ML20199E609
| ML20199E609 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 11/18/1997 |
| From: | Pederson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | John Miller UNITED STATES ENRICHMENT CORP. (USEC) |
| References | |
| 70-7002-97-05, 70-7002-97-5, NUDOCS 9711210263 | |
| Download: ML20199E609 (2) | |
Text
t fiovember 18, 1997 Mr. J. H. Miller Vice President . Production United States Enrichment Corporation Two Democracy Center 6903 Rockledge Drive Bothesda, MD 20817
SUBJECT:
NRC INSPECTION REPORT 70-7002/97005 AND NOTICE OF VIOLATION DATED GEPTEMBER 10,1997
Dear Mr. Miller:
This refers to your October 10,1997, response to the Notice of Violation (NO\/) transmitted to you by our letter dated September 10,1997, with inspection Report 70-7002/97005. In your response, you acknowledged the two cited viol.ations 70-7002/97005-01 and 70 7002/97005 02, bat you disagreed with example B of . 7005-02. We have reviewed your corrective actions for the violations and have no further questions at this time. Your corrective actions will be examined during future inspections.
We have reviewed your response and basis for disagreement with example B of violation 97005-02. After careful consideration of the information provided by you, we believe that our example 0 of violation 97005-02 is valid.
Specifically, we noted that both the Safety Analysis Report (SAR) and the Quality Assurance Plan required the crane work to be performed using approved procedures, unless the tasks were skill-o' the-craft and did not require detai!ed step-by step instructions. We concurred with your position that the SAR allowed the organizational manager to determine which tasks were included in procedures; however, tha provision was only effective for those tasks beyond th6 minimum listing of activities described in the SAR. Crane maintenance, repair, calibration, teshng, and inspection were included in the minimum listing of activities described in the SAR that required a procedure.
Some of the activities performed as a part of the crane work also went beyond the Quality Assurance Plan-provided examples of skill-of-the craft tasks; that is, the tasks required skills not normally possessed by a qualified maintenance individual. Examples of the activities which were not r, kill of the-craft included the use of a specialized measurement and alignment tool and the instrallation of specialized couplings. Finally, the work instructions were both lengthy (complex) ,
and included several sections of detailed step-by step direction to the craft, including mandated quality hold points.
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J. Miller If you have any questions, please contact Patrick Hiland of my sta'i at (630) 829-9603.
Sincerety, Original Signed by Cynthia D. Pederson, Director Division of Nuclear Materials Safety Docket No. 70-7002 s
cc: J. Morgan, Portsmoich Ac'eng General Manager R. W. Gaston, Portsmouth Regulatory Affairs Manager S. A. Polston, Paducah General Manager Portsmouth Resident inspector Office Paducah Resident inspector Office R. M. DeVault, Portsmouth Site Manager, DOE S. Toelle, Manager, Nuclear Regulatory Assurance and Policy, USEC bec w/ltr d!d 10/10/97: E. Ten Eyck, NMSS Y. H. Faraz, NMSS P. Harich, NMSS J. Caldwell, Rill PUBLIC IE07 DOCUMENT NAME: G: \SEC\97005.RSP To receive a copy of this doctane,nt, Indicate in the box:*C = Copy without enebsure "E*'s copy with enebaure"N's No copy A OFFICE Rill l Cs Rlli l0 Rill l0 Rill (T l NAME KNICELEY:dp@ RElplNGER %K % HlLAND (NO R& PEDERSON gDATE 11/M97 1_1/W97 11/t\/97 iil/N97 OFFICIAL RECORD COPY
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Enrchment Corporation
,e 2 Democracy Center T, 6903 nocucoa.oreve Dethesda. MD 2081r Teh (301)564 3200 Far(301)564 3201 October 10,1997 GDP-97 2022 United States Fuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Portsmouth Gaseous Diffusion Plant (PORTS)
Docke', No. 70-7002 .
Response to Inspection Report (IR) 70 7002/97005 Notice of Violation (NOV)
Nuclear Regulatory Commission (NRC) letter dated September 10,1997, transmitted the subject h inspection Report (IR) that contained two violations involving: 1) a non-compliance with the Nuclear Criticality Safety Approval (NCSA) and 2) the use of work instructions for safety related activities. While USEC agrees with both violations cited, our response to violation 97005-02 provides a basis for our disagreement with example B of that citation.
USEC's response to these violations is provided in Enclosures I and 2, respectively and Enclosure 3 lists the commitments made in this report. Unless specifically noted, the corrective actions specified in each enclosure apply solely to PORTS.
The cover letter which transmitted the above referenced Inspection Report indicated that one of the violations (70 7002/97005-01) demonstrated a " lack of rigor" in the control of equipment containing deposits with greater than safe mass (PEll). USEC agrees with the specifics cited in this violation and is equally concemed with how activities related to control of equipment containing deposits with greater than safe mass are performed. While significant improvement has been made in this area, it is my belief that plant operators, managers and planners, must continue to be sensitive to removal, handling and storage of equipment containing deposits with greater than safe mass. It is my intention to continue to take those actions necessary to improve rigor and discipline, not only for controlling PEli equipment, but for all nuclear safe operations. '
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If you have any questions regarding this submittal, please contact Ron Gaston at (614) s97-2710. !
Sincerely, ale Allen .
Ocneral Manager -
Portsmouth Gaseous Diffusion Plant Enclosures (3) i cc:. Regional Administrator, Region 111 -
NRC Resident inspector- PORTS 4
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Enclosure 1 l l
UNITED STATES ENRICllMENT CORPORATION (USEC)
REPIX TO NOTICE OF VIOLATION (NOV) 70-7002/97005-01
- testatement of Violation i
Technical Safety Requirements (TSR) 3.11.2 requires, in part. that all operations involving .
uranium enriched to 1.0 weight percent (wt%) or higher U " and 15 grams (g) or more of U2n - :
shall be pe formed in accordance with a doct ..;nted nuclear criticality safety approval.
Contrary to the 1.':ove, from June 27 to July 15,1997, a cascade compressor in the X-333 building with deposits of uranium enricN J to 1.0 wt% or higher U2" and I Sg or more of Uzu was not stored in accordance with a documented nuclear criticality safety approval.
I. Reasons for Violation The reason for the violation was falh.re to follow Procedure. Specifically, the precautions and limitation section of procedure XP4-CO-CM9709; " Classifying and llandling Equ/pment Containing Uranium Deposits" was not reviewed which contained the NCSA requiremut (NCSA PLANT 028.1C2) to install metal blank-off plates as soon as possible aner removing equipment from the cascade. Contributing to the violation was a human factors error related to the procedure structure, a failure to properly label the removed comp'r essor with the initial survey classification, and management's failure to confirm NCSA PLANT 028.1C2 applicable elements were fully applied to the compressor at the time the compressor was detem11ned to be PEll.
Backeround:
In response to a nuclear criticality safety issue identified at the Paducah Gaseous Phmt, Portsmouth Cascade Operations Group walked-down legacy equipment in the cascade buildings to detemiine if equipment was stored in accordance with approved nuclear criticality safety approvals and as required by the TSR. On June 27, a compressor [33-7-1 stage 8) was discovered stored in location 33 8 6 stage 7 which was removed from the cascade in March of 1997 using maintenance procedure XP4 0M-MM4106;"X-33 Carrier Compressoi Classified as Uncomplicated Handling Removal and Installation." The compressor was originally classified in March as " Uncomplicated llandling" by an Applied Nuclear Technology (ANTS) survey, llowever, at that time, the compressor was not properly labeled to indicate the classification. Because of this, the compressor was reevaluated on June 27, 1997, using conservative new ANTS data and determined to be PEll equipment. Actions were taken by the facility manager to ensure the PEll identified compressor was bufTered with dry air as directed by procedure XP4 CO-CM9709 and properly labeled as PEll. Because the procedure did not specify in the action step of the pmcedure that metal blank-off plates be L
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used to form part of the buffer boundary, only the actions required by the TSR ,
2.2.3.16.." Removed Equipment with Deposits," were applied. De facility manager believed ,
that NCSAs wem adequately flowed into the procedure, and did riot consider consulting the ;
NCSA or reviewing the precautions an( limitations section of the procedure during the time this issue was originally ldentified in the facility. .
f While the material used for the manufacture of the covers was not in verbatim compliance with the type specified in the NCSA, there was no signifi: ant reduction in criticality safety because the plastic covers in use provide adequate moderator control (NCSA 0333_.023.A01) 4 and are capable of maintaining a dry air purge on the PEll compressor.
II. Corrective Actions Taken and Results Achieved 1.) Surveillances wem performed in other kreas in the cascade to determine if other removed compressors existed that were not classified and/or stcred in accordance with the NCSA. This surveillance did not identify other PEH equipment which was not properly stored per an NCSA. ,
2.) A specific NCSA [NCSA 0333,023.A01) was implemented on August 14,1997 for the storage of the 33-8-6 stage 7 compressor which modifies the requirements,such that metal covers are not required for this X-333 compressor. This NCSA specific; the use of a cover (i.e., may be non-metallic) having sufficient stmetural integrity to hold a bufTer pressure above atmosphere. This ensures moderation control by preventing wet air in leakage.
3.) In the referenced inspection, section Ol.l.c. the inspector concluded that this " event demonstraM that the lesson learned for the PEli storage in the X-330 building were not communicated to the X 333 personnel." In response, Portsmouth has an Cascade Operations Council that ir chartered and meets approximately every week to discuss issues, concems, items ofinterests, and problems impacting the process facilities. This council periodically reviews selected problem reports and makes assignmen's to ensure concems are addressed and lessons are leamed from identified issues. In addition, this council provides a medium by which process facilities can communicate their concems and solicit answers to identified problems, in this case, the lessons learned from the X 330 event were discussed.
Ill. Corrective Steps to be Taken None f
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IV. Date of Full Compliance Full c<>mpliance with the specific circumstances of this NOV was achieved on August 14, 1997, when the NCSA (NCSA-0333_023.A01] for the long term storage of 33-8-6 stage 7 PEll compressor was fully implemented. This NCSA modified the requiaments to allow the use of the pbstic covers on the PEli compressor stored at 33-8-6 stage 7.
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Enclosure 2 UNITED STATES ENRICIIMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) [V!O 70-7002/97005-02]
Restattmsrttof_ Violation TSR 3.9.1 requires that written procedures be prepared, reviewed, approved, implemented, and maintained to cover activitics described in S AR (Safety Analysis Report) Section 6.11.4.1.
4 SAR Section 6.11.4.1 requires that maintenance activities be addressed by written procedures, documented work instructions, or drawings appropriate to the circumstances as described in Section 2.5 of the Quality Assurance Program (QAP). ,
Section 2.5.3 of the QAP delineates examples of activities (otherwise know as " skill-of-the-craft")
which do not require step-by-step written procedures.
Contrary to the above, the certificatee performed the following complex safety related maintenance activities without approved procedures:
- a. On April 11,1997, replacement of an x-joint containing a uranium deposu with greater than safe mass from cell 29-2-2.
- b. On June 23-27,1997, replacement of the Icw assay withdrawal station crane trolley wheels and rails.
I. Reasons for Violation USEC agrees with example A of the violation but dist , rees with example B. The cause of the violation is inadequate guidance contained within the maintenance and work control program procedures on what types of maintenance activities require a procedure and what types can be performed using work instructions.
Section 2.5.1 of the Quality Assurance Program (QAP) as well as Section 6.11.4.1 and Appendix A to Section 6.11 of the Safety Analysis Report (SAR). and ANS 3.2 - 1994 Appendix A 6 paragraph (a), permit maintenance activities to be addressed by procedures, work instructions or drawings appropnate for the circumstances. Also, Section 6.11.4.1 of the SAR states Organizational Managers are responsible for identifying which tasks are to be incorporated into procedures. In addition, related industry guidance from the Institute for Nuclear Power Operations (INPO) Guidance 90-023 (MA-318) recommends that procedure requirements should be based on couipment classification, ALARA considerations, and/or extent of repair needed to restore the equipment to operating conditions.
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L USEC agrees that the work performed on April 11,1997 to replace the x-joint containing a uranium deposit with greater than safe mass should have required a procedure. This job, althongh routine from a maintenance skill standpoint, involved nsmerous Nuclear Criticality Safety (NCS) concems and required significant coordination betwecu the maintenance and operations organizations to ensure that Technical Safety Requirement's (TSRs) would not be violated as the work progressed. Section 5.2.2.3 of the SAR states," procedures are prepared or modified to incorporate NCSA requirements. Although all NCSA requirements were met, the NSCAs were not flowed into procedures.
Ilowever, USEC believes the work on the Low Assay Withdrawal (I.AW) station crane was perfomied with work nstructions appropriate for the circumstances and that the requirements of the SAR and QAP were met. The werk package for thisjob is suflicient because:
- 1) A review of the work scope was performed by representatives from Systems Engineering, Operations, IIcalth Physics, Project Management, Code Inspection, Iloisting and Rigging, and Safety.
- 2) There were no significant TSR considerations; except for a requirement to tag the crane out of service once made inoperable. This was performed.
- 3) The LAW station crane wheels and rails are not considered "Q" components even though the work was within "Q" boundaries.
- 4) A large portion of the work was within the skill of-the-cran, such as bearing removal and installation on wheel axle shans, removal and installation of Lovejoy couplings on the drive shan, taking measurements from bearing to wheel, checking alignment and span of the rail with a string gauge, removal and installation of wiring on the trolley, preparation of the rail clamp welding sites, and painting.
- 5) PMT and Operational Functional Testing were performed to ensure operability to the LAW station crane was restored. Also, this testing ensured the design of the crane was not compromised and no new anomalies were introduced as a result of the maintenance.
In addition, performing thejob using work instructions is in line with industry practices. For example, INPO guidelines recommend that if an approved procedure is not required, work instructions to craftsman are to be in sufficient detail to correct the equipment deficiency.
Vendor recommendations, engineering requirements, craft training / skills (skill-of-the-cran),
special tool needs, and hazards involved in performing the tasks should be considered when preparing those instructions. System engineer review of new work instructions should be performed to ensure adequacy.
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4, , y The work instructions used in the crane repair provided sufficient detail to correct the
- equipment deficiency, utilized vendor recommendations and engineering requirements, identified hazards involved, and the work, although involving numerous steps, was not complex and was considered skill-of-the-craft.' In addition, Systems Engineering reviewed the work
. instructions to ensure adequacy and delineated the PMT requirements to ensure operability.was ,
- restored, the design criteria of the crane was not compromised, and no new anomalies were introduced as a result of the maintenance. This test demonstrated full compliance with OSHA as well as Crane Manufacturer's Association of America (CMAA - 70) Standards and included 100% load testing and rail inspection to ensure proper alignment in both directions. To further demonstrate operability, functional testing in accordance with TSR 2.5.3.ls.1_was performed on the hoist, trolley, bridge, stop button and upper limit switch prior to use using an approved procedure, in summary, reviews were extensive and the work package utilized approved
. procedures, instructions and drawings cppropriate for the circumstances as specified by the -
requirements of SAR Section 6.11.4.1 and QAP Section 2.5.1.
II. Corrective Actions Taken and Results Achieved
- 1) USEC developed and issued a procedure from the proposed work instmetions for the removal of process compressors that contain uranium deposits above a safe mass.' This was completed on August 12, 1997. Critiques following these uranium, deposit removals noted that no unusual problems were encountered and that the procedure for performing the work was adequate.
- 2) USEC issued interira guidance to all Maintenance Managers and Work Control planners on whatjobs n quire procedures. This guidance was issued on September 24, 1997.
III. Corrective Steps to be Taken
- 1) USEC is developing guidelines in accordance with guidance provided by the SAR Sections 6.11 and 6.4, ANS 3.2 - 1994, and the QAP Section 2.5 to identify what types of maintenance activities should be performed by formal procedures. Once determined, this information will be incorporated into appropriata procedures or instructions and disseminated to all maintenance managers and planning personnel along with appropriate training. These actions are scheduled to be completed by January 9,1998.
IV. Date of Full Compliance Full compliance was achieved on August 12,1997, when a procedure was issued for work to be performed on compressors containing uranium deposits.
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Enclosure 3 UNITED STATES ENRICHMENT CORPORATION (USEC)
List of Commitments
. NOV 70-7002/97005-01 None ,
NOV 70 7002/97005-02
- 1) USEC is developing guidelines in accordance with guidance provided by the SAR Sections 6.11 and 6.4, ANS 3.2 - 1994, and the QAP Section 2.5 to identify what types of maintenance activities should be performed by formal procedures. Once determined, this information will be incorporated into appropriate procedures or instructions and disseminated to all maimenance managers and planning personnel along with appropriate training. These actions are scheduled to be completed by January 9,1998.
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