ML20206E378

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7002/99-01.Actions Will Be Examined During Future Insp

ML20206E378
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant
Issue date:	04/29/1999
From:	Hiland P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Adkins J UNITED STATES ENRICHMENT CORP. (USEC)
References
70-7002-99-01, 70-7002-99-1, EA-99-052, EA-99-52, NUDOCS 9905050107
Download: ML20206E378 (2)

Text

y April 29, 1999 EA 99-052 Mr. J. N. Adkins Vice President - Production United States Enrichment Corporation Two Democracy Center 6903 Rockledge Drive Bethesda, MD 20817 '

SUBJECT:

RESPONSE TO INSPECTION REPORT 70-7002/99001(DNMS)

Dear Mr. Adkins:

This refers to your April 14,1999, response to the Notice of Violation (NOV) transmitted to you by our letter dated March 17,1999, with Inspection Report 70-7002/99001(DNMS). We have reviewed your corrective actions and have no further questions 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,

/s/ P.L. Hiland Patrick L. Hiland, Chief Fuel Cycle Branch Docket No. 70-7002 Certificate No. GDP-2 cc: J. M. Brown, Portsmouth General Manager P. J. Miner, Manager, Nuclear Regulatory Affairs, Portsmouth H. Pulley, Paducah General Manager S. A. Toelle, Manager, Nuclear Regulatory Assurance and Policy, USEC Portsmouth Resident inspector Office Paducah Resident inspector Office R. M. DeVault, Regulatory Oversight Manager, DOE E. W. Gillespie, Portsmouth Site Manager, DOE /

DOCUMENT NAME: G:\SEC\POR99001.RES To receive a copy of this document, Ind6cate in the box:"C" = Copy without enclosure *E"= Copy with enclosure *N"= No copy bFFICE Rill e5L I E Rlli V l l NAME Kniceley:ib%_., Hiland OMd DATE 04d/99 49 04/JN99 OFFICIAL RECORD COPY 9905050107 990429 '

PDR ADOCK 07007002 C PDR

J. Adkins I bec w/ltr dtd 04/14/99: Docket File l PUBLIC IE-07 l J. Lieberman, OE i D. Dambly, OGC l E. Ten Eyck, NMSS R. Pierson, NMSS P. Ting, NMSS W. Troskoski, NMSS P. Harich, NMSS Y. H. Faraz, NMSS R. Bellamy, RI EJM, Ril (e-mail)

D. B. Spitzberg, RIV Greens w/o encI l

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USEC A Globd Energy Company April 14,1999 GDP 99-2018 4

. U. S Nuclear Regulatory Commission ,

I Attention: Document Control Desk Washington, D.C. 20555-0001 Portsmouth Gaseous Diffusion Plant (PORTS)

Docket No. 70-7002 Reply to Inspection Report (IR) 70-7002/99001 Notice of Violation (NOV) 99001-Ola,b The subject IR contained one violation with two examples involving the retum of" systems to service following safety actuations without appropriately documenting the safety actuations and understanding the root cause of the safety actuations." The United States Enrichment Corporation's response to this violation is provided in Enclosures 1 and 2 for examples (a) and (b) respectively.

Enclosure 3 lists the commitments contained in this submittal. These corrective actions should heighten personnel sensitivity to ensure appropriate actions are taken to prevent recurrence of these actuations. Unless specifically noted, the corrective actions specified in each enclosure apply solely to PORTS.

If you have any questions regarding this submittal, please contact Peter J. Miner at (740) 897-2710. I l

Sincerely, I M h J. Morris Brown General Manager Portsmouth Gaseous Diffusion Plant

Enclosures:

As Stated l

cc: NRC Regional Administrator- Region III-  !

NRC Resident inspector- PORTS l

l P.O. Box 800, Portsmouth, OH 45661 Telephone 614-897-2255 Fax 614-897-2644 http://www.usec.com g j g 1999 Offices in Uvermore, CA Paducah, KY Portsmouth, OH Washington, DC 0h[0l'Wk- /If ,

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Enclosure 1 GDP 99-2018 Page1of4 UNITED STATES ENRICHMENT CORPORATION (USEC)

REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/99001-01a j Restatement of Violation Technical Safety Requirement 3.9.1 requires, in part, that written procedures shall be implemented l for activities described in Appendix A of Safety Analysis Report Section 6.11, " Procedures."

Appendix A of Section 6.11 describes investigations and reporting as an activity that shall be i implemented in accordance with written procedures. Paragraph 2.1.3 of Procedure XP2-BM-  !

CIl030," Problem Reporting", requires that a problem report be initiated for false system actuations j related to safety system items.

Paragraph 5.1.2.a of Procedure XP4-SF-SF1110, " Plant Shift Superintendent Actions on Problem Reports," requires, in part, that anytime a safety system actuates, the system is not retumed to service j until the actuation is investigated, corrective actions are taken to prevent recurrence, and actions are documented and reported to appropriate level of management.

Contrary to the above:

i a) On January 12,1999, the certificatee retumed Autoclave No. I at Building X-344 to service following a steam shutdown, due to an apparent false system actuation of a safety system component, without initiating a problem report. As a result, no actions were taken to prevent recurrence.

USEC Response I. Reason for the Violation The reason for the violation was procedural noncompliances as a result of an error in i judgement by the First Line Manger (FLM) involved in this event. Further discussion as to the reason for this violation is presented below.

l As indicated in the IR, the FLM's reasoning for returning the autoclave to service without notifying the Plant Shift Superintendent (PSS) or investigating the root cause was the FLM believed that the component was not safety-related. The steam shutdown of the autoclave i that occurred at 0445 hours0.00515 days <br />0.124 hours <br />7.357804e-4 weeks <br />1.693225e-4 months <br /> on January 12,1999, was initiated by a spurious low instrument j air alarm. The FLM entered the appropriate Alarm Response Procedure (ARP), XP4-TE-  !

AR8741, which indicated that the initiating device for the alarm was pressure switch PSL-  !

105. The ARP required that actions be performed according to procedure XP4-TE-UH3770, l "X-344 Off-Normal Autoclave Operations." Section 8.3," Loss ofInstrument Air," of this procedure requires that the PSS be notified; however, the FLM did not believe that this 3

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4 Enclosure 1 GDP 99-2018 Page 2 0f 4 l

procedure applied because the instrument air pressure readings were normal indicating that the autoclave steam shutdown was caused by a spurious alarm of pressure switch PSL-105.

1 The FLM subsequently reviewed the plant drawing for Autoclave No.1 in Building X-344,  !

and, because he could not readily identify in the drawing the component that caused the autoclave containment, believed that the steam shutdown for the autoclave was caused by a Non Safety (NS) component.' The FLM also determined that there was no Technical Safety Requirement Limiting Conditions for Operation affected. This rationale led the FLM to believe that he did not have to notify the PSS of the autoclave steam shutdown or have to issue a Problem Report (PR). However, Procedure XP2-BM-CI1030," Problem Reporting,"

requires that a PR be issued for " False alarms or false safety actuations related to safety system items." Therefore, as a minimum, the FLM was procedurally required to initiate a PR which would have ensured that the PSS was notified in a timely manner of the autoclave steam shutdown.

l The FLM then directed plant operators to restart Autoclave No. I at 0500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> on January l 12,1999, utilizing a compensatory action (i.e., monitor the instrument air pressure reading l every hour) that was previously developed for another autoclave that had a problem with the low instrument air pressure switch. However, this action was contrary to the requirements of procedure XP2-SF-SF1034," Management of Compensatory Actions." This procedure 2

requires, as a minimum, that compensatory actions be recorded, be approved by the PSS, and a Plant Change Review (i.e.,10 CFR 76.68 review) be initiated. 1 The IR notes that a similar event occurred in October 1997, as discussed in Inspection Report 70-7002/97010, when Autoclave No. 4 at the X-343 facility was returned to service following a high steam pressure safety actuation without verifying the root cause and taking action to preclude recurrence. In the case ofNOV 97010-01, the reason for the violation was a lack of specific guidance detailing actions that should be taken to determine the reason for the actuation before returning an autoclave to service following an autoclave safety system actuation. Specifically, in that violation the PSS did not document that the actuation was not due to a valid signal or the basis for concluding that the safety system components were operating within design parameters. As a result, the PSS made an error in judgement and failed to make a conservative decision to declare the autoclaves inoperable following the

'In fact, PSL-105 is shown in the autoclave drawing (X-344-CA20-Z). This drawing and the Boundary Definition Manual clearly reflect that this component is a safety-related (i.e.,"Q")

component.

2XP2-SF-SF1034 defines a " Compensatory Action" as nn " action taken to mitigate the effects of an Out of Service, degraded SSC, Nonconforming Condition, or out-of specification parameter."

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I GDP 99-2018 Page 3 of 4 safety actuation. ' Additionally, the PSS did not document the justification for why he believed it was safe to continue operating. In the case of the circumstances that led to this violation (i.e., NOV 99001-Ola), the PSS was not informed that the autoclave had experienced a steam shutdown and was not informed that the autoclave had been returned to service without determining the root cause or actions to preclude recurrence.

II. Corrective Actions Taken

1. On January 12,1999, the FLM generated a work request for Maintenance to evaluate the spurious alarm of PSL-105. At 1040 hours0.012 days <br />0.289 hours <br />0.00172 weeks <br />3.9572e-4 months <br /> on January 12,1999 (i.e., the following shift), in preparation for the maintenance activity, the PSS declared Autoclave No.1 inoperable to investigate the cause of the low instrument air alarm.

It was subsequently discovered that the "as-found' reading on the low instrument air pressure switch was out-of-tolerance. Ilowever, the switch being out-of-tolerance did not contribute to the spurious actuation of the switch.

2. On January 14,1999, a PR was initiated (PR-PTS-99-00231) to evaluate Autoclave No.1 in the X-344 building for its ability to perform its safety function during the time PSL-105 was out-of-tolerance.

3. The Section Manager for the X-344 facility discussed the importance of this incident with the FLM. Specifically, the actions to be taken when a safety system actuates (including contacting the PSS), the methods used to identify safety systems, and the correct method of processing compensatory actions (per XP2-SF-SF1034) were l emphasized with the FLM.

4. . Crew briefings were conducted with the FLMs in the X-342,343, and 344 autoclave facilities regarding the events that led to this NOV. These briefings emphasized that any time a safety system operates or fails to operate (even if it caused by a NS component), the PSS is to be notified and a PR initiated (Note: a similar action for the FLMs in the other process facilities is discussed in Section 111 below).

5. A Lessons Learned Bulletin was developed and issued to Operations personnel  ;

regarding this event. Specifically, this bulletin emphasized that the PSS must be j involved whenever a safety system actuates.  !

6. The Autoclave No. I low instrument air pressure switch was recalibrated, post maintenance testing was completed satisfactorily, and the autoclave was returned to service without compensatory actions being necessary.  !

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Enclosure 1 GDP 99-2018 Page 4 of 4 l -III. Corrective Actions to be Taken l

.l. ' ARP XP4-TE-AR8741 will be revised to require that the1SS be notified when a safety system actuation occurs. Similarly, other ARPs that are Es'sociated with safety system actuations will be reviewed and revised, as appropriate, to require that the PSS be notified when a safety system actuation occurs. These revisions will be completed by August 31,1999

) 2. An Operability Training Module will be developed for Operations and Maintenance

, FLMs which will include the following topics: overview of operability, PSS l notifications, overview of compensatory actions, and boundary definition manual overview. This module will be developed and training of the appropriate FLMs completed by December 15,1999.

] IV. Date of Full Compliance l

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. USEC achieved full compliance on January 14,1999, when a PR was initiated (i.e, PR-PTS- '

l 99-00231) to evaluate Autoclave No. I for its ability to perform its safety function during the l time PSL-105 was out-of-tolerance.

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Enclosure 2 GDP 99-2018 Page1of3 UNITED STATES ENRICHMENT CORPORATION (USEC)

REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/99001-01b l

Restatement of Violation Technical Safety Requirement 3.9.1 requires, in part, that written procedures shall be implemented for activities described in Appendix A of Safety Analysis Report Section 6.11, " Procedures."

Appendix A of Section 6.11 describes investigations and reporting as an activity that shall be implemented in accordance with written procedures. Paragraph 2.1.3 of Procedure XP2-BM-CIl030, " Problem Reporting", requires that a problem report be initiated for false system actuations related to safety system items.

Paragraph 5.1.2.a of Procedure XP4-SF-SFl 110, " Plant Shift Superintendent Actions on Problem Reports," requires, in part, that anytime a safety system actuates, the system is not returned to service until the actuation is investigated, corrective actions are taken to prevent recurrence, and actions are documented and reported to appropriate level of management.

Contrary to the above:

b) On January 15,1999, the certificatee returned both Tails Station cranes to service following an actuation of the emergency braking safety systems without taking actions to prevent recurrence.

I USEC Response I. Background On January 15,1999, power was lost to the X-330 Tails North and South Cranes. At the time the power losses occurred, the North crane was not carrying any load and the South crane was carrying a solid 14 ton UF6 cylinder. The PSS that was on-shift declared the cranes inoperable and initiated a management response team to ascertain the reason for the loss of power. Maintenance inspected the cranes and discovered ice buildup on the feedrails to the cranes (Note: both cranes are covered by a metal canopy). The ice caused a single phase power interruption to the crane, as it transversed along the feedrails. The ice was l cleared from the feedrails and power was restored to both cranes on January 15,1999, and l

(in the case of the South crane) the suspended cylinder was safely set down.

l The PSS reviewed the Boundary Definition Manual (BDM) and determined that the crane bridge motor and brakes (which were actuated by the power outage) were not within the "Q"

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Enclosure 2 GDP 99-2018 Page 2 of 3 system boundary; therefore, the PSS did not consider this a safety system actuation'. Thus, the PSS believed that the requirements of Section 5.1.2.a of Procedure XP4-SF-SF1110,

" Plant Shift Superintendent Actions on Problem Reports," (i.e., anytime a safety system actuates, the system is not returned to service until the actuation is investigated and corrective actions are taken to prevent recurrence) did not apply.

The ice was removed from the feedrails, the cranes were operated through their full range of travel, and the PSS declared the cranes operable on January 15,1999. Ilowever, the PSS l

failed to determine the source of moisture that caused the ice buildup prior to returning the  !

cranes to service. Subsequently, on January 16,1999, the source of the ice buildup was l investigated and it was discovered that moisture was leaking through the Tails canopy and l freezing on the crane feedrails. Additionally,it was discovered that debris had clogged the  !

X-330 roofdrains causing an excessive accumulation of moisture on the Tails canopy. A PR was written and a work request was submitted to correct these problems, but the on-shift PSS did not declare the cranes inoperable nor request an operability determination be performed.

Subsequently, the NRC Resident inspectors expressed concerns about the cranes being returned to service without taking corrective actions to prevent recurrence of the loss of power. As a result, on January 20,1999, the cranes were declared inoperable.

I II. Reason for the Violation The reason for the violation was an error in judgement by the PSS. The PSS rationalized that, because the power loss to the North and South Tails cranes was caused by a NS component, the requirements of section 5.1.2.a of procedure XP4-SF-SFi110 did not apply.

However, regardless of whether the cranes were performing a safety function or not at the time the loss of power occurred, the PSS should have determined the cause of the moisture and ensured appropriate actions were in place prior to retuming the cranes to service.

Additionally, the PSS should have either declared the cranes inoperable or initiated an operability evaluation when it was discovered that the Tails canopy was leaking.

'The BDM and section 3.8.1.2.5,"X-330 Liquid UF Ilandling Cranes," of the Safety Analysis Report, both state that the "Q" safety systems of the X-330 Tails Cranes apply when the cranes are used for handling liquid UF cylinders. At the time the power loss occurred, neither crane was handling a liquid UF. cylinder. Additionally, the components that would perform a safety function, had the cranes been carrying a liquid cylinder (i.e., the hoist holding brake, eddy current brake, hoist motor), had already functioned in their normal mode of operation thus assuring that the crane failed in a safe position on the loss of power, ,

j l Enclosure 2 GDP 99-2018 s Page 3 of 3 IIL Corrective Actions Taken

1. On January 20,1999, both Tails cranes were declared inoperable, the crane canopy was repaired and the debris that clogged the roof drains was removed. Operational checks were performed on the North and South Tails cranes and subsequently, the cranes were declared operable at 2257 hours0.0261 days <br />0.627 hours <br />0.00373 weeks <br />8.587885e-4 months <br /> on January 20,1999,

2. Compensatory actions were developed and approved in accordance with XP2-SF-SF1034," Management of Compensatory Actions," for outside operation of the Tails, ERP, LAW, X-343, and X-344 facility cranes when the potential for freezing l conditions exists.

3. A Lessons Learned Bulletin was issued to the PSSs emphasizing the following:

appropriate corrections are to be taken to prevent recurrence, prior to returning equipment to operable status; prs shall be screened per procedure requirements to ensure appropriate actions are addressed; The PSS shall document the basis for operability and compliance determinations in the justification / comments / action section of the PR j

4. Periodic Preventive Maintenance actions have been added to inspect the facilities that have crane canopies (i.e., Tails and ERP) for leaks. (Tails canopy is the only one where drainage could be a problem.)

IV. Corrective Actions to be Taken

1. Procedure XP4-SF-SFl110. " Plant Shift Superintendent Actions on Problem Reports," will be revised by June 15,1999, to require that any time a TSR, Q, or AQ-NCS SSC actuates, the system is not returned to service until the actuation is investigated, the cause of the actuation is determined (if the cause of the actuation cannot be determined, an engineering evaluation will be conducted), corrective actions are taken to prevent recurrence, and these actions are documented and reported to the appropriate levels of management.

2. Procedures will be developed or revised as appropriate to discuss outside operation of the Tails, ERP, LAW, X-343, and X-344 facility cranes when the potential for freezing conditions exists as recommended by an engineering evaluation currently being performed. This action will be completed by August 18,1999.

V. Date of Full Compliance '

USEC achieved full compliance on January 20,1999, when repairs were made to the Tails canopy and the debris that clogged the roof drains was removed.

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• Enclosure 3 GDP 99-2018 Page1 of1 List of Commitments""

1. ARP XP4-TE-AR8741 will be revised to require that the PSS be notified when a safety system actuation occurs. Similarly, other ARPs that are associated with safety system  ;

actuations will be reviewed and revised, as appropriate, to require that the PSS be notified when a safety system actuation occurs. These revisions will be completed by August 31, 1999. I

2. An Operability Training Module will be developed for Operations and Maintenance FLMs which will include the following topics: overview ofoperability; PSS notifications, even'iew of compensatory actions, and boundary definition manual overview. This module will be i developed and training of the appropriate FLMs completed by December 15,1999.

3. Procedure XP4-SF-SFl110, " Plant Shift Superintendent Actions on Problem Reports," will be revised by June 15,1999, to require that any time a TSR, Q, or AQ-NCS SSC actuates, the system is not returned to service until the actuation is investigated and the cause of the actuation is determined; (If the cause of the actuation cannot be determined, an engineering evaluation will be conducted); corrective actions are taken to prevent recurrence; and these actions are documented and reported to the appropriate levels of management.

4. Procedures will be developed or revised as appropriate to discuss outside operation of the Tails, ERP, LAW, X-343, and X-344 facility cranes when the potential for freezing conditions exists as recommended by an engineering evaluation currently being performed.

This action will be completed by August 18,1999.

! "" Regulatory commitments contained in this document are listed here. Other corrective i actions listed in this submittal are not considered regulatory commitments in that they are either statements of actions completed, or they are considered enhancements to USEC's investigation, procedures, programs, or operations.

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