DUF6-PLN-001
Rev. 3
DUF6-PLN-001
REV. 3
ISSUING ORGANIZATION:
BUSINESS SERVICES
EFFECTIVE DATE: 04/17/2019
REQUIRED REVIEW DATE:
04/17/2020
PAGE 1 OF 58
Project Management Plan
Prepared by: Business Services
Approved by: Zack Smith, President and Project Manager
DUF6-PLN-001
Rev. 3
APPROVAL PAGE
PREPARED BY:
See 4320
Sharon Shirley
Business Manager and Chief Administrative
Officer
Date
CONCURRED BY:
See 4320
Scott Nicholson
ESH&Q Manager
Date
See 4320
Fred Jackson
Chief Process Technical Officer and Chief
Engineer
Date
APPROVED BY:
See 4320
Zack Smith
President and Project Manager
Date
DUF6-PLN-001
Rev. 3
DISCLAIMER
This document was prepared by Mid-America Conversion Services, LLC (MCS)
under U.S. Department of Energy (DOE) Contract DE-EM0004559, and is intended
for use solely in conjunction with the Depleted Uranium Hexafluoride (DUF6)
Conversion Project. The information contained herein shall not be disclosed,
duplicated, or released in whole or in part for any purpose other than the DUF6
Conversion Project without the express written consent of DOE and MCS.
DUF6-PLN-001
Rev. 3
REVISION LOG
Revision
Effective
Date
Description of Change
Pages
Affected
0 03/15/17 Document supersedes DUF6-BWCS-PLN-001 Rev.6 All
1 06/06/18
Updated cover page and Figure 3-2. Updated section
3.5.2 to include functional and operational interfaces.
21-24 & 26
2 12/12/18
Updated Figure 3.2. Added Authorities and
Accountabilities
21-24 & 26
3 04/17/18
Per IA-18-016, Updated Roles, Responsibilities, Authorities
and Accountabilities, that documents "nuclear safety" as a
responsibility of ESH&Q Manager
53
DUF6-PLN-001
Rev. 3
TABLE OF CONTENTS
LIST OF FIGURES ........................................................................................................................... 8
ACRONYMS ................................................................................................................................. 9
EXECUTIVE SUMMARY ............................................................................................................... 12
1 INTRODUCTION ............................................................................................................... 17
2 SCOPE .............................................................................................................................. 18
2.1 Project Objectives ................................................................................................ 19
3 MANAGEMENT APPROACH ........................................................................................... 19
3.1 Project Organization ............................................................................................ 19
3.2 Roles, Responsibilities, Authorities and Accountabilities .................................. 21
3.3 Corporate Governance ...................................................................................... 21
3.4 Corporate Reachback ........................................................................................ 21
3.5 Project Interfaces ................................................................................................. 28
3.5.1 DOE Interfaces ....................................................................................... 28
3.5.2 Site Interfaces ........................................................................................ 28
Functional Interfaces ........................................................................................... 29
Operational Interfaces ........................................................................................ 29
3.5.3 Waste Management Interfaces .......................................................... 29
3.6 Project Reviews .................................................................................................... 30
3.7 Subcontractor Performance ............................................................................... 31
4 BASELINE MANAGEMENT AND CONTROL .................................................................... 32
4.1 Management System .......................................................................................... 32
4.2 Work Breakdown Structure .................................................................................. 33
4.3 Baseline Scope ..................................................................................................... 33
4.4 Baseline Schedule ................................................................................................ 33
4.5 Baseline Cost ........................................................................................................ 34
4.6 Change Management ........................................................................................ 34
5 PROJECT CONTROLS ...................................................................................................... 35
5.1 Project Control System ........................................................................................ 35
5.2 Earned Value Management System ................................................................. 35
5.3 Project Reporting ................................................................................................. 36
5.3.1 Reporting Systems ................................................................................. 36
5.3.2 Key Performance Indicators................................................................. 36
DUF6-PLN-001
Rev. 3
6 RISK MANAGEMENT ........................................................................................................ 36
7 ENVIRONMENTAL, SAFETY, HEALTH, AND QUALITY ...................................................... 37
7.1 Integrated Safety Management ........................................................................ 37
7.2 Occupational Safety and Health ....................................................................... 38
7.3 RadiologicaL Control ........................................................................................... 38
7.4 Nuclear Safety ...................................................................................................... 39
7.5 Environmental/Regulatory .................................................................................. 40
7.5.1 Regulatory Management ..................................................................... 40
7.5.2 National Environmental Policy Act Documentation ......................... 40
7.5.3 Public and Stakeholder Outreach and Involvement ........................ 41
7.6 Quality Assurance ................................................................................................ 41
7.6.1 Project Quality Assurance Plan ............................................................ 41
7.6.2 Assessments and Readiness ................................................................. 42
7.6.3 Contractor Assurance .......................................................................... 43
8 SAFEGUARDS AND SECURITY ......................................................................................... 43
8.1 Physical Security ................................................................................................... 43
8.2 Cyber Security ...................................................................................................... 44
9 PLANT OPERATIONS ........................................................................................................ 45
9.1 Operations Management ................................................................................... 45
9.1.1 Process Facilities Operations ................................................................ 46
9.1.2 Cylinder Yards Surveillance and Maintenance ................................. 46
9.2 Conversion Product Management .................................................................... 47
9.3 WASTE MANAGEMENT ......................................................................................... 48
10 SYSTEMS ENGINEERING ................................................................................................... 48
10.1 Description ............................................................................................................ 48
10.2 Process .................................................................................................................. 48
11 SAFETY BASIS DOCUMENTATION.................................................................................... 49
12 CONFIGURATION MANAGEMENT ................................................................................. 49
13 PLANT DESIGN ................................................................................................................. 50
13.1 System Requirements Documents...................................................................... 50
13.2 Conceptual Design Reports ............................................................................... 51
13.3 Facility Design Documents .................................................................................. 51
14 RECORDS MANAGEMENT AND DOCUMENT CONTROL ............................................. 51
14.1 Document Control ............................................................................................... 51
14.2 Records Management ........................................................................................ 52
DUF6-PLN-001
Rev. 3
15 CONTRACTS AND SUPPLY CHAIN .................................................................................. 52
15.1 Subcontractor Oversight ..................................................................................... 52
15.2 Staff Augmentation ............................................................................................. 53
15.3 Small Business Goals ............................................................................................. 53
16 REFERENCES..................................................................................................................... 54
17 ATTACHMENTS ................................................................................................................. 57
ATTACHMENT A - DUF6 Contract Work Breakdown Structure ................................................. 58
DUF6-PLN-001
Rev. 3
LIST OF FIGURES
Figure ES-1. Key MCS Management Positions .......................................................................... 14
Figure 3-1. Key MCS Management Positions ............................................................................ 19
Figure 3-2. Key Management Staff Roles and Responsibilities .............................................. 21
Figure 15-1. MCS Small Business Subcontracting Goals .......................................................... 50
DUF6-PLN-001
Rev. 3
ACRONYMS
ANSI
American National Standards Institute
AqHF
Aqueous Hydrofluoric Acid
ASME
American Society of Mechanical Engineers
AUW
Authorized, unpriced (undefinitized) work
AWP
Annual Work Plan
BCO
Battelle Columbus Operations
CaF
2
Calcium Fluoride
CAM
Control Account Manager
CAS
Contractor Assurance System
CBB
Contract Budget Base
CDR
Conceptual Design Reports
CFR
Code of Federal Regulations
CPR
Contract Performance Report
CSE
Cognizant System Engineer
DEAR
Department of Energy Acquisition Regulation
DOE
U.S. Department of Energy
DOE-EM
DOE Office of Environmental Management
DOE-HQ
DOE Headquarters
DSA
Documented Safety Analysis
DUF6
Depleted Uranium Hexafluoride
ECI
Export Controlled Information
EIA
Electronic Industries Alliance
EIS
Environmental Impact Statement
EM
Environmental Management
ERP
Enterprise Resource Program
ESH&QA
Environment, Safety, Health and Quality Assurance
ETTP
East Tennessee Technology Park
EVMS
Earned Value Management System
HW
Hazardous Waste
HUB
HubZone Business
INPO
Institute of Nuclear Power Operations
IPABS
Integrated Planning, Accountability and Budgeting System
IPS
Integrated Production System
iREN
iRenaissance
ISM
Integrated Safety Management
ISMS
Integrated Safety Management System
IT
Information Technologies
DUF6-PLN-001
Rev. 3
LEU
Low-Enriched Uranium
LLC
Limited Liability Corporation
LLW
Low-Level Waste
MCS
Mid-America Conversion Services LLC
MLLW
Mixed Low Level Waste
MT
Metric Tons
NDA
Non Destructive Assay
NEPA
National Environmental Policy Act
NM
Nuclear Material
NMC&A
Nuclear Material Control and Accountability
Non-rad
Non-radiological
NQA-1
Nuclear Quality Assurance Level 1
O&M
Operations and Maintenance
ODSA
Officially Designated Security Authority
ODCs
Other Direct Costs
OUO
Official Use Only
PCSD
Project Control System Description
PII
Personally Identifiable Information
PMB
Performance Measurement Baseline
PMP
Project Management Plan
PPPO
Portsmouth/Paducah Project Office
PQAP
Project Quality Assurance Plan
PWS
Performance Work Statement
QA
Quality Assurance
QAP
Quality Assurance Plan
QL
Quality Level
R2A2
Roles, Responsibilities, Authorities, and Accountabilities
RCRA
Resource Conservation and Recovery Act
REA
Request for Equitable Adjustment
RMP
Risk Management Plan
ROD
Record of Decision
S&M
Surveillance and Maintenance
SCASD
Site Contractor Assurance System Description
SB
Small Business
SDB
Small Disadvantaged Business
SDD
System Design Document
SDVOB
Small Disadvantaged Veteran Owned Business
SNM
Special Nuclear Materials
DUF6-PLN-001
Rev. 3
SRD
System Requirements Document
SRNL
Savannah River National Laboratory
SSCs
Structures, Systems, and Components
Tc
Technetium
TRU
Transuranic
TSR
Technical Safety Requirement
U
Uranium
UCNI
Unclassified Controlled Nuclear Information
UCI
Unclassified Controlled Information
UDS
Uranium Disposition Services, LLC
UF6
Uranium Hexafluoride
USC
United States Code
UOx
Uranium Oxide
US EPA
U.S. Environmental Protection Agency
VOSB
Veteran Owned Small Business
WAC
Waste Acceptance Criteria
WBS
Work Breakdown Structure
WOSB
Woman Owned Small Business
DUF6-PLN-001
Rev. 3
EXECUTIVE SUMMARY
The Mid-America Conversion Services LLC (MCS) contract requires development and
implementation of a Project Management Plan. This executive summary presents an
overview of the MCS Project Management Plan, which describes the methodology for
implementing work.
Scope and Objectives. As defined in Section C Performance Work Statement in our
contract (DE-EM0004559), the summary scope of work includes:
• Providing S&M for the depleted uranium hexafluoride (DUF6) conversion facilities
and associated equipment
• Operating the conversion facilities to convert the DUF6 from the inventory at
Paducah and Portsmouth to uranium oxide
• Reusing, storing, and/or transporting and disposing of the DUF6 conversion
process end-products and wastes
• Selling the aqueous hydrofluoric acid product
• Providing S&M services for the cylinder storage yards
The DUF6 Conversion Project has two defined, contractual objectives:
• Operate the DUF6 conversion facilities on DOE property at Paducah, Kentucky
and Portsmouth, Ohio to convert DOE’s inventory of DUF6; now located at the
Paducah Gaseous Diffusion Plant and the Portsmouth Gaseous Diffusion Plant to
a more stable uranium oxide form
• Provide continued cylinder surveillance and maintenance (S&M) services for the
inventory of project-assigned cylinders in a safe, environmentally acceptable
manner
Environmental, Safety, Health, and Quality. The MCS Environmental, Safety, Health, and
Quality (ESH&Q) programs systematically integrate management and work practices at
each level to accomplish our mission while protecting the worker, the public, and the
environment. Policies, programs, processes, and procedures for implementing the
federal, state, and local standards and requirements have been developed to protect
the worker, the public, and the environment. Our Integrated Safety Management
Program Description reflects the MCS approach for integrating safety and security into
all aspects of work planning and execution for operations and maintenance activities of
the project. In accordance with DOE guidance pertaining to integrated safety
management, safety encompasses the environment (including environmental
protection, environmental compliance, pollution prevention, resource conservation, and
waste minimization), safety, health, and radiation protection. To ensure compliance, we
execute work in accordance with our Project Quality Assurance Plan.
DUF6-PLN-001
Rev. 3
Project Management. Our organization is structured so our key production, technical,
and business management personnel report to our project manager. Each organization
and their leader have a specific role in achieving the PWS, our commitments, and
providing control and accountability for performance. Our lines of communication
facilitate an inclusive culture that provides leadership, aligns with Department of Energy
– Portsmouth/Paducah Project Office requirements, and supports effective execution of
the Performance Work Statement scope. Figure ES-1 presents the key MCS management
positions.
DUF6-PLN-001
Rev. 3
Figure ES-1. Key MCS Management Positions
Baseline/Financial Management. MCS operates under a DOE-approved project baseline
that addresses the entire contract performance period. The purpose of the project
baseline is to provide the context to manage the cost, schedule, and technical
performance of each control account. This system provides cost performance reports
that become the basis of variance analysis, allowing the project to identify corrective
actions for performance not meeting expectations. Components of our baseline include:
• Work Breakdown Structure. Our work breakdown structure depicts the
breakdown of work scope for authorization, tracking, and reporting purposes for
the project and reflects the DUF6 work scope at Paducah, Portsmouth, and
Lexington.
• Baseline Scope. The technical baseline defines the contract work scope and
provides the basis for scheduling and estimating the cost of work. Section C
Performance Work Statement, contained in the current version of the contract
defines the work scope.
• Baseline Schedule. The baseline schedule is a time-phased critical path schedule
that identifies the authorized scope in the form of activities, which have a logical
sequencing of the interdependent activities, milestones, and events necessary to
complete the project.
• Baseline Cost. The baseline cost is developed by summing the detailed cost
estimates for each WBS element, created by compiling the cost for each activity
required to execute the WBS element work scope.
MCS implements control of our project and baseline through the processes and
procedures identified in our Project Controls System Description (DUF6-PLN-238). Our
system description presents the organization and purpose of both the work breakdown
structure and organizational breakdown structure; the processes for planning,
scheduling, and budgeting; earned value processes; accounting considerations; data
management; and reporting. Our system description is compliant with the thirty-two
criteria identified in the ANSI/EIA Earned Value System Guidelines.
DUF6-PLN-001
Rev. 3
Our financial/project controls system is composed of commercially available software
packages: Deltek COBRA, iRenaissance Enterprise Resource Program, and Primavera P6.
Deltek COBRA provides performance measurement, baseline management, and cost
processor functions; iRenaissance Enterprise Resource Program provides the accounting
function; and Primavera P6 provides scheduling capabilities for planning and tracking
project progress/performance. These integrated supporting systems/tools provide the
structure for ensuring project work conforms to the intent of the ANSI/EIA-748B guidelines.
Risk Management. Our risk analysis/risk management process implements a systematic
approach for the effective mitigation of cost, schedule, technical, and programmatic
risks to minimize adverse impacts to the successful completion of the project throughout
the contract life cycle. Our Risk Management Plan provides the framework for achieving
project goals by applying a proven risk and opportunity management process. Our
approach deals with foreseeable and unforeseeable risks and uses available techniques
and options for addressing those risks. Our objective is to decrease the probability and
impacts of the events that may be adverse to DOE’s scope, safety, quality, scheduling,
and budgeting goals. In accordance with our approach, we maintain a Risk
Management Plan and the risk register.
Regulatory/Outreach. MCS is responsible for interface and supporting DOE negotiations
with regulators. At the request of DOE, MCS negotiates in good faith and becomes a
signatory to regulatory agreements or orders, as DOE deems appropriate for the work
performed. MCS is also responsible for preparing and managing the development of
permits, applications, licenses, and other authorizations required by the Contract. MCS
assures that environmental requirements, including pollution prevention, waste
minimization, and best management practices are identified and integrated into
conversion facility operations. MCS provides public and stakeholder outreach and
involvement through implementation of our Stakeholder Plan, which establishes the
policy and approach for communications between MCS and its multiple audiences. The
plan addresses communications with DOE, regulatory agencies, project participants,
employees, other DOE site contractors and subcontractors, the general public,
community leaders, plant neighbors, regulators, trade media, and news media.
Safeguards and Security. DOE provides protective forces security services (site security)
contractually for DUF6 facilities in Paducah and Portsmouth. The Officially Designated
Security Authorities coordinate support from the trained and equipped protective forces
at the conversion facilities in Paducah and Portsmouth. Site security provides
appropriately cleared, armed personnel who protect nuclear material, personnel,
classified and UCI matter, and government property and facilities at the sites. Site Security
Plans describe the security measures required for the protection of the security interests
at the DUF6 facilities in Paducah and Portsmouth. Nuclear materials control and
accountability plans for the DUF6 Conversion facilities in Paducah and Portsmouth
describe the methodologies used to control and account for nuclear materials. Cyber
Security requirements are implemented in compliance with requirements identified in
DOE Order 205.1B, DOE Cyber Security Management Program and DOE Order 471.6,
Information Security.
DUF6-PLN-001
Rev. 3
Operations. The MCS operations and maintenance philosophy combines best practices
from the nuclear and manufacturing industries, with a foundation derived from INPO
performance objectives and criteria used for evaluation of operations, maintenance,
and support functions at nuclear facilities. Our processes embody the fundamentals of
integrated safety management, conduct of operations, conduct of maintenance, and
human performance improvement initiatives. Our operations culture is based on sound
ConOps principles and an integrated safety management approach to ensure
operations are conducted with an appropriate level of discipline and rigor to ensure that
safety is always given priority over other considerations.
DUF6-PLN-001
Rev. 3
1 INTRODUCTION
The Mid-America Conversion Services LLC (MCS) contract, number DE-EM0004559,
requires development and implementation of a Project Management Plan (PMP). This
PMP describes the methodology used by MCS to implement work and presents the
umbrella of scope, approaches, and processes used to execute work for conversion of
DUF6.
The PMP addresses the project scope and objectives, MCS’s management approach,
our baseline components and the processes and systems used to manage the baseline,
followed by brief discussions addressing applicable technical aspects of executing the
DUF6 Conversion Project. DOE guidance concerning the development of a project PMP
suggests adding appendices “to provide the detailed documentation for application
and implement of the project strategies”. However, because of the depth and breadth
of work implemented under this contract, our PMP identifies and provides an overview of
the policies, procedures, systems, and processes within the body of this PMP.
The MCS Project Management Plan (PMP) is structured to present and address the
following topics in the identified sections:
• Section 1 Introduction. Section 1 presents the purpose and overview of the DUF6
Conversion Project PMP
• Section 2 Scope. Section 2 presents the scope and objectives of the DUF6
Project, including the beginning state of the project and the planned end state
• Section 3 Management Approach. Section 3 presents the management
approach implemented by MCS, including discussion of the project organization,
key personnel roles and responsibilities, corporate governance and reach-back,
project interfaces, project reviews, and subcontractor performance
management
• Section 4 Baseline Management and Control. Section 4 presents the processes
and systems MCS implements to manage the baseline and contract changes
• Section 5 Project Controls. Section 5 presents the processes and systems used to
implement technical, financial, and schedule controls within the project to
ensure earned value management requirement compliance and effective
project reporting
• Section 6 Risk Management. Section 6 presents processes and systems
implemented to plan for and mitigate risks to successful project implementation
• Section 7 Environmental, Safety, Health, and Quality Management. Section 7
presents the strategy and management systems implemented to ensure that
safe, compliant work is executed while protecting the workers, public, and the
environment
• Section 8 Safeguards and Security. Section 8 presents the systems implemented
to ensure DOE safeguards and security requirements are implemented at each
work location
DUF6-PLN-001
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• Section 9 Plant Operations. Section 9 presents the processes and systems
implemented to ensure safe, effective plant and cylinder operations,
surveillance, and maintenance
• Section 10 Systems Engineering. Section 10 presents the processes for
implementing systems engineering within the DUF6 Conversion Project
• Section 11 Safety Basis Documentation. Section 11 presents the process for
ensuring work performed in the Category 2 and Category 3 nuclear facilities is
performed within the boundaries defined in documented safety analyses
• Section 12 Configuration Management. Section 12 presents the process for
ensuring that configuration management of DUF6 conversion structures, systems,
and components is maintained
• Section 13 Plant Design. Section 13 presents the methodology for ensuring plant
designs conform to functional and performance requirements
• Section 14 Records Management and Document Control. Section 14 presents the
processes and procedures implemented to control the creation, development,
review, and approval of project documents, and their management once
created
• Section 15 Contracts and Supply Chain. Section 15 presents the strategy for
implementing MCS contracts and supply chain activities
• Section 16 References. Section 16 provides a list of documents referenced during
development of this PMP
• Section 17 Attachments. Section 17 presents the attachments to the PMP
2 SCOPE
As defined in Section C Performance Work Statement (PWS) in contract DE-EM0004559,
the summary scope of work includes:
• Providing S&M for the DUF6 conversion facilities and associated equipment
• Operating the conversion facilities to convert the DUF6 from the inventory at
Paducah and Portsmouth to uranium oxide
• Reusing, storing, and/or transporting and disposing of the DUF6 conversion
process
end-products and wastes
• Selling the aqueous hydrofluoric acid (AqHF) product
• Providing S&M services for the cylinder storage yards
The details of the scope are defined in the Performance Work Statement in the current
contract. Detailed implementation methodologies for executing the scope of work are
identified throughout the PMP in referenced policies, plans, and procedures.
DUF6-PLN-001
Rev. 3
2.1 PROJECT OBJECTIVES
The objective of contract DE-EM0004559 is to operate the DUF6 conversion facilities on
DOE property at Paducah, Kentucky and Portsmouth, Ohio to convert DOE’s inventory of
DUF6, now located at the Paducah and Portsmouth Gaseous Diffusion Plants, to a more
stable uranium oxide form (UOx). The inventory of DUF6 is approximately 765,000 metric
tons (MT), combined total for Paducah and Portsmouth combined.
A second objective is to provide continued cylinder surveillance and maintenance
(S&M) services for the inventory of DUF6, low-enrichment uranium (LEU) hexafluoride
(UF6), normal UF6, UOx, and empty and heel cylinders in a safe, environmentally
acceptable manner.
3 MANAGEMENT APPROACH
The MCS organization is aligned to (1) execute the line management mission of routine
cylinder yard operations and conversion to achieve our goal of sustainable conversion
throughput of 34,800 MT/year, (2) implement our Integrated Production System (IPS), and
(3) motivate employees to deliver safe, compliant, exceptional performance.
3.1 PROJECT ORGANIZATION
Our organization is structured so our key production, technical, and business
management personnel report to our project manager. Each organization and their
leader have a specific role in achieving the PWS, our commitments, and providing
control and accountability for performance. Our lines of communication facilitate an
inclusive culture that provides leadership, aligns with DOE-PPPO requirements, and
supports effective execution of the PWS scope.
Figure 3-1 presents the key MCS management positions responsible for safe, compliant
implementation of the DUF6 Conversion Project.
Figure 3-1. MCS Key Management Positions
DUF6-PLN-001
Rev. 3
Each of our plant managers report directly to our project manager and are responsible
for day-to-day operation of the processing facilities at their respective sites. Our site
execution organizations are structured in similar fashion at both sites. Our technical
approach provides standardized execution, supporting personnel cross-training and
continuous improvement initiatives. With the exception of permitting requirements, our
implementation approach is the same at both sites.
In addition to our processing locations at Paducah and Portsmouth, the MCS Lexington
Project Office is designed to support and enable the site organizations in implementing
our technical solution. ESH&Q, engineering, and business management support is housed
at each site but directed through Lexington. We have designated key personnel to lead
these programmatic elements at the Lexington Office. The designated leads define the
requirements to implement across the sites and provide oversight and guidance for
compliance.
Operation of DUF6 Conversion Facilities (RFP DE-SOL-0007016), November 24, 2015
DUF6-PLN-001
Rev. 3
In addition to project management and control, the Lexington staff provides:
• Establishment of culture
• Resource allocation/reallocation
• Reach-back to corporate entities
• Cross-plant efficiencies
• Overall project innovation and optimization
• Program alignment and consistency.
3.2 ROLES, RESPONSIBILITIES, AUTHORITIES AND ACCOUNTABILITIES
Each individual in our organization has clearly defined roles, responsibilities, authorities
and accountabilities (R2A2) to ensure efficient and effective execution of work. Clear
R2A2s maximize the potential for MCS to execute the contract safely and effectively,
which minimizes the risk to DOE, MCS, our staff, our stakeholders, and the public. The
R2A2s of our key personnel are identified in Figure 3-2.
3.3 CORPORATE GOVERNANCE
MCS parent companies have executed an Operating Agreement to govern MCS and
provide clear day-to-day operating control. A six-member Board of Managers has
fiduciary, risk management, and project performance-monitoring responsibility for the
success of the project. The MCS Board Chair ensures regular corporate oversight of the
DUF6 contract, including monthly financial reviews, quarterly project reviews, an annual
audit, independent assessments, and monitoring of transition and ongoing operations.
Our Project Manager reports to the MCS Board Chair for contract performance.
The Board of Managers uses techniques such as independent third-party assessments per
DOE Order 226.1A Contractor Assurance Systems Criteria, regular communication with
our project manager, and monitoring of performance metrics to oversee project
execution. If these reviews indicate a problem, the Board develops and implements
corrective actions. In all cases, the project management team is responsible to notify
DOE and the Board concerning any issue; health, safety, environmental, security,
regulatory, operational, labor, or other significant issues.
3.4 CORPORATE REACHBACK
The MCS Board of Managers also provides immediate access to the skills and capabilities
of our nuclear, chemical, operations, maintenance, engineering, safety, quality,
regulatory, environmental, and business staff through our president and our chief
engineer. The MCS Board also has an independent advisory committee comprising
members from industry and academia to provide expert advice on project
improvements and progress, as needed. Members include representatives from
organizations such as Solvay, Catholic University, and Savannah River National
Laboratory (SRNL), and were chosen based on conversion technology experience,
product experience, and/or processing research capability.
DUF6-PLN-001
Rev. 3
Figure 3-2. Key Management Staff R2A2s
Position Roles Responsibilities Authorities Accountabilities
President and
Project
Manager
•
MCS leader and
manager
• Primary contact to
DOE, regulators,
stakeholders,
bargaining unit
organization,
workforce, and
MCS Board of
Managers
• Chair, Project
Change Control
Board
•
Single point of accountability for all DUF6
contract requirements
• Provides overall leadership to MCS
• Establishes and maintains safety and
work culture
• Leads culture of safe, compliant
operations and sustainable continuous
improvement
• Ensures contract performance and
milestone achievement
• Ensures line management ownership
and worker engagement
• Ensures disciplined use of project
management systems
• Ensures risk minimization and mitigation
strategies are planned and implemented
• Ensures earned value project delivery
• Ensures quality is maintained and
achieved
• Approves contract changes and
authorizes changes
•
Safety and quality of the
project and staff
performance.
• Executing roles and
responsibilities as
defined above.
• Quality and compliance
of DUF6 programs and
procedures.
• Timely submittal to the
customer of
notifications, reports,
and other deliverables
related to the overall
function of the DUF6
Project.
• Oversight of the DUF6
Project and its
personnel.
Chief Process
Technology
Officer/Chief
Engineer
• Chief Process
Technology Officer
• Chief Engineer
• Design Authority
• Acting Project
Manager in the
Project Manager’s
absence
• Primary contact to
project technical
staff and corporate
• Leader of effort to improve and sustain
production
• Ensures development of the MCS
Integrated Production System
• Leads project implementation of process
improvements to achieve Safe Flow and
Sustainable Performance SQP goals
• Ensures configuration control, systems
engineering, and equipment reliability
• Evaluates/implements capital
improvements and systems to achieve
maximum throughput, continuous
• Safety and quality of
the project and staff
performance
• Executing roles and
responsibilities
as
defined
above
• Quality and
compliance
of DUF6
programs and
procedures
•
Timely submittal to
the customer of
• Approve Programs,
Plans, Policies within
department
• Approve Documents
within department &
delegate their approval
to subordinate
managers
• Approve departmental
budget and baseline
• Other authorities as
delegated by the
DUF6-PLN-001
Rev. 3
Figure 3-2. Key Management Staff R2A2s
Position Roles Responsibilities Authorities Accountabilities
technical reachback
staff
improvement, and life of plant
sustainability
• Ensures standardized engineering
process, procedures, and tools to
maintain consistency in engineering and
design
• Directs site engineering managers
• Development of DUF6 long-term
equipment reliability plan
• Communicating and leveraging project
and corporate lessons learned
• Configuration control of design
documents, including as-builts, and
process engineering change proposals
• Designs comply with safety as low-as-
reasonably-achievable (ALARA)
standards, and regulatory/permitting
requirements; and safety significant
structures, systems, and components
(SSCs) meet codes and standards
• TSR, authorization basis documents, and
DSA processes
• As-built configuration management
• Fire protection program
• Nuclear criticality safety program
• Ensures Quality is achieved and
maintained
• Differing professional opinions
program
notifications, reports,
and other
deliverables related
to the overall function
of the DUF6 Project
President and Project
Manager, as defined in
approved MCS
polices, programs and
procedures
ESH&Q
Manager
•
Single point of
accountability for
establishing,
monitoring, and
•
Ensures consistent application and
implementation of all ESH&Q program,
including ISMS, QAP, and radiation
• Approval of ESH&Q
deliverables
submitted to DOE in
accordance with
• Accountable for the
adequacy and
effectiveness of
organizational
DUF6-PLN-001
Rev. 3
Figure 3-2. Key Management Staff R2A2s
Position Roles Responsibilities Authorities Accountabilities
enforcing ESH&Q
programs to
support DUF6
operations
protection in compliance with contract
requirements
• Achievement of VPP Star Status and
annual ALARA reduction goals
• Ensures implementation of observation
program across both plant sites to
analyze and mitigate hazards and risks
• Maintain the regulatory management
program, ensure flowdown of
requirements to implementing plans and
procedures and address regulatory
issues
• Ensures emergency response readiness
with other site contractors and local
agencies
• Leads environmental
monitoring/reporting and
prepares/monitors environmental permits
• Maintain project occurrence and PAAA
reporting and corrective action programs
• Support annual updates to DSA/TSR, as
necessary
• Ensures Quality is achieved and
maintained
• Support and coordinate S&S and
emergency preparedness activities at the
DUF6 plant sites
• Project National Environmental Policy
Act (NEPA) compliance and DOE
support
• Contractor Assurance System (CAS)
program
contract and
programmatic
requirements.
•
Selection of qualified
ESH&Q
personnel.
•
Compensation, appraisal
and development of
ESH&Q
personnel.
•
Administration of
ESH&Q budget and
associated cost centers,
including wellness and
safety promotion.
•
Approval of company
safety statistics and
performance
metrics.
•
Stop work if activities
pose an immediate
threat to employee
safety or to
the
environment.
performance and
programs
to:
a. MCS
President and
Project Manager,
DOE PPPO
Manager,
PPPO
Site Directors
b. Federal and state
regulators
c. MCS Plant
Managers
d. ESH&Q staff
e. MCS workforce and
USW
members
f. Other site-wide
prime
contractors
and
tenants
Plant Managers
• Senior line
manager at their
• Accountable to the Project Manager for
operations, ESH&Q performance,
• Selection of direct
report personnel and
• Accountable for the
adequacy and
DUF6-PLN-001
Rev. 3
Figure 3-2. Key Management Staff R2A2s
Position Roles Responsibilities Authorities Accountabilities
assigned site
(Paducah or
Portsmouth)
regulatory and DOE policy compliance,
financial performance, and continuous
improvement of DUF6 operations at
Paducah and Portsmouth
• Leads conversion operations and
cylinder yard S&M through hands-on
management of work planning and
implementation
• Drives event-free operations
• Leads site implementation of process
improvements to achieve Safe Flow and
Sustainable Performance SQP goals
• Ensures achievement of production goals
and continuous improvement
• Ensures Quality is achieved and
maintained
• Responsible for waste management
operations at the site
• Maintains staff and union relations
• Champions and promotes a healthy
nuclear safety culture and sustainable
manufacturing
• Provides technical support to ensure site
products and performance meet
customer expectations and contract
requirements
• Instills and maintain disciplined conduct
of operations and conduct of
maintenance to safely achieve high
yields within budget and environmental
control limitations
• Develops resources and lead personnel
development
oversight of subordinate
managers' selection of
personnel.
• Compensation,
appraisal and
development of direct
report personnel and
oversight of subordinate
managers' personnel.
• Administration of DUF6
budget.
• Approval of DUF6
program documents.
• Assessment of DUF6
program
implementation.
• Reporting effectiveness
of DUF6 program
implementation
effectiveness of DUF6
organizational
performance and
programs to:
a. DOE PPPO
Manager & PPPO
Site Director
b. Regulators and
Stakeholders
c. Workforce and
Unions
d. LLC Board of
Managers
e. Other site wide
contractors and
tenants
DUF6-PLN-001
Rev. 3
Figure 3-2. Key Management Staff R2A2s
Position Roles Responsibilities Authorities Accountabilities
• Waste Management & Transportation
(WM&T) programs
Implementation
Process
Technology
Officer/Site
Engineering
Manager
•
Process
Technology Officer
• Engineering
Manager
•
Implement projects for the IPS programs
and systems, with direct project
management responsibility for
engineering project baselines and
individual project performance
• Manage day-to-day engineering support
for operations and implement
standardized engineering processes and
procedures to maintain consistency
• Implementation of reliability-centered
maintenance
• Enhance conversion knowledge,
implementation of safe flow/sustainable
performance, and safety- quality-
production systems
• Ensures Quality is achieved and
maintained
• Assist in evaluating/implementing capital
improvements and systems to achieve
maximum throughput, continuous
improvement, and life-of-plant
sustainability
• Ensure configuration control, systems
engineering, and equipment reliability
• Work with the Chief Process Technology
Officer/Chief Engineer to leverage
efficiencies and lessons learned from our
team’s commercial conversion
operations to maximize throughput
•
Selection of direct
report personnel
• Compensation,
appraisal and
development of direct
report personnel
• Administration of the
Mid-America
Conversion Services
LLC budget
• Approval of Mid-
American Conversion
Services LLC program
documents
• Assessment of Mid-
American Conversion
Services LLC program
implementation
• Reporting effectiveness
of Mid-American
Conversion Services
LLC program
implementation
•
Accountable for the
adequacy and
effectiveness of the
Mid-American
Conversion Services
LLC organizational
performance and
programs to:
a. MCS Chief
Engineer
b. DOE PPPO
Manager & PPPO
Site Director
c. Regulators and
Stakeholders
d. MCS Plant
Manager
e. MCS workforce and
unions
f. LLC Board of
Managers
g. Other site wide
contractors and
tenants
Chief
Administrative
Officer and
• Leader and
Manager of All
Business Functions
• Accountable to the Project Manager for
the execution of business services to
• Selection of Business
Services personnel.
• MCS President/Project
Manager for adequacy
and effectiveness of
DUF6-PLN-001
Rev. 3
Figure 3-2. Key Management Staff R2A2s
Position Roles Responsibilities Authorities Accountabilities
Business
Manager
• Secretary, Project
Change Control
Board
support DOE’s mission and DUF6
Project milestones
• Manage all business services and
systems (e.g., accounting, finance, IT,
HR, procurement) to maintain conduct of
business excellence at the DUF6 plants
in Portsmouth and Paducah
• Oversees legal, HR, document control,
IT, project controls, administrative
functions, labor relations, accounting,
and finance
• Develop, use, and maintain business
support systems to implement
conversion activities
• Maintains an EVMS-compliant system
and certified procurement system
• Leads implementation of Fluor business
systems and uses knowledge of people,
interfaces, and processes to share
lessons learned across all
Portsmouth/Paducah contracts
• Provides policies, procedures, and
systems that implement our IPS and
Safe Flow and Sustainable Performance
• Provides the systems and tools to inform
DOE and management of cost, schedule,
and technical baseline performance
• Maintains segregation of cost between
fixed-price and cost-plus scope
• Ensures management of the baseline
• Ensures Quality is achieved and
maintained
• Ensures creation of change notices and
change proposals
• Compensation,
appraisal, and
development of
Business Services
personnel.
• Administration of the
Business Services
budget.
• Approval of Business
Services program
documents.
• Assessment of
Business Services
program
implementation.
• Reporting effectiveness
of Business Services
program
implementation.
Business Services
organizational
performance.
Adequacy and
effectiveness of
Business Services
program.
• Portsmouth/Paducah
Site Managers for
adequacy and
effectiveness of
Business Services
program.
• Other Project Support
organizations for
adequacy and
effectiveness of
Business Services
program.
• MCS Board of
Manager for Board
Treasurer and
Financial/Corporate
Reporting to partner
companies.
DUF6-PLN-001
Rev. 3
Page 28 of 58
3.5 PROJECT INTERFACES
Multiple DOE prime contractors work at the Paducah and Portsmouth sites. MCS
personnel interface with numerous organizations and personnel at both sites, at the DOE
PPPO office in Lexington, at other DOE sites, and at DOE-HQ. Successful interface and
communication provides the conduit to efficient and effective operations at both sites.
• To ensure an integrated approach that successfully delivers the technical scope
in accordance with DOE approved cost and schedule baselines, the MCS project
team executes the DUF
6
Conversion Project by instituting functional, operational,
and contractual interfaces to ensure success. By way of these interfaces, the MCS
project team is integrated into a single organization under the management of a
core staff as described above.
3.5.1 DOE Interfaces
The MCS president/project manager continually communicates and works directly with
the DOE Federal Project Director. Interface with DOE staff leads at the Portsmouth and
Paducah sites is the responsibility of the respective MCS plant managers under our
project manager’s management and oversight. Each level of our management staff is
empowered to interface with their DOE counterpart to communicate and work together
to achieve consensus and resolve issues. Unresolved issues are referred to higher levels
of management for resolution. MCS also maintains liaison with other DOE organizations,
including but not limited to:
• The DOE Office of Health, Safety and Security, and the Office of Disposal
Operations regarding the preparation of commercial exemptions, as
appropriate, in accordance with DOE Order 435.1 Radioactive Waste
Management and implementing documents
• The DOE Office of Disposal Operations integration activities (i.e., annual waste
forecasts, bi-weekly LLW/MLLW conference calls, and lessons learned)
• The DOE Supply Chain Management Center (strategic sourcing, cost savings,
ePlatforms)
3.5.2 Site Interfaces
The Portsmouth and Paducah Plant Managers are responsible for effective
communications and interfaces at their respective sites with DOE and DOE support staff,
multiple prime contractor staff, other stakeholders, and the public. MCS supports and
actively participates in monthly site interface meeting to coordinate and integrate site
activities and resolve issues and concerns. We also interface with site organization to
obtain utilities and services.
DUF6-PLN-001
Rev. 3
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Functional Interfaces
• Functional Interfaces exist between the primary functions of the project:
• Project management
• Engineering, procurement, and operations
• Facility O&M
• Cylinder surveillance and maintenance
• Functional integration began with the coordinated input of project team members
to this PMP to initially discuss and plan for how the DUF
6
Conversion Project was to be
managed. Such functional integration continued with the early deliverables and will
be maintained throughout.
• The operations phase is executed by the plant managers who ensure that there are
an adequate number of trained and qualified personnel to support the successful,
safe and quality driven operation of the plants. Support from other team members in
management, design, operation and administration is critical in providing safe,
quality driven operation of the conversion facilities.
Operational Interfaces
• The operational interfaces that enable the functional interfaces are established
through MCS preparing plans, implementing systems, establishing procedures, and
adopting practices that together describe how MCS performs through safe, efficient
and quality driven practices; and how individuals interface in executing the project.
MCS project team members, the three MCS member companies and subcontractors
participate at various levels of the project, and the specified plans and procedures
dictate how these individuals and groups interface operationally. Specific key
interfaces for each senior management position are discussed above under the
description of that position.
3.5.3 Waste Management Interfaces
Operational waste management staff maintain liaison with DOE and contractors at
federal and/or commercial LLW/MLLW disposal facilities. Associated interfaces activities
include:
• Implementation of DOE Order 435.1
• Maintenance of the DUF6 project Waste Certification Program
• Development of waste disposal profiles for non-radiological Hazardous Waste
(non-rad HW), LLW, and MLLW
• Characterization and certification of non-rad HW, LLW, and MLLW
• Shipment and disposal of non-rad HW, LLW, and MLLW
DUF6-PLN-001
Rev. 3
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• Support preparation of documentation for meetings with DOE and US EPA officials,
state governments, members of the public, and/or representatives from the waste
disposal sites.
Activities implemented during our interface with DOE waste management organizations
and other DOE contractors providing waste management support include:
• Consultation support for other DOE waste generators to ensure proper waste
preparation and demonstration activities
• Integration activities for transfer of waste, samples, etc. to or from other sites
3.6 PROJECT REVIEWS
MCS conducts internal project reviews in accordance with the needs of MCS to
document and discuss progress, address issues requiring management knowledge and
support; therefore, ensuring our management is cognizant of the status of each aspect
of our project. The control account manager (CAM) also addresses cost account
variances and the project estimate-at-completion. As appropriate, the discussion
between the CAM and the audience leads to further refinement of the analysis and
corrective action planning. Decisions regarding corrective actions, estimate at
completion updates, and possible baseline changes are documented as action items.
Action items from prior reviews are monitored to ensure implementation and to evaluate
the efficiency of previously implemented corrective actions.
DUF6-PLN-001
Rev. 3
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3.7 SUBCONTRACTOR PERFORMANCE
MCS personnel from operations, contracts, business services, and quality organizations
monitor subcontractor performance, using the same processes and procedures applied
to MCS to measure their performance as well. Our requirements to our subcontractors
include a policy that places responsibility on personnel, including subcontractors, to
report any nonconforming safety or quality activities.
Examples of our process to monitor and control subcontractor performance include:
• Monitoring business matters related to the prime/subcontractor relationship
(contract administration, invoicing, and payment) is handled by our business
management staff
• Monitoring operational matters, including technical direction and supervision, is
handled at the plant level by the functional group responsible for the type of
activity being performed.
MCS uses the following methods to monitor, control, and integrate our subcontractors:
• Written subcontracts and purchase orders with flow-down clauses from
procurement
• Review and check of subcontractor work using MCS project procedures
• Regular progress and financial reviews, daily and weekly progress reports, and
weekly labor submittals to track cost/schedule
• An oversight manager reviews assigned scope with assigned subcontractors;
conducts a procurement review; negotiates/approves the proposed method of
operation, cost estimate, and schedule; and integrates the deliverables into the
work plan/schedule.
DUF6-PLN-001
Rev. 3
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4 BASELINE MANAGEMENT AND CONTROL
The Performance Measurement Baseline (PMB) is a time-phased budget plan for
accomplishing work, against which contract performance is measured. The PMB includes
the budgets assigned to all elements of scope identified in the WBS, the undistributed
budget, summary level planning package budgets, and control account budgets.
The PMB establishes the scope, schedule, and cost targets for the program. MCS
maintains a baseline for the entire scope and duration of the project called the Contract
Budget Base (CBB). The CBB represents the total budget for all authorized work. It includes
all direct and indirect costs. The CBB is always equal to the currently negotiated project
cost plus the estimated cost of authorized, unpriced (undefinitized) work (AUW) and
Management Reserve, if any. The contractors measure, maintain and report against the
CBB. Changes to the negotiated project cost and estimates are tracked to reflect the
current budget status of the project through a budget log maintained by project
controls.
The performance measurement baseline, or PMB, is fundamental to Earned Value
Management (EVM). The PMB establishes the contract level, timed-phased baseline
against which contract level Earned Value (EV) metrics are computed. MCS utilizes a
project baseline, as required by the Contract, to authorize work and provide
performance feedback.
MCS operates under a DOE-approved project baseline that addresses the entire
contract performance period. The purpose of the project baseline is to provide the
context to manage the cost, schedule, and technical performance of each control
account. This system provides cost performance reports that become the basis of
variance analysis, allowing the project to identify corrective actions for performance not
meeting expectations.
The baseline and subsequent revisions are reviewed and approved by the respective
CAMs for their areas of responsibility. Baseline changes receive reviews by the ESH&Q
Manager to ensure that changes do not compromise ESH&Q principles and
commitments.
Each fiscal year, MCS establishes an Annual Work Plan (AWP), which is drawn from the
Project Baseline. MCS reports performance against the AWP and the Project Baseline
monthly.
4.1 MANAGEMENT SYSTEM
MCS uses an integrated project management methodology to develop, maintain, and
report progress against the PMB/CBB. This methodology is presented and descripted in
the Project Control System Description (PCSD), document number DUF6-PLN-238, to
ensure EVM is responsive to the needs of the contractor and customer management,
and conforms to the Earned Value Management System (EVMS), as documented in
DUF6-PLN-001
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American National Standards Institute - Electronic Industries Alliance (ANSI/EIA)-748C
Earned Value Management Guidelines. The PCSD establishes formal procedures for
planning, authorizing, reporting, analyzing, and controlling project work within technical,
schedule and cost constraints.
The PCSD presents the formally defined set of integrated processes, procedures,
disciplines, software tools, and training programs that collectively promote the effective
and consistent achievement of project scope, cost, and schedule goals for the project.
This system has been designed to comply with DOE Order 413.3B Program and Project
Management for the Acquisition of Capital Assets), ANSI/EIA-748C Earned Value
Management Guidelines, and DOE Guide 413.3-10A Earned Value Management System.
The following sections briefly describe the technical, cost, and schedule baselines that
can only be modified through the formal change control process.
4.2 WORK BREAKDOWN STRUCTURE
Our work breakdown structure (WBS) depicts the breakdown of work scope for
authorization, tracking, and reporting purposes. The WBS defines elements of work for the
project and reflects the DUF6 work scope at Paducah, Portsmouth, and Lexington.
A listing of WBS elements with a description of the work scope content in each element
is contained in the WBS Dictionary. The work descriptions are maintained at Level 7 of the
WBS and provide for clear segregation of work for work authorization and accounting
purposes. The project WBS structure is presented as Attachment A.
4.3 BASELINE SCOPE
The technical baseline defines the contract work scope and provides the basis for
scheduling and estimating the cost of work. Section C Performance Work Statement
(PWS), contained in the current version of the contract defines the work to be planned
and accomplished. The technical content is described in the WBS Dictionary, which
formally defines the technical baseline and provides more detail on scope of work and
performance criteria by WBS element and becomes the basis for the Project Baseline.
Each control account manager (CAM) is responsible for maintaining the WBS Dictionary
for the work for which they are responsible.
4.4 BASELINE SCHEDULE
The baseline schedule is a time-phased critical path schedule that identifies the
authorized scope in the form of activities, which have a logical sequencing of the
interdependent activities, milestones, and events necessary to complete the project. The
scope of work is logically broken down into easily achievable work elements or tasks.
Activities are logically tied such that authorized work is sequenced efficiently and
identifies the relationships between tasks necessary to meet project requirements.
DUF6-PLN-001
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4.5 BASELINE COST
The baseline cost is developed by summing the detailed cost estimates for each WBS
element, created by compiling the cost for each activity required to execute the WBS
element. The resources required to complete the tasks are identified and estimates are
prepared by applying the identified resources to the schedule activity. The baseline cost
estimate include labor, materials, subcontracts, and other direct costs (ODCs) to
encompass the entire scope of work. The basis of each estimate is documented in the
WBS Basis of Estimate (BOE), which contains the assumptions, rationale, and basis for the
estimate.
4.6 CHANGE MANAGEMENT
Project changes are identified, controlled, and managed through a traceable,
documented, and dedicated change-control process in accordance with DUF6-POL-
047 Baseline Change Control Policy. The goals of the change-control process developed
for this project are to:
• Recognize and predict changes
• Evaluate and understand the impacts of each change
• Control consequences of change
• Prevent unauthorized or unintended deviations from approved baselines
• Assure each change to approved baselines is evaluated, reviewed, and
approved at the proper level of management
• WBS structure changes at Level 4 or above require DOE Contracting Officer
approval
Change control is used to ensure that project changes are identified, evaluated,
coordinated, controlled, reviewed, approved, and documented. Errors, problems,
opportunities, or the availability of new methods or tools can trigger project changes.
Approved project scope, schedule, and cost baselines are the controlling elements for
this project. Controlling changes to these baselines is an inherent element of project
management.
MCS executes changes to the Project Baseline that do not add or delete contract scope
or change regulatory or key DOE milestones in accordance with established procedure
DUF6-U-PCP-009 Change Control. Some examples of administrative changes include cost
changes requiring management reserve, schedule changes that do not change
regulatory, or key DOE milestones, or scope alignment/reorganization.
Changes to the contract are typically driven by DOE direction or by events that change
the baseline of the existing contract. MCS develops cost proposals in response to specific
DOE direction. Requests for Equitable Adjustments (REA) are submitted for changed
conditions to the contract. Regardless of the source of the change, a disciplined review
DUF6-PLN-001
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of the effects of the change on cost and/or schedule is conducted and the results
reviewed and approved by MCS management prior to submittal to DOE. After
negotiation with the DOE Contracting Officer and receipt of a formal contract
modification, the appropriate baseline change is incorporated into the baseline.
5 PROJECT CONTROLS
MCS implements control of our project and baseline through the processes and
procedures identified in DUF6-PLN-238, Project Controls System Description. The Project
Controls System Description (PCSD) presents the organization and purpose of both the
work breakdown structure and organizational breakdown structure; the processes for
planning, scheduling, and budgeting; earned value processes; accounting
considerations; data management; and reporting.
5.1 PROJECT CONTROL SYSTEM
MCS maintains a project control system that provides the basis for effective variance
analysis, relevant management reporting, and disciplined change management to
ensure the project baseline remains aligned with the contract. Our PCSD is compliant
with the thirty-two (32) criteria identified in ANSI/EIA-748C Earned Value System
Guidelines.
Our financial/project controls system is composed of commercially available software
packages: Deltek COBRA, iRenaissance (iREN) Enterprise Resource Program (ERP), and
Primavera P6. Deltek COBRA provides performance measurement, baseline
management, and cost processor functions; iREN ERP provides the accounting function;
and Primavera P6 provides scheduling capabilities for planning and tracking project
progress/performance. Other software packages such as Microsoft Office applications
are also utilized within the PCSD to develop support documents such as WBS dictionaries
and basis of estimates. These integrated supporting systems/tools provide the structure
for ensuring project work conforms to the intent of the ANSI/EIA-748B guidelines. MCS will
conduct a self-certification process to ensure compliance to ANSI/EIA-748B guidelines.
5.2 EARNED VALUE MANAGEMENT SYSTEM
Earned Value Management (EVM) is utilized as part of an integrated management
system to evaluate project performance. EVM objectively measures performance
against the approved project baseline plan in terms of scope, deliverables or milestones,
schedule, and cost. Effective application of EVM with project baseline management
improves the success rate of completing projects on time and within budget.
Project performance is assessed monthly and enables managers to identify and correct
problems before they become irrecoverable. This assessment of actual accomplishment
and its translation into a metric called earned value gives managers greater insight into
both progress and potential risk areas and provides a foundation for more accurate
estimates of projected completion costs.
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5.3 PROJECT REPORTING
MCS implements a process that reports work status to DOE on a monthly basis. Project
resource-loaded schedules are used as the basis for conducting these reviews. We report
status against appropriate milestones and performance measures. This reporting provides
information to input into the DOE reporting systems, such as Integrated Planning,
Accountability and Budgeting System (IPABS); and includes planned cost, schedule,
milestones, and performance measures.
5.3.1 Reporting Systems
Reporting systems for the project are structured to gather project status information for
all management levels (i.e., Control Account Managers through senior MCS and DOE
management). Data integrity is maintained to accommodate different focus areas and
crosscuts. Project Controls coordinates the development of the various monthly
management reports, which are required by our contract. Variance analysis and
reporting thresholds are implemented in compliance with procedure DUF6-U-PCP-0012
Variance Analysis. Ad hoc summary and detail reports can be run based on the needs
of the Control Account Manager or any management level reporting desired. The Project
Manager approves the Contract Performance Report (CPR) prior to submittal to DOE.
5.3.2 Key Performance Indicators
MSC management and staff identify, monitor, and document the status of project
performance metrics. The status of each metric is documented and/or updated in
monthly reports, which are reviewed by our staff and management before they are
submitted to DOE to officially communicate and document their status.
6 RISK MANAGEMENT
The MCS risk analysis/risk management process implements a systematic approach for
the effective mitigation of cost, schedule, technical, and programmatic risks to minimize
adverse impacts to the successful completion of the project throughout the contract life
cycle. We implement our risk management strategy, based on a well-structured, formal,
and disciplined approach that focuses on the necessary steps and planning actions to
define, control and mitigate risks to an acceptable level.
Our Risk Management Plan (RMP) (DUF6-PLN-019) provides the framework for achieving
project goals by applying a proven risk and opportunity management process that
meets the specific requirements of DOE 0 413.3B, Program and Project Management for
the Acquisition of Capital Assets dated November 29, 2010, the Office of EM Operations
Activities Protocol, February 28, 2012, and associated guides, principally DOE Guide
413.3-7A, Risk Management Guide, dated January 12, 2011.
The protocols and approach to risk management are described and documented in our
Risk Management Plan, which describes the process for identifying, preventing, reducing,
DUF6-PLN-001
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or managing risks associated with completing the DUF6 Conversion Project. This
overarching document contains detailed descriptions of the risk management process.
Our approach deals with foreseeable and unforeseeable risks and uses available
techniques and options for addressing those risks. Our objective is to decrease the
probability and impacts of the events that may be adverse to DOE’s scope, safety,
quality, scheduling, and budgeting goals. In accordance with our approach, we
maintain a RMP and the risk register.
7 ENVIRONMENTAL, SAFETY, HEALTH, AND QUALITY
The MCS Environmental, Safety, Health, and Quality (ESH&Q) programs implement the
requirements of DEAR Clause Title 48 Code of Federal Regulations (CFR) 970.5223-1,
Integration of Environment, Safety, and Health Into Work Planning and Execution. These
programs systematically integrate management and work practices at all levels to
accomplish missions while protecting the worker, the public, and the environment.
Policies, programs, processes, and procedures for implementing the federal, state, and
local standards and requirements have been developed to protect the worker, the
public, and the environment. Our process includes hazards analysis, an Un-reviewed
Safety Question process, the development of Safety Basis documentation, and a Quality
Assurance Program in compliance with 10 CFR 830, Nuclear Safety Management. It also
incorporates the safety, health, and environmental discipline requirements, including
pollution prevention, waste minimization, radiation protection, fire protection, nuclear
safety, industrial hygiene, and industrial safety.
7.1 INTEGRATED SAFETY MANAGEMENT
The Integrated Safety Management System Plan (DUF6-PLN-040); hereafter, entitled the
ISMS Program Description, reflects the MCS approach for integrating safety into all
aspects of work planning and execution for operations and maintenance (O&M)
activities of the Project. In accordance with DOE guidance pertaining to ISM, safety
encompasses the environment (including environmental protection, environmental
compliance, pollution prevention, resource conservation, and waste minimization),
safety, health, and radiation protection.
The ISMS Program Description was developed in compliance with the Contract, 10 Code
of Federal Regulations (CFR) 830, Nuclear Safety Management, Subpart A; Quality
Assurance Requirements; Department of Energy Acquisition Regulation (DEAR) 952.223-
71, Integration of Environment, Safety, and Health into Work Planning and Execution; DOE
Order 436.1, Departmental Sustainability; DOE 0 450.2, Integrated Safety Management;
10 CRF 835, Occupational Radiation Protection; 10 CFR 851, Worker Safety and Health
Program; DOE Order 440.1B, Worker Protection Program for DOE (including the National
Nuclear Security Administration) Federal Employees; and this PMP.
Key to implementation of this ISMS Program Description is the understanding that it is an
integration document that includes both cylinder storage yards and conversion facilities
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O&M activities. The MCS ISMS Program is implemented primarily through the
management systems defined in DUF6-PLN-003 Project Quality Assurance Plan (PQAP).
Consistent with 10 CFR 830, Nuclear Safety Management, Subpart A Quality Assurance
Requirements, the PQAP integrates the ten QA criteria with the five core functions and
the eight guiding principles of ISMS, as defined in the ISMS Program Description, thereby
ensuring a single integrated management system for the Project. To ensure ISMS
implementation and continuous improvement, assessments are performed in
accordance with the PQAP and its implementing assessment procedures, as defined in
DOE Order 414.1 D, Change 1, Quality Assurance.
The Project's ISMS Program is also supported by other key project-specific documents: this
PMP; the RMP; DUF6-PLN-011, Cylinder Surveillance and Maintenance Plan; DUF6-PLN-
014, Conversion Facilities Operations and Maintenance Plan; DUF6-PLN-015, Document
Control and Records Management Plan; DUF6-U-SMP-005, Safety Management Program
Descriptions for the MCS Conversion Services, LLC DUF6 Conversion Project; DUF6-PLN-
074, Worker Safety and Health Program; and the implementing procedures/documents
for these and other various supporting plans.
7.2 OCCUPATIONAL SAFETY AND HEALTH
A key component to the successful implementation of our Integrated Safety
Management System (ISMS) is compliant implementation of the MCS worker and health
program, DUF6-PLN-074 Worker Safety and Health Program, prepared and implemented
in accordance with 10 CFR 851, Worker Safety and Health Program and the DUF6-POL-
060 Environmental, Safety, and Health Policy, during the planning, execution, lessons
learned, and closeout stages of work activities.
The Environmental, Safety, and Health organization is responsible for guiding the
implementation and routinely evaluating the effectiveness of the Worker Safety and
Health Program. Occupational Safety and Health staff are assigned operations and to
projects and interact on a day-to-day basis with supervisors to support and plan work
activities, communicate requirements, correct safety and health issues, monitor
employees for exposure, and sustain continuous improvement initiatives. Safety and
health professionals provide ongoing support and/or consultation when work is being
performed. Safety and health subject matter experts perform design reviews, program
reviews, procedure reviews, work planning reviews, compliance assessments, exposure
assessments, and interpretation of safety and health requirements.
7.3 RADIOLOGICAL CONTROL
Occupational Radiation Protection, 10 CFR 835, establishes radiation protection
standards, limits, and program requirements for protecting individuals from ionizing
radiation resulting from the conduct of DOE activities such as DUF6 conversion. MCS
operates the conversion facilities in compliance with a documented Radiation
Protection Program (RPP), DUF6-PLN-007, Radiation Protection Plan.
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MCS implements written procedures that flow down from the RPP to ensure compliance
with
10 CFR 835 Occupational Radiation Protection. Our written procedures address topics
including, but not limited to, training of radiological workers; occupational and visitor
dose limit; allowable concentrations of radioactive material in the air; and monitoring of
individuals, areas, air, and packages.
7.4 NUCLEAR SAFETY
Nuclear Hazard Category 2 and 3 facilities have a safety basis document prepared in
accordance with 10 CFR 830, Nuclear Safety Management, Subpart B, and DOE-STD-
3009-94, Change 3, Preparation Guide for U.S. Department of Energy Nonreactor Nuclear
Facility Documented Safety Analysis. As indicated in this standard, the hazard analysis will
meet the requirements for non-radiological hazard analysis required by 10 CFR 851,
Worker Safety and Health Program. DUF6-U-SMP-005, Safety Management Program
Descriptions for the DUF6 Conversion Project, provides descriptions of the MCS Safety
Management Programs (SMPs). The purpose of the SMP description document is to
present information that is common to the MCS managed facilities and support
organizations. It is intended to complement the facility-specific Documented Safety
Analysis (DSA).
For cylinder yard and conversion operations, the documented safety basis is governed
by the DSA, Technical Safety Requirements (TSRs), and referenced supporting
documents. The documents for each respective site are:
Paducah
• DUF6-C-DSA-001, Paducah DUF6 Conversion Facility Documented Safety
Analysis, Paducah, Kentucky
• DUF6-C-DSA-003, Documented Safety Analysis for the DUF6 Conversion Project
Cylinder Storage Yards, Paducah, Kentucky
• DUF6-C-TSR-002, Technical Safety Requirements for the DUF6 Conversion Facility,
Paducah, Kentucky
• DUF6-C-TSR-004, Technical Safety Requirements for the DUF6 Conversion Project
Cylinder Storage Yards, Paducah, Kentucky
Portsmouth
• DUF6-X-DSA-001, Portsmouth DUF6 Conversion Facility Documented Safety
Analysis, Piketon, Ohio
• DUF6-X-DSA-003, Documented Safety Analysis for the DUF6 Conversion Project
Cylinder Storage Yards, Piketon, Ohio
• DUF6-X-TSR-002, Technical Safety Requirements for the DUF6 Conversion Facility
Piketon, Ohio
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• DUF6-X-TSR-004, Technical Safety Requirements for the DUF6 Conversion Project
Cylinder Storage Yards, Piketon, Ohio
Documents and activities that could potentially affect the safety basis are reviewed in
accordance with DUF6-U-NSP-0002, Un-reviewed Safety Question Process. Configuration
management of the facilities is governed by DUF6-PLN-121, Configuration Management
Plan for Operations.
7.5 ENVIRONMENTAL/REGULATORY
MCS is responsible for interfacing with regulators and supporting DOE negotiations with
regulators. At the request of DOE, MCS negotiates in good faith and becomes a signatory
to regulatory agreements or orders, as DOE deems appropriate for the work performed.
MCS has defined a management framework, including roles, responsibilities and
accountabilities, to assure that environmental requirements, including pollution
prevention, waste minimization, best management practices, and as low as reasonably
achievable principals and those authority documents containing standards and
requirements applicable to the scope of work have been identified and integrated into
conversion facility operations.
7.5.1 Regulatory Management
MCS is responsible for preparing and managing the development of permits,
applications, licenses, and other authorizations required by the Contract as identified in
Section H and Section I of the Contract. MCS reviews the Regulatory and Permitting
Management Plan, revises it as necessary (annually as a minimum), submits revisions of
the plan for DOE Contracting Officer approval, and executes revisions to the Plan upon
Contracting Officer approval to ensure the conversion facilities are operated in
accordance with applicable requirements as required by the Section I clause entitled
“DEAR 970.5204-2 Laws, Regulations, and DOE Directives.”
7.5.2 National Environmental Policy Act Documentation
MCS advises DOE of the requirement to prepare additional National Environmental Policy
Act (NEPA) documentation in the event of project changes, then prepares any
additional NEPA documentation required to complete the scope of work in accordance
with:
• 40 CFR 1500-1508, DOE’s Implementing Regulations for NEPA found in 10 CFR
1021
• DOE Order 451.1B, National Environmental Policy Act Compliance Program
MCS provides DOE with draft NEPA documentation for review and comment,
incorporates DOE comments in the final NEPA document, then reproduces and
distributes the appropriate number of final NEPA documents.
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MCS also supports DOE’s NEPA compliance activities. Our support includes tasks such as
responding to questions from the NEPA compliance team, sending one or more subject
matter experts to support the DOE at public meetings if requested, and providing
updated data to the NEPA team.
7.5.3 Public and Stakeholder Outreach and Involvement
MCS provides public and stakeholder outreach and involvement through
implementation of DUF6-PLN-018 Stakeholder Plan. The Stakeholder Plan establishes the
policy and approach for communications between MCS and its multiple audiences.
Primary locations for communications support are Paducah, Kentucky; Piketon, Ohio,
Lexington, Kentucky; and surrounding communities. The plan addresses communications
with DOE, regulatory agencies, project participants, employees, other DOE site
contractors and subcontractors, the general public, community leaders, plant neighbors,
regulators, trade media, and news media.
7.6 QUALITY ASSURANCE
MCS executes work in compliance with DUF6 Project Quality Assurance Plan, which is
DOE-approved and consistent with the DOE-EM QAP, EM-QA-001, Environmental
Management (EM) Quality Assurance Program, and ASME-NQA-1-2004, Quality
Assurance Requirements for Nuclear Facility Applications, with addenda through 2007.
7.6.1 Project Quality Assurance Plan
MCS manages a comprehensive Quality Assurance (QA) program with established
requirements and applicable management controls to assure quality-compliant work
activities are performed. The MCS QA program is described in depth in the PQAP. The
PQAP applies to quality-affecting activities (i.e., deeds, actions, processes, tasks, or work),
which influence the achievement or verification of quality requirements and objectives
for Quality Level (QL) 2 "Safety Significant" Structures, Systems, and Components (SSCs) or
other directed activities using a graded approach.
The PQAP provides the framework for implementation of the MCS audit/assessment
program. The PQAP flows down requirements to the MCS procedures, as reflected in the
Quality Implementation Plan (QIP), such as our quality oversight, surveillance and
assessment procedures, which will be applied to CLIN 0002 and CLIN 0003 scope during
execution.
The PQAP is based on Title 10 CFR 830 Nuclear Safety Management, Subpart A, Quality
Assurance Requirements; DOE 0 414.1 D, Quality Assurance; and EM-QA-001, Revision 1,
Environmental Management (EM) Quality Assurance Program; and implements the
requirements in Part I and applicable subparts in Part II of the ASME NQA-1-2004 and
addenda through 2007 to establish the requirements contained in the PQAP. To maintain
configuration of MCS consensus standards commitments, DUF6-U-QIP-001, DUF6 Quality
Implementation Plan, provides a crosswalk from EM-QA-001 requirements to DOE 0
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414.1D and ASME NQA-1 and to the MCS implementing documents. DUF6-U-QIP-001 is
managed as a controlled document and is maintained current with the proper
implementing documents.
The PQAP prescribes a comprehensive quality program for work performance during the
operation and maintenance of the conversion facilities and the cylinder storage yards
at Paducah and Portsmouth. Utilization of the PQAP and its implementing documents is
required for continued safety, integrated safety management, and programmatic
mission reliability.
The QA organization qualifies suppliers and vendors, maintains an approved suppliers list,
and assists customers in developing procurement specifications for quality level
components. QA performs receipt inspections and periodic supplier audits to ensure
components and parts meet performance specifications. MCS maintains an aggressive
suspect/counterfeit items program. In situations where it is impractical to perform vendor
qualification audits, MCS performs commercial-grade dedication. QAP elements stem
from our QAP and flow down into specific QA procedures.
7.6.2 Assessments and Readiness
Independent assessments are based on DOE Order 414.1D, Quality Assurance,
Assessments/Criterion 10 – Independent Assessment, and a graded approach to ASME
NQA-1-2004 and addenda through 2007, Part 1 Requirement 18, Audits. The MCS ESH&Q
organization has the key role for implementation of independent assessments. Certified
MCS professionals who do not have direct responsibility for performing the activities being
assessed perform independent assessments in accordance with written procedures or
checklists. Independent assessment results are documented and reported to and
reviewed by responsible MCS management. Follow-up actions are taken where
indicated.
The assessment process is integral to establishing readiness to startup or restart operations
and is a part of the ISMS. It is performance-based and focuses on results. The independent
assessment process is performed in compliance with the applicable MCS procedure,
scheduled and based on guidance contained in DOE Guide 414.1C, Management and
Independent Assessments Guide.
Independent assessments are conducted on activities that:
•
Relate directly to final objectives
•
Emphasize safety, reliability, and quality
•
Measure item and process performance
Assessment plans, including those that support startup or restart of operations are
developed to establish the scope, evaluation criteria, assessment personnel, schedule,
and notification requirements to be used during the assessment. Independent
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assessments include verification of the adequacy of corrective actions, including actions
to prevent recurrence or otherwise improve performance. Independent assessments
include such methodology as:
•
Monitoring activities being performed
•
Witnessing inspections or tests
•
Reviewing peer and technical review results
•
Conducting interviews
•
Reviewing required documentation
7.6.3 Contractor Assurance
The Contractor Assurance Program provides the framework and integration of MCS
processes to satisfy Contractor Assurance System (CAS) requirements of DOE 0 226.1B,
Implementation of Department of Energy Oversight Policy. This program describes MCS
integrated site-wide approach to meeting CAS requirements in support of safe, secure
operations and continuous improvement. Although some high-level descriptions of
processes and programs are discussed, this document primarily points to other MCS site-
level guidance that defines CAS implementation and monitors performance. These
processes are documented in DUF6-PLN-145, DUF6 Site Contractor Assurance System
Description.
8 SAFEGUARDS AND SECURITY
Site Security Plans for the MCS facilities in Portsmouth and Paducah were developed in
accordance with U.S. Department of Energy (DOE) Order (O) 470.4B, Change 1,
Safeguards and Security Program, Attachment 1, Contractor Requirements Document.
The plans describe the measures used to protect DOE security interests under the
management of MCS, which includes designated Property Protection Areas (PPAs);
Category IV, Attractiveness Level E, Nuclear Material (NM); Unclassified Controlled
Information (UCI) (to include Official Use Only [OUO], Personally Identifiable Information
[PII], Export Controlled Information [ECI], and Unclassified Controlled Nuclear Information
[UCNI]); and government-owned property to include high-risk and ECI components.
8.1 PHYSICAL SECURITY
Site Security. DUF6-PLN-033, Paducah Site Security Plan describes the protection
programs implemented for the protection of the security interests at the DUF6 facilities in
Paducah, Kentucky, DUF6 facilities. DUF6-PLN-035, Portsmouth Site Security Plan describes
the security measures required for the protection of the security interests at the DUF6
facilities in Portsmouth, Ohio. Both plans were developed in accordance with DOE Order
470.4B, Change 1, Safeguards and Security Program, and references the applicable
topics listed on DOE Form 470.8, Survey/Inspection Report Form. MCS maintains both site
security plans
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In accordance with both site security plans, DOE provides protective forces security
services (site security) contractually for the DUF6 facilities in Paducah and Portsmouth.
The Officially Designated Security Authorities (ODSA) coordinate support from the trained
and equipped protective forces. Site security provides appropriately cleared, armed
protective force personnel who protect Special Nuclear Material (SNM), personnel,
classified and UCI matter, and government property and facilities at the sites.
Nuclear Material Control and Accountability. Nuclear materials control and
accountability (NMC&A) plans describe the programs used to control and account for
nuclear materials in the DUF6 facilities in Paducah and Portsmouth (DUF6-PLN-009,
Depleted Uranium Hexafluoride Conversion Project Nuclear Materials Control and
Accountability Plan for Piketon for the Portsmouth DUF6 facilities and DFU6-PLN-076,
Nuclear Materials and Control (NMC&A) Plan for Paducah for the Paducah DUF6
facilities). The plans comply with requirements of DOE Order 474.2, Chg. 4, Nuclear
Material Control and Accountability, specifically, the Contractor Requirements
Document, Attachment 1.
The goal of the NMC&A programs is to maintain effective control and accountability of
nuclear material. Implementation of NMC&A plans ensures a comprehensive, effective,
and cost-efficient program is maintained to control and account for nuclear materials.
The plans utilize a graded approach that analyzes the consequences of loss and ensures
robust control and accountability mechanisms. The NMC&A plans are fully integrated
with the site Safeguards and Security Programs to ensure continuity of operations.
Requirements, commitments, and actions described in each plan are flowed into
implementing procedures. The plans are reviewed at a minimum of every two years or
as required by program changes, and revised as required. Changes to the plans are
made periodically in accordance with the MCS procedure DUF6-U-DMP-0002, Document
Control and Records Management.
8.2 CYBER SECURITY
Cyber Security, implemented by the DUF6-POL-040 Cyber Security Policy and associated
cyber security procedures and protection strategies, are in alignment with United States
DOE Order 205.1B, Department of Energy Cyber Security Management Program
requirements and DOE Order 471.6, Information Security.
MCS conducts periodic internal assessments of DUF6 security boundaries by periodic
reviews of cyber security controls and risk categorizations of system under its
management. The first assessment is conducted during transition and is made available
to DOE. Using this initial assessment along with existing DOE corrective action lists, a Plan
of Action and Milestones (POAM) is developed to manage improvements to cyber
security at the facility. The Internal Assessment report and POAM are submitted to DOE
to support an interim authority to operate.
During the first 60 days of operation, the MCS Information System Security Manager (ISSM)
updates and submits new System Security Plans (SSP) associated with both the General
Support System (GSS) and the Industrial Control System (ICS) DUF6 project boundaries.
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MCS may recommend changes to the Information Technologies (IT) systems to meet
contractual requirements during operation of the project. These changes are presented
to DOE for review and approval to ensure IT solutions compatible with DOE’s operations
are implemented and maintained.
During the course of the DUF6 Conversion Project, a security life cycle approach will be
used, as documented in the current version of NIST SP 800-37, Guide for applying the Risk
Management Framework to Federal Information Systems.
9 PLANT OPERATIONS
The MCS operations and maintenance (O&M) philosophy is founded on our Integrated
Production System (IPS) which combines best practices from the nuclear and
manufacturing industries, with a foundation derived from Institute of Nuclear Power
Operations (INPO) performance objectives and criteria used for evaluation of operations,
maintenance, and support functions at nuclear facilities. Our IPS embodies the
fundamentals of DOE’s Integrated Safety Management (ISM), conduct of operations
(ConOps), conduct of maintenance, and human performance improvement (HPI)
initiatives. The IPS is based on the principle that safety and quality are fundamental to
production and is linked to all activities we perform.
Our operations culture is based on sound ConOps principles and an integrated safety
management approach to all plant activities. DUF6-U-CON-0001, Conduct of Operations
Manual, outlines the process to ensure operations conducted at MCS facilities have the
appropriate level of discipline and rigor applied and that safety is always given priority
over other programmatic considerations. Conduct of Operations will be instilled as a
cultural norm and will be measured through the MFO process.
In compliance with DOE-STD-1027-92, Hazard Categorization and Accident Analysis
Techniques for Compliance with 5480.23, Nuclear Safety Analysis Reports, the DUF6
conversion facilities are categorized as Hazard Category 3 non-reactor nuclear facilities
and the DUF6 project cylinder storage yards are categorized as Hazard Category 2 non-
reactor nuclear facilities. DSA/TSR requirements are implemented through project plans
and procedures.
9.1 OPERATIONS MANAGEMENT
MCS is responsible for the safe and compliant operation of the conversion facilities at
each site, along with cylinder storage yards at each site. This responsibility also includes
safe and compliant storage of products or wastes until they are transported off-site.
Operations tasks include process equipment operations within the conversion buildings,
providing balance of plant support systems, cylinder operations, management of oxide
load-out areas, use of rail sidings for transportation, and management of the HF storage
and load-out facilities. Qualified facility managers are responsible for the facilities on a
24/7 basis and have overall responsibility for every aspect of facility operations, including
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ensuring procedural compliance and safety. These facility managers own the
implementation and integrity of the safety basis requirements.
Personnel training and qualification programs develop and maintain a competent work
force. MCS training and qualification processes ensure that personnel obtain and
maintain the necessary knowledge, skills, and abilities to perform their assigned tasks
while adhering to the graded approach philosophy as described in DUF6-PLN-027,
Personnel Selection, Training, and Qualification Management Plan.
9.1.1 Process Facilities Operations
DUF6 Conversion Project operation is implemented in accordance with DUF6-PLN-014
Conversion Facilities Operations and Maintenance Plan. Our operations and
maintenance plan describes methods by which the DUF6 conversion facilities are
operated and maintained, and plant operations are optimized. It is implemented
through use of detailed plans and procedures.
Maintenance activities are currently carried out in accordance with DUF6-PLN-056,
Maintenance Implementation Plan, which also serves as the Nuclear Maintenance
Management Plan. This plan provides a description of the maintenance program at both
DUF6 facilities. The program complies with requirements of DOE Order 433.1B,
Maintenance Management Program for DOE Nuclear Facilities, and implements the
intent of NQA-1-2004 and addenda through 2007, Subpart 2.18, Quality Assurance
Requirements for Maintenance of Nuclear Facilities. The maintenance program also
ensures integration of ISMS functions into maintenance activities.
9.1.2 Cylinder Yards Surveillance and Maintenance
The cylinder yards at both Paducah and Portsmouth are managed in accordance with
DUF6-PLN-011 Cylinder Surveillance and Maintenance Plan to ensure compliance with
nuclear safety; criticality safety, combustibility; radiological; and safeguards, security,
and emergency preparedness requirements. The DUF6 cylinder surveillance and
maintenance (S&M) program is implemented to maintain the DOE’s inventory of DUF6,
low-enriched uranium (LEU) UF6, natural assay UF6, heel cylinders, empty cylinders, and
uranium oxide containers in safe storage until ultimate disposition; and to perform initial
screening of DUF6 cylinders for delivery to the conversion facility staging area for
processing. The surveillance program ensures cylinder inspections are implemented on a
timely basis, needed repairs are noted and implemented, and records are maintained.
Cylinders to be delivered to the conversion facility from the cylinder storage yards
undergo records verification and non-destructive assay (NDA) before they leave the
cylinder yards to ensure the cylinders do not contain unexpected fissile materials.
Accurate determinations of uranium content, as well as gross and net weight, are
required in order to comply with nuclear materials control and accountability (NMC&A),
waste certification, and transportation requirements and regulations.
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9.2 CONVERSION PRODUCT MANAGEMENT
The conversion process produces quantities of oxide powder, DUF6 cylinders containing
heel quantities of material, and HF acid product. DUF6-PLN-004, Conversion Product
Management Plan, describes the management of products generated by the
conversion of DUF6 to UOx, which have potential use or reuse opportunities. The plan
describes how each product is generated and managed from the point of generation
to ultimate disposition if the product is not a waste. Included in the plan are quantities,
methods, and timetables for each product, as well as the approach MCS employs to
demonstrate that the materials are released in accordance with the DOE requirements.
Four conversion products are generated during processing: 1) depleted uranium oxide
(principally triuranium octaoxide [U308] [UOx]), 2) aqueous hydrofluoric acid (AqHF), 3)
calcium fluoride (CaF2) from off-gas scrubbers, and 4) steel (UFs cylinders). Of the four
conversion products, only AqHF has a current, viable commercial market. Disposition of
the depleted UOx is not currently in the scope of the MCS contract. MCS safely stores the
converted UOx in containers, which are generally modified cylinders previously
containing DUF6. These cylinders are staged in available areas in the existing cylinder
yards at each site. The post-generation management and disposition of these materials
is detailed in DUF6-PLN-005, Waste Management Plan.
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9.3 WASTE MANAGEMENT
Waste is managed in accordance with the DUF6-PLN-005, Waste Management Plan. This
plan describes how waste is generated and managed from the point of generation to
disposal during the operations phase of this project. The plan also describes how waste
materials are processed, packaged, and certified to meet the waste acceptance
criteria. MCS has identified and planned well-defined treatment and disposal pathways
for each waste stream produced on the DUF6 Project. MCS monitors each shipment of
product or waste using its shipment number, departure location and time, vehicle tag
number, and estimated versus actual arrival time.
10 SYSTEMS ENGINEERING
In general, systems engineering begins with a concise definition of the project’s
requirements and functions. A search is then implemented for viable alternatives that will
perform the functions and meet requirements. Follow-on activities identify deliverables
and activities to meet the defined requirements/functions, track deliverables and
activities to completion, and verify and validate that they meet the intended use. This
process supports project management by ensuring technical control is integrated with
cost, schedule, and performance controls. To obtain the desired results in a controlled
fashion, the process is integrated with other systems and controls, including configuration
management, value engineering, ISM, Quality Assurance (QA) and baseline change
control.
10.1 DESCRIPTION
MCS uses a systems engineering approach to deliver end products that meets technical
requirements while minimizing project ESH&Q risks. System engineering, as part of ISMS,
defines Cognizant System Engineer (CSE) functions, responsibilities, and authorities with a
graded approach and is utilized throughout the Project life cycle. MCS systems
engineering ensures operational readiness of the Safety Related Structures, Systems, and
Components (SSCs) and attainment of their functional and performance requirements.
10.2 PROCESS
The MCS systems engineering process is a disciplined means by which project staff
integrate identification of systems and configuration management. Personnel use
procedurally required engineering processes and tools to ensure that facility designs are
integrated and optimized to meet defined functional and performance requirements.
Program elements of our system engineering approach began with a concise
identification of the systems and their requirements and configuration management from
the earliest stages of design through construction, testing, and operation and
modifications. Follow-on activities identify deliverables and activities to meet those
defined requirements, track deliverables and activities to completion, and verify and
validate that system requirements are met.
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This process ensures that technical control is integrated with cost, schedule, and
performance controls. The process is integrated with other systems and controls, including
configuration management, value engineering, ISM, QA, and baseline change control.
11 SAFETY BASIS DOCUMENTATION
Pursuant to DOE-STD-1027-92, Hazard Categorization and Accident Analysis Techniques
for Compliance with 5480.23, Nuclear Safety Analysis Reports, the Paducah and
Portsmouth cylinder yards are categorized as Hazard Category 2 non-reactor nuclear
facilities. The Paducah and Portsmouth conversion facilities are categorized as Hazard
Category 3 non-reactor nuclear facilities.
The Nuclear Safety Manager, reporting to the Chief Process Technology Officer/Chief
Engineer, is responsible for maintaining the Safety Basis Documents of the nuclear facilities
(i.e., conversion facilities and cylinder storage yards) current to the facility design and
operation. The safety analyses within these documents are used to establish the safety-
related SSCs (i.e., safety significant SSCs), and to identify their safety functions and quality
requirements for the design, procurement, installation, maintenance, and verification
testing of the SSCs.
The Safety Basis Documents include the DSAs and TSRs and are maintained for the
Paducah and Portsmouth nuclear facilities under MCS management. These documents
comply with
10 CFR 830, Nuclear Safety Management, Subpart B, Safety Basis Requirements, and are
developed using guidance in DOE G 421.1-2A, Implementation Guide for Use in
Developing Documented Safety Analyses to Meet Subpart B of 10 CFR 830, and DOE G
423.1-1A, Implementation Guide for Use in Developing Technical Safety Requirements.
The DSAs and TSRs are used in the development and maintenance of the O&M
procedures in a manner to ensure safe and effective facility operations. The engineering
staff at each site uses these documents to analyze any proposed changes to the plant
or plant operations, including plant modifications, to ensure no changes are made that
result in unreviewed safety questions without proper prior approval from DOE.
12 CONFIGURATION MANAGEMENT
MCS configuration management processes are documented in DUF6-PLN-121,
Configuration Management Plan for Operations. The Configuration Management Plan
describes the processes for identifying, documenting, managing, controlling, and
assessing the configuration of designated project safety-related structures, systems, and
components (SSCs). Once identified, these configured items are subject to configuration
management and status reporting as described in the plan. The Configuration
Management Program incorporates elements of design control, documentation, and
verification to ensure maintenance of the program.
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The Chief Process Technology Officer/Chief Engineer is responsible for implementing and
maintaining the Configuration Management Plan. The site operations directors are
responsible for ensuring configuration management controls are maintained during
O&M activities. Appropriate personnel receive training in configuration management as
part of the overall QA training, as described in the PQAP and in DUF6-PLN-027, Personnel
Selection, Training, and Qualification Management Plan.
Configuration management is used to ensure that facilities, structures, systems, and
components, as well as project documentation, interface physically and functionally
and that the configuration of these items is maintained in a controlled manner to serve
the mission need. Configuration control is implemented through the configuration
management process in accordance with ANSI/EIA-649, National Consensus Standard
for Configuration Management. Facilities, structures, systems, components, and
documents critical to the project are identified for configuration management and
control, ensuring consistency in identifying requirements, performance criteria, and
documentation.
MCS controls critical SSCs through the configuration management program.
Configuration of SSCs is maintained through periodic system assessment, change control,
work control, and documentation controls. When design basis information is not
available, it is developed and identified and a new basis and criteria are established,
which are then subject to configuration management. System repairs and maintenance
are formally controlled and verified through testing to ensure capability. Program
assessments are periodically scheduled and conducted in accordance with DUF6-U-
QAP-0013, Management and Technical Assessments, as an oversight role by the QA
organization utilizing DUF6-U-QAP-0012, Independent Assessments, or in other
assessments such as the ISMS.
13 PLANT DESIGN
13.1 SYSTEM REQUIREMENTS DOCUMENTS
Uranium Disposition Services, LLC (UDS) documented the system requirements in DUF6-
UDS-SRD-PROJ Overall System Requirements Document. The overall SRD documented the
functional requirements, performance requirements, and the basis of the requirements.
The overall SRD established high-level requirements applicable to the sites which, when
satisfied, would ensure meeting the mission need.
Site-specific SRDs were also developed to provide further detail in each functional area
in which site operations activities are required (i.e. cylinder management, facility
operations, and waste and product management). These SRDs were developed to meet
the requirements of the overall SRD, but are specific to each of the sites and are
developed to a greater level of detail.
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13.2 CONCEPTUAL DESIGN REPORTS
The conceptual design reports were developed by UDS for each of the conversion facility
sites, Paducah and Portsmouth, and for the East Tennessee Technology Park (ETTP)
cylinder transport DUF6-UDS-CDR-PADU, Paducah Conceptual Design Report; DUF6-UDS-
CDR-PORT, Portsmouth Conceptual Design Report; and DUF6-UDS-CDR-ETTP ETTP
Conceptual Design Report.
13.3 FACILITY DESIGN DOCUMENTS
As part of the design, System Design Documents (SDDs) were developed to identify system
and component level interfaces and to provide requirements governing O&M during
startup, shutdown, normal operations, and upset conditions.
System functional and performance requirements flow down from the SRDs and SDDs.
Equipment requirements flow down from the SDDs to the technical specifications. Any
changes from the approved design include the reasons for the changes and are
identified, approved, documented, and controlled per configuration management with
the procedures DUF6-PLN-121, Configuration Management Plan for Operations and DUF6-
U-PEP-1110, Operations Design Change Control.
14 RECORDS MANAGEMENT AND DOCUMENT CONTROL
The Federal Records Act, as amended and codified in United States Code (USC) Title
44, requires agencies to document their missions, functions, policies, procedures,
decisions, and transactions and to preserve a record of these documents. While leaving
an enduring documented history of the project, these records protect the legal and
financial rights of the government, ensure continuity and consistency in administration,
provide information to reconstruct the development of policies and decisions, and
present information needed for oversight functions. DUF6-PLN-015, Document Control
and Records Management Plan, establishes the document control and records
management program for the project.
14.1 DOCUMENT CONTROL
Document control is implemented in accordance with DUF6-PLN-015, Document
Control and Records Management Plan to meet the requirements identified in DOE O
414.1 D,
Quality Assurance, Criterion 4
-
Management/Documents and Records and
ASME
NQA-1 and addenda through 2007, Requirement 6
-
Document Control.
Preparation, issuance, and revision of documents that prescribe and direct work such
as
instructions, procedures, and drawings are controlled to ensure that correct
documents
are being used. Such documents, including revisions, are reviewed for
compliance and
adequacy of information and approved for release by authorized
personnel. Documents used by MCS to prescribe and direct work are policies, plans,
procedures, drawings,
forms, and specifications. Documents are controlled through the
document management
system, which provides access to documents needed by
personnel to safely and
correctly perform tasks and carry out their responsibilities. The
DUF6-PLN-001
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document management
system controls the revision and approval process and
provides user access to these
documents.
14.2 RECORDS MANAGEMENT
Records management is implemented by DUF6-PLN-015, Document Control and
Records Management Plan to meet DOE 0 243.1 B, Change 1, Records Management
Program; DOE 0 414.1 D, Quality Assurance, Criterion 4 - "Documents and Records"; and
ASME NQA-1-2004 and addenda through 2007, Requirement 17, "Quality Assurance
Records." The MCS records management program implements the requirements for
managing records in all formats, including early capture and control throughout their life
cycle. As well, MCS has implemented a Vital Records Program that identifies vital records,
preserves those records for use in the event of a continuity of operations or catastrophic
event, and includes a records disaster recovery plan. MCS recognizes the necessary role
of records management in supporting all functional areas of the DUF6 Project, including
QA activities that result in evidence of activities to meet specified requirements. Records,
regardless of media, are managed consistent with DOE orders, federal records, and
industry standards. Records are managed throughout the records life cycle, which
addresses the creation/receipt, distribution/use, storage, and disposition of records. The
records management program encompasses the requirements to assure records are
managed appropriately.
15 CONTRACTS AND SUPPLY CHAIN
The MCS acquisition program implements a strategic, sourcing- decision
process,
which provides subcontractors with roles that support project execution.
Subcontractor
resources enhance project team capability, help achieve efficient
execution, and
promote socio-economic development. MCS aligns subcontractor
performance
requirements with DUF6
mission requirements, so that subcontractors are
vested in
project performance and MCS is vested in its subcontractors' successes.
MCS integrates
subcontractors into the project, monitors their performance, and
provides them with
feedback and mentoring. Procurement is implemented in accordance with procedure
DUF6-U-PRP-001 Purchasing Procedure.
15.1 SUBCONTRACTOR OVERSIGHT
Each subcontractor receives regular performance reviews; participates in plan-of-the-
day meetings; and follows our ESH&Q, criticality, safeguards and security, cyber
security, and records management procedures, as appropriate. These procedures are
provided as flow-down subcontract terms and conditions. Each subcontractor is also
assigned a technical representative to ensure integration of work with the overall
program and other site contractors, trained to site safety procedures, and actively
participate in site safety.
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15.2 STAFF AUGMENTATION
The DUF6 Conversion Project requires coordinated execution of many functions (i.e.,
O&M, engineering, business systems). Staff augmentation has the potential to improve
performance by drawing upon specialty capabilities rather than existing staff. Moreover,
staff augmentation scopes are ideal for subcontracting because narrow small business
(SB) and small-disadvantaged business (SDBs) capabilities can be targeted to scopes
where they are likely to succeed. As integrated
performers, SB/SDBs benefit from the
leadership of MCS while MCS retains significant
control over scope execution, which
reduces performance risk.
15.3 SMALL BUSINESS GOALS
In accordance with our Small Business Subcontracting Plan, we continually engage small
and small-disadvantaged businesses in substantial, meaningful, and technically
challenging roles. Our SB/SDB subcontracting approach is focused on utilization of
local and regionally based SB/SDBs that bring a specialized skill to support our technical
approach. The MCS small business (SB) engagement efforts include use of preselected
subcontractors, competitive sourcing, and utilization of small businesses to achieve
contractual goals.
MCS gives
preference to local SBs when purchasing commodity-type
supplies (e.g., parts, tools, consumables, software) whenever reasonable.
Figure 15-1. MCS Small Business
Subcontracting Goals
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16 REFERENCES
The following documents are referenced in this PMP.
• 10 CRF 830, Nuclear Safety Management
• 10 CFR 830, Nuclear Safety Management, Subpart A Quality Assurance
Requirements
• 10 CFR 830, Nuclear Safety Management, Subpart B, Safety Basis Requirements
• 10 CFR 835, Occupational Radiation Protection
• 10 CFR 851, Worker Safety and Health Program
• 40 CFR 1500-1508, DOE’s Implementing Regulations for NEPA found in 10 CFR 1021
• ANSl/EIA-748C, Earned Value Management Guidelines
• ASME NQA-1-2008/2009a, Quality Assurance Requirements for Nuclear Facility
Applications
• ASME NQA-1-2008/2009a, Quality Assurance Requirements for Nuclear Facility
Applications – Requirement 6 – Document Control
• DEAR 952.223-71, Integration of Environment, Safety, and Health into Work
Planning and Execution
• DEAR 970.5204-2 Laws, Regulations, and DOE Directives
• DEAR Clause Title 48 Code of Federal Regulations (CFR) 970.5223-1, Integration of
Environment, Safety, and Health into Work Planning and Execution
• DOE EM-QA-001, Revision 1, Environmental Management (EM) Quality
Assurance
Program
• DOE Form 470.8, Survey/Inspection Report Form
• DOE Guide 413.3-7A Risk Management Guide
• DOE Guide 413.3-10A Earned Value Management System
• DOE Guide 414.1C Management and Independent Assessments Guide
• DOE Guide 421.1-2A, Implementation Guide for Use in Developing Documented
Safety Analyses to Meet Subpart B of 10 CFR 830
• DOE Guide 423.1-1A, Implementation Guide for Use in Developing Technical
Safety Requirements
• DOE Order 205.1B, Department of Energy Cyber Security Management Program
• DOE Order 226.1A, Contractor Assurance Systems Criteria
•
DOE Order 226.1B, Implementation of Department of Energy Oversight Policy
•
DOE Order 243.1b, Change 1, Records Management Program
DUF6-PLN-001
Rev. 3
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• DOE Order 413.3B, Program and Project Management for the Acquisition of
Capital Assets
•
DOE
Order
414.1 D, Change 1, Quality Assurance
• DOE Order 414.1D, Quality Assurance, Assessments/Criterion 10 – Independent
Assessment
• DOE Order 433.1B, Maintenance Management Program for DOE Nuclear Facilities
•
DOE Order 435.1, Radioactive Waste Management
•
DOE Order 436.1, Departmental Sustainability
•
DOE
Order
440.1B, Worker Protection Program for DOE (Including the National
Nuclear Security Administration) Federal Employees
•
DOE
Order
450.2, Integrated Safety Management
•
DOE Order 451.1B, National Environmental Policy Act Compliance Program
•
DOE
Order
470.4B, Change 1, Safeguards and Security Program
• (DOE) Order 470.4B, Change 1, Safeguards and Security Program, Attachment 1,
Contractor Requirements Document
• DOE Order 471.6 Information Security
• DOE-STD-1027-92, Hazard Categorization and Accident Analysis Techniques for
Compliance with 5480.23, Nuclear Safety Analysis Reports
• DOE-STD-3009-94, Change 3, Preparation Guide for U.S. Department of Energy
Nonreactor Nuclear Facility Documented Safety Analysis
• DUF6-C-DSA-001, Paducah DUF6 Conversion Facility Documented Safety Analysis,
Paducah, Kentucky
• DUF6-C-DSA-003, Documented Safety Analysis for the DUF6 Conversion Project
Cylinder Storage Yards, Paducah, Kentucky
• DUF6-C-TSR-002, Technical Safety Requirements for the DUF6 Conversion Facility,
Paducah, Kentucky
• DUF6-C-TSR-004, Technical Safety Requirements for the DUF6 Conversion Project
Cylinder Storage Yards, Paducah, Kentucky
• DUF6-PLN-001, Project Management Plan
• DUF6-PLN-003, Project Quality Assurance Plan
• DUF6-PLN-004, Conversion Product Management Plan
• DUF6-PLN-005, Waste Management Plan
• DUF6-PLN-007 Radiation Protection Plan
• DUF6-PLN-009, Depleted Uranium Hexafluoride Conversion Project Nuclear Materials
Control and Accountability Plan for Piketon
DUF6-PLN-001
Rev. 3
Page 56 of 58
• DUF6-PLN-011, Cylinder Surveillance and Maintenance Plan
• DUF6-PLN-014, Conversion Facilities Operations and Maintenance Plan
• DUF6-PLN-015, Records Management Plan
• DUF6-PLN-018, Stakeholder Plan
• DUF6-PLN-019, Risk Management Plan
• DUF6-PLN-027, Personnel Selection, Training, and Qualification
Management Plan
• DUF6-PLN-033, Paducah Site Security Plan
• DUF6-PLN-035, Portsmouth Site Security Plan
• DUF6-PLN-040, Integrated Safety Management System Plan for
Operations
• DUF6-PLN-056, Maintenance Implementation Plan
• DFU6-PLN-067, Nuclear Materials and Control (NMC&A) Plan for Paducah
• DUF6-PLN-074, Worker Safety and Health Program
• DUF6-PLN-121, Configuration Management Plan for Operations
•
DUF6-PLN-145, DUF6 Site Contractor Assurance System Description
•
DUF6-PLN-238, Project Control System Description
•
DUF6-POL-040, Cyber Security Policy
• DUF6-POL-047, Baseline Change Control Policy
•
DUF6-POL-060, Environmental, Safety, and Health Policy
•
DUF6-U-CON-0001, Conduct of Operations Manual
•
DUF6-U-NSP-0002, Un-reviewed Safety Question Process
• DUF6-U-PCP-009, Change Controls
• DUF6-U-PCP-0012, Variance Analysis
• DUF6-U-PEP-1110, Operations Design Change Control
• DUF6-U-PRP-001, Purchasing Procedure
• DUF6-U-QAP-0012, Independent Assessments
• DUF6-U-QAP-0013, Management and Technical Assessments
• DUF6-U-QIP-001, DUF6 Quality Implementation Plan
•
DUF6-U-SMP-005, Safety Management Program Descriptions for the DUF6
Conversion Project
• DUF6-UDS-CDR-PADU, Paducah Conceptual Design Report
• DUF6-UDS-CDR-PORT, Portsmouth Conceptual Design Report
• DUF6-UDS-CDR-ETTP, ETTP Conceptual Design Report
DUF6-PLN-001
Rev. 3
Page 57 of 58
• DUF6-UDS-SRD-PROJ, Overall System Requirements Document
• DUF6-X-DSA-001, Portsmouth DUF6 Conversion Facility Documented Safety Analysis,
Piketon, Ohio
• DUF6-X-DSA-003, Documented Safety Analysis for the DUF6 Conversion Project
Cylinder Storage Yards, Piketon, Ohio
• DUF6-X-TSR-002, Technical Safety Requirements for the DUF6 Conversion Facility
Piketon, Ohio
• DUF6-X-TSR-004, Technical Safety Requirements for the DUF6 Conversion Project
Cylinder Storage Yards, Piketon, Ohio
• NIST SP 800-37, Guide for Applying the Risk Management Framework to Federal
Information Systems
• NQA-1-2008 and addenda through 2009a, Subpart 2.18, Quality Assurance
Requirements for Maintenance of Nuclear Facilities
• Office of EM Operations Activities Protocol, February 28, 2012
• United States Code Title 44, Federal Records Act
17 ATTACHMENTS
The following attachments are presented in support of the DUF6 Project Management
Plan, DUF6-PLN-001.
• Attachment A. DUF6 Contract Work Breakdown Structure
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ATTACHMENT A - DUF6 Contract Work Breakdown Structure
The DUF6 Contract has developed a comprehensive Work Breakdown Structure that represents the entire contract statement of work. This Work Breakdown Structure is under change control and the most current version
is under configuration control with Project Controls.
