ML20135D356

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Forwards List of Open USEC Commitments to DOE Re Compliance Plan Issue C1/X1
ML20135D356
Person / Time
Site: Portsmouth Gaseous Diffusion Plant, Paducah Gaseous Diffusion Plant
Issue date: 03/01/1997
From: Wooley R
UNITED STATES ENRICHMENT CORP. (USEC)
To: Pierson R
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
GDP-97-0023, GDP-97-23, NUDOCS 9703050205
Download: ML20135D356 (52)


Text

United States Ennchraent Corporation 2 Democracy Center 6903 Rockledge Drive Bethesda, MD 20817 Tel (301)564-3200 Fax. (301) 564-3201 Utilteil States Eririchnierit Corix>ratiori March 1,1997 Mr. Robert C. Pierson SERIAL: GDP 97-0023 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 & 70-7002 Compliance Plan Issue C1/X1, List of Open United States Enrichment Corporation (USEC)

Commitments to the Department of Energy (DOE)

Dear Mr. Pierson:

Issue 1 of the Plan for Achieving Compliance With NRC Regulations at PGDP and PORTS states:

The listing of open USEC commitments to DOE will bo provided to NRC by USEC on the date that NRC assumes regulatory oversight responsibility for PGDP and PORTS.

In accordance with this Compliance Plan issue, enclosed are the following documents: is a list of open regulatory cornmitments assigned to PGDP;

. is a list of open regulatory commitments assigned to PORTS;

  • is a list of open regulatory commitmeia assigned to USEC IIcadquarters (11Q).

The enclosed documents were generated from our Business Prioritization System (BPS) which is the system utilized by USEC to track regulatory commitments. The cutoff date for this report is February 26,1997. If there are any new regulatory commitments to DOE generated between this date and March 3,1997 (i.e., the date that NRC assumes NRC regulatory oversight), USEC will submit a supplemental report by March 17,1997. If you have any questions concerning the enclosures please contact either Bill Sykes, PGDP NRA Manager, at (502) 441-6796, Ron Gaston, PORTS NRA Manager, at (614) 897-2710, or Russ Wells, USEC Senior Regulatory Engineer, at (301) 564-3245.

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Offices in Paducah, Kentucky Portsmouth, Ohio Washington, DC

4 Mr. Robert C. Pierson March 1,1997 GDP 97-0023 Page 2 To assist in your review of the enclosures, a table has been provided which defines the information l

contained in the submittals. Enclosure 4 lists the commitment made in this report.

d Sincerely,

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i j dlA Robert L Wool ey

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Nuclear Regulatory Assurance and Policy Manager i

i Enclosures i

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NRC Region III Office NRC Resident Inspector - PGDP i

NRC Resident Inspector - PORTS DOE Regulatory Oversight Manager i

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Tchie 1 Dermition of Terms Provided in Enclosures 1-3 l Column No.

Term Description 1

1RMS ID This is the commitment tracking number in BPS 2

REG ENGR /

" REG ENGR" is the Regulatory Engineer assigned to follow and be FINDING NO.

knowledgeable of the commitment.

" FINDING NO." is the source document. Regulatory commitments are generated from USEC correspondence to DOE. The primary sources of these commitments are listed below:

Responses to Notices of Violations and Deviations Event Reports Compliance Plan Actions Responses to Regulatory Requests for Information Requests for Enforcement Discretion Regulatory Oversight (ROA) fmdings in Internal Audit reports submitted to DOE on the docket Response to DOE Management Conference Commitments contained in miscellaneous submittals to DOE (e.g., PGDP Tiger Team Findings)

Note: The list of open regulatory commitments also includes actions in correspondence received from DCF (e.g., respond to a Notice of Violation) since these are treated in a manner similar to regulatory commitments.

3 TITLE This is a description of the issue that relates to the regulatory commitment 4

DESCRIPTION This is the action that USEC committed, in writing to DOE or in cases ofincoming correspondence from DOE, the action required by i

DOE.

5 REGULATORY In accordance with procedure UE2-OP-RA1031, USEC Nuclear LEVEL Regulatory Commitment Management System, regulatory commitments are classified as either Priority 1 (i.e., the correspondence submitted to the Regulator specified a date as to when the commitment would be completed) or Priority 2 [i.e., the correspondence submitted to the Regulator did not specify a completion date or the completion date was tied to a milestone.

Incoming actions assigned by the DOE are given due date priorities similar to regulatory commitment due dates.

6 SCH.DATE This is the due date that was committed to the DOE by USEC. This j

column only apples to Priority 1 due dates. As indicated above, Priority 2 commitments do not have a specific commitment due date.

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Enclosure I to GDP 97-0023 Paducah Gaseous Diffusion Plant Open Regulatory Commitments v

Business Prioritization System REGUIA7URY COPNITMENTS PGDP OPEN REGULATORT COPMI7MENTS Issue Regulatory Finding Issue Scheduled ID Engineer Number Title Description Date LEt/EL

1) UC97I0036 COWNE SR 96-07-03 TWO DEVIATIONS FROM The Nuclear Regulatory Affairs Organization will 02/27/1997 1

COMMITMENTS conduct internal assessments of the regulatory comitment management process at PGDP to identify any potential weaknesses and areas for improvement.

2) UC96I2220 JANNE RL Col TRANSITION FROM DOE REGULATION The listing of open USEC comitments to DOE will be 02/28/1997 1

TO FRC REGULATION provided to NRC by USEC on the date that NRC assumes regulatory authority for PGDP. This will be met by providing open regulatory commitments in PGDP BPS.

3) UC9612557 JANNE RL C22 MAINTENANCE PROGRAM Develop procedures and provide the associated training 02/28/1997 1

of appropriate personnel for the performance of surveillance tests which are required to support Technical Safety Requirements. 7his action will be completed prior to the NRC assuming regulatory authority.

4) UC96I2830 JANNE RL C36 SEISMIC CAPABILITY OF At the time of transition from DOE regulatory oversight 02/28/1997 1

BUILDINGS C-331 AND C-335 to NRC regulatory oversight. USEC will inform NRC of the interim measures still in effect for the affected buildings and equipment and the current status of upgrading the seismic capabilities of the affected buildings and equipment.

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5) UC96I2561 JANNE RL C27 PROCEDURES PROGRAM All aspects of Technical Safety Requirement (TSR) 3.9 02/28/1997 1

implementation and its associated tentacles shall be in place no later than the date that the NRC assumes regulatory authority for PGDP.

Procedurers required by TSR 3.9.1 shall be in place by the ass m ion of regulatory authority by NRC except as specified in the Compliance Plan.

6) UC9617029 STADLER D PAD-1996-0040 OSR VIOLATION - UF6 PIPING Implement a plant-level procedure or procedure change 02/28/1997 1

PENETRATED. NOT UF6 NEG to identify a rigorous method of applying a unique identifier on piping and equipment not readily identifiable.

7) UC96I7370 STADLER D PAD-1996-0044 OSR VIOLATION - TIME LIMIT Submit a change to the TSR (Section 1.3), in 02/28/1997 1

BETWEEN FIRE PATROLS coordination with Fire Services and the Portsmouth Gaseous Diffusion Plant, that defines the hourly interval designation, interval between consecutive surveillances, and maximum interval between consecutive surveillances.

8) UC97I0031 STADLER DC 96-07-01 FAILURE TO MEET PASSIVE FIRE A change will be submitted to the TSR that defines the 02/28/1997 1

WATCH REQUIREMENTS hourly interval #-

1gnation and maximum interval

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between consecutive surveillances.

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9) UC97ICO37 ALBRITTON LE 96-07-04 CFENING MADE TO *A* LINE DROP A plant-level procedure, or procedure change, will be 02/28/1997 1

l-W/O UF6 NEGATIVE implemented identifying a rigorous method of applying a unique identifier on piping and equipment not readily

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identifiable.

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REGULATORY COfMIMENTS PGDP OPEN REGULATORY COPHIP1ENTS i

I Issue Regulatory Finding.

Issue Scheduled ID Engineer Number Title Description Date LEVEL j

10) UC9612556 JANNE RL C21 PIANT CHANGES AND Develop the flowdown of commitments from the Technical 03/02/1997 1

CONFIGURATION MANAGEMENT Safety Requirements to procedures and training.

11) UC9612556 JANNE RL C21 PLANT CHANGES AND Develop the flowdown of commitments from the Safety 03/02/1997 1

CONFIGURATION MANAGEMENT Analysis Report and other plans and programs to l

procedures and training.

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12) UC96I2556 JANNE RL C21 PLANT CHANGES AND Incorporate new Technical Safety Requirements into the 03/02/1997 1

CONFIGURATION MANAGEMENT surveillance testing and administrative procedures.

n e procedure development and associated training i

required to resolve this item will be completed l

according to the plan of action and schedule provided

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in the Compliance Plan issue entitled " Procedures Program."

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13) UC96I2561 JANNE RL C27 PROCEDURES PROGRAM Incorporate action statements and operating limits from 03/02/1997 1

the Technical Safety Requirements into operaticul procedures by the date that NRC assumes regulatory authority for PGDP.

[ Functional area managers will l

4 provide subject matter experts on the planned schedule dates to review the documentation.]

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14) UC96I8914 STADLER D 96-05-04 PROCEDURES NOT APPROVED AND he following documents will be flowed down into 03/02/1997 1

f ISSUED FOR USE procedures by January 31. 1997:

NRC CoC for the Paducah Tiger Overpacks UEO-1041. Packaging and Transporation Quality Assurance Plan.

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15) UC96I2554 JANNE RL C19 MANAGEMENT CONTROLS The flowdown to committed USEC position descriptions 03/02/1997 1

l provided in Section 6.1 of the USEC Application will be I

completed and position descriptions revised, if I

necessary, by the date that NRC assumes regulatory authority.

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16) UC9610108 COWNE SR PR-QA-95-4068 LACK OF MANAGEMENT TO MAINTAIN Assess plant personnel knowledge and understanding of 03/03/1997 1

QPP the QPP/QAP.

17) UC96I8581 STADLER D PAD-1996-0062 TRESPASS ON GOVERNMENT Replace c1rrent *No Trespassing
  • signs affixed to gates 03/03/1997 1

PROPERTY with signs that are larger print. Place the signs adjacent to the gates at driver's eye level for ease of reading.

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18) UC96I7925 COW'TE SR PAD-1996-0053 TSR VIOLATION - FAILURE TO Issue an Engineering procedure to provide guidance on 03/10/1997 1

t PERFORM REQUIRED SURVEI defining proper post-maintenance tests.

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19) UC96I9115 COWNE SR 96-06-01 PRESSURE DECAY TESTS NOT Issue an engineering procedure to provide guidance on 03/10/1997 1

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i PERFORMED defining proper post-maintenance tests.

(Regulatory Commitment Stamp to be placed in procedure.)

20) UC9617756 ALBRITTON LE PAD-1996-0047 FAILURE OF C-337 FREEZER Investigate and report findings on why the number of 03/14/1997 1

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SUBLIMER

  • B' VALVE DURING outages associated with C-337 F/S Unit 1 Cell 9; Unit 3, cell 8 Unit 4, Cell 2; Unit 4. Cell 8 and Unit 5 Cell 2, have been greater than other F/S locations i

within C-337.

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Printed 02/27/1997 at 15:18:12 Page 2 f

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Business Prioritization System REGULATORT COPNITME!TPS PGDP OPEN REGUIATORY COPf4I7NENTS Issue Regulatory Finding Issue Scheduled ID Engineer Number Title Description Date LEVEL i

21) UC95I4506 JANNE RL PAD-1995-0080 FIANT PUBLIC WARNING SYSTEM The new system will be installed and operational.

03/15/1997 1

SIREN AAC FAILED TO AC

22) UC9612568 JANNE RL C30 PUBLIC WARNING SIRENS AND The new system will be installed and operational.

03/15/1997 1

CONTROLS

23) UC9615877 ALBRITTON LE PAD-1996-0033 FAILURE OF FREEZER-SUBLIMER Maintenance shall develop an action plan and schedule 03/15/1997 1

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'A' VALVE DURING OPERA to implement the requirement for making electrical wiring connection supplied by Engheering.

24) UC9615912 ALBRITTON LE PAD-1996-0034 FAILURE OF FREEZER-SUBLIMER Maintenance shall develop an action plan and schedule 03/15/1997 1

"B' VALVE to implement the requirement for making electrical wiring connection supplied by Engineering.

25) UC96I5309 COWNE SR PAD-1996-0027 FAILURE OF C-310 NORMETEX UF6 Implement a method to flag ESOs as being regulatory 03/17/1997 1

s DETECTION SYSTEM commitmert. :o ensure that they are completed as i

intended. This requirement shall be included in applicable Engineering procedures.

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26) UC96I6355 ALBRITTON LE PAD-1996-0036 OSR VIOIATION OF WASTE Measure existing containment pans, pallets, and 03/20/1997 1

HANDLING SPECIFICATION birdcages and compare dimensions to drawing measurements. Measurements will be performed based on written guidance to ensure a consistent, formal process. Mark the acceptable pans with unique ID l

numbers. Repair pans to meet specifications or destroy i

rejects.

NOTE: SCAQ PR-CO-96-3531 (UC9615787), Action Step 003, has been duplicated to tMs action. MAAT approval, in

27) UC96I6421 ALBRI7 TON LE PAD-1996-0037 OSR VIOLATION OF WASTE Measure existing centainment pans, pallets, and 03/20/1997 1

HANDLING SPECIFICATION birdcages and cc'4are dimensions to drawi ag

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measurements. Measurements will be performed based on written guidaace to ensure a consistent, formal process. Mark the acceptable pans with unique ID numbers. Repair pans to meet specifications or destroy rejects.

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28) UC96I5309 ALBRITTON LE PAD-1996-0027 FAILURE OF C-310 NORMETEX UF6 Complete design of Normetex pump UF6 detection system 03/27/1997 1

DETECTION SYSTEM modifications to eliminate the 24 VDC power sup;Ly single point failures (as established for ESC siomitted in Action Step 001) and provide to Operations f r installation.

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29) UC96I7757 STADLER D PAD-1996-0048 FAILURE TO DOCUMENT REQUIRED Revise CP2-SS-FS1032 and Fire Patrol Log Form to 03/28/1997 i

FIRE PATROL IN C-335 require the front-line manager to verify each shift, by affixing his/her signature, that the Fire Patrol Log 6

has been checked for accuracy and completeness.

(Regalatory Comnitment Stamp to be placed in procedure.)

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30) UC97ICO31 STADLER DC 96-07-01 FAILURE TO MEET PASSIVE FIRE Issue a procedure (UE2-CP-OP1030. **onduct of 03/28/1997 1

l WATCH REQUIREMENTS Operations") that clearly defines management expectations for promptly returning safety-related Printed 02/27/1997 at 15:18:12 Page 3 f

Business Prioritization System REGULATORY COMMITMENTS PGDP CPEN REGULATORY COMMITMENTS Issue Regulatory Finding Issue Scheduled ID Engineer Number Title Description Date LEVEL equipment to service. (Regulatory Commitment Stamp to be placed in procedure.)

31) UC9710031 STADLER DC 96-07-01 FAILURE TO MEET PASSIVE FIRE Revise CP2-SS-FS1032 and Fire Patrol Log Fcrm to 03/28/1997 1

WATCH REQUIREMENTS require the front-line manager to verify each shift, by affixing his/her signature, that the Fire Patrol Log has been checked for accuracy and completeness.

(Regulatory Comitment Stamp to be placed in procedure.)

32) UC90IO779 HOLT DC TS 3-2 CONFIGURATION MANAGEMENT Complete implementation.

03/31/1997 1

SYSTEM NOT IN PLACE

33) UC95I0045 COWNE SR 94-14-12 PROCEDURE IMPLEMENTATION Revise UE2-HR-LR1030 to ensure accountability for 03/31/1997 1

procedure use will be enforced through the USEC/MMUS employee discipline program known as " Positive Discipline."

(UE2-HR-LR1030 is entitled " Employee Discipline".)

(Regulatory Commitment Stamp to be placed in procedure.)

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34) PC95IO544 STADLER D 94-18-01 CHANGES N ?LANT DESIGN AND Fully implement the Level 3 and 4 procedures for 03/31/1997 1

r EQUIENEL" Configuration Management identified in Corrective Action No. 2.

35) UC9612549 JANNE RL C14 FIRE PROTECTION WATER SYSTEM A Nuclear Safety Upgrade project provides for the 03/31/1997 1

RELIABI' W reconfiguration of the fire water supply piping to Building C-315.

The fixed automatic fire suppression systems covering those areas of Building C-315 in which Q systems are located will be supplied from the HPFWS.

This project includes scheduling, egaipment procurement, installation, and system testing.

36) UC9612554 JANNE RL C19 MANAGEMENT CONTROLS Quality Assurance Program requirements and applicable 03/31/1997 1

NRC requirements (for Q SSCs) will be flowed down to policies and procedures that will be approved and implemented at USEC Headquarters and PGDP in accordance with the Plan of Action and Schedule described in Compliance Plan Issue C27, " Procedures Program."

37) UC96I2556 JANNE RL C21 PLANT CHANGES AND Develop or upgrade remaining engineering procedures 03/31/1997 1

i CONFIGURATION MANAGEMENT that are associated with the change control process and train appropriate personnel on these new or upgraded procedures.

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38) UC96I2557 JANNE RL C22 MAINTENANCE PROGRAM Revise the measuring and test equipment (M&TE) and 03/31/1997 1

E process equipment calibration programs for Q list SSCs.

  • Identify all Q list M&TE.
  • Track the use of calibration standards and verify that all M&TE used for the calibration of Q list SSCs is controlled and traceable to national standards.
  • Develop and implement procedures that define and control the overall METE program.
  • Develop and implement individual calibration Printed 02/27/1997 at 15:18:12 Page 4

Business Prioritization System REGULATORT CCH4IMENTS PGDP OPEN RE7JLATORY COPE 4ITMENTS Issue Regulatory Finding Issue Scheduled I

ID Engineer Number Title Description Date LEVEL

39) UC96I25S7 JANNE RL C22 MAINTENANCE PROGRAM Identify the procedural deficiencies for performing

. 03/31/1997 1

corrective maintenance, preventive maintenance, equipment calibration, or survullance testing for Q SSCs; and develop a composite listirig of the procedures requiring revision, develcWnt, or conversion.

40) UC9612557 JANNE RL C22 MAINTENANCE PROGRAM Revise, develop, or convert corrective maintenance, C3/31/1997 1

preventive maintenance, instrument calibration, and surveillance test procedures for Q S1Cs.

41) UC9612557 JANNE RL C22 MAINTENANCE PROGRAM Develop training materials for the work control, 03/31/1997 1

surveillance testing, instrument calibration, and corrective and preventive maintenance procedures for Q SSCs and provide the associated training of appropriate 2

personnel.

42) UC96I2557 JANNE RL C22 MAINTENANCE PROGRAM Identify and control the vendors' manuals used for 03/31/1997 1

maintenance of Q equipment, including entering them into the document control and records management system.

43) UC96I2561 JANNE RL C27 PROCEDURES PROGRAM Implement new or updated Level 2, 3, and 4 Q procedures 03/31/1997 1

[for the Training and Procedures Organization], other than those required to implement the TSRs, including training, to fully implement the Quality Assurance Program or other activities identified in the application.

44) UC96I2561 JANNE RL C27 PROCEDURES PROGRAM Implement new or updated Level 2, 3, and 4 Q procedures 03/31/1997 1

[for the Engineering Organization], other than those required to implement the TSRs, including training, to fully implement the Quality Assurance Program or other activities identified in the application.

45) UC9612561 JANNE RL C27 PROCEDURES PROGRAM Implement new or updated Level 2, 3, and 4 Q procedures 03/31/1997 1

[for the Plant Shift Superintendents organization),

other than those required to implement the TSRs, including training, to fully implement the Quality Assurance Program or other activities identified in the application.

4

46) UC96I2561 JANNE RL C27 PROCEDURES PROGRAM Implement new or updated Level 2, 3 and 4 Q procedures 03/31/1997 1

[for the Production Support Organization], other than those required to implement the TSRs, including training, to fully implement the Quality Assurance Program or other activities identified in the application.

07) UC96I2561 JANNE RL C27 PROCEDURES PROGRAM Implement new or updated Level 2, 3, and 4 Q procedures 03/31/1997 1

[for the Materials Management Organization], other than those required to implement the TSRs. including training, to fully implement the Quality Assurance Program or other activities identified in the application.

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Business Prioritization System REGULATORY COMMITMEhTS PGDP OPEN REGULATORY COMMITMENTS Issue Pegulatory Finding Issue Scheduled ID Engineer Number Title Description Date LEVEL

48) UC96I2561 JANNE RI, C27 PROCEDURES PROGRAM Implenent new or updated Level 2, 3, and 4 Q procedures 03/31/1997 1

[for the Operations Organization), other than those required to implement the TSRs. including training, to fully implement the Quality Assurance Program or other activities identified in the application.

49) UC9612561 JANNE RL C27 PROCEDURES PRCGRAM Implement new or updated Level 2, 3, and 4 Q procedures 03/31/1997 1

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(for the Nuclear Regulatory Affairs Organization],

cther than those required to implement the TSRs, including training, to fully implement the Quality Assurance Program.

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50) UC96I2565 JANNE RL C29 QUALITY ASSURANCE PROGRAM Develop and implement procedures, including personnel 03/31/1997 1

IMPLEMEMATION training, that define handling and storage activities for Q items and services.

SI) UC9616122 JANNE RL C42 ADMINISTRATIVE CONTROLS ON USEC will supplement current staffing allocations to 03/31/1997 1

OVERTIME meet its proposed working 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-hour period and not 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 shift turnover time.

In addition, USEC will submit a revised TSR to the NRC to add these guidelines to TSR 3.2.2.b at the time sufficient staffing is achieved to meet these guidelines. Sufficient staffing will be achieved and the revised TSR submitted to the NRC by March 31,

52) UC96I7369 STADLER D PAD-1996-0043 TSR VIOLATION - FAILURE TO Issue plant-level procedure which addresses fitness for 03/31/1997 1

PERFORM SMOKE WATCH duty, with a requirement for the employee to inform the front-line manager of a lack of fitness for duty or if they suspect that a co-worker is not fit fer duty.

This information will be communicated to managers for flowdown by the company newsletter, InsideP, and Employee Relations update.

53) UC96I2560 JANNE RL C26 RECORDS MANAGEMENT AND The PGDP Configuration Management Program 03/31/1997 1

DOCUMENT CONTROL PROGRAM implementation procedures will address the measures required to be taken if source information i

[ records / documents) needs to be developed and documented.

54) UC96I8914 STADLER D 96-05-04 PROCEDURES NOT APPROVED AND SS&Q will conduct a follow up surveillance to determine 03/31/1997 1

ISSUED FOR USE the adequacy of the PTQAP flowdown into site level procedures. This is scheduled to be completed by March 31, 1997 SS) UC96I2813 COWNE SR PAD-1996-0013 UF6 RELEASE GREATER THAN 5 Iricorporate torquing values into appropriate 04/01/1997 1

GRAMS C-337 Maintenance procedures involving fasteners for pressure boundary components of uranium process systems which are designated as "Q* systems.

(Regulatory Commitment t

Stamp to be placed in procedures.)

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t Business Prioritization System REGUIATORY COMMITMENTS PGDP OPEN REGULATORY COMMITMENTS h

Issue Regulatory FiMing Issue Scheduled ID Engineer Numaer Title Description Date LEVEL

56) UC96I8914 STADLER D 96-05-04 PROCEDURES NOT APPROVED AND Requirements for retraining PET personnel on new or 04/01/1997 1

(

ISSUED FOR USE revised DOT and NRC Transportation regulations having job assignments requiring a knowledge thereof will be developed and implemented by April 1, 1997 4

57) UC96I8704 STADLER D PAD-1996-0065 OSR VIOLATION - FAILURE TO Complete and document a review of all Fire Services 04/01/1997 1

IMPLEMENT FIRE WATCH procedures to ensure that they do not include exceptions that may be in conflict with an OSR or TSR

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requirement.

58) UC96I7029 STADLER D PAD-1996-0040 OSR VIOLATION - UF6 PIPING Complete conduct of maintenance training developed in 04/15/1997 1

PENETRATED, NOT UF6 NEG Action Step 011 for appropriate Maintenance personnel.

59) UC97IO037 ALBRITTON LE 96-07-04 OPENING MADE TO
  • A* LINE DROP Conduct of Maintenance training will be completed for 04/15/1997 1

W/O UF6 NEGATIVE appropriate Maintenance personnel.

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60) UC9617756 ALBRITION LE PAD-1996-0047 FAILURE OF C-337 FREEZER Conduct an internal surveillance of compliance with 04/18/1997 1

SUBLIMER *B" VALVE DURING preventive maintenance schedules as directed by CP2-EG-EG1030.

61) UC9618782 ALBRITTON LE PAD-1996-0066 STEAM LEAK AT C-337-A Instrument Maintenance procedures will be reviewed and 04/18/1997 1

AUIDCLAVE POSITION 1 WEST modified, if required, to ensure limit switch engagement practices do not result in maladjustments of limit switches.

62) UC9617756 ALBRITTON LE PAD-1996-0047 FAILURE OF C-337 FREEZER Complete loading of information supplied on the 04/21/1997 1

SUBLIMER *B* VALVE DURING preventive maintenance item description data sheets generated from Action Step 005.onto the preventive y

maintenance data base.

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63) UC96I2339 JANNE RL C31 PUBLIC ADDRESS SYSTEM The existing public address system, which includes the 04/30/1997 1

i central public address switching console, speakers, and i

amplifiers, will be upgraded to provide more reliable service to the plant and additional expansion

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capabilities.

64) UC96I7029 STADLER D PAD-1996-0040 OSR VIOLATION - UF6 PIPING Revise / delete existing Operations procedures, as 04/30/1997 1

PENETRATED, NOT UF6 NEG necessary, to ensure no conflicts exist with the requirements of Action Step 005.

Brief appropriate individuals on those requirements.

i

65) UC96I7029 STADLER D FAD-1996-0040 OSR VIOLATION - UF6 PIPING Revise / delete existing Maintenance procedures, as

- 04/30/1997 1

l PENETRATED, NOT UF6 NEG necessary, to ensure no conflicts exist with the requirements of Action Step 005. Brief appropriate

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individuals on those requirements.

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66) UC96I7029 STADLER D PAD-1996-0040 OSR VIOLATION - UF6 PIPING Evaluate and revise, if appropriate, the existing Work 04/30/1997 1

t PENETRATED, NOT UF6 NEG Control procedure, CP2-GP-GP1032, to ensure no conflicts exist with the requirements of Action Step 005 resolution. Brief appropriate individuals on any resulting changes to the Work Control procedure and on the resolution to Action Step 005 of this event report.

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Business Prioritization System REGULATORY COMMITMENTS PGDP OPEN REGULATORY COMMITMENTS I

Issue Regulatory Finding Issue Scheduled ID Engineer Number Title Description Date LEVEL

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67) UC96I8782 AL9RITTON LE PAD-1996-0066 STEAM LEAK AT C-337-A Eigineering will provide technical guidance to 04/30/1997 1

AUTOCLAVE POSITICN 1 NEST Maintenance to adjust the physical location of, or modify, the autoclave knife switches.

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68) UC96I7370 ALBRITTON LE PAD-1996-0044 OSR VIOLATION - TIME LIMIT Submit a change to CP2-SS-FS1032, in coordination with 05/07/1997 1

BETWEEN FIRE PATROLS the Operations organization, that modifies the Fire Patrol Log to require the front-line manager to verify i

each shift, by affixing his/her signature, that the Fire Patrol Log has been checked for accuracy and completeness. (Regulatory Commitment Stamp to be placed in procedure.)

69) UC96I7925 CONNE SR PAD-1996-0053 TSR VIOLATION - FAILURE TO Review CP3-CO-C01013 " Post Maintenance Testing," and 05/10/1997 1

l PERFORM REQUIRED SURVEI make changes, as necessary, in accordance with the i

Engineering procedure developed in Action Step 002 of PAD-1996-0053.

(Regulatory Comitment Stamp to be placed in procedure.)

70) UC96I5616 EVERETT RL PAD-1996-0030 UNREVIEWED SAFETY QUESTION.

Revise UE2-TO-EG1030 to list the requirement to issue 05/19/1997' 1

CRITICALITY ACCIDENT A an ESO when portable structures are added, placed, or '

moved.

(Regulatory Comitment Stamp to be placed in J

procedure.)

71) UC96I7925 COWNE SR PAD-1996-0053 TSR VIOLATION - FAILURE TO Review MAP-FMT-001, " Post Maintenance Testing," and 05/20/1997 1

I PERFORM REQUIRED SURVEI make changes, as necessary, in accordance with the

{

Engineering procedure developed in Action Step 002 of

{

PAD-1996-0053.

(Regulatory Committeent Stamp to be placed in procedure.)

72) UC96I5309 EVERETT RL PAD-1996-0027 FAILURE OF C-310 NORMETEX UF6 Complete installation of Normetex pump UF6 detection 05/23/1997 1

DETECTION SYSTEM system modifications to eliminate the 24 VDC power supply single point failures (as designed for ESO submitted in Action Step 001 and provided to Operations by Action Step 0"2).

73) UC96I6111 JANNE RL C40 CHEMICAL SAFETY MECHANICAL The mechanical integrity program for maintenance and 05/26/1997 1

+

INTEGRITY PROGRAM inspection PSM requirements will be implemented by May 26, 1997.

74) UC97IO9"'7 ALBRITION LE CM-3 CORRECTIVE ACTIONS FROM PORTS Corrective actions (taken and to be taken) described in 05/30/1997 1

NOV 96-08-03 E 96-11 PORTS response to NOV 96-08-03, 96-11-02, and 96-11-01 will be evaluated for applicability to PGDP through the USEC Operating Experience Review Program (UE2-QA-QA1037)

75) UC9612551 JANNE RL C16 FIRE PROTECTION PROCEDURES Those fire protection procedures identified for upgrade 06/01/1997 1

and not directly related to the commitments identified in the application will be upgraded.

i

76) UC9617599 EVERETT RL PAD-1996-0046 C-333 CAAS OSR VIOLATION System Engineer shall complete an analysis of the BOL 06/15/1997 1

assay machine to determine ths cause and recommend generic actions to improve the operational reliability

[

of these critical instruments.

Printed 02/27/1997 at 15:18:12 Page 8 h

Business Prioritization System REGULATORY COPMI1MENTS PGDP OPEN REGULATORY COMMI'INENTS Issue Regulatory Finding Issue Scheduled ID Engineer Number Title Description Date LEVEL

77) UC97I0038 ALBRITTON LE 96-07-05 OPERATIONS > 1.0% U-235 W/O System Engineering shall complete an analysis of the 06/15/1997 1

[

CAAS IN SERVICE BOL assay machine to determine the cause and recommend l

generic actions to improve the operational reliability of these critical systems.

78) UC95I1648 EVERETT RL PR-QA-95-0745 NONCOMPLIANCE WITH TRAINING Complete NUREG 1220 Assessment of Electrical 06/30/1997 1

(

PROCEDURES Maintenance Training Program.

79) UC9511648 EVERETF RL PR-CA-95-0745 NONCOMPLIANCE WITH TRAINING Complete NUREG 1220 assessment of Maintenance Mechanics 06/30/1997 1

PROCEDURES Training Program.

P

90) UC95I1648 EVERETT RL PR-CA-95-0745 NONCOMPLIANCE WITH TRAINING Complete NUREG 1220 assessment of Instrument and 06/30/1997 1

PROCEDURES Electronic Mechanics Training Program.

[

81) UC9511648 EVERETT RL PR-CA-95-0745 NONCOMPLIANCE WITH TRAINING Complete NUREG 1220 Assessment of Laboratory Technician 06/30/1997 1

i PROCEDURES Training Program.

?

L

82) UC95I1648 EVERETT RL PR-CA-95-0745 NONCOMPLIANCE WITH TRAINING Complete NUREG 1220 Assessment of Waste Management 06/30/1997 1

[

PROCEDURES Operator Training Program.

[

83) UC96I2558 JANNE RL -

C23 OPERATIONS PROGRAM Continuing training material and qualification 06/30/1997 1

requirement development will be completed and appropriate personnel trained and qualified for Cascade l

Operator, Chemical Operator, Operations

[

Manager / Supervisor, and Plant Shift Superintendent positions.

[ Functional area managers will provide review of materials developed and ensure individuals assigned to the positions are available and trained.)

-t

84) UC96I2559 JANNE RL C24 SYSTEMS APPROACH TO TRAINING Training programs will be developed and implemented 06/30/1997 1

based upon a systems approach to training for workers who are relied upon to operate, maintain, or modify structures, systems, and components identified as Q or AQ-NCS items. For those job classifications initially

[

identified under the Nuclear Safety Upgrade Project (i.e., cascade operators, chemical operators, electricians, instrument and electronic mechanics, maintenance mechanics, plant shift superintendents, laboratory technicians, waste management operators, and 6

t

85) UC96I2559 JANNE RL C24 SYSTEMS APPROACH TO TRAINING-For the additional job classifications not previously 06/30/1997 1

included in the Nuclear Safety Upgrade Project (i.e.,

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

program design have not been completed. The following actions will be completed:

  • Revise and validate the existing job task lists.
  • Design a curriculum that covers the job tasks selected for training.
86) UC96I2832 JANNE RL C38 HIGH-VOLUME AM.BIENT AIR In 1997, a comparison of the EDE calculated using 1996 06/30/1997 1

SAMPLERS release data and the EDE calculated using the 1996 data from the high-volume ambient air samplers will be performed. The comparison will be provided to the NRC.

Printed 02/27/1997 at 15:18:12 Page 9 L

~

+

1 Business Prioritization System REGULATORY COMMITMENTS PGDP OPEN REGULATORY COMMITMENTS Issue Regulatory Finding Issue-Scheduled ID Engineer Number Title Description Date LEVEL

87) UC9616117 JANNE RL C41 HEPA FILTER SYSTEMS TESTING HEPA filter systems will be evaluated, and those 06/30/1997 1

determined to be required will be periodically tested as described in SAR Section 5.3.2.10.

If necessary,

[

HEPA filter systems will be modified to allow the performance or passing of the required periodic testing i

or inspection. Documentation to justify reclassifying

[

(to non-HEPA filter system status) or retention of any HEPA filter systems will be developed by Systems 6

Engineering and approved by the managers of Radiation Protection and Nuclear Safety. The applicable

98) UC96I2552 JANNE RL C17 FIRE PROTECTION PREFIRE PLANS An analysis will be conducted to determine the maximum 06/30/1997 1

allowable combustible loadings within the process

~

buildings. The analysis will 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 t

control these specific occupancy areas. Some local

[

occupancy areas to be considered include burnable

,F

" anti-C* waste storage, lube oil in process reserves, waste storage, maintenance shops, and Stores. Building t

89) UC96I6542 EVERETT RL PAD-1936-0038 STEAM LEAK ON C-333-A In response to ESO submitted as Action Step 001, 06/30/1997 1

)

AUTOCLAVE 4 SOUTH VACUU provide (design and implement) a design modification to eliminate the entry of rust and dirt particles into the autoclave vacuum relic valves (e.g., eliminate source of foreign material entry into the vent line, source of corrosion products, etc.).

t

90) UC9618782 ALBRITTON LE PAD-1996-0066 STEAM LEAK AT C-337-A Maintenance will proceduralize the methodology for 07/01/1997

-1

}

AUTOCLAVE POSITION 1 WEST adjusting or modifying autoclave mechanical stops.

91) UC9618782 ALBRITTON LE PAD-1996-0066 STEAM LEAK AT C-337-A Operations will place on the preventive maintenance 07/01/1997 1

AttroCLAVE POSITION 1 WEST schedule, requirements to implement routine adjustments, or modifications of the autoclave knife switches for C-333-A/C-337-A autoclaves.

92) UC96I6129 JANNE RL C49 UF6 LEAK DETECTOR SENSITIVITY USEC will develop and complete a program to relate the 07/31/1997 1

TESTING response of UF6 leak detectors to manual test methods and to the detection of an actual UF6 leak. A field test method for the detectors will be developed by July 31, 1997.

93) UC96I2830 JANNE RL C36 SEISMIC CAPABILITY OF Modifications to increase the seismic capability for 07/31/1997 1

L BUIIDINGS C-331 AND C-335 floor and roof sections in Buildings C-331 and C-335 will be completed by July 31, 1997.

NOTE: Modifications include structural steel installation and shear block installation in support of the seismic capability. Does not include as-builts, final waste, disposal, demobilization, and project close-cut.

Printed 02/27/1997 at 15:18:12 Page 10 F

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s Busineso Prioritiration System REGULA7VRY COPNI7NENTS PGDP OPEN REGULATORY COtNI7NENTS q

Issue Regulatory Finding Issue Scheduled I

ID Engineer Number Title Description Date LEVEL

{

94) UC96I2221 JANNE RL CO2 UPDATE THE APPLICATION SAFETY By no later than August 17, 1997, USEC shall submit an 08/17/1997 1

ANALYSIS REPORT amendment to their Certification Application which i

includes:

a) Identification of all information, findings, and

[

recommendations which indicate differences between the

}

DOE site-wide SAR and the USEC Application for Certification.

t b) An evaluation of the effects of those differences on

[

95) UC96I2221 JANNE RL CO2 UPDATE THE APPLICATION SAFETY At the same time the Application amendment is due, USEC 08/17/1997 1

ANALYSIS REPORT shall also submit for NRC approval its proposed resolution of matters contained in the DOE-approved site-wide SAR not incorporated by USEC in its request for amendment of their Application for certification.

95) UC9612221 JANNE RL CO2 UPDATE THE APPLICATION SAFETY From September 30, 1995, until NRC approves the 08/17/1997 1

ANALYSIS REPORT submittals in Action Steps 3 and 4 changes made by

+

USEC in accordance with DOE's ROA requirement concerning Unreviewed Safety Question Deteminations (USQDs) or with 10 CFR 76.68 must be addressed either I

in the DOE SAR Upgrade results or in the amended SAR submitted by USEC based upon those results. The following will assure such changes are properly considered and addressed:

97) UC96I2221 JANNE RL' CO2 UPDATE THE APPLICATION SAFETY From September 30, 1995, until NRC approves the C8/17/1997 1

[

ANALYSIS REPORT submittals in Action Steps 3 and 4, changes made by USEC in accordance with DOE's ROA requirement 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 SAR t

submitted by USEC based upon those results. The f

following will assure such changes are properly considered and addressed:

-l t

96) UC96I2221 JANNE RL CO2 UPDATE THE APPLICATION SAFETY From September 30, 1995, until NRC approves the 08/17/1997 1

ANALYSIS REPORT submittals in Action Steps 3 and 4, changes made by

}

USEC in accordance with DOE's RCA requirement j

concerning Unreviewed Safety Question Determinations t

(USQDs) or with 10 CP1t 76.68 must be addressed either in the DOE SAR Upgrade results or in the amended SAR

[

submitted by USEC based upon those results. The j

following will assure such changes are properly f

considered and addressed:

99) UC96I2221 JANNE RL CO2 UPDATE THE APPLICATION SAFETY The update to the Application'SAR will also reflect 08/17/1997 1

ANALYSIS REPORT those commitments made by USEC to the NRC during the initial certification Application process as identified in the Application and the responses to NRC f

questions / comments.

-i f

100) UC96I2342 JANNE RL C03 AUTOCLAVE UFGRADES The UF6 detection systems for Zone 1 and Zone'4 [at 08/31/1997 1

C-360] will be modified such that upots detection of a UF6 release, multiple valves will be closed on the Printed 02/27/1997 at 15:18:12 Page 11 i

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Business Prioritization System t

REGULATORY COMMITMENTS PGDP OPEN REGULATORY COMMITMENTS Issue Regulatory Finding Issue Scheduled i-ID Engineer Number Title Description Date LEVEL t

transfer and/or sampling piping.

101) UC96I2342 JANNE RL CO3 AL N VE UPGRADES

' Add a low instrument air pressure switch to the 08/31/1997 1

autoclaves in C-360 to initiate containment upon loss of instrument air.

102) UC96I2557 JANNE RL C22 MAINTENANCE PROGRAM Develop and implement a maintenance history and trend 09/30/1997 1

f analysis program.

  • Develop a master equipment list for equipment i

critical to facility safety and production critical equipment.

103) UC96I2557 JANNE RL C22 MAINTENANCE PROGRAM Develop and implement a maintenance history and trend 09/30/1997 1

analysis program.

  • Establish information flow for corrective and preventive maintenance by documenting "as found*

conditions and field activities.

104) UC9612557 JANNE RL C22 MAINTENANCE PROGRAM

' Develop and implement a maintenance history and trend 09/30/1997 1

analysis program.

  • Perform data trending and preventive maintenance effectiveness analysis through the use of system engineering tasking.

105) UC96I7909 COWNE SR PAD-1996-0052 LEAK FROM STEAM CONTROL VALVE Develop and implement a maintenance history and trend 09/30/1997 1

ON C-337-A AUTOCLAVE analysis program. Perform data trending and preventive

[

maintenance effectiveness analysis through the use of 1

system engineering tasking.

I 106) UC96I2556 JANNE RL C21 PIANT CHANGES AND Identify and document all other AQ items, including 10/01/1997 1

CONFIGURATION MANAGEMENT system boundarieu and support systems required for performance of the intended safety function, to be

[

included in the scope of the Configuration Management Program.

.I 107) UC96I2556 JANNE RL C21 PIANT CHANGES AND Identify, document, and communicate definitive 10/01/1997 1

]

CONFIGURATION MANAGEMENT boundaries for the other AQ systems. Identify and a

^

document the design requirements for these AQ t

systems / items, including support system required for performance of the required safety function, for which the design requirements must be known.

108) UC96I8782 ALBRITTON LE PAD-1996-0066 STEAM LEAK AT C-337-A Operations will implement required preventive 10/30/1997 1

AUTOCIAVE POSITION 1 WEST maintained to ensure mechanical stops on autoclave knife switches are located or modified to ensure appropriate anti-rotation limits.

109) UC96I2342 JANNE RL C03 AUTOCLAVE UPGRADES The pressure monitoring instrumentation serving the 10/31/1997 1

autoclave safety systems and defense-in-dapth systems for C-333-A, C-337-A, and C-360 autoclaves will be replaced.

110) UC96I2342 JANNE RL C03 AUTOCLAVE UPGRADES Modify the controls for the autoclaves in C-360 to 10/31/1997 1

prevent them from being inadvertently opened when an i

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i Business Prioritiration System

. l REGULATORY COMMITMENTS PGDP OPEN REGULATORY COMMITMENTS

[

i Issue Regulatory Finding Issue Scheduled

[

ID Engineer Number Title Description Date LEVEL Autoclave High-Pressure Isolation System containment signal is present.

r 1

111) UC94I1399 CADWALIADER JG PAD-1994-0056 DISCOVERY OF CONTAMINATED Complete Site Characterization Program which will '

11/30/1997 1

)

ARTICLES IN C-611 include identification of legacy contaminated items for p

leased areas of the plant.

t 112) UC95IO414 STADLER D PAD-1994-0123 UNEXPECTED CONTAMINATION FOUND Complete Site Characterization Program which will 11/30/1997 1

IN EMPLJYEE'S DESK, include identification and correction of any legacy contaminated items for all areas of the plant.

113) UC96I0081 STACLER D PAD-1995-0100 CONTAMINATED TOOL FOUND IN Conduct special " sweep

  • surveys of site areas 11/30/1997 1

[

SUBCONTRACTOR TRAILER identified in the site characterization to ensure that legacy contaminated items that could be in l

nonradiological areas are found and corrected.

t 114) UC95I3019 ALBRIT'IVN 1.E PAD-1995-C052 ACIUATION OF A SAFETY SYSTEM Replace the C-310-A condenser high pressure process gas 11/30/1997 1

DURING OPERATION non-Monel/non-Inconel piping and welds with Monel pipe

.{

and welds at all three condenser locations.

1 115) UC96I1645 A1SRITTON LE PAD-1995-0141 C-310-A PGLD SAFETY SYSTEM Replace the C-310-A condenser high pressure process gas 11/30/1997 1

ACTUATION non-Monel/ non-Inconel piping and welds with Monel pipe i

and welds at all three condenser locations.

L 116) UC96I1757 ALBRITTON LE PAD-1995-0146 C-310-A UF6 DETECTION SAFETY h e future planned repairs on the Nos. 2 and 3 11/30/1997 1

SYSTEM ACTUATION condensers (PAD-1995-0052, Action Step 001) shall include supplemental helium leak testing.

I 117) UC9610947 ALBRITTON LE PAD-1995-0118 SAFETY SYSTEM ACTUATION DUE TO Replace the C-310-A condenser high pressure process gas 11/30/1997 1

UF6 RELEASE non-Monel/non-Inconel piping and welds with Monel pipe i

and welds at all three condenser locations.

l 118) UC9612545 JANNE RL C10 POSTING OF RADIOACTIVE Necessary radiological characterization a.nd reposting 11/30/1997 1

MATERIAL of leased areas within the PGDP site boundary will be

[

completed by November 30, 1997 I

119) UC96I2830 JANNE RL C36 SEISMIC CAPABILITY OF By December 1, 1997, USEC shall submit for NRC approval 12/01/1997 1

BUILDINGS C-331 AND C-335 an updated seismic risk analysis for the Paducah plant site. The analysis shall

  • Consider all available regional and site-specific data published by the U.S. Geological Survey.
  • Provide an estimate of the peak ground acceleration for a seismic event with a 250-year return period. If l

the estimate is greater than 0.15 g, then the return period for a 0.15-g event shall also be determined.

120) UC96I8581 ALBRITION LE PAD-1996-0062 TRESPASS ON GOVERNMENT Determine the number cf nonmotorized gates located in 12/1F/1997 1

PROPERTY the perimeter of the CAA and, in conjunction with Construction and Project Management, install replacement gates that are motorized in areas in which there is daily high-volume vehicular traffic.

6 i

i 121) UC9511648 EVERETT RL PR-QA-95-0745 NONCOMPLIANCE WITH TRAINING Complete NUREG 1220 assessment of Health Physics 12/30/1997 1

FROCEDURES Technicians Training Program.

Printed 02/27/1997 at 15:18:12 Page 13 j

h i

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i f

r Business Prioritization System REGULATORY COMMITMENTS i

PGDP OPEN REGULATORY COMMITMENTS k

Issue.

Regulatory Finding Issue Scheduled E

I ID Engineer Number Title Description Date LEVEL

+

l 122) UC90I0848 HOLT DC M.5 PROACTIVE ES&H TRAINING 05/03/95: Action scope revised during review of.

12/31/1997

-1 I

PROGRAM NOT ESTABLISMED special review items to correspond to regulatory requirement. Ltion is as follows:

Implementatior of Nuclear Safety Training for Waste Management Technicians should be completet by January 31, 1996.

Original Action - Begin implementation of Nuclear Safety Upgrade training by January 31, 1995.

k 123) UC9411014 JANNE RL F-01 PGDP PROCEDURE MANAGEMENT Complete all overdue Level 2, 3, and 4 AQ procedure 12/31/1997 1

[

periodic reviews.

l 124) UC94I1443 HOLT DC F-04 TRAINING Complete implementation phase of Nuclear Safety 12/31/1997 1

Upgrades project for training.

125) UC95I0045 ALBRITTON LE 94-14-12 DROCEDURE IMPLEMENTATION Complete the Procedure Upgrada Project. Any additional 12/31/1997 1

safe *y related procedures that are identified to be developed or upgraded will be added to the critical procedures list. This will allow the development or i

upgrading of nuclear safety related procedures, emergency response, safeguards and security, radiation protection, and en rironmental/ waste management t

activities affecting nuclear safety.

[

126) UC95I0094 ALBRITION LE 94-16-02 PROCEDURE REVIEW CYCLE REPORT OSR and FSAR requirements are being incorporated into 12/31/1997 1

I procedures through the Nuclear Safety Upgrades Program seneduled for completion by December 31, 1996.

127) UC9511648 COWNE SR PR QA-95-0745 NONCOMPLIANCE WITH TRAINING Complete NUREG 1220 assessment of Cascade Coordinator 12/31/1997 1

l I

PROCEDURES Training. Program.

.j 128) UC9511648 COWNE SR PR-CA-95-0745 NONCOMPLIANCE WITH TRAINING Complete NUREG 1220 assessment of Nuclear Criticality 12/31/1997 1

PROCEDURES Safety Engineer / Specialist Training Program.

I 129) UC95I1648 STADLER D PR-QA-95-0745 NONCOMPLIANCE WITH TRAINING Complete NUREG 1220 Assessment of System Engineer 12/31/1997 1

PROCEDURES Training Program.

I 130) UC96I2554 JANNE RL C19 MANAGEMENT CONTROLS The INJS position descriptions will again be reviewed 12/31/1997 1

and revised, if necessary, with the completien of the procedures upgrade effort.

131) UC96I2556 JANNE RL C21 PLANT CHANGES AND Develop procedures required to implement an assessent 12/31/1997 1

CONFIGURATION MANAGEMENT program to systematically evaluate the development and effective implementation of the Configuration i

Management Program elements and related processes.

l r

132) UC96I2556 JANNE RL C21 PLANT CHANGES AND Implement a training program for plant personnel relied 12/31/1997 1

. CONFIGURATION MANAGEMENT upon to operate, maintain, or modify the plant.

[

Include initial training on improved or newly developed programs and procedures identified as required to support the Configuration Management Program objectives.

Printed 02/27/1997 at 15:18:12 Page 14 i

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BusinesO Prioritization Syctem i

REGULRTORY COPMI7MENTS PGDP OPEN REGULATCRY COf9tI7MENTS I

Issue Regulatory Finding Issue Scheduled ID Engineer Number Title Description Date LEVEL 1

i 133) UC9EI2558 JANNE RL C23 OPERATIONS PROGRAM Procedures addressing the operations program elements 12/31/1997 1

discussed in Section 6.5 of the Safety Analysis Report g

will be developed or revised [during the NSR procedures i

upgrade program).

[runctional area managers will provide SME review support and ensure individuals i

assigned to positions associated with affected areas t

are trained.]

i 134) UC96I2558 JANNE RL C23 OPERATIONS PROGRAM Associated initial training materials will be 12/31/1997 1

developed, and appropriate personnel will receive initial training. [ Functional area managers will provide personnel the necessary time to attend training j

j sessions.]

=

135) UC9612558 JANNE RL C23 OPERATIONS PROGRAM Continuing training material will be completed and 12/31/1997 1

appropriate personnel trained and qualified for Cascade Coordinator position by the Training Organization.

136) UC96I2559 JANNE RL C24 SYSTEMS APPROACH TO TRAINING Training for those holding these additional job 12/31/1997 1

i classifications at the time the program is implemented will be completed.

[ Functional area managers will provide and make available the personnel and ensure l

they are qualified for the position trained.)

I 137) UC96I2561 JANNE RL C27 PROCEDURES PROGRAM Implement new or updated Level 2, 3, and 4 AQ and NS 12/31/1997 1

procedures [for the Training and Procedures Organization], including training, to fully implement the Quality Assurance Program or other activities identified in the application I

i 138) UC96I2573 JANNE RL C35 DEPLETED URANIUM MANAGEMENT For all USEC depleted uranium cylinders that were 12/31/1997 1

l PLAN placed in storage prior to implementation of the documented baseline inspection procedure noted in

[

Action Step 2, perform a baseline inspection in

[

accordance with that procedure.

[

139) UC96I2831 JANNE RL C37 ENVIRONMENTAL TRENDING The required procedures will be developed and 12/31/1997 1

PROCEDURES implemented using the process described in Application Section 6.11.

140) UC9612561 JANNE RL C27 PROCEDURES FROGRAM

' Implement new or updated Level 2, 3, and 4 AQ and NS 12/31/1997 1

procedures (for the Engineering Organization),

j including training, to fully implement the Quality Assurance Program or other activities identified in the

(

application.

t i

141) UC96I2561 JANNE RL C27 PRCCEDURES PROGRAM Implement new or updated Level 2, 3, and 4 NS 12/31/1997 1

procedures (for the work Control Organization),

)

including training, to fully implement the Quality Assurance Program or other activities identified in the application.

142) UC96I2561 JANNE RL C27 PROCEDURES PROGRAM Implement new or updated Level 2, 3, and 4 AQ and NS 12/31/1997 1

procedures [for the Plant Shift Superintendents Printed 02/27/1997 at 15:18:12 Page 15 i

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Busineos Prioritization SyQtem REGULATORY COMMITMENTS 3

PGDP OPEN REGULATORY COttiITMENTS Issue Regulatory Finding Issue Scheduled ID Engineer Number Title Description Date LEVEL Organization], including training, to fully implement.

l the Quality Assurance Program or other activities identified in the application.

143) UC96I2561 JANNE RL C27 PROCEDURES PROGRAM Implement new or updated Level 2, 3, and 4 AQ and NS 12/31/1997 1

[

procedures (for the Production Support Organization],

including training, to fully implement the Quality

}

Assurance Program or other activities identified in the application.

144) UC96I2561 JANNE RL

- C2 7 PROCEDURES PROGRAM Implemmt new or updated Level 2, 3, and 4 AQ and NS 12/31/1997 1

s procedures [for the Fire Services Department],

including training, to fully implement the quality l

Assurance Program or other activities identified in the application.

t 145) UC96I2561 JANNE RL C27 PROCEDURES PROGRAM Implement new or updated Level 2, 3, and 4 AQ and NS 12/31/1997 1

procedures [for the Materials Management Organizationi, inclading training, to fully implement the Quality Assurance Program or other activities identified in the application.

146) UC96I2561 JANNE RL C27 PROCEDURES PROGRAM Implement new or updated Level 2, 3, and 4 AQ and NS 12/31/1997 1

procedures [for the Operations Organization), including training, to fully implement the Quality Assurance Program and other activities identified in the application.

r 147) UC96I.2561 JANNE RL C27 PROCEDURES PROGRAM Implement new or updated Level 2, 3, and 4 AQ and NS 12/31/1997 1

procedures [for the Emrironmental Safety and Health Organization], including training, to fully implement f

the Quality Assurance Program or other activities identified in the application.

l L

148) UC96I2561 JANNE RL C27 PROCEDURES PROGRAM Implement new or updated Level 2, 3, and 4 AQ and NS 12/31/1997 1

procedures (for the Nuclear Regulatory Af fairs Organization], including training, to fully implement

[

the Quality Assurance Program or other activities identified in the application.

t 149) UC96I2561 JANNE RL C27 PROCEDURES PROGRAM Implement new or updated level 2, 3, and 4 NS 12/31/1997 1

[

procedures [for the Maintenance Organization],

including training, to fully implement the Quality Assurance Program or other activities identified in the j

application.

F 150) UC9615390 COWNE SR CM-01 PROCEDURE ADEQUACY AND USE USEC will complete the upgrade of site procedures as 12/31/1997 1

defined in the Procedures Upgrade Program consistent with the schedule shown in the Compliance Plan.

151) UC9615390 JANNE RL 04-01 PROCEDURE ADEQUACY AND USE As indicated in the Compliance Plan, organizational 12/31/1997 1

roles and responsibilities provided in Section 6.1 of the Application will be flowed down to connitted position descriptions; and position descriptions will Printed 02/27/1997 at 15:18:12 Page 16 f

l

__-_- _ ~,.

Business Prioritizar. ion System REGULATORY COMMITMENTS PGDP OPEN REGUIATORY COMMITMENTS Issue Regulatory Finding Issue Scheduled ID Engineer Number Title Description Date LEVEL be reviewed and revised. if necessary, with the completion of the procedures upgrade effort.

152) UC9612565 JANN3 RL C29 QUALITY ASSURANCE PR93 RAM Develop and implement procedures, including personnel 12/31/1997 1

IMPLEMENTATION training, that define handling and storage activities i'

for other AQ items and services.

153) UC96I2561 JANNE RL C27 PROCEDURES PROGRAM Complete all overdue Level 2, 3 and 4 AQ procedure 12/31/1997 1

periodic reviews.

154) UC96I6124 JANNE RL C44 OPERATIONAL / SAFETY SYSTEM TRIP A review of system designs will be performed where 12/31/1997 1

REDUNDANCY operational trips and alarms coincide with the setpoints for safety system actuation based on the same I

monitored parameter and the same equipment actuated.

Where redundant operational and safety system actuations exist, corrective action will be identified

)

that may include justification either for the i

redundancy or system modifications to eliminate the

[

redundancy. The results of this review will be submitted to the NRC for review and approval by 155) UC9616082 ALBRITTON LE 96-03-02 PLANT PROCEDURES NOT The required review of Procedure CE-31 will occur as 12/31/1997 1

IDENTIFIED AS SAFETY-REIATED part of the planned revision discussed in Example 1 to this NOV.

Periodic reviews for overdue Level 2, 3, and i

4 AQ procedures will be completed by 12/31/97 in accordance with DOE Compliance Plan (DOE /ORO-2026) r Issue C27.

i 156) UC96I2561 JANNE RL C27 PROCEDURES PROGRAM Implement new or updated Level 2, 3, and 4 AQ and NS 12/31/1997 1

L procedures [for the Facility Maintenance Department].

including training, to fully implement the Quality Assurance Program or other activities identified in the application.

157) UC96I2554 JANNE RL C19 MANAGEMENT CONTROLS The USEC position descriptions will again be reviewed 12/31/1997 1

and revised, if necessary, with the completion of the procedures upgrade effort.

l L

156) UC96I2554 JANNE RL C19 MANAGEMENT CONTROLS Quality Assurance Program requirements and applicable 12/31/1997 1

NRC requirements [for AQ SSCs) will be flowed down to policies and procedures that will be approved and implemented at USEC Headquarters and PGDP in accordance with the plan of action and schedule described in t

Compliance Plan Issue C27,

  • Procedures Program.*

159) UC9618581 ALBRITTON LE PAD-1996-0062 TRESPASS ON GOVERNMENT Perform an end-point assessment to determine if the 01/07/1998 1

PROPERTY corrective actions have been effective in eliminating the identified problems. The end-point assessment shall be presented to the Management Assessment and Analysis Team (MAAT).

i 160) UC94TOS69 ALBRITTON LE PAD-1993-0026 CASCADE EQUIPMENT FAILURE Set torque level on compressor bearing cap bolts at 01/31/1998 1

[

PGDP and verify the proper grade bolts and washers are being used. This work will be done as cells come down.

i Printed 02/27/1997 at 15:19:12 Page 17 r

Business Prioritization System REGULA1 CRY COPHI1MENTS PGDP OPEN REGUIATORY COMMITMENTS Issue Regulatory Finding Issue Scheduled ID

' Engineer Number Title Description Date LEVEL 161) UC94IO569 AIERITION L3 PAD-1993-iO27 CASCADE EQUIPMENT FAILURE Change the accelerometers to geophones at PGDP because 01/31/1998 1

geophones have proven to be more reliable. This process was accelerated after the incident and now includes all of the *00* and 10 out of 120 *000* cells.

This work is being done as cells come down.-

162) UC96I2813 CONNE SR PAD-1996-0013 UF6 RELEASE GREATER THAN 5 Incorporate torquing values into appropriate 04/01/1998 1

GRAMS C-337 Maintenance procedures involving fasteners for pressure boundary components of uranium process systems which are designated as *AQ* systems.

(Regulatory Commitment Stamp to be placed in procedures.)

163) UC9512021 ALBRITTON LE PAD-1995-0032 PROCESS GAS LEAK DETECTION Assure old reset switches are replaced and reset switch C6/30/1998 1

FAILURE status indicating lights are installed on high-voltage PGID systems in cascade areas currently not scheduled for above-atmospheric operation but which have a potential to be scheduled for above-atmospheric operation.

164) UC96I2557 JANNE RL C22 MA NTENANCE PROGRAM Upgrade the current maintenance work control process to 06/30/1998 1

provide the committed level of planning and work package development for other AQ items.

  • Develop work package specifications.
  • Develop guidance for integration of configuration management-.
  • Define and implement other AQ items identification and control within the maintenance program.
  • Initiate revised work control performance indicators.

165) UC96I2557 JANNE RL C22 MAINTENANCE PROGRAM Revise the measuring and test equipment (M&TE) and 06/30/1998 1

process equipment calibration programs for other AQ SSCs.

  • Identify all other AQ M&TE.
  • Track the use of calibration standards and verify that all M&TE used for the calibration of other AQ SSCs is controlled and traceable to national standards.
  • Develop and implement procedures that define and control the overall M&TE program.

166) UC96I2557 JANNE RL C22 MAINITNANCE PROGRAM Identify the procedural deficiencies for performing 06/30/1998 1

corrective maintenance, preventive maintenance, equipment calibration, or surveillance testing for other AQ SSCs; and develop a composite listing of the procedures requiring revision, development, or conversion.

167) UC96I2557 JANNE RL C22 MAINTENANCE PROGRAM Revise, develop, or convert corrective maintenance.

06/30/1998 1

preventive naintenance, instrument calibration, and surveillance test procedures for other AQ SSCs.

168) UC96I2557 JANNE RL C22 MAINTENANCE PROGRAM Develop training materials for the work control, 06/30/1998 1

surveillance testing, instrument calibration, and corrective and preventive maintenance procedures for Printed 02/27/1997 at 15:18:12 Page 18

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REGULATORY COMMITMENTS PGDP OPEN REGULATORY COMMITMENTS Issue Regulatory Finding Issue Scheduled

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'ID Engineer Number Title Description Date LEVEL other AQ SSCs and provide the associated training of appropriate personnel.

169) UC96I2560 JANNE RL C26 RECORDS MANAGEMENT AND Records being maintained in the divisions will not be 06/30/1998 1

DOCUMENT CONTROL PROGRAM turned over to the D&R Group innediately but will be retained by the responsible division until the D&R Group can process them.

Pre-existing records will be

[

turned over and incorporated into the records j

management system by June 30, 1998.

[

170) UC9612560 JANNE PL C26 RECORDS MANAGEMENT AND Documents within the scope of the document e-strol 06/30/1998 1

DOCUMENT CONTROL PROGRAM program, according to the application, will be identified. Documents being maintained in the divisions will not be turned over to the D&R Group but will be retained by the responsible division until the r

D&R Group can process them.

Pre-existing documents

[

will be turned over and incorporated into the document s

control system by June 30, 1998.

I 1711 UC96I2560 JANNE RL C26 RECORDS MANAGEMENT AND Computer codes and test result data used to directly or 06/30/1998 1

DOCUMENT CONTROL PROGRAM indirectly support the PGDP process systems will be I

submitted to the D&R Group in accordance with the turnover schedule identified in Action Step ID.

172) UC9615131 JANNE RL PAD-1996-0025 CRITICALITY ACCIDENT ALARM Permanent criticality accident alarm detector clusters 06/30/1998 1

SYSTEM UNREVIEWED SAFET will be installed, relocated, and/or reconditioned in

[

Building C-710 to replace the existing portable detectors in Building C-710 (ESO 295820).

I 173) UC96I2543 JANNE RL CCS EXCEPTIONS FOR CRITICALITY Permanent criticality accident alarm detector clusters 06/30/1998 1

ACCIDENT ALARM SYSTEM will be installed, relocated, and/or reconditioned in p

Building C-710 to replace the existing portable detectors in Building C-710.

i 174) UC96I2559 JANNE RL C24 SYSTEMS APPROACH TO TRAINING Training programs for the above job classifications 06/30/1998 1

h list (those jobs listed in Action Steps 1 and 2 of this

[

issue], with respect to AQ activities, will be developed and implemented following completion of v

8 identification of AQ ltems and associated procedures.

175) UC96I2560 JANNE RL C26 RECORDS MAL'\\GEMENT AND Records being maintained in the organizations will be 06/30/1998 1

i DOCUMENT CONTROL PROGRAM turned over to the D&R Group in accordance with the

['

records management turnover schedule identified in Action Step 1D of this issue. Pre-existing records required to be maintained under the USEC Quality i

Assurance Program will be turned over and incorporated into the revised records management system in accordance with the approved records management turnover schedule. After the turnover of an I

organization's records to Records Management, the 176) UC9615310 STADLER D PAD-1996-0028 FAILURE OF C-310 PROCESS GAS Complete activities described in the Project Change 06/30/1998 1

LEAK DETECTION SYSTEM Order for ESO 291460.

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Busineos Prioritization System REGULATORY COW 1ITMENTS PGDP OPEN REGULATORY COMMI7MENTS

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Issue Regulatory Finding Issue Scheduled ID Engineer Number Title Description Date LEVEL 177) UC96I4456 (ENNE SR Q1-14 CRITICALITY ACCIDENT ALARM Perform the engineering and install the necessary plant 06/30/1998 1

J SYSTEM INAUDIBILITY modifications to ensure that the CAAS alarm horns are capable of being heard throughout the affected area of C-710.

178) UC96I6129 JANNE RL C49 UF6 LEAK DETECTOR SENSITIVITY USEC will develop and complete a program to relate the 07/31/1998 1

TESTING response of UF6 leak detectors to manual test methods i

and to the detection of an actual UF6 leak. The initial periodic testing of the detectors will be completed by July 31, 1998.

179) UC96I4456 COWNE SR CM-14 CRITICALITY ACCIDENT ALARM Perfem the engineering and install the necessary plant 12/15/1998 1

l SYSTEM INAUDIBILITY modifications to ensure that the CAAS alarin horns are capable of being heard throughout the af fected areas of I

C-331, C-335, and C-337.

180) UC9616126 JANNE RL C46 CAA3 - HORN AUDIBILITY Plant modifications will be initiated to ensure that 12/15/1998 1

the CAAS alam horns are capable of being heard I

4 throughout the affected ares of process buildings. The f

modifications will be complete by December 15, 1998.

181) UC9616130 JANNE RL C50 CRITICALITY ACCIDENT ALARMS Evacuation horns (for those unalarmed buildings where 12/15/1998 1

FOR NEARBY BUILDINGS nearby CAAS horns cannot be adequately heard) and/or l

lights will be installed in the unalarmed buildings

}

located within the evacuation area of CAAS-clustered buildings, or the unalarmed buildings will be removed I

from the evacuation area. These horns and/or lights p

will be activated from a nearby clustered building or other alarmed building. Unalarmed facilities that have been identified as of June 19, 1996, will be modified 5

l with the required horns and/or lights, as appropriate, 182) UC9615616 EVERETT RL PAD-1996-0030 UNREVIEWED SAFETY QUESTION, Evscuation horns will ba installed in the unalarmed 12/15/1998 1

CRITICALITY ACCIDENT A buildings located within the evacuation area of CAAS clustered buildings if nearby CAAS horns cannot be i

heard, t

t 183) UC96I1301 EVERETT RL PAD-1995-0135 CASCADE R-114 Ih 6 E FROM Document the analysis for the failure mode of the 11/25/2000 1

C-337-6.3 C-337, Unit 6, Cell 3; determine if any additional corrective measures are needed; and initiate as appropriate.

184) UC96I2561 JANNE RL C27 PROCEDURES PROGRAM

. The PORC will review all procedures designated as 12/31/2001 1

in-hand and procedures that involve liquid UF6 handling activities within a 5-year period after the date that L

the NRC assumes regulatory authority for PGDP.

This commitment pertains only to those procedures [as i

required by TSR 3.9.2] which will not otherwise be reviewed by the PORC (as required by Section 6.11.4.1),

or by a PORC subcommittee, before the expiration of the 5-year period. Procedures in this scope have been, and will continue to be, reviewed by a PORC subcommittee, Printed 02/27/1997 at 15:18:12 Page 20 f

Busineas Prioritization System REGULATORY COMMITMENTS PGDP OPEN REGULATORY COMMITMENTS Issue Regulatory Finding Issue Scheduled ID Engineer' Number Title Description Date LEVEL

1) UC9610053 EVERETT RL CM-14 JCO -- REVISION TO OSR The systems identified to be out of compliance will be 2

e KY/D-4151 recalibrated prior to starting a new cylinder heating cycle.

1

2) UC96I2830 JANNE RL C36 SEISMIC CAPABILITY OF Documentation prepared for the design of the 2

BUILDINGS C-331 AND C-335 modification and other relevant information concerning implementa* ion will be provided M the NRC, upon issue, for information and review.

NOTE: Documentation and other relevant information includes:

Design drawings for modification Design specifications for modification

3) UC96I8694 COWNE SR CM-24 USQ INVOLVING C-360 Quick exhaust valves wil.1 be added between the solenoid 2

CONTAINMEN'" VALVE valve and block valve actuator for all the affected valves on each autoclave. The quick exhaust valves will allow the proper exhaust capacity to assu.4 the block valves close within 10 seconds. The modification will be made to five valves on each autoclave to ensure that the 10-second criteria is met.

4) UC9614601 WELLS R I-01 SHARED SYS. AND CONTINUITY OF Revise or issue procedure (s) to establish a process 2

ESSENTIAL SERVICES

. whereby USEC and DOE will work together to ensure that interruptions to services necessary for the safety, safeguards, and security of the GDPs are minimized and that C red systems remain operable. (Regulatory Commi M.i: Stamp to be placed in procedure.)

5) UC96I4602 WELLS R I-02 CONTROL OF WORK ACTIVITIES Revise or issue procedure (s) to establish a process 2

whereby, prior to conducting work in nonleased spaces, USEC (including their contractors / subcontractors) will obtain DOE's approval.

(Regulatory Commitment Stamp to be placed in procedure.)

6) UC96I4603 WELLS R I-03A PLANT CHANGES Revise the CM procedure (UE2-IO-CF1032) to specify 2

application of configuration management to all plant SSCs applying the elements of the CAP based on importance of safety.

(Regulatory Commitment Stamp to be placed in procedure.)

7) UC9614604 WELLS R I-03B PLANT CHANOES Establish procedural controls to ensure that USEC and 2

i DOE are promptly notified and appropriate approvals obtained prior to conducting activities that affect the design, construction, operation, or maintenance of facilities and systems on their respective portions of.

the GDP sites.

(Regulatory Commitment Stamp to be placed in procedure.)

8) UC96I7370 STADLER D PAD-1996-0044 OSR VIOLATION - TIME LIMIT On receipt of approval of the TSR change in Action Step 2

BETWEEN FIRE PATROLS 003 of this issue, change CP2-SS-FS1032, in conjunction with the Operations organization, that defines the hourly interval designation, interval between consecutive fire monitoring checks, and the maximum interval between consecutive fire monitoring checks.

Printed 02/27/1997 at 15:19:47 Page 1 i

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Business Prioritization System REGUIATORY COPMI1NENTS PGDP CPEN REGULATORY COPHITENTS Issue Regulatory Finding Issue Scheduled ID Engineer Number Title Description Date LEVEL (Regulatory Commitment Stamp to be placed in procedure.)

9) UC97ICO31 STADLER DC 96-07-01 FAILURE TO MEET FASSIVE FIRE Following receipt of approval of the TSR change related

'2 WATCH REQUIREMENTS to hourly surveillance interval definition, a change will be incorporated in CP2-SS-FS1032 that defines the hourly interval designation on fire watch checks.

Completion will be scheduled within 30 working days of receipt of TSR approval. (Regulatory Comitment Stamp '

to be placed in procedure.)

NOTE: This action is designated as a Priority 2 comitment. Upon receipt of approval of the TSR

10) UC9612834 JANNE RL C39 DECOMMISSIONING FUNDING The following executed documents required to assure 2

FROGRAM adequate funding for USEC's portion of PGDP's decontamination and decommissioning costs will be submitted to the NRC at the time USEC privatization occurs:

  • An executed sinking fund arrangement.
  • A standby trust agreement. and/or
  • A payment surety bond
11) VC9616SB0 EVERETT RL CM-23 NUMAN FACIORS PROJECT Develop and implement a program to ensure that human 2

f actors evaluations of those steps identified as -

necessary to complete operator actions to prevent or mitigate identified accident scenarios on a three-year periodic schedule.

1.

Develop the procedural basis or BPS items for accomplishment of the program and associated checklists.

Printed 02/27/1997 at 15:19:47 Page 2

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_ _ _ _ _.. _ - _ - _ _ _ _ to GDP 97-0023 Portsmouth Gaseous Diffusion Plant Open Regulatory Commitments

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Business Prioritization System REGULATORT COMMIMEErrS PORTS OPEN R N TORY COMMITMENTS

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Issue Regulatory Finding Issue Scheduled l

ID Engineer Number Title Description Date LEVEI.

1) UX9612946 BLACKSTON 70-7002/09 NUCLEAR CRITICALITY SAFETY complete verification program (of the roughly 150 02/28/1997 1

i APPROVAL IMPLEMENTATION procedures and 150 postings) for all current fissile material operations prior to NRC assuming regulatory

[

oversight of PORTS for NCSAs that need to flow into Technical Safety Requirements (Reference I2FXO330/19.A

[MSU Project]).

f

[ DOE Tracker # CPI-POA-19.la]

[

I

2) UX96I3233 BLACKSTON C 70-7002/23 FLANT CHANGES E CONFIGURATION Identify and document all Q and AQ-NCS items including 02/28/1997 1

MANAGEMENT system boundaries and support systems required for j

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

(RefereMe ERFX0920/X23.1A [NSU Project])

[ DOE Tracker # CPI-POA-X23.lal/23.la2]

j

3) U19613233 BLACKSMI C 70-7002/23 FLANT CHANGES E CONFIGURATION Review all Nuclear Criticality Safety Approvals & NCSEs 02/28/1997 1

MANAGEMENT to identify AQ-NCS items, to identify and track the designated design requirements, system boundaries, including support systems required for performance of i

this intended safety functions and to verify full implementation of these requirements. To the extent completed, this information will be maintained and made available to the NRC. before regulatory jurisdiction, e

for planned inspection activities.

I

4) UX96I3342 BLACKSTON C 70-7002/24 MAINTENANCE FROGRAM Revise, develop, or convert corrective maintenance, 02/28/1997 1

preventive maintenance, calibration, and surveillance i

test procedures for AQ-NCS items. (Reference

'[

B2PX1150/X24.9B [NSU Project])

[ DOE Tracker # CPI-POA-X24.8a]

l

5) UX96I3352 BLACKSTON C 70-7002/30 FROCEDURES FROGRAM Implement new or updated procedures (including required 02/28/1997 1

training) to fully implement the Quality Assurance

[

Program or other activities identified in the p

Application in accordance with Level 2, 3, and 4 AQ-NCS L

(unless covered in Action si procedures (Reference -

[

B2PX1550/X30.9B [NSU Project])

[ DOE Tracker # CPI-POA-130.9b]

)

i

6) UX9613342 BLACKSTON C 70-7002/24 MAINTENANCE PROGRAM Develop training materials for the work control.

02/28/1997 1

surveillance testing, inst ument calibration, and j

corrective and preventive maintenance procedures for AQ-NCS items and provide the associated training of i

appropriate personnel. (Reference B2PX1170/X24.10B [NSU l

Project]

[ DOE Tracker 8 CPI-POA-X24.9a]

y t

7) UX97I2637 CADE MD PTS-ER-97-03 SAFETY SYSTEM ACTUATION.

Provide Event Report Response 97-03 to the Regulator.

02/28/1997 1

X-343 AUTOCLAVE #1

8) UX9619652 BCKSHER KP PTS-96-073 VIOLATION OF AN OPERATIONAL Operations will develop an administrative procedure for 03/01/1997 1

[

S*.FETY REQUIREMENT (OS preparation of written Cascade Operating Instructions that require non-routine changes in plant conditions.

The procedure will verify the planned operation is l

t Printed 02/27/1997 at 15:13:15 Page 1

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Business Prioritiration System REGULATORY COMMIMENTS

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PORTS OPEN REGUIATORY COMMITMENTS l

Issue Regulatory Finding Issue Scheduled ID Engineer Number Title Description Date LEVEL

?

governed by existing procedures, and that the i

procedures are linked and referenced to ensure all safety precautions and limitations have been met.

9) UI96I2902 BIACKSTON C 70-7002/01 TRANSITION FROM DOE REGUIATION To ensure that USEC commitments to DOE are not lost in 03/03/1997 1

TO NRC REGUIATION the transition of regulatory authority USEC will provide to NRC a listing of all open USEC commitments l

made in response to regulatory oversight Inspections, modifications to the ROA, or other regulatory oversight activities on the day that NRC assumes regulatory

[

oversight responsibility for PORTS. The listing will j

include references to the original sources of the commitments, such as regulatory oversight inspection t

reports or correspondence with the DOE Regulatory.

l

10) UX96I2902 BLACKSTON C 70-7002/01 TRAN9ITION FROM DOE REGULATION Complete the transition from OSRs to TSRs within 120 03/03/1997 1

TO NRC REGUIATION days from the date of the NRC certification decision.

[ DOE tracker # CPI-JCO-X1.2]

11) UI9613233 BLACKSTON C 70-7002/23 FIANT CHANGES & CONFIGURATION Develop the flowdown of commitments from the TSR; the 03/03/1997 1

MANAGEMENT SAR, & other plans and programs to procedures and training in accordance with the POA and schedule for Issue 30.

(DOE Tracker # CPI-POA-X23.lb]

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12) UX9613351 BLACKSTON C 70-7002/28 EVENT INVESTIGATIONS AND Implement both procedures with effective dates of the 03/03/1997 1

REPORTING PROGRAM date NRC assemes regulatory oversight at PORTS.

(Reference FX1370/X28.1B [NSU Project])

(DOE Tracker # CPI-POA-X28.1c] E DOE Tracker l

  1. CPI-JCO-X28.1]
13) UK9613352 BLACKSTON C 70-7002/30 PROCEDURES PROGRAM Incorporate action statements and operating limits frem 03/03/1997 1

[

the Technical Safety Requirements into operational procedures by the date that NRC assumes regulatory authority for PORTS.

(Reference B2PX1530/X30.8 {N3U Project])

[

[ DOE Tracker # CPI-POA-X30.8]

14) UX96I2902 BLACKSTON C 70-7002/01 TRANSITION FRCM DOE REGUIATION Some of the activities necessary for USEC to implement 03/03/1997 1

TO NRC REGULATION this phased tnnsition are described in this Compliance Plan. USEC is currently developing additional detailed 6

plans and schedules to implement the phased transition.

Consistent with RCA requirements 3.2.2.2, 3.3.2.6, and 3.4.2.3, DOE will review all proposed changes from OSRs to TSRs, and USEC will not implement any such changes without the consent and written approval of the DOE Regulatory Oversight Manager.

15) UK96I2946 BLACKSTON C 70-7002/09 NUCLEAR CRITICALITY SAFETY If a new or revised NCSE identified the need for 03/03/1997 1

APPROVAL IMPLEMENTATION modifications to the existing plant configuraticn, affected activities will be curtailed and will not be restarted until either--(1) the plant configuration is modified or (2) the activity is modified so that it can be performed safety in the current configuration. If Printed 02/27/1997 at 15:13:15 Page 2 s

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Business Prioritization System REGUIATORY COPNITMENTS PORTS OPEN REOCIATORY CCNMITMENTS Issue Regulatory Finding Issue Scheduled ID Engineer Number Title Description Date LEVEL the plant configuration or activity is modified, then PORC will review the proposed modification prior to its resumption to verify that the activity, as modified, can be perforned safely.

16) UX97I2639 CADE MD PTS-ER-97-04 SAFETY SYSTEM ACW ATION, X-343 Provide Event Report Response 97-04 to the Regulator.

03/03/1997 1

AITTOCLAVE #1

17) UX9712639 CADE MD PTS-ER-97-05 SAFETY SYSTEM ACTUATION, X-343 Provide Event Report Response 97-05 to the Regulator 03/03/1997

'1 AUTOCALVE #2

19) UX971264J BOWSHER KP PTS-ER-97-06 SAFETY SYS ACIUATN-CADPS SMOIE Provide Event Report Response 97-06 to the Regulator.

03/06/1997 1

DETECTOR AT 33-3-7

19) UX9712765 BOWSHER KP PTS-ER-97-07 SAFETY SYSTEM ACIUATION, CP.DPS Provide Event Report Response 97-07 to the Regulator.

03/07/1997 1

SMOKE De.u.twa

20) UX9615619 BLACKSTON C 01 HEU ORE SCHEDULE Complete CRR X-705 Cylinder Cleaning Facility Phase II 03/14/1997 1

- West Annex (without cylindar cutting station and includes 5" cylinder cleaning).

21) UX96I9167 CADE MD PTS-96-069 FOUR (4) EVENTS PREVIOUSLY Operations to incorporate applicable recommendations 03/15/1997 1

IDENTIFIED AS OFF-NORMA from Engineering into affected operating procedures.

22) UX96I9167 CADE MD PTS-96-069 FOUR (4) EVENTS PREVIOUSLY Maintenance to incorporate (as-left and as-found) 03/15/1997 1

IDENTIFIED AS OFF-NORMA information to be collected during 0-ring maintenance into procedures.

23) UX9710063 WALDER A PTS-96-075 ACTUATION OF CASCADE AITTOMATIC Operations to perform leak testing of Unit 4. G-17 03/15/1997 1

DATA PROCESSING (CA buffer system and identify leaking components and potentfal UF6 deposits. Maintenance Service Request (MSR) will be entered as needed for repairs.

24) UK97I1669 RALEIGH JJ SSR-96-08-01 PROCEDURE DEFICIENCIES REIATED A random survey of Caution Tags currently in use at 03/15/1997 1

TO CYLINDER RAILCAR PORTS will be conducted to determine: 1) if Caution Tags requirements are being met; and 2) if the use of a Caution Tag is the appropriate administrative control.

This survey will be completed by March 15, 1997.

Problem reports will be generated to address discrepancies identified as a result of this survey.

25) UX97I2766 BOWSHER KP PTS-ER-97-08 SAFETY SYSTEM ACTUATION, CADPS Provide Event Report Response 97-08 to the Regulator.

03/20/1997 1

SMOKE DETEC1VR

26) UX9613132 WALDER A PTS-96-031 ACIUATION OF CADP SMOKE Reliability Engineering to observe the maintenance of 03/30/1997 1

DETECTOR (SAFETY SYSTEM)

X-31-4-3, provide an engineering root cause analysis of the event and develop corrective actions based on the results of the analysis.

27) UX96IS019 CADE MD PTS-96-052 SAFETY SYSTEM ACTUATION (CADP Reliability Engineering to evaluate the failure 03/30/1997 i

SMOKE DETECTOR),

mechanism for the failed expansion joint and determine any needed programmatic actions.

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Business Prioritization System REGULATORY COMMITMENTS PORTS OPEN REGULATORY Cwrilimr.mS i

Issue Regulatory Finding Issue Scheduled ID Engineer Number Title Description Date LEVEL

28) UX9613233 BLACKSTON C 70-7002/23 PLANT CHANGES & CONFIGURATION Develop or upgrade remaining engineering procedures 03/31/1997 1

MANAGEMENT that are associated with the change control process and train appropriate personnel on these new or upgraded procedures. (Reference B2PX0980/X23.4B [NSU Project])

[ DOE Tracker # CPI-POA-X23.4c]

29) UX96I3342 BLACKSTON C 70-7002/24 MAINTENANCE PROGRAM Upgrade the preventive maintenance program for Q items 0?/31/1997 1

to meet the commitments for greater formalism.

(Reference FX1080/X24.5B [NSU Project])

[ DOE Tracker # CPI-POA-124.4b]

30) UX96I3342 BIACKSTON C 70-7002/24 MAINTENANCE PROGRAM Revise, develop, or convert corrective maintenance.

03/31/1997 1

preventive maintenance, calibration, and surveillance test procedures for Q items. (Reference B2PX1140/X24.9A

[NSU Project])

[ DOE Tracker # CPI-POA-X24.8b]

i

31) UX9613342 BLACKSTON C 70-7002/24 MAINTENANCE PROGRAM Develop training materials for the work control, 03/31/1997 1

surveillance testing, instrument calibration, and corrective and preventive maintenance procedures for Q items and provide the associated training of appropriate personnel. (Reference B2PZ1160/X24.10A [NSU Project])

[ DOE Tracker # CPI-POA-X24.9b]

32) UK9613342 BIACKSTON C 70-7002/24 MAINTENANCE PROGRAM Identify and control the vendors manuals used for 03/31/1997 1

maintenance of Q List equipment, including entering them into the document control and records management system. (Identify vendor manuals used; verify appropriate vendor's manuals for accuracy / completeness; and enter vendor manual data into the RM & DC system.)

(Reference FX1180/X24.11 [NSU Project])

[ DOE Tracker # CPI-POA-X24.10]

33) UX9613442 BIACXSTON C 70-7002/A.1 MAT *L CONTROL & ACCOUNTABILITY Revise shipping procedures to require PORTS to obtain C3/31/1997 1

MANUALS & PROCEDURE copies of license agreements or nuclear material

[

receipt authorization letters from receiving sites prior to shipment. [2.2.3] (Reference B2PZ1960/XA1.2

[NSU Project])

{ DOE Tracker # CPI-POA-IA1.2j I

34) UX9613442 BLACKSTON C 70-7002/A.1 MAT'L CONTROL & ACCOUNTABILITY Develop approved implementing procedures for 03/31/1997 1

MANUALS & PROCEDORE determining active inventory. [6.3] (Reference B2PX2210/XA1.11 [NSU Project])

IDOE Tracker # CPI-POA-XA1.11]

35) UX96I3442 BLACKSTON S 70-7002/A.1 MAT'L CONTROL & ACCOUNTABILITY Develop procedures requiring the use of NRC Form 327 to 03/31/1997 1

MANUALS & PROCEDURE report inventories and inventory differences. [7.1]

(Reference B2PX2160/XA1.15 [NSU Project]).

(DOE Tracker # CPI-POA-XA1.14]

36) UX96I3477 BLACKSTON C 70-7002/32 QUALITY ASSURANCE PROGRAM Institute training program on procedures and other 03/31/1997 1

IMPLEMENTATION documents for involved personnel to implement the quality assurance program for Q items and services.

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i

Business Prioritization System REGULAM RY COMMITMENTS PORTS OPEN REGULA ERY COMMIIMENTS Issue Regulatory Finding 1ssue Scheduled ID Engineer Number Title Description Date LEVEL

[ DOE Tracker # CPI-POA-X32.2b]

37) UX9613352 BLACKSTCN C 70-7002/30 FROCEDURES PROGRAM Implement new or updated procedures (including required 03/31/1997 1

training) to fully implement the Quality Assurance Program or other activities identified in the.

Application in accordance with Level 2, 3, and 4 Q procedures (unless covered in Actions).

[ DOE Tracker # CPI-PCA-X30.9c]

38) UX97I1669 RALEIGH JJ SSR-96-08-01 PROCEDURE DEFICIENCIES RELATED PORC will conduct further lessons learned training on 03/31/1997 1

TO CYLINDER RAILCAR the circumstances of this example by March 31, 1997

39) UX9711669 RALEIGH JJ SSR-96-08-01 PRCCEDURE DEFICIENCIES RELATED Procedure UE2-PO-OR1030 will be revised to:

03/31/1997 1

TO CTLINDER RAILCAR al provide further guidance on adequate content of material presented to the PORC, and b) require that new PORC members receive procedure (UE2-RA-RR1036, Plant Change Reviews, training. Procedure UE2-PO-OR1030 will be revised and training completed by March 31, 1997.

40) UX97I1669 RALEIGH JJ SSR-96-08-01 PROCEDURE DEFICIENCIES RELATED Any existing PORC members at PORTS that do not have 10 03/31/1997 1

TO CTLINDER RAILCAR CFR 76.67 training will receive this training by March 31, 1997.

41) UX9613465 BLACKSTON C 70-7002/02 UPDATE THE APPLICATICN SAFETY Provide information required to complete the DOE 04/01/1997 1

ANALYSIS REPORT site-wide Safety Analysis Report, and provide technical reviews of the ongoing analysis to ensure that the analysis accurately reflect the facility configuration.

[ DOE tracker # CPI-JCO-X2.2]

42) UX9711669 RALEIGH JJ SSR-96-08-01 PROCEDURE DEFICIENCIES RELATED Organizational, Group, Sectional, and Front Line 04/25/1997 1

TO CYLINDER RAILCAR Managers are assessing their policies and memoranda to ensure that the requirements for items to be captured in procedures have not been circumvented, and identify necessary procedure changes. This action will be completed by April 25, 1997.

43) UX96I3342 BLACKSTON C 70-7002/24 MAINTENANCE PROGRAM Upgrade the current work control process to provide the 04/30/1997-1 committed level of planning and work package development for Q List SSCs. (Reference FX1060/X24.4B

[NSU Projectl).

[ DOE Tracker # CPI-POA-X24.3b]

44) UX9615065 ROCKHOLD DE SSR-96-09-01 FAILURE TO MINIMIZE AMT. OF Reissue Standard Practice Procedure (SPP) H-56, 04/30/1997 1

PCB/R DISPOSAL WASTE

  • Housekeeping,' that has been reviewed for applicability and adequacy and reissued consistent with the PORTS procedures upgrade program by April 30, 1997.
45) UX96IS065 ROCKHOLD DE SSR-96-09-01 FAILURE TO MINIMIZE AprF. OF Upgrade the procedure XP2-EW-EW1031,
  • Waste 04/30/1997 1

PCB/R DISPOSAL WASTE Management " with the PCB breakpoint information that USEC has taken ownership for all PCB wastes < 50 ppm generated from USEC operations at PCRTS, except when other previously agreed to criteria (such as asbestos or assay > 10 %) becomes a factor. PCB wastes > 50 ppm are the responsibility of DOE.

This action will be

{

k Printed 02/27/1997 at 15:13:15 Page 5

~

, ~. _ -,

Business Prioritization System REGUIMORY COMMITMENTS t

PORTS OPEN REGULATORY COPHI7MENTS Issue Regulatory Finding Issue Scheduled ID Engineer Number Title Description Date IEVEL completed by April 30, 1997.

5

46) UK97I1669 RALEIGH JJ SSR-96-08-01 PROCEDURE DEFICIENCIES RELATED Af fected organizations will be trained on the proper u4/30/1997 1

TV CYLINDER RAILCAR use of Caution Tags by April 30, 1997.

47) UX9613441 BLACKSTON C 70-7002/38 DECOMMISSIONING FUNDING Provide executed documents (executed sinking fund 05/19/1997 1

PROGRAM arrangement, standby trust agreement, and/or payment surety bond) required tu assure adequate funding for

?

USEC's portion of PORTS decontamination and decomissioning costs to the NRC at the time US::C privatization occurs.

[ DOE Tracker # CPI-POA-X38.1)

48) UX96I6812 BLACKSTON C 70-7002/39 CHEMICAL SAFETY MECHANICAL Implement the mechanical integrity program for 05/26/1997 1

INTEGRITY PROGRAM maintenance and inspection PSM requirements.

[ DOT Tracker # CPI-POA-X39.1}

49) UX96I1251 WAIDER A PTS-95-223 NONCOMPLIANCE WITH URANIUM Enrichment Technical Support (ETS) to modify the CADP 05/30/1997 1

ENRICHMEh*P CASCADE CELL Syst*m to provide improved audible and visual annunciation when system goes offline.

r

50) UXy6I9226 CADE MD PTS-96-070 SAFETY SYSTEM PERFORMANCE Maintenance to incorporate applicable recommendation 06/15/1997 1

DEGRADATION DISCOVERED D from Engineering into affected maintenance p ocedures.

(Duplicate of CA 004 from Event Report PTS-1996-069)

51) UX9310439 SCHOLL DS PTS-91-030 LOST PRODUCTION OF A *000*

The Genaral Electric contacts on the capacitor 06/20/1997 1

'r CELL (33-3-10) overcurrent relays that cannot be closed by outside sources will be removed through the normal relay calibration schedule by Electrical Maintenance.

52) UX9310602 BLACKSTON C PORTS-92-37 VENTILATION FANS NOT OPERABLE Replace failed fans.

06/30/1997 1

53) UX93IO892 SCHOLL DS PTS-92-285 IDSS OF "00* CELL 31-3-3 Conduct a technical review and equipment investigation 06/30/1997 1

of defective hardware and compressor components for possible corrective action planning.

E4) UX96I1251 WALDER A PTS-95-223 NONCOMPLIANCE WITH URANIUM Upon receipt of ETS recnmmended modifications 06/30/1997 1

ENRICHMENT CASCADE CELL accomplish the tasks necessary to install and test hardware changes.

55) UX96I2977 BLACKSTON C 70-7002/25 OPERATIONS PROGRAM Complete continuing training material and qualification 06/30/1997 1

requirement development, and ensure appropriate personnel are traired and qualified for Cascade Operator, Feed and Product Operator, Chemical Operator, Uranium Material Handler, Operations Manager / Supervisor, and Plant Shift Superintendent L

positions consistent with the plan of action and i

schedule for Issue 26, " Systems Approach to Training".

l (Reference B2PX1270/X25.4 [NSU Project]).

56) UX7612991 BLACKSTON C 70-7002/26 SYSTEMS APPROACH TO TRAINING Develop and implement training programs based upon a 06/30/1997 1

systems approach to training for workers who are relied upon to operate maintain, or modify structures, systems, and components identified as Q or AQ-NCS Printed 02/27/1997 at 15:13:15 Page 6 r

f i

i l

Business Prioritization System j

REGUIATORY COMMITMENTS PORTS OPEN REGULATORY COrusilmm Issue Regulatory Finding Issue Scheduled ID Engineer Number Title Description Date LEVEL

-[

items. For the previously identified job classifications, training for the job incumbents at certification will be completed by 6/30/97.

(Reference B2PX1290/X26.1 [NSU Project)).

[ DOE Tracker # CPI-POA-X26.1)

57) UX9612981 BLACKSTON C 70-7002/26 SYSTEMS APPROACH TO TRAINING Revise and validate the existing job task lists.

06/30/1997 1

(Reference B2PX1300/X26.2 [NSU Project])

[ DOE Tracker # CPI-POA-X26.3]

58) UX9612981 BLACKSTON C 70-7002/26 SYSTEMS APPROACH M TRAINING Design a curriculum that covers the job tasks selected C6/30/1997 1

^

for training. (Reference B2PX1300/X26.2 [NSU Project])

[ DOE Tracker # CPI-POA-X26.3]

$9) UX96I2981 BLACKSTON C 70-7002/26 SYSTEMS APPROACH E TRAINING Develop specific learning objectives from the job 06/30/1997 1,

I performance requirements. (Reference B2PX1300/X26.2

[M W Project])

[DGE Tracker # CPI-POA-X26.3]

L

60) UX96I2991 BLACKSTON C 70-7002/26 SYSTEMS APPROACH TO TRAINING Develop training materials. (Reference B2PX1300/X26.2 06/30/1997 1

[NSU Project])

[ DOE Tracker # CPI-POA-X26.3]

61) UX96I3457 BLACKSTON C 70-7002/07 HEPA FILTER SYSTD4S TESTING The fixed HEPA filter systems required to practice 06/30/1997 1

ALARA principles and to control worker exposure will be retrofitted or replaced with new systems to allow

[

testing in accordance with (1) the requirements of ANSI /ASME N510, (2) the intent of the requirements of l

ANSI /ASME N510 for systems not designed to ANSI /ASME

(

N509. (Refererce HFPX0210/X7.1) f

[ DOE Tracker # CPI-POA-X7.la]

{

62) UX9613457 BLACKSTON C 70-7002/07 HEPA FILTER SYSTEMS TESTING Develop a database of portable HEPA filtration units 06/30/1997 1

I and to perfonn in-place leak testing of all portable l

NEPA filter units.

l

[ DOE Tracker # CPI-POA-X7.1b]

e

63) UX9613052 BLACKSTON C 70-7002/18 EMERGENCY PAuu:,a Fire Services to conduct an analysis to determine the 06/30/1997 1

maximum allowable combustible loadings within the process buildings.

l f

[ DOE Tracker # CPI-POA-X18.2]

64) UX96I4166 RALEIGH JJ 06 LUBE CIL DISCHARGES GENERATING Efforts have been initiated, due to an expanded 06/30/1997 1

UNNECESSARY WASTE interpretation of the MOU scope, to further contain lube oil inventory. Additional drop legs will be installed to existing drip pans on an as needed basis.

l t

(

65) UX9613457 BLACKSTON C 70-7002/07 HEPA FILTER SYSTEMS TESTING

'Ihe HEPA filter systems / units that are not required 06/30/1997 1

based on the Environmental Filter Criteria established

' by the High-Efficiency Filter System Team and accepted by the ALARA committee have been downgraded to non-HEPA

}

filter system units. Documentation is on file to j

justify and downgrade or retention of any HEPA filter i

systems / units.

l Printed 02/27/1997 at 15:13:15 Page 7

[

L

-m.

m,

.mm m.m _ m.

mm., - _.

-m t

Business Prioritization System REGUIATORY COMMITMENTS PORTS OPEN REGUIATORY COP 9fI'INENTS o

Issue Regulatory Finding Issue Scheduled

- ID Engineer Number Title Description Date LEVEL l

[ DOE tracker # CPI-PCA-X-7.lc]

66) UX9710998 CADE MD PTS-96-079 PERFORMANCE DEGRADATION OF By June 30, 1997, a project to restore approximately 85 06/30/1997 l'

CRITICALITY ACCIDENT percent capacity to the motor exhaust duct fans and supply fans in the X-330 and X-333 process building will be completed.

I

67) UK9613140 BIACKSTON C 70-7002/03 AUTOCLAVE UPGRADES Prmride the capability to separately test the inner and 07/01/1997 1

i outer containment valves on the autoclaves in X-342A,-

p X-343, X-344A. (Reference AMPX0080/X3.1 [NSU Project]).

l

[ DOE tracker # CPI-JCO-X3.la]

6

68) UX96I6781 BLACKSTON C 70-7002/44 CRITICALITY ACCIDENT AIARM POR Install CAAS radiation warning lights and/or evacuation 07/01/1997 1

i NEARBY BUILDINGS borns (where nearby CAAS horns cannot be adequately heard) in routinear manned, unalarmed buildings that i

have been identified as of 6/10/96 that are within 200' of a CAAS clustered building, or relocate the building outside the 200' immediate evacuation zone.

[ DOE Tracker # CPI-POA-X44.la]

69) UX96I3140 BLACKSTON C 70-7002/03 AITTOCIAVE UPGRADES Submit a revised TSR to reflect the new configuration 07/01/1997 1

to NRC.

[ DOE tracker # CPI-JCO-X3.1b]

70) UX9613442 BIACKSTON C 70-7002/A.1 MAT'L CONTROL & ACCOUNTABILITY Develop and implement procedure requiring all 07/31/1997 1

MANUALS & PROCEDURE measurement and measurement control procedures be i

reviewed by the Measurement Control Coordinator at least every three years. [5.1.2] (Reference r

B2PX2060/XA1.6 [NSU Project])

(DOE Tracker # CPI-POA-XA1.6]

71) UX7613442 BLACKSTON C 70-7002/A.1 MAT'L CONTROL & ACCOUNTABILITY Revise implementing procedures for approving 07/31/1997 1

MANUALS & PROCEDURE measurement systems to require the approval of the r

Measurement Control Coordinator and provide formal

?

documentation of this approval. [5.11 I

IDOE Tracker # CPI-POA-XA1 7]

[

72) UK9613442 BLACKSTON C 70-7002/A.1 MAT'L CONTR0L & ACmUNTABILITY Revise the Measurement Control Program implementing 07/31/1997 1

MANUALS & PRv N procedures to require monitoring all accountability and confirmatory measurement systems, analyze control standards, make bias estimates and report all data to

[

the Measurement Control Coordinator. [5.1.1] (Reference i

B2PX2082/XA1.8 [NSU Project)

[ DOE Tracker # CPI-POA-KA1.8]

73) UX9613442 BLACKSTON C 70-7002/A.1 MAT'L CONTROL & ACCOUNTABILITT Modify purchasing requirements to include e.aceability 07/31/1997 1

I MANUALS E PROCEDURE documentation for all calibration standards utilized by off-site contractors. Obtain traceability i

documentation for all calibration standards currently being utilized for accountability measurements. [5.1.3]

(Reference B2PX2090/XA1.9 [NSU Project]

f

[ DOE Tracker # CPI-POA-XA1.9]

{

u Printed 02/27/1997 at 15:13:15 Page 8 i

Buoineos Prioritization System REGULATORY COMMI*IMENTS i

PORTS OPEN REGULATORY COMMITMENTS Issue Regulatory Finding Issue Scheduled ID Engineer Number Title Description Date LEVEL 741 UX9613442 BLACKSTON C 70-7002/A.1 PET'L CONTROL E ACCOUNTABILITY Modify software and develop implementing procedures 07/31/1997 1

i MANUALS & PROCEDURE necessary to allow anaLIS to report out-of-limits analytical measurement control program information

.i directly to the Measurement Control Coordinator.

[5.3.2) (Reference B2FX2100/XA1.10 [NSU Project])

[

[ DOE Tracker SCPI-POA-XA1.10]

L

75) UX96I6780 BLACKSTON C 70-7002/42 UF6 LEAK DETECTOR SENSITIVITY Develop and complete a program to relate the response 07/31/1997 1

I TESTING of UF6 leak detectors to manual test methods and to the I

detection of an actual UF6 leak.

I

[ DOE Tracker # CPI-POA-X42.1]

[

76) UX9613465 BIAm W C 70-7002/02 UPDATE THE APFLICATION SAFTTY Submit an amendment to USEC's Certification Application 08/17/1997 1

ANALYSIS REPORT which includes: A) identification of all information, findings, and recommendations whic.a indicate differences between the DOE site-wide SAR and the USEC Application for Certification; B)an evaluation of the effects of those differences on the safety of workers and offsite members of the publics and C) proposed modifications to the compliance certificate and/or facility including proposed modifications to the Application SAR and TSRs.

(Reference PX0060/X2.2)

77) UX9613465 BLACKSTON C 70-7002/02 UPDATE THE AFFLICATION SAFETY Submit, for NRC approval, the proposed resolution of 08/17/1997 1

ANALYSIS REPORT matters contained in the DOE-approved site-wide SAR not incorporated by USEC in its request for amendment of the Application for Certification.

+

[ DOE tracker # CPI-JCO-X2.4]

I

19) UX96I3342 BLACKSTON C 70-7002/24 MAINTENANCE PROGRAM Develop and implement a maintenance history program.

09/30/1997 1

(Develop a master equipment list for safety critical equipment and implement a new computer-based maintenance system with the capability to collect and trend the data).

(Reference FX1020/X24.1 [NSU Project])

[ DOE Tracker # CPI-POA-X24.1]

79) UX9613465 BLACKSTCN C 70-7002/02 UPDATE THE AFFLICATION SAFETY From 9/30/95, until NRC approves the submittals from 09/30/1997 1

ANALYSIS REPORT Actions 3 and 4, changes made by USEC in accordance with DOE's RCA requirement concerning USCDs or with 10 I

CFR 76.68 must be addressed either in the DCE SAR Upgrade results or in the amended safety analysis report submitted by USEC based upon those results.

[ DOE tracker # CPI-JCO-X2.Sa, X2.5b, X2.5c, and X2.5d]

80) UX9613452 BLACKSEN C 70-7002/A.2 RECEIPTS BASED ON PEASURED Complete the cycle time analysis of sampling and 09/30/1997 1

VALUES analysis requirements and the evaluations of sample witnessing programs. Statistical sampling utilization and alternate analysis techniques.

[ DOE Tracker # CPI-POA-XA2.2]

B1) UX9613465 BLACKSTON C 70-7002/02 UPDATE THE APPLICATION SAFETY The update to the Application SAR will also reflect 09/30/1997 ANALYSIS REPORT those commitments made by USEC to the NRC during the initial certification application process as identified Printed 02/27/1997 at 15:13:15 Page 9

_. _,., ~..__. _. _-

Business Prioritization System REGUIATORY COMMITMENTS PCRTS OPEN REGUIATORY COMMITMENTS Issue Regulatory Finding Issue Scheduled ID Engineer Number Title Description Date LEVEL in the Appication and the responses to NRC questions /comn. nts.

[ DOE tracker # CPI-JCO-12.6]

^

92) UX9615065 BLACTSTON C SSR-96-09-01 FAILURE TO MINIMIZE AMT. OF Operations is generating maintenance service requests 09/30/1997 1

PCB/R DISPOSAL WASTE (MSRs) for the X-333, X-330, and X-326 f acilities for:

cascade process lube oil hosing in need of repair or replacement, the repair of leaking stage control valves, and transformers with oil leaks that contribute to the generation of PCB waste (i.e., determined to originate on the cell floor and pass through to the j

operating floor). This program is expected to be fully implemented before September 30, 1997.

83) UZ97IO172 WALDER A PTS-96-076 ACTUATION OF CRITICALITY Inspect CAAS clusters for proper mounting during the 6 09/30/1997 1

)

ACCIDENT AIARM SYSTEM, X-month Surveillance.

t

84) UX96I3233 BIACKSTON C 70-7002/23 PLANT CHANGES E CONFIGURATION Identify and document other AQ items including system 10/01/1997 1

MANAGEMENT boundaries and support systems required for performances of the intended safety function, to be included in the scope of the Configuration Management Program.

(Reference ERPIO930/123.1B [NSU Project])

7

85) UX9613233 BIACKS1VN C 70-7002/23 PLA?TT CHANGES E CONFIGURATION Identify, document, and communicate definitive 10/01/1997 1

MANAGEMENT boundaries for other AQ systems for which the design requirements must be known.

Identify and document the design requirements for these AQ systems / items, l

including support systems required for performance of t'

the intended safety function, for which the design requirements must be known.

(Reference ERPIO950/X23.2B

[NSU Project])

[ DOE Tracker # CPI-POA-X23.2c]

l

86) UK96I3342 BIACKSTUN C 70-7002/24 MAINTENANCE PROGRAM Identify the procedural deficiencies for performing 10/31/1997 1

(

corrective maintenance, preventive maintenance, calibration, and surveillance testing of other AQ SSCs and develop a composite listing of the procedures

{

requiring revision, development or cor: version.

(Reference B2PX1120/X24.7B [NSU Projec1])

[

[ DOE Tracker # CPI-POA-X24.6c]

l P

87) UX9613442 BIACKSTON C 70-7002/A.1 MAT *L CONTROL E ACCOUNTABILITY Revise all NMCEA procedures to reflect 3RC item 10/31/1997 1

MANUALS E PROCEDURE monitoring and discrepancy reporting re pirements.

i

[8.6] (Reference B2PX2330/XA1.20 [NSU Pr7 ject])

[ DOE Tracker # CPI-PCA-KA1.20]

88) UX9613442 BLACKSTON C 70-7002/A.1 MAT'L CONTROL E ACCOUNTABILITY Develop procedures detailing how indications of 10/31/1997 1

f MANUALS E PROCEDURE unauthorized production or loss of enriened uranium are resolved. [11] (Reference B2PX2450/XA1.21 [NSU Project])

[ DOE Tracker # CPI-POA-XA1.21]

89) UX96I3442 BIACKSTCM C 70-7002/A.1 MAT'L COffrROL E ACCOUNTABILITY Develop procedures a d programs to train personnel in 10/31/1997 1

MANUALS E PROCEDURE the detection and reporting of unauthorized enrichment Printed 02/27/1997 at 15:13:15 Pa r la j

u

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+,w.r

f i

Business Prioritisation System REGULATORY COMMITMENTS PORTS OPEN PERJLATORY COMMITMElfrS Issue Regulatory Finding Issue Scheduled

[

. ID Engineer Number Title Description

Date, LEVEL

[

and production activities. [12.4] (Reference DAPX2460/XA1.22 [NSU Project])

I

[ DOE Tracker # CPI-POA-XA1.22]

f

90) UX96I1943 CADE MD PTS-96-023 PERFURMANCE DEGRADATION OF Submit an 2nd Point Assessment to management to assure 11/30/1997 1

AUTOCLAVE SAFETY VALVES plan effectiveness.

91) UX9512569 CADE MD PTS-95-068 DEGRADATION OF SAFETY SYSTEM Evaluate and install an approved / upgraded valve and 12/01/1997 1

COMPONENT DISCOVERED conduct a controlled test in an applicable UF6 System.

i

?

92) UX9410043 SCHOLL DS PTS-91-079 SAFETY SYSTEMS IMPROVEMENT Implement Operations and Maintenance (OU4) Program 12/30/1997 1

INITIATIVE (II) (RETITLE Fixes.

93) UX9410043 SCHOLL DS PTS-91-079 SAFETY SYSTEMS IMPROVEMENT Implement future Enhancements for program major 12/30/1997 1

INITIATIVE (II) (RETITLE documents.

i

94) UX95I4345 CADE MD PTS-95-139 SAFETY SYSTEM ACTUATION DURING The Proposed Autoclave Nuclear Safety Upgrade project' 12/30/1997 1

PRE-OPERATIONAL TES

(#J20340) calls for the autoclave containment valve to be upgraded to a bellows-sealed globe-type valve. This

[

upgrade will reduce seat and stem leakage associated y

with this valve, j

L

95) UX92IO437 BLACKSTON C EM-87-11-05-E TRANSFER STATIONS Complete an engineering design and contract to an 12/31/1997 1

t ENVIRONMENTAL EVALUATIONS outside contractor to construct all necessary h

facilities.

[

f

96) UX9510521 BLACKSTON C SSR-94-14-05 "AS FOUND* CONDITIONS Upgrade procedures to meet requirements.

12/31/1997 1

t

[

97) UX95ICS21 BLACKSTON C SSR-94-14-05 "AS FOUND* CONDITIONS Revise remaining surveillance and maintenance 12/31/1997 1

procedures

[t

[

98) UX95IO530 BLACKSTON C SSR-94-16-10 OPERATIONS NOT CONDUCTED Complete NCS documentation upgrades.

12/31/1997 1

WITHIN BOUNDARIES

[

99) UX9513718 BOWSHER KP PTS-95-115 IDENTIFICATION OF PCYTENTIAL Complete NCS Documentation and Upgrades to provide 12/31/1997 1

NCS CONCERNS DEEMED WO facility double contingencies under new i

interpretations.

I 100) UK9612975 BLACKSTON C 70-7002/17 FIRE PROTECTION PROCEDURES Create or revise, as part of the procedure upgrade 12/31/1997 1

program, the identified fire protection procedures.

(Reference PX0580/X17.A [NSU Project]).

j

[ DOE Tracker # CPI-POA-X17.la) 101) UX9612977 BLACKSTON C 70-7002/25 OPERATIONS PROGRAM Develop or revise procedures addressing the operations 12/31/1997 1

program elements discussed in Section 6.5 of the Safety

[

Analysis Report, develop associated initial training l

materials and conduct initial training for appropriate '

r personnel consistent with the Plan of Action and f

Schedule of Issue 30

  • Procedure Program". (Reference

[

B2PX1220/X25 and B2PX1230/X25.1B [NSU Project]).

)

[ DOE Tracker # CPI-POA-X25.1]

I 102) UX96I2977 BLACKSTON C 70-7002/25 OPERATIONS PROGRAM Complete continuing training material and qualification 12/31/1997 1

requirement development, and ensitre appropriate Printed 02/27/1997 at 15:13:15 Page 11

[

f

Busineco Prioritization System REGUIATORY COMMITMENTS PORTS OPEN REGUIATORY COMMITMENTS Issue Regulatory Pinding Issue Scheduled ID Engineer Number Title Description Date LEVEL personnel are training and qualified for Cascade Controller position consistent with the plan of action and schedule for Issue 26

  • Systems Approach to Training *.

[ DOE Tracker # CPI-POA-X25.3]

103) UK9612981 BIACKSTON C 70-7002/26 SYSTEMS APPROACH TO TRAINING Complete training for those holding these additional 12/31/1997 1

job classifications at the time the program is implemented. (Reference B2PX1320/X26.4 [NSU Project]).

[ DOE Tracker # CPI-POA-X26.4]

104) U196I3111 BLACKSTON C 70-7002/21 MANAGEMENT CONTROLS Quality Assurance Program requirements and applicable 12/31/1997 1

NRC requirements will be ficwed-down to policies and procedures that will be approved and implemented at USEC headquarters and at PORTS in accordance with the Plan of Action and schedule described in Issue 30,

" Procedures Program. UX9673352 (Reference B2PX0790/121.1A/1B [NSU Project]).

[DCE Tracker # CPI-POA-X21.la/X21.1b]

105) UX9613111 BLACKSTON C 70-7002/21 MANAGEMENT CONTROLS Review and revise, if necessary, position descriptions 12/31/1997 1

with the completion of the procedures upgrade effort.

(Reference PX0820/X21.2B [NS'J Project])

[ DOE Tracker # CPI-POA-X21.2b]

106) UX96I3233 BLACKSTON C 70-7002/23 PLANT CHANGES & CONFIGURATION Incorporate new TSRs into the surveillance testing and 12/31/1997 1

MANAGEMENT administrative procedures. Procedure development and the associated training required to resolve this item will be completed according to the POA and schedule for Issue 30.

[ DOE Tracker # CPI-POA-X23.1c]

107) UX9613233 BLACKSTON C 70-7002/23 PLANT CHANGES & CONFIGURATION Develop procedures required to implement an assessment 12/31/1997 1

MANAGEMENT program to systematically evaluate the development and ef fective implementation of the Configuration Management Program elements and related processes in accordance with Compliance Plan 30

  • Procedures Program *, (Reference B2PX0990/X23.5 [NSU Project])

[ DOE Tracker # CPI-POA-X23.5a]

108) UX9613233 BLACKSTON C 70-7002/23 PLANT CHANGES & CONFIGURATION Train appropriate personnel to ensure proper 12/31/1*97 1

MANAGEMENT implementation and application of these procedures in accordance with the Compliance Plan 30 " Procedures Program. (Reference B2PX0990/123.5 [NSU Project])

a

[ DOE Tracker # CPI-PGA-X23.5b]

109) UX9613233 BLACKSTON C 70-7002/23 PLANT CHANGES & CON

  • ICE.7 RATION Implement a training program for plant personnel relied 12/31/1997 1

MANAu N upon to operate, maintain, or modify the plant.

Include initial training on improved or newly developed programs and procedures identified as required to suppcrt the Configuration Management Program in accordance with the Compliance Plan entitled

  • Systems Approach to Training"

[ DOE Tracker # CPI-POA-X23.6]

Printed 02/27/1997 at 15:13:15 Page 12

Business Prioritization System REGULATORY COMMITMENTS p

PORTS OPEN REGULATORY COMMITMENTS i

Issue Regulatory Finding Issue Scheduled ID Engineer Number Title Description Date LEVEL 7

110) UX9613342 BLACKSTON C 70-7002/24 MAINTENANCE PROGRAM Revise the AQ measuring and test equipment calibration 12/31/1997 1

program, develop and implement procedures and provide training to meet the more formal requirements.

l (Reference FX1100/X24.6B [NSU Project))

(DOE Tracker # CPI-POA-X24.Sc]

F 111) UX9613352 BLACKSTON C 70-7002/30 PROCEDURES PROGRAM Implement new or updated procedures (including required 12/31/1997 1

training) to fully implement the Quality Assurance Program or other activities identified in the t

Application in accordance with Level 2, 3, and 4 AQ and NS procedures (Reference B2PX1560/X30.9C [NSU Project])

[ DOE Tracker # CPI-POA-X30.9d]

112) UX9613352 BLACKSEN C 70-7002/30 PROCEDURES PROGRAM Issue analyticel laboratory procedares updated to.

12/31/1997 1

current requirements.

[ DOE Tracker # CPI-POA-X30.10]

i 113) UX96I3442 BLACKSEN C 70-7002/A.1 MAT'L CONTROL & ACCOUNTABILITY Revise procedures to require accountability 12/31/1997

-1 MANUALS & PROCEDURE measurements be made in Building X-705 before the item is transferred to another building. [8.4] (Reference t

B2PX2440/XA1 19 [NSU Project])

[ DOE Tracker # CPI-POA-XA1.19]

i 114) UX9613477 BLACKSTON C 70-7002/32 QUALITY ASSURANCE PROGRAM Institute training program on procedures and other 12/31/1997 1

IMPLEMENTATION documents for involved personnel to implement the c2uality assurance program for AQ items. (Reference B2PX1680/X32.4B [NSU Project))

1

[ DOE Tracker # CPI-POA-X32.2c]

1 115) UX9613477 BLACKSTON C 70-7002/32 QUALITY ASSURANCE PROGRAM Develop and implement procedures that define 12/31/1997 1

IMPLEMENTATION procurement for AQ items.

[ DOE Tracker # CPI-POA-132.2c}

116) UX9613477 BLACKSTON C 70-7002/32 QUALITY ASSURANCE PROGRAM Develop and implement procedures that define handling 12/31/1997 1

I IMPLEMENTATION and storage activities for AQ items.

[ DOE Tracker # CPI-POA-X32.2c}

I 117) UX9613352 BLACKSTON C 70-7002/30 PROCEDURES PROGRAM Complete all overdue Level 2, 3, & 4 AQ procedure 12/31/1997 1

periodic reviews.

[ DOE Tracker # CPI-POA-X30.11]

i t

118) UX9612946 BLACKSTCN C 70-7002/09 NUCLEAR CRITICALITY SAFETY If an administrative requirement for double contingency 12/31/1997 1

?

APPROVAL IMPLEMENTATION controls is found to be missing during the verification, the procedure or checklist modification to implement such a requirement will be expedited through the procedure change process and other appropriate actions will be taken.

l

[ DOE tracker # CPI-POA-X9.1c]

I 119) UX93IO318 SCHOLL DS PTS-91-528 EVACUATION OF X-345 SNM Engineering will install underground instrument and 01/31/1998 1

i STORAGE PACILITY power cables for X-345 to reduce the system susceptibility to severe weather.

Printed 02/27/1997 at 15:13:15 Page 13 I

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Business Prioritization Systes REGUI.ATORY COPNITMENTS PORTS OPEN REGULATORY COHITNENTS Issue Regulatory Finding Issue Scheduled-ID Engineer Number Title Description Date LEVEL 120) UX93IO320 SCHOLL DS PTS-92-194 ACTUATION OF UF6 OUTLEAKAGE Concurrent with the engineering review and correction 01/31/1998 1

DETECTORS AT 1AW STAT of the deficiencies of the X-333 Building LAW Station Worthington lube oil drain system. Operations shall revise the appropriate cms to reflect all system instrumentation and operational changes.

121) UX9614166 RALEIGH JJ 06 LUBE OIL DISCHARGES GENERATING Engineering modifications at the LAW in X-333 included 02/28/1998 1

UNNECESSARY WASTE additional actions for the assessment and control of oil leaks. Similar Engineering modification projects for the ERP, Tails and both EBS stations will include additional actions associated with the identification and correction of oil leaks. Engineering will incorporate a design change in the ERP, Tails and EBS lube oil system designs. The basic concept is to change from a pressurized system, which will tend to have more leaks, to a volumetrically controlled oil 122) UX96I3140 BLACKSTON C 70-7002/03 AUTOCLAVE UPGRADES A detailed schedule for completion of these actions 03/31/1998 1

will be available for review at PORTS.

123) UX97I1717 HOLLIDAY RT COC-98 RENEWAL OF THE CERTIFICATE OF USEC will be requested to file an application for 04/15/1998 1

COMPLIANCE Renewal of the Certificate of Compliance.

124) UX96I3140 BLACKSTON C 70-7002/03 AUTOCLAVE UPGRADES Install fail-safe containment valves upstream of the 05/01/1998 1

UF6 feed isolation and flow control valves on the autoclaves in X-342A and X-343 and modify the programmable logic control system. Install fail-safe containment valves on liquid UF6 drain line on autoclaves 3 and 4 in X 344A.

Replace or modify the daughter cylinder isolation valves on the autoclaves in X-344A for fail-safe position on loss of air.

(Reference AMPX0090/X3.2 [NSU Project])

125) UX96I3140 BLACKSTON C 70-7002/03 AUICCLAVE UPGRADES Add a low air pressure switch to autoclave 2 in X-344A 05/01/1998 1

to initiate containment upon loss of air to pressure transmitter PT-134.

[ DOE tracker # CPI-JCO-X3.3]

126) UX9613140 BLACKSTON C 70-7002/03 AUTOCLAVE UPGRADES Upgrade the internal autoclave and UF6 pressure 05/01/1998 1

transmitters to improve their temperature compensation capability and accuracy in the operating range.

[ DOE tracker # CPI-JCO-X3.5]

127) UX96I3140 BLACKSTON C 70-7002/03 AUTOCLAVE UPGRADES Provide operational alarms on the autoclave safety 05/01/1998 1

systems to alert operators to potential upset conditions.

t

[ DOE tracker # CPI-JCD-X3.6]

128) UX9613140 BLACKSTON C 70-7002/03 AUTOCLAVE UPGRADES Modify the autoclave steam supply and condensate 05/01/1998 1

removal systems on X-342A, X-343 and X-344A to minimize the back up of condensate in the autoclave.

[ DOE tracker # CPI-JCO-X3.7]

?

Printed 02/27/1997 at 15:13:15 Page 14 a-....

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i Business Prioritization System REGULATORY COMMI"lMENTS PORTS OPEN REGUIATORY COMMI7MENTS Issue Regulatory Finding Issue Scheduled ID Engineer Number Title Description Date LEVEL 129) CX96I3140 BIA6C 70-7002/03 AUIOCLAVE UPGRADES Restore the autoclave head /shell sealing surfaces for 05/01/1998 1

the autoclaves in X-342A, X-343 and X-344A.

.l

[ DOE tracker # CPI-JCO-X3.8]

130) UX9613140 BIACKSTON C 70-7002/03 AOTOCIAVE UPGRADES Modify the High Pressure Containment Shutdown System 05/01/1998 1

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.

[ DOE tracker # CPI-JCO-X3.4]

l 131) UX96I3140 BIACKSTON C 70-7002/03 AUTOCLAVE UPGRADES A code interpretation from the ASME Code Committee will 05/01/1998 1-

[

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 I

interpretation and the assessment results will be i

submitted to NRC for review and approval.

[ DOE tracker # CPI-JCO-13.9]

132) UX97IO998 CACE MD PTS-96-079 PERFORMANCE DEGRADATION OF By May 30, 1998, additional testing of scintillation 05/30/1998 1

CRITICALITY ACCIDENT crystals will be completed to define their operating characteristics at temperatures greater than 150 degrees Fahrenheit.

133) UX9613342 BIACKSTON C 70-7002/24 MAINTENANCE PROGRAM Develop training materials for the work control, 06/30/1998 1

i surveillance testing, instrument calibration, and corrective and preventive maintenance procedures for other AQ items and provide the associated training of appropriate personnel. (Reference B2PX1170/X24.10B [NSU Project]

[ DOE Tracker # CPI-POA-X24.9e]

134) UX96I2981 BIACKSTON C 70-7002/26 SYSTEMS APPROACH TO TRAINING Develop and implement training programs for the job 06/30/1998 1

classifications listed, with respect to AQ activities following completion of identification of AQ items

[

(Issue 23) and associated procedures (Issue 30).

L

[ DOE Tracker # CPI-POA-X26.5) 135) UX96I3342 BLACKSTON C 70-7002/24 MAINTENANCE PROGRAM Upgrade the current work control process to provide the 06/30/1998 1

i committed level of planning and work package development for other AQ items.

(Reference PX1060/X24.4B (NSU Project)).

L

[DOd Tracker # CPI-POA-X24.3c]

136) UK9613342 BIACKSTON C 70-7002/24 MAlfrTENANCE PROGRAM Upgrade the preventive maintenance program for other AQ 06/30/1998 1

i items to meet the commitments for greater formalism.

(Reference PX1080/X24.5B [NSU Project])

[ DOE Tracker # CPI-POA-X24.4c]

137) UX9613342 70-7002/24 MAINTENANCE PROGRAM Revise, develop, or convert corrective maintenance 06/30/1998 1

preventive maintenance, calibration, and surveillance test procedures for other AQ items.

7

[ DOE Tracker # CPI-POA-X24.8c]

Printed 02/27/1997 at 15:13:15 Page 15 i

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1 Business Prioritization System REGUIATORY COMMITMENTS PORTS OPEN REGUIATORY COMMI1MENTS Issue Regulatory Finding Issue Scheduled ID Engineer Number Title Description Date IJVEL I

138) UX9612973 BLACKSTON C 70-7002/11 EXCEPTIONS FOR CRITICALITY Ccmplete the tie for the evacuation horns in Building 07/01/1998 1

ACCIDENT AIARM SYSTEM X-744H to the X-744G CAAS that provides detection coverage for Building X-744H.

[ DOE Tracker # CPI-POA-X11.3]

139) UX9616781 BLACKSTON C 70-7002/44 CRITICALITY ACCIDENT ALARM FOR Install CAAS radiation warning lights and/or evacuation 07/01/1998 1

NEARBY BUILDINGS horns (where nearby CAAS horns cannot be adequately

- heard) in routinely unmanned, unalarmed buildings that i

have been identified as of 6/10/96, that are within 200' of a CAAS clustered building, or relocate the building outside the 200* immediate evacuation zone.

[ DOE Tracker # CPI-POA-X44.1b]

140) UX96I2973 BIACKSTON C 70-7t;2/11 EXCEPTIONS FOR CRITICALITY This Compliance Plan issue will be modified to provide 07/01/1998 1

ACCIDENT ALARM SYSTEM a plan and schedule for establishing adequate detector coverage if the adequacy of the current detector coverage is not verified by the NRC review.

i

[ DOE tracker # CPI-POA-X-11.2]

141) UX9010156 BLACKSTON C SW/CF-6 INADFQUATE Design, bid, and award construction of the dikes.

07/31/1998 1

CONTAINMENT / ABOVEGROUND SLEAGE TANKS 142) UX96I3455 BLACKSTON C 70-7002/A.4 POSSESSION OF URANIUM ENRICHED Complete refeed of HEU through Building 326. (Reference 08/31/1998 1

TO > 10% 235U PX2840/XA4.11 [NSU Project])

[ DOE Tracker # CPI-POA-XA4.17]

143) UX9613455 BIACKSTON C 70-7002/A.4 POSSESSION OF URANILH ENRICHED Develop and implement additional controls and 08/31/1998 1

TO > 10% 235U monitoring activities to preclude and detect the presence of uranium enriched to greater than 9.99 wt. %

within the top purge cascade in quantities that would lead to exceeding Category III limits _across all USEC-leased and certified spaces.

i

[ DOE Tracker # CPI-POA-XA4.18]

144) UX90I0156 BLACKSTON C SW/CF-6 INADEQUATE Complete construction and test.

09/30/1998 1

CONTAINMENT /ABvvu,xvuau STORAGE TANKS 145) UX9310091 SCHOLL DS PTS-92-065 SAFETY SYSTEM ACIUATION Maintenance conduct a comprehensive study of 09/30/1998 1

instrumentation line failures for preventative j

maintenance (PM) planning purposes. This FM Plan will evidence the need and schedule for relacement of the lines.

i 146) UX93IO121 BLACKSTON C 02 VAGUE DESCRIPTION FOR PROPER Re-issue corrected procedurer from the affected 09/30/1998 1

RESPIRATOR PROTECTION divisions.

147) UX96I3455 BIACKSTON C 70-7002/A.4 POSSESSION OF URANIUM ENRICHED Certify that the total quantity of SNM present within 09/30/1998 1

i TO > 10% 235U the total of all leased areas, other than the " leased but not certified" areas within Building 705, meets NRC Category III limits, and then turn over the remaining leased areas of Ruilding 326 to NRC regulation.

Printed 02/27/1997 at 15:13:15 Page 16 e

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i Business Prioritization System i*

REGULATORY COMMITMENTS PORTS OPEN REGEIATORY COMMITMENTS Issue Regulatory Finding Issue Scheduled ID Engineer Number Title Description Date=

LEVEI,

{

(Reference PX2850/XA4.12 [NSU Project])

[DCE Tracker # CPI-POA-XA4.19]

148) UX97IO998 CADE MD PTS-96-079 PERFORMANCE DEGRADATION OF Following completion of process building ventilation 09/30/1998 1

CRITICALITY ACCIDENT

. repairs and scintillation crystal evaluaticns, Engineering will determine an appropriate long-term surveillance frequency that will ensure CAAS clusters remain in calibration.

I 149) UX96I2985 BIACKSTON C 70-7002/29 RECORDS MANAGEMENT AND Records being maintained in the organizations will not 12/31/1998 1

DOCUMENT CONTROL PROGRAM be turned over to the Administrative Support immediately, but will be retained by the responsible organization until Administrative Support can process them.

Pre-existing organization records will be turned over and incorporated into the records management system. (Reference C8PX1420/X29.1C [NSU Project]).

[ DOE Tracker # CPI-POA-X29.la.4]

[

150) UX9612985 BLACKSTON C 70-7002/29 RECO*4DS MANAGEMENT AND Identify documents within the scope of the document 12/31/1998 1

l DordMENT CONTROL PROGRAM control program, according to the application.

Documents being maintained in the organizations will not be turned over to Administrative Support but will be retained by the responsible division until Administrative Support can process them.. Pre-existing documents will be turned over and incorporated into the document control system via a turnover schedule.

[

(Reference C8PX1440/X29.2A [NSU Project])

151) UX96I2985 BLACKSTON C 70-7002/29 RECORDS MANAGEMENT AND Evaluate final tally of documents identified in Action 12/31/1998 1

DOCUMENT CONTROL PROGRAM S and 6 and catalogue as to their document type, distribution requirements, and information to provide an index for ease of retrieveabililty. (Reference C8PX1440/X29.2A [NSU Project!)

[ DOE Tracker # CPI-POA-X29.2a.5]

152) UX96I3455 BLACKSTON C 70-7002/A.4 POSSESSION OF URANIUM ENRICHED Complete large (8, 12 in.) cylinder, heel cleanouts in 12/31/1998 1

TO > 10% 235U Building 705 (Reference FX2820/XA4.9 [NSU Project])

[ DOE Tracker # CPI-PCA-XA4.15]

153) UX9613455 BLACKSTON C 70-7002/A.4 POSSESSION OF URANIUM ENRICHED Complete 5-in. cylinder cleaning in Building 705.

12/31/1998 1

f TO > 10% 235U (Reference PX2860/XA4.13 [NSU Project])

[ DOE Tracker # CPI-POA-XA4.20]

154) UX96I2985 BLACKSTON C 70-7002/29 RECORDS MANAGEMENT AND Computer codes and test result data used to directly or 12/31/1995 1

DOCUMENT CVNTROL PROGRAM indirectly support the PORTS process systems will be submitted to Administrative Support in accordance with the turnover scheduled identified in Action 009.

[ DOE Tracker # CPI-POA-X29.1d.2]

155) UX9613038 70-7002/13 POSTING OF RADIOACTIVE Necessary radiological characterization and re-posting 12/31/1998 1

MATERIALS of leased areas within the PORTS site boundary will be completed by December 31, 1998.

[ DOE Tracker # CPI-POA-X13.3]

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Business Prioritization SyRtem REGUIATORY COPHITMENTS PORTS OPEN REGUIATORY COPHITMENTS Issue Regulatory Finding Issue Scheduled ID Engineer Number Title Description Date LEVEL 156) UX9613452 BLACKSTON C 70-7002/A.2 RECEIPTS BASED ON MEASURED Complete the upgrade of the sampling autoclaves and the 12/31/1998 1

VALUES implementing of sampling program modifications to be compliant with NRC requirements.

l

[ DOE Tracker # CPI-POA-XA2.3]

6 157) UX96I2985 BIACKSTUN C 70-7002/29 RECORDS MANAGEMENT AND Records being maintained in the organizations will be 12/31/1998 1

DOCUMENT CONTROL PROGRRt turned over to ASO in accordance with the records management turnover schedule identified in Action 009.

Pre-existing records required to be maintained under the USEC QAP will be turned over and incorporated into

[

the revised records management system in accordance with the approved records management turnover schedule.

I After the turnover of an organization's records to Records Management, the temporary storage of subsequent records will be in one-hour fire-rated file cabinets.

158) UX9613455 BIACKSTON C 70-7002/A.4 POSSESSION OF URANIUM ENRICHED Certify that the total quantity of SNM present within 01/31/1999 1

i TO > 10% 235U the total of all leased areas meets NRC Category III limits, and then turn over the remaining leased areas of Building 705 leased areas to NRC regulation.

(Reference PI2870/XA4.14 (NSU Project])

l

[ DOE Tracker # CPI-POA-XA4.21]

159) UX94IOS75 BOWS *tER KP PTS-94-057 SAFETY SYSTEM w uvnraA FOUND Replace the existing PI 205 pneumatic transmitter on 04/30/2000 1

OUT OF CALIBRATION UF6 lines with alectronic transducers and remote signal conditioners, which can be located outside of the autoclave heated housing.

160) UI95I0059 BOWSHER KP PTS-94-118 AUTOCLAVE #7 ItrTERNAL PRESSURE Replace the existing PI 721 pneumatic transmitter with 04/30/2000 1

INDICATOR (PI) electronic transducers and remote signal conditioners which can be located outside of the autoclave heated housing.

(E)

[

161) UX9610895 CADE MD PTS-95-213 SAFETT STSTEM ACTUATION (STEAM Complete Autoclave Nuclear Safety Upgrade Project 06/30/2000 i

SHUTDOWN) ON HIGH construction which will relocate or replace the pressure transmitters located inside the heated control cabinet.

162) UX9613140 BIACKSTON C 70-7002/03 AUTOCLAVE UPGRADES The completion schedule for the remaining 12 autoclaves 02/01/2001 1

will be such that the final autoclave is completed by 2/1/2001.

{

163) UX9613140 BIACKSTON C 70-7002/03 AITIOCLAVE UPGRADES The TSRs for all autoclaves will be revised to declare 02/01/2001 1

[

an autoclave inoperable and taken out of service when any containment valve is determined to be inoperable until the capacity to perform autoclave pressure decay testing within inner loop and outer loop containment valves is provided.

'[ DOE tracker # CPI-JCO-X3.1c]

(

164) UK9010031 BLACKS 1VN C MA-4 ELECTRICAI, EQUIPMENT NOT Draft Conceptual Design Report. Delete scheduled dates 07/31/2001 1

SECURELT MOUNTED 6-10 per letter from E. W. Gillespie to R. G. Donnelly, October 6, 1992, EO-23-3131.

I r

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i Business Prioritization System RNATORY CCM4IINENTS PORTS OPEN REGULATORY COP 9fITHENTS 4

Issue Regulatory Pinding Issue Scheduled ID Engineer Number Title Description Date LEVEL 2

+

165) UX90I0031 BLACKS 1VN C MA-4 ELECTRICAL EQUIPMENT NOT Perform design. Delete scheduled dates 6-10 per letter 07/31/2001 1

SECURELY POUNIED from E. W. Gillespie to R. G. Donnelly, October 6, 1992, EO-23-3131.

166) UX90I0031 BIJdtSTON C MA-4 ELECTRICAL EQUIPMENT NOT Start construction. Delete scheduled dates 6-10 per 07/31/2001 1

SECURELY MOUNTED letter f rom E. W. Gillespie to R. G. Donnelly, October 6,

1992, EO-23-3131, 167) UX9010031 BIACKSTON C MA-4 ELECTRICAL EQUIPMENT NOT Complete project. Delete scheduled dates 6-10 per 07/31/2001 1

SECURELY MOUNTED

. letter from E. W. Gillespie to R. G. Donnelly, October l

6, 1992 EO-23-3131.

168) UX9010031 BLACKSTON C MA-4 ELECTRICAL EQUIPMENT NOT Verify compliance. Delete scheduled dates 6-10 per 07/31/2001 1

SECURELY MOUNTED letter from E. W. Gillespie to R. G. Donnelly, October 6, 1992, EO-23-3131.

169) UX91IO734 BIACKSTON C ENG 24 EMERGENCY BATTERY STORAGE Design /specify necessary changes.

07/31/2001 1

170) UX9110734 BLACKSTON C ENG 24 EMERGENCY BATTERY STORAGE Install changes via contractor as part of Line Item 07/31/2001 1

Project.

171) UX9CID030 BIACKSTON C MA-3 SPARE PARTS INADEQUATELY Draft conceptual design report. Delete scheduled dates 07/31/2001 1

SECURED IN PROCESS BLDG 6-10 per letter from E.W. Gillespie to R.G. Donnelly October 6.

1992, EO-23-3131, 172) UX9010030 BLACKSTON C MA-3 SPARE PARTS INADEQUATELY Perform design. Delete scheduled dates 6-10 per letter 07/31/2001 1

SECURED IN PROCESS BLDG from E. W. Gillespie to R. G. Donnelly October 6, 1992.

EO-23-3131.

173) UX9010030 BLACKSTON C MA-3 SPARE PARTS INADEQUATELY Start construction. Delete scheduled dates 6-10 per 07/31/2001 1

SECURED IN PROCESS BLDG letter from E. W. Gillespie to R. G. Donnelly, October 6, 1992 EO-23-3131.

174) UX90I0030 BIACKSTON C MA-3 SPARE PARTS INADEQUATELY Complete project. Delete scheduled dates 6-10 per 07/31/2001 1

SECURED IN PROCESS BLDG letter from E. W. Gillespie to R. G. Donnelly, October 6, 1992 EO-23-3131.

175) UX9010030 BLACKSTON C MA-3 SPARE PARTS INADEQUATELY Verify compliance. Delete scheduled dates 6-10 per 07/31/2001 1

SECURED IN PROCESS BLDG letter from E. W. Gillespie to R. G. Donnelly, October 6, 1992, EO-23 3131.

176) UX96I3352 BLACKSTON C 70-7002/30 PROCEDURES PROGRAM The PORC will review all procedures designated as 12/10/2001 1

In-hand and procedures that involve liquid UF6 handling l

activities within a 5 year period after the date that NRC assumes regulatory authority at PORTS. Itis Committee pertain only to those procedures which will not otherwise be reviewed by the PORC (as required by Section 6.11.4.1), or by a PORC subcommittee, before the expiration of the 5-year period. Procedures in this scope have been, and will continue to be, reviewed

,i by a PORC subcommittee, thereby satisfying this s

Printed 02/27/1937 at 15:13:15 Page 19 l

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l Buciness Prioritization System REGUIATORY COMMIIMENTS PORTS OPEN REGUIATORY COMMITMENTS Issue Regulatory Finding Issue Scheduled ID

. Engineer Number Title Description Date LEVEL

1) 1J19614 818 HOLLIDAY RT 70-7002/01 DOE ORDER TO TAKE ACTION Track and complete disposition of items identified in 2

PR-PTS-95-2862.*

l

2) UX9619328 HOLLIDAY RT-JCO-02 CELL DEATMENT COOLANT SYSTEM Ensure administrative controls are in place for Cell 2

PRESSURE Treatment Cbolant System Pressure JCO I

(POEF-831-96-1260, Rev. 0).

3) UX9619328 HOLLIDAY RT JCO-02 CELL TREAIMENT COOLANT SYSTEM Ensure an operator continuously monitors the cell 2

PRESSURE pressure and temperature, whenever a shot is in the i

cell. and stops the cell treatment if there are any abnomal pressure or temperature excursions. This continuous monitoring means that an operator is always-present at the Local Control Center. If the assigned a

operator needs relief then a replacement operator will be assigned.

4) UX9619328 HOLLIDAY RT JCO-02 CELL TREAIMENT COOLANT SYSTEM Ensure that the analyses using the infrared analyzer 2

PRESSURE will include a specific check for coolant at each of the 30-minute intervals.

5) UX9619328 HOLLIDAY RT JCO-02 CELL TREATMENT COOLANT SYSTEM Ensure the X-326 Building operation will include 2

PRESSURE evacuation of the coolant system to at least 18' Hg prior to introducing the shot to prevent the possibility of reaching an explosive concentration, and, limit the cell pressure for dumping the shot so that the cell pressure does not rise above the coolant system pressure.

6) UX9710164 BLACKSTON C CPJCO-23 PLANT CHANGES AND Section 3.8 of the Application contains a current 2

CONFIGURATION MANAGEMENT - JCO listing of the Q, AQ-NCS, and AQ systems and the associated boundary definitions. As additional Q, t

AQ-NCS, and AQ items are identified, Section 3.8 vill be revised accordingly. DOE Tracker # CPI-JCO-X23.1.

i

7) UX9710164 BLACKSIUN C CPJCO-23 PLANT CHANGES AND Until the upgrade change control process consistent 2

i CONFIGURATION MANAGEMENT - JCO with the requirements cf the Configuration Management Program is in place, the integrity of the existing configuration will be maintained by identifying, i

controlling, documenting, and recording plant changes.

DOE Tracker # CPI-JCO-123.4a.

l

8) UX96I5889 RALEIGH JJ JCO-01 JCO OF THE CRITICALITT Ensure these homs and lights will be slaved from a 2

i ACCIDENT ALARM SYSTEM -CAAS nearby clustered building or otner slaved buildings.

9) UX9710138 BL4CKSTON C CPJCO-03 AUTOCLAVE UPGRADES - JCO Uhtil fail-safe containment valves can be added or 2

I replaced, the existing valves will either be cycled twice or verified operable prior to each cylinder heating cycle. DOE Tracker # CPI,JCO-X3.2a.

10) UX9710138 BLACKSTON C CPJCO-03 AUTOCLAVE UPGRADES - JCO The autoclave locking ring interlock contains pressure 2

limit switches which lock out the hydraulics to prevent the autoclaves from being opened when the internal pressure is greater than 0.5 psig. The autoclave L

locking ring interlock is tested quarterly to verify Printed 02/27/1997 at 15:15:03 Page 1

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Business Prioritization System REGUIATORY COPH11NENTS PORTS OPEN REGULATURY COMMITMENTS Issue Regulatory Finding Issue Schedulsd f

ID Engineer Number Title Description Date LEVEL t

its ability to perform this function. DOE Tracker

  1. CPI-JCO-13.4b.
11) UK97IO138 BLACKSTON C CPJCO-03 AUIOCIAVE UPGRADES - JCO Uhtil the steam supply and condensate removal systems 2-are upgraded, a hose will be used during the first hour of heating to allow the condensate to drain to an open drain instead of a steam trap. This temporary I

modification has been shown to reduce the activation of the high condensate level alarms to almost zero. DOS Tracker # CPI-JCO-13.7a.

12) U19710138 BIACKSTON C CPJCO-03 AUTOCLAVE UPGRADES - JCO Until the autoclave head /shell sealing r,urfaces are 2

restored, thin strips of Viton " shim

  • rill be used, as necessary, behind the 0-ring gasket t', compensate for irregularities in the mealing sur h es.

DOE Tracker #

CPI-JCO-13. B a.-

13) UX97IO138 BIACKSTON C CPJCO-03 AUTUCIAVE UPGRADES - JCO The autoclaves will be pressure decay or leak rate 2

[

tested quarterly and each time the 0-ring gasket is replaced. DOE Tracker # CPI-JCO-X3.la, 13.1c, X3.2b and

'X3.8b.

14) UX97IO138 BIACKSTON C CPJCO-03 AUTOCIAVE UPGRADES - JCO Perform quarterly system channel functional test to 2

verify the containment valve closure. DOE Tracker #

CPI-JCO-13.la, Z3.1b, and K3.2a.

15) Ux9710138 BIACKST'N C CPJCO-03 AUTOCLAVE UPGRADES - JCO The alarm response procedure for the autoclave in 2

X-342A, X-343, and X-344A only allow the operator to open the autoclave after clearing the High Pressure Containment Shutdown System alarm condition. DOE Tracker # CPI-JCO-K3.4a.

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h Printed 02/27/1997 at 15:15:03 Page.2 r

b to GDP 97-0023 USEC IIQ Open Regulatory Commitments

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.m.

Buainess Prioritiration Syctem REGUIAIDRY COPHITNENTS

-,~

HQ OPEN REGDIATVRY CDPHIIMENTS Issue Regulatory Finding Issue Scheduled ID Engineer IUumber Title Description Date IEJEL

?

1) US9710044 ADAMS, J^

DOE LTR-2/5/97 PERMIT TO CARRY FIREARMS AND Assure weapons authoria.a. tion cards are returned to DOE 03/03/1997 1

MAKE ARRESTS at tranimition to NRC.

t

2) U597I0023 ROUTH, S COC DOCUMENT CERTIFICATE OF COMPLIANCE USEC will be required to file an application for 04/15/1998 1

RENEWAL renewal.of the Certificates of Compliance by April 15, 1998.

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1 i

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t.

Printed 02/27/1997 at 10:47:17 Page 1

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Business Prioritization System REGUIATORY CCFMITMENTS HQ OPEN REGULATORY col 9f1TMENTS Issue Regulatory Finding Issue Scheduled ID Engineer Number Title Description

~ Date LEVEL

1) US9710040 WELLS,R' CALEA7001/97000 CAL-SHUTDolN OF C-400, UF6 Prepare request for restart of C-400.

2 2

CYLINDER WASH OPERATION 21 US97IO041 GASTON, R DOE LTR-2/21/97 PORTS UF6 CYLINDER MOVEMENT Keep interim planner awareness in place until 76.69 2

checklist implemented.

3) US97I0025 WELLS, R COMPLIANCE FLAN STATUS REPORTING USEC will provide quarterly reports to NRC on the 2

implementation status of Compliance Plan commitments.

These quarterly status reports will include, where appropriate, proposed revisions to remove the discussions of noncompliances that have been closed.

Printed 02/27/1997 at 10:48:16 Page 1

. ~.

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l' i

i

! to GDP 97-0023

)

List of Commitments If there are any new regulatory commitments to DOE generated between this date and March 3, 1997 (i.e., the date that NRC assumes NRC regulatory oversight), USEC will submit a supplemental report by March 17,1997.

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