ML20212F695
| ML20212F695 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 10/29/1997 |
| From: | Morgan J UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-7002-97-206, GDP-97-2026, NUDOCS 9711050070 | |
| Download: ML20212F695 (10) | |
Text
. _ _ _ _ _ _ _. _ _ _ _.
United States Enrichment Corpor:teon 2 Democracy Center.
T~
6903 nockiedoe Drwe Betheada, MD 20817 Tel. (301) 564 3200 Fao(301)564 32')1 October 29,1997 GDP-97-2026 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Portsmouth Gascous Diffusion Plant (PORTS)
Docket No. 70-7002 Response to Inspection Report (IR) 70-7002/97206 Notlee of Violation (NOV)
Nuclear Regulatory Commission (NRC) letter dated September 29,1997, transmitted the subject inspection Report (IR) that contained three violations involving: 1) failure to flowdov. firefighting instmetions into emergency packets; 2) failure to identify the technical basis for the 10 foot spacing between Planned Expeditious llandling (PEll) equipment in a Nuclear Criticality Safety Approval documr:nt; and 3) failure to establish a Technical Safety Requirement for single contingent operations.
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.
Ifl In the cover letter which transmitted the Inspection Report. NRC stated that:
these violations are ofconcern because they allinvolve thefailure to identify and j
flowdown an adequate criticality safety basis in yourfacilities. There does not appear to be a positive trend in >vur performance on this aren.
USEC recognizes that substantial improvement is warranted in the Nuclear Criticality Safety (NCS) program at PORTS USEC has detennined that the primary reasons for the deficiencies in the PORTS NCS program are as follows:
Luck of adequate management oversight of the NCS program. Specifically, the goals, purpose, and expectations of the NCS organization and its interface with the plant have not been clearly defined.
Inadequate Nuclear Criticality Safety Assessments and Evaluations (NCSAs/NCSEs)
[{\\l]l}$[\\\\%i aMl$\\}
9711050070 971 PDR ADOCK 07 002 C
, Offices in LMrmore.Cahfornia Paducah. Kentucky Portsmouth, Ohio Wr shington, DC
United States Nuclear Regulatory Commission October 29,1997 Page Two -
NOV 97206-11 and the failure to properly How NCSA/NCSE requirements into implementing procedures.
Lack of adequate training of NCS procedures and policies.
Failure to follow procedural requirements. For example. on October, 17, 1997, USEC discovered that Engineering Change Notices were bcing used to change NCSA requirements which is in violation of NCS procedures.
Ineffective corrective actions from previous identified NCS deficiencies.
Ineffective self-assesstr.ents by the NCS Organiz aan.
As a result 4 weaknesses identified by both USEC and NRC in the PORTS NCS program, USEC is developing a corrective action p!an to improve the perfbrmance of the NCS Program and its support to the operah.n of PORTS. This plan will cover all aspects of the NCS Program and its function from the identification of fissile material operations through the implementation of the controls necessary to ensure criticality safety. The plan wi!! contain both short-term and long-temi objectives in order to ensure continuous improvement in the NCS Program at PORTS.
Additionally, per discussions between Russ Wells of US!!C and Dennis Morey of NRC on October 29,1997, USEC has requested a meeting with NRC to discuss the details of our corrective action plan to improve ou-NCS performance at PORTS.
If you have any questions regarding this submittal, please contact Ron Gaston at (614) 897-2710.
Sincerely, S.b James B. Morgan General Manager Portsmouth Gaseous Diffusion Plan' Enclosures (4)-
cc:
~ Regional Administrator, Region ill NRC Resident inspector, PORTS DOE Site Safety Repusentative. PORTS J
4 UNITED STATES ENRICllMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/97-206-11 Restatement of Violation SAR Section 6.11.1 requires, in part, that "...USEC is committed to the use of approved and controlled written procedures to conduct nuclear safety, safeguards, and secud y activities for t
the protection of the public, plant employees, and the environment."
PORTS procedure XP2-EP EP1049 requires maintenance of Emergency Packets with complete information at the Emergency Operations Center, the 300 building, and the affected facility.
Contrary to the above, on August 27,1997, the Emergency Operations Center and the 300 building packets for Building 344 did not have information concerning criticality safety requirements for firefighting.
I.
Reasons for Violation The reason for the violation was failure to follow procedure and the lack of a management control and verification ;rocess to measure the performance, maintenance, and quality of the emergency packet review / surveillance activity. By procedure (XP2-EP-EP1049; Emergency Ahmagement Program), the facility manager is responsible for the technical content of the emergency packet and semiannual review of all emergency packets to ensure that the technical information contained in the packets is complete, accurate and up-to-date. In this case, the facility manager reviewed the packat, as indicated by signature, but did not identify the deficiency documented in this citation
Background:
At Portsmouth, Emergency packets are used in lieu of pre-fire plans and contain information about the building, the layout, apecific hazards and other infomaation applicable to the individual facility (SAR-PORTS 5.4.1.3, Pre Fire Planning). These packets are designed to be used in an emergency situatinn to provide vital inforn.ation to the incident commander to minimize / mitigate the hazards of an event. Included in the Packet are NCS concems to alert the incident commander and fire service personnel of potential NCS issues.
By procedure, facility managers maintain the master copy of the facility emergency packet, from which two other copies are made and distributed to the EOC and the X-300 facility.
Should the facility authorize a modification which changes the configuration of the facility and '
could affect management response efforts, the facility custodian is responsible for updating El-1
=
i---
the master copy of the facility emergency packet and to update appropriate pages of the other two distributed facility emergency packets. A review of the packets is required every six months by the facility custodian to ensure the packets are complete, accurate, and up to date, in discussions with the inspector, fire service personnel indicated that the emergency packets did not contain sullicient firefighting infonnation regarding fire fighting restrictions in moderation control areas. Ilme gency Packets were subsequently examined by the inspector to detennine whether they contained information on NCS firenghting restrictions (primarily on the use of water as an extinguishing agent). When the IImergency packets in the limergency Operations Center (I!OC) and the X-300 facility were reviewed, the emergency packet for the X 705 building was found to be inadequate because they contained only a list of associated NCSAs, which in efTect, would requSe an individual to detemiine which NCSA governed the particular area of concem..nd to examine the appropriate analysis to make a judgement concerning the use of water. In addition, the emergency packets located in the IIOC and X-300 for the X-344 facilities were not consistent with the master.
To determine if this denciency represented an isolated or generic concern, all emergency packets were reviewed for completeness. The review concluded that the issue was symptomatic of a weak fire protection and emergency management control process and a weak verification process.
II.
Corrective Actions Taken and Itcsults Achieved 1.)
To correct the deficient X-344 cmcrgency packet, on August 27,1997, copies of the missing information were provided to update the packets. The packets were then reviewed to ensure no additional required information was missing.
2.)
A review of all remaining limergency Packets was conducted to ensure that appropriate and required infonnation was in each facility emergency packet. Missing or out of date information was corrected and documented.
3.)
Current I!mergency Packet requirements fbr NCS safety concerns were reviewed by representatives from limergency Management, Plant Shill Superintendent's Organization, Fire Services, and Nuclear Criticality Safety. The committee developed a standard format for communicating NCS safety concerns in emergency packets during an emergency situation. The format standardizes infonnation for emergency response personnel and makes the information " user friendly." The new lbrmat identifies building specific NCS safety concerns, the precautions to be taken, and alternate fire fighting measures.
til 2
. _. _. ~
- u. s. ; c.
"4'
- i
= Ill.' : Corrective Steps to be Taken 1
.tv
.c I
1)-
To provide an additional. measure of assurance that new/ updated information is
--included in eraergency packets, emergency packets will be managed in accordance with UE2-TO RM1031, " Document Control Program" or equivalent. 'Ihis action will e be completed by December 31,1997.
l 2)
' A procedure will be developed to document the management process for the use of
- emergency packets. The procedure will assign organizational responsibilities, provide
-guidelines for content and use, and provide instructions for how the document is
- controlled. This procedure is expected to be completed and implemented by February 27,1998-lIV.
Date of Full Compliance Full compliance with the specific circumstances of this NOV was achieved on August 27, -
-i
- 1997,-when the emergency packets were updated with the missing information previously -
misplaced.
3
'T B
+
J 4
4 4
El-3 '
a 4
I
+ -
---y
,m.,.
,.g..
.r f
UNITED STATES ENRICilMENT CORPORATION (USEC)
REPLV TO NOTICE OF VIOLATION (NOV) 70-7002/97206-05 Restatement of Violation SAR'5.2.2.3, Process Evaluation and Approval, states, in part, that "Each operation involving uranium... is evaluated for NCS prior to initiation. The operation and related NCS requirements are documented in Part A of a NCSA. The evaluation is documented in an NCSE... The NCS evaluation process invelves.. 3) development of the controls necessary to meet the double contingency principle, and 4) identification of the assumptions and equipment (i.e., physical controls) needed to ensure criticality safety."
NCSA PLANT 028 requires a 10-foot spacing between stored Planned Expeditious Handling (PEH) equipment.
Contrary to the above, as of July 25,1997, the technical basis for the 10-foot spacing between PEH equipment, an operation involving uranium, was not evaluated. Specifically, no documented NCS evaluation provided the basis for the assumption that the use of this physical control was sufficient to ensure criticality safety.
I, Reason for Violation The reason for the violation was due to a failure to follow procedure and the lack of management enforcement of the procedural requirements. Specifically, procedure XP4-EG-NS1001;" Nuclear Criticality Safety Evaluation and Approval" specifies requirements to
"... include the calculated K,y values necessary to ascertain sut;riticalky and the computer validation document shall be referenced, if applicable." Since the requirements were unclear, NCS management loosely interpreted the procedural requirement to permit the use of historical infomiation without justification or challenging the basis.
II.
Corrective Actions Taken and Results Achieved Calculations were completed on October 24,1997, to provide the required justification for the 10-foot spacing specified in NCSA PLANT 028.
III.
Corrective Steps to be Taken The NCS Organization will conduct a thorough assessment (i.e., vertical slice) of NCSAs/NCSEs for completeness and accuracy, proper procedural implementation, proper training of personnel on the NCS requirements. Additionally, this assessment will include a review of NCS administrative procedures to endure they comply with requirements and NCS E2-1
T. c,o
.=..-
- management expectations. The completion date of this assessment cannot yet be determined since the scope and magnitude of the assessment may increase if additionalproblems are -
discovered!
IVh. Date of Full Compliance -
Full compliance was achieved on October 24,1997, when the NCS calculations justifying the -
- 10; foot spacing criteria were completed.
'h E2 _
9 l
_________________________________________________________________L__,
UNITED STATES ENRICliMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/97206-06 Restatement of Violation TSR Section 3.11.5 requires, in part, that "In those instances where double contingency is not met, TSRs shall be established, implemented, and maintained..."
Contrary to 'he above, as of August 29,1997, Nuclear Criticality Safety Evaluations for Tails and Low Assay Withdrawal stations noted that these operations were singly contingent and no TSR had been established.
I.
Reasons for Violation The reason for the violation was a conceptual error regarding the relationship of the Withdrawal Station TSR to the Cascade TSR. Specifically, personnel viewed the Withdrawal Station TSR ar'd NCSE/NCSAs as subordinate to the Cascade and safely operated the withdrawal stations with the understanding that the Cascade TSR and NCSE/NCSAs were applicable. Thus, when the NCSE/NCSAs were reviewed and approved by management the concept of needing an additional TSR was not considered. This conceptua! error contributed to the issuance of an incomplete NCSE/NCSA for the Withdrawal Stations in November of 1996. Contributing to the violation was an inadequate procedure.
Specifically, the NCSE/NCSA implementing procedure XP4 EG-NS1001, Nuclear Criticality Safety Evaluation and Approval did not direct personnel to confirm the requirements of TSR 3.11.5 were met.
II.
Corrective Actions Taken and Results Achieved 1)
On August 4,1997, NCSE-0333_017.E01 was revised to reflect double contingency for the LAW Stations. The procedure requirements for implementation of the revised NCSA, did not change.
2)
On October 20,1997, NCSE-0330_007.E0I was revised to reflect double contingency forine Tails Withdrawal Station. The procedure requirements for implementation of the revised NCSA, did not change.
111.
Corrective Steps to be Taken hucedure XP4-EG-NS1001 will. be revised by November 30, 1997, to include the requirements of TSR 3.11.5.
E3-1
. ~..
- , c' it.;
- i.
IV. = - Date of Full Compliance -
! Full ~ compliance was achieved on October 20.1997, ivhen NCSE-0333_017.E01 and NCSE- -
0330_007.E01 were revised to accurately demonstrate double contingency for both the LAW :
- and Tails Withdrawal Stations.
s E3-2 :
6 I
UNITED STATES ENRICilMENT CORPORATION (USEC)
List of Commitments NOV 70-7002/97206-11 1)
To provide an additional measure of assurance that new/ updated information is included in emergency packets, emergency packets will be managed in accordance with UE2-TO-RM1031 " Document Control Program" or equivalent. This action will be completed by December 31,1997.
2)
A procedure will be developed to document the management process for the use of emergency packets. The procedure will assign organizational responsibilities, provide guidelines for content and use, and provide instructions for how the document is controlled. This procedure is expected to be completed and implemented by February 27,1998 NOV 70-7002/97206-05 The NCS Organization will conduct a thorough assessment (i.e., vertical slice) of NCS As/NCSEs for completeness and accuracy, proper procedural implementation, proper training of personnel on the NCS requirements. Additionally, this assessment will include a review of NCS administrative procedures to endure they comply with regulatory requirements and NCS management expectations.
This completion date of this assessment cannot yet be determined since the scope and magnitude of the assessment may increase if additional problems are discovered.
NOV 97206-06 Procedure XP4-EG-NS1001 will be revised by November 30,1997, to include the requirements of TSR 3.11.5 E4-1
.