ML20197H576
| ML20197H576 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 12/22/1997 |
| From: | Polston S UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-7001-97-08, 70-7001-97-8, GDP-97-1055, NUDOCS 9712310323 | |
| Download: ML20197H576 (11) | |
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USEC A Globd Eno,gy Company December 22,1997 United States Nuclear Regulatnry Commission SERIAL: GDP 97-1055 Attention: Document Control Desk Washington, D.C. 20555 Paducah Gaseous Diffusion Plant (PGDP)
Docket No. 70-7001 Response to Inspection Report (IR) 70-7001/97008 Notices of Viobtlons (NOVs)
The Nuclear Regulatory Commir.sion (NRC) letter dated Ncvember 20,1997, transmitted the subject IR which contained four NOVs. United States Enrichment Corporation's (USEC) response to these violations is provided in Enclosures 1-4. Enclosure 5 lists the commitments
. made in this repcrt. Unless specifically noted, the co rective actions specified in each enclosure apply solely to PGDP.
If you have any questions regarding this submittal, please contact Bill Sykes at (502) 441-6796.
Sincerely,
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ve Polston General Manager Paducah Gaseous Diffusion Plant j
SP:SRC: mig Enclosures (5) cc:
.NRC Region 111 NRC Senior Resident inspectotPGDP 9712310323 971222 PDR ADOCK 07007001 C
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. P.O. Box 1410, Paducah, KY 42001
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Telephone 502-441-5803 Fax 502-441-5801 http://www.usec.com -
OfEces in Livermore, CA Paducah, KY Portsmoaa, OH Washington, DC
i ENCLOSUREI UNITED STATES ENRICllMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7001/97008-01 Technical hv.fety Requirement 3.9.1 requires, in part, that procedures shall be implemented for activities described in Safety Analysis Report, Section 6.11, Appendix A.
Safety Analysis Report, Section 6.11, Appendix A identifies,in part, proc dures management (use) as an activity that shall be perfbrmed in accordance with approved procedures.
Procedure CP2-PS-PS1038,"Use ofI'rocedures at PGDP," requires, in part, that the first line manager must approve and documeri, in the logs, the reason for and the special entry and exit points for use of a partial procedure.
yielption Cited Ccintrary to the above, on July 27,1997, the certificatec failed to docum :nt the reason for and the special entry and cxit points for partial procedures used during restait of the purge cascade.
USEC Response 1.
Backgrou;id Infbrmation in July 1997, the C-310 purge cascade was lost when the high speed cells tripped due to UF entering the cells and causing an overload.
6 A procedure for the recovery from loss of high speed cells was not available. Therefore, procedure CP4-CO-CN2017," Start-Up of a C-310 Cell," was used. The procedure was entered at n special entry point several steps into the procedure. Ilowever, the requirement of step 6.1.9 of CP2-PS-PS1038,"Use of Procedures at PGDP," to document the reason for the special entry point in the procedure, work package or narrative log book was not performed, 11.
Ecason ihr Violation The reason for the violation was the training method on the reouirements of CP2-PS-PS1038,"Use of Procedures at PGL)P," was not adequate regarding the documentation requirements for use of a partial procedure. More than a dozen managers in various groups in Operations, Maintenance, and Engineering were surveyed to determine their understanding of the special use requirements of this procedure. The majority of those personnel were not familiar with the special use requirements of CP2-PS-PS1038. Most did not believe there was any llexibility in the requirements for using procedures. These personnel would follow procedures as written.
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, A contributing cause to this violation was the lack of a procedure for recovery from a loss i
of high speed cells.
Ill.
Conective Actions Taken and Results Achieved 1.
On July 21,1997, CP4-CO-CN2017 was exited and the procedure was no longer applicable.
2.
A crew briefing training package has been developed describing :his deficiency and the requirements of CP2-PS-PS1038,"Use of Procedures at PGDP."
Training using this package is ongoing.
D IV.
Corrective Actions to be Taken 1.
PGDP will conduct crew briefmgs on this particular deficiency and the requirements of CP2-PS-PS1038,"Use of Procedures at PGDP," for appropriate managers in Operations, Maintenance, and Engineering. This will be completed by March 6,1998.
2-.
PGDP will issue a procedure for recovery from loss of high speed cells by May 22,1998.
3.
PGDP will revise appropriate Training Development Administrative Guide Enes to include training on CP2-PS-PS1038,"Use of Procedures at PGDP." This will be completed by July 31,1998.
V.
Date of Full Comnliance USEC achieved full compliance on July 21,1997, aner CP4-CO-CN2017 was exited and the procedure was no longer applicable. Corrective actions to prevent recurrence will be completed by July 31,1998.
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ENCLOSURE 2 UNITED STATES ENRICliMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7001/97008-02 Technical Safety Requirement 3.9.1, requires, in part, that written procedures shall be maintained, and implemented for activities described in Safety Analysis Report, Section 6.11, appendix A.
Safety Analysis Report, Section 6.11, Appendix A identifies,in part, operations, including system procedures addressing startup, shutdown, nomial operations, and abnonnal operations as activities requiring written procedures.
Violation Cited Contrary to the above the certificatee failed to implement and maintain written procedures for operations, including system procedures addressing wartup, shutdown, normal operations, and abnormal operations as described by the following examples:
A.
On September 2,1997, operations management used an outdated procedure, CE-16,
" Emergency Cwrations in Building Fires," during their oversight of the response to a small fire in buiiding C-310.
B.
As of September 30,1997, numerous corolled manuals of plant procedures included canceled and outdated operations normal, off-normal, and emergency procedures.
USEC Response 1.
llackumund The administrative controis for maintenance of controlled procedure manuals and other documents are defined in the " Document Control Program" procedure, UE2-TO-RM 1030.
The following is a summary of thow controls as they apply to this NOV.
The Document Control crganization or the Procedure Control Organization transmits controlled copics of documents, identified by a " Controlled Copy" stamp or mark on the title page of the document along with a controlled copy number, to the " Controlled Copy lloider." Then documents are transmitted using a " Transmittal / Receipt Acknowledgment" form. The Controlled Copy lloider verifies the infomaation on the new Controlled Copy agrees with that on its associated transmittal form and following the transmittal form instructions, replaces the superseded documents. The removed / superseded documents are dispositioned as directed by Transmittal / Receipt Acknowledgement form or otherwise as approved by Document Control. The Controded Copy lioider signs and dates the E2-1 I
transmittal form acknowledging receipt of the documents and returns the transmittal and the superseded documents to Document Control. As noted in the statement of the violation, examples were found where superseded documents remained in the controlled manuals and the Document Control / Procedure Control record of the activity indicated satisfactory completion of the required transmittal instructions. Although the Controlled Copy lloider is accountable for maintenance of the controlled documents received, there is no prohibition precluding individuals other than the copy holder from updating the manuals. Following the second example of this violation, USEC initiated a review for similar problems in other controlled procedure manual sets. Thirty-eight problem reports were initiated by various organizations documenting problems with other procedure manuals.
It should be noted here that an additional example of a problem similar to this violation was found with other controlled documents. While reviewing Nuclear Criticality Safety issues in certain site facilities, a controlled manual containing Nuclear Criticality Safety Approvals (NCSAs) was found to be deficient in a manner similar to that of the procedures addressed by this NOV. An expanded review of additional controlled NCSA manuals found additional similar deficiencies. A problem report was initiated and is being treated as a Significant Condition Adverse to Quality (SCAQ). Preliminary evaluations indicate this issue will find similar circumstances and root cause to that of this vioimion.
11.
Benson for Violation The reason for this violation was a failure to follow the required precedural/ administrative contrcis for updating the procedures, A contributing cause was the lack of enforcement of accountability for properly updating controlled procedure manuals.
111.
Corrective Actions Taken and Results Achieved 1.
The Cascade Standard Operation Procedure Manuals were reviewed and corrected by Cascade Operations personnel by October 6,1997.
2.
The Enrichment Plant Marager directed that a plant-wide review of all controlled procedure manuals, by the manual owner, be conducted to determine if other manuals exhibited similar discrepancies. Problem Reports were initiated to document any discrepancies found. Thirty-eight problem repons were generated by multiple organizations on site. These problem report discrepancies identified were corrected by November 13,1997.
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,lV.
Corrective Actions to be Taktn 1.
Document Control will implement a self assessment prognun of controlled documents as addresse.1in the Document Control Program procedure by April 15, 1998. The program will include notification of supervision when deficiencies are discovered in maintaining controlled documents.
2.
A revision will be made to the " Employee Discipline llandbook" under the
" Guidelines for Administrative Control of Work Rules" Section which will incorporate errors in maintenance of controlled documents as an offense subject to escalated levels of disciplinary actions. This will be completed by April 15, 1998.
3.
USEC currently has an ongoing efTort to supplement controlled procedure manual sets with a controlled electronic on line procedure version. This effort will allow redaction of the number of cortrolled copies and reduce the reliance on manual update of procedures. This ef fort is expected to be completed by June 30,1998.
V.
Date of Full Compliance USEC achieved full compliance when the procedures cited in the violation were updated by October 6,1997. Correctise actions to prevent recurrence will be completed by June 30,1998.
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ENCLO3URE3 UNITED STATES ENRICllMENT CORPORATION (USEC) l REPLY TO NOTICE OF VIOLATION (NOV) 70-7001/97008-04 Technical Safety Requirement 3.9.1 requires, in part, that written procedures shall be prepared and impleraer ;cd to cover the activities described in Safety Analysis Report, Section 6.11.4.1.
Section 6.11.4.1 of the Safety Analysis Report states,in cart, that: "A a minimum, a procedure is required for any task that is describ.d in, or implements a commitment that is described in, the Safety Analysis Report..."
Ecction 6.8.2.4 of the Safety Analysis Report," Problem Re irting," states, in part, that: "All pimit employees have the responsibility to write problem rt,. orts on safety, operating, and noncomplitnce items... Corrective actions are tracked through the plant's corrective action program."
Procedum UE2-IIR-C11030," PROBLEM REPORTING," Revision 0, dated April 10,1996, iden.ifies " false alarms or false actuations related to safety system items" and " violations of, or deviations from, progrmns, policies, and procedures or deficiencies which could cause satety, operability, or reportability concerns" as problems requiring a problem report (PR). Step 6.1.3C requires that the problem report fomt be oclivered to the Plant Shift Superintendent as soon as practical, but always prior to the end of the shift.
Violation Cited Contray to the above, the certificatee failed to deliver problem report forms to the plant shift superintendant by the end of the shill for the following examples of problems (false alarms or deviations from policies and procedures):
A.
A false actuation of the high condensate safety system for the building C-333A Position 4 South autoclave on September 19,1997.
B.
A deviation from the proced'irally required criticality safety posting for a fissile s acuum and its hose in building C-310 on September 23,1997.
C.
A deficient independent verification of assay form (missing originator signature) discovered in building C-400 on September 24,1997.
D.
The identification on September 24,1997, that the certificatee had not performed load tests after moditications to two NCil-35 cylinder haulers were made in September and October 1996.
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, USEC. Response 1.
Reason for violation Based upon interviews with plant personnel,sUSEC has determined that the root cause of the violation was that some plant personnel were not aware of the specific time requirements associated with Problem Reports. They were also not aware of the guidance given in the procedure for what conditions warrant a problem report. They were, however, aware of the use of Problem Reports and the form used to document the problem.
11.
Corrective Actions Taken and Results Achieved s
1.
A series of articles in the plant newspaper (InsideP) were initiated to discuss the timeliness and applicability of situations which would dictate when problem reports should be written. These articles also discussed some of the cenents of the system. Additionally, a plant wide bulletin was prepared and issued. This bulletin dealt with the specific probicm of a lack of awareness of the requirements for writing a proHem report. This information has increased discussion site-wide on when a problem report should be written and prompted discussion on changes to the system.
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Corrective Actions to be Taken 1.
The Problem Reporting Form included in procedure UE2-IIR-C11030," Problem Reporting," will be revised by February 28,1998, to specify the time requirements for submitting a problem report.
IV. Ilait of Full Comoliance USEC has taken efforts to reinforce compliance with submission of problem reports in accordance with the requirements as stated in UE2-IIR-C11030. Actions to prevent recurrence will be completed by February 28,1998.
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ENCLOSURE 4 UNITED STATES ENRICllMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7001/97008-08 Title 10 of the Code of Federal Regulations, Part 76.68 (b) requires, in part, that the certificatee shall evaluate any as-found conditions that do not agree with the plant's programs, plans, policies, and operations in accordance with Part 76.68 (a).
Violation Cited Contrarv to the above, between August 13 and September 5,1997, the certifirmee failed to evaluate the safe'y impact of as-found nonconfo mances identified in the purge cascade, a system described in the Safety Analysis Report, plant programs, plans, and operations.
USEC Reiponse 1.
Backcround Information
- On August 13,1997, purge cascade valve sizes were discovered to be difTerent than that shown on a plant drascing. Specifiedly, the actual size of the valves was found to be 2 inches instead of the 3 inches shown in the engineering drawing. A problem report was filed for this condition by the System Engineer. At the time of filing, the System Engineer and Plant Shift Superintendent discussed the problem and its operational impact. This discussion addressed on the safety function of these AQ valves (which is a process pressure boundary not associated with the details of valve size or type). These individuals believed that the nonconforming valves would perform their safety function, therefbre, system operations were continued.
The Problem Reporting Procedure requires that a Nonconfbrmance Report Form (UE-685) should have been initiated along with the problem report. This is noted in the inspection Report. This omission was an oversight on the part af the system engineer.
Following initial processing of the problem report by the Plant Shift Superintendent, the Shill Engineer then performed a screening for potential Unreviewed Safety Questions (USQL This review was intended as a Part 76.68 (b) screen; however, the existing proc ral guidance for the USQ screening was not detailed and prescriptive enough to fuP chieve the intent of Part 76.58 (b). This led to an inadequate screening of the noi. onformance.
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Reason for Violation The reason for this violation was that procedural guidance for screening problem reports for Pari 76.68 (b) issues was insufliciently detailed. Specifically, PGDP did not provide adequate procedural gmdance to shift personnel to ensure that nonconforming conditions are evaluated in accordance with 10CFR76.68 in a timely and thorough manner, llad the system engineer or shift engineer documented a thorough 76.68(b) screening on the day the Problem Report was tumed in, this violation would have been avoided.
III.
Corrective Actions Taken and Results Achieved 1.
The Syst:m Engineer completed an engineering evaluation on the nonconforming condition in accordance with 10CFR76.68 on September 5,1997.
2.
System Engineering Standing Order 97-SE-003 was issued October 10,1997.
This interim order provides guidance to the Shift Engineer, who reviews all problem reports, on the review scope and timeliness criteria associated with problem report reviews for Part 76.68 (b) issues. In addition, guidance to System / Shill Engineers is provided to better clarify the definition of "nonconformance" in order to drive the timely disposition of these problems via the existing process.
3.
Problem Reporting procedure UE2-IIR-C11030 was chaaged on November 14, 1997, to augment the Shill Engineer problem report screening actions such that potential Part 76.68 (b) issues are appropriately reviewed in a timely manner.
IV. Corrective Stens to be Taken 1.
The interim guidance of System Engineering Standing Order 97-SE-003 will be issued as either changes to existing procedures or as a new general procedure covering review and disposition of rionconfonning conditions. Final incorporation into procedures will be accomplished by March 26,1998.
V.
Date of! oil Comnliance USEC achieved full compliance with the requirements cited in this violation on September 5,1997, when Engineering completed the evaluation of the nonconforming condition in accordance with Part 76.68. Corrective actions to preveal recurrence will be complete on March 26,1998.
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ENCLOSURE 5 LIST OF COMMITMENTS Enclosure i
- 1. PGDP will' conduct crew briefings on this particular deficiency and the requirements of CP2-PS-PS1038,"Use of Procedures at PGDP," for appropriate managers in Operations, Maintenance, and Engineering. This will be completed by March 6,1998.
- 2. PGDP will issue a procedure for recovery from loss of high speed cells by May 22,1998.
- 3. PGDP will revise appropriate Training Development Administrative Guidelines to include training on CP2-PS-PS1038,"Use of Procedures at PGDP." This will be completed by July 31,1998
- 1. Document Control will implement a self-assessment program of controlled procedure manuals as addressed in the Document Contml Program procedure by April 15,1998. The program will include notification of supervision when deficiencies are discovered in maintaining controlled documents.
- 2. A revision will be made to the " Employee Discipline llandbook" under the "Guiuelines for Administrative Control of Work Rules" Section which will incorporate errors in maintenance of controlled documents as un ofTense subject to escalated levels of disciplinary actions.
This will be completed by April 15,1998.
- 3. USEC currently has an ongoing etTort to supplement controlled p ocedure manual sets with a controlled electronic on-line procedure vesion. This effort will allow reduction of the number ofcontrolled copies and reduce the reliance on manual update of procedures. This effort is expected to be completed by June 30,1998.
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- 1. The Problem Reporting Form included in procedure UE2-IIR-C11030," Problem Reporting."
will be revised by February 28,1998, te specify the time requirements for submitting a problem report.
1, The interim guidance of System Engineering Stand Order 97-SE-003 will be issued as either changes to existing procedures or as a new general procedure covering review and disposition of nonconforming conditions. Final incorporation into procedures will be accomplished by March 26,1998.
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