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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217N7591999-10-18018 October 1999 Provides Monthly Update on Progress of Installation of Seismic Upgrade Mods to Bldgs C-331 & C-335 ML20217M3861999-10-15015 October 1999 Provides Addl Changes to SAR Update Certificate Amend Request,Containing Changes That Resulted from re-evaluation of Autoclave head-to-shell O-ring Leakage Analysis Provided by DOE SAR Repts ML20217G1811999-10-14014 October 1999 Forwards Reissued Amend to Coc for Usec Paducah Gdp.Coc Corrects Coc Issued on 991006.Amend Number & Effective Date Were Inadvertently Incorporated as 3 & 991026,instead of 4 & 991105 ML20217G1731999-10-14014 October 1999 Requests Addl Info Re Applications Dtd 990924,requesting Amends to Cocs for Paducah & Portsmouth GDPs for Revised QA Programs.Encl Identifies Specific Info Needed.Info Should Be Provided within 30 Days ML20217F6801999-10-12012 October 1999 Forwards Updated Paducah GDP Certificate Amend Requests at NRC for Approval ML20217B3521999-10-0606 October 1999 Forwards Amend 3 to Certificate of Compliance GDP-1 to Revise Six Technical Safety Requirements Sections.Sections Are 2.1.4.17,2.1.4.8,2.3.4.1,2.3.4.4,2.3.4.16 & 3.10.4.b. Compliance Evaluation Rept Also Encl ML20217B2801999-10-0606 October 1999 Forwards Insp Rept 70-7001/99-203 on 990921-23.No Violations Noted ML20212K8941999-10-0404 October 1999 Forwards Insp Rept 70-7001/99-10 on 990720-0907 & Forwards NOV Indicating That Some Personnel Were Incorrectly Granted Unescorted Access to Controlled Access Areas Without Having Necessary Specific Training ML20216J8931999-10-0101 October 1999 Forwards Copy of Security Incident Log & Associated Info for Sept 1999 ML20216J9081999-09-30030 September 1999 Forwards Revised Written Event Rept 99-10,rev 3,pertaining to Corroded Fire Sprinkler Heads Affecting Operability of high-pressure Fire Water (HPFW) Sprinkler Sys.No Commitment Contained in Rept ML20217M3701999-09-29029 September 1999 Submits bi-monthly Update on Progress of Mods to Upgrade Audibility of Criticality Accident Alarm Sys (Caas).Schedule for CAAS Audibility Upgrades Attached ML20212H1251999-09-24024 September 1999 Notifies NRC of Change in Regulatory Commitments Associated with Submittal Date for Update of Application SAR Chapter 3.Specifics of Commitment Changes of Listed ML20212H3801999-09-24024 September 1999 Responds to 990723 RAI Re 1999 Annual Update to Certification Applications ML20212H3721999-09-22022 September 1999 Forwards NRC Form 790 Classification Record Documents for Paducah & Portsmouth GDPs That Were Generated During Month of Aug 1999.Without Encl ML20212F0981999-09-22022 September 1999 Forwards Insp Rept 70-7001/99-12 on 990830-0902.Purpose of Insp Was to Determine If Security Requirements Adequately Implemented & Included Review of Approved Plant Security Plan.No Violations Identified ML20217J1211999-09-20020 September 1999 Submits Listed Comments on NRC Proposed Rule, Reporting Requirements for Nuclear Power Reactors ML20212D4291999-09-17017 September 1999 Forwards Required 30-day Written Event Rept Re Criticality Accident Alarm Sys Response Time in Bldg C-710.Encl 2 Contains Commitments Contained in Submittal ML20212D4231999-09-16016 September 1999 Informs That Review of Event Rept Er 99-12 Revealed Listed Two Statements Inadvertently Omitted from Document ML20212D2361999-09-15015 September 1999 Submits Monthly Update on Progress of Installation of Seismic Upgrade Mods to Bldgs C-331 & C-335 ML20212B6611999-09-15015 September 1999 Forwards Insp Rept 70-7001/99-202 on 990816-20.No Violations Noted ML20212A5441999-09-14014 September 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7001/99-07 ML20212A5531999-09-14014 September 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7001/99-08 ML20211Q9951999-09-10010 September 1999 Forwards 30-day Written Rept ER-99-12,re Loss of Power to Autoclave Position 1 North & 1 South Process Gas Leak Detection (Pgld) in Bldg C-333-A.Caused by Electrical Short Circuit.Submitted Work Request 501636 for PI SEX-4 ML20216E4891999-09-0909 September 1999 Responds to Violations Noted in Insp Rept 70-7001/99-08. Corrective Actions:On 990602 Responsible Organization Manager Met with FP Engineer Performing Bldg Reappraisal & Made Clear Expectation for Prompt Reporting of Deficiencies ML20211P2091999-09-0909 September 1999 Provides Staff Written Clarification of NRC Reporting Expectations of When Double Contingency Losses Should Be Reported to NRC IAW Bulletin 91-001, Reporting Loss of Criticality Safety Controls, & Suppl ML20211P3831999-09-0303 September 1999 Forwards Coc GDP-1,amend 3 & Coc GDP-2,amend 4 for Paducah (Pgdp) & Portsmouth (Ports) Gdps,Respectively by Revising Pgdp & Ports QAPs in Vol 3 of Respective Certificate Applications ML20211L6441999-09-0202 September 1999 Forwards Insp Rept 70-7001/99-11 on 990802-06.No Violations Noted.Insp Consisted of Selective Exam of Procedures & Representative Records,Interviews with Personnel & Observations of Activities in Progress ML20211M3551999-09-0101 September 1999 Forwards Copy of Security Incident Log & Associated Info for Month of Aug 1999,IAW 10CFR95.57(b) ML20211K4041999-08-31031 August 1999 Forwards Responses to Remaining NRC Questions/Comments from 980601 & 0709 NRC RAIs Re SAR Update ML20211M7031999-08-30030 August 1999 Forwards Proprietary Rev 0 to Arming & Arrest Authority Security Plan for Paducah & Portsmouth Gaseous Diffusion Plants, for Review & Approval.Encl Withheld ML20211G9971999-08-26026 August 1999 Forwards Rev 2 to Written Rept Er 99-10,re Corroded Fire Sprinkler Sys in Bldg C-337 & C-333.Analysis of Root Cause Has Not Been Completed.Statistically Based Sprinkler head- Sampling Plan Has Been Completed & Approved ML20211B5021999-08-20020 August 1999 Forwards Amend 2 to Certificate of Compliances GDP-1, Revising Paducah GDP Technical Safety Requirements Re Audibility Requirements for Criticality Accident Alarm Sys at Facility & Related Sections of SAR ML20211F1761999-08-20020 August 1999 Requests That Paducah GDP facility,C-709 Lab Annex Bldg Be Added to List of Facilities to Be Exempted from CAAS Detection Coverage ML20211D9751999-08-20020 August 1999 Forwards Rev 1 to Final Written Event Rept Er 99-11,re Unplanned Actuation of C-333-A Autoclave 1 North Autoclave Steam Pressure Control Sys (Aspcs) on 990623 ML20211A7011999-08-17017 August 1999 Forwards Copy of Final Amend to 10CFR76 for Info of Subcommittee.Final Rule Is Being Transmitted to Fr for Publication.Final Rule Will Amend Regulations That Apply to Paducah & Portsmouth Gaseous Diffusion Plants ML20211D5811999-08-16016 August 1999 Submits Monthly Update on Progress of Installation of Seismic Upgrade Mods to Bldgs C-331 & C-335 ML20210P7421999-08-10010 August 1999 Forwards Insp Rept 70-7001/99-08 on 990529-0719 & Nov. Violations of Concern Because Late Reporting of Problems with safety-related Equipment Could Negatively Impact Continued Availability of Equipment ML20210Q6061999-08-0909 August 1999 Forwards NRC Form 790 Classification Record Documents for Paducah & Portsmouth Gdps,Per 10CFR95.57.Records Were Generated During Month of July 1999.Without Encl ML20210L6571999-08-0404 August 1999 Informs That Staff Completed Initial Review of 990720 Application to Amend Coc GDP-1.Staff Anticipates Completing Review by 990930 ML20211A7901999-08-0404 August 1999 Forwards Info Requested During Briefing by NRC Staff on 990726 Re NRC Interactions with Usec ML20210H3161999-07-30030 July 1999 Forwards Rev 1 to Written Event Rept ER-99-10,re Corroded Fire Sprinkler Heads Affecting Operability of HP Fire Water Sprinkler Sys in Bldg C-337 & C-333.Testing & Analysis of Root Cause & Corrective Actions Necessary Are Not Complete ML20210J1331999-07-30030 July 1999 Forwards Copy of Security Incident Log & Associated Info for Month of July 1999,per Reporting Requirements of 10CFR95.57(b) ML20210H2181999-07-29029 July 1999 Responds to Violations Noted in Insp Rept 70-7001/99-07. Corrective Actions:Smoke Watch Was Established Covering Area Affected by Process Gas Leak Detection Inoperabilty & Individuals Involved Were Counseled for Personnel Errors ML20210P7871999-07-29029 July 1999 Provides bi-monthly Update on Progress of Modifications to Upgrade Audibility of Criticality Accident Alarm Sys,In Response to NRC 981217 Request ML20210F9761999-07-28028 July 1999 Forwards Compliance Evaluation Rept Prepared to Support Amend of Coc GDP-1 Re Criticality Accident Alarm Sys Audibility.Notice of Amend Forwarded to Ofc of Fr Also Encl ML20210J7921999-07-27027 July 1999 Forwards Proprietary NRC Form 327, Special Nuclear Matl (SNM) & Source Matl (SM) Physical Inventory Summary Rept, for Paducah & Portsmouth Gdps.Rept Covers Period Ending 990528.Proprietary Info Withheld,Per 10CFR2.790(d) ML20210G0391999-07-26026 July 1999 Forwards Compliance Evaluation Rept & Fr Notice for Revised Qaps,Per 990212 Application ML20210H6001999-07-26026 July 1999 Forwards NRC Form 790 Classification Record Documents for Paducah & Portsmouth Gaseous Diffusion Plants That Were Generated During Month of June 1999.Without Encl ML20210D8181999-07-23023 July 1999 Submits Response to SA Toelle Ltr Dtd 990614, 10CFR76.68(a)(3) Decreased Effectiveness Reviews & RAI for Paducah & Portsmouth Transmittals of 1999 Annual Update to Certification Applications ML20210E4291999-07-23023 July 1999 Forwards Required 30-day Written Event Rept Re Unplanned Actuation of C-333-A Autoclave 1 North Autoclave Steam Pressure Control Sys (Aspcs) on 990623.Investigation Ongoing for Root Cause 1999-09-09
[Table view] Category:OUTGOING CORRESPONDENCE
MONTHYEARML20217G1731999-10-14014 October 1999 Requests Addl Info Re Applications Dtd 990924,requesting Amends to Cocs for Paducah & Portsmouth GDPs for Revised QA Programs.Encl Identifies Specific Info Needed.Info Should Be Provided within 30 Days ML20217G1811999-10-14014 October 1999 Forwards Reissued Amend to Coc for Usec Paducah Gdp.Coc Corrects Coc Issued on 991006.Amend Number & Effective Date Were Inadvertently Incorporated as 3 & 991026,instead of 4 & 991105 ML20217B3521999-10-0606 October 1999 Forwards Amend 3 to Certificate of Compliance GDP-1 to Revise Six Technical Safety Requirements Sections.Sections Are 2.1.4.17,2.1.4.8,2.3.4.1,2.3.4.4,2.3.4.16 & 3.10.4.b. Compliance Evaluation Rept Also Encl ML20217B2801999-10-0606 October 1999 Forwards Insp Rept 70-7001/99-203 on 990921-23.No Violations Noted ML20212K8941999-10-0404 October 1999 Forwards Insp Rept 70-7001/99-10 on 990720-0907 & Forwards NOV Indicating That Some Personnel Were Incorrectly Granted Unescorted Access to Controlled Access Areas Without Having Necessary Specific Training ML20212F0981999-09-22022 September 1999 Forwards Insp Rept 70-7001/99-12 on 990830-0902.Purpose of Insp Was to Determine If Security Requirements Adequately Implemented & Included Review of Approved Plant Security Plan.No Violations Identified ML20212B6611999-09-15015 September 1999 Forwards Insp Rept 70-7001/99-202 on 990816-20.No Violations Noted ML20212A5441999-09-14014 September 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7001/99-07 ML20212A5531999-09-14014 September 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7001/99-08 ML20211P2091999-09-0909 September 1999 Provides Staff Written Clarification of NRC Reporting Expectations of When Double Contingency Losses Should Be Reported to NRC IAW Bulletin 91-001, Reporting Loss of Criticality Safety Controls, & Suppl ML20211P3831999-09-0303 September 1999 Forwards Coc GDP-1,amend 3 & Coc GDP-2,amend 4 for Paducah (Pgdp) & Portsmouth (Ports) Gdps,Respectively by Revising Pgdp & Ports QAPs in Vol 3 of Respective Certificate Applications ML20211L6441999-09-0202 September 1999 Forwards Insp Rept 70-7001/99-11 on 990802-06.No Violations Noted.Insp Consisted of Selective Exam of Procedures & Representative Records,Interviews with Personnel & Observations of Activities in Progress ML20211B5021999-08-20020 August 1999 Forwards Amend 2 to Certificate of Compliances GDP-1, Revising Paducah GDP Technical Safety Requirements Re Audibility Requirements for Criticality Accident Alarm Sys at Facility & Related Sections of SAR ML20211A7011999-08-17017 August 1999 Forwards Copy of Final Amend to 10CFR76 for Info of Subcommittee.Final Rule Is Being Transmitted to Fr for Publication.Final Rule Will Amend Regulations That Apply to Paducah & Portsmouth Gaseous Diffusion Plants ML20210P7421999-08-10010 August 1999 Forwards Insp Rept 70-7001/99-08 on 990529-0719 & Nov. Violations of Concern Because Late Reporting of Problems with safety-related Equipment Could Negatively Impact Continued Availability of Equipment ML20210L6571999-08-0404 August 1999 Informs That Staff Completed Initial Review of 990720 Application to Amend Coc GDP-1.Staff Anticipates Completing Review by 990930 ML20211A7901999-08-0404 August 1999 Forwards Info Requested During Briefing by NRC Staff on 990726 Re NRC Interactions with Usec ML20210F9761999-07-28028 July 1999 Forwards Compliance Evaluation Rept Prepared to Support Amend of Coc GDP-1 Re Criticality Accident Alarm Sys Audibility.Notice of Amend Forwarded to Ofc of Fr Also Encl ML20210G0391999-07-26026 July 1999 Forwards Compliance Evaluation Rept & Fr Notice for Revised Qaps,Per 990212 Application ML20210D8181999-07-23023 July 1999 Submits Response to SA Toelle Ltr Dtd 990614, 10CFR76.68(a)(3) Decreased Effectiveness Reviews & RAI for Paducah & Portsmouth Transmittals of 1999 Annual Update to Certification Applications ML20210V3481999-07-16016 July 1999 Informs That Staff Completed Review of New Payment Surety Bonds (Psb) for Paducah & Portsmouth Gdps,Which Were Provided in .Cancelled Psbs for Liberty Mutual Insurance Co & Safeco Insurance Co of America,Encl ML20209F0611999-07-0909 July 1999 Forwards Insp Rept 70-7001/99-09 on 990621-25.No Violations Noted ML20196K0981999-07-0101 July 1999 Forwards Insp Rept 70-7001/99-07 on 990413-0528 & Nov. Violations Re Failure to Fully Evaluate Situation in Which Safety Sys Relied Upon to Mitigate Consequences of Accident Was Inappropriately Returned to Svc ML20196A1571999-06-17017 June 1999 Confirms Discussions Between K Obrien & L Jackson to Conduct Meeting on 990630 to Discuss Apparent Violation ML20207F1311999-06-0404 June 1999 Responds to Requesting Copy of OI Rept 3-1998-033 Re Docket Potential Violation of 10CFR76.7 Concerning Employee Protection at Plant.Request Denied for Listed Reasons ML20207F2571999-06-0202 June 1999 Informs That NRC Disagrees with Usec Conclusion for Not re-opening Issue 2 of Compliance Plan,Since Proposed Change to Sarup Submittal Constitutes Major Rev to Operating Safety Bases Contained in Technical Safety Requirements ML20207E8201999-05-18018 May 1999 Refers to Investigation Case 3-1998-033 Re Apparent Violation Involving Usec & Lockheed-Martin Utility Service, Inc Mgt Discriminating Against Employee at Paducah Gaseous Diffusion Plant.Synopsis Encl.Without Encl 2 ML20206N3851999-05-12012 May 1999 Forwards Amend 1 to Coc GDP-1 & Amend 3 to Coc GDP-2 IAW 990316 Applications,Revising Paducah & Portsmouth Gaseous Diffusion Plants Technical Safety Requirement Sections 3.1.1 & 3.10.4 ML20206H5161999-05-0606 May 1999 Informs That NRC Will Not Be Able to Complete Review of Paducah Certificate Amend Request on Criticality Accident Alarm Sys Audibility Upgrade by 990507,as Indicated in NRC .Review Should Be Completed by 990630 ML20206E6481999-04-29029 April 1999 Forwards Insp Rept 70-7001/99-04 on 990224-0412.No Violations Noted ML20205R8041999-04-20020 April 1999 Forwards Partially Withheld Insp Rept 70-7001/99-201 Conducted on 990322-26.Scope & Results of Insp Summarized in Rept ML20205K4251999-04-0707 April 1999 Forwards Compliance Evaluation Rept for GDP-1 & GDP-2, Supporting Change in Title of Executive Vice President, Operations.Notice of Amend,Which Has Been Forwarded to Ofc of Fr for Publication,Encl ML20205K4481999-04-0707 April 1999 Forwards Addl Info Needed for Staff to Complete Review of 990112 Application for Amend Re Seismic Upgrades for Bldgs C-331 & C-335 at Paducah Gaseous Diffusion Plant ML20205J3021999-04-0202 April 1999 Forwards Insp Rept 70-7001/99-05 on 990322-25.No Violations Noted.Insp Included Review of Approved Paducah Physical Security Plan ML20204H9611999-03-18018 March 1999 Forwards RAI Re 990212 Applications Requesting Amends to Coc for Paducah & Portsmouth Gaseous Diffusion Plants for Revised QAPs ML20204F2511999-03-17017 March 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7001/98-18.Actions Will Be Examined During Future Insp ML20204C2721999-03-17017 March 1999 Ack Receipt of Application to Amend Coc GDP-1,re Criticality Sys Audibility Upgrades,Transmitted by Ltr . NMSS Anticipates Completing Technical Review by 990301 ML20207M1081999-03-11011 March 1999 Discusses Us Enrichment Corp Participation in Round Robin Sample Exchange Program Administered by Nbl for Verfying Quality of Licensee U Destructive Measurement Sys.Invoices FL0237-99 & FL0238-99 for Amount Listed Encl ML20207K3011999-03-11011 March 1999 Forwards Insp Rept 70-7001/99-01 on 990113-0223.No Violation Noted.Continuing Problems with Some Plant Staff Understanding & Adherence to long-standing Plant Policies & Procedures Were Found ML20207J7641999-03-11011 March 1999 Requests Addl Info,Specified in Encl,Re 980918 Paducah Gaseous Diffusion Plant Seismic Hazard Analysis,Rev 2,for Staff Review ML20207G2231999-03-0505 March 1999 Discusses Insp Rept 70-7001/98-18 on 981201-990112 & Forwards Notice of Violation Re Failure to Maintain Control of Classified Matter at Paducah Facility ML20207B3361999-03-0202 March 1999 Ack Receipt of 990212 Applications for Amend to Cocs GDP-1 & GDP-2.Staff Has Completed Initial Administrative Rev of Applications & No Omissions of Deficiencies Were Identified. Staff Anticipates Completing Review by 990416 ML20203G4011999-02-0909 February 1999 Forwards Insp Rept 70-7001/99-02 on 990125-29.No Violations Noted.Insp Consisted of Selective Exam of Procedures & Representative Records,Interviews with Personnel & Observations of Activities in Progress ML20202F0531999-01-29029 January 1999 Forwards Renewed Cocs for Paducah & Portsmouth Gaseous Diffusion Plants Located in Paducah,Ky & Piketon,Oh. Compliance Evaluation Rept Encl Also ML20202G2501999-01-29029 January 1999 Discusses 990125 Meeting with Us Enrichment Corp in Lisle,Il Re Implementation Status of C/A Plans for Nuclear Criticality Safety Program & Basis for Proposed Changes to Completion Dates for Some C/A.List of Attendees Encl ML20202F5591999-01-26026 January 1999 Expresses Appreciation for 981104,comments on Draft Rept to Congress.Future Repts Will Be Prepared in Conjunction with Recertification Reviews ML20202F0461999-01-26026 January 1999 Expresses Appreciation for 981104,comments on Draft Rept to Congress.Changes Were Made to Rept to Address All of Comments Except for One.Event Notification Summary Was Not Revised to Addl Info Requested ML20202F5731999-01-26026 January 1999 Informs That Chairman Has Sent Rept to Congress on Gaseous Diffusion Plants,As Required by Aec.Rept Discusses Status of Health,Safety & Environ Conditions at Plants Located Near Paducah,Ky & Portsmouth,Oh for Period from 971001-980930 ML20199H1011999-01-15015 January 1999 Forwards Second NRC Rept to Congress,Covering Period from 971001-980930.Rept Discusses Status of Health,Safety & Environ Conditions at Gaseous Diffusion Plants Near Paducah,Ky & Portsmouth,Oh ML20199G2161999-01-14014 January 1999 Forwards Amend 23 to Coc GDP-1,revising TS Requirement 2.3.4.7 on Product & Tails Withdrawal Facilities Criticality Accident Alarm Sys 1999-09-09
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l Mr. J. N. Adkins Vice President - Production United States Enrichment Corporation Two Democracy Center 6903 Rockledge Drive Bethesda, MD 20817 i
SUBJECT:
RESPONSE TO INSPECTION REPORT 70-7001/99007(DNMS) j
Dear Mr. Adkins:
i This refers to your July 29,1999, response to the Notice of Violation transmitted to you by our letter dated July 1,1999, with inspection Report 70-7001/99007(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.
Sincerely,
/
Monte P. Phillips, Acting Chief Fuel Cycle Branch Docket No. 70-7001 Certificate No. GDP-2 s
H. Pulley, Paducah General Manager I
cc:
L. L. Jackson, Paducah Regulatory Affairs Manager j
J. M. Brown, Portsmouth General Manager S. A. Toelle, Manager, Nuclear Regulatory Assurance and Policy, USEC
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Paducah Resident inspector Office Portsmouth Resident inspector Office R. M. DeVault, Regulatory Oversight Manager, DOE J. C. Hodges, Paducah Site Manager, DOE I
J. Volpe, State Liaison Officer i
DOCUMENT NAME: G:\\SEC\\ PAD 99007.TY To receive a copy of this document, IndicateJn the box:"C" = Copy without enclosure "E"= Copy with enclosure"N"= No copy j
OFFICE Rlli lA/
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NAME Phillips/ml DATE 09fy09 s ~;n r.o'n OFFICIAL RECORD COPY
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J. Adkins bec w/itr dtd 7/29/99: PUBLIC IE-07 w/ encl R. Pierson, NMSS P. Ting, NMSS t
W. Troskoski, NMSS l
P. Harich, NMSS
- Y. H. Faraz, NMSS R. Bellamy, RI EJM, Rll (e-mail)
D. B. Spitzberg, RIV I
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-l v LSEC A Global Energy Company July 29,1999 GDP 99-1023 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Paducah Gaseous Diffusion Plant (PGDP)
Docket No. 70-7001 Reply to Inspection Report 70-7001/99007 Notice of Violation (NO\\9 99007-02 The subject NOV involved two examples of a violationof plant Technical Safety Requirements.
The United States Enrichment Corporation's response to this violation is provided in Enclosure 1. lists the commitments contained in this submittal. Unless specifically noted, the corrective actions specified in each enclosure apply solely to PGDP.
If you have any questions regarding this submittal, please contact Larry Jackson at (270) 441-6796.
Sincerely, hwa y
General Manager Paducah Gaseous Diffusion Plant
Enclosures:
As Stated cc: NRC Regional Administrator - Region Ill NRC Resident Inspector - PGDP P.O. Box 1410 Paducah, KY 42001 AtJG 3 1999 l
Telephone 502-4415803 Fax 502-441-5801 http://www.usec.com Offices in Livermore, CA Paducah, KY Portsmouth, OH Washington, DC 0? SCW]lA
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f Enclosure i GDP 99-1023 Page 1 of 5 UNITED STATES ENRICIIMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7001/99007-02 Restatement of Violation
" Technical Safety Requirement 2.4.4.1, requires, in part, that within one hour after the discovery of a process gas leak detection system inoperability, a continuous smoke watch shall be implemented for the cell or cells affected by the process gas leak detection system inoperability or the cells shall be placed in a Mode for which the Limiting Condition for Operation does not apply.
Contrary to the above, on April 11 and April 27,1999, the plant staff did not implement a continuous smoke watch for areas surrounding Building C-333 Unit 5, Cell 4 and Unit 5, Cell 1, respectively, or place the cells in a Mode for which Technical Safety Requirement 2.4.4.1, Limiting Condition for Operation did not apply within one hour after the associated process gas leak detection system heads were determined to be inoperable. Specifically, the plant staffdid not implement a continuous smoke watch for or place the cells in a Mode for which the Limiting Condition for Operation did not apply until greater than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for Building C-333 Unit 5, Cell 4 and greater than one and a half hours for Unit 5, Cell 1, respectively."
USEC Response To TSR 2.4.4.1 Violation on April 11,1999, at C-333 Unit 5, Cell 4 I. Background Summary On April 11,1999, a problem was identified with the C-333 Unit 5, Cell 4 PGLD system during routine test firing of the heads per CP4-CO-CN6020t. At the time of the test, C-333 Unit 5, Cell 4 was operating in Cascade Mode 2 and the Process Gas Leak Detection (POLD) system was required to be operable per TSR 2.4.4.1.
During test firing of the Unit 5, Cell 4 heads, the system did not function properly. The problem was identified by the operator performing the surveillance; however, no notification was made to the First line Manager (FLM) or Plant Shift Superintendent (PSS) and steps were not taken to implement the Limited Conditions for Operations (LCO) actions until approximately two (2) hours later when the FLM reviewed the data sheets. This exceeded the one-hour time limit specified in the TSR action statement. While investigating this event, it was also discovered that receipt of the UF detection alarms was not verified in the Area Control Room (ACR), as I
required by step 8.2.0 of CP4-CO-CN6020t, Revision 0.
l The operator assigned to test fire the PGLD systems began this task at approximately 2115 hrs.
f As the systems were test fired, they were called out over the radio. When no response was l
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L GDP 99-1023 Page 2 of 5 received, the operator assumed the alarms had been received and cleared in the ACR, and proceeded to test the next system. At this point, the operator in the field violated CP4-CO-CN6020t by failing to notify the ACR.
In addition to the procedure violation in the field, no one in the ACR was performing the verification required in CP4-CO-CN6020t. While the ACR operator was aware the PGLD systems were being test fired, he was not verifying receipt of the alarms and was aware that no one else in the ACR was verifying the alarms either. When questioned, the ACR operator stated he was aware of the requirement to verify the alarms in the ACR, yet he did not notify the FLM that the alarms were not being verified in the ACR.
II. Reasons for Violation The root cause was personnel error, in that the operator in the field and the ACR operator failed to follow procedure. A contributing cause was a weakness identified in CP4-CO-CN6020t.
Had the procedure required the ACR operator verifying receipt of the alarms to sign the data 1
sheet, the missed surveillance might have been caught before the LCO time was exceeded.
The NRC inspection report identified operator training as a potential weakness. The NOV investigation did not reveal a serious weakness with training; however, a future corrective action for this and the following examples will address training module adequacy and procedure quality.
III. Corrective Actions Taken
- 1. On April 12,1999, at 0010 hrs., a smoke watch was established covering the area affected by the PGLD inoperability.
- 2. Both the operator performing the surveillance and the ACR operator were counseled / disciplined for their personnel errors.
- 3. Operations issued a memo on April 16, 1999, to all appropriate personnel in C-333 emphasizing that PGLD surveillances are to be given top priority when operating in Cascade t
Mode 2.
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- 4. A Lessons Leamed (99-005) was issued as a crew briefing to all cascade operations l
personnel on April 28,1999, addressing the importance of team work and stopping work if the task is not perfonned correctly. The Lessons Leamed also emphasized the importance of procedure compliance and stressed that any problems with TSR systems must be reported to management immediately.
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GDP 99-1023 Page 3 of 5
- 5. A Long Tenn Order (LTO 99-002) was issued on April 16,1999, requiring the operator in the ACR responsible for verifying alarm receipt to sign the surveillance sheet along with the operator performing the surveillance.
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- 6. CP4-CO-CN6020t was revised to incorporate the requirements of LTO 99-002 on May 14, 1999.
IV. Corrective Actions to be Taken
- 1. By November 17, 1999, Operations will review training modules and procedures (this includes ARPs, surveillance procedures and emergency procedures) for cascade UF. leak detection. This review will evaluate module and procedure adequacy in providing personnel guidance for determining system operability based on system indications such as indicating lights, alarms, etc.
V. Date of Full Compliance USEC achieved full compliance with TSR 2.4.4.1 in C-333 on April 12,1999, at 0010 hrs. when a smoke watch was established covering the area alTected by the PGLD inoperability.
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i USEC Response To TSR 14.4.1 Violation on April 27,1999, at C-333 Unit 5, Cell 1 L Background Summary On April 2/,1999, detector head YE-45 alarmed on the Unit 5, Cell 1 PGLD system and continued to alarm when reset. YE-45 provides coverage for the No. 2 low speed pump and was not required to be operable per TSR 2.4.4.1. It was determined YE-45 was alarming due to maintenance work occurring on the No. 3 low speed pump that was generating smoke. The head was declared inoperable with the alarm locked in at both the signal conditioner and ACR. [ Note:
When the ACR PGLD alarm is locked in, it will not alarm again (referred to as "reflash") if a second head were to fire; therefore, the enCre system is rendered inoperable.]
While ACR personnel were aware of the locked in alarm, they failed to understand its impact on system operability and assumed the issue was resolved when YE-45 had been declared inoperable. They also failed to communicate this to the FLM or PSS.
When the problem with YE-45 was reported by the operator to the FLM and discussed (even to the point of researching operability requirements in the TSR), the FLM never understood the
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Unit 5, cell 1 PGLD alarm was locked in until it was pointed out by a second manager in the building. When the FLM became aware ofit, the LCO actions were taken and the PSS notified.
I Since actions under the LCO were not taken within one hour of the time the system was discovered to be inoperable, a violation of TSR 2.4.4.1 occurred.
II. Reasons for Violation.
The root cause of the event was inadequate training of the operators on the PGLD system. This '
was evident by their poor understanding ofsystem operation. In addition, there appeared to be procedure weaknesses which contributed to the TSR violation, i
. III. Corrective Actions Taken i
- 1. On April 27,1999, at 1115 hrs., a smoke watch was established covering the area affected by the inoperable PGLD system.
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- 2. As an interim compensatory action, immediately following the April 27 event, LTO 99-003 was issued in Cascade Operations for all areas operating in Cascade Mode 2 which required:
Hourly ACR panel board walkdowns by both the FLM and ACR operators; Assistant PSS oversight of the two TSR 2.4.4.1 surveillances performed per shift; Strict adherence to the Alarm Response Procedures for PGLD alarms; Implementation of a policy which declares the complete PGLD system inoperable when any component's operability is questioned; and, Incorporation of the guidance of LTO 99-002 (discussed in the first example).
- 3. LTO 99-001, Rev. I was issued on June 21,1999. This LTO requires operator training be conducted on the operation of the PGLD system prior to retuming to Cascade Mode 2.
IV. Corrective Actio a to be Taken I
- 1. By November 17,1999, Operations will review training modules and procedures (this includes ARPs, surveillance procedures and emergency procedures) for cascade UF leak l
detection. This myiew will evaluate module and procedure adequacy in providing personnel l'
guidance for determining system operability based on system indications such as indicating 1-lights, alarms, etc.
- 2. Any deficiencies identified in the cascade UF leak detection module from action I will be corrected prior to' conducting the training specified in LTO 99-001.~
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- 3. Any deficiencies identified in the procedures for cascade UF, leak detection from action I will be corrected prior to resuming operations in Cascade Mede 2.
V. Date of Full Compliance USEC achieved full compliance with TSR 2.4.4.1 in C-333 on April 27,1999, at i 115 hrs. when a smoke watch was established covering the area affected by the inoperable PGLD system.
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Page1ofI List of Commitments'
- l. By November 17,1999, Operations will review training modules and procedures (this includes 2ARPs, surveillance procedures and emergency procedures) for cascade UF leak detection. This 6
review will evaluate module and procedure adequacy in providing personnel guidance for
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determining system operability based on system indications such as indicating lights, alarms, etc.
(This commitment is repeated in each example discussed in Enclosure 1.)
- 2. Any deficiencies id' entified in the cascade UF leak detection module from action I will be i
corrected prior to conducting the training specified in LTO 99-001.
- 3. Any deficiencies identified in the procedures for cascade UF. leak detection from action I will i
L be corrected prior to resuming operations in Cascade Mode 2.
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' Regulatory commitments contained in this document are listed here. Other corrective
. 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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