ML20198A540
| ML20198A540 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 12/29/1997 |
| From: | John Miller UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Pederson C NRC |
| References | |
| GDP-97-0217, GDP-97-217, NUDOCS 9801060013 | |
| Download: ML20198A540 (32) | |
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USEC A Wehol as, orgy compw y JAnnas H. heLLaR Dir: (301) 664-3309
%CE PRESIDENT, PRODUCTION Fax'(301) 671-8279 December 29,1997 t
l Ms. Cynthia Pederson, Director SERIAL: ODP 97-0217 Director of Division of Nuclear Materials Safety United States Nuclear Regulatory Commission 801 Warrenville Road Lisle, Illinois 60532-4351 Portsmouth Gaseous Diffusion Plant (PORTS)
Docket No. 70 7002 Transmittal of the Revised Corrective Action Plan for the Portsmouth Nuclear Criticality Safety Program
Dear Ms. Pederson:
(Note: his letter was originally submitted to the NRC on December 22,1997, however the USEC letter number on the cover page was incorrect. The correct letter number is ODP 97 0217. Thus, this letter supersedes the previous version submitted to you on December 22,1997. Dank you.)
This letter provides the infonnation requested in Nuclear Regulatory Commission (NRC) letter dated
.i December 1,1997. This NRC letter requested that USEC:
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- 1. Provide a revised Corrective Action Plan which integrates USEC letters dated November 7 and 10,1997, (ODP 97 2028 and ODP 97 2030) and incorporates the specific commitments, includir.g schedules and completion dates, made during teleconferences held on November 12 and 18,1997.
Response: Enclosed is the PORTS Nuclear Criticality Safety (NCS) Program revised Corrective Action Plan. This Corrective Action Plan integrates USEC letters dated November 7 and 10, 1997,(GDP 97 2028 and ODP-97 2030),and incorporates the commitments, including schedules and completion dates, made during teleconferences held on November 12 and 18,1997. His revised Corrective Action Plan is more comprehensive than the plan previously provided because, in part, it addresses enhancements to nuclear criticality safety programmatic controls and related management systems, ne schedules provided in the enclosed Corrective Action Pian continue to represent target dates. By the end of January 1998, these dates will be reevaluated based on
, experience gained during implementation of the plan.
U lll-l' lf,l'-l lll-l 6903 Rockledge Drive. Bethesda. MD 20817 1818 Telephone 301564 3200 Fu 301564-3201 http://wwwusec.com Omces in ljvermore. CA Paducah. KY Portsmouth. OH Washington, DC y.
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9901060013 971229 s
PDR ADOCK 07007002 I
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$4s. Cynthia Pederson December 29,1997 ODP 97-0217, Page 2
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- 2. Identify those areas involving the initial development of the nuclear criticality safety approvals (NCSAs) and the implementation of NCSA requirements in the field, where additional corrective or compensatory actions may 'oe warranted.
Response: Sections B and D of the Corrective Action Plan discuss immediate and compensatory actions (i.e., the interim NCSA review process), respectively. These actions were developed based, in part, on root cause analysis performed to date on NCS related Event and Problem Reports. These measures will be implemented over and above existing program requirements.
Examples include:
the use of additional review groups during the drafting of NCSA/Es; improved procedural guidance on NCSA/E development and activation; an additional review of Problem Reports on a daily basis to ensure that the proper immediate actions and reporting were taken; implementation of a second management review team for each NCSA/E prior to PORC review; and the establishment of an NCS Duty Engineer program to provide readily available support to the Plant Shift Superintendent.
Additional corrective actions to address programmatic improvements are discussed in Section E of the Plan. As programmatic improvements are identified through a review of existing NCS program requirements against applicable industry standards, completion of the comprehensive root cause analysis, and the vertical slice review, a feedback mechanism will be in place to adjust the interim NCSA process as necessary. Furthermore, lessons leamed from implementation of t
the interim NCSA review process will be fed back to the programmatic review and improvement effort as approprinte.
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- 3. Identify any interim compenntory measures which assure that management and staff, especially l
those principally responsible for operational safety features and particularly for those involving single contingency systems, understand their responsibilities and are implementing the controls in accordance with managements's expectations.
Ecsnansc: Compensatory measures (i.e., additional training) to improve the understanding of management and staff are discussed in the Corrective Action Plan, Section D.S.
- 4. Describe and provide supporting justification for any interim compensatory actions which are relied upon until long term corrective actions become fully effective in correcting root causes and j
preventing the recurrence of similar nuclear criticality safety problems.
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Ms. Cynthis Pederson L
December 29,1997 -
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ODP 97-0217, Page 3 i
Raspanne: 'Ihe descriptions ofimmediate and compensatory actions are provided in Sections B f
and D of the attached Corrective Action Plan. As discussed in Section B.! of the Corrective j
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Action Plan, an evaluation of NCS program safety was performed. USEC concluded from these i
reviews that: (a) the evaluations performed were of sufRcient scope and depth to provide an adequate assessment of program safety; and (b) the Andings to date do ist represent an immediata l
anfety problem.
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in order to keep NRC abreast of improvements to the PORTS NCS program, USEC will provide NRC with a quarterly update report of the enclosed Corrective Action Plan. Accordingly, USEC will submit the first update report to the NRC by January 31,1998.
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l, Table 2 lists the commitments made in this submittal. Enclosure 2 provides a list of 1
NCSAs that are being reviewed a part of the NCS Corrective Action Plan. As was documented in USEC letter ODP 97 0211 dated December 12,1997 NRC agreed to extend the due date for this letter'to l
December 22,1997.
If you have questions regarding this submittal, please contact Ron Gaston at (740) 897-2710.
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J es d. Miller ice President, Production Enclosures (2): As stated f
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INRC'DoomaantConne! Desk it NRC Resident Inspector. PORTS NRC Resident inspector.PODP DOE Regulatory Oversight Manager j
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PORTS Nuclear Criticality Safety Program Revised Correttive Action Plan 1
A. Background As part of the Certification Application effort, PORTS NCSA/Es were upgraded to provide more rigorous and accurate NCS documentation. This effort *vu completed in December of 1996.
Subsequent to this effort, in early 1997, USEC began to gstion the effectiveness of the NCS program. 'Ihis 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 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 flawed. Subsequent to this event, it was identified that Engineering Notices (ens) were being used to amend requirements in NCSAs, 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 NCSAs in a prioritized manner based on their potential riskt (4) Evaluating and upgrading NCS programmatic controls and related management systems; (5) Reviewing completed NCSAs 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.
t The date by which each overall task will be completed is contained in Table 2.
B. Immediate Compensatory Actions 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 El-1 J
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of certain FMOs, and the implementation of an additional review of past problems. These actions
, are discussed in mole detail below.
- 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 NCSAs Associated with SAR Accident Scenario. Walkdowns were performed on 13 NCSAs determined to be associated with the Safety Analysis Report (SAR) accident analysis. These walk-downs were completed and concluded that the associated NCSA controls were adequately implemented. Twenty two prs were identified, one of which was a 24-hour NRC event report.
(b) Review of Surveillance Reauirements. A review was performed 'o verify that NCS surveillances and Technical Safety Requirement (TSR) surveillances for single contingency FMOs were being performed. No surveillances were overdue.
(c) Building Revicw of NCSAs The managers for each building in which FMOs are performed have begun to review the implementation status of the existing NCSAs in their buildings.
These reviews are to ensure that the descriptions in Part A of the NCSAs are accurate and complete and that the controls identified in Part D and Part C are being implemented. The plan for performing these reviews follows:
Task 1 Building Review of NCSAs Subtask No.
Description 1.1 Develop a list of NCSAs 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 i
Subtask 1.2.
i 1.4 Perform reviews of NCSAs. Report completion to Nuclear Safety 1
Manager.
l 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
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Report.
1.8 Implement corrective actions.
(d) Review of NCSAs Comoleted by Non-ounlified Personnel - It was determined that NCS l
engineers that were not properly qualified authored certain NCSAs. These NCSAs are being reevaluated by qualified NCS personnel. The plan for performing these reviews follows:
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Task 2 Review of NCSAs Completed by Non-qualified Personnel Subtank No.
Deer!aian 2.1 Develop list ofindividuals who are not qualified.
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2.2 Develop list of NCSAs that were authored or peer reviewed by these l
individuals.
t 2.3 Write a review plan.
2.4 Assign review team (s).
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t 2.5 Review NCSAs ort the list against the guidance provided in the review-plan. Document deficiencies in a Problem Report. The Problem Repost system will be used to document and initiate the corrective actions for these deficiencies, i
2.6 For NCSAs that have identified deficiencies, assign a qualified NCS '
engineer to correct problems.
2.7 Correct NCSAs.
(c) Rt view of Event Ranaris - A focused review was performed of ad 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 lou of t
contingency situation.
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- 2. FMos Shutdown t
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 tha requirements or changing the activity, in addition, FMOs may be stopped as a result of the reviews performed under Task 2.
- 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 NCS personnel in iw ar, ding to requests from the PSS. The purpose of the flowchart is to ensure that e
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the thought process for all NCS engineers is consistent v ;.en 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.'
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0 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 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 1997 NCS related Problem Reports intended to drive the individual root causes down to a Level 5 (specific) cause. These Problem Reports inc!uded deficiencies identified in NRC Inspection Reports and Intemal Assessment Findings. The details of each of the three evaluations follow.
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- 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 falhtre; technical rigor in the development and implementation of NCSAs was inadequate; the Audit cod Evaluation Process did not work to detect NCS problems; and the Standard, Policy, or Admin Control (SPAC) goveming the development of NCSAs was confusing or incomplete. These root causes were used tojustify the main thmst of the corrective action program which was described in USEC letter ODP 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 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 NCSAs Some NCSAs were determined to have technical errors which made it difficult to implement their requirements in the field,
- b. Inadequate implementation In some cases the requirements contained in the NCSAs were not adequately implemented in the field.
- c. Self-assessment and intemal corrective action processes were inadequate to detect and correct the problems.
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- 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. 'Ihis Taproot evaluation was performed by a team consisting of i
the Nuclear Safety Manager (part time), PORC chairman (part time), a Taproot process El-4 l
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facilitator, and a number ofindividuals who were familiar with the details and history surrounding the Individual Problem reports themselves. At a minimum, two individuals 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. Each step in the process was assigned an identifying number. De Problem Reports were evaluated to a Level 4 "near root cause". Each Problem Deriort was also assoclited with a specific step number. De results are as follows:
Number of Problem 1
Step Number Sten Descriotion Reoorts Associated 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 1
6 Procedure Development 18 7
Procedure Review Board 0
8 PORC 0
9 Verification Walkdown 28 10 Activation 1
11 Use (implementation) 113 12 Monthly Ops walkdown 1
13 Biennial NCS walkdown 1
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 of root 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 Table I 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.
D, Interim NCSA 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 development, approval, and implementation process. Bey include:
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- 1. Enhanced Review Process (Murder Board)
To ensure that the NCSA development process is carried out properly, an additional resiew board has been added to enhance the PORC and subconunittees' review. This review board is referred to as the murder board and works in accordance with a formal chaner. The owner (operations) and developer (NCS Engineer) will be tasked with presenting drafled NCSAs 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.g., assumptions, calculations, procedure steps) are correct. This satisfaction is created by obtaining the appropriate answers to questions from the board from the NCSA developer and/or owner. The murder board concept.as been borrowed from the reactor industry S
where it has proven to be successful in improving the quality of final documents such as NCSAs.
This addition to the existing process will improve the quality of the NCSAs 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 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.
'Ihe Murder Board will review major revisions of NCSAs and new NCSAs. At the discretion of the Nuclear Safety Manager, minor changes to NCSAs will be excused from Murder Board review.
- 2. Involvement by Owners and Engineering As noted in the root cause results, the lack of ownership by the actual users (owners) of the NCSAs has been responsible for a large portion of the NCSA problems. This lack of ownership has contributed to the technical shortcomings of the NCSAs when proper support and reviews of draft NCSAs were not adequately perfomied, and contributed to a lack of understanding of the final NCSAs themselves, resulting in implementation deficiencies.
1 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 Ergineer, and a NCS engineer will be required on the team which develops the NCSA, supports its progress dugh the review and approval process, and performs the required plant walkdowns to verify the NCSA. This will help ensure the technical accuracy of the NCSA, ensure that any required actions can actually be physically accomplished, and that the procedures implementing NCSA 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, liowever, members of the murder board will accompany the review teams on field walkdowns of selected NCSAs.)
t in addition, a review will be performed to verify all PORC approved NCSA's are being implemented or are in the process of being implemented in the field.
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- 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 j
the interim changes. Refer to Section E, Task 12 (NCS Policies and Procedures) for a discussion j
of the plan to implement these procedure revisions, i
- 4. Review /Walkdown NCSAs using the Prioritized List In parallel with activities to improve the NCS program, existing NCSAs will be subjected to the NCSA Upgrade Project on a prioritized basis. The list of applicable NCSAs, by priority, is included in Enclosure 2. This will ensure that high risk NCSAs are reviewed for technical adequacy and proper procedural flowdown and implementation as soon as practical.
As the long term programmatic improvements are implemented, NCSAs which have been subjected to the interim process will be evaluated to determine if they need to be reverified to ensun: 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 bc used to finish the reviews and walkdowns on the remainder of the NCSAs. The plan for performing these reviews follows:
Task 3 NCSA Upgrade Project Subtask No.
Subtask Descriotion 3.1 Classify the NCSAs into three groups accoiding to priority.
3.2 Verify that all PORC approved NCSAs are activated or progress towwd activation is being accomplished.
3.3 Form review groups consisting of representatives from NCS, Systems Engineering, Operations Management, and a hands on operator or
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3.4 Develop a procedure for the performance of reviews and walkdowns.
Maintain procedure current through life of upgrade project.
3.5 Table top semb NCSAs and their supporting documents 3.6 Field walkdown all NCSAs.
3.7 Ensure consistency with PGDP NCSAs for similar activities.
3.8 Accelerate processing ofidentified changes to NCSAs and procedures.
3.9 Review and approve NCSA/ implementing procedure changes.
3.10 Walkdown PORC approved NCSAs to document their readiness for activation.
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- 5. Enhance NCSA Training In response to recent NCS events, the General Manager conducted all hands briefings to communicate management's expectations regarding implementation ofNCS controls. To further ensure that the interim NCSA Review process is implemented correctly, training will be provided to personnel who will use, or be afTected by, the interim process. The plan for developing and implementing this training follows:
Task 4 Enhance NCSA Training Subtask No.
Subtask Description I
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 group.
4.4 Develop training effectiveness evaluation tool (test) 4.5 Administer training.
4.6 Utilize effectiveness evaluation tool (test).
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Retrain as indicated by test results.
In addition to the interim process training, training will be given as determined to be necessary to communicate such things as lessons leamed from the NCSA walkdowns currently being performed or other information determined to be important for all affected personnel to know.
'the exact nature of this training may vary from required trading, memos and e mail rnessages to formal classroom training, depending upon the nature and complexity of the subject matter.
- 6. Safety, Safeguards and Quality (SS&Q) Review ofImplementation f
As part of the ongoing self-assessment activities at PORTS, SS&Q will be tasked with monitoring j
the implemen lon of new NCSAs in the field. This monitoring will utilize ANSI /ASQC Zl.4, Sampling Pru edures and Tables for inspection by Attributes, for sampling guidance and is expected to take the form of a series of assessments that will begin as the NCSAs coming from the interim change process are implemented, currently scheduled for mid to late February. The plan for implementmg this review process follows:
4 Task 5 SS&Q Review ofimplementatloa Subtask No.
Subtask Descrintion 5.1 Develop list of NCSA chang from Task 3.
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5.2 Write an Assesstnent Plan. The plan will include, in part, a sample irview of NCSA 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 3
canceled Engineering Notices and therefore the cancellation of that specific operation as defined by the Engineering Notice.
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, on as groups of similar deficiencies, can be used to identify weaknesses in the program and/or its implementation. 'Ihis task is intended to ensure that lessons have been leamed 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 action to complete this task. (For the completed actions see Section C, Roct Cause Analysis, of this plan.)
Subtnd No.
Subtask Description 6.1 For each step of the NCSA process review a representative sample c'f 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 cummary 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 teamed / enhancement in accordance with the procedure described in Task 9.
6.3 If the detailed review mot 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 NCSA 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.
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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. 'lhi: eview 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 for this review follows:
Subtna No.
Subtask Descripilon 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 (j
a discrepancy list.
i 7.4 Evaluate discrepancies for need for immediate action, a Problem Report, or repor*tbihty.
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 tenn programmati: enhancements, for input to task 12.
Task 8 Vertical Slice Review To ensure that we have identified all potential areas of enhancement, an in-depth vertical slice review of the NCS program will be performed. The vertical slice review will be performed by a team consisting of the NCS Managers from PORTS and PGDP and an outside expert in NCS. Using selected NCSAs, the review will identify any crhancements that could be implemented to improve the program. 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 in the field, including on going assessments. The subtasks of this activity are shown below.
j Subtask No.
Subtask Description 8.1 Assemble the team for the vertical slice review.
8.2 Develop a procedure for doing the review. The procedure shall cover:
selection of NCSAs to ensure that all aspects of the program are included in the review, selection of NCSAs 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
the methods to be used to initiate changes to the NCS program l
(e.g., Procedure Development Forms.)
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e 8.3 Conduct the vertical slice review of the program using each selected NCSA. (As each NCSA is completed, enhancements to the NCS program will be developed.)
8.4 Submit program enhancements to the Nuclear Safety Manager for inclusion in the coudnuous 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 lessons learned for enhancements to the NCS program. Some of these lessons teamed will directly affect the NCSA/Es and others will afTect other aspects of the program such as procedural implementation of controls and NCSA training. In order to ensure that all lessons learned and enhancement ideas are appropriately incorporated into the NCS Corrective Action Plan, a single methodology will be utilized. The subtasks to establish and use this methodology are described below.
Suhtad No.
Subtask Description 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 leamed and enhancement ideas. The procedure shall cover:
use of a standard format.
a documented disposition for each lesson learned 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.
j Primary users of the lessons leamed/ enhancement mechanism.
liow the lessons leamed will be shared with all affected organizations. Training will be utilized as necessary to ensure proper understanding of the lessons leamed.
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 NCSAs that are affected by changes in the program due to lessons leamed throughout the program, ensure that there is a positive contro! mechanism to track the need for a re review to incorporate the lessons teamed.
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Task 10 Personnel Qualification Verification To ensta 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:
Subtask No.
Subtask Desenption 10.1 Review available qualification requirements in applicable 'ndustry guidance.
10.2 Compaie guidance to existing administrative control procedures, i
10.3 Resolve any identified discrepancies (revise procedures).
10.4 Compare qualification requirements to NCS engineers' records 10.5 Generate list of people to have upgrade qualifications.
10.6 Utilizing the new procedures, qualify individuals identified in step 10.5.
i Task 11 Outside/ Independent Assessments As part of the effon to identify potential areas of improvement, 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 p rforming these reviews follows:
j Subtask No.
Subtask Descrintion 11.1 Identify reports that fall within the scope of this task.
I 1.2 Review each repon and document potential problem areas.
11.3 Compare the list of problem areas with the list of known deficiencies identified through other means (e.g., compr-hensive root cause, ANSI reviews, etc.)
s 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 k
- 9).
Task 12 Policy / Procedure ReMon and Training The NCS program from beginning to end (each step of the process) has had problem reports associated with it over the pa.t year. The root cause evaluation has identified the problem reports El 12 i
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from 1997 and the steps of the NCS program to which they are associated. In order to provide !ong
, term enhancements to the NCS program and thereby ensure that the NCSA/Es arid tl,cir iraplementation 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 te be changed. These changes will also have to be communicated to affected personnel through training. Changes will need to be coordinated to maximize eflicient use of procedure and training resources. %e plan to accomplish needed changes to policies / procedures follows:
Subf aa No, Subtask Descriotion 12.1 Implement procedure changes for interim program as described in Section D.
12.2 Develop list of needed procedure changes, new procedures, from the applicable tasks.
12.3 Accomplish procedure changes (including required reviews).
12.4 Develop training modules.
12.5 Identify target audience for training.
12.6 Adtninister needed training.
12.7 Implement procedure changes.
Task 13 Revise Training Program for Site Personnel One of the identified root causes for NCSA implementation problems was that the training on NCSAs was not effective. To address this, the overall training for NCSAs will be evaluated to identify improvements which are needed. The plan to accomplish this review and upgrade follows:
Subtask No.
Subtask Description 13.1 Evaluate results of prior training.
3 l
13.2 Develop a list of programmatic problems.
j 13.3 Perform a root cause evaluation on each identified problem.
13.1 Identify actions to address root causes.
13.5 Incorporated improvements into the training administrative control process.
l 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.
El-13 l
l
1 I.
Task 14 Corrective Action Program Enhancements As a result of the review of the current NCS program implementation deficiencies, it is apparent that many of the existing problems have been in existence for some time, (e.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 after their first appearance. While this ineffectiveness of the corrective action program for PORTS is applicable to areas other than NCS, the subtasks described below are intended to focus on the NCS related portions of the corrective action program.
Subtask No.
Subtask Descriotion J
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 NCSAs.
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 activitic : and equipment.
14.4 Evaluate the administrative system of the corrective action program, especially the status tracking and action response mechanism, to I
streamline the process so the reporting of completed actions and tracking of open items is less time intensive.
Task 15 Configuration Management Program Enhancements I
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:
Suhtsk No.
Subtask Description
}
15.1 Develop program changes to ensure that engineering documents are maintained consistent with NCSAs, 15.2 Implement the new program requirements.
El 14
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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:
Subtaa No.
Subtask Description 11.1 Develop criteria for assessment program reviews.
16.2 Review each assessment program against eriteria.
16.3 List any identified problems.
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 affect:d personnel 16.8 Implement upgraded assessment programs.
Task 17 Oversight of Plan implementation.
To provide assurance that the Corrective Action Plan is being implemented in accordance with management's expectations, SS&Q will perform bi monthly assessments, to verify proper implementation. The first assessment will be completed before the first quarterly review.
Subtask No.
Subtask Description j
17.1 Develop assessment plan and schedule to be used to ovaluate the effectiveness of Corrective Action Plan implementation.
17.2 Perform assessments as defined in the assessment plan.
q 0
l F. Schedule See Table 2.
O. 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.
F1-15 1-
4 h
i Task 18 Evaluation and Feedback
' SM Daarrintinn 18.1-Gather pertinent status information.
18.2 Compare status with the respective Tas; guirement and schedule.
1 18.3 Initiate any requirti corrective actions.
l 18.4 Factor in lessons leamed through Task 9.
I8.5 Report to management.
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-l Table 1. Level 5 Root Cause by Process Block Nansber 1
2 3
4 5
6 7
8 9
10 11 12 13 14 No SPAC*
X X
X X
X i
SPAC not Strict Enough X
X Confusing orincompletc X
X X
X' SPAC Technical error X
X X
X 1
Procedure use not required but X
X X
X X
X should be Procedure difficult to use X
Task not analyzed X
Accountability X
X X
Procedure facts wrong X
p j
Training Lesson Plan X
No way toimplement SPAC X
X
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- SPAC-Standards, Policies, or Administrative Controls t
NOTE: For NCSA process step names, refer to Section C3.
-1
- i El-17 1
i
't.shle 2. Implementation Schedule End Dates
,e Task #
Description Target Date 1
Facility review ofNCSAs 12/24/97 f
2 Review of NCSAs regarding qualifications 2/28/93 3
NCSA/Es Upgrade Project Pri 1 3/27/98 Pri2 7/31/98 Pri3 4/30/99 4
Enhance NCSA Training (Interim Process) 2/28/98 5
SS&Q Review ofImplementation PriI 4/27/98 Pri2 8/31/98 Pri3 5/31/99 6
Complete Comprehensive Root Cause Analysis 2/28/98 7
Compare applicable industry standards against NCS 1/31/98 Program 8
Vertical Slice Review 3/31/98 9
Continuous Improvement Program 1/31/P8 10 Personnel Qualification Verification 3/31/98 11 Ou' side / Independent Assessments 4/30/98,
12 Policy / Procedure Revision and Training 12/31/98 13 Revise Training Program for Site Personnel 4/30/9" C,ebtask 13.5) 14 Corrective Action Program Enhancements 6/30/98 15 Configuration Managemeut Program Enhancements 2/28/98 16 Revise Assessment Programs 3/31/98 17 Oversight of Plan Implementation 4/30/99 (bl. monthly) 18 Evaluation and feedback Quarterly starting on 1/31/98 19 Evaluate continued use of Murder Board Not before 5/31/98 El-18
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ENCLOSURE 2 LibT OF CURRENT KLSAs 6
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t.lSTING'CP PftlO!11 TIES WITH COUNT :.. -.....
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_ PfW0lW7Y NCSANBR SUBJECT 1
032s_013.A03.
Cannede operusens in the X428 Building (Implemented) 1 032s_014.0C1 opnseen of Seal Exhaust Pew wnh the Kinney Veouum Pwnp, hiedel MT.170LP in the X.' 8 5 u lity.
1 032e_018.A02
& ~ f2._.s Product f iWithdrawal Station 1
0328.024.301 '
Peeding of 54nch,84nch and 12 inch HEU Cylinders at the X428 Produce Withdrawal and Produce Purenessen 1
032s_023.A00 HandRng and Storneo of Seals with Unknown Enrichment in X-328 1-0330,,004.A02 Cascade operadons in the X430' Building (:..N 2 f) 1 r.10,00L*Jie X430 Area 2 Seal Exhaust 1
0330_006.A01 X430 Area 3 Seal Exhaust and Wet Air Evacuation 1
0330.007.A00 Tails Withdrawal Station 1
0330.013.A00 Long Term Storage of PEH Converterin X430 1
0333.015.A02 Cascade operations in the X433 Bui: ding (Implemented) 1 0333.014.A01 X433 Area 1 Seal Exhaust and Wet Air Evacuation 1
0333_017.A00 Low Assay Withdrawal (LAW) Station 1
0342A001.001 General Handling, Weighing, & Storage 1
0342A002.A01 Autoclave Operation 1
0342A004.A01 ou interceptor 1
0342A00s.001 Sump 1
0343_001.001 General Handling, Weighing, & Storag )
'1 0343.002.A01 Autoclave Operation 1
0343_003.101 OilInterceptors 1
0343.004.A02 Waste Streams s
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.1 0344A001.A02 -
Autoclave Operation 1
nmaans ami Gulper System 1
nmanns aan X444A Scale Pits and Sumps 1
OM4A011.A00 Techneeum (Tc) Trap in Ar_:-in
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- 11 2 12 PIWOfuTY i
NCSANSR l
SUBJSCT 1
0705.012.A00 Small Parts HendtatWes Cp dr 1
0705_018. 0 8 Waste Water Trastment (IScronitration System) 1 070$_018.A02
- 8. and it. inch Cylicder Cleaning 1
0705.034.0C5 Calcinors. Solution Rwevery 1
070s_034.A02 Spesy Booth operations 1
0705_038.A01 Truck Alley Cleaning 3
1 970s_0:s.A02 oil and Grene Removat System 1
070s_042.A00 Small Equipment Teor.Down (" Slue Room")
jt 1
0708.082.A00 "A", "S", "C" Loop Pro. Evaporator Systerns 1.-
0708,,,088.A00 "A", "B", and "C" Loop Post Evaporator Systems 1
0706_132.A00 Replacing 8" and 12* HEU Cylinder Valves 1
0710.009.A00,
Storage Requirements for Mssile Material Transfer (Uranium Chain of Custody) Room 1
0710.028.A00 Sampling, Transporting, and Handling in X 710 1
PLANT 004.A01 Storing and Handling of Large Cylinders of Uranium Material i
l 1
PLANT 006.A02 General Use of Small Diameter Containers for Storing High Enriched j
Material p
1 PLANT 029.A00 Cascade Datum Systems 1
PLANTO30.A02 Evacuation Rooster Stations l
1 PLANT 033.A01 Surge Drums l'
1 PLANT 038.A00 Inter 4ullding Tie Lines l
1 PLANTrus aan Fissile Material Transport 1
PLANT 049.0C1 Always Safe Portable Small UF6 Release Gulpers 1
s 1
PLANT 064.A00 Lube Oil System i
1 PLANT 088.A00 Laundry 1
PLANT 082.A00 Cascade Maintenance 1
Pt. ANT 078.A00 Oli interceptors and Surnps in X443 and X-342
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MurAuTV NCSANSR SUSJECT 1
PLANTU79 A01 Opening Equipment containing Gester than A Safe Mass of Uraniunk seering Masertal TU7AL PHIDurfY t 01 PfuofuTY NCSANSR SUBJECT 2
Osas_022.101 X 32s Use of Portable HEPA Vendission Units for Specifle Activities t
0:30.003.101 Storage and Hondung of Seals in X 330 2
034aA00s.A02 Weste Streams 2
0343_008.001 Disposal of PM Manifolds, Cylinder Safety Valves, and Other Used Autocieve C:r;: : 2 2
0344A006.A03 Sample Cylinder Hondung and Storage 2
0344A007.A04 Waste Streams
-2 0344A010.0C1 Disposal of Pigtails, Manifolds, and Cylinder Safety Valves, and Other Used AutoclaveComponents 2
0705.002.A02 2.5 Ton,10 Ton, and 14 Ton Cylinder Cleaning s
2 0705_010.101 Small Parts Glass Bead Blaster i
2 0705_033.1C4 South Annex Operations. Cascade Equipment 2
0710_004.101 Gulpers for Mass Spectromotors I
2 0710,006.A00 Uranium Sampling Laboratory 2
0710_008.A01 UPS lootopic Stanfdards Preparation Laboratory i
2 0710_011.A00 Process S;:m. if aboratory L
2 0710_012.A01 UraniumAnasysis Laboratory
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2 0710_020.A00 Process Chemistry Laboratory 3
2 0710J.21.A00 Process Services Laboratory 2
0780 003.A41 Sample Buggy Itepair 2
PLANT 011.001 Use of Portable HEPA Ventilation Units for Specific Maintenance Activities j
i 2
PLANT 012.A01 k
Poverable c::.-
^.f Vacuum Cleaner
~-
3 2.
PLANT 013.A00 Batching Solueens and Solids s
2 PLANT 018.A01 Dry Active Weste (Contaminated Burnables) in Waste Generation Areas and in Interim Storage i
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USTING OF PRIORITIES WITH COUNT g
PRIORITY NCSANBR SUBJECT 2
PLANT 022.A40 Sample Cylinder Hand!!ng and Storage 2
Pt. ANT 021A01 General Use of Small Diameter Containers for Storing up to 10%
Enriched Material 2
Pl. ANT 031.A02 Use of Portable infrared Analyzers (PIRA Buggles, FTIRs, etc.)
I 2
Pt. ANT 044.A00 Cold Recovery. Cold Traps 2
Pt. ANT 048 A00 Contaminated Metal 2
PLANT 0$0.A00 Use, Hand!!ng,'and Storage of Fixed HEPA Filters and Preft!!sts 2
PLANT 051.A00 Cold Recovery Chemical Traps 2
PLANT 052.A00 Cold Recovery. Holding Drums 2
Pt. ANT 053.A01 Uranium Analysis and Sampling 2
PLANT 057.001 Use of Gas Sampling Cart 2
PLANT 060.A01 Cylinder Valve Replacement 2
PLANT 063.A00 Building Decontamination Activities l
2 PLANT 064.A00 Handling and Storage of Seals in X.326, X 330, X.333 2
PLANT 065.A00 Use of Umited. Safe Geometry Vacuum Cleaners 2
PLANT 068.A00 Negative Air Machine (NAM) 1 2
PLANT 069.A00 Test Buggles 2
PLANT 075.A00 Batching of Contaminated Components Which Are Exposed to UF6 or Other Non Olly Uranium Processes 2
PLANT 078.A00 Use of Ladout 15 Cylinders at PORTS TOTAL PfUCRITY :
40 reemme
_ PRIORITY NCSANBR SUBJECT 3
0326,,001.A02 Nuclear Criticality Safety of Shutdown and Standby X 320 Calls
\\i 5
3 0326_016.A00 Operating Floor Freon Degrader 3
0326,,,027.A00 Operation of the X-326 NDA Laboratory 3
0330,,,009.001 Flushing / Cleaning of 1/2" Vented Cavity Pipes and Compressor "B" Seal Cavities, X-330 l
3 0333.,007.A41 1000 CFM Negative Air Machine l
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l 11:44:12 A48 I*
PRIORffY IGCSANBR SUBJECT 3
0333,,018.001 :
Freezer / Sublimer 3
0333_022.A00 Flushing / Cleaning of Vented Cavity Pipes and Cwp n M "B" Seaf Cavities 3
0333.023.A01 Long Term Storage of 33-4 4 State 7 PEH Compessor 3
0344A004.A00 Evacuation System and Cold Traps j
3 0344A005.A02 X344A Small Diameter Container Storage 3
0700.001.001 Flasile Material at The Radiation Instrument Calibration Facility.
3 0700_002.A01 Heavy Metals Sludge Storage 3
0700.004.A00 X 700 Converter Disassembly and Repair Area 3
0700_005.A00 Glass Bead Blaating 3
0700.004.A00 Blodenitrif! cation (Pilot Plant and New Plant) 3 0700_007.A00 Cleaning Tank #31 Converter Flushing Station 3
0700.014.A01 Uranium Bearing Mstorials Storage Area Between Columns D10 and D12 3
0700_017.A00 RCRA 90 Day Storage Area Bounded by Co.umns 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 3
0700_020.A00 Operattun of the X 700 Chemical Tanks 1,2,4, and 5 3
0705_004.A00
- 5. Inch Cylinder Cleaning 3
0705_005.A00 Small Cylinder Rinse Pit 3
4705.009.A00 Seal Diamantling Room 3
0705.,011.A01 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 34, B 1, and Dissolver Solution Storages t
3 0705.,023.A00 Operation of the "A " "B," and "C" Loop Extractor / Stripper Systems 1
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- 11
- 48:12 Aas :-
PRIORffY IICSANBR SUBJECT 3
0705,,,035.A00 Nitrous Oxide (NOx) Seruther System 3
0705.0rt. Ass Hoovy Metals TM;1o 3
070$_038.A00 Techno6um len Exchange 3
0705.030.A00 Recovery Elevator 3.
0705_031.A00 Equipment D'----
12i n the North Toerdown Ares i
3 0705.,038.A05 Tunnel Storage 3
0705_037.A00 Ground Water Sumps t
0705.040.A00 overhead Storage 3
0705.041.A00 C. Area Material HendUng & Storage 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 Preparation 3
0705.055.A00 Facility Drains 3
0705.064.A00 Seal Can Handling and Storage in X 705 3
0705.,,071.001 2.5. ton,10-ton, and 14. ton Cylinder Drying 3
0705.072.A00 inspection and Testing of UPS Cylinders 3
0705.073.001 Genie Model AWP30 Manlift i
3 0705.075.A00 F. Area Fissile Material Handling and Storage 3
070f_078.A00 Inadvertent Containers 3
0705_083.A01 "A", "B", and "C"!. cop Concentrate Storage and Metering Systems q
3 0705,,,054.A00 "A" and "B" Loop Raffinate Storage and Recycle System 3
0705.088.A00 -
"A","B,""C" Loop T-Water Storages 3
0708,,,000.A01 Post Evaporatorspray Condenser and Sample Condenser Systems
,'3 0705_100 A02 Pro. Evaporator Spray Condenser and Sample Condenser Systems
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g _." 6 USTING OF PRIORITES WITH COUNT
,,* 11:44:12 AAA r
MWORffY NCSANBR SUSJECT -
3 070s_1o2.A00 s Area Condensens prain System 3~
070s_193.A00 Process vent System 3
0748_108.A01 Cylinder Cleaning Gulper System 3
070s_107.A00 2.s. ten,10 ton, and 14 4en Cylinder Receiving & Storate t
3 070S_108.001 SES (Solution Entlehment System) 2 (X 705) 3 0708,,110.A01 Used lacroelters Removal and Storage 3
070$_111.A01 tufRng Booth 3
0708.114.A00 Facilitsee utstles/ Services. Process Steam 3
070$_122.A02 Blending Cylinder Wash Solution 3
0705.123.A00 -
Small Cylinder Receipt and Storage 3
0705_124.A01 F Area Oxide Glovebox 3
0705_128.A00 RCRA 90 Day Storage Area Roughty Bounded by Columns F 23,G 23, F 24 and G-24 3
0705.127.A00 Classified Scrap Metal (Seel Parts Only) 3 0705_128.A00 Storage of 84nch EBS Ptpe in the Large Parts Cage 3
0705_129.A00 Decontamination of Unfavorable Geometry Parts in Tunnel Spray Booths 3
0708.130.A00 Testing of the 54nch and 8.& 12. inch Cylinder Cleaning Operations 3
0705.131.A00 Draining, Transferring, and Collecting Uranium-Bearing Liquids in X.
705 3
0710.001.101 Use of NilFisk Model 80 Portable Vacuum in X 710 t
3 0710.007.A00 Small Diameter Container Storage in X 710 3
0710.014.A00 X Ray Fluorescence Laboratory 3
0710,015.A42 Handling of Samples and Process Waste in ES&H Analytical Labs 3-0710.022.A00 Laboratory Standards and Con mis e
i3 0710_023.A00 Miscellaneous Uranium Operations 3
0710.024.A00 Handling and Storage of Sources l
3 0710_025.A00 Handling and Storage of Samples from ES&H Analytical Labs j
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MODIUTY 90CSANSR SUBJECT 3
0710.027.A00 Uranium Sampung Laboratory HEU C ::t.-
3 0720.,,001.A02 Cleaning Ughtly Cantaminated Ploor Areas 3
0720.003.A01 Dry Blast Machines for Non Visibly Contaminated Parts 4
3_
0720_000.A00 Smed Parts Glovebos i
3 0720.014.A00 -
Valve Shop Vapor Detrosser
]l.
3 0720_018.A02 Cleaning and Decontaminating Space Recorder Cans 3
0720.,016.A00 Transmitter Cleaning Season 4
3 0720,,018.A00 Hydro Table in the X-720 Hydro Shop J
_3 0847.001.A03 General Storage of Uranium.8 earing Weste. XT 447 3
0847.,002.001 Storage of B-25 Waste Boxes at XT.447 l
3 PLANT 001.0C1 Storing Small Diameter Containers in Plastic Bags, Plant
,3 PLANT 002.0C1 Water Cooling of UPS Cylinders at LAW, ERP, Tails, X 342 and X 343 3
PLANT 014.A00 Use of Unsafe Geonwiry 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 Pumps 3
PLANT 028.A03 Removal and Handling of PEH Equipment 3
PLANT 034.A00 Uquid Waste Collection and Sampling Systems 3
PLANT 034.A00 Storage of Safe Batch Containers 3
PLANT 037.A00 Use of Small Diameter Container Carts 3
PLANT 046.A01 Umited Safe Volume Containers 3
PLANT 048.A02 Mop Buckets
'g 3
PLANT 070.A00 Miscellaneous Waste Accumulation Areas i
3 PLANT 071.A00.
Use of Portable HEPA Ventillation Unite 3
PLANT 073A01 Removal and Handung of Two C,,,..,,,- :- s Above Masa Removal i
Limit and Instaustion of '; t : n.; Compressors
-l 3
PLANT 074.A00 Decontaminallon using a Steam Jenny i
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LISTING OF PRIORITIES WITH COUNT Q
811:4S:12 Aad. +'
a
- MuCRITY NCSANBR SUBJECT 3
PLANTUU.A00 Long Twm Storage of Lagocy PEN Equipment foraa.nuomy:
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