ML20212A544

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7001/99-07

ML20212A544
Person / Time
Site:	07007001
Issue date:	09/14/1999
From:	Phillips M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Adkins J UNITED STATES ENRICHMENT CORP. (USEC)
References
70-7001-99-07, NUDOCS 9909170052
Download: ML20212A544 (2)

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Mr. J. N. Adkins Vice President - Production l

United States Enrichment Corporation Two Democracy Center 6903 Rockledge Drive

! Bethesda, MD 20817  ;

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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,

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Monte P. Phillips, Acting Chief Fuel Cycle Branch Docket No. 70-7001 Certificate No. GDP-2 s

cc: H. Pulley, Paducah General Manager I L. L. Jackson, Paducah Regulatory Affairs Manager j J. M. Brown, Portsmouth General Manager S. A. Toelle, Manager, Nuclear Regulatory Assurance and Policy, USEC )

Paducah Resident inspector Office '

Portsmouth Resident inspector Office R. M. DeVault, Regulatory Oversight Manager, DOE l 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/ l l NAME Phillips/ml DATE 09fy09 s ~;n r.o'n OFFICIAL RECORD COPY \

9909170052 990914 i f PDR ADOCK 07007001 l C PDR j

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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 l

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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.

Enclosure 2 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 General Manager y

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

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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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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 l 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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Enclosure 1 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. j

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. )

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 ' I 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. l

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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Enclosure 1 GDP 99-1023 Page 5 of 5

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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Enclosure 2 GDP 99-1023 i Page1ofI  !

List of Commitments'

l. By November 17,1999, Operations will review training modules and procedures (this includes 2

ARPs, surveillance procedures and emergency procedures) for cascade UF 6 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.

(This commitment is repeated in each example discussed in Enclosure 1.)

2. Any deficiencies id' entified in the cascade UFi leak detection module from action I will be 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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