ML103620448
| ML103620448 | |
| Person / Time | |
|---|---|
| Site: | 07003103 |
| Issue date: | 12/22/2010 |
| From: | Sexton D Urenco, Louisiana Energy Services |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| ir-10-014, LES-10-00260-NRC | |
| Download: ML103620448 (5) | |
Text
DEC 2 2 2010 LES-10-00260-NRC ATTN: Document Control Desk Office of Nuclear Material Safety and Safeguards U. S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Louisiana Energy Services, LLC NRC Docket Number: 70-3103
Subject:
Reply to Notice of Violation 70-3103/2010-014
Reference:
Letter from J. Calle (NRC) to D. Sexton (LES), NRC Inspection Report No. 70-3103/2010-014 and Notice of Violation, dated December 9, 2010 In response to the referenced NRC Notice of Violation (Notice), URENCO USA (UUSA) herewith provides the enclosed reply (Enclosure). This violation relates to Section 3, "Design Control," of UUSA's Quality Assurance Program Description (QAPD).
Pursuant to instructions specified in the Notice, the enclosed UUSA reply (Enclosure) includes for the violation: 1)'the reason for the violation; 2) the corrective steps that have been taken and the results achieved; 3) the corrective steps that will be taken; and 4) the date when full compliance will be achieved.
Should there be any questions regarding this submittal, please contact Wyatt Padgett, LES Licensing Manager, at 575.394-5257.
Respectfully, Allen Sorrell for David E. Sexton Chief Nuclear Officer and Vice President of Operations
Enclosure:
Reply to Notice of Violation 07-3101/2010-014 LES,PO Box 1789, Eunice, New Mexico 88231,USA T: +1 575 394 4646 F: +1 575 394 4545 W: www.urenco.com/LES
LES-10-002260-NRC cc:
Joselto 0. Calle Acting Chief, Fuel Facility Branch 2 USNRC, Region II 245 Peachtree Center Ave, NE Suite 1200 Atlanta, GA 30303-1257 Deborah A. Seymour Chief, Construction Projects Branch 1 US NRC, Region II 245 Peachtree Center Ave, NE Suite 1200 Atlanta, GA 30303-1257 Anthony T. Gody Deputy Director, Construction Projects US NRC, Region II 245 Peachtree Center Ave, NE Suite 1200 Atlanta, GA 30303-1257 Tyrone D. Naquin, Project Manager Two White Flint Mail Stop EBB2-C40M 11545 Rockville Pike Rockville, MD 20852-2738 Sarah Cottrell, Deputy Secretary New Mexico Department of Environment Office of the Secretary 1190 St. Francis Drive P. O. Box 26110 Santa Fe, NM 87502-0157 Gregory H. Fulfer Chairman Lea County Board of County Commissioners Lea County Courthouse 100 North Main Lovington, NM 88260 Matt White, Mayor City of Eunice P.O. Box 147/1106 Ave J Eunice, NM 88231 Richard A. Ratliff, PE, LMP Radiation Program Officer Bureau of Radiation Control Department of State Health Services Division for Regulatory Services 1100 West 49th Street Austin, TX 78756-3189 Michael Ortiz, Chief Radiation Controls Bureau Field Operations Division Environmental Department Harold S. Runnels Building 1190 St. Francis Drive, Room S 2100 P.O. Box 26100 Santa Fe, NM 87502-0157 Gary Don Reagan, Mayor City of Hobbs 200 E. Broadway Hobbs, NM 88240 Cheryl Chance, Mayor of Jal P.O. Box Drawer 340 Jal, NM 88252
LES-10-00260-NRC ENCLOSURE LOUISIANA ENERGY SERVICES/URENCO USA (LES/UUSA)
REPLY TO NOTICE OF VIOLATION (NOTICE) 70-3103/2010-014-002 Restatement of Violation:
During an NRC inspection conducted on October 4-7, 2010, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:
Special Nuclear Material (SNM) License No. 2010 requires, in part, that the licensee shall conduct authorized activities at the Louisiana Energy Services, L.L.C., National Enrichment Facility (LES NEF) in accordance with statements, representations, and conditions in the approved Quality Assurance Program Description (QAPD), dated April 9, 2004, and supplements thereto. The LES NEF QAPD commits to American Society of Mechanical Engineers (ASME) NQA 1994, Quality Assurance Requirements for Nuclear facility Applications, including supplements as revised by the ASME NQA-la-1995 Addenda for implementation of 10 CFR 50 Appendix B.
Section 3, "Design Control, "of the LES NEF QAPD and Basic Requirement 3, "Design Control," of NQA-1-1994 states, in part, that changes to final designs, field changes, and modifications to the operating facility, shall be governed by control measures commensurate with those applied to the original design.
Contrary to the above, prior to October 4, 2010, the licensee modified the process piping associated with Cascade 1 without conducting the required design activities commensurate with those applied to the original design of the subject piping. The modification included cutting and subsequently re-welding a section of the Cascade 1 process piping.
This is a Severity Level IV violation (Supplement 6.2.d)
UUSA Reply to Violation:
- 1)
The Reason for the Violation This was a human performance event. The reason for the violation was that inadequate knowledge and skills of effective planning/procedure writing led to the development of a work plan and execution that lacked sufficient detail to ensure that scope, quality, compliance, configuration, and other requirements could be controlled. In summary, the apparent and contributing causes were:
Worker Knowledge and Skills Less Than Adequate Procedure Level of Detail Less Than Adequate Communication Less Than Adequate/Improper Mental Model Page 1 of 3
LES-10-00260-NRC 0
Supervisory Oversight Less Than Adequate
- 2)
The Corrective Steps That Have Been Taken and Results Achieved Corrective actions (steps) that have been taken pursuant to the applicable Condition Report (CR 2010-3207) are as follows:
CR Action No. 1 -
An appropriate and approved plant modification (encompassing Design Change Notice DCN 2010-001 (Cascade 1 Bung Removal) and the associated 70.72 review) was included in Work Order WO 3003881 prior to closure of the work package and restart of Cascade 1 (thereby conducting design activities commensurate with those applied to the original design of the subject piping).
[Action Completed on October 29, 20101 CR Action No. 2 - A memorandum was issued by the Maintenance Manager to the appropriate Maintenance personnel to communicate the management expectation that for work plans associated with QL-1 and QL-2 activities, the primary supervisor shall be a UUSA employee, or the appropriate representative of a vendor/contractor listed in the ASL approved for the performance of that work; and reinforce the expectation that when work is assigned to an approved vendor/contractor, oversight responsibility is maintained by the Maintenance management staff.
[Action Completed on October 28, 20101 CR Action No. 3 - Copies of the CR problem description and Detailed Apparent Cause Evaluation (DACE) report were shared with the Maintenance staff (as maintenance support required reading).
[Action Completed on October 29, 20101 CR Action No. 4 - Training Needs Analyses were performed for 1) Human Performance Error Reduction Techniques/Verification and Validation; and
- 2) Level of Detail; Work Control Process Changes; Contractor Oversight.
[Action Completed on November 15, 20101 CR Action No. 6 - Work Control Procedure WC-3-1000-02, "Work Package Development, Issuance, and Closure" was revised to include specific steps to ensure the appropriate implementation of the Plant Modification process. [Action Completed on October 28, 20101 CR Action No. 7 - A (CR 2010-3207) Lessons Learned briefing was conducted by the Maintenance Manager for the Maintenance organization. [Action Completed on November 18, 20101
- 3)
The Corrective Steps That Will Be Taken Pursuant to CR 2010-3207, Action No. 5, training (derived from the training needs analyses in CR Action 4 above) will be performed for planners on:
Human Performance Error Prevention Tools (for office workers)
Page 2 of 3
LES-10-00260-NRC Technical Writing The 70.72 Process The QAPD
[Action No. 5 Scheduled Completion Date: January 28, 20111
- 4)
The Date When Full Compliance Will Be/Was Achieved Full compliance was achieved on October 29, 2010, upon completion of CR Action No. 1 above. Further actions entailing training activities derived from the training needs analyses are scheduled for completion by January 28, 2011.
Page 3 of 3