ML20154P422
| ML20154P422 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 10/19/1998 |
| From: | Toelle S UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Caniano R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| GDP-98-0216, GDP-98-216, NUDOCS 9810220321 | |
| Download: ML20154P422 (34) | |
Text
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USEC A Global Energy Company October 19,1998 GDP 98-0216 Mr. Roy Caniano, Acting Director Division of Nuclear Material Safety U. S. Nuclear Regulatory Commission Region III 801 Warrenville Road Lisle, Illinois 60532-4351 Portsmouth Gaseous Diffusion Plant (PORTS)
Docket No. 70-7002 Portsmouth Nuclear Criticality Safety Program Revised Corrective Action Plan
Dear Mr. Caniano:
Enclosed is Revision 4 of the Portsmouth NCS Program Corrective Action Plan (CAP). This revision reflects the current status of the NCS CAP tasks. Changes have been made to Task 20 and the subtasks for Task 21 as shown in Enclosure 1.
This revision also reflects that two Priority 2 (0705_024.0C5 and PLANT 022.A00) and one Priority 3 (PLANT 066.A02) NCSA/Es have been upgraded to Priority 1. Three Priority 1 (0326_028.A00, 0705_031 A00, and 0705.033.1C4) NCSA/Es have been downgraded to Priority 2. Two Priority 1 (0705_132.A01 and PLANT 086.A00) NCSA/Es have been deleted. In addition, two Priority 3 (0710_027.A00 and PLANT 071.A00) NCSA/Es have been deleted. Also, six new Priority 3 (0330_014.A00,0330_015.A00,0847_003.A00, PLANT 081.A00, PLANT 083.A00, and PLANT 084.A00) NCSA/Es have been added. These changes are shown in Enclosure 2 and are provided as an update to the NCS CAP Quarterly Status Report submitted by letter GDP 98-0147 dated July 31,1998.
These changes are reflected by margin bars on the right-hand side of the document. The commitments contained in this submittal are listed in Table 2 of Enclosure 1.
d go 6903 Rockledge Drive, Bethesda, MD 20817-1818 relephone 301-5603200 Fax 301-5643201 http://www.usec.com cah. KY Portsmouth. OH Washington, DC
Mr. Roy Caniano October 19,1998 GDP 98-0216, Page 2 If you have questions regarding this submittal, please contact Pete Miner at (740) 897-2710.
Sincerely, A
S. A.
I' Steven A.Toelle Nuclear Regulatory Assurance and Policy Manager Enclosure cc:
NRC Document Control Desk NRC Resident Inspector-PGDP & PORTS NRC Project Manager - PORTS NRC Special Projects Branch DOE Regulatory Oversight Manager l
GDP 98-0216 Page1of22 PORTS Nuclear Criticality Safety Program Corrective Action Plan, Revision 4 A.
Background
As part of the Certification Application eftbrt, PORTS NCSA/Es were upgraded to provide more rigorous and accurate NCS documentation. This ellbrt was completed in December 1996. Subsequent to this effbrt, in early 1997, USEC began to question the effectiveness of the NCS program. This concern was based, in part, on the large number of Problem Reports being generated that identified problems with the implementation of the NCS program. In October 1997, it was determined that the NCSA/E controls developed to keep cooling water from entering the process gas system during the cell treatment process were not being properly maintained. Further evaluation of this event determined that the respective NCSA/E was llawed. Subsequent to this event, it was identified that Engineering Notices (ens) were being used to amend requirements in NCSA/Es, effectively circumventing the NCS review and approval process.
The identification of these problems and the recognition that they represent deficiencies in the implementation of the NCS program have resulted in the need to establish a comprehensive Corrective Action Plan. The goals of this Plan are to put in place a high quality NCS program and to ensure that NCS implementing documents provide the necessary level of safety. These goals will be accomplished by:
(1)
Ensuring the safety of ongoing Fissile Material Operations (FMOs);
(2)
Identifying the scope and depth of the deficiencies (root causes);
(3)
Initiating an interim program to review and correct NCSA/Es in a prioritized manner based on their potential risk; (4)
Evaluating and upgrading NCS programmatic controls and related management systems; (5)
Reviewing completed NCSA/Es against the enhanced program for potential changes; and, (6)
Improving the NCS training for NCS and site personnel.
The remainder of this Plan lists both completed actions and actions which remain to be completed.
Those actions remaining to be completed have, for completeness been broken into sub-tasks which are contained in the body of the plan by task number. Each remaining task is preceded by a short description. The date by which each overall task will be completed is contained in Table 2.
B.
Immediate Compensatory Actions l
in November 1997, USEC recognized, based on the magnitude of the deficiencies being identified, that immediate compensatory measures would be required while an overall NCS program upgrade was being formulated. These immediate actions included an evaluation of program safety, shutdown of certain FMOs, and the implementation of an additional review of past problems. These actions are discussed in more detail below.
l GDP 98-0216 Page 2 of 22 1.
Evaluation of Program Safety An evaluation of NCS program safety was initiated in order to provide management with confidence that the findings identified to date do not represent an immediate safety problem.
The following specific actions were initiated in order to provide this level of confidence.
(a)
Walkdown of NCSA/Es Associated with SAR Accident Scenario Walkdowns were performed on 13 NCSNEs determined to be associated with the Safety Analysis Report (SAR) accident analysis. These walk-downs were completed and concluded that the associated NCSA/E controls were adequately implemented.
Twenty-two prs were identified, one of which was a 24-hour NRC event report.
(b)
Review of Surveillance Requirements A revie'v was performed to verify that NCS surveillances and Technical Safety Requirement (TSR) surveillances for single contingency FMOs were being performed.
No surveillances were overdue.
(c)
Building Review of NCSA/Es The managers for each building in which FMOs are performed have begun to review the implementation status of the existing NCSA/Es in their buildings These reviews are to ensure that the descriptions in Part A of the NCSA/Es are accurate and complete and that the controls identified in Part B and Part C are being implemented. The plan for performing these reviews follows:
Task 1 Building Review of NCSA/Es Subtask No.
Description 1.1 Develop a list of NCSA/Es by facility. Assign reviews and schedule for completion.
1.2 Develop review guidance for building personnel.
1.3 Perform training of building personnel, using the guidance developed in Subtask 1.2.
1.4 Perform reviews of NCSA/Es. Report completion to Nuclear Safety Manager.
1.5 Write Problem Reports for identified deficiencies.
1.6 Evaluate Problem Reports for reportability.
1.7 Develop corrective action to address deficiency identified in Problem Report.
1.8 Implement corrective actions.
(d)
Review of NCSA/Es Completed bv Non-aualified Personnel It was detemiined that NCS engineers that were not properly qualified authored certain l
NCSA/Es. These NCSA/Es are being reevaluated by qualified NCS personnel. The plan for performing these reviews follows:
GDP 98-0216 Page 3 of 22 Task 2 Review of NCSA/Es Completed by Non-qualified Personnel 1
Subtask No.
Descrintion 2.1 Develop list ofindividuals who are not qualified.
2.2 Develop list of NCSA/Es that were authored or peer reviewed by these individuals.
2.3 Write a review plan.
2.4 Assign review team (s).
2.5 Review NCSA/Es on the list against the guidance provided in the review plan. Document deficiencies in a Problem Report.
The Problem Report system will be used to document and initiate the corrective actions for these deficiencies.
2.6 For NCSA/Es that have identified deficiencies, assign a qualified NCS engineer to correct problems.
2.7 Correct NCSA/Es.
Task 26 will document the review of the calculations completed by personnel for which full documentation of qualification was not evident for the time frame in which the calculations were done. There are no immediate safety concerns with the calculations because:
the peer review for calculations was, and is, more rigorous than that for NCSAs; many of the calculations are not specifically referenced by NCSAs; the calculations done by the NCS engineer of concern, based on the NCSA review, have been reviewed and found to be correct.
(c)
Review of Event Renorts A focused review was performed of all event reports where either single or double contingency was lost. Each event was evaluated to ascertain what conditions remained which would have prevented a criticality. This review concluded that conservatisms built into the NCSA/E process were effective in providing protection even under a lo.ss of contingency situation.
2.
FMOs Shutdown FMOs such as cell treatment activities and those covered by NCSA/Es which were improperly altered by ens were either brought into compliance or stopped until compliance was achieved by either changing the requirements or changing the activity. In addition, FMOs may be stopped as a result of the reviews performed under Task 2. Task 21 identifies additional work being undertaken to assure that all FMOs are identified.
3.
Daily Review of Problem Reports A team of NCS personnel has been assembled to review Problem Reports, on a daily basis, to ensure that the proper immediate actions and reporting were taken. In addition, a flowchart for providing assistance to the PSS for NCS prs has been developed and is being used by
GDP 98-0216 Page 4 of 22 NCS personnel in responding to requests from the PSS. The purpose of the flowchart is to ensure that the thought process for all NCS engineers is consistent when responding to the PSS. Also, a two-man rule for responding to NCS prs has been put into effect along with implementation of the Duty NCS engineer. These activities will be proceduralized as part of Task 12.
C.
Root Cause Analysis Three separate root cause evaluations of problem reports related to the NCS program have been, or are being, performed since the cell treatment NCSA/E problem was identified: 1) an informal evaluation performed by the Nuclear Safety Manager; 2) a Taproot review on NCS Problem Reports from 1997 performed by the Corrective Action Program Manager; and 3) an ongoing Taproot evaluation on the 1977 NCS related Problem Reports intended to drive the individual root causes down to a Level 5 (specifir.) cause. These Problem Reports included deficiencies identified in NRC Inspection Reports and h.ternal Assessment Findings. The details of each of the three evaluations follow.
1.
Nuclear Safety Manager This evaluation was performed to support the development of an initial corrective action program. Four specific root causes were cited: management systems failure; technical rigor in the development and implementation of NCSA/Es was inadequate; the Audit and Evaluation Process did not work to detect NCS problems; and the Standard, Policy, or Administrative Control (SPAC) governing the development of NCSA/Es was confusing or incomplete. These root causes were used to justify the main thrust of the corrective action program wUch was described in USEC letter GDP-97-2030, dated November 10,1997, 2.
Corrective Action Program Manager To provide a more detailed evaluation of the root causes, the Corrective Action Program Manager performed a formal Taproot root cause determination. Problem reports written against the NCS program in 1997 were evaluated to determine near root causes and then an i
aggregate set of those near root causes was evaluated The near root causes were largely grouped into three main root cause focus areas: NCSA/E errors (84), procedure flowdown errors (95), and failure to follow procedures (124). The aggregate set determination yielded three root causes:
a.
Errors in the NCSA/Es Some NCSA/Es were determined to have technical errors which made it difficult to implement their requirements in the field, b.
Inadeauate imnlementation In some cases the requirements contained in the NCSA/Es were not adequately implemented in the field.
c.
Self-assessment and intemal corrective action processes were inadequate to detect and correct the problems.
~
GDP 98-0216 Page 5 of 22 3.
Comprehensive Root Cause Evaluation In response to questions regarding assurance that all root causes have been identified and are being addressed in the corrective action program, a third root cause evaluation was initiated.
This Taproot evaluation was performed by a team consisting of the Nuclear Safety Manager (part time), PORC chairman (part time), a Taproot process facilitator, and a number of individuals who were familiar with the details and history surrounding the individual Problem Reports themselves. At a minimum, two individnis plus the facilitator were present for the evaluation of each Problem Report.
The first step in this evaluation was to identify, in flow chart form, the process of development, review and approval, activation, and implementation of a typical NCSA/E.
Each step in the process was assigned an identifying number. The Problem Reports were evaluated to a Level 4 "near root cause." Each Problem Report was also associated with a specific step number. The results are as follows:
Number of Sten Number Sten Descrintion ProblemRecorts 1
Identification of Fissile Material Operation 5
2 Part A Prepared 28 3
Part B, Part C Prepared 52 4
NCS Subcommittee 1
5 PORC (approval of NCSA/E) 1 6
Procedure Development 18 7
Procedure Review Board 0
8 PORC (approval of procedures) 0 9
Verification Walkdown 28 10 Activation 1
11 Use (implementation) 113 12 Monthly Ops walkdown 1
13 Biennial NCS walkdown i
14 SelfAssessments 4
The above results were then evaluated against the Taproot list of root causes. For each step, the basic root causes which clearly did not apply were eliminated and those which did, or could, apply were captured on a list ofroot causes to be treated. The result of this evaluation is a list of root causes sorted by process block number. This sort is shown in Table 1. The root causes listed in attached Table 1 will be corrected as part of the NCS corrective action program.
Validation of the results of the root cause evaluation and other completion activities will be completed in accordance with Task 6 which is located in Section E of this plan.
Enclosure i GDP 98-0216 Page 6 of 22 D.
Interim NCSA/E Review Process While the longer term upgrades to the NCS administrative control process are identified, developed, and implemented, a number of enhancements will be added to the NCSA/E development, approval and implementation process. They include:
1.
Enhanced Review Process (Murder Board)
To ensure that the NCSA/E development process is carried out properly, an additional review board has been added to enhance the PORC and subcommittees' review. This review board is referred to as the murder board and works in accordance with a formal charter. The owner (operations) and developer (NCS Engineer) are tasked with presenting drafted NCSA/Es in front of a board consisting of a minimum of four professionals representing Nuclear Safety, Operations, Maintenance, Work Control, or Safety, Safeguards and Quality, whose task is ensuring that aspects of the draft NCSA/E (e.g., assumptions, calculations, procedure steps) are correct. This satisfaction is created by obtaining the appropriate answers to questions from the board from the NCSA/E developer and/or owner. The murder board concept has been borrowed from the reactor industry where it has proven to be successful in improving the quality of final documents such as NCSA/Es. This addition to the existing process will improve the quality of the NCSA/Es and help the NCS and Procedure Review Board subcommittees of the PORC improve the quality of their reviews. The Murder Board will be used until USEC is satisfied that the quality of NCSA/E development and review has reached an acceptable level. Discontinuing the use of the Murder Board will not be considered until at least May 31,1998. See Task 19.
a er careful consideration, the Murder Board was discontinued because the changes to the l
NCS subcommittee of the PORC are sufticient to effectively and appropriately ensure l
NCSA/Es are properly developed.
l 2.
Involvement by Owners and Engineering As noted in the root cause results, the lack of ownership by the actual users (owners) of the NCSA/Es has been responsible for a large portion of the NCSA/E problems. This lack of ownership has contributed to the technical shortcomings of the NCSA/Es when proper support and reviews of draft NCSA/Es were not adequately performed, and contributed to a lack of understanding of the final NCSA/Es themselves, resulting in implementation deficiencies.
To correct this problem, representation by the implementing organization in the form of a management individual and a hands-on user (typically an hourly person), a System Engineer, and a NCS engineer will be required on the team which develops the NCSA/E, supports its progress through the review and approval process, and performs the required plant walkdowns to verify the NCSA/E. This will help ensure the technical accuracy of the NCSA/E, ensure that any required actions can actually be physically accomplished, and that the procedures implementing NCSA/E actions are correct.
It will also help ensure that the actual implementation in the field will be correct. (Note: Murder Board members cannot be used as members of the walkdown and review teams. Ilowever, members of the murder board will accompany the review teams on field walkdowns of selected NCSA/Es.)
l l
l GDP 98-0216 Page 7 of 22 In addition, a review will be performed to verify all PORC approved NCSA/E's are being implemented or are in the process of being implemented in the field.
3.
Revise NCS Procedures In order to ensure the interim NCS administrative controls are implemented correctly and consistently, the procedures which provide the administrative controls will be revised to reflect the interim changes. Refer to Section E, Task 12 (NCS Policies and Procedures) for a discussion of the plan to implement these procedure revisions.
4.
Review /Walkdown NCSA/Es Using the Prioritized List t
l In parallel with activities to improve the NCS program, existing NCSA/Es will be subjected l
to the NCSA/E Upgrade Project on a prioritized basis. The list of applicable NCSA/Es, by l
priority, was included in Enclosure 2 to USEC letter GDP 97-0217, dated December 22,1997.
l This will ensure that high risk NCSA/Es are reviewed for technical adequacy and proper procedural flowdown and implementation as soon as practical.
As the long term programmatic improvements are implemented, NCSA/Es which have been subjected to the interim process will be evaluated to determine if they need to be reverified to ensure they reflect all program improvements. Once the.NCS program improvements have been incorporated into procedures and site personnel training is complete, this new program will be used to finish the reviews and walkdowns on the remainder of the NCSA/Es. The plan for performing these reviews follows:
Task 3 NCSA/E Upgrade Project Subtask No.
Subtask Description 3.1 Classify the NCSA/Es into three groups according to priority.
3.2 Verify that all PORC approved NCSA/Es are activated or progress toward activation is being accomplished.
l 3.3 Form review groups consisting of representatives fiom NCS, Systems Engineering, Operations Management, and a hands-on operator or l
l maintenance technician.
3.4 Develop a procedure for the perfbrmance of reviews and walkdowns.
Maintain procedure current through life of upgrade project.
l 3.5 Table top scrub NCSA/Es and their supporting documents 3.6 Field walkdown all NCSA/Es.
3.7 Ensure consistency with PGDP NCSA/Es fbr similar activities.
3.8 Accelerate processing of identified changes to NCSA/Es and procedures.
3.9 Review and approve NCSA/E implementing procedure changes.
3.10 Walkdown PORC approved NCSA/Es to document their readiness for activation.
4
GDP 98-0216 Page 8 of 22 5.
Enhance NCSA/E Training In response to recent NCS events, the General Manager conducted all-hands briefings to communicate management's expectations regarding implementation of NCS controls. To further ensure that the interim NCSA/E Review process is implemented correctly, training will be provided to personnel who will use, or be affected by, the interim process. The plan for developing and implementing this training fbliows:
Task 4 Enhance NCSA/E Training Subtask No.
Subtask Descriotion 4.1 Compile list of administrative controls document changes.
4.2 Identify target training audience by organization orjob function.
4.3 Develop training module for each target gn op.
4.4 Administer training.
In addition to the interim process training, training will be given as determined to be necessary to communicate such things as lessons learned from the NCSA/E walkdowns currently being perfomied or other information determined to be important for all affected personnel to know.
1 The exact nature of this training may vary from required reading, memos and e-mail messages to fonnal classroom training, depending upon the nature and complexity of the subject matter.
Also see Task 23, 6.
Safety, Safeguards and Quality (SS&Q) Review of Implementation As part of the ongoing self assessment activities at PORTS, SS&Q is monitoring the implementation of new NCSA/Es in the field. This monitoring utilizes ANSI /ASQC Zl.4, Sampling Procedures and Tables for inspection by Attributes, for sampling guidance and takes the form of a series of assessments that began as the NCSA/Es coming from the interim change process ere implemented. The plan for implementing this review process follows:
Task 5 SS&Q Review ofImplementation Subtask No.
Subtask Description 5.1 Develop list of NCSA/E changes from Task 3.
5.2 Write an Assessment Plan. The plan will include, in part, a sample review of NCSA/E requirements and verification of those requirements in the implementing procedures.
5.3 Schedule assessments as an extension of Subtask 3.10's schedule.
5.4 Perform assessments in accordance with applicable procedures 5.5 Complete a review of all canceled Engineering Notices to ensure that the Document Control Organization has functioned properly to make each controlled copyholder and each affected organization aware of the canceled Engineering Notices and therefore the cancellation of that specific operation as defined by the Engineering Notice.
GDP 98-0216 i
Page 9 of 22 7.
Response to Anomalous NCS Conditions i
To ensure consistency between the GDPs, PORTS has provided the following guidance to plant personnel as to the actions to take in response to anomalous conditions regarding NCS controls:
l Activities in the immediate area will be stopped.
The area will be secured.
The supervisor of the person discovering the condition will be notified.
The Plant Shift Superintendent (PSS) will be notified and will subsequently notify the NCS manager or the Duty NCS Engineer.
An NCS Engineer will direct the recovery operation. (The NCS Engineer along with the PSS will decide if the NCS Engineer should be present during the recovery operations.)
l These actions have been communicated via a standing order and training of all FMO personnel has been completed. These actions were incorporated into appropriate procedure (s). These actions fulfill the requirements of paragraph 7.6.4 of ANSI 8.20 - 1991 and of paragraph 5.2.2.2 of the Safety Analysis Report.
8.
NCS Oversight NCS oversight has been provided on the operating floors to ensure continued heightened awareness of the importance of NCS controls. This is a temporary measure which will remain in effect until USEC is assured that proper awareness has been achieved regarding NCS controls. Also see Task 20.
E.
Programmatic Upgrades Task 6 Complete a Comprehensive Root Cause Analysis The problem reports (and other deficiency reports) that have been written during the past year have identified many deficiencies. These deficiencies when taken individually, or as groups of similar deficiencies, can be used to identify weaknesses in the prognun and/or its implementation. This task is intended to ensure that lessons have been learned from our known problems, and incorporated into corrective actions. Since part of the root cause analysis has been done, this task starts with the next l
action to complete this task. (For the completed actions see Section C, Root Cause Analysis, of this plan.)
S.ubtask No.
Subtask Description 6.1 For each step of the NCSA/E process review a representative sample of the prs associated with that step and identify the specific Level 5 root cause(s).
6.2 Verify that the root causes identified above are included in the summary level root causes which were identified by the root cause team. For those that are not, revise the root cause documentation, increase the sample size, and submit a lessons learned / enhancement in accordance with the procedure described in Task 9.
l
GDP 98-0216 Page 10 of 22 6.3 If the detailed review root causes are included in the summary level root causes, document the review.
6.4 For each Level 5 root cause associated with each step of the NCS A/E process, (See Table 1 attached) or associated Management Systems, develop programmatic changes to correct root cause as part of this Corrective Action Plan for input to Task 12.
Task 7 Compare Applicable Industry Standards Against NCS Program To ensure that the NCS program complies with all applicable Industry standards, a detailed review will be performed. This review will be point-by-point, and the product of the review will be a set of NCS administrative control changes to be implemented. The plan ihr this review follows:
Subtask No.
Subtask Description 7.1 Review applicable industry standards.
7.2 Develop a list of applicable requirements.
7.3 Compare requirement list to our NCS programmatic controls and develop a discrepancy list.
7.4 Evaluate discrepancies Ihr need for immediate action, a Problem Report, or reportability.
7.5 Take any necessary immediate actions.
7.6 Evaluate discrepancies for need for interim action.
7.7 Develop and implement any interim actions required.
7.8 Develop long term programmatic enhancements, for input to task 12.
Task 8 Vertical t' lice Review To ensure that we have idet.tified all potential areas of enhancement, an in-depth vertical slice review of the NCS program is beirc performed. The vertical slice review is being performed by a team consisting of the NCS Managers from PORTS and PGDP and an outside expert in NCS. Using selected NCS A/Es, the review will identify any enhancements that could be implemented to improve the progmm. The vertical slice method is intended to look at all aspects of the NCS program from the initial identification of a potential Fissile Material Operation to the use of the NCSA/E in the tield, including on-going assessments.
The subtasks of this activity are shown below.
Subtask No.
Subtask Descrintion 8.1 Assemble the team for the vertical slice review.
8.2 Develop a methodology for doing the review. The methodology shall cover:
selection of NCSA/Es to ensure that all aspects of the program are included in the review, selection of NCSA/Es to ensure that all organizations affected by the NCS program are included in the review, the methods to be used for the review, the documentation to be provided as a result of the review, 4
J
't Enclosure I GDP 98-0216 Page11of22 the methods to be used to initiate changes to the NCS program (e.g.,
Procedure Development Fonns.)
8.3 Conduct the vertical slice review of the program using each selected NCSA/E.
(As each NCSA/E is compleud, enhancements to the NCS program will be developed.)
8.4 Submit program enhancements to the Nuclear Safety Manager for inclusion in the continuous improvement mechanism for the NCS Corrective Action Plan.
(See Task # 9.)
Task 9 Continuous improvement Program Throughout the NCS Corrective Action Plan implementation, there will be a lessons learned program to ensure that lessons learned are documented, disseminated to the appropriate personnel, and incorporated into procedures, as applicable. The lessons learned program will ensure that the NCS program and implementation continue to improve over time. Another major part of the lessons teamed program is ensuring that previously approved products are sufficient to ensure safety in light of the new lesson learned. Each lesson learned will be reviewed to identify the effect on related NCSA/Es whether or not the respective NCSA/E has already been reviewed under the Corrective Action Plan. Lessons learned that affect the safety of approved Fissile Material Operations (FMOs) will be documented in a PR. The PR will then be used as the method to document the specific actions taken to ensure safety.
Subtask No.
Subtask Descrintion 9.1 Develop or revise a procedure applicable to all personnel involved in the NCS Corrective Action Plan implementation, that provides the guidance for documenting lessons learned and enhancement ideas.
The procedure shall cover:
use of a standard format.
a documented disposition for each lesson teamed to identify how and when to incorporate the enhancement into the process.
A documented identification of the potential affect of the enhancement on previous work performed under the NCS Corrective Action Plan.
Primary users of the lessons learned / enhancement mechanism.
Ilow the lessons learned will be shared with all affected organizations.
Training will be utilized as necessary to ensure proper understanding of the lessons learned.
9.2 Implement the new procedure.
9.3 Track the disposition of each lesson learned / enhancement idea to ensure that those agreed to by the Nuclear Safety Manager are incorporated into the NCS program.
9.4 For those NCSA/Es that are affected by changes in the program due to lessons learned throughout the program, ensure that there is a positive control mechanism to track the need for a re-review to incorporate the lessons leamed.
4 4
+
+
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i GDP 98-0216 Page 12 of 22 Task 10 Personnel Qualification Verification To ensure all PORTS NCS personnel qualification requirements meet applicable industry standards, a detailed review of qualification requirements will be accomplished to verify their adequacy.
Engineers not meeting upgraded standards will be retrained as necessary. The plan to accomplish these reviews follows:
S.ubtask No.
Subtask Description 10.1 Review available qualification requirements in applicable industry guidance.
10.2 Compare guidance to existing administrative control procedures.
10.3 Resolve any identified discrepancies (revise procedures).
10.4 Compare qualification requirements to NCS engir.eert records 10.5 Generate list of people to have upgrade qualifications 10.6 Utilizing the new procedures, qualify individuals identified in step 10.5.
10.7 Re-evaluate and identify upgrades to the training and qualification program for NCS personnel to more clearly describe additional details such as applicability, tasks covered, restrictions during training status, evaluation of candidate's qualifications, and documentation requirements.
10.8 Develop or upgrade procedures, TDAG, training modules as appropriate to support 10.7. (See Task 12.)
10.9 Train and qualify NCS personnel in accordance with the upgraded program.
(See Task 12.)
Task 11 Outside/ Independent Assessments As part of the effort to identify potential areas ofimprovement, assessment reports performed by independent groups, e.g., George Bidinger, Quality Assurance and the Plant Performance Review Committee, etc., will be re-reviewed and re-evaluated to identify problem areas in the NCS program and to ensure proper closure of the issues. Additionally, NRC inspection reports will be evaluated for similar problem areas. Problems identified through this review will be considered for programmatic improvements. The plan for performing these reviews follows:
Subtask No.
Subtask Descriotion 11.1 Identify reports that fall within the scope of this task.
I 1.2 Review each report and document potential problem areas.
I 1.3 Compare the list of problem areas with the list of known deficiencies identified through other means (e.g., compreheicive root cause, ANSI reviews, etc.)
'11.4 For those problem areas that were not documented under other tasks, identify potential programmatic improvements using the process established for feedback oflessons learned and enhancements. (See Task #9.)
Task 12 Policy / Procedure Revision and Training The NCS program from beginning to end (each step of the process) has had Problem Reports associated with it over the past year. The root cause evaluation has identified the Problem Reports from 1997 and the steps of the NCS program to which they are associated. In order to provide long-
i GDP 98-0216 Page 13 of 22 tenn enhancements to the NCS program and thereby ensure that the NCSA/Es and their implementation is excellent, we plan to upgrade NCS policies and procedures.
As programmatic upgrades are identified, it is expected that a number of procedures and other administrative control documents will need to be changed. These changes will also have to be communicated to affected personnel through training. Changes will need to be coordinated to maximize efficient use of procedure and training resources. The plan to accomplish needed changes to policies / procedures follows:
Subtask No.
Subtask Descrintion 12.1 Implement procedure changes for interim program as described in Section D.
12.2 Develop list of needed proc edure changes, new procedures, from the applicable tasks.
12.3 Accomplish procedure changes (including required reviews).
12.4 Develop training modulen.
i 12.5 Identify target audience far training.
l 12.6 Administer needed training.
12.7 Implement procedure changes.
Task 13 Revise Training Program for Site Personnel One of the identified root causes for NCSA/E implementation problems was that the training on NCSA/Es was not effective. To address this, the overall training for NCSA/Es will be evaluated to identify improvements which are needed. The plan to accomplish this review and upgrade follows:
Subtask No.
Subtask Descrintion j
13.1 Evaluate results of prior training.
13.2 Develop a list of programmatic problems.
13.3 Perfbnn a root cause evaluation on each identified problem.
13.4 Identify actions to address root causes.
13.5 Incorporated improvements into the training administrative control process.
13.6 Upgrade training modules to reflect improvements.
13.7 Determine retraining required to reflect upgrades.
13.8 Administer required retraining using the revised program.
Task 14 Corrective Action Program Enhancements As a result of the review of the current NCS progrc.m implementation delciencies, it is apparent that many of the existing problems have been in existence for some time, 4.g., there are 500+ Problem Reports related to NCS from 1997). If our corrective action program was effective, many, if not most, of the NCS problems should have been solved aller their first appearance. While this ineffectiveness of the corrective action program for PORTS is applicable to areas other than NCS, the subtasks t
described below are intended to focus on the NCS related portions of the corrective action program, i
I I
l l
GDP 98-0216 Page 14 of 22 Subtask No.
Subtask Descrintion 14.1 Evaluate the PR procedure and form to determine what improvements are required to better document the following:
immediate actions taken, actions taken to prevent recurrence, extent of condition evaluation, root cause determination, corrective actions taken, basis for safety and compliance with TSRs and NCSA/Es.
14.2 Ensure that the team assigned to determine the response to an NCS related PR includes a representative from the NCS organization.
14.3 All NCS prs should include an evaluation for the extent of condition of the problem on other activities and equipment.
14.4 Evaluate the administrative system of the corrective action program, especially the status tracking and action response mechanism, to streamline the process so the reporting of completed actions and tracking of open items is less time intensive.
14.5 Enhance the corrective action program by implementing the improvement ideas.
Conbguration Management Program Enhancements Task 15 As changes are made to the NCS program, it is imperative that supporting design documents are changed appropriately to maintain their accuracy and consistency with one another. The plan for effecting the needed changes to design documents follows:
Subtask No.
Subtask Descrintion 15.1 Develop program changes to ensure that engineering documents are maintained consistent with NCSA/Es.
15.2 Implement the new program requirements.
Task 16 Revise Assessment Programs As part of the overall upgrade of our NCS program, evaluation of supporting programs will be done and any changes or improvements identified as necessary will be accomplished. Among the most important of these programs is the assessment program. All of the various assessment processes will be reviewed for potential improvements. The plan to accomplish these reviews follows:
Subtask No.
Subtask Descrintion 16.1 Develop criteria for assessment program reviews.
16.2 Review each assessment program against criteria.
l 16.3 List any identified problems.
l 16.4 Perform a root cause evaluation on each identified problem.
16.5 Develop list of root causes.
16.6 Develop corrective action plan for each program.
16.7 Train affected personnel 16.8 Implement upgraded assessment programs.
Enclosure i GDP 98-0216 Page 15 of 22 Task 17 Oversight of Plan Implementation.
To provide assurance that the Corrective Action Plan ir being implemented in accordance with management's expectations, SS&Q will perform bi-monthly assessments, to verify proper implementation. The first assessment was completed before the first quarterly review.
Subtask No.
Subtask Description 17.1 Develop assessment plan and schedule to be used to evd
- the effectiveness of Corrective Action Plan implementation.
17.2 Perform assessments as defined in the assessment plan.
F.
Schedule See Table 2.
G.
Evaluation and Feedback As this Plan is implemented, adjustments to action scope, prioritization, and schedules may be required. At least each quarter, a formal review will be performed to assess the adequacy and effectiveness of the program. Included in this review will be an assessment of the existing schedule and the findings from the applicable SS&Q assessment addressed by Task 17.
Task 18 Evaluation and Feedback Subtask No.
Descrintion 18.1 Gather pertinent status information.
I 8.2 Compare status with the respective Task requirement and schedule.
18.3 Initiate any required corrective actions.
18.4 Factor in lessons learned through Task 9.
18.5 Report to management.
Task 19 Evaluate Continued Use of hlurder Board See Section D.1 of the Corrective Action Plan.
l l
Task 20 NCS Field Operational Assistants (FOA)
FOAs were assigned to provide on-shift, field support to Operations regarding nuclear criticality safety l
concerns. Ilowever, this interim measure has fulfilled its purpose since Operations personnel have l
an increased awareness of NCS requirements. Therefore, this position has been eliminated.
l l
Task 21 Fissile Material Operation (FMO) Identification This task is intended to assure that all FMOs are identified. A short-tenu effbrt consisted of a review of canceled NCSAs and verifying that those operations were indeed shut down. A long term effort consists of developing a procedure fbr a documented review of all operations, determining and classifying operations as fissile and non-fissile, and communicating these classifications to the field.
l GDP 98-0216 Page 16 of 22 Suhlasido Subtask Descrintion 21.1 Review canceled NCSAs and verify that those operations are shutdown.
21.2 Develop methodology and documentation requirements to review and classify operations as fissile or non-fissile.
l 21.3 Develop and submit a Request fbr Criticality Safety Evaluations (RCSE) to l
NCS for determination of non-fissile material operations.
l 21.4 Develop non-fissile material operation evaluation for each RCSE submitted by l
Operations.
l 21.5 Develop a non-fissile material operation listing and distribute to all NCSA/E l
manual holders.
l l
Task 22 Compare SAR Chapter 5.2 To Applicable Industry Standards and the NCS Program This task was added to the CAP to ensure that all documentation that describes the NCS program is l
consistent between SAR Chapter 5.2, industry standards, and NCS program documents. The plan for accomplishing this task is as fbliows:
Subtask No.
Subtask Descriotion 22.1 Compare requirements list generated under Task 7 to SAR Section 5.2, industry standards, and NCS prograni not conflict with standards.
22.2 Compare SAR Section 5.2 to plant NCS procedures and if neccesary develop a discrepancy list.
22.3 Evaluate discrepancies for need for immediate action, a problem report, reporting, and then take appropriate action.
l 22.4 Develop long term programmatic enhancemems for input to Task 12.
Task 23 NCS Short-Term Corrective Actions Due to the continued number of NCS violations and subsequent NRC event reports, a process for implementing short-tenn (quickly implemented) corrective actions that focus on the recent and current problem reports was instituted in an effort to stop the violations. The short-term corrective actions are intended to allow time for the long-tenn NCS program upgrade actions to take hold. These short-term actions are discussed daily and new actions are added as additional problems (or near misses) identify the need; actions, responsibilities and due dates are tracked to completion. This is an ongoing task and there are no further subtasks. The following describes those short-term actions taken to date; Between March I l-13,1998, the Portsmouth Plant initiated a " Plant Wide NCS Stand-j down". During this time period, each operation having NCS controls was suspended from performing NCS related activities (except for those required by the TSR) while l
facility Fissile Material Operations ( FMO) personnel (i.e., currently,1217 plant personnel) participated in crew briefings on the NCS Corrective Action Plan, the
" spacing" problems, the affected NCSAs, spacing controls, and expected responses to anomalous NCS conditions. An error lab was also established to challenge and introduce personnel to NCS control problems and to emphasize correct solutions to various NCS non-conformances. Over 1400 plant personnel have completed this exercise. In addition, FMO personnel were issued key chain type tape measures as an NCS awareness tool to be used in the field to ensure proper spacing.
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GDP 98-0216 l
Page 17 of 22 1
i Process building access control was implemented to ensure that building managers are l
thoroughly aware of all storage activities within their buildings and that personnel l
j understand controls and requirements prior to the start of the activity.
4 Require that all work packages include specific action steps / check sheets (consistent
=
with approved procedures) for disposal of scrap or waste generated during the job.
l This action is intended to ensure jobs involving potentially fissile material and/or waste have adequate guidance in the work packages with respect to how to handle and i
store potentially lissile wastes.
i j
Add some " operating margin" to items that are stored under administrative spacing i
requirements. (Areas where it is physically impossible to do this are exempt.) This 1
action is intended to look for areas where NCS controls (such as spacing) could be i
enlarged to give personnel some operating margin prior to reaching a limit. For example, if the requirement for spacing is a minimum 2 feet edge-to-edge, the storage j
arrays should preferably be greater thaa 2 feet.
Institute pre-job briefs for all NCS related activities to discuss the NCS requirements of the job. This action is intended to ensure that prior to starting a job involving potentially tissile material the workers performing the job have adequate guidance in where to put the waste, the workers are briefed on the associated NCS controls, and there are adequate storage locations ready to receive the waste.
Revisit pre-job briefing activities to ensure adequate follow-on implementation
}
guidance / procedure is in place, and pre-job brielings are consistent plant-wide. This action is intended to ensure that the improvements to pre job briefings were consistent across the plant, and that they continue.
Review all storage areas to ensure NCS compliance (this was done in conjunction with the task described in the second bullet concerning adding " operating margin" to items that are stored under administrative spacing requirements).
Revise NCSA Plant 18, " Dry Active Waste," and NCSA Plant 48, " Contaminated Metals," to establish short term improvements. This action is intended to correct the most frequent sources of NCSA compliance issues.
Conduct a building-by-building clean-up to eliminate scrap. This action is intended to get rid of excess material in the process buildings and to minimize the material available that could potentially lead to violations of NCS requirements.
Establish controls over all aspects of storage areas such as: boundaries, access pennits, postings. This action is intended to address the apparent inconsistent and/or informal implementation of NCS waste storage areas across plant site. Guidance has been provided to the field for boundaries, access permits, and postings. Field personnel are currently evaluating and implementing changes to the storage areas, llowever, this is becoming less of an issue as the storage areas are being cleaned-up.
I GDP 98-0216 Page 18 of 22 Disseminate Problem Report infonnation to the floor level. This action is intended to ensure the details and lessons learned from NCS violations are being relayed to the l
craft verbally in a face-to face setting.
Implement Boundary Control Station (BCS) improvements. This action is intended to evaluate, and if possible, reduce the need for the number of BCSs. This effort is intended to limit the potential for NCS violations.
l Establish routine PA announcements on NCS violations / lessons learned. This action is intended to provide a mechanism to inform all plant personnel of current NCS violation lessons learned, and to provide capsules ofinformation of some NCSAs to stimulate discussion.
Task 24 PEll Deposit Surveillance Tracking As detailed in USEC's response to NOV 70-7002/98003-01 (USEC letter GDP 98-2018, dated April 27, 1998), regarding a loss of fluorinating environment associated with a PEll deposit, USEC committed to develop and implement a formal prognun procedure for tracking PEII equipment. The procedure includes detailed administrative control requirements for maintaining this PEll equipment l
in a fluorinating environment.
Subtask No.
Subtask Descrintion 24.1 Review effectiveness of short-term corrective actions and appropriateness of their inclusion in long term administrative control requirements; define any additional requirements.
24.2 Develop and approve procedure.
24.3 Develop and administer needed training.
24.4 Implement procedure.
Task 25 Compliance Plan Review This task will review Compliance Plan actions that impact NCS to ensure that the documentation is l
complete.
l Subtask No.
Subtask Descrintion 25.1 Define / document management expectations as well as standards and acceptance criteria.
25.2 Identify Compliance Plan issues which impact NCS.
25.3 Obtain appropriate evidence packages.
25.4 Review evidence packages and discuss issues with appropriate issue owners, i
as necessary, l
'5.5 Identify discrepancies.
l 25.6 Evaluate discrepancies for need for immediate actions, problem reports, reporting, and then take appropriate corrective action.
1 GDP 98-0216 Page 19 of 22 Task 26 NCSA/E Calculation Review This task was developed as follow-on from Task 2. During assembly of closure documentation for l
Task 2 it was determined that some NCS A/E supporting calculations were done by " unqualified" NCS l
l Engineers. This task will identify and review those calculations L
Subtask No.
Subtask Descrintion 26.1 Develop a matrix of NCSA/E calculations with respect to date, preparer, and peer reviewer.
26.2 Develop a list of calculations not prepared or peer reviewed by qualified I
personnel.
26.3 Review calculations identified in 26.2 for technical adequacy.
26.4 Evaluate discrepancies forimpact on NCSA/E and need for immediate actions, problem reports, reporting, and then take appropriate corrective action.
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GDP 98-216 Page 20 of 22 Table 1. Root Cause by Process Block Number 1
2 3
4 5
6 7
8 9
10 11 12 13 14 No SPAC' X
X X
X X
SPAC not Strict Enough X
X Confusing or incomplete X
X X
X SPAC Technical error X
X X
X Procedure use not required but X
X X
X X
X t
should be Procedure difficult to use X
Task not analyzed X
l Accountability X
X X
l Procedure facts wrong X
Training Lesson Plan X
No way to implement SPAC X
X g
- SPAC-Standards, Policies, or Administrative Controls t
NOTE: For NCSA/E process step names, refer to Section C.3.
I n
i F
GDP 98-0216 Page 21 of 22 Table 2. Implementation Schedule End Dates Task #
Description Target Date 1
Facility review of NCSA/Es 12/24/97 - Complete 2
Review of NCSA/Es regarding qualifications 04/30/98 - Complete 3
NCSA/Es Upgrade Project Pri l 12/31/98 Pri 2 06/22/99 Pri 3 05/31/00 4
Enhance NCSA/E Training (Interim Process) 02/28/98 - Complete 5
SS&Q Review ofimplementation Pri 1 02/15/99 Pri 2 08/15/99 Pri 3 07/15/00 6
Complete Comprehensive Root Cause Analysis 02/28/98 - Complete 7
Compare applicable industry standards against NCS Program 01/31/98 - Complete 8
Vertical Slice Review 05/31/98 - Complete l
9 Continuous improvement Program 01/31/98 - Complete 10 Personnel Qualification Verification 07/27/98 - Complete l
11 Outside/ Independent Assessments 04/30/98 - Complete 12 Policy / Procedure Revision and Training 12/31/98 13 Revise Training Program for Site Personnel 04/30/98 - Complete (Subtasks 13.6,13.7, and 13.8 will be completed by 05/31/00).
(Subtask 13.5) l 14 Corrective Action Program Enhancements 06/30/98 - Complete l
15 Configuration hfanagement Program Enhancements 02/28/98 - Complete 16 Revise Assessment Programs 10/30/98 17 Oversight of Plan Implementation 04/30/99 I
(bi-monthly) l 18 Evaluation and feedback Quarterly starting on 01/31/98 19 Evaluate continued use of Murder Board Not before 05/31/98 l
- Complete l
GDP 98 0216 Page 22 of 22 Table 2. Implementation Schedule End Dates Task #
Description Target Date D.7 incorporate Response to Anomalous NCS Conditions into 02/11/98 - Complete Procedure (s),
i D.8 Provide NCS Oversight on Operating Floors 02/02/98 - Complete 20 NCS Field Operational Assistants (FOA) 06/15/98 - Complete l
21 Fissile Material Operation (FMO) Identification 10/23/98 22 Compare SAR Chapter 5.2 to Applicable Industry Standards 06/15/98 - Complete I
and the NCS Program l
l 23 NCS Short-Term Corrective Actions Ongoing l
l 24 PEll Deposit Surveillance Tracking 05/11/98 - Complete l
[
25 Compliance Plan Review 11/30/98 l
26 NCSA/E Calculation Review TBD - Complete l
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i ENCLOSURE 2 GDP 98-0216 LIST OF CURRENT NCSAs i
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. -. - -.. ~ -
.. ~. _.. ~. ~... -.. ~........
... - ~ -
Manday, October 05,1998 Page 1 of 9 PRIORITY NCSANBR SUBJECT 1
0326_013.A06 Cascade Operations in the X-326 Building 1
0326_014.A01 X-326 Seal Exhaust Stations 1
0326_015.A04 Extended-Range Product (ERP) Withdrawal Station 1
0326_024.A04 Feeding of 5-inch,8-inch and 12-inch Cyts. in the X-326 Product Withdrawal Area 1
0330_004.A03 Cascade Operations in the X-330 Building 1
0330_005.A00 X-330 Area 2 Seal Exhaust 1
0330_006 A01 X-330 Area 3 Seal Exhaust and V.E r Evacuation 1
0330_007.A01 Product Withdrawal at the Tails Withdrawal Station 1
0330_013.A00 Lorig Term Storage of PEH Converter in X-330 1
0333_015.A03 Cascade Operations in Y X-333 Building 1
0333_016 A01 X-333 Area 1 Seal Exhaust and Wet Air Evacuation 1
0333_017.A01 Low Assay Withdrawal (LAW) Station 1
0342A001.A02 General Handling, Waighing, & Storage 1
0342A002.A01 Autoclave Operation 1
0342A004.A01 Oil Interceptor 1
0342A005 001 Sump 1
0343_001.001 General Handling, Weighing, & Storage 1
0343_002.A02 Autoclave Operation 1
0343_003.101 Oil Interceptors 1
0343_005.A02 Waste Streams 1
0344A001.A02 Autoclave Operation 1
0344A002.A01 Gulper System 1
0344A003.A00 X-344A Scale Pits and Sumps 1
0344A011.A00
- Technetium (Tc) Trap in Autoclave 1
0705_009.A00 Seal Dismantilng Room
_. m.a m
_ _._ _. _ _._._ ~. _ _... _
~.. _ _._._ _.
Monday, October 05,1998 Page 2 of 9 l
1 0705,012.A02 Small Parts Handtable Operatons i
1 0705.015.A09 -
Waste Water Treatment (Microfiltration System) 1 0705.024.0C5 Calciners, Solution Recovery l
1 0705_025.A00 N trous Oxide (NOx) Scrubber System
.1 0705_034.A02 Spray Booth Operations 1
0705_041.A00 C-Area Material Handhng & Storage 1
0705_042.A01 Small Equipment Tear-Down (" Blue Room")
1 0705_064.A00 Seal Can Handling and Storage in X-705 1
0710.009.A00 Storage Requirements for Fissile Material Transfer (Uranium Chain of Custody) Room 1
0710_026A00 Sampling, Transporting, and Handling in X-710 1
PLANT 004.A01 Storing and Handling of Large Cylinders of Uranium Material 1
PLANT 006.A04 General Use of Small Diameter Containers for Storing High Enriched Material 1
PLANT 018.A02 Dry Active Waste (Contaminated Dumablet) in Waste Generation Areas and in Interim Storage
-1 PLANT 022.A00 Sample Cylinder Handling and Storage 1
. PLANT 029.A00 Cascade Datum Systems 1
PLANT 030.A02 Evacuation Booster Stations 1
PLANT 033.A01 Surge Drums 1
PLANT 036.A00 Inter-Building Tie Lines 1
PLANT 043.A00 Fissile Material Transport 1
PLANT 049.0C1 Always-Safe Portable Small UF6 Release Gulpers 1
PLANT 054.A00 Lube Oil System 1-PLANT 055.A01 Laundry 1
PLANT 062.A00 Cascade Maintenance I
1 PLANT 066.A02.
Mop Buckets 1
PLANT 076.A00 340 Complex Oil interceptors, Scale Pits, & Sumps i
i l
,___.__.__m.,
_.m m..
l l
Monday. October 05,1998 Page3at 9 1
PLANT 079.A01 Opening Equipment containing Greater than A Safe Mass of Uranium-Beanng Material l
1 PLANT 080.A00 Use, Handling and Storage of Autoclave Filter Units 1
PLANT 082.A00 340 Complex Waste Streams l
1 PLANT 085A00 X-340 Complex Autoclave Operation TOTAL =
54 l
PRIORITY l NCSANBR SUBJECT 2
0326_022.101 X-326 Use of Portable HEPA Ventilation Units for Specific Activities 2
0326_028.A00 Handling and Storage of Seals with Undetermined or Unknown Enrichment in X-326 2
0330_003.A02 Storage and Handling of Seals in X430 2
0342A006.A02 Waste Streams 2
0343_008.001 Disposal of Pigtails, Manifolds, Cylinder Safety Valves, and Other Used Autoclave Componeds 2
0344A006.A03 Sample Cylinder Handling and Storage 2
0344A007.A04 Waste Streams 2
0344A010.0C1 Disposal of Pigtails, Mantfolds, and Cylinder Safety Valves, and Other Used AutoclaveComponents 2
0705.002.A02 2.5 Ton,10-Ton, and 14-Ton Cylinder Cleaning 2
0705_010.101 Small Parts Glass Bead Blaster 2
0705.018.A03 8-and 12-inch Cytinder Cleaning 2
0705_031.A00 Equipment Disassembly in the North Teardowti Area 2
0705.033.1C4 South Annex Operations. Cascade Equipment 2
0705.038.A01 Truck Alley Cleaning 2
0705_039.A02 Oil and Grease Removal System 2
0705_082A00 "A", "B", "C" Loop Pre-Evaporator Systerns 2
0705.086.A00 "A","B", and "C" Loop Post Evaporator Systenis l
2 0710.004.101 Gulpers for Mass Spectrometers 2
0710_006.A01 Uranium Samphng Laboratory (Implemented) l l-
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Monday, October 05,1998 Page 4 of 9 2
0710_008.A01 UF6 Isotopic Standards Preparation Laboratory j
2 0710_011.AQO Mass Spectrometry Laboratory l
2 0710_012.A01 UraniumAnalysis Laboratory 1
t 2
0710_020.A00 Process Chemistry Laboratory i
l 2
0710_021.A00 Process Services Laboratory l
2 0760_003.A01 Sample Buggy Repair 2
PLANT 011.A01 Use of Portable HEPA Ventilation Unds
(
2 PLANT 012.A01 Favorable Geometry Vacuum Cleaner 2
PLANT 013.A00 Batching Solutions and Solids 2
PLANT 025.A01 General Use of Small Diameter Containers for Stonng up to 10% Enriched Material 2
PLANT 031.A02 Use of Portable infrared Analyzers (PIRA Buggies, FTIRs, etc.)
2 PLANT 044.A00 Cold Recovery Cold Traps 2
PLANT 048.A03 Contaminated Metal 2
PLANT 050.A00 Use. Handling, and Storage of Fixed HEPA Filters and Prefilters l
l 2
PLANT 051.A00 Cold Recovery Chemical Traps l
2 PLANT 052.A00 Cold Recovery. Holding Drums 2
PLANT 053.A01 Uranium Analysis and Sampling 2
PLANT 057.001 Use of Gas Sampling Cart 2
PLANT 060.A02 Cylinder Valve Replacement l
2 PLANT 063.A01 Building Decontamination Activities 2
PLANT 064.A00 Handling and Storage of Seals in X-326, X-330, X 333 2
PLANT 065.A00 Use of Limded-Safe Geometry Vacuum Cleaners i
2 PLANT 068.A00 Negative Air Machine (NAM) i 2
PLANT 069.A00 Test Buggies t
i 2
PLANT 078.A00 Use of Ledoux iS Cylinders at PORTS 1
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.-- _ - -. - _ _.. -. - -.. ~ _ -
Monday. October 05.1998 page $ of g l TOTAL =
44 l
l PRIORITY NCSANBR SUBJECT 3
0326.001.A 32 Nuclear Cnticality Safety of Shutdown and Standby X-326 Cells 3
0326_016.A 00 Operating Floor Freon Degrader 3
0326_0273.00 Operation of the X-326 NDA Laboratory 3
0330_009A01 Flushing / Cleaning of 1 1/2" Vented Cavity Pipes and Compressor"B" Seal Cavities 3
0330_014A00 X-330 Cold Recovery Area Wet Air Evacuation System 3
0330_015,A00 X-330 Interim Purge f
3 0333,007.A01 1000 CFM Negative Air Machine 3
0333,018.001 Freezer / Sublimer 3
0333_022.A00 Flushing / Cleaning of Vented Cavity Pipes and Compressor "B" Seal Cavities 3
0333_023.A01 Long Term Storage of 33-8-6 Stage 7 PEH Compressor 3
0344A004.A00 Evacuation System and Cold Traps 3
0344A005.A02 X344A Small Diameter Container Storage 3
0700_001.001 Fissile Material at The Radiation Instrument Calibration Facility.
3 0700_002.A01 Heavy Metals Sludge Storage i
3 0700.004.AOC X-700 Converter Disassembly and Repair Area 3
0700,005.A00 Glass Bead Blasting
~
4 3
0700_006.A00 Blodenitrification (Pilot Plant and New Plant) 3 0700.007.A00 Cleaning Tank #3/ Converter Flushing Station 3
0700.016 A01 Uranium Bearing Matenals Storage Area Detween Columns D10 and D12 3
0700_017 A00 RCRA 90 Day Storage Area Bounded by Columns E2, E3, F2, and F3 3
0700_018.A00 X 700 Large Sandblasting Operation 3
0700_019.A00 Routine Operations in x-700 Cleaning Tanks 1,2,4,5 l
3 0700_020.A00 Operation of the X-700 Chemical Tanks 1,2,4, and 5
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I Monday. October 05,1998 page g ny 9 3
0705_004.A01 5-inch Cytinder Cleaning 3
0705_005.A00 Small Cylinder Rinse Pit 3
0705_011.A02 Small Parts Pit 3
0705.014 A01 Leaching / Complexing Handtable 3
0705.020.A00 Flocculation & Filtration of Solutions from Leaching Operations 3
0705_021.A01 B-Area Batching Handtable Operations 3
0705.022.A01 B-38, B-1, and Dissolver Solution Storages 3
0705_023.A00 Operation of the "A,""B," and "C" Loop Extractor / Stripper Systems 3
0705_027.A03 Heavy Metals Precipitation 3
0705_028.A00 Technetium ion Exchange 3
0705_030.A00 Recovery Elevator 3
0705.035.A05 Tunnel Storage l
3 0705_037.A00 Ground Water Sumps 3
0705_040.A00 Overhead Storage i
3 0705_043.A00 Elevator Tunnel 3
0705_044.001
' Maintenance Shop 3
0705_050.A00 X 705 Process Laboratory 3
0705_051.A01 Solution Preparat:on 3
0705.055.A00 Facility Drains 3
0705_071.001 2.5-ton,10-ton, and 14-ton Cylinder Drying 3
0705.072.A00 Inspection and Testing of UF6 Cylinders 3
0705_073.001 Genie Model AWP30 Manlift 3
0705_075.A00 F-Area Fissile Matertal Handling and Storage 3
0705_076.A00 Ina&ertent Containers i
3 0705.083.A01 "A","B", and "C" Loop Concentrate Storage and Metenng Systems i
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Monday, October 05.1996 Page 7 of 9 3
0705_084.A00 "A* and "B" Loop Raffir' ate Storage and Recycle System 3
0705_085.A00 "A","B,""C" Loop T-Water Storages 3
0705_099.A01 Post EvaporatorSpray Condenser and Sample Condenser Systems 3
0705.100.A02 Pre-Evaporator Spray Condenser and Sample Condenser Systems 3
0705_102.A00 B Area Condensate Drain System 3
0705.103.A00 Process Vent System 3
0705.105.A01 Cytinder Cleaning Gulper System 3
0705_107.A00 2.5-ton,10-ton, and 14-ton cylinder Receiving & Storage 3
0705_108.001 SEb (Solution Enrichment System) 2 (X 705) 3 0705_110.A01 Used Microfilters Removal and Storage 3
0705_111.A01 Buffing Booth 3
0705_114. A00 Facilities Utihties/ Services. Process Steam 3
0705_122.A02 Blending Cytinder Wash Solution
~
3 0705_123.A01 Small Cylinder Receipt and Storage 3
0705_124.A01 F-Area Oxide Glovebox 3
0705_126.A00 RCRA 90 Day Storage Area Roughly Bounded by Columns F-23,G-23, F-24 and G-24 3
0705_127.A00 Classified Scrap Metal (Seal Parts Only) 3 0705_128.A00 Storage of 8-inch EBS Pipe in the Large Parts Cage 3
0705_129.A00 Decontamination of Unfavorable Geometry Parts in Tunnel Spray Booths 3
0705_130 A00 Testing of the 5-inch and 8- & 12 inch Cytinder Cleaning Operations 3
0705_131.A00 Draining, Transferring, and Conecting Uranium-Bearing Liquids in X-705 l
3 0710.001.101 Use of NilFisx Model 80 Portable Vacuum in X-710 3
0710_007.A00 Small Diameter Container Storage in X-710 l
3 0710_014.A00 X-Ray Fluorescence Laboratory 3
0710_015.A02 Handling of Samples and Process Waste in ES&H Anar/tical Labs l
.. _... _~
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. Monday 0ctober03, f998 page a of g 3
0710_022.A00 Laboratory Standards and Controls 3
0710_023.A00 Miscellaneous Uranium Operatxms 3
0710_024.A00 Handhng and Storage of Sources l
3 0710_025.A00 Handling and Storage of Samples from ES&H Analytical Labs 3
0720.001.A02 Cleaning Lightly Contaminated Floor Areas 3
0720,003.A01 Dry Blast Machines for Non-Visibly Contaminated Parts 3
0720_009.A00 Small Parts Glovebox.
l 3
0720_014.A00 Valve Shop Vapor Degreaser 3
0720_015 A02 Cleaning and Decontaminating Space Recorder Cans 3
0720_016.A00 Transmitter Clea,ing Station 3
0720_018.A00 Hydro Table In the X-?20 Hydro Shop 3
0847_001.A03 General Storage of Uraqium-Beanng Waste, XT-847 1
3 0847_002.A02 Storage of B-25 Waste Boxes at XT-847 3
0847.003.A00 XT-847 Drum Crusher 3
PLANT 001.A02 Storing Small Diameter Containers in Plastic Bags, Plant 3.
PLANT 002.001 Water Cooling of UF6 Cylinders at LAW, ERP, Tails, X-342 and X 343 3
PLANT 014.A00 Use of Unsafe Geometry Vacuum Cleaners 3
PLANT 016.A00 Use of Commercial Floor Scrubbing Machines and Power Sweepers 3
PLANT 017.A00 Storage and Handling of B-4 Purrps 3
PLANT 028.A04 Removal and Handling of PEH Equipment 3
PLANT 034.A00 Liquid Waste Codection and Sampiing Systems 3
PLANT 036.A00 Storage of Safe Batch Containers 3
PLANT 037.A00 Use of Small Diameter Container Carts
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.3 PLANT 045.A01 Limited Safe Volume Containers 3
PLANT 070.A00 Miscellaneous Waste Accumulation Areas
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Monday, October 05.1998 Page 9 of 9 3
PLANT 074 A00 Decontamination Using a Steam Jenny 3
PLANT 077.A00 Long Term Storage of Legacy PEH Equipment
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3 PLANT 081.A00 Dry Ice Blasting For Decontamination 3
PLANT 083 A00 Use of Cascade Cells as Surge Volumes 3
PLANT 084.A00 Removal of Urantum Beanng Components with Less than 15g 235U TOTAL =
103 l
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