ML20217B379

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Rev 6 to Plan for Achieving Compliance W/Nrc Regulations at Portsmouth Gaseous Diffusion Plant
ML20217B379
Person / Time
Site: Portsmouth Gaseous Diffusion Plant
Issue date: 03/16/1998
From:
UNITED STATES ENRICHMENT CORP. (USEC)
To:
Shared Package
ML20217B359 List:
References
DOE-ORO-2027, NUDOCS 9803260051
Download: ML20217B379 (6)


Text

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GDP 98-0048 Revision 6 to DOFJORO-2027

" Plan for Achieving Compliance With NRC Regulations at the Portsmouth Gaseous Diffusion Plant" 9903260051 990316 POR ADOCK 07007002 PDR g.

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Revision 6 to DOE /ORO-2027 Plan for Achieving Compliance With NRC Regulations at the Portsmouth Gaseous Diffusion Plant Removal / Insertion Instructions Remove Pages Insert Pages issue 24 Issue 24 Pages 3/4,5/6 Pages 3/4,5/6

Maimenance Program '

Issue 24, Page 3 in addition, the maintenance organizations have initiated special provisions and ; interim

'. commitments for the safety systems. These provisions, which are now in place and are incorporated into 4'

existing procedures,' and will be incorporated into new procedures as they are developed, include the following actions.

1.

~A work package is prepared prior to commencement of any corrective maintenance work on safety l

systems. The minimum requirements of a work package for safety system maintenance include: a l

maintenance service request; a planning checklist; written work instructions; and a safety system - l data sheet, which provides verification of post maintenance testing. Depending on the scope of the work, the package may also include equipment specific procedures or checklists and quality control inspection, nuclear criticality safety analysis, radiation protection, OSHA, or operational l

requirements. The composition of a work package is dependent on the maintenance to be performed and is defined in the work control procedure.

E 2.

Systems engineers have been assigned specific responsibility for the technical aspects of designated safety systems. The systems engineers provide technical support for maintenance activities of these systems, including assistance in work package preparation, determination of post maintenance test requirements, observation of surveillance testing, review of procedures, and input to the plant preventive maintenance program. Systems engineers are required to have an engineering education

.or an appropriate technical background and a basic knowledge of plant systems, principles of gaseous diffusion, administrative procedures and policies, plant layout and location of components of assigned systems, technical specifications, and in-service inspection requirements.

Interim Regulatnrv Commitments The following commitments derived from the ROA requirements will remain in efrect until replaced by Application commitment implementation.

1.

A corrective maintenance program shall be implemented to ensure that prompt and effective maintenance is performed on malfunctioning nuclear safety systems, safeguards, and security equipment.

I 2.

A preventive maintenance program shall be implemented to ensure the operability of nuclear safety systems, safeguards, and security equipment.

?3.

A documented instrument calibration program, employing standards traceable to the national standards system or to nationally accepted standards, shall be implemented for the calibration of equipment and monitoring devices necessary for the proper maintenance and operation of nuclear safety systems and safeguards equipment.

4.

Controls shall be established to ensure safety systems are not disabled or diminished by planned activities.

L5....

. Work on safety systems shall be controlled and performed with the use of approved procedures l

and/or work instructions. The procedures and work instructions shall be based upon established and l

well-recognized codes and standards in applicable areas such as welding, l

PORTS Rev. 3,7/9/96

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Issue 24. Page 4 Maintenance Program electrical, piping, and instrumentation. As applicable, codes and standards shall be identitled in the procedures as source references, PLAN OF ACTION AND SCHEDULE The actions required to complete the maintenance program are the following:

Develop and implement a maintenance history program. The scheduled completion date for this action is September 30,1997.

Develop a master equipment list for safety critical equipment.

Implement a new computer-based maintenance management system with the capability to collect and trend the data.

Develop guidance for cleanliness control and measures to prevent entry of extraneous material into a closed system. The scheduled completion date for this action is July 31,1996.

Upgrade the current work control process to provide the committed level of planning and work package development for Q, AQ-NCS, and other AQ items. The scheduled completion dates for these actions are Febmary 28,1997, for AQ-NCS items; April 30,1997, for Q items; and June 30, 1998, for other AQ 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.

Upgrade the preventive maintenance program to meet the commitments for greater formalism. The scheduled completion dates for these actions are February 28,1997, for AQ-NCS items: March 31, 1997, for Q items; and June 30,1998, for other AQ items.

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 technical / historical basis for use in evabating preventive maintenance task adequacy.

l.

Revise the measuring and test equipment and process equipment calibration programs to meet the more formal requirements. The scheduled completion dates for these actions are December 31,1996, l

for Q SSCs; February 28,1997, for AQ-NCS SSCs; and June 30,1998, for other AQ SSCs.

Implement procedures that define and control the overall measuring and test equipment program. (Complete)

PORTS Rev. 6,3/12/98

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i Maintenance Progrmn Issue 24, Page 5 1

Develop and implement individual calibration procedures for Q, AQ-NCS, and other AQ SSCs and for M&TE.

l Provide training on calibration requirements to affected coordinators, managers, technicians, and users.

l Identify the procedural deficiencies for performing corrective maintenance, preventive maintenance, calibration, and surveillance testing of Q, AQ-NCS, and other AQ SSCs, and develop a composite listing of the procedures requiring revision, development, or conversion. The scheduled completion dates for these actions are October 31,1996, for Q SSCs; January 31,1997, for AQ-NCS SSCs; and October 31,1997, for other AQ SSCs.

Develop procedures and provide the associated training of appropriate personnel for the performance of surveillance tests which are required to support Technical Safety Requirements. This action will -

be completed prior to the NRC assuming regulatory authority.

Revise, develop, or convert corrective maintenance, preventive maintenanco, calibration, and l

surveillance test procedures for Q, AQ-NCS, and other AQ SSCs. The scheduled completion dates l

for these actions are February 28,1997, for AQ-NCS items; March 31,1997, for Q items; and June 30,1998, for other AQ items.

Develop training materials for the work control, surveillance testing, instrument calibration, and l

l corrective and preventive maintenance procedures and provide the associated training of appropriate l

personnel. The scheduled completion dates for these actions are February 28,1997, for AQ-NCS items; March 31,1997, for Q items; and June 30,1998, for other AQ items.

Identify and control the vendors' manuals used for maintenance of Q equipment, including entering l

them into the document control and records management system. The scheduled completion date fer this action is March 31,1997.

Identify vendor manuals used for maintenance activities of Q equipment.

Verify appropriate vendors' manuals for accuracy and completeness.

l Enter vendor manual data into the records management and document control system.

The procedure upgrades and associated training to address this area of the noncompliance will be completed in coordination with the plans and schedules set forth in the Compliance Plan issues " Procedures Program" and " Systems Approach to Training."

l l

PORTS Rev. 6,3/12/98

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Maintenance Program issue 24, Page 6

SUMMARY

OF REQUIREMENTS, COMMITMENTS AND NONCOMPLIANCES Issue: Maintenance Program Code of Federal Regulations Part l

Title 10 76.87(c)(7)

Application Commitment Section Safety Analysis Report 3.5.1, 5.3.5, 5.6.5, 5.6.5.1, 5.6.5.2, 5.6.5.3, 5.7.3, 5.7.3.2, 5.7.3.4, 5.7.3.5, 6.1.1, 6.1.1.9, 6.1.1.1 I,

l 6.1.1.14,6.1.1.20,6.1.1.25,6.3.5.2.3.6, l

6.3.5.2.4.2, 6.3.5.4.2, 6.3.5.6, 6.3.5.7, 6.4, 6.5.7, l

6.6.1, 6.6.3, 6.6.3.1, 6.6.5, 6.6.13, 6.8.2.2, 6.8.2.3, 6.8.2.4, 6.10.1.13, 6.1 1.1, 6. I 1.5, 6.1 1 -A ppendix l

A l

l Technical Safety Requirements 3.2.2.b, 3.9.1, 3.15, 3.24 l

Fundamental Nuclear Materials Control 2.2.7, 2.6,4.1,4.1.1,5.1.2,5.2,5.2.1, 5.2.3, 13.1 Plan l

Emergency Plan 4.1.5, 7.6, 8.2 l

Quality Assurance Program 1-2.18, Appendix A Application Noncompliance Statement Section Safety Analysis Report 6.4.13.1,6.4.13.2, 6.4.13.3, 6.4.13.4, 6.4.13.5 PORTS Rev. 3,7/9/96

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