

PORTS 01-POA-X07.Ola 6/30/97 The fixed ifEPA filter systems required to practice ALARA principles and to control worker expose.e will be retrofitted or replaced with new systems to allow testing in accordance with (1) the wpm _.r, of ANSI /ASME N510 or (2) the intent of the requirements of ANSI /ASME N510 for systems not <'.: signed to ANSI /ASME N509.

CPI POA-X07.01b 6/30/97 Also, efforts are underway to develop a deabase of portable llEPA filtration units and to perform in-place leak testing of all portable liEPA filter units.

PORTS 08 CPI-POA-X08.01 2/28/97 Formal NCSAs and NCSEs will be completed for all current operations invohing uranium enriched to I wt Ett Requested

% or higher 235U and 15 grams or more 235U by November 30.1996, and will be properly documented and approved in accordance with the NCS program requirements contained in the approved Certificate.

Enclosure I, Page 4 of22

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FACILITY ISSUE #

TASK ID DUE D ATE COMMITMENT DESCC.IFTION STATUS CPI-POA-X08.02 11/30/96 The procedural changes to resolve the administrative noncompliances in the nuclear criticality safet)

Complete program will be completed by November 30,1996.

k' CPI-POA-X08.03 Transition All aspects of Technical Safety Requirement 3.9 impicmentation and its associated tentacles for NCS will.

be in place no later than the transitior to NRC regulatory oversight.

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rORTS 09 CPI-POA-X09.01a Transition See issue 8 A program is in place to review all NCSAs in order to identify and track the designated NCS conditions, specifications, and controls and to verify their full implementation. Particular attention is being focused on i

ensuring ma% between each NCSA and the operation including work-site postings.The verification l

program (of the roughly 150 operating procedures and 150 postings) will be compicted for all current fissile material operations, prior to NRC assuming regulatory oversight of PORTS for NCSAs that need to flow -

J into Technical Safety Requirements

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t CPI-POA-XO9.Olb 1/31/97 Identification of the remaining NCSA requirements to be flowedslowii into procedures will be completed Est Requested by December 2,1996.

j CPI-POA-XO9.01e 2/28/97 A procedure for contamer handling and storage will be developed prior to December 2,1996.

Ent Reaguested i

CPI-POA-XO9.02 12/2/96 The procedural changes to resolve the administrative noncompliances in the Nuclear Criticality Safety coinplete Program (from SAR Section 5.2.4 and as identified in the Summary of Requirements and Cm....L..;..;s tabic below) will be completed by December 2,1996.

CPI-POA-XO9.03 Transition All aspects of Technical Safety Requirement 3.9 implementation and its associated tentacles for NCS will be in place no later than the transition to NRC regulatory oversight.

CPI-POA-X09.04 Also see issue 30

- The plant-wide procedure upgrade initiative will provide additional assurance of the full and proper flow-dowli of NCS conditions and specifications to operating procedures and postings. The compliance plan item entitled " Procedures Program

• addresses the implementation of operating procedures.

j CPI-POA-XO9.05 On Going If a new or revised NCSE identifies the need for modifications to the existing plant configuration, affected

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activities will be curtailed and will not be restarted until either (I) the plant configuration is modified or (2)

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the activity is modified so that it can be performed safely in the current configuration. If the plant configuration or activity is modified, the Plant Operations Review Committee will review the proposed modification prior to its resumption to verify that the activity, as modified, can be performed safely.

PORTS 10 l

CPI-POA-X10.01 3/31/96 A list of managers who require training for oversight of nuclear criticality issues will be developed.

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i CPI-POA-X10.02 3/31/96 Individuals requiring training will complete the designated NCS manager training course.

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FACILITY ISSUE O TASK ID DUE DATE COMMITMENT DESCCIFTION STATUS

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i CPI-POA-Xil.01 9GOS6 USEC will provide criticality detector coverage in all areas of the plant except for those areas identified and Complete 4

justified by USEC and approved by NRC. Analyses that provide the technical justification for not providing criticality accident alarm system coverage in designated areas of the plant are being developed. Except for Buildings X-330, X-333, and X-700, analyses have been submitted to NRC that (1) verify the adequacy of the existing criticality accident alarm system and its detector locations for detecting a criticality accident i

and (2) justify that detectors are not required for monitoring other areas of the plant. The analyses for I

Buildings X-330, X-333, and X-700 will be completed by September 30,1996.

CPI-POA-X11.02 7/1/98 The analyses already submitted identified the need to tie the evacuation homs in Building X-74411 to the Building X-744G CAAS that provides detection coverage for Building X-744f L Building X-74411 contains lightly contaminated waste with a comparatively low potential for a criticality accident.

PORTS 12 CPI-POA-X12.01 10/24/95 The required procedure changes will be implemented.

Complete CPI-POA-X12.02 10/1/96 Plant procedures will be issued by October 1,1996, to incorporate the annual radiation protection program Complete revi:w requirement from SAR paragraph 53.1.3.

j PORTS 13 CPI-POA-X13.01 Transition Building work areas previously posted as ' Regulated Areas

• will be re-posted to reflect the current Complete

• Restricted Area

• and " Contamination Control Zone" designations CPI-POA-X13.02 12G1/96 Restricted areas within USEC leased space which contain unlabeled, but potentially radioactive, material containers will be posted with signs stating that each unlabeled contamer may contain radioactive material.

CPI-POA-X13.03 12G1/98 Necessary radiological c:

.du kaiion and re-posting ofleased areas within the PORTS site boundary will

.I be completed by December 31,1998.

1 PORTS 14 CPI-POA-X14 01 10/24/95 USEC will provide NVLAP-accredited dosimetry for those relatively few individuals who are required to Complete be monitored under 10 CFR 20.1502.

j PORTS 15 CPI-POA-XI5.01 12G1/95 A procedure defining fire prevention requirements for compensatory action will be descloped to address (1) Complete preplanned and emergency impairment program,(2) limiting conditions for operation, and (3) compensatory actions.

PORTS 16 CPI-POA-X16.01 11G0/95 The Fire Department will test the fire systems at the required ORO Fire Protection periodic testing Closed f

frequencies. Implementation of the testing frequencies mill be completed by November 30,1995.

PORTS 17 L, Page 6 of22 h

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FACILfTY ISSUE #

TASKID DUE DATE CO313tlTMENT DESCRIPTION STATI'S CPI-POA-XI7.01a Also see issue 30 The fire protection procedures will be created or revised as part of the overall procedure upgrade project by December 31,1997.

CPI-POA-XI7.0lb 12/31/96 Fire Protection programmatic procedures (1) Standard Practice Procedure S-20, ' Fire Protection *;(2)

• Fire Protection Requirements for Welding, Buming, and flotwork Practices," UE2-SS-FS1031; and (3) a formal procedure for the performance of fire hazard assessments will be upgraded and implemented by December 31,1996.

CPI-POA-X17.01c 12/31/96 The hot work permit procedure and applicable training programs will be revised to ensure Fire Services involvement and oversight of the hot work permit program by December 31,1996.

PORTS 18 CPI-POA-XI8 01 10/1/96 De emergency packets will be updated by Emergency Management to reflect current facility Complete configurations and conditions. This update will include the information required by the emergency packet control procedure including such information as:(1) general building / area layout drawings or sketches,(2) critical action, equipment, or material listing, (3) facility / area utility services, (4) facility emergency systems and equipment, (5) lists of hazardous, toxic, and/or radioactive materials, including compressed gases, and (6) list (s) of facility tenant organizations CPI-POA-XI8.02 6/3M7 An analysis will be conducted by Fire Services personnel to determine the maximum allowable combustible loadings within the process buildings. The analysis uill include determination of the existing combustible loadings of selected specific occupancy areas within the process buildings and the verification of the ability of the sprinklers to control these specific occupancy areas. Some local occupancy areas to be considered include bumable " Anti-C" waste storage, lube oil in process reserves, waste storage, maintenance shops.

and stores. Building custodians will be provided information and training on recognizing the acceptable levels of combustible loading in the process buildings, both in general and in local areas.

PORTS 19 CPI-POA-X19.01 4/30S6 Upon app oval of the Packaging and Transportation Quality Assurance Plan and acceptance of USEC as Complete holder of the NRC certificate of compliance for the Paducah Tiger overpack, USEC will begin shipment under the NRC certificate of compliance.

PORTS 20 CPI-POA-X20.01 5/26/97 DOE and Third-Party tenants will notify USEC before hazardous chemicals, including UF6 and UF4, are introduced onto the site. All initial process hazards analyses are to be completed by May 26,1997.

CPI-POA-X20.02 3/14/96 Finalize the resolution document and forward to NRC Complete CPI-POA-X20.03 5/26/96 Complete 75% of the initial process hazard analyses to conform with the federally mandated requirement.

Complete CPI-POA-X20.04 6/28/96 If the material exceeds specified CFR threshold quantities, a safety risk will be performed to identify the Complete hazardous and mitigating actions in accordance uith those regulations. If required, develop and distribute DOE directive.

PORTS 21 Endosure 1 Page 7of22

FACILITY ISSUE e TASK ID DUE DATE COM%flTMENT DESCRIPTION STATUS CPI-POA-X21.01a Also see Issue 30 For Q to support TSRs and AQ-NCS: QAP and Regulatory Requirements flowdown - Quality Assurance Program requirements and applicable NRC requirements will be flowed down to policies that will be approved and implemented at USEC lleadquarters and PORTS in accordance with the Plan of Action and Schedule described in issue 30, " Procedure Program?

CPI-POA-X21.0lb 12/3187 For balance of Q and other AQ: QAP and Regulatory Requirements Flowdown - Quality Assurance Program requirements and applicable NRC requirements will be flowed down to procedures that will be approved and implemented at USEC lleadquarters and PORTS in accordance with the Plan of Action and Schedule described in issue 30, " Procedure Program?

CPI-POA-X21.02a Transition Organizational Roles, Responsibilities, Relationships, and Authorities flowdown - The flowdown to committed position descriptions provided in Section 6.1 of the USEC Application will be corryleted and position descriptions resised. if necessary, by the date that NRC assumes regulatory authority.

CPI-POA-X2I.02b 12/3167 The position descriptions will again be reviewed and revised, if necessary, by December 31,1997.

PORTS 22 CPI-POA-X22.01 Transition A charter for the PORC is in place; however, it requires revision to ensure consistency with commitments made in the NRC-approved Safety Analysis Report Section 6.2 and Technical Safety Requirement 3.10.

This review and the charter upgrade uill be completed and implemented by the date that NRC assumes regulatory authority.

PORTS 23 CPI-POA-X23.01al 12/31N6 Identify and document all Q items items including system boundaries and support systems required for performance of the intended safety function, to be included in the scope of the Con 0guration Management Program.

CPI-POA-X23.01a2 2/28N7 Identify and document all AQ-NCS items including system boundaries and support systems required for Ext Requested performance of the intended safety function, to be included in the scope of the Configuration Management Program.

CPI-POA-X23.01a3 10/187 Identify and document all other AQ items including system boundaries and support systems required for i

performance of the intended safety function, to be included in the scope of the Configuration Management Program.

CPI-POA-X23.01b Transition Develop the flowdown of commitments from the Technical Safety Requirements, the Safety Analysis Report, and other plans and programs to procedures and training.

CPI-POA-X23.01e 12/31 S 7 Incorporate new Technical Safety Requirements into the surveillance testing and administrative procedures.

CPI-POA-X23.01d 10/IS7 Identify and document all other AQ items, including system boundaries and support systems required for performance of the intended safety function, to be included in the scope of the Configuration Management Program.

CPI-POA-X23.02a 12/31N6 Develop the baseline documentation that establishes the design requirements for all Q systems / items, including support systems seguired for performance of the intended safety function.

, Page 8 of22 i

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t FACILITY ISSUE O TASK ID DUE DATE COMMITMENT DESCRIPTION STATUS j

CPI-POA-X23.02b 2/28 S 7 Review all Nuclear Criticality Safety Approvals and Nuclear Giticality Safety Evaluations to identify AQ-Est Requested NCS items (items which support the nuclear criticality double contingency principle); to identify and document the designated design requirements and system boundaries, including support systems required for Wo.m-of the intended safety function; and to verify the implementation of these requirements. To the extent completed, this information will be maintained and made available to the NRC, before regulatory jurisdiction for planned inspection activities.

CPI-POA-X23.02c 10/167 Identify, document, and communicate definitive boundaries for the other AQ systems. Identify and document the design requirements for these AQ systems / items, including support systems required for performance of the required safety function, for which the design requirements must be known.

}

CPI-POA-X23.03a Also see Issue 29 Develop improved records management and document control programs to satisfy the needs of the Complete Configuration Management Program. Develop and implement the required procedures.

t CPI-POA-X23.03b Also see Issue 29 Train appropriate plant personnel in the requirements of these programs and procedures.

Complete CPI-POA-X23 Bla 7/3166 Upgrade the four core engineering procedures that specify the requirements for the change control process Complete to ensure the identification, technical and safety review, approval, implementation, validation, documentation, and recording of plant changes.

CPI-POA-X23_04b 7/3166 Train appropriate personnel to ensure proper implementation and application of these upgraded core Complete

[

procedures.

CPI-POA-X23.04c 3/3187 Develop or upgrade remaining engineering procedures that are associated with the change control process and train appropriate personnel on these new or upgraded procedures.

CPI-POA-X23.05a See issue 30 Develop procedures required to implement an assessment program to systematically evaluate the development and effective implementation of the Configuration Management Program elements and related processes.

CPI-POA-X23.05b See Issue 30 Train appropriate personnel to ensure proper implementation and application of these gesa.u.

CPI-POA-X23 06 Also see issue 26 Implement a training program fix plant personnel relied upon to operate, maintain, or modify the plant.

Include initial treining on improved or newly developed programs and procedures identified as required to

[

support the Configuration Management Program objectives.

t i

i PORTS 24 i

i CPI-POA-X24.01 See issues 26 and 30 Develop and implement a maintenance history and trend analysis program.

l

- Develop a master equipment list for safety critical equipment.

- Implement a new computer-based maintenance management system with the capability to collect and trend the data.

CPI-POA-X24.02 7/3166 Develop guidance for cleanliners control and measures to prevent entry of extraneous material into a closed Complete system.

j l

I t Page 9 of22 j

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FACILITY ISSUE #

TASK ID Dt'E DATE COM311TMENT DESCRIPTION STATUS CPI-POA-X24.03a 4/30S7 For Q items: Upgrade the current maintenance work control process to provide the committed level of planning and work package development for Q items.

- Centralize all planning and work control functions in the Work Control organization. (Complete)

- Revise the work control procedure.

- Develop and provide training on the upgraded work control process.

CPI-POA-X24.03b 2/28/97 For AQ-NCS items: Upgrade the current maintenance work control process to provide the committed level Ett Requested ofplanning and work package development AQ-NCS items.

- Centralize all planning and work control functions in the Work Control organization. (Complete)

- Revise the work control procedure.

- Develop and provide training on the upgraded work control process.

CPI-POA-X24.03c 6/30N8 For other AQ items: Upgrade the current maintenance work control process to provide the committed level of planning and work package development other AQ items.

- Centralize all planning and work control functions in the Work Control organization. (Complete)

- Revise the work control procedure.

- Develop and provide training on the upgraded work control process.

CPI-POA-X24.04a 2/28/97 For AQ-NCS items: Upgrade the preventive maintenance program to meet the commitments for greater Ett Requested formalism.

- Develop an overall performance indicator to measure preventive maintenance etTectiveness.

- Identify current preventive maintenance performed on Q, AQ-NCS, and other AQ items.

- Reiise the preventive maintenance program procedure to establish a formal mechanism to justify and document changes to Q, AQ-NCS, and other AQ item requirements.

- Develop the technical / historical basis for use in evaluating preventive maintenance task adequacy.

CPI-POA-X24 04b 3/31/97 For Q items: Upgrade the preventive maintenance program to meet the commitments for greater formalism.

- Develop an overall performance indicator to measure preventive maintenance effectiveness.

- Identify current preventive maintenance performed on Q, AQ-NCS, and other AQ items.

- Revise the preventive maintenance program procedure to establish a formal mechanism tojustify and document changes to Q AQ-NCS, and other AQ item requirements.

- Develop the technical! historical basis for use in evaluating preventive maintenance task adequacy.

CPI-POA-X24 Ole 6/30S 8 For other AQ items: Upgrade the preventive maintenance program to meet the -

. - ats for greater formalism.

- Develop an overall performance indicator to measure preventive maintenance effectiveness.

- Identify cunent preventive maintenance performed on Q. AQ-NCS, and other AQ items.

- Revise the preventive maintenance program procedure to establish a formal mechanism tojustify and document changes to Q, AQ-NCS, and other AQ item requirements.

- Develop the technical / historical basis for use in evaloning preventive maintenance task adequacy.. Page 10 of22

- - - - - - - -. ~ -.. - ~ - - - - - - - - - - - - - - - - - - - - - - - - -. - - - - - - - -. - - - - - - - - - - - --. -. - -.

. 1 FACILITY ISSUE #

TASKID DUE DATE COMMITMENT DESCRIPTION STATUS CPI-POA-X24.05a 2/28S7

' For AQ-NCS MATE: Revise the measuring and test equipment calibration program to meet the more Est Requested formal requirements.

- Implement procedures that define and control the overall measuring and test equipment program (Complete)

- Develop and implement individual calibration procedures for Q, AQ-NCS, and other AQ SSCs.

i

- Provide training on calibration requirements to affected coordinators, managers, technicians, and users.

l CPI-POA-X24 05b 12GIS6 For Q M&TE: Revise the measuring and test equipment calibration piegram to meet the more formal requirements.

- Implement procedures that define and control the overall measuring and test equipment program.

(Complete)

- Develop and implement individual calibration procedures for Q AQ-NCS, and other AQ SSCs-

- Provide training on calibration requirements to affected coordinators, managers, technicians, and users.

CPI-POA-X24.05c 12 GIN 7 For other AQ M&TE Revise the measuring and test equipment calibration program to meet the more formal requirements.

- Implement procedures that define and control the overall measuring and test equipment program.

(Complete)

- Develop and implement individual calibration procedures for Q AQ-NCS, and other AQ SSC4.

- Provide training on calibration requirements to affected coordinators, managers. technicians, and users.

CPI-POA-X24.06a 10 GIN 6 For Q SSCs: Identify the procedural deficiencies for performing corrective maintenance, preventive Complete maintenance, equipment calibration, or surveillance testing for Q, AQ-NCS, and other AQ SSCs and develop a composite listing of the procedures requiring revision, development, or conversion.

CPI-POA-X24.06b IGIS7 For AQ-NCS SSCs: Identify the procedural deficiencies for performing corrective maintenance, preventive Est Requested maintenance, equipment calibration, or surveillance testing for Q, AQ-NCS, and other AQ SSCs and develop a composite listing of the procedures requiring revision, development, or conversion.

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CPI-POA-X24.06c 100IS7 For other AQ SSCs: Identify the procedural deficiencies for performing corrective maintenance, preventive j

maintenance, equipment calibration, or surveillance testing for Q, AQ-NCS, and other AQ SSCs and develop a composite listing of the yiecebs requiring revision, development, or conversion.

CPI-POA-X24.07 Transition Develop procedures and provide the associated training of appropriate personnel for the performance of

'i surveillance tests which are required to support Technical Safety Requirements.

[

CPI-POA-X24.08a 2/28S7 For AQ-NCS items: Revise, develop, or convert corrective maintenance, preventive maintenance, Est Requested i

instrument calibration, and surveillance test procedures for AQ-NCS structures, systems, and w=rv=ots.

CPI-POA-X24.08b 3GIS7 For Q items: Revise, develop, or convert corrective maintenance, preventive naa. we, instrument calibration, and surveillance test procedures for Q structures, systems, and wmpv-ou CPI-POA-X24.08c 6G068 For other AQ items: Revise, develop, or convert corrective maintenance, preventive maintenance,

[

+

instrument calibration, and surveillance test procedures for other AQ structures, systems, and components.

i CPI-POA-X24 09a 2/28 S 7 For AQ-NCS items: Develop training materials for the work control, surveillance testmg, mstrument Est Requested i

calibration, and corrective and preventive maintenance procedures and provide the associated training of appropriate personnel.

Enclosurei N > 11422

~

FACILITY ISSUED TASK ID '

DUE DATE COMMITMENT DESCRIPTION -

STATTS.

CPI-POA-X24.09b 3/31S 7

- For Q items: Develop training materials for the work control, surveillance testing. instrument calibration,

- and corrective and preventive maintenance procedures and provide the associated training of appropriate personnel.

CPI-POA-X24.09c 6/3088 For other AQ items: Develop training materials for the work control, surveillance testing, instrument -

r calibration, and corrective and preventive maintenance procedures and provide the associated training of appropriate personnel.

L CPI-POA-X2410 3/3187 Identify and control the vendors

• manuals used for maintenance of Q equipment, including entering them I

into the document control and records management system.

- Identify vendor manuals used for maintenance activities of Q equipment.

t

- Verify appropriate vendors

• manuals for accuracy and completeness.

- Enter vendor manual data into the records management and document control system.

I PORTS 25 CPI-POA-X25.01 12/31/97 Procedures addressing the operations program elements discussed in Section 6.5 of the Safety Analysis i

Report will be developed or revised, associated initial training materials will be developed, and appropriate personnel will receive initial training by December 31,1997, consistent with the plan of action and schedule of the Compliance Plan issue entitled " Procedures Program?

l CPI-POA-X25.02 6/30/97 Continuing training material and qualification requirement development will be completed, and appropriate 1

personnel trained and qualified for Cascade Operator, Feed and Product Operator, Chemical Operator, t

Uranium Material llandler, Operations Manager / Supervisor, and Plant Shift Suga.6A.t positions by

[

June 30,1997, consistent with the plan of action and schedule of the Compliance Plan issue entitled

• Systems Approach to Training?

1 CPI-POA-X25.03 12/31/97 Continuing training material and qualification requirement development will be completed, and appropriate personnel trained and qualified for Cascade Controller position by December 31,1997, consistent uith the i

plan of action and schedule of tic Compliance Plan issue entitled ' Systems Approach to Training?

j

?

PORTS 26 i

CPI-POA-X26.01 6/30/97 Training programs will be developed and implemented based upon a systems approach to training for l

workers who are relied upon to operate, maintain, or modify structures, systems, and components identified as Q or AQ-NCS items. For the previously identifiedjob classifications training for thejob incumbents at certification will be completed by June 30,1997.

[

l CPI-POA-X26 02 6/27 S 6 A detailed schedule for the completion of all training programs not in wwla with 10 CFR 76.95 will Cosapicte

[

be issued by June 27,1996.

CPI-POA-X26.03 6/30/97 For the additionaljob classifications not previously included in the Nuclear Safety Upgrade Project,(i.e.,

systems engineers, cascade coordinators, and NCS engineers / specialists), the job analyses and training.

program design have not been completed. De following actions will be completed by June 30,1997.

[

i

- Revise and validate the existing job task lists.

- Design a curriculum that covers thejob tasks selected for training _

- Develop specific learning objectives from thejob performance.w.m..u.ts.

- Develop training materials., Page 12 of22 i

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FACILITY ISSUE #

TASK ID DUE DATE.

COMMITMENT DESCRIPTION STATUS CPI-POA-X26D4 -

See CPI-POA-X26.3 Training for those holding these'additionaljob classifications at the time the program is implemented will i

be completed by December 31,1997.

L CPI-POA-X26.05 6/30/98 Training programs for thejob classifications list abose, uith respect to AQ activities, will be developed and

[

implemented by June 30,1998, following completion ofidentification of AQ items (see Compliance Plan j

Issue 23,

• Plant Changes and Configuration Management") and associated procedures (see Compliance Plan Issue 30, " Procedures Progranf).

I PORTS 27 CPI-POA-X27.01 9/3066 An organizational level assessment program will be implemented consisting of the preparation and Complete implementation of a procedure for the performance of organizational level assessments in a uniform manner t-1 PORTS 28 l

CPI-POA-X28 Ola 5/1/96 A nuclear regulatory event reporting procedure meeting the event notification and reporting requirements Complete required by the USEC application, and an event investigations procedure that defines the event investigation process and assigns responsibilities and authority for its implementation will be approved by May 1,1996.

L CPI-POA X28.0lb Transition Training on these documents will be completed prior to the date NRC assumes regulatory oversight at

{

PORTS.

CPI-POA-X28.01c Transition ne pmcedures will become effective on the date NRC assumes regulatory oversight at PORTS.

I PORTS 29 CPI-POA-X29.01a.1 6/30S6 Records being maintained by the plant organizations and Administrative Support will be verified to Complete determine the storage locations of these records and the methods of protection being employed to preserve f

the~,,

CPI-POA-X29.0 t a.2 6/30/96 He final tally of records identified in item (1) above will be evaluated against applicable requirements and Complete then catalogued as to their record type, categorization, and retention. His information will be characterized I

in a combined PORTS and PGDP Uranium Enrichment Records Manual that will be utilized by both sites.

i Both the tally of records and the manual will be completed by June 30,1996.

I CPI-POA-X29.01a.3 6/30/06 A records managernent turnover schedule has been drafted and submitted to the functional organizations Complete which prioritizes the tumover based on the record's importance to the safety and quality of plant operations.

i His schedule will be formalized by June 30,1996.

CPI-POA-X29.01a.4 12/3168 Records being maintained in the organizations will not be tumed over to Administrative Support immediately but will be retained by the responsible organization until the D&R Group can pmcess tfxm.

t Pre-existing records will be tumed over and incorporated into the records management system.

CPI-POA-X29.Ola.5 6/30!96 A new electronic records indexing database based on the evaluation conducted in item (2) above and item Complete f

1.d)(1) below will be put into service by June 30,1996.

CPI-POA-X29.Olb Also see issue 23 For legacy records: He PORTS Configuration Management Program implementation procedures will Complete address the measures required to be taken if source information needs to be developed and documented. See issue 23, " Plant Changes and Configuration Management."

, Page 13 of22 L

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FACILITY ISSUEO TASK ID DOE DATE COMMITMENT DESCRII' TION STAlTS s

CPI-POA-X29.0!c 12/31M8 Records being maintained in the organizations will be turned over to Administrative Support in accordance with the records management turnover schedule identified in item (aX3) above. Pre-existing records required to be maintained under the llSEC Quality Assurance Program will be turned over and incorporated into the revised secords management system in accordance with the approved records management tumover j

schedule. After the turnoser of an organization's records to Records Management, the temporary storage of i

subsequent records will be in one-hour fire-rated file cabinets.

[

CPI-POA-X29.01d.1 8/15N6 The PORTS mpad records indexing system will be evaluated to make certain that the necessary Complete

[

information required by each organization for its records is consistently applied to ensure the ready i

retrievability of the records.

CPI-POA-X29.01d.2 12/31/98 Computer codes and test result data used to directly or indirectly support the PORTS process systems will I

be submitted to Administrative Support in accordance with the turnover schedule identified in item (aX3) l above.

CPI-POA-X29.02a.1 6/30/96 Documents being maintained by the plant organizations and Administrative Support will be verified.

Complete CPI-POA-X29.02a.2 6/3066 A document control tumover schedule has been draAed which prioritizes the turnover based on the Complete document's importance to the safety and quality of plant operations. This schedule uill be formalized by June 30,1996.

CPI-POA-X29.02a3 6/30S6 The document control system will be updated on an ongoing basis to provide controlled distribution lists Complete -

and to control the actual distribution of documents under the control of the D&R Group commencing June 30,1996.

CPI-POA-X29.02a.4 12/31M8 Documents within the scope of the document control program, according to the application, will be identified. Documents being maintained in the organizations will not be tumed over to Administrative Support but will be retained by the responsible disision until Administrative Support can process them. Pre-l existing documents will be turned over and incorporated into the document control system.

CPI-POA-X29.02a.5 12/3168 Ihe final tally of documents identified in items (I) and (3) above will be catalogued as to their document

[

type, distribution requirements, and information to provide an index for ease of retrievability, t

f CPI-POA-X29.02a.6 6/30/96 The new electronic document control inventory system that identifies the controlled copy holder number Complete and custodians, storage location, and retrieval capability 3ill be put into service.

CPI-POA-X29.02b Also see issue 23 For legacy dom ~i The plan of action and schedule provided in 1(b) above will also resolve this item.

Compicte PORTS 30 i

t CPI-POA-X30.01 7/31M6 By July 31,1996, incorporate into the Procedure Control Process procedure the SAR4.11.4.1 criteria for Complete use by responsible management in complying with TSR 3.9 by identifying applications requiring additional written procedures.

CPI-POA-X30.04 6/I!96 Document the criteria for use in determining when work must be stopped because a procedure cannot be Complete performed as written.

CPI-POA-X30.06 Transition By Oc date that the NRC assumes regulatory authority for PGDP, incorporate into the Procedure Control Proct ss procedure the SAR4.11.4.5 criteria for identifying procedures that TSR 3.9 requires review by the i

PORC.. Page H of22 l

FACILITY ISSUE O TASKID DUE DATE CO313tlT3 TENT DESCRIPTION STATUS e

CPI-POA-X30.08 Transition Incorporate action statements and operating limits from the Technical Safety Requirements into operational procedures by the date that the NRC assumes regulatory authority for PORTS.

CPI-POA-X30.09a 6/28/96 Issue the required operational policy statements and implement new or updated procedures (including Complete required training) to fully implement the Quality Assurance Program or other actitities identified in the application in accordance with the following schedule:

- Operational policy statements: June 28,1996 CPI-POA-X30.09b 2!28/97 Issue the required operational policy statements and implement new or updated procedures (including Ext Requested required training) to fully implement the Quality Assurance Program or other activities identified in the application in accordance with the following schedule:

- Level ? %, v.'

• AQ-NCS procedures (unicss covered by item 8): December 31,1996 CPI-POA-X30.09c 3/31/97 Is,uc the required opera:ianal policy statements and implement new or updated procedures (including required training) to fully implement the Quality Assurance Program or other actis ities identified in the application in accordance sith the following schedule:

- Level 2,3. and 4 Q procedures (unless covered by item 8): March 31, lo97 CPI-POA-X30 09d 12/31/97 Issue the required operational policy statements and implement new or updated pmcedures (including required training) to fully implement the Quality Assurance Proram or other activities identified in the application in accordance with the following schedule:

- Level 2,3, and 4 AQ and NS procedures: December 31,1997 CPI-POA-X30.10 12/31/97 Issue analytical laboratory procedures updated to current requirements by December 31,1997.

CPI-POA-X30.1 I 12/31/97 Complete all overdue Level 2,3, and 4 AQ procedure periodic reviews by December 31,1997.

CPI-POA-X30.12 Transition + 5 ycars De PORC will review all procedures designated as In-liand and procedures that involve liquid UF6 handling activities within a 5-year period after the date that the NRC essumes regulatory authority for PORTS. His commitment pertains only to those pmcedures which will not otherwise be reviewed by the PORC (as required by Section 6.11.4.1), or by a PORC subecmmittee, before the expiration of the 5-year period. Procedures in this scope have been, and will ccntinue to be, reviewed by a PORC subcommittee, thereby satisfying this w. mea.t for those specific procedures.

CPI-POA-X30.13 Transition All aspects of TSR 3.9 implementation and its associated tentacles shall be in place no later than the date that the NRC assumes regulatory authority for PORTS. Procedures required by Technical Safety Requirement 3.9.1 shall be in place by the assumption of regtdatory authority by NRC except as specified in the Compliance Plart PORTS 32 CPI-POA-X32.01 12/31/96 Deselop and implement procedures, including personnel training, for the scheduling and conduct ofintemal and supplier audits, including auditing the development, maintenance, adequacy, and effectiveness of the QAP, by December 31,1996.

CPI-POA-X32.02a 2/28/97 Develop and implement procedures, in:luding personnel training, that define p-a..t. handling, and Est Requested storage activities for AQ-NCS items and services by December 31,1996. Page 15 of22

FACILITY ISSUEO TASKID DUE DATE COMMITMENT DESCCRTION STATUS CPI-POA-X32.02b 3!31/97 Develop and implement procedures, including personnel training, that define p Am.

..t, handling, and storage activities for Q items and services by March 31,1997.

CPI-POA-X32.02c 12/31/97 Develop and implement procedures, including personnel training, that define p

m. mot. handling, and storage activities for other AQ items and services by December 31,1997.

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PORTS 33 CPI-POA-X33.01 6/30S6 The emergency plan support documents will be upgraded.

Complete

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5 PORTS 34 i

CPI-POA-X34.01a 9/30/96 All tenant organization personnel will be given emergency preparedness General Employee Training.

Complete '

CPI-POA-X34.Olb 6/30/96

. Updated formal training will be given to ua.emy response personnel.

Complete CPI-POA-X34.01c 12/31/96 Off-site emergency support personnel will be trained on the revised emergency plan and procedures as appropriate by December 31,1996.

PORTS 35 CPI POA-X35.01 -

10/24 S 5 A quality control program including all elements necessary to ensure compliance with 10 CFR 61.55 and Complete i

10 CFR 61.56 will be implemented.

L PORTS 36 CPI-POA-X36.01 12/3166 Update existing depleted uranium handling, moving stacking, and inspection procedures to current format and content requirements (see the compliance plan issue entitled " Procedures Program") and provide training to affected personnel.

CPI-POA-X36.02 12/31/96 Develop a process for use in scheduling the periodic visual inspections.

PORTS 37 CPI-POA-X37.Ola 8/1/96 The current staffing allocations will be supplemented if necessary to meet working hour guidelines stating Complete that an individual should not be permitted to work more than 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> in any 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period and no more than 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> in any 7 day period, excluding shiR turnover time.

i CPI-POA-X37.Olb 8/1/96 A revised TSR will be submitted to the NRC to add these guidelines to TSR 3.2.2.b.

Complete CPI-POA-X37.02a 12/31/96 USEC will supplement current staffing allocations to meet its proposed making hour guidelines that state that an individual should not be permitted to work more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period and no more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7 day period exclusive of shiA tumover time.

CPI-POA-X37.02b 12/31/96 USEC will submitted a revised TSR to the NRC to add these guidelines to TSR 3.2.2.b at the time sufficient staffmg is achieved to meet these guidelines.

i.

PORTS 38 l

Enclosure L Page 16 of22

. ~

FACILITY ISSUE #

TASK ID DUE DATE COMMITMENT DESCEIPTION STA11'S CPI-POA-X38.01 Privatization The following executed documents required to assme adegoate funding for USEC's portion of PORTS's i

decontamination and decommissioning costs will be opmitted to the NRC at the time USEC privatization occurs:

v

- an executed sinking fund arrangement.

- a standby trust agreement, and/or

- a payment surety bond.

The above-listed doce:,nents mill closely adhere to the recommended wording for such instruments set forth l

in NRC Regularc.y Guide 3.66, ' Standard Format on and Content of Financial Assurance Mechanisms Required fe: Decommis - oning under 10 CFR Parts 30,40,70, and 72."

PORTS 39 CPI-POA-X39.01 5/26/97 The mechanical integrity program for maintenance and inspection PSM im;.w ts will be implemented.

PORTS 40 CPI-POA-X40.08 10/i/96 A retiew of system designs will be performed where operational trips and alarms coincide with the Complete setpoints for safety system actuation based on the same monitored parameter and the same equipment actuated. Where redundant m..ii-.I and safety system actuations exist, corrective action will be identified that may includejustification either for the redundancy or system modifications to climinate the redundancy. The results of this review will be submitted to the NRC for review and approval by October 1, 1996.

6 PORTS 41 CPI-POA-X41.01 2/1/97 The docurwnts referenced in Appendix A to SAR Chapter I.0 will be reviewed, and a listing of specific sections of the codes, standards, and NRC regulatory guidance documents to which PORTS is committed will be compiled. The results will be transmitted to NRC at least 30 days prior to the date that the NRC assumes regulatory authority for PORTS.

l PORTS 42 CPI-POA-X42.01 7/31/97 USEC will develop and complete a program to relate the response of UF6 leak detectors to manual test methods and to the detection of an actual UF6 leak.

PORTS 44

- t CPI-POA-X44.01a 7/31/97 Unalarmed facilities that have been identified as of June 10,1996, will be modified with the required horns and/or lights, as appropriate, or relocated to locations outside the 200-foot evacuation zone in accordance with the following schedule:

Routinely Manned Facilities: July I,1997 i, Page 17of22

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