ML20154C741
| ML20154C741 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 10/01/1998 |
| From: | Reidinger T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | John Miller UNITED STATES ENRICHMENT CORP. (USEC) |
| References | |
| 70-7002-98-11, NUDOCS 9810070012 | |
| Download: ML20154C741 (2) | |
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5' October 1, 1998 Mr. J. H. Miller
~ Vice President-Production United States Enrichment Corporation zTwo Democracy Center
~ 6903 Rockledge Drive Bethesda, MD 20817 f
SUBJECT:
RESPONSE TO INSPECTION REPORT 70-7002/98011 Dear Mr. Miller.
- This refers to your August 31 and September 23,1998, responses to the Notice of Violation (NOV) transmitted to you by our letter dated July 30,1998, with Inspection Report 70-7002/98011. We have reviewed your corrective actions for the violations and have no further questions at this time. Your corrective actions will be examined during future inspections.
If you have any questions, please contact me at (630) 829-9816.
i Sincerely, Original Signed by J.
Kniceley for 9810070012 981001 PDR ADOCK 07007002 Timothy D. Reidinger, Acting Chief C
PDR Fuel Cycle Branch Docket No. 70-7002 Certificate No. GDP-2 cc:.
J. M. Brown, Portsmouth General Manager D. B. Waters, Acting Manager, Portsmouth Regulatory Affairs f
H. Pulley, Paducah General Manager S. A. Toelle, Manager, Nuclear Regulatory Assurance and Policy, USEC h
v' o Portsmouth Resident inspector Office f
Paducah Resident inspector Office 7
R. M. DeVault, Regulatory Oversight Manager, DOE E. W. Gillespie, Portsmouth Site Manager, DOE DOCUMENT NAME: G:\\SEC\\POR98011.RES Te r+ceive a copy of this document, indicate in the box:"C" = Copy without enclosure "E" = Copy with enclosure *N"= No copy OFFICE Rlli l0 Rill l
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DATE-10/8/98 10/l/98 f,fC UL OFFICIAL RECORD COPY
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~ J. Miller bec w/itrs dtd 08/31/98 & 9/23/98:
Docket File PUBLIC IE-07 R. Pierson, NMSS P. Ting, NMSS W. Troskoski, NMSS P. Harich, NMSS Y. H. Faraz, NMSS R. Bellamy, RI EJM, Ril (e-mail)
D. B. Spitzberg, RIV/WCFO Greens w/o encis
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3 CSEC A Global Energy Company September 23,1998 GDP-98-2041 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Portsmouth Gaseous Diffusion Plan,t (PORTS)
Docket No. 70-7002 Revised Reply to Notice of Violation (NOV) 70-7002/98011-03 On August 31,1998, USEC submitted a reply to the subject NOV which concerned a failure to take corrective actions to prevent spurious safety system actuations (see USEC letter GDP 98-2040).
USEC is submitting this revised response to NOV 98011-03 to provide additional clarification regarding this violation. Changes to the original NOV reply are indicated by margin bars on the right-hand side of the document.
USEC requests NRC replace Enclosure 1 of our previous
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submittal with the enclosed revised NOV response. Also, replace the commitments made for NOV
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98011-03 in Enclosure 4 of our previous submittal with the commitments listed on Enclosure 2 attached. Unless specifically noted, the corrective actions specified in each enclosure apply solely to PORTS.
If you have any questions regarding this submittal, please contact Dave Waters at (740) 897-2710.
Sincerely,
. Morris Brown General Manager Portsmouth Gaseous Diffusion Plant
Enclosures:
As Stated cc:
NRC Region III Office.
NRC Resident Inspector-PORTS NRC Director, Office of Enforcement f30o) M '
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.Y Do P.O. Box 800, Portsmouth, OH 45661 Telephone 740-897-2255 Fax 740-897-2644 http://www.usec.com Offices in Livermore, CA Paducah. KY Portsmouth, OH Washington, DC SEP 2 8 RB
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Page1of4 UNITED STATES ENRICIISIENT CORPORATION (USEC)
SUPPLEMENTAL REPLY TO NOTICE OF VIOLATION (NOV) 70-?^02/98011-03 Restatement of Violation 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-t-1989. " Quality Assurance Program Requirements for Nuclear Facilities."
ASME NQA-1-1989, Basic Requirement 16," Corrective Action," states that conditions adverse to quality (CAQs) shall be identified promptly and corrected as soon as possible.
C8 ofAppendix A of XP4-BM-CIl002," Problem Report Screening Process," lists inadequate work instructions as a specific example of a CAQ.
Contrary to the above, the certificatee did not take action to prevent the spurious containment isolation of Autoclave No. 3 in the X-344 Building on June 30,1998. The certificatee's intended corrective action to prevent recurrence of an August 1997 event, to add a precaution to the work
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package to isolate Autoclave No. 4 during a maintenance activity, was not implemented.
USEC Response I.
Background
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The August 1997 event occurred while electricians were making repairs to Autoclave No.
- 3. In the course of the repair, the electricians opened the breakers inside of the EPTAK control cabinet. When the breaker for the EPTAK Input / Output (I/0) boards was opened, the EPTAK controller shutdown and placed Autoclave No. 4 in containment. A Problem Report (PR PTS-97-7051) was written to document this event. As a corrective action to this event, Operations personnel issued a memorandum which stated, in part, that "when developing work packages that consist of troubleshooting or repairs to the control panels or EPTAK I/O boards, an instruction should be included in the work package to turn the controller off-line on the autoclave being repaired." This guidance is included in the procedure for replacing the EPTAK I/O modules for Autoclave No. 3 and 4 in the X-344 Building.
The June 30,1998, event occurred due to a spurious closure of the autoclave containment valves leading to a high condensate level alarm. It was initially thought that the containment isolation was due to a short or open circuit which resulted from electrical maintenance
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troubleshooting activities on Autoclave No. 4. Electricians were searching for the cause of v
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j GDP 98-2041 i(/
Page 2 of 4 fuses blowing in the Autoclaye No. 4 hydraulic control panel. While lifting and landing control level wires for short/ ground determinations, Autoclave No. 3 went into containment isolation. The troubleshooting activity was later repeated in an attempt to validate our initial speculation. However, we could not reproduce the containment isolation of Autoclave No.
3.
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USEC has determined that the corrective action from the August 1997 event was not needed for the troubleshooting that was being performed when the June 30,1998, event occurred.
The individuals involved in planning and reviewing this activity were aware of the Operations memorandum when developing the troubleshooting work package and l
appropriately concluded that this precaution did not apply to this activity. This determination was based on the knowledge that troubleshooting of the autoclave hydraulic control panels cannot cause a loss of power to the autoclave control panels or EPTAK I/O boards.
Furthermore, Autoclave No. 4 was in a shutdown condition when the troubleshooting of the hydraulic control circuits was performed.
II.
Reason for the Violation
[S USEC has detemiined that the root cause of the autoclave containment isolations that have l
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been experienced since June 30,1998, was the malfunctioning of the EPTAK CPU module l
and subsequent failure of the replacement CPU module. PORTS has experienced spurious l
EPTAK CPU halts and subsequent autoclave containment isolations between mid-August l
and early September 1998. These events occurred both while the autoclaves were in l
operation and while shutdown. While these isolations are undesirable from an operational l
standpoint, they do not place the plant in an unsafe condition since the isolation causes the l
autoclave to be placed in containment.
l A contributing cause of the autoclave contaimnent isolations was the failure to develop a l
routine preventative maintenance (PM) task for the EPTAK system. The failure to perform l
a routine PM task on the EPTAK system may have resulted in spurious electronic transients l
caused by corrosion, dirt, vibration, and thermal cycling. Additionally, this system is within l
a "Q" boundary as described in Section 3.8.1.4 of the SAR. USEC has reviewed the closure l
package for Compliance Plan issue 24 and determined that the action to develop a PM for l
the EPTAK system was closed based on the existence of surveillance procedures which test l
the. safety system function of the EPTAK system. This methodology uses equipment l
condition monitoring to determine when maintenance should be performed. However, these l
surveillance procedures do not provide for a routine PM task to be performed on the EPTAK l
system.
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Page 3 of 4 III.
Corrective Actions Taken and llesults Achieved 1.
Electronic Maintenance replaced EPTAK components as specified by the vendor's manual. Post maintenance testing of Autoclave No. 3 was successfully performed on August 20,1998, and the autoclave was declared operable. The autoclave then successfully completed a product transfer operation with no EPTAK CPU halts.
2.
Post maintenance testing of Autoclave No. 4 was successfully performed on August 22,1998, and the autoclave was declared operable. Subsequently, the autoclave successfully completed a product transfer operation with no EPTAK CPU halts.
3.
Power line filtering equipment was installed on the incoming line for the EPTAK system on August 26,1998, in order to prevent electrical transients from causing EPTAK CPU halts.
4.
On August 31, 1998, another EPTAK CPU halt was experienced and another l
extensive troubleshooting effort began. Vendor manual recommendations for l
proceeding with the troubleshooting process were followed. This process suspected l
CN the EPTAK CPU module as the source of the malfunction. The CPU module was l
j replaced on September 10,1998, and the EPTAK began to operate normally. No l
malfunctions have been encountered during the subsequent six day testing period.
l A statistical analysis of the failure intervals experienced show a 99.5% probability l
of not experiencing another failure beyond the six days of continued EPTAK l
operation.
l 5.
Also, the EPTAK grounding system was modified in accordance with the original l
manufacturer's installation manual on September 16, 1998. This action should l
eliminate any potential concern for degraded grounding due to the age of the system j
and minimize the effects of electrical transients on system operation.
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USEC is currently performing a review of the adequacy of the closure of Compliance Plan issues at PORTS.
IV.
Corrective Actions to be Taken l
1.
A PM program for the EPTAK system and the other autoclave programmable logic l
controllers (PLCs) will be established and implemented for operable autoclaves by l
l November 20,1998.
2.
Engineering will review other plant safety system equipment programmable logic p) controllers for adequacy of their PM program by December 15,1998. Subsequently, l
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l GDP 98-2041 Page 4 of 4 any PM program revisions deemed necessary will be established and implemented l
by March 5,1999.
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By February 15.1999 Engineering will review the PMs developed for Q system l
components that specify surveillance procedures as the PM task to ensure other l
routine PM tasks are not needed. Subsequently, any PM program revisions deemed l
necessary will be established and implemented by August 20,1999.
l V.
Date of Full Compliance l
l Full compliance was achieved on September 16.1998, ss hen the EPTAK CPU module was l
replaced and exhibited satisfactory operation.
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Page1ofI List of Commitments' NOV 70-7002/980I l-03 1.
A-PM program.for' the EPTAK system and the other autoclave programmable logic controllers (PLCs) will be. established and implemented for operable autoclaves by l
. November 20,1998.
l 2.
Engineering will review other plant safety system equipment programmable logic controllers.
for adequacy of their PM program by December 15,1998. Subsequently, any PM program l
revisions deemed necessary will be established and implemented by March 5,1999.
l 3.
By February 15,1999, Engineering will review the PMs developed for Q system components l
that specify surveillance procedures as the PM task to ensure other routine PM tasks are not l
. needed. Subsequently, any PM program revisions deemed necessary will be established and l
implemented by August 20,1999.
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' Regulatory commitments contained in this document are listed here. Other corrective i
actions listed in this submittal are not considered regulatory commitments in that they are either
' _O statements of actions' completed, or they are considered enhancements to USEC's investigation, V
procedures, programs, or operations.
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e kCSEC A Global Energy Company August 31,1998 GDP-98-2040 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Portsmouth Gaseous Diffusion Plant (PORTS)
Docket No. 70-7002 Response to Inspection Report (IR) 70-7002/98011 Notice of Violation (NOV)
The subject Inspection Report (IR) contained three violations involving: 1) a failure to take corrective actions to prevent spurious safety system actuations,2) violation of the design basis related to building evacuation horn usage instead of the criticality accident alarm system horns,,and rx
- 3) failure to make a required one hour notification. USEC's response to these violations is provided I
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in Enclosures 1 through 3, respectively. Enclosure 4 lists the commitments made in this report.
'd Unless specifically noted, the corrective actions specilled in each enclosure apply solely to PORTS.
If you have any questions regarding this submittal, please contact Dave Waters at (740) 897-2710.
i Sincerely, l
N rr B n
General Manager pgl[
Portsmouth Gaseous Diffusion Plant
Enclosures:
As Stated cc:
NRC Region 111 Office NRC Resident Inspector - PORTS
-9809040312-980831~
Dd N PDR ADOCK 07007002 i
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PO. am soo. Ponsnmuth. OH 45661 Telephone 40-89'-2255 I n 40-89'-264a http://www.usec.com Otlices in livermort. CA Paducah KY Portsmouth. OH Tashington. DC
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GDP 98-2040 Page1of3 UNITED STATES ENRICIIMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/98011-03 Restatement of ViolatiQn 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 ofMechanical Engineers (ASME) NQA-1-1989," Quality Assurance Program Requirements for Nuclear Facilities."
ASME NQA-1-1989, Basic Requirement 16 " Corrective Action," states that ccnditions adverse to quality (CAQs) shall be identified promptly and corrected as soon as possible.
C8 of Appendix A of XP4-BM-CIl002," Problem Report Screening Process," lists M6quate work instructions as a specific example of a CAQ.
Contrary to the above, the certificatee did not take action to prevent the spancus containment isolation of Autoclave No. 3 in the X-344 Building on June 30,1998. The certificatee's intended corrective action to prevent recurrence of an August 1997 event, to add a precaution to the work
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package to isolate Autoclave No. 4 during a maintenance activity, was not implemented.
USEC Response I.
Reason for the Violation Based on information obtained following the exit meeting for the above violation and the subsequent issuance of the IR, USEC has determined that the isolation of Autoclave No. 3 in the X-344 Building that occurred on June 30,1998, did not result from a failure to implement corrective actions from an event that occurred in August 1997. Furthermore, USEC has determined that the even if the work package for this troubleshooting activity had contained the precaution from the August 1997 corrective action, the isolation of Autoclave No. 3 would still have occurred. Rather the isolation of Autoclave No. 3 occurred primarily due to a failure to establish a Preventise Maintenance (PM) program for the programmable logic controller (EPTAK) for these autoclaves. In addition, electrical transients continue to be experienced on the incoming electrical power source to the EPTAK. This also has caused containment isolation of the autoclaves. This is described in furthei detail below.
The August 1997 event occurred while electricians were making repairs to Autoclave No.
- 3. In the course of the repair, the electricians reset the breakers inside of the EPTAK control p
cabinet. When the breaker for the EPTAK input / Output (1/0) boards was reset, the EPTAK controller shutdown and placed Autoclave No. 4 in containment. A Problem Report (PR
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GDP 98-2040 Page 2 of 3 PTS-97-7051) was written to document this event. As a corrective action to this event.
Operations personnel issued a memorandum which stated, in part, that "when developing work packages that consist of troubleshooting or repairs to the control panels or EPTAK 1/O boards, an instruction'should be included in the work package to turn the controller off-line on the autoclave being repaired." This guidance has been included in the procedure for replacing the EPTAK I/O modules for Autoclave No. 3 and 4 in.the X-344 Building.
The June 30,1998, event occurred due to a spurious closure of the autoclave containment valves leading to a high condensate level alann. Initial speculation was that the containment isolation was due to a short or open circuit which resulted from electrical maintenance troubleshooting activities on Autoclave No. 4. Electricians were searching for the cause of fuses blowing in the Autoclave No. 4 hydraulic control panel. While lifting and landing control level wires for short/ ground determinations, Autoclave No. 3 went into containment isolation. The troubleshooting activity was later repeated in an attempt to validate our initial speculation. No containment isolation of Autoclave No. 3 occurred.
USEC has determined that the corrective action from the August 1997 event was not required for the troubleshooting work package that was being performed at the time the June 30, h
1998, event occurred. The individuals involved in planning and reviewing this activity were j
aware of the Operations memorandum when developing the troubleshooting work package and appropriately concluded that t'is precaution did not apply to this activity. This determination was based on the knowledge that troubleshooting of the autoclave hydraulic control panels cannot cause a loss of power to the autoclave control panels or EPTAK 1/0 boards.
Furthermore, Autoclave No. 4 was in a shutdown condition when the troubleshooting activity was performed en its hydraulic control circuits.
USEC has determined that the principal root cause of the autoclave containment isolation that occurred on June 30,1998. was the failure to conduct routine PM for the EPTAK system. The failure to perform routine PM on the EPTAK system resulted in spurious electronic transients caused by corrosion, dirt, vibration, and thermal cycling. This system performs a "Q" function as described in Section 3.8.1.4 of the SAR. Therefore, a PM procedure should have been developed pursuant to Compliance Plan issue 24. USEC has reviewed the closure package for this Compliance Plan issue and determined that the action to develop a PM procedure for the EPTAK system was closed based on the existence of surveillance procedures which test the safety system function of the EPTAK system.
However, these surveillance procedures do not provide for a routine PM of the EPTAK system. USEC is continuing to investigate the causes of the electrical transients being experienced on the incoming power source to the EPTAK Voltage surges and impulses that have been monitored are also causing EPTAK CPU halts and subsequent autoclave containment isolations.
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GDP 98-2040 m.J Page 3 of 3 II.
Corrective Actions Taken 1.
Electronic Maintenance replaced EPTAK components as specified by the vendor's manual. Post maintenance testing of Autoclave No. 3 was successfully performed on August 20,1998, and the autoclave was declared operable. The autoclave then successfully completed a product transfer operation with no EPTAK CPU halts.
2.
Post maintenance testing of Autochve No. 4 was successfully performed on August 22,1998, and the autoclave was declared operable. Subsequently, the autoclave successfully completed a product transfer operation with no EPTAK CPU halts.
3.
Power line filtering equipment was installed on the incoming line for the EPTAK system, On August 26,1998, in order to prevent electrical transients from causing EPTAK CPU halts.
4.
USEC is currently performing a review of the adequacy of the closure of Compliance Plan issues at PORTS.
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III.
Corrective Actions to be Taken
' t.J 1.
A PM program for the EPTAK system and the other autoclave programmable logic controllers (PLCs) will be established and implemented by November 20,1998.
2.
Engineering will review other plant safety system equipment programmable logic controllers for adequacy of their preventative maintenance program by December 15, 1998.
3.
By February 15,1999 PORTS will review the closure package for Compliance Plan issue 24 to verify PMs for other Q system components have been adequately identified.
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- UNITED STATES ENRICIIMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/98011-04 l
Restatemem of Violatiqn Technical Safety Requirement 3.9.1 requires that written procedures shall be prepared, reviewed, approved, implemented, and maintained to cover activities described in the Safety Analysis Report p
(SAR), Section 6.11.4.1, and listed in Appendix A to SAR 6.11.
Appendix A to SAR Section 6.11 requires that " communications" shall be covered by written procedures.
Paragraph 3.3 of procedure XP2-US-FOl 105, " COP-6 Policies a-d Instructions," states, in part, that l-daily operating instructions (Dols) will not instruct anyone to replace guidance in approved procedures.
Contrary to the above, DOI 300-98-111 dated June 15, 1998, replaced guidance in approved Procedure XP2-CO-CA2030," Operation of Criticality Accident Alarm System (CAAS)," to allow
,O building evacuation horns to be used to maintain operability of the CAAS in affected facilities if local CAAS nitrogen horns were inoperable.
USEC Response I.
Reasons for Violation The reason for the violation was an inadequate procedural guidance to ensure compensatory actions / instructions are not initiated prior to being reviewed such that approved procedural actions are not circumvented. Contributing to this violation was an inadequate understanding of the TSR related to CAAS operations. Due to this lack of understanding, personnel i
believed that the compensatory action could be implemented via the DOI procedure, to improve operational flexibility while maintaining compliance with the TSRs. In hindsight, a PCR (i.e.,10 CFR 76.68 review) should have been performed prior to issuance of the compensatory action; however, there is currently no proceduralized guidance for development, implementation, and control of compensatory actions.
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' Corrective Actions Taken and Results Achieved 1.
On June 19, 1998, the compensatory action which lead to this violation was rescinded which re-established the 200' TSR requirement around buildings when CAAS horns were out of service. This action suspended the previous practice which allowed the plant to take credit for the building evacuation horns should CAAS nitrogen homs be inoperable.
2.
In addition, other compensatory actions contained in DOI 300-98-11 I were reviewed to determine if other actions caused a change to approved proceduralized guidulce or resulted in a change to plant operations as described in the SAR or TSR. None were identified.
3.
This event was reviewed with the PSS Organization Manager, who is responsible for issuing compensatory actions listed in Dols to heighten his awareness that compensatory actions need to be evaluated to ensure that the action does not change proceduralized guidance or result in a change to plant operations as described in the SAR or TSR.
k III.
Corrective Steps to be Taken 1.
A lessons learned bulletin will be issued as required reading to the organizations responsible for preparing and issuing Dols and to qualified PCR evaluators to communicate specific issues which caused this violation. This action will be completed by September 30,1998.
2.
Lessons learned from this issue will be incorporated into the PCR training module to ensure future PCR evaluators learn from the weaknesses which lead to this citation. This action will be completed by September 30,1998.
3.
A procedure will be developed or revised to better define the process for controlling and reviewing compensatory actions / instructions contained in Dols to ensure that:
a) Dols are not used to change, supersede, or take the place of procedures when a procedure is required, and b) Dols which involve changes to the plant or plant operations are reviewed in accordance with the plant 10 CFR 76.68 PCR process.
This action will be completed by November 30,1998.
IV.
Date of Full Compliance USEC achieved full compliance on June 19.1998, when DOI 300-98-111 was rescinded.
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GDP 98-2040 v
Page1of2 UNITED STATES ENRICIIMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/98011-05 Restatement of Violation l
1 Technical Safety Requirement 3.9.1 requires that written procedures be implemented to cover activities described in SAR Section 6.11.4.1, and listed in Appendix A to SAR Section 6.11.
Appendix A to SAR Section 6.11 states that " investigations and reporting" shall be covered by written procedure.
Paragraph 6.2.1.E of Procedure UE2-RA-RE1030, " Nuclear Regulatory Event Reporting,"
requires that the certificatee verbally notify the appropriate NRC office of reportable events within the time requirements shown in Appendix A of the procedure.
Paragraph L.4 of Appendix A to Procedure UE2-RA-RE1030, requires that any possible compromise of classified information or classified documents be reported verbally to NRC immediately (within I hour).
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Contrary to the above, on July 9,1998, the certificatee did not verbally notify the NRC i
within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of discovering classified documents in an unapproved storage container, a possible compromise of classified information.
USEC Response 1.
Reason for Violation The reason for the violation was failure to follow the Problem Reporting (PR) procedure which requires personnel to piomptly initiate a problem report when a problem is discovered.
Specifically, the acting NRA manager did not promptly initiate a PR when the material marked as classified was discovered that was not properly secured. Since the PSS determines reportability via the PR process, if the PSS does not have a PR or is unaware of the issue, the PSS can not make the necessary reports in a timely manner.
The documents were discovered by the acting NRA Manager after normal working hours on July 9,1998, and promptly secured in an approved classified repository. The acting NRA j.
Manager believed that no further actions needed to be taken until security verification of the classification status was completed. However, since the documents were clearly labeled as l
containing classified information, the acting NRA Manager should have immediately p
generated a PR to notify the PSS.
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i GDP 98-2040 Page 2 of 2 Subsequently, at approximately 0900 on July 10,1998, Security Management confirmed that the documents were classified and the acting NRA Manager was notified of this determination. Ilowever, this individual again failed to take prompt action to ensure that the PSS was notified and that a PR was written. The acting NRA Manager believed that because Security and another NRA member were aware of the incident, they would notify the PSS, so that notification could be made within the one hour reporting requirement. The acting NRA Manager thought that notification could occur prior to the preparation of a PR.
At approximately 1110 hours0.0128 days <br />0.308 hours <br />0.00184 weeks <br />4.22355e-4 months <br />, the acting NRA Manager realized the one hour notification to NRC had been missed and prepared and submitted the PR on the discovery of classified material to the PSS. Subsequently the PSS determined that the event was reportable and NRC notification was made at approximately 1151 on July 10,1998.
II.
Corrective Actions Taken and Results Achieved I,
Once the PSS received the problem report PR-PTS-98-05243 at approximately 1110 on July 10,1998, notification to NRC was made at 1151.
2.
The acting NRA Manager was counseled regarding this event. Additionally, procedure XP2-BM-CI1030 " Problem Reporting" was reviewed with NRA personnel to reinforce the requirement to promptly initiate problem reports when a problem is discovered.
III.
Corrective Steps to be Taken A lessons learned will be issued to Organization Managers, by September 15, 1998, explaining what occurred, and what types of problems require immediate notification of the PSS so that timely notification to NRC can be made.
V.
IV.
Date of Full Compliance i
i Full compliance was achieved on July 10,1998, when the PSS made notification to the NRC.
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v GDP 98-2040 Page1ofI List of Commitments' NOV 70-7002/98011-03 1.
A PM program for the EPTAK system and the other autoclave programmable logic controllers (PLCs) will be established and implemented by November 20,1998.
2.
Engineering will review other plant safety system equipment programmable logic controllers for adequacy of their preventative maintenance program by December 15,1998.
3.
By February 15,1999 PORTS will review the closure package for Compliance Plan issue 24 to verify PMs for other Q system components have been adequately identified.
NOV 70-7002/98011-04 1.
A lessons learned bulletin will be issued as required reading to the organizations responsible for preparing and issuing Dols and to qualified PCR evaluators to communicate specific issues which caused this violation. This action will be completed by September 30,1998.
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This action is intended to be an enhancement and not a regulatory commitment.
3.
A procedure will be developed or revised to better define the process for controlling and reviewing compensatory actions / instructions contained in Dols to ensure that: a) DOIs are not used to change, supersede, or take the place of procedures when a procedure is required, and b) Dols which involve changes to the plant or plant operations are reviewed in accordance with the plant 10 CFR 76.68 PCR process. This action will be completed by November 30,1998.
NOV 70-7002/98011-05 A lessons learned will be issued to Organization Managers. by September 15, 1998, explaining what occurred, and what types of problems require immediate notification of the PSS so that timely notification to NRC can be made.
' 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
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statements of actions completed, or they are considered enhancements to USEC's investigation.
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procedures, programs, or operations.