ML20195C742
| ML20195C742 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 11/13/1998 |
| From: | Pulley H UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-7001-98-13, GDP-98-1076, NUDOCS 9811170205 | |
| Download: ML20195C742 (5) | |
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USEC A Global Energy Company November 13,1998 GDP 98-1076 7
U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Paducah Gaseous DifTusion Plant (PGDP)
Docket No. 70-7001 Response to Inspection Report (IR) 70-7001/98013 Notices of Violation (NOVs)
Nuclear Regulatory Commission (NRC) letter dated October 16,1998 transmitted the subject IR which contained two NOVs. USEC's response to NOV 70-7001/98013-02 is provided in Enclosure i
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As indicated in the subject IR, NRC has concluded that information regarding NOV 70-7001/98013-03 has been sufliciently addressed in previous irs and no response is required. lists the commitments made in this report. Unless specifically noted, the corrective actions specified apply solely to PGDP.
Any questions regarding this matter should be directed to Larry Jackson at (502) 441-6"96.
Sincere,
ward P ey eneral Manager Paducah Gaseous Diffusion Plant
Enclosures:
As Stated cc: NRC Region 11I Office NRC Resident Inspector - PGDP I
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t raa " n a n a u w PDRj C
s e a6 EO. Box 1410, Paducah, KY 42001 Telephone 502-441-5803 Fax 502-441-5801 http://www.usec.com Offices in Livermore, CA Paducah, KY Portsmouth, OH Tashington, DC
i GDP-98-1076 1
Page1of3 UNITED STATES ENRICHMENT CORPORATION (USEC) j REPLY TO NOTICE OF VIOI.ATION (NOV) 70-7001/98013-02 1
Restatement of Violation Title 10 of the Code of Federal Regulations, Part 76.68(a), " Plant Changes," requires, in part that 4
the Corporation may make changes to the plant's operations as described in the Safety Analysis Report provided the Corporation shall conduct a written safety analysis which demonstrates the changes would not result in undue risk to public health and safety.
j Section 4.3.3.1.1 of the Safety Analysis Report states, in part, if the pump discharge valve failed 4
closed on an on-stream pump, the discharge pressure would rise quite rapidly and could conceivably
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rupture the pump discharge bellows. To prevent this type of accident dual high pressure shut-down instmmentation is installed as a safety system on the pump discharge. The high discharge pressure l
safety system will trip the pump at 42 psia to prevent exceeding the 45 psia pressure rating of the j
discharge bellows.
i Contrary to the above, on August 27,1998, the Corporation made changes to the plant's operations j
as described in the Safety Analysis Report without conducting a written safety analysis.
j Specifically, the Plant Operations Review Committee approved changes to Procedures CP4-CO-CN2021a," Operation of the C-310 Normetex Pump," and CP4-CO-CN2012b, " Operation of the C-315 Normetex Pump." which added operator actions to ensure the pressure rating (Safety Limit 2.3.2.1) of 45 psia f.>r the pump discharge bellows would not be exceeded beause the high discharge pressure safety system was nonconforming (could not be relied upon). The reliance on 1
operator action was a change to operations as described in Section 4.3.3.1.1 of the Safety Analysis j
Report which described the automatic action of the high discharge pressure safety system as the sole i
means to prevent the safety limit from being exceeded in the event the discharge valve failed closed.
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USEC Response I.
Reason for the Violation
- 1 The reason for this v!olation was an inadequate understanding regarding the guidance for answering Questions 14.1 and 14.2 of the Plant Change Review (PCR) by the PCR preparer,
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evaluator, reviewer, and the Plant Operations Review Committee (PORC). Questions 14.1 and 1
14.2 asked the evaluator and reviewer to determine if the proposed change involved a change to the plant or plant operations as described in the SAR, or if the proposed change directly or 4
indirectly impacted the plant or plant operations as described in the SAR. The individuals involved failed to realize the procedure revisions constituted a change to the Safety Analysis Report (SAR) due to the addition ofmanual actions to supplement the function of the automatic j
High Discharge Pressure Safety System (HDPSS). Consequently, either question 14.1 or 14.2 should have been answered "yes" which would have required completion of a written safety analysis.
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The PCR evaluator and reviewer believed the procedure revisions did not constitute a change to the plant or plant operations and therefore did not require a written safety analysis report.
Rationale for their decision was that the procedure revisions limited the operating pressures, but did not change the range ofpressures described in the SAR. PORC did consider the safety significance of the change. However, since the procedure revisions added a manual function not described in the SAR of a Safety System Component (SSC), the PCR preparer, evaluator, and the PORC should have realized that the proposed revisions did involve a change to the plant as described in the SAR.
The Inspection states the cited violation is similar to a previous violation documented in Inspection Report 70-7001/97007 (70-7001/97007-06). While deficient PCRs contributed to both violations, violation 70-7001/97007-06 focused on Design Engineering's failure to recognize a deviation from a test plan constituted a change to the plant which also required a written safety evaluation. Subsequently, the corrective actions for violation 97007-06 were appropriately directed to Design Engineering personnel. While both violations are based on an inconoct evaluation by the PCR evaluators and reviewers, the violations differ in scope and corrective actions.
II. Corrective Actions Taken and Results Achieved
- 1. The General Manager rejected the recommendation of the PORC and the affected PCR was re-written. The responses to questions 14.1 and 14.2 were revised to state the proposed changes involved a change to the plant or plant operations as described in the SAR/FSAR and the proposed change directly or indirectly impacted the plant or plant operations as described in the SAR/FSAR. As a result of the revised PCR, Safety Evaluation 98-076, Rev.
0 was written. This safety evaluation concluded there was no reduction in the margin of safety of the operation of the Normetex pump associated with the addition of manual actions associated with the procedure changes. The PORC reviewed and approved this PCR and SE on August 27,1998.
- 2. The lessons-learned from this violation were distributed for review to all PORC members, PORC subcommittee members and alternates, and the Nuclear Safety Analysis organization.
IIL Corrective Actions to be Taken
- 1. By December 9,1998, training module 701.06.03 (Plant Change Review) will be revised to include the lessons learned from NOVs 97007-06 and 98013-02.
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- 2. By January 15, 1999, Functional Organizational Managers will ensure crew l
briefings / required reading are conducted on the lessons learned from NOVs 97007-06 and 98013-02 with all current PCR evaluators and reviewers.
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IV. Date of Full Compliance L
Full coinpliance was achieved on August 27,1998, when the PORC re-reviewed, and approved PCR C-98-1240, Rev, I and Safety Evaluation 98-076. Rev. O.
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c GDP 98-1076 Page1of1 List of Commitments
- NOV 98113-02 1.
By December 9,1998, training module 701.06.03 (Plant Change Review) will be revised to inclue the lessons learned from NOVs 97007-06 and 98013-02.
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By January 15,1999, Functional Organivational Managers will ensure crew briefings / required reading are conducted on the lessons learned from NOVs 97007-06 and 98013-02 with all current PCR evaluators and reviewers.
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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, procedures, programs, or operations.