ML20217F824

Criticality Safety Program Update Fourth Quarterly Status Rept

ML20217F824
Person / Time
Site:	07000036
Issue date:	09/30/1997
From:	ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY
To:
Shared Package
ML20217F788	List: ML20217F783 ML20217F824
References
ZAR-970930, NUDOCS 9710090062
Download: ML20217F824 (11)

Text

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!!nclosure I fo llA97/629 I

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i CRITICALITY SAFETY l'ROGRAM UI'DATE FOURTil QUARTERLY STATUS REPORT 1

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1 COMilUSTION ENGINEEltlNG,INC, September 30,1997 1

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INTI(OI)UCTION Findings fiom our self assessment program, as emphasized during NFC inspection 70 36/96 202 highlighted the need for increased documentation and Ibrmalization of our criticality safety program. Speellically identified were the need to expand and strengthen procedures, provide additional training to personnel involved with SNM handling and processing, and streamline the change management and configurmion control process. It was decided to develop a comprehensive improvement plan that would encompass all aspects of criticality safety. This plan, called the Criticality Safety Program Update (CSPU). was presented at a management meeting held at NRC lleadquarters on August 14,1996. A further description of the plan elements was submitted to the NI(C 1.icensing liranch on September 20,1996. The CSPU consists of two major elements: The Administrative Update and the Analysis Update. The Administrative Update addresses programmatic revisions and the Analysis Update will result in improved safety bases documentation. This report is the lhurth quarterly status report on the progress made in implementation of the USPU plan. The first quarterly progress report was su5mitted on December 20, 1996, the second on March 27.1997 and the third on.'une 27,1997 Since the milestones fbr the remainder of the program are less fiequent, it is proposed that status reports be submitted semiannually. If this is agreeable, the fifth status report will be submitted by March 31,1998.

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AI)MINISTitATIVE UPI) ATE STATUS The progress made and status of plan elements as described in our September 20 plan to date are shown below.

1.

Present plan to NRC The Criticality Safety Program Update was presented to the NRC on August 14.1996.

Status: Complete.

2.

Submit reply to criticality safety NOV from inspection 96 202 The reply to NOV 96 202 was submitted on September 13,1996.

Status: Complete.

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3.

Submit plan to NilC The Criticality Safety Program Update plan and schedule was submitted to NRC on September 20,1996.

Status: Complete.

4.

Quarterly Progress Iteport to NRC 1

This report is the fourth quarterly status report on the progress made in implementation of the CSPU plan.

l Status: As scheduled. The administrative goals and criteria of the CSPU have essentially been met, with the remainder of the program being implemented in conjunction with the ISA schedule.

l S.

Itevise ISA schedule A letter transmitting a revised schedule and scope for conducting the ISAs was submitted to NitC on November 12,1996.

Status: Complete. On November 19,1996, NitC replied that the revised schedule is acceptable.

111.

CONitlG UltATION CONTilOL STATUS 1,

llevise Change Management Process The level of review required and the responsibilities concerning plant change management were to be specified. The required scope ofinput to a change request was to be defined. The various procedures governing change management were to be integrated into a nmre efficient and harmonious change program, lilements of the task were

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170rm team:

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listablish requirements

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Proceduralize:

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Automate Change Management Process:

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Status: On Schedule. A document management sothvare package has been selected. This software will be evaluated Ihr use in the change 4

management process and, ifit proves satisthetory, will be used for other procedures and programs (see Centralize Document Control, below).

l 2.

Centralize Document Con'ml Document control has br n centralized in lluilding 110 (the front office building) Change man >genn:nt packages are being added to the Central Document Control system when completed. Additional documentation resulting from the CSPU will be added when generated and approved.

Continuing improvements are underway to enhance the quality of records keeping. A number of document management programs were evaluated for use by Central Document Control. An electronic tool has been selected and is being modified to provide adequate coverage of the change i

management program requirements. The process will then undergo testing i

nrior to site wide implementation.

3.

Surveillance testing The installation of the Preventive MaintenanevCalibrations program.

Nuclear criticality safety inspections, maintenane and calibrations 4

required by license are to be tracked by this program to ensure they are performed on schedule.

Status: A PM database has been established Ihr Plant Facilities and for Production. Virtually all major pieces of production equipment have now been entered into the production database items continue to be added to both databases as requested by process engineers and llegulatory Affairs.

4.

Criticality Safety Program (Program Document RAAP-109)

Status: Complete. This document has been approved and issued.

5.

Criticality Analysis Procedure (Program Document RAAP 108)

Status: Complete. This document has been approved and issued, i:

6 Commitment / Corrective Action Tracking (Program Document RAAP 102)

Status: Complete. This document has been approved and issued.

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7.

NitC Reporting llequirements (Program Document RAAP 104)

Status: Complete. This document has been approved and issued.

8.

Abnonnal Event / Occurrence Reporting (Program Document RAAP 105) l Status: Complete. This document has been approved and issued.

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Record Retention (Program Document i(AAP 107) 1 Status: Complete. This document has been approved and issued.

10. Document Control (l'rogram Document RAAP 111)

Status: Complete. This document has been approved and issued.

I1. License Change (Program Document RAAP 112)

Status: Complete. This document has been approved and issued.

12. Safety Related Documents (Program Document RAAP ll3)

Status: Complete. This document has been approved and issued.

13. Safety Related Positions (Program Document RAAP 116)

Status: Complete.

14. Organization and Responsibilities (Program Document AD 1)

Status: On plan for completion in October,

15. Update of Emergency Plan implementing Procedures (EPIP)

Status: Complete. The Emergency Plan Implementing Procedure (EPIP) regarding the nuclear criticality program was evaluated in conjunction with the information produced from the CSPU and found to include an adequate response in the event of a Nuclear Criticality Safety (NCS) incident.

16. Description of NCS Alann System Status: Complete.

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1.lCENSE UPDATE 1.

llevise chapter 4 of SNht 33 Chapter 4 of SNht 33, Nuclear Criticality Safety has been revised to incorporate applicable portions of the CSPU. Typographical errors were corrected and license conditions reworded to clarify their meaning. An amended Chapter 4 was submittea :o NitC 1.icensing April 17,1997.

Status: Waiting for NI(C response to amendment request.

IV.

TRAINING l.

Training Program (llAAP 121)

Status: Complete.

2.

Professional training for hinnagement Supervisors and Engineers Status: Process engineers received training on the Criticality Analysis Procedure, ilAAP 108, h1 arch 31,1997. Supervisors received training on internal reporting of NCS events in September 1997. Additional training will be conducted as the CSPU progresses.

3.

Operators Continued training is to be provided to operators in the area of Nuclear Criticality Safety. The training includes safe movement and storage of material, the requirements of the NitC license, and internal procedures.

Status: A continuing program of short, topical criticality safety training on a weekly or biweekly schedule has been instituted. The training subject is generally chosen from in-plant observations by regulatory personnel. The primary recipients of the training have been Ceramics factory operators.

Additional refinements to the nuclear criticality safety section training document, OlT 27, have been made based on lessons learned from the ISA and NCS evaluation of this area.

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9 V.

SELF ANNI'SSMI NT PitOGitAM 4

1.

Internal Audits / Inspections Procedure (Program 1)octunent ilAAP 110)

Status: Complete.

VI.

ANAINSIS UPDATE l.

Con \\ ersion

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Plant configuration: Update P&lDs: and drawings

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Safety liasis: Iteview and revise as required Monte Carlo and hand analyses with attendant criticality safety evaluations.

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ISA: lleview and revise as required.

Status:

Complete.

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Itecycle/Itecovery a)

Plant configuration: The current plant contiguration and process flow diagrams will be reviewed against existing documentation. The ibliowing items will be verified and updated as required:

i)

P&lDs: Schematic diagram ofitems with safety implications, ii) Drawings: 1.ayout drawings of the relative positions and critical dimensions of equipment in which the accumulation of more than a safe mass of SNM is possible.

Status: P&lDs are complete. Drawings are on schedule, b)

Safety liasis: Documentation including Kl!NO analyses, hand calculations, and change requests will be reviewed and revised as necessary.

Status: Documentation pertaining to the liquid waste systems was reviewed in conjunction with the proposed contiguration changes.

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c) livaluation: Aller the existing documentation is assembled, each category, process, or piece of equipment as appropriate will be reviewed to identify any assumptions, bounding conditions, upset conditions, contingencies, margin to criticality, and NCS barriers.

Status: This evaluation was completed for the liquid wastes systems.

d)

Analy sis Upgrade: The nuclear caiticality safety analysis will be updated if required.

Status: An updated nuclear criticality safety evaluation was prepared for the liquid waste systems.

e)

ISA: The ISA team will use the above intbrmation during its assessment.

Status: The ISA team used the updated nuclear criticality safety evaluation during its assessment of the changes and operation of the modified liquid waste systems.

VI.

SUMMAltY Progress this quarter on the CSPU plan was generally as scheduled.

Iteview of criticality safety evaluations based on revised analyses of the conversion process were completed. Administrative procedures were essentially completed, lirequent on shill training of operators continues.

Supervisory personnel received professional training. As scheduled, the focus will now shill to the critier'ity analysis update of the recycle / recovery process.

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