ML20195C312
| ML20195C312 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 05/28/1999 |
| From: | Jonathan Brown UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-7002-99-06, 70-7002-99-6, GDP-99-2025, NUDOCS 9906080068 | |
| Download: ML20195C312 (14) | |
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A Global Energy Company May 28,1999 GDP 99-2025 U. S. 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) 70-7002/99006 Notice of Violation (NOV)
The subject IR contained three violations involving 1) failure to follow procedures,2) failure to develop and implement an alarm response procedure, and 3) failure to implement effective corrective actions. The United States Enrichment Corporation's response to these violations is provided in Enclosures 1 through 3, respectively. Enclosure 4 lists the commitments contained in this submittal.
Unless specifically noted, the corrective actions specified in the enclosures apply solely to PORTS.
Pursuant to a conversation between Peter J. Miner of USEC and Kenneth G. O'Brien of the Nuclear Regulatory Commission, the due date for this NOV response was extended to May 28,1999. If you have any questions regarding this submittal, please contact Peter J. Miner at (740) 897-2710.
Sincerely, w h h4-J. Morris Brown General Manager -
Portsmouth Gaseous Diffusion Plant
Enclosures:
As Stated liC RegiEnal AdministritsfRegiodIII/
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NRC Resident Inspector-PORTS l
9906080068 990528 PDR ADOCK 07007002 C
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j United States Enrichment Corporation i
Portsmouth Gaseous Diffusion Plant l
P.O. Box 628. Piketon, OH 45661 lu l
GDP 99-2025 Page 1 of 7 UNITED STATES ENRICIIMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/99006-01 Restatement of Violation
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Technical Safety Requirement 3.9.1 requires, in part, that written procedures shall be implemented for activities listed in Appendix A to Safety Analysis Report, Section 6.11. Appendix A listed the startup, operation, and shutdown of cascade cells; nuclear criticality safety; and investigations and reporting as activities requiring written procedures. In addition, A.
Procedure XP4-CO-CA3900C, Revision 0," Control of Damaged Centrifugal Compressors,"
effective date December 24,1997, Section 2.0, "Immediate Actions," Step 2.1 required, in part, an operator to stop affected cell motors from the fastest location upon excessive stage overload or an unexplained rise in motor amp load. Step 2.2 required the operator to take the cell off stream [ isolate] in accordance with procedure XP4-CO-CN2102C. Procedure XP4-CO-CN2102 referred the operator to Procedure XP4-CO-CN2410 which contained guidance on how to isolate Cell 25-7-2 in Building X-326 from the rest of the cascade.
B.
Procedure XP4-EG-NS1025, "NCS Nuclear Criticality Safety Response to Anomalous Conditions," Revision 0, Change B, effective date November 30,1998, required, in part, that nuclear criticality safety staff shall: 1) determine if an anomalous condition involved an unanalyzed condition; 2) assess the safety significance of an as-found condition; 3) identify the nuclear criticality safety controls affected by the anomalous condition; and 4) complete the anomalous condition report within the reportability time-frame for the condition.
C.
Procedure UE2-RA-RE1030, " Nuclear Regulatory Event Reporting," Revision 2, Change C, effective date March 3,1997, required, in part, the Plant Shift Superintendent to determine whether an event or condition was reportable to the NRC according to the criteria listed in Appendix D of the procedure. Appendix D, criteria A.3.a.,c(1), and c(3) specified, in part, that a report shall be made to the NRC, within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from initial observation, for operations that do not comply with the double contingency principle [i.e., operations that are singly contingent) for which moderation is used as the primary criticality control and that involve: 1) the occurrence of any unanalyzed event for which the safety significance of the event or corrective actions to re-establish the approved controls are not readily identifiable; or 2) the controlled parameter and the control on the parameter cannot be re-established within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after the initial observation of the event.
D.
Procedure XP4-CO-CA2182, " Control of Large Air Inleakage," Revision 1, Change C, effective date February 10,1997, and XP2-SH-IS1034," Accident Prevention / Equipment Control Tags," Revision 0, Change A, effective date July 7,1997, required, in part, that the plant staff shall take specific actions to control (tagging and logging) recirculating cooling
GDP 99-2025 Page 2 of 7 water to shutdown cells and shall implement specific temporary repairs for events which result in large inleakages to the cascade.
Contrary to the above, A.
On December 9,1998, a Building X-326 operator did not stop cell motors from the fastest location upon unexplained rises in motor amp load which lead to an excessive stage overload in Stage 2 of Cell 25-7-2. In addition, the operator did not refer to or immediately isolate the cell from the rest of the cascade in accordance with Procedures XP4-CO-CA3900C, XP4-CO-CN2102C and XP4-CO-CN2410.
B.
On December 9,1998, the nuclear criticality safety staff did not: 1) identify that an anomalous condition resulting from the Cell 25-7-2 fire involved an unanalyzed condition;
- 2) incorporate into the safety evaluation the potential presence and impact of a deposit within the cell; 3) properly identify the nuclear criticality safety controls affected by the anomalous condition; and 4) complete the anomalous condition report within the reportability time-frame (4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) for the conditions present.
C.
On December 9,1998, the Plant Shift Superintendent did not make a notification to the NRC within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> ofinitial observation of the loss of moderation control for a singly contingent activity, operation of cascade Cell 25-7-2, as a result of holes in the cascade piping and components which precluded the implementation of moderation control using a dry gas buffer, an unanalyzed condition, for which corrective actions were not readily identifiable.
D.
On December 9,1998, the plant staff did not tag and log the status of cell 25-7-2 related recirculating cooling water valves and pipe spool pieces, controlled for nuclear criticality safety-related purposes, and did not implement temporary repairs to the cascade as specified in procedure XP4-CO-CA2182 and XP2-SH-IS1034 for a cell that was shutdown as a result of a fire which caused a large in leakage of air into the cascade.
USEC Response I.
Background Information The examples of the cited violation all relate to an X-326 fire in Stage 2 of Cell 25-7-2 which occurred on December 9,1998. At approximately 0605 hours0.007 days <br />0.168 hours <br />0.001 weeks <br />2.302025e-4 months <br /> on December 9,1998, the Area Control Room 6 (ACR-6) operator, while recording hourly readings, observed Cell 25-7-2, Stage 2, ammeter briefly deflect to 70% of the full scale reading and then return to a normal reading of approximately 30% of full scale. The operator interpreted this momentary deflection as a possible coolant bubble moving through the Purge Cascade. This incorrect assumption was based upon the ACR-6 operator's knowledge of a previous condition where b
- i GDP 99-2025 Page 3 of 7 a " bubble" had moved up the cascade earlier that morning. A conceptual error related to system response resulted in an incorrect evaluation by the operator of the Stage 2 motor ammeter deflection, because an actual coolant bubble moving through the Purge Cascade would have resulted in minor decreasing motor ammeter oscillations.
hnmediately following the Cell 25-7-2 trip, the operator depressed the Cell-Off-Split button (which should have resulted in a full split in Cell 25-7-2) but, the expected equipment response (i.e., a green light) did not occur, indicating one or more cell isolation valves were not fully closed. In addition, because the operator was not fully cognizant of the unique system configuration of the Side Purge, an additional isolation valve (i.e., the intemal A-line Stage 4 manual block valve [AB2S4], used to create the stripping section) remained open.
While procedure XP4-CO-CN2410 contained guidance on isolating Cell 25-7-2 from the cascade, the operator had to utilize several other cascade procedures before obtaining the appropriate method to isolate the affected cell which was not conducive to this particular emergency situation.
By 0800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br />, firefighters began to examine the affected area for hot spots, and noticed that the process piping had been breached. Firefighting activities were curtailed and Nuclear Criticality Safety (NCS) was consulted to determine how best to proceed. The NCS staff responded with verbal and written guidance on firefighting techniques and post-fire corrective actions which directed that the cell be monitored for deposits, any openings in the cell be covered, and to buffer the cell as soon as practical. In addition, NCS reviewed previous cell deposit monitoring information which indicated that a less than " safe mass" condition existed in the cell prior to the event. NCS also reviewed the expected cell UF6 inventory (documented in the Safety Analysis Report) and concluded that it was unlikely that deposits exceeding a minimum critical mass were possible. Thus, plant personnel focused on Technical Safety Requirement (TSR) limitations and other equipment and occupational safety issues to the extent that personnel did not correctly apply the reporting criteria which required the NRC to be notified within four hours after an initial observation of an event where moderation control was lost. Recovery efforts focused on retuming the damaged cell to a condition compliant with the existing Nuclear Criticality Safety Approval (NCSA) and TSR (i.e., covered and buffered within eight hours).
At approximately 1630 hours0.0189 days <br />0.453 hours <br />0.0027 weeks <br />6.20215e-4 months <br />, plant personnel realized that " moderation control" could not be restored to the damaged cell within the time limits specified in the NCSA or the TSR. A i
problem report was subsequently initiated to report this NCS non-compliance and an anomalous condition incident report was completed within four hours from receipt of the problem report. The report concluded that all double contingency controls had been lost. This conclusion was reached because the Nuclear Safety Criticality Evaluation / Approval (NCSE/A) stated that a wet air in-leakage event was singly contingent only if a greater than safe mass deposit existed. While the SAR evaluation documented that the mass of any
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GDP 99-2025 Page 4 of 7 i
deposit formed in the Side Purge would likely be less than a minimum critical mass, the NCS Manager required confirmation (via Non-Destructive Analysis) that a safe mass condition had not been exceeded. In the case of this exothennic incident, " mass control" was not lost because the resultant pressure surge dispersed UF away from the breach reducing the 6
probability of forming a significant UF deposit. However, the anomalous condition report that was completed was not adequate in determining if the Cell 25-7-2 fire involved an unanalyzed condition, because the Nuclear Criticality Safety Evaluation (NCSE) used for the assessment did not document or analyze for the condition that potentially existed if cell containment could not be restored and buffered within the time constraints specified by the NCSA.
Shortly after the fire was declared out, the affected areas were boundaried off and access strictly limited to only essential personnel who would be needed to assess the status of the i
cascade, assess the damage, and to take appropriate corrective measures to ensure the affected area remained in a safe condition. Some of these activities involved isolating cells j
that had been tripped, performing leak rate checks of shutdown cells, ensuring that recirculating water was isolated from shutdown cells, and shutting down cells that were suspected ofexperiencing in-leakage to the cascade. The environment in which the operators assigned to stabilize the cascade were asked to work included oil and water on process floors and equipment, the structural integrity of the cell housing being severely compromised, and residual process contaminants being present on plant components. These hazardous conditions slowed progress, and due to the complexity of the recovery effort, participating personnel overlooked the requirement to hang a caution tag on the 25-7-2 Recirculating Cooling Water (RCW) Condenser Drain valve or to take the appropriate administrative precautions to ensure tags would be hung at a later date.
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II.
Reason for the Violation Based on the background information provided above, the reasons for the cited violation were due to:
4 Inadequate training which led to a misinterpretation of observed plant parameters resulting in operator not recognizing the appropriate entry conditions of the referenced abnormal operating procedure (Example A). Specifically, the operator failed to recognize the initial motor ammeter deflection as an overload condition or j
to recognize that a compressor failure was about to occur.
Procedures used were not adequate to support emergent actions (Example A).
Specifically, inadequate procedure design was the reason Cell 25-7-2 was not expeditiously isolated from the operating cascade as discussed in the accident x
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GDP 99-2025 Page 5 of 7 analysis. Inadequate training also contributed to not immediately isolating the cell because the operator was not fully aware of the system's configuration.
Inadequate procedure guidance specific to preparing complete anomalous condition reports in a timely manner (Example B). Specifically, procedure XP4-EG-NS1025,
" Anomalous Condition," has been deterrnined to be iradequate because the procedure did not include action steps to require the user to document why an anomalous condition is, or is not, analyzed.
1 Incorrect application of the reporting criteria due to personnel error (Example C).
Specifically, personnel did not correctly apply the reporting criteria (i.e., to notify NRC within four hours after an initial observation of an event where moderation control was lost ), because plant personnel believed that the reporting criteria did not apply until the time limits specified in the X-326 Building Cascade Operations NCSA had been exceeded.
i The documentation and caution tagging requirements for the coolant condenser RCW valves were overlooked because of the complexity of the recovery activities.
Consolidation of supplemental actions necessary, as a result of a fire, should be captured in a stand alone Off-Normal procedure (Example D).
III.
Actions Taken and Results Achieved I
i Actions 1-3 are corrective actions previously described in Event Report 98-17.
1.
Training was developed and implemented to address cell trips, cell isolation, compressor surging, and compressor overloads. The training module has also been updated to provide a thorough discussion of off-normal conditions and indications, alarm response actions, and pertinent design basis accidents as discussed in the SAR.
Specifically, the training module provides a more defined criteria for taking actions to trip and isolate a cell based on the ammeter indications.
2.
A briefing was initiated for X-326 Facility Operations personnel. The briefings included a description of the X-326 fire incident, how the incident was handled and what indicators to be aware of when such an event is occurring. The briefimg emphasized the steps necessary for tripping and isolating a cell and those actions to take if cell block isolation valves fail to fully close.
3.
Operators were provided guidance on the causes of motor amp changes and how each of these causes affect cell panel ammeter indications in the ACR and other available
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instrumentation.
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I GDP 99-2025 Page 6 of 7 4.
On May 1,1999, required reading was initiated for the Plant Shift Superintendents to increase the awareness level of the reporting criteria where NCS controls are lost involving singly contingent operations.
5.
On March 26,1999, a group briefing was conducted with the NCS staff to discuss NCS's responsibility in assisting the plant in determining if an identified hazard involves an unanalyzed condition.
6.
On February 22,1999, caution tags were prepared and hung on Cell 25-7-2 Coolant Condenser RCW Isolation, Vent and Drain valves to meet the requirements of XP4-CO-CA4625.
7.
On March 25,1999, a corrected four hour notification was submitted to report the loss of moderation control resulting from the December 9,1998, X-326 Cell fire.
IV.
Actions to be Taken 1.
By August 8,1999, PORTS will revise 6 Anomalous Condition Procedure (XP4-EG-NS1025) to includ action steps v u requires the responder to document why an anomalous condition is, or is not, analyzed.
l 2.
The actions to be taken for the inadequate procedures (Examples A and D) are discussed under the response to violation 70-7002/99006-02.
V.
Date of Full Compliance USEC achieved full compliance as follows:
Examnle A on December 23, 1998, when a briefing was initiated for X-326 Facility Operations personnel to discuss the X-326 fire incident, how the incident was handled and what indicators to be aware of when such an event is occurring. The briefing emphasied the steps necessary for tripping and isolating a cell and those actions to take if cell block isolation valves fail to fully close.
Examnle B on March 26,1999, when a group briefing was conducted with the NCS staff to discuss NCS's responsibility in assisting the plant in determining if an identified hazard involves an unanalyzed condition.
Example C on May 1,1999, when a lessons learned bulletin was prepared and training provided to the PSS staff to increase the awareness level to the reporting criteria.
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GDP 99-2025 Page 7 of 7 Examnle D on February 22,1999, when caution tags were prepared and hung on Cell 25-7-2 Coolant Condenser RCW Isolation, Vent and Drain valves to meet the requirements of XP4-CO-CA4625.
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GDP 99-2025 Page1of2 UNITED STATES ENRICIIMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/99006-02 Restatement of Violation Technical Safety Requirement 3.9.1 requires, in part, that written procedures shall be prepared, reviewed, approved, and implemented to cover activities listed in Appendix A to Safety Analysis Report, Section 6.11. Appendix A listed cell load alarms and cell coolant alarms as examples of cascade area control room alarms requiring written procedures for " abnormal operation / alarm response."
Contrary to the above, as of December 9,1998, the certificatee had not prepared, reviewed, approved, and implemented alarm response procedures for alarms such as cell load and cell coolant alarms in the cascade area control rooms.
I.
Reason for the Violation i
The reason for the violation was due to a management decision during the procedures upgrade effort.
Specifically, during the procedures upgrade effort associated with Compliance Plan Issue 30, action step-09D, " Implement new or update procedures (including required training) to fully implement the Quality Assurance Program or other activities identified in the application in accordance with Level 2,3, and 4 'Q' procedures," guidelines were developed and used to determine which Alarm Response Procedures (ARPs) were to be developed. ARPs were subsequently developed for high risk 'Q' system operations such as Autoclaves, Withdrawal Stations, Cold Recovery, and selected Chemical Operations Activities. As a result, many cascade activities, while considered for ARP development, were not selected because these operations were addressed in Off-Normal and/or other types of cascade procedures. Because of this management decision, alarms associated with cell panels, auxiliary equipment panels, or other cascade alarms which would normally occur in the Area Control Rooms (ACR) were not identified or developed into ARPs.
II.
Actions Taken and Results Achieved The following corrective actions were previously described in Event Report 98-17.
1.
Training was developed and implemented to address cell trips, cell isolation, compressor surging, and compressor overloads. The training module has also been updated to provide a thorough discussion of off-normal conditions and indications, alarm response actions, and pertinent design basis accidents as discussed in the Safety Analysis Report (SAR). Specifically, the training module provides a more
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GDP 99-2025 Page 2 0f 2
~ defined criteria for taking actions to trip and isolate a cell based on the ammeter indications.
2.
A briefing was initiated for X-326 Facility Operations personnel. The briefings included a description of X-326 fire incident, how the incident was handled and what indicators to be aware of when such an event is occurring. The briefing emphasized the steps necessary for tripping and isolating a cell and those actions to take if cell block isolation valves fail to fully close.
3.
Operators were provided guidance on the causes of motor amp changes and how each of these causes affect cell panel ammeter indications in the ACR and other available instrumentation.
III.
Actions to be Taken 1.
As part of the corrective actions detailed and communicated in Event Report 98-17, by November 3,1999, USEC will develop and implement ARPs for Top and Side Purge.
2.
PORTS will evaluate plant operations using Gaseous Diffusion Industry acceptable practice 3 to identify those activities where an ARP would enhance or improve operator responsiveness. PORTS will develop and implement ARPs/Off-Normal procedures identified by this evaluation. This action will be completed by May 31, 2000.
IV.
Date of Full Compliance USEC will achieve full compliance upon implementation of the ARPs/Off-Normal procedures described in III.2 above. As an interim compensatory action, on May 19,1999, training was complete for cascade personnel on off-normal conditions and indications, alarm response actions, and peninent design basis accidents as discussed in the SAR.
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L GDP 99-2025 Page1of3 UNITED STATES ENRICIIMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/99006-03 Restatement of Violation Title 10 of the Code of Federal Regulatio.ns, Part 76.93," Quality Assurance," requires, in part, that the Corporation shall establish and execute a Quality Assurance Program.
Section 2.16, Appendix A, Section 1, Item 1.16, and Appendix A Section 2 Item 2.16 of the Quality Assurance Program required, in part, that conditions adverse to quality are identified and corrected as soon as practical.
Contrary to the above, as of March 22,1999, A.
The plant staff did not identify ar4 sorrect, through an August 1998, condition adverse to quality corrective action plan, a failure by some staff to implement portions of procedure XP2-GP-GP1040, " Equipment History Program." Specifically, the plant staff, in August 1998, developed and implemented a corrective action plan to ensure the full implementation of Procedure XP2-GP-GP1040 which did not identify the need for or include corrective actions to ensure that responsibilities assigned to the Reliability Engineering Manager were implemented. These responsibilities included the pre-implementation review of work packages and the identification of equipment failures requiring evaluation and failure cause analysis.
B.
The plant staff did not identify and correct, through a March 1999, significant condition adverse to quality corrective action plan, inconsistencies between the Emergency Plan and Emergency Plan Implementing Procedure XP2-EP-EP1050. Specifically, the plant staff, in March 1999, developed and implemented a corrective action plan to ensure consistency between the Emergency Plan and Emergency Plan Implementing Procedures which did not resolve inconsistencies. The unresolved inconsistencies between the Emergency Plan and Emergency Plan Implementing Procedures included the classification level and initiating conditions for severe wind and security emergencies.
I.
Reason for the Violation
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The reasons for the violation were due, in part, to management being too narrowly focused on correcting specific and/or inunediate problems and due to an inadequate technical review of the corrective action plans. Both of these conditions are symptomatic of an immature corrective action program which continues to improve as program elements are enforced.
To support this conclusion, USEC completed an independent assessment of the corrective action prograrn late in October 1998, and self-identified a weakness where Significant
GDP 99-2025 Page 2 of 3 Conditions Adverse to Quality (SCAQ) investigations were limited in scope and did not consider site-wide or generic implications. In addition, the report suggested that corrective action plans were often limited to the specific issues. To address this finding, PORTS developed an action plan which was not fully implemented until April 12,1999. Thus, this violation provides additional examples where actions were too narrowly focused to be globally effective. Further specifics as to the reason for the violation are discussed below.
In the first example, on August 6,1998, a problem report was generated to identify a non-compliance issue related to the material history program. Specifically, maintenance procedure XP2-GP-GP1040," Equipment IIistory Program" stipulated the development of an equipment history database, work history database, and that trending analysis and failure analysis be performed. Unfortunately, the corrective actions that were developed to correct these deficiencies focused primarily on the acquisition of maintenance history data and did not address or consider the additional procedural requirements associated with review of work requests to identify equipment failures. The Reliability Engineering Manager, Maintenance Program Manager, and the Planning Group Manager investigated the specific concern, and developed a corrective action plan which concentrated on those aspects of the program most difficult to implement (i.e., action items which depended heavily on actions to be implemented by other organizations and outside the managers control). This caused the individuals to overlook the more subtle issue of failure analysis.
In the second example, management failed to address classification levels and initiating conditions for severe wind and security emergencies in the Emergency Action Levels (EALs). Specifically, following the December 9,1998, fire in X-326, a problem report was written to document and to begin an investigation into the plant's failure to declare an Alert.
A corrective action plan was subsequently developed to resolve the identified inconsistency between the Emergency Plan (EP) and the Emergency Plan Implementing Procedure (EPIP) relative to initiating conditions for fires which could lead to a release of radioactive material or could have a direct effect on the health and safety of plant personnel. During the technical review of the plan, management did not thoroughly evaluate potential inadequacies in the EALs nor determine if there were other inconsistencies between the EP and the EPIP. As in the first example, management focused the investigation on the immediate issue, developing corrective actions which effectively addressed the specific issue, but did not consider if other generic implications existed.
II.
-Actions Taken and Results Achieved l
1.
On April 12, 1999, PORTS issued to Organization Managers and Evaluators /
l Investigators a lessons learned bulletin resulting from the recent independent
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assessment of the Corrective Action Program. The bulletin noted that the Corrective j
Action Program is maturing, but improvement in some areas is still needed.
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GDP 99-2025 Page 3 of 3
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Specifically, investigators were identified as being too narrowly focused during the I
investigation process.
2.
As noted in Inspection Report 70-7002/99006, PORTS documented, in a problem report (PR-PTS-99-0182), the plant's failure to develop classification levels and initiating conditions for severe wind and security emergencies. In addition, the Inspection Report acknowledges the implementation of interim compensatory measures (CA-99-020, dated March 23,1999) to address the EALs.
3.
On May 20,1999, Engineering developed a new corrective action plan to supplement the original corrective action plan to include actions to implement the failure analysis j
program.
4.
On April 28,1999, Reliability Engineering implemented a failure analysis process and began to review work requests for failed equipment to determine if a failure j
analysis needs to be performed.
III.
Actions to be Taken 1.
By August 15,1999, Engineering will coordinate with Commitment Management to develop a training plan to address developing effective broad-based corrective action plans. This training will be provided specifically to investigators and evaluators.
2.
On May 19,1999, representatives from PORTS, Paducah, and USEC Headquarters met to review industry EALs and identify other areas where the Gaseous Diffusion Plant EALs need to be improved and/or modified. Accordingly, by June 8,1999, PORTS will revise procedure XP2-EP-EP1050," Emergency Classification," to include other applicable EALs from Regulatory Guide 3.67 criteria.
IV.
Date of Full Compliance Full compliance with the specific issues of the violation were achieved for:
Examnle A on April 28,1999, when Reliability Engineering implemented a failure analysis process and began to review work requests for failed equipment to determine if a failure analysis needs to be performed.
Example B on March 25,1999, when the plant implemented interim compensatory measures to address the EALs associated with security and natural phenomena events.
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GDP 99-2025 Page1of1 List of Commitments
- 70-7002/99006-01 By August 8,1999, USEC PORTS will revise the Anomalous Condition Procedure (XP4-EG-NS1025) to include action steps which requires the responder to document why an anomalous condition is, or is not, analyzed.
70-7002/99006-02 PORTS will evaluate plant operations tcing Gaseous Diffusion Industry acceptable practices to identify those activities where an ARP would enhance or improve operator responsiveness.
PORTS will develop and implement ARPs/Off-Normal procedures identified by this evaluation. This action will be completed by May 31,2000.
70-7002/99006-03 1.
By August 15,1999, Engineering will coordinate with Commitment Management to develop a training plan to address developing effective broad-based corrective action plans. This training will be provided specifically to investigators and evaluators.
2.
By June 8,
1999, PORTS will revise procedure XP2-EP-EP1050," Emergency Classification," to include other applicable EALs from Regulatory Guide 3.67 criteria, F
- 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, procedures, programs, or operations.
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