ML20199L568
| ML20199L568 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 11/26/1997 |
| From: | Morgan J UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-7002-97-08, 70-7002-97-8, GDP-97-2035, NUDOCS 9712020057 | |
| Download: ML20199L568 (12) | |
Text
I United Sttas c
Enrichment Cor poration "7
2 Democracy Center 6903 Rockledge Drive Dethesda IAD 20817 Tel (301)564 3200 (nilcelN.ile*
l:niirinneni t :<ir p.:niii.n November 26,1997 United States Nuclear Regulatory Commission GDP 97-2035 Attention: Document Control Desk Washington, D.C. 20555 Portsmouth Gaseous Diffusion Plant (PORTS)
Docket No. 70-7002 Response to inspection Report (IR) 70 7002/97008 Notice of Violation (NOV)
Nuclear Regulatory Commission (NRC) letter dated October 28,1997, transmitted the subject inspection Repor1 (IR) that contained four violations involving: 1) minimum staffmg,2) inadequate chemical safety controls for the removal of an X joint containing a uranium deposit 3) receipt and storage of nonstandard IS sample cylinders, and 4) exceeding technical safety requirement (TSR) overtime limits without prior approval.
USEC's response to these violations is provided in Enclosures 1 through 4, respectively and lists the commitments mcdc in this report. Unless specifically noted, the corrective lf actions specified in each enclosure apply solely to PORTS.
l In the cover letter which transmitted the Inspection Report, NRC stated that:
"The violations were ofconcern because similar issues were previously identified.
h which indicates that implementation of your corrective action program was inefective. In addition, slagimpicmentation of the technical safety requirements (ISR 's) continues to be weal "
USEC understands the importance and value of an effective corrective action program and believes that significant improvement has been made in this area. Recently, an independent assessment of the corrective action program was perfomied at Pommouth and recommendations for
- mprovement were presented to the Management Analysis Assessm.nt Team (MAAT). The MAAT accepted the recommendations for continued improvement and implementing organizations have begun work to implement the recommendations. Specific actions are documented in Problem Report PR-PTS 97 9355 and the assessment is documented in memorandum 97 890-257. Both of these documents are available for the NRC Resident Inspector's review.
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9712020057 971126 PDR ADOCK 07007002 flrfff, f) ll
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C PDR Offices an Paducah Kentucky Por tsmoutn. Oh.o Washington. DC
United States Nuclear Regulatory Commission November 26,1997 Page 2 To address the overtime issue on how USEC will ensure excessive ov.rtime is not authorized for projects like the preplanned conspressor disassembly evolution, specific guidan:e has been provided to the Plant Shill Superintendent (PSS) Group to specify a duration for how long an employee can work overtime. This information will be recorded and communicated to the individual requesting the overtime. Should additional overtime be needed beyond the time specif..;, an additional approval by the PSS will be required. Additiona! actions are discussed in Enclosure 4.
1 If you have any questions regarding this submittal, please contact Ron Gaston at (614) 897-2710.
Sincerely, k
Uames it hk n
Acting Genera Manager Portsmouth Gaseous DifTusion Piant Enclosures (5) cc:
NRC Region 111, Regional Administrater NRC Resident inspector, PORTS F
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UNITED STATES ENRICilMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70 7002/97008-01 i
Restatement of Violation f
i Tuhnical Safety Requirement 3.2.2.a specified the minimum staffing requirements for each facility (shown in Table 3.2.21).
Table 3.2.21 requires that a Plant Shin Superintendent (PSS) be present in the X 300 facility at all s
times, if the PSS needs to leave the X-300, an authorized designee trained to execute plant emergency -
procedures can be assigned in accordance with TSR 3.1.3.
- Contrary to the above, on September 13,1997, the PSS exited the X 300 facility without assigning i
a designec in accordance with TSR 3.1.3.
i 1.
Reasons for Violation The reason for the violation was inattention to detail. Procedure XP2 US F01204, Sh!ft Functional Staging Requirements, was implemented on July 31,1997. Included ir.his procedure are dermitions of the watch stations and the boundaries that apply. The PSS who leR the boundary was trained on the new procedure, but did not realize that he was violating it merely by stepping out to the X-300 " porch" until this actior, was identified by the inspector.
3 Background
On the moming of September 13,1997, the General Manager entered X 300 and requested the on-duty PSS to accompany hira outside of X-300 to discuss the previous evenings emergency management exercise. The on-duty PSS went outside to the X-300 " porch" as requested. nt the time the request was made, the on-duty APSS was outside of X-300 directing an emergency response. Another PSS who remained in X 300 v, n not fully trained to execute emergency procedures and had not received a turnover.
NRC identified a previous violation concerning the failure to maintain minimum shin stalling in inspection Report 97002. The corrective actions implemented for this prior violation were to create a new procedure, XP2 US F01204, defining minimum stafling requirements and the boundaries.of the various duty stations and to train operating personnel on the new requirements. The PSS involved in the September incident remembered the procedural requirements when it was pointed out that the " porch" was outside the boundary of the X 300 building.
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Corrective Actions Taken and Results Achieved 1.
The on-duty PSS who went outside to the X-300 " porch" returned to the control floor when non-compliance with the above TSR was identified, i
I 2.
The PSS who caused the violation was counseled for inattention to detail.
3.
PSS required reading was conducted to cornmunicate the requirements for minimum shif1 staffing and the defined boundaries. This material emphasized the definitions of the watch stations and the boundaries that apply.
Ill.
Corrective Steps to be Taken i
None I V.
Date of Full Compliance USliC achieved full compliance on September 13,1997, when the PSS returned within the boundary of the X 300 fac.iity.
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UNITED STATES ENRICllMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) lVIO 70 7002/97008-02]
Restatement of Violation Technical Safety Requirement 3.9.1 requires that written procedures be prepared, reviewed, approved, implemented, and maintained to cover activities described in the safety analysis report (S AR), Section 6.11.4.1.
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 S:ction 2.5 of the Quality Assurance Plan (QAP).
Contrary to the above, plant procedure CMG 21 " Expansion Joint Removal And Installation,"
Revision 3 was not adequately prepared in that it did not provide sufficient chemical safety controls for removal of a piping X joint containing a uranium deposit from cell 33 3 3 on August 30,1997.
I, Reasons for Violation The reason for the violation was inadequate communication between the implementing organizations responsible for the X-joint removal. Specifically, the Cascade Coordination, Operations, and Industrial Safety organizations ware aware that the alTected cell contained liF and that a Negative Air Machine (NAM) should have been used during this work activity.
Ilowever, these organizations failed to properly communicate this information to the Maintenance organization prior to the X joint removal evolution. Contributing to the violation was that policies, procedures, and work packages were not strict enough or did not contain sufficient criteria to ensure chemicel safety controls were implemented,
Background
During July 1997, cell 33 3 3 was shutdown when the 8B seal failed while the cell was operating on stream. A large wet air in leakage occurred and it was anticipated that a UO F 2 2 deposit had fom;cd. A dresser seal was installed and the cell was evacuated and purged to a PG negative.
The suspect cell was scheduled for maintenance in mid August. Based on the history of this cell, (i.e., the mode of failure and the method for attaining the PG negative) the facility manager correctly recommended that the cell be wet air evacuated in order to purge any residualllF from the cell prior to maintenance. Cascade Operations agreed and the evolution began. During the evolution, an llF sample was ordered and the results indicated an liF concentration of 2200 ppm. Wet air evacuation continued until the evolution had to be E2 1
suspended due to high parts (UF ) showing up on the space recorder. Additional samples were ordered to verify that the PO was not originating from the target cell. Results of the samples showed UF. concentration less than 1 ppm in the cell. At the same time this evolution was occurring, the facility was experiencing problems at the seal exhaust station which was
- believed to be causing the high parts reading on the space recorder.
13ecause of the problems experienced with the wet air evacuation and the initial sample results, a meeting was held with Cascade Coordination, Operations, and Industrial Safety to detemiine a conservative course of action. The conclusion of the meeting determined that while there.
were no specific requirements for liF concentration in cells, a Negative Air Machine (NAM) should be used as a conservative measure to address the primary concern of lif' in the -
breathing zone. The cell was subsequently released to maintenance by building operations without knowledge of the discussion and conservative decision to use the NAM during the X-joint removal evolution. Subsequently, tiie PG system was opened at the X joint and : wisp of smoke (liF) was observed. Investigation, showed that a deposit had been cut into, exposing the deposit to the surrounding wet air which caused the a reaction producing IIF. Personnel protective equipment was properly used and no exposure was detected. Air samples taken by emergency response did not detect any airborne contaminants 11.
Cm rective Actions Taken and Results Achieved 1.
The Maintenance Manager issued a directive on September 16,1997, requiring large cascade components to be scanned for UO F and sampled for ilF prior to removal.
2 2 Pending the results of the sample, Industrial liygiene would be consulted for additional controls prior to opening a PG system. This action will remain in place until all applicable maintenance procedures have been updated to incorporate chemical safety control criteria.
2.
Several operations and maintenance procedures have been revised to provide guidance for llF abatement prior to opening a process gas system. Some of the procedures include but are not limited to the following:
XP4-CO CA2173: Purging X 330 Cells and Process System to a Negative XP4-CO-CA2174t Purging Cells and Process Systemsfor a Negative in X 333 XP4 OM MM4502; Removal and installation of Uncomplicated llandling Converters in X-330 a sdX-333 Building XP4 OM.MM4529; RemovalandInstallation ofPrc. cess Gas Control Valve Classified as Uncomplicated Handling XP4-OM.MM4506; Auxiliary Compressor Classified as Uncomplicated Handling - RemmalandInstallation.
3.
Work Control implemented a prerequisite requirement (POEF.WC 97-172) on September 23,1997, for planners to incotporate into prepared work packages a step E2 _
a to require equipment to be sampled and evaluated for llF concentration prior to
_ opening a PG sy!, tem to atmosphere, Ill. -
Corrective Steps to be Taken 1.
The Work Control procedure will be revised by January 23,1998, to incorporate the provisions for use of a safety and health work permit to be used during the planning process.
2.
The Safety & llealth Work Permit program will be revised by January 15,1998, to require chemical safety controls be specified during the planning process.--
3.
Maintenance procedures, including CMG 21, will be revised by January 15,1998, to inecrporate chemical safety control criteria to be used when a PG system will be opened or removed.
IV.
I)ste of Full Compliance Full compliance was achieved on September 23,1997, when maintenance and work control took appropriate actions to ensure that chemical safety controls are applied for work ac:ivities.
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UNITED STATES ENRICllMENT CORPOP.ATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) lVIO 70 7002/97008-03)
Restatement of Violation Technical Safe'y Requirement 3.11.2 requires, 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 perfonned in accordance with documented nuclear criticality safety approval.
Contrary to the above, from August 15 to September 15,1997, receipt and storage of nonstandard 1S sample cylinders with uranium enriched to 1.0 wt% U 235 and 15 g or more of U-235 at the X 344 building was not perfonned in accordance with a nuclear criticality safety approval (NCSA).
Specifically, geometry control was not in accordance with NCSA 0344 A006.
~i.
Reasons for Violation The reason for the violation was due to a lack of understanding and implementation of the procedure governing NSCAs when reviewing NCSAr. for applicability to other similar activities. Specifically, the Nuclear Criticality Safety (NCS) engineer who reviewed the IS cylinder NCSA to determine if the controls were adequate for the non-standard IS Russian cylinders did not appropriately consider modifying the scope of the NCSA to address the non-standard 1S cylinders. De NCS engineer instead based the decision of applicability only on the adequacy of the existing controls for ensuring nuclear criticality safety and not on the specific list of equipment to which the NCSA actually applied. The NCS engineer was more focused on the physical aspects for ensuring nuclear safety rather than the administrative correctness.
11.
Corrective Actions Taken and Results Achieved 1.
On September 22,1997, NCSA PLANT 078.A00; Use of Ledoux /S Cylinders at POR7N, was approved and implemented. This NCSA evaluated the criticality safety aspects of using the non standard "Ledoux" IS sample cylinders at PORTS. Because the NCSA did not alter any controls initially crablished by NCS A-0344 A006, changes to implementing procedures were not required.
2.
To heighten the sensitivity of the NCS organization, several informal training sessions were held by the new NCS manager to review current procedures and to discuss lessons. earned from this violation and other recent events.
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111.
Corrective Steps to be Taken No additional actions required.
IV.
Date of Full Compliance USlic achieved full compliance on September 22,1997, when NCSA PLANT 078.A00; U3c ofLedoux IS Cylimhrs at POR75 was approved and implemented.
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UNITED STATES ENRICilMENT ColtPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) lVIO 70 7002/970E04l hstatement of Violation 10 CFR 76.93," Quality Assurance" requires that the Corporadon shall establish, maintain, and execute a quality a%urance program satisfying each of the applicable requirements of American Society of Mechanical Engineers (ASME) NQA 1-1989," Quality Assurance Program Requirements for Nuclear Facilit!es."
American Society of Mechanical Engineers (ASME) NQA 1-1989," Quality Assurance Program Requirernents for Nuclear Facilities," llasic 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 tr. ken to preclude recurrence.
Contrary to the above, on September 10 and September !8,1997, the certificatee identified two examples where required technical safety requirement (TSR) overtime limits were exceeded without prior approval. This is a sepetitive violation of TSR 3.2.2 which requires prior approval fbr exceeding overtime requirements and previously identified overtime concerns were not adequately corrceted to prevent recurrence.
I.
Reasons for Violation The reason Ibr the violation is administrative controls used to manage employee overtime has been either confusing or incomplete. Specifically, while the TSR requirement associated with oveitime was restated (i.e., flowed down) in procedures, the procedures do not provide a detailed method for complete implementation. In addition, in reviewing the corrective actions already taken to address the overtime issue, many of the actions only fbcussed on the immediate problem.
13ackground Procedure Xp2 IIR-LR 1030, Limitations of Ilours of Work, was created during the administrative process of flowing down TSR requirements into procedures prior to NRC transition. Implementation of these requirements involved ftdl participation of all site personnel, causing implementation problems with the new process due to several individuals misunderstanding of the requirements. Interpretations were b:ing made to address individual situations by persannel who were unfamiliar with the new procedure and employees were not being accountable fbr preventing owrtime exceedences. These individual problems were E4 1
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addressed through procedure upgrades and resolved through increased ernployee training and er'nployee disciplinary actions.
Prior to transition to NRC regulatory oversight, a computerized overtime canvassing system t
was bnplemented for a selective group of hourly employees. This system is effective for normally scheduled work. Ilowever, the system does not alert personel to the potentail for exceeding ovenime limits future scheduled work hours. This problem is being addressed through improvements to the computer programs.
l II.
Corrective Actions Taken and Results Achieved 1
1.
Managemert expectations were communicated to plant employees addressing concerns regarding violations of hours of work.
2.
A manager was appointed to oversee the Plant ilours of Work program.
3.
Supervision was given guldance on use of appropriate discipline for employees who execeded authorized work hours.
4.
Improvements in computerized overtime canvassing system's functionality and effectiveness have been developed to further enhance the system.
5, A computeri7ed hours of work monitoring system has been fully implemented. This i
system compares personnel time reports to TSR overtime requirements and management overtime report approvals.
i 6.
Clarifications have been made to procedure XP2 IIR-LR1030 discussing hours of work.
Ill.
Corrective Steps to be Taken I
1.
Senior Mancgement appoli.t;d a multi diteiplined team to assess the ovenime process to improt e overtime exceedence compliance.
This team will submit recommendations to the General Manager by March 31,1998.
2.
Further improvements will be made to the overtime canvassing system to enhance the plant's ability to prevent overtime exceedences. This action will be completed by June 1998.
1 IV.
Date of Full Compliance Full compliance will be achieved on June 30.1998, when the corrective actions to prevent personnel from exceeding hours of work limitations are ftdly implemented.
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Erclosure 5 UNITED STATES ENRICHMENT CORPORATION (USEC) i List of Commitments l
NQY.70-7002/97008-01 i
None NOV 70-7002/97008-02 l.
The Work Control procedure will be revised by January 23, 1998, to incorporate the provisions for use of a safety and health work permit to be used during the planning process.
2.
The Safety & !!calth Work Permit program will be revised by January 15,1998, to require chemical safety controls be specified during the planning process.
t 3.
Maintenance procedures, including CMG 21, will be revised by January 15,1998, to incorporate chemical safety control criteria to be used when a PG system will be opened or removed.
NOV 70-7002/97008-03 None NOV 70-7002/07008-04 Senior Managemen' appointed a multi-disciplined team '.o assess the overtime process to l.
improve overtime exceedence compliance. This team wil submit recommendations to the General Manager by March 31,19?t.
2.
Further improvements will be n.ade to the overtime canvassing system to enhance the plant's ability to prevent overtime exceedences. This action will be completed by June 1998.
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