ML20203F841
| ML20203F841 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 02/25/1998 |
| From: | Pederson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | John Miller UNITED STATES ENRICHMENT CORP. (USEC) |
| References | |
| 70-7002-97-13, NUDOCS 9803020064 | |
| Download: ML20203F841 (27) | |
Text
.
o i
February 25, 1998 EA 98-012 Mr. J. H. Miller Vice President - Production United States Enrichment Corporation
- Two Democracy Center 6903 Rockledge Drive Bethesda, MD 20817 1
SUBJECT:
PREDECISIONAL ENFORCEMENT CONFERENCE
SUMMARY
I
Dear Mr. Miller:
On February 19,1998, representatives of the United States Enrichment Corporation (USEC) met with NRC personnel in the Region lil office located in Lisle, Illinois, to discuss the apparent violations identified in Inspection Report 070-07002/97013(DNMS). The predecisional enforcement confarence was held at the request of Region Ill.
NRC mresentatives described the bases for the predecisional enforcement conference, the purps of the meeting, and the proposed agenda. Your representatives agreed with the facts detaned in the inspection report foi the twelve apparent violations. Representatives from USEC distributed a document entitled," United States Enrichme".t Corporation Portsmouth Gaseous Diffusion Plant Pre-Decisional Enforcement Conference," dated February 19,1998, which is provided as Enclosure 2 of this letter. USEC representatives then presented root cause analyses, corrective actions, and mitigating factors for the apparent violations described in Inspection Report 070-07002/97013(DNMS).
A list of individuals that participated in the conference is provided as Enclosure 1 of this letter.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and its enclosures will be placed in the NRC Public Document Room.
Sincerely, Original Signed by 020013 Cynthia D. Pederson, Director Division of Nuclear Materials Safety Docket No. 070-07002 T. ko,
l E
Certificate No. GDP-2
Enclosures:
As stated ll I.l 1.1 i.lli I,Il Il.i See Attached Distribution DOCUMENT NAME: G:\\SEC\\nOR97013. PRE To eoceive a co py of this document, Indicate in the box 'C's Copy w/o attach /enci *E' = Co)y w/ attach /eq%
= No copy ( 1 YFFICE Rlll*D N M S _ E-Rlll:DNMS l td Rlll:EICS Rill lOfblS
'd R NAME Krsek/kjc&t Hiland SMg Clayton #v Pedbrtbn "M
DATE 024,N/98 02/W/98 02/2(/98 02/r(/98 OFFICIAL RECORD COPY N
hNN02 i
C PDR
J. H. Mille: cc w/encis:
S. A. Polston, Paducah General Manager J. B. Morgan, Acting Portsmouth General Manager R. W, Gaston, Portsmouth Nuclear Regulatory Affairs Manager S. A. Toelle, Manager, Nuclear Regulatory Assurance and Policy, USEC Paducah Resident inspector Office Portsmouth Resident inspector Office E. W. Glliespie, Portsmouth Site Manager, DOE Distribution PUBLIC (IE 07)w/encls J. Goldberg, OGC w/encls W. Brach, NMSS w/encls
- A. B. Beach, I"'I w/encls P. Ting, NMSS w/encls R. Bellamy, RI w/encls J. l. Caldwei.,
ll w/encls R. P!erson, NMSS w/encls E. McAlpine, Ril w/encls
' C. D. Pederson, Rill w/encls W. Schwink, NMSS w/encls F. Wenslawski, RIV/WCFO w/encls R. J. Canlano, Rlll w/encls P. Harich, NMSS w/encls Rlli Enf. Coordinator w/encls J. Lieberman, OE w/encls Y. H. Faraz, NMSS w/encls a
?
f e
n.
CONFERENCE PARTICIPANT ATTENDANCE LIST Ur"-4 At
- r Errici..r.er.i cc,M'.r, (USEC)
__Goorge Rifakes, Executive Vice President -
- James Miller, Vice President Production -
Steve Toolle, Manager, Nuclear Regulatory Assurance and Policy Ron Gaston, Portsmouth Nuclear _ Regulatory Affairs Manager -
Russ Wells, Senior Regulatory Engineer i are--4 umrtin u=f marvic James' Morgan, Acting Portsmouth Gcneral Manager
. Mark Hasty, Engineering Organization Manager, Portsmouth Dan Wilczynski, Nuclear Safety Manager, Portsmouth Ed Wagner, Safety Analysis Report Upgrade Engineer, Portsmouth U S. Nuelaar Rans Mnrv Nnmla=16ri (NRC)
A, Bill Beach, Regional Administrator, Region lli Cynthia Pederson, Director, Division of Nuclear Materials Safety Region 111 Bill Brach, Deputy Director, Fuel Cycle Safety and Safeguards, Office of Nuclear Material Safety and Safeguards (NMSS)
Bruce Berson, Regional Counsel, Region Ill -
Brent Clayton, Enforcement / Investigations Officer, Region ill-s Patrick Hiland, Chief, Fuel Cycle Branch, Region lli-Kenneth O'Brien, Senior Resider., inspector, Paducah Gaseous Diffusion Plant, Region til David Hartland, Senior Resident inspector, Portsmouth Gaseous Diffusion Plant, Region lll.
- Toye Simmons, Enforcement Coordinator, Region lli Yawar Faraz, Project Manager-Portsmouth, Fuel Cycle Safety and Safeguards, NMSS Jack Davis, Criticality Safety inspector, Fuel Cycle Safety and Safeguerds, NMSS Timothy Reidinger, Senior Fuel Facility Inspector, Fuel Cycle 3 ranch, Region ill Courtney Blanchard, Fuel Facility inspector, Fuel Cycle Branch, Region lli
- Susan Greene, NMSS (via teleconference)
Jay Henson, Enforcement Specialist, Office of Enforcement (via teleconference)
John Lusher, Enforcement Specialist, Office of Enforcement (via teleconference)
U.S Danartment of Energy (DOE)-
Randall DeVault, DOE Regulatory Oversight Manager, Office of Assistant Manager for.
Enrichment Facilities (via teleconference)-
Wayne Yoder, DOE Safeguards and Security Specialist, Office of Assistant Manager for Enrichment Facilities (via teleconference) i__-_--___._-_.-__-_--a-_. _ - - _ - _ _ - - _ -. _.. _ -
~
l l
/ USEC A Global Energy Company i
4 t
UNITED STATES ENRICHMENT CORPORATION PORTSMOUTH GASEOUS DIFFUSION PLANT PRE-DECISIONAL ENFORCEMENT CONFERENCE l
1 February 19,1998
AGENDA A.
Introduction B.
Apparent Violation 97013-01 (Loss of Criticality Controls for Shutdown Cells)
===1.
Background===
2.
As-Fornd Condition of Cell 29-5-8 3.
Concinoions 4.
Root Causes and Corrective Actions 5.
Mitigating Factors C.
Apparent Violations 97013-02 thru 97013-12 (NCS Program Deficiencies) 1.
Introduction 2.
Root Cause Analysis 3.
Corrective Actions 4.
Mitigating Factors D.
Closing Remarks Y
A
[USEC A Global Energy Compa.y
APPARErff VIOi%ATION 97013-01 BACKGROUND On November 4,1997, USEC reported to NRC that a loss of two Nuclear Criticality Safety (NCS) controls was discovered for a shutdown cascade cell.
At the time this event was reported, USE( bekved that the applicable contingency event in the Engineering Evaluation for the applicab' Nuclear Criticality Safety Assessment (i.e., NCSA-0330-004.A01) was contingency B.6.a.1, oduction of RCW into the Cascade."
The applicable NCSA controls for contingent vent B.6.a.1 were:
1.
Coolant pressure greater than Recirculating Water (RCW) pressure; and RCW supply pressure verified quarterly; and Following maintenance on condenser, open RCW return valve before charging cell w/ UF.
6 2.
Cascade design providing single barrier protection during treatment or shutdown; and RCW supply valved off, condenser drained, drain valve left open.
3 UnitedStates Enrichment Corporation j
A Global Energy Company l
APPARENT VIOLATION 97013-01 AS-FOUND CONDITION OF CELL 29-5-8 Cell buffered with plant air >14 psia.
RCW Condenser Drained:
Supply and return isolation valves closed - controlled by Lockout /fagout (LOTO) permit Condenser vent valve open - controlled by LOTO permit Condenser drain valve closed Visible air gap at RCW control valve Cell had greater than a " safe mass."
The above conditions existed when the cell was shutdown in 1995.
l The existence of a deposit greater than a safe mass was identified in March 1997, at which time j
USEC took actions as required by the Technical Safety Requirements (TSRs).
l m
r -SEC U
" " " " --~~-
l
l APPARENT VIOLATION 97013-01 CONCLUSIONS Criticality was not possible.
Safety Analysis Report (SAR) section 5.2, " Nuclear Criticality Safety," states that for shutdown cascade equipment with greater than a safe mass, adequate safety is achieved by the development of a TSR for moderation control.
TSR 2.2.3.15, " Moderation Control," was applicable to cell 29-5-8. Specifically, TSR Action C addresses a "UO F deposit > safe mass, not in a fluorinating environment, system is in a shutdown 2 2 mode, and coolant pressure s; RCW condenser pressure."
The required actions for this TSR are:
Increase coolant system pressure to > RCW pressure within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />; or Drain RCW from coolant condenser within 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />.
hm r USEC
" " " " --*-~-
l
APPARENT VIOLATION 97013-01 CONCLUSIONS (cont'd)
Compliance with this TSR action statement for cell 29-5-8 was satisfied as follows:
Condenser was drained at all times; Physical barriers between RCW system and Process Gas System maintained. In 1995, a cell negative was achieved verifying the integrity of the gas coolers. An R-114 negative verified the integrity of the coolant system; No indication ofRCW block valve leakage as evidenced by absence ofleakage at the air gap for the control valve.
The "Part C Matrix" of the NCSA was not satisfied since:
the cell was shutdown, the coolant pressure was not greater than the RCW pressure; and the drain valve was closed.
USEC has reevaluated the NCSA and its associated Engineering Evaluation, and has determined that the Part C matrix was flawed.
Compliance with the controls in the NCSA Part C matrix was not possible because when a cell is shutdown with the R-114 and RCW removed it is not possible to have the coolant pressure above the RCW pressure.
r
_SEC U
6 UnitedStates Enrichment Corporati<m
~ APPARENT VIOLATION 97013-01 ROOT CAUSES The NCSA Part C contingency :natrix was flawed:
The Part C matrix did not accurately reflect the evaluation (i.e., the NCSE).
It was not possible to achieve verbatim compliance with contingency B.6.a.1 controls for a shutdown cell with the R-114 removed as described in the Part C matrix.
The NCSA implementation process was inadequate. When the NCSA was initially developed in October 1996, it did not assure that cells shutdown under previous controls would be in compliance with the new controls in the NCSA.
M r
_SEC U
APPARENT VIOLATION 97013-01 CORRECTIVE ACTIONS Immediate_ Corrective Actions The RCW drain valve for cell 29-5-8 was opened.
All other condensers in a shutdown condition were inspected and, if the condenser drain valve was found closed, the drain valve was opened.
AdditionaLCorrectivelctions The NCS procedure was modified to include implementation requirement to review potential pre-existing conditions.
This particular NCSA was revised under the new NCS process, outlined in the NCS CAP committed to NRC to assure that reasonable, understandable controls are in effect and properly flowed down and implemented.
All NCSAs are undergoing an upgrade in the NCS corrective action plan to eliminate confusing controls.
=
4 Ayggc s
c.,-
4 l
APPARENT VIOLATION 97013-01 MITIGATING FACTORS This condition was self-identified by USEC during follow-up to a previous event and reported to NRC.
1 Prompt and thorough corrective actions were initiated by USEC upon discovery of this event.
The requirements ofTSR 2.2.3.15, " Moderation Control" were satisfied for cell 29-5-8.
Nuclear criticality was not possible.
The violation did not involve any deliberate non-compliances or careless disregard for NRC requirements.
Pased on the above, the condition of cell 29-5-8 does not meet the criteria for escalated enforcement.
r
_SEC U
~,
APPARENT VIOLATIONS 97013-02 thru 12 INTRODUCTION The remaining apparent violations concern weaknesses in the PORTS NCS program which are being addressed in the NCS Corrective Action Plan (CAP) that has been developed by USEC.
Tne NCS CAP was initially submitted to NRC on November 10,1997, and docketed updates were submitted to NRC on December 29,1997, and January 30,1998. Additionally, USEC has committed to provide NRC with quarterly updates, on the docket, to this CAP.
The NCS CAP includes an extensive root cause analysis and thorough, comprehensive corrective actions.
t The NCS CAP is dynamic. USEC will adjust it as new concerns are identified. For example, in the January 30,1998, submittal USEC informed NRC that this action plan did not adequately address the discovery of various operations where an NCSA did not exist. Accordingly, USEC is adjusting the CAP to address this issue.
&4 r
SEC U
" " " - -~-
APPARENT VIOLATIONS 97013-02 thru 12 ROOT CAUSE ANALYSIS A key element of the NCS CAP is the development of a thorough and accurate root cause assessment.
USEC embarked upon an aggressive program to analyze Problems Reports (prs) written during the past year to address NCS deficiencies.
Approximately 600 prs were analyzed and grouped into the following NCS process categories:
Self-Assessments (170)
Use (161)
Part B (Controls) and Part C Preparation (96)
Procedure Development
( 72)
Verification Walkdown (49)
Identification of Fissile Material Operation (FMO)
(21) t A variety of root causes applicable to most portions ofNCS Program.
MUSEC A Ghhal Energy Company
i APPARENT VIOLATIONS 97013-02 thru 12 ROOT CAUSE ANALYSIS (cont'd)
The Root Causes for the NCS Program Deficiencies have been grouped into the following categories:
Communications Procedures Training Accountability
[.*
t.SEC U
""~ - --- ~ ~ -
APPARENT VIOLATIONS 97013-02 thru 12 NCS CORRECTIVE ACTION PLAN Task 1:
Building Review ofNCSAs Complete Last 2 tasks (corrective actions) being done in accordance with Task 3 Task 2:
Review of those NCSAs Completed by Non-Qualified Personnel Completed ahead of schedule 6 prs issued Task 3:
NCSA Upgrade Project Ongoing Team members assigned from the facilities Adding NCS Engineers Scheduled for completion April 30,1999 MUSEC
"""""-- - ~ -
A Global Energy Company
APPARENT VIOLATIONS 97013-02 thru 12 NCS CORRECTIVE ACTION PLAN (cont'd)
Task 4:
Enhance NCSA Training (Interim NCSA Process)
Training started and scheduled List of people to be trained distributed to Organization Managers First Line Manager (FLM) and above that use, approve, or generate NCSAs Scheduled to be completed by February 28,1998 Task 5:
SS&Q Review ofImplementation Assessment Plan prepared Assessments scheduled with NCS A Upgrades SS&Q reviews of existing NCSAs on-going Scheduled to be completed by May 31,1999 Task 6:
Complete Root Cause Analysis Lower level root cause complete All identified root causes covered by a task subject Scheduled to be completed by February 28,1998 MUSEC
" " " " " " " ~ ~ " ' "
A Global Energy Company
APPARENT VIOLATIONS 97013-02 thru 12 NCS CORRECTIVE ACTION PLAN (cont'd)
Task 7:
Compare Applicable Industry Standards Against NCS Program Complete. Areas of concern noted.
Final report prepared, Problem Report issued Task 8:
Vertical Slice Methodology complete and in the approval process Team membership being finalized Scheduled to be completed by March 31,1998 Task 9:
Continuous Improvement Program Complete Lessons learned procedure approved and in place Five (5) Lessons Learned processed MUSEC A Global EnerEy Company
l APPARENT VIOLATIONS 97013-02 thru 12 NCS CORRECTIVE ACTION PLAN (cont'd)
Task 10:
Personnel Qualification Verification Compilation of qualification complete Changes: continuing training, minimum on-site requirements, disqualifications, qualifications of contractors, training records Scheduled to be completed by March 31,1998 Task 11:
Outside/ Independent Assessments Reports to be included identified Scheduled to be completed by April 30,1998 Task 12:
Policy / Procedure Revision and Training Procedure changes implemented for some actions On-going work on other procedure changes (Murder Board)
Scheduled to be completed by December 31,1998 l
l i
"""""-- - ~c - -
A Global Energy Company
APPARENT VIOLATIONS 97013-02 thru 12 NCS CORRECTIVE ACTION PLAN (cant'd)
Task 13:
Revise Training Program for Site Personnel Report drafled for evaluation of previous training Root cause evaluation completed Training program modified (NCSA specific, classroom & in-field drills)
Scheduled to be completed by April 30,1998 Task 14:
Corrective Action Program Enhancements Root cause complete Scheduled to be completed by June 30,1998 Task 15:
Configuration Management Program Enhancements Several changes identified and being made (e.g. Engineering packages)
Other changes being identified (e.g., Preventive Maintenance program)
Scheduled to be completed by February 28,1998 l
l s.
MUSEC
" " " " " ~ ~ ~ " ' " ' ' - " ~
A Global EnerEy Company
APPARENT VIOLATIONS 97013-02 thru 12 NCS CORRECTIVE ACTION PLAN (cont'd)
Task 16:
Revise Assessment Programs Focusing on "doing the right thing" Root causes and recommendations developed Scheduled to be completed by March 31,1998 Task 17:
Oversight ofPlan Implementation On-going assessments Scheduled to be completed by April 30,1999 Task 18:
Evaluation and Fc adback Weekly review meetings set for Thursday each week Detailed review of the task products Ongoing Task 19:
Evaluate Continued Use of" Murder Board" Ongoing MUSEC
" " " " " * ' " = " ~ ' ' ' ' "
A Global Energy Company
]
4 APPARENT VIOLATIONS 97013-02 thru 12 NCS CORRECTIVE ACTION PLAN (cont'd)
New Task:
Field Personnel 5 Full-time personnel assigned to facilities Selected from Health Physics, Operations & Engineering Personnel trained to NCS Supervisory Module NCSA specific training scheduled Guidance documents issued - procedure to be prepared New Task:
FMO Identification Short term review completed Systematic methodology developed and in review Control and communication mechanism being developed for non-fissile operations m'
r
_SEC U
" " " " ---c--
d APPARENT VIOLATIONS 97013-02 thru 12 i
l i
SUMMARY
OF ELEVEN VIOLATIONS IN NRC INSPECTION KlPORT 97013 (EXCLUDES CELL 29-5-8)
Description of Violation Appliczble CAI' Reference and Sumsnary 97013-02: Inadequate procedures or responding to the loss NCS CAP section D.7 has been implemented-Directions to stop f
of a nuclear criticality safety approval control and. secure activities and involve % uniste supervision and NCS experts has been implemented via standing orders and training.
l Procedure changes have been made.
97013-03: Failure to use material labeling and posting to Failure to use material labeling and posting identified as part of communicate procedural criticality controls Task 7 Industry Stancads Review. Problem Report issued.
Procedure changes will be made. Industry review being done to
[
identify the best method to implement.
i
[
97013-04: Failure to implement nuclear criticality safety Task 4, Enhance Training, is being implemented to continue to raise l
approval controls the awareness and importance of NCS Fur #=n compliance. Peopic f
on the operating floor to continue to raise the NCS awareness. Task 3 NCSA/E Upgrade Project,is revising NCSAs using a team concept. Task 13, Revise Training Program for Site Personnel,is ensuring a revised training gugam for NCSAs as they are developed.
i 97013-05: Failure to define or coi duct specific training for Training planned for NCS Manager
{
the nuclear criticality safety manager i
L t
t i
I a.
f USEC A cw Enerzr compaar 7
I
APPARENT VIOLATIONS 97013-02 thru 12
SUMMARY
OF ELEVEN VIOLATIONS IN NRC INSPEcuON REPORT 97013 (EXCLUDES CELL 29-5-8)
Description of Violation Applical,Je CAP Reference and Summary 97013-06: Failure to complete required training for nuclear Task 7, Compare Industry Standards Against NCS Propwn, was e:cended to cover SAR/ procedure differences. Task 2 is resiewing criticality safety stafT NCSAs of "nonqualified'* resenr.cl. Task 12, Policy / procedure Revision and Training, will revise procedures based on Task 7 findings.
97013-07: Failure to complete required training for nuclear Lesson learned submitted for qualification verification for NCS contractor staff.
l criticality safety contractors l
97013-08: Inadequate internal nuclear criticality safety self-Task 16, Revise Assessment Program, will initiate wustive action.
Root cause complete and recommended actions being developed I
assessment program and implementation 97013-09: Inadequate independent nuclear criticality safety Task 16, Revise Am.i.cn Prtgram, will initiate coustive action.
self-assessment program and implementation Root cause complete and recommended actions being developed 97013-10: Inadequate root cause evaluation and ccrrective Task 6, Complete a Comgem6ive Root Cause Analysis, will actions for recent nuclear criticality safety issues.
ensure that all root causes are identified and resolved as part of the CAP.
97013-11: Inadequate and improper procedure used in Task 3 NCSA/E Upgrade Process, is being done in accordance with corrective action process for recent nuclear criticality safety resised procedure.
issues.
~
" " " " - ~
r SFC U
l APPARENT VIOLATIONS 970!3-02 thru 12
SUMMARY
OF ELEVEN VIOLATIONS IN NRC INSPECTION REPORT 97013 (EXCLUDES CELL 29-5-8)
Description of Violation Applicable CAP Reference and Sususmary 97013-12: Inadequate corrective actions to a previous Task 14,Torrective Action Progran Eniwgen.er.ts " addresses the nuclear criticality safety violation deficiencies.
I 4
s f
SEC U
- -"= ~ -
APPARENT VIOLATIONS 97013-02 thru 12 MITIGATING FACTORS No previous escalated enforcement action for PORTS.
The apparent violations were not willful.
Violations did not individually or collectively involve deliberate noncompliances.
Reasons for violations vary, but none involve careless disregard of requirements.
All events were reported to NRC in accordance with regulatory requirements.
Broad and Comprehensive Corrective Action NCS Corrective Action Plan submitted December 22,1997, and January 30,1998.
Revised to address issues raised in cited violations.
Corrective Actions developed from thorough analysis of root causes for identified program deficiencies.
Generic implications for identified violations were considered.
USEC does not believe that a civil penalty should be assessed for these apparent violations because USEC has developed and is implementing broad and comprehensive corrective actions.
r USEC
" ~ ' - ' ' - -
I I
i l
j Uranium Enrichment Processes I
i SCHEMATIC OF RCW SYSTEM 4
DRIFT PLUME l
}
~
c RCWR w-
)
. gg i Y
CFC-114 VAPOR l
~
l [f-3 l
~ CONDENSER I
n
\\_
1 1
j CFV-114 U QUID UF6 g
COOLER Y-l RCW PUMP DNSEE y
CONVERTER) l COOLING TOWER
~
~
l E COLD
..y E VAPOR 4
E U QUID 4
E HOT
..