ML20141G590
| ML20141G590 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 06/30/1997 |
| From: | Polston S UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-7001-97-02, 70-7001-97-2, GDP-97-1017, NUDOCS 9707090407 | |
| Download: ML20141G590 (27) | |
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I United stries Enrichment Corporation Paducah site Ofrux t
P.O. Iku 1410 Paducah. KY 42001 Tel: 502 441-5803 iax: 502 441-5801 June 30,1997 U.S. Nuclear Regulatory Commission GDP-97-1017 l
ATTN: Document Control Desk Washington, D.C. 20555 i
Paducah Gaseous Diffusion Plant (PGDP)
Docket No. 70-7001 Response to Inspection Report (IR) 70-7001/97002 Notices of Violation (NOVs) l l
Nuclear Regulatory Commission (NRC) letter dated May 30,1997, transmitted the subject IR that contained eight NOVs. United States Enrichment Corporation's (USEC) response to these violations is provided in Enclosures 1-8, respectively. Enclosure 9 lists the commitments made in this report. Unless specifically noted, the corrective actions specified in each enclosure apply l
solely to PGDP.
i Additionally, our investigation into the circumstances that led to the failure to maintain proper l
security for Confidential Restricted Data (i.e., NOV 70-7001/97002-31) has identified similar problems which has caused us to broaden the scope of our investigation. Therefore, in order to l
ensure that our response to this NOV is fully adequate, USEC will provide a supplemental response to NOV 97-002-31 by August 1,1997.
l If you have any questions regarding this submittal, please contact Bill Sykes at (502) 441-6796.
Sincerely, i
9707090407 970630 General Manal,er a
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[DR ADOCK 0700 001 Paducah Gaseous Diffusion Plant L
SP:SRC: mig
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Enclosures
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NRC Region JII
(({g(($((l{\\f$)$f$hkkkk,kk NRC Senior Resident inspector,PGDP l
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ENCLOSURE 1 UNITED STATES ENRICHMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7001/97002-01 Restatement ofViolation Technical Safety Requirement 3.2.2.a. requires, in part, that: Minimum staffing requirements for each facility are as shown in Technical Safety Requirement Table 3.2.2-1.
Technical Safety Requirement Table 3.2.2-1 defines the minimum stafling requirements for Building 1
C-360 during Mode 7 (sampling) operations as: "At least one person in the laboratory. One person l
in the facility or immediately surrounding grounds to include the guard station and the cylinder l
yard."
j Procedure, OPS-11, Rev. 2, Change D, dated March 3,1997, " Shin Tumover," step 6.2, requires, in part, that: "The shiR operating personnel shall not leave their work area until they are satisfied l
that their reliefis fully aware of existing conditions."
l Procedure, OPS-8, Rev. 0, Change G, dated March 3,1997, " Shift Routines and Operating l
Practices," step 5.4.1, requires, in part, that operators: " Exhibit professional conduct and good watch standing practices to assure proper attention to plant conditions."
l Pmcedure CP2-TR-TR1030, Rev.1, Change A, dated February 28,1997, " Required Reading," steps l
6.4 and 6.7, require, in part, that: personnel review, initial, and date the Immediate Required Reading file prior to performing tasks and/or duties to which the material applies by reading the material within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of assignment.
1 Contrary to the above, on April 14,1997, between 6:30 a.m. and 7:00 a.m., only one operator was in the Building 360 Laboratory, facility, or immediately surrounding grounds while the facility operated in Mode 7. Specifically, one of the two required Building 360 operators: (1) len the i
assigned work an:a without being relieved; (2) retumed to the assigned work area attired in personal clothing which precluded normal access and proper attention to plant conditions controlled from or displayed in portions of the routine work area; and, (3) assumed watch standing responsibilities l
without reviewing, initialing, or dating immediate required reading files, which included materials issued since March 3,1997, that applied to the normal tasks and duties of the Building 360 operator.
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I.
Reason for Violation i
l' The reason for examples 1 and 2 of this violation was that administrative controls and policies were not specific with regard to the requirements as identified in TSR section 3.2.2.
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The operative procedure (OPS-11, section 6.7.1) permitted operators to utilize a period of time prior to shin turnover to shower and be prepared to conduct shin tumover when their relief arrived. Management had reasoned that an operator in the shower could respond to alarm conditions in roughly the same time as an operator that was remotely located in the El-1
. facility work area as described in the TSR. Also it was determined that operators could respond to alarm conditions in personal clothes even if this required entrance into a Contamination Control Zone (CCZ). These assumptions and the TSR training provided were not sufficiently conservative and failed to meet the intent of the requirements as described in the TSRs or upgraded Operations and Health Physics procedures.
The reason for example 3 of the violation was that appropriate barriers were not established to ensure that operators completed the required reading assignments prior to being assigned to the affected facility. At the time of the incident, the operator qualified to work in C-360 was normally assigned to building C-335 and kept up to date on his required reading through the required reading book in C-335. No requirements or controls were in -
place to ensure that personnel not normally assigned to C-360 were provided the same inform:ition to review.
II.
Corrective Actions Taken and Results Achieved 1.
The compensated shift tumover time period was expanded from 12 minutes to 24 minutes for pesonnel to meet the TSR staffing requirements. This allows adequate time for shift turnover and for oncoming shift personnel to assume facility operational responsibilities.
2.
C-360 backup operators have been placed on the C-360 required reading list in their respective normally assigned facilities.
3.
Requimd reading manuals were reviewed and revised as required to ensure Cascade and UF. Handling personnel were listed in the appropriate required reading manuals according to their qualifications, i
III. Corrective Actions to be Taken 1.
By July 18,1997, Cascade Training Review group (TRG) will develop a methodology i
for implementation of training requirements.
2.
By July 31,1997, conduct a root cause analysis to determine reasons for workforce unfamiliarity with TSR's and develop a corrective action plan to address root causes (This analysis should address a lack of specificity in TSR requirements that are not well defined in flowdown documents).
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l IV. Date of Full Compliance
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USEC achieved full compliance with examples 1 and 2 of the violation when the shift turnover policy was revised from 12 minutes to 24 minutes on April 25, 1997. Full compliance with example 3 of the violation was achieved on May 30,1997, when the qualified l
operators were verified to be on the appropriate list (s). The corrective actions to prevent I
recunence will be completed by July 31,1997.
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ENCLOSURE 2 UNITED STATES ENRICHMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7001/97002-02 Restatement of the Violation Technical Safety Requirement 3.2.2.b. requires, in part, that: administrative procedures be implemented to limit the working hours of facility staff who perform safety functions such that an individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period.
Procedure CP2-HR-LR1030, " Limitations on Hours of Work," step 6.3.4, requires, in part, that: "a person shall not be permitted to work mom than 16 consecutive hours, excluding shift tumover time, without preauthorized approval from the general manager or designee."
Contrary to the above, on March 5,1997, two instrument mechanics performing safety functions (work on criticality accident alarm cluster "V" in Building C-337 and the associated required documentation) worked more than 16 consecutive hours, excluding shift turnover time, without preauthorized approval from the general manager or designee.
I.
Backcround Information On February 5,1997, the General Manager issued a directive to the Organizational Managers to implement the Hours of Work Limitations (32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> in a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period, 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> in a 7-day period, and 16 bours in a 24-hour period,16 continuous hours and returning to work less than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after last work period) effective March 3,1997 thru March 31,1997. These limitations would be complied with over the March 3-31,1997, period by policy directive until the limits were revised in accordance with the Compliance Plan. (The plant (vas operating under the assumption that the hours of work lir.titations would change on March 31,1997.)
On February 15,1997, procedure CP2-HR-LR1030 rev. O, " Limitations on Hours of Work," was signed, effective date March 31,1997. This procedure stated the hours of work limitations were the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48-hour period,72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7-day period, etc. These limitations were the limits to be imposed once the NRC reviewed and approved the TSR change request required by the Compliance Plan. The March 31 date was the Compliance Plan commitment date to submit a proposed change to the TSR imposing the more stringent overtime limits. As noted above, we mistakenly identified this date as the date needed for compliance with the new limits.
II.
Reasons for Vio!ations The violation resulted from less than adequate administrative control in that the policy directive written for March 3,1997, which was issued, did not detail the process and was not i
adequately available to all personnel. The policy directive needed to provide more detail on the exceptions allowed and the process to follow in gaining approval for these exceptions.
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. Communication of this process was ineffective.
III. Corrective Actions Taken and Results Achieved 1.
On March 7,1997, Change A of procedure CP2-HR-LR1030, " Hours of Work l
Limitations," was issued. This change included the 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in a 24-hour period,32 l
hours in a 48-hour period and 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> in any 7-day period, etc. (This e,ction provided l
a procedure to replace the ineffective policy.)
2.
Guidance in the form of electronic mail was provided to managers / employees clarifying the procedure and time entry methods during March and April of 1997. (This guidance communicated more clearly and reinforced the procedure.)
3.
An Overtime Canvassing System (OCS) computer program has been placed into service to assist in compliance with TSR Hours of Work Limitations.
4.
Awareness sessions were conducted with managers on Hours of Work Limitations and the monitoring system (OCS) on March 17,1997 and March 26,1997.
5.
A performance indicator has been initiated to track the plant's progress for TSR Hours of Work Limitations compliance.
6.
USEC informed each individual covered by the Hours of Work Limitations by letter on June 16,1997, of the TSR requirements and the problems that have been encountered.
IV. Corrective Actions to be Taken 1.
Procedure CP2-HR-LR1030 will be revised by August 1,1997, to better define working periods, shift tumover, and provide adequate explanation on how to calculate hours of work.
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The revised precedure will be communicated by September 30,1997, through the use of plant-wide required reading and the use of the site newsletter.
V.
Date of Full Comoliance USEC achieved compliance with this violation when the affected individuals were relieved off shift on the day of the violation. The corrective actions taken to prevent recurrence will be completed by September 30,1997.
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ENCLOSURE 3
. UNITED STATES ENRICIIMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7001/97002-03 Restatement of Violation Technical Safety Requirement 3.9.1 requires, in part, that written procedures shall be implemented to cover the activities described in Safety Analysis Report, Section 6.11.4.1 and listed in Safety Analysis Report, Section 6.11, Appendix A.
Safety Analysis Report, Section 6.11, Appendix A lists Operations activities (including alarm j
response) as activities requiring written procedures.
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Alarm Response Procedure CP4-CO-AR8360-7,"HIGH LEVEL DRAIN D101," Rev. O, dated July 31,1995, step 9 requires,in part, that following actuation of the water inventory control system (drain level probes), operators may retum the autoclave to service: "When...cause of alarm has been -
determined and corrected."
Contrary to the above, on April 9,1997, Building 360 operators retumed autoclave number 1 to service, following actuations of the water inventory control system, without determining or correcting the cause of the alarm.
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Backcround Information On April 9,1997, at 2030, the C-360 No. I autoclave experienced a high drain alarm.
The autoclave was 30 minutes into a heating cycle. The alarm condition cleared immediately aner being received. Only one of the two installed condensate probes actuated.
The alarm response procedure, CP4-CO-AR8360-7, requires the cause of the alarm to be determined and corrected before retuming the autoclave to service. The evaluation of the condition by the PSS and C-360 management determined that the autoclave isolation was the result of a spurious actuation of the water inventory control system.
Although, the personnel responsible for compliance with supplemental Step 9 in CP4-CO-AR8360-7 believed they had adequately established the cause of the system actuation as spurious, the C-360 No. I autoclave was retumed to service without fully investigating the cause of primary system actuation. Their review did not include an analysis of the chart recorder data or instrumentation and control troubleshooting to establish continuity data l
regarding the conclusion that a spurious incident did occur.
l On April 10,1997, after extensive review of chart recorder information, Engineering l
personnel detennined that the system actuation was not spurious. The review included an evaluation and analysis of autoclave process parameters which provided inferential information about the pmsence ofcondensate. The actuation was the result of high condensate E3-1 l
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. conditions caused by initiating heating cycles simultaneously for Autoclaves 1 and 2. The details of this event are the subject of Event Report PAD-1997-07.
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Reasons for Violation l
The reason for the violation was that clear and explicit guidance did not exist regarding l
the depth and nature ofinvestigations required prior to the return of a system to operation after I
safety system actuation in that there was not a requirement for an appropriate management review prior to returning the affected equipment to service.
III. Corrective Actions Taken and Results Achieved 1.
On April 10,1997, the PSS group adopted the requirement to involve Systems / Shift Engineering in subsequent safety system actuations in C-360.
2.
Upon completion of the current heat cycle for Autoclave No.1, Instrument Maintenance j
l performed the Water Inventory Control System (WICS) functional test and operability was restored on April 11,1997.
3.
On April 17, 1997, Shift Operations Long Term Order 300-97-003 was issued to implement the practice described in Action 1 above. Per this long term order, any future safety system actuations (not limited to those in C-360) should be investigated with tha aid of the assigned Systems Engineer.
l IV. Corrective Actions to be Taken 1.
By August 8,1997, procedural guidance will be issued which establishes management expectations and investigation methodologies to be employed prior to returning equipment to service aller a safety system actuation.
V.
Date of Full Comoliance USEC is currently in full compliance with the requirements of the TSR in that a l
procedure is in place to provide guidance to activities as described in the SAR. Long Term L
Order 300-97-003 which clarifies the requirements of this process was issued on April 17, i
1997. The corrective actions to prevent recurrence will be completed by August 8,1997.
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1 ENCLOSURE 4 UNITED STATES ENRICIIMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7001/97002-04 i
Restatement of the Violation Technical Safety Requirement 2.2.4.3.a and Technical Safety Requirement 2.2.4.2.a require that criticality accident detection shall be operable in areas, equipment, or processes which contain greater than 700 grams of uranium-235 at an enrichment greater than or equal to 1.0 weight percent uranium-235.
Contrary to the above, on March 4,1997, Building C-337 criticality accident detection cluster "V" and on March 18,1997, Building C-337-A criticality accident cluster "N" were inoperable for areas which contained greater than 700 grams of uranium-235 at an enrichment greater than or equal to 1.0 weight percent uranium-235.
1.
Backcround Information The Criticality Accident Alarm System (CAAS) at the PGDP is designed to detect gamma radiation levels that would result from the minimum criticality accident of concern and to warn plant personnel by activating evacuation alarms. The CAAS consists of clusters of three detector modules and one logic module. According to the Safety Analysis Report (SAR),
Section 3.12.6, "The clusters consist of three detector modules which alarm when a gamma dose-rate of 10 milliroentgen per hour (mR/hr) above background is detected." Each detector module has an internally generated signal to maintain a constant operational check of the l
detection circuits.
Currently the backgmund reading of the detector is initially adjusted to display a nominal 10 mR/hr on the front panel of the detector module. The alarm set point of each detector module is currently set at a nominal 20 mR/hr so that the detector module will go into alarm status ifit receives radiation of 10 mR/hr or greater above background. The fault set point of 1
each detector module is currently set at a nominal 5 mR/hr so that the detector module will go into fault status if the background reading drops significantly. A fault status is indicative of equipment problems and causes the CAAS to transmit a trouble signal to the central control room. Each detector module will detect radiatien independently of each other. The cluster is designed to minimize the number of false audible evacuation alarms that plant personnel experience by applying the following logic to interpret detector module alarm status. To receive an audible CAAS alann, one of two conditions must exist: (1) at least two of the three detector modules must be in alarm status simultaneously; or (2) only one detector module is in alarm status while the other two detector modules are in fault status.
On November 6,1996, under regulation of the Department of Energy, two CAAS detector modules in cluster "X" in the C-337 building were observed with low background readings of 9 mR/hr. (Event Report PAD-1996-0058). While the actual background radiation E4-1
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, level would be essentially zero, the CAAS indicating meter is set to indicate a background of 10 mR/hr 10.5 mR/hr. This means at an actual radiation field of 10 mR/hr, the meter will l
indicate 20 mR/hr.t0.5 mR/hr. The alamlis set to initiate at 10 mR/hr above background. (10 l
mR/hr background set point plus 10 mR/hr radiation field equals 20 mR/hr alarm set point nominal values.) A low background reading on a module could prevent the module from going into alarm status even though it has detected a 10 mR/hr increase in radiation. As stated i
above,in order to generate an audible alarm, the cluster logic requires either (a) two detectors to be in alarm status; or (b) One detector to be in alarm status while the other two detector modules are in fault status. Therefore, simultaneous low background readings on two detector modules could prevent an audible alarm from being generated even though one or more modules has detected 10 mR/hr radiation. For that reason, clusters are currently declared inoperable if two of the three detector modules have background readings below 9.5 mR/hr.
As a result of the above event, Long-Term Orders (LTO) were issued to establish weekly field monitoring of CAAS clusters to determine if the low background readings constitute a system problem. The LTO instructs operators that " modules with readings found below 9.5 mR/hr are to be promptly reported to the plant shift superintendent and a work order initiated for change out." On February 4,1997, another incident of two CAAS modules with low background readings occurred (Problem Report PR-CO-97-0556). A preliminary event report was submitted April 2,1997 to NRC. CAAS clusters "U" and "AK" located in the C-337 building were observed with the two modules reading 9.0 mR/hr. The clusters were declared inoperable and the Limiting Condition for Operation (LCO) action steps as defined by Operational Safety Requimments (OSR), KY/D-3971, Section 3.1.2.3 were implemented. The modules were replaced by Instrument Maintenance and clusters "U" and "AK" were declared operable on February 4 and 7, respectively.
On March 4,1997, during the weekly field monitoring of the CAAS clusters, cluster "V" in C-337 process building was found with two of the three modules displaying background i
readings below 9.5 mR/hr. Detector Module Serial No. 580054 and Detector Module Serial No. 580105 were both reading 9.0 mR/hr. The cluster detector units are Model GCM-650 gamma criticality monitors, manufactured by Nuclear Research Corporation. Cluster "V" was declared inoperable. Since TSR Section 2.4.4.2a defines the LCO as " Criticality accident detection shall be operable" and since cluster "V" does not have complete overlapping i
coverage from adjacent clusters, the LCO action steps as defined by TSR Section 2.4.4.2 were implemented. Due to this "as found" inoperable condition, an event notification (# 31892) was made on March 4,1997, pursuant to 10CFR76120(c)(2)(I).
During the course of the investigation, another was observed with two modules exhibiting background readings below 9.5mR/hr. On March 18,1997, at 1305, Cluster N in C-337A building was observed by the NRC inspector with two detector modules reading 9.0 mR/hr (Detector Module Serial No. 580133 and.580142.) Cluster N was declared inoperable and the LCO action steps as defined by TSR Section 2.4.4.2 were implemented. Due to this "as found" inoperable condition, an event notification (#31968) was made on March I 8,1997,
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pursuant to 10CFR76120 (c)(2)(I). The modules were replaced by Instrument Maintenance i
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,and ClusterN was declared operable at 1710 on March I8,1997. The modules were retumed to the Instrument Maintenance Shop for testing.
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Reason for Violation i
Eis violation occurred because the radiation alarm set point of 20 mlVhr was too high given the variations which occur in the background readings on the modules. Setpoint drift in the pre-set background setpoint of 10 mR/hr was determined to be 2 mR/hr. This setpoint drift resulted in module readings below 9.5 mR/hr.
Ill.
Corrective Actions Taken and Results Achieved 1.
On January 2,1997, Operations issued LTOs to perform weekly checks of the CAAS clusters to check for low background readings. Modules with readings found below 9.5 mR/hr were to be promptly reported to the plant shift superintendent and a work order issued for change out.
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On March 4,1997, Instrument Maintenance replaced two modules in cluster "V" and the cluster was returned to an operable status at 2330.
3.
On March 7,1997, Instrument Maintenance retumed three detector modules to the vendor for further diagnostic tests and evaluation.
4.
On March 18,1997, Instrument Maintenance replaced two modules in cluster "N" and the cluster was retumed to an operable status at 1710.
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On April 7,1997, Engineering completed an Engineering Evaluation to support a change in the CAAS detector module set points. The new values will be 10 mR/hr for the alarm ret point and 4 mR/hr for the background setting. The trouble alarm will be lowered to 2.5 mR/hr. Engineering also generated required documentation to support the associated procedure changes.
VI. Corrective Actions to be Taken By September 23,1997, Instrument Maintenance will complete changes on set points of l
all CAAS detector modules as defined in the Engineering Evaluation in Planned Corrective Action No.1. Affected Instrument Maintenance procedures will be modified, as required, prior to changing set points.
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Date of Full Compliance Full compliance with the specifics described in the NOV will be achieved on September E4-3 I
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23,1997. The corrective actions taken to prevent recurrence will be completed on
' September 23,1997.
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ENCLOSURES 1
l UNITED STATES ENRICHMENT CORPORATION (USEC)
RESPONSE TO NOTICE OF VIOLATION (NOV) 70-7001/97002-13 i
l Restatement of Violation Technical Safety Requirement 3.11.1 requires, in part, that a Criticality Safety Program be implemented as described in the Safety Analysis Report.
Safety Analysis Report, Section 5.2.2.6 states, in part, that: " Operations to which NCS [ nuclear criticality safety] pertains shall be governed by written procedures. These procedures contain the i
appropriate NCS controls for processing, storing, and handling of fissile material."
Procedure, CP2-TS-TS2030, Rev. 0, dated December 10,1996, " HANDLING AND STORAGE OF LEGACY PROCESS EQUIPMENT,"is a procedure for handling fissile material which implements the controls for the Criticality Safety Program for handling legacy equipment with unknown amounts of potentially fissile material.
Procedure CP2-TS-TS2030, step 8.2.1, requires, in part, that personnel: " mark / rope off equipment and tag with a Legacy Process Equipment Tag."
Contrary to the above, from March 3 through April 15,1997, legacy process equipment on the cell floorin Building 335 (compressors and a G-17 valve), was tagged with a Legacy Process Equipment Tag, identifying the equipment as containing unknown amounts of potentially fissile material, but had not been marked or roped off.
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Reason for Violation The reason for the violation is the failure to demarcate potentially fissile legacy equipment, as required in CP2-TS-TS2030, " Handling and Storage of Legacy Process Equipment." CP2-TS-TS2030 was later found to contain errors and inconsistencies with NCSA GEN-27 which were umelated to the posting requirement but prevented the safe implementation of NCSA GEN-27.
11.
Corrective Actions Taken and Results Achieved 1.
Due to inconsistencies and enors which were discovered in CP2-TS-TS2030, the procedure was placed on administrative hold. Engineering Notice EN-C-832-97-016 was written to document the basis for the procedural hold, and a Functional Directive was issued to ensure that all affected personnel were made aware of the procedural hold.
This required the immediate suspension oflegacy process equipment handling.
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With CP2-TS-TS2030 placed on hold, Engineering Notice EN-C-832-97-018 was issued, as a safety enhancement, to require an NCS " styled" posting to be placed on legacy l
process equipment which was not previously posted or otherwise demarcated. This was -
I needed since full implementation of the posting requirements of CP2-TS-TS2030 had I
not been achieved prior to the procedural hold being issued.
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All areas which could have contained legacy equipment at PGDP were walked down by plant staff. These walk downs identified existing legacy equipment at PGDP and ensured that the equipment was posted and/or roped to ensure that potentially fissile i
equipment is clearly demarcated with Nuclear Criticality Safety postings.
4.
' NCSA GEN-27 was revised to clarify posting requirements and NCSA applicability.
5.
CP2-TS-TS2030 was mvised and implemented to correct errors and inconsistencies with i
NCSA GEN-27. This action included appmpriate training to support the implementation -
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ofCP2-TS-TS2030.
l IV. Corrective Actions to be Taken l
No additional corrective actions were required to address the concerns ofNOV 97002-13.
V.
Date of Full Comoliance -
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Full compliance was attained on June 27,1997, when the existing GEN-27 equipment l.
at PGDP was posted and demarcated in accordance with CP2-TS-TS2030 to ensure that it was l
l made identifiable as potentially fissile.
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s ENCLOSURE 6 UNITED STATES ENRICHMENT CORPORATION (USEC) l REPLY TO NOTICE OF VIOLATION (NOV) 70-7001/97002-19 i
Restatement of Violation j
10 CFR 76.120(c)(2) requires that the certificatee notify the NRC Operations Center within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the discovery of an event in which equipment is disabled or fails to function as designed when:
' (1) the equipment is required by a Technical Safety Requirement to mitigate the consequences of l
an accident; (2) the equipment is required by a Technical Safety Requirement to be available and
' operable and either should have been operating or should have operated on demand; and (3) no redundant equipment is available and operable to perform the required safety function.
Technical Safety Requirement 2.4.4.5 requires that the fire protection sprinkler systems m process l
Buildings C-331, C-333, C-335, and C-337 be operable in modes Cascade 1.through Cascade 3,
.I except when the tube oil is valved off or removed from the cells covered by a specific sprinkler system.
Contnuy to the above, as of 9:30 a.m., on March 13,1997, the certificatee had not notified the NRC Operations center 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the discovery, on March 12 at 9:30 a.m., of a disabled sprinkler system required to be operable by Technical Safety Requirement 2.4.4.5. Specifically, numerous 3
cells'withinLBuilding C-331 were operating in modes Cascade 1 through Cascade 3, and no redundant equipment providing an equivalent fire-mitigating safety function was available, when sprinkler system 33, between columns V-33 and W-33 ef Building C-331, was declared inoperable.
The Certificatee notified the NRC Operations Center on March 27,1997.
I.
Backcround Information On March 12,1997 at 9:30 a.m., Fire Services identified a disconnected sprinkler system branch pipe in C-331. This section of system 33 pipe supplies water to sprinkler heads located inside ventilation ductwork and near the ceiling above the ductwork between columns V-33 and W-33. The Plant Shift Superintendent (PSS) declared the C-331 system 33 inoperable in the area with the disconnected pipe at 10:21 a.m. and a fire patrol was initiated in this area at 10:30 a.m.
The PSS reviewed the Technical Safety Requirement (TSR) 2.4.4.5," Fire Protection System - Building Sprinkler System" basis that stated "As discussed in the SAR accident analysis (Sections 4.3.2.5.1 and 4.3.2.5.2), an umnitigated lube oil fire in the process lube oil pits or on the cell floor could cause failure of the structural steel followed by localized collapse.
of the structure. This collapse could damage process piping allowing a release of UF." The 6
PSS also reviewed SAR Sections 4.3.2.5.1, " Lube Oil Fires" and 4.3.2.5.2, " Ventilation Duct i
Fires". Based on his review, he determined that the event did not meet the reporting criteria of 10 CFR 76.120(c)(2)(1) because the TSR basis and the referenced SAR sections did not j
indicate that section of sprinkler system was required nor did it specify the extent of systems E6-1 l
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. adjacent to lube oil sources that might be required. "... by a Technical Safety Requirement to l
prevent releases, prevent exposures to radiation and radioactive materials exceeding specified limits, mitigate the consequences of an accident, or restore this facility to a preestablished safe condition after an accident,...
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On March 13,1997, a review of this event was completed by PSS, Engineering, and i
Nuclear Regulatory Affairs (NRA) personnel and again the conclusion was reached that the event was not reportable. This review was conducted before the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> reporting period had l
expired.
l During subsequent discussions among Engineering, NRA, and PSS personnel on the potential reportability of this issue, Engineering was requested by the PSS group to develop -
l a position on the reportability of this event. In the interim, the decision was made to report any l
newly identified items of this type under 10 CFR 76.120(c)(2).
On March 27,1997, Engineering completed an Engineering Position on Reportability on this subject and stated that the as found condition appeared to constitute a reportable condition under 10CFR76.120(c)(2). During this evaluation, the appropriate engineering basis for the sprinkler system was identified. This basis is that the sprinkler systems provide l
protection to building structural components by cooling the aree, thus, preventing damage potentially resulting in the collapse of building structures and a release.
I.
Reasons for Violation i
i The violation occurred when the PSS classified this e ent as not reportable, based on an incorrect conclusion that the equipment was still capable ofinitigating the consequences of an accident as described in the SAR. 'Ihis conclusion was based on insufficient knowledge of the i
requirement that heads not directly adjacent to or associated with potential lube oil fire areas be operable in order to adequately protect the building structural members in the event of the HPFW sprinkler system actuation.
II.
Corrective Actions Taken and Results Achieved 1.
A 10 CFR 76.120(c)(2) report on the subject event was filed with NRC on March 27, 1997.
2.
The PSSs and Assistant PSSs were informally briefed to report any similar newly j
identified Sprinkler System Discrepancies per 10 CFR 76.120(c)(2) until an Engineering.
I position on reportability was established. Since the briefing, no similar reporting i
problems have occurred.
IV. Corrective Actions to be Taken i
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Complete a crew briefmg on this event with all PSSs, APSSs, and Cascade Coordinators by July 8,1997.
L 2.
Engineering will issue an engineering basis for which sprinkler systems are required to be operable under TSR 2.4.4.5 and TSR 2.3.4.8 by November 21,1997.
3.
Incorporate the engineering basis provided by Engineering and TSR sections 2.3.4.8 and 2.4.4.5 as well as SAR sections 4.3.2.5.1 and 4.3.2.5.2 into the lesson plan for the High Pressure Firewater System by February 27,1998.
4.
Complete training on the revised lesson plan for all PSSs, Assistant PSSs, and Cascade Coordinators by May 29,1998.
V.
Date of Full Comnliance Full compliance was achieved on March 27,1997 when the event was reported in accordance with 10 CFR 76.120(c)(2). The corrective actions to prevent recurrence will be completed by May 29,1998.
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ENCLOSURE 7 UNITED STATES ENRICHMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7001/97002-31 Restatement of Violation -
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' 10 CFR 95.35(a) requires, in part, that no person subject to the regulations in this part may receive i
or may permit any individual to have access to matter revealing Confidential Restricted Data unless the individual has a "Q or "L" access authorization.
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. Contrary to the above, from March 3 through April 15,1997, the certificatee, a person subject to the l~
L regulations in Part 95, permitted individuals who did not have "Q" or "L" access authorizations to have access to drawings revealing Confidential Restricted Data.
I.
Backcround Information L
The issue addressed by this Notice of Violation involves USEC not taking the actions necessary to prevent individuals not having a "Q" or "L" access authorization from having access to drawings revealing Confidential Restricted Data (CRD). This CRD information was l-not marked or protected as classified and was found in areas for which uncleared persons were allowed access. This CRD information was generated during two different times but its unmarked availability had similar root causes. The matter in both instances had apparently not received a classification review. A contributing cause to this issue was that in one case the i
information on which the drawing was based was also not marked as being classified, This issue is similar to other issues addressed in various PGDP Problem Reports where information that should have been classified has been found not marked as classified. This l
issue was identified prior to transition to NRC oversight and was included as a Noncompliance in the " Plan for Achieving Compliance with NRC Regulations at the Paducah Gaseous L
Diffusion Plant," DOF10RO-2026/R3 (Compliance Plan). That Noncompliance was cited as follows, in part, "Some legacy documents have been identified which may not have received a proper classification review and may have been improperly marked with respect to j
classification." This issue is being treated as part ofIssue 26, " Records Management and Document Control Program," in " Description of Noncompliance" paragraph 1.b) " Legacy Records." Due to an apparent oversight, a corrective action plan was not proposed for this l
legacy issue.
II.
Reasons for Violation i
The reasons for this violation were:
1.
A document originated in the early 1950's was apparently generated prior to the current procedures for Authorized Derivative Classification and never received a classification l
review.
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2.
The originator of a drawing failed to follow current procedures and obtain an Authorized Derivative Classification review ofhis drawing prior to distribution. This was due to a mistaken belief that the document would not be classified since the drawing on which it was based had not been classified.
Ill. Corrective Actions Taken and Results Achieved 1.
The subject events were reported to NRC and were documented as PAD-1997-018 and PAD-1997-023, dated April 14 and April 17,1997, respectively.
2.
An investigation was conducted to determine whether other copies of the drawings cited might exist in areas accessible by uncleared individuals. Some additional copies were located and sanitized of the classified information, i.e., the classified information was removed from the drawing, the drawings were destroyed, or were protected in a classified vault. This was completed on June 13,1997.
3.
Employees were notified through Functional Organizations and the Site newspaper, Inside P, that all uncleared individuals were to be denied access of electronically generated documents as well as hard copies of documents, until their work area could be reviewed by an Authorized Derivative Classifier and sanitized as required. This was completed on June 20,1997.
IV. Corrective Stens to be Taken 1.
Issue a plant bulletin that states the policy / procedures associated with the requirements for Authorized Derivative Classification review of documents. This is to be completed by July 31,1997.
2.
Functional Organization Managers will each review the current procedural requirements for document classification and ensure they understand their responsibilities regarding document classification. The intent is to ensure that management is aware of their classified information responsibilities and that they may assure documents generated by their respective functional organizations are appropriately documented, classified, and protected. This is to be completed by July 31,1997.
3.
Institute periodic surveillances of Functional Organization areas to assess conformance to the requirements of Classified Matter control. A status of the planning for this action will be provided by August 1,1997.
4.
A procedure is being developed for uncleared personnel access that stipulates no future i
contract or employment of uncleared personnel will be permitted without receiving Security approval and documented sanitation of the uncleared persons assigned work areas. This is intended to prevent access to Classified Matter while uncleared. This E7-2
procedure will be implemented by July 31,1997.
V.
Date of Full Comnliance Full compliance with the specifics described in the NOV was achieved on June 13,1997 when the noted classified matter was sanitized, destroyed, or protected.
A supplemental response to this NOV will be provided by August 1,1997.
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ENCLOSURE 8 l
. UNITED STATES ENRICIIMENT CORPORATION (USEC) REPLY TO NOTICE OF i
VIOLATION (NOV) 70-7001/97002-32 i
i Restatement of the Violation 10 CFR 76.60(g) requires that the certificatee comply with the applicable provisions of 10 CFR Part 71.
10 CFR 71.5(a) requires, in part, that the certificatee shall comply with Department of Transportation requirements in 49 CFR 170 through 189 for shipments oflicensed material outside of the plant boundaries.
10 CFR 71.12 states that a genemi license is issued to any licensee to transport, or deliver to a carrier for transport, licensed material in a package for which a license, certificate of compliance, or other approval is issued by the NRC. 10 CFR 71.12 requires that the licensee comply with the terms and conditions of the certificate.
49 CFR 173.420(a)(2)(1) requires, in part, uranium hexafluoride must be offered for transportation in packages (cylinders) marked in accordance with American National Standards Institute Standard i
N14.1.
l Condition 6 of Certificate of Compliance No. 6553, Revision 10, for the Paducah tiger overpack, required that each 48X cylinder be inspected, tested, maintained, assembled, and used in accordance with American National Standards Institute Standard N14.1-1990.
American National Standards Institute Standard N14.1-1990, Sections 6, requires, in part, that j
cylinder valve and plug threads are tinned with a thin uniform coating of ASTM B32 alloy 50A solder. Section 6 also requires that cylinder name plates are stamped with the cylinder tare weight in pounds.
l Contrary to the above, from March 3 through April 21,1997, the certificatee delivered cyli iers to carriers for transport, outside the plant boundaries, that were not assembled and maintained in accordance with American National Standards Institute Standard N14.1. Specifically, cylinder valve and plug threads were not tinned with ASTM B32 alloy 50A solder and revised tare weights, determined during 5-year hydrostatic tests, were not stamped on the cylinder name plates, i
Example 1 I.
Background Information i
The cited violation states that USEC was in noncompliance with ANSI N14.1 from March 3 through April 21,1997. However, it is noteworthy that USEC did not identify this deficiency (i.e., that the tin content of the cylinder valves and plugs) until April 9,1997. Upon i
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. discovery of this event, USEC took immediate and prompt corrective actions to: 1) stop l
shipment of the affected cylinders; 2) report this to NRC (both verbally and written); 3) submit an application for revision to the Certificate of Compliance (CoC) (USEC letter GDP 97-0065 dated April 14,1997); 4) submit an application for revision to the Radioactive Material Packaging and Transportation Quality Assurance Program (PTQAP) (USEC letter GDP 97-l 006 dated April 15,1997); 5) and a request for an exemption from the applicable DOT Regulations All of these actions were described in more detail in our 10CFR71.95 report sent to the NRC on May 8,1997. This issue was self-identified, resolved expeditiously and explained to the NRC in a prompt manner.
11.
Reason for Violation The violation resulted from continuation oflong standing practices without assurance of their conformance to the applicable requirements.
111. Corrective Actions Taken and Results Achieved USEC mquested and received, from both the NRC and the Department of Transportation (DOT), an amendment to the NRC Certificate of Compliance (CoC), PTQAP, and an exemption to the DOT regulations to allow resumption of shipping.
IV. Corrective Stens to be Taken Internal maintenance procedures pertaining to cylinder valve and cylinder plug tinning will be reviewed and modified, if necessary, to include steps to test and verify that the tinning solder mixture meets the limits imposed by the CoC. These actions will be completed by August 27,1997. (These procedure changes are being made to add the new mixture limits and other criteria added as a result of the CoC amendment and PTQAP change. They are not j
needed for compliance.)
)
i V.
Date of Full Compliance Full compliance with the specifics described in the NOV was achieved on April 16,1997 when the DOT regulation was appropriately exempted and the PTQAP was revised. The corrective actions taken to prevent recurrence will be completed by August 27,1997, 1
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Example 2 1.
Reasons for violation The reason for the violation is that the ANSI Standard does not contain a clear requirement to update the tare weight on the cylinder nameplate as it changes during the life of the cylinder. Many sections of the Standard actually lead the cylinder user to believe that the Standard did not intend that this value be changed after it was originally stamped. For example, the Standard section which recommends that the cylinder tare weight be re-established during the five year recertification, continues in the same paragraph to direct that the month and year of the hydrostatic test be stamped on the cylinder nameplatt ar.d other records ofinspection and test be retained by the cylinder owner for a period of five years or until the next recertification. Additionally, the figure in the ANSI Standard showing the cylinder nameplate contains one and only one blank for tare weight and multiple blanks for hydrostatic test month and year.
The second cause of this violation was an inadequate review of the ANSI Standard by plant personnel. Reviewers of the standard should have questioned the lack of clear guidance on this subject in the standard, knowing that tare weight values do change and are a key input to the cylinder fill process. This resulted from the fact that plant personnel do not use the i
nameplate markings on the cylinder for operational purposes. Instead the paper documentation that accompanienhe cylinder is relied upon to ensure that cylinder fill limits are not exceeded.
11.
Corrective Actions Taken and Results Achieved a
1.
A fo1 mal assessment of altematives for stamping re-established tare weights on cylinder nameplates was conducted and technically feasible altematives were identified. A long-term corrective action plan was forn ulated which will accomplish the objective of stamping re-established tare weights on cylinder nameplates within a reasonable period of time.
2.
The assessment included a determination of whether not stamping re-established f are weight values on cylinder nameplates has any immediate impact on the safe operation i
of the plant. The results of this assessment concluded that, even if the operator mistakenly used the original cylinder tare weight value stamped on the cylinder nameplate, conservatism in the cylinder fill limits tabulated in the ANSI Standard would prevent any cylinder from being filled without ovidi.cg the required 5% ullage c.llowance. The conservatism credited in the assessment is the fa.t that cylinde-fill limits in the ANSI Standard are based on the density ofliquid UF. at 250"F. The gaseous diffusion plant uses a controlled steam pressure of 8 psig, equivalent to 235 F, during the feed process. This conservatism results in the actual weight limits used during cylinder fill being at least 390 pounds less than the weight limits corresponding to a density ofliquid UF at 235 F. A random sampling of cylinder documentation
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revealed that worst case tare weight loss over cylinder lifetime is much less than 390 pounds. Based on this determination, PGDP has concluded that it is safe to continue plant operations while administrative controls are revised to formalize what is currently standard practice, i.e. not using tare weight infctmation stamped on the cylinder nameplate during the cylinder fill process.
III. Corrective Stens to be Taken 1.
By June 30,1997, the Plant General Manager will issue a policy memorandum stating
- hat a long-term plan has been initiated to commence stamping of cylinder nameplates with re-established tare weight values.
2.
By June 30,1997, the Operations Manager will issue a Long-Term Order directing Operations to continue to use the value of tare weight contained in the Nuclear Materials Controls and accountability documentation for the cylinder till process and not use the tare weight value stamped on the nameplate.
3.
By July 31,1997, cylinder fill procedures will be updated to specify that tare weights used during the cylinder fill process shall be obtained from NMC&A documentation and not from the cylinder nameplate.
4.
By September 30,1997, all plant engineers will complete required reading on this issue in order to emphasize the need to closely scrutinize all specifications, even indastry standards, for circumstances not forernen by the original authors of the specification.
5.
By October 15,1997, procedures will be updated and a work control process will be in place to begin stamping of re established cylinder tare weights on the cylinder nameplates (either the existing nanseplate or a supplemental nameplate to be welded onto l
the cylinder) as each cylinder comes due for its periodic cleaning, inspection and hydrostatic test. This commitment applies only to the 48X cylinde described in the CoC no. 6553.
IV. Date of Full Compliance i
The corrective actions necessary to establish the process for achieving compliance will be completed by October 15,1997.
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ENCLOSURE 9 LIST OF COMMITMENTS Cover Letter USEC will provide a supplemental response to NOV 97-002-31 by August 1,1997.
Enclosure I 1.
By July 18,1997, Cascade Training Review group (TRG) will develop a methodology for implementation of training requirements.
2.
By July 31, 1997, conduct a root cause analysis to determine reasons for workforce unfamiliarity with TSR's and develop a corrective action plan to address root causes (This analysis should address a lack of specificity in TSR requirements that are not well defined in flowdown documents).
1.
Procedure CP2-HR-LR1030 will be revised by August 1,1997, to better define working periods, shift tumover, and provide adequate explanation on how to calculate hours of work.
2.
The mvised procedure will be communicated by September 30,1997, through the use of plant-wide required reading and the use of the site newsletter.
1.
By August 8,1997, procedural guidance will be issued which establishes management i
expectations and investigation methodologies to be employed prior to retuming equipment to service after a safety system actuation.
By September 23,1997, Instrument Maintenance will complete changes on set points of all 1.
l CAAS detector modules as defined in the Engineering Evaluation in Planned Corrective i
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Action No.1. Affected Instrument Maintenance procedures will be modified, as required, l
prior to changing set points.
l No additional corrective actions were required to address the concems of NOV 97002-13.
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1.
Complete a crew briefing on this event with all PSSs, APSSs, and Cascade Coordinators by July 8,1997.
2.
Engineering will issue an engineering basis for which sprinkler systems are required to be operable under TSR 2.4.4.5 and TSR 2.3.4.8 by November 21,1997.
3.
Incogorate the engineering basis provided by Engineering and TSR sections 2.3.4.8 and 2.4.4.5 as well as SAR sections 4.3.2.5.1 and 4.3.2.5.2 into the lesson plan for the High Pressure Firewater System by February 27,1998.
4.
Complete training on the revised lesson plan for all PSSs, Assistant PSSs, and Cascade Coordinators by May 29,1998.
1.
Issue a plant bulletin that states the policy / procedures associated with the requirements for Authorized Derivative Classification review of documents. This is to be completed by July 31,1997, 2.
Functional Organization Managers will each review the current procedural requirements for i
document classification and ensure they understand their responsibilities regarding document classification. The intent is to ensure that management is aware of their classified information responsibilities and that they may assure documents generated by their respective functional organizations am appropriately documented, classified, and protected. This is to be completed by July 31,1997.
3.
Institute periodic surveillances of Functional Organization areas to assess conformance to the requirements of Classified Matter control. A status of the planning for this action will be provided by August 1,1997.
l 4.
A procedure is being developed for uncleared personnel access that stipulates no future l
contract or employment of uncleared personnel will be permitted without receiving Security l
approval and documented sanitation of the uncleared persons assigned work areas. This is l
intended to prevent access to Classified Matter while uncleared. This procedure will be implemented by July 31,1997.
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l Example 1 1.
Internal maintenance procedures pe taining to cylinder valve and cylinder plug tinning will be reviewed and modified, if necessary, to include steps to test and verify that the tinning solder mixture meets the limits imposed by the CoC. These actions will be completed by August 27,1997.
Example 2 1.
By June 30,1997, the Plant General Manager will issue a policy memorandum stating that a long-term plan has been initiated to commence stamping of cylinder nameplates with re-established tare weight values.
2.
By June 30,1997, the Opemtions Manager will issue a Long-Term Order directing Operations to continue to use the value of tare weight contained in the Nuclear Materials Controls and Accountability documentation for the cylinder fili process and not use the tare weight value starr. ped on the nameplate.
3.
By July 31,1997, cylinder fill procedures will be updated to specify that tare weights used j
during the cylinder fill process shall be obtained from NMC&A documentation and not from the cylinder nameplate.
4.
By September 30,1997, all plant engineers will complete required reading on this issue in order to emphasize the need to closely scrutinize all specifications, even industry standards, for circumstances not foreseen by the original authors of the specification.
5.
By October 15,1997, procedures will be updated and a work control process will be in place i
to begin stamping of re-established cylinder tare weights on the cylinder nameplates (either the existing nameplate or a supplemental nameplate to be welded onto the cylinder) as each cylinder comes due for its periodic cleaning, inspection and hydrostatic test.
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