ML20198D193
| ML20198D193 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 12/14/1998 |
| From: | Jonathan Brown UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-7002-98-16, GDP-98-2050, NUDOCS 9812230028 | |
| Download: ML20198D193 (4) | |
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0 VCSEC A Clobd Energy Company December 14,1998 GDP 98-2050 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555-0001 Portsmouth Gaseous Diffusion Plant (PORTS)
Docket No. 70-7002 Reply to Inspection Report (IR) 70-7002/98016 Notice of Violation (NOV) 98016-01 The subject IR contained a NOV involving the failure to establish measures to ensure that instruments used to measure the closing time ofisolation valves (Q items) were of the proper type, range, and accuracy. The United Stated Enrichment Corporation response to this NOV is provided in Enclosure 1. Enclosure 2 lists the commitments made in this letter. Unless specifically noted, the corrective actions specified in each enclosure apply solely to PORTS.
If you have any qu.stions regarding this submittal, please contact Peter J. Miner at (740) 897-2710.
Sincerely,
- rp; J. Morris Brown General Manager Portsmouth Gaseous Diffusion Plant
Enclosures:
As Stated
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NRC Region III Office NRC Resident Inspector - PORTS D['
NRC Project Manager - PORTS 9812230028 981214
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P.O. Box 800, Portsmouth, OH 45661 Telephone 614-897-2255 Fax 614-897-2644 http://www.usec.com Omces in Livermore, CA Paducah, KY Portsmouth, OH Washington, DC
c GDP 98-2050 Page1of2 UNITED STATES ENRICIIMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/98016-01 Restatement of Violation Title 10 of the Code of Federal Regulations, Part 76.63, " Quality Assurance," requires, in part that the Corporation shall establish, maintain, and execute a Quality Assurance Program.
Section 2.12 of the Quality Assurance Program, " Control of Measuring and Test Equipment,"
requires, in part, that a system is established for the control of measuring and test equipment for Q items as specified in Section 2.2 of the Quality Assurance Program. Section 2.12 further requires the system establish measures to ensure that instruments and other measuring and testing devices used in activities affecting quality are of the proper type, range, and accuracy.
Quality Assurance Program Section 2.2 and Safety Analysis Report Section 3.8, "Q, and AQ Structures, Systems and Components," establish withdrawal station pigtail isolation and autoclave containment isolation valves as Q items. Safety Analysis Report Section 4.2.3.2, " Pigtail Rupture Accident Analysis," and 4.2.3.4, " Pigtail Gasket Failure Accident Analysis," require the withdrawal station pigtail isolation and autoclave containment isolation valves to close within 5 and 15 seconds, respectively, in order to ensure that accidental releases of uranium hexafluoride remain within the bounds of the accident analysis.
Contrary to the above, from March 3,1997 through October 21,1998, the Corporation did not establish measures to ensure that instruments and other measuring and testing devices used to measure some activities affecting quality were of the proper type, range, and accuracy. Specifically, the Corporation failed to establish measures to ensure that instruments used to measure the closing time, an activity affecting quality, of the withdrawal station pigtail isolation and autoclave containment isolation valves (Q items) were of the proper type, range, and accuracy.
USEC Response I.
Reasons for the Violation The reason for the above violation was a misunderstanding regarding the applicability of Measuring and Test Equipment (M&TE) for the measurement time of Q safety system components. The PORTS Quality Assurance Program (QAP), which became effective on March 3,1997, requires that measures be established to ensure M&TE be of the proper type.
range, and accuracy and that M&TE be used in activities affecting quality. However, Section 2.12.3 of the QAP also states that " Calibration controls are not necessary for rulers, tape measures, levels and other devices if the commercial equipment provides adequate accuracy." PORTS personnel believed that commercially available timing devices (e.g.,
m%2WT":semmMan 1
GDP 98-2050 Page 2 of 2 stopwatches, wristwatches, clocks) had " adequate accuracy." Therefbre, timing devices were not included in the Calibration Program.
II.
Corrective Actions Taken and Results Achieved 1.
On October 21,1998, a Daily Operating Instruction (DOI) was issued directing that controlled M&TE be used for Q, AQ-NCS, and AQ Systems, Structures, and Components (SSCs) testing where timing devices were required.
2.
On October 22,1998, after receipt of calibrated timing devices from the Paducah Gaseous Diffusion Plant, functional tests were begun on the withdrawal station pigtail isolation valves and the autoclave containment isolation valves. Some closure time discrepancies unrelated to the use of uncalibrated timing devices were discovered. In all instances where the closure time acceptance criteria were exceeded, the Plant Shin Superintendent declared the systems inoperable pending further evaluation or corrective actions, as appropriate.
3.
Procedure XP4-TE-IM6715. " Autoclave Air Volume Tank Containment Valve Testing," was revised to require the use of a calibrated timing device for containment valve testing.
III.
Corrective Steps to be Taken 1.
PORTS will review other inspection and test procedures to determine if other test equipment used on Q, AQ-NCS, or AQ SSCs needs to be included in the Calibration Program. This review and a schedule to revise the affected procedures will be completed by February 28,1999.
2.
By May 15,1999, the following Calibration Program procedures will be revised, as necessary, to require the use of a calibrated timing device when conducting maintenance and surveillances on Q, AQ-NCS, and AQ SSCs. Additionally these procedures will be revised to require M&TE for inspection / test acceptance and to define use of commercial equipment.
XP2-GP-GP1044
" Calibration Program" XP2-GP-GP1045
" Measuring And Test Equipment Control And Calibration" XP2-GP-IM6033
" Calibration Of Fixed Instrumentation / Systems" IV.
Date of Full Compliance USEC achieved full compliance on October 24,1998, after isolation valve retesting was completed with calibrated timing devices.
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GDP 98-2050 Page1ofI List of Commitments
- 1.
PORTS will review other inspection and test procedures to determine if other test equipment
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used on Q, AQ-NCS, or AQ SSCs needs to be included in the Calibration Program. This review and a schedule to revise the affected procedures will be completed by February 28,
.1999.
i 2.
By May 15,1999, the following Calibration Program procedures will be revised to require the use of a calibrated timing device wh'en conducting maintenance and surveillances on Q, AQ-NCS, and AQ SSCs. Additionally these procedures will be revised to require M&TE for inspection / test acceptance and to define use of commercial equipment.
XP2-GP-GP1044
" Calibration Program" XP2-GP-GP1045
" Measuring And Test Equipment Control And Calibration" l
XP2-GP-IM6033
" Calibration Of Fixed Instrumentation / Systems"-
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- Regulatory commitments contained in this document are listed here. Other corrective actions listed in this submittal are not considered regulatory commitments in that they are either statements of actions completed, or they are considered enhancements to USEC's investigation, procedures, programs, or operations.
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