ML20199K221
| ML20199K221 | |
| Person / Time | |
|---|---|
| Site: | 07007001 |
| Issue date: | 02/02/1998 |
| From: | Hiland P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | John Miller UNITED STATES ENRICHMENT CORP. (USEC) |
| References | |
| 70-7001-97-11, NUDOCS 9802060132 | |
| Download: ML20199K221 (1) | |
Text
February 2, 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 INSPECTION REPORT 70 7001/97011 Dear Mr. Miller.
This refers to your January 22,1998, response to Notice of Violation (NOV) transmitted to you by our letter dated December 9,1997, with Paducah inspection Report 70-7001/97011. In your response, you acknowledged the violations. We have reviewed your corrective actions for the violations and have no further quest 8ons 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 Pe' rick L. Hiland, Chief Ft. : Oycle Branch Docket No. 70-7001 cc: S. A. Polston, Paducah General Manager J. S. Morgan, Portsmouth Acting General Manager W, E. Skyes, Paducah Regulatory Affairs Manager S. Toelle, Manager, Nuclear Regulatory Assurance and Policy, USEC Paducah Resident inspector Office Portsmouth Resident inspector Office
, J. C. Hodges, Paducah Site Manager, DOE h bec w/Itr dtd 1/22/98: R. Pierson, NMSS P. Ti,)g, NMSS g W. Schwink, NMSS P. Harich, NMSS 7 M. L. Hom, Project Manager Paducah, NMSS "kW R. Beliamy, RI E. McAlpine, Rll /
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United States Nuclear Regulatory Commission SERIAL: ODP 981002 Attention: Document Control Desk g Washington, D.C. 205$5 0001 1 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, transmitted the subject IR which contained three NOVs. The United States Enrichment Corporation's (USEC)
' response to these violations is provided in Enclosures 13. Enclosure 4 lists the commitmer.ts made in this report. Unless specifically noted, the corrective actions specified in cach enclosure apply solely to PODP, d
- Pursuant to a discussion between Stes e 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 questions regarding this submittal, please contact Bill Sykes at (502) 441-6796.
Sincerely, n ,
eve Polston General Manager Paducah Gaseous Diffusion Plant SP:SRC: mig Enclosures (4) cc: NRC Region 111 NRC Senior Resident Inspector, PGDP P.O.11ox 1410 Paducah. hY 42001 Telephone 502 4415803 Fax 502 441-5801 httpd/www.usec.com
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ENCLOSURE 1 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 A.1 and listed in Appendix A to SAR Section 6.11.
Appendix A to SAR Section 6.11 identifies " investigations and reporting" as an activity requiring an administrative procedure.
Step 6.1.2 of Procedure UE2 RA RE1030," Nuclear Regulatory Event Reporting," Revision 2.
dated February 28,1997, requires that the plant shift superintendent (PSS) review problem repons and determine reportability of the event or condition using Appendix D. Step 6.2.lE of the procedure requires that the PSS verbally notify the appropriate NRC oflice 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,1.a requires, in part, a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> repon for an event in 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 and either 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 w ith the double contingency principle in which moderation is used as the primary criticality control and where it is determined that a criticality safety analysis was deficient and the necessary controlled parameters were not established or maintained.
Criterion L4 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 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 Octooer 17,1997, an event occurre I causing a loss of power (tripped breaker) for the Building C 310 high voltage process gas leak detection (PGl..D) system alanns required by TSR 2.3.4.4 to be operable and available to mitigate the consequences of an accident (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 Duilding C 310 high voltage PGLD system alanns required by TSR 2.3.4.4 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 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.
D. On November 10,1997, the certificatee discovered that the cri'.icality safety 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 pr.imary criticality control, was deficient in that it did not establish the controlled parameters for the holding drums associated with the system. The certificatee did not report the condition until November 19,1997, a period exceeding the four hour reporting requirement ofCriterion A.2.c.
C. On November 18,1997, at approximately 5:15 p.m., the certificatee discovered an infraction of classified infonnation controls in that a classified document was improperly shredded in an unapproved device. The certificatee did not report the infraction until approximately six hours later, a period exceeding the one hour reporting requirement of Criterion L.4.
USEC Response
- 1. Reason for the Violation The reason for the violation was that the Plant Shill Superintendents (PSSs), who are responsible for making reportability determinations, failed to perfonn a rigorous review of these events resulting in the failure to complete the required notification repons. The contributing factors for each of the above examples of the cited violation are discussed below:
Example 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 alami system to ascertain if this system was affected by the power El.2
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loss. This concern contributed to a non rigorous evaluation of the reportability of the loss of the PGLD alann. When the loss ofpower occurred on October 18, the event was l
' a repeat of an 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.
Examnle B On November 10,1997. it was discovered that the C 335 Freon and uranium I
hexafluoride separation system holding drum temperature was approximately 100 4
degrees Fahrenheit and that the 1.nplemented Nuclear Criticality Safety Analysis (NCSA) for the system did not establish controls for the holding drums. The PSS detennined this event to not be reponable, primarily based on an criticality incident report 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 complete 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 implemented NCSA had not established the necessary control. USEC's response to violation 70 7001/9701107 (see Enclosure 3) contains additional information about the issue that led to this violation.
Examnle C On November 18,1997, when the classified information was discovered improperly
' shredded, the PSS recognized that this event was reportable under Criterion L4 as a one-hour report. liowever, aRer further consideration and discussion, the PSS determined that the event fell within the exemption granted by NRC regarding 10 CFR 95.57(b) reporting requirements. NRC letter dated October 28,- 1997, permits USEC to provide 4
written reports on a weekly basis to NRC for those 10 CFR 95.57(b) reportable events that occur within the CAA as a result of the classified matter review, lionever, this
- determination was incorrect since the infraction occurred outside the CAA. .
- 11. Corrective Actions Taken and Results Achieved
- 1. On October 21,1997, ShlR Operations implemented a Long Term Order requiring 4
the oncoming shlR to review the previous shin's reportability evaluations of problem reports as a second check. This action will complete a second check on reportability determinations.
111. Corrective Actions to be Taken
- 1. Each PSS and Assistant PSS will complete an evaluation of five problem reports selected by the Shin Operations 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 t
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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.
IV. Date of Full Comn11anec 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 i
to prevent recurrence will be completed by March 31,1998.
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ENCLOSURE 2 UNITED STATES ENRICllMENT CORPORATION (USEC)
REPLY TO NO11CE OF VIOLATION (NOV) 70 7001/9701106 Technical Safety Requirement 3.10.5, requires, in part, that the Plant Operations Review Committee (PORC) review all nuclear criticality safety evaluations and approvals.
Violation Cited Contrary to the above, as of November 7,1997, the PORC was not used to conduct a review of a change ca'ising a decrease in the approved margin of safety documented in the nuclear criticality safety evaluations for use of fissile waste drums, due to approval of drum wall thicknesses less than the minimum value previously assumed by the Nuclear Criticality Safety staff.
USEC Response
- 1. Backcround Infomiation The current procedures which document the requirements for the use and maintenance of Nuclear Criticality Safety Evaluations (NCSE) and their associated Nuclear Criticality Safety Approvals (NCSA), as they apply to this violation, are as follows:
(1) CP2 EG NS1031," Nuclear Criticality Safety" (2) CP4-EG NSI101," Evaluation of Requests for Criticality Safety Approval" 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 Engineering 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 thicknesses 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 detemiined that, because the results of the new calculations did not alter the criticality determinations documented in the NCSE/A, there was n i need to change the associated NCSE/A. Following communiention of this deto.nination to his immediate supervision,it was determined that since "no" NCSE change had occurred, the appropriate means to disseminate the results E21
l of the calculations was via an engineering notice.
Procedure CP3 EO E01074 " Design Document Change Process."at paragraph 6.2.2 defines NCSE/As as other design documents. If the wall thickness had been treated as a design input parameter, then the design change / configuration management process muld I have required a revision to the NCSE because of the additional wall thicknesses the new calculation allowed, 11.
Reason for the Violation i
The root cause of this issue was that the requirements associated with making changes as I specified in engineering procedures (i.e., CP3 EG EG1086 and CP3 EG EG1074) were i not adequately communicated to the NCS organization.
1 The reason for the violation was two fold:
An error in judgement on the part of the NCS Manager occurred in not recognizing that the drum wall thickness is a design input parameter to the NCSA/E If the wall thickness had been treated as a design input parameter, then the design change / configuration management process would have required a revision to the NCSE.
t As a result of the above, NCS personnel failed to follow the procedure requirements of CP3 EG E01086 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 and 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 Committee (PORC)) as a change to an NCSA/E.
111.
Corrective Actions Taken and Results Achieved 1.
The engineering evaluation and engineering 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 formally 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 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 briefing for NCS and other appropriate engineering personnel emphasizing the requirements of CP3 EG E01086 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 brieling 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 November 20,1997, when the PORC approved the Engineering Evaluation and Engineering Notice identified in section til above. The corrective actions to prevent recurrence will be completed by July 31,1998.
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ENCLOSURE 3 UNITED STATES ENRICHhlENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70 7001/9701107 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 perfonned in accordance with a documented nuclear criticality safety approval.
Violation C!'ed Contrary to the above, from March 3 through November 19,1997, operation of the Building C-335 Freon and uranium hexaflouride system holding drums in a standby mode, while containing Freon and uranium hexalluoride enriched to greater than one weight percent in uranium 235, was perfomied without a documented criticalhy safety evaluation or approval.
USEC Response I. Backcround information The instcllation of the R il4/UF separation system was completed in mid 1978 in building C 335 as a prototype for the present Freezer /Sublimers. The separation unit is used to freeze out UF. from process pas that has been significantly contaminated with R il4. The primary purpose of the R-ll4/UF. separation system is to prm ide a mechanism to remove the R 114 and recover the UF. from process streams significantly contaminated with R 114. 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 effect until April 12,1994.
A subsequent request for an NCSA (3971-05, Request No.1404) was initiated on January 28,1995, 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" cf the operation prior to implementation.
On November 26,1996, Request No.1888 for NCSA 3971-05 was initiated to shut down the R-ll4/UF, separation system as a result of an effon to keep from being in non-E31
compliance with Compliance Plan issue 05. The Compliance Plan action required all existing operations with an enrichment > 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 397105, 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 l 14/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 1873)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.
- 11. Beason for Violation I
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 evaluating the system in Stand By/ Shut Down Mode (Request 1888) nor the previous requests for evaluating I the system for operation (Requests 1166 and 1404) identified or even mentioned the~
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 ll4/UF.
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 failure 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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I 111. Corrective Actions Taken and Results Ach'eved l.- NCS implementing procedure CP4 EO NS1101," Evaluation of Requests lbr 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 i i
requiring the owner organization to review the NCSE Process Description and i
the llazard identincation Evaluation section and perform a " Dry Run" of the operation prior to implementation of the NCSE/A.
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- 7. - With regard to the issue the failure to selfidentify the issue or classify as an "As i Found" condition, USEC implemented an action in response to NOV 97008 08 on November 14,1997, to require Shift Engineus 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 Cow 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 llazards identification / Analysis sections against the actual field operations will be performed to ent se all aspects of the operation are bounded by the NCSE process description. Tir action will be completed by March 31,1998,
- 2. Crew briefings will be held with NCS engineers and sub-contractors to review the i
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 Comollance 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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ENCLOSURE 4 LIST OF COMMITMENTS l Enclosure 1 l 1. Each PSS and Assistant PSS will complete an evaluation of five problem reports selected by l
l the Shill Operations 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 PSS/APSS. This will be completed by February 28, 1998.
- 2. The lesson plan used to train PSS on t norting 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 detennination. This will be completed by March 31,1998.
Enclosure 2
- 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 evaluations and notices generated by NCS during the part 2 years will be reviewed to detennine if similar inadvenent changes to NCSE/As have been made. This will be completed by July 1,199.8.
- 3. Conduct a crew brienng 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 briefing will also review the approved processes for changing NCSE/As. This will be completed by March 6,1998.
Enclosure 3
- 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 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 completed by February 18.1998.
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