ML20197H966

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7002/97-08 on 971028 & Cited Violations 70-7002/97-08-01 70-7002/97-08-02 70-7002/97-08-03 & 70-7002/97-08-04

ML20197H966
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant
Issue date:	12/29/1997
From:	Hiland P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	John Miller UNITED STATES ENRICHMENT CORP. (USEC)
References
70-7002-97-08, 70-7002-97-8, NUDOCS 9801020042
Download: ML20197H966 (1)

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December 29, 1997 Mr. J. H. Miller Vice President - Prod M United States Enrichment Corporretion -

Two Democracy Center 6903 Rockledge Drive Bethesda, MD 20817

SUBJECT:

RESPONSE TO INSPECTION REPORT 70 7002/97008

Dear Mr,

Miller:

inis refers to your November 26,1997, response to Notice of Violation transmitted to you by  !

our letter dated October 28,1997, with inspection Report 70 7002/97008. In your responso, 4

you acknowledged the four cited violations 70 7002/97008-01,70 7002/97008-02,70-7002/97008-03, and 70 7002/97008-04. We have reviewed your corrective actions for the violations and have no further questions at this time. Your corrective actions will be examined during future inspections.

if you have any questions, please contact me at (630) 829 9603. ,

Sincerely, Original Signed by Patrick L. Hiland, Chief Fuel Cycle Branch Docket No. 70 7002 cc: J. B. Morgan, Portsmouth Acting General Manager i R. W. Gaston, Portsmouth Regulatory Affairs Manager E. W. Gillesple, Portsmouth Site Manager, DOE S. A. Polston, Paducah General Manager S. Toelle, Manager, Nuclear Regulatory Assurance  :

and Policy, USEC Portsmouth Resident inspector Office Paducah Resident inspector Office l

bec w/ttr did 11/26/97: E. Ten Eyck, NMSS Y. Faraz, NMSS R. Pierson, NMSS

{I P. Tin 0, NMSS W. Schwink, NMSS

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OFFICIAL RECORD COPY C PDR

United States

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? Democracy Center l r;903 nockledge Dnve l Dethesen. MD P081r l g Tef. (3011 %4 3?o0

' * * ' ' " "' ' 3 2" ttoiini %:is l'.tiserluncol o (' rpilation November 26,1997 United States Nuclear Regulatory Commission GDP 97-2035 Attention: Document Control Desk Washington, D.C. 20555 Portsmouth Gaseous Diffusion Plant (PORTS)

Docket No. 70 7002 Response to inspection Report (IR) 70 7002/97008 Notice of Violation (NOV)

Nuclear Regulatory Commission (NRC) letter dated October 28,1997, transmitted the subject inspection Report (IR) that contained four violations involving: 1) minimum staffing,2) inadequate chemical safety controls for the removal of an X -joint containing a uranium deposit 3) receipt and storage of nonstandard IS sample cylinders, and 4) exceeding technical safety requirement (TSR) overtime limits without prior approval .

USEC's response to these violations is provided in Enclosures 1 through 4 respectively and Enslosure 5 lists the commitments made in this report. Unless specifically noted, the corrective actions specified in each enclosure apply solely to PORTS.

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In the cover letter which transmitted the Inspection Report, NRC stated that:

"The violations were ofconcern because signitar issues were previously identijled, f,(

which indicates that implementation of >vur corrective action program was ine))ective. In addition, slagimplementation of the technical safety requiremerus (ISR's) continues to be weak "

USEC understands the importance and value of an effective cortective action program and believes that significant improvement has been made in this area, Recently, an independent assessment of the corrective action program was performed at Portsmouth and recommendations for improvement were presented to the Management Analysis Assessment Team (MAAT). The MAAT accepted the recommendations foi contint.ed improvement and implementing organizations have begun work to implement the recommendations. Specific actions are documented in Problem Repor1 PR PTS 97 9355 and the assessment is documented in memorandum 97 890-257. Both of t documents are available for the NitC Resident inspector's review,

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OHices m Paducah Kentucky itetsmouth Ohio Was5ingtoa hC

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. . I Unitd SM:s Nuclear Regulatory Commission i Nr,vember 26,1997 3

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. Page 2 To address the overtime issue on how USEC will ensure excessive overtime is not authorized .

lbr ptajects like the preplanned compressor disassembly evolution, specific guidance has been piavided to the Plant Shift Superintendent (PSS) Group to specify a duration for how long an employee can work ovealme. 'Ihis infannation will be recorded and communicated to the individual l requesting the overt.me, 8 Should additional . overtime be needed beyond the time specified, an- l additicnal approval by '.he PSS will be required. Additional actions are discussed la Enclosure 4. l If you have any que tler.: regarding this submittal, please contact Ron Gaston at (614) 897- l

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Sineetely,  !

h Unmes B. M l Acting Genera Manager l Portsmouth Gaseous DitTusion Plant .

Enclosures (5) cc: NRC Region lil, Regional Administrator  !

NRC Resident inspector, PORTS l l

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i Enclosure ! I i

UNITED STATES ENRICllMENT CORPORATION (USEC)  ;

REPLY TO NOTICE OF VIOLATION (NOV) 70 7002/97008-01 e Restatement of Violation Technical Safety Requirement 3.2.2.a specified the minimum staffing requirements for each facility  :

4 (shown in Table 3.2.2 1).

Table 3.2.21 requires that a Plant Shill Superintendent (PSS) be present in the X 300 facility at all [

times. If the PSS needs to leave the X 300, an authorized designec trained to execute plant emergency  :

procedures can be assigned in accordance with TSR 3.1.3. ,

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Contrary to the above, on September 13,1997, the PSS exited the X 300 facility without assigning a designec in accordance with TSR 3.1.3.

4 I. Reasons for Violation The reason for the violation was inattention to detail. Procedure XP2 US Fol204, Sh(ft Functional Stqging Requirements, was implemented on July 31,1997. Included in this procedure are definitions of the watch stations and the boundaries that apply. The PSS who left the boundary was trained on the new procedure, but did not realize that he was violating it merely by stepping out to the X 300 " porch" until this action was identified by the inspector.

1)ackground On the morning of September 13,1997, the General Manager entered X 300 and requested the on-duty PSS to accompany him outside of X 300 to discuss the previous evenings emergency '

4 management exercise. The on-duty PSS went outside to the X 300 " porch" as requested. At the time the request was made, the on-duty APSS was outside of X 300 directing an emergency response. Another PSS who remained in X 300 was not fully trained to execute emergency procedures and had not received a turnover, NRC identified a previous violation conceming the failure to maintain minimum shill stalling ,

in inspection Report 97002. The correctie netions implemented for this prior violation were

. to create a new procedure, XP2-US F01204, defining minimum stalling requirements and the boundaries of the various duty stations and to train operating personnel on the new requirements. -The PSS involved in the September incident remembered the procedural requirements when it was pointed out Qat the " porch" was outside the boundary of the X 300 building.

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II. Corrective Actions Taken and Results Achieved  !

1.-- The on-duty PSS who went outside to the X 300 " porch" returned to the control floor-when non-compliance with the above TSR was identified. -

2. The PSS who caused the violation was counseled for inattention to detail.

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3. PSS required reading was conducted to communicate the requirements for minimum l shift stalling and the defined boundaries. This material emphasized the definitions of the watch stations and the boundaries that apply.  !

III. Corrective Steps to be Taken  ;

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' Nor.c IV. Date of Full Compliance USEC achieved full compliance on September 13,1997, when the PSS returned within the boundary of the X 300 facility. l f

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t Enclosure 2 ,

UNITED STATES ENRICilM ENT CORPORATION (USEC) i REPLY TO NOTICE OF YlOLATION (NOV) lVIO 70 7002/97008 02)

Restatement of Violation Technical Safety Requirement 3.9.1 requires that written procedures be prepared, review ed, approved, implemented, and maintained to cover activities described in the safety analysis report (SAR), Section ,

6.11.4.1.

SAR Section 6.11.4.1 requires that maintenance activities be addressed by written procedures, I

. documented work instructions, or drawings appropriate to the circumstances as described in Section  :

2.5 of the Quality Assurance Plan (QAP),

Contrary to the above, plant procedure CMG 21, " Expansion Joint Removal And installation,"

. Revision 3 was not adequately prepared in that it did not provide sufficient chemical safety controls for removal of a piping X Joint containing a uranium deposit from cell 33 3 3 on August 30,1997.

I, Reasons for Violation '

The reason for the violation was inadequate communication between the implementing organizations responsible for the X-joint removal. Specifically, the Cascade Coordination, Operations, and Industrial Safety organizations were aware that the affected cell contained liF and that a Negative Air Machine (NAM) should have been used during this work activity.

Ilowever, these organizations failed to properly communicate . bis information to the Maintenance organization prier to the X joint removal evolution. Contributing to the violation was that policies, procedures, and work packages were not strict enough or did not contain sufficient enteria to ensure chemical safety controls were implemented.

Hackeround During July 1997, cell 33 3 3 was shutdown when tt 813 seal failed while the cell was operating on stream. A large wet air in leakage occurred and it was anticipated that a UO2 F deposit had formed. A dresser seal was installed and the cell was evacuated and purged to a pG negative.

The suspect cell was scheduled for maintenance in mid August,11ased on the history of this

. cell, (i.e., the mode of failure and the method for attaining the PG negative) the facility manager correctly recommended that the cell be wet air evacuated in order to purge any residual llF from the cell prior to maintenance. Cascade Operations agreed and the evolution began. During the evolution, an liF sample was ordered and the results indicated an liF concentration of 2200 ppm Wet air evacuation continued until the evolution had to be

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suspended due to high parts (UF.) showing up on the space recorder. Additional samples were ordered to verify that the PO was not originating from the target cell. Results of the samples showed UF. concentration le:.s than I ppm in the cell. At the ume time this evolution was occurring, the facility was experiencing problems at the seal exhaust station which was believed to be causing the high parts reading on the space recorder.

llecaux of the problems experienced with the wet air evacuation and the initial sample results, a meeting was held with Cascade Coordination, Operations. and Industrial Safety to detennine a conservative course of action. The conclusion of the meeting determined that while there were no specific requirements for liF concentration in cells, a Negative Air Machine (NAM) should be used as a conser <ative measure to address the primary concern of IIF in the breathing zon . 'ihe cell was subsequently released to maintenance by building operations without knowledge of the discussion and :onservative decision to use the NAM during the X.

joint removal evolution. Subsequently, the PG system was opened at the X joint and a wisp of smoke (liF) was observed. Investigation, showed that a deposit had been cut into, exposing the deposit to the surrounding wet air which caused the a reaction producing IlF. Personnel protective equipment was properly used and no exposure was detected. Air samples taken by emergency response did not detect any airborne conisminants II. Corrective Actions Taken and Hesults Achieved

1. The Maintenance Manager issued a directive on September 16,1997, requiring large cascade components to be scanned for UO 2 F, and sampled for llF prior to removal.

Pending the results of the sample, Industrial Ilygiene would be consulted for additional controls prior to opening a PG system. This action will remain in place until all applicable maintenance procedures have been updated to incorporate chemical safety control criteric.

2. Several o;v: rations and maintenance procedures have been revised to pmvide guidance for llF abatement prior to opening a process gas system. Some of the procedures include but are not limited to the following:

XP4 CO CA2173; Purging X 330 Cells and Process System to a Negative XP4-CO-CA2174: Purging Cells and Process Systemsfor a Negative in X 333 XP4 OM MM4502t Removal and Installation of Uncomplicated Handling Converters in X 330 andX 333 Building XP4 OM MM4529; Removal andInstallation ofProcess Gas Control l'alve Classified as Uncomplicated Handling XP4 OM MM4506; Auxiliary Compressor Classified as Uncomplicated Handling - RemovalandInstallation

3. Work Control implemented a prerequisite requirement (POEF-WC-97-172) on September 23,1997, for planners to incorporate into prepared work packages a step I!2 2

to require equipment to be sampled and evaluated for liF con. centration prior to opening a PG system to atmosphere.

III. Corrective Steps to be Taken

1. The Work Control procedure will be revised by January 23,1998, to incorporate the provisions for use of a safety and health work permit to be used during the planning process.

2. The Safety & llealth Work Permit program will be revised by January 15,1998, to require chemical safety controls be specified during the planning process.

3. Maintenance procedures, including CMO.21, will be revised by January 15,1998, to incorporate chemical safety control criteria to be used when a PG system will be opened or removed.

I V. Date of Fuu complianec Full compliance was achieved on September 23,1997, when maintenance and work control took appropriate actions to ensure that chemical safety controls are applied for work activities.

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Enclosure 3 UNITED STATES ENRICllMENT CORPORATION (USEC) .

, REPLY TO NOTICE OF VIOLATION (NOV)lVIO 70 7002/97008 03)  !

i Entr*cment of Violation Techm al Safety Pequirement 3.11.2 requires, in part, that all operations involving uranium enriched to 1.0 w :ight percen,(wt.%) or higher U 235 and 15 grsms (g) or more of U 235 shall be performed in accort.snce with do. umented nuclear criticality safety approval.

Contrary to the above, from August 15 to September 15,1997, receipt and storage of nonstandard 1 S sample cylirders with uranium enriched to 1.0 wt% U 235 and 15 g or more of U 235 at the X-344 building was not perfonned in accordance with a nuclear criticality safety approval (NCSA).

Specifically, geometry control was not in accordance with NCSA 0344A006.

I. Reasons for Violation r

The reason for the violation was due to a lack of understanding and implementation of the procedure governing NSCAs when reviewing NCSAs for applicability to other similar activities. Specifically, se Nuclear Criticality Safety (NCS) engineer who reviewed the iS cylinder NCSA to determine if the controls were adequate for the non standard 1S Russian cylinders did not appropriately consider modifying the scope of the NCSA to address the non-standard IS cylinders. The NCS engineer instead based the decision of applicability only on the adequacy of the existing controls for ensuring nuclear criticality safety and not on the specific list of equipment to which the NCSA actually applied. The NCS engineer was more focused on the physical aspects for ensuring melear safety rather than the administrative correctness.

11. Corrective Actions Taken and Results Achi:ved

1. On September 22,1997 NCSA pl. ANT 078.A00; U3c of Lcdoux /S Cylinders at POR7N, was approved and implemented. This NCSA evaluated the criticality safety aspects of using the non standard "1.edoux" IS sampl: cylinders at PORTS. Because the NCSA did not alter any controls initially established by NCSA-0344A006, cbsnges to implementing procedures were not required.

2. To heighten the sensitivity of the NCS orgardation, several informal training sessions were held by the new NCS manager to review current procedures and to discuss lessons learned from this violation and other recent events.

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ill. Corrective Steps to be Taken No additional actions required.

I V. Date of Full Compliance USEC achieved full compliance on September 22,1997, when NCSA PLANT 078.A00; Use ofI.edour JS cylinders at PORTS, was approved and implemented.

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Enclosure 4 UNITED STATES ENRICllMENT CORPORATION (USEC) ,

REPLY TO NOTICE OF VIOLATION (NOV) lVIO 70 7002/97008-04l l

Restatement of Violation 1 10 CFR 76.93, " Quality Assurance," requires that the Corporation shall establish, maintain, and l execute a quality assurance program satisfying each of the applicable requirements of American l Seciety of Mechanical Engineers (ASME) NQA 1 1989," Quality Assurance Program Requirements l for Nuclear Facilities." i l

American Society of Mechanical Engineers (ASMB) NQA t 1989," Quality Assurance Program Requirernents for Nuclear Facilities," Basic Requircruent 16. " Corrective Action," states that '

conditions adverse to quality shall be identified fromptly r.nd corrected as soon as practical. In the case of a significant condition adverse to quality, the cause of the condition shall be determiacd and l corrective action taken to preclude recurrence. l Contrary to the above, on September 10 and September 18,1997, the certificatec identified two ,

examples where required technical safety requirement (TSR) overtime limits were exceeded without prior approval. This is a repetitive violation of TSR 3.2.2 which requires prior approval for exceeding ,

overtime requirements and previously identified overtime concerns were not adequately corrected to prevent recurrence.

I, Reasons for Violation ,

The reason for the violation is administrative controls used to manage employee overtime has

. been either confusing or incomplete. Specifically, while the TSR requirement associated with overtime was restated (i.e., flowed down) in procedures, the procedures do not provide a detailed method for complete implementation. In addition,in reviewing the corrective actions already taken to adiress the overtime issue, many of the actions only focussed on the .

I immediate problem.

11r' and Procedure XP2 IIR LR 1030, Limitations of Ilours of Work, was created during the administrative process of flowing down TSR requirements into procedures prior to NRC transition. Implementation of these requirements involved ftdl participation of all site

. personnel, causing implementation problems with the new process due to several individuals misunderstanding of the requirements. Interpretations were being made to address individual situations by personnel who were unfamiliar with the new procedure and employees were not '

being accountable for preventing overtime exce3dences. These individual problems were E4 1

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. l addressed through procedure upgrades and resolved through increased employee training ani

- employee disciplinary actions.

Prior to tri.asition to NRC regulatory oversight, a computerized overtime canvassing system was implemented for a selective group of hourly employees. This system is effective for normally scheduled work. liowever, the system does not alert personel to the potentail for exceeding overtime limits future scheduled work hours. This problem is being addressed through improvements to the computer programs.

II, Corrective Actions Taken and Results Achieved

1. Management expectations were communicated to plant employees addressing concerns regarding violations of hours of work.

2. A manager was appointed to or.7rsee the Plant ilours of Work program.

3. Supervision was given guidance on use of appropriate discipline for employees who exceeded authorized work hours.

4. Improvements in computerized overtime canvassing system's functionality and efTectiveness have been developed to further enhance the system.

5. A computerized hours of work monitoring system has been fully implemented. This system compares personnel time reports to TSR overtime requirements and management overtime repon approvals.

6. Clarifications have been inade to procedure XP2-liR-LR1030 discussing hours of work.

Ill. Corrective Steps to be Taken

1. Senior Management appointed a laulti disciplined team to assess the overtime process to improve overtime exceedence compliance. This team will submit recommendations to the General Manager by March 31,1998.

2. Further improvements will oc made to the ovenime canvassing system to enhance the plant's ability to prevent overtime exceedences. This action will be completed by June 1998.

IV. Date of Full Compliance Full compliance will be achieved on June 30,1998, when the corrective actions to prevent personnel from exceeding hours of work limitations are fully implemented.

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Enclosure 51 1

i UNITED STATES ENRICHMENT CORPORATION (USEC) l List of Commitments -

q NOV 70-7002/97008 01 -

-None 4

- NOV 70-7002/97008 02

1. The Work Control procedure will be revised by January 23, 1998, to incorporate the l 1 provisions for use of a safety and health work permit to be used during the planning process. l

2. - The Safety & Health Work Permit program will be revised by January 15,1998, to require

- chemical safety controls be specified during the planning process. ,

3. ' Maintenance procedures, including CMG-21, will be revised by January 15,1998, to incorparate chemical safety control criteria to be used when a PG system will be opened or removed.

4 NOV 70-7002/97008-03 1

, Non:

~ NOV 70-7002/97008-04

1. Senior Management appointed a multi-disciplined team to assess the overtime process to improve overtime exceedence compliance. This team will submit recommendations to the r General Manager by March 31,1098.

2. Further improvements will be made to the overtime canvassing system to enhance the plaat's ability to prevent overtime exceedences. This action will be completed b,7 June 1998.

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