ML20149J183
| ML20149J183 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 07/21/1997 |
| From: | Allen D UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-7002-97-03, 70-7002-97-3, GDP-97-2014, NUDOCS 9707280102 | |
| Download: ML20149J183 (14) | |
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United States
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Enrichment Corporation
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2 Democracy Center 6903 Rockledge Drive Bethesda, MD 20817 Tel. (3011564-3200 Fax: (301) 564-3201 Untitetl b,lates Eiirichinceit Coiporatiori July 21,1997 GDP-97-2014 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Portsmouth Gaseous Diffusion Plant (PORTS)
Docket No. 70-7002 Response to Inspection Report (IR) 70-7002/97-003 Notice of Violation (NOV)
Nuclear Regulatory Commission (NRC) letter dated June 20, 1997, transmitted the subject Inspection Report (IR) that contained four violations involving: 1) failure to prevent recurrence of clogging of strainers for autoclaves; 2) failure to restore plant N / air to greater than 14 psia on an 2
UO F deposit located on the cell bypass line following an X-joint piping replacement; 3) a cascade 22 converter was surveyed and found with deposits of uranium enriched to 1.0% U-235 and 15 g or more of U-235 and the storage was not performed in accordance with a nuclear criticality safety approval; and 4) shipment of two 30B cylinders in noncompliance with ANSI N14.1.
USEC's response to these violations is provided in Enclosures I through 4, respectively. Enclosure 5 lists the commitments made in this report. Unless specifically noted, the corrective actions specified in each enclosure apply solely to PORTS.
The cover letter to the IR indicated that two of the violations (i.e., Enclosures 1 and 4) resulted from
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inadequacies in our corrective action program at PORTS. USEC continues to take action to improve /
the effectiveness of the corrective action program. During May and June of 1997, training was provided to over 700 plant personnel on the proper methods for completing problem reports and/or developing effective corrective actions. USEC has confidence in our corrective action improvement program and will continue to work to achieve consistent and effective identification of our problems and develop corrective actions which correct the identified deficiency and prevent recurrence.
9707280102 970721*
PDR ADOCK 07007002
&cn MElR!RIQgn Offices in Paducah, Kentucky Portsmouth, Ohio Washington. DC w___-_-_
United States Nuclear Regulatory Commission J61y 21,1997 Page Two If you have any questions regarding this submittal, please contact Ron Gaston at (614) 897-2710.
Sincerely, Dale Allen General Manager Enclosures e
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Regional Administrator, Region III NRC Resident Inspector - PORTS l
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3 United States Nuclear Regulatory Commission
- fuly 21,1997 Page Three Distribution-Robert L. Woolley - 001 bec:
J. Adkins,IIQ J. Dietrich, LMUS
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' D. Silverman, ML&B J. Slider, liq B. Sykes, PGDP R. Wells, IIQ Wob\\jdale\\ ports \\nov97003. pts l
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UNITED STATES ENRICHMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/97003-02 Restatement of Violatian h
10 CFR' 76.93, " Quality Assurance," requires that the Corporation shall establish, maintain, and execute a quality assurance program satisfying each of the applicable requirements of American Society of Mechanical Engineers (ASME) NQA-1-1989, " Quality Assurance Program Requirements for Nuclear Facilities."
American Society of Mechanical Engineers (ASME) NQA-1-1989, Quality Assurance Program
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Requirements for Nuclear Facilities," Basic Requirement 16 " Corrective Action" states that conditions adverse to quality shall be identified promptly and corrected as soon as practical. In the case of a significant condition adverse to quality, the cause of the condition shall be determined and corrective action taken to preclude recurrence.
Contrary to the above, a significant condition adverse to quality was identified in April 1997 in that the corrective actions taken did not prevent the in-line strainer for Autoclave No.1 in the X-344 building from clogging. As a result a safety system actuation occurred m May 13,1997.
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Reason; for Violation USEC agrees that the corrective actions implemented to reduce the occurrence of the High Condensate Level Cutoff Safety System (IICLS) actuation were not adequate to pievent the actuation of this autoclave safety feature. However, Issue 3 item 7 of the Compliance Plan acknowledges that the design and configuration of the autoclave steam supply and condensate m
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removal systems in the X-342, X-343, and X-344 are not adequate to prevent excess condensate from collecting in the autoclave and activating the High Condensate Level Cutoff System The corrective actions taken as a result of the referenced safety system actuations were not designed to prevent the High Condensate Level Cutoff Safety System actuation but were to reduce the frequency of the activations caused by debris accumulating on the in-line j
strainer until more permanent design changes could be fully implemented. In addition, not all the corrective actions committed to as a result of the referenced actuations have been fully implemented. The long term corrective actions, USEC has committed to, are documented in the Plan of Action and Schedule section ofIssue 3 of the Compliance Plan.
Backcround.
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On April 8,1997, at 1454 hours0.0168 days <br />0.404 hours <br />0.0024 weeks <br />5.53247e-4 months <br />, X-344 (AC) #3 experienced a safety system actuation. The event was reported to the Nuclear Regulatory Commission [ Event Report 97-04] because a safety system actuation had occurred due to the detection of a high condensate level in AC #3.
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The direct cause of the event was determined to be debris accumulation in the condensate strainer. The root cause of the event was determined to be the frequency at which the in-line straim r was inspected and cleaned. Following the discovery of the AC#3 restricted strainer, the X-344 AC#2 and AC#4 were inspected for debris. A small amount of rust was found in the AC#2 strainer which had been cleaned 38 days earlier and no debris was detected for AC#4 which had been cleaned 21 days earlier. Autoclaves had previously operated for six months before in-line strainer cleaning was required. Ilowever, based on sound engineering principles and the given information, a monthly inspection and cleaning schedule for in-line strainers was implemented in an attempt to reduce the frequency ofliigh Condensate Level Cutoff Safety System actuations.
On May 13,1997, at 1718 hours0.0199 days <br />0.477 hours <br />0.00284 weeks <br />6.53699e-4 months <br />, X-344 AC#1 experienced a safety system actuation due to a high condensate level. The event was reported to the NRC [ Event Report 97-07]. The direct cause for the IICLS safety system actuation was the accumulation of debris in the condensate strainer. The root cause fo the event was that an abnormal amount of rust accumulated within v
the AC#1 causing the condensate strainer to become more rapidly plugged. In review of the performance history of the autoclaves for a six month period, the information showed that strainers did not plug during the first month of operation. Ilowever, in this case, the in-line strainer became plugged after 88 minutes of opeiation. This in-line strainer was last serviced on May 7,1997. This event [97-07] resulted in the implementation of a weekly inspection and cleaning program for in-line strainers in an effort to detect the accumulation of debris prior to plugging. In additi,n, because the X-344 condensate drain lines are 1" vice 2" as compared with the other autoclave facilities, the surface area of the X-344 in-line strainer is significantly less which causes the X-344 in-line stminers to become restricted more easily. This condition resulted in the need to increase the mesh size and the surface area of the autoclave in-line strainers, however, this action was not accomplished until June 4,1997.
On May 18,1997, at 1420 hours0.0164 days <br />0.394 hours <br />0.00235 weeks <br />5.4031e-4 months <br />, X-344 AC#1 again experienced a safety system actuation due to a high con +nsate level. The event was reported to the NRC [ Event Report 97-08].
The direct cause for the IICLS safety system actuation was the accumulation of debris in the condensate strainer. The root cause for the event was that an abnormal amount of rust accumulated within the AC#1 causing the condensate strainer to become rapidly plugged. It is believed that the weekly autoclave cleaning program is loosening the rust such that while in operation, the rust is released from inaccessible areas and is eventually collected in the in-line strainer. Since the accumulation of rust within the autoclave shell cannot be controlled, the engineering organization has determined that the strainer design should be changed to accommodate the increased amount of rust debris generated as a result of the nckly autoclave cleaning program. As a result of this second actuation of autoclave #1 in less ti.a a week, AC
- 1 remained inoperable until June 4,1997 when the mesh size and the surface area of the autoclave in-line strainers was increased.
Oa June 1,1997, X-344 AC#4 experience a llCLS safety system actuation caused by partial blockage of the condensate drain line. This investigation revealed that the condensate piping El-2
t upstream of the in-hae strainer was partially blocked by foreign debris (i.e., Teflon gaskets) inadvertently dropped through the grating when pigtails were connected / disconnected. The root cause of this event was detemlined to be the lack of adequate controls to preclude foreign material from getting into the condensate drain line.
In summary, given the information available, each corrective action developed was based on operational judgement and sound engineering and maintenance practices. The corrective actions were, at the time judged adequate by the Plant Operational Review Committee.
Ilowever; the corrective actions themselves produced unanticipated conditions that necessitated further corrective actions.
II.
Corrective Actions Taken and Results Achieved 1.)
Worx instructions were revised on June 2,1997 for front line managers to issue weekly work reouests for in-line strainer cleaning after shell cleaning and prior to returning an autoclave to service. [ Duplicate commitment from Event Report 97-07 and 97-08]
2.)
On June 4,1997, work instructions for all autoclaves were issued to ensure that any known or suspect foreign material entering the autoclave condensate drain system is removed or its absence verified by visual inspection prior to autoclave startup. This action provides interim controls while a procedure revision is completed. (Duplicate commitment from Event Report 97-07 and 97-08]
3.)
On June 4,1997, a new condensate strainer incorporating a larger surface area and i
mesh size was installed in the X-344 AC #1. The results of this action are being I
evaluated to confirm desired results are being achieved. [ Duplicate commitment from
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Event Report 97-07 and 97-08]
4.)
On June 26,1997, the work control planners were instructed that the requirements for foreign material exclusion must be included in the applicable work packages anytime work is to be performed inside the autoclave.
5.)
As described in event report 97-07 and 97-08, on July 16,1997, a weekly condensate in-line strainer cleaning for X-344 building autoclaves was included on the PM Master portion of the Computer Maintenance Management System (CMMS). This frequency 4
will continue until an appropriate frequency can be determined based on the rate of debris accumulation.
III.
Corrective Steps to be Taken 1.)
By August 31,1997, the sequence of events ibntified in this report, including this violation, will be reviewed with the Plant Operations Review Committee (PORC) and El-3 i
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selected members of the engineering organization as a Lessons Learned exercise to raise awareness of the corrective action weaknesses identified.
.2.)
By August 21,1997, Autoclave operating procedures will be revised to add steps to ensure that any known or suspect foreign material entering the condensate drain system is removed or its absence verified by visual inspection prior to autoclave startup.
IV.
Date of Full Compliance Full compliance with the specific circumstances of this NOV was achieved on June 4,1997, when the mesh size and the surface area of the autoclave in-line strainer was increased. The corrective action to prevent recurrence will be completed by August 31,1997.
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UNITED STATES ENRICIIMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/97003-07 Restatement of Violation Technical Safety Requirement 2.2.3.15 requires, in part, that within eight hours after entering MODE VI (shutdown), a system which contains an uranyl fluoride (UO F ) deposit greater than safe mass, 2 2 not in a fluorination environment and not undergoing chemical treatment shall be pressurized with nitrogen (M )/ air to greater than 14 psia.
2 Contrary to the above, between April 11 and 12,1997, with cell 29-2-2 in MODE VI, facility staff did not restore plant N2/ air to greater than 14 psia on an UO F deposit located on the cell bypass line 2 2 following an X-joint piping replacement.
I.
Reasons for Violation The n:ason for this violation was due to an error injudgement by an individual in the Nuclear Regulatory AfTairs staff when evaluating which of two TSR requirements applied to the x-joint removal when in fact both TSR requirements were applicable.
Backemund:
During work planning for the removal of the deposit, operations and work control contacted NRA to clarify TSR applicability and limitations. Because it was not recognized that the removal activities would create two separate deposits, the individual involved identified only one applicable TSR requirement. As a result, incorrect information was given. Further evaluation of the event indicated that one deposit was to remain in the in-service piping while the other was to be removed from the system. The NRA staff member did not recognize that the deposit which remained in the system was governed by TSR 2.2.3.15 which requires USEC to pressurize the system with plant N / air to 214 psia within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after entering 2
Mode VI, while the x-joint being removed was govemed by TSR 2.2.3.16 which, for removed equipment, requires USEC to ensure equipment openings remain covered or closed and dry air or N at atmosphere within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Because of this misunderstanding, the TSR 2.2.3.15 2
eight hour limitation was exceeded.
II.
Corrective Actions Taken and Results Achieved Training was provided to the NRA staff on proper communications and on how to respond to questions involving TSRs. In addition, the staff was trained on who should respond to these requests for information. This action was an effort to ensure that uniform and consistent guidance is provided to the implementing organization. This action was completed on June 27,1997.
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Corrective Steps to be Taken t
None required IV.
Date of Full Compliance Full compliance was achieved on April 12,1997, when the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> checks were implemented and plant N2/ air was restored to greater than 14 psia on the UO F deposit located on the cell 22 bypass line following an X-joint piping replacement as required by the TSRs. The :orrective actions to prevent recurrence were completed on June 27,1997 when training was provided.
to the NRA staff, i
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UNITED STATES ENRICIIMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/970003-08 Restatement of Violation Technical Safety Requirement 3.11.2 requires, in part, that all operations involving uranium enriched to 1.0 weight-percent (wt%) or higher U-235 and 15 grams (g) or more of U-235 shall be performed in accordance with a documented nuclear criticality safety approval.
Contrary to the above, on May 1,1997, a cascade converter was surveyed and found with deposits of uranium enriched to 1.0% U-235 and 15 g or more of U-235 and the storage was not performed in accordance with a nuclear criticality safety approval.
I.
Reasons for Violation The reason for this violation was the absence of an administrative Nuclear Criticality Safety Approval (NCSA) specific to handling material discovered that is greater than Planned Expeditious liandling (PEH). The plant has a general NCSA for PEH and has routinely used administrative measures to take control of equipment greater than PEH. The focus of these administrative actions, was to ensure moderation conditions remained unchanged until a specific NCSA was written and approved by the PORC for the specific condition identified.
Special NCSAs for material greater than PEH are generally completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from discovery.
Backcround:
On May 1,1997 an old "29" size converter was surveyed and results indicated a potentially large deposit. More accurate surveys were conducted on May 2,1997 which indicated the deposit exceeded the minimum critical mass of 45 pounds for the approximate five percent assay deposit. The converter was cut-out of the cascade in the 15 70's and at that time the openings on the converter were covered with steel plates tack welded in place. This was an acceptable past practice to minimize wet air in leakage into the converter thus preventing a criticality.
II.
Corrective Actions Taken and Results Achieved 1.)
When Portsmouth became aware that the identified converter was not in compliance with the TSR, work immediately began to buffer the converter with dry air. Buffering of the converter was completed within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> as required by the TSR. During preparation of the response to this violation, it was determined that the requirements of NCSA 0330-013.A00 had not been adequately implemented in plant procedures.
Daily Operating Instruction (DOI)97-119 for the X-330 building and DOI 300-97-071 E3-1 i
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r-for the X-300 building were revised to fully address the applicable NCSA l
requirements until the appropriate procedures can be revised.
2.)
Surveys were performed throughout the process areas to determine if there was any other legacy equipment in storage areas that needed to be classified. The results of the survey identified several pieces of equipment that had not been classified. (e.g.,
several old disconnected cascade converters were found stored in place) The equipment found during the survey was promptly classified and controlled per plant procedures.
3.)
The PSS organization implemented a tracking program for ider.iified PEH equipment.
This provides a tool for the PSSs to ensure LCOs are properly implemented and specific NCSAs were prepared as appropriate.
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Corrective Steps to be Taken 1.)
The Nuclear Criticality Safety Group will develop a generic administrative NCSA specific to the storage and handling of equipment discovered and classified as greater than PEH. This action will be completed by September 30,1997.
2.)
ne generic NCSA developed in action item 1 above will be flowed into appropriate operating procedures as required. This action will be completed by November 30, 1997.
3.)
Procedures to address the requirements of NCSA 0330-013.A00 will be implemented by July 25,1997.
IV.
Date of Full Compliance NCSA 330_013.A00 was approved by PORC on May,31997, to specify the storage and handling requirement for the identified PEH cascade converter. USEC was in full compliance with the TSR 3.11.2 on July 21,1997, when the referenced DOI's were written to implement i.
the speciSc requirements of the NCSA. Actions to prevent recurrence will be completed when i
the generic NCSA has been flowed down into appropriate procedures scheduled for completion by November 30,1997.
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.g UNITED STATES ENRICIIMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/97003-11 i
Restatement of Violation 10 CFR 76.60(g) requires that the Corporation comply with the applicable provisions of 10 CFR Part 71.
10 CFR 71.5(a) requires, in part, that the Corporation shall comply with Department of Transportation requirements in 49 CFR 170 through 189 for shipments of licensed material outside of plant boundaries.
10 CFR 71.12 states that a general 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.
Condition 11 ofCertificate of Compliance No. 4909, Revision 14, for a Model GE-21PF-1 overpack, requires that each 30B cylinder be inspected, tested, maintained, assembled, and used in accordance with American National Standards Institute (ANSI) N14.1-1990.
Section 6.12.6 of ANSI N14.1-1990 requires that the valve and plug threads for 30B cylinders be tinned with a thin uniform coating of ASTM B32 alloy 50A solder.
Contrary to the above, on April 10,1997, the Corporation delivered two 30B cylinders to carriers for transport but failed to assemble and maintain the cylinders in accordance with ANSI N14.1.
Specifically, tinning for the valve and plug threads was not made of alloy ASTM B32 50A solder.
NOTE: Thefourth paragraph above should read, " Condition 6 of certificates ofcompliance no.
6553, no. 9196 and no. 9234 and regulations ofthe Department of Transportation (DOT) 49 CFR 1
173.420 require that each 30 B cylinder he inspected.. ANSIN14.1. "
I.
Reasons for Violation j
The reason for this violation was because the Plant Shift Supervisor &) was not made l
aware of the significance of the Paducah valve tinning issue until a second notification was received detailing the scope of the identified non-conformance. Portsmouth has investigated this issue and determined that the first notification was received at 0010 on April 10,1997, by the Plant Shift Engineer. This information was documented in the Shift Engineer's log book to indicate that Paducah had issued an order to prevent the shipment of all Paducah E4-I t
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.c product cylinders. The Plant Shift Engineer did not clearly communicate this important information to the Plant Shift Supervisor in a timely manner due to other priorities.
' II.
Corrective Actions Taken and Results Achieved 1.)
When the scope of the valve tinning issue was fully understood, stop work notice #37 was issued on April 10,1997 at 1837 preventing the transfer of all 30B cylinders having valve and/or plug changes performed on plant site and the return shipment of Paducah Product Feed Cylinders. This action ensured that suspect cylinders did not a
leave the plantsite until the tinning issue specification was resolved.
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I 2.)
USEC requested and received an amendment to the NRC Certificate of Compliance from NRC and an exemption to the Department of Transportation (DOT) regulation from DOT. These actions were completed by April 16,1997.
j III.
Corrective Steps to be Taken 1.)
USEC will conduct a lessons learned session to be used to train PSSs and Plant Shift Engineers on the importance of clear and timely communications. The session will focus on improving personnel sensitivity to sister plant identified non-conformance in an effort to ensure prompt action is taken to assess the scope of the identified concern. This training will be completed by August 31,1997. This commitment is applicable to both Gaseous Diffusion Plants.
IV.
Date of Full Compliance Full compliance was achieved on April 10,1997, when shipment of all 30B cylinders was stopped. The correction action to prevent recurrence will be completed by August 31,1997.
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,g, lf UNITED STATES ENRICHMENT CORPORATION (USEC)
LIST OF COMMITMENTS 70-7002/97002 i
NOV 97003-02 1.)
By August 31,1997, the sequence of events identified in this report, including this violation, will be reviewed with the Plant Operations Review Committee (PORC) and selected members of the engineering organization as a Lessons Leamed exercise to raise awareness of the corrective action weaknesses identified.
2.)
By August 21,1997, Autoclave operating procedures will be revised to add steps to ensure that any known or suspect foreign material entering the condensate drain system is removed or its absence verified by visual inspection prior to autoclave startup.
NOV 97003-08 1.)
The Nuclear Criticality Safety Group will develop a generic administrative NCSA specific to the storage and handling of equipment discovered and classified as greater than PEll. This action will be completed by September 30,1997.
2.)
The generic NCSA developed in action item I above will be flowed into appropriate operating procedure as required. This action will be completed by November 30, 1997.
3.)
Procedures to address the requirements of NCSA 0330-013.A00 will be implemented by July 25,1997.
NOV 97003-11 1.)
USEC will conduct a lessons learned session to be used to train PSSs and Plant Shift Engineers on the importance of clear and timely communications. The session will focus on irnproving personnel sensitivity to sister plant identified non-conformance in an effort to ensure prompt action is taken to assess the scope of the identified concern. This training will be completed by August 31,1997. This commitment is applicable to both Gaseous Diffusion Plants.
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