ML20210K029
| ML20210K029 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 07/30/1999 |
| From: | Jonathan Brown UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-7002-99-06, GPD-99-2035, NUDOCS 9908050186 | |
| Download: ML20210K029 (19) | |
Text
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USEC A Global Energy Company
-July 30,1999 GDP 99-2035 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Portsmouth Gaseous Diffusion Plant (PORTS)
Docket No. 70-7002 Revised Reply to Inspection Report (IR) 70-7002/99006 Severity Level (SL) IV Notice of i
Violations (NOVs)
On May 28,1999, the United States Enrichment Corporation (USEC) submitted to the Nuclear Regulatory Commission (NRC) a reply to the SL IV NOVs contained in IR 99006 (see USEC letter
' GDP 99-2025). On June 23,1999, the NRC submitted a letter to USEC which expressed concerns with USEC's reply to NOVs 99006-01 and 99006-03. Enclosure 1 lists each of the NRC's concerns followed by USEC's response. For purposes ofcontinuity, USEC is resubmitting our entire response to the SL IV NOVs in IR 70-7002/99006 (see Enclosures 2,3, and 4). The revisions to the NOV replies are indicated by change bars in the right hand margin. Enclosure 5 lists the commitments contained in this submittal. Unless specifically noted, the corrective actions specified in the enclosures apply solely to PORTS.
During a conversation on July 20,1999, the PORTS Nuclear Regulatory Affairs Manager advised the NRC Resident inspector that additional time was required to respond to the NRC's concerns.
Accordingly, USEC requested the due date for this NO V response to be extended to July 30,1999.
If you have any questions regarding this submittal, please contact Peter J. Miner at (740) 897-2710.
Sincerely, X
}
f-J. Morris Brown I/<
General Manager Portsmouth Gaseous Diffusion Plant
Enclosures:
As Stated
.cc.
NRC Regional Administrator - Region Ill
'hiD NRC Resident Inspector - PORTS 9909050186 990730
' 'tates Enrichment Corporation PDR ADOCK 07007002 iuth Gaseous Diffusion Plant C
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.ox 628, Piketon, OH 45661 lL.
GDP 99-2035 Page1of3 UNITED STATES ENRICIIMENT CORPORATION (USEC)
RESPONSE TO NRC CONCERNS ON INSPECTION REPORT (IR) 70-7002/99006 SEVERITY LEVEL (SL) IV NOTICE OF VIOLATIONS (NOVS)
Restatement of NRC Concern With regard to Violation 1.B, our Notice detailed four deficiencies in the performance of the nuclear criticality staffincluding failure to: 1) determine if an anomalous condition involved an unanalyzed condition; 2) assess the safety significance of an as-found condition; 3) identify the nuclear criticality safety controls affected by the anomalous condition; and 4) complete the anomalous condition report within the reportability time-frame for the condition.Section II, " Reason for the Violation," and Section III, " Actions Taken and Results Achieved," of your response to Violation 1.B only addressed sub-item 1) which involved the failure to determine if the condition was an unanalyzed condition.
The response failed to discuss root cause(s) or actions to prevent recurrence for sub-items 2),3) and
- 4) of Violation 1.B.
USEC Resnonse USEC concurs with the above NOV comment and has revised the response to Example B of NOV 99006-01 accordingly.
Restatement of NRC Concern With regard to Violation 1.D,Section II, " Reason for the Violation,' of your response appears to identify two causes for the violation; the " complexity of the recovery activities," appears to be a stated cause, and the need for " supplemental actions necessary, as a result of a fire, should be captured in a stand alone Off-Normal procedure" appears to be another identified cause. Our review of your entire response indicates that the first stated cause for Violation 1D " complexity of the recovery activities" may be adequately addressed by your corrective actions for Violation 2 in the Notice. In your response to Violation 2, you stated that alarm response procedures would be developed, and we believe this actica can address the first stated cause, i.e., "the complexity of recovery activities." The second cause for Violation 1 D " supplemental actions necessary, as a result of a fire, should be captured in a stand alone oft-Nonnal procedure," does not appear to be addressed in your response. In your response to Violation 1.D, in Section IV, " Actions to be Taken," you state that inadequate procedures are discussed under your response to Violation 2; however, the corrective actions stated for your response to Violation 2,Section III, " Actions to be Taken," do not provide sufficient detail to provide assurance that the stated cause for Violation 1.D will be corrected.
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GDP 99-2035 Page 2 of 3 USEC Response 1
The documentation and caution tagging requirements for the coolant condenser Recirculating Cooling Water (RCW) valves were overlooked because of the complexity of the recovery activities.
However, the root cause of this example of the violation was the lack of an Off-Normal procedure to ensure that when requirements contained in normal operating and information use procedures are not able to be performed due to an off-normal situation, then these requirements are performed following the recovery effort. The Reason for the Violation and Corrective Actions to Be Taken sections for this example of the NOV response have been revised accordingly.
Restatement ofNRC Concern With regard to Violation 3.A your response addressed the two areas of responsibilities referenced in the Notice where the duties of the Reliability Engineering Manager were not being implemented
- by site procedures; however, the two referenced responsibilities were only examples of the deficient corrective action plan and were not intended to be the only identified deficiencies. During the course of our inspection, the inspectors discussed in detail with cognizant Portsmouth staff members the
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failure of the existing." Equipment History Program" corrective action plan to address all the necessary elements with respect to assuring the Reliability Engineering Manager's responsibilities were clearly defined and implemented. At the time of our inspection, there were numerous responsibilities assigned to the Reliability Engineering Manager, none of which had been captured in the corrective action plan.
USEC Response USEC concurs with the above NRC comment. The responsibilities of the Reliability Engineering
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Manager (section 5.3 ofXP2-GP-GP1040) have been reviewed and it has been determined that these responsibilities are either being fulfilled or that an action is being taken to address the deficiency.
USEC's reply to Violation 3.A has been revised accordingly.
Restatement of NRC Concern Based upon our review and the corrective actions specified in your response, we also determined that the presented "Date of Full Compliance" provided for Violations 1.A., l.B., l.D.,3.A., and 3.B. were
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not valid in that corrective actions for certain of the root causes were not provided.
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GDP 99-2035 Page 3 of 3 USEC Response USEC has typically interpreted the "Date of Full Compliance" to be when the actions were completed which brought USEC into compliance with the specific noncompliance that resulted in j
the violation. In the case of Violations 1.A, l.B. 3.A, and 3.B, USEC agrees that the Date of Full Compliance is not properly worded and has revised these sections, respectively. With respect to Violation 1.D, USEC believes that the Date of Full Compliance is correct in that compliance was achieved when the RCW Isolation Valves were properly tagged and logged.
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4 GDP 99-2035 Page 1 of 8 UNITED STATES ENRICIIMENT CORPORATION (USEC)
REVISED REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/99006-01 Restatement of Violation Technical Safety Requirement 3.9.1 requires, in part, that written procedures shall be implemented for activities listed in Appendix A to Safety Analysis Report, Section 6.11. Appendix A listed the startup, operation, and shutdown of cascade cells; nuclear criticality safety; and investigations and reporting as activities requiring written procedures. In addition, A.
Procedure XP4-CO-CA3900C, Revision 0, " Control of Damaged Centrifugal Compressors,"
effective date December 24,1997, Section 2.0, "Immediate Actions," Step 2.1 required, in part, an operator to stop afTected cell motors from the fastest location upon excessive stage overload or an unexplained rise in motor amp load. Step 2.2 required the operator to take the cell off stream [ isolate] in accordance with procedure XP4-CO-CN2102C. Procedure XP4-CO-CN2102 referred the operator to Procedure XP4-CO-CN2410 which contained guidance on how to isolate Cell 25-7-2 in Building X-326 from the rest of the cascade.
B.
Procedure XP4-EG-NS1025, "NCS Nuclear Criticality Safety Response to Anomalous Conditions," Revision 0, Change B, effective date November 30,1998, required, in part that nuclear criticality safety staff shall: 1) determine if an anomalous condition involved an unanalyzed condition; 2) assess the safety significance of an as-found condition; 3) identify the nuclear criticality safety controls affected by the anomalous condition; and 4) complete the anomalous condition repcrt within the reportability time-frame for the condition.
j C.
Procedure UE2-RA-RE1030," Nuclear Regulatory Event Reporting," Revision 2, Change z
C, effective date March 3,1997, required, in part, the Plant Shift Superintendent to determine whether an event or condition was reportable to the NRC according to the criteria listed in Appendix D of the procedure. Appendix D, criteria A.3.a.,c(1), and c(3) specified, in part, that a report shall be made to the NRC, within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from initial observation, for operations that do not comply with the double contingency principle [i.e., operations that are singly contingent) for which moderation is used as the primary critica control and that involve: 1) the occurrence of any unanalyzed event for which the safety significance of the event or corrective actions to re-establish the approved controls are not readily identifiable; or 2) the controlled parameter and the control on the parameter cannot be re-established within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after the initial observation of the event.
D.
Procedure XP4-CO-CA2182, " Control of Large Air Inteakage," Revision 1, Change C.
effective date February 10,1997, and XP2-SH-IS1034, " Accident Prevention / Equipment Control Tags," Revision 0, Change A, effective date July 7,1997, required, in part, that the plant staff shall take specific actions to control (tagging and logging) recirculating cooling
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GDP 99-2035 Page 2 of 8 water to shutdown cells and shall implement specific temporary repairs for events which result in large inleakages to the cascade.
Contrary to the above,
'A.
On December 9,1998, a Building X-326 operator did not stop cell motors from the fastest location upon unexplained rises in motor amp load which lead to an excessive stage overload
' in Stage 2 of Cell 25-7-2. In addition, the operator did not refer to or immediately isolate the cell from the rest of the cascade in accordance with Procedures XP4-CO-CA3900C, XP4-CO-CN2102C and XP4-CO-CN2410.
B.
On December 9,1998, the nuclear criticality safety staff did not: 1) identify that an anomalous condition resulting from the Cell 25-7-2 fire involved an unanalyzed condition;
- 2) incorporate into the safety evaluation the potential presence and impact of a deposit within the cell; 3) properly identify the nuclear criticality safety controls affected by the anomalous condition; and 4) complete the anomalous condition report within the reportability time-
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frame (4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) for the conditions present.
- C, On December 9,1998, the Plant Shift Superintendent did not make a notification to the NRC
._within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> ofinitial observation of the loss of moderation control for a singly contingent activity, operation of cascade Cell 25-7-2, as a result of holes in the cascade piping and components which precluded the implementation of moderation control using a dry gas buffer, an unanalyzed condition, for which corrective actions were not readily identifiable.
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D.
On December 9,1998, the plant staff did not tag and log the status of cell 25-7-2 related -
recirculating cooling water valves and pipe spool pieces, controlled for nuclear criticality safety-related purposes, and did not implement temporary repairs to the cascade as specified
'in procedure XP4-CO-CA2182 and XP2-SH-IS1034 for a cell that was shutdown as a result of a fire which caused a large in leakage of air into the cascade.
- USEC Response I.
Background Information The examples of the cited violation all relate to an X-326 fire in Stage 2 of Cell 25-7-2 which occurred on December 9,1998. At approximately 0605 hours0.007 days <br />0.168 hours <br />0.001 weeks <br />2.302025e-4 months <br /> on December 9,1998, the Area Control Room 6 (ACR-6) operator, while recording hourly readings, observed Cell 25-7-2, Stage 2, ammeter briefly deflect to 70% of the full scale reading and then return to a normal reading of approximately 30% of full scale. The operator interpreted this momentary
- deflection as a possible coolant bubble moving through the Purge Cascade. This incorrect assumption was based upon the ACR-6 operator's knowledge of a previous condition where
. a " bubble" had moved up the cascade earlier that morning. A conceptual error related to
a GDP 99-2035 Page 3 of 8 system response resulted in an incorrect evaluation by the operator of the Stage 2 motor ammeter deflection, because an actual coolant bubble moving through the Purge Cascade would have resulted in minor decreasing motor ammeter oscillations.
Immediately following the Cell 25-7-2 trip, the operator depressed the Cell-Off-Split button (which should have resulted in a full split in Cell 75-7-2) but, the expected equipment response (i.e., a green light) did not occur, indicating one or more cell isolation valves were not fully closed. In addition, because the operator was not fully cognizant of the unique system configuration of the Side Purge, an additional isolation valve (i.e., the internal A-line Stage 4 manual block valve [AB2S4], used to create the stripping section) remained open.
While procedure XP4-CO-CN2410 contained guidance on isolating Cell 25-7-2 from the cascade, the operator had to utilize several other cascade procedures before obtaining the appropriate method to isolate the affected cell which was not conducive to this particular emergency situation.
By 0800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br />, firefighters began to examine the affected area for hot spots, and noticed that the process piping had been breached. Firefighting activities were curtailed and Nuclear Criticality Safety (NCS) was consulted to determine how best to proceed. The NCS staff responded with verbal and written guidance on firefighting techniques and post-fire corrective actions which directed that the cell be monitored for deposits, any openings in the cell be covered, and to buffer the cell as soon as practical. In addition, NCS reviewed previous cell deposit monitoring information which indicated that a less than " safe mass" condition existed in the cell prior to the event. NCS also reviewed the expected cell UF, inventory [ documented in the Safety Analysis Report (SAR)] and concluded that it was unlikely that deposits exceeding a minimum critical mass were possible.. Thus, plant personnel focused on Technical Safety Requirement (TSR) limitations and other equipment and occupational safety issues to the extent that personnel did not correctly apply the reporting criteria which required the NRC to be notified within four hours after an initial observation of an event where moderation control was lost. Recovery efforts focused on returning the damaged cell to a condition compliant with the existing Nuclear Criticality Safety Approval (NCSA) and TSR (i.e., covered and buffered within eight hours).
At approximately 1630 hours0.0189 days <br />0.453 hours <br />0.0027 weeks <br />6.20215e-4 months <br />, plant personnel realized that " moderation control" could not be restored to the damaged cell within the time limits specified in the NCSA or the TSR. A problem report was subsequently initiated to report this NCS non-compliance and an anomalous condition incident report was completed within four hours from receipt of the problem report. The report concluded that all double contingency controls had been lost. This conclusion was reached because the Nuclear Safety Criticality Evaluation / Approval (NCSE/A) stated that a wet air in-leakage event was singly contingent only if a greater than safe mass deposit existed. While the SAR evaluation documented that the mass of any
- deposit formed in the Side Purge would likely be less than a minimum critical mass, the NCS
. Manager required confirmation (via Non-Destructive Analysis) that a safe mass condition
GDP 99-2035 Page 4 of 8 l
had not been exceeded. In the case of this exothermic incident, " mass control" was not lost because the resultant pressure surge dispersed _UF away from the breach reducing the probability of fomiing a significant UF deposit. Ilowever, the anomalous condition report that was completed was not adequate in determining if the Cell 25-7-2 fire involved an unanalyzed condition, because the Nuclear Criticality Safety Evaluation (NCSE) used for the assessment did not document or analyze for the condition that potentially existed if cell containment could not be restored and buffered within the time constraints specified by the NCSA.
Shortly after the fire was declared out, the affected areas were boundaried off and access strictly limited to only essential personnel who would be needed to assess the status of the cascade, assess the damage, and to take appropriate corrective measures to ensure the affected area remained in a safe condition. Some of these activities involved isolating cells that had been tripped, performing leak rate checks of shutdown cells, ensuring that recirculating water was isolated from shutdown cells, and shutting down cells that were suspected of experiencing in-leakage to the cascade.- As a result, the documentation and l
caution tagging requirements for the Recirculating Cooling Water (RCW) valves were l
overlooked because of the complexity of the recovery activities. These requirements were l
contained in normal operating and information use procedures.
l II.~
Reason for the Violation Examole A l
The reasons for this example of the violation were:
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Inadequate training led to a misinterpretation of observed plant pararneters. This l
resulted in the operator not recognizing the appropriate entry conditions of the l
referenced abnormal operating procedure. Specifically, the operator failed to l
recognize the initial motor ammeter deflection as an overload condition or to I
recognize that a compressor failure was about to occu-Procedures used w.cre not adequate to support emergent actions. Specifically, l
inadequate procedure design was the reason Cell 25-7-2 was not expeditiously isolated iiom the operating cascade as discussed in the accident analysis. Inadequate training also contributed to not immediately isolating the cell because the operator was not fully aware of the system's configuration.
GDP 99-2035 Page 5 of 8 Example B l
l The reasons for this example of the violation were:
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There was inadequate procedure guidance concerning preparing and completing l
anomalous condition reports in a timely manner. Specifically, procedure XP4-EG-l NS1025, " Anomalous Condition," is inadequate because the procedure did not l
include action steps to require the user to document why an anomalous condition is, I
or is not, analyzed.
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The above procedure does not provide guidance on the level ofinformation to be l
included in the Anomalous Condition Report. ' As a result, while the initial evaluation l
of the safety significance of the event included consideration of the potential presence j
of a deposit in the cell prior to the event, this assessment was not included in the l
Anomalous Condition Report.
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NCS properly identified that moderation controls were lost when it was reported to l
them that the system was breached. ' NCS provided instructions to the plant to cover l
and buffer the cell as soon as possible. However, due to not reviewing the SAR l
designation of the cascade as a singly contingent operation in addition to the TSR and l
NCSA/E, NCS did not identify that they were outside the TSR/NCSA moderation l
control parameters when the initial breach was reported. Specifically, NCS believed ' l that the system could remain within the moderation control requirements ifit could l
be buffered within eight hours.
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NCS was fully _ consumed with providing analysis, consultation and direction to l
response personnel during the initial hours following the event. NCS did not initiate l
an Anomalous Condition Report when.the system breach was first reported because j
they believed that they were within the TSR/NCSA parameters for moderation l
control if the system could be covered and buffered within eight hours. In addition, l
they believed that the event had been communicated to the NRC.
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Example C l
l The reason for this example of the violation was incorrect application of the reporting criteria l
due to personnel error. Specifically, personnel did not correctly apply the reporting criteria l
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(i.e., to notify NRC within four hours after an initial observation of an event where moderation control was lost), because plant personnel believed that the reporting criteria did
, not apply until the time limits specified in the X-326 Building Cascade Operations NCSA had been exceeded.
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GDP 99-2035 Page 6 of 8 l
~ Example D The reason fer this example of the violation was the lack of an Off-Normal procedure to l
ensure' that procedure requirements that are not able to be performed during recovery l
activities are properly coordinated and performed following the termination of the recovery l
activity.
l Ill.
Actions Taken and Results Achieved Actions 1-3 are corrective actions previously described in Event Report 98-17.
l.
Training was developed and implemented to address cell trips, cell isolation, compressor surging, and compressor overloads. The training module has also been updated to' provide a thorough discussion of off-normal conditions and indications, alarm response actions, and pertinent design basis accidents as discussed in the SAR.
Specifically, the training module provides a more defined criteria for taking actions to trip and isolate a cell based on the ammeter indications. (Addresses Example A) l 2.
A briefing was initiated for X-326 Facility Operations personnel. The briefings included a description of the X-326 fire ir.cident, how the incident was handled and what indicators to be aware of when such an event is occurs. The briefing l
emphasized the steps necessary for tripping and isolating a. cell and those actions to take if cell block isolation valves fail to fully close. (Addresses Example A) 1
- 3.
. Operators were provided guidance on the causes ofmotor amp changes and how each of these causes affect cell panel ammeter indications in the ACR and other available instrumentation. (Addresses Example A) l 4.
On March 26,' 1999, a group briefing was conducted with the NCS staff to discuss l
NCS's responsibility in assisting the plant in determining if an identified hazard involves an unanalyzed condition. Specifically, NCS staff does not need to wait for l
a Problem Report (PR) to be issued before evaluating an emergent condition.
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'(Addresses Example B) l
'5.
NCS staff were also issued a Lessons Leamed that the cascade operation, as a whole, l
- is singly' contingent for a' loss of-moderation control. Th'e Lessons Learned l
emphasized that a loss of moderation control in the cascade requires evaluation using l
the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> reporting criteria. (Addresses Example B) l 6.-
NCS_ staff were briefed on the need to include all pertinent factors considered in l
making a determination _of safety significance in preparation of the Anomalous l
Condition Report using the example cited by the NRC concerning the failure to l
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l GDP 99-2035 Page 7 of 8 include the consideration of the potential presence of a deposit in the cell prior to the l
event (i.e., the fire). (Addresses Example B) l 7.
Procedure XP4-EG-NS1025, "NCS Response to Anomalous Conditions," was l
-revised to include a requirement for NCS to provide guidance to the Plant Shift l
Superintendents (PSS) to reestablish compliance with the applicable NCSA and to l
. develop (or revise) an NCSA if compliance cannot be reestablished in a timely l
manner. (Addresses Example B) l l
' 8.
On March 25,1999, a corrected four hour notification was submitted to report the l
loss of moderation control resulting from the December 9,1998, X-37.6 Cell fire.
(Addresses Example C) l 9.
On May 1,1999, required reading was initiated for the PSS to increase the awareness level of the reporting criteria where NCS controls are lost involving singly contingent operations. (Addresses Example C) l 10.
On February 22,1999, caution tags were prepared and hung on Cell 25-7-2 Coolant l
Condenser RCW Isolation, Vent and Drain valves to meet the requirements of XP4-CO-CA4625. (Addresses Example D) l l
IV.
Actions to be Taken Examples A and D l
The actions to be taken for the inadequate procedures (Examples A and D) are discussed l
under the response to violation 70-7002/99006-02. In the specific case of Example D this l
will include identification of new Off-Normal procedures required to ensure that procedure l
requirements unable to be performed during recovery activities are properly coordinated and l
- performed following the tennination of the recovery activity.
l Examole B ~
l By August 8,1999, PORTS will revise the Anomalous Condition Procedure (XP4-EG-u NS1025) to include action steps which requires the responder to evaluate the condition l
against the TSR/SAR in addition to the NCSA/E, to document why an anomalous condition l
- is, or is not, analyzed, and to include all pertinent factors considered in evaluating the safety l
significance of the condition.
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Examole C.
No additional actions are required.
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GDP 99-2035 L
Page 8 of 8 V.
Date of Full Compliance USEC achieved full compliance as follows:
Example A l
USEC achieved full compliance on December 9,1998, when cell 25-7-2 was isolated - l -
from the rest of the cascade. Additionally, on December 23,1998, a briefing was l
initiated for X-326 Facility Operations personnel to discuss the X-326 fire incident, how the incident was handled and what indicators to be aware of when such an event is occurring. The briefing emphasized the steps necessary for tripping and isolating a cell and those actions to take if cell block isolation valves fail to fully close.
Example B l
USEC achieved full compliance on March 26,1999, when a group briefing was l
- conducted with the NCS staff to discuss their responsibility concerning: 1) assisting l
the plant in determining if an identified hazard involves an unanalyzed condition; 2) l SAR identification of the cascade operations as singly contingent, relying on i
moderation control; and 3) the need to more completely describe the basis for l
concluding that the condition is, or is not, analyzed and to provide more discussion l
of all factors considered in describing the safety significance of the condition.
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Example C USEC achieved full compliance on March 25,1999, when a corrected four hour l-notification was submitted to report the loss of moderation control resulting from the l
December 9,1998, X-326 Cell fire.
l Examnle D l
USEC achieved full compliance on February 22,1999, when caution tags were l
prepared and hung on Cell 25-7-2 Coolant Condenser RCW Isolation, Vent and l
Drain valves to meet the requirements of XP4-CO-CA4625.
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GDP 99-2035 Page1of2 UNITED STATES ENRICIIMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/99006-02 Restatement cf Violation Technical Safety Requirement 3.9.1 requires, in part, that written procedures shall be prepared, reviewed, approved, and implemented to cover activities listed in Appendix A to Safety Analysis Report, Section 6.11. Appendix A listed cell load alarms and cell coolant alarms as examples of cascade area control room alarms requiring written procedures for " abnormal operation / alarm response."
Contrary to the above, as of December 9,1998, the certificatee had not prepared, reviewed, approved, and implemented alarm response procedures for alarms such as cell load and cell coolant alarms in the cascade area control rooms.
I.
Reason for the Violation The reason for the violation was due to a management decision during the procedures upgrade effort.
Specifically, during the procedures upgrade effort associated with Compliance Plan Issue 30, action step-09D, " Implement new or update procedures (including requued training) to fully implement the Quality Assurance Program or other activities identified in the application in accordance with Level 2,3, and 4 'Q' procedures,"
guidelines were developed and used to determine which Alarm Response Procedures (ARPs) were to be developed. ARPs were subsequently developed for high risk 'Q' system operations such as Autoclaves, Withdrawal Stations, Cold Recovery, and selected Chemical Operations Activities. As a result, many cascade activities, while considered for ARP development, were not selected because these operations were addressed in Off-Normal and/or other types of cascade procedures. Because of this management decision, alarms associated with cell panels, auxiliary equipment panels, or other cascade alarms which would normally occur in the Area Control Rooms (ACR) were not identified or developed into ARPs.
II.
Actions Taken and Results Achieved The following corrective actions were previously described in Event Report 98-17.
1.
Training was developed and implemented to address cell trips, cell isolation, compressor surging, and compressor overloads. The training module has also been updated to provide a thorough discussion of off-normal conditions and indications, alarm respon3e actions, and pertinent design basis accidents as discussed in the Safety Analysis Report (SAR). Specifically, the training module provides a more t
a
GDP 99-2035
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Page 2 of 2 defined criteria for taking actions to trip and isolate a cell based on the ammeter indications.
' 2.
A briefing was initiated for X-326 Facility Operations personnel. The briefings included a description of X-326 fire incident, how the incident was handled and what indicators to be aware of when such an event is occurring. The briefing emphasized the steps necessary for tripping and isolating a cell and those actions to.take if cell block isolation valves fail to fully close.
3.
Operators were provided guidance on the causes of motor amp changes and how each of these causes affect cell panel ammeter indications in the ACR and other available instrumentation.
III.
Actions to be Taken 1.
As part of the corrective actions detailed and communicated in Event Report 98-17, by November 3,1999, USEC will develop and implement ARPs for Top and Side Purge.
2.
PORTS will evaluate plant operations against Technical Safety Requirement (TSR) l and SAR requirements to identify those activities where an ARP would enhance or l
improve operator responsiveness. PORTS will develop and implement ARPs/Off-Normal procedures identified by this evaluation. This action will be completed by May 31,2000. This will also include the development of an Off-Normal procedure j
to ensure that procedure requirements that are not able to be performed during l
recovery activities are properly coordinated and performed following the termination i
of the recovery activity.
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~IV.
Date of Full Compliance USEC will achieve full compliance upon implementation of the ARPs/Off-Normal procedures described in 111.2 above. As an interim compensatory action, on May 19,1999, training was complete for cascade personnel on off-normal conditions and indications, alarm response actions, and pertinent design basis accidents as discussed in the SAR.
i GDP 99-2035 Page 1 of 4 UNITED STATES ENRICIIMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/99006-03 l
Restatement of Violation Title 10 of the Code of Federal Regulations, Part 76.93," Quality Assurance," requires, in part, that the Corporation shall establish and execute a Quality Assurance Program.
Section 2.16, Appendix A, Section 1, item 1.16, and Appendix A Section 2 Item 2.16 of the Quality
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Assurance Program required, in part, that conditions adverse to quality are identified and corrected as soon as practical.
Contrary to the above, as of March 22,1999, A.
The plant staff did not identify and correct, through an August 1998, condition adverse to
_ quality corrective action plan, a failure by some stalT to implement portions of procedure l
XP2-GP-GP1040," Equipment History Program." Specifically, the plant staff, in August 1998, developed and implemented a cetive action plan to ensure the full implementation f
of Procedure XP2-GP-GP1040 whien did not identify the need for or include corrective actions to ensure that responsibilities assigned to the Reliability Engineering Manager were implemented. These responsibilities in-luded the pre-implementation review of work packages and the identification of equipment failures requiring evaluation and failure cause analysis.
5 B.
The plant staff did not identify and correct, through March 1999, a significant condition adverse to quality corrective action plan, inconsistencies between the Emergency Plan and Emergency Plan Implementing Procedure XP2-EP-EP1050. Specifically, the plant staff, in March 1999, developed and implemented a corrective action plan to ensure consistency between the Emergency Plan and Emergency Plan Implementing Procedures which did not resolve inconsistencies. The unresolved inconsistencies between the Emergency Plan and Emergency Plan Implementing Procedures included the classification level and initiating conditions for severe wind and security emergencies.
I.
Reason for the Violation The reasons for the violation were due, in part, to management being too narrowly focused on correcting specific and/or immediate problems and due to an inadequate technical review of the corrective action plans. Both of these conditions are symptomatic of an immature corrective action program which continues to improve as program elements are enforced.
To support this conclusion, USEC completed an independent assessment of the corrective action program late in October 1998, and self-identified a weakness where Significant
7; l-[<
GDP 99-2035 Page 2 0f 4 Conditions Adverse to Quality (SCAQ) investigations were limited in scope and did not consider site-wide or generic implications. Further specifics as to the reason for the violation l
- are discussed below.
' Example A -
l
' The Equipment History Program procedure, XP2-GP.-GP1040, was written and became l
effective before any formalized engineering guidance for program implementation was l
provided. Management did not specify how tasks, required to be performed by engineering, l
. were to be completed. An equipment history list was not developed for those components l
to be tracked. Additionally, no means of correspondence was developed between the l
maintenance planner and reliability engineer for inspection criteria to be inec,rporated into l
the' work package.
l l
On August 6,1998, Problem Report (PR) PR-PTS-98-05796 was written to address the j
above deficiency. A Corrective Action Plan (CAP) was developed for this PR which l
j contained the following actions: 1) emphasize the importance of completing the work history l
form; 2)' revise the work history form;. 3) incorporate coding information into the l
Computerized Maintenance Management System (CMMS) for tracking equipment history; l
)
- 4) identify and develop equipment history / failure reports; and 5) revise procedure XP2-GP-l GP1040. However, this CAP did not address other areas of the procedure that were not l
being implemented, such as the responsibilities of the Reliability Engineering Manager.
l During the X-326 fire investigation, the NRC Augmented Inspection Team noted l
deficiencies in the Equipment IIistory Program. Inspectors determined that some equipment l
history information was not captured during maintenance efforts involving the replacement l
of failed or excessively vibrating compressors. Additionally, the NRC identified that the l
CAP for PR-PTS-98-05796 did not include the pre-implementation review of work packages l
and the identification of equipment failures requiring evaluation and failure cause analysis.
l As a result, on March 25,1999, PR-PTS-99-01744 was written to address this deficiency.
l I
Thus, the reason for this example of the violation was that the CAP developed for PR-PTS-l 98-05796 was too narrowly focused.
l 1
Example B l
I
- Management f ailed to address classification levels and initiating conditions for severe wind l
and security emergencies in the Emergency Action Levels (EALs). Specifically, following the December 9,1998, fire in X-326, a problem report was written to document and to begin an investigation into the plant's failure to declare an Alert. A corrective actbn plan was
. subsequently developed to resolve the identified inconsistency between the Emergency Plan d
GDP 99-2035 Page 3 of 4 (EP) and the Emergency Plan' Implementing Procedure (EPIP) relative to initiating conditions for fires which could lead to a release of radioactive material or could have a direct effect on the health and safety of plant personnel. During the technical review of the plan, management did not thoroughly evaluate potential inadequacies in the EALs nor determine if there were other inconsistencies between the EP and the EPIP. As in the first
. example, management focused the investigation on the immediate issue, developing corrective actions which effectively addressed the specific issue, but did not consider if other generic implications existed.
II.
Actions Taken and Results Achieved On April 12,1999, PORTS issued to Organization Managers and Evaluators / Investigators a lessons learned bulletin resulting from the recent independent assessment of the Corrective Action Program. The bulletin noted that the Corrective Action Program is maturing, but improvement in some areas is still needed. Specifically, investigators were identified as being too natiowly focused during the investigation process.
Other actions that were taken to address the specific examples of this violation are listed l
below:
l l
Example A l
On May 20,1999, Engineering developed a new CAP (i.e., PR-PTS-99-01744) to l
supplement the original CAP (PR-PTS-98-05796) to include actions to ensure that j
the requirements of XP2-GP-GP1040 are being properly implemented. A number l
of actions have already been completed. Elements of this CAP include the l
following:
l On April 28,1999, Reliability Engineering implemented a failure analysis l
process and began to review work requests for failed equipment to determine l
if a failure analysis needs to be performed.
l l
l An Equipment History List ofitems has been provided to Work Control so l
i that equipment history can be documented in the work packages for these l
items.
l l
i A revision to XP2-GP-GP1040 to better define the responsibilities for failure l
analysis and trending will be implemented.
l l
. The responsibilities of the Reliability Engineering Manager (section 5.3 of XP2-GP-l r
GP1040) have been reviewed and it has been determined that these responsibilities l
(
GDP 99-2035 Page 4 of 4 are either being fulfilled or that an action to address the deficiency is contained in l
either PR-PTS-99-01744 or PR-PTS-98-05796.
l l
Examnle B l
l i
As noted in Inspection Report 70-7002/99006, PORTS documented, in a problem l
report (PR-PTS-99-01682), the plant's failure to develop classification levels and l
initiating conditions for severe wind and security emergencies. In addition, the Inspection Report acknowledges the implementation of interim compensatory measures (CA-99-020, dated March 23,1999) to address the EALs.
PORTS revised procedure XP2-EP-EP1050 on June 7,1999, to expand the EALs to l
make them consistent with the EP and Regulatory Guide 3.67 for both an Alert and l
Site Area Emergency. This includes fires, explosions, natural phenomenon events, l
security events, and other adverse events.
l 111.
Actions to be Taken By August 15,1999, Engineering will coordinate with Commitment Management to develop l
a training plan to address developing effective broad-based corrective action plans. This training will be provided specifically to investigators and evaluators.
By September 15, 1999, PORTS will revise XP2-GP-GP1040 to better define the l
responsibilities for failure analysis and trending.
1 IV.
. Date of Full Compliance Full compliance with tile specific issues of the violation were/will be achieved as follows:
l l
Examnle A USEC will achieve full compliance by September 15,1999 upon revision of procedure XP2-l GP-GP1040," Equipment History Program."
l l
Example B l
l USEC achieved full compliance on June 7,1999, when PORTS revised procedure XP2-EP-l EP1050 to expand the EALs to make them consistent with the EP and Regulatory Guide 3.67 l
for both an Alert and Site Area Emergency.
l
=
7 l.
t
~
L GDP 99-2035
[
Page1ofI l
List of Commitments" t
L 2(h7002/99006-01 L
l Fvamnles A and D '
l The actions to be taken for the inadequate procedures (Examples A and D) are discussed under the response to violation 70-7002/99006-02. In the specific case of example D, this will include l
identification of new Off-Normal procedures required to ensure that procedure requirements unable l
to be performed during recovery activities are properly coordmated and performed following the l
termination of the recovery activity. This action will be completed by August 8,1999 l
b Examnle B l
L By August 8,1999, PORTS will revise the Anomalous Condition Procedure (XP4-EG-NS1025) to l
include action steps which requires the responder to' evaluate the condition against the TSR/SAR in l
L addition tc. the NCSA/E, to document why an anomalous condition is, or is not, analyzed, and to l
include all pertinent factors considered in evaluating the safety significance of the condition.
-l 70-7002/99006-02
- PORTS will evaluate plant operations against TSR and SAR requirements to identify those activities l
o where an ARP would enhance or improve operator responsiveness. PORTS will develop and implement ARPs/Off-Normal procedures identified by this evaluation. This will also include the l
development of an off-normal procedure to ensure that procedure requirements that are not able to l
be performed during recovery activities se properly coordinated and performed following the -l t.
termination of the recovery activity. This action will be completed by May 31,2000.
l l
70-7002/99006-03 By. August 15,1999, Engmeenng will coordinate with Commitment Management to develop a training plan to addreas developing effective broad-based corrective action plans. This training will be provided specifically to' investigators as,d evaluators.
~ By September 15,19M, PORTS will revise XP2-git-GP1040 to better define the respons.ibilities - l
, for failure analysis and trendirg.
l IRegulatory commitments contair:d 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.
i 1
Nh.
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