ML20196F112

Responds to 990528 Response to NOV Submitted by with Insp Rept 70-7002/99-06.Response Not Fully Addressing Informational Needs in Notice.Response to Notice Requested to Be Resubmitted within 30 Days of Date of Ltr

ML20196F112
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant
Issue date:	06/23/1999
From:	Pederson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Adkins J UNITED STATES ENRICHMENT CORP. (USEC)
References
70-7002-99-06, 70-7002-99-6, EA-99-080, EA-99-80, NUDOCS 9906290131
Download: ML20196F112 (3)

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1. ' -June 23, 1999 EA 99-080 Mr. J. N. Adkins

, Vice President - Production United States Enrichment Corporation

.Two Democracy Center-6903 Rockledge Drive Bethesda, MD 20817

SUBJECT:

RESPONSE TO INSPECTION REPORT 70-7002/99006(DNMS)

Dear Mr. Adkins:

- This refers to your May 28,1999, response to the Notice of Violation (NOV) transmitted to you

- by our letter dated April 22,1999, with inspect!on Report 70-7002/99006(DNMS). We have

!- revlewed your response and have determined that the response did not fully address the informational requirements specified in the Notice. The response did not: 1) identify the root  ;

causes and provide corrective actions for each of the sub-items cited as part of Violation 1.B., 1

2) provide corrective actions for one of the root causes for Violation 1.D., and 3) provide i corrective actions for all of the unimplemented procedural responsibilities cited in Violation 3.A.

Based upon our review and the corrective actions specified in your response, we also determined that the presented "Date of Full Compliance" provided for Violations 1.A.,1.B.,

1.D.,3.A., and 3.B. were not valid in that corrective actions for certain of the root causes were not provided.

With regard to Violation 1.B. our Notice detailed four deficiencies in the performance of the nuclear criticality staff including failure to: 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. Section 11,

" Reason for the Violation," and Section Ill," Actions Taken and Results Achieved," of your response to Violation 1.B only addressed sub-item 1) which involved the failure to determine if the condition was an unanalyzed condition. The response failed to discuss root cause(s) or actions to prevent recurrence for sub-items 2),3) and 4) of Violation 1.B.

With regard to Violation 1.D Section ll,

• Reason for the Violation," of your response appears to identify two causes for the violation; the ." complexity of the recovery activities,"

appears to be a stated cause, and the need for " supplemental actions necessary, as a result of a fire, should be captured in a stand alone Off-Normal procedure" appears to be another identif;ed cause. ' Our review of your entire response indicates that the first stated cause for Violation 1.D, " complexity of the recovery activities" may be adequately addressed by your 1 corrective actions for Violation 2 in the Notice. In your response to Violation 2, you stated that alarm response procedures would be developed, and we believe this action can address the

- first' stated cause,i.e.,"the complexity of recovery activities." The second cause for Violation 1.D, " supplemental actions necessary, as'a result of a fire, should be captured in a stand alone Off-Normal procedure," does not appear to be addressed in your response, in your { b.

response to Violation 1.D, in Section IV, " Actions to be Taken," you state that inadequate procedures'are discussed under your response to Violation 2; however, the corrective actions t

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'f J. Adkins stated for your response to Violation 2, Section Ill, " Actions to be Taken," do not provide sufficient detail to provide assurance that the stated cause for Violation 1.D will be corrected.

With regard to Violation 3.A, your response addressed the two areas of responsibilities referenced in the Notice where the duties of the Reliability Engineering Manager were not being implemented by site procedures; however, the two referenced responsibilities were only examples of the deficient corrective action plan and were not intended to be the only identified deficiencies. During the course of our inspection, the inspectors discussed in detail with cognizant Portsmouth staff members the failure of the existing "Equipmant History Program" corrective action plan to address all the necessary elements with respect to assuring the Reliability Engineering Manager's responsibilities were clearly defined and implemented. At the time of our inspection, there were numerous responsibilities assigned to the Reliability i' Engineering Manager, none of which had been captured in the corrective action plan.

We also noted that the corrective actions to Violation 2 did not identify a need for corrective j action to ensure conformance with Technical Specification 3.9.1 and Safety Analysis Report, 1 Section 6.11. However, subsequent discussions with the Portsmouth Regulatory Affairs I Manager indicated that your staff is aware of the need to ensure that the corrective actions are implemented in accordance with the referenced regulatory requirements.

I Because the response did not fully address the informational needs specified in the Notice, you are required to resubmit a response to the Notice within 30 days of the date of this letter. We will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements. _

i in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and your response will be placed in the NRC Public Document Room. l We will gladly discuss any questions you have concerning these observations.

Sincerely, 4

/s/ C.D. Pederson Cynthia D. Pederson, Director Division of Nuclear Materials Safety Docket No. 70-7002 Certificate No. GDP-2 See Attached Distribution DOCUMENT NAME: GASEC\POR99006.RES To receive a copy of this document, indicate in the box:"C" = Copy without enclosur s Copy with enclosure"N"= No copy OFFICE Rill , l4 Rlli lC RIV7 l l NAME O'Brien:ib M W Hiland M -h Peberson DATE 06/22/99 "V 06A3/90' " ' OWQ99 OFFICIAL RECORD CQP'Y

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r J. Adkins cc: J. M. Brown, Portsmouth General Manager P. J. Miner, Manager, Nuclear Regulatory Affairs, Portsmouth H. Pulley, Paducah General Manager S. A. Toelle, Manager, Nuclear Regulatory Assurance and Policy, USEC Portsmouth Resident inspector Office Paducah Resident inspector Office R. M. DeVault, Regulatory Oversight Manager, DOE E. W. Gillespie, Portsmouth Site Manager, DOE Distribution:

Docket File PUBLIC IE-07 J. Lieberman, OE N. Mamish, OE D. Dambly, OGC E. TenEyck, NMSS R. Pierson, NMSS J P. Ting, NMSS j W. Troskoski, NMSS P. Harich, NMSS Y. H. Faraz, NMSS R. Bellamy, RI EJM, Ril (e-mail)

D. B. Spitzberg, RIV )

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