ML20196F042
| ML20196F042 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 06/21/1999 |
| From: | Jonathan Brown UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-7002-99-04, 70-7002-99-4, GDP-99-2033, NUDOCS 9906290089 | |
| Download: ML20196F042 (13) | |
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W USEC A Global Energy Company June 21,1999 GDP 99-2033 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) 70-7002/99004 Notice of Violation (NOV)
The subject IR contained four violations involving issues related to implementation of Nuclear Criticality Safety at the Portsmouth Gaseous Diffusion Plant. The United States Enrichment Corporation's response to these violations is provided in Enclosures 1 through 4, respectively.
{ lists the commitments contained in this submittal. Unless specifically noted, the corrective actions specified in the enclosures apply solely to PORTS.
If you have any questions regarding this submittal, please contact Peter J. Miner at (740) 897-2710.
Sincerely,
/ 07f-b W
. Morris Brown General Manager i
i Portsmouth Gaseous Diffusion Plant
Enclosures:
As Stated cc.
NRC Regional Administrator - Region III NRC Resident Inspector-PORTS reF":885t U8 h C
PDR v
34 United States Enrichment Corporation Portsmouth Gaseous Diffusion Plant P.O. Box 628, Piketon. OH 45661 E
GDP 99-2033 Page1of4 UNITED STATES ENRICHMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/99004-01 Restatement of Violation Technical Safety Requirement 3.11.1 requires, in part, that the Nuclear Criticality Safety Program shall be established, implemented, and maintained as i escribed in the Safety Analysis Report and shall address process evaluations and approvals.
l Safety Analysis Report Section 5.2.2.3," Process Evaluation and Approvals," required, in part, that the nuclear criticality safety evaluation process shall include: 1) a determination of the credible process upsets which need to be considered; 2) the development of controls necessary to meet the double contingency principle; and 3) the identification of the assumptions and equipment needed to ensure nuclear criticality safety.
Contrary to the above, as of March 12,1999, the certificatee failed to determine all credible process upsets, develop controls necessary to meet double contingency principle, and identify all the assumptions and equipment needed to ensure nuclear criticality safety for Nuclear Criticality Safety Evaluation (NCSE) 0705-015 and Plant 079. Specifically, the certificatee did not:
)
a.
Identify the presence of and applicable controls for materials (e.g., Polyvinyl Chloride),
involved with the operations, which could affect nuclear criticality safety (NCSE 0705-015);
b.
Perform and document reviews, for adequacy and applicability, of referenced and relied upon calculations and did not identify and document assumptions related to the fissile material operations (NCSE 0705-015 and Plant 079);
4 c.
Identify or document controls and justifications, in terms of the availability and reliability, necessary to support the use of"unlikely events" as a part of the double contingency principle (NCSE 0705-015).
I.
Reason for the Violation The reason for the violation is due to a combination ofinadequate procedure guidance and the fact that previous corrective actions had not yet been fully implemented. The specific reasons for each of the identified examples are detailed below.
Examnle a The rearon for this example of the violation was due to an inadequate procedure. Procedure XP4-EG-NSI100, " Nuclear Criticality Safety Calculations," does not specifically include L
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GDP 99-2033 Page 2 of 4 instructions to account for uncertainties in the neutron cross-sections in the materials of construction. This lack of procedural guidance resulted in a failure to account for chlorine in the calculations used to support NCSE 0705_015.A09. Cortributing to the vio!ation was I
an inadequate review of the NCSE since procedure XP4-EG-NS1001, " Nuclear Criticality Safety Evaluations and Approvals," requires the NCS engineer to ensure calculations used j
in an NCSE contains sufficient detail tojustify the basis and bounds the condition analyzed.
Examnle b The reason for the violation was because corrective actions had not been fully implemented.
As a result of a previous violation, on May 7,1998, PORTS committed to re-verify calculations used in support of NCSE/As. This commitment was made after NCSE
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0705_015.A09 was activated in the field (i.e., April 9,1998). The review and re-verification j
of all calculations were performed in conjunction with numerous other activities associated I
with the NCS Corrective Action Plan (CAP). Calculations were assessed / evaluated and a matrix was generated on June 30,1998, to clearly identify those calculations which appeared inadequate and/or had not been peer reviewed by qualified personnel. In addition, calculations which were identified at that time as questionable, were reviewed for safety significant concerns. At this point, personnel began to work-off the list of identified calculations, which involved more than a review for safety, and appropriately documented the peer review as required.
Example c The reasons for this example of the violation were due to an inadequate procedure (XP4-EG-NS1001) and due to confusing or incomplete documentation in NCSE PLANT 079.
Specifically, in the first case, personnel were not required, by procedure, to specify the quantity and type ofinformation needed to support the use of unlikely events. In addition, NCS personnel did not routinely include the depth of information needed to adequately justify the use of unlikely events to show double contingency. In the second case, the NCSE did not document assumptions relating to the potential need to cover all containers (i.e., not just the equipment containing the deposit) with pre-staged moderation covers in the event of a fire sprinkler discharge. Our investigation concluded that additional controls for moderation covers were not needed for the containers, because the permitted containers were either safe under optimum moderation conditions, or else the moderation controls were already specified in other NCSAs for the containers in question. The conflict in the controls relate to the NCSE stating that " interaction was wt controlled," even thought Section A.10 of the NCSE required a 10-foot separation between the uranium deposits and other fissile material containers. Thus, personnel did not document interaction control in the proper section (A.7) of the NCSE or document why moderation controls were not necessary for containers used to collect deposit material.
m GDP 99-2033 Page 3 of 4 II.
Actions Taken and Results Achieved 1.
On June 17',1999, NCS issued DOI-832-99-03 which requires NCS engineers to ensure calculations referenced in an NCSE/A are appropriately peer reviewed and
, approved.
2.
On May 10,1999, procedure XP4-EG-NS1001, was revised and implemented to include a definition of"unlikely events" and provided instructions on using "unlikely events"in an evaluation.
3.
.On March 5,1999, a preliminary review of NCSE/As was performed to identify where "unlikely events" were used as single, stand alone contingency controls and confirm that the controls were justifiable.
III.
Actions to be Tiken 1.
Required Reading will be conducted with the NCS staff, by June 30,1999, to re-emphasize the use of" materials of construction" credited in NCS evaluations.
2.
By July 30,1999, NCS will generate final calculations investig9m the effects of chlorine concentration and distribution and will revise NCSE 0,
. 015.A09 to include any changes which may be required as a result of the final calculations.
3.
By September 30,1999, NCS will revise procedure XP4-EG-NS1001, " Nuclear Criticality Safety Evaluations and Approvals," to incorporate the requirements 1~
documented in DOI-832-99-03, 4.
By November 30,1999, NCS will revise procedure XP4-EG-NSI100, " Nuclear Criticality Safety Calculations," to include instructions to account for uncertainties in the neutron cross-sections in the materials of construction.
5.
PORTS will revise and implement NCSE PLANT 079, by September 30,1999, to document interaction controls in the proper section and to document why moderation
. controls are not required for collection containers.
6.
By July 30,1999, PORTS will revise NCSE 0705_.015.A09 to include sufficient I
justification as to the availability and reliability of the control for "unlikely events" used as a single control for either leg of the double contingency matrix.
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GDP 99-2033 Page 4 of 4 7.
By July 16,1999, PORTS will review implemented NCSE/As to ensure "unlikely events" used as single controls for either leg of the double contingency matrix has sufficientjustification as to the availability and reliability of the control.
8.
A lessons learned will be developed for NCS engineers, NCS sub-committee members, and PORC members to emphasize the importance of documenting assumptions made in NCSEs, and documenting controls in the correct section of the document. This action will be completed by July 16,1999.
IV.
Date of Full Compliance USEC will achieve compliance with the specific issues associated with the violation on September 30,1999, when both NCSE 0705,_015 and NCSE PLANT 079 are revised and implemented.
V.
Additional Concerns Identified in the Inspection Report Examnle a A concern was noted in the inspection report related to POEF-520-94-036," Criticality Safety Analysis of a Preliminary Design for an F-Can Secondary Container." The report identifies that the applicability of the chlorine calculations used in NCSE 0705,_015.A09 were flawed.
Specifically, errors have been identified within the industry accepted SCALE cesputer code (specifically 27GROUPNDF4). Based on discussions with Oak Ridge National Laboratory, the error resides in the data used to model or generate the representative chlorine cross sectional area for neutron absorption. The impact of this error on a given system is problem dependent (i.e., it may have a large impact on K, for one system, but negligible impact on I
another). In the case of the microfiltration module, preliminary calculations indicates that the impact is inconsequential. (Note: A corrective action to address this concern is discussed in Section 111, item 2 above)
Exampkh The inspection report included an additional concern related to POEF-340-98-113 being referenced in NCSE 0705_015.A09 as an unreviewed calculation. This document is not an NCS calculation, rather it is an explanation of the chemical relationship between pH and uranium and was generated by a laboratory chemist. The NCS staff specifically requested the generation of this document because of the specialized nature of the concern. POEF-340-98-113 was generated in accordance with approved procedures. Due to the specific nature of the information communicated in the referenced document, the discussion precluded a peer review by the NCS staff; because the document was generated by a qualified chemist.
E GDP 99-2033 Page1 of2 UNITED STATES ENRICilMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/99004-02 Restatement of Violation Technical Safety Requirement 3.11.2 requires, in part, that all operations involving uranium enriched to 1.0 weight percent or higher uranium-235 and 15 grams or more of uranium-235 shall be based upon a documented nuclear criticality safety evaluation and shall be performed in accordance with a documented nuclear criticality safety approval.
Contrary to the above, as of March 12,1999, the certificatee conducted laboratory activities, in support of NCSE 0705-015 which involved uranium enriched to greater than 1.0 weight percent tranium-235 and 15 grams or more or uranium-235, that were not based upon a documented nuclear criticality safety evaluation. Specifically, the laboratory staff:
Conducted analyses of nuclear criticality safety-significant samples using a single laboratory a.
technician to prepare samples for, and to perform, the wet chemistry process, with and without the use of the spectrophotometer instrument and with the mass spectrometer instrument, without an evaluation of the operation and without an identification of the required controls necessary to avoid a loss of double contingency; and b.
Conducted analyses of nuclear criticality safety-significant samples using the mass spectrometer and spectrophotometer instruments, without an evaluation of the operation and without an identification of the required controls to ensure that any out-of-control measurements on the low side would be detected t.nd evaluated in a timely manner to avoid a potential loss of double contingency.
l I.
Reason for the Violation The reason for the violation was because corrective actions associated with the Nuclear i
Criticality Safety Corrective Action Plan, Task 21, had not been fully implemented.
Specifically, personnel have not yet performed the initial Fissile Material Operation (FMO) walkdowns for laboratory activities such as for NCSA PLANT 053," Uranium Analysis and Sampling." The review of this NCSA is currently on the Priority 2 list of NCSE/As to be reviewed and upgraded.
11.
Actions Taken and Results Achieved 1.
On June 17,1999, PORTS issued a policy statement which requires out-of-control
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measurements for NCS significant samples be reported to NCS for evaluation.
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GDP 99-2033 i
Page 2 of 2 1
2.
On April 28, 1999, two Daily Operating Instructions were issued to facility personnel. Specifically, DOI-705-99-12, was issued to X-705 to provide instruction and restricted operations personnel from processing solutions prior to receiving results of the independent samples. DOI-340-99-01, was issued to provide instruction on the identification of NCS significant samples and the revised analysis approach.
In addition, DOI-340-99-01, provides guidance which now requires NCS significant samples to be independently analyzed using two different laboratory technicians 3.
On April 28,1999, an anomalous condition report was completed to evaluate the use of a single technician for NSC significant samples and determined that "there were no credible scenarios that could result in a criticality due to the same person performing the analysis."
III.
Actions to be Taken 1.
Existing NCSAs will be reviewed to confirm FMO support functions are properly idenQed and/or applicable to the evaluation. This action will be completed by July 30,1999.
2.
PLANT 053 NCSA will be modified or a new NCSA will be developed, as needed, to address independence of NCS significant samples and provide controls for out-of-
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control measurements on the low side to ensure the condition is detected and j
evaluated in a timely manner. This action will be completed by January 28,2000.
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IV.
Date of Full Compliance USEC will achieved compliance with the specific issues cited in the violation when NCSA 9
PLANT 053 is modified or a new NCSA is written to address independence of NCS signiscant samples and provide controls for out-of-control measurements. Daily Operating Instructions and a Policy Statement have been issued to ensure NCS significant samples are j
independent, restrict operations personnel from processing solutions prior to receiving results of the independent samples, and to require out-of-control measurements for NCS significant samples be reported to NCS for evaluation.
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GDP 99-2033 Page 1 of 2 UNITED STATES ENRICHMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/99004-03 Restatemet of Violation
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4 Technical Safety Requirement 3.11.1 requires, in part, that the Nuclear Criticality Safety Program shall be established, implemented, and maintained as described in the Safety Analysis Report and shall address identification of safety system components and support systems necessary to meet the double contingency principle.
Safety Analysis Report Section 5.2.2.8, " Change Control," required, in part, that functional and physical characteristics of operations controlled for nuclear criticality safety were described in nuclear criticality safety evaluations and approvals. Components and features which were identified in the nuclear criticality safety evaluations and approvals were analyzed to determine the " boundary" of the system, encompassing those items that were essential to ensure operability. Structures, systems, and components which require configuration control were identified as quality (Q) or augmented quality (AQ)-NCS.
Contrary to the above, as of March 12,1999, the certificatee did not identify the filter press blank plate, a component relied upon for double contingency in Nuclear Criticality Safety Approval NCSA-0705-015.A09 and ssential to ensure operability, as an item relied on for criticality safety in the Boundary Definition Manual and did not classify the filter press blank plate as an AQ-NCS item.
2 1.
Reason for the Violation The reason for the violation was due to an inadequate Structure, System, and Component (SSC) classification procedure, XP3-EG-EG1037, " Establishing and Controlling Quality Boundaries." Specifically, the procedure lacked sufficient detail to ensure AQ-NCS SSCs were correctly identified which resulted in the blank filter press plate being removed from the " passive design features" section of NCSA 0705_015.A09 during the NCSE/A review and approval process. Contributing to the cited violation was inadequate corrective actions.
Specifically, VIO-98-206-02 stated that SSCs in NCSE/A 0326_013 and 0326_024 were not classified as AQ-NCS items. USEC responded to the violation and indicated the violation was due to inadequate guidance for classifying SSCs required to meet the double contingency principle. Procedure XP3-EG-EG1037 was revised as of August 27,1998, and the new criteria was used to review NCSA 0705_015,A09 which subsequently did not identify the filter press blank plate as AQ-NCS. Thus, the procedure used for classifying AQ-NSC SSCs continues to contain inadequate guidance to correctly identify SSCs important to NCS as AQ-NCS items.
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GDP 99-2033 Page 2 0f 2 II.
' Actions Taken and Results Achieved'
. On April 28,1999, the filter plate was included in' the Boundary Definition Manual and ii appropriately classified as an AQ-NCS controlled item.
III.
Actions to be Taken 1.
USEC will revise the AQ-NCS criteria to include passive design features relied upon for NSC and revise procedure XP3-EG-EG1037 to clarify the guidance'used for classifying SSCs as AQ-NCS. This action will be completed by July 30,1999.
2.
A lessons learned briefing will.be provided to the Plant Operation Review Committee (PORC) members and to the Configuration Management group related to NRC Violations 98 2064)2,98014-01c, and to the specific issues associated with
- this cited violation. In addition, PORC will be provided instructions on the criteria 4
used to classify SSCs as AQ-NCS to include active and passive features. This action
' will be completed by August 6,1999, 3.
Configuration Management.will review AQ-NCS flowdown of NCSAs completed as part of the NSC Corrective Action Plan to identify other SSCs which may not have been correctly classified. This action will be completed by September 30,1999.
IV.
Date of Full Compliance USEC achieved compliance with the specific issues associated with this violation on April 28, 1999, when the filter plate was included in the Boundary Definition Manual and appropriately classified as an AQ-NCS controlled item.
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GDP 99-2033 Page1of2 UNITED STATES ENRICIIMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/99004-05 Restatement of violation 10 CFR 76.93, Quality Assurance, requires, in part, 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."
Section 2.16, of the Quality Assurance Program, " Corrective Action," required, in part, that conditions adverse to quality shall be identified promptly and corrected as soon as practical. In the case of significant conditions adverse to quality, the cause of the condition shall be determined and corrective actions taken to preclude recurrence.
Procedure XP2-BM-CIl031," Corrective Actions Process," Revision 0, Change A, dated June 15, 1998, Section 6.0, required, in part, that plant staff shall verify that changes to corrective action plans for significant conditions adverse to quality: 1) were warranted; 2) would fix the root or contributing causes, as originally determined; and 3) were reviewed and approved by the Corrective Action Review Board.
Contrary to the above, as of March 12,1999, the plant staff made changes to the corrective actions for a significant condition adverse to quality, as outlined in Problem Report PR-PTS-08987 and NCSA-PRI-01 and as communicated to the NRC in a letter dated November 13,1998, which reduced the scope of Priority 2 and 3 nuclear criticality safety evaluation and approval reviews and upgrades without: 1) determining that the changes were warranted; 2) determining that the revised corrective action plans would fix the root or contributing causes, as originally determined; and 3) having the changes reviewed and approved by the Corrective Action Review Board.
I.
Reason for the Violation The reason for the violation was due to a failure to follow procedure XP2-BM-C11031,
" Corrective Action Process." The former engineering manager, with agreement from affected line organizations, implemented the reduction-in scope without considering the procedural requirements necessary to implement the desired changes to the NCS Corrective Action Plan (CAP).
II.
Actions Taken and Results Achieved On April 20,1999, the nuclear safety manager presented the revised NCS CAP (Revision 5) to the CARB for approval. The manager used the proper procedure (XP2-BM-C11031) to present the revised corrective action plan to the CARB, which included the justification for the changes to ensure the changes would still correct the deficiency originally presented to
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i GDP 99-2033 Page 2 of 2 the Management Analysis and Assessment Team on November 16,1997. The CARB subsequently approved the revised CAP for the associated problem report, PR-PTS-08987.
III.
Actions to be Taken By July 13,' 1999, a lessons leamed will be issued to organizational managers discussing the -
manner in which the NCS CAP was handled. The lessons learned will specifically emphasize the procedural requirement that changes or modification to the scope of a CAP must receive review and approval by the CARB.
IV.
Date of Full Compliance i
USEC achieved full compliance on April 20,1999, when the CARB reviewed and approved the revised plan as required by procedure XP2-BM-CIl031.
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1 GDP 99-2033 h.
Page1of2 i M List of Commitments
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~ 70-7002/99004 01 L
l 1.'
Required Reading will be conducted with the NCS staff, by June 30,1999, to re-emphasize the use of" materials of construction" credited in NCS evaluations.
2.
~ By July 30,1999, NCS will generate final calculations investigating the effects of chlorine concentration and distribution and will revise NCSE 0705_015.A09.to include any changes which may be required as a result of the final calculations.
3.
By September 30,1999, NCS will revise procedure XP4-EG NS1001, " Nuclear Criticality Safety Evaluations and Approvals," to incorporate the requirements documented in DOI-832-99-03. (Example a) 4.
By November 30,1999, NCS will revise procedure XP4-EG-NS1100, " Nuclear Criticality Safe:y Calculations," to include instructions to account for uncertainties
. in the neutron cross-sections in the materials of construction.
5.
- PORTE will revise and implement NCSE-PLANT 079, by September 30,1999, to document interx
- tion controls in the proper section and to document why moderation controls are not required for collection containers.
6.:
By August 30,1999, PORTS will revise NCSA-0705_015.A09 to include sufficient
. justification as to the availability and reliability of the control for "unlikely events" used as a single control for either leg of the double contingency matrix.
17.
- By July 16,1999, PORTS will review implemented NCSE/As to ensurc "unlikely events" used as single controh for either leg of the double contingency matrix has sufficientjustification as to the availability and reliability of the control.
- 8.
A lessons learned will be developed for NCS engineers, NCS sub-committee E
members, 'and PORC _membert to emphasize the importance of documenting assumptions made in NCSEs, and documenting controls in the correct section of the document. This action will be ccmpleted by July 16,1999.
i.
- 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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i GDP 99-2033 A,
Page 2 of 2 70-7002/99004-02 l'1 Existing NCSAs will be reviewed to confirm FMO support functions are properly identified and/or applicable to the evaluation. This action will be completed by July 30,'1999.
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- 2.
PLANT 053 NCSA will be modified or a new NCSA will be developed, as needed, to address independence of NCS significant samples and provide controls for out-of-control measurements on the low side to ensure the condition is detected and.
evaluated in a timely manner. This action will be completed by January 28,2000.
70-7002/99004 '
1 j
1.
l USEC will revise the AQ-NCS criteria to include passive design features relied upon
~ for NSC and revise procedure XP3-EG-EG1037 to clarify the guidance used for classifying SSCs as AQ-NCS. This action will be completed by July 30,1999.
2.
A" lessons learned briefing will be provided to the Plant Operation Review Committee (PORC) members and to the Configuration Management group related to NRC Violations 98-206-02,98014-01c, rwi to the specific issues associated with this cited violation. In addition, PORC will be provided instructions on the criteria used to classify SSCs as AQ-NCS to include active and passive features. This action will be completed by August 6,1999.
3.
Configuration Management will review AQ-NCS flowdown of NCSAs completed as part of the NSC Corrective Action Plan to identify other SSCs which may not have l
been correctly classified. This action will be completed by September 30,1999.
70-7002/99004-05 By July 13,1999, a lessons leamed will be issued to organizational managers discussing the manner in which the NCS CAP was handled. The lessons learned will specifically emphasize the procedural requirement that changes or modification to the scope of a CAP
- must receive review and approval by the CARB.
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