ML20198N607
| ML20198N607 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 01/15/1998 |
| From: | Hiland P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | John Miller UNITED STATES ENRICHMENT CORP. (USEC) |
| References | |
| 70-7001-97-12, NUDOCS 9801210142 | |
| Download: ML20198N607 (1) | |
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January 15, 1998 Mr. J. H. Miller Vice President = Production United States Enrichment Corporation Two Democracy Center 6903 Rockledge Drive Bethesda,MD 20817
SUBJECT:
RESPONSE TO PADUCAH IN6$9CTION K5 PORT 70 7001/J7012
Dear Mr. Miller:
This refem to your December 23,1997, respon se to Nouco of Violation (NOV) transmitted to you by our letter dated November 26,1997s with Paducah inspection Report 70=7001/97012. In your response, you acknowledged the violation. We have rev'mwed your corrective actions for the violation 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 J. Kniceley for Patrick L. Hiland, Chief
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Fuel Cycle Branch Docket No. 70 7001 cc:
S. A. Polston, Paducah General Manager W. E. Skyes, Paducah Regulatory Affairs Manager 3
j J. B. Morgan, Portsmouth Acting General Manager S. Toolle, Manager, Nuclear Regulatory Assurance fi and Policy, USEC Paducah Resident inspector Office Portsmouth Resident Inspector Office J. C. Hodges, Paducah Site Manager bec w/itr dtd 12/23/97:
R. Pierson, NMSS P. Ting, NMSS W. Schwink, NMSS P. Harich, NMSS k
M. L. Hom, Project Manager-Paducah, NMSS R. Bellamy, RI l
E. McAlpine, Ril F. Wenslawski, RIV/WCFO PUBLIC (IE 07) l]l 2100fj9 DOCDESK DOCUMENT NAME: G:\\SEC\\ PAD 97012.RES To sneebee e espy of thle doeu,,,ent bersee b the ben:"C* = Copy without enclosure *E* = Copy with enctonuto*N* = No c^ py OFFICE Ritt b
Rlli NAME KniceJey:Ib MIL-Hiland Q% h j
1 DATE Ot!W98 01/\\s/98 9901210142 900115 OFFIC/AL RECORD COPY PDR ADOCK 07007001 C
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A Glebal E.cgy Company Deember 23,1997 -
United States Nuclear Regulatory Commission SERIAL: GDP 97-1052 Attention: Document Control Desk Washington, D.C. 20555-0001 Paducah Gaseous Diffusion Plant (PGDP)
Docket No. 70-7001 Response to Inspection Report (IR) 70-7001/97012 Notice of Violation (NOV)
The Nuclear Regulatory Commission's (NRC) letter dated November 26,1997, transmitted the subject IR which contained one NOV. The United States Enrichment Corporation's (USEC) response to this violation is provided in Enclosure 1. Enclosure 2 lists the commitments made in this report.
If you have any questions regarding this submittal, please contact Bill Sykes at (502) 441-6796.
Sincerely, h
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Steve Polstor.
General Manager Paducah Gaseous Diffusion Plant SP:SRC: mig
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Enclosures (2) cc:
NRC Region 111
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f-NRC Senior Resident inspector, PGDP 11ll Ill,I!ll!L11Il
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P.O. Box 1410 Paducah, KY 42001 Telephone 502-4415803 Fax 502-441-5801 http://www.usec.com Omces in Livermore, CA Paducah, KY Portsmouth OH Washington, DC
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4 ENCLOSURE 1 UNITED STATES ENRICIIMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7001/97012-01 Technical Safety Requirement 3.9, requires, in part, that written procedures shall be implemented for activities described in the Safety Analysis Report, Section 6.11.4, and listed in Appendix A to Section 6.11.
Safety Analysis Report, Section 6.11, Appendix A, describes a partial list of activities that shall be covered by written procedures including work control, management control, chemical safety, and radiation protection.
Procedure CP2-SH-SH 1031, "Confmed Space Program," required, in part, that work activities conducted in confined spaces, shall be conducted in accordance with an approved and issued confine space or confined space downgrade certificate. Confined space downgrade Certificate Number 97-335-18 required the buddy system, an employee stationed outside the confine space, be in;plemented for work activities in Building C-335, Unit 4, Cell 8. In addition,if a worker station d outside the confined space was not in visual contact with the entrants, one of the entrants had to have a plant radio.
!'rocedure CP2-GP-GP1032," Main % nance Work Activities," required,in part, that maintenance work packages undergo a management review prior to release for maintenance work activities to ensure the maintenance work package instructions were edequate.
I Procedure CP2-SH-Ill1036," Respiratory Protection Program," required, in part, that if respiratory protection equipment allowed, the respirator wearer performed a negative and positive pressure fit check for 10 seconds each, to verify the respirator seal cach time the respiratoris donned or adjusted.
Violation Cited Contrary to the above, maintenance and work control activities were not performed in accordance with documented procedures appropriate to the circumstances in the following examples.
A.
On October 7,1997, engineering troubleshooting activities in building C-335 Unit 4, Cell 8, were performed in a downgraded confine space without having an employee stationed outside the downgraded confine space entry. The entrants into the downgraded confined space were also out of visual contact and did not take a plant radio into the downgraded confined space.
- B.
On October 10,1997, Maintenance Work Package (MWP) No. R9702287, for installing building C-360 autoclave conductivity cell time delays, was available for maintenance El-1 l
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work and did not reference an appropriate test and acceptance criteria procedure for the post maintenance test of the 30-second time delay modification. The MWP had been reviewed by management and was issued with inadequate instructions for the post maintenance testing of the autoclave modification.
C.
On October 7 and 8,1997, workers did not perform a 10-second positive and negative pressure fit check on respiratory protective equipment prior to performing maintenance and work activities. The respiratory protection equipment being used would have allowed the fit checks to be perfomied.
USEC Response to Exampic A 1.
Reason for Violation The reason for the violation was the administrative control of downgraded confined spaces was confusing. As a result, personnel, primarily in Engineering, failed to understand the entry requirements.
The individuals involved in this example of the violation reviewed the work package and failed to follow the requirements of the downgrade certificate. The downgrade certificate was not reviewed in detail prior to entering the confined space. The individuals noticed the DOWNGRADING OF PERMIT posting in the work package and incorrectly considered this a relaxation of the individual entry requirements of a confined space. The format of the downgrade posting sign de-emphasized the entry requirements.
II.
Corrective Actions Taken and Results Achieved 1.
The Enrichment Plant Manager issued a plant-wide confined space stop work order on October 9,1997. (This order required a stand-down on alljobs involving work in any confined spaces until personnel were briefed on the incident and the procedural requirements for entering confined spaces. A follow-up survey was conducted with 78 people to determine if they received the briefing and to find out their understanding of key issues. This tasked was completed on October 17,1997.)
2.
13ctween October 11 and 17,1997, managers increased field observations of their personnel entering confined spaces. No procedure violations were observed.
3.
Coaching and counseling was completed on October 11,1997, with the engineering personnel who violated the confined space procedure requirements.
4.
Crew briefings on the event with System Engineering personnel were completed on October 10,1997.
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- Si LThe Confined Space Downgrade Certificate format was revised on October 30,b
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m 1111.1 Corrective Actians to be Takan;
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Date of Full Cnmnliance
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( USEC achieved full compliance on October 7,1997, when the. engineering personnel
' who violated the procedure exited the downgraded confined spade.
USEC Response to Example B:
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Pa==an for Violation -
The violation was caused by inattention to detail by the modification designer and a less than adequate maintenance work activities procedure, ne designer failed to verify the conect revision of the Post-Maintenance Test (PMT) procedure referenced in the MWP when he released the package for work. In' addition, the procedure had no checks or sign-
- offs by Engineering holding them accountable for the adequacy of the MWP PMT
- tequirements. Sign-offs verifying package accuracy is an accepted industry practice, s
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11.
Corrective Actions Taken and Results Achieved
-1.
As discussed in the Inspection Report, a stop work order was issued for the PMT section of the maintenance work package. Subsequently, signature points were >
placed in the associated work packages for the 30-second time delay modification
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in C-360 on October 16,1997. (This signature point required the Modification-Manager to ensure the correct procedure was used for operability testing.)
I 2.
Information was circulated to Engineering Managers on October 16,1997, j
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- ensuring that work packages associated with modifications in progress (which
. require operability testing) have a modification manager signature point to verify the proper PMT revision.- (his action was taken to ensure that Engineering reviews and sign-offs are accomplished for modification packages before release.)
- 3. _
Crew briefings with design engineers on this event were completed on October 31,1997J
' The work control procedure, CP2-GP-GP1032, Rev.1, was revised and
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implemented on December 19,1997, to require a PMT signature point -
'l l verification sign-off for Engineering. This sign-ofTholds Engineering accountable for MWP PMTaccuracy.
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Corrective Actions to be Taken Nonc IV.
Date of Full Compliance USEC achieved full compliance on Octob:r 10,1997, when the stop work order was issued for the PMT section of the maintenance work package (This is noted in the inspection Report). The corrective action to prevent recurrence was completed on December 19,1997.
USEC Response to Example C I.
Reason for the Violation The reason for this violation was a lack of knowledge on the part of some personnel regarding the respirator fit check requirements. Additionally, the procedure requirement to complete a 10 second fit check was not emphasized in training. That was because ANSI Z88.2-1992 does not require a 10-second fit check. This led to some confusion.
The respirator use procedure, CP2-SH-IH1036, was mere stringent than required.
Not all personnel who were intersiewed were deficient in this knowledge. The maintenance and operations personnel who use respirators regularly are more familiar with the procedure requirement to do a fit check. Some of the system engineering personnel had an inadequate knowledge of respirator fit check requirements.
II.
Corrective Actions Taken and Results Achieved 1.
Specific field observations were conducted by selected managers to check compliance with procedures between October 11 to October 17,1997.
2.
PGDP evaluated the 10-second respirator fit check requirement and concluded that a specific time is not required. This evaluation was completed on December 17,1997.
3.
The Enrichnunt Plant Manager instructed functional organization managers to remind qualified respirator wearers of the requirement to perform a 10-second fit check.
111.
Corrective Actions to be Taken 1.
PGDP will revise CP2-Sil lH1036, Rev. O, to remove the 10-second fit check requirement February 12,1998.
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Date of Full Compliance -
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The last known non-compliance with the 10-second fit check requirement wm on
- October 8,1997, which was the subject of this violation. PGDP management will.
enforce the 10-second requirement until the procedure is changed. The corrective action ~
to prevent recurrence will be complete on February 12,1998.
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- ENCLOSURE 2.
j LIST OF COMMITMENTS
- EnclAsure l' Example A
. Nonet Example B -
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- Example C.
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. PGDP will revise CP2-Sii-Ili1036, Rev,0, to remove the 10-second fit check --
requirement February 12,1998.
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