ML20206F718
| ML20206F718 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 04/30/1999 |
| From: | Jonathan Brown UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Pederson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| GDP-99-2020, NUDOCS 9905060217 | |
| Download: ML20206F718 (26) | |
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USEC A G%al Energ Company April 30,1999 GDP 99-2020 Ms. Cynthia D. Pederson Director, Division of Nuclear Materials Safety U.S. Nuclear Regulatory Commission Region III 801 Warrenville Road Lisle, Illinois 60532-4351 Portsmouth Gaseous Diffusion Plant (PORTS)
Docket No. 70-7002 Submittal of Revision 5 of the PORTS Nuclear Critically Safety (NCS) Program Corrective Action Plan (CAP) and NCS Program Quarterly Status Report
Dear Ms. Pederson:
Pursuant to References 1 aad 2, the United Stated Enrichment Corporation (USEC) is transmitting revision 5 of the PORTS NCS CAP (see Enclosure 1). As indicated in References 1 and 2, the reasons for this revision to the PORTS NC CAP are summarized below:
reflects the current ongoing work, provides an updated list of NCSA/Es, and deletes those tasks which have been completed or are no longer needed; clarifies the process for handling emergent work and the criteria for determining
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whether revised or new NCSA/Es should be covered under the NCS CAP; provides the basis for the projected milestone completion dates for Task 3; and a
includes a detailedjustification for the consolidation of the revision 4 Priority 2 and a
3 NCSA/Es.
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-PORTS has placed greater emphasis and focus on completion of the NCS CAP. Specifically, an NCSA Implementation Team has been assembled reporting directly to the General Manager. This team is headed up by the Commitment Management Manager and other managers that will provide a full time effort towards completing the near-term task ofimplementing the Priority 1 NCSA/Es.
It should be noted that the tasks and completion dates in revision 5 of the NCS CAP were reviewed and approved by the PORTS Corrective Action Review Board. Attachment 2 to Enclosure 1 provides the current list of Priority 1 and 2 NCSA/Es, those NCSA/Es requiring " Additional Reviews" (e.g., completion of the AQ-NCS classification), and a list of NCSA/Es deletions and consolidations.
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P.O. Box 800, Portsmouth, OH 45661
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Tele h n 740-897 2255 Fax 740-897-2644 http://www.usec.com 9905060217 990430 PDR ADOCK 07007002 ucah, KY Portsmouth, OH Washington, DC C
PDR 3
Ms. Cynthia D. Pederson
- April 30,1999
Highlights of the revised CAP are listed below:
The implementation date for the Priority 1 and Additional Reviews NCSNEs has not been changed. The scope of the Priority 2 NCSA/Es has been increased to 27 from 22 and the implementation date for the Priority 2 NCSA/Es has been extended from March 3,2000, to July 30,2000.
The completion dates for Task 5 have been extended from December 15,1999, to March 30,2000, for Prior:ty 1 NCSA/Es and May 20,2000, to January 31,2001, for Priority 2 NCSNEs.
Tasks 8 and 21 have been reopened with both task completion dates being January 28,2000. to this letter is the Quarterly Status Report for the PORTS NCS CAP for the period of
' January 21,1999, through April 20,1999. This status report reflects the information provided to
.the NRC in Reference 2; USEC previously identified that AQ-NCS requirements were not fully implemented for the following five Priority 1 NCSA/Es:
NCSNE 0326_013.A06 NCSA/E 0330_004.A03
- NCSA/E 0333_015.A03 NCSA/E 0705_015.A09 NCSA/E PLANT 079.A01 USEC previously reported these NCSNEs as approved and implemented; however, after NRC violation 98206-02 was identified, these NCSA/Es should have been reported as implemented with
-AQ-NCS flowdown in process. This is properly reported in Enclosure 3.
After evaluating the extensive calibrations and other field-work associated with the flow-down of AQ-NCS requirements for the NCSA/Es' associated with cascade operations, USEC recently decided it is more appropriate to rewrite certain portions of the NCSA/Es. As a result of this additional information, USEC is changing the status of these five NCSA/Es to implemented with AQ-NCS
- flow-down in process." The revision of these five NCSA/Es will not change USEC's Priority 1
. NCSA/E implementation completion dates.
The commitments contained in this letter are located in Enclosure 1, Attachment 1.
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K Ms. Cynthia D. Pederson April 30,1999 -
GDP 99-2020, Page 3 If you have any questions concerning this submittal, please contact Peter J. Miner at (740) 897-2710.
Sincerely,.
h
. Morris Brown General Manager.
Portsmouth Gaseous Diffusion Plant
Enclosures:
As Stated cc:
- NRC Document Control Desk' NRC Resident Inspector; PGDP NRC Resident Inspector-PORTS NRC Project Manager - PORTS NRC Special Projects Branch DOE Regulatory Oversight Manager i
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4 Ms. Cynthia D. Pederson
- April 30,-1999
- GDP 99-2020, Page 4 References 1-
. USEC letter to NRC dated February 1,1999, GDP 99-0020, "Portsmouth Nuclear Criticality
' Safety Program. Quarterly Status Report."
2.
USEC letter to NRC dated March 19,1999, GDP 99-0050, " Notification of Change in
- Regulatory Commitments, Nuclear Criticality Safety Program Corrective Action Program."
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GDP 99-2020 Page1of5
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PORTS Nuclear Criticality Safety Program
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Corrective Action Plan, Revision 5 i
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.B' ackground As explained in earlier versions of the NCS CAP, the purpose of the CAP is to identify and define the steps to increase the effectiveness of the NCS Program and its support for the operation of the plant.
Since all.but 4 of the 26 Tasks in revision 4 have been completed, revision 5 was prepared to make the document more concise and useful; In revision 5, subtasks were renumbered starting with.1 in each Task.
USEC letter GDP 99-0020 committed to clarify whether revisions to NCSA/Es should be covered under the NCS CAP. New NCSA/Es or changes to NCSA/Es are often needed to support plant safety, operational, or regulatory issues. This type of change (i.e., response to emergent work) is processed as a revision to an NCSA/E.
Revising NCSA/Es is considered routine support of day-to-day operations and there is no
- need to include the details of this activity in the NCS CAP.'
I USEC letter GDP 99-0050 committed to provide the basis for the Task 3 projected milestone completion dates. Although historical data of the time required to implement an NCSA/E
.is available, additional factors were considered to determine the time to implement the
- upgraded Priority 1 NCSA/Es.. Factors considered included, the coordination of NCSA/E implementation with other important work that must be accomplished in the same time
-period, the personnel resources, especially subject matter experts, who are in most cases the same personnel being used to assist with upgrading Priority 2 NCSA/Es and related activities such as the additional reviews, and the need for proper sequencing of NCSA/Es being implemented. To determine completion dates, working sessions for each Priority 1 NCSA/E lieing implemented were held to identify and review implementing tasks (such as identifying
- which specific AQ-NCS instrumentation requires calibration, confirming adequacy of the related calibration procedures, initiating calibration work planning packages, and scheduling the calibrations), durations for these specific tasks were based on past performance and j
recent experience, critical paths were identified, and the specific tasks and times were
- integrated into a master schedule.
The processes for upgrading Priority 2 NCSA/Es are the same as the Priority 1 NCSA/E upgradesi The time to upgrade Priority 2 NCSA/Es is based on averages of the actual time to upgrade Priority 1 NCSA/Es.
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GDP 99-2020 Page 2 of 5 USEC letter 99-0050 also committed to include a detailedjustification for the consolidation of the list of Priority 2 and _3 NCSA/Es. To identify the remaining NCSA/Es requiring upgrade, the Non-Priority 1 NCSA/Es from revision 4'of the NCS CAP were reviewed in a systematic manner, using a che' klist and criteria. For example: an outstanding problem c
report indicated a significant concern, or the NCSA controls could be worded significantly better for the user, or an NCSA control could be replaced with a better control (such as a passive barrier or active design feature). This review was performed by a Senior NCS Engineer. The results were reviewed by the managers of the Fissile Material Operations r
(FMOs), and approved by the NCS Manager. Based on the review, the new number of Priority 2 NCSNEs is 27, the new number of NCSA/Es requiring " Additional Reviews" is 93, and the number of NCSNEs that will be deleted or consolidated is 42.
The completion of Task 5 is dependent upon completion of Task 3, experience with performing previous surveillances of the implementation of NCSA/Es, with allowance for the fact that the implementation of NCSA/Es, and allowing for the fact that the implementation of NCSNEs tend to accumulate toward the end of the schedule. The completion dates for Task 8 are based on the previous experience with resolving concerns in the NCS_ Vertical Slice Report with an allowance for time to review and compile the documentation as task closure evidence. The completion dates for Task 21 are based on previous experience with building walkdowns, the time to process drawings if required, and to compile the documentation as closiire evidence.
II.
Details of Open Tasks Task 3.
NCSA/E Upgrade project The objective of the NCSA/E upgrade project is to improve the technical content of the NCSA/Es while making them easier to understand and enhance compliance, and to ensure proper flow-down and implementation of NCSA requirements.
- NCSNEs upgrades were prioritized as follows:
Priority 1: NCSNEs for continuous operations which support feed, enrichment or
- withdrawal activities because these are the activities performed the most often and therefore 1have the highest potential risk.
Priority 2: A review, using a checklist and criteria, determined these NCSA/E should be upgraded. For example: an outstanding problem report indicated a significant concern, or
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the NCSA controls could be worded significantly better for the user, or an NCSA control
. could be replaced with a better control (such as a passive barrier or active design feature) i
m Enclosure i GDP 99-2020 Page 3 of 5 Additional Reviews: For NCSNEs not classified Priority 1 or 2, a review will be performed to ensure proper AQ-NCS determination and flow-down of NCSNE
. requirements.
Subtask Noc Subtask Descrintion 3.1
' Upgrade and implement Priority 1 NCSA/Es in accordance with approved procedures, including the following:
Complete PORC approval.
Complete AQ-NCS classification of Systems, Structures, and components (SSCs).
Complete the procedures, training, and implementation.
3.2 Upgrade and implement Priority 2 NCSA/Es in accordance with approved procedures, including the following:
f Form review groups which would typically consist of representatives a
from NCS, Systems Engineering, Operations Management, and a hands-on, operator or maintenance technician.
4 Perform reviews and walk-downs in accordance with an a
approved procedure (e.g.,
XP4-EG-NS2042, Nuclear Criticality Safety).
Table top scrub NCSA/Es and their supporting documents, including a review and closeout of applicable problem reports.
Review PGDP NCSNEs for similar activities and apply where appropriate.
Conduct peer review.
Obtain PORC approval.
Complete AQ-NCS classification of SSC.
Update applicable procedures, postings, training, Boundary Manuals, and associated plant conditions (e.g., calibrations).
Walk-down approved (PORC and General Manager) NCSNEs to document their readiness for implementation.
Implement the NCSA/E.
3.3 For NCSNEs not Priority 1 or 2, perform reviews of the implementation of NCSA/Es to ensure or correct the following:
AQ-NCS classifications of SSC are proper, and, Requirements are properly flowed-down (e.g., into procedures, postings, and training).
Task 5.
Safety, Safeguards and Quality (SS&Q) Review ofimplementation
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Enclosure I j
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GDP 99-2020 Page 4 of 5 As part of the ongoing self-assessment activities at PORTS, SS&Q is monitoring the
' implementation ofnew NCSA/Es in the field. This nionitoring utilizes ANSI /ASQC Z1.~4, Sampling Procedures and Tablesfor Inspection by Attributes, for sampling guidance and takes the form of a series of assessments after the NQSA/Es are:
implemented. The plan for implementing this review process follows:
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- Subtask No.. Subtask Descriotion.
l 5.1 -
Develop list of NCSA/E changes from Task 3.
5.2 Write an Assessment Plan.
5.3 Schedule assessments as an extension of Task 3's schedule.
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- 5.4 Perform assessments in accordance with applicable procedures.
Task 8.
Vertical Slice Review This task is to ensure the recommendations, observations, and concerns in the final signed version, of the NCS' Vertical Slice Report are properly evaluated and dispositioned.
i Subtask No.
Subtask Descriotion 8.1 '
Evaluate recommendations, observations, and concerns in the NCS
!i Vertical Slice Report.'-
s 8.2 Provide an explanation for those items considered acceptable-as-is (i.e.,
no change is required).
8.3 Where applicable,~ determine corrective ac. ions and completion dates.
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8.4 Complete corrective actions.
, Task 21.
- Fissile Material Operation (FMO) Identification The FMOs were previously identified. The objective of this task is to confirm these
- FMOs (including handling, storage, processing, and transportation) involving uranium enriched to 1.0 wt. % or higher 235U and 15 grams or more of 235U are properly identified and to enhance the documentation associated with the identification of FMOs.
Subtask No.
Subtask Descriotion i
21 1 =
. Issue an approved procedure for identifying and documenting FMOs.
-21.2 Conduct training on the methods for identifying and documenting FMOs.
-21.3
. Conduct field walk-downs to identify and document FMOs.
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GDP 99-2020 Page 5 of 5 Attachments i
1.
Implementation Schedule End Dates 2.
List of NCSA/Es
i GDP 99-2020 -
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Implementation Schedule End Dates Task #
Description Target Date 3
Complete PORC approval of 4 Priority 1 NCSA/Es 05/21/99 i
Complete AQ-NCS classifications for 4 PORC approved 06/09/99 Priority 1 NCSA/Es ~
Complete procedures, training, and implementation of 09/30/99
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Priority 1 NCSA/Es Complete PORC approval of Priority 2 NCSA/Es 01/28/00 Complete AQ-NCS classifications for Priority 2 NCSA/Es 02/25/00 Complete procedures, training, and implementation of -
l Priority 2 NCSA/Es 07/30/00 Complete changes to AQ-NCS classifications resulting from -
additional reviews 05/19/00 Complete changes to procedures, training, and implementation resulting nom additional reviews 05/18/01 5
Complete SS&Q review ofimplementation of Priority 1 03/30/00 NCSA/Es 4
Complete SS&Q review ofimplementation of Priority 2 -
01/31/01 NCSA/Es 8
Complete resolution of recommendations and observations 01/28/00 in the NC.S Vertical Slice Report l21 Complete the documentation of Fissile Material Operations 01/28/00 J
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Priority i NCSA/Es (Without Date Extensions)
NCSA # -
SUEJECT I
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. 0326_013.A06 : Ce.scade Operations in the X-326 Building l
- 0326_015.A05 ; Extended-Range Product (ERP) Withdrawal Station 1
- 0330_004.A03 1 Cascade Operations in the X-330 Building 0330_007.A02. Product Withdrawal at the Tails Withdrawal Station -
. 0330_013.A01 Long Term Storage of PEH Converter in X-330 0333_015.A03 Cascade Operations in the X-333 Building 0333_017.A02 Low Assay Withdrawal (LAW) Station 0344A002.A03. X-344A Pigtail Vent System 0705_009.A01 Seal Dismantling Room 0705_012.A03 Small Parts Hand-Table Operations 0705_015.A09 Waste Water Treatment (Microfiltration System) 0705_024.A01 Calciners, Solution Recovery 0705_025.A01 Nitrous Oxide (NOx) Scrubber System
- 0705_034.A03 Spray Booth Operations 0705_041,A01. Material Handling and Storage in X 705 0705_042.A02 Small Equipment Tear-Down (Blue Room) 0705_064.A01 Seal can Handling and Storage in X-705 0710_009.A01.. Uranium Chain of Custody PLANT 004.A03 Storage, Handling, and Transportation of Large UF6 Cylinders
' PLANT 006.A07 General Use of Small Diaracter Containers for Storing High Enriched Material PLANT 018.A02 Dry Active Waste (Contaminated Burnables)in Waste Generation Areas and in Interim Storage PLANT 022.A01 Sample Cylinder Handling and Storage PLANT 030. 03 Evacuation Booster Stations PLANT 033.A02 Surge Drums
- PLANT 038.A01 Interbuilding Tie Lines -
PLANT 043.A02 Fissile Material Transport -
PLANT 049.A02 Portable, Small UF6 Release Gulpers
- PLANT 054.A01 Lube Oil System PLANT 055.A01 Laundry PLANT 062.A02 Cascade Mahtenarce, Equipment Removal and Storage P
- LANT066.A03 Mopping Contaminated Areas'(CCZs, CAs and HCAs)
PLANT 076.A00_ 340 Complex Oil Interceptors, Scale Pits, & Sumps PLANT 079.A01 Opening Equipment containing Greater than A Safe Mass of Uranium-Bearing Material PLANT 082.A00 340 Complex Waste Streams PLANT 085.A00 X 340 Complex Autoclave Operation Total: 35-L
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Page 2 0f 8 Priority 1 NCSA/Es(With Date Extensions)
NCSA #
SUBJECT 0326,014.A02 X 326 Seal Exhaust 0330_005.A01 X 330 Seal Exhaust and Area 3 Wet Air Evacuation 0333_016.A02 ~ X-333 Seal Exhaust and Wet Air Evacuation PLANT 029.A02 Cascade Datum Systems
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Page 3 of 8 I
Priority 2 NCSA/Es
- NCSA # -
SUBJECT j
0326_001.A02 - Nuclear Criticality Safety of Shutdown and Standby X-326 Cells
-0326_022.101.X-326 Use of Portable HEPA Ventilation Units for Specific Activities
- 0326_028.A00 Handling and Storage of Seals with Undetennined or Unknown Enrichment in X-326 0330_003.A02 Storage and Handling of Seals in X-330 j
0344A005.A02 ' X344A Small Diameter Container Storage 0705_002.A02 2.5-Ton,10-Ton, and 14-Ton Cylinder Cleaning
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0705_021.A01 B. Area Batching Handtable Operations
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0705_031.A00 ' Equipment Disassembly in the North Teardown Area 0705_033.lC4 South Annex Operations - Cascade Equipment 0705_038.A01 Truck Alley Cleaning 0705_076.A00 Inadvertent Containers 0705_083.A01 "A", "B", and "C" Loop Concentrate Storage and Metering Systems 0710_006.A01 Uranium Sampling Laboratory 0710_008.A01 L #6 Isotopic Standards Preparation Laboratory '
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0710_011.A00 Mass Spectrometry Laboratory
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0710_012.A01 ' Uranium Analysis Laboratory 0720_018.A00 Hydro Table in the X 720 Hydro Shop PLANT 013.A00 Batching Solutions and Solids PLANT 025.A01 General Use of Small Diameter Containers for Storing up to 10% Enriched Material PLANT 034.A00 Liquid Waste Collection and Sampling Systems
, PLANT 036.A00 Storage of Safe Batch Containers PLANT 045.A01 Limited Safe Volume Containers PLANT 048.A03 Contaminated Metal j
PLANT 053.A01 Uranium Analysis and Sampling PLANT 057.001 Use of Gas Sampling Cart PLANT 063.A01 Building Decontamination Activities PLANT 064.A01 Handling and Storage of Seals in X-326, X-330, and X 333 Total: 27L I
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GDP 99-2020 Page 4 of 8 I
NCSA/Es Additional Reviews :
' NCSA #
SUBJECT -
0326_027.A00. Operation of the X 326 NDA Laboratory i
0330_009.A01 - Flushing / Cleaning of 1-1/2" Vented Cavity Pipes and Compressor "B" Seal Cavities
' 0330_014.A00 : X 330 Cold Recovery Area Wet Air Evacuation System j
0330_015.A00 Interim Purge Area 1
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0333_022.A00 Flushing / Cleaning of Vented Cavity Pipes and Compressor "B" Seal Cavities 0700_001.001-Fissile Material at the Radiation Instrument Calibration Facility 0700_002.A01 Heavy Metals Sludge Storage -
0700_004.A01 X 700 Converter Disassembly, Repair, and Storage 0700_005.A00 ' Glass Bead Blasting
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0700,006.A00 - Biodenitrification (Pilot Plant and New Plant) 0700_007.A00 Cleaning Tank #3 Converter Flushing Station j
0700_020.A00 Operation of the X-700 Chemical Tanks 1,2,4, and 5 0705_,004.A01 5-Inch Cylinder Cleaning
- 0705_005.A00 Small Cylinder Rinse Pit.
' 0705_,010.A02 Small Parts Glass Bead Blaster
. 0705_011.A02 Small Parts Pit 0705_014.A01 Leaching / Complexing Handtable 0705_018.A03
'8 and 12 Inch Cylinder Cleaning 070$_022.A01 ' B 38, B 1, and Dissolver Solution Storages-0705,,023.A00 Operation of the "A," "B," and "C" Loop Extractor / Stripper Systems 0705_027.A03 Heavy. Metals Precipitation
..0705_,028.A00 Technetium lon Exchange
- 0705_030.A00' Recovery Elevator
-070$_035.A05_ Tunnel Storage
- 0705_037.A00 Ground Water Sumps
- 0705_039.A02 Oil and Grease Removal System 0705_040.A00 Overhead Storage; f
0705_043.A00 Elevator Tunnel -
0705_044.001 Maintenance Shop.
0705_050 A00. X 705 Process Laboratory
-~ 0705 051.A01. Solution Preparation 0705_055.A00 Facility Drains 0705_072.A00 ' Inspection and Testing of UF6 Cylinders 0705_073.001 Genie Model AWP30 Manlift 0705_075.A00 F-Area Fissile Material Handling and Storage
n GDP 99-2020 -
Page 5 of 8 NCSA/Es Additional Reviews NCSA#
SUBJECT 0705_082.A00. "A", "B", "C" Loop Pre-Evaporator Systems
- 0705_084.A00 "A" and "B" Loop Raffinate Storage and Recycle System 0705,085.A00 "A",."B," "C" Loop T-Water Storages -
0705_086.A00 "A", "B", and "C" Loop Post Evaporator Systems 0705_099.A01 Post Evaporator Spray Condenser and Sample Condenser Systems 0705_100.A02 Pre-Evaporator Spray Co'ndenser and Sample Condenser Systems 0705_102.A00 B Area Condensate Drain System 0705_103.A00. Process Vent System.
0705_105.A02 Cylinder Cleaning Gulper System 0705_107.A00 2.5-ton,10-ton, and 14-ton Cylinder Receiving & Storage 0705_110. A01 Used Microfilters Removal and Storage
,0705_111.A01 Buffing Booth 0705_l !4.A00 Facilities Utilities / Services - Process Steam -
- 0705_122.A02 Blending Cylinder Wash Solution 0705_123.A01 Small Cylinder Receipt and Storage 0705_124.A01. F-Area Oxide Glovebox 0705_127.A00 Classified Scrap Metal (Scal Parts Only) 070$_128.A00. Storage of 8-inch EBS Pipe in the Large Parts Cage 0705_129.A00 Decontamination of Unfavorable Geometry Parts in Tunnel Spray Booths 0705_131.A00 Draining, Transferring, and Collecting Uranium-Bearing Liquids in X-705 0710_001.A02 Use of NilFisk Model 80 Portable Vacuum in X-710 0710_004.101-Gulpers for Mass Spectrometers 0710_007.A01 Small Diameter Container Storage in X 710 q
0710,,,014.A00. X Ray Fluorescence Laboratory i
0710_015.A02 Handling of Samples and Process Waste in' ES&H Analytical Labs
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1 0710_020.A00 Process Chemistry Laboratory 0710_021.A00 Process Services Laboratory 0710_022.A00 _ Laboratory Standards and Controls
~ 0710_,023.A00 ' Miscellaneous Uranium Operations 0710_024.A00. Handling and Storage of Sources 0710,.025.A00 Handling and Storage of Samples from ES&ll Analytical Labs 0720_009.A00 Small Parts Glovebox l
0720_014.A00. Valve Shop Vapor Degreaser 0720_015 A02 Cleaning and Decontaminating Space Recorder Cans 0720_016.A00 Transmitter Cleaning Station b
o GDP 99-2020 Page 6 of 8 4~
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NCSA/Es Additional Reviews NCSA#-
= SUBJECT.
0760,003.A01 Sample Buggy Repair 0847_001.A03 : ' General Storage of Uranium-Bearing Waste, XT-847 0847_002.A02 : Storage of B-25 Waste Boxes at XT-847
= PLANT 011.A02 Use of Portable HEPA Ventilation Units -
' PLANT 012.A01 Favorable Geometry Vacuum Cleaner PLANT 014.A00 Use of Unsafe Geometry Vacuum Cleaners
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1 PLANT 016.A00 Use of Commercial Floor Scrubbing Machines and Power Sweepers
- PLANT 017.A00 Storage and Handling of B-4 Pumps
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PLANT 028.A04 Removal and Handling of PEH Equipment
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PLANT 031.A03 Use of Portable infrared Analyzers (PIRA Buggies, FTIRs, etc.)
i PLANT 037.A00 Use of Small Diameter Container Carts
. PLANT 044.A00 Cold Recovery Cold Traps PLANT 050.A00. Use, Handling, and Storage of Fixed HEPA Filters and Prefilters
. PLANT 051.A00 Cold Recovery Chemical Traps.
1 PLANT 052.A00 Cold Recovery-Holding Drums PLANT 060.A02 Cylinder Valve Replacement
- PLANT 065.A00 Use of Limited-Safe Geome*.ry Vacuum Cleaners PLANT 068.A00 Negative Air Machine (NAM)
. PLANT 069.A00 Test Buggies
' PLANT 070.A00 Miscellaneous Waste Accumulation Areas -
PLANT 077.A00 Long Term Storage of Legacy PEH Equipment PLANT 081.A00 Dry Ice Blasting For Decontamination PLANT 083.A00 Use of Cascade Cells as Surge Volumes
. Total: 93 -
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NCSA/Es Subject to Deletion or Consolidation NCSA #
SUBJECT 0326.016.' 00 ' Operating Floor Freon Degrader' A
0326_024.A04 ' Feeding of 5-inch,8-inch and 12-inch Cyls. in the X 326 Product Withdrawal Area 0330_006.A01 X-330 Area 3 Seal Exhaust and Wet Air Evacuation 0333_007.A01 1000 CFM Negative Air Machine 0333_018.001 Freezer / Sublimer 0333_023.A01 = Long Term Storage of 33-8-6 Stage 7 PEH Compressor 0342A001.A02 General Handling, Weighing, & Storage 0342A002.A01: Autoclave Operation 0342A004.A01 Oil Interceptor-
- 0342A005.001 Sump 0342A006.A02 ~ Waste Streams 0343_001.001 General Handling, Weighing, & Storage 0343_002.A02 Autoclave Operation
'0343_003.101 Oil Interceptors,
~ 0343_005.A02 Waste Streams 0343_008.001 Disposal of Pigtails, Manifolds, Cylinder Safety Valves, and Other Used Autoclave Components 0344A001.A02 Autoclave Operation 0344A003.A00 X-344A Scale Pits and Sumps 0344A004.A00 Evacuation System and Cold Traps 0344A006.A03 Sample Cylinder Handling and Storage 0344A007.A04 Waste Streams 0344A010.0Cl Disposal of Pigtails, Manif olds, and Cylinder Safety Valves, and Other Used 0344A0ll.A01. Technetium (Tc) Trap in Autoclave
- 0700_016.A01 Uranium Bearing Materials Storage Area Between Columns DIO and D12 0700_017.A00 RCRA 90 Day Storage Area Bounded by Columns E2, E3, F2, and F3 0700_018.A00 X-700 Large Sandblasting Operation
' 0700_019.A00 Routine Operations in x 700 Cleaning Tanks 1,2,4,5 0705_020.A00 ' Flocculation & Filtration of Solutions from Leaching Operations l
0705_071.001 2.5 ton,10-ton, and 14-ton Cylinder Drying 0705_108.001 SES (Solution Enrichment System) 2 (X-705) 0705_126.A00 RCRA 90 Day Storage Area Roughly Bounded by Columns F 23,G-23, F-24 and G 0105_130.A00 Testing of the 5-inch and 8. & 12-inch Cylin' der Cleaning Operations
- 0710_026.A00 Sampling, Transporting, and Handling in X 710 J
0720_001.A02 Cleaning Lightly Contaminated Floo'r Areas 0720_003.A01 Dry Blast Machines for Non-Visibly Contaminated Parts 0847_003.A00 XT 847. Drum Crusher.
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GDP 99-2020 Page 8 of 8 NCSA/Es Subject to Deletion or Consolidation
'NCSA#
SUBJECT PLANT 001.A02 Storing Small Diameter Containers in Plastic Bags, Plant PLANT 002.0Cl Water Coolmg of UF6 Cylinders at LAW, ERP, Tails, X 342 and X-343 PLANT 074.A00 Decontamination Using a Steam Jenny PLANT 078.A00 Use of Ledoux IS Cylinders at PORTS PLANT 080.A00 Use, llandling and Storage of Autoclave Filter Units PLANT 084.A00 Removal of Uranium Bearing Components with Less than 15g 235U Total: 42 I
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GDP 99-2020 Page1of5 Summary of Changes Between Revision 4 and 5 of the NCS CAP USEC letter GDP 99-0020, dated February 1,1999, reported that Task 3, NCSA/E Upgrade Project; Task 5, SS&Q Review ofImplementation; Task 17, Oversight of Plan Implementation; and Task 18, Evaluation and Feedback, remained open in the NCS CAP.- In revision 5, Tasks 17 and 18 have been deleted (see task description below). Recently, USEC decided to reopen Task 8, Vertical Slice Review, and Task 21, Fissile Material Operation (FMO) Identification.
Also, subtasks were renumbered starting with.1 in each task in revision 5. All tasks identified in revision 4 and their current status is discussed below.
Task 1 Facility Review of Nuclear Criticality Safety Subtask 1.8, Implement Corrective Action, was rolled over into Task 3. Outstanding corrective actions were documented on problem reports. Task 3 includes a review of problem reports to ensure any work rolled over to Task 3, as well as other outstanding work,is appropriately incorporated into NCSA/Es. Task 1 is considered completed and the text was deleted in revision 5.
Task 2 Review of NCSA/Es Regarding Qualification Six NCSA/Es were found to have significant problems. Five of these were redone by qualified individuals and were PORC approved. The sixth was for one-time use and was deactivated. This task is considered completed and the text was deleted in Revision 5.
Task 3 NCSA/E Upgrade Project The task description and subtasks were updated to reflect current status and activities.
Subtasks that were one time activities and are completed were deleted.
Task 4 Enhance NCSA/E Training (Interim Process)
This task is considered completed and text was deleted in revision 5.
GDP 99-2020 Page 2 of 5 Task 5 Safety, Safeguards and Quality (SS&Q) Review ofImplementation The task description and subtasks were updated to reflect current status and activities.
l Subtask 5.5 was completed and text was deleted in revision 5.
1 Task 6 Complete Comprehensive Root Cause Analysis This task is considered completed and text was deleted in revision 5.
Task 7 Compare Applicable Industry Standards This task is considered completed and text was deleted in revision 5.
Task 8 Vertical Slice Review This task was reopened because resolution of the recommendations, observations, and
. concerns in the final signed version of the NCS Vertical Slice Report is still in
- progress.
Task 9 Continuous Improvement Program This task is considered completed and text was deleted in revision 5.
Task 10 Personnel Qualification Verification
- This task is considered completed and text was deleted in revision 5.
Task 11 Outside/ Independent Assessments This task is considered completed and text was deleted in revision 5. In response to concems about incomplete documentation identified during a recent NRC inspection, the results of Task 11 were reviewed again and documentation was corrected.
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GDP 99-2020 Page 3 of 5 Task 12 Policy / Procedure Revision and Training This task is considered completed and text was deleted in revision 5.
Task 13 Revise Training Program for Site Personnel This task is complete through subtask 13.5. Subtasks 13.6,7, and 8, upgrading and implementing training modules to reflect improvements in NCSA/Es, are covered by Task 3. Task 13 is considered completed and the text was deleted in revision 5.
Task 14 Corrective Action Program Enhancements This task is considered completed and text was deleted in revision 5.
Task 15 Configuration Management Program Enhancements I
This task is considered completed and text was deleted in revision 5.
Task 16 Revise Assessment Programs This task is considered completed and text was deleted in revision 5.
Task 17 Oversight of Plan Implementation The objective of this task was to perform an independent assessment of the NCS CAP on a bimonthly frequency. Evaluations of the effectiveness of the implementation of the tasks in the NCS CAP were conducted to ensure management's expectations were being met. Since the number of NCS CAP activities involving physical work is now significantly reduced (from 26 to 3), the objectives of this task can be met through management oversight. There is no longer a need for separate SS&Q assessments.
Therefore, this task is deleted and the text was deleted in revision 5.
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GDP 99-2020 Page 4 of 5 Task 18 Evaluation and Feedback The objective'of this task was to conduct a systematic evaluation of each task in the NCS CAP to support the NCS CAP Quarterly report. Since the number of activities
- in the NCS CAP is now significantly reduced, the need for a task separate from day-to-day supervision and management is no longer necessary. Therefore, this task is
-deleted and the text was deleted in revision 5.
Task 19 Evaluate Continued Use of Murder Board This task is considered completed and text was deleted in revision 5.
1 D.7 Response to Anomalous NCS Conditions This task is considered completed and text was deleted in revision 5.
i D.8 NCS Oversight on the Operating Floors This task is considered completed and text was deleted in revision 5.
Task 20 NCS Field Operational Assistants This task is considered completed and text was deleted in revision 5.
Task 21 Fissile Material Operation (FMO) Identification
- This task was reopened to confirm FMOs are properly identified and enhance the documentation associated with the identification of FMOs.
Task 22 Compare SAR Chapter 5.2 to Applicable Industry Standards and the NCS Program This task is considered completed and text was deleted in revision 5.
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GDP 99-2020 Page 5 of 5
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Task 23 Short Term Corrective Actions This task is considered completed and text was ' deleted in revision 5.
Task 24 PEH Deposit Surveillance Tracking This task is considered completed and text was deleted in revision 5.
Task 25 Compliance Plan Review This task is considered completed and text was deleted in revision 5.
Task 26 NCSA/E Calculation Review This task is considered completed and text was deleted in revision 5.
Attachments Table 1, Root Cause by Process Block Number, on page 20 of revision 4 was deleted.
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y GDP 99-2020 Page1of3
' April 1999 Quarterly Status Report of the PORTS Nuclear Criticality Safety Program Corrective Action Plan I.
Purpose To convey the status of the tasks in the NCS CAP.
1 II.
Scope This report covers the four open tasks (numbered ',5,8, and 21) in Revision 5 of the NCS CAP. The report period is from January 21,1999, to April 20,1999. Note: Target dates are shown on Attachment 1 of revision 5 of the NCS CAP (Enclosure 1).
III.
Executive Summary Two milestones were met: PORC approved 36 of 40 Priority 1 NCSA/Es by March 19,1999, and the associated AQ-NCS classification of structures, sy stems, and components (SSC) was completed for these 36 Priority 1 NCSA/Es by April 9,1999. Four Priority i KCSA/Es are still being upgraded (reference GDP 99-0050, Ated March 19, 1999). One Prioirty 1 NCSA/E (0326_024.A04) of the 36 has been deleted subsequent to its PORC approval and AQ-NCS classification being completed. Additionally,19 Priority 1 NCSA/Es were upgraded and PORC approved during this report period.
i A review (using a checklist aad criteria) of revision 4 Non-Priority 1 NCSA/Es was completed to determine the NCSA/Es that require upgrading as Priority 2. New listings of Priority-2 NCSA/Es and NCSA/Es requiring " Additional Review" were developed.
Upgrading of Priority 2 NCSA/Es has started with 13 in NCS engineeering review.
IV.
Details of Open Tasks Tnd 3 NCSA/E Upgrade Project Revision 4 of the NCS CAP identified 54 Priority 1 NCSA/Es to be upgraded.
Fourteen of these NCSA/Es were consohdated into other Priority 1 NCSA/Es and i
1 GDP 99-2020
' Page 2 of 3 NCSA/E 0326_024, Feeding of 5-inch,8-inch, and 12-inch Cylinders in the X-326
' Product. Withdrawal Area, was' deleted because this activity is no longer being j
performed. The number of Priority 1 NCSA/Es is 39. Two NCSA/Es were
' implemented during this report period. _ As explained in the cover letter, U5uC has :
identified that AQ-NCS requirements were not fully implemented for five Priority 1 NCSA/Es previously reported as complete.
PORC approval of 36 Priority 1 NCSA/Es was completed'by March 19,1999.' AQ-NCS classification for these 36 NCSA/Es was completed by April 9,1999. PORC
' approval and AQ-NCS classification of the 4 remaining Priority 1 NCSA/Es is on schedule.
The following chart illustrates the status of Priority. I and Priority 2 NCSA/Es:
Priority IStatus l Priority 1 Status Priority 2 Status
' Activity 01/20/99 04/20/99 04/20/99 Approved and Implemented 8
4 0
Implemented with AQ-NCS 0
5 0
flow-down in proc ~ess
' Approved by PORC and 13 26 1
awaiting implementation Scheduled for PORC review 4
0 0
Reviewed by NCS 4
0 0
Subcommittee and being Prepared for PORC Review Scheduled for NCS 9
0 0
Subcommittee In Peer Review ~
2 4
1 Started NCS Engineering 0
0~
13 Review-Not Started.
0 0
12 Total 40 39 27 l
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P, GDP 99-2020 Page 3 of 3 The upgrading of Priority 2 NCSA'Es is in progress (e.g., a schedule was established, assignments for upgrading NCS A/Es were made, and changes to NCSA/Es are being
_ evaluated). One Priority 2 NCSA/E has previously been upgraded and approved by PORC.
NCSA/Es not classified Priority I or 2 upgrade will receive additional review.
Although some initial review activities are complete; the details of the additional review process, final expectations and acceptance criteria, and coordination with other I
NCS CAP activities are being planned.
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' Task 5 SS&Q Review ofImplementation Two SS&Q walkdowns are in progress for the two NCSA/Es that were implemented during this report period.
Task 8 Vertical Slice Review Although problem reports were processed where applicable and some corrective actions were completed, this task was reopened because resolution of the recommendations, observations, caJ concems in the final signed version of the NCS Vertical Slice Report is still in progress. A review of the entire report was performed
- and there are no outstanding safety significant concerns. Although many of the recommendations and concerns from the report have already been incorporated in'.o approved NCS procedures, the recommendations, observations, and concerns were
'b recently reassigned to ' applicable organizations for additional evaluation and resolution. After corrective actions have been completed, the documentation for this task will be reviewed and consolidated to ensure a proper close-out of the report.
Task 21 Fissile Material Identification A procedure for confirming and documenting the identification of FMOs is being planned. Work has not started on walk-downs or verifications for this task.
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