ML20202E859
| ML20202E859 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant, Portsmouth Gaseous Diffusion Plant |
| Issue date: | 01/21/1999 |
| From: | Toelle S UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Paperiello C NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20136E161 | List: |
| References | |
| GDP-99-0004, GDP-99-4, NUDOCS 9902030211 | |
| Download: ML20202E859 (73) | |
Text
{{#Wiki_filter:s l d USEC A Global Energy Company January 21,1999 GDP 99-0004 Dr. Carl J. Paperiello Director, Office of Nuclear Material Safety and Safeguards j - Attention: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Paducah Gascous Diffusion Plant (PGDP) Portsmouth Gaseous Diffusion Plant (PORTS) Docket Nos. 70-7001 & 70-7002 Compliance Plan Status Report i INFORMATION TRANSMITTED IN ENCLOSURE 2 IS PROTECTED FROM PUBLIC DISCLOSURE AS CONFIDENTIAL COMMERCIAL OR FINANCIAL INFORMATION AND/OR TRADE SECRETS PURSUANT TO 10 CFR 2.790(d)(1) AND 9.17(a)(4)
Dear Dr. Paperiello:
In the Introduction section of the PGDP and PORTS Compliance Plans, the United States Enrichment Corporation (USEC) committed to provide the United States Nuclear Regulatory Commission (NRC) with periodic reports on the implementation status of the Compliance Plans. Accordingly, enclosed is the Compliance Plan Status Report for the period of July 16,1998, through January 1,1999. As required by the Compliance Plan, the executive summary portion of the status report contains a listing of Compliance Plan issues that were completed / closed during this reporting / period and a listing of Compliance Plan issues that are scheduled to be completed during the next / reporting period. Additionally, as required by the Compliance Plan, Enclosures 1 and 2 contain a detailed listing, sorted by noncompliance, of the individual commitments within each Compliance gh Plan issue. On October 9,1998, USEC provided NRC with a status of the PORTS Compliance Plan Issues (see USEC letter GDP 98-0214). This letter was generated as a result of a self-assessment at PORTS that discovered discrepancies in the implementation of some of the PORTS Compliance Plan issues. In this submittal, USEC informed the NRC that deficiencies were found in the completion of several PORTS Compliance Plan issues. These deficiencies are reflected in the enclosed status report. 9902030211 990121 1 PDR ADOCK 070070019 C PDR j. 6903 Rockledge Drive, Bethesda, MD 20817-1818 Telephone 301-564-3200 Fax 301-564-3201 http://www.usec.com OfTices in Livermore, CA Paducah, KY Portsmouth, OH Washington, DC
l' i i Dr. Carl J. Paperiello January 21,1999 . GDP 99-0004, Page 2 . Additionally, USEC committed to perform a 100% review of the remaining PORTS Compliance Plan issues. If additional deficiencies are discovered during this review, they will be reflected in future Compliance Plan status reports. Additionally, on January 19,1999, USEC submitted a letter to NRC concerning the reopening of Compliance Plan issues (see USEC letter GDP 99-0002). In this letter, USEC indicated that PORTS Compliance Plan issues 9 and the portion ofissue 23 which relates to AQ-NCS systems will be reopened. Additionally, this letter stated that USEC is currently evaluating the progress made in addressing the NCS issues under the NCS Corrective Action Plan to determine if programmatic issues still exist that would warrant reopening Compliance Plan issue 8. Afler further consideration, l USEC has determined that issue 8 will be reopened. The CARS for reopening these issues will be
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submitted to DOE no later than February 25,1999. This information is reflected in the enclosed status report. In accordance with 10 CFR-76.33(e) and consistent with the NRC's December 18,1995, letter, the information related to Compliance Plan issues A.1 through A.5 for PORTS, and A.1 through A.7 for PGDP is considered to be proprietary commercial and financial information pursuant to 10 CFR 2.790(d)(1) and 9.17(a)(4) and is exempt from public disclosure. These Compliance Plan issues have been clearly identified as proprietary information in Enclosure 2 to this report. Updates to the Executive Summary section of this report are indicated by change bars in the right-hand margin. If you have any questions or require additional information concerning the enclosed report, please contact Russ Wells at (301) 564-3245. There are no new commitments contained in this submittal. USEC plans to submit the next Compliance Plan Status Report to NRC by July 15,1999, which will l cover the period from January 2,1999, through June 30,1999. On January 14,1999, USEC verbally requested an extension of the due date for this submittal to January 20,1999, due to inclement weather conditions at PORTS and USEC HQ. This extension was confirmed in a telephone conversation between R. Wells of USEC and Y. Paraz of NRC on January 19,1999. Subsequently, on January 20,1999, USEC verbally requested that the due date for this submittal be further extended to January 21,1999. Sincerely, P
- 5. A.
G Steven A. Toelle Nuclear Regulatory Assurance and Policy Manager
Enclosures:
As stated cc: NRC Region III Office NRC Resident Inspectors - PGDP and PORTS NRC Special Projects Branch NRC Project Managers - PGDP and PORTS DOE Regulatory Oversight Manager
GDP 99-0004 Page 1 of 7 ' TABLE OFCONTENTS A. Executive Summary $ I. Introduction II. Status of Proposed Changes to Compliance Plan Issues III. Completed Compliance Plan Issues IV. Reopened Compliance Plan Issues and Status of any Deficient Compliance l Plan Actions that have not been Resolved l l V. Compliance Plan Issues that are Scheduled to be Completed During the Next Reporting Period VI. Discussion of any Compliance Plan Issues that are Behind Schedule VII. _ Detailed Listing of the Individual Commitments within each Compliance Plan Issue B. References l C. Tables Compliance Plan Issues that have not yet been completed or which are currently l behind schedule. l l D. Figures Summary ofIndividual Compliance Plan Actions E. Enclosures 1. Description of Compliance Plan Issues and Actions for PORTS and PGDP 2. Description of Compliance Plan Issues and Actions for PORTS and PGDP l (proprietary information) l )
GDP 99-0004 Page 2 of 7 EXECUTIVE
SUMMARY
I. Introduction On September 15,1995, USEC initially submitted the Compliance Plans for PGDP and PORTS to NRC as part of the Certification Application. The latest revisions to the l Compliance Plans were submitted to NRC on January 8,1999,(Revision 8 for PGDP) and l December 28,1998, (Revision 9 for PORTS). The Compliance Plans include the following l infortnation: A description of the areas of noncompliance; A plan of actions and schedule for achieving compliance; and A justification for continued operation with adequate safety and safeguards. The Compliance Plans contain 106 individual areas of noncompliance or " issues," 57 at PGDP and 49 at PORTS. Each issue includes one or more actions that must be completed in the next several years. There are approximately 450 individual actions contained in the Compliance Plans. Figure I shows graphically the Compliance Plan actions that have been completed and those actions that remain to be completed. The initial Compliance Plan status report was submitted to NRC on December 18,1996 (reference USEC letter GDP 96-0194). Subsequent reports were submitted to NRC on a quarterly basis. As indicated in References 1 and 2, USEC and NRC agreed to extend the I reporting period for the Compliance Plan Status report from March 1,1998 through July 15, 1998, and from July 16,1998 through January 1,1999. II. Status of Proposed Changes to Compliance Plan Issues The following is a description of Certificate Amendment Requests (CARS) affecting Compliance Plan issues that were either submitted to the NRC or approved by the NRC during this reporting period. On June 11,1998, USEC submitted a CAR to revise Compliance Plan Issue 11 for PORTS regarding the connection of evacuation homs in the X-744H Building to the X-744G Criticality Accident Alarm System (CAAS). Issue 11 committed USEC to tie the evacuation homs in Building X-744H to the Puilding X-744G CAAS by July 1,1998. With the elimination of fissile operations in Building X-74411, a nuclear criticality safety evaluation concluded that due to the absence of fissile operations in the X-744H facility and the intrinsic nature of the residual contaminated material, which contain no visible quantities of uranium, a nuclear criticality is not credible in the X-744H warehouse. Therefore, the requested change revised Issue 11 to
GDP 99-0004 Page 3 of 7 eliminate the action to tie evacuation horns in X-744H to the X-744G CAAS. This CAR was approved by NRC during this reporting period. l l On October 14,1998,,USEC submitted a CAR to revise PORTS Compliance Plan l. Issue A.4, which committed USEC to clean 5,8 and 12 inch cylinders that were fed l to the cascade under the HEU Refeed Program by December 31, 1998. The l requested change revised Issue A.4 to change the completion time for cleaning these l HEU Refeed cylinders to March 31,2000. In conjunction with the delay in cylinder l cleaning, the date for turning over the remaining portions of X-705 leased areas to l NRC regulation was also changed from January 31,1999 to April 30,2000. This l CAR was approved by NRC during this reporting period. l l On November 5,1998, USEC submitted a CAR to revise PGDP Compliance Plan l Issues 46 and 50, " Criticality Accident Alarm System Audibility Upgrades." l Compliance Plan Issues 46 and 50 require plant modifications to ensure that the l CAAS alarm horns are capable of being heard throughout the affected areas of the l process building and to provide CAAS alarm homs for those unalarmed facilities l within the evacuation area of CAAS-clustered buildings, respectively. This CAR l proposed to change the Compliance Plan due date associated with Issues 46 and 50 l from December 15,1998, to hnuary 18,2000. In addition, this CAR requested l approval of attemate SAR criteria for detemlining CAAS audibility. This CAR was I approved by NRC on January 7,1999. l l On December 23,1998 USEC submitted a CAR to revise PORTS Compliance Plan l Issue A.2, which states that physical modifications to the sampling autoclaves and l modifications to the sampling program are required to be completed by December 31, l 1998. Physical modifications are planned to the sampling autoclaves as required by l Compliance Plan Issue 3, but no physical modifications to the sampling autoclaves l are required to support meeting the NRC requirements described in Compliance Plan l Issue A.2, Action 3. Consequently, USEC is requesting NRC approval of the change l to Issue A.2, Action 3, which proposes to delete the wording regarding physical l modifications to the sampling autoclaves. This CAR is awaiting NRC review and l approval. l l The NRC requirements for sampling enriched UF. cylinder receipts are clearly stated l in Compliance Plan Issue A.2 and the Fundamental Nuclear Materials Control Plan 1 (FNMCP), Section 9. USEC's sampling program for these types of cylinders is now l fully compliant with these requirements, and no additional program or hardware l modifications are required. While all actions required by Compliance Plan Issue A.2 l are complete, USEC requested that the Compliance Plan Issue A.2 verbiage be l revised to reflect the information described above. l l i
-.~.. - - - GDP 99-0004 Page 4 of 7 On January 12,1999, USEC submitted a CAR to revise PGDP Compliance Plan l Issue 36, " Seismic Capability'of Buildings C-331 and C-335," which requires I modifications to increase the seismic capability for floor and roof sections in l Buildings C-331 and C-335 to be completed by June 30,1999. This submittal l 1 proposes to change the Compliance Plan scheduled date for this issue to June 30, l l 2000. This CAR is awaiting NRC review and approval. l III.- Completed Compliance Plan Issues This section identifies those Compliance Plan Issues which USEC has completed as of the cutoff date for this report. A " complete" Compliance Plan issue means that USEC has I fulfilled 'all of the individual actions described in the issue. A Compliance Plan issue is j considered " closed" when the regulator has reviewed and concurred that all actions have been I completed and documented its review in writing. l There were 7 Compliance Plan issues completed during this reporting period (issues 39,44, l and 49 for PGDP and issues 13,29, and 38, and A.2 for PORTS). Additionally, there were l ~4 Compliance Plan issues closed by NRC during this reporting period (i.e., PORTS l Compliance Plan issues 6,17,21, and 27)'. Of the 106 Compliance Plan issues,98 (i.e.,53 l 2 for PGDP and 45 for PORTS ) were completed as of the cutoff date for this report. Of the l approximately 450 Compliance Plan actions,433 (i.e.,96%) were completed as of the cutoff l date for this report (see Figure 1). All Compliance Plan issues, and their associated actions, due to be completed by USEC as of the cutoff date for this report, were completed except l l those for which either: 1) a CAR has been submitted to revise the Compliance Plan issue as noted in Section II of this report; or 2) a CAR is being prepared to reopen a Compliance Plan issue as discussed in Section IV of this report. USEC had previously reported PORTS Compliance Plan issue 11 as complete. However, l the last sentence for the POAS for this issue states, "This compliance plan issue will be l modified to provide a plan and schedule for establishing adequate detector coverage if the l adequacy of the current detector coverage is not verified by the NRC review." USEC has l submitted an exclusion request to NRC for criticality detector coverage in certain areas at l PORTS (reference USEC letters GDP 96-0055 dated April 9,1996,96-0107 dated May 22, l 1996, and 96-0172 dated August 15,1996). NRC letter dated December 4,1998, requested l that USEC provide additional information before the NRC can take final action on USEC's l 'See NRC Inspection Report 70-7002/98014 dated October 23,1998 l 2This includes the following Compliance Plan issues that were deleted or canceled as reflected in Revision 3 to the Compliance Plan: 1-PGDP issues 28,47, A.5, and A.6 PORTS issues 31,43, and A.3 n 1 . ~
1 GDP 99-0004 l Page 5 of 7 i l request. Therefore, USEC has changed the status of this issue to "Open" and modified l accordingly, pending USEC's response to the NRC letter of December 8,1998, l l and NRC's review of USEC's response. l l As indicated in USEC's response to Notice of Violation 70-7002/98014-02 (reference USEC l letter GDP 98-2048 dated November 23,1998), this status report no longer includes the table l that listed Compliance Plan issues that were previously reported as " Complete" or " Closed." l I IV. Reopened Compliance Plan Issues and Status of any Deficient Compliance Plan Actions l that have not been Resolved l As discussed in Reference 3, the purpose of this section is to inform NRC of any Compliance l Plan issues that will be reopened and a discussion of any unresolved deficient Compliance l P'an actions. In Reference 4, USEC provided NRC with a status of the PORTS Compliance l Pan Issues. This letter was generated as a result of a self-assessment at PORTS that l l discovered discrepancies in the implementation of some of the PORTS Compliance Plan l issues. In this submittal, USEC informed NRC that deficiencies were found in the l completion of PORTS Compliance Plan Issues 8,9,18,23, and 42. Pursuant to References l 5 though 9, USEC and NRC are currently in the process of establishing criteria for reopening l Compliance Plan issues. As noted in References 7 and 8, USEC is preparing CARS to I reopen PORTS CP issues 8,9 and the portion ofissue 23 which relates to AQ-NCS systems. l l In Reference 4, USEC informed NRC that compliance with issue 42 had been restored and l ) that the discrepancies related to issue 18 would be completed by April 15,1999. Significant l progress has been made on issue 18, and USEC currently anticipates that full compliance will l be achieved no later than January 31,1999. Therefore, USEC does not plan to submit a CAR l to revise this CP issue. l l Additionally, as noted in Reference 9, USEC has also identified a deficiency related to action l 1 of PORTS Compliance Plan issue 23 conceming the flowdown of commitments from the l Technical Safety Requirements, the Safety Analysis Report, and other plans and programs I to procedures and training. USEC has notified the PORTS NRC Resident inspector of this I deficiency and USEC plans to reopen this action as part of the CAR for issue 23 related to l AQ-NCS systems. l l V. Compliance Plan Issues that are not yet completed As shown in Table 1, there is one (1) Compliance Plan issue coming due between January 1 2,1999, and June 30,1999 (i.e., issue 36 for PGDP). As indicated in Section II of this l report, a CAR has been submitted to extend the due date for this issue. This table also l l reflects the remaining open Compliance Plan issues. l
GDP 99-0004 Page 6 of 7 VI. Discussion of Any Compliance Plan Issues that are Behind Schedule As shown in Table 1, PGDP Compliance Plan issue 36 is currently behind schedule, pending the completion of NRC review of the CAR to revise the due date for this issue. Additionally, as indicated in Section IV of this report, USEC is currently preparing CARS to reopen PORTS issues 8,9, and 23 VII. Detailed Listing of the Individual Commitments within each Compliance Plan issue Enclosures I and 2 to this report lists each Compliance Plan Issue, a description of the l commitments for each issue and the due date committed to in the Compliance Plan. These l enclosures also identify if the commitment has been completed. As previously noted in this I report, a " complete" Compliance Plan issue means that USEC has fulfilled all of the l individual actions described in the issue. A Compliance Plan issue is considered " closed" l when the regulator has reviewed and concurred that all actions have been completed and l documented its review in writing. This Enclosure is not intended to represent a current status l of substantial compliance for Compliance Plan issues or actions that were completed or l closed prior to the reporting period for this status report. The Enclosure does reflect those l Compliance Plan actions that USEC plans to reopen or any deficient actions that were l unresolved as of the cutoff date for this report. l
i GDP 99-0004 Page 7 of 7 l 1 References i 1. USEC letter to NRC dated May 8,1998, GDP 98-0097, " Revised Schedule for Submission . of Quarterly Compliance Plan Reports." m t 2. NRC letter to USEC dated May 15,1998, " Schedule for Submission for Quarterly Compliance Plan Reports." (
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USEC letter to NRC dated November 23,1998, GDP 98-2048, " Reply to Inspection Report . (IR) 70-7002/98014 Notice of Violations (NOVs) 98014-01 and 02." 4. USEC letter to NRC dated October 9,1998, GDP 98-0214, " Current Status of Compliance Plan Issues Closure Review." t 1 ~5. USEC letter to NRC dated November' 5,1998, GDP 98-0237, " Proposed Criteria for l . Reopening Compliance Plan Issues." l l 6.' NRC letter to USEC dated November 25,1998, "Portsmouth and Paducah Graous Diffusion l Plants: Criteria for Identifying Deficient Closure and Reopening of Compliance Plan Issues l l (TAC No,. L32104)." l l -i 7. .USEC letter to NRC dated. December 9,1998, GDP 98-0264, " Proposed Criteria for l Reopening Compliance Plan Issues (Revised)." l I 8. NRC letter to USEC dated December 18,1998, "Portsmouth and Paducah Gaseous Diffusion l Plants: Criteria for Identifying Deficient Closure and Reopening of Compliance Plan Issues l (TAC No,. L32104)." l l I l
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USEC letter to NRC dated January 19,1999, GDP 99-0002, Docket Nos. 70-7001 & 70-l 7002, " Reopening of Compliance Plan issues." l l I i 4. 7 1 I
Page1 TABLE 1 l COMPLIANCE PLAN ISSUES THAT HAVE NOT YET BEEN COMPLETED l OR WHICH ARE CURRENTLY BEHIND SCHEDULE. l l PORTSMOUTH ISSUENO. DESCRIPTION OFISSUE DUEDATE STATUS 3 Autoclave Upgrades 2/1/01 On Schedule l 11 Exceptions for Criticality Accident Alarm System Pending Completion On Schedule l ofNRC review 30 Procedures Program 3/3/02 On Schedule, but process is not l currently in place for assuring l PORC review of in-hand l-procedures in 5 years l A.4 Possession of Uranium enriched Greater than 10% 235U 3/31/00 On Schedule l f i h
i Page 2 TABLE 1 l COMPLIANCE PLAN ISSUES THAT IIAVE NOT YET BEEN COMPLETED l OR WHICH ARE CURRENTLY BEHIND SCHEDULE. l 1 PADUCAH ISSUENO. DESCRIPTIONOFISSUE DUEDA TE STA TUS 27 Procedures Program 3/3/02 On Schedule l 36 Seismic Capability of Buildings C-331 and C-335 6/30/99 Behind Schedule l l A CAR has been submitted to l change the Compliance Plan l scheduled date for this issue l to June 30,2000. This CAR l is currently with NRC for l review and approval, prior to l submission to NRC. l 46 Criticality Accident Alarm System - Horn Audibility 1/18/00 On Schedule l 50 Criticality Accident Alarms for Nearby Buildings 1/18/00 On Schedule l
FIGURE I
SUMMARY
OF INDIVIDUAL COMPLIANCE PLAN ACTIONS
1 l 1 Compliance Plan Tasks as ofJanuary 1,1999 80 - - -- 500 -- 450 70 -- O a i 5 d E -- 400 60 -- $0 8 z 3u ea EE O n -- 350 e E O 2 w 50 -- j i ,m Extended S 4 iammmmeopen -- 300 j c y > a o g 11 iComplete 4 2 = I s. E Cum. Completed i = 40 -- r g i i -- 250 2 Q-g g [= = = Cumulative Tasks l I E e 5 5 E 4 ~~ 30 -- -- 200 $ o -- 150 20 -- r-' p r-- I l -- 100 7 r t 10 -- R- -lj p-q 3 j -) -- 50 t i i 0
- -T': :
- -T : : : -T : : :-'-7-T :
0 1/1 4/1 7/1 10/1 1/1 4/1 7/1 10/1 1/1 4/1 7/1 10/1 1/1 4/1 1996 1997 1998 1999
ENCLOSUREI DESCRIPTION OF COMPLIANCE PLAN ISSUES AND ACTIONS ?
. ENCLOSURE 1- .' PORTS Action Status by Issue 20Jan-99 FACILITY ISSUE # TASK ID DUE DATE COMMIT. MENT DESCRIPTION STATUS PORTS 01 CPI-POA-X01.0; Transition Some of the activities necessary for USEC to implement this phased Complete transition are described in this Compliance Plan. USEC is currently developing additional detailed plans and schedules to implement the phased transition. Consistent with ROA requirements 312.2,3.3.2.6 and 3.4.2.3, DOE will review all proposed changes from OSRs to TSRs, and USEC will not implement any such changes without the consent and written approval of the DOE Regulatory Oversight Manager. CPI-POA-X01.02 Transition ' In the mterest of amuring a safe, smooth transition from DOE to NRC Complete regulatory authority, including a safe transition from OSRs to TSRs, USEC will keep the DOE Regulatory Oursight Manager and the NRC fully informed of USEC plans, schedules, and the status of activities to implement the phased transition. The information USEC will provide will include detailed tasks, schedules, and milestones for completing the transition; identification of areas requiring interface resiews and the schedules for performing such review; and the schedules for procedure development, personnel training, and operational readiness evaluations. Except as identified in this Compliance Plan, all actisities required to complete the transition from compliance with DOE requirements to NRC regulations will be completed by the date hTC assumes regulatory authority. The transition to NRC regulatory oversight is scheduled to occur 120 days after the NMSS Director's decision regarding USEC's certification. CPI-POA-X01.03 Transition The listing of open USEC.__- --.ts to DOE will be provided to NRC Complete by USEC on the date that NRC assumes regulatory authority for PGDP. 02 CP!-POA-X02.01 2/1$!?7 The approved DOE site-wide Safety Analysis Report and supporting Complete Issue 2, POA leem I contains an documentation mitt then be forwarded to USEC by February 15,1997. extensive description of the contents of the DOE SAR. - CPI-POA-X02.02 4/1/97 USEC will provide information required to complete the DOE site-wide Complete Safety Analysis Report and will provide technical reviews of the ongoing analyses to ensure that the analyses accurately reflect the facility configuration. ., Page i of 29
FACHJIT IS$UE O - TASK G : DUEGMTE . COMMPTMENTDESCRIPTION ~ STATUS FORTS
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CPI-POA-X02.03a 8/17S7 By no later than August 17,1997. USEC shall submit an amendment to ~ Coenylete ~ CAR requested delay to 10/3187 their Certification Apprration which includes: I a) identificsion of all informanon, findings, and Wons which indicate differences between the DOE site-wide Safety Analysis Report and the USEC Application for Certification. CPI-POA-X02.03b. 8/17S7
- By no later than August 17,1997, USEC shall submit an amendment to Counplete
- CAR requested delay to 10/3187 ' their Certification Application which includes: ~ b) an evaluation of the effects of those differences on the safety of workers, and off-site members of the public. CPI-POA-X02.03c 8/1787 By no later than August 17,1997, USEC shall submit an amendment to Consplete . CAR requested delay to 10/31S7 their Certification Application which "mcludes: c) proposed modifications to the r=nniiance certificate and/or facility, including proposed modifications to the Application SAR and TSRs. 7 s CPI-POA-XO2.M 8/1787 At the same time the Application -.l.~a is due, USEC shall also - Cosmplete CAR requested delay to 10/3187 submit for NRC approval, its proposed resolution of matters contained in the DOE-approved site-wide Safety Analysis Report not incorporated by 5 USEC in its request for --- ----- ; of their Application for Certification. CPI-POA-X02.05a 8/1787 - From September 30,1995, until NRC approves the submittals in . Complete paragraphs 3 and 4 above, changes made by USEC in accordance with DOE's ROA requirement concerning Unreviewed Safety Question - Determinations (USQDs) or with 10 CFR 76.68 must be addressed either ^ in the DOE SAR Upgrade results or in the amended safety analysis report submitted by USEC based upon those results. The following will assure such changes are properly considered and addressed: n
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- t ..o.--.- - + ~. - -. - -- -m
FACIllIT ISSUE # 'TASKID DUE DATE CO%I3tlTalEST DESCRIPTION STATUS PORTS 02 CPI-POA-X02.05b 8/17S7 From September 30,1995, until NRC approves the submittals in Complete CAR requested delay to 10/31S7 paragraphs 3 and 4 above, changes made by USEC in i w.as with DOE's ROA requirement concerning Unreviewed Safety Quesuas Determinations (USQDs) or aith 10 CFR 76.68 must be addressed either in the DOE SAR Upgrade results or in the amended safety analysis report submitted by USEC based upon those results.1he following will asme such changes are property considered and addressed: - Changes made to the plants after September 30,1995, will be addressed by USEC in its - - a-J Applicatiort The amendment Application will reflect the plant as it exists 6 months before the amendment submittal. CPI-POA-X02.05c 8/17S7 From September 30,1995, until NRC approves the submittals in Complete CAR requested delay to 10/31S7 paragraphs 3 and 4 above, changes made by USEC in accordance with DOE's ROA requirement concerning Unreviewed Safety Question Determinations (USQDs) or with 10 CFR 76.68 must be addressed either in the DOE SAR Upgrade results or in the amended safety analysis report subrnitted by USEC based upon those results. The following will assure such changes are pmperly considered and addressed- - Once the amendment is submitted, USEC will inform NRC of changes that are made in accordance uith 10 CFR 76.68 that could render the amendment to be incorrect, inaccurate, or incomplete until the amendment is appmved by NYC. CPI-POA-X02.05d 8/1787 Fmm September 30,1995, until NRC approves the submittals in Complete CAR requested delay to 10/3187 paragraphs 3 and 4 above, changes made by USEC in accordance with DOE's ROA icvko t conceming Unresiewed Safety Question Determinations (USQDs) or with 10 CFR 76.68 must be addressed either in the DOE SAR Upgrade results or in the amer.ded safety analysis report submitted by USEC based upon those results. The !bilowing will assure such changes are properly considered and addressed: - NRC is noriGed of changes ma& in accordance with 10 CFR 76.68 as part of the annual Application for renewat required by 10 CFR 7636. CPI-POA-X02.06 8/17S7 The update to the Application SAR will also reflect those commitments Cumplete CAR requested delay to 10/3187 made by USEC to the NRC during the initial certification Application process as identified in the Application and the responses to NRC questions / comments. . Enclosure 1 Page 3 of29
FACILITY ISSUE # TASK ID DUE DATE CO%DitTMENT DESCRIPTION STATUS PORTS 03 CPI-POA-X03.01a 7/1/97 Provide the capability to separately test the inner and outer loop Consplete containment s alves on the autoclaves in X-342A, X-343, and X-344A. CPI-POA-X03.01b 7/1/97 A revised TSR to reflect the new [ inner and outer loop containment valse Complete test] configuration mill be submitted to NTC by July 1,1997. CPI-POA-X03.01c Certification The TSRs for all autoclaves will be resised to declare an autoclase Complete inoperable and taken out of service when any containment s alve is determined to be inoperable until the capability to perform autoclave pressure decay testing with inner loop and outer loop containment valves is provided. CPI-POA-X03.02a 2/1/01 Insta!! fail-safe containment valves upstream of the UF6 feed isolation The scheduled completion date for and flow control valves on the autoclaves in X-342A and X-343 and Actions 2 through 9 for the first of modify the programmable logic control system. thirteen autoclaves,(as applicabic) was] May 1,1998, and was completed on schedule. The completion sci:edule for the remaining tutive autoclaves, as applicable, is February 1,2001. CPI-POA-X03.02b 2/1/01 Install fail-safe containment salves on the liquid UF6 drain line on The scieduled completion date for autoclaves 3 and 4 in X-344A. Actions 2 through 9 for the first of thirteen autoclaves,(as applicabic) was] May I,1998, and was cornpleted on schedule. The completion schedule for the remaining twelve autoclaves, as applicabic, is February I,2001. CPI-POA-X03.02c 2/1/01 Replace or modify the daughter cylinder isolation valves on the The scheduled completion date for autoclaves in X-344A for fail-safe (i.e., closed) position on loss of cir. Actions 2 through 9 for the first of thirteen autoclaves,(as applicable) was] May I,1908, and was completed on schedule. The completion schedule for the remaining twelve autoclas es, as applicable, is Feinuary 1,2001., Page 4 of29
FACILITY ISSUE # TASK ID Di'E DATE CONIMITMENT DESCRIPTION STATUS PORTS 03' CPI-POA-XO3.C3 2/1/01 Add a low air pressure switch to autoclave 2 in X-344A to initiate The scheduled completion date for containment upon loss of air to pressure transmitter PT-134. Actions 2 through 9 for the first of thirteen autoclaws,(as applicabic) was] May I,1998, and was completed on schedule. The completion schedule for the remaming twelve autoclases, as applicabic, is February I,2001, CPI-POA-X03.08 2/1/01 Modify the Ifigh Pressure Containment Shutdown System controls for the lhe scheduled completion date for autoclaves in X-342A, X-343, and X-344A to prevent them from being Actions 2 through 9 for the first of inadvertently opened when the pressure in the autoclave exceeds the thirteen autoclaves,(as applicable) setpoint as defined in the Technical Safety Requirements. was] May 1,1998, and was compicted on schedule. The completion schedule for the remaining twelve autoclaves, as applicable, is February 1,200L CPI-POA-X03.05 2/1/01 Upgrade the internal autoclave and UF6 c3 nder pressure transmitters to The scheduled ccaipletion date for Ii improve their temperature compensation capability and accuracy in the Actions 2 thrty4h 9 for the first of operating pressure range. thirteen autcclaves, (as applicable) was] May 1,1998, and was completed on schedule. The completion schedule for the remaining twelve autoclaves, as applicable is February 1,2001. CPI-POA-XO3.% 2/l/01 Prtnide operational alanns on the autoclave safety systems to alert The scheduled completion date for operators to potential upset conditions. Actions 2 through 9 for the first of thirteen autoclaves,(as applicabic) was] May 1,1998, and was completed on schedule. The completion schedule for the remaining twelve autoclaves, as applicable, is February 1,2001. Enclosure I, Page 5 of 29
FAClLIIT ISSFE # TASKID DUE DATE COM311TMENT DESCRIPTION STA RS PORTS 03 CPI-POA-X03.07 2/1/01 Modify the autoclave steam supply and condensate removal systems in X-The scheduled completion date foe 342A, X-343, and X-344A to minimize the back up of mad== in the Actions 2 through 9 for the first of autoclave-thirteen au:oclaves,(as applicable) was] May I,1998, and was completedonschedule The compienon schedule for the remaming tweht autoclasts, as applicabic, is Fetruary I,2001. CPI-POA-X03.08 2/l/01 Restore the autoclave head /shell scaling surfaces for the autoclaves in X-The scheduled completion date for 342A, X-343, and X-344A. Actions 2 through 9 for the first of thirteen autoclaves. (as applicabic) was] May 1,1998, and was completed on schedule. The completion schedule foe the semaining twehr autoclases, as applcable, is February 1,2001. CPI-POA-X03.09 2/I!01 A code interpretation from the ASME Code Committee will be obtained USEC is relying on a previously regarding the need for pressure relief for the UF6 cylinders. Based on this obtained ASME Code Interpretation interpretation, the need for modifications to the affected system to satisfy this action. See USEC operations will be assessed. Both the ASME Code interpretation and the letters GDP 98-0017 dated 2NS8, assessment results will be submitted to NRC for review and approval. 98-0178 dated 8/14/98 and 98-0201 dated 11/2N8 CPI-POA-X03.10a 12/31N6 Pressure decay testing procedures that assure that backpressure does not Closed mask leaks in autoclave steam admission lines will be implemented by December 31,1996. CPI-POA-X03.10b 12/31/96 Modifications to the buffer air supply lines on nine autoclases to Closed eliminate backpressure masking and resulting changes to pressure decay testing procedures uill be made. CPI-POA-XO3.11 3/31/98 A detailed schedule for completion of these action will be available for Complete lhe scheduled completion date for resiew at PORTS. Actions 2 through 9 for the first of thirteen autoclaves is May 1,1998. The completion schedule for the remaining twelve autoclaves will be such that the final autoclase is complete by February 1,2001. Encloswe 1. Page 6 of29
FAC11.ITY ISSUE # TASK ID pt'E CATE CO313flT31ENT DESCRIPTION STATi3 PORTS 03 CPI-POA-X03.12 2/1/01 The completion schedule for the remaining twelve aLeclaves will be The scheduled completion date of such that the final autoclave is complete by February 1,2001. hlay 1,1998 for Actions 2 through 9 for the first of thirteen autoclaves (as applicable) was met on schedule. 04 CPI-POA-XROI 12/31/96 Install instrumentation and system modifications in the steam condensate G esed drain piping from the evaport: tor heat exchangers to provide double contingency for nuclear criticality safety. CPI-POA-X04.02 12/31/96 Replace the evaporator heat exchangers to climinate the unfavorable O osed geometry expansionjoint. 05 CPI-POA-X05 01 6/30/96 Block valves, test taps, and a valve Icak test cart have been installed to G osed allow leak testing of the following isolation valves: (1) the uranyl nitrate feed isolation valves to the X-705 calciners feed pumps and (2) the isolation valves between the microfiltration units bag filters and effluent storage tank. The leak testing of these isolation valves nill commence prior to June 30, 1996. 06 CPI-POA-XO6.01a 6/30/96 Repipe a section of the feed sy stem to the microfiltration process. O osed Closed by NRC in IR 70-7002/98014 CPI-POA-XO6.01b 6/3a96 Deactivate the microfiltration influent pli shutdown synem (located Gosed Closed by NRC in IR 70-between second stage pil adjust and the micr0 filtration feed tank). 7002 S 8014 CPI-POA-XO6.01c 6/30S6 Install a microfiltration effluer.t pil shutdown system (located between O osed Cosed by NRC in IR 70-the microfiltration modules and the effluent tanL). 7002 S 8014 07 CPI-POA-X07.01a 6/30/97 The fixed IIEPA filter systems required to practice AI. ARA principles Complete and to control worker exposure will be retrofitted or replaced with new systems to allow testing in accordance with (1) the sq-iiu~.ts of u ANSI /AShlE N510 or (2) the intent of the requirements of ANSI /AShfE N510 for systems not designed to ANSI / ash 1E N509. Enclosure f, Page 7 of29
t FACIIJTY MSUE O ; TASK ID . DUE DATE J ~ COMMITMENT DESCRIPTION STA1TS - l PORTS 07 CPI-POA-XO7.01b - 6/30S 7 Also, efTorts are underway to develop a database of portable HEPA -- ~ Complete - filtration units and to perform in-place leak testing of all portable HEPA filter units.. CPI-POA-X07.0!e 6/3a97 The IIEPA filter systems / units that are not required based on Complete theenvironental Filter Critera established by the Ifigh-Efficiency Filter 53 tem Team and accepted by the ALARA committee have been downgraded to Non-IIEPA filter s>m status. 08 CPI-POA-X08.01 2/28S7 Formal NCSAs and NCSEs will be completed for all current operanons Complete issue will be reopened see USEC involving uranium ennched to I ut % or higher 235U and 15 grams or letter GDP 98-0264 more 235U by November 30,1996, and will be properly documented and approved in accordance with the NCS program requirements contamed in . the approved Certificate. . CPI-POA-X08.02 11/30/96 The procedural changes to resolve the administrative noncompliances in, (,eeplete . Issue uill be reopened see USEC ' the nuclear criticality safety program will be completed by November 30, letterGDP98-0264 - 1996. CPI-POA-X08.03 Transition All aspects of Technical Safety Requirement 3.9 implementation and its Complete 1ssue will be reopened see USEC.. associated tentacles for NCS mill be in place no later than the transition letter GDP 98-0264 to NRC regulatory oversight. 09 CPI-POA-X09.01a Transition See issue 8 A program is in place to review all NCSAs in order to identify and track Complete issue will be reopened see USEC the designated NCS conditions, specifications, and controls and to verify Ictter GDP 98-0264 their full implementation _ Particular attention is being focused on i ensuring consistency between each NCSA and the operauon including ' work-site postings. The verification program (of the roughly 150 operating procedures and 150 postings) will be completed for all current fissile material operations, prior to NRC assuming regulatory oversight of PORTS for NCSAs that need to flow into Technical Safety Requirements. I CPI-POA-X09.01b 1/31/97 Identification of the remaining NCSA requirements to be flowed-down Complete issue will be reopened see USEC into procedures will be completed by December 2,1996. . Ictter GDP 98-0264 CPI-POA-X09.0lc 2/28N7 A procedure for container handling and storage will be developed prior to Complete. Issue will be reopened see USEC 7 December 2,1996. letter GDP 98-0264 l i, Page 8 of29 { ~ - _. -,., ~ =. -_<, -
1.. i FACILITY ISSUE # TASK ID - DUE CATE COMMITMENT DESCRIPTION STATUS 3 . PG3TS 09 - CPI-POA-XO9.02 12/2/96... The procedural changes to resolve the administrative u-in ; Cosmplete . Issue will be reopened see USEC. the Nuclear Criticality Safety Prograrn (from SAR Sectum 5.2.4 and as letter GDP 98-0264 identifed in the Summary of Rwe and Cr r: table ~ below) will be compicted by December 2,1996.. 1 CPI-POA-X09.03 Transition All ap #fechnical Safety Requirement 3.9 in=d-eawian and its ' Cosmplete Issue will be reopened see USEC ' associated tentacles for NCS will be in place no laser than the transition letter GDP 98-0264 to NRC regulatory oversight. ) CPI-POA-X09.05 On Going If a new or revised NCSE identifies the need for isodifications to the Cossplete - Issue will be reopened see USEC existing plant configuration, affected actis ities will be curtailed and will letter GDP 984264 -
- not be restarted until either (1) the plant configuration is modified or (2) the activity is modified so that it can be performed safely in the current 1
configurnhon. If the plant configurauon or activity is modified, the Plant - i Opersoons Resiew Comnunce will review the proposed modification prior to its resumpuon to verify that the activity, as modified, can be performed safely. 10 CPI-POA-X10.01
- 3/3I/96 A list of managers w ho require training for oversight of nuclear criticality Closed
. issues will be developed. t t CPI-POA-X10.02 3/31/96 Individuals requiring training will complete the designaaed NCS manager Closed training course. - ' ? j f II CPI-POA-XI1.01 9/3096 USEC will provide criticality detector coverage in all areas of the plant Cosmplete except for those areas identified andjustified by USEC and approved by NRC. Analyses that provide the technicaljustification for not providing criticality accident alarm system coverage in designated areas of the plant [ 2 are being developed. Except for Buildings X-330, X-333, and X-700, analyses have been submitted to NRC that (1) verify the adequacy of the [ existing criticality accident alarm systern and its detector locations for - } detecting a criticality accident and (2) Justify that detectors are not - required for monitoring other areas of the plant. The analpes for l Buildings X-330, X-333, and X-700 will be completed by September 30, 1996. i h t E Endosure 1. Page 9 of29 + ~ .-...~z .....m.-
+ L FACILITY IS$t.'E# ' TASK ID - Dt'E DATE ' -- COMMITMENT DESCRIFDO"i STATUS _ PORTS' 1I CPI-POA-X11.02. 7/1/98 . The analyses already submitted identified the need to tie the evacuation Complete . Action was deleted, see NRC leect horns in Building X-744H to the Building X-744G CAAS that prwides '. daned September 21,1998 (TAC - - detection coverage for Building X-7441L Building X-744H contains - No.L12004) ligin.ly contaminated waste with a comparatively low potential for a' - criticality accident. ' l Pending Completion of This CW-Plan Issue will be modified to provide a plan and. NRCletter deced December 4, CPI-POA-XI1.03 NRC Review - schedule for establishing adequate detector coverage if the adequacy of 1998, requested additional : a the current detector coverage is not verified by the NRC review. - mformation concernag USECs request for exclusion from CAAS - . coverage at PORTS (reference j USEC letters GDP 96-0055 4/9S6, ~t 96-0107 5/22/96,96-0172 FI5196) i 12 CPI-POA-XI2.01 10/24/95 The required procedure changes will be implemented. O seed 4 i CPI-POA-X12.02 10/1/96 Plant procedures will be issued by October 1,1996, to incorporate the Ossed i annual radiation protection program review requirement from SAR paragraph 53.1J. [ 7 13 CPI-POA-X13.01 Transition Building work areas previously posted as " Regulated Arens" will be re ' Gesed 4 posted to reflect the current " Restricted Area" and
- Contamination.
Control Zone" designations ? CPI-POA-X13.02 12/31S 6 Restricted areas within USEC leased space which contain untabeled, but G esed - 7 potentially radioactive, material contamers will be posted with signs stating that each unlabeled contamer may contain radioactive maserial. t I CPI-POA-X13.03 12/31/98 . Necessary radiological c6ka im and re-posting ofleased areas Complete I within the PORTS site boundary will be completed by December 31, 1998. [ E i4 CPI-POA-X14.01 10/24/95 USEC will provide NVLAP-accredited dosimetry for those relatively few G esed individuals who are required to be monitored under 10 CFR 20.1502. t L t i L Enclosure I, Page 10 ofi9 l t
FACILITY ISSUE # TASK ID DUE CIATE CO\\l%ilT3 TENT DESCRIPTION STA11'S PORTS I5 CPI-POA-X15.01 12/31195 A procedure defining fire prevention reqRa.u.ts for compensatory G osed action will be des eloped to address (I) preplanned and emergency impairment program. (2) limiting conditions for operation, and (3) compensatory actions. 16 CPI-POA-X16.01 11/30/95 The Fire Department uill test the fire systems at the required ORO Fire Gowd Gosed by NRC in IR 70-Protection periodic testing frequencies. Implementation of the testing 7002/97208 frequencies will be completed by November 30,1995. 17 CPI-POA-XI7.01a Also see Issue 30 The fire protection procedures will be created or revised as part of the Gowd The procedure upgrades and - overall procedure upgrade project by December 31,1997. associated training required to address this area of noncomNiance will be completed in accordance with the plan of action and schedule of the Compliance Plan issue entitled " Procedures Program
- Closed by NRC inIR 70-7002/98014 CPI-POA-X17.01b 12/31/96 Fire Protection pmp-mmaic procedures (1) Standard Practice Procedure O osed Gosed by NRC in IR 70-S-20," Fire Protection";(2)" Fire Protection Requirements for Welding, 7002/98014 AND97208 Burning, and liotwork Practices," UE2-SS-FS1031; and (3) a formal procedure for the performance of fire hazard assessments will be upgraded and implemented by December 31,1996.
CPI-POA-XI7.0?c 12/31/96 The hot work permit procedure and applicable training programs will be Gowd Closed by NRC in IR 70-revised to ensure Fire Senices involvement and oversight of the hot work 7002/98014 permit program by December 31,1996. I8 CPI-POA-X18.01 10/1/96 The emergency packets will be updated by Fmergency hianagement to Gowd Discrepancies were found in the reflect current facility configurations and conditions. This update will emergency packets. Compliarr e is include the information required by the emergency packet control anticipated to be restored by procedure iricluding such information as: (1) general building / area layout .lanuary 31,1999. drawings or sketches,(2) critical action, equipment, or material listing, (3) facility / area utility services,(4) facility emergency systems and equipment, (5) lists of hazardous, toxic, and/or radioactive materials, including compressed gases, and (6) list (s) of facility tenant organizations ,, Page iI of29
w.- FACILITY ISSt'E O TASK I D - Dt'E DATE ' COMMITMENT DE-N STATUS'- -PORTS 18 - CPI-POA-XI8.02 6/3087 An analysis will be conducted by Fire Sen' ices personnel to deternune Cleoed Closed by NRC inIR 70-' the maximmn allowable combustible Icedings within the process - 7002/97208 buildings. The analysis will include determmation of the existing. combustible loadmgs ofselected speciSc occupancy areas within the process buildings and the verification of the ability of the sprmLlers to control these specific occupancy areas. Some local occupar cy areas to be considered include burnable " Anti-C' waste storage, lobe oil in process reserves, waste storage, maintenance shops, and stores. Building custodians mill be provided information and training on recognizing the acceptable levels of combustible loading in the process buildings, both in general and inlocal areas. 19 CPI-POA-X19.01 4/30/96 Upon approval of the Packaging and Transportation Quality Assurance Complete Plan and accep'ance of USEC as holder of the NRC certificate of compliance for the Paducah Tiger overpack, USEC will begin shipment under the NRC certificate ofcompliance. 20 CPI-POA-X20.01 5/2687 DOE and Third-Party tenants will notify USEC before hazardous Closed chemicals, including UF6 and UF4, are introduced onto the site. All initial process hazards analyses are to be completed by May 26,1997. CPI-POA-X20.02 3/14/96 Finalize the resolution document and forward to NRC Gesed CPI-POA-X20.03 5/26/96 Complete 75% of the initial process hazard analyses to conform with the Closed federally mandated requirement. - CP!-POA-X20At 6/28/96 If the material exceeds specified CFR threshold quantities, a safety risk. Closed will be performed to idemify the hazardous and mitigating actions in accordance with those regulations. If required, develop and distribute DOE directi*e. 21 CPI-POA-X21.01a Also see issue 30 For Q to support TSRs and AQ-NCSi QAP and Regulatory Closed Closed by NRC in IR 70-Requirements Flowdowti-Quality Assurance Program requirements and 7002/98014 applicable NRC requirements will be flowed down to policies that will bc. approved and implemented at USEC Headquerters and PORTS in accordance with the Plan of Action and Schedule described in Issue 30,
- Procedure Program."
r, Page 12 of29 ,.,i r .m..c .m m .1 .mm m m ma. - .m m m m
FACILITY ISSI E # TASK ID DUE DATE CO31311T31ENT DESCRll410N STATt3 PORTS 'l CPI-POA-X21.Olb 12/3187 For balance of Q and other AQ:. QAP and Regulatory Requirements G osed Closed by NRC in IR 70-Flowdown -Quality Assurance Program requirements and applicable 7002 S 8014 NRC requirements will be flowed down to procedures that will be approved and impicmented at USEC fleadquarters and PORTS in accordance with the Plan of Action and Schedule described in Issue 30, " Procedure Program." CPI-POA-X21.02a Transition Organizational Roles, Responsibilities Relationships, and Authorities Closed Closed by NRCin IR 70-Flowdoum - The flowdown to committed position descriptions provided 7002 S 8014 in Section 6.1 of the USEC Application uill be completed and position descriptions revised, if necessary, by the date that NRC assumes regulatory authority. CPI-POA-X21.02b 12/3187 The position descriptions uill again be res iewed and rnised, if O osed Gosed by NTC in IR 70-necessary, by December 31,1997. 7002 S 8014 22 CPI-POA-X22.01 Transition A charter for the PORC is in place; however, it requires revision to ensure G esed consistency with commitments made in the NRC-approved Safety Analysis Report Section 62 and Technical Safety Requirement 3.10. This review and the charter upgrade will be completed and implemented by the date that NRC assumes regulatory authority. 23 CPI-POA-X23.01al 12/3186 Identify and document all Q items items including system boundaries and Complete support systems required for performance of the intended safety function, to be included in the scope of the Configuration blanagement Program. CPI-POA-X23.01a2 2/28/97 Identify and document all AQ-NCS items including system boundaries Complete Action uill be reopened see USEC and support systems required for puim.w of the intended safety letter GDP 98-0264 function, to be included in the scope of the Configuration blanagement Progrant CPI-POA-X23.01a3 10/187 Identify and document all other AQ items including system boundaries Complete and support sy stems required for performance of the intended safety function, to be included in the scope of the Configuration klanagement Program.. Page 13 of29
- - - - = - l FACILITY - ISSUEO TASK ID DUE DATE, COMMITMENT DESCRIPTION . STATUS. PORTS 23-CPI-POA-X23.0lb Transition Develop the flowdown of----- -- --ts from the Technical Safety ~ Complete Deficiencies identified related to Requirements, the Safety Analysis Report, and other plans and programs flowdown of application. to procedures and training. -
ts for procedures and training. NRC Resident Inspector was motified. Action will be i
reopened.- - CPI-POA-X23.01c 12/31M7 Incorporate new Technical Safety Requirements into the surveillance Closed ' The procedure development and the - testing and administrative procedures. associated training required to resolvethisitemwillbe completed - accordmg to the plan of action and s schedule presided in the Compliance Plan issue 30,
- Procedures Progrant*
CPI-POA-X23.01d 10/IM7 Identify and document all other AQ items, including system boundaries. Complete. and support systems required for performance of the intended safety function, to be included in the scope of the Configuration Management Program. CPI-POA-X23.02a 12/31/96 Develop the baseline documentation that establishes the design Closed requirements for all Q systems / items, including support systems required for performance of the intended safety function. s CPI-POA-X23.02b 2/28/97 Review all Nuclear Criticality Safety Approvals and Nuclear Criticality Complete Action will be reopened see USEC I Safety Evaluations to identify AQ-NCS items (items which support the letterGDP98-0264 - nucicar criticality double contingency principle); to identify and document the designated design requirements and system boundaries, including support systems required for pu 6m-n of the intended safety function; and to verify the implementation of these requirements. To the extent completed, this information uill be maintained and made available to the NRC, before regulatoryjurisdiction, for planned inspection activities. CPI-POA-X23.02c 10/IM7 Identify, document, and communicate definitive boundaries for the other ~ Complete AQ systems. Identify and document the design requirements for these AQ systems / items, including support systems required for performance of the required safety function, for which the design requirements must be. known. Enclosure I, Page 14 of29 i . _ _ _ - _. _.. ~ - - _, _ _,.. _ _ -. _ _ _ - - - - -. - - _ _ - _ - --v-. - - - - -. ~. -.. -
FACILITY ISSUE O TASK ID DUE DATE CO.%I%IITMENT DESCRIPTION STATTS PORTS 23. CPI-POA-X23 03a Also see issue 29 Develop improved reconis management and document control programs. O osed ' The program and procedure to satisfy the needs of the Configuration Management Program. Deselop developrnent and associated and implement tbc required procedures. training required to resolve this noncompliance will be completed according to the plan of action and schedule provided in the Compliance Plan Issue 29, " Records Management and Document Control Programs? CPI-POA-X23.03b Also see Issue 20 Train appropriate plant personnel in the requirements of these programs Closert The program and procedure and procedures. developnwnt and associated training required to resohr this repfiance will be completed according to the plan of action and schedule prosided in the Compliance Plan Issue 29,
- Records Managernent and Doctanent Control Programs?
CPI-POA-X23.04a 7/3186 Upgrade the four core engineering pmcedures that specify the Closed requirements for the change control process to ensure the identification. technical and safety review, approval, impt - 2---; validation, docurnentation, and recording of plant changes. CPI-POA-X23.04b 7/31S6 Train appmpriate personnel to ensure proper impl di.o and G osed application of these upgraded core procedures. CPI-POA-X23.04c 3/3167 Develop or upgrade remaining engineering procedures that are associated Cesaplete with the change control process and train appropriate personnel on these new or upgraded procedures. CPI-POA-X23.05a See issue 30 Develop procedures required to implement en assessment program to Complete The pmcedure des-clopment and the systematically evaluate the development and effective implementation of associated training required to the Configuration Management Program elements and related processes. resolve this area ofnoncompliance uill be completed according to the plan of action and schedule provided in the Compliance Plan issue 30, " Procedures Program
- Enclosure I, Page 15 of29
. FACILITY ISSEE # - TASK ID . DEE YATE - COMMITMENT DESCRIPTION. STATUS 3 PORTS-23 ' CPI-POA-X23.05b See Issue 30 Trainwdus personnel to ensure proper - ;'-- - - --ion and Complete The procedwe development and the application of these procedures associated training required to resolve this area of noncompliance mill be completed according to the plan of actiort and schedule provided in the Compliance Plan ; j 1ssue 30," Procedures Program." CPI-POA-X23.06 See issue 26 Implement a training program for plant personncI relied upon a3 operate, Complete The training program . maintain, or modify the plant. Include initial training on improved or 'g'---..; ::aa and the training newly developed programs and procedures identified as required to required to resohe this area of - support the Configuration Management Program objectives.1 si,w y:La will be completed - according to the plan of action and schedule of the CWi-Plan . Issue 26, *S mmns <W to 3 Training? 24 CPI-POA-X24.01 See issues 26 and 30 Develop and implement a maintenance history and trend analysis Consplete - The procedure upgrades and program. . associated training to address this area of the scrw.y"; will be - Develop a master equipment list for safety critical equipment. completed in coordination with the - Implement a new computer-based maintenance management system plares and schedules set forth in the with the capability to collect and trend the data. Compliance Plan issues' Procedures Program"and" Systems Approach to Train' g." m CPI-POA-X24.02 7/31/96 Develop guidance for cleanliness control and measures ta prevent entry Closed of extraneous material into a closed system. CPI-POA-X24.03a 4/30S 7 for Q items: Upgrade the current maintenance work control process to Complete provide the committed level of planning and work package development for Q items. - Centralize all planning and work control functions in the Work Control organizathr-(Co.-ylete) - Revisethewai entrolprocedure. - Develop and provide training on the upgraded work control process. Encloswe L Page 16 of29
FACILITY ISSUE # ~ TASK ID . DUE DATE COMMITMENT DESCRIPTION. STATUS PORTS 24 ~ CPI-POA-X24_03b ~2/28/97 For AQ-NCS items: Upgrade the current -- :-- = E work control ~ Complete _ process to provide the committed level of planning and work package. development AQ-NCS items.' ~ - Centralize all planning and work control functions in the Work Control . organization. (Complete) - Revise the work control procedure.' -. - Develop and provide training on the upgraded work control process. + CPI-POA-X24.03c 6/30S8 For other AQ items: Upgrade the current maintenance work control Complete process to proside the commi:ted level of planning and work package development other AQ items. - Centralize all planning and work contml functions in the Work Control organization. (Complete) - Retise the work control procedure - Develop and provide training on the upgraded work control process. CPI-POA-X24Ala 2/28!97 For AQ-NCS items: Upgrade the preventive maintenance pmgram to Complete .f meet the commitments for greater formalism. - Develop an escrall performance indicator to measure preventive maintenance effectiveness. - Identify current pre.wtive maintenance performed on Q, AQ-NCS, and lr other AQ items. - Revise the preventive maintenance program procedure to estaMish a fonnat mechanism tojustify and document changes to Q, AQ-NCS, and other AQ item requirements. T - Develop the technical /histoncal basis for use in evaluating preventive maintenance task adequacy. F CPI-POA-X24.04b 3/31/97 Fm Qitems: Upgrade the preventive maintenance program to meet the Complete wanmitments for greater formalism. - Develop an overall performance indicator to measure preventive j maintenance effectiveness. - Identify current preventive = :- - -- - performed on Q, AQ-NCS, and other AQ items. - Revise the preventive maintenance program procedure to establish a formal mechanis:in tojustify and document changes to Q, AQ-NCS, and other AQ item requirements. - Develop the technical /ldstorical basis for use in evaluating preventive - ----- task adequacy. I l Declostue1 Page17of29 I
FACILITY ISSUE # TASK ID DOE CATE CON 13tITMENT DESCRIP110N STATt3 PORTS 24 CPI-POA-X24Dic 600/98 For other AQ items-Upgrade the presenthe maintenance program to - Compiere meet the wm.ni:mcras for greater formalism. - Develop an overall performance indicator to measure preventive maintenance effectiveness. - Identify current preventive maintenance performed on Q, AQ-NCS, and other AQ items. - Revise the preventive maintenance program procedure to establish a formal mechanism to justify and document changes to Q, AQ-NCS, and other AQ item requirements. - Develop the technicattistorical basis for use in evaluating preventive maintenance task adequacy. CPI-POA-X24.05a 2/28/97 For AQ-NCS MATT Resise the measuring and test equipment Complete calibration program to meet the more formal RSoaas. - Implement procedures that define and control the overall measuring and test equipment program. (Complete) - Develop and implement individual calibration procedures for Q, AQ-NCS, and other AQ SSCs. - Provide training on calibration requirements to affected coordinators, managers, technicians, and users. CPI-POA-X24.05b 12/3 tN6 For Q MATE: Revise the measuring and test equipment calibration Complete program to meet the more formal requirements. - Implement procedures that define and control the overall measuring and test equipment program. (Complete) - Develop and implement indhidual calibration procedures for Q, AQ-NCS, and other AQ SSCs. - Provide training on calibration requirements to affected coordinators, managers, technicians, and users. CPI-POA-X24.05c 6/30N8 For other AQ MATE: Resise the measuring and test equipment Complete calibration program to meet the more formal requirements. - Implement procedures that define and control the overall measuring i and test equipment program. (Complete) - Develop and implement individual calibration procedures for Q, AQ-i NCS, and other AQ SSCs. - Provide training on calibration requirements to affected coord'mators, managers, technicians, and users.. Page 18 of29
[b . FACILITY ISSUE # D TASK ID DUE L* ATE ' COMMITMENT DESCLIPDON - STAR 5 - PORTS' 24 CPI-POA-X24.06a. 10/3I/96 - ' For Q SSCs: Identify the procedural deficiencies for performing ' Closed' ~ corrective maintenance, preventive.----- --- =. equipment calibration, or surveillance testing for Q, AQ-NCS, and other AQ SSCs and develop a - composite listing of the procedures requiring revision, developmera, or conversion.. CPI-POA-X24.06b IGI/97 For AQ-NCS SSCs Identify the procedural deficiencies for performing _ Closed corrective maintenance, preventive ma ntenance, equipment calibration, or surveillance testing for Q, AQ-NCS, and other AQ SSCs and develop a composite listing of the procedures requiring revision, development, or conversion. CPI-POA-X24.06c 1001/97 For other AQ SSCs: Identify the procedural deficiences for performing Completc _ corrective maintenance, preventive maintenance, equipment calibration, 'l or surveillance testing for Q, AQ-NCS, arul other AQ SSCs and develop a composite listing ofthe procedures requiring revision, development, or i conversion. CPI-POA-X24.07 Transition Develop procedures and proside the associated training of appropriate Complete personnel for the performance of sun eillance tests which are required to support Technical Safety Requirements. CPI-POA-X24.08a 2/28/97 For AQ-NCS items: Revise, develop, or convert corrective maintenance, Complete preventive maintenance, instrument calibration, and suntillance test t procedures for AQ-NCS structures, systems, and components. + r CPI-POA-X24.08b 381/97 For Q items: Revise, develop, or convert corrective maintenance, Complete preventive maintenance, instrument calibration, and surveillance test i procedures for Q structures, systems, and components. CPI-POA-X24.08c 600/98 For other AQ items: Revise, develop, or convert corrective maintenance, Complete preventive n6E,ew instrument calibration, and surveillance test procedures for other AQ structures, systems, and components. + CPI-POA-X24.09a 2/28/97 For AQ-NCS items: Develop training materials for the work control, Complete surveillance testing, instrument calibration, and corrective ami preventive maintenance procedurcs and provide the associated training of appropriate personnel. .i, Page 19 of29 4 - - ~. - -
FACILITY ISSUE # TASK ID DUE DATE COM31tTMENT DESCRIPTION STATUS PORTS 24 CPI-FOA-X24.09b 3/3187 For Q items: Develop training materials for the work control, Complete suncillance testing, instrument calibranen, and corrective and preventive maintenance procedures and provide the associated training of appropriate personnel CPI-POA-X24.00c 6G0/98 For other AQitems: Develop training materials for the work contml, Complete surveillance testing, instrument calibration, and corrective and preventive maintenance procedures and provide the associated training of appropriate personncL CPI-POA-X24.10 3G187 Identify and control the vendors' manuals used for maintenance of Q Complete equipment, including entering them into the document control and records :nanagement system. - Identify vendor manuals used for maintenance activities of Q equipment. - Verify appropriate vendors' manuals for accuracy and completeness. - Enter vendor manual data into the records management and document control system. 25 CPI-POA-X25.01 12/3187 Procedures addressing the operations program elements discussed in Co:nplete Section 6.5 of the Safety Analysis Report will be developed or revised. associated initial training materials will be deseloped, and appropriate personnel will receive initial training by December 31,1997, consistent with the plan of action and schedule of the Compliance Plan issue entitkd
- Procedures Program?
CPI-POA-X25.02 6G W97 Continuing training material and qualification requirement develop:nent Complete will be completed, and appropriate personnel trained and qualified for Caxade Operator, Feed and Product Operator, Chemical Operator, Uranium Material llandler, Operations Manager /Supenisor, and Plant Shift Superintendent positions N June 30.1997, consistent with the plan of action and schedule of the D mpliance Plan issue entitled
- Systems Approach to Training?
CPI-POA-X25 03 12G187 Continuing training material and qualification requirement development Complete uill be completed, and appropriate personnel trained and qualified for Cascade Controller position by December 31,1997, consistent with the plan of action and schedule of the Compliance Plan issue entitled
- Systems Appmach to Training."
Enclossee 1. Pare 20 of29
FACILITY ISSUE O TASK ID DUE DATE CO3t%II13 TENT DESCOIPTION STATUS PORTS 26 CPI-POA-X26.01 6/30/97 Training programs will be developed and implemented based upon a Complete systems approach to training for workers who are relied upon to operate, maintain, or modify structures, systems, and components identified as Q or AQ-NCS items. For the previously identifiedjob classifications training for the job incumbents at certification will be completed by June 30,1997. CPI-POA-X26.02 6/27/96 A detailed schedule for the completion of all training programs not in Clased compliance with 10 CFR 76.95 will be issued by June 27,1996. CPI-POA-X26.03 6/3a97 For the additional job classifications not previously included in the Complete Nuclear Safety Upgrade Project, (i.e., systems engineers, cascade coordinators, and NCS engineers / specialists). thejob analyses and training program design have not been completed. The following actions will be completed by June 30,1997. - Revise and validate the existing job task lists. (complete) - Design a curriculum that covers thejob tasks selected for training. (complete) - Develop specific learning objectives from the job performance requirements. (complete) - Develop training materials. (open) CPI-POA-X26.04 12/31/97 Training for those holding these additional job classifications at the time Complete NCS training discrepancies were the program is implemented will be completed by December 31,1997. found and corrected (see USEC letter GDP 98-0214) CPI-POA-X26.05 6/30/98 Training programs for the job classifications list above, with respect to Complete AQ activities, will be developed and implemented by June 30,1998, following completion ofidentification of AQ items (see Compliance Plan Issue 23,
- Plant Changes and Configuration h1anagement") and associated procedures (see Compliance Plan Issue 30, " Procedures Program").
27 CPI-POA-X27.01 9/30/96 An organizational level assessment program will be implemented Closed Closed by NRC in IR 70-consisting of the preparation and implementation of a procedure for the 7002/98014 performance of organizational lesel assessments in a uniform manner. Enclosure I, Page 21 of29
FACILITY ISSUE # TASK ID DL'E DATE COMMITMENT DESCRIPTION STAT 1:S PORTS -28 CPI-POA-X28.01a Transition A nuclear regulatory event reporting procedure meeting the event O osed notification and reporting requirements required by the USEC application, and an es ent investigations procedure that defines the event investigation process and assigns responsibilities and authority for its implementation will be approved by the date NRC assumes regulatory oversight. CPI-POA-X23.01b Transition Training on these documents will be completed prior to the date NRC Closed assumes regulatory oversight at PORTS. CPI-POA-X28.01c Transition The procedures will become effective on the date NRC assumes Complete regulatory oversight at PORTS. 29 CPI-POA-X29.01 a.1 6/30/96 Records being maintained by the plant organizations and Administrative O osed Suppor* will be verified to determine the storage locations of these records and the methods of protection being employed to preserve these docu nents. CPI-POA-X29.01a.2 6/3096 ne final tally of records identified in item (I) above will be evaluated C osed against applicable requirements and then catalogued as to their record type, categorization. and retention. This information will be chsracteriicd in a combined PORTS and PGDP Uranium Enrichment Records Manual that will be utilized by both sites. Both the tally of records and the manual will be completed by June 30,1996. CPI-POA-X29.01 a3 6/3086 A records management turnover schedule has been drafted and submitted G osed to the functional organizations which prioritizes the turnover based on the record's importance to the safety and quality of plant operations. This schedule will be formalked by June 30,1996. CPI-POA-X29.01 aA 12/3188 Records being maintained in the organizations will not be turned over to Complete Administrative Support immediately but will be retained by the responsible organization until the D&R Group can process them. Pre-existing records will be tumed over and incorporated into the records management system. CPI-POA-X29_01 a.5 6/30S 6 A new electronic records indexing database based on the evaluation O osed conducted in item (2) above and item I.d)(1) below will be put into service by June 30,1996., Page 22 of29 + ..--m
-ha FACILITY. ISSUEO TASK ID DUE DATE COMMITMENT DESCRIPTION STATUS ~ PORTS 29: CPI-POA-X29.01b. Also see issue 23 ~ For legacy records: The PORTS Configuration Management Program Complete - implementation procedures will address the measures required to be taken if source information needs to be developed and documented. See issue 23,
- Plant Changes and Configuration Management."
CPI-POA-X29.01c ' 12/31N8 Records bemg mamtained in the organizations will be turned over to Complete Administrative Support in accordance with the records management - tumover schedule identificJ in item (aX3) above. Pre-existing records required to be maintained under the USEC Quality Assurance Program - v - will be tumed over and incorporated into the revised records management system in accordance with the approved records management turnover schedule. After the turnover of an organization's records to Records Management, the temporary storage of subsequent records will be in one-hour fire-rated file cabinets. t CPI-POA-X29.01d.l 8/15196 The PORTS computerized records indexing system will be tvaluated to Closed make certain that the necessary information required by each 7 organization for its records is consistently applied to ensure the ready retrievability of the records. CPI-POA-X29.01d2 12/31N8 Computer codes and test result data used to directly or indirectly support Complete the PORTS process systems will be submitted to Administrative Support in Amas vlh the turnover schedule identified in item (aM3) above. ? CPI-POA-X29.02a.1 6/3096 Documents being maintained by the plant organizations anu Closed ' Administrative Support will be verified. ~ 2 CPI-POA-X20.02a.2 6/30/96 A document control turnover schedule has been drafted which prioritizes Closed the tumover based on the document's irnportance to the safetv and quality of plant operations. This schedule will be formalized by June 30, 1996. i CPI-POA-X29.02a.3 6/30/96 The document control system will be updated on an ongoing basis to Closed l provide controlled distribution lists and to control the acwM distribution of documents under the control of the D&R Group commerxing June 30, 1996. i, Page 23 of29 l l Am-.m-.., ...-..m m.. ......m.~ -. w - w -. m.- m m - m. 2 m. .imu r e -s .. er w e m as w m-
FACILITY ISSUE O . TASK ID - DUE DATE COMMITMENT DESCRII" TION STATUS PORTS " 29 CPI-POA-X29.02a.4 12/31/98 ~ Documents within the scope of the document control program, according ' Complete to the application, will be identified. Documents being maintained in the organizations will not be turned over to Administrative Support but uill be retained by the responsible division until Administrative Support can process them. Pre-existing documents will be turned over and incorporated into the document control system. CPI-POA-X29.02a.S 12/31/98 The final tally of documents identified in items (1) and (3) above will be Complete catalogued as to their document type, distribution requirements, and information to provide an index for case of retrievability. ' CPI-POA-X29.02a.6 6/3086 The new electronic document control inventory system that identifies the - Closed controlled copy holder number and custodians, storage location, and retrieval capability will be put into service. t CPI-POA-X29.02b Also see Issue 23 For legacy documents: The plan of action and schedule provided in 1(b) Complete above will also resolve this item. 30 CPI-POA-X30.01 7/31/96 By July 31,1996, incorporate into the Procedure Control Process Closed f procedure the SAR-6.11.4.1 criteria for use by responsible management in complying with TSR 3.9 by identifying applications requiring additional wTitten procedures.. k f CPI-POA-X30.04 6/1/96 Document the criteria for use in determining when work must be stopped Closed because a procedure cannot be performed as written. b CPI-POA-X30.06 Transition - By the date that the NRC assumes regulatory author ty for PGDP, Closed incorporate into the Procedure Control Process procedure the SAR-6.I1.4.5 criteria for identifying procedures that TSR 3.9 requires review l by the PORC. . i h CPI-POA-X30_08 Transition incorporate action statements and ope ating limits from the Technical Complete Safety Requirements into operational procedures by the date that the NRC assumes regulatory authority for PORTS. } ? r r i Decloswr 1. Page 24 of29 f E m m
m .2. i - FACILITY ' ISSUE # TASK 13 DUE DATE COMMITMENT DESCRIPTION STATUS E PORTS 30 CPI-POA-X30.09a '.6/28/96 Issue the required operational policy statements and impicment ne v or. Complete - updated procedures (including required training) to fully implement the Quality Assurance Program or other activities identified in the application in accordance with the following schedule- [ i r - Operational policy statements: June 28,19% CPI-POA-X30.09b 2/25/97 Issue the required operational policy statements and implement new or Complete updated procedures (including required training) to fully implement the Quality Assurance Program or other activities identified in the . application in accordance with the following schedule: l - Level 2,3, and 4 AQ-NCS procedures (unless covered by item 8): I December 31,1996 - CPI-POA-X30.09c 3/31/97 issue the required operational policy statements and implement new or Complete Refer to issue 24 forlater updated procedures (including required training) to fully implement the Maintenance Program procedure Quality Assurance Program or other activities identified in the completion dates. - ' application in accordance with the following schedule: - Level 2,3, and 4 Q procedures (unless covered by item 8): March 31, i 1997 i CPI-POA-X30.09d 12/31/97 issue the required operational policy statements and implement new or Complete Refer to Issue 24 forlater updated procedures (including required training) to fully implement the - Maintenance Program procedure - Quality Assurance Program or other activities identified in the completion dates. application in accordance with the following schedule: f - Level 2,3, and 4 AQ and NS procedures: December 31,1997 CPI-POA-X30.10 12/31/97 Issue analytical laboratory procedures updated to cunent requirements by Complete December 31,1997. 5 l CPI-POA-X30.11 12/31/97 Complete all overdue Level 2,3, and 4 AQ procedure periodic reviews Complete i by December 31,1997. o t ? Enclosrae 1. Page 25 of29 f i ., __.. ~,
' FACILITY ISSUEO 'TASKID. DUE DATE COMMITMENT DESCRIPTION L . STATUS / PORTS 30 CPI-POA-X30.12 Transition + 5 years The PORC will review all precedures designated as in-fland and ~ . Reviews i,rwaJ,.g but process not procedures that involve liquid UF6 handling activities within a 5-> tar ~ in place for assuring PORC review period after the date that the NRC assumes regulatory authority for ofin-hand procedures in 5 tars. 3 PORTS. This commitment pertains only to those procedures which will ' not otherwise be revicued by the PORC(as required by Section 6.11.4.1), or by a PORC subcammiw before the expiration of the 5-yerr period. Procedures in this scope have been, and will continue to be, reviewed by a PORC subcommittee, thereby satisfying this commitment for those specific procedures. CPI-POA-X30.13 Transition All aspects of TSR 3.9 implementation and its associated tentacles shall Complete be in place no later than the date that the NRC assumes regulatory authority for PORTS. Procedures required by Technical Safety Requirement 3.9.1 shall be in place by the assumption o,cgulatory r authority by NRC except as specified in the Compliana Plan. 32 CPI-POA-X32 01 12/3166 ~ Develop and implement procedures, including personnel training, for the Closed scheduling and conduct ofintemal and supplier audits, including auditing the development, maintenance, adequacy, and effectiveness of the QAP, by December 31,1996. CPI-POA-X32.02a 2/28/97 Develop and implement procedures, including personnel training, that Closed - defirae pram-est, handling, and storage activitics for AQ-NCS items and services by December 31,1996. CPI-POA-X32.02b 3/31M7 Develop and implement procedures, including personnel training, that Complete define pism-esi handling, and storage activities for Q items and services by March 31,1997. CPI-POA-X32.02e -12/31/97 Develop and implement procedures, including personnel training, that Complete define pis.- ant, handling, and storage activities for other AQ items and services by December 31,1997. 33 CPI-POA-X33.01 6/3086 The emergency plan support documents will be upgraded. Closed 34 CPI-POA-X34.01a 9/3086 All tenant organization personnel will be given emergency preparedness Closed General Employee Training., Page 26 of29..
4 t FACIIJTY ISSUE #
- TASKIJ.
- DUE CATE. COMMITMENT DESCRIPTION STATUS TS - 34 ' . CPI-POA-X34.01b &30/96~ Updated formal training will be given to emergency response personnel. ' Complete CPI-POA-X34.01c 12/31/96 ' ' Off-site emergency support personnel mill be trained on the revised Closed emergency plan and procedures as appropnate by December 31,1996. ~ 35 CPI-POA-X35.01 10/24/95 A quality control program including all elements necessary to ensure Closed. u.-- n.un with 10 CFR 61.55 and 10 CFR 61.56 will be implemented. v 36 CPI-POA-X36.01 12/31/96 Update existing depleted uranium handling, moving, stacking, and Closed - inspection procedures to current format and content requirements (see the compliance plan issue entitled ' Procedures Program *) and proside training to affected personnel. E CPI-POA-X36.02 12/31/96 Develop a process for use in scheduling the periodic visual inspections. Closed 37 CPI-POA-X37.01a 8/1/96 The current staffing allocations will be supplemented if necessary to meet Closed ^ working hour guidelines stating that an individual should not be permitted to work more than 32 hours in any 48 hour period and no mtwe than 80 hours in any 7 day period, excluding shift turnover time. CPI-POA-X37.01b 8/1/96 A revised TSR will be submitted to the NRC to add these guidelines to Closed TSR 311.b. i CPI-POA-X37.02a 12/31/96 USEC uill supplement cunent staffing allocations to meet its proposed Complete l working hour guidelines that state that an indisidual should not be permitted to work more than 24 hours in any 48 hour period and no more j than 72 hours in any 7 day period exclusive of shift turnover time. 'h CP!-POA-X37.02b 12/31/96 USEC will submitted a revised TSR to the NRC to add these guidelines Closed to TSR 321.b at the time sufficient staffing is achieved to meet these cuidelines. -I I Exloswe L Page 27of29 I
I ) ___...__-__..m.rr=-.._---.&- - "-----~ - ~ - ~ l ~ FACit.IIT ISSUE # TASKlil' ' IDUE DNI E CO%I%III'hlENT l>ESCRIP'IION . STA'lUS ' - 4 = -, _- ~.-- ; -35.
==.+e.- .f ._=.------h _,. m._ _ _ = PORTSL 38 CPI-POA-X38 Of Pris alisation lhe following exceuted docunwnis rtquired to assure adequate fimding Compicte - for llSI'C's portiam of POR I S's decontaminatiini and deconunissioning ~ costs will be submitted to the NRC at the time llSi C privatizatism occurs; - an esecuted sinLing fund arrangenent, - a standby : rust agscement, and/or - - a payment surety bond. 1he atm e-listed documents uill ch sely adhere to the reconunended wording for such instruments set forth in NRC Regulatory Guide 3 66, " Standard Format on and Content of Financial Assurance Mechanisms 4 Required for I)econunissiuning under 10 CFR Parts 30,40,70, and 72." 4 39 CPI-POA-X39.01 5/26/97 The mechanical integrity program for maintenance and inspect on PSIC Closed Closed by NRC in IR 70-i requirements will be -7002/97208 implemented. 1 40 CPI-POA-X40.01 10/186 A review of system designs will be performed where operational trips and Closed alarms coincide with the setpoints for safety system actuation based on the same monitorcJ parameter and the same equipment actuated. Where redundant operatismal and safety system actua6ons exist, corrective action will be identiGed that may include justincation either for the ) redundancy or system nwilifications to eliminate the redundancy.1he results of this tesicw uitt be submitted to the NRC for teview and approval by October I,1996. 4i CPI-POA-41.01 2/IN7 The documents referenced in Appemfix A to SAR Chapter 1.0 uill be Closed res icwed, and a listing of specinc sectiims of the cmles, standards, and ' NRC regulatory guidance documents to which IUR I S is camunitted uill r be cinnpiled. 't he results will be transmitted to NRC at least 30 days prior to the date that the NRC assumes regulatory authosity for PORTS. l 42 CPI-POA.X42.01 7/3tN7 USEC will develop and complete a program to relate the response of UF6 Complete Discrepancies were found in the leak detectors to manual test methods and to the detection of an actual - implementation of this issue, but i UF6 leak-subsequently corrected, see USEC Ictier GDP 98-0214 dated 10/9N8. 4 4 -, l' age 28 of29 1 m-. ..m
x. L 4 "^., % ((.'T 7.I " ' ,. 74IY 7 7I E. ' " ' ~
- ^
. FArli.ITY ISstiED TASK lin, ' pt'E p.VI E CO%IntIl klENT DESCIlllllON -- -KlWlUS' ... ; 2.:.. .: ~:. -=,..: -z u =,:_C
- _c : ;z r.
- M)RTS : 44 CPI-N)A-X44.Ola - 7/1/98 - tInalarmed fxilitics that have turn hientified as of June 10.1996, will be Complete ' nustified with the resguised lawns and/or lights, as appropriate, or - rehicated to locations muside the 200-fet evacuation rone in accordance with the following schedule: 4 >.j Routinely hiaimed Facilitics: July I,1997 - 5 t 5 Cl*l-M)A-X44.0lb 7/1/98 . Unalarmed facilities that have been identified as of June 10,1996,will be - Cesnplete e nmwlified with the required horns and/or lights, as appropriate, or i relocated to heations outside the 200-foot esacuation rone in accordance . with the following schedule: Routinely Unmanned Facilities: July I,1998 t 1 .L. i 5 I k i I i 3 i Enclosure I,l' age 29 of29 m
g -=.=.+%._< m. w.- .+e W 4- - = =.- .-***.m-3.,..# m - .-e a oss s ENCLOSURE 1 PGDP Action Status by Issue 204m-99 ' m ~~ -:.2 : - --un- - =::. = FACILITY ISSUE # TASK ID pl!E DATE - CO31%IITMENT l>ESCRIP llON STATUS l PGDP -Of . CPI-POA-001.01 Transitiam Some of the activities necessary for USI:C to implement this phased - Complete. transititm are described in this Ctunpliance Plan. USEC is currently T' des ch> ping addititmal detailed plans and schetiules to implement the phased transition. Consistent with ROA requirements 3.2.2.2,3.3.2.6, anal - 3 4.2.3, IX)E will review all proposed changes th>m OSRs to 1 SRs, and USEC u til not implement any such changes without the consent and written approval of the IX)E Regulatory oversight Manager. CPI-POA-001.02 Transition In the interest of assuring a safe, snumth transition Imm DOE to NRC Complete regulattwy authierity, including a safe transitiam lhwn OSRs to TSRs, USI:C will keep the Doli Regulatory oversight Manager and the NRC j fully informed a>I USliC plans, schedules. and the status of actis itles to impleinent the phased transitism.~1 he informatism USI:C will proside will include detailed tasks, schedules, and milesttmes for completing the transition; identification of areas requiring interface reviews and the - schedules for pet funning such resiew; and the schedules for procedure des clopment, personnel training, and operathmal readiness evaluatisms. I xcept as identified in this Compliance l'hm. all activities required to .. i ctwnplete the transition from cannpliance with IM)t? requirements to NRC regulatiims will be completed by the daic NRC assumes regulatory authority.1he transition to NRC regulatory mersight is scheduled to ( occur 120 days aller the NMSS Directos's decisiam regarding USEC's certificalitm. f CPI-POA-Col.03 Transition 1he listinE of open USEC commitments to DOE will be provided to NRC Compfese by USEC on the date that NRC assumes regulatory authority for PGDP 02 CPI-POA-002.01 2/15S7 1he approsed IX)E site-wide Safety Analysis Report and supporting Complete documentatiam uilt then be ftwuerded to Ust-:C by I chruary 15,199L a CPI-POA-C02.02 4/IN7 USI.C uilt proside inftsmatism required to complete the DOE site-wide Complete Safety Analysis Report and will provide technical reviews of the ongoing j analyses to ensure that the analyses accurately reticct the facility - configuration. Enclosure I, l' age i rf30 i
i . FACII.lTY ISSUE # TASK II)
- IDUE IDATE CO3thilI3tENTIDESCitlPilON.
' SI'ATUS -.7._ =.~
- =-
-gg ; PGDP- '02 CPI-POA-C02 03a 8/17S 7 Ily no later than August 17.1997, UNI'C shall submit an amendment to Consplete. CAR requested delay to 10f3IS7 - ti- ' Wincation Application which includes: a) VNiication of all informatism, findings, and recommendations which indicate differences between the DOE site-wide Safcty Analysis Report and the U$lic Application for Certification. l CPI DOA-002.03b 8/27/97 fly no later than August 17,1997 USEC shall submit an amendment to Complete CAR requested delay to 10/3 tM7 ' I their Certification Application uhich includes: - an evaluation of the effects of those di!Terences on the safety of 5 workers, ankl o!T-site members of the public. e CPI-POA-002.03c 8/17/97 - Ily no later than August 17,1997, USEC shall submit an amendment to Complete CAR requested delay to 10/3IS7 - their Certification Application which includes: -proposed nwnfifications to the compliance certificate and/or facility, -1 't including proposed nwxtifications to the Application SAR and TSRs. CPI-POA-C02.04 8/17/97 At the same time the Application amendment is due USEC shall also Complete CAR requested delay to 10/31/97 submit ihr NRC approval, its proposed resolution of matters contained in the IX)li-approved site-uide Safety Analysis Repost not incorporated by I USI'C in its sequest for amendment of their Application Ibr Certification. t CPI-POAkO2.05a 8/87/97 l' rom September 30,1995, until NRC approves the sulunitials in Consplete paragraphs 3 and 4 above, changes made by llSEC in accordance with IX )li's ROA requirement concerning t herevicued Safety Questitm I ' Ikierminations (tISQlls) or with 10 CI R 76 68 ruust be addressed either in the iM)li NAR Upgrade results or in the amended salcty analysis report i submitted by USI C based upon those results. The Ibikming will assure such changes swe property considered and addressed. 5 1he plant configuration was considered to be fruren for the purpose of e IX)E's analysis on September 30,1995. i i h i l '. Page 2 of3t) L
IcACII.Il V ISSUE # T ASt< ID DUE DATE CO%I%Ill!tIENT DESCitirllON STA1 ifs - =. _ ~ _ _, _ _ - - - _- _ = =.== .-.=.;..;-= PGDP 02 CPI-POA-C02.05b R/17N7 i rom September 30. l'NS, until NRC approves the submittals in Complete CAR requested delay to 10/3187 paragraphs 3 and 4 abme. changes made by USI.C in accordance uith IX)l?s ROA requirement concerning iImesicued Safety (Juestion iktenain:uions (US(JDs) or uith 10 Cl R 76 68 must be addressed either in the IX)li SAR Upgrade results or in the amended safety analysis report submitted by UsliC based upon those results. The following will assure such changes are properly considered and addressed: - Changes made to the plants after September 30.1995, will be addressed by USI:C in its amendment Application. The amendment Application will reflect the plant as it exists 6 months before the amendnwnt submittal. CPI-POA-002.05c 8/l7M7 l' rom September 30,1995, until NRC approves the submittals in Complete CAR requested delay to 10/3187 paragraphs 3 aml 4 above, changes made by USI:C in accordance with IX)lfs ROA requirenwnt conceming iinres iewed Safety Question Determinations (llS(JDs) or with 10 Cl R 76.6M must be addressed either in the IM)l? SAR llPFrade results or in the amended safety analy sis repint j submitted by USFC based upon those results. The following uill assure such changes are property considered and addsessed. - Once the amendment is submitted. USl?C will inform NRC of changes that are made in acctwdance with 10 Cl R 76.68 that could render the amendment to be incorrect. inaccurate, or incomplete until the amendment is approved by NRC. CPI-POA-C02.05d 8/l7N7 From September 30.1995, until NRC approves the submittals in Complete CAR requested delay to 10/3187 l paragraphs 3 aml 4 above, changes made by USI'C in accordance with IX)l?s ROA requirement etmeerning Unreviewed Safety Question Determinations (IISt)Ds) <w with 30 Cl R 76 68 must be addressed either in the IM pli S Alt t fpgrade results or in the anwr.ied safety analysis repsut submitted by USl!C based upon those results. I he following will assure sus h changes sie properly considered and addressed. - NRC is notitied of changes made in accordance uith 10 CI'R 76 68 as part of the annual Application for renewal required by 10 CFR 76.36. CPI-POA-C02.06 8/17M7 1 he update to the Application S AR will also reflect those commitments Complete CAR requested delay to 10/3 t N7 made by USl?C to the NRC during the initial certification Application process as identified in the Application and the responses to NRC questions /conunents. Enclosure !. Page 3 of30 f . _ = - _ _. _ -.. _,
FACII.IW ISSilE # TASK II) 11UE IIVI E CO\\l%IITMENT llESCRIrllON STATt!S - Nil)P 03 CPI-NIA-CO3 Ola 9/30N6 lix C-UlA and C-317A autoclase camtainment systems will be (losed Hktelitictl by installing three inanttaI actuation des ices, tme at the Oh!R dinw, one at the crane bay exit near the local cylinder yard, and eme in tic ALR u hit-h can be used to place the aututlases into ctmtainment upon etmfirmation of a UI 6 release. 1 he scheduled completion date for these actions (with the exception of NRC a; pan al of the associated 1SR) is September 30,19%. CPI-POA-CO3.Olb 10/31N6 The C-333A and C-337A autoclave containment systems uilt be Closed nuxlitied by installing three manual push buttons one at the OMR door, one at the crane bay exit near the local cylinder yard and one in the ACR u hich can be used to place the autoclaves into containment upon continnation of a UI'6 release.1he scheduled date fbr submittal of the 1SR to the NRC is October 31,1996. CPI-POA-C03.02 3/3N7 lhe control logie ihr the C-333A and C-337A Autoclave Iligh-Pressure Complete l Isolation System will be nuxlified such that upon reset of the containment signal, the valves will remain closed, but the valves can be opened by subsequent operator action CPI-POA-C03.03 8/31N7 1 he pressure transmitters for the autoclave opening prevention and Complete cy linder ro!! interlocl6 systems in C-360 will be replaced. CP!-POA-C03 04 10/3tN7 The pressure monitoring instrumentation xtsing the autoclave safety Complete I systems and defense-in-depth systems for C-333 A, C-337A, and C-360 autoclaves will be replaced. CPI-N)A-C03.05 8/31N7 The 111'6 detection systems for Zones I and 4 will be modified sirh that Complete upon detection of a I!F6 release, multiple valves (FV *50, *52, a..d *47 from Zone I and I V *47 and *49 from Zone 4) will be closed on the transfer and/or sampling piping. CPI-POA-C03.06 12/3tN6 Perfiumance criteria and a test plan will be des chped to demonstrate Complete whether the nitrogen backup can close the cylinder valve in 30 seconds in C-3 t o, C-315, ami C-360. Further design requirements will be completed pending the outcome of this testing. CPI-POA-CO3.07 10/3 tN7 Add a low instrument air pressure switch to the autoclaves in C-360 to Complete NRC granted CAR request to delay initiate comtainment upon loss of instrttment air. to 10/31N7 Duclosure 1, Page 4 of30 t ~.
.-----3 FACII.IlY ISSttE O TASK 18) Di1E I)NI E COM %Ill3 TENT lil5CillP'llON STNillS - u. = :: _...a w. ;. : - _ . = --. IUDP 03 CPI-POA-003.08 10/31N7 hiodify the centrols for the autoclaves in C-360 to prevent them from Ceneplete twing inadvertently opened w hen an Autoclave liigh-Pressure Isolation System camtainment signal is present. CPI lHA-C03.09 12/31N6 A code interpretation from the ASNIE Code Committee will be obtained (1nsed regarding the C-360 parent-daughter transfer system and the need for pressure reliefen the transfer manifWd. Itased on this interpretation the need for modiGcations to the system or operations will be assessed. Both the ASMii Code interpretation and the assessment results will be submitted to NRC fin review and appros al. CPI-POA-CO3. loa 12/3tN6 hiodincations to allow a pressure decay test to be perfomed separately for Complete the inner and outer containment valves and assurance that backpressure does not mask lesLs, for att autoclaves in C-333A, C-337A, and C-360 will be complete by December 31,1996 1 CPI-POA-CO3.10b 12/3 tN6 A revised TSR to reDect the new l inner and outer containnent valse Closed testing) connguration will be submitted to NRC by I)ecember 31,19%. 04 CPI-POA-C04.01 a 9/30N6 1he chial hoist /irolley and control systems on the Fast and West C-360 Close loll Iransfer and Sampling l'acility twidge cianes uill be replaced with a single polar hoist / trolley and control 53 stem consistent uich the other PGDP crancs that handle liquid Ill:6 cylinders. 't he schedule for - completion of the upgrade for the east bridge crane is September 30, ( 1996. CPI-POA-0010lb 9/30N6 1he dual hoist / trolley and control systems on the I ast.ind West C-360 Clnsed Toll 'I ransfer and Sampling l'acility bridge cr c-s uM be replaced uith a single polar hoist / trolley and control system consistent with the other PGDP cranes that handle liquid Ul~6 cylinders.1 he schedule for completion of the upgrade for the ucst bridge crane is September 30, 1996. 05 CPI-POA-C05.01 I2/2N6 All operatisms with >2 ut % 235U and all other new operations that Closed require NCS approval will have properly documented and implemented NCSAs and NCSlis that have been approved in accordince with the NCS program requirements contained in the approsed Certifwate prior to staitup. Enclosure I, l' age 5 of30 0
M__..._._._.__m ~...,. - - _ u __ _ FACil.ITY ISSITE # TASK ID - DOE DA1 E CO%I%llTMENI' DESCitli'I'lON STA1U5 __ runt :
- 1...
IUDP - US CPI-POA-COS 02 _ 12/N liw esisting i perationis with I wt % rv higher 23511 and f 5 grams or . (losed. nuwe 2351i uhere formal documentation is incompletc or imavailable, Ilst C will prepare the necessary NCSE ami NCSA documentation, appmve it in accordance with the NCS program requirements contained in the appms ed Certificate, prm ide infiermation flow-down to operating procedures and n ork-site postings, and verify implementation of the [ procedures and postings. CPI-POA-C05.03 10/31/96' ~ The procedural changes to resolve the administrative noncompliances in Closed - the nucicar criticality safety program will be completed by October 31, 1996. CPI-POA-005.04 Transition All aspects of Technical Safety Requirement 3.9 implementation and its Complete i associated tentacles for NCS will be in place no later than the transition to NRC regulatory mersight. 1 06 CPI-POA-C06.01 12/2/96 The Compliance Assessment Team was established in March 1995 to Complete verify the 11ow-down of the requirements from each existing NCSA. Their surseillance plan u as completed in June 1995. Ihc field verification (of the roughly 300 procedures and 200 postings) uill be completed and documented by Decemhe 7,1996. 07 CPI-POA-C07.01 I/31/96 Criticality accident alarm s) stems will be instatied in lluildings C.720 Closed See GDP-0172,dtd August 15,1996 and C-728, or all components containing uranium enriched to >l ut % - l 2350 will be removed from the unalarmed areas. I 08 CPI-POA-CJ8.01 2/29/96 Analyses that pmvide the technical justification for not providing Closed Analyses that provide the technical criticality accident alarm system coverage in designared areas of the plant justification for not providing l were developed.1he analyses has e been submitted to NRC tmder criticality accident alami system separate cmcr from the application.1 he analyses include (I) verification cmerage in designated areas of the - of the adequacy of the existing criticality accident alarm system and its plant were descloped. The analyses detector kications for detecting a criticality accident aml(2) justification hase been submitted to the NRC l that detectors are not required for monitoring other areas of the plant. under separate cover from the Application. See GDP-0172, did August 15,1996. f CPI-POA-C08.02 6/30/98 Permanent criticality accident alarm detector clusters will be installed, Cosaplete - See GDP-0130 and GDP-0055. rehicated, and/or recomlitioned in lluilding C-710 to replace the existing f portable detectors in lluilding C-7 to. r i Enclosure I, l' age 6 of30 t i# 9
q FACILIlY ' ISSOE # 'TASKID Dt!E DATE Ont%IITMENT DESCRIPllON '..w-- -. -... -. ~ .-..o- ,.-~_,..r---...-.-.m. m.y.-~.. STATUS -.. m.., r -': n n _ _- c.u:
- ru__ -
MIDP 09 - Cri-M)A-C09.01 ' 10/24N5 ' The required pmcedure changes will be inglenwnted. . Closed CPI-M)A-C09.02 ~ 10/IM6. Plant procedures uill be issued by October I,1996, to incorporate the Closed annual radiatam protection program revsew requirement from SAR 5 paragraph 5.3.1.3. 10 CPI-POA-C10.01 Transition lluilding work areas previmisty posted as " Regulated Areas" will be re-Complete posted to tellect the current
- Restricted Area" and " Contamination Control Zone
- designations prior to NRC assuming regulatory oversight of PGDP.
CPI-N)A-C10.02 12/3 tN6 Restricted areas uithin USEC leased space which contain tmlabeled, but O osed potentially radioactis e, material containers will be posted with signs stating that each unlabeled container may contain radioactive material. CPI-M)A-CIO.03 II/3067 Necessary radiological characterization and re-posting ofleased areas Consplete within the PGDP site boundary will be completed by November 30,1997. Il CPI-POA-Ci 1.0I 10/31M5 Replacement sources that meet the *5% with NIST traceability standard Closed will be requisitioned. CPI-POA-fi t.02 $/3N7 Within 12 months of receipt of the 15% sources, all alTected instruments Closed will be recalituated using the new standards, I f 12 CPI-POA-Cl2.01 10/24 S 5 USEC uill provide NVLAP-accredited dosimetry for those relatively few Closed individuals who are required to be monitored undet 10 CI R 20.1502. 13 CPI-M)A-Cl3.01 g/31M6 'lhe Nuclear Safcty tipgrade project provides for an upgrade of the fire Closed l alarm system to enhance the overall reliability of the system.1he project 6 includes scheduling, equipment procurement, installation, system testing, and personnel training. I I4 CPI-POA C14.01 1I/22N6 A Nuclear Safcty Upgrade project prosides for refurbishnent of two of Closed the electric the water paunps. ~lhese two pinnps are in excess of 30 years old. 'Ihis project includes scheduling, equipment procurement, installation, and system testing. f i I L Enclosure I, Page 7 of30 [ t 5 a_ - -._ _ _ - _ _ _ __,
-.__y FACII.IIT ISStiE # TASK ID Dif E DATE CO%I%III hlENT DESCillPllON STA10S
- = = = =:-====-:==-
~- z : :=====:=== ::= '. ---.-T.=z_
- r==.n = = - -- - =.=7 7--
PGDP 14 CPI-POA-Cl4.02 3/3 tN7 A Nuclear Safety lipgrade pniect pnnides for the reconfiguration of the Complete fire w ater supply piping to Ituilding C-315. The fixed autwtatic fire sopprenion sptems covering those areas of fluilding C-315 in which Q systems are located will be supplied hom the llPi-WS. Ihis project includes scheduling, equipment procurement, installati m. and sptem testing. 15 CPI-POA-C15.01 12/31N5 T he manual equipment needs and locations will be identified by the Closed Authority liasing Jurisdiction, and a plan will be developed and impicmented to purchase and install the equipment. 16 CPI-POA-C16 01 Also see issue 27 The fire protectii n procedure review and upgrade program is in Closed 1 he procedure upgrades and implementation. I ire pndection procedures, including cach of the associated training required to identified procedures, are being created or resised as part of that program address this area of noncompliance to ensure that the level of technical and precess control detail will be will be completed in accordance sullicient to ensure commitment compliance. Incept for procedure UE2-with the plan of action and schedule $%I S1031. I ire Protection Requirements for Welding. Durning, and ohhc Compliance Plan laue 27, llotwo:L Practices, the fire protection procedoies identified almve for " Procedures Progrant" upgrade and specifically related to the application commitments will be upgraded and impicmented. CPI-POA-C16 02 12/3 tN6 Procedure UE2 SS-I S1031 uilt be revised and implernented by Closed The procedure upgrades and December 31.1996. associated training required to adJress this ares of noncompliance will be completed in accordance with the plan of action and schedule g of the Compliance Plan Issue 27,
- Procedures Program.*
CPI-POA-Cl6.03 6/l/97 1 hose fire protection procedures identified for uPFrade and not di:ectly Complete The procedure upgrades and related to the couunitments identified in the application will be upgraded. associated training required to addrcss this area of noncompliance uill be completed in accordance with the plan of action and schedule of the Compliance Plan issue 27, " Procedures Program." 17 CPI-POA-C17.01 12/3 tN6 1he pre-fire plans will be updated to reflect current facility G used camfigurations and conditions. Drciosure 1. Page 8 sf30
_~ FACll.1I Y ISSUE # TASKIll til1E 1111 E CO%I A18'l AlENT IDEM:RIPIION S l'A I IIS ~. ~ PGI)P 17 CPI-lUA-Cl7.02 M3W97 An niulysis will be conductcal to descimine the matinuun allowable Complete combustible loadings within tlic twocess benidings. line asialysis will imlenti: descaminasi.m of the esisting cmuhustible hia tings of scletted specilic occupancy areas within the process buildings and the verification of the ability of the sprinklers to control these specilic occupancy areas. Some local occupancy areas to be considered include burnable " Anti-C" n aste storage. lube oil in process reser es, waste storage, maintenance shops, and stoses. lluilding custodians will be prmided information and training to recognize the acceptable les cis of comimstible loading in the process buildings. both in general and in hical areas.1 his combustible loading analysis is scheduled to be completed by June 30,1997. 18 CPI-POA-Cl8.01 4/30/96 Upon approval of the Packaging and Trat'sportatim Quality Assurance Closed Pian and acceptance of USEC as holder of the NRC certificate of compliance for the Paducah Tiger m crpack. USliC uill begin shipment under the NRC certificate of compliance. I 19 CPI-l'OA-CI9.01 See issue 27 QAP and Regulatory Requirements flowdown -Quality Assurance Complete Program requirements and applicable NRC requirements will be llowed down to policies and procedures that will be apprm ed and implenwnted at tISI'C lleadquarters and P(iDP in acciwdance with the Plan of Action and Schedule described in issue 27,
- Procedure Piogrant*
CP!-POA CI9 02a Transition Organizational Roles, Responsibilities, Relationships, and Authorities Complete floudown: I - lhe fl mdown to committed position descriptkms provided in Section 6 I of the USI.C Applicatkm will be completed and position descriptions revised, if necessary, by the date that NRC assumes regulatory auttuwity. CPI-POA-C19.02b 12/31/97 Organizational Roles, Responsibihties, Relationships, and Authorities Compiere Fiondown: - The position descriptions will again be reviewed and revised, if necessary, by December 31,1997. 20 CPI-POA-C20 01 Transition A charter for the PORC is in place; however, it requires res ision to ensure Complete cimsistency with commitments made in the NRC-apprmed Safety Anal) sis Repor Section 6 2 aml'lc(hnical Safety Requirement 3.10.1his enicw and the charter upgrade uill be completed and implemented by the date that NitC asstunes regulatoiy authority. Enclosure I, Page 9 of 30
FACil.IIT ISSI'E # TASK ill Illf E llATE Coil 3til hlENT ilESCRIPilON STAllis NiDP 21 CPI-IM-C21.01 a 12/3 tM6 Identify and document all Q items and AQ-NCS items, including system C!osed The scheduled completion dates kw boundaries and support systems required for per formance of the intended these acthms are Ikeember 31, safety function. to be included in the scope of the Configuration 1996, for Q and AQ-NCS items and blanagement Program. October I,1997 for other AQ items. CPI-POA-C21 Olb Transition Ikvelop tie flowdown ofcommitments from the Technical Safety Complete - The scheduled completion date for Requirements the Safety Analysis Report, and other plans and programs this action is in accordance with the to procedures and training. Plan of Action and Schedade provided in the Compliance Plan Issue 27,' Procedures Program." CPI-POA-C21 Ole Transition incorporate new Technical Safety Requirements into the surveillance Complete The procedure development and the testing and administratisc procedures. associated training required to resolv- *- - tem will be com + scording to the plan of e action + /xhedule provided in the Ciluptia n Manissue entitled %ocedures Program." CPI-POA-C21.Old 10/1/97 Identify and docmnent all other AQ items, including system Imundaries Complete The scheduled completion dates for and support sy stems required for perfonnance of the intended safety these actions are December 31, fimction, to be included in the scope of the Configuration klanagement 19%, for Q and AQ-NCS items and Progrant October I,1997 for other AQ items. CPI-POAI21.02a 12/31/96 Develop the baseline docmnentation that establishes the design Closed requirements for all Q systems / items, including support systems required fi>r performance of tie intended safety function. CPI-POA-C21.02b 12/31/96 Revicw all Nuclear Criticality Saf:ty Approvals and Nuclear Criticality Closed Safety Evaluations to identify AQ-NCS items litems which support tir nuclear criticality doubic conting-ncy principle). to identify and document the t esignated design requirements and syston tmundaries, i inchiding support systems required for performance of the intended safety lunction; and to s crify the implementathm of ttese requirements. To the extent cunpleted. this information will be maintained and made available to the NRC, befinre regulatory jurisdictkm, for planned inspecthm activities.. Page 10 of30
' FACILI1T ISSitE# TASKID ' Dt!E DAIE COM%IllMENT DESCRIPI'lON STATtIS - ~:=~=~~==-~z".N======-.----.-n-=:=?.m=========--,.__.- -_.,-_:==w. - ~~~: - :: _ _._ 10DP 21 CPI-POA-C2102c 10/IN7 ' identiry, document and cornimmicate dclinitise boundaries for the other Complete.. . AQ systems. Identify and documcut the design requirements for these AQ - s3 stems / items, including support systems required for performance of the required safety functi:m, for which the design requirements must be Lrum n. CPI-POA C21.03a Also see issue 26 Develop improved records management and document control programs Closed The program and procedure to satisfy the needs of the Configuration Management Program. Develop . development and associated s and impicment the required procedures. training required to resolve this - .. noncompliance will be completed according to the plan of action and - schedule provided in the Compliance Plan issue 26," Records Management and Document Control Programs? .. ~ ' CPI-POA-C21.03b Also see issue 26 ~ Train appropriate plant personnel in the requirements of these programs Closed '. T$c program and procedure and procedures. development and associated taaining required to resolve this noncompliance will be completed according to the plan of action and schedule provided in the Compliance Plan Issue 26," Records ' Management and Document Control Progtams? - CPI-POA 21.04a 6/30M6 tipgrade the four core engineering procedures that specify the Closed requiiements for the change control process to ensure the identification, tecimical and sarcty review, appros at, implementation, validation, documentation, and recording of plant changes. 4 cpi-POA-C21.04b 6/30M6 Train appropriate personnel to ensure proper implementation and Closed - application of these upgraded core procedures. I i CPI-IUA-('2 I.04c 3/3IN7 Des clop or upgrade remaining engineering procedures that are associated Complete with the change control process and train appropriate personnel on these new or upgraded procedures. I t & closure I, l' age 11 of30 I
e .m m' -.--m . FACILITY ISSI!E # ' TASKID'
- htfE IMTE COMIhllDIENT I ESCitlPTION STATUS 7
-__3--.- -,g _.37.. _ :.2L.- y .--.-.3- - z = = y --.. -,...; -. 53 -. 7...- L. 3 PGDP: 21: CPI-POA-C21.05a - ' Also see issue 27. - Ikvelop procedures reytdred to implement an assessment pmgram to Comeplete. . 'Ihe procedure derchipenent and the
- systematically esaluate the development and clTective implementation of -
E associated training required to - 7 the Configuration Management Program elements ami telated processes. ' resolve this area of-- ~ noncompliance will be completed. according to the plan of action and schedule provided in the Compliance Plan issue 27. -
- Procedures Program?
t e CPI-POA-C21.05b Also see Issue 27. Train appnyriate personnel to ensure proper implementatiott and Complete. De procedure devchipment and the application of these procedures. associated training required to I, ' resolve this area of [ se _-----. M --- + will be completed according to the plan of action and schedule psovided in the Compliance Plan Issue 27, [ ' " Procedures Program." \\' r CPI-POA-C21.06 Also see issue 24 Implement a training program fier plant personnel relied upon to operate, Complete De training program - . maintain, or nuxlify the plant. Include initial training on improved or implementation and the training -[ newly devchyed psogra ns and procedures identified as required to _ required to resolve this area of support the Configuration Mmagement Program objectives. noncompliance will be completed according to the pfan of action and l schedule of the Cornpiiance Plan Issue 24," Systems Approach to Training." - j 'I 22 CPI-POA-C22.01 9/30/97 Develop and implement a maintenance history and trend analysis Complete i r i program. i-t t - Devchy a master equipment list for equipment critical to facility safety and productism critical equipment. 7 - listablish infonnation flow for corrective aiul preventive maintenance 5 by documenting "as-found* conditions and field activities. - Peelierm data tremling and presentive maintenance clicctiveness analysis through the use of system engineering tasking.. CPI-POA-C22.02 7/31/96 Ikvchy guidance for cleanliness control and measures to prevent entry Closed l ofesiraneous material into a closed system. { i r _.. l' age 12 of 30
- f
FACII.llT ISSUE # TANK ID DilE llATE COPlall I 511'N I' llEM:ltf r ilON S I A ll!S -_-....u-PGDP 22 CPI-LOA-C22 03a 128IN6 l'or AQ-NCS items: Ifpgrade the current maintenance work control Closed process to prmide the commitTd level of planning and wtuk package - development for t). AQ-NCS, and other AQ items. - Inevclop wiwL package specifications. - Iks clop guidance for integration of conGguration management. - Define and implement Q, AQ-NCS, anti other AQ item identification and control within the maintenance program. - Initiate revised work control perfoimance indicators. - Develop wurk control metluxiologies such as muik flow anal) sis, problem anal sis, and 3 implementatiim of corrective actions. - Prm ide training for planners, supers isors, managers. maintenance personnel, and all other perstumel involved in requesting or performing services. - Procure and implement a computerlied maintenance management system. 1 CI1-POA-C22.03b 480/97 I or Q items: tipgrade the current maintenance work control process to Complete provide the ctmunitted level of planning and work package development for Q, AQ-NCS, and other AQ items. - Develop work package specifications. - Ibclop guidance for integr( *n of configuration management. - Define and implement Q, AQ-NCS, and other AQ item identification and control within the maintenance program. [ - Initiate revised work control perfomiance indicators. - Desclop work control methodologies such as wesk flow analysis, problem analysis and implementation of corrective actions. - Provide training for planners, supervisors, managers, maintenance personnel, and all otler personnel imotved in requesting or perlimning services. - Pmcure and implement a computerized maintenance management sy stem. ., Page 13 of30 l
l'ACil.l W ISSUE # TASlslD DttE IWI E CO\\l%Ill MENT DESCitiPIlON STATUS 14iDP 22 CPI-lUA-C22.03c 6/30N8 l'or other AQ items: lipgrade the current maintenance work control Consplete process to provide the committed level of planning and umL package desclopment for Q AQ-NCS,and other AQ items. - Ikschip umL pacLage specificathms. - Ikschip guidance for integration of configuration management. - Ikline and implement Q, AQ-NCS, and other AQ item identification and contrul within the maintenance program. - Initiate revised work control performance indicators. - Ikvelop wmL control niethodologies such as work flow anal) sis, problem anal) sis, and implemen ation of coriective actions. s - Provide training for planners, supervisors, managers, maintenance personnel. and all other personnel involved in requesting or perliwming services. - Pmcure and implement a computerized maintenance management system. CPI-pOA-C22.04a 12/31N6 l'or AQ-NCS SSCs: Itevise the measuring and test equipment and Closed j process equipment calibration programs. - Identify all measuring and test equipment. - Track the ir.e of calibratism standards and verify that all measuring and test equipment uwd for the calibaation of t). AQ-NCS. and other AQ items is cimtrolled and traceable to national standards. - Ikvelop amt implement pmeedures that define and control the overall nwasuring and test equipment program. - Develop and implement hidividual calibration procedures for Q. AQ- [ NCS, and other AQ kl& fli - Provide training on calibration requirements to alTected coordinators, supertisors, managers, tecimicians, and users. CPI-POA-C22.04b 3/3tN7 I or Q SSCs: Itevise the measuring and test equipment and process Complete equipment calibratism programs. - Identify all measuring and test equipment. - Track the use of calibration standards and verify that all measuring and test equipment used for the calibrathm of Q. At)-NCS, and other AQ items is controlled and traceable to national standards. - Ikvclop and impicment pmcedures that deline and control the overall measuring and test equipment program. - Ikscicp amt implement indisidual calibratism procedures for Q, AQ-NCS, und other AQ hla 1IL - Provide training on calibrathm requirements to alTected coordinators, supen isors, uusiagers, technicians, and users. Enclosure I, Page 14 of 30 e ..... r .m m
__m FACILilY ISSUE # TASK ID IlUE I) ATE CO3thilThlENT DESCRIPl!ON STATt!S pGI)P 22 CI'l-N)A-C22.0lc 6/30N8 l'or seher At) SSCs: Revise the neasuring and test equipment and Complete process equipnwnt calibration programs. - Identify all measuring and test equipment - Track the use ofcalibration standards and s crify that all measuring and test equipment used for the calibration of Q, AQ-NCS, and other AQ items is controlled and traceable to national standards. - 1)evelop and implement procedures that define and control the oserall measuring and test equipment prugram. - lievelop and implement individual calibtation procedures for Q, AQ-NCS, and other AQ ht&1 E. - Pmside training on calibration requirements to affected coordinattws, supen isors, managers, technicians, and users. CPI-N)A-C22.05a 12/3 tN6 for AQ-NCS SSCs: Identify the procedural deficiencies for performing Closed corrective maintenance, preventive maintenance, equipment calibration, or sun cillance testing lbr Q, AQ-NCS, and other - AQ SSCs and develop a composite listing of the procedures requiring j res ision, development, or conversion. CPI-M)A-C22.05b 3/3IN7 for Q SSCs Identify ihe procedural deliciencies for performing Complete correctis e maintenance, presentive maintenance, equipment calibration-or surveillance testing for Q. AQ-NCS, and other AQ SSCs and develop a composite listing of the procedures requiring res ision, development, or cons ersion. CPI-N>A '22.05c W30N8 l'or other AQ: Identify the procedural deficiencies liv performing Complete corrective maintenance, prevetnis e maintenance, equipment calibration, or surveillance testing for Q, AQ-NCS, and other AQ SSCs and develop a cmnposite listing of the procedures requiring revision, development, or conversiort CPI-M)A-C22.06 Transition lies clop procedures and provide the associated training of appropriate Complete personnel for the performance of suncillance tests which are required to support Technical Safety Requirements. CPI-POA-C22.07a 12/3IN6 Ior AQ-NCS SSCs: Revise, des clop, or convert ctwrective maintenance, Closed preventive maintenance, instrument calibration, and surveillance test procedmes for structures, systems, and components. Duclosure 1. Page 13 of30 i
___m f L. L - --g -Q,..y _ %.. __ m- + 7 - _;y y ~ u- _._. . FACRIJIT ISSUE #. TASK ill Di!E D.VI E CO%INillblFNI DESCRIPl~lON SI A llis - F _-._____-.__m PGDP '22 _ CPI-IVA-C22.07b 3/31/97 hw Q SSCs: Revise. develop, or consett corrective maintenance, Complete i preventive maintenance, instrument calitwation, and surveillance test piocedures for structures, systerns, and components.. I CPI-POA-C22.07c. 6/30N8 For other AQ SSCs: Revise, develop,or convert corrective maintenance, ' Compacte - p presentive maintenance, instrument calibration, and surveillance test pmcedures for structures, systems, and compiments CPI-POA-C22.08a 12/3tM6 l'or AQ-NCS SSCs: Develop training materials for the work control.. Closed ' surseillance testing, instrument calibration, and corrective and preventive maintenance procedures and provide the associated training of ' argwopslate personnel. i l CPI-POA-C22.08b ' 3/3 tM7 l'or Q SSCs: Iksetop training materials for the work control,' Complete surveillance testing, instrument calibration, and corrective and preventive j. maintenance procedures and provide the associated training of appropriate personnel. i CPI-l'OA-C22.08e 6/30S8 for other AQ SSCs: Develop training materials for the work control, Complete surveillance testing, instrument calibration, and corrective and preventive - maintenance pmcedures and provide the associated training of. appropriate personnel, C CPI POAk'22.09 3/3tM7 Identify and control the vendors' manuals used for maintenance of Q. Complete equipment, including entering them into the document control and [ records management system. [ t f 23 CPI-POA4'23.01 ' 12/31M7 Procedures addressing the operations program elements discussed in Compicte f Section 6.5 of the Safety Analysis Report uill be developed or revised, associated initial training materials will be des eloped, and appropiiate t personnel uill receise initial training by Ikccmber 31,1997, consistent with the plan of action and schedule of the Compliance Plan issue 27 [ " Procedures 14ogram." k l i i i r ' Enclosen I, l' age 16 of30
FACILl1T ISSUE # TASKID DUEInlE CO%I%IITMENT 11LSCRIPIION SIXlliS PGDP 23 CPI-POA-C23.02 6/30N7 Continuing training material and qualification requirement development Compicie uill be completed aimi appropriate perstmnet trained and qualified for Cascade Operator. Chemical Operator, Operations Manager /Supersisiv, and Plant Shift Superintendent positions 1*y June 30.1997, consistent with she plan of action and schedule of the Omnpliance 11an issue entitled " Systems Approach to Training? CPI-POA-C23.03 12/3 tN7 Continuing training material and qualification requirement development Complete mit be compleied and appropriate persmmel trained and qualified few Cascade Omwdinator position by Ikccmber 31,1997, comistent with the plan of action and schedule of the Compliance Plan issue entitled " Systems Approach to Training? 24 CPI-POA-C24 01 6/30M7 1 raining programs will be developed and implemented based upon a Complete sy stems npivoach to training for wmkers who are relied upon to operate, maintain. or nmdify structures, systems, and components identined as Q or AQ-NCS items. I'or almse job classincations initially identified under I the Nuclear Safety lipgrade Proicct (as listed in lkscription of Noncompliance). training kw the job incumbents will be completed by June 30,1997. CPI-POA-C24.02 6/27N6 A detailed schedule for the completion of all training pmgrams not in Closed compliance with 10 Cl R 76.95 will be issued by 6/27N6. CPI-POA-{24.03 600N7 l'or the additional job classiGcations not pecsiously includ 1 in the Complete Nuclear Safety L1pgrade Project,(i c systems engineers,- 4scade coordinators, and NCS engineers /specialistsk the job analyses and training pmgram design have not been completed. 'I he following actions will be completed by June 30,1997. - kesise and validate the existing job task lists. - Iksign a curriculum that covers the job tasks selected for training. - Iksclop specific learning objectives from thejob perfiwmance requiseraents. - Ikve' *p training materials. CPI-POA-C24.04 12/31N7 Training ihr those holding these adddional job classilications at the time Complete the program is implemented will be cunpleted by Ikccmber 31,1997. l Enclosure !. Page 17 of30
4_ 4 4 4 4 L L ~' - - A S._. ' d 1 - L-- r ______m._._. _ _ _.. - _ - - - _ _ _.. _. x.u. c .a u. FACILIfY ISSUE # TASKlit IMIElaATE - COSl%IITMENT IDESCRIPTION. ' STATUS _..;. 7 _ ;_ ;... _ . r_ __. 7 m... 1411)P 24 CPI.POAr24.05 6/30N8 - Itaining pmprams for the ahose job classificalituis list. with respect to . Compicte - At) actisitics. will be developed and implemented by June 30 Iws, - following counpletion ofidenlificatism of At) items (see Cannpliance Plan Issue 21," Plant Changes and Configuration htanagenwnt*) and - associated pmcedures (see Cannpliance Plan Issue 27, " Procedures Program")- - 25 cpl IVA-C25.01a - 5/IN6 ' A nuclear regulatory event reporting procedure meeting the event . Closed l notification and reporting requirenwnts required by the llSEC application, and an event investigations procedure that defines the event ' investigation process and assigns responsibilities and authority for its [ implementation uill be approved by May 1,1996. CPI-POA-C25.Olb Transition Training on these documents will be completed prior to the date NRC. Com.plete. assumes regulatory oversight at PGDP. l k CPI-POA-C25.0 t c Transition . 'the procedures will become efTective on the date NRC assumes - Complete regulatory crersight at PGDP. 26 CPI-POA-C26.0 t a I 6/30N6 " Records being maintained by the plant organizatisms and the D&R Group ' Closed. uill be verified to determine the storage locatisms of these records and i the methmis of protection being emplo)ed to prescrs e these docunwnts. { i CPI-POA '26.0ta.2 6/30S6 1 he final tally of records' identified in item (1) above will be evaluated Closed against applicable requirements and then catalogued as to tlwir record i ) pe, categtuization, and retention. This information will he chwacterized in a combined IURTS and PGDP Uranium I?nrichment Records Manual that will be utilized by both sites. floth the tally of records and the l manual will be completed by June 30,1996. [ CPI-IVA-C26.0la.3 6/30/96 A records management tumover schedule has been drahed and submitted Closed b to the functional. organisations w hich prioritires the turnover based on the record's [ imptutance to the safety and - quality of plant operations. f P h t i Enclosure i, Page 13 of30 .[ t .2 i...,-_ e
-( ^ ' * ' Mi.. ;_ .y - _, _ _ _ -4h.mNr7T, _ _.. _ _, _, _ _, _ a. J ' ~? _-,,_ Jr~ - .. FACII.lTY ' ISSUE # 1 TASIC 10 - blIE HA1 E. - Ctmimill' MENT DENCitti"Il()N : - STATl"i - PGDP - 26 ~ CPI-tuA-C26.0la.4 : 6 don 8 Records being maintained in the organiiations wil! not he turned over to Consplete : the IM R Group immediately but uill he retained by the responsible
- [
mganization until the D&R Group can process them. Pre-esisting records will be tumed over and incorporated into the records management system - by June 30,19981 CPI-IVA-C26.0la.5 ' 680N6 - A new clectronic records indesing database based on the evaluation. Closed - 4 conducted in item (2) above and item 1.dM I) below will he put into service by June 30,1996. CPI-POA-C26.01b 381M7 Ior I.egacy Records: The PGDP Configuration Management Program Comepicte f i implementation procedures uill address the measures required to be taken. l if source inbrmation needs to be devchmed and docunwnted. Scc issue. 2 I,
- Plant Changes and Configuration Management."
CPI-IVA-C26.01c 600S8 Records hemg mamtamed in the organizatums will he turned over to the - Cosmplete.. f IM R Gnuip in accordance with the records management tumover schedule identified in item (a)(3) almve. Pre-existing records required to be maintained under the IJSI'C Quality Assurance Program will be turned ~ over amt incorporated into the revised records management system in accordance with the approved records management turnover schedule. ARer the turnover of an organization's records to Records Management, the temporary storage of subsequent recua ds will be in ene-hour fire-rated ' file cabinets. t I CPI-IUA-C26.Old.1 60086 The PGDP computerized records indexing system will he evaluated to Closed ) make certain that the necessary information required by each organizatien for its records is consistently applied to ensure the ready - [ I retrievability of the records. i l A r Consplete CPI-POA-C26.01J.2 600/98 Computer codes and test result data used to directly or indirectly support - the ITiDP process systems will be submitted to the IM R Group in accordance u ith the tumover schedule identified in item (aX3) above i i-CPI-IVA-C26.02a.1 60066 Documents being maintained by the plant organizations and the D&R Closed [ Group uill be verilled. ) 'i 1. 3 Declosure f Page 19 of30 f m .m m m m
a L. e - - ~. - z:.- . FACILITY ISSifE # TASK lil IDUE17 ATE - COMallTMENT DESCRIP110N STATUS m ;._ _;_---..= g= MIDP 26 _ CPI-POA-C26 02a.2 6/30/96 A doctanent contml turnover schedule has been tiralled which gwioritires O osed the turraner based on the document's importance to the safety and quality of piant operations. . CPI-POA-C26.02a 3 6/30/96 1 he doctment control system will be updated on an ongoing Isasis to O ased pmvide controlled distribution lists and to control the actual distribution - i - of docimwnts imder the ctmtrol of the D&R Group commencing June 30, 1996. 1 CPI-POA-C26.02a 4 -- ' 6f30/98 Documents within the scope of the document control program, according Comi ete d to the application, will be identined. Documents being maintained in the f organisations will not be turned over to the DA R (inmp but will be retained by the responsible division until the D&R (iroup can pmcess - . them. Prc. esisting dm:uments will be turned mer and hicorporated into ? the document control system by June 30,1998. l \\ CPI-POA-C26.02a.$ 6/30/98 The final tally of documents identified in items (1) and (3) above mill be - Complete catalogued as to their document type, distribution requirements, and information to pro ide an index for case of retrievability.- CPI-POA-C26.02a 6 6/30N6 . The new electronic document control inventory system that identifies the Closed controlled copy holder immber and custodians storage location, and retrieval capability will be put into service. 1 CPI-POA-C26.02b 3/31/97-For I egacy Documents:1he plan of action and schedule provided in 1(b, Complete above will also resolve this item. 27 CPI-POA-C27.08 7/31/96 Dy July 31.1996, incorporate into the Procedure Control Process Closed procedure the SAR-6.I1.4.1 criteria for use by responsible management in complying with 13R 3.9 by identifying applications requiring additional written procedures. l CPI-POA-C27.04 6/1/96 Document the criteria fiw use in determining when work must be stopped Closed i because a procedure cannot be performed as written k ? .. Page 20 of30 ,..._.m.~
FACll.IIT ISSUE # TASK ll1 Dl!E IDATE CO.\\l311TM ENT l>ESCRIPilON STATlis NiDP 27 CPI-POA-C27W 1ransitism Ily the date that the NRC assumes regulatory authority for 14iDP. Clowil incorporate into lle Procedure Con' sol Process procedure the SAR-6.114.5 criteria for identifying procedures that TSR 3.9 requires review by the PORC. cpi-POA-C27.08 Transition incorporate action statements and operating limits from the Technical Complete Safety Requirements into operational procedures by the date that the NRC assuntes regulatory authority for 14iDP. CPI-lM)A-C27.09a 6/28/96 Issue the required operational policy statements and implement new or Closed updated procedures (includir.g required training) to fully implement tic Quality Assertance Program or other actisities identified in the application in accordance with the following schedule: - Operatitmal policy statements: June 28,1996 i l CPI-POA-C27.09b 12/31/96 issue the required operational policy statenents and implement new or Cosuplete updated peocediares (including required training) to fully implement the Quality Assurance Program or other actisities identified in the application in accordance nith the folloning schedule: - I evel 2,3, and 4 AQ-NCS procedures (unless covered by item 8): December 31,1996 CPI-14)At27.09c 3/31M7 Issue the required operational policy statenrnes arul impicnent new or Complete Refer to issue 22 for later updated procedmes (including required eraimngl to fully implenent the Maintenance Program procedure Quality Assurance Program or other activities idemified in the completion dates. application in accordane with the following schedule: - I esel 2,3, and 4 Q precedures (unless covered by item 8): March 31, 1997 CPI-M)A-C27 09J 12/31/97 issue the required operational policy statements and implement new or Complete Refer to issue 22 forlater updated procedures (including required training) to fully implement the Maintenance Program procedure Quality Assurance Program or other actisities identified in the completion dates. application in accordance with tie following schedule: - 1.csel 2,3, and 4 AQ and NS procedures: December 31,1997. Page 21 of30
!i ~ ~k FACll.I'l Y : IS$trE O TASK lis - IH!E IMTE CO%intil%IENT DIXBill'I'lON ~STATl!S . -......,. -~ w.=. .PGDP. - CPI-POA-C27.10 ~ 12/3187 Complete all overdue 1.evel 2,3, and 4 AQ procedure periodic reviews Comptese y by December 31,1997c ~ .t CPI-POA C27.1I. - Transition + 5 years lhe PORC u ill review all prucedures designated as In-Iland and 'i _ procedures that involve liquid UF6 handling actisities uithin a 5-year. period aRet the date that the NRC assumes regulatory authority for PGDP. This commitment pertains only to those procedines which will not - oilstruise he resiewed by the IURC (as required by Section 6.11.4.1), or by a l'URC subconuniuce, bcfore the expiration of the 5-year period l Procedures in this scope have been, and will contimse to be, reticurd by [ a l' ORC subconunittee, thereby satisfy ing this commitment for those specinc procedures. ? I CPI-10A-C27.12 - Transition - All aspects of TSR 3.9 implementation and its associated tentacles shall-Complete be in place no later than the date that the NRC assumes regulatory authority for PGDP, Procedures required by lechnical Safety Requirement 39 I shall be in place by the asstunption of regulatory l auttority by NRC except as specified in the Compiiance Plan. [ i 1 29 CPI-POA-C29.01 12/3tM6 Develop and implement procedures, including personnel training, for the Closed scheduling and conduct ofinternal and supplier audits, including auditing ' the development, maintenance, adequacy, and eiTectiveness of the QAP, p [ by December 31,1996. CPI-POAt29.02a 12/31N6 Develop and implement procedures including personnel training, that Closed define procurement, handling, and storage activities for AQ-NCS items + and services by Ikcember 31,1996. l f CPI-POA-C29.02b 3/31/97 Ikvelop and implement procedures, including personnel training, that Complete denne procurement, handling, and storage actisitics for Q items and services by hlarch 31,1997. 1 I CPI-POA-C29 02c 12/31N7 Det elop and implement procedures, inchafing personmel training, that Complete y define procurement, handling, and storage activities for non *AQ-NCS* items and services by December 31,1997. [ t f F i ( f, l' age 22 of30 '} 4
_.x
- m. = g--
=-_-
- =-
+ FACII.11T ISSUE 8 TASKIll DUElWIE Ct mIMil 815E I'I4.SCitlPllON SI A'IUS L -; c.
- u :
MIDP 30 CPI-POA-C30.01a 1/15/97 lhe three esisting sirens will be replaced with a new siren system to . Closed - cidumcc reliability and ensure better coverage of tie inunediate . mitification area. All rules ami sires.s nill be installed by January 15, s E' 1997. CPI-POA-C30 Olb 3/I5M7 An analysis of the number, capabilities, and coverage of the new sirens Complete will be performed.He new system will be installed and operational by i March 15,1997. 31-CPI-PGA-C31.0I 4/30/97 The esisting public address system, which includes the central public Complete address switching console, speakers, and amplifiers, will be upgraded to provide nune reliable service to the plant ami additional expansion
- {
capabilities.- i 4 I L CPI-POA-C32.01 6/30/96 The emergency plan support documents will be upgraded to include the Closed j. inzandous chemical requirements. i 33 CPI-M)A-C33.01 6/30s6 Updated formal training will be given to emergency response personnel. Closed 4 34 CPI-M)A-C34 DI 10/21N5 A quahty control program including all elements necessary to ensure Gesed compliance with 10 CI R 61.55 and 10 CI R 61.56 mill be implemented. [ t I 35 CPI-POA-C35.0i 12/31M6 Update existing depleted uranium c3 mler handling, moving, and - Closed Ii stacking procedures to current format and content requirements (see the [ compliance plan issue entitled Procedures Program") and provide l V training to alTected personnel. [ ? t i CPI-POA-C35.02 12/3iM6 1ssue pnicedures required to implement the baseline and periodic (i.e., Oesed every four years or less) depleted uranium c3 nder sisual inspections and [ ti punide training to alrected personm-l.1 hese visual inspections mill (1) i cle.k fier evidence of cylinder leaLage;(2) s crify that the eylinders are ~; pnTeily oriented (i.e, valves in top center position); (3) verify that the c3 nders are stacked correctly (i.e., not in contact with portions of l fi adjacent cylinders such that damage might occur);(4) check esternal c3 nder surfaces fi r dents, budges. cracks, tears, gouges, { 1i and excessive scale or rust; aml(5) verify that the cylinder weep hole is [ l not plugged. t i & closure I, Page 23 of30 l I I l
CO. l31tTMENT DESC'ZIPTION FTATUS FACII.ITY ISSUE C TASK D DUE DATE -:= =-... v-._--. --.: 2 - -
== = r- := : -- - - = - -- - NiDP 35 CPI-fUA-C35.03 12/31N6 Develop a process for use in scheduling the periodic visual inspections Closed noted in item 2, almve. CPI-POA-C35.04 12/31/97 For all USrc depleted uranium cylinders that were placed in storage Complete prior to implementation of the documented baseline inspection procedure noted ir, item 2 above, perform a baseline inspection in accordance with that prmrdure. 36 CPI-14)A-C36 GIa 8/30/96 Ilased on a Directive fbr information prmided to USFC by DOE on Closed September 22.1995, the tJSI C evaluation of the currently available - informatim fron: the DOE safety analysis upgrade elkwt related to seismic capabilities at the facility cuenpleted on October 23,1995, the IMil? evaluation of the USEC response dated October 31,1995, and iISI C's proposed resolution documented on January 9.1996, the iblioning actions are twing impicmented to ensore the protection of the workers and public health and safety: 1 - 1Intil the completion of modifications discussed below, operations in fluildings C-331 and C-335 mill be limited to subatmospheric pressure within the enrichment cascade equipment. Cpl-14)A-C36.0lbi 8/30/96 Ilased on a Directive for Information provided to USEC by DOE on Closed September 22,1995, the (JSEC evaluation of the cuncntly as ailable information from the DOE safety anal) sis upgrade ef%ut related to seismic capabilities at the facility completed on October 23,1995, the iM)!! cvaluation of the tISEC response dated October 31,1995, and g USI:C's proposed resolutiisi documented on January 9,1996, tie following actions are being wplemented to ensure the protection of the wo Lers and public nealth and safety- - Operations [ Cascade Coordinators l persmmel will be instructed tm tie specific emergency procedures for shutting (kmn the allected enrichment cascade equipment and building ventilation systems following a seismic event., Page 24 of30
^ FACll.I IT ISSl!E s TASKID 1)UE DAT E CO%l AllulEN T I)ESCRIP'llON STATUS ~
====== =: .: = = 1===z- = - = ===.::== : :
- :. z :==.== _===:_. _.
- = - .:. =-- PGDP 36 CPI-POA-C36.Olb2 12/31/96 Itased on a Directive for Infonnation prosided to USFC by IM)E on G ased September 22.1995, the USI:C esatuation of the currently available infonnathm fann the DOE safety anal sis upgrade cfTort related to 3 scismic capabilities at the facility completed mi October 23,1995, the IMIE esaluatien of the tISI!C respmse dated October 31,1995, and USl C~s proposed resolution documented on January 9.1996, the foltoning actions are being impicmented to ensure the protection of tie uurLess and public health and rafety: - Operations IPSS Group] persomwl uill be instructed on the specific emergency procedures for shutting skwn the aticcted enrichment eascaJe equipment and building sentilation systems following a seismic event. CPI-POA-C36.01e 8/30N6 Itased on a Directis e for Infonnation pros ided to llSI:C by DOli on Closed September 22,1995, the tISI C es aluathm of the ciwrently available information from the IM)li safety analysis upgrade efliert related to sciunic capabilities at the facility completed on October 23.1995, the IM)l? evaluatiim of the UM C response dated October 31,1995, and j lISI'Cs proposed resolutite documented on January 9,1996, the following actions are being implemented to ensure the protection of the workers and public health and safety: - Iluilding access will be limited to only timse individuals essential to operations, inspections, or those persormet performing the modifications until they are complete. CPI-POA-C36 o f d 6/30N9 Ilased on a Directive for information pnwided to USEC by DOE on Resised by NRC Lar 3/70NR, TAC b September 22,1995, the USI'C evaluation of the currently available No.1.32028. CAR to extend date to infonnatkm from the IX)E safety analysis upgrade effort related to 6/30/00 is at NRC for retiew. sciunic capabilities at the facility completed on October 23,1995, the IM)I! evaluatiam of the !!SI:C response dated October 31,1995, and 1151 Cs proposed resolution docunwnted on January 9,1996, the following actions are being implemented to ensure the protection of the umkers and public health and safety: - Modifications to increase the seismic capability for floor and roof sections in fluildings C-331 and C-335 uill be completed by June 30, 1999. CPI-l'OA-C36 02 Transition At the time of transition from 1M)E regulatory oversight to NRC Complete regulatory og ersight. USI:C uilt infonn NRC of the interim measures still in ef fect for the afTected buildings and equipment and the current status of wgrading the seismic capabilities of the affected buildings and equipment. .. Page 25 of30
FACll.IIT issilE # TASK ID Dl'E DXI E CO%I%IllMEN I DESCIUl* LION SITills NiDP 36 CPI-POA-C36 03 When Available liocumentation prepared for the design of the modification and other Complete reles ant inforuution concerning implementation uill be prosided to the NRC. upon issue, for infmmation and resicw. CPI-N3A-C36 04 12/IN7 11y December 1.1997, USEC shall submit for NRC apprusal an updated Complete seismic risk analysis for the Paducah plant site. Any proposed mmfifications that may result from this analysis shall be subject to a backlit arral sis pursuant to 10 CI R 76.76(b) The analysis shalt: 3 - Consider all avadable regional and site-specific data published by the U.S. Geological Suivey. - Proside an estimate of the peak ground acceleration for a seismic event with a 250-y ear return period. If the estimate is greater thart 0.15g. then the return perim! for a 0.15g event shall also be estimated. 37 CPI-POA-C37.01 12/31N7 1he required procedure will be devchiped and implemented using the Complete process desceihed in Application section 6.11. Procedures to implement I the trending actisities are being developed as part of tle pmcedure upgrades within the Nuclear Safety lipgrade Project. 38 CPI-POA-C38 01 5/30/96 The data obtained from the first sit months operation of the new high-Closed Closed by NRC. See NRC letter volume ambient air samplers will be revieued in May 199611y hlay 30 dated August 4,1998. 1996. baseline ambient air radios uclide levels for routine plant operations, based on the 6-mtmth data, uilt be established for each high-volume ambient air sampling kwalion. Ilsing the baselme lesels, action les els will be established by klay 30.19tn, f.w requiring additional g analyses and, ifnecessary,insestigation of the cause for exceeding an action level. CPI-POA-C38.02 6/30M7 in 1997, a comparison of the FDE calculated using 1996 release data and Closed the FDE calculated using the 1996 data from the high-vohnne ambient air samplers will be performed.1he comparison will be prosided to the NRC at the time of the PGDP submission ofits 1996 NESilAl" teport to the B K)E li e., June 30,1997). ., l' age 26 of30
'4 + ~ 1I ACII.lTY ISS$fE# TASK ID pt!E DATE . COMhtlThlENT DESCM P N STAlllS _, ~ T:=====r:::r. = = =~ -- + = = :
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PtiDP 39 cpi-POA-C39 of Privatiration 1* Ding executed alocuments required to assure adequate fusulmg Compacte - r for tISI C s postiam of P(iDP's decontamination and deconunissisming. costs uit be submitted to the NRC at the time iISI.C privatiration arcurs: . an creenteil sinking final arsangement. - a standby inest agreement, and/or - ( - a payment surety tumd. The atxne-listed documents mill closely adhere to the recommended. wording for such instruments set forth in NRC Regulatory Guide 3.66," Standard l'ormat on and - Content ofl'inancial Assurance klechanisms Required for ikcommissiiming under 10 CI'R Parts 30,40, J 70, and 72? ~ l 40 CPI-POA-C40.01 5/26/97 ne mechanical integrity program for maintenan e and inspection PSM -. Complete ? requirements mill be implemented. 1 41 CPI-POA-C41.01 8/30/96 Retisc the applicable procedures to incorporate the requirement to verify CInsed - i the differential pressure checks on the litiPA filters used on local - I ventilation systems to control worker exposure. t CPI-POA-C4i.02a 6/30/97 III!PA filter systems will be evaluated and tinse eletermined to be Complete I required will be periodically tested as described in SAR Sectiim 5 3.2.10. ' If necessary Ill!PA filter systems will be nuwlified to allow tlw. j performance or passing of the required periodic testing or inspection. g Ibcumentation tojustify reclassifying (to rum-Ill'PA litter system status) [ or retention of any litiPA filter systems will be developed in Systems l I:ngineeting and approved by the blanagers of Rsdiation Protection and j Nuclear Safety. CPI-POA-C41.02b 6/30/97 De applicable procedures will be revised to flow-down the llEPA filters Complete systems test and inspection rcquirements. t 42 CPI-POA C42.01a 3/3/97 He current staffing allocations will be supplemented if necessary to meet - Complete I f working lumr guidelines stating that an individual slumid not he [ permitted to norL more than 32 leurs in any 48 hour periini and no more .[ i than 80 hours in any 7 day period, excluding shift tunamr time. f I I i i '. l' age 27 of30 i u' y
FACIl_I1Y ISSt!E # TASK ID DtIE DATE CO%I%Ill%IENT DESCRIPTION STATIIS
-=:
=~ u-PGDP 42 CPI-M)A-C42.0lb 6/2886 A revised TSR will be submitted to the NRC to add these guidelines to Closed 1SR 3.2.2 h. CPI-N)A-C42.02a 3/3 tN7 IIStlC uill supplement current stamng allocations to meet its proposed Complete wtuking hour guidelines that state that an individual should smt be permitted to work more than 24 Imers in any 48 hour period and no more than 72 hours in any 7 day pc iod culushe of shift turnover time. CN-POA-C42.02b 3/3 tN7 USEC will submitted a revit-d 1SR to the NRC to add these guidelines Complete to 1 SR 3.2.2 b at the time sufficient stamng is achieved to meet these guidelines. 43 CPI-M)A-C43.01 5/26N7 DOE and 1hird-Party tenants will notify 1150C before harardous Complete chemicals, including til 6 and UF4, are introduced onto the site. All initial process haiards analyses are to be completed by May 26,1997. 44 CPI-POA-C44.01 12/31/97 A res icw of $3 stem designs will be performed where operational trips and Complete alarms coincide with the setroints for safety system actuation based on the same numitored parameter and the same equipment actuated Wtere redundant operational and safety s3 stem actuations esist corrective acti m will be identified that may include justificatism either for the redundancy or s3 stem nmdifications to climinate the scdundancy. t he results of this review will he submitted to the NRC for res icw and approval by December 31,1997. 5 CPI-M)A-C44 02 To De Determined If the review determines that a system naalification is reqmred, this Complete see NRC letter dated September 14, Compliance Plan will be resised to establish a new completion date of 1998 (TAC No.132091) cumpliance. 45 CPI-N)A-C45.01 2/1/97 'Ihe documents referenced in Appendix A to SAR Chapter 1.0 will be Closed reviewed, and a listing of specific sections of the codes, standards, and NRC regulatory guidance documents to which ITiDP is committed will be compiled.1he results uilt he transmitted to NRC at least 30 days prior to the date that the NRC assumes regulatory authority for PGDP. 46 CPI-M)A-C46.01 til8/00 Plant modifications will be initiated to ensure that the CA AS alarm horns CAR approved by NRC on 1/7N9 are capable of being heard throughout the afTected areas of the process to change completion date to l>uildings. I/t 8/00 -. Page 28 of30 t
l ACII ITY ISSI!E # TASK 11) Dl'E IMTE CO%I%Ili SIENT DiMEIPilON STAlllS 2== = 1 : r n=== --, _ - - ===2 := z = - =:.-
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7 :-- - .r- = 2 = PUDP 48 CPI-141A-C48.01 a J/30N6 'I he limiting specific values for battery performance listed in the TSR Clused wiil be recon 0rmed and akicinnented, either through engineering analysis, sarcy demonstration, or a combination of Imth methods, and uilt be serined by subsequent independent review to pmtide adequate margin for determining the operability of the cascade cell trip function. L Cl%IM)A-C43.0lb 9/29N6 If new limiting specific values are detennined as a result of this analysis Closed and/or denumst:ation, then llSI.C uilt submit a revised TSR and TSR basis statement uithin 30 days of verifying these new values. CPI-POA-C48.02a 8/30N6 1he limiting wcific values for air pressure requirements for the *000" Closed air circuit breakers will be reconfirmed and doctmented cither through engineering analy sis, safety denumstration, or a ctunbinathm of both nwthods, and will be verified by subsequent independent review to prmide adequate margin for determining the operability of tic cascade cell trip functmn. l CPI-POA-C48 02b 9/29N6 If new limiting specific values are determined as a result of this analysis Closed and'or demonshation, then IJStiC uill submit a revised SAR section .3.9.I.3.2 within 30 days of verifying these new values. 49 CPI-POA-C49.01 a 1/3187 IISl?C will des clop and complete a pmgram to relate the response of UF6 Closed leak detectors to manual test mclluxts and to the detectkm of an actual 1106 leak. The scheduled date for developing a testing methodology plan l is Janu.m y 31,1997. CPI-POA-C49 Olb 7/31N7 Ilstic will derchy and complete a program to relate the response of Ur6 Complete leak detectors to manual test methods and to the detection of an actual I!! 6 leak.1he scheduled date for developing a field test mettuxl for the detectors is July 31,1997. CPI-POA-C49.Olc 7/3188 USI!C will develop and complete a program to relate the response of UT6 Complete. leak detectors to manual test metiumis and to the detection of an actual 118~6 leak. the scheduled daic for completing the initial periodic testing of the detectors is July 31,1998. t Enclosure I, Page 29 of30
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~ ~ ~ = ^ FACalIIY issue # TASK III DtiE DATI: Coslairl hlENT DESCRlrilON STATUS 10DP 50 CPI-POA-C50.01 IllRA10 1:1 acuation lawns ifor those unalarmed buitdings where nearby CA AS CAR approved by NRC on I/7/99 lawns cannot be adequately heard) and/or lights uilt be installed in the to thange completiori date to imstarmed buildings located within the cvacuatiim area of CA AN-1/lRM) clustered buildings. or the unalanned buildings nill be renmn ed fiom tie evacuation anca i hese innns and/or lights uill be activated from a nearby chsteved building or other alarmed building. Unalarmed facilitics that has e been identified as of June 19,1996, uill be modified with the required horns and/or lights, as appropriate, or rek>cated to locations muside of the evacuation area by December 15,1998. 1 i T Enciasure I, Page 30 of 30 -}}