ML20198H102
| ML20198H102 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 01/08/1998 |
| From: | Hiland P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | John Miller UNITED STATES ENRICHMENT CORP. (USEC) |
| References | |
| 70-7001-97-08, 70-7001-97-8, NUDOCS 9801130198 | |
| Download: ML20198H102 (2) | |
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2 January 8, 1998 l
Mr. J. H. Meer i
Vice President Production
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i United States Enrichment Corporation Two Democracy Center 9903 Rockledge Drive
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Bethesda, MD 20017
SUBJECT:
RESPONSE TO PADUCAH INSPECT 60N REPORT 70 7001/97000 Dear Mr. Miller; This refers to your December 221997, response to Notice of Violation (NOV) transmitted to you by our letter dated November 20,1997, with Paducah inspection Report 70 7001/97008. In your response you Wr;if;I the cited violations. We have reviewed your corrective actions for the violations and have no further questions at this time. Your conective actions will be examined during future inspections.
If you have any questions, please contact me et (630) 829 9603.
- Sincereh, Original Signed by i
Patrick L Hiland, Chief Fuel Cycle Branch Docket No. 70 7001 oc:
J. C. Hodges, Paducah site Manager, DOE
- 8. A. Folston, Paducah General Manager J. B. Morgan, Portsmouth Acting General Manager W. E. Skyos Paducah Regulatory Affairs Manager S. Toolle, Manager Nudear Regulatory Assurance and Policy, USEC Paducah Resident inspector Offlos Portsmouth Resident inspector office See Attached Distribution i
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USEC A GMd Enngy Company December 22.1997 L
United States Nuclear Regulatory Commission SERIAL: GDP 971055 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 Notlees of Violations (NOVs)
The Nuclear Regulatory Commission (NRC) letter dated November 20,1997, transmitted the subject IR which contained four NOVs. United States Enrichment Corporation's (USEC) response to these violations is provided in Enclosures 14. Enclosure 5 lists the commitmen's made in this report. Unless specifically noted, the corrective actions specified in each encio.ure c
apply solely to PGDP.
If you have any questions regarding this submittal, please contact Bill Sykes at (502) 441 6796.
Sincerely, ve Polston General Manager Paducah Gaseous Diffusion Plant t
SP:SRC: mig Enclosures (5) ee:
NRC Region !!!
NRC Senior Resident inspector, PGDP 110. Box 1410, Paducah, IG' 42001 Telephone 502-4415803 l'as 502 4415801 http://www.usec.com Omces in 1.ivermore. CA Paducah. kT Portsmouth. OH Washington. DC kt Mb/
ENCLOSURE 1 UNITED STATES ENRICllMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70 7001/97008-01 Technical Safety Requirement 3.9.1 requires,in pan, 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, procedures managemect (use) as an activity that shall be perfomied in accordance with approved procedures.
Procedure CP2 PS PS1038,"Use of Procedures at PGDP,"rer res,in part, that the first line manager must approve and document, in the logs, the reason for and the special entry and exit points for use of a partial procedure.
Violation Cited Contrary to the above, on July 27,1997, the certificatee failed to document the reason for and the special ci,try and exit points for panial procedures used during restart of the purge cascade.
USEC Response 1.
Ilpekcround Infom1ation 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.
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 a special entry point several steps into the procedure. However, the requirement of step 6.1.9 of CP2 PS PS1038,"Use of Procedures at PGDP," to document the reason foi the special entry point in the procedure, work package or narrative log book was not performed.
II.
Reason for Violation The reason for the violation was the training method on the requirements of CP2 PS-PS1038,"Use of Procedures at PGDP," was not adequate regarding the documenhtion requirements for use of a partial procedure. More than a dozen managers in various groups in Operations, Maintenance, and Engineering were surveyed to detennine their understanding of the special use requirements of this procedure. The majority of those personnel were nc t familiar with the special use requirements of CP2 PS-PS1038. Most did not believe there was any flexibility in the requirements for using procedures. These personnel would follow procedures as written.
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/ contributing cause to this violation was the lack of a procedure for recovery from a loss of high speed cells.
111.
Corrective Actions Taken and Results Achieved I.
On July 21,1997. CP4 CO CN2017 was exited and the procedure was no longer applicable.
i 2.
A crew briefing training package has been developed describing this deficiency and the requirements of CP2 PS PS1038,"Use of Procedures at PGDP."
Training using this package is ongoing.
IV.
Corrective Actions to be Taken 1.
PODP will conduct crew briefings on this particular deficiency and the requirements of CP2 PS PS1038,"Use of Procedures at PODP," for appropriate managers in Operations, Maintenance. and Engineering. This will be completed by March 6,1998.
2.
PODP will issue a procedure for recovery from loss of high speed cells by May 22,1998.
3.
PODP will revise appropriate Training Development Administrative Guidelin s to include trairiing on CP2 PS PS1038,"Use of Procedures at PGDP." Thia will be completed by July 31,1998.
V.
Date of Full Comnliance USEC achieved full compliance on July 21,1997, after 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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4 ENCLOSURE 2 UNITED STATES ENRICliMENT CORPORATION (USEC)
REPLY TO NOTICE OF VlOI.ATION (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, nonnal operations, and abnomial 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 startup, shutdavn, normal operations, and abnonnal operations as described by the following examples:
A.
On September 2,1997, operations management used an outdated procedure, CE 16,
" Emergency Opera' ions in Building Fires," during their oversight of the response to a small fire in building C 310.
D.
As of September 30,1997, numerous controlled manuals of plant procedures included canceled and outdated operations nonnal, off nonnal, and emergency procedures.
USEC Response 1.
Backcround The administrative controls for maintenance ofcontrolled procedure manuals ad other documents are defined in the " Document Control Program" procedure, UE2 'IO SM 1030.
'lhe following is a summary of those controls as they apply to this NOV.
The Document Control organization or the Procedure Control Organization transmits controlled copies 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," These documents are transmitted using a " Transmittal / Receipt Acknowledgment" fbnn. The Controlled Copy lloider verifies the infonnation on the new Controlled Copy agrees with that on its associated transmittal form and fbilowing the transmittal form instructions, replaces the superseded documents. The removed / superseded documents are dispositioned as directed by Transmittal / Receipt Acknowledgement fonn or otherwise as approved by Document Control. The Controlled Copy lloider signs and dates the E2-1 y
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transmistal fonn acknowledging receipt of the documents and retums 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 proHems in other controlled procedure manual sets. Thirty-eight problem repons 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 repon 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 violation.
11.
Reason for Violation ne reason for this violation was a failure to follow the required procedural / administrative controls for updating the procedures. A contributing cause was the lack of enforcement of accountability for properly updating controlled procedure manuals.
111.
Carrective Actions Taken and Results Achieved 1.
The Cascade Standard Opersion Procedure Manuals were reviewed and corrected by Cascade Operations personnel by October 6,1997.
2.
The Enrichment Plant Manager 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 reports were generated by multiple organizations on site. These problem report discrepancies identified were correctcd by November 13,1997.
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IV. Corrective Actions to be Taken l.
Document Control will impivment a self assessment program ofcontrolled documents as addressed in 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 mainteiiance of controlled documents as an ofTense subject to escalated levels of disciplinary actions. This will be completed by April 15, 1998.
3.
USliC currently has an ongoing cfron to supplement controlled procedure manual sets with a controlled electronic on line procedure version. This efTort will allow reduction of the number of controlled copies and reduce the reliance on manual update ofprocedures. This effott is expected to be completed by June 30,1998.
V.
Date of Full Comnllanss USEC achieved full compliance when the procedures cited in the violation were updated by October (i,1997. Corrective actions to prevent recurrence will be completed by June 30,1998.
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i ENCLOSURE 3 UNITED STATES ENRICIB1ENT CORPORATION (USEC)
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 implemented to cover the activities described in Safety Analysis Report, See:lon 6.11.4.1.
Section 6.11.4.1 of the Safety Analysis Report states,in part, that: "As a minimum, a procedure is required for any task that is described in, or implements a commitment that is described in, the Safety Analysis Repon..."
Section 6.8.2.4 of the 3afety Analysis Report," Problem Reporting," states, in part, that: "All plant employees have the responsibility to write problem reports on safety, operating, and noncompliance iterns... Corrective actions are tracked through the plant's corrective action program."
Procedure UE2 liR-C11030," PROBLEM REPORTINO," Revision 0, dated April 10,1996, identifies " false alarms or false actuations related to safety system items" and " violations of, or deviations from, programs, policies, and procedures or deficiencies which could cause safety, operability, or reportability concems" as problems requiring a problem report (PR). Step 6.1.3C requires that the problern report form be delivered to the Plant Shift Superintendent as soon as practical, but always prior to the end of the shin.
Violation Cited Contrary to the above, the cenificatee failed to deliver problem report fomis to the plant shift superintendent by the end of the shlll 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.
II.
A deviation from the procedurally required criticality safety posting for a fissile vacuum and its lose in building C-310 on September 23,1997.
C.
A deficient independent verification of assay fonn (missing originator signature) discovered in building C-400 on September 24,1997.
D.
The identification on September 24,1997, that the certificatee had not perfomied load tests aller moditications to two NCil-35 cylinder haulers were made in September and October 1996.
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USEC Response l.
Reason for Viol ttjnn llased upon interviews with plant personnel, USEC has detennined 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 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 benefits of the system. Additionally, a plant wide bulletin was prepared and issued. 'Ihis bulletin dealt with the specific problem of a lack of awareness of the requirements for writing a problem report. This information has increased discussion site wide on when a problem report should be written and prompted discussion on changes to the system.
Ill.
Conective 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, Date of Full CorupJlDILCI USEC has taken ef1brts 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 ColU' ORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7001/97008 08 l
Title 10 of the Coe of Federal Regulations, Pr 76.68 (b) requires, in pan, 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).
i Violation Cited Contrary to the above, between August 13 and September 5,1997, the eenificatee failed to i
evaluate the safety impact of as found nonconfortnances identified in the purge cascade, a system described in the Safety Analysis Repor;, plant programs, plans, and operations.
USEC Response 1.
Backcround Information On August 13,1997, purge cascade valve sizes were discovered to be difTerent than that shown on a plant drawing. Specifically, the actual size of the valves was found to be 2 i
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 i
and Plant ShlR 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, therefore, system operations were continued.
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'lhe Problem Reporting Procedure requires that a Nonconformance Repon Form (UE-685) should have been initiated along with the problem report. This is noted in the inspection Repsd. This omission was an oversight on the part of the system engineer.
Following initial processing of the problem report by the Plant ShlR Superintendent, the Shift Engineer then performed a screening for potential Unreviewed Safety Questions (USQ), This review was intended as a Part 76.68 (b) screen; however, the existing procedural guidance for the USQ screening was not detailed and prescriptive enough to fully achieve the intent of Part 76.68 (b). This led to an inadequate screening of the nonconformance.
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Reason for Violation The reason for this violation was that procedural guidance for screening problem reports for Part 76.68 (b) issues was insufriciently detailed. Specifically, PGDP did not provide adequate procedural guidance to shin personnel to ensure that nonconforming conditions are evaluated in accordance with 10CFR76.68 in a timely and thorough manner. Ilad the system engineer or shin engineer documented a thorough 76.68(b) screening on the day the Problem Report was tumed in, this violation would have been avoided.
111.
Corrective Actions Taken and Results Achieved 1.
The System Engineer completed an engineering evaluation on the nonconfonning 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 Shih 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 / Shin Engineers is provided to better clarify the definition of "nonconformance' in order to drive the thnely disposition of these problems via the existing process.
3.
Problem Reporting procedure UE2.llR.C11030 was changed on November 14, 1997, to augment the Shin Engineer problem report screening actions such that potential Part 76.68 (b) issues are app.opriately reviewed in a tirnely manner.
IV. Corrective Steps 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 nonconfonning conditions. Final incorporation into procedures will be accomplished by March 26,1998.
V.
Date of Full Comp!!ance USEC achieved full compliance with the requirements cited in this violation on September 5,1997, when Engineering completed the evaluation of the nonconfonning condition in accordance with Part 76.68. Corrective actions to prevent recurrence will be complete on March 26,1998.
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ENCLOSURE 5 LIST OF COMMITMENTS
- 1. PODP will conduct crew briefings on this particular deficiency and the requirements of CP2-l PS PS1038,"Use of Procedures at PODP." for appropriate managers in Operations, Maintenance, and Engineering This will be completed by March 6,1998.
- 2. PODP will issue a procedure for recovery from loss of high speed cells by May 22,1998.
- 3. PODP will revise appropriate Training Development Administrative Guidelines to include training on CP2 PS PS1038,"Use of Procedures at PODP." This will be completed by July 31,1998
- 1. Document Control willimplement a self assessment program orcontrolled procedure manuals as addressed in the Docunut Control Program procedure by April 15,1998. Tne 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 ofTense sulpet to escalated levels of disciplinary actions.
This will be completed by April 15,1998.
- 3. USEC currently has an ongoing effort to supplement controlled procedure manual sets with a controlled electronic on line procedure version. This effort will allow reduction of the number ofcontrolled copies and reduce the reliance on manual update ofprocedures. This effort is expected to be completed by June 30,1998.
- 1. The Problem Reporting Fonn included in procedure UE2 HR-C11030,"Probleni Reporting."
will be revised by February 28,1998, to specify the time requiremerits 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 nonconfonning conditions. Final incorporation into procedures will be necomplished by March 26,1998.
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