ML20210M926
| ML20210M926 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 08/18/1997 |
| From: | Allen D UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-7002-97-004, 70-7002-97-4, GDP-97-2017, NUDOCS 9708220296 | |
| Download: ML20210M926 (15) | |
Text
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United States g
E nrichment Corporation 2 Democracy Center 6903 Rockledge Drtve Bethesda. MD 20817 Tel (301)564 3200 Far (301) 564 3201 August 18,1997 GDP 97 2017 United States b uclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Portsmouth Gaseous Diffusion Plant (PORTS)
Docket No. 70-7002 Response to Inspection Report (IR) 70-7002/97-004 Notice of Violations (NOVs)
Nuclear Regulatory Commission (NRC) letter dated July 18,1997, transmitted the subject inspection Report (IR) that contained three violations (i.e., NOVs 70 7002/97004-01,02, and 03).
USEC's response to these violations is provided in Enclosures 1 through 3, respectively. Enclosure 4 lists the commitments made in this report. Unless specifically noted, the corrective actions specified in each enclosure apply solely to PORTS.
USEC agrees that two of the three violations (i.e. NOVs 97004-01 and 97-004 03) occurred as stipulated in the IR. Ilowever, we disagree with NOV 97-004-02 which, as was cited in the IR, stated that PORTS procedure XP2 EG NS1030," Safety Evaluations of As Found Discrepancies,"
did not provide sufficient guidance to satisfactorily accomplish an Unreviewed Safety Question Determination (USQD). The basis for our disagreement with this NOV is provided in Enclosure 2.
In the cover letter to the IR, NRC suggests that there are fundamental weaknesses in our control process for ensuring the plant operates within the design basis and requested that our response address "the generic concem with the adequacy of procedural controls for high risk evolutions." While USEC agrees that additional enhancements to the valving order procedure are appropriate; as indicated in the attached response, we believe our "rocedural controls are adequate to ensure the plant operates within the design basis. USEC is confident that the controls for 76.68 process are adequate and the use of valving orders is proper, if you have any questions regarding this submittal, please contact Ron Gaston at (614) 897-0 9708220296 970818 PDR ADOCK 07007002 l l]llll ll l l ll PDR Offices in Livermore. California Paducah. Kentucky Portsmouth. Otuo Washington. DC
f United States Nuclear Regulatory Commission August 18,1997 Page Two Sincerely, M10@(I Dale Allen
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General Manager l
Enclosures ec:
Regional Administrator, Region ill NRC Resident Inspectors - PORTS
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United States Nuclear Regulatory Commission
' ugust 18,1997 l
A Page Three Distribution Steven A.Toelle
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J. Adams,llQ J. Adkins,llQ J. Dietrich, LMUS li. Fink, PORTS -
R. Gaston, PORTS J. Labarraque, PODP A. Rebuck Main,llQ S. Routh,11Q =
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Enclosure I l
UNITED STATES ENRICilMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/97004 01 Restatement of Violation Technical Safety Requirement 3.9.1 requires, in part, that written procedures shall be maintained to cover operator actions to prevent or mitigate the consequences of accidents described in Safety Analysis Report (SAR) Chapter 4.
Contrary to the above:
l A.
Portsmouth Procedure XP4-CO-CA 2380, " Operations of the Tails Station " Revision 1, was not maintained to cover operator actions to prevent or mitigate the consequences of accidents i
described in SAR Chapter 4, Table 4.2 5. Specifically, changes A and 11 to the procedure did not correct a reference to high pressure vent panels that were not fully installed.
B.
Plant Procedurc XP4-CO-CN2116(C), " Cell Treatments in X-330," did not require that safety screenings to changes in the normal valve line up for cell treatment were performed to ensure that the ability to evacuate a cell in an emergency was maintained as described in SAR Section 4.1.1.2.2.
I, Reasons for Violation The reason for the violation was due to technical inadequacies with design documents, inelTective configuration management, and training inadequacies. Specifically, example "A" of this violation was caused by a lack of operator knowledge concerning the as-built configuration of the fligh Pressure Vent (llPV) for the Tails Withdrawal Station and a historical weakness in the configuration management program. The reason for example "B" of the violation was inadequate procedural guidance which may allow deviations from normal valve lineups without first assessing whether theses deviations could reedt in a change to the facility as described in the SAR. The following discussion provides further details on the causes of each example cited in this violation, Dmmnle A:
The llPV for the Tails Withdrawal Station, originally certified for construction on October 14,1983, was designed to provide additional engineered features to limit / mitigate the consequences of a UFirelease and to provide over pressure protection to the accumulator, condenser and associated piping. The FSAR was written to reflect this original design, llowever, the dcsign of the system was subsequently changed and the installation built in accordance with these changes. ' Although the Tails llPV hardware installation (completed in October 1987) was walked down and the as built condition verified, the FSAR was not changed to reflect the actual installation The NRC approved SAR was developed using the El-1
FSAR as a basis, and thus contained the incorrect description of the system, System
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procedures also relied on this incorrect FSAR information and contain inaccuracies regarding the design and operation of the llPV installation.
1 Available engineering drawings are inconsistent as to what actually occurs when llPV f;.
is hitiated. Additionally, there is no documentation of a functional test of this system. While drawings indicate isolation will occur, the specific mechanism of this isolation is in doubt.
b Procederes cordain operator actions if the 11PV isolation is operable and also ifit not operable.
'lowever. as stated above, the procedures also reficct the innrrect information as contained in the FSAR and the SAR.
The reason for the SAR and procedure discrepancies was inadequate walkdown or validation in this case,if the procedure had been correctly walked down, the flowdown and h
review process would have identified that the withdrawal station liPV hand switch is not available and that the SAR is incorrect.
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Examnle B:
7p-(
On August 21,1996, procedne XP4-CO-CN2116, Rev. O Change B was modified which deleted the specific requirement to line up the emergency evacuation route via the
" Evacuation IIcader." The specific requirement was replaced by a requirement to simply
" set-up valving to transfer CG from the CG room to the cell evacuation header" and then refers to XP4-CO-CA2228; " Valve Orders." Because the SAR states that " material is transferred to a cell through available heaaers and provisions are made for emergency evacuation to surge drums," amt personnel believed that the size of the header wao not as critical as the requirement to establish an emergency evacuation route. A safety screening was performed for this change per procedure UE2-PS PS1031 by a safety analysis engineer anc' independently verified by a senior safety analysis engineer to detemline if the change constituted a change to the authorization basis. The review indicated that a safety evaluation I
was not needed to implement the proposed change because no change was made to the safety basis of the plant.
l On June 15,1997, while purging conditioning gases from Cell 29-3-7 through a three inch header in accordance with an approved procedure, plant operators observed a pressure rise in the cell. During a follow-up inspection of the area, an operator discovered that a blowout preventer actuator was overheating and the stage one cell temperature reached the 280 degree Fahrenheit limit. The NRC inspector believed that the temiierature transients resulted f~ :m the use of a smaller three inch diamerci evacuation route instead of the preferred 12-inch evacuation route. Therefore, NRC contends that, in this particular case, a "USQD would have been required because the use of the smaller diameter evacuation line may have hindered the operators' ability to evacu-te the cell." LSEC perfonned a Preliminary Safety Evaluation for the ne of a three inch header to address the inspectors conclusions related to using a three inch e vrgency evacuation route and d;termined that a USQ did not exist El-2
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US v
The specific issue related to this cited example focuses on the need for additional controls and enhancements to the vd.ing order procedure to ensure that high risk evolutions will not circumvent the normal procedure / safety review process. The inspector expressed a concern that the valving order procedure did not have sufficient restrictions to administratively prevent an operator from deviating from the normal valve lineup without first determining whether the alternate line-up deviated from the SAR. Recognizing that a weakness in the 5
valving order procedure existed, USEC modified the valving order procedure as described in the following section.
II.
Corrective Actions Taken and Results Achieved 1)
On Jtme 25,1997, operations management performed a shift briefing to communicate
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to operations personnel in the X-330 building that the HPV system has not been 4
verified as functional. In addition, personnel were notified that the HPV initiation f
switches were administratively tagged out-of-service and advised of the actions to take should the withdrawal station experience a release or a high pressure condition.
2)
On June 30,1997, Systems Engineering performed a walkdown of the HPV initiation system to confinn that the as-built condition was in accordance with approved drawings. The results determined that the HPV circuits in Tails could only be operated in manual and initiated from the ACR2 or airlock #33 near the compressor area on the cell floor.
3)
On July 28,1997, procedure XP4-CO-CA2228; " Valving Orders" was modified to provide additional procedural guidance when valving orders are prepared.
Specifically, procedural guidance was added which prevents initiation of a valving order which could result in the release of UF to the environment, which would violate 6
an NSCA, or which link systems containing gases which react explosively together.
To date, these changes have been communicated to the affected operations personnel via the required reading program. Additional training is detailed below.
Ill.
Corrective Steps to be Taken 1)
To correct the technical error in the SAR relatt to the HPV Tails Withdrawal, a Request for Application Change will be submitted to the PORC for approval by September 30,1997, 2)
To correct the identified procedure discrepancies associated with IIPV initiation. Tails withdrawal procedures and alarm response procedures will be reviewed and modified, as appropriate, to reflect the as-built condition of the Withdrawal Station. This action will be completed by September 30,1997.
3)
To ensure the basis for the new procedural requirements, incorporated into procedure XP4-CO-CA2228; "I'alving Orders," are communicated to the implementing facilities, E1-3 4
-11 managers responsible for the review and approval of valving orders will be briefed by
.; September 15,1997.
-IV.
'Date of Full Compliance
' Full compliance was achieved for exaniple A on June 25,1997, when operations
- management performed a shifl briefing to communicate to operations perso:mel in the X-330 building that the llDV initiation system was not functional and what procedure to use in the event of a release or a high pressure condition.
- Full compliance was achieved for example B on July 28,1997, when the valving order procedure was modified to provide procedural guidance to ensure valving orders are reviewed l
prior to initiation to verify that cafety limits are not being exceeded. The corrective actions to prevent recurrence with this specific violation will be completed by September 30,1997.
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UNITED STATES ENRICllMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/97004-02 Restatement of Violation 10 CFR 76.93, " Quality Assurance," requires that the Corporation shall establish, maintain, and execute a quality assurance program satisfying each of the applicable requirements of American Society of Mechanical Engineers (ASME) NQA 1-1989," Quality Assurance Program Requirements for Nuclear Facilities."
American Society of Mechanical Engineers (ASME) NQA-1-1989, " Quality Assurance Program Requirements for Nuclear Facilities," Basic Requirement 5, " Instructions, Procedures, and Drawings" states, in part, that activities affecting quality shall be prescribed by procedures which shall include or reference appropriate quantitative or qualitative acceptance criteria for determining that prescribed l
activities have been satisfactorily accomplished.
C,ntrary to the above, a procedure for an activity affecting quality did not include or reference appropriate quantitat ve or qualitative acceptance criteria for determining that prescribed activities had i
j been satisfactorily accomplished. Specifically, Portsmouth Procedure XP2-EG-NS1030, " Safety Evaluations of As-Found Discrepancies," Revision 0, did not provide enough guidance to satisfactorily accomplish an Unreviewed Safety Question Determination. The safety evaluation did not identify that an as-found condition of a condensate drain screen in the X-344 building autoclaves could potentially increase the consequences of an accident identified in Section 4.2.3.2 of the SAR.
USEC Response USEC does not agree with this violation. The cited vielation concerns an "as found" condition that was discovered on May 14,1997, regarding installed screens (i.e., strainer) above the condensate probes in the drain lines for the X-344 autoclaves. During a conference call between USEC and NRC on May 14,1997, a concern was raised that the screens could potentially defeat the safety function of the probes if clogged. Therefore, the installed screens were tcmoved on May 14,1997, and the X-344 autoclaves were declared operable, in a letter to USEC dated March 17,1997, NRC provided guidance as to when an Unreviewed Safety Question Determination (USQD)is required, pursuant to 10 CFR 76.68.' Specifically, this letter states:
We agree that the original as-found condition does not need to be evaluated under 10 CFR 76.68(a) unless you plan to continue with the
'See NRC letter from Robert C. Pierson to Robert L. Woolley, " Response to Evaluation of As-Found Conditions Letter (GDP 97-0022)."
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condition as discussed above. As a point of clarification. If the corrective action is to modify the as-foundcondition to conform with the SAR, 10 CFR 76.68 would not require an evaluation to determine ifprior NRC approval is necessary because the NRC has already approved the SAR.
The as-found condition (i.e., the screens above the condensate probes) is not described in the SAR. Therefore, the action taken to remove the screens restored the plant to conformance with the SAR. Therefore, per the above NRC guidance, a USQD, pursuant to 10 CFR 76.68, was not required for the asfoundcondition. However, as verbally requested by NRC, USEC performed a USQD for this condition to determine if the existence of these xainers had represented a USQ.
i The USQD for the as-found condition was documented in Safety Evaluation (SE) 97-0134, Rev. 0, which was approved on May 23,1997. This SE concluded that th: presence of the strainers above the condensate probes did not constitute a USQ. The IR states Portsmouth Procedurc XP2-EG-NS1030, " Safety Evaluations ofAs-Found Discrepancies", Revision 0, was the procedure used to conduct the SE. Thepurpose oftheprocedure was to evaluate an as-foundcondition'spotentialafect on the safety basis.
l Procedure XP2-EG-NS1030, which was issued on December 30,1996, provides direction on how to identify and disposition as-found conditions. Specifically, the action steps of this procedure are as follows:
1.
Once a Problem Report (PR) is determined to have a potential affect on the safety basis, Safety Analysis categori:es prs as afecting "Q", "AQ", or "OTHER" systems.
2.
prs are logged in Safety Analysis tracking system.
3.
Nuclear Safety Analysis manager assigns PR to quahfled USQD evaluator.
4.
USQD evaluatorprepares appropriate documentation (USQD, PCR, Memo, etc.)for submittal to Nuclear Regulatory Afairs (NRA).
5.
Safety Analysis tracking system is updated to maintain the current status ofall PR resolutions within the department.
6.
Safety Analysis administration personnel issue look ahead reports to assist responsible individuals with timelyiesolution.
As indicated in the above action steps, procedure XP2-EG-NS1030, does nol provide any directions or actions for conducting a SE for as-found conditions. Rather, SEs are prepared in accordance with procedure UE2-EG-NS1030, Unreviewed Safety Question Determination (Note:
UE2-EG-NS1030 is listed as a Use Rejbrence in XP2-EG-NS1030). Appendix E to this procedure E2-2
contains a form (UE-687) which is used for preparing a SE and which provides the questions for making a USQD in accordance with 10 CFR 76.68. The SE for the as-found condition regarding the strainers above the autoclave condensate probes was prepared in accordance with the requirements of UE2-EG-NS1030.
The IR states that procedure XP2 EG NS1030, did notprovide adequate guidance to IN safety analysis engineers to identify that the potentialfor blockage existed and that there was the potential for the condition to increase the consequences of an accident previously identified in the SAR..'
Proccdure XP2-EG-NS1030 is not intended to provide guidance to determine whether an as-fmmd condition could increase the consequences ofan accidentpreviously identifledin the SAR. Again, this guidance is contained in UE2-EG-NS1030. Specifically, Appendix F to this procedure provides guidance for the preparation of responses to the questions in the SE in order to make a USQD pursuant to 10 CFR 76.68. In responding to the question as to whether the activity or condition could increase the consequences of an accident previously evaluated in the SAR, Appendix F to UE2-EG-NS1030 provides the following guidance:
J In responding to this question, first determine which ac:idents evaluated in the FSAR/SAR may have consequences increaseddue to a direct or indirect impact ofthe proposed change /artivity, Consider whether the proposed activity / change could degrade orprevent actions describedin the FSAR/SAR or alter any assumptions made that could impact the consequences ofan accident.
l In addition to the abo.'c discussion, the following questions should be considered when forming the response to the question:
What are the consequences considered aDbeted by this issue?
identify the protective boundaries (Physical or Administrative) ifany.
=
Are any acceptance limitsfor the protective boundaries impacted?
Ilow are the protective boundaries, ifany, are [ sic] directly affected by the issue or failure modes ofthe issue.
The above guidance was used in preparation of SE97-0134, X-344A Autoclaves Strainer As Found Evaluation. However, the IR indicates that this SE was not fully adequate in addressing whether the as-found condition could increase the consequences of an accident previously evaluated in the SAR. Specifically, the IR states:
Partial blockage of the screen could cause the water inventory to be exceeded in an autoclave. Ifa UFs release occurred in an XJ44 autoclave and the water inventory was exceeded, then the autoclave rupture dise would be challenged increasing the consequences ofan accident identified in Section 4.2.3.2 ofthe SAR.'
2see page 8, last paragraph ofIR 70-7002/97004 3see page 9,1st paragraph ofIR 70-7002/97004 E2-3 i
'The analysis in SE97-0134 addresses the above NRC concern as summarized below:
As indicated in the section titled Strainer Evaluation - Engineering Design (page 2 of the SE), the design of the strainer with a top hat and handle make it extremely difficult to clog; As discussed in the section titIed X-344 Condensate Drain Strainer Operating History
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(page 3 of the SE), from May 1995 to May 1997, a review of prs associated with strainers / screens was conducted. None of the prs indicated any clogging or massing of material around the condensate inlet drain strainer. Additionally, the required operator checks before each autoclave startup and the autoclave weekly shell cleaning would make it difficult to accumulate enough material in the autoclave to clog the
[
condensate inlet drain strainer.
1 The section titled Accident Scenarios (page 3 of the SE), addresses the concern g
regarding exceeding the autoclave water inventory. Specifically, the SE notes that t
SAR section 4.2.3 states the X-344 autoclaves (& foot diameter) were tested and had
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an acceptable maximum water inventory andare ventedjust outside the autoclaves but
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inside the building exterior, The pressure reliefsystems willprevent an autoclave rupture in the event of a major cylinder or pigtail release of UFe in any autoclave regardless ofwater inventory.
As previously noted, NRC expressed a concern in the IR that the as-found condition could increase the consequences of an accident identified in Section 4.2.3.2 of the SAR. This section states:
In the event the autoclave retains more than the allowable water inventory, e.g. fails the water inventory test, a UF6 release inside the autoclave will activate the pressure reliefsystem and usult in a source term. The source term will be afamction ofvessel volume, pressure reliefvalve setting.
water inventory, and UF6 leak rate. However, the maximum release is equivalent to a 700 pound UF6 release directly to the ambient environment ! s abou' minutes. This release will occur at the X-343 orX-342 buildings since these are the only locations that contain outoclaves that havefaiteJ the water inventory tests.
The above section of the SAR notes that water inventory is a concern for the autoclaves in the X-343 and X-342 buildings. As noted in PR PTS-97-4672, the as-foundcondition did not exist in the autoclaves for these buildings. Therefore, the possibility of an increase in the consequences of an m
accidet did not exist for these facilities.
The IR further noted a concern that: The inspectors discussed the SE with the safety analysis engineers. The engineers indicated that there was not very goodguidance on how to do an as-found safety evaluation. The above quote was discussed with the safety analysis engineers who met with NRC concerning the as-found condition. The engineers indicated that they wre aware of the NRC letter dated March 17,1997, and informed NRC that an SE was not required per this letter since the screens had been removed. However, since USEC had agreed that an SE would be performed, the safety analysis engineers believed that the SE should be based on a review of past history to detennine E2-4 l
if blockage of the strainers had ever occurred. it was apparently the NRC's opinion that the SE should
' consider the hypothetical effects of a clogged strainer. This difference in opinion apparently led to the NRC conclusion that the safety analysis engineers did not believe that there was adequate guidance to perform a SE for an as-foundcondition. in retrospect, the SE considered not only past operating history to determine if blockage of the strainers had occurred, but also examined the design of the strainer, current inspection practices, and the accident scenarios in the SAR to assess the potential consequences of a clogged strainer above the condenst.te probes.
In summary, USEC believes that:
Pursuant to written NRC guidance, a SE of the as-found condition was not required; The SE that was performed was done in accordance with the USEC procedure for determining whether a USQD existed pursuant to 10 CFR 76.68; The SE adequately assessed whether the as-found condition could have increased the consequences of an accident previously analyzed in the SAR; and l
The procedure governing performance of SEs contain sufricient guidance to satisfactorily accomplish a USQD.
Based on our investigation of this event, USEC has identified that enhancements to procedure XP2-EG-NS1030 are warranted. These enhancements are discussed in section Ill below.
II.
Corrective Actions Taken and Results Achieved 1)
On July 28, 1997, the Safety Analysis Manager issued a memorandum to the Engineering Manager clarifying the requirements for when a 10 CFR 76.68 evaluation is required for as-found conditions per the NRC guidance.
2)
At a Safety Analysis staff meeting, the above memorandum was discussed along with the details of the event discussed in this violation to ensure a consistent understanding as to when a SE is required for an as-found conditions, and the applicable procedural requirements for performing the SE.
III.
Corrective Steps to be Taken USEC will revise XP2-EG-NS1030 to make the following enhancements: 1) incorporate the guidance as to when a 76.68 review is required for as-found conditions, and 2) denote the applicable procedures that apply for performing a SE for an as-found condition. This procedure revision will be completed by September 26,1997.
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q UNITE 0 STATES ENRICIIMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/970004-03 l
Restatement of Violation 10 CFR 95.35(a) requires, in part, that no person subject to the regulations in this part may receive or may permit any individual to have access to matter revealing Confidential Restricted Data unless the individual has a "Q" or "L" access authorization.
- Contrary to the above, from March 3 through June 13,1997, the certificatee subject to the regulations in Part 95, permitted individuals not having "Q" or "L" authorizations to have access to an area where valve labeling revealed Confidential Restricted Data.
1.
Reasons for Violation l
USEC agrees that a condL'.an was identified where individuals, not having "Q" or "L" clearances, could have been permitted access to an area where valve labeling revealed
- Confidential Restricted Data. The reason for the violation was inattention to detail and inadequate guidance,
- Background On June 13,1997, the inspector conducted a walkdown for a valving line-up in the X-330 building. The inspectors noted a valve actuator cover plate in ACR2 was labeled with information which appeared to identify a confidential restricted process. A security a
investigation into this concern confirmed that the informally applied label identified a confidential restricted process. The date when the label was affixed to the control panel could not be determined.
Security practices currently restrict access to Area Control Rooms (ACR) such that classified material should be secured before uncleared personnel are permitted into the area.
However; in this case, the labeling was not identified or recognized by area personnel as classified material. Thus; ACR personnel were not aware that the label needed to be obscured should uncleared personnel be permitted into the area.
II.
Corrective Actions Taken and Results Achieved 1)
Upon discovery, on June 13,1997, the label was removed from the panel.
2)
To ensure other areas were in compliance with the regulations, on June 16,1997,a walkdown of other ACRs containing classified operations was completed. The E3 l
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walkdown did not identify additional examples where labeling revealed classified restricted data.
3)
Because ACR personnel did not recognize that the information provided in the label was " Classified," Portsmouth Organizational Managers are reviewing this incident with their staff to communicate what type ofinformation is considered sensitive.
Security also advised the organizational managers as to " Unclassified" alternative language that can be used for identifying the process.
111.
Corrective Steps to be Taken None IV.
Date of Full Compliance l
l USEC achieved full compliance with the regulation as related to protection of classified information on June 13,1997, when the classified information was removed from the control panel.
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1 8'.
UNITED STATES ENRICllMENT CORPORATION (USEC)
~ LIST OF COMMITMENTS 70-7002/97002 70-7002/97004-01' 1)
To correct the technical error in the SAR related to the HPV Tails Withdrawal, a Request for Application Change will be submitted to the PORC for approval by September 30,1997.
- 2)
To correct the identified procedure discrepancies associated with HPV initiation, Tails
-withdrawal procedures and alarm response procedures will be reviewed and modified,
(.
as appropriate, to reflect the as-built condition of the Withdrawal Station. This action will be completed by September 30,1997.
3)-
To ensure the new procedure requirements of procedure XP4-CO-CA2228; " Valving
- Orders," are' communicated to the implementing facilities, managers responsible for the review and approval of valving orders will be briefed by September 15,1997, i
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