ML20197F630
| ML20197F630 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 12/23/1997 |
| From: | Polston S UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-7001-97-12, GDP-97-1052, NUDOCS 9712300261 | |
| Download: ML20197F630 (7) | |
Text
_.
. A cann.ru comp.,y
' December 23,' 1997 United States Nuclear Regulatory Commission SERIAL: GDP 97-1052 Attention: Document Control Desk Washington, D.C. 20555-0001 Paducah Gaseous Diffusion Plant (PGDP)
Docket No. 70-7001-
- Response to inspection Report (IR) 70-7001/97012 Notice of Violation (NOV)
The Nuclear Regulatory Commission's (NRC) letter dated November 26,1997, transmitted the subject IR which contained one NOV, The United States Enrichment Corporation's (USEC) response to this violation is provided in Enc! 3sure 1. Enclosure 2 lists the comraitments made in this report.
If you have any questions regarding this submittal, pleere contact Bill Sykes at (502) 441-6796.
Sincerely, 3
h Steve Polston General Manager Paducah Gaseous Diffusion Plant SP:SRC: mig f
Enclosures (2) ec:
NRC Region 111.=
NRC Senior Resident laspector, PGDP
, 2 (.)
9712300261 971223
,I EO. Box 1410, Paducah, KY 42001 Telephone 502-441-5803 Fax 502.-441-5801 hup://wwwr.cc.com Offices in I.ivermore, CA Paducah, KY lbrismouth, OH Washington, DC
. =
i 0
ENCLOSURE 1
. UNITED STATES ENRICilMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7001/97012-01 Technical Safety Requirement 3.9, requires, in part, that written S,edures shall be
- implemented for activities described in the Safety Analysis Report, Section 6.11.4, and listed in Appendix A to Section 6.11, Safety Analysis Report, Section 6.11, Appendix A, describes a partial list of activities that sha'l be covered by written procedures including work control, management control, chemical safety, and radiation protection.
I Procedure CP2 Sil-Sil1031," Confined Space Program," required,in part, that work activities conducted in confined spaces, shall be conducted in accordan;,; with an approved and issued confine space or confined space downgrade certificate Confined space downgrade Certificate
-Number 97-335 18 required the buddy system, an employee stationed outside the confine space, be implemented for work activities in Building C-335, Unit 4. Cell 8. In addition, if a worker stationed outside the confined space was not in visual contact with the entrants, one of the
~ ntrants had to have a plant radio.
e Procedure CP2-GP GP1032," Maintenance Work Activities," required, in part, that maintenance work packages undergo a management review prior to release for maintenance work activities to.
ensure the maintenance work package instructions were adequate.
Procedure CP2 Sildll1036," Respiratory Protection Program," required, in part, that if respiratory protection equipment allowed, the respirator wearer performed a negative and positive pressure fit check for 10 seconds each, to verify the respirator seal cach time the respirator is donned or adjusted.
y_inlation Cited Contrary to the above, maintenance and work control activities were not perfonned in accordance with documented procedures appropriate to the circumstances in the following examples.
A.
- On October 7,1997, engineering troubleshooting activities in building C 335 Unit 4, Cell 8, were performed in a downgraded confine space without having an employee stationed outside the downgraded contine space entry. The entrants into the downgraded confined space were also out of visual contact and did not take a plant radio into the downgraded contined space.
B.
On October 10,1997, Maintenance Work Package (MWP) No. R9702287, for installing building C-360 autoclave conductivity cell time delays, was available for maintenance El-1
work and did not reference an appropriate test and acceptance criteria procedure for the post maintenance test of the 30-second time delay modification. The MWP had been reviewed by management and was issued with inadequate instructions f or the post maintenance testing of the autoclave modification.
C.
On October 7 and 8,1997, workers did not perform a 10-second positive and negative pressure fit check on respiratory protective equipment prior to perfomling maintenance and work activities. The respiratory protection equipment being used would have allowed the fit checks to be performed.
USEC Response to Example A 1.
Reason for Violation The reason for the violation was the administrative control of downgraded confined spaces was confusing. As a result, personnel, primarily in Engineering, failed to understand the entry requirements.
The individuals involved in this example of the violation reviewed the work package and failed to follow the requirements of the downgrade certificate. The downgrade certificate was not reviewed in detail prior to entering the confined space. The individuals noticed the DOWNGRADING OF PERMIT posting in the work package and incorrectly considered this a relaxation of the individual entry requirements of a confmed space. The fonnat of the downgrade posting sign de-emphasized the entry requirements.
II, Corrective Actions Taken and Resul:s Achieved 1.
The Enrichment Plant Manager issued a plant-wide contined space stop work order on Octobei 9,1997. (This order required a stand-down on alljobs involving work in any confined spaces until personnel were briefed on the incident and the procedural requirements for entering confined spaces. A follow-up survey was conducted with 78 people to determine if they received the briefing and to find out their understanding of key issues. This tasked was completed on October 17,1997.)
2.
Between October i1 and 17,1997, managers increased field observations of their personnel entering confined spaces. No procedure violations were observed.
3.
Coaching and counseling was completed on October 11,1997, with the engineering personnel who violated the confined space procedure requirements.
4.
Crew briefings on the event with System Engineering personnel were completed on October 10,1997.
El-2
t
- (4
- ?!
,,. ~ p.
}
5.
The Confined Space Downgrade Certificate format was revised on October 30/
1 E. c
- 1997, to improve communication of entrant requirements.
=
= III. O Corrective Actions to be Taken U
= None '
4
.t
-IV..
Date of Full Comoliance
~
USEC achieved full compliance on October 7,1997,' when the engineering personnel who violated the procedure exi'ed the downgraded confined space.
USEC Response to Example H
- I.-
Reason for Violation The violation was caused by inattention to detail by the modification designer and a less than adequate maintenance work activities procedure. The designer failed to verify the' conect revision of the Post Maintenance Test (PMT) procedure referenced in the MWP 1
when he released the package for work.- In addition, the procedure had no checks or sign-offs by Engineering holding them accountable for the adequacy of the MWP PMT' requirements. Sign-ofrs verifying package accuracy is an accepted industry practice.
11.
Corrective Actions Taken and Res.ults Achieved 1.-
' As discussed in the Inspe-tion Report, a stop work order was issued for the PMT section of the maintenance work package. Subsequently, signature points were placed in the associated work packages for the 30 second time delay modification in C-360 on October 16,1997. (This signature point required the Modification Manager to ensure the correct procedure was used for operability testing.)
2.
Information was circulated to Engineering Managers on October 16,1997, ensuring that work packages associated with modifications in progress (which require operability testing) have a modification manager signature point to verify the proper PMT revision. (This action was taken to ensure that Engineering reviews and sign ofTs are accomplished for modification packages before release.)
3.
Crew briefings with design engineers on this event were completed on October 31,1997.
-4.
JThe work control procedure, CP2-GP-GP1032, Rev.1, was revised and f
implemented ca December 19,1997, to require a PMT signature point verification sign-off for Engineering. This sign-off holds Engineering
. accountable for MWP PMT accuracy.
t
- El-3 '
a.
~
a:
r 111.
Corrective Actions to be Taksa None IV.
Date of Full Compliance USEC achieved full compliance on October 10,1997, when the stop work order was issued for the PMT section of the maintenance work package (This is noted in the inspection Report). The corrective action to prevent recurrence was complete 1 on December 19,1997.
USEC Response to Example C 1.
hason fof the Violation The reason for this violation was a lack of knowledge on the part of some personnel regarding the respirator fL check requirements. Additionally, the procedure requirement to complete a 10-second fit check was not emphasized ir. training. 'I hat was because ANSI Z88.21992 does not require a 10 second fit check. This led to some confusion.
The respirator use procedure, CP2-Sil llll036, was more stringent than required.
Not all personnel who were interviewed were deficient in this knowledge. The maintenance and operations personnel who use iespinitors regularly are more fluniliar with the procedure requirement to do a fit check. Some of the system engineering personnel had an inndequate knowledge of respirator fit check requirements, 11.
Corrective Actions Taken and Results Achieved 1.
Specific field observations were conducted by selected managers to check compliance with procedures between October 11 to October 17,1997.
2.
PGDP evaluated the 10-second respirator fit check requirement and concluded that a specific time is not required. This evaluation was completed on December 17,1997.
3.
The Enrichment Plant Manager instructed functional organization managers to remind qualified respirator wearers of the requirement to perform a 10-second fit
- check, 111.
Corrective Actions to be19193 1.
PGDP will revise CP2-SM-Ill1036, Rev. 0, to remove the 10-second fit check requirement Febmary 12,1998.
El-4
IV, Date of Full Comnliance
'ihe last known non-compliance with the 10-second fit check requirement was on October 8,1997, which was the subject of this violation. PGDP management will enforce the 10-second requirement until the procedure is changed. The corrective action to prevent recurrence will be complete on February 12,1998.
m El-5
c ENCLOSURE 2 LIST OF COMMITMENTS linclosure 1 Exempic A None Example II None Example C 1.
PGDP will revise CP2-Sil Ill1036, Rev,0, to remove the 10-second fit check requirement February 12,1998.
F3-1