ML20197J563
| ML20197J563 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 12/23/1997 |
| From: | Morgan J UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-7002-97-10, GDP-97-2041, NUDOCS 9801050026 | |
| Download: ML20197J563 (13) | |
Text
'
1 United St tis Ennchm:.nl Corporition 2 Democracy Center 6903 Rockledge Dnve Dethesda MD20817 j
Tel (300 564 3200 Uniteil Staten Emirlwnt G pimtisen December 23,1997 United States Nuclear Regulatory Commission GDP-97-2041 Attention: Document Control Desk Washington, D.C. 20555 Portsmouth Gaseous Diffusion Plant (PORTS)
Docket No. 70-7302 Response to Inspection Report (IR) 70-7002/97010 Notice of Violation (NOV)
Nuclear Regulatory C mmission (NRC) letter dated November 24,1997, transmitted the subject inspection Report (IR) that contained five violations involving: 1) inadecuate corrective actions to preclude potential recurrence of a safety system actuation,2) F-cans containing uranium bearing material not properly capped,2) initiating cylinder heating without confirming compliance with the TSR,4) use of engineering change notices to modify NCSA requirements, and 5) failure to conduct semiannual and monthly survaillance of the Public Warning System.
USEC's response to these violations is provided in Enclosures 1 through 5 respectively and lists the commitments made in this report. Unless specifically noted, the corrective actions specified in each enclosure apply solely to PORTS.
Two of the cited violations (i.e., NOVs 97010-02 and 97010-04) involved inadequacies with implementation of Nuclear Criticality Safety (NCS) requirements. In a letter dated December 22, 1997 (i.e., GDP-97-0217), USEC provided the NRC with a corrective action plan that identified short-term and long-term improvements to our NCS program. Therefore, this response addresses only USEC actions regarding the specific deficiencies for these cited violations,
[2M,//
s
%7 g jjpg n..[1.l 9001050026 971223 PDR ADOCK 07007002 C
PDR Offices in Paducah. Kentucky Portsmouth. Ohio Washington DC
np,
-f F'
,e i.
j
't 7
,x
' i idsited States Nucicar Regulatory Comniission -
! December 23,1997
- Page 2~
r If you have any questions regarding this submittal, please contact Ron Gaston at (614) 897-
- 2710; I'
Sincerely.
~
~
ames B.' M an i
Acting General Manager Portsmouth Gaseous Diffusion Plant
?
Enclosures (6)-
. cc:: l NRC Region Ill, Regional Administrator i NRC Resident Inspector, PORTS 7-
- \\
i b'
N 1
s-3.1
, 7:
i 1
,'h p
+
UNITED STATES ENRICHMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/97010-01 Restatement of Violation 10 CFR 76.93, " Quality Assurance, " requires 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 t-1989," Quality Assurance Program Requirements -
for Nuclear Facilities."
- ASME NQA-1-1989 Basic Requirement 16," Corrective Action," states that conditions adverse to quality shall be identified pro.mptly and corrected as soon as practical. In the case of a significant condition adverse to quality, the cause of the condition shall be determined and corrective action taken to preclude recurrence.
Contrary to the above, on October 18,1997, the certificatee retumed autoclave #4 at the X-343 facility to service following a high steam pressure safety actuation, a significant condition adverse to quality, without verifying the root cause and taking action to preclude recurrence.
I.
Reasons for Violation The teason for the violation was due to a lack of specific guidance detailing actions that should be taken to determine the reason for the actuation before returning an autoclave to service following an autoclave safety system actuation. As a result, the PSS made an error in judgement and failed to make a conservative decision to declare the autoclaves out of service following the safety actuation. Additionally, the PSS did not document that the actuation was not due to a valid signal or the basis for concluding that the safety system components were operating within design parameters.
Backcround
- On October 18,1997, at 1645 hours0.019 days <br />0.457 hours <br />0.00272 weeks <br />6.259225e-4 months <br />, X-343 autoclave #4 was operating ia Mode IV, feeding a Uranium llexafluoride (UF.) cylinder to the enrichment cascade, when an audible and visual alarm for steam shutdown was received. Operators resp aded to the alarm and discovered that the Autoclave Shell liigh Pressure Containment Shutdown (ASilPCS) safety system had actuated in addition to the Autoclave Shell liigh Steam Pressure Shutdown (ASIISPS) safety
~
systeni.
The operators followed the alarm response procedures and determined that channel "A" of the ASHPCS had caused the actuation. Condensate samples were collected to verify that no UF, release had occurred. The autoclave alarms were reset after verifying that all containment El-1
y
.4
. 4 I-
'4-), f y'
- valves had actuated as designed thus confirming operability of the containment safety feature._
q
~
,^
V
? The autoclave was then opened and inspected and no abnormal conditions were identified.
R Since the PSS believed the safety systems were functional and that the actuation did not -
1 4
appear to be' due to a. signal _ associated with a design' basis accident or high _ temperature '
condition, operators closed the autoclave, restarted the steam, and continued with the cylinder
- feed'cyclec 4
in addition, because the autoclave safety system actuation was assumed to be due to rising steam pressure only (no UFi release involved) and because the autoclave contained a hot liquid'.
-I cylinder, the on-duty PSS believed it was safer to continue feeding the cylinder to' remove the liquid UF. from the autocla've prior to taking the autoclave out of service to determine the actual cause of the actuation (i.e., "as soon as practical" is after the hot liquid cylinder is
. empty).~ liowever the PSS did not take immediate action to clearly establish the reason for the actuation.~
11.-
LCorrective ActionsTaken and Results Achieved
}
1;-
. On November 27 1997 the PSS organization was instructed, via Department j
Operating Instruction (DOI), to declare an autoclave inoperable following a safety-
- system actuation and keep the autoclave inoperable until the cause of the actuation is~
known.1This instruction will remain in place until adequate guidance provided to
. personnel for investigating safety system actuations.
2.-
LRequired reading.was developed for the PSS to communicate the lessons learned associated with this event.- This action was completed November 29,1997.
i III.i Corrective Steps to be Taken-Guidance will be developed for evaluating safety system actuations and to properly determine a reason for the actuation prior to retuming a system to senice. This action will be completed.
by January 31.- 1998.
2
. IV.
Date of Full Compliance USEC achieved full compliance on October 19,- 1997, when the autoclave was taken out of service to investigate the reason /cause of the _ actuation. The corrective actions to prevent recurrence will be completed on January 31,-1998.
-?
=
c El-2 '
i 1
~
UNITED STATES ENRICilMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70 7002/97010-02 Restatement of Violation -
Technical Safety Requirement 3.11.2 requires, in part, that all operations involving uranium enriched to 1.0 weight-percent (wt%) or higher U 235 and 15 grams (g) or more of U-235 shall be perfonned r accordance with a documented nuclear criticality safety approval (NCSA).
NCSA PLANT 025.A01," General Use of Small Diameter Containers for Storing up to 10% Enriched Material " requires that when F cans are outside of a nuclear criticality safety (NCS) approved storage area, a minimum spacing of 24 inches edge-to-edge sh-ll be maintained between non-empty cans and all other equipment which holds uranium-bearing material. in addition, the NCSA requires that non-empty cans be capped at all times except when filling, sampling, or emptying containers.
Contrary to the above, on October 16, 1997, two non-empty F-cans located at the low assay withdrawal station were discovered uncapped and within 24 inches of uranium bearing material, I.
Reasons for Violation The reason for the violation was due to a sack of knowledge of the specific requirements imposed by NCSA PLANT 025.A01. Specifically, while facility personnel were aware of the 2-foot spacing requirements imposed by withdrawal specific NCSAs, facility personnel did not know that NCS A-PLANT 025.A01 also applied and imposed additional requirements on the facility which did not exclude "in-service" F-cans. As a result,"in service" F-cans were not spaced 2 feet from other uranium bearing equipment, or appropriately capped when not in use.
II.-
Corrective Actions Taken and Results Achieved 1.
As an immedia'e corrective action, the cans were properly spaced and capped. Two permanent holders were subsequently installed and bolted to the floor at the correct location at the low assay withdrawal station to ensure proper spacing. In addition, cognizant personnel in other locations where F-cans are used were contacted to make them aware of this violation and ensure they were in compliance with NCSA PLANT
- 025, 2,
The following training was provided:
E2-1
l.
l.
- a.
- A group briefmg was held with cognizant personnel to reemphasize the use of procedures, the importance of NCSA compliance, and the expectations of management in terms of NCS compliance, b.
He PORTS General Manager conducted all-hands meetings to ensure employees are aware of the recent problems in the NCS program, the NCS Corrective Action Plan, and the iruportance of being aware of and complying with NCS requirements.
c.
On October 23, 1997, operating instructions were issued to cognizant personnel in the X-333 facility to make them aware that two F-cans were mounted on the floor at the LAW station W/D room, that no uranium bearing materials are to be stored within 2 feet of the cans, and that lids must remain on the can when not in use.
III.
Corrective Steps to be Taken 1.
The need for securing the F-can holders to the floor in other process buildings and at the autoclaves in building X-340 is being evaluated. This evaluation will be completed by January 31,1998, 2.
To provide more specific guidance, the NCSA and implementing procedures are being revised and training provided as explained in the revised NCS Corrective Actions Plan (GDP-97-0217) submitted to NRC on December 22,1997.
IV.
Date of Fu'l Compliance Full compliance was achieved on October 23,1997, when the F-cans were properly stored, lids were properly in place, and instructions were issued. Corrective actions to prevent recurrence are being addressed by the NCS Corrective Action Plan.
E2-2
4 UNITEI) STATES ENRICilMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/97010-03 Restatement of Violation Technical Safety Requirement 2.1.3.4. requires two operable autoclave shell high steam pressure shutdown instrument channels when operating in Modes II, IV, and VI. With one channel inoperable, the Technical Safety Requirement requires that operability be restored prior to initiating a new cylinder heating cycle.
Contrary to the above, between March 3, and September 22,1997, the certificatec initiated new cylinder heating cycles on facility autoclaves with a single operable autoclave shell high steam pressure shutdown instrument channel.
1.
Reasons for Violation The reason for the violation was a TSR technical error during the review of the Safety Analysis Report (SAR)/ Application The reason this condition was not readily apparent to the SME when reviewing the applicable TSR is because sb SAR described two valves which close on a valid signal (i.e., the steam regulator, and ti ? 'rst steam block valve) which was consistent with the condition implied by the TSR.110 wever; the SME erred in not recognizing that the steam regulator is not a safety system isolation valve.
Ilackcround Prior to approval of the certification application document, the SAR and TSR were extensively reviewed for content and efforts were made to ensure the most complete document was submitted to the NRC, llowever, not all errors were identified by the reviewing subject matter experts (SME). In the case of this violation, the error was not detected during the SME review of the TSR. Specifically, the as-built design of the autoclaves and the Safety Analysis Report did not agree with TSR 2.1.3.4. The TSR implies that the high steam pressure shutdown safety feature consisted of" pressure sensing channels and two channels ofisolation valves" when in fact the actual system design consisted of only one channel. The SAR
. correctly described the as-built design as having three pressure switches. One switch was
- dedicated to initiate steam shutdown at a lower set point while the other two were set at a higher pressure to cause a containment shutdown in the event of a UF. release inside the
, autoclave. As' stated above, the reason this condition was not readily apparent to the SME when reviewing the applicable TSR because the SAR described two valves wh.:ch do close on a valid signal, however; the SME did not recognize that the steam regulator was not a safety system isolation valve.
E3-l'
t
' On September 23,1997. PORTS selfidentified this issue and submitted problem report PR-PTS 97 8349, documenting that the autoclaves as built' condition and the SAR Report did not _
agree with TSR 2.1.3.4. The plant responded immediately to the employee's concern and declared all autoclaves inoperable until the condition was resolved.
' Due to the extensive reviews performed in response to a previous viobion, 70 7002/9700?-'
02, and to the circumstances which caused this error, this violation is believed to be an isolmeu occurrence.
II. -
Corrective Actions Taken and Results Achieved 1.
Autoclaves were immediately declared inoperable and an ' Operations Assessment
'i Team'(OAT) was assemoled to review the TSR issue and develop an action plan for restoring autoclave operability.
2.
Redundant pressure instruments were recalibrated on September 24,1997 to actuate at 8 psig. This action modified the autoclave design to match the implied configuration described in the TSR.
3.
The SAR was revised per 10 CFR 76.68 to reflect the changes recorded in action step 3 above and to reflect the implied design specified in the TSR.
4.
Procedures were modified to implement the modifications to the autoclaves and provide operators w'.h actions to take in the event of an alarm or safety system actuation in this new configuration. This action was completed on September 26,1997 111.
Corrective Steps to be Taken None IV.
'Date of Full Compliance USEC achieved full compliance on September 26,1997, when redundant pressure instruments were recalibrated to actuate at 8 psig, thereby providing two operable channels as required by TSR 2.1.3.4.
E3-2 1
4 UNITED STATES ENRICIIMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/97010-04 Restniement of Violatior, Technical Safety '.tequirement 3.10 requires, in part, that the Plant Operations Review Committee shall review and approve or disapprove all nuclear criticality safety evaluations and approvals.
Contrary to the above, between March 3 and September 10,1997, the plant staff made changes to nuclear criticality safety evaluations and approvals, using the engineering notice system, which were
- not reviewed and approved or disapproved by the Plant Operations Review Committee.
'I.
Reasons for Violation USEC has detennined the violation was caused by the misapplication of Engineering Notices in order to expedite clarifications to NCSAs. Step 6.1.5 of XP2 EG-NS1031; " Nuclear Criticality Safety," states "The NCS Section may issue Engineering Notices to provide clarification of any NCS controls specified in NCSAs." The processing of Engineering Notices is controlled by XP2-EG-EG1042, Engineering Notices. In this case, however, the use of Engineering Notices went beyond simply clarifying NCS controls and improperly changed controls, changed the description of fissile material operations, and changed the applicability of NCSAs to different facilities than originally described, 11.
Corrective Actions Taken and Results Achieved 1.
On October 21,1997, the issuance of new Engince-ing Notices was halted by the Engineering Manager. Organization Managers confirmed Engineering Notices were not in use for fissile material operations on December 9,1997.
2.
Fissile Material Operations (FMO) covered b;/ NLSA/Es which were improperly altered by Engineering Notices were either brought into compliance or stopped until compliance was achieved.
3, Engineering Notices from the remaining engineering sections were reviewed to determine if potential violations of the design basis controls had occurred. No additional examples were identified.
E4-1
a-
-i
~ * $ III, 'M Corrective Steps to be Taken '
'i
..~
e, Training on the specific conditions that lead to this violation and the proper use of Engineering
{ Notices _will be provided to Engineering personnel who prepare or process Engineering -:
l Notices by March 16,1998. The use of Engineering Notices will not.be resumed until this.
{
- training has been completed.
IV.-
Date of Full Compliance'-
L Full compliance was confi med on December 9,-1997, wh~en Organization Managers verified Engineering Notices were not in use for fissile material operations, improperly. altered by.
t Engineering Notices.
r f
t E4-2 2 m
m 2.-
l r
^
1 UNITED STATES ENRICilMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV)70-7002/97010-05 ~
Restatement of Violation Technical Safety Requirement 3.9.1 requires that written procedures be implemented to ' cover activities described in Safety Analysis Report 6.11.4.1.
Safety Analyses Report Section 6.11.4.1 states that a procedure is required for any task that implements a commitment described in the Emergency Plan.
The Emergency Plan requires, in part, that the Emergency Plan implementing Procedures will be implemented to ensure that the emergency response equipment and facilities are maintained to enhance emergency preparedness effective response actions taken to mitigate the consequences of an emergency and to protect the health and safety of the public and workers at the plant.
The Emergency Plan Implementing Procedure, XP2 EP-EP5034, Revision 0, " Maintenance of Emergency Facilities and Equipment," Section 6.1, states, in part, that inaudible testing of the Public Warning System (PWS) will be condo.d at least monthly, and that the audible testing is conducted semiannually.
Contrary to the above, from March 3 three n September 26,1997, the certificatee failed to conduct the semiannual and monthly surveillance of the PWS in accordance with implementing procedure XP2-EP-EP5034," Maintenance of Emergency Facilities and Equipment."
1.
Reasons for Violation The reason for the violation was a failure to follow procedure due to a misunderstanding of the resourse requirement to perfonn the PWS Surveillance.
On March 3,1997 a new requirement was implemented oy the Quality Assurance Plan
[section 2.4.2] which requires vendors of Q and AQ systems be certified. - Past surveillances were performed with a PWS vendor representative on plant site to resolve any abnormal conditions following the test. Given the new requirement, the Emergency Management Organization believed that belbre the required PWS surveillance could be performed, a certified vendor representative had to be onsite.. To facilitate the presence of a certified vendor, Emergency-Managemen, began coordinating efforts to help the vendor obtain it's vendors certification. llowever, this action was not completed in time to complete the surveillance within its due date. LAs a result, prior to the NRC inspection, Emergency -
management filed a problem report [PR-PTS-97-8294, dated September 19,1997] to document the inevitable delay of the semi-annual surveillance.
During the NRC inspection of the Emergency Management program, the inspector noted that
, the test had not been performed as required by the emergency plan and questioned the non-~
- conformance. After some discussion, Portsmouth learned that the vendor's presence _was not required to perform the test.' Following the~ discussions, Emergency Management initiated
! actions to test the Public Waming System as required.-
- II.
Corrective Actions Taken and Results Achieved On October 10,1997, Emergency Management conducted an audible semi-annual test of the Public Waming System. The results of the test indicated that all system were functioning as designed.
Ill.
Corrective Steps to be Taken Nonc IV.
Date of Full Copliance Full compliance was achieved on October 10,1997, when the PWS system was tested as required by procedure XP2 EP-EP5034.
E5-2 r-
Encheure 6 IJNITED STATES ENRICHMENT CORPORATION (USEC) l List of Commitments j
h NOV 70 7002/97010-01 1
Guidance will be developed for evaluating safety system actuations and to properly determine l
- a reason for the actu? tion prior to setuming a system to service. This action will be completed by January 31, IL j
NOV 70 7002/97010-02 1.
Th'e need fbr meuring the F can holders to the floor in other process buildings and at the-l l
autoclaves in building X 340 is being evaluated. This evaluation will be completed by January 31,1998.
- 2.
To provide more specific guidance, the NCS A and implementing procedures are being revised
+
and training provided as explained in the revised NCS Corrective Actions Plan (GDP.97 0216) submitted to NRC on December 22,1997. _
2 NOV 70 7002/97010-03 None i
NOV 70 7002/97010-04 i
Training on the specific conditions that lead to this violation and the proper use of Engineering Notices will be provided to Engineering personnel who prepare or process Engineering Notices by March 16,1998. The use of Engineering Notices will net be resumed until this training has been completed.
'NOV 70 7002/97010 01 None
?
i i
E6. I
~
,