ML20155C312
| ML20155C312 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 10/26/1998 |
| From: | Jonathan Brown UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-7002-98-13, GDP-98-2045, NUDOCS 9811020188 | |
| Download: ML20155C312 (5) | |
Text
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o USEC A Global Energy company October 26,1998 GDP 98-2045 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Portsmouth Gaseous Diffusion Plant (PORTS)
Docket No. 70-7002 Reply to Inspection Report (IR) 70-7002/98013 Notice of Violation (NOV) 98013-01 The subject inspection Report contained a violation involving continued operation without Plant Operations Review Committee (PORC) review of Nuclear Criticality Safety Approvals (NCSAs).
USEC's response to this violation is provided in Enclosure 1. Enclosure 2 lists the commitments made in this report. Unless specifically noted, the corrective actions specified in each enclosure apply solely to PORTS.
If you have any questions regarding this submittal, please contact Pete Miner at (740) 897-2710.
Sincerely, b
. Morris Brown
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General Manager
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Portsmouth Gaseous Diffusion Plant i
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Enclosures:
As Stated cc:
NRC Region Ill Office NRC Resident inspector - PORTS 9811020100 991026 PDR ADOCK 07007002 C
PDR P.O Box 800, Iortsmouth, OH 45661 Telephone 740-897-2255 Fax 740 897-2644 http://www.usec.com OfRces in Livermore, CA Paducah, KY Portsmouth. OH Washington, DC
i GDP 98-2045 Page1of3 UNITED STATES ENRICllMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/98013-01 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-1-1989," 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.
Item S2 of Appendix A of XP4-BM-CI1002," Problem Report Screening Process," lists a Technical Safety Requirement (TSR) violation as a specific example of a significant CAQ.
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Contrary to the above, on August 25,1998, the certificatee did not take prompt action to correct a significant CAQ. Specifically, the certificatee identified that 14 Nuclear Criticality Safety Approvals had not received Plant Operations Review Committee approval as required by TSR 3.10.5.f, but continued affected operations until NRC involvement the following day.
USEC Response
Background
The NRC Inspection Report (IR) discusses events which occurred on August 26,1998. During
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USEC's investigation of this event, clarification of details in the NRC IR was obtained and is presented below. This information does not affect the context of the cited violation.
The NRC IR discusses six of the fourteen NCSAs and states:"After further discussion and review, the certificatee initiated six additional stop work notices." Actually, only five additional stop work notices were issued on August 26,1998. Operations being performed under NCSA PLANT 001,
" Storing Small Diameter Containers in Plastic Bags," was allowed to continue until this NCS A was PORC approved on August 26,1998.
Also, the NRC IR discusses the remaining eight of the fourteen NCSAs and states: "The other eight NCSAs involved operations no longer performed, and the NCSAs were canceled." These eight NCSAs were actually dispositioned as follows:
Three of the NCSAs involve operations no longer performed, and these NCSAs are scheduled to be deleted. Administrative controls were put in place on August 26-27,
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1998, to ensure these operations could not be resumed.
Two operations were stopped on August 26,1998, and their NCSAs were PORC approved on August 27,1998, to allow the operations to be resumed.
One operation was stopped on August 26,1998, and it was subsequently determined the operation was adequately covered by an existing PORC approved NCSA. The non-approved NCSA is scheduled to be deleted.
One operation which was previously shut down on August 19,1998, will have its NCSA revised and PORC approved before allowing operations to resume.
Therefore, compliance with TSR 3.10.5.f for this NCSA was met on August 19, 1998. However, prior to August 19,1998, compliance with the TSR was not met.
One operation which was stopped on August 26,1998, will have its NCSA replaced by another NCSA currently being revised and the revised NCSA will be PORC approved before allowing operations to resume.
1 I.
Reast n for the Violation The rcot cause for the violation is the process that wa.s used to evaluate this issue only l
addrested safe plant operations and did not address compliance with TSR 3.10.5.f. The management group which assembled to evaluate this issue did recognize that the NCSAs did not comply with the TSR. However, there are no action statements in the administrative l
control TSRs nor was other plant guidance available to provide a time frame in which PORC approval of the NCSAs should be obtained. As a result, the group focused solely on maintaining safe plant operations and did not address the need to immediately restore compliance with the administrative control TSR or obtain NRC concurrence for continued operation in the non compliant condition. It was determined that this issue is restricted to the administrative control TSRs. The root cause resulted in the failure to take the appropriate prompt actions to restore compliance with the TSR commensurate with maintaining plant j
safety._
II.
Corrective Actions Taken 1.
On August 26,1998, stop work notices were issued for operations affected by five of the fourteen NCSAs to prevent performing activities associated with these NCSAs.
i 2.
On August 26,1998, NCSA PLANT 001 was PORC approved as required by the TSR.
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linclosure 1 GDP 98-2045 Page 3 of 3 3.
On August 26,1998, administrative controls (such as lock-out/ tag-out, hanging signs, or attaching warning tags) were in place fbr operations affected by seven NCSAs to prevent perfbrming activities associated with these NCSAs. [ Note: One of these operations was previously shutdown on August 19,1998, by a lock-out/ tag-out and two of these operations are the operations that are no longer performed.]
4.
On August 27,1998, a lock-out/ tag-out was in place for operations alTected by the last of the fourteen NCSAs. [ Note: This operation is one of the operations that is no longer performed.]
5.
A memorandum was issued to the Plant Shill Superintendents (PSS) to increase their awareness and sensitivity to administrative TSR non-compliances on September 16, 1998.
6.
As of October 2,1998, six of these NCSAs have been PORC approved, thus allowing their operations to resume.
7.
On October 22,1998, guidance on actions to take when an administrative TSR is not met was developed and issued to the PSSs and other senior management individuals as an interim action until a revision to the training program can be completed as described below.
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III.
Corrective Actions to be Taken l
1.
Guidance on what actions to take when an administrative TSR is not met will be incorporated into a training module and taught to those individuals identified as the target audience. These actions will be completed by April 1,1999.
i IV.
Date of Full Compliance Full compliance was achieved on August 27,1998, when all administrative controls were in place to prevent performing operations without PORC approved NCSAs.
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ODP 98-2045 Page1ofI List of Commitments' NOV 70-7002/98013-01 1.
Guidance on what actions to take when an administrative TSR is not met will be incorporated into a training module and taught to those individuals identified as the target audience. These actions will be completed by April 1,1999, i
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' Regulatory commitments contained in this document are listed here. Other corrective l-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, procedures, programs, or operations.
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