ML20198N616

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7002/97-10. Corrective Actions Will Be Examined During Future Insp

ML20198N616
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant
Issue date:	01/14/1998
From:	Hiland P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	John Miller UNITED STATES ENRICHMENT CORP. (USEC)
References
70-7002-97-10, NUDOCS 9801210145
Download: ML20198N616 (1)

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January 14, 1998 >

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Mr. J. H, Miller ,

Vice President- Production United States Enrichment Corporation Two Democracy Center 6903 Rockledge Drive Bethesda, MD 20817

SUBJECT:

- RESPONSE TO INSPECTION REPORT 70-7002/97010

Dear Mr. Miller:

This refers to your December 23,1997, response to Notice of Violation (NOV) transmitted to you by our letter dated November 24,1997, with inspection Report 70 7002/97010. In your response, you acknowledged the violations. We have reviewed your cormctive 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: S. A. Polston, Paducah General Manager J. B. Morgan, Portsmouth Acting General Manager R. W. Gaston, Portsmouth Nuclear Regulatory Affairs Manager S. Toolle, Manager, Nuclear Regulatory Assurance and Policy, USEC Paducah Resident inspector Office Portsmouth Resident inspector Office E. W. Gillespie, Portsmouth Site Manager, DOF.

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Enricinn. ni Corp.,rati..n December 23,1997 United States Nuclear Regulatory Commission GDP-97-2041 Attention: Document Control Desk Washington, D.C. 20555 Pt rtsmouth Gaseous Diffusion Plant (PORTS)

Docket No. 70-7002 Response to Inspection Report (IR) 70-7002/97010 Notice of Violation (NOV)

Nuclear Regulatory Commission (NRC) letter dated November 24,1997, transmitted the subject Inspection Report (IR) that contained five violations involving: 1) inadequate corrective actions to preclude potential recurrence of a safety system actuation,2) F-cans containing uranium bearing material not properly capped,3) initiating cylinder heating without confirming compliance with the TSR,4) use of engineering change notices to modify NCSA requiretnents, and 5) failure to conduct semiannual and monthly surveillance of the Public Warning System.

USEC's response to these violations is provided in Enclosures 1 through 5, respectively and Enclosure 6 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-tenn and long-temi improvements to our NCS program. Therefore, this response addresses only USEC actions regarding the specific deficiencies for these cited violations, jfyntf;0n /M' osc :: 1m o,,e.s.e, m ,ces x,,,,ec,, m,,smee,n ns., e - .--.,- , -

11nited States Nuclear Regulatory Commission December 23,1997 Page 2 If you have any questions regarding this submittal, please contact Ron Gaston at (614) 897 Sincerely, am Acting General Manager Portsmouth Gaseous Diffusion Plant Enclosures (6) cc: NRC Region 111, Regional Administrator NRC Resident inspector, PORTS 1

Enclosure 1 UNITED STATES ENIUCIIMENT CORPORATION (USEC) l REPLY TO NOTICE OF VIOLATION (NOV) 70 7002/97010-01 i 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 1-1989," Quality Assumnce Program Requirements for Nuclear Facilities."

ASME NQA-1-1989 Basic Requirement 16," Corrective Action," states that conditions adverse to quality shall be identified promptly 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, withcc verifying the root cause and taking action to preclude recurrence.

I. Reasons for Violation The reason for the violation was due to a hek 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 rnade an error in judgement and failed to make a conservative decision to declare the autoclaves out of service following the safety actuation. Additionally, the FSS 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.

Background

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 in Mode IV, feeding a Uranium Hexafluoride (UF.) cylinder to the enrichment cascade, when an audible and visual alarm for steam shutdown was received. Operators responded to the alarm and discovered that the Autoclave Shell High Pressure Containment Shutdown (ASHPCS) safety system had actuated in addition to the Autoclave Shell High Steam Pressure Shutdown (ASHSPS) safety system.

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 alanns were reset after verifying that all containment El- 1

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valves had actuated as designed thus confirming operability of the containment safety feature.

The autoclave was then opened and inspected and no abnormal conditions were identified.

Since the PSS believed the safety systems were functional and that the actuation did not appear to be due to a signal associated with a design basis acciuent or high temperature condition, operators closed the autoclave, restarted the steam, and continued with she cylinder feed cycle.

In addition, because the autoclave safety system actuation was assumed to be due to rising steam pressure only (no UF. release ' avolved) and because the autoclave contained a hot liquid cylinder, the on-duty PSS believed v wrt safer to continue feeding the cylinder to remove the liquid UF. from the autoclave prio. . trking 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). However the PSS did not take immediate action to clearly establish the reason for the actuation.

!!. Corrective Actions Taken and Results Achieved I, On November 27, 1997 the PSS organization was instmeted, vis Department 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. This instruction will remain in place until adequate guidan:e provided to personnel for invectigating safety system actuations.

2. Required reading was developed for the PSS to communicate the lessons learned associated with this event. This action was completed November 29,1997.

III. 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 returning a system to service. This action will be completed by January 31,1998.

1 IV. Date of Full Compliance i i

USEC achieved full compliance on October 19,1997, when the autoclave was taken out of

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service to investigate the reason /cause of the actuation. The corrective actions to prevent recurrence will be completed on January 31,1998.

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1 Enclosure 2 UNITED STATES ENRICIIMENT CORPORATION (USEC)

REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/97010-02 RestMement of Violation Technical Safety P.equirement 3.11.2 remires, 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 performed in 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 shall 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-besing material.

I. Reasons for Violation The reason for the violation was due to a lack 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 NCSA-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.

IL Corrective Actions Taken and Results Achieved

1. As an immediate corrective action, the cans were properly spaced and capped. Two permaner.t holders were subsequently mstalled and bolted to the floor at the correct location at the low assay withdrawal station to ensure proper spacing. In addition, cognizant personnel in otlwr locations whu F-cans are used were contacted to make them mvare of this violation and ensure they were in compliance with NCS A PLANT 025.

2. The following training was provided:

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a. A group briefing 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. The PORTS General Manager _ conducted all-hands meetings to ensure -  ;

employees'are aware of the recent problems in the NCS program, the NCS I

Corrective Action Plan, and the importance of being aware of and complying with NCS requirements.

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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 umain ' ,

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 f.he 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 pmvided as explained in the revised NCS Corrective Actions Plan (GDP-97-0217) submitted to NRC on December 22,1997.

'IV. Date of Full Compliance-Full compliance was achieved on October 23,1997, when the F-cans were paperly stored, lids were properly in place, and instructions were issued. Corrective actions to prevent recurrence are being addressed by the NCS Corrective Action Plan.

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Enclosure 3 UNITED STATES ENRICHMENT 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 instmment 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 certificatee inidated new cylinder heating cycles on facility autoclaves with a single operable autoclave shell high steam pressure shutdown instrument channel.

I. 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 4 SME when reviewing the ac: cable TSR is because the SAR described two valves which close on a valid signal (i.e., me steam regulator, and the first steam block valve) which was consistent with the condition implied by the TSR. However; the SME erred in not recognizing that the steam regulator is not a safety system isolation valve.

Backcround Prior to approval o. te certification application document, the SAR and TSR were extensively reviewed tor content and efforts were made to ensure the most complete document was submitted to the NRC. However, 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 which do close on a valid signal, however; the SME did not recognize that the steam regulator was not a safety system isolation valve.

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On Septer.iber 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 :noperable until the cos.dition was resolved.

Due to the extensive reviews performed in response to a previous violation, 70-7002/97002-02, and to the circumstances which caused this error, this violation is believed to be an isolated occurrenCC.

II. Corrective Actions Taken and Results Achieved

1. Autoclaves were immediately declared inoperable and an Operations Assessment Team (OAT) was assembled 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 reucct 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 with 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 III. 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.

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Enclosure 4 UNITED STATES ENRICHMENT CORPORATION (USEC)

REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/97010-04 Restatement of Violation Technical Safety Requirement 3.10 requires, in part, that the Plant Operations Review Committee shall review and approve or disapprove all r.uclear criticality safety evaluations and approvals.

Contrary to the above, between March 3 and September 10,1997, the plant staff made changes to nuclear cdticality 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 l

,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 ditTerent facilities than originally described.

II. Corrective Actions Taken and Results Achieved

1. On October 21,1997, the issuance of new Engineering Notices wai falted by the Engineering Manager. Organization Managers confirmed Engineerig, notices were not in use for fissile material operations on December 9,1997.

2. Fissile Material Operations (FMO) covered by NCSA/Es which were improperly altered by Engineering Notices were either brought into coa.plianc- or stopped until l 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.

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III.. Corrective Steps to be Taken

4 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 not be resumed until this training has been completed.

IV. Date of Full Compliance Full compliance was confirmed on December 9,1997, when Organization Managers verified

' Engineering Notices were not in use for fissile material operations, improperly altered by '

Engineering Notices.

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I Enclosure 5 UNITED' STATES ENRICIIMENT CORPORATION (USEC)

REPLY TO NOTICE OF VIOLATION (NOV)70-7002/97010-05 Restatement of Violation Technical Safety Requirement 3.9.1 requires that written pr.>cedures 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 comraitment described in the Emergency Plan.

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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 eme gency 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 Waming System (PWS) will be conducted at least monthly, and that the audible testing is conducted semiannually.

Contrary to the above, from March 3 through 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 reascn for the violation was a failure to follow procedure due to a misunderstanding of the resourse requirement to perform the PWS Surveillance.

On March 3,1997 a new requirement was implemented by 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 ebnormal conditions following the test. Given the new requirement, the Emergency Management Organization believed that before the required PWS surveillance could be performed, a certified vendor representative had to be onsite. To facilitate the presence of a certified vendor, Emergency Management began coordinating efforts to heir the vendor obtain it's vendors certification. However, this acticn was not completed in time to complete the surveillance within its due date. As a result, prior to the NRC inspection, Emergency manttgement filed a problem report (PR-PTS-97-8294, dated September 19,1997] to ,

document the inevitable delay of the semi-annual surveillance.

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4 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 leamed that *.he vendor's presence was not required to perform the test. Following the discussions, Emergency Management initiated -

actions to test the Public Warning 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 Warning System. The results of the test indicated that all system were functioning as designed.

III. Corrective Steps to be Taken None IV. Date of Full Compliance Full compliance was achieved on October 10,1997, when the PWS system was tested as required by procedure XP2-EP-EP5034.

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