ML20212H599

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Responds to Violations Noted in Insp Rept 70-7002/99-09. Corrective Actions:Engineering Evaluated Site Rail Track Insp Process for Improvement
ML20212H599
Person / Time
Site: Portsmouth Gaseous Diffusion Plant
Issue date: 09/27/1999
From: Jonathan Brown
UNITED STATES ENRICHMENT CORP. (USEC)
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
70-7002-99-09, GDP-99-2055, NUDOCS 9910010248
Download: ML20212H599 (5)


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September 27,1999 GDP 99-2055 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Portsmouth Gaseous Dihsion Plant (PORTS)

Docket No. 70-7002 Reply to Inspection Report (IR) 70-7002/99009 Notice of Violation (NOV) 99009-02 i

The subject IR contained a violation involving inadequate corrective actions taken to adu ss issues with the material condition of the railroad track and associated equipment. The United States Enrichment Corporation's response to this violation is provided in Enclosure 1. Enclosure 2 lists the.

commhments contained in this submittal. Unless specifically noted, the corrective actions specified J

in each enclosure apply solely to PORTS.

If you have any questions regarding this submittal, please contact Peter J. Miner at (740) 897-2710.

Sincerely,

. Morris Brown 1

General Manager Portsmouth Gaseous Diffusion Plant

Enclosures:

As Stated i

cc:

NRC Regional Administrator - Region III 1

NRC Resident Inspector - PORTS 9910010248 990927 PDR ADOCK 07007002 C

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United States Enrichment Corporation Portsmouth Gaseous Diffusion Plant P.O. Box 628 Piketon. OH 45661 L

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GDP 99-2055 l

Page1of3 UNITED STATES ENRICIIMENT CORPORATION (USEC)

REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/99009-02 Restatement of Violation Title 10 of the Code of Federal Regulations (CFR), Part 76.93, " Quality Assurance," requires, in part, that the Corporation shall establish, implement, and maintain a Quality Assurance Program.

Section 2.16, of the Quality Assurance Program " Corrective Action," requires, in part, that conditions adverse to quality shall be corrected as soon as practical.

Appendix A of Procedure XP4-BM-CIl002, " Problem Report Screening Process," def'mes a condition adverse to quality to include failures to perform activities described in the Safety Analysis Report and to execute processes or procedures.

Contrary to the above, between June 3,1998, and June 2,1999, the plant management did not correct a condition adverse to quality as soon as practical. Specifically, the plant management did not correct deficiencies identified with the inspection criteria, preventative maintenance program, and the condition of the rail cars, track, switches, and safety appliances, until two railcars carrying cylinders filled with liquid UF., an activity described in the Safety Analysis Report, derailed on June 2,1999.

USEC Response

Background

On May 20,1998, the Nuclear Safety Assurance (NSA) engineer, who was a member of the NSA assessment team for railcar safety, issued four problem reports (prs) to document findings identified during the assessment. Subsequently, on June 3,1998, NSA issued report NSA-X98-04, Nuclear Safety Assurance Assessment of Rail Car Safety.

Responses to the prs were submitted by Engineering in mid-June 1998, to address the report findings. The NSA engineer reviewed the PR responses and determined that three of the four report findings had not been properly addressed. Therefore, on June 26,1998, the NSA engineer issued three additional prs to ensure these findings identified in NSA-X98-04 would be re-addressed.

On August 27,1998, PR-PTS-98-06158 was written to document an empty rail car derailed in the middle of a rail switch south of Building X-343 when the rail cars were being moved into building X-343 for loading. A Corrective Action Plan (CAP) was written and approved for this PR in mid-October 1998, to address issues with the rail cars and rail track.

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GDP 99-2055 Page 2 of 3 On January 15,1999, Engineering closed the three additional prs issued for report NSA-X98-04 to the PR for the August 1998, derailment stating that the CAP for PR-PTS-98-06158 is addressing the findings in NSA-X98-04.

i The present status of the CAP for PR-PTS-98-06158 was recently reviewed with a focus on how the three additional prs issued for the findings in report NSA-X98-04 have been addressed. The results j

of this review showed that: 1) only two of three actions relating to the first additional PR would be adequately responded to by the CAP; 2) the one action relating to the second additional PR would be adequately responded to by the CAP; and 3) the third additional PR was not adequately responded to by the CAP.

On June 2,1999, PR-PTS-99-03092 was written to document the derailment of two railcars carrying six cylinders ofliquid UF.. A review of the CAP for this PR showed that one of the three actions relating to the first additional PR issued and the action relating to the third additional PR issued for the findings in report NSA-X98-04 will be adequately addressed upon successful completion of the CAP.

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Reason for Violation The reason for the violation was the PORTS management staff was not accountable for the

' quality of the corrective action process to ensure the prs were properly completed.

Responses to the initial four prs issued for the findings in report NSA-X98-04 were submitted as completed during the revisions PORTS was making to enhance the Corrective Action Program in mid-June 1998. These responses lacked quality based on the revised program requirements. The responses to two of the three additional prs issued were closed to an approved CAP of a different PR as allowed by the Corrective Action Program.

However, closing part of the first additional PR and the third additional PR to this different PR also lacked quality in that corrective actions to address the issue were not adequate. In closing the three additional prs to another PR, the PORTS staff did not question the timeliness of the scheduled corrective actions based on the risk significance of these issues in relation to the other sa ety significant issues the site was working to resolve.

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Corrective Actions Taken and Results Achieved 1.

Engineering evaluated the site rail track inspection process for improvement. This evaluation was completed and approved by March 29,1999, and determined that the current procedure and inspection process provides for a safe railway system for the movement of railcars carrying UF.. Therefore, no revisions to the site rail track inspection process was needed. (This action completed part of one action associated with the first additional PR issued for report NSA-X98-04).

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,2-H GDP 99-2055 Page 3 of 3 2.

On June 5,1999, a compensatory action was put into place to limit the movement of liquid UF. cylinders on railcars to only straight sections of reinforced concrete track beds.

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Corrective Actions to be Taken 1,

Engineering will evaluate the interplant rail car inspection process for improvement.

This will include a review of the periodicity, attributes, and specifications for the l

inspections and the inspection report review process. This action will be completed i

by October 29,1999.

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. PORTS will revise the interplant rail car inspection process using the recommendations issued by Engineering. This action will be completed by October 29,1999.

Note: Completing actions No. I and No. 2 stated above will resolve two of three actions relating to the first additional PR issued and will resolve the action relating to the second additional PR issued for report NSA-X98-04.

3.

Develop and issue a procedure that establishes an oversight process for the PORTS railroad system. This action will be completed by December 17,1999.

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Note: Completing this action will resolve the third action relating to the first additional PR issued and will resolve the action relating to the third additional PR issued for report NSA-X98-04.

4.

Issue lessons learned bulletin from PORTS General Manager to reemphasize the importance of properly completing all conditions adverse to quality issues. This action will be completed by October 22,1999.

5.

Perform a representative surveillance of recommendations, assessments, and reviews in selected PORTS organizations to determine if conclusions from these reports were adequately evaluated. This action is scheduled to be completed by October 15,1999.

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Date of Full Compliance Full compliance with the cited violation will be achieved by December 17,1999, when the L

last conective action to correct the deficiencies identified as conditions adverse to quality is scheduled for completion thus resolving and completing the three additional prs issued for i

report NSA-X98-04.

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GDP 99-2055 Page1ofI List of Commitments

  • 1.

. Engineering will evaluate the interplant rail car inspection process for improvement. This will include a review of the periodicity, attributes, and specifications for the inspections and the inspection report review process. This action will be completed by October 29,1999.

2.

PORTS will revise the interplant rail car inspection process using the recommendations issued by Engineering. This action will be completed by October 29,1999, t 3.

Develop and issue a procedure that establishes an oversight process for the PORTS railroad system. This action will be cc npleted by December 17,1999.

4.

Issue lessons leamed bulletin from PORTS General Manager to reemphasize the importance of properly completing all conditions adverse to quality issues. This action will be completed by October 22,1999.

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  • Regulatory commitments contained in this document are listed here. Laer 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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