ML20202D683
| ML20202D683 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 02/09/1998 |
| From: | Morgan J UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-7002-97-12, GDP-98-2005, NUDOCS 9802170148 | |
| Download: ML20202D683 (9) | |
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USEC A Glotal E..ergy Company February 9,1998 United States Nuclear Regulatory Commission GDP-98-2005
- Attention: Document Control Desk 3
Washington, D.C. 20555 Portsmouth Gaseous Diffusion Plant (PORTS)
Docket No. 70-7002 Response to laspection Report (IR) 70-7007/97012 Notice of Violation (NOV) l.
Nuclear Regulatory Commission (NRC) letter dated January 9,1998, transmitted the subject Inspection Rt port (IR) that contained four violations involving: 1) F-cans containing uranium bearing material not properly capped,2) failure to make required NRC notificatiors,3) failure to follow procedure, and 4) failure to conduct semiannual calibration of relief drum pressure instrument.
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As indicated in the NRC cover letter transmitting the IR, USEC is not required to respond to the first violation (i.e.,97012-01) since our response to NOV 70-7002/97010-02 adequately addressed this issue. USEC's response to the remaining violations is provided in Enclosures 1 through 3, respectively. Enclosure 4 lists the commitments made in this report. Unless specifically noted, the corrective actions specified in each enclosure apply solely to PORTS.
If you have any questions regarding this submittal, please contact Ron Gaston at (614) 897-2710.
Sincerely, es B. Mor a 980217014e 980209 3 Acting Genera anager ADOCK 0700 002(
Portsmouth Gaseous Diffusion Plant PDR C
4 4
Enclosures (4) g t
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NRC Region III, Regional Administrator ll }l lhll,llhll d [fl-NRC Resident Inspector, PORTS P.O. Box 800, Ibrtsmouth. OH 45661 Telephone 614-897-2255 Fax 614-897-2644 http:#w vw.usec.com OtTices in Liveimore, CA Paducah. KY Portsmouth. OH Washington, DC y
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UNITED STATES ENRICIIMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/97012-02 Restatement of Violation Technical M.fety Requirement 3.9.1 require:; that written procedures be implememed to cover activities described in Safety Analysis Report Section 6.11.4.1 and listed in Appendix A to Safety Analysis Report Section 6.11.
Appendix A to Safety Analysis Report Section 6.11 states that " investigations rid reporting" shall be covered by a written procedure.
Paragraph 6.2.1 of plant Procedure UE2-PA-RE1030, Revision B, " Nuclear Regulatory Event
. Reportin;;," requires verbal notification to the appropriate NRC office within the time requirements shown in Appendix D of the procedure, and that the information is completely and accurately described.
Contrary to the abcve:
On October 15,1997, the certificatee failed to make a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> notification, to report the e.
use of Engineering Notices to modify nuclear criticality safety approval requirements.
The event was reportable because the changes were not formally approved in accordance with nuclear criticality safety program mquirements. This event was subsequently reported to the NRC on November 5,1997 (NRC Event Notification 33219).
b.
On October 16,1997, the certificatee failed to make a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> notification to report the loss of one control, with regards to storage of pigtail gaskets in F-cans at the X-333 low assay withdrawal station. The event was subsequently reported to the NRC on November 13,1997 (NRC Event Notification 33256).
c.
On December 8,1997, the certificatee determined that a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> notification made on December 4,1997, should have been reported as a loss of two rather than a single control (NRC Event Notificction ' Number 33353).
d.
On October 27,1997, the certificatee identified that a failure of the cylinder internal pressure loop on Autoclave #3 at the X-344 facility during operation on October 25, 1997, was reportable as a safety system component failure (NRC Event Notification t
Number 33158). In addition. on November 3,1997, the certificatee identified that a loss of two nuclear criticality safety controls in the enrichment cascade on November El-1
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'2> 1997, was reportable as a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> notification (NRC Event Notification 33206).-
USEC Response
- 1.-
Reasons fo-Violation The reasons for the examples "a" through "c" of this violation was the Plant Shift Superimendent (PSS) did not perform a rigorous review of the conditions which resulted in these events and did not adopt a conservative seporting approach. The reporting decisions made by the PSS were not conservative because th< v were based on the assumption that a notification was not required unless it could be demonstrated that a control was lost. A more conservative reporting approach would have required that a notification be made unless it can be demor.strated that controls were not lost. Although insdequate technical guidance provided w
to the PSS through Nuclear Criticality Safety Approvals (NCSA's) and Nuclear Criticality Ss.fety (NCS) personnel contributed to incorrect and untimsly reportability determinations, the lack of rigor and conservatism by the PSS is the primary cause for the late notifiedons.
The reason for example "d" of this violation was inadequate communicatior, between shifts.
L The PSS, Shift Engineer and X-34_4 Front Line Manager who were on shift when the cylinder I
internal pressure indicator malfunctioned were not aware that an engineering evaluation completed the previous day determined that this type of malfunction could result in loss of the.
s high cylinder pressure shutdown instrumentation. Without this technical information, it was not rcadily apparent to the PSS that the obswed pressure indicator malfunction could -
constitute a safety system failure. As a result, an event notification was not made within the required 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time period.
II..
Corrective Actions Taken and Results Achieved 1.
. A Daily Operatirg Instruction (DOI) was issued to the PSSs directing them to report NCSA violations tudess it can be clearly demonstrated that the NCS controls specified in the NCSA were met. If there is any un :ertainty as to whether a control was lost, the
- DOI requires that an event notification be made within the required time frame. This action was completed on November 18,1997, however this action did not have the
. desired effect. An additional instance was noted where the PSS did not take the-l appropriate conservative action towards reporting. As a result, to ensure the instructions were understoed, on February 4,1998, the PSS Group Manager completed
~ a one-on-one training session with the PSSs concernine conservative reporting.
-- 2.
A daily review of Problem Reports was initiated by the NCS Organization to ensure that cvent notifications _were made as required. A flowchart was developed and implemented to ensure that a consistent thought process is used by NCS personnel for
- providing guidaace to the PSS. A duty NCS engineer concept was put in place to El-2 I
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_ ensure that NCS support is available at all times. A two man rule was clso put into affect to ensure that NCS guidance provided to the PSS receives an independent NCS
- review, Implementation of *hese actions was completed on December 16,1997.
These compensatory actions will be re-evaluated in conjunction with the NCS Corrective Action Plan submitted on December 22.1997 and January 30,1998..
3.
A " Lessor.s teamed" progrcm discussing the inadequate turnover that resulted in late notification of the X-344 Autoclave #3 safety system failure was developed. Tne lessons lesmed was provided to the PSS, Shift Engineers and the X-340 Complex First -
Line Managers. Implementatico of this action was completed January 15,1998.
-III.-
Corrective Steps to be Taken 1.-
By April 30,1998, the lesson plan used to train the PSS on reporting requirements will be revised to include an exercise which requires.an evaluatwn of selected prc+1em reports to determine reportability.
L 2.
By February 27,1993, a " Lessons Learned" will be developed and provided to each -
- NCS engineer emphasizing their role.vhen providing support to the PSS for L
reportability determinations.
i-3, By March 31,1998, procedure XP4-SF-SFl110, " Plant Shif\\ Superintendent Actions i
on Problem Reports," will be revised to include some of the
' ions discussed in -
Section 11 above.
IV.
.Date of Full Compliance Full compliance was achieved when the event notifications were made as described in the provided examples. The action to prevent rectrrence will be completed by April 30,1998.
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Enclosurc 2 UNITED STATES ENRICilMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/97012-03 Restatement of Violation Technical Safety Requirement 3.9.1 requires that wTitten procedures be implemented to cover activities described in Safety Analysis Report Section 6.11.4.1 and listed in Appendix A to Safety l
Analysis Report Section 6.11.
Appendix A to Safety Analysis Report Section 6.1I states that cell treatments shall be covered by a wTitten procedure.
Paragraph 8.4.2 of plant Procedure XP4-CO-CN2118-TMP, Revision 0, "Stetic Cell Treatment in X-330," required, if the presence of fluorocarbons or hydrocarbons was detected and there w:re no in<lications of an abnormal reaction, to evacrate the cell contents to surge drums as needed.
Contrary to the above, on November 11-12, 1997, during static treatment on Cell 29-4-4, the certificatee did not evacuate the contents of the cell when the presence ofhydrocarbons was detected.
I 1.
Reasons for Violation The reasons for the violation vare an inadequate procedure and a failure to ccmply with a plant policy governing procedure use. Specifically, phnt personnel did not revise procedure XP4-CO-CN2118(u)," Static Cell Treatment," prior to continuing with the cell treatment evolution of Cell 29-4-4 as directed by plant policy. Continuation of the cell treatment evolution was based on an engineering evaluation which concluded that plant conditions were =
safe and recommended that treatment continue to pres ent the formation of C!-O compounds which are considered to be potentially explosive compounds during cold trapping operations.
Plant procedures require personnel to follow procedures, and if a procedure is found to be incorrect or incomplete, personnel are expected to: stop work, pla:e the plant in a safe condition, and correct the procedure. In this case, since the plant was already in a safe condition, plant personnel should have revised procedure XP4-CO-CN2118(u) prior to continuing the cell treatment evalution.
II.
Corrective Actions Taken and Results Achieved 3
1)
On December 12,1997, procedure XP4-CO-CN2118-TMP, " Static Cell Treatment in X-330" was revised. The change directs the First Lin: Manager to request an engineering evaluation / review to determine if the cell treatment process should continue in the event fluorocarbons or hydrocarbons are detected and there are no indications of an abnorraal reaction.
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P,crsonal Coaching and Counseling was administered to those indhI.luals _directly involved with this event to stress the importance of procedure compliance. This action was completed February 6,1998,
' III.
Corrective Steps to I,e Taken Lessons leamed training will be conducted with operrtions personnel to communicate the cictails of this violation. This action will be completed by March 15,1998.
IV.
Date of Full Compliance Full compliance was achieved on December 12,1997, when procedure XP4-CO-CN2118 TMP, " Static Cell Treatment in X-330" was revised, The corrective action to prevent recurrence will be completed by March 15,1998, I
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UNITED STATES ENRICIIMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/9'012-05 Restatement of Violation Surveillance Requirement 2.4.3.2.1 requires that the cold trap pressure relief system instrumentation be calibrated on a semiannual basis.
Contrary to the above, from March 3,1997, through December 14,1997, infrared analyzers used to verify relief drum pewure less than or equal to 0.3 pounds per square inch absolute, as required by Technical Safet3 Rg ament 2.4.3.2.D, were not calibrated semiannuclly.
I.
Reasons for Violation The reason for the violation was due to a misinterpretation of the Temporary Modification Procedure and the misapplication ofmobile test equipment fe routine monitoring of operating
_ parameters. Specifically, when it was recognized that the installed instrumentation used to -
monitor relief drum pressure wa.; not accurate enough for operator use, plant personnel decided to use an infrared analyzer (FTIR) cart to more accurately read the TSR surveillance parameter. Plant personnel determined that the only change needed to implement the use of the FTIR instrument for monitoring pressure was a procedure change directing it's use.
However, plant personnel failed to recognize that to use portable test equipment for routine monitoring constituted a modification to the plant and is subject to :he same surveillance frequency as the installed instmmentation.
II.
Corrective Actions Taken and Results Achieved
.1)
On Decenicer 18,1997, operations discontinued the use of the Infrared Analyzer Cart to monitor relief drum pressure and implemented administrative controls to prevent the use i
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IV.L Date of Full Compliance
. Full compliance was achieved on December 18,1997, when use of the infrared analyzer was suspended and appropriate instrumentation was intalled. The corrective actions to prevent
- recurrence will be completed by March 15,1998.
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1 UNITED STATES ENRICHMENT CORPORATION (USEC)
List of Commitments NOV 70-7002/97012-02 1.
By April 30,1998, the lesson plan used to train the P5S on reponing requirements will be revised to include an exercise which requires an evaluation of selected problem reports to determine reportability.
2.
' By February 27,1998, a " Lessons Learned" will be develv ed and provided to each NCS engineer emphasizing their role when providing suppoit to the PSS for reportability determinations.
3.
By March 31,1998, procedure XP4-SF-SFl110, Plant Shift Superintendent Actions on Problem Reports," will be revised to include some of the actions discussed in Section 11 above.
NOV 70-7002/97012-03 Lessons learned training will be conducted with operations personnel to communicate the details of this violation. This action will be completed by March 15,1998 NOV 70-7002/97012-05 Systems Engineers and the PSS organization will be briefed on the correct application of the modification control procedure and the proper use of M&TE. This action will be completed
, by March 15,1998.
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