ML20212A553

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7001/99-08

ML20212A553
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
70-7001-99-08, NUDOCS 9909170056
Download: ML20212A553 (2)

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September 14, 1999 y

. 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 70-7001/99008(DNMS)

Dear Mr. Adkins:

3 This refers to your September 9,1999, response to the Notice of Violation transmitted to you by our letter dated August 10,1999, with inspection Report 70-7001/99008(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, Chief Fuel Cycle Branch -

- Docket No. 70-7001 -

Certificate No. GDP-2 cc: H. Pulley, Paducah General Manager

- L. L. Jackson, Paducah Regulatory Affairs Manager

' 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

- J. C. Hodges, Paducah Site Manager, DOE J. Volpe, State Liaison Officer DOCUMENT NAME: G:\SEC\ PAD 99008.ty To receive e copy of this document. Indicate in the box:C" = Copy without enclosure "E"= Copy with enclosure"N"= No copy DFFICE R% / l/V l l l NAME 1411ilipphtf DATE 09////99

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, A Clobal Energy Company September 9,1999 GDP 99-1030 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 70-7001/99008 Notice of Violation (NOV) 99008-02 The subject NOV involved a violation of plant procedural requirements for prompt notification to the Plant Shift Superintendent ofidentified problems involving potential operability or reportability concerns. The United States Enrichment Corporation's response to this violation is provided in Enclosure 1. Enclosure 2 lists the commitments contained in this submittal.

Ifyou have any questions regarding this submittal, please contact Larry Jackson at (270) 441-6796.

Sincerely, H w. - ) 11 General M ger Paducah Gaseous Diffusion Plant

Enclosures:

As Stated cc: NRC Regional Administrator- Region III [

NRC Resident Inspector - PGDP 1

P.O. Box 1410, Paducah, KY 42001 Telephon 502-441-5803 Fax 502-441-5801 http://www.usec.com Offices in Livermore, CA Paducah, KY Portsmouth, OH Washington, DC U I3 F

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Enclosure 1 GDP 99-1030 Page1of2 UNITED STATES ENRICIIMENT CORPORATION (USEC)

REPLY TO NOTICE OF VIOLATION (NOV) 70-7001/99008-02 Restatement of Violation Procedure CPI-PO-SF1001," Plant Shift Superintendent Communication," Revision 0, dated May 16,1996, required, in part, that the plant staff shall promptly notify the Plant Shift Superintendent ofidentified problems with Technical Safety Requirement-related systems.

Procedure CP2-BM-CIl031," Corrective Action Process at Paducah Gaseous Diffusion Plant,"

Revision 1, Change A, dated March 18,1999, required, in prt, that the plant staff shall notify the Plant Shift Superintendent immediately upon the identification of conditions which have the potential to be an operability or reportability concern.

Contrary to the above, between May 10 and June 1,1999, the plant staff did not promptly notify the Plant Shift Superintendent ofidentified problems and conditions associated with the process building I fire protection systems which had the potential to be either an operability or reportability concern.

Specifically, the plant staff did not notify the Plant Shift Superintendent of corrosion, observed j during annual reappraisals and reviews of the systems, on sprinkler heads associated with the l Technical Safety Requirement-related process building fire protection systems.

USEC Response I. Reasons for Violation The individual performing the building reappraisal decided to issue an individual Assessment

& Tracking Report (ATR) for each sprinkler head deficiency found, since tracking and l resolution would be easier with one ATR for each issue. However, the individual completed l

the C-337 building reappraisal walk-down before he informed the Plant Shift Superintendent (PSS) of the sprinkler deficiencies. Once notified of the sprinkler problems, the PSS took appropriate action per the Technical Safety Requirements. .

l The root cause of this violation is personnel error in that the individual responsible for the fire protection system reappraisals did not follow procedure. In addition, the significance of the corrosion and mineral deposits and its impact on sprinkler system operability was not fully understood.

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j-Enclosure 1 GDP 99-1030 Page 2 of 2 II. Corrective Actions Taken

1. On June 2,1999, the responsible organization manager met with the fire protection engineer performing the building reappraisal and made clear his expectation for the prompt reporting of deficiencies.

2. On August 3,1999, Fire Services included expectations for inspection completion and the writing of ATRs in a Night Order.

3. On August 12,1999, the Fire Services Manager issued a memo to all Fire Services personnel giving expectations for prompt notification to the PSS of potential problems  ;

via the ATR process. Additionally, he held meetings with each shift to discuss and I answer questions on the memo's contents.

4. On July 23, 1999, an article was put in the plant newspaper, "InsideP," which emphasized the requirement to report system or component deficiencies in a timely manner to the PSS.

III. Corrective Actions to be Taken

1. To address the generic aspects of this issue, a site wide briefing will be conducted by November 15, 1999, stating management's expectations to initiate ATRs when offnormal/ abnormal conditions are identified and to immediately notify the PSS of those conditions as identified in the procedure " Corrective Action Process at PGDP."

2. By November 30,1999, posters will be fabricated and displayed throughout work areas in prominent locations, as determined by the Functional Organization Managers, stressing the requirement to initiate an ATR when offnormal/ abnormal conditions are identified, and to immediately notify the PSS of those conditions as identified in the procedure " Corrective Action Process at PGDP."

IV. Date of Full Conpliance Full compliance with the TSRs was achieved on June 2,1999, when the Limiting Condition for Operation actions were implemented for the sprinkler systems. These systems were declared inoperable due to the sprinkler head corrosion when the appropriate ATRs were turned in to the PSS.

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1-Enclosure 2 GDP 99-1030 Page1of1 I

! List of Commitments'

l. To address the generic aspects of this issue, a site wide briefing will be conducted by November

15, 1999, stating management's expectations to initiate ATRs when offnormal/ abnormal

! conditions are identified and to immediately notify the PSS of those conditions as identified in the procedure " Corrective Action Process at PGDP." '

l j 2. By November 30,1999, posters will be fabricated and displayed throughout work areas in l- prominent locations, as determined by the Functional Organization Managers, stressing the requirement to initiate an ATR when offnormal/ abnormal conditions are identified, and to immediately notify the PSS of those conditions as identified in the procedure " Corrective Action Process at PODP "

- 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.