ML20151Z578
| ML20151Z578 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 09/17/1998 |
| From: | Reidinger T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | John Miller UNITED STATES ENRICHMENT CORP. (USEC) |
| References | |
| 70-7001-98-11, NUDOCS 9809220028 | |
| Download: ML20151Z578 (1) | |
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September 17, 1998 Mr. J. H. Miller Vice President-Production United States Enrichment Corporation Two Democracy Center 6903 Rockledge Drive Bethesda, MD 20817 Dear Mr. Miller.
This refers to your September 4,1998, response to the Notice of Violation (NOV) transmitted 4
to you by our letter dated August 5,1998, with inspection Report 70-7001/98011. We have reviewed your corrective actions for the violation and have no further questions at this time.
You corrective actions will be examined during future inspections.
If you have any questions, please contact me at (630) 829-9816.
Sincerely, Original Signed by P.
Hiland for Timothy D. Reidinger, Acting Chief Fuel Cycle Branch Docket No. 70-7001 Certificate No. GDP-1 cc:
H. Pulley, Paducah General Manager L. L. Jackson, Paducah Regulatory Affairs Manager J. M. Brown, Portsmouth General Manager S. A. Toelle, Manager, Nuclear Regulatory Assurance and Policy, USEC l
Paducah Resident inspector Office Portsmouth Resident inspector Office
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R. M. DeVault, Regulatory Oversight Manager, DOE J. C. Hodges, Paducah Site Manager, DOE bec w/itr dtd 9/4/98: Docket File PUBLIC IE-07 R. Pierson, NMSS P. Ting, NMSS W. Schwink, NMSS P. Harich, NMSS M. L. Horn, NMSS ntP,g:j R. Bellamy, RI EJM, Ril (e-mail)
D. B. Spitzberg, RIV/WFCO Greens w/o enci DOCUMENT NAME: G:\\SEC\\ PAD 98011.RES To receive a copy of this document, indicate in the box:"C" = Copy without enclosure "E" = Copy with enclosure"N" = No copy OFFICE Rlli lN Rlli
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s USEC A Global Energy Company September 4,1998 GDP 98-1067 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Paducah Gaseous Diffusion Plant (PGDP)
Docket No. 70-7001 1
Response to Inspection Report (IR) 70-7001/98011 Notice of Violation (NOV)
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The subject IR contained one NOV conceming the faihrre to identify, review, and translate design l
requirements associated with installation of the Building C-710 criticality accident alarm system, j
into design output and procedural documents. USEC's response to the violation is provided in. Enclosure 2 lists the conunitments made in this response. The corrective actions specified in the enclosures apply solely to PGDP.
In addition to the cited violation, the IR also identified other concerns regarding the exercise of management oversight for activities that have the potential to impact plant operations. USEC has previously committed to submit a supplemental response to NOV 98009-02 by September 30, 1998, to address actions that are being taken to " ensure that the impact of work directly and indirectly affecting safety related systems is accurately assessed." The supplemental response to IR 98009-02 will address the similar concerns in IR980ll.
Any questions regarding this matter should be directed to Larry Jackson at (502) 441-6796.
Sincerely, b
oward Pulley General Manager Paducah Gaseous Diffusion Plant
Enclosures:
As Stated cc:
NRC Region III Office NRC Resident Inspector - PGDP P.O. Box 1410, Paducah, KY 42001 Telephone 502-441-5803 Fax 502-441-5801 http://www.usec.com y4g Omces in Livermore, CA Paducah, KY Portsmouth, OH Washington, DC
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GDP 98-1067 Page 1 of 4 UNITED STATES ENRICHMENT CORPORATION (USEC) l REPLY TO NOTICE OF VIOLATION (NOV) 70-7001/98011-02 Restatement of Violation l
L Title 10 of the Code of Federal Regulations, Part 76.93, " Quality Assurance," requires, in part, that the Corporation shall establish, implement, and maintain a Quality Assurance Program.
_ Section 2.3, of the Quality Assurance Program,." Design Control," required, in 1, art, that design i
requirements shall be correctly translated into design output and procedural documents of adequate quality to support facility installation and operation.
L Contrary to the above, as of June 27,1998, the Corporation failed to identify, review, and l
translate design requirements, associated with installation of the Building C-710 criticality accident alarm system, into design output and procedural documents. Specifically, design inputs associated with operational mode installation limitations, quality classification of installation activities, and other work controls were not identified, properly reviewed, or translated into design output documents such as the design installation and verification specification, work package directions, and modification drawings.
USEC Response I.
Reasons for the Violation The root cause of the violation was inadequate guidance in Engineering Standard, ES-0.9-l 1, " Design histallation and Verification Specifications." The standard, which provides the designer guidance on development of fabrication, installation and testing requirements, did not specify a requirement to identify critical work activities. As a result, the designer did not identify that landing a wire from the new equipment to an existing equipment terminal, would be an interface with a safety related circuit, which could impact the l
operability of the existing criticality accident alarm system.
i Contributing factors to this violation were:
l An undetected transcription error was introduced when an existing drawing was I
redrawn and modified in one step on a computer-assisted drafting (CAD) system.
I The new drawing incorrectly relabeled some existing circuits that connected with the safety-related Criticality Accident Alarm System (CAAS) with an alphanumeric identifier that was not indicative of the source of the circuit. This
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GDP 981067 Page 2 of 4 masked the fact that a safety related interface existed. As a consequence, it was no longer apparent to the drawing reviewers that the safety related interfaces existed.
The transcription error resulted from a designer failing to follow procedure CP2-EG-EG1073, " Engineering Drawings," and failing to conduct an adequate review of the drawing after conversion to the CAD system. The new drawing incorrectly relabeled mme existing circuits that interconnect with the safety-related CAAS system and masked the fact that a safety related interface existed.
As a consequence, it was no longer apparent that the interfaces existed.
This transcription error resulted from the designer failing to follow the procedure requirement to have initial editions of CAD drawitigs correctly reflect the non-CAD drawing and be independently verified and approved prior to modifying the drawing. The designer was a contractor employee and was familiar with the requirements of procedure CP2-EG-EG1073. Subsequently, the technical review of the drawing did not detect the error.
II.
Corrective Actions Taken and Results Achieved i
1.
The modification work activity was suspended on June 23, 1998. The work package was modified, prior to resumption of work, to inchide establishing appropriate work boundaries; establishing appropriate limiting conditions for operation for affected facilities; assuring proper documentation oflifted and landed leads; and appropriate electrical checks to preclude applying grounds or shorts on the existing electrical system. The work activity was completed on June 27,1998, using the modified work package.
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A lessons-leamed presentation was given to the Design Engineering organization that outlined the event, and the failure of the design installation and verification specification to communicate the impact of the tie-ins. The presentation also included a discussion regarding the quality class of the work package.
3.
A review of modification instructions issued for installation by Engineering that could potentially impact quality-related systems was conducted. The review, completed on July 29,1998, determined that no active or pending installation packages had the potential for unexpected impact on safety-related equipment with the exception of three work packages for Engineering Service Order (ESO)
Z72020, " Process Inventory Control System for the New Freezer /Sublimers." 'Ihe affected packages will not be released by Engineering until follow-up reviews are complete. This project is inactive.
GDP 98-1067 Page 3 of 4 4
4.
Effective August 14,1998, an upgraded modification procedure, CP2-EG-EG1046,
" Nuclear Modification Design Development and Implementation Process,"
i Revision 0, was issued, which included specific treatment of design installation and verification specifications, and responsibilities for modification team reviews.
This procedure formalized the site specific requirements for the development, review, and use of the design installation and verification specification (DIVS) 4 design product and its associated Engineering Standards. Crew briefings were provided to appropriate personnel.
The issuance of CP2-EG-EG1046, in conjunction with items III.1 and 2 below, addreens the root cause by formally documenting the responsibilities and expectations associated with the modification team reviews and design development oversight requirements.
5.
Reviews of planned work packages that consisted of non-repetitive tasks were i
completed August 18,1998. Those repetitive task packages that had already been performed successfdy, were not reviewed. No problems were identified. This review was intended to identify work package concems for modifications currently j
i issued for construction.
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Corrective Steps to be taken III.
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To correct the root cause, Engineering Standard ES-0.9-1 will be revised by October 26,1998, to address the following items:
The standard will require identification of sensitive steps where modification work activities may impact safety systems.
The standard will require identification of the necessary operating state or condition of systems which may be impacted by the modification installation work activities.
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A formal Engineering Standard will be developed to expand the details of, and clearly define, the expectations required of the modification team reviews of design output documents. The new Engineering Standard will be approved and issued by October 26,1998.
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GDP 981067 Page 4 of 4 3.
An Engineering Standard will be developed to better define the expectations for oversight of contractor engineering personnel. The new Engineering Standard will be approved and issued by October 26,1998.
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Date of Full Compliance Full compliance was achieved on June 27,1998, when the maintenance work package was revised and the work activity completed.
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l t-GDP 98-1067 Page 1 of I List of Commitments
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- The concerns that NRC addressed in IR 98011 regarding the oversight of activities that have the potential to impact plant operations will be evaluated and addressed as part of the supplemental response to IR 98009-02.
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Engineering Standard ES-0.9-1.will be revised by October 26, 1998, to address the
' following items:
l The standard will require identification of sensitive steps where modification work' L
activities may impact safety systems.
l The. standard will require identification of the operating state of systems impacted by the modification work activities during installation of the modification.
1 3.
A formal Engineering Standard will be developed to expand the details of, and clearly define, the expectations required of the modification team reviews of design output documents. The new Engineering Standard will be approved and issued by October 26, 1998.
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- Regulatory commitments contained in this document are listed here. Other corrective actions listed in this submittal are not considered regulatory commitments in that they are either statements of actions completed, or they are considered enhancements to USEC's investigation, l
procedures, programs, or operations.
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