20140617 PPPO-02-2300999-14 Environmental Management … · 2021. 1. 2. · DSA Documented Safety Analysis EOC Emergency Operations Center ... OGRU Oil and Grease Removal Unit ONG

�

�

�

�

�

�

�

�

�

�

�

FBP-NSE-RPT-00014 Rev.1 Extent of Condition Review on Deferred Maintenance

Applicable for the Fluor-B&W Portsmouth LLC (FBP) Project

June 4, 2014

�

�

�

�

�

��

�

�

�

FBP-NSE-RPT-00014 Rev.1 Page 2 of 47

�

�

TABLE OF CONTENTS

�

TABLES & FIGURES ................................................................................................................................ 5�

ACRONYMS ............................................................................................................................................... 6�

1.� EXECUTIVE SUMMARY .................................................................................................................... 8�

2.� INTRODUCTION ................................................................................................................................ 10�

3.� APPLICATION OF RESOURCES TO SYSTEM & EQUIPMENT MAINTENANCE ............... 12�3.1 Lifecycle Overview�................................................................................................................�12�

3.2 Evolution of the S&M Budget�...............................................................................................�12�

4.� MAINTAINING CONFIGURATION CONTROL ........................................................................... 14�4.1� Configuration Management Program Overview�..................................................................�14�

4.2� CMP Challenges�...................................................................................................................�18�

5.� NECESSARY UPGRADES TO SUPPORT SYSTEM INFRASTRUCTURE ............................... 20�5.1� Mechanisms being Implemented to Enhance System and Infrastructure Reliability�..........�21�

6.� IMPACT OF EQUIPMENT CONDITION ON FACILITY OPERATIONAL READINESS ..... 25�6.1� Process Building Roof Repairs/Facility Conditions�..............................................................�25�

6.2� X-530 Switchyard�.................................................................................................................�26�

6.3� Air Plant �............................................................................................................................�27�

6.4� Public Address (PA) System�.................................................................................................�29�

6.5� X-690 Steam Plant�................................................................................................................�30�

6.6� Sewage System�......................................................................................................................�30�

6.7� Raw Water System�...............................................................................................................�31�

6.8� Water Treatment Plant X-611�..............................................................................................�31�

6.9� X-705 Facility�.......................................................................................................................�32�

6.10�Fire Protection and Suppression Systems�..........................................................................�32�

6.11�UF6 Transfer�.......................................................................................................................�33�

6.12�Groundwater Treatment Facilities (GWTF)�......................................................................�34�

6.13�Air Monitoring Network�.....................................................................................................�34�

6.14�Groundwater Monitoring Network�....................................................................................�35�

6.15�X-120H New Weather Tower�..............................................................................................�35�


�

�

6.16�Holding Ponds�.....................................................................................................................�35�

6.17�Single Point Failures�...........................................................................................................�35�

7.� BACKLOGS AND TRENDS ............................................................................................................... 38�7.1� Total Backlog Performance�..................................................................................................�38�

7.2� Corrective Maintenance Backlog Trend�..............................................................................�38�

7.3� Preventive Maintenance Performance�.................................................................................�41�

7.4� Planned Maintenance Improvements�...................................................................................�42�

7.5� Average Age of Open Corrective Action Process Items�.......................................................�44�

7.6� Number of Corrective Action Process Items Overdue�.........................................................�45�

7.7� Number of Personal Radiological & Chemical Contaminations�..........................................�46�


�

�

TABLES & FIGURES �

Table 3.1 FY14 Budgets and Variance – Utilities & Maintenance Budgets Were 50% Low 13 Figure 4.1 Configuration Management Program Effectively Integrates Design Control, Work Control,

Change Control, Assessment, and Document Control to Assure Configuration Control 15

Table 4.1 The Number of Engineering Service Orders Are High and Growing 16

Table 4.2 Number of USQ Evaluations Is High and Growing 17

Table 4.3 Engineering Service Orders to Re-establish Accurate Documentation of Plant Configuration 18

Table 4.4 Engineering Service Orders Related To Retrofit of Components or Requirements 19

Table 5.1 PORTS System Health Report for April 2014 22

Table 6.1 Summary of X-330 Dry Air Plant Issues 28

Table 6.2 Summary of Power and Utilities Operations – Single Point Failures 36

Figure 7.1 Total Backlog Performance 38

Figure 7.2 CM Backlog Aging Report – April 2014 39

Figure 7.3 CM Backlog Aging Report – Safety Related Systems 40

Figure 7.4 CM Backlog Aging Trend – Regulatory Systems 40

Figure 7.5 CM Backlog Aging Trend – General/Balance of Plant Systems 41

Figure 7.6 Open PMs in Grace Period 42

Figure 7.7 Delinquent PM’s – June 2013 –Present 43

Figure 7.8 Open Issues & Action by Age as of April 2014 45

Figure 7.9 Ratio of Open Issues to Issues Generated vs. Month Shows Number of Open Issues Growing 46

Figure 7.10 % Issues Overdue vs. Month through April 2014 46

Table 7.1 Non-Reportable Skin and Clothing Contamination Events Since March, 2012 47

Table 7.2 Chemical Exposure Events since April 2012 48


�

�

ACRONYMS

ACP American Centrifuge Plant ADT American District Telegraph AEC Atomic Energy Commission BOP Balance of Plant BWCS Babcock& Wilcox Conversion Services CAAS Criticality Accident Alarm System CFR Code of Federal Regulations CI Configuration Item CM Corrective Maintenance CMP Configuration Management Program DAP Dry Air Plant D&D Decontamination and Decommissioning DOE U.S. Department of Energy DOS Disk Operating System DPC Digital Programmable Controller DSA Documented Safety Analysis EOC Emergency Operations Center ERDA Energy Research and Development Agency ESO Engineering Service Order FBP Fluor-B&W Portsmouth LLC FY Fiscal Year FERC Federal Energy Regulatory Commission PORTS-GDP Portions of the Portsmouth Gaseous Diffusion Plant GWTF Groundwater Treatment Facilities GSM Greater than Safe Mass HF Hydrogen Fluoride HMI Human Machine Interface HPFW High Pressure Fire Water ISMS Integrated Safety Management System ITS Issue Tracking System IWCP Integrated Work Control Program LCO Limiting Condition for Operation LLC Limited Liability Company MW Megawatt NEC National Electric Code NCS Nuclear Criticality Safety NERC North American Electric Reliability Council NFPA National Fire Protection Association NPDES National Pollutant Discharge Elimination System NRC Nuclear Regulatory Commission NRTL National Recognized Testing Laboratories OGRU Oil and Grease Removal Unit ONG Ohio National Guard OOS Out-of-Service ORPS Occurrence Reporting and Processing System OSWDF Onsite Waste Disposal Facility PA Public Address System


�

�

PCM Personnel Contamination Monitor PEH Planned Expeditious Handling PGE Process Gas Equipment PIP Performance Improvement Plan PIT Process Improvement Team PM Post Maintenance PORC Plant Operations Review Committee PORTS Portsmouth Gaseous Diffusion Plant PPE Personal Protective Equipment PR Problem Report PSPI Process Systems Power Improvement QA Quality Assurance RCM Reliability Centered Maintenance RCW Recirculating Cooling Water RFP Request for Proposal RICE-MACT Reciprocating Internal Combustion Engine Maximum Achievable Control Technology RMDC Records Management Document Control SAFA Superior American Fire Alarm SCADA Supervisory Control and Data Acquisition S&M Surveillance and Maintenance SHR System Health Report SMIDD Site Maintenance/Infrastructure/Deactivation & Demolition SRD System Requirements Document SSC System, Structure, Component TCE Trichloroethylene TSR Technical Safety Requirements USEC United States Enrichment Corporation USQD Unreviewed Safety Question Determination WC Work Control WEMS Wasren-EnergX Mission Support, LLC


�

�

1. EXECUTIVE SUMMARY�Portions of the Portsmouth Gaseous Diffusion Plant (PORTS GDP) were returned to DOE from a private operator in FY2011, and the entire site was turned over to the current DOE contractor (Fluor-B&W Portsmouth LLC) in FY2012. During the two years since, a number of unexpected vulnerabilities have emerged as a consequence of the generally poor infrastructure conditions at turnover from the previous private operator, and the combined effects of plant age (greater than 60 years) and shutdown of enrichment operations. As these problems were revealed, a number of proactive initiatives were undertaken to maintain and upgrade the most critical infrastructure systems. In January and February of 2014, however, the Midwest region of the United States, including the location of PORTS GDP, experienced multiple polar vortices, which revealed additional and unexpected vulnerabilities to essential systems, including in particular dry pipe fire suppression systems in the process buildings. As a collective consequence of these factors, more resources have been and will be required to maintain and upgrade PORTS critical system infrastructure than had been originally planned.

This report was prepared to provide an initial extent of condition review assessing the adequacy of resources applied to PORTS for system and equipment maintenance, to maintain up-to-date configuration control, and to make necessary upgrades to support the system infrastructure. This report also contains an assessment of the cumulative impact of the combination of degraded equipment on overall facility operational readiness. The factors considered in these reviews include corrective and preventive maintenance backlogs, age, and trends; issues management; and personnel radiological contamination and chemical exposure events.

Based on these reviews, FBP concludes the following regarding the current status of PORTS infrastructure and the associated maintenance deferral trends:

1. Proactive initiatives have been undertaken to maintain and upgrade the most critical infrastructure systems; more are needed, and some are planned to be completed this year and next

2. The required safety envelope has been maintained 3. In many cases, efficacy of safety management programs (SMPs) and the associated defense-in-depth for

site nuclear facilities is eroded due to age-induced problems with safety-related systems and increasing reliance on compensatory measures in lieu of restoration.

4. Mission risks remain elevated as corrective and preventive maintenance backlogs continue at a high level and essential infrastructure systems become impaired

5. Resources currently committed to infrastructure and maintenance activity and support must be significantly increased to stabilize and ultimately reverse these negative trends

6. PORTS should continue to develop, implement, and improve mechanisms to optimize resource application to facility and equipment maintenance to more effectively and efficiently preserve defense-in-depth and manage mission risk.

Infrastructure upgrades and repairs to improve reliability and availability of critical SSCs had been made earlier in the contract period, and more are planned for FY14 and FY15. Upgrades/repairs in FY14 include: switchyard improvements to address vulnerabilities to the plant high-voltage switchgear; roof structures in active nuclear facilities; emergency response warning and communication systems; and the plant dry air system. Upgrades in FY15 include: other critical roof structures; 13.8kV electrical power distribution; weather enclosure for the X-690 steam plant; completion of repairs to the X-670 dry air plant; repairs/upgrades to the HPFW system and nuclear facility fire suppression systems, and emergency vehicle replacement. These improvements will re-strengthen defense-in-depth and reduce mission risk profile.

PORTS has implemented or is developing several initiatives to identify and prioritize corrective and preventive maintenance and needed infrastructure upgrades in a manner that optimizes the application of resources to preserve safety margins and manage mission risk. These initiatives include mechanisms to monitor and report critical system health, inspect and evaluate safety-related structures, and to integrate this information into a


�

�

comprehensive reliability-centered maintenance program and into a more formalized maintenance prioritization process. PORTS has also developed a Utilities Infrastructure Plan that summarizes the critical utility systems required to sustain the PORTS D&D mission. This document provides a strategic planning framework to support the five-year/ten-year site goals. Conditions will be monitored and vulnerabilities will be identified, prioritized, and corrected on the basis of ongoing mission need. This plan will also be used to identify opportunities to abandon or isolate infrastructure that is no longer required to sustain the PORTS mission.

These initiatives notwithstanding, preventive and corrective maintenance backlogs are high and rising. The growth trend is continuing as more work requests and related engineering service requests are being received each month than can be closed. Despite these trends, PORTS has continued to prioritize requests based on safety and compliance requirements to preserve the plant’s safety envelope.

Control accounts related to utility, infrastructure, and balance-of-plant surveillance & maintenance currently project a 50% negative variance for FY14. Even after accounting for acute events (mainly polar vortex conditions in January and February of 2014), the data indicate a chronic budget deficit for these areas and systems, whose performance capability must be maintained to support both the near term safety of PORTS and the remaining project lifecycle. Primary contributing factors to this deficit and to the accumulation of the maintenance backlog include:

1. age;2. obsolescence; 3. historical neglect of systems and equipment as received from the previous contractors; 4. legacy deficiencies in configuration management; 5. shutdown of enrichment operations, which has accelerated the decline in certain structures and critical

systems; 6. increased rigor and formality with which maintenance work is planned and controlled.

The plant’s current configuration management program has been effective in maintaining configuration control of safety related SSCs. It has also been effective at confirming or re-establishing configuration control on other systems as they are upgraded, repaired, or maintained. However, historical deficiencies in configuration management – including undocumented plant modifications, failure to maintain as-built drawings, missing technical information, failure to maintain compliance with changes in applicable industry standards, and degraded facility/equipment condition - have resulted in substantially more time and effort than originally planned to accurately verify and document system configuration in order to ensure that pending maintenance and upgrade work could be accomplished safely and reliably.

Deficient facility and equipment conditions have diminished operational readiness of some facilities and systems, including ones on which other site tenants rely for utility service. Required safety margins have been preserved through various actions including suspension of the operation protected by the impaired SSC, implementation of compensatory measures, and reduction/control of relevant hazard(s). Additional actions to improve safety and reduce vulnerability to equipment failures include contingency planning, identifying and correcting single-point failures, and re-directing resources to address highest priority system deficiencies. Nevertheless, defense-in-depth has been weakened, reliability issues persist, and the capability and reliability of critical systems has diminished.

In conclusion, this evaluation finds that dedication of DOE resources to the support of PORTS infrastructure and maintenance activity must be significantly increased to fully restore defense-in-depth protections, to improve critical infrastructure reliability and availability, and to stabilize and reverse the deferred maintenance trends. �


�

�

2. INTRODUCTION

This extent of condition review arose from problems revealed by recent events at the Waste Isolation Pilot Plant; one of the early “lessons learned” is that nuclear facilities “must not accept, tolerate, or otherwise justify out of service safety-related equipment.” As the Portsmouth GDP (PORTS) transitions from nuclear operations, to deactivation, to demolition (and will find itself simultaneously in all of these life cycle phases - as well as new construction and start-up - for years to come), this matter is one that will require continuous attention and action.

The PORTS mission is to D&D the uranium enrichment facilities and remediate the site for future use. For the nuclear facilities, FBP is in the process of deactivating the enrichment process buildings, operating the X-340 complex to support the uranium barter program, and providing the support services required for the deactivation work (e.g. decontamination services, uranium deposit storage and processing, laboratory support, radioactive and hazardous waste management, storage and shipping, maintenance support including instrument calibration, etc.) FBP is also responsible for providing site infrastructure support services including utilities, site control, security and emergency response. These services will continue to be required, in gradually diminishing degree, as the process building deactivation and D&D progresses. Power, sanitary water, sewage and fire protection services are also provided to American Centrifuge Plan (ACP), B&W Conversion Services (BWCS) and Ohio National Guard (ONG). FBP also supplies high pressure fire water (HPFW), natural gas and dry air to ACP. Many of these services would also be required to support the possible construction and operation of an Onsite Waste Disposal Facility (OSWDF) and the completion of site remediation for future re-industrialization. The nuclear facilities and their required support systems require adequate maintenance to assure safety; site utilities must be effectively maintained to ensure sufficient reliability and availability to meet the demands of FBP and other site tenants; the Systems, Structures and Components (SSCs) and facilities utilized for site control, security and emergency response require adequate maintenance to assure that they are available and reliable upon demand. Unchecked degradation of these systems and infrastructure erodes plant defense-in-depth protections and operating margins.

The Portsmouth Gaseous Diffusion Plant (PORTS) functioned for over 50 years producing enriched uranium for commercial and defense applications. Due to national security and location constraints, PORTS was designed and functioned to provide almost all of the required services onsite to support the uranium enrichment mission. In 2001, the uranium enrichment process was shut down as a production operation, but portions of the enrichment process and support facilities continued nuclear operations to support various DOE mission activities (e.g. removal of residual uranium deposits and recovery of DOE UF6 inventories). Thus, when PORTS was transferred back to DOE control and regulation, many of the previous nuclear operations were ongoing.

While approximately four years of preparation preceded the transition of the facility from DOE to USEC operation and NRC regulation, there was about six months of transition in returning some facilities to DOE at the beginning of the FBP contract (March 2011), with full transition of all facilities and utility infrastructure occurring September 30, 2011. The transition of all site facilities to FBP management had not originally been proposed to be completed for several years, by which time operations in the major nuclear facilities were expected to have been concluded and the facilities in “cold and dark” condition. While nuclear safety was maintained during the transition and afterward, there were many compliance issues in transitioning from NRC to DOE regulation. Accordingly, significant effort during the first year following completion of transition was devoted to fully consolidating sixteen major functional area programs from two legacy operators into one set of DOE-compliant safety management programs and processes, which was completed in September 2012.

Currently, PORTS has eight Category 2 nuclear facilities in operation (full or partial) essentially as originally intended; the three major enrichment process buildings are Category 2 facilities, but the enrichment operations are shutdown – deactivation and S&M are the primary activities; and the remaining Category 2 nuclear facilities have minimal ongoing nuclear operations but have not been surveyed to downgrade them from nuclear to non-nuclear category.


�

�

During the time from shutdown of the enrichment process to the turnover of the privately operated facility to DOE, limited funding and maintenance resources were committed to the infrastructure and physical condition of the facilities. The previous private operator of the infrastructure had adopted a “run to failure” maintenance philosophy. Systems that had redundant equipment were allowed to fail and were never repaired (i.e. X-530 Transformers, sewage lift stations, well field raw water pumps etc.), and equipment protective systems like the Cathodic Protection and valve exercise programs were abandoned, allowing the underground piping systems to degrade. When FBP assumed operating responsibilities of the utility infrastructure systems, the as-found conditions were worse than expected, with several single point failures existing in the electrical, water, and sewage systems. As FBP has gained operating experience and firsthand knowledge of the infrastructure systems over the intervening two years, a number of other problems have surfaced with infrastructure and support systems. While the SSCs required to maintain the nuclear safety envelope had been adequately maintained, age, obsolescence, and the return of previously shutdown nuclear facilities to operation has demanded growing resource commitment.

The change from operating to standby mode has significantly stressed some infrastructure, especially to the Process Buildings. The Process Buildings were originally designed without any auxiliary heat since the process itself kept the roofs and building structures warm, minimizing thermal cycling. These stresses were further exacerbated by the polar vortex weather conditions in January and February of 2014, which revealed weak portions of the physical plant and required support systems. During the winter of 2014 three separate polar vortices produced historic low temperatures at the PORTS facility. The High Pressure Fire Water (HPFW) system experienced failures due to the extreme temperatures, some that caused sections to be taken out of service. The cold temperatures also affected structural components such as roofs across the site that have not been replaced or maintained as needed. Water infiltration below membranes, under flashing, and in expansion and construction joints expanded and froze during this period. The electrical distribution system was affected by tree and ice damage that caused area outages. As discussed in more detail within this report, currently budgeted resources are not adequate to cope with these conditions to sustain the infrastructure required to support the ongoing long-term PORTS D&D mission.

While there have been a number of challenges associated with maintaining an aging plant in the condition required to support ongoing nuclear operations in over 20 Category 2 nuclear facilities, and to provide essential utility and infrastructure support services to FBP and other Portsmouth Gaseous Diffusion Plant (GDP) tenants, operations have been conducted safely since FBP assumed operation of these facilities and no nuclear safety incidents have occurred, nor have issues been identified that are inimical to the health and safety of the public, collocated site tenants or the environment. Over the last 2-1/2 years, as the new safety management programs were developed and fully implemented, and FBP progressed towards successful phase 2 verification of its ISMS program in February 2014, all of the enrichment process equipment has been shut down and a new Documented Safety Analysis (DSA) has been prepared and approved by DOE for the shut-down Process Buildings (X-326 DSA has been implemented, and anticipated implementation of the new DSAs for X-330 & X-333 is August 2014). In addition, a number of administrative and non-nuclear support facilities have been shut down and demolished. During FYs 2012 and 2013, significant utility infrastructure improvements were also undertaken to upgrade certain site utilities and to better match them to site needs as progression from operational to deactivation modes continued. At the same time, as the plant’s operational profile diminished, utility support and infrastructure cost reductions were achieved to support the Site's D&D mission. Nevertheless, particularly over the past year, maintenance backlogs have grown substantially and the conditions of certain facilities, structures, and systems have continued to degrade, some at an accelerated pace due to age as well as extreme weather conditions experienced in the Winter 2014. These conditions and trends are more fully described and evaluated in the later sections of this report.


�

�

3. APPLICATION OF RESOURCES TO SYSTEM & EQUIPMENT MAINTENANCE

Over the course of this fiscal year, the control accounts related to infrastructure and maintenance have experienced a significant cost variance, and are projected to show a negative 50% variance by the end of the FY. This section presents the evolution and status of resource budgets and funding.

3.1 Lifecycle Overview

Portsmouth GDP D&D project was bid, evaluated and awarded based on a ten-year schedule made up of a base period of five years and an option period of up to five years. The scope of work for the full ten year period included demolition of the three process buildings, demolition of the Balance of Plant (BOP) facilities, waste disposal, and excavation and site restoration in all areas of the site.

The current life cycle baseline forecasts a project completion in 2034 (23 years). The growth of the project schedule by more than 100% is a primary contributor to increased cost of surveillance and maintenance as the useful life spans of numerous facilities must be extended. This and other unanticipated scope contributes to the need for dedication of additional resources to these accounts.

3.2 Evolution of the S&M Budget

The extent of material deficiencies in the GDP facilities and systems were unknown at the time of transition from the previous GDP operator in October 2011. During the first 24 months of operation, inspections, operations, PMs and CMs were evaluated to determine the condition of the facilities and infrastructure so that appropriate plans could be made for resources and funding. The assessments considered facility age, changes in the plant’s operational profile, and the lack of recent maintenance. Additional information emerged from system and component failures, including power poles and crossarms, lift stations, cranes, piping, electrical components and systems, and the X-670 air plant. These factors were all considered in these ongoing evaluations. Upgrades to address immediate needs have been completed for some systems and facilities - and others are in progress or being planned (see Sections 5 and 6).

In FY13 and FY14, the cumulative effect of changed or discovered conditions, scope changes, constrained funding profiles (including drop in uranium barter proceeds), and other factors extended the project life cycle baseline well into the 2030s. One of the significant consequences of this growth in the project’s lifecycle term was the need for a more robust S&M program to sustain the reliable infrastructure required to support the longer-term D&D mission.

The collective impact of these factors, in combination with the damages caused by last winter’s unprecedented multiple polar vortices, has been to significantly increase the demand for infrastructure and maintenance resources beyond currently budgeted levels. As demonstrated in Table 3.1 below, the FY14 allocated budget is $26M or (~50%) below the actual need. The budget need reflects approximately $8M - $10M of unplanned work associated with the 2014 Polar Vortex, but does not reflect the additional funding required to achieve a sustainable S&M program reflective of the extended plant lifecycle. The current estimate moving forward is $52 -$54M dollars required annually to maintain the plant at an acceptable level that ensures adequate safety systems and reliable infrastructure to support the D&D mission and other site tenants.


�

�

Table 3.1 FY14 Budgets and Variance – Utilities & Maintenance Budgets were 50% low Control Account EM.PO.01.03.06.01 Utilities $ 7,880,000 EM.PO.01.03.06.06 Infrastructure Services $ 5,760,000 EM.PO.04.03.01.05 Balance of Plant S&M $ 11,332,000 Total Budget $ 24,972,000 Total Budget Need $ 51,055,235 Total Calculated Budget Variance $ (26,083,235) March ETC Projection $ (24,930,596)


�

�

4. MAINTAINING CONFIGURATION CONTROL

The FBP configuration management program has been effective in maintaining configuration control of safety related SSCs. It has also been effective at confirming or re-establishing configuration control on other systems as we upgrade, repair, or maintain them. However, historical deficiencies in configuration management – including undocumented plant modifications, failure to maintain as-built drawings, missing technical information, failure to maintain compliance with applicable industry standards, and degraded facility/equipment condition - have resulted in substantially more time and effort than originally planned to accurately verify and document system configuration in order to ensure that pending maintenance and upgrade work could be accomplished safely and reliably.

4.1Configuration Management Program Overview

FBP has implemented a Configuration Management Program (CMP) that is based on the criteria outlined in DOE STD-1073-2003. The CMP (Figure 4.1) effectively integrates design control, work control, document control, assessment feedback, and key change control mechanisms to ensure that the design, documentation, and physical configuration of the facilities remain mutually consistent and in compliance with the approved safety basis throughout the lifecycle of the facility. Although directly impacting the Category 2 Facilities, the CMP is applied to all other facilities and process utilizing a graded approach. The FBP CMP integrates all aspects of plant design, operation, and maintenance that could impact the safety basis of facilities by implementing required controls for design, modifications, maintenance, equipment identifications, procurement/inventory control, acceptance testing, procedure development, change control and records management. Engineering, Operations, and Maintenance procedures are established which ensure the Configuration Management Requirements are used and applied to specified safety related items and, if appropriate, non-safety SSCs in a graded manner.

FBP-

NSE

-RPT

-000

14 R

ev.1

Pa

ge 1

5 of

47

�

�

Figu

re 4

.1 -

Con

figur

atio

n M

anag

emen

t Pr

ogra

m e

ffec

tivel

y in

tegr

ates

des

ign

cont

rol,

wor

k co

ntro

l, ch

ange

con

trol

, as

sess

men

t, an

d do

cum

ent

cont

rol

to a

ssur

e co

nfig

urat

ion

cont

rol


�

��

�

Essential elements of the FBP CMP include design control, work control, change control, document control, and assessments. Relevant aspects of each element are summarized below.

Design Control: The FBP design process ensures required design input and constraints needed for detail design are identified, interdisciplinary reviews and approval of the requirements are performed and that the final design output requirements include the functional requirements, as well as procurement requirements, quality assurance requirements, construction/installation specifications and instructions, post-installation testing, post-maintenance testing, and periodic surveillance/testing requirements.

Integrated Work Control Program (IWCP): The IWCP establishes a methodology for requesting, screening, scheduling, planning, authorizing, and performing work, including maintenance activity, vendor support, and sub-contractor work. This process ensures the requirements of Configuration Management are maintained for Structures, Systems, and Components SSCs using a graded approach based on the quality classification of each SSC.

Table 4.1 – The number of Engineering Service Orders are high and growing

Engineering Service Orders FY13FY14(6 months)

Modifications 102 64 Projects 15 13 TOTAL 117 77


�

��

�

Change Control: Changes are identified and assessed through a formal change control process. The configuration management program specifically requires that the DOE-approved USQ procedure be applied to evaluate proposed changes (including those to performance documents) that could affect or be affected by nuclear facilities or their operations. FBP currently has no categorical exclusions in place, so the USQ process is applied to nearly all significant performance document changes, and to essentially all plant modifications, whether inside a specific nuclear facility or not. This broad application of the USQ process provides strong assurance that configuration control of the plant with respect to the approved safety bases will be preserved, and that changes to plant structures or operations will not inadvertently introduce unevaluated nuclear or chemical hazards or reduce credited safety margins. This practice is particularly important given the pace and breadth of change the plant and workforce have experienced (and continues to experience) since contract transition in 2011. As indicated by the trend in the number of USQ screens and USQ determinations (Table 4.2), the rate of changes to facilities, operations, and procedures is accelerating. The USQ process has been an essential mechanism to maintain configuration control.

Table 4.2 – Number of USQ evaluations is high and growing

FY13FY14

(6 months) USQ Screens/Determinations 1102 901

Document Control Records management and document control programs are established to ensure records and documents are appropriately managed and controlled. These programs are designed to meet the specific recordkeeping and document control requirements set forth in 10 CFR 830 and other applicable provisions of Title 10, Code of Federal Regulations. Documents are prepared, reviewed, approved, and released in accordance with a level of control appropriate to their intended purpose and applicability. New procedures and procedure changes are subject to Unreviewed Safety Question (USQ) screening. The USQ process is broadly applied to performance documents (plans, procedures, work packages, etc.); FBP currently has no categorical exclusions in place.

Assessments Independent assessments and management assessments are performed within the framework of the overall FBP management program, which has been fully implemented and is nearing maturity. Assessment plans are developed at the start of each year to: implement specific assessments mandated by regulatory requirements; evaluate effectiveness of previous corrective actions; assess performance in areas where there have been previous problems; and to ensure comprehensive evaluation of all elements of each assessed program over a period of time, usually three years. The objective of assessing configuration management is to detect, document, determine the cause of, and initiate correction of inconsistencies among design requirements, documentation, and physical configuration. Assessments should identify inconsistencies between these areas, evaluate the root causes for these problems, and prescribe improvements to avoid similar inconsistencies in the future. FBP has completed management assessment earlier this calendar year of key elements of its CMP, and DOE conducted a major CMP assessment in June-July of 2013. These assessments revealed no significant weaknesses in the FBP CMP.

Specific mechanisms to ensure the effective configuration control of safety-related SSCs include the following:


�

�

NOTEFor purposes of this discussion, “safety-related SSCs” means those SSCs designated as safety class or safety significant in the FBP nuclear safety basis documents, including all SSCs designated as Q, AQ-NCS, and AQ. This definition of “safety-related” therefore includes some SSCs that are not explicitly credited to reduce the likelihood or mitigate the consequences of postulated accident sequences for collocated workers or the public.

� Boundary Definition Manuals (BDMs) are established and controlled as a guide to effective configuration management of the safety-related SSCs designated in the safety basis documents. BDMs identify the extent of safety-related boundary for each designated system to enable users to determine which parts and components are safety-related, and which ones are not.

� A configuration Item (CI) database is maintained and controlled to provide relevant design, operating and maintenance information for safety-related SSCs.

� QA of process control software that is classified as, or directly supports, safety-related SSCs is applied in conformance to requirements of 10 CFR 830 subpart A and DOE O 414.1D.

� FBP has established Cognizant System Engineer program in accordance with the requirements of DOE O 420.1 to provide technical oversight of the maintenance, operation, or modification of safety-related systems to ensure their functional capability is maintained in accordance with the approved safety basis documentation.

� The FBP Plant Operations Review Committee (PORC) reviews nuclear safety activities at PORTS and advises senior FBP management on matters related to nuclear safety.

4.2 CMP Challenges

There have been no PISAs, positive discovery USQs, or TSR violations related to failure to adequately design, maintain, or operate safety-related SSCs since the commencement of FBP’s PORTS GDP D&D contract. Accordingly, in combination with positive management and independent assessment results over the past 12 months, FBP concludes that its CMP has been effective in maintaining configuration control of safety related SSCs. Nevertheless, several factors present challenges to maintaining Configuration Management compliance relative to current DOE standards, as discussed below.

The Portsmouth GDP was originally commissioned in the 1950s to support the United States Strategic Nuclear Defense Programs. The DOE Predecessor Agencies (i.e. AEC and ERDA) did not maintain the same level of Configuration Management control as outlined in the current DOE STD-1073-2003 directive. Undocumented changes were often made to non-safety SSCs that create problems for maintaining these systems. Development and review of maintenance work packages for hazardous energy isolation and equipment repair require significant effort to revise drawings that were not maintained “as-built” by the previous PORTS contractors, replace lost vendor information, and require “hand-over-hand’ validation of systems because of unauthorized and undocumented changes performed decades ago; for example the large electrical Process Systems Power Improvement (PSPI) program.

Table 4.3 – Engineering Service Orders to re-establish accurate documentation of plant configuration

Engineering Service Orders FY13FY14

(6 months) Excavation Permits 38 8 Penetration Permits 25 15 Maintenance Assist 57 30 Drawing/Doc Changes 9 10 TOTAL 129 63


�

�

A second major challenge is the age of the equipment and identifying suitable replacement parts that are compliant to current codes and standards. Retrofitting equipment standards such as the National Electric Code (NEC), National Recognized Testing Laboratories (NRTL) standards and new safety work practices such as NFPA 70E increase the preplanning efforts expended by Maintenance and Engineering to keep the plant operational and compliant to DOE requirements.

Table 4.4 – Engineering Service Orders related to retrofit of components or requirements

Engineering Service Orders FY13FY14

(6 months) Equivalency 33 18 ESDS/SPEC 3 1 Arc Flash Evaluations 182 51 Other Evaluations 173 130 TOTAL 391 200

A third major challenge facing FBP was the condition of the facilities at the time of transition, October 2011. In anticipation of the return of the utility and power facilities to the DOE, Power and Utilities Operations facilities had undertaken several upgrade projects under USEC in 2010 and 2011. Such projects included the following installations:

� X-670 Dry Air Plant (DAP) with three air compressors and dryers � X-670 Recirculating Cooling Water (RCW) system; � X-675 Nitrogen plant; � X-640-2 High Pressure Fire Water (HPFW) elevated storage tank electric boiler facility; � X-640-1 HPFW substation � X-611 Substation; and � X-6644 and X-626 HPFW telemetry project.

However, some of these USEC managed projects were installed under a very compressed schedule and now have experienced premature failures (i.e., X-670 air plant and RCW system). As-built documentation on these systems is minimal and the exact system’s configuration is unknown, making maintenance more difficult.

These legacy conditions continue to require significant engineering attention and resources to effectively manage configuration control. Currently, the number of Engineering Service orders (ESOs) received each month is outpacing the number closed by about 25 percent. Over the past six months, FBP has generated an average of 54 ESOs per month and closed an average of 38 per month.


�

�

5. NECESSARY UPGRADES TO SUPPORT SYSTEM INFRASTRUCTURE

This section summarizes recently completed infrastructure upgrades, the current priorities for additional upgrades to be accomplished during the remainder of FY14, and which ones are being deferred into FY15. It also describes some of the key initiatives FBP has undertaken to more effectively and efficiently apply infrastructure and maintenance resources where they are most needed.

Constrained funding levels, increasing requirements, and declining infrastructure reliability made it necessary to balance the cost of upgrades to the aging PORTS utility infrastructure in order to ensure reliability of utility services to PORTS site tenants, and to support the long term PORTS D&D mission. Insufficient budget for maintaining the PORTS infrastructure increases the present risks associated with the single point system failures or dilapidated systems caused by lack of, or deferred maintenance. Despite the funding constraints, several major upgrades have been completed, others are planned, and some have been deferred until a later date.

Major Infrastructure upgrades completed:

� In FY2012 the X-152I Data Center was completed expanding the PORTS data communication system infrastructure to accommodate the increased communication needs of PORTS D&D mission.

� In FY2012 the X-151, X-152, and X-157 Trailer Complexes were installed to expand and improve the site infrastructure for the D&D mission.

� In FY2012 the RMDC Record Vault Storage was relocated from the X-100 and X-1000 to the X-720 in an effort to centralize and accommodate the site’s growing need for secure, records management and controlled document storage and processing.

� In FY2012 the X-690 Steam Plant was constructed replacing the coal-fired steam plant with a natural gas-fired steam plant reducing gaseous emissions and operating costs.

� In FY2013 the initial phase of the reconfiguration of the sitewide 13.8 kV power distribution infrastructure was completed, supporting future plans to mitigate facility power outages due to the aging infrastructure and minimize disruptions from D&D activities, as well as make future isolations easier to implement.

� In FY2014 the X-152A Medical Trailer was installed to consolidate the site medical and diagnostic services for site personnel in a more efficient and cost effective manner.

Current planned FY14 infrastructure upgrades:

� The PORTS power distribution system is in the process of upgrading the X-530 power distribution system associated with the 345kV/13.8kV distribution.

� The X-670 Dry Air Plant and X-670A Cooling Tower system is in the process of being restored to operational condition.

� X-6619 CL2/SO2 Monitoring and Controls for NPDES Effluent Discharge Sampling Systems have been replaced for the 2014 Monitoring season.

� X-530/X-300 Disturbance Monitoring Equipment Upgrades for monitoring the PORTS power systems in compliance with recently implemented NERC requirements.

� X-530 Medium Voltage Reutilization Project � X-300 SCADA UPS Upgrades for maintaining NERC Compliance with existing standards. � X-330 Dry Air Plant upgrades to Air Compressors #5, #6, and #8 to maintain site air supply � Sewage Lift Stations – replacement of 4 sewage lift station pumps – prioritized through the work

control process.


�

�

� Roof repairs (X-326 warranty repairs, X-705, X-333, X-342/344, and X-530 Control room/switch house)

� X-720 upgrades (establish maintenance hub) – replacing 6 overhead doors in the X-720 and 1 overhead door in the X-700. Upgrade 1 locker room in the X-720.

� Completed the X-720 laundry/respirator facility � Site Public Address System repairs � Dry Air Plant – installation of the coils, consolidation of the dry air system with relocation of the #7

X-330 air compressor to the X-670 #4 air compressor position and improvements � X-104 replacement with triplex trailer

The following upgrades are currently being deferred until FY15 or beyond:

� Other roofs (, X-700, X-750 and X-104A) � Electrical Distribution System (13.8kV upgrade tie-ins to buildings) � X-690 Steam Plant- plans to improve cold resistance, enclosure, spare parts � Utility pole inspection and repairs � X-710 and X-104 employee relocations with procurement of six-plex trailers for X-710 employees � Emergency Vehicle Replacement � X-333 dry pipe system repairs � HPFW underground distribution

The deferred projects are reviewed periodically against the available funding and ongoing condition to assign a Site priority. As funding becomes available, or if the condition warrants, the projects are prioritized into the current year plan.

5.1 Mechanisms being Implemented to Enhance System and Infrastructure Reliability

Several initiatives have been completed or are underway to identify and prioritize corrective and preventive maintenance and needed infrastructure upgrades in a manner that optimizes the application of resources to preserve safety margins and manage mission risk.

� S&M Performance Improvement Team During FY12 and FY13 the focus at Portsmouth was on evaluating the surveillance and maintenance (S&M) activities and evaluating where efficiencies and improvements could free up resources to support D&D activities in the X-326. In January 2013 an S&M Process Improvement Team (PIT) was established to identify and implement potential cost savings and efficiencies in the S&M area. The PIT was cross-cutting and included participants from FBP, DOE and WEMS. The team identified and prioritized a listing of 25 items ranging from reducing recirculating cooling water (RCW), to consolidating plant air at X-670, to shutting down the on-site laboratory X-710. The potential savings from efficiencies were ~$10M if implemented. The team also tracked initiatives already in progress including transitioning laundry cleaning to an off-site vendor ($1M/yr. savings), relocating X-7721 staff to other site facilities (~$250K/yr. savings) and reducing criticality alarm preventive maintenance inspection frequencies ($205K/yr. savings). Finally the team tracked cost avoidances by not maintaining buildings demolished in the last year or scheduled to be demolished in FY13 (i.e., X-100 complex demolition saved ~$650K/yr., X-600 demolition saved ~$2.2M/yr. and demolition of X-102/X-106 saved $255K/yr.).


�

�

� 5-5-5 Team In addition to the S&M PIT, a 5-5-5 team was established to find ways to increase overall efficiency of the Site Maintenance/Infrastructure/D&D (SMIDD) division and to reduce costs. The premise was 5 people, 5 months with a savings of $5 million. The team began in late January 2013 to identify opportunities and where time should be spent developing the most effective solutions. PMs were averaging 9,000 annually with a target of reducing them by 40%. The CM backlog was over 22,000, so it was decided to cut any outdated CMs and to revamp the priority status of the remaining tasks. Active PMs were reduced by almost 30% to 6,500 annually (all of which were on systems no longer in service) and CMs dropped to over 40% to 12. This action allowed Maintenance to excess 39 individuals outside the Maintenance group. Additional analysis and reduction in PM activities did not occur with any active systems.

� System Health Report FBP has developed a System Health Report (SHR) to monitor reliability and availability of 15 critical systems required for the safe, effective, and efficient execution of FBP’s Ports D&D mission, including delivery of utility services to all Portsmouth Gaseous Diffusion Plant tenants. This report will be maintained continuously and issued monthly, and will be one of the mechanisms used to optimize utility and infrastructure surveillance and maintenance. For each system or facility, four attributes are evaluated: material condition, condition trend, PM deferral status/trend, and (if applicable) “as-found” TSR surveillance status. The parameters monitored for each attribute are tailored to the particular characteristics important to that system’s safety and reliability posture. For each parameter, in turn, criteria are established to assign a numerical score relative to overall system availability. The weighted average of the parameter scores provides the overall system score. Scores are correlated with a color coding system to highlight problem areas in the report and to produce a system health dashboard. Each monthly report includes an overall system health dashboard, detailed evaluation of each system’s status, and comparison to previous month’s status to highlight improving or declining trends. The SHR data and other plant information will be integrated into the Reliability Centered Maintenance program and maintenance prioritization process being developed under the Work Planning & Control PIP to optimize application of S&M resources and infrastructure upgrades. An example of the dashboard for the SHR, and the current status of the systems, is represented in Table 5.1.

Table 5.1 - PORTS System Health Report for April 2014

PORTS SYSTEM HEALTH for the month of April-2014 Air Plant X-670 & X-330 4

NitrogenPlant X-675 7

CAAS 8

Public Address 5

Electrical Switchyards 4

UF6 Cranes 8

Water Wells & Distrib.5

X-611 Wtr. Trtmt. 4

SewageTreatment 4

Fire Protection 3

UF6Sample & Transfer 7

Wet Air Vent 8

Public Warning Sirens5

Steam6

X-705 3

Color Codes: Green – System in perfect condition (rating 9 and 10) White – System fully functional with some PMs delinquent (rating 6-8) Yellow – System degraded (rating 3-5) Red – System not operational and not capable of performing intended function (rating 1-2)


�

�

As the mission progresses, it is expected that the relevance of some systems or system parameters to plant infrastructure reliability will diminish, while others may grow. Accordingly, the SHR systems, parameters, and criteria will be revised from time to time to reflect the changing plant configuration and operational profile.

� Structural Inspections Per FBP-NSE-PRO-00101, Structural Inspection and Maintenance of Structures Important to Safety, the facilities designated as Safety Significant are inspected every 5 years. These inspections result in a prioritized action list, from which work requests are initiated. During the inspections, the following structural elements are assessed for deformation degradation, or other criteria relevant to structural integrity: o Foundations o Base Plates o Building Frames o Column Anchorage o Load Bearing Walls o Reinforcing tees o Bracingo Seismic expansion joints (gaps between floor sections) o Structural steel connectors o Transite side at the cell floor and above o Roof

Other structural inspections are performed either on a periodic basis (for safety-significant systems; these are driven by either procedure requirements of preventive maintenance), or on an as-needed basis when requested by the Facility Manager. FBP has maintained the inspection schedule and none are overdue.

� Utilities Infrastructure Plan The Utilities Infrastructure Plan (Document No. FBP-DD-UT-PL-0001) is currently being developed and will be submitted to DOE in June 2014. A draft sample chapter of the document was previously submitted to DOE for format review on January 30, 2014. This plan summarizes the critical utility systems required to sustain the mission at the PORTS plant, and will allow strategic planning to support the 5-year/10-year long term goals of the site. Each utility system is described with the current mission and condition. The single point failure vulnerabilities, major equipment list with condition, system health and projects proposed for each utility are described. Finally, each utility has a recommendation and conclusion with as-is risk and rough order of magnitude costs estimates included. Once this plan is complete, it will be maintained and updated on a periodic basis, and will be used to identify opportunities to abandon or isolate infrastructure that is no longer needed for the PORTS mission. Systems covered by the plan are:

� Raw Water � X-611 Water treatment Plant � Recirculating Cooling Water � Make-Up Water � High pressure Fire Water � Sanitary/Fire Water � Recirculating Heating Water � Storm Drains � Sanitary Sewer � Steam/Condensate � Dry Air


�

�

� Nitrogen Gas � Fluorine Gas � Natural Gas � Electrical Power � Communications


�

�

6. IMPACT OF EQUIPMENT CONDITION ON FACILITY OPERATIONAL READINESS

While significant resources have been applied to maintaining critical systems, significant impairments in some of the affected SSCs persist; this section summarizes current impairments of some degraded SSCs and associated costs and risks.

As summarized in Section 5 of this report, FBP System Engineering prepares a System Health Report (SHR) each month covering 15 critical systems (Table 5.1). Five systems currently categorized as white(rating of seven or eight out of ten) are the Criticality Accident Alarm System (CAAS), Nitrogen System, Liquid UF6 Handling Cranes, UF6 Sample and Transfer, and the Wet Air Vents. In addition, recent repairs were completed to the Public Warning Sirens. These systems are operational and have few negative impacts. The PMs on these systems are current and their material condition is fair to good. Impairments or vulnerabilities of the remaining nine systems are discussed below, along with those of other SSCs whose condition is considered deficient. Each sub-section summarizes system use/importance; current status and associated hazards, risks, and impairments; and path forward to improve reliability and availability.

6.1 Process Building Roof Repairs/Facility Conditions

The leaks in the X-326 and X-333 process building roofs impair the ability to perform cut and cap activities as well as degrade the equipment within the buildings. There are auxiliary substations that provide power to stand-by lighting, welding receptacles, cranes and the sprinkler riser valve vault (in the X-330 and X-333), all of which are needed to support future cut and cap operations. There are also nuclear safety/criticality safety concerns during cut and cap activities with the possibility of water in-leakage into breached process equipment. At present, there are no “cut and cap” activities occurring in the X-333; the conditions described above would prevent any “cut and cap” project work from being performed in areas experiencing significant leakage. The other issues with in-leakage of water are potential HF generation, mold formation, migration of contamination, electrical hazards and slip/trip/fall issues. In X-333, these leaks are impeding the inspections and PMs of electrical equipment, could cause electrical faults, and accelerate the physical degradation of the building structures. Since the fire suppression system is already impaired, fires from arcing of electrical faults are more likely to spread. Further, we are already seeing spalling of concrete from the operations level ceiling, whose structural integrity needs to be preserved for the equipment that will be required to repair the sprinklers and to support the removal of 000 PGE components.

The X-333 south section of the roof (approximately 2/3) was repaired by the previous contractor in 2010. Currently, there are no issues with this repair. However, the north section of the roof (approximately 1/3 or 11 acres) is in poor material condition as documented in evaluation EVAL-TS-2013-0225. The X-326 roof was repaired by the previous contractor in 2010. In 2013, roof spot repairs were completed in small concentrated areas to repair the leaks in the cut and cap working area. The roof continues to have leak issues and spot repairs are being performed. The major leak area is located at column W37 area on the west side of the building. The X-330 roof has no current issues.

� Path Forward The X-326 roof is covered under warranty and the installing contractor is scheduled to make repairs during the summer of 2014. They are currently submitting their work plans for approval and attending


�

�

the required site training in preparation for this activity. The north 1/3 of the X-333 Roof that was not previously repaired is scheduled to be replaced late this summer and into the fall.

� Other Balance of Plant Roofs The X-340 complex, X-700 Cleaning, X-705 Decontamination, X-750 Garage, X-530 Control Room and Switch House, and X-104A Firing Range, have roof issues/leaks identified. Repairs to these facilities are being evaluated, prioritized and scheduled as funding is available, to support plant operations.

6.2 X-530 Switchyard

X-530 switchyard provides all electric power for FBP and other GDP tenants. This switchyard is one of the two original high voltage distribution yards built for the GDP plant in 1952. The X-530 was originally designed to provide up to 1000 MW of power for the GDP plant. The facility is oversized for the current loading of approximately 30 MW. The X-530 has not experienced a general upgrade of equipment. As a result, the systems and equipment are typically obsolete with limited spare parts availability and prone to frequent failures. The X-530 is comprised of 345 kV oil circuit breakers, 345kV to 13.8kV transformers, and 13.8kv air circuit breakers and distribution feeders that are used to distribute power to plant site facilities.

The X-530 current configuration provides double-ended service on the North and South 13.8kv distribution system. The X-530 north supplies power to facilities: X-330, X-333, X-342/344, X-330 Air Plants, X-742, X-744G, X-6609 & X-608 Well Fields, X-611, All Trailer Complexes. The X-530 south supplies power to facilities: X-326, X-626, X-700, X-705, X-710, X-720, X-300 & BWCS.

X-530 is suffering the effects of aging. Increased maintenance with lower availability of spare parts for much of the equipment is being experienced. Some equipment does not have any known source for critical spare parts. Failures of equipment in this category, namely the 5000A transformer secondary air circuit breakers (ACBs), would require major modifications of the breakers to be returned to service in the event of a failure.

Significant vulnerabilities include the 13.8 kV busses that connect power transformers to the transformer secondary breakers and the interconnecting 13.8kV reserve buss needed for equipment redundancy. This vulnerability was highlighted by the failure of isophase buss 201 in September 2013. Transition to the newly purchased X-530 switchgear will alleviate degraded material conditions associated with the 13.8kv equipment.

The 345 kV oil circuit breakers (OCBs) are original equipment and past typical service life. An additional vulnerability exists in the 5000 amp transformer ACBs that have delamination in the primary arc chute components. DOE/FBP have committed to an aggressive PM program for their reliability under NERC/FERC. Parts availability is very limited; most need to be scavenged or custom fabricated at great cost and long lead time. Long term solutions for the OCBs have not been fully developed, but are likely to include bay-by-bay replacement with modern technology breakers. Even though the system is operating, the material condition of the system is poor and prone to failure. Combined with the difficulty of locating replacement parts and consequence of system failure, the X-530 upgrade is of paramount priority.

� Path Forward Consequences of equipment failure vary from feeder specific, facility specific to a total loss of power to either switch house. Plans to restore power have been developed and are dependent on the location of a failure. Contingency plans were developed and selected refurbishments completed to minimize the


�

�

likelihood that the failure of any single component could result in prolonged outage of power feed to either the north or south 13.8Kv distribution system.

During construction of the X-530 Medium Voltage Reutilization Project, both ends of X-530 will be reduced to single feeds. While operating in this configuration essentially all facilities on-site will be operating under a single-point failure condition. Should a failure occur while operating in this configuration, the reserve bus tie switches would be closed to serve both the north and south systems.

After X-530 Medium Voltage Reutilization Project switchgear installation is complete, feeders F3, C1 (north) and F4 (south) will remain connected to both the X-530 Medium Voltage Reutilization Project designated feed and their current connection to the X-530 13.8kv bus. In the event of a failure, on either end, existing circuit breakers can be closed to restore both north and south 13.8kv distribution systems.

At the completion of the X-530 Medium Voltage Reutilization Project switchgear installation, all overhead feeders will be transferred over to the new switchgear. The transfer of other facilities fed from the underground cables to overhead lines will be accomplished as funding becomes available.

6.3 Air Plant

The Plant Air System supplies dry compressed air to the process buildings and the autoclave buildings. The two primary sources of plant air are X-330 and X-670 compressors. System design capacity is more than 25,000 scfm for the X-330 Dry Air Plant (DAP) and 10,000 scfm for the X-670. The X-330 has four electric compressors, three of which are rated at 5500 scfm, and one of which is rated at 3500 scfm. X-670 is a newer installation, and has three electric compressors, all rated at 3500 scfm. Additionally, there are backup/emergency diesel-powered compressors at both X-326 and X-330; each of these compressors is rated at 3750 scfm.

Dry air is produced with a dew point of at least -25F, and is used to maintain dry buffer on the process gas equipment (PGE) as a nuclear criticality safety control. Other uses for Plant Air include purging process equipment; as a backup for the nitrogen system; to operate instruments, controls, air ejectors, and alarms; to provide air for the plant datum systems; to provide process system buffers; to provide air for compressor seal operation; and to provide air for general maintenance and laboratory operations. Reliance of the Ports GDP facilities on the dry plant air system is described in more detail below.

In the X-344/X-342 complex, dry air is used for many applications, including air-operated cylinder scale carts, the process gas evacuation air jets, and general instrument air. Many process valves are pneumatically operated. Autoclaves in particular have pneumatic containment valves, as well as buffer air for the roll and tilt mechanisms. The process gas system is purged with dry air. The X-342 Cold Boxes currently being installed require a dry air buffer. Without a dry air supply, autoclave operations and cylinder weighing (and shipping) operations would cease.

The X-705 uses dry air for process operations and instrumentation, including the Wilden pumps, Bubbler systems in Recovery and Tunnel storage, as well as the purge for the South Annex. The ability to support Cut and Cap for removal of deposits is directly affected by having an adequate air supply in the South Annex. The Recovery and Tunnel systems require the Bubbler systems for solution movement.

The Process Buildings use dry air for buffering of the process equipment for NCS Control, Instrumentation and Vent Air Ejectors. Dry air is needed if a condition is found that requires entrance into TSR 2.2.3.15 or potentially 2.2.3.16. Using a Dry Air Buffer is the Limiting Condition for Operation


�

�

(LCO) for a Greater than Safe Mass (GSM) or Planned Expeditious Handling (PEH) potential deposit. Nitrogen can be used as a backup or when a component must be moved.

The X-670 was built in 2010 and the three air compressors were operational by September 2010. At FBP Transition in October 2011, the X-670 Air Plant was operational. FBP planned to centralize the air needs in the X-670 and eliminate the X-330 air plant. In July 2012, the X-670 began to experience serious equipment problems, and in September 2013, the X-670 Air Plant was taken out of service. The failure was traced to improper startup of the system by the former GDP operator. The system had high dissolved solids most likely due to inadequate flushing and/or passivation.

Currently, only the X-330 compressors are operational, with # 8 being out of service most of April and the diesel being unavailable. At this time only 13500 scfm is available in the X-330. Presently, the X-330 DAP can maintain the level of dry air needed to fulfill our mission. The X-326 diesel compressor has been run in excess for 400 hours during the last 12 months, but the majority of the hours were in April and May 2013 so more hours will become available at the end of May 2014. The diesel compressors are limited to 500 annual run hours by the Reciprocating Internal Combustion Engine Maximum Achievable Control technology (RICE MACT) rule. The X-330 diesel has been out of service for at least a year. Corrective maintenance to repair the diesel is in progress, which would provide another 500 hours of diesel run time. The loss of another compressor could compromise our ability to support all of the functions that need dry air.

The X-326 #1 diesel remains available with no issues. The X-333 #1 and #2 air compressors were taken out of service permanently by the previous GDP operator due to mechanical issues and the removal of the X-533 Switchyard.

Because of the plan to centralize the air needs at the X-670, minimal maintenance had been performed for the X-330 dry air plant. With the recent failures, the maintenance focus has been to ensure continued reliability of the X-330 air plant until the X-670 is operational (at which time the X-330 air compressor can be moved to the X-670). There is some maintenance that is required to keep the X-330 Air Plant operating until the X-670 is returned to service. As detailed above, the inability to adequately supply centralized dry air would:

o Impair ability to buffer process gas equipment in the process buildings o Disrupt cut and cap work activities o Increases maintenance costs by maintaining the X-330 dry air plant. o Delay the D&D of the X-626. (The cooling water is provided to the X-330 Dry Air Plant.)

The table below details the X-330 Dry Air Plant issues and impacts:

Table 6.1 - Summary of X-330 Dry Air Plant Issues

Position Issue Description Impact AirCompressor #1- Electric

Air Compressor is Permanently Out of Service. Dryer #1 used to support air compressors #7 and #8.

Cannot use this air compressor to support the plant air needs.

AirCompressor #2 –Electric

Air Compressor is Permanently Out of Service. Dryer #2 is used to support air compressors #7 and #8.

Cannot use this air compressor to support the plant air needs.

AirCompressor #3

Currently out of service. Aftercooler needs replaced and the

Needs fixed to allow #7 to be sent offsite for rebuild.


�

�

–Diesel hydrier repaired. Also needed to support air requirements until X-670 is back in service.

AirCompressor #4 - Electric

Permanently Out of Service Cannot use this position to support the plant air needs.

AirCompressor #5 – Electric

Currently in operation. Desiccant needs replaced in the dryer.

When the ambient temperature rises (summer timeframe), it will be difficult to maintain the dry air quality that is required to buffer process equipment

AirCompressor #6 - Electric

Currently out of service. Desiccant needs replaced in the dryer. #6 Dryer temperature controllers failed and have not been replaced.

Currently, cannot use this position to support the plant air needs until the dryer is fixed.


Currently out of service (on stand-by). System due for rebuild.

Needed to operate until the other air compressors can reliably support the site need.


Currently in operation. There is a 2nd stage cooler issue. Need to have the dual oil cooler installed.

Will operate at ¾ load, but will not operate when the ambient temperature rises (summer timeframe).

Since the X-670 air plant is out of service, the preventive maintenance (PM) was not performed, resulting in a negative PM deferral trend. The required PMs will be performed prior to restart and resumption of operations.

� Path Forward Currently, there is a project to replace the damaged recirculating cooling water cooling coils to return the three air compressors to service in the X-670. Also, there is a plan to move one compressor from X-330 to X-670 after refurbishment to centralize air production and to allow eventual deactivation of the X-330 air plant. In this plan, the X-330 Compressor #7 will be moved to become X-670 Compressor #4 since it is identical to the three compressors currently in X-670. This project is currently underway and is planned to be completed by March 2015.

6.4 Public Address (PA) System

The Public Address System is used to communicate with plant personnel during normal, abnormal, and emergency conditions. This system is for plant use only and is different from the Public Warning System used to alert the surrounding public should there be an emergency situation. There are three public address control consoles – two consoles in X-300 and one in X-1020 (EOC). Two of the three consoles (including the one in EOC) have not been operational for several years, but the system functions through the use of the X-300 console. The X-300 console is usable, but has a fault with an audio cutout at around 15 seconds. Electronic maintenance has not been able to identify the fault, and reloading the software as part of troubleshooting is not an option, as the Digital Processor Controller (DPC) software could be erased. This is a potentially unrecoverable system casualty that FBP has elected not to risk with the only operating console. Additionally, there are issues with PA speakers throughout the plant site. Roughly 30% of the speakers may be less than adequate. Provisions in the procedures allow for radios or a runner to be used as a temporary compensatory measure, but not as a permanent alternate to a functional PA system in an occupied facility.


�

�

System failure would mean extended notification time to employees during abnormal and emergency situations. If the PA console failure occurred in conjunction with an emergency, the only way to communicate with site personnel would be radios and runners.

� Path Forward A plan is being developed to solicit bids to replace the PA control with new hardware and software connected to the individual bridging amplifiers in the X-300 basement and X-1020. An ESO has been submitted and a System Requirements Document (SRD) has been prepared. This upgrade is planned to be completed this FY. Meanwhile, as a contingency measure, a temporary modification has been designed to bypass the DPC in the event of its failure. To ensure coverage and audibility, speakers in numerous locations have been replaced as problems are identified and funding is made available.

6.5 X-690 Steam Plant

The current steam plant consists of two gas fired boilers with accompanying condensate and feed water/deaerator skids. The plant is automatically controlled, but may be run manually if needed. X-690 currently supplies all needed steam for the FBP facilities. The system is designed and sized such that two boilers are required in the winter to provide process steam and steam for heat. One boiler is sufficient for process steam in the summer.

Severe weather conditions from the 2014 Polar Vortexes demonstrated the marginal reliability of the X-690 operations during abnormally cold weather. This event required extraordinary temporary measures to maintain steam availability during the past two winters. A temporary enclosure was installed in 2013 and 2014 and will continue to be used until a permanent structure is constructed. Additionally, the Deaerator Tank Steam Regulator Valve has failed (the manual bypass valve is currently being used), requiring repair or replacement. New Human Machine Interface (HMI) control screens are needed on the deaerator tank and on both boilers.

Steam outages due to severe weather during the two most recent winters have resulted in extended down time and repairs in the X-340 complex, X-705, X-710, some of which have yet to be completed.

� Path Forward A project has been initiated to build a metal frame structure over the two gas fired boilers. The new structure will protect the boilers from extreme temperatures, but will also protect critical components such as HMI screens, valves and piping. An additional benefit is that the structure will reduce operational energy costs approximately $250K per year. Technical requirements have been developed for the project and the final details are being finalized. The project is not funded for FY14, but has been placed on the priority list to be completed in FY15.

6.6 Sewage System

The X-6619 Sewage Plant was built in the early 1980s and was designed to process 600,000 gallons of sewage per day, but is currently processing only about 350,000 gallons per day. The sewage system is presently running and handling the waste water produced by the site; however, the material condition of the system is not robust and several parts of the system are in single point failure condition, and others are not operating and compensatory measures have been implemented. The X-614A, which is the primary pumping station, is not operating at full capacity and the modification of the #1 pump is not tested due to a clogged system. Once #1 pump can be tested, additional electrical changes may be needed for full operation with new pumps. X-614 D is operating on only one pump and the X-614P is completely shut down, requiring frequent pumping of the station. Two of the four aeration basins need repairs; they are


�

�

full and will not drain. The system is at a single point failure on backwash pumps; #2 is the only one in operation. The site’s ability to reliably handle site waste water, and that of Pike County when it arrives, is at risk.

� Path Forward Projects and multiple maintenance activities are being developed and applied to the sewage system infrastructure to maintain and repair the aging systems. The X-614A is expected to be fully operational in the summer of 2014, and repair packages are being planned for the basin repairs at the X-6619. 6.7 Raw Water System

Raw water is supplied to the X-611 water treatment plant from two separate, independent well fields (X-608B and X-6609) using two separate raw water pipelines. The X-608/X-608B was constructed in the early 1950s. The X-608/X-608B consists of 10 wells capable of operation. Presently, three wells are operational and providing adequate raw water to the X-611 for treatment. The X-608B well field’s remote start/stop capability failed. This failure eliminates the start/stop capabilities during flooding conditions. The pumps require regular maintenance to prevent clogging with silt.

The X-6609 was constructed in the 1980s as a back-up raw water supply. The X-6609 is currently out of service due to needed repairs on a leaking air release valve and replacement of control well batteries. The remote start/stop capability also needs to be repaired. With the X-6609 out of service, the X-608B well field is vulnerable to a single point failure for providing water to the site (e.g., if the discharge pipeline between the well field and the water treatment plant failed, no large-volume supply of water would be available to the site until it was repaired).

If the discharge pipeline between the well field and the water treatment plant failed, no large-volume supply of water would be available to the site until it was repaired. This would be a significant repair requiring several days. The X-611 contains a two-day supply of water with restricted use and a slightly longer supply of Sanitary Water, but within days the plant could be without water. Restriction/loss of treated and sanitary water is discussed in the Water Treatment Section below.

� Path Forward Resources continue to be applied as necessary to keep the raw water supply system operable. A plan is underway to reduce the Site’s overall water usage, which will alleviate some of the risk of well field failure. The Site has an eventual goal to transition to commercially supplied water sources and eliminate the need for the water treatment process.

6.8 Water Treatment Plant X-611

The X-611 was designed to process 40M gallons of water per day. Currently, the site demand is about 3M gallons of water per day. Even though the X-611 system is oversized, the components to process the water are still needed and the system is in poor material condition and there has been a delinquent PM trend. There are no spare lime blowers, the north slow mixer is out of service for pedestal and shaft repairs, the south slow mixer has a broken flocculation arm, the sanitary water pump #4 discharge valve no longer seals and needs to be replaced and the concrete basin and trough walls is degrading (exhibiting cracks and spalling).

The degraded condition does not presently impact the system’s ability to treat and supply water to the plant; however there are several areas that are considered to be single point failures, such as the lime blower and the south slow mixer.


�

�

If the X-611 were to completely fail, there would be a two-day supply of treated water if use were restricted. Restrictions would be on the steam plant and RCW systems which would negatively impact X-344 operations and the Dry Air Plant. There would be a slightly longer supply of sanitary water, but the impacts would be significant. Portable toilets and wash stations could be brought in for some employees, but that would not be sufficient for employees who need to enter contamination areas and need to shower after exiting the areas.

� Path Forward Resources continue to be applied as necessary to keep the water treatment system operable. Work packages to repair the blowers are being developed, and other repairs are being prioritized for future repair as resources are available.

6.9 X-705 Facility

The X-705 Chemical Processing system consists of Recovery, West Annex, South Annex, Tunnel/Small Parts, Microfiltration, and the Oil and Grease Removal Unit (OGRU). Presently most of the systems are out of service due to overdue PMs or needed repairs, except for the Tunnel /Small Part section of the system. Recovery A-Loop and C-Loop, Ion Exchange, Heavy Metal Press #2, and the Group I Handtable are currently operational. However, Recovery B-Loop and Group II Handtable are abandoned in place, and B and C Post Evaporators are out of service. Microfiltration and Calciners are currently inoperable due to equipment issues. The Oil and Grease Removal Unit, Large and Small Cylinder Cleaning, Seal Dismantling, Small Parts Pit areas are all out of service due to various reasons which include procedure hold, awaiting equipment repairs and awaiting Readiness Assessment for restart.

As a result of the Polar Vortex, leak issues have prevented water from being supplied to Microfiltration which prevents PMs/CMs from being completed. Other items have been impacted by Work Control issues and parts. The Tunnel/Small Parts, West Annex and the South Annex are presently available. Other systems are being worked to return the Recovery system to operation. Most other processes are limited by shut down of the Recovery system.

� Path Forward Maintenance is working with Nuclear Operations to restore the Handtable and processing columns in June 2014 to allow processing of the material currently in solution. The recovery plan extends to the other portions of the system such as the Geometrically Safe Storage (GSS), Microfiltration, and the Small Parts Pit that are necessary to process ash and gunk. These systems are all expected to be operational during the summer of 2014, pending the completion of required repairs, PMs, and Readiness Assessments as required. Ongoing work will be managed as part of the Preventative Maintenance program and necessary resources will be assigned to maintain the system in a safe operating condition. This intensive operation will continue until the inventory of ash, gunk and in-process solutions are properly treated and disposed.

6.10 Fire Protection and Suppression Systems

The High Pressure Fire Water System (HPFWS) consists of the X-640-2 elevated tank, the electric and diesel pumps, the dry pipe sprinkler systems in the X-333 and X-330, wet sprinkler systems in the X-326 and other buildings, as well as the underground piping, hydrants and valves. This system provides fire protection for the entire site including FBP, ACP, BWCS and ONG.

The current overall condition of the Fire Protection System is poor. There are over 30 hydrants out of service, 74 sprinkler systems out of service (approximately 20,800 sprinkler heads) in the process


�

�

buildings, and over 10 facilities with sprinkler systems out of service, most of which are due to the extremely cold weather in 2014. There are several sectional valves closed and underground water leaks that need to be repaired. The ADT/SAFA fire alarm loops are in-service, but there are supervisory and sprinkler system alarms that need to be fixed. The air regulators (173) need to be replaced on the sprinkler systems in the X-330 and X-333. Also, the X-640-2 high pressure fire water storage tank and fire pumps are operable; however, the equipment is past due for inspections. Due to the sprinkler systems and hydrants out of service, and the underground water leaks, the material condition of the Fire Protection system is considered poor. Testing and surveillance activities are being performed as scheduled; however, other preventive maintenance activities are delinquent.

The elevated tank and pumps are presently operable but are past due on some inspections/PM. Presently, there are numerous systems that are inoperable in the X-333 building due to unusually cold weather during this year’s polar vortex. The sprinkler outages are significant and should a building fire occur with the system out of service, the entire facility would be involved. Systems are down in other buildings as well.

� Path Forward Work requests for the systems to be repaired have been written and parts have been ordered. The work will be performed based on a risk based priority with the assistance of Fire services. Progress on the repairs will be made throughout the summer and fall of 2014. Compensatory measures are in place that requires 3-hour fire patrols in the affected facilities and restrictions on hot work.

A project has been initiated to repair the underground issues and parts have been ordered for many of the piping and sprinkler repairs. A related project is planned for FY15 to repair the deficient fire suppression system in X-333 – this is a significant effort far beyond the typical scope of a maintenance activity.

6.11 UF6 Transfer

The current UF6 Sample and Transfer system is in good condition. Two X-342 autoclaves are currently out of service due to the installation of cold boxes and will be returned to service in March, 2015. In April, the X-344 autoclaves availability averaged fewer than two (there are four autoclaves total with the system goal of maintaining three) due to leaking manifold valves, semi-annual and quarterly calibrations and corrective maintenance on the locking ring limit switch. Nevertheless, availability has so far been sufficient to maintain the UF6 transfers required to support the uranium barter program, although the need for frequent PM and CM work has reduced autoclave availability to a level that has so far prevented the goal of building a six-month back-log of transferred cylinders as a contingency against a prolonged facility outage.

The X-344 cold trap availability averaged more than two (with the system goal of maintaining three). Preventive maintenance activities are being completed as scheduled with no deferral or delinquent trends.

� Path Forward Maintenance will continue to support the UF6 facility with resources to maintain acceptable system operability.


�

�

6.12 Groundwater Treatment Facilities (GWTF)

GWTF Operations provide support of the remediation of the PORTS groundwater plumes in accordance with the U.S. EPA Administrative Order by Consent. GWTF Operations and Maintenance are performed at the X-622, X-623, X-624, X-625 (maintenance only), X-627 plants and X-701E Neutralization Building, which is a support facility for X-623, treating groundwater from the Quadrant (Q)-I X-749 and the 5-Unit plumes, and the Q-II X-701B and 7-Unit plumes. The four GWTFs exist for groundwater pump and treat in Q-I and Q-II. In the last 10 years, an average annual combined total of approximately 31 million gallons of water were treated at the X-622, X-623, X-624, and X-627 GWTFs. Associated with the operations of the GWTFs are the 29 extraction wells and the transfer system pipelines.

All of the GWTFs have various issues which potentially could impact their ability to operate in accordance with the regulatory drivers. The effluent flow meters in all of the facilities which measure the amount of groundwater treated in order to be in compliance with the NPDES Permit require preventive maintenance to ensure accuracy. The air compressor in X-622 is failing and will be replaced with a spare compressor from X-701E. The #1 pump & motor in the X-749 EQ tank needs troubleshooting to get it operating again. The backup pump is operating but the system needs both available. This is a single point of failure for transferring groundwater from the 10 extraction wells in the X-749/X-120 plume. Additionally there are several X-622 extraction wells which need maintenance to free sticking float switches, change out fuses, troubleshoot control panel issues, etc. The X-623 GWTF, which operates only as needed, has increasing issues with the electronic controls. This is due to both age and inactivity. If this GWTF were to be operated more frequently than it is now, a significant amount of maintenance would be required to update the antiquated controls, and change out failing pumps and motors throughout the facility. The X-624 GWTF is the oldest facility (the treatment system is the newest having been updated in 2006) and the two extraction wells here need their controls updated to enhance reliability and to standardize with the other extraction wells. Additionally, the TCE meter on the Vapor phase carbon vessels needs repairing, and a work request is in the system. In the X-627 GWTF, the ultra-sonic tank level indicator needs repair along with work on several system valves which don’t function properly. X-627 treats water from the X-700 and X-705 building sumps and cannot be shut down for any extended period of time without negatively impacting X-700 and X-705.

� Path Forward The Environmental Management group works closely with the S&M groups to set appropriate priorities and ensure that the facilities remain compliant. All of the work is either in planning, planned or resident on the list of priorities for completion.

6.13 Air Monitoring Network

The Portsmouth Air Monitoring Network consists of 16 ambient air monitoring stations, 6 of which are on-site and 10 at various locations in the surrounding countryside. Issues with the air stations are normally corrected as soon as they are reported and a work request submitted. There is currently only one open issue, the X230A-T7 air station has lost power.

� Path Forward Power Operations is investigating the issue. New work will be completed as it is identified to keep the Air Monitoring Network functional.


�

�

6.14 Groundwater Monitoring Network

The Portsmouth Groundwater Monitoring Network consists of approximately 900 groundwater monitoring wells and piezometers, both on-site and on various properties in the surrounding countryside. Maintenance requirements here, to remain compliant with OEPA requirements include repainting well casings; repairs to well pads; replacement of well lids; and cleaning or installing weep holes.

� Path Forward Work will be completed this year as planning is accomplished.

6.15 X-120H New Weather Tower

The X-120H Weather Tower (“Met Tower”) is used to monitor and record meteorological data for both environmental monitoring and emergency management purposes. Routine operation of the Weather Tower and associated facilities includes: instrument change out on a semi-annual basis for calibration; a tower inspection by an independent contractor every other year; and additional inspection by PORTS between the independent inspections.

� Path Forward A modification is planned to update the tower’s hardware and software system- the original system was installed in late 1994 and went on line in early 1995. An RFP has been issued for the independent inspection; the instrument change out is a scheduled PM; and an ESO has been initiated for the updating project. The project will be scheduled for completion during FY15.

6.16 Holding Ponds

The site has multiple holding ponds that are used to ensure surface water is compliant with the Clean Water Act standards before it exits the Site. Many of these ponds are equipped with oil containment booms, flow and pH instrumentation, valves and piping that allow them to function for their intended purpose. In many cases these items are failing due to age, severe weather, and lagging service and maintenance.

� Path Forward Engineering Service Orders (ESO’s) and work requests have been submitted for all known issues that exist at the holding ponds. The repair and upgrade work at these facilities is prioritized and will be completed in an order of importance.

6.17 Single Point Failures

The deteriorating condition of the infrastructure has outpaced the ability to maintain it at current funding levels. As a result, a significant backlog of deferred corrective and preventative maintenance has accumulated. The resulting risks from unplanned utility outages by deferring maintenance are growing and shared by all PORTS tenants.

The utility and infrastructure upgrades currently in progress are limited and primarily focused on maintaining safety systems, regulatory compliance and mission critical systems. Utility systems having redundant and/or back-up systems have received lower priority for corrective and preventative maintenance work.


�

�

As a result of this funding-driven approach, the list of key Utility and Infrastructure components are either currently Out-of-Service (OOS) or are found to be in a state of ‘single point failure’ continues to grow and is summarized in the table below.

Table 6.2 - Summary of Power and Utilities Operations - Single Point Failures

Facility/System Single Point Failure Description

Restoration Description Expected Duration

X-530 North Bus

Transformer T208 single power source for north bus.

Transformer T207: Out-of service for X-550 substation project. T207 will provide one source of power to the new substation

Restoration upon completion of the X-550 substation project.

X-611B lagoon Diesel Generator providing power.

X-611B transformer, cables, and switch box has been replaced. Transformer oil was purchased and will be added week of 04/21/14.

Normal power can be restored after transformer oil is added and system tested.

X-614P Sewage Lift Station

Both raw sewage pumps are out-of-service. Vacuum truck being used to keep from overflowing.

Two new pumps and motors are on site, in addition to new level controls. This job needs planned and scheduled.

Restoration in summer of 2014

X-670DAP/RCW

The new Dry air system out-of-service.

X-330 DAP and X-326 DAP providing dry air to site.

Restoration planned for March 2015

Raw Water Supply

1. X-6609 well field out-of-service for air relief repairs and well battery replacement.

2. X-608B start/stop O/S from X-611 River Flooded – can’t change well operation.

#4 well pole-mounted transformer was replaced, but rotation needs checked. Control batteries for wells need replaced. The air relief repairs need leak checked once wells are in service.

Restoration expected 05/06/14. River level at flood stage, cannot access wells.

X-300 SCADA SCADA breakers single power source.

Breakers require corrective and preventive maintenance to restore double ended power source to SCADA substation.

Restoration expected in the fall of 2014

Similarly, S&M programs to proactively characterize and address the deteriorating infrastructure require additional funding. The following Surveillance and Maintenance (S&M) work has been recently placed on hold:

� The sitewide Utility Pole Inspection Program was recently placed ‘on-hold’ due to a lack of FY14 funding. A total of 82/900 sitewide utility poles have been inspected; resulting in one utility pole’s condition being rated ‘severe’ requiring immediate replacement; and seven utility poles’ condition being rated ‘unsatisfactory’ requiring replacement within the next year.


�

�

� Isolation of the X-608 Pump House would reduce S&M costs and environmental risks; however, lack of funding has precluded required planning and implementation of deactivation activities (e.g., removes abandoned oil, isolate power, etc.).

In summary, a number of key SSCs at the PORTS site continue to experience degradation that places increasing reliance on compensatory measures and increase the likelihood and consequence of equipment failures. Mechanisms have been developed to track and monitor the infrastructure at PORTS, and plans have been developed to address each affected system. The System Health Report, Infrastructure Plan, and the Corrective Maintenance Management System are all tools used to ensure the correct resources are being applied as available to maintain the systems. Even though resources are being applied as efficiently as possible, the systems are old, in some cases neglected, large and complex and more resources than those currently budgeted will be required to adequately maintain them


�

�

7. BACKLOGS AND TRENDS

The following sections present an analysis of the FBP maintenance backlog including total backlog performance, corrective maintenance (CM) backlog aging and trend, preventive maintenance (PM) performance, issue management trends and recent history of personal radiation and contamination events. Overall the CM and PM backlogs continue to grow. This includes backlogs for safety-related SSCs, but most of these are out of service and required safety envelopes have been maintained. Overdue Issues dropped steadily and significantly over the first six months this data was tracked, and have held steadily in the <10% range for the past year.

7.1 Total Backlog Performance

FBP began monitoring total backlog against new and closed work orders in October 2013. Figure 7.1 below shows the trend of the total backlog, which has shown a slight increase for the FY through April 2014. This data illustrates that work requests are being received faster than they are being closed - resulting in a steady increase in overall backlog. Currently, FBP is receiving 1075 work requests on average each month, and closing an average of about 850.

Additional detail on CM and PM backlog trend by equipment category are presented in Section 7.2.

7.2 Corrective Maintenance Backlog Trend

Figure 7.2 presents the current CM backlog by age and type, and Figures 7.3 through 7.5 illustrate the CM backlog trend over the past two years. The trend is negative, as the CM backlog has continued to climb. Early in 2012 FBP completed an extensive review and scrub of the existing backlog transitioned from USEC and evaluated it relative to the current mission. As a result of this review, FBP cancelled a majority of the existing CM backlog as many of the items were determined to be no longer needed. However, what was not understood at that time was the level of resources that would be needed to maintain the existing SSCs and keep the backlog in equilibrium. Resources have not been adequate to


�

�

keep pace with CM demand, leading to steady rise in backlog. Figures 7.3 through 7.5 illustrate the overall CM backlog is increasing in all three categories (i.e., safety-related, regulatory and general/balance of plant). These figures also show the greatest increase in the general/balance of plant category, since higher priority was assigned to the safety-related and regulatory categories. The CM backlog associated with the safety-related systems makes up around 10% of the overall CM backlog. When a safety-related SSC is unable to perform its intended safety function, affected systems are placed in an operational mode for which the safety-related SSC function is not required, and/or approved compensatory measures are implemented.

�

��


�

�


�

�

7.3 Preventive Maintenance Performance

PM activities are scheduled based on predefined periodicities. When a PM is not performed by its scheduled due date, an evaluation is conducted to determine whether or not a grace period may be allowed. Typical grace periods for PM intervals of one month and longer are 25% of the prescribed maintenance interval, although regulatory requirements may preclude grace period altogether. Safety-related PMs may be allowed a grace period from time to time, but the average PM interval over the long term must be maintained. If a prescribed PM for a safety-related system is not performed by the end of the grace period, the associated system(s) is (are) removed from service and/or compensatory actions implemented.

As of May 1, 2014, there were 132 PM activities in their grace period (see Figure 7.6 below).

�

If a PM activity is not completed by the end of the grace period (or by the scheduled due date for those without a grace period), the PM becomes delinquent. Figure 7.7 illustrates the two-year trend for delinquent PMs across FBP, which indicates a stable trend of approximately 330 delinquent PMs compared to 500 or so per month that are performed. The highest priority over the past two years has been on completing the safety-related PMs, followed by the regulatory PMs, with the lowest priority being the general/balance of plant PMs. The number of delinquent PMs associated with the safety-related and regulatory PMs is relatively small overall, and in each case, these delinquent PMs have been evaluated by system engineering to determine their significance, and required actions have been taken to meet safety and regulatory requirements. Actions to address these have included compensatory measures and/or placing the affected system(s) out of service until the PM activity is completed. Delinquent safety-related PMs included, for example, the autoclave condensate and conductivity probes in X-344A, deferred based on as-found conditions provided to engineering for evaluation. The autoclave was removed from service until the PM had been successfully completed.


�

�

�

7.4 Planned Maintenance Improvements

There are several enhancements, either ongoing or planned, with respect to the maintenance program at FBP. Below are the three ongoing program improvements to more formally and effectively optimize management of maintenance backlogs.

Development of Reliability Centered Maintenance (RCM) Program RCM is a systematic, qualitative decision making methodology that defines the most cost effective Preventive Maintenance (PM) tasks for plant equipment. The objective of any modern-day PM program is to focus on improving life cycle and equipment availability and reliability. The current S&M inefficiencies are placing a tremendous burden on effective performance of PM activities, with many missing their established due dates, thereby increasing the likelihood of equipment failure. Implementation of an effective and appropriate RCM program will ensure FBP is performing the “right” PM activities in order to manage the consequence of failures as they occur. With the site’s mission being D&D, implementing the appropriate elements of RCM will reduce the implementation costs, reduce the burden on S&M, and ensure reduction of overall life cycle costs.

A Maintenance and Work Control (M&WC) Performance Improvement Plan (PIP) has been developed to drive improvement in the overall S&M program, including implementation of an RCM program. With over 6,500 existing active PM activities, FBP is committed to implementing the elements of an effective RCM program with the initial focus on the safety related and critical infrastructure and mission-essential systems.

Maintenance Prioritization Criteria and Process ISMS Guiding Principle No. 4 states: “Resources are effectively allocated to address safety, programmatic, and operational considerations. Protecting the workers, the public, and the environment is a priority whenever activities are planned and performed.” On March 17, 2014, FBP implemented a new Integrated Work Control Program (IWCP) focused on enhancing ISMS at the activity level. With this IWCP came a new prioritization process. This prioritization process will ensure the S&M focus is placed on the safety-related and mission-critical SSCs first before other activities are addressed.


�

�

Maintenance Committee There has been a great deal of change in the S&M areas since FBP took control of the Portsmouth Site. Much of this change has been positive, although there have been a few enhancements that have not achieved the desired results. FBP is, therefore, considering implementing a Maintenance Committee comprised of stakeholders from various organizations and levels within FBP to improve effectiveness and efficiency of the maintenance function in the current dynamic environment.


�

�

7.5 Average Age of Open Corrective Action Process Items

Equipment and system deficiencies can be identified multiple ways, including during operator rounds, supervisor or manager walk arounds, assessments, surveillances, inspections, and occurrences. When the equipment owner or facility manager is notified of a deficient condition the manager will submit a work request under the Integrated Work Planning and Control process to correct the deficiency. If the deficient condition involves safety, impacts facility operation or involves an event, a Problem Report (PR) is generated using the site Issues Tracking System (ITS) to track the issue to closure. Based on the significance of the discovered condition or event, an extent of condition review may be conducted to identify and prevent issues with similar equipment before a failure occurs. In addition, FBP uses the DOE complex Operating Experience (OE)/Lessons Learned (LL) program to evaluate relevant and significant events at other DOE sites for applicability at FBP. If OE/LL is determined applicable to the site work activities/equipment, a problem report is generated for tracking required actions in the ITS. The ITS also tracks many other types of issues not related to equipment or system deficiencies.

A review was completed of all open Issues and Actions recorded in the FBP Issues Tracking System (ITS). An Issue is a deficiency, concern, or observation documented on a Problem Report (PR), and Actions are the specific corrective measures being taken to resolve the Issue. There will be one or more Actions for each Issue, unless the Issue is resolved before the period allowed for developing associated Corrective Actions expires. Issues are categorized as deficiencies, concerns, or observations with deficiencies and concerns being more serious. Once an Issue is identified in ITS, one or more Actions to correct the Issue may be assigned or the Issue may be closed once the work request is submitted, depending upon categorization.

As indicated in Figure 7.8 below, current ITS data indicates that approximately 65 percent of all open Issues and 75 percent of all open Actions are less than seven months old. Review of just the open Issues categorized as deficiencies and concerns (ignoring the observations) in ITS, reveals that over 50 percent of these PRs are less than three months old, with most of the remainder less than 12 months old.

�

Over 280 Issues are identified via Problem Reports each month, and this rate has been relatively constant since September, 2012. Issues are being resolved at a fairly constant rate of 250 per month for this same time period. Consequently, the number of open Issues being tracked has continued to grow. Some of this growth is a result of workers being more willing to report issues for resolution now than in the past. Figure 7.9 shows the ratio of open Issues to the number of new Issues generated each month since

0

50

100

150

200

250

300

Figure 7.8 - Open Issues & Action by Age as of April 2014

Issues Actions


�

�

September, 2012, and indicates that the backlog of open issues is steadily growing. As discussed in the next section, while the number of open Issues has been increasing, FBP has significantly improved its management of Issues since September 2012.

�

7.6 Number of Corrective Action Process Items Overdue

Management of Issues and Actions has significantly improved since September 2012. As shown in Figure 7.10 below, overdue Issues have decreased from between 40 to 50 percent of open Issues in September and October of 2012 to approximately 7 percent of open Issues by April 2014. The percentage of overdue corrective actions has experienced a similar significant decline. The current trend shown by the thin line in Figure 7.10 indicates improvement in FBP’s issues management practices.

0.00.51.01.52.02.53.03.54.0

Sep�

12O

ct�1

2N

ov�1

2De

c�12

Jan�

13Fe

b�13

Mar

�13

Apr�

13M

ay�1

3Ju

n�13

Jul�1

3Au

g�13

Sep�

13O

ct�1

3N

ov�1

3De

c�13

Jan�

14Fe

b�14

Mar

�14

Apr�

14

Figure 7.9 - Ratio of Open Issues to Issues Generated vs. Month Shows Number of Open Issues Growing

Open�Issues��vs�Issues�Generated

0

10

20

30

40

50

60

% o

f Ope

n Is

sues

Ove

rdue

Figure 7.10 - % Issues Overdue vs. Monththrough April 2014

Monthly�%�Past�Due Poly.�(Monthly�%�Past�Due)


�

�

7.7 Number of Personal Radiological & Chemical Contaminations

Radiological and chemical contamination events have been few and minor in nature, and no trend related to facility or equipment maintenance deferrals emerged.

No personal contamination events were identified prior to September 2013. ORPS reportability is determined using reporting criteria contained in DOE O 232.2 and in FBP occurrence reporting procedure. A review of available data found no reportable skin contaminations in the past two years, and two reportable clothing contaminations. These were unrelated incidents; one involved potential wicking of contamination through a seam in an anti-contamination garment and the other involved contamination of an employee’s boot due to a small tear in an anti-contamination bootie. The wicking occurred in a production environment; the small tear occurred in a laboratory environment.

Table 7.1 below presents the data on non-reportable skin and clothing contamination since March 2012. There were seven non-reportable clothing contamination events and two non-reportable skin contamination events. These events do not suggest a negative trend.

Table 7.1 – Non-Reportable Skin and Clothing Contamination Events since March, 2012

Date Type Description of Event

Jan 2014 Skin X-344 employee alarmed PCM2 when exiting the autoclave contamination area. Skin In X-326 an employee found a spot of contamination (8000 dpm/100cm2

beta/gamma) on crown of head (hair) after performing surveys on CAAS clusters that were in alert in an area flooded with water. Employee found the contamination while surveying out of the area. Final surveys with showed no activity.

Sept2013

Clothing X-326 Cut & Cap worker alarmed PCM2 while exiting area after working in cell 25-6-17 of X-326 Cascade building.

Oct2013

Clothing In X-326 a chemical operator found ~25k dpm/100cm2 beta/gamma on bottom front of scrub shirt. No skin contamination was detected. Employee had been deconning in a high contamination area. Employee was wearing appropriate PPE for the area and task.

Nov2013

Clothing In X-326, an employee alarmed the PCM2 at column U-56 upon exiting the contamination area after cleaning highly contaminated equipment. Monitoring detected 46,000 dpm/100cm2 Beta contamination on his left blue coveralls sleeve.

Clothing In X-326, an employee detected contamination on his right forearm when monitoring out of the area at the PCM2. He had been cutting compressor lines with a reciprocating saw.

Clothing X-710 lab employee alarmed PCM2 while exiting a Contamination Area. Initial survey found no contamination. Employee changed into freshly laundered coveralls and re-surveyed. PCM2 alarmed again. Survey of original coveralls found ~6500dpm/100cm2 on right cuff. The new coveralls had approximately 5000dpm/100cm2 on the right cuff.

Clothing In X-326, a Cut & Cap employee alarmed PCM2 and survey showed 37000 dpm/100cm2 beta and 0 dpm/100cm2 Alpha contaminations on right chest area. A whole body scan was performed and no skin contamination was found. Employee changed coveralls and cleared PCM.


�

�

Date Type Description of Event

Feb2014

Clothing X-326 Cut & Cap worker had 80 dpm/100cm2 alpha and 21k dpm/100 cm2

beta/gamma on right thigh of company issued coveralls. No skin contamination detected. Employee had been setting up for PEH compressor buffering in contamination area. Employee was wearing appropriate PPE required by the RWP.

FBP Industrial Hygiene tracks potential chemical exposures based on air monitoring data. As shown in Table 7.2, there was one actual exposure and one apparent chemical exposure reported within the past two years. There were no exposures above threshold limit values (TLVs). The identified instances were determined to be isolated events; there are no negative trends in personal chemical exposures

Table 7.2 – Chemical Exposure Events since April 2012

Date Type Description of Event June 2012 Actual

exposureIn X-710 laboratory a technician moving a glass 2.5 liter bottle of nitric acid shattered the bottle when it bumped another bottle. The employee was splashed on the arm and face and received minor nitric acid burns.

Jan 2013 Apparent exposure

In X-326 a radiological control technician (RCT) detected high levels of hydrogen fluoride (HF) near an opening in equipment that was being prepared for removal from the X-326. After evacuating other employees from the area, the RCT and a Mechanic placed a metal cap over the equipment opening to mitigate any continued release of HF. During that evolution the RCT’s cloth hood gapped, exposing the neck area to the HP vapors. The injury was diagnosed by the Site Occupational Medical Director as a first degree HF burn.

Portsmouth/Paducah Project Office (PPPO)

Office of Environmental Management

DEPLETED URANIUM HEXAFLUORIDE CONVERSION PROJECTDOE PPPO Integrated Project Team

Assessment Report

Of

BABCOCK & WILCOX CONVERSION SERVICES, LLC

Extent of Condition Review on Safety Systems Deferred Maintenance IAW EM Memo dated April 16, 2014

May 2014

Executive SummaryAt the request of Acting Assistant Secretary for Environmental Management (EM), the Department of Energy (DOE) Portsmouth/Paducah Project Office (PPPO) and Integrated Project Team (IPT) performed an Extent of Condition assessment of Babcock & Wilcox Conversion Services, LLC (BWCS) on Deferred Maintenance. The assessment was performed at the Piketon Conversion Facility on May 5-8, 2014. The assessment continued through May 21, 2014 through remote access to folders and files containing evidence for the identified 30 area review as contained in the EM Memorandum dated April 16, 2014.

The DUF6 Project at Portsmouth, Ohio and Paducah, Kentucky: - Applies sufficient resources to maintain system and equipment maintenance. - Maintains configuration control for the safety related systems. Some minor deficiencies,

associated with maintenance and configuration control, had already been identified through normal oversight activity and assessments and are being addressed through corrective actions via the condition reporting system.

- Institutes necessary upgrades through plant modifications performed through scheduled plant outages. Ongoing Throughput Improvement Team Meetings are conducted to evaluate and implement additional modifications to support system infrastructure requirements and growth to improve overall operations and maintenance support.

- Maintains overall facility operational readiness through diligent effort to repair and understand equipment related issues that could impact operations. The focus to repair and understand equipment and operational problems renders the cumulative impact of degraded equipment insignificant on operational readiness.

The review identified some weak areas associated with: � timeliness and consistency with resolving previously noted alarm management

concerns from a Conduct of Operations Assessment in March 2013 � senior management documented corrective action tracking and follow-up � temporary procedure processing times � increasing use of the grace period for Technical Safety Requirements (previously

identified in a recent Field Inspection Report (FIR C-201403-007)

These items have been captured in the condition reporting system for action and follow-up.

Additional areas reviewed during this assessment included cylinder hauler maintenance, including fire suppression systems, and vehicle inspections entering the site. Routine inspections are occurring within scheduled frequencies at both sites.

Technical Report

1.0 Introduction

The Extent of Condition on Deferred Maintenance Review Assessment scope focused on the 30 areas/topics identified in the EM Memorandum referenced above. Additional areas reviewed included cylinder hauler maintenance, including fire suppression systems, and vehicle inspections entering the site.

2.0 Scope

Peter Burban (DOE) was assigned as the Team Leader for this assessment and was assisted by Greg Bazzell (DOE), John Saluke (DOE), Jim Kenney (DOE-IPT), Jay Collins (DOE-IPT), and Ray Fischels (DOE-IPT).

The assessment team reviewed documentation surrounding the 30 identified areas in the EM Memorandum dated April 16, 2014 directing an extent of condition review on deferred maintenance. Evidence files with information gathered to address the focus areas were created and posted to a shared drive (BWCS “S” drive “Engineering Review/TIP/EOC for Deferred Maintenance”) to aid in review of the respective areas. Two additional evidence folders were established at DOE’s request to provide for reviewing information associated with plant modifications as well as cylinder handling equipment and waste transportation vehicle inspections. A total of 32 folders were created and populated with relevant information surrounding the topics requested in the EM Memo and the two additional areas mentioned above.

3.0 Technical Review

1� Number�of�unplanned�TSR�Limited�Conditions�of�Operability�(LCO)�entries�

Currently�no�unplanned�TSR�LCO�entries�exist.��The�Project�averages�about�one/month/plant�or�less,�over�the�last�2�years.��The�majority�of�previous�LCO�entries�include�autoclave�isolation�valve�and�pressure�switch�issues�that�have�been�trending�downward�with�material�upgrades�and�modification�changes.��Other�entries�include�equipment�leak�related�problems�in�HF�systems�that�are�also�trending�downward�over�time�with�torque�practices�and�gasket�improvements.��The�Project�maintains�metrics�in�this�area�which�are�discussed�monthly.�

2� Number�of�inoperable�control�room�indicators�and�controls�

“Forced�values”�were�used�as�an�indicator�for�inoperable�control�room�indicators�and�controls.��Piketon�has�5�active�forced�values�that�are�on�non�safety�systems.��Paducah�has�70�90�forced�values�which�do�not�involve�a�safety�function.��

Corrective�maintenance�will�resolve�approximately�½�the�forced�values,�and�the�other�½�will�be�resolved�as�resources�become�available�to�eliminate�nuisance�alarms.��Paducah’s�forced�value�numbers�are�significantly�higher�than�Piketon’s�due�to�Paducah�has�used�forced�values�as�a�method�to�eliminate�“nuisance�alarms”.��A�Condition�Report�(CR)�(14�00200)�was�generated�to�generate�guidelines�and�evaluate�the�outstanding�forced�values�for�a�more�permanent�fix�(software�change�or�modification)�to�the�nuisance�alarms.�

3� Number�of�lit/alarming�control�room�annunciators�

Alarm�management�has�been�identified�as�a�weakness�during�a�Conduct�of�Operations�Assessment�(PPPO�01�1901082�13)�performed�in�March�2013.��BWCS�issued�a�CR�(13�00199)�to�address�the�issue.��Corrective�actions�remain�open�due�to�lack�of�resources�to�identify,�prioritize,�and�eliminate�nuisance�alarms.��There�are�over�40�alarms�currently�locked�in�at�both�sites�that�are�“expected”�for�the�“normal”�conditions�that�need�resolution�to�eliminate�nuisance�alarms.��The�list�of�alarm�management�Software�Change�Requests�attached�to�the�condition�report�lacks�prioritization�and�specifics�to�correct�the�identified�issues.��DOE�will�continue�to�track�and�monitor�progress�to�improve�alarm�management.�

4� Corrective�maintenance�backlog,�age,�and�trend�

Corrective�maintenance�backlog�has�trended�downward�over�the�last�two�years.��Currently,�Paducah�is�at�141�and�Piketon�is�at�87,�both�below�the�goal�for�the�respective�site.��Approximately�20�of�the�141�at�Paducah�and�7�of�the�87�at�Piketon�are�associated�with�safety�related�systems�which�have�been�screened�for�safety�basis�and�mission�impact.��Plant�operability�has�not�been�impacted�by�current�backlog�levels.��Fire�Protection�area�was�also�reviewed�and�work�orders�were�found�in�the�system�at�both�plants.��None�of�the�work�orders�are�associated�with�TSR�credited�components.��Piketon�had�4�active�fire�impairments�and�associated�work�orders�to�effect�repairs.��Paducah�had�no�active�fire�impairments�but�did�have�11�fire�system�corrective�maintenance�work�orders.��Paducah�has�aged�corrective�maintenance�for�fire�system�repairs�and�they�are�currently�being�evaluated�for�subcontract�work�at�Paducah.��The�Project�maintains�metrics�in�this�area�which�are�discussed�monthly.��Fire�protection�impairments�are�not�in�the�current�metrics�but�are�being�evaluated�for�inclusion�on�future�metric�reports.�

5� Preventive�maintenance�backlog,�and�in�grace�period,�and�trend�

Preventive�maintenance�(PM)�backlog�has�trended�downward�over�the�last�two�years.��The�Project�maintains�metrics�in�this�area�which�are�discussed�monthly.��Currently,�Paducah�is�at�27�and�Piketon�is�at�21,�both�below�established�goals.��Additionally,�the�PM�backlog�does�not�contain�any�safety�system�related�

items.��PM’s�are�tracked�at�the�daily�status�meeting�to�ensure�completion�within�established�time�frames.��The�Project�maintains�metrics�in�this�area�which�are�discussed�monthly.�

6� Surveillances�performed�in�grace�period�and�trend�

Currently�there�are�no�surveillances�in�the�grace�period�scheduled�for�performance.��A�DOE�Field�Inspection�Report�(C�201403�007)�performed�in�March�2014,�identified�valve�leak�check�and�interlock�performance�as�an�area�of�concern�due�to�42%�of�the�surveillances�reviewed�had�utilized�the�extension�period�with�the�frequency�of�using�the�extension�period�as�increasing.��A�CR�(14�00176)�was�issued�to�evaluate�use�of�the�extension�period.��The�Project�maintains�metrics�in�this�area�which�are�discussed�monthly.�

7� Safety�system�availability� All�safety�systems�are�normally�maintained�operable/available.��Scheduled�surveillance�activity�and�unplanned�entries�into�the�LCO�process�will�render�a�safety�system�inoperable�but�they�are�restored�within�allowable�TSR�timelines�and�restrictions.��The�Project�maintains�metrics�in�this�area�which�are�discussed�monthly.�

8� Number�of�safety�system�challenges(number�of�times�a�safety�system�has�been�demanded�to�respond�or�be�manually�initiated)�

Averaging�about�1/month�total�from�both�plants�combined�and�that�number�is�dropping�as�we�continue�into�FY14�to�approximately�1�every�2�months.��FY14�to�date�has�experienced�4�total�challenges�and�FY13�experienced�12�total�challenges.��The�Project�maintains�metrics�in�this�area�which�are�discussed�monthly.�

9� Number�of�unplanned�safety�system�actuations�

Same�as�#8�above.��The�Project�maintains�metrics�in�this�area�which�are�discussed�monthly.�

10� Corrective�action�process�(issues�management�system)�items�initiated�and�trend�

Initiated�~�30�50/month�on�a�relatively�constant�trend.��The�Project�maintains�metrics�in�this�area�which�are�discussed�monthly.�

11� Average�age�of�open�corrective�action�process�items�(both�open�issues�and�open�corrective�actions)�

The�majority�of�the�Condition�Reports�are�contained�in�the�less�than�90�day�old�category.��Smaller�percentages�reside�in�the�90�180�day�category�and�an�even�smaller�percentage�resides�in�the�greater�than�180�day�category.��However,�the�greater�than�180�day�category�percentage�has�recently�been�creeping�up�which�is�indicative�of�lingering�corrective�actions�and�condition�report�close�out�associated�delays.��The�Project�maintains�metrics�in�this�area�which�are�discussed�

monthly.�12� Number�of�corrective�action�

process�items�overdue�CR�overdue�numbers�have�risen�slightly�over�the�past�6�months�to�~10�due�to�spring�outage�focus�at�both�sites.��Previous�months�average�values�of�~2�4�are�more�typical�of�overdue�CR�numbers.��This�metric�is�monitored�closely�by�contractor�and�oversight�management.��The�Project�maintains�metrics�in�this�area�which�are�discussed�monthly.�

13� Number�and�rate�of�human�performance�errors�

Human�performance�error�tracking�began�formally�in�July�2013�when�a�continuing�poor�trend�in�conduct�of�operations�issues�demanded�improved�metrics�and�tracking�in�this�area�for�improvement.��Since�July�of�2013,�the�Paducah�plant�has�had�approximately�20�human�performance�related�errors�that�impacted�plant�operations�and/or�maintenance.��The�average�time�between�human�performance�related�events�has�improved.��Piketon�is�currently�adopting�a�human�performance�system�like�Paducah’s.��Using�the�CR�system,�Piketon�has�reported�24�errors�categorized�as�having�human�performance�implications.��The�Project�maintains�metrics�in�this�area�which�are�discussed�monthly�and�are�part�of�the�Quarterly�Trend�Analysis�performed�by�BWCS.�

14� Number�of�abnormal�procedure�entries�

The�absence�of�abnormal�operating�procedures�was�identified�in�the�March�2013�conduct�of�operations�assessment.��The�first�abnormal�operating�procedures�to�cover�the�most�frequent�process�shutdowns�were�implemented�near�the�end�of�2013�in�Paducah�and�in�February�2014�at�Piketon.��Since�implementation,�Paducah�has�had�15�entries�into�abnormal�procedures�and�Piketon�has�had�2,�primarily�at�both�sites,�DUF6�shutoff�and�isolation.��Plans�are�to�continue�to�develop�abnormal�operating�procedures�as�resources�permit.�

15� Number�of�emergency�procedure�entries�

Emergency�procedure�entries�are�few�with�four�occurring�at�each�site�over�the�last�two�years.��They�included�at�Piketon:�smoke�issuing�from�cylinders�during�modification,�cylinder�movement�equipment�contact�with�cylinders,�and�a�HF�leak�by�the�outside�tanks.��At�Paducah:�oxide�powder�releases,�a�tornado�warning,�and�an�HF�leak�in�the�scrubber�room.��Emergency�procedure�entry�and�use�is�becoming�less�frequent�as�the�plant�matures�and�personnel�gain�experience�to�proactively�recognize�and�take�actions�to�avoid�emergencies.�

16� Number�of�unplanned�manual�process�shutdowns�

Paducah�experienced�22�unplanned�manual�process�shutdowns�in�FY14�to�date�and�40�in�FY13.��Manual�process�shutoffs�are�dominated�by�powder�discharge�and�blower�issues�that�have�been�significantly�reduced�with�modifications�to�system�operation�and�components.��Piketon�experienced�16�unplanned�

manual�process�shutdowns�in�FY14�to�date�and�38�in�FY13.��Piketon’s�manual�shutoffs�are�similar�in�nature�to�Paducah’s.��The�trend�is�improving�with�unplanned�shutdowns�becoming�less�frequent�at�both�sites.��The�Project�maintains�metrics�in�this�area�which�are�discussed�monthly.��Engineering�continuously�analyzes�opportunities�to�reduce�shutdowns�through�process�optimization.�

17� Number�of�unplanned�automatic�process�shutdowns�

Paducah�experienced�11�unplanned�automatic�process�shutdowns�in�FY14�to�date�and�27�in�FY13.��Automatic�process�shutoffs�vary�in�nature�but�have�been�significantly�reduced�with�modifications�to�system�operation�and�components.��Piketon�experienced�8�unplanned�automatic�process�shutdowns�in�FY14�to�date�and�22�in�FY13.��Piketon’s�manual�shutoffs�are�similar�in�nature�to�Paducah’s.��The�trend�is�improving�with�unplanned�shutdowns�becoming�less�frequent�at�both�sites.��The�Project�maintains�metrics�in�this�area�which�are�discussed�monthly.��Engineering�continuously�analyzes�opportunities�to�reduce�shutdowns�through�process�optimization.�

18� Number�of�procedure�non�compliance�events�

Procedure�non�compliance�events�have�been�lowering�over�the�last�couple�years�as�operators�and�the�procedures�become�more�mature.��Over�the�last�two�quarters�the�drop�has�been�more�profound�and�encouraging�as�procedure�non�compliances�associated�with�maintenance�and�operations�has�improved�from�~30%�of�all�non�compliances�to�about�15�%�in�the�last�quarter.��The�Project�conducts�Noncompliance�determination�trending�analysis�on�a�quarterly�basis.�

19� Number�and�age�of�LO/TO�hanging�

LOTO’s�greater�than�90�days�old�exist�at�Paducah�on�two�pieces�of�equipment.��One�is�on�the�waste�evaporator�(component�required�and�recently�received)�where�work�is�scheduled�to�begin�soon,�and�the�other�is�on�the�ETS�for�a�valve�that�needs�replaced�and�was�rescheduled�due�to�higher�priority�work.��Piketon�has�no�LOTO’s�in�place�greater�than�90�days�old.��The�contractor�conducts�quarterly�reviews�to�determine�LOTO�necessity�for�anything�greater�than�90�days�old.�

20� Number�and�age�of�temporary�modifications�

Paducah�has�3�temporary�modifications�in�place�which�will�be�eliminated�following�scheduled�contractor�work,�permanent�modification/design�change�and�future�equipment�installation.��Piketon�has�2�temporary�modifications�which�will�be�eliminated�following�permanent�modification/design�changes.��None�of�the�temporary�modifications�directly�affect�safety�system�operability.�

21� Number�and�age�of�inoperable� Both�plants�currently�have�no�inoperable�safety�systems�on�any�

safety�systems� commissioned/operable�equipment.��All�instances,�with�one�exception,�of�safety�system�inoperability�over�the�last�two�years�have�occurred�within�the�constraints�of�the�TSR’s�and�are�tracked�and�trended�as�unplanned�LCO�entries.��The�one�exception�was�an�inoperability�condition�associated�with�incomplete�post�maintenance�testing�of�a�HF�detector�strobe�light�at�the�Paducah�facility.��The�issue�was�resolved�by�re�performing�the�TSR.�

22� Safety�system�performance�(successful�or�not)�when�tested�

Safety�system�performance�was�successful�when�testing�operating�systems.��LCO’s�were�initiated�in�cases�where�surveillances�did�not�pass�due�to�calibration�or�response�time�frame�issues.��In�all�cases�the�system�was�restored�to�normal�within�the�LCO�actionable�period.��Both�sites�have�instituted�proactive�detector�testing�and�trend�evaluation�to�determine�if�any�procedural�and/or�material�changes�are�necessary.�

23� Safety�system�performance�(successful�or�not)�in�response�to�actual�demand�

Safety�system�performance�was�successful�in�all�actual�demand�cases.��See�#8�above�for�specifics.�

24� Number�of�spurious�safety�system�actuations�

Paducah:��8�in�FY13�and�14�combined�Piketon�:��4�in�FY13�and�14�combined�Most�of�the�spurious�alarms�have�been�bumped�detectors�which�have�been�reduced�through�improved�awareness�when�working�around�detectors,�and�circuitry�spikes�that�are�continuously�being�evaluated.��The�Project�maintains�metrics�in�this�area�which�are�discussed�monthly.�

25� Number�of�significant�unplanned�production�level�changes�

Numbers�provided�in�#16�above.��All�the�significant�unplanned�production�level�changes�occurred�primarily�as�a�result�of�powder�discharge�&�transfer�issues,�blower�failures,�process�pressure�indicators,�process�isolation�valve�limit�switches,�and�hydrogen�supply�reliability.��Material�changes�and�modifications�should�greatly�improve�this�area�over�time,�and�the�limited�operating�time�since�modifications�were�implemented�have�demonstrated�positive�results.��The�Project�maintains�metrics�in�this�area�which�are�discussed�monthly.�

26� Number�of�temporary�procedure�changes�

There�are�currently�18�open�temporary�changes�with�an�average�age�range�for�maintenance�procedures�of�273�days�and�an�average�range�for�operations�procedures�of�108�days.��This�review�has�caused�BWCS�to�update�its�procedure�revision�tracking�to�flag�temporary�procedure�changes�that�are�greater�than�60�days�old�for�management�attention�to�improve�processing�time�which�will�be�tracked�with�CR�(14�00192).�

27� Number�of�grievances� Safety�First�information�was�utilized�for�this�metric.��The�majority�of�concerns�are�resolved�within�30�days�with�an�average�of�about�4/month�generated�and�carrying�0�2�open/month�greater�than�30�days.��The�Project�maintains�metrics�in�this�area�which�are�discussed�monthly�to�include�corrective�action�progress�to�resolve�safety�first�issues.�

28� Management�of�observation�system�data,�number�of�observations�by�senior�managers,�number�of�management�observations�that�identify�deficiencies�and�result�in�corrective�action�

Senior�Manager�observation�data�(PM,�Deputy�PM,�and�Safety)�is�documented�but�there�is�little�formal�documented�evidence�that�the�identified�deficiencies�are�corrected.��The�contractor�initiated�a�CR�(14�00201)�to�correct�this�issue.�

29� Number�of�personal�contamination�events�

Piketon�Skin�Contamination:��FY13�–�0,�FY14�–�0�Paducah�Skin�Contamination:��FY13�–�0,�FY14�–�0�Piketon�Clothing�Contamination:��FY13�–�0,�FY14�–�5�Paducah�Clothing�Contamination:��FY13�–�0,�FY14�–�2��Condition�reports�have�been�written�for�the�clothing�contamination�events�and�the�associated�corrective�actions�are�being�tracked�and�monitored�closely.��The�Project�maintains�metrics�in�this�area�which�are�discussed�monthly.�

30� Number�of�personal�chemical�exposure�events�

There�have�been�no�confirmed�skin�chemical�exposure�or�personnel�exposed�to�air�concentrations�greater�than�established�limits.��The�Project�maintains�metrics�in�this�area�which�are�discussed�monthly.�

31� Plant�Modifications/Upgrades� Funding�has�been�established�and�utilized�over�the�past�two�years�to�execute�plant�operational�upgrades�to�support�continued�production�level�increases�as�plant�operations�continue�to�mature.�

32� Cylinder�Handling�Equipment�and�Waste�Transportation�Vehicle�Inspections�

Cylinder�handling�equipment�has�established�planned�maintenance�schedules�which�are�being�carried�out�at�each�site�and�daily�inspections�are�carried�out�prior�to�use.��Vehicle�inspections�are�routinely�performed�and�include�transport�vehicles�brought�on�site�for�loading�and�shipping�hazardous�materials�that�are�performed�before�the�vehicle�is�permitted�to�enter�the�plant�gate.�

4.0 Conclusion

The maintenance and engineering programs are effective in maintaining the overall DUF6 facility in a high degree of operational readiness. The Project maintains metrics in most of the areas reviewed as identified in Section 3 Technical Review. The Project team periodically modifies present metrics and adds additional metrics where deemed appropriate to further improve the organizational learning and feedback process.

Areas identified for improvement:

1. Timeliness and consistency with resolving previously noted alarm management concerns needs added management attention to resolve identified issues. CR-13-00199 continues to close out corrective actions and CR-14-00200 issued.

2. Senior management documented corrective action tracking and follow-up requires improvement. CR-14-00201 issued.

3. Temporary procedure processing times are aged and not being tracked to ensure processing times are timely. CR-14-00192 issued.

4. Technical Safety Requirement surveillances are utilizing the grace period extension with increasing frequency. CR-14-00176 issued.

5. The number of condition report greater than 180 day since initiation has slowly increased due to corrective actions lingering without resolution. This project metric is reviewed monthly and has gathered some attention for improvement.

6. Metrics to be evaluated for modification include: Forced values, inoperable control room indicators/controls, temporary modifications, temporary procedure changes, senior manager identified issues corrective action tracking, fire protection system impairments/challenges, and improved categorization/tracking of spurious-manual-automatic shutoffs.