ML20207G264

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7002/99-03 Sent on 990528.Reviewed Corrective Actions & Have No Futher Questions.Actions Will Be Examined During Future Insp

ML20207G264
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant
Issue date:	06/08/1999
From:	Hiland P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Adkins J UNITED STATES ENRICHMENT CORP. (USEC)
References
70-7002-99-03, 70-7002-99-3, NUDOCS 9906110080
Download: ML20207G264 (2)

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! l June 8, 1999 l

Mr. J. N. Adkins Vice President - Production United States Enrichment Corporation '

Two Democracy Center 6903 Rockledge Drive Bethesda, MD 20817 i

Dear Mr. Adkins:

This refers to your May 28,1999, response to the Notice of Violation (NOV) transmitted to you by our letter dated April 29,1999, with inspection Report 70-7002/99003(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, f f Patrick L. Hiland, Chief  ;

Fuel Cycle Branch l Docket No. 70-7002 Certificate No. GDP-2 .

cc: J. M. P;own, Portsmouth General Manager P. .'. Miner, Manager, Nuclear Regulatory Affairs, Portsmouth P. Pulley, Paducah General Manager S. A. Toelie, Manager, Nuclear Regulatory Assurance and Policy, USEC Portsmouth Resident inspector Office Paducah Resident inspector Office .

R. M. DeVault, Regulatory Oversight Manager, DOE i E. W. Gillespie, Portsmouth Site Manager, DOE DOCUMENT NAME: G:\SEC\POR99003.RES To receive a copy of this document, indicate in the box:"C" = Copy without enclosure "E*= Copy with enclosure"N"s No copy C

DFFICE Rill lC Rlil l NAME Kniceley:ib %$ '

Hiland P#~6efM DATE 06/n/99 06/$ /99 OFFICIAL RECORD COPY 9906110000 990608 PDR ADOCK 07007002 C pon

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J. Adkins cc w/ltr dtd 05/28/99: Docket File PUBLIC IE-07 l R. Pierson, NMSS l P. Ting, NMSS l W. Troskoski, NMSS ,

I P. Harich, NMSS Y. H. Faraz, NMSS R. Bel:amy, RI EJM, Ril (e-mail)

D. B. Spitzberg, RIV Greens J

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I May 28,1999 GDP 99-2028 .

l U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Portsmouth Gaseous Diffusion Plant (PORTS)

Docket No. 70-7002 Reply to Inspection Report (IR) 70-7002/99003 Notice of Violation (NOV) 99003-02a,b The subject IR contain~' te violation with two examples involving the failure to follow procedures i while performing u Snra space entry. The United States Enriclunent Corporation's response to this violation is provicea in Enclosure 1. Enclosure 2 lists the commitments contained in this submittal. Unless specifically noted, the corrective actions specified in each enclosure apply solely to PORTS.

If yo'u have any questions regarding this submittal, please contact Peter J. Miner at (740) 897-2710.

Sincerely, L-l w .lA 6 J. Morris Brown General Manager Portsmouth Gaseous Diffusion Plant

Enclosures:

As Stated cc: NRC Regional Administrator - Region III NRC Resident Inspector - PORTS United States Enrichment Corporation JUN 4 E Portsmouth Gaseous DifTusion Plant p '.O. Ikix 628. Pileton. OH 45661

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i Enclosure 1 GDP 99-2028 Page 1 of 4 UNITED STATES ENRICIIMENT CORPORATION (USEC)

REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/99003-02a,b Restatement of Violation

• Technical Safety Requirements 3.9.1, requires that written procedures shall be prepared, reviewed, )

approved, implemented, and maintained 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.

Safety Analysis Report, Section 6.11, Appendix A, described a partial list of activities that shall be covered by written procedures, including chemical safety and radiation protection.

a) Procedure XP2-SH-IH1032, Revision 0, Change A, dated May 3,1995, " Confined Space Program," required, in part, that work activities conducted in confined spaces, shall be conducted in accordance with an approved and issued confined space permit. Confined Space Entry Permit Number 99-330-04 required, in part, an attendee [an employee stationed outside the confined space] to maintain continuous visual and voice communication with operators working inside Building X-330, Cell 31-3-3.

b) Procedure XP2-HP-HO1032, Revision 0, dated May 22,1998, " Radiological Work Permit,"

required, in part, that work activities conducted in a radiological control area, shall be conducted in accordance with an approved and issued radiological work permit. Radiation Work Permit Number 99-330-0008-3-G required, in part, the group manager to ensure that air samples and contamination surveys were performed prior to entry into a cell housing.

Contrary to the above, operations activities were not performed in accordance with documented procedures in the following examples, respectively:

a) On March 25,1999, the attendee failed to implement the requirements of Confined Space l Entry, Permit Number 99-330-04, which was required by Procedure XP2-SH-IH1032.

Specifically the attendee failed to maintain continuous visual and voice communication with operators working inside Building X-330, Cell 31-3-3.

b) On March 25,1999, the group manager failed to implement the requirements of Radiation Work Permit Number 99-330-0008-3-G, which was required by Procedure i XP2-HP-HO1032. Specifically the group manager failed to ensure that air samples and

! contamination surveys were performed prior to operators entering Building X-330, Cell 31-3-3.

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I Enclosure 1 GDP 99-2028 Page 2 of 4 l USEC Response I

L Reason for the Violation The reason for the violation was due to a failure to follow procedures by the Facility '

Operations Manager (referred to as the group manager in the cited violation) who was coordinating the confined space entry.

The FacMity Operations Manager failed to review the requirements of procedure XP2-SH- ,

IH1032, " Confined Space Program," during the pre-job briefing, as required. Section 5.7.3 )

of this procedure specifically requires that the Authorized Attendant to the confined space be responsible for ensuring that the communication methods for maintaining contact with ,

authorized entrants are established prior to allowing entry into a permit space. On the i Confined Space Permit, the Facility Operations Manager incorrectly checked " voice" and  !

" visual" as the communication methods. Neither of these methods were effective in the confined space due to noise levels from the adjacent cell, the distance the entrants were from the attendant's location and visual obstructions inside the housing. An alternate choice (i.e.,

"other") should have been checked on the Confined Space Permit and the appropriate  ;

communication method provided to, and understood by, the parties involved prior to entry. l As a result of the investigation into this event, we discovered that the confined space l procedure does not provide examples of the types of communication methods that can be l utilized during a confined space entry.

l The applicable Radiation Work Permit (RWP), Number 99-330-0008-3-G, contained a " Hold Point" section which specifically required that a radiological air sample be obtained for the confined space entry and also that a contamination survey was required prior to entry. l Performance of these tasks require assistance from the Health Physics (HP) Department.

However, the Facility Operations Manager incorrectly determined that the " Hold Points" l were not applicable since he believed that these requirements did not apply for the

" inspection" that was being performed. Therefore, the Facility Operations Manager did not request HP's assistance prior to the confined space entry.

Additionally, the Facility Operations Manager did not comply with the requirements of XP3-CO-C01230, " Management Control ofInfrequently Performed Tests or Evolutions." The confined space entry was properly classified as an Infrequently Performed Tests or Evolution (IPTE). The purpose of this procedure is to increase management's attention to and control ofIPTEs This procedure requires operations management to appoint an IPTE Coordinator and that both the IPTE Coordinator and the designated operations management representative attend the pre-job briefing in order to provide the appropriate management oversight.

However, in this case, the Facility Operations Manager served both as the operations management representative and the IPTE Coordinator. The Facility Operations Manager

i Enclosure 1 GDP 99-2028 Page 3 of 4 should have appointed a separate individual to perform one of these functions.

II. Corrective Actions Taken

1. On March 25,1999, following the receipt ofinformation that the requirements of the Confined Space Program procedure were not being followed, a stop work notice was issued which prohibited confined space entries into cell housings until the procedural requirements for confined space entries were reinforced with applicable personnel.

The stop work notice was subsequently lifted on March 31,1999, upon completion of reviewing these requirements with applicable operation personnel.

2. The requirements for confined space entries were discussed with the Facility Operations Manager responsible for the Cell 31-3-3 entry.

3. Industrial Hygiene and Safety issued a memorandum reinforcing the requirements of the Confined Space Program procedure regarding the responsibilities of the Authorized Attendant and the need for maintaining communication during a confined space entry. This memorandum was reviewed with the Cascade First-Line Managers and Operators.

4. The Radiological Protection Manager directed HP to close the RWPs for X-326, X-330, and X-333 associated with Cell Housing Entries. New RWPs were issued with Hold Points which require a radiological air sample to be performed prior to the first entry and UF6leak detector cannot be in alarm status.

III. Corrective Actions to be Taken

1. Lessons Learned on the events that led to this NOV will be developed and crew 7 briefings will be conducted with Cascade Operations personnel to reinforce the j requirements for procedural compliance, pre-job briefing, and understanding job responsibilities prior to performing an IPTE. This action will be completed by June 29,1999.

2. Procedure XP2-SH-lH1032, " Confined Space Program," will be revised to provide examples of the types of comtr mication methods that can be utilized during a confmed space entry. This action will be completed by November 5,1999.

IV. Date of Full Compliance USEC achieved full compliance on March 31,1999, when the stop work notice was lifted which had prohibited confined space entries into cell housings and the procedural requirements for confined space entries were reinforced with applicable operations personnel.

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! Enclosure 2 GDP 99-2028 Page1ofI List of Commitments

• l l 1. Lessons learned on the events that led to this NOV will be developed and crew briefings will

l. be conducted with Cascade Operations personnel to reinforce the requiren*nts for procedural compliance, pre-job briefing, and understanding job responsibilities prior to performing an IPTE. This action will be completed by June 29,1999.

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• Regulatory commitments contained in this document are listed here. Other corrective l 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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