ML20137B453

Forwards Proprietary Quarterly Repts on Implementation Status of Compliance Plans.Encl Withheld,Per 10CFR2.790(d)(1) & 9.17(a)(4)

ML20137B453
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant, Paducah Gaseous Diffusion Plant
Issue date:	03/18/1997
From:	Woolley R UNITED STATES ENRICHMENT CORP. (USEC)
To:	Pierson R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
Shared Package
ML20057G509	List: ML20137B453
References
GDP-97-0035, GDP-97-35, NUDOCS 9703210332
Download: ML20137B453 (46)

Text

J United States Enrichment Corporahon 2 Democracy Center 6903 Rockledge Drive i

Bethesda, MD 20817

]

Tel: (301)564-3200 United States Enrichment Corporation March 18,1997 Mr. Robert C. Pierson SERIAL: GDP 97-0035 Chief, Special Projects Branch i

Division of Fuel Cycle Safety j

and Safeguards, NMSS i

United States Nuclear Regulatory Commission Washington, D.C. 20555-0001 Paducah Gaseous Diffusion Plant (PGDP)

Portsmouth Gaseous Diffusion Plant (PORTS)

Docket Nos. 70-7001 and 70-7002 Quarterly Compliance Plan Report INFORMATION TRANSMITTED llEREWITH IS PROTECTED FROM PUBLIC DISCLOSURE AS CONFIDENTIAL COMMERCIAL OR FINANCIAL INFORMATION AND/OR TRADE SECRETS PURSUANT TO 10 CFR 2.790(d)(1) AND 9.17(a)(4)

Dear Mr. Pierson:

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

Accordingly, enclosed is the quarterly Compliance Plan Report for the period of December 1,1996 through March 3,1997 (i.e., the date NRC assumed regulatory oversight). As required by the Compliance Plan, enclosed is the following information: 1) an executive summary that identifies Compliance Plan issues that were completed during the past quarter, Compliance Plan issues that are scheduled to be completed during the next quarter, and a discussion of any Compliance Plan issues that are behind schedule; and 2) a detailed listing, sorted by noncompliance, of the individual commitments within each Compliance Plan issue.

As you are aware, the Department of Energy (DOE) has conducted inspections at both sites to l

review those Compliance Plan issues that USEC considers complete. The results of the DOE l

inspections were documented in a letter from DOE to NRC dated February 24,1997, " Compliance Plan Turn-Over to the Nuclear Regulatory Commission." The enclosed report identifies thos Compliance Plan issues that DOE considers closed.

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} JoQm fhh Offices in Paducah, Kentucky Portsmouth, Ohio Washington, DC

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Mr. Robert C. Pierson March 18,1997 GDP 97-0035, Page 2 t

In accordance with 10 CFR 76.33(e), and consistent with the NRC's December 18,1995 letter, the information related to Compliance Plan issues A.1 through A.5 for PORTS, and A.1 through A.7 for PGDP is considered to be proprietanf commercial and financial information pursuant to 10 CFR 2.790(d)(1) and 9.17(a)(4) and is exempt from public disclosure. These Compliance Plan issues have been clearly identified as proprietary information.

i i

If you have any questions or require additional information concerning the enclosed report, please contact Russ Wells at (301) 564-3245. There are no new commitments contained in this submittal.

Sincerely, 6.D.N+1,p Robert L. Woolley Nuclear Regulatory Assurance and Policy Manager Enclosure ec:

NRC Region III Office NRC Resident Inspector - PGDP and PORTS DOE Regulatory Oversight Manager

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TABLE OF CONTENTS l

A.

Executive Summary I.

Introduction II.

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

Completed Compliance Plan Issues i

IV.

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

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

Detailed Listing of the Individual Commitments within each Compliance Plan Issue

. B.

Tables 4

1.

Description of Completed / Closed Compliance Plan Issues f

2.

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

Figures 1.

Summary of Individual Compliance Plan Actions i

i i

D.

Enclosures j

1.

Description of Compliance Plan Issues and Actions l

A

l 1

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EXECUTIVE

SUMMARY

i 1.

Introduction On September 15, 1995, USEC initially submitted the Compliance Plans for PGDP and PORTS to NRC as part of the Certification Application. Subsequent revisions to the Compliance Plans were submitted to NRC on November 7,1995 (Revision 1), February 5, 1996 (Revision 2), July 12,1996 (Revision 3), and August 1,1996 (Revision 3, Change A).

The Compliance Plans include the following information:

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

i The Compliance Plans contains 106 individual areas of noncompliances or " issues," 57 at PGDP and 49 at PORTS. Each issue includes one or more actions that must be completed in the next several years. There are approximately 450 individual actions contained in the Compliance Plans. Figure 1 shows graphically the Compliance Plan actions that have been completed and those actions that are remaining to be completed.

The Introduction sections of the Compliance Plans state-

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

implementation status of Compliance Plan commitments. These quaderly status reports will include, where appropriate, proposed revisions to remove the discussions of noncompliances that have been closed. The reports will also include an executive summary that identifies plans of actions that were completed during the past quarter, plans of actions scheduled to completed /sicJ during the next quader, and a discussion of any plans of actions that are behind schedule'. The executive summary will be supported by a detailed listing, sorted by noncompliance, of the individual commitments within each plan of action. The listing will j

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

The initial Compliance Plan report was submitted to NRC on December 18, 1996 (reference USEC letter GDP 96-0194). The reporting period for this quarterly report is December 1,1996 to March 3,1997 (i.e., the date NRC assumed regulatory oversight).

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

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

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

II.

Proposed Revisions to t'ne Compliance Plans for " Closed" Noncompliances In the Compliance Plans, USEC committed to provide NRC with " proposed revisions to remove the discussions of noncompliances that have been closed." Updates to the Compliance Plans to reflect completed or closed 2 Compliance Plan issues actions will be submitted to NRC as part of Certificate of Compliance amendment or renewal applications as required by 10 CFR

76. Additionally, USEC letter to NRC dated December 11,1996', documented an agreement between USEC and NRC that changes to Compliance Plan issues will be implemented as follows:

Changes to the " Justification for Continued Operation" and " Plan of Action and Schedule" sections require NRC approval prior to implementation.

Changes to the " Requirements," " Commitment," and " Description of Noncompliance" sections do not require NRC approval prior to implementation provided the change meets the criteria of 10 CFR 76.68 (a)(1), (2), (3), (4), and (6) and does not result in a change to the Technical Safety Requirements.

3 In the initial quarterly Compliance Plan report, USEC included a table that identified those Certificate Amendment Requests (CARS) that USEC had submitted to NRC to revise Compliance Plan action due dates. NRC letter to USEC dated December 18, 1996', stated that no action on NRC's part was required for these CARS because the proposed changes to the due dates would be completed prior to March 3,1997. On March 4,1997, USEC submitted a CAR to, in part, revise Compliance Plan Issue A.2 for PGDP (reference USEC letter GDP 97-0028). This CAR proposes to revise the Plan of Action for this Compliance Plan issue to allow dimensional measurement calculations to determine equipment volumes. This CAR is currently awaiting NRC review and approval.

III.

Completed Compliance Plan Issues i

This section identifies those Compliance Plan Issues which USEC has completed as of the cutoff date for this report. Additionally, this section reflects the results of DOE " closure" 2The term " complete" means that USEC has fulfilled all of the individual actions described in a Compliance Plan issue. A Compliance Plan issue is considered " closed" when the regulator has reviewed and concurred that all actions have been completed and documented its review in writing.

' Robert L. Woolley to Robert C. Pierson, "10 CFR 76.68 Requirements for Changes to the Compliance Plans."

dElizabeth Q. TenEyck to James H. Miller, " Changes to Portsmouth Compliance Plan Due Dates for NCS Related Issues and an HEU Related Issue; Change to Paducah Compliance i-Plan Due Date for Fire Pump Refurbishment" activities relating to Compliance Plan issues. Of the 106 Compliance Plan issues,46 (i.e.,23 s

for PGDP and 23 for PORTS) were completed as of March 3,1997, and are listed in Table

1. Of the approximate 450 Compliance Plan actions, about 250 (i.e., 55%) were completed as of March 3,1997. During this reporting period, USEC completed 18 Compliance Plan i

issues as reflected in Table 1. All Compliance Plan issues due to be completed by USEC as of March 3,1997 were completed.

i IV.

Compliance Plan Issues that are Scheduled to be Completed During the Next Quarter There me 6 Compliance Plan issues coming due between March 4,1997 and May 31, 1997. These issues are listed in Table 2.

V.

Discussion of Any Compliance Plan Issues that are Behind Schedule Table 2 identifies those Compliance Plan issues that have completion dates between March 4,1997 and May 31, 1997, but which are currently behind schedule. USEC is placing additional emphasis on these issues to complete them within their required due dates. USEC is required to submit a CAR for NRC review and approval if we cannot complete a Compliance Plan issue within its required due date.

VI.

Detailed Listing of the Individual Commitments within each Compliance Plan Issue Enclosure I to this report lists each Compliance Plan Issue, a description of the commitments for each issue and the due date committed to in the Compliance Plan. Enclosure I also identifies if the commitment has been completed.

5This report does not include the following Compliance Plan issues that were deleted or canceled as reflected in Revision 3 to the Compliance Plan:

PGDP issues 28,47, A.5, and A.6 PORTS issues 31,43, and A.3

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Page1 TABLE 1 DESCRIPTION OF COMPLETED / CLOSED COMPLIANCE PLAN ISSUES PORTSMOUTH ISSUE NO.

DESCRIPTION OFISSUE STATUS 1*

Transition from DOE Regulation to NRC Regulation Complete 4*

X-705 Evaporator Heat Exchanger Modifications Closed 5

X-705 Isolation Valve Testing Closed 6

X-705 Microfiltration Influent pH Shutdown System Replacement Closed 8*

Nuclear Criticality Safety Approval Documents Complete t

10 Nuclear Criticality Safety Training for Managers Closed 12 Radiation Protection Procedures Closed 14 NVLAP Certification Closed 15 Fire Protection Compensatory Measures Closed 16 Fire Protection Sprinkler Testing Closed 19 Packaging and Transportation Complete 20*

DOE Chemical Safety and Third-Party Use of hazardous Chemicals Closed 22*

Safety Committees Closed 27 Assessments Closed 28*

Event Investigations and Reporting Program Complete 33 Emergency Plan Support Documents Closed This issue was completed or closed during the reporting period for this submittal.

Page 2 TABLE 1 DESCRIPTION OF COMPLETED / CLOSED COMPLIANCE PLAN ISSUES PORISMOUTH ISSUE NO.

DESCRIPTION OF ISSUE STATUS 34 Training for Emergency Preparedness Complete 35 Quality Control Program for Low-Level Waste Disposal Closed 36*

Depleted Uranium Management Plan Closed 37*

Administrative Controls on Overtime Complete 40 Operational / Safety System Trip Redundancy Closed 41*

Codes and Standards Closed A.5

• DOE Materials Stored in Leased Space Complete This issue was completed or closed during the reporting period for this submittal.

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Page 3 TABLE 1 DESCRIPTION OF COMPLETED / CLOSED COMPLIANCE PLAN ISSUES PADUCAH ISSUE NO.

DESCRIPTION OFISSUE STATUS 1*

Transition from DOE Regulation to NRC Regulation Complete 4

C-360 Crane Upgrades Closed 5*

Nuclear Criticality Safety Approval Documents Complete 6

Nuclear Criticality Safety Approval Implementation Complete 7

Criticality Accident Alarm System Coverage Closed 9

Radiation Protection Procedures Closed i

e 11 Radioactive Calibration Source Accuracy Closed 12 NVLAP Certifications Closed 13 Fire Alarm System Reliability Closed 15 Fire Protection Equipment Closed 18 Packaging and Transportation Closed 20*

Safety Committees Complete 25*

Event Investigations and Reporting Program Complete 32 Emergency Plan Support Documents Closed 33 Training for Emergency Response Organization Closed 34 Quality Control Program for Low-Level Waste Disposal Closed This issue was completed or closed during the reporting period for this submittal.

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Page 4 TABLEI DESCRIPTION OF COMPLETED / CLOSED COMPLIANCE PLAN ISSUES PADUCAH ISSUE NO.

DESCRIPTION OF ISSUE STATUS 45*

Codes and Standards Closed 48 Cascade Cell Trip Function System Requirements Closed A. l

• Materials Control and Accountability Manuals and Procedures Complete A.2*

Measurement Systems Complete A.3 Receipts Based on Measured Values Closed A.4 Inventviy Program for Uranium IIoldup Closed A.7*

DOE Materials Stored in Leased Space Complete This issue was completed or closed during the reporting period for this submittal.

Page1 TABLE 2 COMPLIANCE PLAN ISSUES COMING DUE DURING THE NEXT QUARTER PORISMOUTH ISSUE NO.

DESCRIPTION OFISSUE DUE DATE STATUS 39 Chemical Safety Mechanical Integmy Program 5/26/97 On schedule l

PADUCAH ISSUE NO.

DESCRIPTION OFISSUE DUE DATE STATUS 14 Fire Protection Water System Reliability 3/31/97 On Schedule 30 Public Warning Sirens and Controls 3/15/97 On Schedule 31 Public Address System 4/30/97 Behind Schedule 40 Chemical Safety Mechanical Integrity Program 5/26/97 Behind Schedule 42 Administrative Controls on Overtime 3/31/97 On schedule 43 DOE Chemical Safety and Third-Party Use of 5/26/97 On schedule Hazardous Chemicals 1

.2.

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FIGURE 1

SUMMARY

OF INDIVIDUAL COMPLIANCE PLAN ACTIONS

Compliance Plan Tasks as ofMarch 3,1997

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1996 1997 1998 1999 4

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ENCLOSURE 1 DESCRIPTION OF COMPLIANCE PLAN ISSUES AND ACTIONS i

ENCLOSURE 1 PORTS Action Status by Issue 17-Mar-97 I

FACILITY ISSUE #

TASK ID Dl'E DATE COMMITMEST DESCRIPTION

' STATUS PORTS 01 CPI-POA-X0LOI Transition Some of the activities necessary for USEC to implement this phased transition are described in this Complete Compliance Plan. USEC is currently developing additional detailed plans and schedules to implement the phased transition. Consistent with ROA 6.

..ts 3.2.2.2,33.2.6, and 3.4.23, DOE will review all proposed changes from OSRs to TSRs, and USEC will not implement any such changes without the consent and written approval of the DOE Regulatory Oversight Manager.

CPI-POA-X01.02 Transition In the interest of assuring a safe, smooth transition from DOE to NRC regulatory authonty, including a safe Complete transition from OSRs to TSRs, USEC will keep the DOE Regulatory Oversight Manager and the NRC fully '

r informed of USEC plans, schedules, and the status of activities to implement the phased transition. The information USEC will provide will include detailed tasks, schedules, and milestones for completing the transition; identification of areas requiring interface reviews and the schedules for performing such review; and the schedules for procedure development, personnel training, and operational readiness evaluations.

Except as identified in this Compliance Plan, all activities required to compkte the transition from o

compliance with DOE requirements to NRC regulations will be completed by the date NRC assumes regulatory authority. The transition to NRC regulatory oversight is scheduled to occur 120 days after the NMSS Director's decision regarding USEC's certification.

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

- 02 CP3-POA-X02.01 2/ISN7 The approved DOE site-mide Safety Analysis Report and supporting documentation will then be forwarded Complete to USEC by February 15,1997.

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

CPI-POA-X02.03a 8/17/97 By no later than August 17,1997 USEC shall submit an -..be to their Certification Application which includes:

s a) identi6 cation of all information, findings, and recommendations which indicate differences betwecia the DOE site-wide Safety Analysis Report and the USEC Application for Certification.

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

. whichincludes:

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

CPI-POA-X02.03c 8/17/97 Dy no later than August 17,1997, USEC shall submit an amendment to their Certification Application which includes:

c) proposed modifications to the compliance certificate and/or facility, including proposed modifications to the Application SAR and TSRs.. Page I of15 m

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FACILITY ISSUE #

TASK ID DUE DATE COMMITMENT DESCRIPTION STATUS PORTS 02 CPI-POA-X02 04 8/17M7 At the same time the Application --,dwa is duc, USEC shall also submit for NRC approval, its proposed resolution of matters contained in the DOE-approved site-wide Safety Analysis Report not incorporated by USEC in its request for amendment of their Application for Certification.

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

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

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

CPI-POA-X02.05c 9/30S 7 From September 30,1995, until NRC approves the submittals in paragraphs 3 and 4 above, changes made by USEC in accordance with DOE's ROA requirement conceming Unreviewed Safety Question Detern:inations (USQDs) or with 10 CFR 76.68 must be addressed either in the DOE SAR Upgrade results or in the amended safety analysis report submitted by USEC baxd upon those results. The following will assure such changes are property considered and addressed:

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

CPI-POA-X02.05d 4/30/98 From September 30,1995, until NRC approves the submittals in paragraphs 3 and 4 above, chariges made by USEC in accordance with DOE's ROA requirement conceming Unreviewed Safety Question Determinations (USQDs) or with 10 CFR 76.68 must be addressed either in the DOE SAR Upgrade results or in the amended safety analysis report submitted by USEC based upon those results. lhe following will assure such changes are property considered and addressed:

- NRC is notified of changes made in d.w with 10 CFR 76.68 as part of the annual Application for renewal rcquired by 10 CFR 7636.

CPI-POA-X02.06 8/17/97 The update to the Application SAR will also reflect those commitments made by USEC to the NRC during the initial certification Application process as identified in the Application and the responses to NRC questions / comments.

03 CPI-POA-X03.01a 7/1/97 Provide the capability to separately test the inner and outer loop containment valves on the autoclaves in X-342A, X-343, and X-344A.

CPI-POA-XO3.01b 7/1/97 A revised TSR to reflect the new [ inner and outer loop containment valve test] configuration will be submitted to NRC by July 1,1997.. Page 2 of15

FACllRY ISSUE #

TASK ID DUE DATE COSINIITMENT DESCRIPTION STATTS PORTS 03 CPI-POA-XO3 01c Certification The TSRs for all autoclaves will be revised to declare an autoclave inoperable and taken out of ser ice Complete when any containment valve is determined to be inoperable until the capability to perform autoclave pressure decay testing with inner loop and outer loop containment valves is provided.

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

CPI-POA-XO3 02b 5/1N8 Install fail-safe containment valves on the liquid Ur6 drain line on autoclaves 3 and 4 in X-344A.

CPI-POA-X03.02c 5/IN8 Replace or modify the daughter cylinder isolation valves on the autoclaves in X-344 A for fail-safe (i.e.,

closed) position on loss of air.

CPI-POA-X03.03 5/1N8 Add a low air pressure switch to autoclave 2 in X-344A to initiate contamment upon loss of air to pressure transmitter PT-134.

CPI-POA-XO3 M 5/1N8 Modify the fligh Pressure Containment Shutdown System controls for the autoclaves in X-342A, X-343, and X-344A to prevent them from being inadvertently opened when the pressure in the autoclave exceeds the setpoint as defined in the Technical Safety Requirements.

CPI-POA-X03.05 5/IN8 Upgrade the intemal autoclave and UF6 c)linder pressure transmitters to improve their i.w-compensation capability and accuracy in the operating pressure range.

CPI-POA-XO3.06 5/IN8 Provide operational alarms on the tutoclave safety systems to alert operators to potential upset conditions.

CPI-POA-XO3.07 5/IN8 Modify the autoclave steam supply and condensate removal systems in X-342A, X-343, and X-344A to minimize the back up of condensate in the autoctave.

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

CPI-POA-XO3 09 5/188 A code interpretation from the ASME Code Committee will be obtained regarding the need for pressure relief for the UF6 cy linders. Based on this interpretation, the need for modifications to the afTected system operations will be assessed. Both the ASME Code interpretation and the assessment results mitt be submitted to NRC for review and approval.

CPI-POA-X03.10a 12/31N6 Pressure decay testing procedures that assure that backpressure does not mask leaks in autoclave steam G osed admission lines will be implemented by December 31,1996.

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

CPI-POA-XO3.11 3/31/98 A detailed schedule for comletion of these action will be available for review at PORTS.

CPI-POA-XO312 2/1/2001 The completion schedule for the remaining twelve autoclaves will be such that the final autoclave is complete by February 1. 2001.

04 CPI-POA-X04.01 12/31/96 Install instrumentation and system modifications in the steam condensate drain piping from the evaporator O osed heat exchangers to provide double contingency for nuclear criticality safety.

CPI-POA-X04.02 12/31/96 Replace the evaporator heat exchangers to eliminate the unfavorable geometry expansion joint.

O osed, Page 3 of15

FACILITY ISSCE #

TASK ID Dl'E DATE COM3tITMENT DESCRIPTION STATUS PCOTS 05 CPI-POA-X05.01 6/3066 Block valves, test taps, and a valve leak test cart have been installed to allow leak testing of the following G osed isolation valvet (1) the uranyl nitrate feed isolation s alves to the X-705 calciners feed pumps and (2) the isolation valves between the microfiltration units bag filters and effluent storage tank.

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

06 CPI-POA-XO6 01a 6/30S6 Repipe a section of the feed system to the microfiltration process.

O osed CPI-POA-XO6.01b 6/30S6 Deactivate the microfiltration influent pit shutdown system (located between second stage pil adjust and G osed the microfiltration feed tank).

CPI-POA-X06 01e 6/30S6 install a microfdtration effluent pII shutdown system (located between the microfiltration modules and the O osed effluent tank).

07 CPI-POA-X07.01a 6/30/97 De fixed IIEPA filter systems required to practice 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 or (2) the intent of the requirements of ANSI /ASME N510 for systems not designed to ANS!!ASME N509.

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

08 CPI-POA-X08.01 2/28S7 Formal NCSAs and NCSEs will be completed for all current operations involving uranium enriched to I wt Complete

% or higher 235U and 15 grams or more 235U by November 30,1996, and will be properly documented and approved in accordance with the NCS program requirements contained in the approved Certificate.

CPI-POA-X08.02 11/3086 ne procedural changes to resolve the administrative noncompliances in the nuclear criticality safety Complete program will be completed by November 30,1996.

CPI-POA-X08.03 Transition All aspects of Technical Safety Requirement 3.9 implementation and its associated tentacles for NCS will Complete be in place no later than the transition to NRC regulatory oversight.

09 CPI-POA-XO9.01 a Transition See issue 8 A program is in place to review all NCSAs in order to identify and track the designated NCS conditions, Complete specifications, and controls and to verify their full implementation. Particular attention is being focused on ensuring consistency between each NCSA and the operation including work-site postings. De verification program (of the roughly 150 operating procedures and I 50 postings) will be completed Ibr all current fissile material operations, prior to NRC assuming regulatory oversight of PORTS for NCSAs that need to flow into Technical Safety Requirements.

CPI-POA XO9.Olb 1/31S 7 Identification of the remaining NCSA requirements to be flowed-down into procedures will be completed Complete by December 2,1996.

CPI-POA-X09.01e 2/28/97 A procedure for container handling and storage will be developed prior to December 2,1996.

Complete CPI-POA-X09.02 12/2/96 The procedural changes to resolve the administrative noncompliances in the Nuclear Criticality Safety Complete Program (from SAR Section 5.2.4 and as identified in the Summary of Requirements and Commitments table below) will be completed by December 2,1996.

CPI-POA-X09.03 Transition All aspects of Technical Safety Requirement 3.9 implementation and its associated tentacles for NCS will Complete be in place no later than the transition to NRC regulatory oversight.

Enclosure L Page 4 of13

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FACILITY ISSUE O TASK ID DUE DATE CO31%IITMENT DESCRIPTION STATUS o

PORTS 09 CPI-POA XO904 Also see Issue 30 ne plant-wide procedure upgrade initiative will provide additional assurance of the full and proper flow-down of NCS conditions and specifications to operating procedures and postings. He compliance plan item entitled " Procedures Program" addresses the implementation of operating procedures.

CPI-POA-X09.05 On Going If a new or revised NCSE identifies the need for modifications to the existing plant configuration, affected Complete 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 safely in the current configuration. If the plant configuration or activity is modified, the Plant Operations Review Committee will review the proposed modification prior to its resumption to verify that the activity, as modified, can be performed safety.

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

O osed C?l-POA-X10.02 3/3166 Individuals requiring training uill complete the designated NCS manager training course.

Closed i1 CPI-POA-XI1.01 9/30S 6 USEC will proside criticality detector coverage in all areas of the plant except for those areas identified and Complete justified by USEC and approved by NRC. Analyses that provide the technicaljustification for not providing criticality accident alarm system coverage in designated areas of the plant are being developed. Except for Buildings X-330, X-333, and X-700, analyses hase been submitted to NRC that (I) verify the adequacy of the existing criticality accident alarm system and its detector locations for detecting a criticality accident and (2) justify that detectors are not required for monitoring other areas of the plant. The analyses for Buildings X-330, X-333, and X-700 mill be completed by September 30,1996.

CPI-POA-XI I.02 7/1/98 ne analyses already submitted identified the need to tie the evacuation hems in Building X-744tl to the Building X-744G CAAS that progides detection coverage for Buildmg X-74411. Building X-74411 contains lightly contaminated waste with a comparatively low potential for a criticality accident.

12 CPI-POA-X12.01 10/24 S 5 ne required procedure changes will be implemented.

O osed CPI-POA-X12.02 10/186 Plant procedures will be issued by October 1,1996, to incorporate the annual radiation protection program G osed review requirement from SAR paragraph 5.3.1.3.

CPI-POA-X13.01 Transition Building work areas previously posted as

• Regulated Areas" will be re-posted to reflect the current O osed 13

' Restricted Area" and " Contamination Control Zone" designations CPI-POA-X13.02 12/3166 Restricted areas within USEC leased space which contain unlabeled, but potentially radioactive, material Closed containers will be posted with signs stating that each untabeled container may contain radioactive material.

CPI-POA-X13 03 12/3168 Necessary radiological characterization and re-posting ofleased areas within the FORTS site boundary will be completed by December 31,1998.

14 CPI-POA-X14.01 10/24 S 5 USEC will provide NVU2-accredited dosimetry for those relatitely few individuals who are required to Closed be monitored under 10 CFR 20.1502.

15 CPI-POA-X15 01 12/31S 5 A procedure defining fire prevention requirements for compensatory action will be developed to address (1) Closed preplanned and emergency impairment program, (2) limiting conditions for operation, and (3) compensatory actions.

16 CPI-POA-X16.01 11/30S 5 ne Fire Department will test the fire systems at the required ORO Fire Protection periodic testing G osed frequencies. Implementation of the testing frequencies will be completed by Ncvember 30,1995.

17 CPI-POA-X17.01a Also see issue 30 The fire protection procedures will be created or revised as part of the overall procedure upgrade project by December 31,1997.

Enciosure 1. Page 5 of15

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FACilJIY ISSt'E O TASKID Dt'E DXIE CO%I3tlT5 TENT DESCRIPTION STATUS

=u__:= --- - - - - - -

= ~ -

PORTS 17 CPI-POA-XI7.01b 12/31/96 Fire Protection programmatic piocedures (I) Standard Practice Procedure S-20,

• Fire Protection";(2)

• Fire Complete Protection Requirements for Welding, Buming, and llotwork Practices," UE2-SS-FS103I; and (3) a formal procedure for the performance of fire hazard assessments will be upgraded and implemented by December 3I,1996.

CPI-POA-X17.01e 12/3 tN6 ne hot work permit procedure and applicable training programs uill be resised to ensure Fire Senices Complete involvement and oversight of the hot work permit program by December 31,1996.

I8 CPI-POA-XI8.01 10/IN6 The emergency packets will be updated by Emergency Management to reflect current facility Closed configurations and conditions. This update will include the information required by the emergency packet control procedure including such information as: (I) general building! area layout drawings or sketches, (2) critical action, equipment. or material listing, (3) facility / area utility senices, (4) facility emergency systems and equipment, (5) lists of hazardous, toxic, and/or radioactis e materials, including compressed gases, and (6) list (s) of facility tenant organizations CPI-POA-X18.02 6/30N7 An analysis uill be conducted by Fire Services personnel to determine the maximum a!!owable combustible loadings uithin the process buildings. He 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 control these specific occupancy areas. Some local occupancy areas to be considered include burnable " Anti-C" waste storage, tube oil in process reserves, waste storage, mainterance shops, and stores. Building custodians will be provided information and training on recognizing the acceptable levels of combustible loadirig in the process buildings, both in general and in local areas.

19 CPI-POA-X 19.01 4/30N6 Upon approval of the Packaging and Transportation Quality Assurance Plan and acceptance of USEC as Complete holder of the NRC certificate of compliance for the Paducah Tiger overpack, USEC will begin shipment under the NRC certificate of compliance.

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

CPI-POA-X20.02 3/14N6 Finalire the resolution document and forw ard to NRC Closed CPI-POA-X20.03 5/26/96 Complete 75% of the initial process hazard analyses to conform uith the federally mandated requirement.

Closed CPI-POA-X20.04 6/28/96 If the material exceeds specified CFR threshold quantities, a safety risk will be performed to identify the C!ased hazardem and mitigating actions in accordance with those regulations. Ifrequired, develop and distribute DOE directive.

21 CPI-POA-X21.01a Also see issue 30 For Q to support TSRs and AQ-NCS: QAP and Regulatory Requirements Flowdown - Quality Assurance Complete Program requirements and applicable NRC requirements uill be flowed down to policies that will be approsed and implemented at USEC lleadquarters and PORTS in accordance with the Plan of Action and Schedule described in issue 30, " Procedure Progrant" CPI-POA-X21.0lb 12/31N7 For balance of Q and other AQ: QAP and Regulatory Requirements Flowdown - Quality Assurance Program requirements and applicable NRC requirements will be flowed down to procedures that wiil be approved and implemented at USEC Ileadquarters and PORTS in accordance with the Plan of Action and Schedule described in Issue 30," Procedure Program."

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

Enciasure 1. Page 6 of15

FACILITY ISSUE O TASKID DUE DATE COMMITMENT DESCRIPTION STATUS o

PORTS 21 CPI-POA-X21.02o.

12/3167 The position descriptions will again be reviewed and revised, if nccessary, by December 31,1997.

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

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

23 CPI-POA-X23.01al 12/31M6 Identify and document all Q items items including system boundaries and support systems required for Complete performance of the intended safety function, to be included in the scope of the Configuration Management Program.

CPI-POA-X23.Ola2 2/28/97 Identify and document all AQ-NCS items including system boundaries and support systems required for Complete performance of the intended safety function, to be included in the scope of the Configuration Management n'rogram.

CPI-POA-X23.01a3 10/IN7 Identify and document all other AQ items including system boundaries and support systems required for performance of the intended safety function, to be included in the scope of the Configuration Management Program.

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

CPI-POA-X23.01c 12/3187 Incorporate new Technical Safetv Requirements into the surveillance testing and administrative procedures.

CPI-POA-X23.01d 10/187 Identify and document all other AQ items, including system boundaries and support systems required for performance of the intended safety function, to be included in the scope of the Configuration Management Program.

CPI-POA-X23.02a 12/31/96 Develop the baseline documentation that establishes the design requirements for all Q systems / items.

- G osed including support systems required for performance of the intended safety function.

CPI-POA-X23.02b 2/28/97 Review all Nuclear Criticality Safety Approvals and Nuclear Criticality Safety Evaluations to identify AQ-Complete NCS items (items uhich support the nuclear criticality double contingency principle); to identify and document the designated design requirements and system boundaries, including support systems required for performance of the intended safety function; and to serify the implementation of these requirements. To the extent completed, this infonnation will be maintained and made available to the NRC, before regulatory jurisdiction, for planned inspection activities.

CPI-POA-X23.02c 10/1/97 Identify, document, and communicate definitive boundaries for the other AQ systems. Identify and document the design requirements for these AQ systems / items, including support systems required for performance of the required safety function, for which the design 4d,e.ts must be known.

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

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

O osed CPI-POA-X23Na 7/31/96 Upgrade the four core engineering procedures that specify the requirements for the change control process Gesed to ensure the identification, technical and safety review, approval, implementation, validation, documentation, and recording of plant changes.

f

! Page 7 of15 i

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FACILITY ISSUE 0 TASK ID DUE DATE COMMITMENT DESCRIPTION

-STATUS'

. 4 I

PCOTS 23

- CPI-POA-X23.04b 701/96-Tram appropriate personnel to ensure proper implementation and application of these upgraded cost Oswd phh.

CPI-POA-X23.04c 3G1/97 Develop or upgrade remaining engineering procedures that are associated with the change control process

=

.and train appropriate personnel on these new or upgraded procedures.

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

CPI-POA-X23.05b See issue 30 Train appropriate personnel to ensure proper implementation and aplication of these procedures.

CPI-POA-X23.06 Also see issue 26 Implement a training program for plant personnel relied upon to operate, maintam, 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, j

t 24 CPI-POA-X24.01 See Issues 26 and 30 Develop and implement a maintenance history and trend analysis program.

- Develop a master equipment list for safety critical equipment

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

j CPI-POA-X24.02 701/96 Develop guidance for cleanliness control and measures to prevent entry of extraricous material into a closed O wed system.

CPI-POA-X24.03a 400/97 For Q items: Upgrade the current maintenance work control process to provide the committed level of planning and work package development for Q items.

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

- Revise the work control procedure.

6

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

CPI-POA-X24.03b 2/28S7 For AQ-NCS items: Upgrade the current maintenance work control process to provide the committed level Cesaplete ofplanning and work package A.J,-..t AQ-NCS items.

g e

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

- Revise the work control procedure.

t

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

CPI-POA-X24.03c 6/3088 Ior other AQ items: Upgrade the current maintenance work control process to provide the committed level

- of planning and work package development other AQ items.

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

- Revise the work control procedure.

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

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FACILITY lsSUE O TASKID Dl'E DATE COSINIITNIENT DESCRIPTION STATL'S PORTS 24 CPI-POA-X24.04a 2/28M7 For AQ-NCS items: Upgrade the preventive maintenance program to meet the mimdb ts for greater Cumplete formalism.

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

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

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

- Develop the technicathistorical basis for use in evaluating preventive maintenance task adequacy.

CPI-POA-X24Alb 3/31M7 For Q items: Upgrade the presentive maintenance program to meet the commitments for grtater formalism.

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

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

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

- Develop the technicathistorical basis for use in evaluating preventive maintenance task adequacy.

CPI-POA-X24 04c 6/30/98 Forother AQitems: Upgrade the preventive maintenance program to meet the m.mdmets for greater formalism.

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

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

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

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

CPI-POA-X24.05a 2/28M7 for AQ-NCS M&TE: Revise the measuring and test equipment calibration program to meet the more Complete formal requirements.

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

(Complete)

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

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

CPI-POA-X24.0$b I2/3tM6 For Q M&TE: Revise the measuring and test equipment calibration program to meet the more formal Complete requirements.

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

(Complete)

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

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

CPI-POA-X24.05c 12/31M7 For other AQ M&TE: Revise the measuring and test equipment calibration program to meet the more formal requirements.

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

(Complete)

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

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

Enclosrae 1, Page 9 of15

FACILITY ISSUE #

TASK ID DUE DATE COMMITMENT DESCRIPTION STATUS

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PORTS 24 CPI-POA-X24 06a 10GIS6 For Q SSCs: Identify the procedural deficiencies for performing conective maintenance, preventive Closed maintenance, equipment calibration, or surveillance testing for Q, AQ-NCS, and other AQ SSCs and develop a composite listing of the procedures requiring revision, development, or conversion.

CPI-POA-X24 06b IG1/97 For AQ-NCS SSCs: Identify the procedural deficiencies for performing corrective maintenance, preventive Closed maintenance, equipment calibration, or surveillance testing for Q, AQ-NCS, and other AQ SSCs and develop a composite listing of the procedures requiring revision, development, or conversion.

CPI-POA-X24.06c 10G1/97 For other AQ SSCs: Identify the procedural deficiencies for performing corrective maintenance, preventive maintenance, equipment calibration, or surveillance testing for Q AQ-NCS, and other AQ SSCs and develop a composite listing of the procedures requiring revision, development, or conversion.

CPI-POA-X24.07 Transition Develop procedures and prmide the associated training of appropriate personnel for the performance of Complete surveillance tests u hich are required to support Technical Safety Requirements.

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

Complete instrument calibration. and surveillance test procedures for AQ-NCS structures, systems, and components.

CPI-POA-X24 08b 3/3187 For Q items: Revise, develop, or convert corrective maintenance, preventive maintenance, instrument calibration, and surveillance test procedures for Q structures, systems, and components.

CPI-POA-X24.08c 630S8 For other AQ items: Revise, develop, or convert corrective maintenance, preventive maintenance, instrument calibration, and surveillance test procedures for other AQ structures, systems, and components.

CPI-POA-X24 09a 2/28/97 For AQ-NCS items: Develop training materials for the work control, surveillance testing, instrument Complete calibration, and corrective and preventive maintenance procedures and provide the associated tra' ing of m

appropriate personnel CPI-POA-X24.09b 3G1/97 For Q items: Develop training materials for the work control, surveillance testing, instrument calibration, and corrective and preventive maintenance procedures and prmide the associated training of appropriate personnel.

CPI-POA-X24 09c 6G0/98 For other AQ items: Develop training materials for the work control, surveillance testing, instrument calibration, and corrective and preventive maintenance procedures and provide the associated training of appropriate personnel.

CPI-POA-X24.10 3/31S 7 Identify and control the vendors' manuals used for maintenance of Q equipment, including entering them into the document control and records management system.

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

- Verify appropriate vendors' manuals for accuracy and completeness.

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

25 CPI-POA-X25.01 12/31/97 Procedures addressing the operations program elements discussed in Section 6.5 of the Safety Analysis Report will be developed or revised, associated initial training materials uill be developed, and appropriate personnel will receive initial training by December 31,1997, consistent with the plan of action and schedule of the Compliance Plan issue entitled " Procedures Program."

Enclosure I, Page 10 ofI5

FACILfiY LSSUE #

TASK ID DUE DATE COMMfrMENTDESCLIPTION -

STATUS' PC3TS 25 CPI-POA-X25.02 6/30/97 Continuing training matenal and qualification requirement development will be completed, and appropriate personnel trained and qualified for Cascade Operator, Feed and Product Operator, Chenucal Operator,

- Uranium Material llandler, Operations Manager / Supervisor, and Plant Shift Superintendent positions by June 30,1997, consistent with the plan of action and schedule of the Compliance Plan issue entitled

' Systems Approach to Training?

CPI-POA-X25.03 12/31/97 Continuing training material and qualification requirement development will be completed, and appropriate personnel trained and qualified for Cascade Controller position by December 31,1997, consistent with the plan of action and schedule of the Compliance Plan issue entitled " Systems Approach to Training."

26 CPI-POA-X26.01 6/30/97 Training programs will be developed and implemented based upon a systems approach to training for workers who are relied upon to operate, mamtam, or modify structures, systems, and wm,a.s identified as Q or AQ-NCS items. For the previously identifiedjob classifications training for thejob 6As at certification will be completed by June 30,1997.

CPI-POA-X26.02 6/27/96 A detailed schedule for the compiction of all training programs not in compliance with 10 CFR 76.95 will Closed be issued by June 27,1996.

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

systems engineers, cascade coordinators. and NCS engineers / specialists), thejob analyses and training program design have not been completed. The following actions will be completed by June 30,1997.

- Revise and validate the existing job task lists.

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

- Develop specific learning objectives from thejob performance requirements.

- Develop training materials.

CPI-POA-X26M See CPI-POA-X26.3 Training for those holding these additionaljob classifications at the time the program is implemented will be completed by December 31,1997.

CPI-POA-X26.05 6/30/98 Training programs for thejob classifications list above, with respect to AQ activities, will be developed and implemented by June 30,1998, following completion ofidentification of AQ items (see Compliance Plan issue 23," Plant Changes and Configuration Management *) and associated procedures (see Compliance Plan Issue 30, " Procedures Program *).

27 CPI-POA-X27.01 9/30/96 An organizational level assessment program will be implemented consisting of the preparation and Closed implementation of a procedure for the performance of organizational level assessments in a uniform manner.

28 CPI-POA-X28.01a Transition A nuclear regulatory event reporting procedure meeting the event notification and reporting requirements Closed required by *.he USEC application, and an event investigations procedure that defines the event investigation process and assigns responsibilities and authority for its implementation will be approved by the date NRC assumes regulatory oversight.

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

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

Complete 29 CPI-POA-X29.01 a.1 6/3096 Records being maintained by the plant organizations and Administrative Support will be verified to Closed determine the storage locations of these records and the methods of protection being employed to presene these documents. Page 11 of15

FACILITY ISSUE O TASK ID DUE DATE COMMITMENT DESCRII* TION STATUS PORTS 29 CPI-POA-X29.01a.2 6/30/96 The final tally of records identified in item (1) above will be evaluated against applicable requirements and G esed then catalogued as to their record type, categorization, and retention. This information will be characterized in a combined PORTS and PGDP Uranium Enrichment Records Manual that will be utilized by both sites.

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

CPI-POA-X29.01a.3 6/30/96 A records management tumover schedule has been drafted and submitted to the functional organizations Closed which prioritizes the turnover based on the record's importance to the safety and quality of plant operations.

This schedule will be formalized by June 30,1996.

CPI-POA-X29.01a.4 12/31/98 Records being maintained in the organizations wi!! not be turned over to Administrative Support immediately but will be retained by the responsible orgardzation until the D&R Group can process them.

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

CPI-POA-X29.01 a.5 6/30/96 A new electronic records indexing database based on the evaluation conducted in item (2) above and item G osed I d)(1) below will be put into service by June 30,1996.

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

CPI-POA-X29.01e 12/31/98 Records being maintained in the organizations will be turned over to Administrative Support in accordance with the records management turnover schedule identified in item (aX3) above. Pre-existing records required to be mair.tained under the USEC Quality Assurance Program will be turned over and incorporated into the resised records management system in accordance with the approved records management turnover schedule. 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.

CPI-POA-X29.01 d.1 8/15/96 The PORTS computerized records indexing system will be evaluated to make certain that the necessary Closed information required by each organization for its records is consistently applied to ensure the ready retrievability of the records.

CPI-POA-X29.01d.2 12/31/98 Computer codes and test result data used to directly or indirenly support the PORTS process systems will be submitted to Administrative Support in accordance with the tumover schedule identified in item (aX3) above.

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

Closed CPI-POA-X29.02a.2 6/30/96 A document control tumover schedule has been drafted which prioritizes the tumover based on the O osed document's importance to the safety and quality of plant operations. This schedule will be formalized by June 30,1996.

CPI-POA-X29.02a.3 6/30/96 The document control system will be updated on an ongoing basis to provide controlled distribution lists G osed and to control the actual distribution of documents under the control of the D&R Group commencing June 30,1996.

CPI-POA-X29.02a.4 12/31/98 Documents within the scope of the document control program, according to the application, will be identified. Documents being maintained in the organizations will not be tumed oser to Administrative Support but uill 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.

CPI-POA-X29.02a 5 12/31/98 lhe final tally of documents identified in items (1) and (3) above will be catalogued as to their document type, distribution requirements, and information to provide an index for case of retrievability., Page 12 ofI$

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FACILITY ISSUE #

TASKID DUE EATE COMMITMENTEESCRIPTION STATUS

-PCHTS 29 CPI-POA-X29.02a.6 '

6/30/96 The new electronic document control inventory system that identifies the controlled copy holder number Closed and custodies, storage location, and retrieval capability will be put into service.

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

Comeplete 30 CPI-POA-X30.01 7/31/96 By July 31,1996, incorporate into the Procedure Control Process procedure the SAR-6.11.4.1 criteria for Closed use by responsibic management in complying with TSR 3.9 by identifying applications requiring additional written procedures.

CPI-POA-X30.04 6/1/96 Document the criteria for use in determining when work must be stopped because a procedure cannot be Closed performed as uTitten.

CPI-POA-X30.06 Transition By the date that the NRC assumes regulatory authority for PGDP, incorporate into the Procedure Control Closed Process procedure the SAR-6.11.4.5 criteria for identifying procedures that TSR 3.9 requires review by the PORC.

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

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

- Operational policy statements: June 28,1996 CPI-POA-X30.00b 2/28/97 Issue the required operational policy statements and implement new or updated procedures (including Complete required training) to fully implement the Quality Assurance Program or other activities identified in the

(

application in accordance uith the following schedule:

- Level 2,3, and 4 AQ-NCS procedures (unless covered by item 8): December 31,1996 i

CPI-POA-X30.09c 3/31/97 Issue the required operational policy statements and implement new or updated procedures (including required training) to fully implement the Quality Assurance Program or other activities identified in the j

application in accordance with the following schedule:

I

- Level 2,3, and 4 Q procedures (unless covered by item 8): March 31,1997 CPI-POA-X30.09d 12/31/97 Issue the required operational policy statements and implement new or updated procedures (including required training) to fully implement the Quality Assurance Program or other activities identified in the

-i application in accordance with the following schedule:

I

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

CPI-POA-X30.11 12/31/97 Complete all overdue Level 2,3, and 4 AQ procedure periodic reviews by December 31,1997.

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Encloswe I, Page 13 of15 1

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FACILITY ISSUE O TASK ID DUE DATE COMMITMENT DESCCIPTION STATUS-PORTS 30 CPI-POA-X30.12 Transition + 5 years ne PORC will res iew all piocedures designated as In-Hand and procedures that involve liquid UF6 handling activities within a 5-year period after the date that the NRC assumes regulatory authority for PORTS. This 9---

t=t pertams only to those procedures which nill 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, thereby satisfying this commitment for those specific procedures.

CPI-POA-X30.13 Transition All aspects of TSR 3.9 implementation and its associated tentacles shall be in place no later than the date.

Complete that the NRC assumes regulatory authority for PORTS. Procedures required by Technical Safety Requirement 3.9.1 shall be in place by the assumption of regulatory authority by NRC except as specified in the Compliance Plan.

32 CPI-POA-X32.01 12/31/96 Develop and implement procedures, including personnel training, for the scheduling and conduct ofinternal Oceed and supplier audits, including auditing the development, maintenance, adequacy, and effectiveness of the QAP, by December 31,1996.

CPI-POA-X32.02a 2/28S7 Develop and implement procedures, including personnel training, that define procurement, handling, and G osed storage activities for AQ-NCS items and services by December 31,1996.

CPI-POA-X32.02b 3/31S 7 Develop and implement procedures, including personnel training, that define procurement, handling, and storage activities for Q items and services by March 31,1997.

CPI-POA-X32.02c 12/3187 Develop and implement procedures, including personnel training, that define pw..a..t. handling, and storage activities for other AQ items and sers ices by December 31,1997.

33 CPI-POA-X33 01 6/30/96 ne emergency plan support documents will be upgraded.

Closed 34 CPI-POA-X34.01a 9/30/96 All tenant organization personnel will be given emergency preparedness General Employee Training.

O osed i

CPI-POA-X34.01b 6/30/96 Updated fosmal training will be given to emergency response personnel.

Complete CPI-POA-X34.01c 12/3166 Off-site emergency support personnel will be trained on the revised emergency plan and procedures as G osed appropriate by December 31,1996.

r 35 CPI-POA-X35.01 10/24S5 A quality control program including all elements necessary to ensure compliance uith 10 CFR 61.55 and G osed 10 CFR 61.56 will be implemented.

36 CPI-POA-X36.01 12/3166 Update existing depleted uranium handling, moving, stacking, and inspection procedures to current format O osed

)

and content requirements (see the compliance plan issue entitled ' Procedures Program") and provide training to affected personnel.

CPI-POA-X36.02 12/3166 Develop a process for use in scheduling the periodic visual inspections O osed 37 CPI-POA-X37.01a 8/1/96 ne current staffing allocations will be supplemented if necessary to meet working hour guidelines stating Gosed -

that an individual should not be permitted to work more than 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> in any 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period and no more than 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> in any 7 day period, excluding shift turnover time.

CPI-POA-X37.0lb 8/1/96 A revised TSR will be submitted to the NRC to add these guidelines to TSR 3.2.2 b.

O osed CPI-POA-X37.02a 12/31/96 USEC will supplement current stafTing allocations to meet its proposed working hour guidelines that state Complete that an individual should not be permitted to work more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period and no more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7 day period exclusive of shift tumover time.1. Page H of13

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FACILfTY ISSUE #

TASK ID DUE EATE CONT %IfDIENT DESCRIPTION STATUS PORTS 37 CPI-POA-X37.02b 12/3186 USEC will submitted a revised TSR to the NRC to add these guidelines to TSR 3.2.2.b at the time sufficient Closed staffmg is achieved to meet these guidelines.

38 CPI-POA-X38.01 Privatization The following executed documents required to assure adequate funding for USEC's portion of PORTS'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.

The above-listed documents will closely adhere to the recommended wording for such instruments set forth in NRC Regulatory Guide 3.66," Standard Format on and Content of Financial Assurance Mechanisms Required for Decommissioning under 10 CFR Parts 30,40,70, and 72."

39 CPI-POA-X39.01 5/26/97 The mechanical integrity program for maintenance and inspection PSM requirements will be implemented.

40 CPI-POA-X40.01 10/1/96 A review of system designs will be performed where operational trips and alarms coincide with the Closed setpoints for safety system actuation based on the same 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 redundancy or system modifications to climinate the redundancy. The results of this review will be submitted to the NRC for review and approval by October 1, 1996.

41 CPI D9A-X41.01 2/1/97 The documents referenced in Appendix A to SAR Chapter 1.0 will be reviewed, and a listing of specific Closed sections of the codes, standards, and NRC regulatory guidance documents to which PORTS is committed will be compiled. The results will be transmitted to NRC at least 30 days prior to the date that the NRC assumes regulatory authority for PORTS.

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

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

Routinely Manned Facilities: July 1,1997 CPI-POA-X44.01b 7/3188 Unalarmed facilities that have been identified as of June 10,1996, will be modified with the requNd homs and/or lights, as appropriate, or relocated to locations outside the 200-foot evacuation zone in accordance with the following schedule:

Routinely Unmanned Facilities: July 1,1998 Enclosure I, Page 13 of13

e ENCLOSURE 1 PGDP Action Status by Issue 17-Mar-97 FACILITY ISSUE #

TASK ID DEE DATE COMMITMENT DESCRIP110N STATUS PGDP.

01 CPI-POA COI.01 Transition Some of the activities necessary for USEC to implement this phased transition are described in this Complete Compliance Plan. USEC is currently developing additional detailed plans and schedules to implement the phased transition. Consistent with ROA rcquirements 3.2.2.2,332.6, and 3.423, 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.

CPI-POA-C01.02 Transition In the interest of assuring a safe, smooth transition from DOE to NRC regulatory authority, including a safe Complete transition from OSRs to TSRs, USEC will keep the DOE Regulatory Oversight Manager and the NRC fully informed of USEC plans, schedules, and the status of activities to implement the phased transition. De information USEC will provide will include detailed tasks, schedules. and milestones for completing the transition; identification of areas requiring mterface reviews and the schedules for performing such review; and the schedules for procedure development, personnel training, and operational readiness evaluations.

Except as identified in this Compliance Plan, all activities required to complete the transition from compliance uith DOE requirements to NRC regulations will be completed by the date NRC assumes regulatory authority. De transition to NRC regulatory oversight is scheduled to occur 120 days after the NMSS Director's decision regarding USEC's certification.

CPI-POA-C01.03 Transition The listing ofopen USEC commitments to DOE uill be provided to NRC by USEC on the date that NRC Complete assumes regulatory authority for PGDP.

02 CPI-POA-C02.01 2/15/97 He approved DOE site-wide Safety Analysis Report and supporting documentation will then be forwarded Complete to USEC by February 15,1997.

?

CPI-POA-C02.02 4/1/97 USEC will provide information required to complete the DOE site-wide Safety Analysis Report and will Complete.

provide technical reviews of the ongoing analyses to ensure that the analyses accurately reflect the facility configuration.

CPI-POA-C02.03a 8/I7/97 By no later than August 17,1997, USEC shall submit an amendment to their Certification Application which includes:

a) identification of all information, findings, and recommendations which indicate differences between the

. DOE site-wide Safety Analysis Report and the USEC Application for Certification.

CPI-POA-C02.03b 8/17/97 By no later than August 17,1997, USEC shall submit an amendment to their Certification Application which includes:

- an evaluation of the effects of those differences on the safety ofworkers, and off-site members of the public.

CPI-POA-C02.03c 8/17/97 Dy no later than August 17,1997, USEC shall submit an amendment to their Certification Application which includes:

- proposed modifications to the compliance certificate and/or facility, including proposed modifications to the Application SAR and TSRs.

Enclosure I, Page i of17

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FACIMFY ISSUE #

T.6 LID DOE DATE CO31MITMENT DESCRIPTION STATUS PGDP 02 CPI-POA-C02.04 8/17/97 At the same time the Application amendment is due, USEC shall also submit for NRC approval, its proposed resolution of matters contained in the DOE-approved site-wide Safety Analysis Report not incorporated by USEC in its request for amendment of their Application for Certificatioit CPI-POA-C02.05a 9/30/97 From September 30,1995, until NRC approves the submittals in paragraphs 3 and 4 above, changes made by USEC in accordance with DOE's ROA requirement conceming Unreviewed Safety Question Determinations (USQDs) or with 10 CFR 76 68 must be addressed either in the DOE SAR Upgrade results or in the amended safety analy sis report submitted by USEC based upon those results. The following will assure such changes are properly considered and addressed:

De plant configuration was considered to be frozen for the purpose of DOE's analysis on September 30, 1995.

CPI-POA-C02.05b 9/30/97 From September 30,1995, until NRC approves the submittals in paragraphs 3 and 4 above, changes made by USEC in accordance with DOE's ROA requirement concerning Unresiewed Safety Question Determinations (USQDs) or with 10 CFR 76.68 must be addressed either in the DOE SAR Upgrade results or in the amended safety analysis report submitted by USEC based upon those results. ne following will assure such changes are properly considered and addressed:

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

CPI-POA-C02.05c 9/30/97 From September 30,1995, until NRC approves the submittals in paragraphs 3 and 4 above, changes made by USEC in accordance with DOE's ROA requirement concerning Unreviewed Safety Question Determinations (USQDs) or with 10 CFR 76.68 most be addressed either in the DOE SAR Upgrade results or in the amended safety analysis report submitted by USEC based upon those results. The following will assure such changes are properly considered and addressed:

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

CPI-POA-C02.05d 4/30/98 From September 30,1995, until NRC approves the submittals in paragraphs 3 and 4 abow, changes made by USEC in accordance with DOE's ROA requirement concerning Unreviewed Safety Question De'erminations (USQDs) or with 10 CFR 76 68 must be addressed either in the DOE SAR Upgrade results or in the amended safety analysis report submitted by USEC based upon those results. The following will assure such changes are properly considered and addressed:

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

CPI-POA-C02 06 8/17/97 The update to the Application SAR will also reflect those commitments made by USEC to the NRC during the initial certification Application process as identified in the Application and the responses to NRC questions / comments.

03 CPI-POA-C03.01a 9/30/96 De C-333A and C-337A autoclave containment systems will be modified by installing three manual Closed actuation devices, one at the OMR door, one at the crane bay exit near the local cylinder yard, and one in the ACR which can be used to place the autoclaves into containment upon confirmation of a UF6 release.

He scheduled completion date for these actions (with the exception of NRC approval of the associated TSR) is September 30,1996.. Page 2 of17

FACILITY ISSI'E O TASKID DUE DATE COMMITMENT DESCRilmOM STATT'S PGDP 03 CPI-POA-C03.0lb 10/3 tN6 The C-333A and C-337A autoclave containment systems will be modified by installing three manual push G osed buttons, one at the OMR door, one at the crane bay exit near the local cylinder yard, and one in the ACR which can be used to place the autoclaves into containment upon confinnation of a UF6 release. The scheduled date for submittal of the TSR to the NRC is October 31,1996.

CPI-POA-C03.02 3/3N7 The control logic for the C-333A and C-337A Autoclave liigh-Pressure Isolation System uill be modified Complete such that upon reset of the containment signal, the valves will remain closed, but the valves can be opened by subsequent operator action.

CPI-POA-CO3.03 8/3 tN7 The pressure transmi:ters for the autoclave opening prevention and cylinder roll interlock systems in C-360 Complete will be replaced.

CPI-POA-C03.04 10/31N7 De pressure monitoring instrumentation serving the autoclave safety systems and defense-in-depth systems for C-333A, C-337A, and C-360 autoclaves will be replaced.

CPI-POA-C03.05 8/31N7 The UF6 detection systems for Zones I and 4 will be modified such that upon detection of a UF6 release, multiple valves (FV *50, *52, and '47 from Zone I and FV *47 and *49 from Zone 4) will be closed on the transfer and/or sampling piping.

CPI-POA-C03.06 12/31/96 Performance criteria and a test plan will he developed to demonstrate whether the nitrogen backup can Complete close the cylinder valve in 30 seconds in C-310, C-315, and C-360. Further design requirements will be completed pending the outcome of this testing.

CPI-POA-C03.07 8/31M7 Add a low instrument air pressure switch to the autoclaves in C-360 to initiate containment upon loss of instrument air.

CPI-POA-C03.08 10/31N7 Modify the controls for the autoclaves in C-360 to prevent them from being inadvertently opened when an Autoclave fligh-Pressure Isolation System containment signal is present.

CPI-POA-C03.09 12/31N6 A code interpretation from the ASME Code Committee will be obtained regarding the C-360 parent-G osed daughter transfer system and the need for pressure relief on the transfer manifold. Based on this interpretation, the need for modifications to the system or operations will be assessed. Both the ASME Code interpretation and the assessment results will be submitted to NRC for rtview and approval.

CPI-POA-C03.10a 12/31N6 Modifications to allow a pressure decay test to be perfomed separately for the inner and outer containment Complete valves, and assurance that backpressure does not mask leaks, for all autoclaves in C-333A. C-337A, and C-360 will be complete by December 31,1996.

CPI-POA-C0310b 12/31N6 A revised TSR to reflect the new [ inner and outer containment valve testing] configuration will be C osed submitted to NRC by December 31,1996.

04 CPI-POA-C04.01a 9/30N6 The dual hoist / trolley and control systems on the East and West C-360 Toll Transfer and Sampling Facility G osed bridge crancs will be replaced uith a single polar hoisttolley and control system consistent with the other PGDP cranes that handle liquid UF6 cylinders. The schedule for completion of the upgrade for the east bridge crane is September 30,1996.

CPI-POA-C04.0lb 9/30N6 The dual hoist / trolley and control systems on the East and West C-360 To!! Transfer and Sampling Facility Closed bridge cranes will be replaced with a single polar hoist / trolley and control system consistent with the other PGDP cranes that handle liquid UF6 cylinders. The schedule for completion of the upgrade for the west bridge crane is September 30,1996. Page 3 of17

FACILITY ISSUE O TASKID DCE DATE CO%I3 TIT 3f ENT DESCRIPTION STATUS PGDP 05 CPI-POA-C05.01 12/2/96 All operations u ith >2 wt % 235U and all other new operations that require NCS approval will have O osed properly documented and implemented NCSAs and NCSEs that have been approved in accordance with the NCS program requirements contained in the approved Certificate prior to startup.

CPI-POA-C05.02 12/2/96 For existing operations with I wt % or higher 235U and 15 grams or more 235U where formal G osed documentation is incomplete or unavailable, USEC will prepare the necessary NCSE and NCSA documentation, approve it in accordance with the NCS program requirements contained in the approved Certificate, provide information flow-down to operating procedures and work-site postings, and verify implementation of the procedures and postings.

CPI-POA-C05.03 10/31/96 De procedural changes to resolve the administrative noncompDances in the nuclear criticality safety G osed program will be completed by October 31,1996.

CPI-POA-C05.04 Transition All aspects of Technical Safety Requirement 3.9 implementation and its associated tentacles for NCS will Complete be in place no later than the transition to NRC regulatory oversight.

06 CPI-POA-C06.01 12/2N6 The Compliance Assessment Team uas established in March 1995 to verify the flow-down of the Complete requirements from each existing NCSA. Heir surveillance plan uas completed in June 1995. De field verification (of the roughly 300 procedures and 200 postings) will be completed and documented by December 2,1996.

07 CPI-POA-C07.01 1/31/96 Criticality accident alarm systems will be installed in Buildings C-720 and C-728, or all components Closed containing uranium enriched to >l wt % 235U will be removed from the unalarmed areas 08 CPI-POA-COS 01 2/29/96 Analyses that provide the technicaljustification for not providing criticality accident alarm system coserage O osed in designated areas of the plant were developed. He analyses have been submitted to NRC under separate cover from the application. The analyses include (1) verification of the adequacy of the existing criticality accident alarm system and its detector locations for detecting a criticality accident and (2) justification that detectors are not required for monitoring other areas of the plant.

CPI-POA-C08.02 6/30M8 Permanent criticality accident alarm detector clusters will be installed, relocated, and/or reconditioned in Building C-710 to replace the existing portable detectors in Building C-710.

09 CPI-POA-C09.01 10/24/95 The required procedure changes will be implemented.

O osed CPI-POA-C09.02 10/1/96 Plant procedures will be issued by October 1,1996, to incorporate the annual radiation protection program G osed review requirement from SAR paragraph 53.I.3.

10 CPI-POA-C10.01 Transitics Building wo* areas previously posted as " Regulated Areas" will be re-posted to reflect the current Complete

" Restricted Area" and " Contamination Control Zone" designations prior to NRC assuming regulatory oversight of PGDP.

CPI-POA-C10.02 12/31/96 Restricted areas within USEC leased space which contain unlattled, but potentially radioactive, material G osed containers will be posted with signs stating that each unlabeled container may contain radioactive material.

CPI-POA-C10.03 11/30/97 Necessary radiological characterization and re-posting ofleased areas within the PGDP site boundary will be completed by November 30,1997.

1I CPI-POA-Cl 1.01 10/31/95 Replacement sources that meet the *5% with NIST traceability standard uill be requisitioned.

O osed CPI-POA-Cl1.02 5/3/97 Within 12 months of receipt of the *5% sources, all affected instruments will be recalibrated using the new G osed standards.. Page 4 of17

4 FACILITY ISSUE #

TASK ID DUE DATE CO31311T31ENT DESCRIPTION STATUS PGDP 12 CPI-POA-Cl2.01 10/24S5 USEC will provide NVLAP-accredited dosimetry for those relatively few individuals who are required to Gosed be monitored under 10 CFR 20.1502.

13 CPI-POA-Cl3.01 8/31/96 De Nuclear Safety Upgrade project provides for an upgrade of the fire alarm system to enhance the overall Closed reliability of the sy stem. De project includes scheduling, equipment procurement, installation, system testing, and personnel training.

14 CPI-POA-Cl4.01 11/22/96 A Nuclear Safety Upgrade project provides for refurbishment of two of the electric fire water pumps. These Closed two pumps are in excess of 30 years old. His project includes scheduling, equipment procurement, installation, and system testing.

CPI-POA-Cl4.02 3/31N7 A Nuclear Safety Upgrade project provides for the 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 symems are located will be supplied from the IIPFWS. His project includes scheduling, equipment procurement, installation, and system testing.

I5 CPI-POA-C15.01 12/3IS5 He manual equipment needs and locations will be identified by the Authority llaving Jurisdiction, and a Closed plan will be developed and implemented to purchase and install the equipment.

16 CPI-POA-C16.01 Also see issue 27 De fire protection procedure review and upgrade program is in implementation. Fire protection procedures, O osed including each of the identified procedures, are being created or revised as part of that program to ensure that the level of technical and pmcess control detail will be sufficient to ensure commitment compliance.

Except for procedure UE2-SS-FS1031, Fire Protection Requi:ements for Welding, Burning, and llotwork Practices, the fire protection procedu es identified above for upgra e and specifically related to the application commitments will be upgraded and implemented.

CPI-POA-C16.02 12/3166 Procedure UE2-SS-FS1031 will be revised and implemented by December 31,1996.

O osed CPI-POA-C16.03 6/1/97 Hose fire protection procedures identified for upgrade and not directly related to the emabucuts identified in the application will be upgraded.

17 CPI-POA, Page 9 of17 w

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TASK ID DUE DATE COMMITMENT DESCRIPTION STAR'S PGDP 23 CPI-POA-C23.01 12/31S 7 Procedures addressing the operations program elements discussed in Section 6.5 of the Safety Analysis Report will be developed or revised, associated initial training materials will be developed, and appropriate personnel will receive initial training by December 31,1997, consistent with the plan of action and schedule of the Compliance Plan Issue 27 ' Procedures Program?

CPI-POA-C23.02 6/3087 Continuing training material and qualification requirement developmc aill be completed and appropriate personncI trained and qualified for Cascade Operater, Chemical Operator, Operations Manager / Supervisor, and Plant Shift Superintendent positions by June 30,1997, consistent with the plan of action and schedule of the Compliance Plan issue entitled " Systems Apprcach to Training?

CPI-POA-C23.03 12/31/97 Continuing training material and qualification requirement development will be completed and appropriate personnel trained and qualified for Cascade Coordinator position by December 31,1997, consistent with the plan of action and schedule of the Compliance Plan issue entitled " Systems Approach to Training."

24 CPI-POA-C24.01 6/3087 Training programs will be developed and implemented 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 thosejob classifications initially identified under the Nuclear Safety Upgrade Project (as listed in Description of Noncompliance), training for the job incumbents uill be completed by June 30,1997.

CPI-POA-C24.02 6/27!96 A detailed schedule for the completion of all training programs not in compliance with 10 CFR 76.95 will Closed be issued by 6/27S6.

CPI-POA-C24.03 6/30/97 For the additionaljob classifications not previously included in the Nuclear Safety Upgrade Project. (i.e.,

systems engineers, cascade coordinators, and NCS engineers / specialists), the job analyses and training program design have not been completed. The following actions will be completed by June 30,1997.

- Revise mad validate the existing job task lists.

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

- Develop specific Icaming objectives from the job performance requirements.

- Develop training materials, CPI-POA-C24.04 12/31N7 Training for those holding these additionaljob classifications at the time the program is implemented will be completed by December 31,1997.

CPI-POA C24.05 6/30 S 8 Training programs for the above job classifications list, with respect to AQ activities, will be developed and implemented by June 30,1998, following completion ofidentification of AQ items (see Compliance Plan issut 21, " Plant Changes and Configuration Management") and associated procedures (see Compliance Plan issue 27," Procedures Program")-

25 CPI-POA-C25.01a S/IS6 A nuclear regulatory event reporting procedure meeting the event notification and n porting requirements Closed required by the USEC application, and an es ent investigations procedure that defines the event investigation process and assigns responsibilities and authority for its implementation will be appmved by May 1,1996 Training on these documents will be conf eted prior to the date NRC assumes regulatory oversight at Complete l

CPI-POA-C25.0lb ansition PGDP.

CPI-POA-C25.Olc Transition De procedures will become effective on the date NRC assumes regulatory oversight at PGDP.

Complete, Page 10 of17

me FACILITY ISSUE #

TASK ID DUE DATE COM3tITMENT DE1GIPTION STATUS PGDP 26 CPI-POA-C26 01a.1 6/30S6 Records being maintained by the plant organizations and the D&R Group will be verified to determine the O osed storage locations of these records and the methods of protection being employed to preserse these documents.

CPI-POA-C26.01a.2 6/30S 6 The final tally of records identified in item (1) above will be evaluated against applicable requirements and Gosed then catalogued as to their record type, categorization, and retention. This information will be charactertred in a combined PORTS and PGDP Uranium Enrichment Records Manual that will be utilized by both sites.

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

CPI-POA-C26.01a.3 6/30/96 A records management turnover schedule has been drafted and submitted to the functional G osed organizations which prioritizes the turnover based on the record's importance to the safety and quality of plant operations.

CPI-POA-C26.01a.4 6/30 S 8 Records being maintained in the organizations will not be tumed over to the D&R Group immediately but will be retained by the responsible organization until the D&R Group can process them. Pre-existing records u ill be turned over and incorporated into the records management system by June 30,1998.

CP!-POA-C26.01a.5 6/30/96 A new electmnic records indexing database based on the evaluation conducted in item (2) above and item G osed 1.d)(I) below will be put into service by June 30,1996.

CPI-POA-C26.Olb 3!31/97 For Legacy Records: The PGDP Configuration Management Program implementation procedures will address the measures required to be taken if source information needs to be developed and documented. See issue 21,

• Plant Changes and Configuration Management."

CPI-POA-C26.01c 6/30/98 Records being maintained in the organizations will be turned cver to the D&R Group in accordance with the records management turnover schedule identified in item ta)(3) above. Pre-existing records required to be maintained under the USEC Quality Assurance Program will be tumed over and incorporated into the revised records management system in accordance with the approved records management tumover schedule. 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.

CPI-POA-C26.01d.1 6/30/96 The PGDP computerized records indexing system will be evaluated to make certain that the necessary G osed information required by each organization for its records is consistently applied to ensure the ready retrievability of the records.

CPI-POA-C26.0ld.2 6/30/98 Computer codes and test result data used to directly or indirectly support the PGDP process systems will be submitted to the D&R Group in accordance with the turnover schedule identified in item (a)(3) above.

CPI-POA-C26.02a.1 6/30/96 Documents being maintained by the plant organizations and the D&R Group will be verified.

O osed CPI-POA-C26.02a.2 6/30/96 A document control tumover schedule has been drafted which prioritizes the turnover based on the G esed document's importance to the safety and quality of plant operations.

CPI-POA-C26.02a.3 6/30/96 The document control syst m will be updated on an ongoing basis to provide controlled distribution lists G osed and to control the actual distribution of documents under the control of the D&R Group commencing June 30,1996.

CPI-POA-C26.02a.4 6/30/98 Documents within the scope of the document control program, according to the application. will be identified. Documents being maintained in the organizations will not be tumed over to the D&R Group but will be retained by the responsible division until the D&R Group can process them. Pre-existing documents will be turned over and incorporated into the document control system by June 30,1998.

Enclosure I, Page 1i ofI7

• O FACILITY ISSUE #

TASKID Dl'E DATE CO3131tTMENT DESCRIPTION STATUS PGDP 26 CPI-POA-C26 02a.5 680/98 The final tally of documents identified in items (1) and (3) above will be catalogued as to their document Complete type, distribution requirements, and information to provide an index for case of retrievability.

CPI-POA-C26.02a 6 6 SON 6 The new electronic document rantrol inventory system that identifies the controlled copy holder number Closed and custodians, storage location, and retrieval capability will be put into service.

CPI-POA-C26.02b 3 SIN 7 For Legacy Documents: The plan of action and schedule provided in 1(b) above will also resolvt this item.

27 CPI-POA-C27.01 781N6 Dy July 31,1996, incorporate into the Procedure Control Process procedure the SAR-6.11.4.1 criteria for O osed use by responsible management in complying with TSR 3.9 by identifying applications requiring additional written procedures.

CPI-POA-C27.04 6flN6 Document the criteria for use in determining u hen work must be stopped because a procedure cannot be O osed performed as witten.

CPI-POA-C27.06 Transition By the date that the ?:RC=-sumes regulatory authority for PGDP, incorporate into the Procedure Control G osed Process procedure the SAR-6.11.4.5 criteria for identifying procedures that TSR 3.9 requires review by the PORC.

CPI-POA-C27.08 Transition incorporate action statements and operating limits from the Technical Safety Requirements irdo operational Complete procedures by the date that the NRC assumes regulatory authority for PGDP.

CPI-POA-C27.09a 6/28N6 Issue the required operational policy statements and implement new or updated procedures (including G osed required training) to fully implement the Quality Assurance Program or other activities identified in the application in accordance with the following schedule:

- Operationa! policy statements: June 28,1996 CPFM)A-C27.09b 128166 issue the required operational policy statements and implement new or updated procedures (including Complete required training) to fully implement the Quality Assurance Program or other actisities identified in the application in accordance uith the following schedule:

- Level 2,3, and 4 AQ-NCS procedures (unless covered by item 8): December 31,1996 CPI-POA-C27.09c 3 SIN 7 Issue the required operational policy statements and implement new or updated procedures (including required training) to fully implement the Quality Assurance Program or other activities identified in the application in accordance with the following schedule:

- Level 2,3, and 4 Q procedures (unless covered by item 8): March 31,1997 CPI-POA-C27.09d 128IN7 Issue the required operational policy statements and implement new or updated procedures (including required training) to fully implement the Quality Assurance Program or other actisities identified in the application in accordance with the following schedule:

- Level 2,3, and 4 AQ and NS procedures: December 31,1997 CPI-POA-C27.10 12S!!97 Complete all overdue Level 2,3, and 4 AQ procedure periodic reviews by December 31,1997.. Page 12 of17

4 FACILITY ISSUE O TASK ID DUE DATE CO%I3flT3f ENT DESCRIPTION STATUS PGDP 27 CPI-POA-C27.11 Transition + 5 years The PORC w ill review all procedures designated as In-l!and and procedures that involve liquid UF6 handiing activities within a 5-year period after the date that the NRC assumes regulatory authority for PGDP. His commitment pertains only to those procedures uhich will not otherwise be reviewed by the PORC (as required by Section 6.I1.4.1), 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, thereby satisfying this commitment for those specific procedures.

CPI-POA-C27.12 Transition All aspects of TSR 3.9 implementation and its associated tentacles shall be in place no later than the date Complete that the NRC assumes regulatory authority for PGDP. Procedures required by Technical Safety Requirement 3.9.1 shall be in place by the assumption of regulatory authority by NRC except as specified in the Compliance Plan.

29 CPI-POA-C29.01 12/31/96 Develop and implement procedures, including personnel training, for the scheduling and conduct ofinternal G osed and supplier audits, including auditing the development, naintenance, adequacy, and effectiveness of the QAP, by December 31,1996.

CPI-POA-C29.02a 12/3166 Develop and implement procedures, including personnel training, that define procurement, handling, and Closed storage activities for AQ-NCS items and services by December 31,1996.

CPI-POA-C29.02b 3/31 S 7 Develop and implement procedures, including personnel training, that define procurement, handling, and storage activities for Q items and services by March 31,1997.

CPI-POA-C29.02c 12/31/97 Develop and implement procedures, including personnel training, that define procurement, handling, and storage activities for non "AQ-NCS" items and services by December 31,1997.

30 CPI-POA-C30.01a 1/15S7 The three existing sirens will be replaced with a new siren system to enhance reliability and ensure better O osed coverage of the inunediate notification area. All poles and sirens will be installed by January 15,1997.

CPI-POA-C30.Olb 3/15/97 An analysis of the number, capabilities, and coverage of the new sirens will be performed. The new system u ill be installed and operational by March 15,1997.

l 31 CPI-POA-C3I 01 4/30S7 The existing public address system, which includes the central public address switching console, speakers, and amplifiers, will be upgraded to provide more reliable service to the plant and additional expansion capabilities.

32 CPI-POA-C32.01 6/30S 6 The emergency plan support documents will be upgraded to include the hazardous chemical requirements.

O osed 33 CPI-POA-C33 01 6/30/96 Updated formal training will be given to emergency response personnel.

O osed 34 CPI-POA-C34.01 10/24 S 5 A quality control program including all elements necessary to ensure compliance with 10 CFR 61.55 and C osed 10 CFR 61.56 uill be implemented.

35 CPI-POA-C35.01 12/31/96 Update existing depleted uranium cylinder handling, moving, and stacking procedures to current format and C osed content requirements (see the compliance plan issue entitled " Procedures Program") and provide training to affected personnel., Page 13 ofI7

e As FACILITY ISSUE C TASKID DUE DATE CmlMITMENT DESCE.lPTION STATUS PGDP 35 CPI-POA-C35.02 12/31/96 issue procedures required to implement the baseline and periodic (i.e., every four years or less) depleted Closed uranium cylinder visual inspections and provide training to affected personnel. These visual inspections will (1) check for evidence of cylinder leakage; (2) verify that the cylinders are properly oriented (l.c.,

valves in top center position); (3) verify that the cylinders are stacked correctly (i e., not in contact with portions of adjacent cylinders such that damage might occur); (4) check external cylinder surfaces for dents, budges, cracks, tears, gouges, and excessive scale or rust; and (5) verify that the cylinder weep hole is not plugged.

CPI-POA-C35.03 12/31/96 Develop a process for use in scheduling the periodic visual inspections noted in item 2, above.

Closed CPI-POA-C35.04 12/31/97 For all USEC depleted uranium cylinders that were placed in storage prior to implementation of the documented baseline inspection procedure noted in item 2 sbove, perform a baseline inspection in accordance with that procedure.

36 CPI-POA-C36.01a 8/30/96 Based on a Directive for Information provided to USEC by DOE on September 22,1995, the USEC Closed evaluation of the currently available information from the DOE sakty analysis upgrade effort related to seismic capabilities at the facility completed on October 23,1995, the DOE evaluation of the USEC response dated October 31,1995, and USEC's proposed realution documented on January 9,1996, the following actions are being implemented to ensure the protection of the workers and public heahh and safety:

- Until the completion of modifications discussed below, operations in Buildings C-331 and C-335 mill be limited to subatmospheric pressure within the enrichment cascade equipment.

CPI-POA-C36.01bl 8/30/96 Based on a Directive for Information provided to USEC by DOE on September 22,1995, the USEC Closed evaluation of the currently available infonnation from the DOE safety analysis upgrade efTort re!ated to seismic capabilities at the facility completed on October 23,1995, the DOE evaluation of the USEC response dated October 31,1995, and USEC's proposed resolution documented on 1anuary 9,1996, the following actions are being implemented to ensure 15e protection of the workers and public health and safety:

- Operations [ Cascade Coordinators] personnel will be instructed on the specific emergency procedures for shutting down the affected enrichment cascade equipment and building ventilation systems following a seismic event.

, CPI-POA-C36.01b2 12/31/96 Based on a Directive for Information provided to USEC by DOE on September 22,1995, the USEC Closed cvaluation of the currently available information from the DOE safety analysis upgrade etTort related to seismic capabilities at the facility completed on October 23,1995, the DOE evaluation of the USEC response dated October 31,1995, and USEC's proposed resolution documented on January 9,1996, the following actians are being implemented to ensure the protection of the workers and public health and safety:

- Operations [PSS Group) personnel will be instructed on the specific emergency procedures for shutting down the afTected enrichment cascade equipment and building ventilation systems following a seismic event.

Drclosure 1. Page H of17

e e

e FACILITY ISSUE #

TASKID DUE DATE CO%INIIT31ENT DESCC.IPTION STATUS PGDP 36 CPI-POA-C36.01c 8/30/96 Based on a Directive for Information provided tc USEC by DOE on September 22,1995, the USEC Closed evaluation of the currently available information from the DOE safety analysis upgrade effort related to seismic capabilities at the facility completed on Octueer 23,1995, the DOE evaluation of the USEC response dated October 31,1995, and USEC's proposed resolution documented on January 9,1996, the following actions are being implemented to ensure the protection of the workers and public health and safety:

- Building access will be limited to only those individuals essential to operatior s, inspectice.s, or those personnel performing the modifications until they are complete.

CPI-POA-C36.Old 7/31N7 Based on a Directive for Information provided to USEC by DOE on September 22,1995, the USEC evaluation of the currendy available information from the DOE safety analysis upgrade effort related to seismic capabilities at the facility completed on October 23,1995, the DOE evaluation of the USEC response dated October 31,1995, and USEC's proposed resolution documented on January 9,1996, the following actions are being implemented to ensure the protection of the workers and public health and safety:

- h1odifications to increase the seismic capability for floor and roof sections in Buildings C-331 and C-335 will be completed by December 31,1997,(pending DOE approval of USEC request with justification for a delay from July 31,1997 -current commitment date to DOE).

CPI-POA-C36.02 Transition At the tirne of transition from DOE regulatory oversight to NRC regulatory oversight, USEC will inform Complete 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.

CPI-POA-C36.03 When Available Documentation prepared for the design of the modification and other relevant information concerning implementation will be provided to the NRC, upon issue, for inforrnation and review.

CPI-POA-C36.04 12/IN7 By December 1,1997, USEC shall submit for NRC approval an updated seismic risk analysis for the Paducah plani site. Any proposed modifications that may result from this analysis shall be subject to a backfit analysis pursuant to 10 CFR 76.76(b). The analysis shall:

- Consider all availabic regional and site-specific data published by the U.S. Geological Survey.

- Provide an estimate of the peak grotmd acceleration for a seismic event with a 250-y ear retum period. If the estimate is greater than 0.15g, then the return period for a 0.1 Sg event shall also be estimated.

37 CPI-POA-C37.01 12/31/97 The required procedure will be developed and implemented using the process descr; bed in Application section 6.11. Procedures to implement the trending activities are being developed as part of the procedure upgrades within the Nuclear safety Upgrade Project.

38 CPI-POA-C38.01 5/30/96 The data obtained from the first six months operation of the new high-volume ambient air samplers will be Cimed reviewed in hiay 1996. By klay 30,1996, baseline embient air radionuclide levels for routine plant operations, based on the 6-month data, will be established for each high-volume ambient air sampling location. Using the baseline levels, action levels will be established by hlay 30,1996 for requiring additional analyses and, if necessary, investigation of the cause for exceeding an action level.

CPI-POA-C38.02 6/30/97 in 1997, a comparison of the EDE calculated using 1996 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 at the time of the PGDP submission ofits 1996 NESILAP report to the DOE (i.e., June 30, 1997).

Enclosure !, Pap 15 of17

1. 4 FACILITY ISSUE #

TASKID DUE DATE CO313 TIT 3 TENT DESCRIPTION STATUS PGDP 39 CPI-POA.C39.01 Privatization The following executed documents required to assure adequate funding for USEC's portion of PGDP's decontamination and decommissioning costs will be submitted to the NRC at the time USEC privatizatbi occurs:

- an executed sinking fund arrangement,

- a standby trust agreement, and/or

- a payment surety bond.

De above-listed documents u ill closely adhere to the recommended wording for such instruments set forth in NRC Regulatory Guide 3.66, ' Standard Format on and Content of Financial Assurance hiechanisms Required for Decommissioning under 10 CFR Parts 30,40,70, and 72."

40 CPI POA-C40.01 5/26M7 ne mechanical integrity program for maintenance and inspection PShi requirements will be implemented.

4i CPI-POA-C41.01 8G0/96 Revise the applicable procedures to incorporate the requirement to verify the differential pressure checks on Closed the IIEPA filters used on local ventilation systems to control worker exposure.

CPI-POA-C41.02a 600S7 IIEPA filter systems will be evaluated and those determined to be required will be periodically tested as described in SAR Section 5.3.2.10. If necessary, IIEPA filter systems will be modified to allow the performance or passing of the required periodic testing or inspection. Documentation to justify reclassify ing (to non-flEPA filter system status) or retention of any llEPA filter systems u til be developed in Systems Engineering and approved by the hianagers of Radiation Protection and Nuclear Safety.

CPI-POA-C4 I.02b 680/97 The applicable procedures uill be revised to flow-down the IIEPA filters systems test and inspection requirements.

42 CPI-POA-C42.01a 3GS7 he current stalling allocations will be supplemented if necessary to meet working hour guidelines stating Complete that an individual should not be permitted to work more than 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> in any 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period and no more than 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> in any 7 day p;riod, excluding shift tumover time.

CPI-POA-C42.Olb 6f28S6 A revised TSR will 1:e subniitted to the NRC to add these guidelines to TSR 32.2.b.

O osed CPI-POA-C42.02a 3G1/97 USEC uill supplement current stafYing allocations to 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 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period and no more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7 day period exclusive of shift tumover time.

CPI-POA-C42.02b 3G1/97 USEC will submitted a revised TSR to the NRC to add these guidelines to TSR 3.2.2 b at the time sufficient stafling is achieved to meet these guidelines.

43 CPI-POA-C43.01 5/26/97 DOE and Third-Party tenants will notify USEC before hazardous chemicals, including UF6 and iIF4, are introduced onto the site. All initial process hazards analyses arc to be completed by hiay 26,1997.

44 CPI-POA-C44.01 12GI/97 A review of system d signs uill be performed where operational trips and alarms coincide with the setpoints for safety system actuation based on the same monitored parameter and the same equipment actuated. Where redundant operational and safety system actuations exist. corrective action will be identified that may includejustification either for the redundancy or system modifications to eliminate the redundancy. He results of this review will be submitted to the NRC for review and approval by December 31,1997.. Page 16 ofI7

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FACILITY ISSUE #

TASK ID DUE DATE CONIMITMENT DESCRIPTION STATUS PGDP 45 CPI-POAC45.01 2/IS7 He documents referenced in Appendix A to SAR Chapter 1.0 will be reviewed, and a listing of specific G osed sections of the codes, standards, and NRC regulatory guidance documents to which PGDP is committed will be compiled. He results will be transmitted to NRC at least 30 days prior to the date that the NRC assumes regulatory authority for PGDP.

46 CPI-POA-C46.01 12/15S 8 Plant modifications will be initiated to ensure that the CAAS alarm homs are capable of being heard throughout the afTected areas of the process buildings.

48 CPI-POA.C48.01a 8/30/96 He limiting specific values for battery performance listed in the TSR will be reconfirmed and documented.

Oosed either through engineering analysis, safety demonstration, or a combination of both methods, and will be verified by subsequent independent review to pros ide adequete margin for determining the operability of the cascade cell trip function.

CPI-POA-C48.0lb 9/29 S 6 If new limiting specific values are determined as a result of this analysis and/or demonstration, then USEC G osed will submit a revised TSR and TSR basis statement within 30 days of verifying these new values.

CPI-POA-C48.02a 8/30/96 The limiting specific values for air pressure requirements for the *000" air circuit breakers will be c osed reconfirmed and documented, either through engineering analysis, safety demonstration, or a combination of both methods, and will be verified by subsequent independent review to provide adequate margin for determining the operability of the cascade cell trip function.

CPI-POA-C48.02b 9/29 S 6 If new limiting specific values are determined as a result of this analysis and/or demonstration, then USEC O osed will submit a revised SAR section 3.9.l.3.2 within 30 days of verifying these new values.

49 CPI-POA-C49.01a 1/3167 USEC will develop and complete a program to relate the response of UF6 leak detectors to manual test O osed methods and to the detection of an actual UF6 leal The scheduled date for developing a testing methodology plan is January 31,1997.

CPI-POA-C49.Olb 7/31/97 USEC will develop and complete a program to relate the response of UF6 leak detectors to manual test methods and to the detection of an actual UF6 leak The scheduled date for developing a field test method for the detectors is July 31,1997.

CPI-POA-C49.01c 7/31/98 USEC will develop and complete a program to relate the response of UF6 leak detectors to manual test methods and to the detection of an actual UF6 leak. The schedu!cd date for completing the initial periodic testing of the detectors is July 31,1998.

50 CPI-POA-C50.01 12/15S 8 Evacuation homs (for those unalarmed buildings where nearby CAAS horns cannot be adequately heard) and/or lights will be installed in the unalarmed buildings located within the evacuation area of CAAS-clustered buildings, or the unalarmed buildings will be removed from the evacuation area. Rese horns anfor lights 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 with the required homs and/or lights, as appropriate, or relocated to locations outside of the evacuation area by December 15,1998.

Enclosure I, Page 17 of17

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