ML20199D281
| ML20199D281 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 01/22/1998 |
| From: | Polston S UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-7001-97-11, GDP-98-1002, NUDOCS 9801300180 | |
| Download: ML20199D281 (12) | |
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I USEC A Globet Energy Company -.
January 22,1998 United States Nuclear Regulatory Commission SERIAL: GDP 98-1002 Attention: Document Control Desk Washington, D.C. 20555-0001
' Paducah Gaseous Diffusion Plant (PGDP)
Docket No. 70-7001 Response to Inspection Report (IR) 70-7001/97011 Notices of Violation (NOVs)
The Nuclear Regulatory Commission (NRC) letter dated December 9,1997, transmiited the
.subiect IR which contained three NOVs. The United States Enrichment Corporation's (USEC)
' respaw.c to these violations is provided in Enclosures 1-3. Enclosure 4 lists the commitments made in this report. Unless specifically nott
' orrective actions specified in each r closure apply solely to PGDP.
Pursuant to a discussion between Steve Cowne of USEC and Ken O'Brien on December 16, 1997, the due date for this submittal was extended to January 22,1997.
If you have any questimis regarding this submittal, please contact Bill Syies at (502) 441-6796.
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Sincerely, D
$b eve Polston General Manager Paducah Gaseous DitTusion Plant SP:SRC: mig 3gyyC3 Enclosures (4) m NRC Region HI llllllllllllll lllllll NRC Senior Resident Inspector, PGDP 9001300100 900122 PDR ADOCK 07007001 C
PDR PO. Box 1410, Paducah, IG 42001 1
Telephone 502-441-5803 Fax 502-441-5801 http://www.usec.com l
Offices in Livermore, CA Paducah, KY Portsmouth, OH Washington, D^
l
4 ENCLOSUIE UNITED STATES ENRICllMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7001/97011-01 Technical Safety Requirement 3.9.1 requires, in part, that written procedures be prepared and implemented to cover the activities described in Safety Analysis Report (SAR) Section 6.11.4.1 and listed in Appendix A to SAR Section 6.11.
Appendix A to SA?. Section 6.11 identifies " investigations and reporting" as an activity requiring an administrative procedure.
Step 6.1.2 of Procedure UE2-RA-RE1030," Nuclear Regulatmy Event Reporting," Revisicn 2, dated February 28,1997, requires that the plant shift superintendent (PSS) review problem reports and determine reportabP.ity of the event or condition using Appendix D. Step 6.2.1E of the procedure requires t'lat the PSS verbally notify the appropriate NRC office within the time requirements shown in Appendix D.
Appendix D of Procedure UE2 RA-RE1030,"NRC Reporting Criteria," specifies the criteria and reporting time for events and conditions. Specifically, the following criteria and reporting times are identified:
Criterion J.l.a requires, in part, a 24-hour report for an event ia which equipment is disabled or fails to function when it is required by Technical Safety Requirement (TSR) to mitigate the consequences of an accident; is required by TSR to be available and operable arbither should have been operating or should have operated on demand; and no redundant equipment is available and operable to perform the required safety ftmetion.
Criterion A.2.c requires, in part, a four-hour report for operations that comply with the double contingen:y principle in which moderation is used as the primary citicality control a'id where it is determined that a criticality safety analysis was deficient and the necessary controlled parameters were not established or maintained.
Criterion L.4 requires, in part, an immediate report (within one hour) for any infractions, losses, compromises, or possible compromise of classified information or classified documents.
Violation Cited Contrary to the above, investigation and reporting activities were not performed in accordance with the written procedure. Specifically, the certificatee failed to determine the reportability of J
the event and notify the appropriate NRC office within the time requirement shown in Appendix D in the following examples:
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A. -
On October 17,1997, an event occurred causing a loss of power (tripped breaker) for the Building C-310 high-voltage process gas leak detection (PGLD) system alarms required by TSR 2.3.4.4 to be operable and available to mitigate the consequences of c< necident (release) and for which there was no redundant equipment. The certificate did not report the event until October 20,1997, a period exceeding the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> reporting requirement of Criterion J.l.a.
On October 18,1997, an event occurred causing a loss of power (tripped breaker) for the Building C-310 high-voltage PGLD systen alarms required by TSR 2.3.4 A to be operable and available to mitigate the consequences of an accident (release) and for which there was no redundant equipment. The certificatee did not report the event until October 21,1997, a period exceeding the 24-hour reporting requirement of Criterion J.1.a.
B.
On November 10,1997, the certificatee discovered that the criticahty sf:ty analysis for the Freon and uranium hexafluoride separation system, an operation that complies with the double contingency principle and in which moderation is used as the primary criticality control, was deficient in that it did not establish the controlled parameters for the holding drums asscciated with the system. The certificatee did not report the condition until November 19,1997, a period exceeding the four-hour reporting requirement of Criterion A.2.c.
C.
On November 18,1997, at approximately 5:15 p.m., the certificatee discovered an infraction of classified information controls in that a classified document was improperly shredded in an unapproved device. The certificatee did not repcrt the infraction until approximately six hours later, a period exceeding the one-hour reporting requirement of Criterion L.4.
USEC Response I.
Beason for the Violation The reason for the violation was that the Plant Shift Superintendents (PSSs), who are responsible for malcing reportability determinations, failed to perfomi a rigorous review of these events resulting in the failure to complete the required notification reports. The contributing factors for each of the above examples of the cited violation are dis. ussed below:
Examnle A On October 17,1997, when the loss of power occurred in C-310, it was recognized that the high-voltage (PGLD) system was inoperable and the required Limiting Conditions for Operation actions were implemented. In this instance, special attention was focussed on the criticality accident alarm system to ascertain if this system was afTected by the power El-2 1
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loss, This concem contributed to a non rigorous evaluati a. of the reportability of the loss of the PGLD alann. When the loss of power occurred on October 18, the event was a repeat of en event previously evaluated for reportability within the last day. This contributed to the non rigorous evaluation of the reportability for the event on October 18,1997.
Examnie B On November 10,1997, it was discovered that the C-335 Freon and uranium hexafluoride separation s/ stem holding drum temperature was approximately 100 degrees Fahrenheit and that the implemented Nuclear Criticality Safety Analy sis (NCS A) for the system did not establish controls for the holding drums. The PSS detennined this event to not be reportable, primarily based on an enticality incident rel ort that categorized the event as a level 4 incident report (loss of an NCSA requirement that does not violate the double contingency principle). The PSS failed to cornplete a critical review of the incident report conclusion given that the report categorized the event as a loss of an NCSA requirement but also stated that the implement d NCS A had not established the necessary control. USEC's tesponse to violation 70-7001/97011-07 (see ) contains additional information about the issue that led to this violation.
Examnle C On November 18,1997, when the classified infctmation was discovered improperly shredded, the PSS recognized that this event was reportable under Criterion L.4 as a one-hour report. Ilowever, after further consideration and discussion, the PSS determined that the event fell within the exen.ption granted by NRC regarding 10 CFR 95.57(b) reporting requirements NRC letter dated October 28,1997, permits USEC to provide written reports on a weekly basis to NRC for those 10 CFR 95.57(b) reportable events that occur within the CAA as a i sult of the classified ma:ter review. However, this determination was incorrect since the infraction occurred outside the CAA II.
Corrective Actions Taken and Results Achieved 1.
On October 21,1997, Shift Operations implemented a Long Tenn Order requiring the oncoming shift to review the previous shift's reportability evaluations of problem reports as a second check. This action will complete a second check oa reportability determinations.
111.
Corrective Actions to be Taken 1.
Each PSS and Assistant PSS ovill complete an evaluation of five problem reports selected by the Shif10perations Manager to determine reportability. The evaluation will include the reasoning used in the determination and be peer reviewed The completed evaluations will be placed in required reading for the El-3 l
PSS/APSS. This will be completed by February 28.1998.
2.
The lessou plan used to train PSS on reperting requirements will be revised to include an exercise portion to include an evaluaiion of selected problem reports to determine reportability. The exercise willinclude the teasoning used in the determination. This will be completed by March 31,1998.
IV.
Date ef Full Comnliance USEC achieved full compliance on November 18,1997, following completion of the one-hour security event. This was the last of the three examples. The corrective actions to prevent recurrence wil; be completed by March 31,1998.
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ENCLOSURE 2 UNITED STATES ENRICHMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7001/97011-06 Technical Safety Requirement 3.10.5, requires, in part, that the Plant Openitions Review Comm'ittee (PORC) review all nuclear criticality safety evaluations ar.d approvals.
Violation Cited Contrary to the above, as of November 7,1997, the PORC was not used to conduct a review of a change causing a decrease in the approved margin of safety documented in the nuclear criticality safety evaluations for use of fissile waste drums, due to appmval of drum wall thicknesses less than the minimum valte previously assumed by the Nuclear Criticality Safety staff.
g USEC Response 1.
Backuround Infomintion The current procedures which document the requirements for the use and maintenance of '
Nuclear Criticality Safety Evaluations (NCSE) and their associated Nuclear Criiicality Safety Approvals (NCSA), as they apply to this violation, are as follows:
(1)
CP2-EG-NS1031, ' Nuclear Criticality Safety" (2)
CP4-EG-NS1101," Evaluation of Requests for Criticality Safety Approvai" These procedures also document the requirements for PORC required approvals of NCSE/As.
Additionally, procedure CP3-EG-EG1086," Engineering Conduct of Operations" addresses the issuance of Engineering Guidance and includes the use, or prohibitions for use, of Engieeering Notices.
As noted in the IR, the NCS organization performed calculations to demonstrate that safety was maintained with maximum 5.5-gallon waste drums being used with wall thick-sses less than that previously analyzed. This demonstration, as noted in the IR, verified that with thinner drum walls, the calculations continued to meet the Technical Safety Requirements' criticality limit. The NCS Manager determined that, because the results of the new calculations did not alter the criticality determinations documented in the NCSE/A, there was no need to change the associated NCSE/A. Following communication of this determination to his immediate supervision, it was determined that since "no" NCSE change had occurred, the appropriate means to disseminate the results E2-I w.
of the calculations was via an engineering notice.
Procedure CP3-EG-EG1074," Design Document Change Process." at paragraph 6.2.2 delmes NCSE/As as other design documents, if the wall thickness had been treated as a design input parameter, then the design chenge/ configuration management process would have required a revision to the NCSE because of the additional wall thicknesses the new calculation allowed, 11.
Reason for the Violation The root cause of this issue was that the requirements associated with making changes as specified in engine : ring procedures (i.e., CP3-EG-EG1086 and CP3-EG-EG1074) were not adequately communicated to the NCS organization.
The reason for the violation was two-fold:
An error in judgement on the part of the NCS Manager cccurred in not recognizing that the drtun wall thickrass is a dcsign input parameter to the NCSA/E. If the wall thickness had been treated as a design input parameter, then the decign change / configuration management process would have required a revision to the NCSE.
As a result of the above, NCS personnel failed to follow the procedure requirements of CP3-EG-EG1086 in issuing the engineering notice that was used to disseminate the results of the wall thickness calculations. Section 6.2.3 of this procedure states that Engineering Guidance (i.e., engineering notices ) shall receive the appropriate level of approval ard any " intent" changes to an approved document in its use or applicability must receive the same level of approval as the original document. In this case, since the engineering notice and evaluation were being used to supplement information contained in an NCSA/E, they should have received the same level of review and approval (i.e., Plant Operations Review Cc.nmittee (PORC)) as a change to an NCSA/E.
Ill.
Corrective Actions Taken and Results Achieved 1.
The engineering evaluation and engineeri:.g notice, used to evaluate the impact of
- wall thickness on the NCSE were reviewed and approved by the PORC on November 20,1997. This is a compensatory measure to remain in place until the NCSE can be fonnally revised.
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IV.
Corrective Actions to be Taken 1.
Revise the associated NCSE/As for 5.5-gallon waste storage drums to incorporate the calculations documented in the PORC approved engineering evaluation and engineering notice documented above. This will be completed by July 31,1998.
2.
Engineering evaluatiora and notices generated by NCS during the past 2 years will be reviewed to detennine if simuar inadvertent changes to NCSE/As have been made. This will be completed by July 1,1998.
3.
Conduct a crew briefing for NCS and other appropciate engineering personnel emphasizing the requirements of CP3-EG-EG1086 regarding the requirement that any intent changes to the use or applicability of an approved document receive the same level of approval as the original document. This briefing will also review the approved processes for changing NCSE/As. This will be completed by March 6,1998.
V.
Date of Full Comoliance Full compliance was achieved on Novembei 20,1997, when the PORC approved the Engineering Evaluation and Engineering Notice identified in section 111 above. The corrective actions to prevent recurrence will be completed by July 31,1998.
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ENCLOSURE 3 UNITED STATES ENRICHMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7001/970.1-07
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Technical Safety Requirement 3.11.2, requires, in part, that all operations involving uranium enriched to 1.0 weight percent or higher and 15 grams or more of uranium 235 be based upon a documented nuclear criticality safety evaluation and perfomied in accordance with a documented nuclear criticality safety approval.
Violation Cited Contrary to the above, from March 3 through November 19,1997, operation of the Building C-335 Freon aad uranium hexaflouride system holding drums in a standby mode, while containing Fieon and uranium hexalluoride enriched to greater than or.e weight percent in uranium-235.
was performed without a documented criticality safety evaluation or approval.
USEC Response 1.
Backcround Information The installation of the R-114/UF. separation system was completed in mid l978 in building C-335 as a prototype for the present Freezer /Sublimers. The separation unit is used to freeze out UF from process gas that has been significantly contaminated with R-114. The primary purpose of the R-114/UF separation system is to provide a mechanism to remove the R-114 and recover the UF from process streams significantly contaminated with R-t 14. When the system was installed the holding drums were already in existence and were not part of the project. The holding drums were tied to the system to provide a discharge path for the rupture disks associated with the NaF traps and the UF. analyzer.
A temporary request for a Nuclear Criticality Safety Approval for the Operation and Maintenance of the R-114/UF Separation System was initiated on February 1,1994, and became effective on February 8,1994. This NCSA (3971-05, Request 1166) described the system as it had been installed and made no reference to the holding drums since they were not considered part of the system and remained in etTect until April 12,1994.
A subsequent request for an NCSA (3971-05, Request No.1404) was initiated on January 23,1995, to provide an update for the Operation and Maintenance of the R-114/UF. Separation System. This request was approved on January 30,1995. There was not a requirement at the time these request were initiated to have the system owner review the NCSE or perform a " Dry Run" of the operation prior to implementation.
On November 26,1996, Request No.1888 for NCCA 3971-05 was initia>ed to shut down the R-114/UF. separation system as a result of an effort to keep from being in non-E3-1
compliance with Compliance Plan issue 05. The Compliance Plan action required all existing operations with an enrichment 2 I wt. % U-235 to have an approved and implemented NCSA. This action was taken since the NCSA for the R 114/UF.
separation system did not meet the quality requirements required by NCS. The requirements of 3971-05, Request 1888 simply required the system to be isolated with at least two valves at each process system boundary point, which did not isolate the holding drums.
In an effort to maintain the capability to operate the R-114/UF, separation system and meet the quality standards which were deficient when the system was shut down, an update to NCSA 3971-05 was initiated (Request i873)in December 1996. This update included the operation of the holding drums. This revision (Request 1873) to the NCSA was PORC approved on December 20,1996, but was never implemented since the separation system was shutdown and there was no immediate need to operated the system.
II.
Reason for Violation The reason for this violation was that the Request for Criticality Safety Evaluation (RCSE) was inadequate and there was not a requirement at the time to have the optem owner review the NCSE or perform a " Dry Run" of the operation prior to implementation. The request was very brief and did not completely describe the physical aspects of the system. Neither the request for evr'aating the system in Stand-By/ Shut-Down Mode (Request 1888) nor the previous requests for evaluating the system for operation (Requests 1166 and 1404) identified or even mentioned the e
holding drums as an integral part of the system. As a result, the NCS analyst did not realize that the holding drums were associated with the operation of the R 114/UF 6 Separation System and did not analyze the impact on the operation of the system from an NCS perspective. During this time frame it was common practice for NCS engineers to accept RCSE forms with little detail and to work with the requesting organization to develop an accurate process description.
A contributing factor to this violation was the faih". to recognize the existence of an "As Found Condition" and the failure to take effective corrective actions to address this discrepancy. As noted above, request 1873 did recognize that the drums were part of the separation system. This should have prompted plant personnel to question why these drums were not included in previous NCSA requests. Such a questioning attitude would have resulted in the recognition that the failure to include the drums as part of the separation system was an "As-Found" Condition, in that there was not a documented criticality safety evaluation or approval. In addition, the problem report that identified the temperature drop (PR-CO-97-6630) was not evaluated for an as found" condition which could have also identified the deficiency.
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111.
C[rrective Actions Taken and Results Achieved 1.
NCS implementing procedure CP4-EG NSI101," Evaluation of Requests for Criticality Safety Approval," was revised on August 13,1997, to provide more explicit expectations for acceptance of the RCSE by NCS personnel as well as requiring the owner organization to review the NCSE Process Description and the llazard Identification Evaluation section and perform a " Dry Run" of the operation prior to implementation of the NCSE/A.
2.
With regard to the issue the failure to selfidentify the issue or classify as an "As Found" condition, U3EC implemented an action in response to NOV-97008-08 on November 14,1997, to require Shift Engineers to review all problem reports such that potential Part 76.68 (b) (i.e. "As-Found") issues are identified.
3.
Cascade Operations Long Term Order No.97-012, Rev. O was made effective on November 19,1997. This long term order implements minimum temperature requirements for the holding drums to maintain any UF in the gaseous state.
This long term order will remain in effect until the procedures which flow down the NCSA requirements (NCSA 3971-05, Request 1873) are PORC approved and implemented.
IV.
Corrective Actions to be Taken 1.
A review of all NCSE Process Description sections and Hazards Identification / Analysis sections against the actual field operations will be performed to ensure all aspects of the operation are bounded by the NCSE process description. This action will be completed by March 31,1998.
2 Crew briefings will bc held with NCS engineers and sub-contractors to review the details of this violation and how inadequate evaluations and reviews prevented identification of a system without an appropriate NCSA. This action will be completed by February 18,1998.
V.
Date of Full Compliance Full compliance was achieved on November 19,1997, when the holding drum temperature was restored and the Long Term Order was initiated to shut the system down until the NCSA for the R-114 system could be implemented. The corrective actions to prevent recurrence will be completed by March 31,1998.
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e t a ENCLOSURE 4 LIST OF COMMITMENTS
- 1. Each PSS and Assistant PSS will complete an evaluation of five problem reports ; elected by the Shift Operations Manager to determine reportability. The evaluation will include the reasoning used in the determination a id be peer reviewed. The completed evaluations will be placed in required reading for the PSS/APSS. This will be completed by February 28, 1998.
- 2. The lesson plan used to train PSS on reporting requirements will be revised to include an exercise portion to include an evaluation of selected problem reports to determine reportability. The exercise will include the reasoning used in the determination. This will be completed by March 31,1998.
- 1. Revise the associated NCSE/As foi 5.5-gallon waste storage drums to incorporate the calculations documented in the PORC approved engineering evaluation and engineering notice documented above. This will be completed by July 31,1998.
- 2. Engineering evaluations and notices generated by NCS during the past 2 years will be reviewed to determine if similar inadvertent changes to NCSE/As have been made. This will be completed by July 1,1998.
- 3. Conduct a crew brief.ng for NCS and other appropriate engineering personnel emphasizing the requirements of CP3-EG-EG1086 regarding the requirement that any intent changes to the use or applicability of an approved document receive the same level of approval as the original document. This briefmg will also review the approved processes for changing NCSE/As. This will be completed by March 6,1998.
- 1. A review of all NCSE Process Description sections and llazards Identification / Analysis sections against the actud field operations will be performed to ensure all aspects of the operation are bounded by the NCSE process description. This action will be completed by March 31,1998.
- 2. Crew briefings will be held with NCS engineers and sub-contractors to review the details of this violation and how inadequate evaluations and reviews prevented identification of a system without an appropriate NCSA. This action will be compn.ted by February 18.1998.
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