ML20211L487

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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7002/99-07 Issued on 990709
ML20211L487
Person / Time
Site: Portsmouth Gaseous Diffusion Plant
Issue date: 09/01/1999
From: Phillips M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Adkins J
UNITED STATES ENRICHMENT CORP. (USEC)
References
70-7002-99-07, NUDOCS 9909080254
Download: ML20211L487 (2)


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September 1,1999 l

Mr. J. N. Adkins Vice President-Production United States Enrichment Corporation Two Democracy Center 6903 Rockledge Drive Bethesda, MD 20817 l

SUBJECT:

RESPONSE TO INSPECTION REPORT 70-7002/99007(DNMS)

Dear Mr. Adkins:

This refers to your August 9,1999, response to the Notice of Violation (NOV) transmitted to you by our letter dated July 9,1999, with inspection Report 70-7002/99007(DNMS). We have reviewed your corrective actions for the violation and have no further questions at this time.

Your corrective actions will examined during future inspections.

If you have any questions, please contact me at (630) 829-9806.

Sincerely, Monte P. Phillips, Acting 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 j

Portsmouth Resident inspector Office i

Paducah Resident inspector Office i

R. M. DeVault, Regulatory Oversight Manager, DOE E. W. Gillespie, Portsmouth Site Manager, DOE J. R. Williams, State Liaison Officer DOCUMENT NAME: G:\\SEC\\POR99007.RES I

To receive a copy of this document, Indicate in the box:"C" a Copy without enclosure "E"= Copy with enclosure"N"a No copy OFFICE Cj lC l

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NAME Fhi44/

DATE 09/f/99 OFFICIAL RECORD COPY 9909000254 990901 PDR ADOCK 07007002 i

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PUBLIC IE-07" R. Pierson, NMSS P. Ting, NMSS W. Troskoski, NMSS P. Harich, NMSS Y. H. Faraz, NMSS R. Bellamy, RI EJM, Rll (e-mail)

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- August 9,1999 GDP 99-2043 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) 70-7002/99007 Notice of Violation (NOV) 99007-04 The subject IR contained one violation involving a lack of rigor in failing to ensure that nuclear criticality safety controls were implemented following response to an anomalous condition. The United States Enriehment-Corporation's response to this violation is provided in Enclosure 1.

  1. 'N lists the commitments contained in this submittal. Unless specifically noted, the t(,)

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.

Si'ncerely, F

. Morris Brown General Manager Portsmouth Gaseous Diffusion Plant

Enclosures:

As Stated cc:

NRC Regional Administrator-Region III 4 NRC Resident Inspector - PORTS

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United States Enrichment Corporation lJj 3 1 7 M Portsmouth Gaseous Diffusion Plant P.O. Box 628, Piketon, OH 45661

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l GDP 99-2043 Page 1 of 4 UNITED STATES ENRICIIMENT CORPORATION (USEC)

REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/99007-04 Restatement of Violation Technical Safety Requirement 3.11.2 requires, in part, that all operations involving uranium enriched to 1.0 weight percent or higher uranium-235 and 15 grams or more of uranium-235 shall be performed in accordance with a documented Nuclear Criticality Safety Approval.

Nuclear Criticality Safety Approval-PLANT-048.A03, " Contaminated Metal," requires that

~ individual items having hidden volumes greater than 1 gallon or visible uranium bearing materials beyond fixed stains / films shall be stored with a minimum 2 foot edge-to-edge spacing to other uranium-bearing items until non-destructive analysis information (indicating less than or equal to i

350 grams uranium-235) is obtained. The Nuclear Criticality Safety Approval also required that contaminated metal storage areas be posted delineating the above requirements.

Contrary to the above, between June 9 and 22,1999, the certificatee batched G-17 valves with hidden volumes greater th m I gallon in a staging outside Building X-744H, with less than 2 foot A

edge-to-edge spacing to each other, before non-destructive analysis information indicating less than or equal to 350 grams uranium-235 was obtained. In addition, the certificatee failed to post the staging area as required by Nuclear Criticality Safety Approval-PLANT-048.A03.

USEC Response Bac'kground j

On May 7,1999, Engineering requested non-destructive analysis (NDA) testing and Health Physics

-(HP) swipes to be taken for G-17 valves to be used for the Side Purge Project. The reason for the i

request was that building X-330 needed assay value to comply with the building NCSA. On June 1,1999, NDA testing and HP swipes were performed on the valves in preparation to move the valves from the warehouse (building X-744H) to building X-330 dry ice blaster.

On June 9,1999, a problem report (PR-PTS-99-03225) was filed which stated simply: "10 swipe samples taken from 12" G-17 valves in WH18 (building X '/44H) with assay measurements above 10%." The Nuclear Criticality Safety (NCS) staff was asked to respond to an anomalous condition, although NCSA-PLANT 048 clearly allows storage of contaminated metal with up to 100% enriched 2"U on it. Since the swipes could not indicate the mass of the material found, no determination could be made regarding whether a spacing violation had occurred with the contaminated metal components. An attempt was made to confirm compliance with NCSA-PLANT 048 for all the equipment in the entire facility, however this attempt was not pursued to completion. At the time, b. there was no reason to assume the mass of the material was in l

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GDP 99-2043 Page 2 of 4 operation of the warehouse. Since no violation was believed to have occurred, the NCS engineers believed there was no need to curtail any operation at the warehouse. At this time, the G-17 valves were still inside the warehouse (building X-744H).

On June 12,1999, the G-17 valves that had NDA testing performed were moved to the concretc pad outside building X-744H even though the NDA results were not yet received. This was performed by stores / warehouse personnel in order to try and match the valves to previous NDA data received i

from Oak Ridge for the shipments received in early 1997. NCSA-PLANT 048 spacing requirements were adequately flowed down into the procedure being used for moving the valves. However, the stores / warehouse personnel believed, due to prior agreements with Oak Ridge, that the equipment did not contain more than 15 grams "U and therefore, the requirements of the NCSA and procedure 2

did not apply.

On June 22,1999, another problem report (PR-PTS-99-03554) was filed documenting that NDA results were received showing that some of the valves had more than 15 grams "U enriched to 2

2 greaterthan 20 wt% "U. NCS responded again and found that the valves had been moved outside the warehouse and were now between buildings X-744H and X-744J. Since the NDA results showed that more than 15 grams "U were detected on some of the valves, the configuration of the 2

n valves was reviewed to determine if any batch of valves (i.e., group of valves within two feet edge-(

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to-edge ofits nearest neighbor) was greater than 350 grams "U. The review indicated that no batch 2

U 2

was greater than 350 grams "U. Therefore, there was no known violation for the G-17 valves for which the problem report had been written. On June 23,1999, NCS was told that the valves were awaiting transport to building X-326 which would take place relatively soon. NCS did not take any additional steps at this time to ensure the remaining equipment stored in building X-744H was stored in compliance with NCSA-PLANT 048.

'NCS's response to the problem reports about the equipment in building X-744H was complicated by the fact that the exact history of the equipment stored in the facility was known to only a small

. group of people. The very long history of the quipment in the facility required a knowledge based decision be made regarding the potential nature of the contamination of the G-17 valves. This knowledge was not readily available to the NCS staff and although the information was requested, this was not rigorously pursued.

L Reason for the Violation The reason for the violation was the stores / warehouse personnel did not follow the procedure. As noted above, stores / warehouse personnel believed that the G-17 valves contained less than 15 grams "U Thus, the spacing requirements of NCSA-PLANT 048 and 2

the procedure did not apply for valve spacing. A contributing cause was that although the personnelinvolved with the movement of the G-17 valves had completed training on the

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NCSA, these personnel were not able to correctly apply the NCSA requirements to their (j

areas of responsibility.

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GDP 99-2043

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Page 3 of 4 An additional contributing cause to the violation was the NCS staff did not obtain sufficient information on the.G-17 valves equipment history relating to mass and nature of contamination to adequately assess the anomalous condition found with the valves. Also, since the valves stored outside the building were being readied for transport, the NCS staff did not believe that this area qualified as a contaminated metal storage area, thus contributing to the failure to post the area.

II.

Corrective Actions Taken and Results Achieved 1.

On June 22,1999, the results of the NDA surveys for the G-17 valves moved outside building X-744H were obtained. Of the 30 valves located in this outside storage area, only four valves were batched with less than two foot edge-to-edge spacing. A review of the NDA survey results for these four valves showed these valves contained less than 350 grams "U. Therefore, no additional spacing of these valves 2

was required.

2.

On June 23,1999, the concrete pad storage area outside building X-744H was posted as re' quired by NCSA-PLANT 048.

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On June 23,1999, personnel began two foot spacing of equipment within building X-744H which did not have known NDA survey results. This spacing was completed on-June 25, 1999, to ensure building X-744H met the spacing requirements of NCSA-PLANT 048. To help support this effort, NCS provided written guidance (Ref. POEF-832-99-058) to summarize the steps needed to become I

compliant with NCSA-PLANT 048 requirements. Throughout the evening of June 23,1999, and into the moming hours of June 24,1999, NCS engineers were available in building X-744H to support the spacing effort.

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4.

On June 25,1999, a walkthrough of other facilities (X-3448, X-720 Stores, X-744J, X-744L North, and X-744W) which could contain equipment similar to that stored in building X-744H was performed to ensure the requirements of NCS A-PLANT 048 were met. No other violations of the NCSA were found.

III.

Corrective Actions to be Taken 1.

A method for documenting and tracking NDA survey results and the movement of equipment in the stores areas and warehouses will be developed and personnel will be trained on using this method. This action will be completed by November 1, 1999.

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Page 4 of 4 2.

The requirements of NCSA-PLANT 048 will be re-emphasized to storeshvarehouse personnel through round table discussions. These discussions on the NCSA will be J

completed by September 15,1999.

3.

As an interim action, a lessons learned will be generated and distributed through required reading to all NCS anomalous condition responders. The required reading will review the violation of NCSA-PLANT 048 at building X-744H and emphasize the importance of a questioning attitude regarding complex issues, especially involving legacy equipment whose operation history is not well documented. This action will be completed by August 27,1999.

4.

Subsequently, the training for NCS anomalous condition responders will be changed from required reading and crew brief to formal classroom training with specific anomalous condition examples given to help emphasize the importance of a questioning attitude regarding compliance with NCS requirements. The re-training of the responders will be completed by October 29,1999.

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Date of Full Compliance l

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\\V) i USEC achieved full compliance with the cited violation on June 23,1999, when the concrete pad storage area outside building X-744H was posted as required by NCSA-PLANT 048. No additional movements of the G-17 valves staged outside building X-744H were made until after the NDA survey results were obtained on June 22,1999. The spacing requirement of NCSA-PLANT 048 was met for all equipment with unknown NDA survey results in building X-744H on June 25,1999.

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List of Commitments

  • 1.

A method for documenting and tracking NDA survey results and the movement of equipment in the stores areas and warehouses will be developed and personnel will be trained on using this method. This action will be completed by November 1.1999.

2.

The requirements ofNCS A-PLANT 048 will be re-emphasized to stores / warehouse personnel through round table discussions. These discussions on the NCSA will be completed by September 15,1999.

3.

As an interim action, a lessons learned will be generated and distributed through required reading to all NCS anomalous condition responders. The required reading will review the violation of NCSA-PLANT 048 at building X-744H and emphasize the importance of a questioning attitude regarding complex issues, especially involving legacy equipment whose operation history is not well documented. This action will be completed by August 27,1999.

4.

Subsequently, the training for NCS anomalous condition respenders will be changed from required rea, ding and crew brief to formal classroom training with specific anomalous

,m condition examples given to help emphasize the importance of a questioning attitude

('v) regarding compliance with NCS requirements. The re-training of the responders will be completed by October 29,1999.

('N statements of actions completed, or they are considered enhancements to USEC's investigation,

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procedures, programs, or operations.

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