ML20137D560
| ML20137D560 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant, Paducah Gaseous Diffusion Plant |
| Issue date: | 03/25/1997 |
| From: | Yawar Faraz NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Pierson R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9703260216 | |
| Download: ML20137D560 (41) | |
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MEMORANDUM TO:
Robert Pierson, Chief Special Projects Branch Division of Fuel Cycle Safety 4
and Safeguards, NMSS FROM Yawar Faraz, Project Manager briginal Signed By Enrichment Section Special Projects Branch Division of Fuel Cycle Safety and Safeguards, NMSS
SUBJECT:
MEETING
SUMMARY
FOR REGULATORY ISSUES GROUP MEETING OF MARCH 12,1997, AT THE PORTSMOUTH GASEOUS DIFFUSION PLANT (PORTS)
On March 12,1997, Yawar Faraz and Robert Pierson from the Special Projects Branch, Nuclear Regulatory Commission (NRC) and Charlie Cox, Senior NRC Resident inspector for PORTS, met with the United States Enrichment Corporation (USEC) and the Department of Energy (DOE) at PORTS in Piketon, Ohio, to discuss regulatory issues. NRC discussed their proposed changes to Part 76 and the status of the staff's Backfit Procedures for the gaseous diffusion plants. USEC and DOE presented the status of High Enriched Uranium refeed activities being conducted at PORTS. USEC presented the status of privatization, certificate amendment requests and closure of Compliance Plan issues. The agenda, list of h
attendees and handouts are attached. The next regulatory issues meeting is tentatively scheduled for June 11,1997, at PORTS.
Attachments: (1) Agenda (2) List of Attendees h%
hhh (3) Handouts Dockets 70-7001,70-7002 DISTRIBUTION: x' It Dockets 70-7001,70-7002 NRC File Center PUBLIC NMSS r/f FCSS r/f SPB r/f KO'Brien, Rlll CCox, Rlll GShear, Rlli MHorn RPierson EBrach ETen Eyck WSchwink, FCOB G:\\TRPRPT1.YHF OFC SPB f
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R REGULATORY ISSUES GROUP MEETING AGENDA MARCH 12,1997 LEADERSHIP CONFERENCE ROOM PORTSMOUTH, OHIO 1:00 PM Introductions - DOE /USEC/NRC HEU Activities - USEC/ DOE Refeed Status and X-705 Cylinder Cleaning Status TSR Status Upcoming Inspections Status of Privatization - USEC NRC Activities - NRC Inspections Changes to Pan 76 Internal Guidance / Procedures TSR Change Request Status - USEC PORTS Initiatives - USEC Compliance Plan Status Review - USEC Overview Autoclave Upgrades NCS Procedures Upgrades Criticality Accident Alarm for Nearby Buildings NMCA Date and Location of Next Meeting
3ENT BY: DOE
- 3-19-97 ; 13:28 ; REGULATORY OVERSIGHT-301 415 5370;# 2/ 3 c
SHEET f _OF _2 ATTENDANCE SHEET Portsmouth Gaseous for g',997 Diffusion Plant REGULATORYISSUES
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COMPLIANCE PLAN STATUS UPDATE t
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i REGULATORY ISSUES MEETING i
March 12,1997 I
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Total Non-Compliance issues 49 57 4
Completed issues 23 23 (Completed issues Closed By 16 15 DOE)
Open issues Due by 5/30/97 1
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- Chemical Safety Mechanical Green Yellow Integrity Program (X39/C40) l B
- Fire Protection Water System NA Green Reliability (C14) j o Public Warning Sirens and I
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Controls (C30) i
- Public Address System (C31)
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' Administrative Controls on Complete Green Overtires (X37/C42)
- DOE Chem Safety and 3rd Party Use of Hazardous Chemicals Complete Green (X20/C43) l l
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N HESCRIPTION Olt OPEN COMPI LANCE PI,AN ISSUFS PORTShl0UTil ISSUE NO.
DESCRIPTION OF ISSUE DUE DA TE FOR i
COMPLETION r
2 Update the Application SAR 4/30/98 f
3 Autoclave Upgrades 2/1/2001 7
IIEPA Filter Systems Testing 6/30/97 9
Nuclear Criticality Safety Approval Implementation 3/3/2002 II Exceptions for CAAS.
7/1/98 13 Posting of Radioactive Materials 12/31/98 f
17 Fire Protection Procedures and llot Work Permit Program 3/3/2002 18 Emergency Packets 6/30/97 21 Management Controls 3/3/2002 23 Plant Changes and Configuration Mangement 3/3/2002 24 Maintenance Program 3/3/2002 25 Operations Program 12/31/97 26 Systems Approach to Training 6/30/98 29 Records Management and Document Control Program 12/31/98 30 Procedures Program 3/3/2002 32 Quality Assurance Program 12/31/97 II.
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DESCRIPTION OF OPEN COMPLIANCE PLAN ISSUES PORTSMOUTH ISSUE NO.
DESCRIPTION OF ISSUE DUE DATE FOR COMPLETION 38 Decommissioning Funding Program Privatization 39 Chemical Safety Mechanical Integrity Program 5/26/97 42 UF6 Leak Detector Sensitivity Testing 7/31/97 44 Criticality Accident Alarm for Nearby Buildings 7/31/98 Al Material Control and Accountability Manuals and Procedures 10/31/97 A2 Receipts Based on Measured Values 9/30/97 A4 Possession of Uranium Enriched to > 10% U-235 1/31/99 l
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s-4 DESCRIPTION OF OPEN COMPLIANCE PLAN ISSUES PADUCAH ISSUE NO.
DESCRIPTION OF ISSUE DUE DATE FOR COMPLETION 2
Update the Application SAR 4/30/98 3
Autoclave upgrades 10/31/97 8
Exceptions for CAAS 6/30/98 10 Posting of Radioache Materials 11/30/97 14 Fire Protection Wate System Reliability 3/31/97 16 Fire Protection Procedures and llot Work Permit Program 6/1/97 17 Fire Protection Pre-Fire Plans 6/30/97 19 Management Controls 3/3/2002 21 Plant Changes and Configuration Mangement 3/3/2002 22 Maintenance Program 6/30/98 23 Operations Program 12/31/97 24 Systems Approach to Training 6/30/98 26 Records Management and Document Control Program 6/30/98 27 Procedures Program 3/3/2002 29 Quality Assurance Program 12/31/97 30 Public Warning Sirens and Controls 3/15/97 (I.
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DESCRIPTION OF OPEN COMPLIANCE PLAN ISSUES PADUCAH ISSUE NO.
DESCRIPTION OF ISSUE DUE DATE FOR CO3iPLETION 31 Public Address System 4/30/97 35 Depleted Uranium Management Plan 12/31/97 36 Seismic Capability for C-331 and C-335 12/1/97 37 Environmental Trending Procedures 12/31/97 38 High-Volume Ambient Air Samplers 6/30/97 39 Decommissioning Funding Program Privatization 40 Chemical Safety Mechanical Integrity Program 5/26/97 42 Administrative Controls on Overtime 3/31/97 43 DOE Chemical Safety 5/26/97 44 Operational / Safety System Trip Redundancy 12/31/97 46 Criticality Accident Alarm - IIorn Audibility 12/15/98 49 UF6 Leak Detector Sensitivity Testing 7/31/98 50 Criticality Accident Alarm for Nearby Buildings 12/15/98 I,
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Compliance Plan Tasks as ofMarch 3,1997
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t To data, USEC has discussed the following 45 l
Compliance Plan issues in the Reg. Issues Meetings:
Transition to NRC Regulation (C1/X1) i SAR Upgrade Status (C2/X2) i Seismic Capability of C-331 and C-335 (C36)
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- Nuclear Criticality Safety (X4, C5/X8, C6/X9, C8, X11, C46, C50, X44)
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Posting of Radioactive Materials (C10/X13)
Radioactive Calibration Source Accuracy (C11)
Environmental Trending Procedures (C37)
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High Volume Ambient Air Samples (C38)
Fire Protection (C13, C14, C16/X17, C17, X18)
Configuration Management (C21/X23)
Management Controls (C19/X21)
Event Investigation and Reporting (C25/X28)
- Procedures Upgrade Status (C27/X30, C23/X25, C24/X26)
- Autoclave Upgrades (C3/X3) l Public Waming and Address Systems (C30 and C31)
Cascade Cell Trip Fuctions (C48)
- NMCA (CA.1-7/XA.1-5) i l ill be discussed at today's meeting
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1 3l1>}9'1 DESCRIPTION OFNONCOMPLIANCE ISSUE 50 PGDP HIE EVACUATION AREA AROUND THE CAAS CLUSTERS (" CLUSTERED" BUILD DETERMINED BASED ON A 12 RAD EXPOSURE FROM A POSTULATED CRITIC WlTIHN THESE BUILDINOS. SEVERAL LEASED BUILDINGS THAT ARE LOCATE EVACUATION AREA DO NOT HAVE EVACUATION HORNS AND LIGHTS ACTIVA i
CLUSTERS. FUR 1HERMORE, THE CRITICALITY ALARM HORNS FROM ADJACENT AIhRMED BUILDINGS CANNOT BE HEARD WIHUN MOST OF THESE UNALARMED BUIL THE REQUIREMENTS THAT A CRITICALITY ACCIDENT BE ANNUNCIATED INTO REQUIRING EVACUATIONIS NOTMET.
CORRECTIVE ACTIONPLAN EVACUATION HORNS (FOR THOSE UNALARMED BUILDIh4GS WHERE NEAR CANNOT BE ADEQUATELY HEARD) ANIWOR LIGHTS WILL BE INSTALLED BUILDINGS LOCATED WITHIN THE EVACpATION AREA OF CAAS-CLUSTERED BUILDINGS UNALARMED BUILDINGS WILL BE REMOVED FROM THE EVACUATION AREA AND/OR LIGHTS WILL BE ACI1VATED FRDM'A NEARBY CLUSTERED BUILD ALARMED BUILDING.
SCHEDULE OF COMPLETION OF CORRECTIVE AGiONS UNALARMED FACILITIES THAT HAVE BEENIDENTIFIED AS OF JUNE 19, L996, WILL E E MODIFIED WITH THE REQUIRED HORNS AND/ORLIGHTS, AS APPROPRIATE, OR RELOCA1ED TO LOCATIO OUTSIDE OF THE EVACUATION AREA BY DECEMBER 15,1998.
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STATUS OFIMPLEMENTATION ISSUE 50 PGDP (cont.)
i A PROJECT TEAM HAS BEEN ASSIGNED. THE. ENGINEERING STUDYIS IN PROGRESS, AND A PROJECT PROPOSAL; WILL; BE SUBMITTED FOR APPROVAL IN OCTOBER. A PHASED APPROACH i
WILL BE USED, FOCUSING ON MANNED FACILI11ES BEFORE UNMANNED FACILITIESI SoK was w see awW kkiso cols;de 4 & 4
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i-3p/n UNSLAVED CAAS FACILITIES DESCRIPTION OF NONCOMPLIANCE ISSUE 44 PORTS Several leased buildings located within 200 feet of buildings with Criticality Accident Alarm System (CAAS) clusters do not have evacuation homs and lights activated by these clusters and the criticality alarm l
homs from adjacent buildings cannot be heard within most of these unalarmed buildings. Consequently, fomteen facilities leased by USEC have been identified which are not in compliance with the 10 CFR 76.89 i
requirement that a criticality accident be annunciated into nearby buildings.
CORRECTIVE ACTION PLAN Install evacuation horns (in those unalarmed buildings from which the audibility of existing CAAS horns is inadequate) and radiation warning lights in the unalarmed buildings located within 200 feet of CAAS-clustered buildings, or remove the nonconforming buildings from the 200-foot evacuation zone.
1 SCHEDULE OF COMPLETION OF CORRECTIVE ACTIONS The compliance plan dates for this corrective action plan are as follows:
SIX ROUTINELY MANNED FACILITIES:
JULY 1,1997 f
EIGHT ROUTINELY UNMANNED FACILITIES:
JULY 1,1998 t
_-__-______.________________--______________-__________________________________________-_______j
j UNSLAVED CAAS FACILITIES STATUS OF IMPLEMENTATION Work under this project is in the constmetion phase for the 6 manned facilities and continues in the design phase for the 8 unmanned facilities. Fixed Price Subcontractor (FPSC) constmetion for the manned facilities is complete and Lockheed Martin Utility Services (LMUS) construction for the manned facilities i
is scheduled to begin in March. Overall, work on this project is approximately 19% complete and is ahead of the baseline schedule. We expect to complete construction, final tie-ins, and testing on the manned facilities on or about April 30,1997.
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3hz/97 DESCRIPTION OF NONCOMPLIANCE ISSUE 3 PORTS Pressure decay testing procedures and autoclave modifications that ensure that backpressure does not mask leak rate determinations have not been implemented.
CORRECTIVE ACTION PLAN Pressure testing procedures that assure that backpressure does not mask leaks in autoclave steam admission lines will be implemented. Modifications to the buffer air supply lines on nine autoclaves to eliminate backpressate masking and resulting changes to pressure decay testing procedures will be completed.
SCHEDULE OF COMPLETION OF CORRECTIVE ACTIONS The compliance plan date associated with action is December 31,1996.
STATUS OF IMPLEMENTATION COMPLETE The modifications were completed on September 12,1996 and the procedures were completed by December I,1996 l
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DESCRIPTION OF NONCOMPLIANCE ISSUE 3 PORTS The capability to test the containment valves (i.e. inner and outer loop valves) separately for the autoclaves in X-342A, X-343 and X-344A is not provided.
CORRECTIVE ACTION PLAN Provide the capability to test the inner and outer loop containment valves on the autoclaves in X-342A, X-343, and X-344A. A revised TSR to reflect the new configuration will be submitted to the NRC.
SCHEDULE OF COMPLETION OF CORRECTIVE ACTIONS The modifications will be completed and the revised TSR submitted to the NRC by July 1,1997 STATUS OF IMPLEMENTATION The two autoclaves in X-342 and the seven autoclaves in X-343 have been completed. Modifications have begun on the first of the four autoclaves in X-344. TSR revisions are to be completed.
DESCRIPTION OF NONCOMPLIANCE ISSUE 3 PORTS The UF feed isolation and flow control valves in X-342A and X-343 are not fail safe on loss of air or electric 6
power. The containment valves on the liquid UF drain line are not fail safe on loss of air or electric power on 6
autoclaves 3 and 4 in X-344A. The daughter cylinder isolation valves on the autoclaves in X-344A do not fail closed on loss of air.
Autoclave 2 in X-344A does not have a low pressure switch to initiate containment upon loss of air.
The Iligh Pressure Containment Shutdown System control logic for the autoclaves in X-342A, X-343, and X-344A does not lock out the hydraulics to prevent the autoclaves from being inadvertently opened when the pressure in the autoclave exceeds the setpoint.
The internal autoclave and UF cylinder pressure transmitters have too large of a pressure range and 6
insufficient temperature compensation to perfonn within the operational accuracy and tolerances needed.
There are no alarms to alert operators of possible upset conditions prior to the activation of the autoclave safety systems.
The design and configuration of the autoclave steam supply and condensate removal systems in X-342A, X-343, and X-344 A are not adequate to prevent excess condensate from collecting in the autoclave, activating f
the High Condensate Level Cutoff System.
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D The head /shell sealing surfaces for the autoclaves in X-342A, X-343, and X-344A are experiencing significant
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corrosion, which affects their ability to seal.
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The UF cylinders are not provided with pressure relief protection.
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CORRECTIVE ACTION PLAN Install fail-safe containment valves upstream of the UF feed isolation valves on the autoclaves in X-342A and 6
X-343 and modify the programmable logic control system. Install fail-safe containment valves on the liquid i
UF drain line on autoclaves 3 and 4 in X-344A. Replace or modify the daughter cylinder isolation valves on 6
i the autoclaves in X-344A for fail-safe (i.e., closed) position on loss of air.
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Add a low air pressure switch to autoclave 2 in X-344A to initiate containment upon loss of air to pressure transmitter PT-134.
Modify the controls for the autoclaves in X-342A, X-343, and X-344A to prevent them from being r
inadvertently opened when the pressure in the autoclave exceeds the High Pressure Containment Shutdown i
System setpoint as defined in the Technical Safety Requirements.
i Upgrade the internal autoclave and UF cylinder pressure transmitters to improve their temperature 6
compensation capability and accuracy in the operating range.
Provide operational alanns on the autoclave safety systems to alert operators to potential upset conditions.
j 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 autoclaves.
4 Restore the autoclave head /shell sealing surfaces for the autoclaves in X-342A, X-343, and X-344A.
A code interpretation from the ASME Code Committee will be obtained regarding the need for pressure relief for the UF cylinders. Based on this interpretation, the need for modifications to the affected system 6
operations will be assessed. Both the ASME Code interpretation and the assessment results will be submitted to NRC for review and approval.
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t SCHEDULE OF COMPLETION OF CORRECTIVE ACTIONS The scheduled completion date for these actions for the first autoclave is May 1,1998. The completion schedule for the remaining twelve autoclaves will be such that the final autoclave is completed by February 1, 2001. A detailed schedule for completio.. of these actions will be available for review at PORTS by March 31,1998 STATUS OF IMPLEMENTATION Design is being completed on these actions. Actual modifications are to begin July 1997.
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. DESCRIPTION OF NONCOMPLIANCE ISSUE 4 PORTS A TUBE FAILURE IN EITHER THE' PRE-OR POST-URANIUM EVAPORATOR HEAT EXCHANGER -
COULD RESULT IN CONCENTRATED URANIUM-BEARING SOLUTION BEING DISCHARGED INTO AN UNFAVORABLE GEOMETRY THROUGH THE STEAM CONDENSATE DRAIN PIPING.
ALSO, A TUBE FAILURE CONINCIDENT WITH A U235 FEED SOLUTION CONCENIRATION
>60% AND A HIGH FEED SOLUTION LEVEL COULD RESULT IN URANIUM-BEARING SOLUTION BEING INTRODUCED INTO AN UNFAVORABLE GEOMETRY IN THE H' EAT EXCHANGER EXPANSION JOINT.
CORRECTIVE ACTION PLAN INSTALL INSTRUMENTATION AND SYSTEM MODIFIC^TIONS IN THE STEAM CONDENSATE DRAIN PIPING FROM THE EVAPORATOR HEAT EXCHANGER TO PROVIDE DOUBLE CONTINGENCY FOR NCS.
REPLACE THE EVAPORATOR HEAT EXCHANGER TO ELIMINATE THE UNFAVORABLE GEOMETRY EXPANSION JOINT.
SCHEDULE OF COMPLETION OF CORRECTIVE ACTIONS THE INSTALLATION IS COMPLETE.
STATUS OF IMPLEMENTATION COMPLETE: ITEM CLOSED.
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. DESCRIPTION OF NONCOMPLIANCE ISSUE 5 PGDP i
THERE ARE OPERATIONS AT PGDP FOR WHICH EITHER (1) THE NCS EVAL ARE INCOMPLETE FOR FORMAL DOCUMENTATION IS UNAVAILABLE OR (2) DOUBLE CONTINGENCY EVALUATION HAS NOT BEEN FULLY DOCUMENTED IN AN NCSE.
1 THERE ARE ALSO ADMINISTRATIVE ASPECTS OF THE NCS PROGRAM, INCLUDING THOSE RELATED TO ANSI /ANS-8 STANDARDS, ANALYST AND RE'" EWER QUALIFICATIONS, AND COMPUTER CODE QUALIFICATION, THAT HAVE NOT BEEN FROCEDURALIZED OR DOCUMENTED.
CORRECTIVE ACTION PLAN FOR EXISTING OPERATION WITH I WT% OR HIGHER U235 AND 15 GRAMS OR MORE U235, WHERE FORMAL DOCUMENTATION IS INCOMPLETE OR UNAVAILABLE, USEC WILL' PREPARE THE NECESSARY NCSE AND NCSA DOCUMENTATION, APPROVE IT IN 0
ACCORDANCE WITH THE NCS PROGRAM R EQUIREMENTS CONTAINED IN THE APPROV CERTIFICATE, PROVIDE INFORMATION FLOW-DOWN TO OPERATING PROCEDURES AND WORK-SITE POSTINGS, AND VERIFY IMPLEMENTATION OF THE PROCEDURES AND POSTINGS.
PROCEDURES SHALL BE DEVELOPED TO RESOLVE ADMINISTRATIVE NON-COMPLIA SCHEDULE OF COMPLETION OF CORRECTIVE ACTIONS
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ALL NCSA'S WERE COMPLETED BY DECEMBER 2,1996. THE NCS PROGRAM PROCEDURES WERE COMPLETED OCTOBER 31,1996.
I STATUS OFIMPLEMENTATION ISSUE 5 PGDP (Con't)
APPROXIMATELY 120 NCSA/E'S AND NINE NCS ADMINISTRATIVE PROCEDURES WERE COMPLETED. MM CLOSED.
s DESCRIPTION OF NONCOMPLIANCE ISSUE 6 PGDP I
THERE ARE INCONSISTENCIES BETWEEN THE SPECIFICATIONS IN THE NCSA'S hND THE 4-SUPPORTING IMPLEMENTATION PROCEDURES AND WORK-SITE POSTINGS. THE KNOWN INCONSISTENCIES ARE MINOR AMBIGUITIES, SMALL DISCREPANCIES IN DIMENSIONS, AND g
VARIANCES IN FORMAT OR LOCATION OF POSTINGS.
g CORRECTIVE ACTION PLAN fd FIELD VERIFY PROCEDURES AND POSTINGS.
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?d SCHEDULE OF COMPLETION OF CORRECTIVE ACTIONS THE FIELD VERIMCATION OF ROUGHLY 120 NCSA'S SHALL BE COMPLETED BY
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DECEMBER 2,1996.
g STATUS OF IMPLEMENTATION
{,g COMPLETE: ITEM CLOSED.
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DESCRIPTION OF NONCOMPLIANCE ISSUE 8 PORTS t
I THERE ARE OPERATIONS AT PORTS FOR WHICH EITHER (1) THE NCS EVALUATIONS (NCSE'S) ARE INCOMPLETE OR FORMAL DOCUMENTATION IS UNAVAILABLE OR (2)
DOUBLE CONTINGENCY OR OTHER BASIS FOR ACCEPTANCE HAS NOT BEEN FULLY DOCUMENTED IN AN NCSE. PRIORITY WAS GIVEN TO THE DOCUMENTATION EOR THE OPERATIONS INVOLVING OILS AND OTHER LIQUIDS AND FOR UNFAVORABLE GEOMETRIES THERE'ARE ALSO ADMINISTRATIVE ASPECTS OF THE NCS PROGRAM, INCLUDING THOSE RELATED TO ANSI /ANS-8 STANDARDS, THAT HAVE NOT YET BEEN PROCEDURALIZED OR DOCUMENTED.
CORRECTIVE ACTION PLAN ALL NEW OPERATIONS THAT REQUIRE NCS APPROVAL WILL HAVE PROPERLY DOCUMENTED AND IMPLEMENTED NCSA'S AND NCSE'S THAT HAVE BEEN APPROVED IN ACCORDANCE WITH THE NCS PROGRAM REQUIREMENTS CONTAINED IN THE APPROVED l
CERTIFICATE PRIOR TO STARTUP. FORMAL NCSA'S AND NCSE'S WILL BE COMPLETED FOR ALL CURRENT OPERATIONS INVOLVING URANIUM ENRICHED TO 1 WT% OR HIGHER U235 AND 15 GRAMS OR MORE U235 AND WILL BE PROPERLY DOCUMENTED AND APPROVED IN ACCORDANCE WITH THE NCS PROGRAM REQUIREMENTS CONTAINED IN THE APPROVED CERTIFICATE. THE PROCEDURAL CHANGES TO RESOLVE THE ADMINISTRATIVE NONCOMPLIANCE IN THE NCS PROGRAM WILL ALSO BE COMPLETED. ALL ASPECTS OF TSR 3.9 IMPLEMENTATION AND ITS ASSOCIATED TENTACLES WILL BE IN PLACE NO LATER THAN THE TRANSITION TO NRC REGULATORY OVERSIGHT.
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. SCHEDULE OF COMPLETION OF CORRECTIVE ACTIONS ISSUE 8 PORTS (Con't) 3,.
ALL NCSA'S WERE COMPLETED DECEMBER 31,1996. ALL NCS PROCEDURES WERE COMPLETED NOVEMBER 30,1996.
I STATUS OF IMPLEMENTATION COMPLETE: ITEM CLOSED.
DESCRIPTION OF NONCOMPLIANCE ISSUE 9 PORTS s
THERE ARE INCONSISTENCIES BETWEEN THE SPECIFICATIONS IN NCSA'S AND THE SUPPORTING IMPLEMENTATION PROCEDURES AND \\ ORK-SITE POSTINGS. THE KNOWN INCONSISTENCIES ARE MINOR AMBIGUITIES, SMALL DISCREPANCIES IN DIMENSIONS, AND VARIANCES IN FORMAT OR LOCATION OF POSTINGS.
THERE ARE ALSO ADMINISTRATIVE ASPECTS OF THE NCS PROGRAM IMPLEMENTATION
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INCLUDING THOSE RELATED TO ANSI /ANS-8 STANDARDS, THAT HAVE NOT YET BEEN PROCEDURALIZED OR DOCUMENTED.-
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. CORREbTIVE ACTION PLAN. ISSUE 9 PORTS (Con't) t A PROGRAM IS IN PLACE TO REVIEW ALL NCSA'S IN ORDER TO IDENTIFY AND TRACK THE DESIGNATED NCS CONDITIONS, SPECIFICATIONS, AND CONTROLS AND TO VERIFY THEIR FULL IMPLEMENTATION. THE VERIFICATION PROGRAM WILL BE COMPLETED FOR ALL l
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CURRENT FISSILE MATERIAL' OPERATIONS, PRIOR TO NRS' ASSUMING REGULAkORY OVESIGHT FOR NCSA'S THAT NEED TO' FLOW INTO TSR'S. IDENTIFICATION OF PMA NCSA REQUIREMENTS TO BE FLOWED-DOWN INTO PROCEDURES WILL BE COMPLETED BY i
DECEMBER 2,1996. IF AN-ADMINISTRATIVE REQUIREMENT FOR DOUBLE CONTINGENCY CONTROLS IS FOUND TO BE MISSING DURING THE VERIFICATION, THE PROCEDURE OR CHECKLIST MODIFICATIONS TO IMPLEMENT SUCH A REQUIREMENT WILL BE EXPIDITED THROUGH THE PROCEDURE CHANGE PROCESS.
l A PROCEDURE FOR CONTAINER HANDLING AND STORAGB WILL BE DEVELOPED BY DECEMBER 2,1996.
i SCHEDULE OF COMPLETION OF CORRECTIVE ACTIONS
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IDENTIFICATION OF REMAINING NCSA REQUIREMENTS TO BE FLOWED-DOWN INTO
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PROCEDURES SHALL BE COMPLETED BY DECEMBER 2,1996.
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A PROCEDURE FOR CONTAINER HANDLING AND STORAGE SHALL BE DEVELOPED BY DECEMBER 2,1996.
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STATUS OF IMPLEMENTATION -
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COMPLETE: ITEM CLOSED.
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-. -. -. -.. - -. -. - - - - -. - - -. - =. -. - _..
- DESCRIPTION OF NONCOMPLIANCE ISSUE 8 PGDP A CRITICALITY ACCIDENT ALARM SYSTEM (CAAS) IS NOT PROVIDED FOR ALL AREAS OF THE FACILITY. IN SOME AREAS OF BUILDING C-710, A PORTABLE CRITICALITY ACCIDENT ALARM SYSTEM (CAAS) IS BEING USED RATHER THAN A PERMANENT SYSTEM. URANIUM CYLINDER AND LOW-LEVEL WASTE STORAGE AREAS AND SOME FISSILE MAdiRIAL TRANSPORTATION ACTIVITIES HAVE BEEN EXCLUDED CONSISTENT WITH DOE GUIDANCE.
NRS APPROVAL HAS NOT BEEN RECEIVED FOR EXCLUDING THE APPLICABLE ELANT AREAS (i. e., THOSE CONTAINING >700 GRAMS OF U235) FROM CAAS COVERAGE.
i CORRECTIVE ACTION PLAN l
I USEC VTLL PROVIDE CRITICALITY DETECTOR COVERAGE IN ALL AREAS OF THE PLANT EXCEPT FOR THOSE AREAS IDENT1HED AND JUSTIFIED BY USEC AND APPROVED BY NRC.
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SCHEDULE OF COMPLETION'OF CORRECTIVE ACTIONS PERMANENT CRITICALITY ACCIDENT AL' ARM DETECTOR CLUSTERS WILL BE INSTALLED, RELOCATED, AND/OR RECONDITIONED IN BUILDING C-710 TO REPLACE THE EXISTING r
PORTABLE DETECTORS IN BUILDING C-710 BY JUNE 30,1998.
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. STATUS OF IMPLEMENTATION ISSUE 8 PGDP (Con't) u ANALYSES THAT PROVIDE THE TECHNICAL JUSTIFICATION FOR NOT PROVIDING CAAS COVERAGE IN DESIGNATED AREAS OETHE PLANT WERE DEVELOPED. THE ANALYSES l
HAVE BEEN SUBMITTED TO NRC AND INCLUDE (1) VERIFICATION OF THE ADEQUACY OF THE EXISTING CAAS AND ITS DETECTOR LOCATIONS FOR DETECTING A CRITk'ALITY l
ACCIDENT AND (2) JUSTIFICATION THAT DETECTORS ARE NOT REQUIRED FOR l
MONITORING OTHER AREAS OF THE PLANT. AN ESO HAS BEEN PREPARED AND SUBMITTED; A NSU PROJECT PROPOSAL HAS BEEN PREPARED.
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SUPPORT IS BEING CONTRACTED TO PROVIDE ANALYSES FOR SITING THE ADDITIONAL l
CLUSTERS IN C-710.~
STATUS 3/12/97: NO CHANGES.
I DESCRIPTION OF NONCOMPLIANCE ISSUE 11 PORTS
)
i A CRITICALITY ACCIDENT ALARM SYSTEM (CAAS) IS NOT PROVIDED FOR ALL AREAS OF THE FACILITY URANIUM CYLINDER AND LOW-LEVEL WASTE STORAGE AREAS AND SOME
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FISSILE MATERLAL ACTIVITIES HAVE BEEN EXCLUDED CONSISTENT WITH DOE GUIDANCE.
NRC APPROVAL HAS NOT BEEN RECEIVED FOR EXCLUDING THE APPLICABLE PLANT I
AREAS FROM CRITICALITY ACCIDENT ALARM SYSTEM COVERAGE.
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_ CORRECTIVE ACTION PLAN ISSUE 11 PORTS (Con't)
USEC WILL PROVIDE CRITICALITY DETECTOR COVERAGE IN ALL AREAS OF THE PLANT EXCEPT FOR THOSE AREAS IDENTIFIED AND JUSTIFIED BY USEC AND APPROVED BY NRC.
l ANALYSES THAT PROVIDE THE TECHNICAL JUSTIFICATION FOR NOT PROVIDING i
CRITICALITY ACCIDENT ALARM SYSTEM COVERAGE IN DESIGNATED AREAS DF THE i
PLANT ARE BEING DEVELOPED. THIS COMPLIANCE PLAN ISSUE WILL BE MODIFIED TO PROVIDE A PLAN AND SCHEDULE FOR ESTABLISHING ADEQUATE DETECTOR' COVERAGE j
IF THE ADEQUACY OF THE CURRENT DETECTOR COVERAGE IS NOT VERIFIED BY THE NRC REVIEW.
SCHEDULE OF COMPLETION OF CORRECTIVE ACTIONS EVALUATIONS OF X-330, X-333, AND X-700 HAVE BEEN COMPLETED. CORRECTIVE ACTIONS ARE REQUIRED AT ALL THREE FACILITIES.
STATUS OF IMPLEMENTATION ANALYSES HAVE BEEN SUBMITTED TO NRC VERIFYING ADEQUACY OF THE EXISTING CAAS AND ITS DETECTOR LOCATIONS FOR DETECTING A CRITICALITY ACCIDENT EXCEPT FOR BUILDINGS X-330, X-333, AND X-700; AND A JUSTIFICATION FOR EXCEPTIONS FOR i
OTHER AREAS OF THE PLANT WAS SUBMITTED TO NRC FOR APPROVAL. IT HAS BEEN DETERMINED THAT THE X-330 CAAS COVERAGE IS ADEQUATE, BUT AN ALARM REQUIRES j
EXTENSION FROM THE DETECTOR ON THE CELL FLOOR TO THE OPERATING FLOOR i
BELOW, IN THE NORTHWEST CORNER OF THE BUILDING. THE X-700 CAAS DETECTOR WILL BE RELOCATED TO ENSURE COVERAGE OF X-700. THE X-333 DOES NOT HAVE ADEQUATE COVERAGE IN THE EAST CENTRAL PORTION OF THE OPERATING FLOOR. THE TWO l
OPTIONS UNDER STUDY INCLUDE MOVING THE EAST CENTRAL CLUSTER OR ADDING ANOTHER CLUSTER FURTHER EAST OF THE PRESENT CLUSTER.
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. DESCRITION OF NONCOMPLIANCEi
- IS$UE 46 PGDP-
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'l THERE ARE AREAS IN PROCESS BUILDlNGS C-3312 C-335, AND C-337-WHERE THE CRITICALITY ACCIDENT ALARIVfSYSTEM (CAAS) HORNS ARE NOT AUDIBLE TO y
PERSONNEL DUE TO MIGH AMBIENTNOISE LEVELS. A FULL SOUND SU BUILDINGS WITH CAAS HORNS IS BEING CONDUCTED. THE INAUDIBILITY DOES NOT
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AFFECT THE CAPABILITY OF;THE CAAS TO DETECT'A CRITICALITY ACCIDENT g
CORRECTIVE ACTION PLAN i
PLANT MODIFICATIONS WIL BE INITIATED TO ENSURE THAT THE CAAS ALARM HORNS l
ARE CAPABLE OF BEING HEARD THROUGHOUT TIIE AFFECTED AREAS OF THE PROCESS BUILDINGS.
SCHEDULE OF COMPLETION OF CORRECTIVE ACTIONS THE MnDIFICATIONS WILL BE COMPLETE BY DECEMBER 15,1998.
STATUS OFIMPLEMENTATION THE PLANT WIDE AUDIBILITY SURVEY HAS BEEN COMPLETED AND THE NEEDS FOR EAC FACILITY ARE CURRENTLY BEING ASSESSED.
STATUS 3/12/97: NO CHANGES.
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PROCEDURES PROGRAM ISSUE 30 Completed Elements Criteria for requiring procedures Work stoppage rules PORC review required criteria Incorporate TSR's into procedures TSR's for HEU refeed working
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Operational Policy Statements Level 2, 3, and 4 AQ-NCS procedures Implement TSR 3.9 In Progress Elements Level 2, 3, 4 Q procedures Level 2,3,4 AQ and NS procedures Issue analytical laboratory procedures Complete all overdue procedure periodic reviews PORC will review all required procedures i
Ralph Lipfert (614)897-3791 l
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4 DESCRIPTION OF NONCOMPLIANCE Level 2, 3, and 4 procedures required to implement the Quality Assurance Program or other activities identified in the Application have not been prepared / upgraded and approved and training has not been provided for all affected personnel.
CORRECTIVE ACTION PLAN Upgrade 261 Q procedures and completed required training.
SCHEDULE OF COMPLETION OF CORRECTIVE ACTIONS i
Complete remaining procedures and training prior to March 31, 1997.
i STATUS OF IMPLEMENTATION l
46 of 261 procedures remain to be upgraded.
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DESCRIPTION OF NONCOMPLIANCE Level 2, 3, and 4 procedures required to implement the Quality Assurance Program or other activities identified in the Application have not-been prepared / upgraded and approved and training has not been provided for all affected personnel.
CORRECTIVE ACTION PLAN Upgrade all Regulatory procedures and complete required training.
SCHEDULE OF COMPLETION OF CORRECTIVE ACTIONS Complete remaining procedures and training prior to December 31, 1997.
STATUS OF IMPLEMENTATION Approximately 1000 procedures remain to be upgraded at PORTS.
DESCRIPTION OF NONCOMPLIANCE Analytical laboratory procedures have not been updated to current requirements.
CORRECTIVE ACTION PLAN Upgrade laboratory procedures in conjunction with work on other regulatory procedures.
l SCHEDULE OF COMPLETION OF CORRECTIVE ACTIONS l
l Comnlete upgrade by December 31,1997.
STATUS OF IMPLEMENTATION 125 Regulatory procedures are identified and the list is being scrubbed. In addition,140 other Non-Regulatory procedure.s need to be reviewed for potential upgrades.
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3 DESCRIPTION OF NONCOMPLJANCE Not all procedures requiring periodic review have been reviewed.
l CORRECTIVE ACTION PLAN i
Start Periodic Review Program XP2-PS-PS1035 applies
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Some overdue Periodic Reviews completed recently.
Completed Technical Adequacy check of almost 800 procedures for the end of the year.
SCHEDULE OF COMPLETION OF CORRECTIVE ACTIONS 4
Have Periodic Review program up to date by December 31,1997.
STATUS OF IMPLEMENTATION Governing procedure complete.
Some reviews complete.
Upgrade program will complete others.
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3 DESCRIPTION OF NONCOMPLIANCE
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Initial review by PORC of all in-hand procedures and procedures that involve liquid UF6 handling activities has not been completed.
CORRECTIVE ACTION PLAN l
Review procedures as upgrades are completed.
i SCHEDULE OF COMPLETION OF CORRECTIVE ACTIONS Review remaining upgrades as upgrade process is completed.
Routinely examine others in 1998.
1 STATUS OF IMPLEMENTATION In progress.
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REGULATORY ISSUES MEETING MARCH 12,1997 Certificate Amendment Reauests at NRC for Review SUBJECI' USEC NRC ISSUE USEC NRC ISSUE RESPOND CER &
NRC ISSUE IMPLEMENT RAI TO RAI FR NOTICE FINAL CAR CAR COMMENT PGDP - CASCADE CELL TRIP N/A N/A CMPLT CMPLT 5/4/97F FUNCTION CER 2/5/97 3/5/97 (SUBMITTED 9/30/96)
FR 2/12/97 PGDP - AU f0 CLAVE MANUAL CMPLT CMPLT NO F/C ISOLATION SYSTEM i/15/97 2/14/97 (SUBMITTED 10/31/96)
PORTS - WITIIDRAWAL STAT!ON CMPLT CMPLT CMPLT CMPLT CMPLT STANDBY OPERATIONAL MODE I1/29/96 12/13/96 CER 2/5/97 2/27/97 3/3/97 (SUBMITTED 11/8/96) 12/31/96 1/16/97 FR 2/12/97 PGDP-AUTOCLAVE 4/30/97 F INBOARD / OUTBOARD TESTING (SUBMITTED 12/23/96)
PORTS - ADMIN CONTROLS ON NO F/C OVERTIME (SUBMITTED 12/23/96)
BOTII-REVISION OF TRANS QAP N/A N/A N/A CMPLT CMPLT FOR ORGANIZATION ClIANGES 2/28/97 3/3/97 (SUBMITTED 1/31/97)
PORTS - SAR CIIANGE, OPERATION NO F/C.
AT 3% ASSAY IN X-333 (SUBMITTED 2/25/97)
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3 REGULATORY ISSUES MEETING MARCH 12,1997 Certificate Amendment Reauests at NRC for Review SUBJECT USEC NRC ISSUE USEC NRC ISSUE RESPOND CER &
NRC ISSUE IMPLEMENT RAI TO RAI FR NOTICE FINAL CAR CAR COMMENT i
BOTil -IIOURLY DEFINITION No F/C (SUBMITTED 2/28/97)
PGDP - FEED FACILITIES CRANE CMPLT CMPLT NO F/C DESIGN FEATURES 2/28/97 3/10/97 (SUBMITTED 2/25/97)
PGDP - FNMCP/CP PLAN CilANGES No F/C
-C-400 TANK VOLUME (SUBMITTED 3/4/97) i m
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4 REGULATORY ISSUES MEETING MARCH 12,1997 Certificate Amendment Reauests In Preparation SUBJECT ISSUE CAR COMMENT TO NRC BOTH - CAAS TSRs PGDP RAC 97C025 3/18/97 F PORTS RAC 97X052 3/18/97 F PGDP-ADMIN CONTROLS ON 3/31/97 OVERTIME CP DUE DATE RAC 97C031 PGDP - CELL TRIP, B ATTERY 3/14/97F SUBMIT TO NRC WITH RAC 97C014 PARAMETERS RAC 96C212 PGDP - C-310 FIRE PROTECTION 3/25/97 F RAC 96C234 PGDP - NMC&A SCALE USAGE 3/17/97 F RAC 95C183 PORTS - SEAL EXHAUST PUMP 3/14/97 F RAC 96X090 PGDP-TSR 2.6.4.1, ADD C-709 CAAS 4/4/97F RAC 96C180 BOTH - CASCADE CELL TRIP-3/14/97F PORTS RAC IN PREPARATION PLANNED CELL SHUTDOWN SUBMIT PGDP CAR WITH RAC 96C212 PGDP RAC 97C014 PORTS RAC -TBD
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+1 REGULATORY ISSUES MEETING MARCH 12,1997 CERTIFICATE AMENDMENT REOUEST REOUESTED REVIEW PRIORITY Paducah 1.
CP - FNMCP/CP Changes-C400 Tank Volume 2..
TSR - Feed Facilities Crane Design Features 3.
TSR - Completion Time Definition 4.
CP/TSR - Autoclave Manual Isolation System 5.
CP/TSR - Autoclave Inboard / Outboard Testing Portsmouth 1.
SAR Change - Operation at 3% Assay in X-333 2.
Compliance Plan /TSR - Admin. Controls on Overtime 3.
TSR - Completion Time Definition
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