ML20154L353

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7001/98-09

ML20154L353
Person / Time
Site:	07007001
Issue date:	10/14/1998
From:	Reidinger T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	John Miller UNITED STATES ENRICHMENT CORP. (USEC)
References
70-7001-98-09, 70-7001-98-9, NUDOCS 9810190256
Download: ML20154L353 (2)

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, Octoberr14, 1998 o

Mr. J. H. Miller. '

i Vice President - Production United States Enrichment Corporation Two Democracy Center 6903 Rockledge Drive Bethesda, MD 20817

SUBJECT:

RESPONSE TO INSPECTION REPORT 70-7001/98009 Dear Mr. Miller-I This refers to your September 30,1998, supplemental response to the Notice of Violation (NOV) transmitted to you by our letter dated June 30,1998, with inspection Report 70-7001/98009. We have reviewed your corrective actions for the violation and have '

no further questions at this time. Your corrective actions will be examined during future -

inspections. ,

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~ If you have any questions, please contact me at (630) 829-9816. .j l

l Sincerely, Original Signed by  ;

Timothy D. Reidinger, Acting Chief l: Fuel Cycle Branch f Docket No. 70-7001 cc: . H. Pulley, Paducah General Manager L L. L. Jackson, Paducah Regulatory Affairs Manager l J. M. Brown, Portsmouth General Manager ,

1 S. A. Toelle, Manager, Nuclear Regulatory l Assurance and Policy, USEC -

- Paducah Resident inspector Office Portsmouth Resident inspector Office R. M. DeVault, Regulatory Oversight Manager, DOE J. C. Hodges, Paducah Site Manager, DOE DOCUMENT NAME: G:\SEC\ PAD 98009.RE2 Tm r+ceive e copy of this docuenent, Indicete in the boa:"C" = Copy without enclosure "E* = Copy with enclosure"N' = No copy i OFFICE Rill _

lC, Rlll ,l l l NAME Krsek:ib[f/ ReidingerW

i. DATE 10/14/98 % 10/l@98'

'0FFICIAL RECORD COPY 9810190256 981014 "

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J. Miller ' ,

bec w/itr dtd 09/30/98: Docket File PUBLIC IE-07 .

R. Pierson, NMSS P. Ting, NMSS W. Schwink, NMSS 1 P. Harich, NMSS M. L. Horn, NMSS R. Bellamy, RI EJM, Rll (e-mail)

D. B. Spitzberg, RIV/WFCO ,

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USEC A Global Energy Company 'j September 30,1998 GDP 98-1070 i

l U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Paducah Gaseous Diffusion Plant (PGDP)

Docket No. 70-7001 Revised Response to Notice of Violation (NOV) 70-7001/98009-02 I On July 30,1998, USEC responded to the subject NOV (see USEC letter GDP 98-1059) which concerned the " testing of the Switchyard C-537 fire sprinkler system for Transformer No. 72, an i

activity which affected quality, was conducted without documented instructions, procedures, or i drawings appropriate to the circumstances." USEC's response to this NOV committed to submit a l

- revised response to this NOV by September 30,1998. USEC conducted an evaluation of the root cause and developed additional actions to those in the previous response. These additional actions i

have been incorporated into a revised response. Accordingly, the revised response to NOV 98009-02 is provided in Enclosure 1. Changes to this NOV response are indicated by margin bars.

Additionally, as committed to in USEC's response to IR 98011 (See USEC letter GDP 98-1067 dated i

September 4,1998), Enclosure 1 also envelopes the concerns that NRC expressed in IR 98011 regarding the " oversight of activities that have the potential to impact plant operations." Enclosure i 2 lists the commitments contained in this submittal. Any questions regarding this matter should be directed to Larry Jackson at (502) 441-6796.

Sincerel av Pu ey GeneralManag r-Paducah Gaseous Diffusion Plant

Enclosures:

As Stated

[- cc:: ' NRC Region III. Office ; #

NRC Resident Inspector - PGDP

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P.O. Box 1410, Paducah, KY 42001 Telephone 502 441-5803 Fax 502-441-5801 http://www.usec.com O& ices in Uvermore, CA Paducah, KY Portsmouth. OH Washington, DC OCT 05. 3

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i Enclosure 1 GDP 98-1070 l

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l UNITED STATES ENRICHMENT CORPORATION (USEC)

REVISED REPLY TO NOTICE OF VIOLATION (NOV) 70-7001/98009-02 [ l Resta._lement of Violation 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 2.5 ofthe Quality Assurance Program, " Procedures," required, in part, that activities affecting  !

quality shall be prescribed by documented instructions, procedures, or drawings appropriate to the I circumstances, and shall be accomplished in accordance with these documents.

Contrary to the above, on May 14,1998, testing of the Switchyard C-537 fire sprinkler system for Transformer No. 72, an activity which affected quality, was conducted without documented instructions, procedures, or drawings appropriate to the circumstances. Specifically, the task test package did not include documented instructions or procedures, as appropriate, to ensure a minimum water flow rate, from the common water supply header to both the fire sprinkler and plant air systems, for continuous operation of the plant air compressors at a level suflicient to provide the minimum system air capacity required for operability of the criticality accident alarm system horns.

USEC Response L Background Dry compressed air is supplied from three buildings (C-600, C-620, and C-335) and an auxiliary air supply is located in Building C-607. Air compressor facilities may be operated separately or together to maintain air supply to the distribution headers. The minimum operability requirements for on-line air availability was 11,250 scfm.

Compressor trips have previously occurred during flow testing of the deluge systems in the switch yards. To mimmize the risk of a compressor trip, prior to this event, testing was initiated with the transformer deluge system's supply valve (S2) closed. This method had been used previously with no resultant compressor trips. To preclude a surge of water that could reduce the water pressure to the C-335 XLE compressors, the S2 valve was slowly opened. However, the full flow of water through the transformer deluge system resulted in a reduced flow of cooling water available to the Centac compressor in C-335 and caused the compressor to trip.

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Enclosure 1 GDP 98-1070 Page 2 of 3 II. Reason for the Violation The reason for this violation was that the evaluation conducted by power operations, utility operations, and fire services prior to the testing at C-537 was inadequate in that the impact of the ambient water temperature, the closed sanitary water header, and a partially closed

! compressor cooling water valve were not accurately assessed. i A review of the events that led to this NOV and those associated with NCV 98011-01 and l l NOV 98011-02 determhied that the process for control of work and infrequent operational l evoh:tions are not adequately defined. Specifically, USEC determined that improvements are l needed in the communication of system interrelationships so that appropriate compensatory l measures and written guidance can be implemented prior to initiating work. Due to incomplete l j communication ofinformation, planners failed to recognize the interfaces between operating l 1

safety systems and non-safety systems. Additionally, compensatory requirements were not l specified, and subsequent Operation's review and approval failed to identify the impact of the l work activities.

l III. Corrective Actions Taken and Results Achieved

1. All flow testing ofswitchyard fire suppression systems was suspended until corrective actions are taken to prevent recurrence.

2. Routine testing and maintenance of fire hydrant and suppression systems that place  !

flow demands on the sanitary and fire water system were stopped until the potential impacts on safety systems'can be addressed.

, 3. Current plant modifications being implementea and those modifications in the planning phase were reviewed to ensure that similar vulnerabilities did not exist for future work.

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4. As committed to in the original response to this NOV, USEC has evaluated the l process for controlling work to determine what actions are necessary to ensure that l  ;

i the impact ofwork directly and indirectly affecting safety related systems is accurately l assessed. Some of the actions taken as a result of this evaluation are listed below: l l

l A dedicated agenda item (Plant Status-Operations) for the Daily l l Communication & Teamwork (DC&T) meeting was initiated to ensure plant l wide work activities (planned or emergent) are communicated to impacted l organizations and any problems are resolved. Previously, all significant work l activities were not reported in the DC&T Meeting. l l

Enclosure 1 GDP 98-1070 Page 3 of 3 l

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Shift turnover status sheets were developed for Recirculating Cooling Water [

( RCW), Chemical Operations, Utilities, and Power Operations and added to l the existing sheets of Cascade Operations, Feed / Sampling Operations, and l Withdrawal Operations. These were added to the turnover to help ensure l equipment outages, planned activities, and planned maintenance items were j identified to all groups within Operations. l l

The Operations Manager briefed the Shift Front Line Managers on recent l issues associated with oversight and control of work activities. The briefmg l made the FLMs aware ofissues that have resulted in recent regulatory l problems and potential violations. l IV. Corrective Action to Be Taken Programmatic requirements to guide the review and approval of work control packages will be l implemented by May 17, 1999. The intent of this corrective action is to implement l programmatic requirements for Operations to review proposed maintenance activities to ensure l the operational impacts have been reviewed and addressed prior to implementation. The l development of these programmatic requirements are intended to: l l

Address how Work Packages identify the interfaces between safety-related and non- l safety-related systems impacted by the Work Package; l l

Address how Limiting Conditions of Operation (LCO) and Technical Safety l Requirements (TSR) are addressed and LCO actions implemented prior to l commencement of work activities as appropriate; and l l

• Address how infrequent or nonstandard operational activities are adequately I coordinated and controlled. l V. Date of Full Compliance USEC achieved full compliance with TSR 2.4.4.2 on May 14,1998, when the C-335 Centac compressor was restarted and the on-line plant air availability was restored to the minimum required for CAAS horn operable level.

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I Enclosure 2 GDP 98-1070

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l LIST OF COMMITMENTS NOV 98009-02 i

Programmatic requirements to guide the review and approval of work control packages will be [- f

. implemented by May 17,1999.

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