ML20216B101

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7001/97-14

ML20216B101
Person / Time
Site:	07007001
Issue date:	04/06/1998
From:	Hiland P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	John Miller UNITED STATES ENRICHMENT CORP. (USEC)
References
70-7001-97-14, NUDOCS 9804130367
Download: ML20216B101 (1)

Text

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April 6,1998 Mr. J. H. Miller Vice President - Production United States Enrichment Corporation Two Democracy Center 6903 Rockledge Drive Bethesda, MD 20817

SUBJECT:

RESPONSE TO PADUCAH INSPECTION REPORT 70-7J01/97014

Dear Mr. Miller:

This refers to your March 16,1998, response to Notice of Violation (NOV) transmitted to you by our letter dated February 12,1998, with Paducah Inspection Report 70-7001/97014. We have reviewed your corrective actions and have no further questions at this time Your corrective actions will be examined during future inspections.

If you have any questions, please contact me at (630) 829-9603.

Sincerely, Original Signed by Patrick L. Hiland, Chief Fuel Cycle Branch Docket No. 70-7001 cc: S. A. Polston, 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 bec w/ltr did 03/16/98: Docket File w/enci PUBLIC IE-07 w/enci R. Pierson, NMSS w/enci P. Ting, NMSS w/enct W. Schwink, NMSS w/ encl P. Harich, NMSS w/ encl M. L. Hom, NMSS w/enct l R. Bellamy, RI w/enct EJM, Rll w/o enci (e-mail) k F. Wenslawski, RIV/WFCO w/encI

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G:\SEC\ PAD 97014.RES To receive a copy of this document. Indicate in the boa:"C" - Copy without enclosure 'E" = Copy with enclosure"N* = No copy OFFICE Rlli lC Rill lC NAME Kniceley:ib P19 L Hiland II.l W DATE 04/6/98 I 04/6/98 OFFICIAL RECORD COPY

[USEC A Clebal Energy Company l l

l March 16,1998 j GDP 98-0018 i

l U. S. Nuclear Regulatory Commission i

Attention: Document Control Desk Washington, D.C. 20555-0001 l Paducah Gaseous Diffusion Plant (PCDP)

Docket No. 70-7001 Response to Inspection Report (IR) 70-7001/97014 Notices of Violation (NOVs)

The Nuclear Regulatory Commission (NRC) letter dated February 12,1998, transmitted the subject  :

IR which contained three NOVs. As indicated in NRC's letter, USEC is not required to respond to i

one of the violations (i.e., NOV 97014-04). USEC's response to the remaining violations is provided in Enclosures 1 and 2. Enclosure 3 lists the commitments made in this report. Unless )

specifically noted, the corrective actions specified in each enclosure apply solely to PGDP.  ;

Any questions regarding this matter should be directed to Larry Jackson at (502) 441-6796.  !

Sincerely, E f w

Q ston General Manager

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Paducah Gaseous Diffusion Plant

Enclosures:

As Stated cc: NRC RegionIII Office NRC Resident inspector- PGDP P.O. Bor 1410, Paducah, KY 42001 Telephone 502 4415803 Fax 502-4415801 http://www.usec.com 00 ices in Uvermore, CA Paducah, KY lbnsmouth. OH Washington DC 20*d BCPL 2## 209 8344J0 dsuI quaptseH dODd V4C:60 86-90-adv j

Enclosure 1 GDP 98-0018 Page 1 of 2 UNITED STATES ENRICHMENT CORPORATION (USEC)

REPLY TO NOTICE OF VIOLATION (NOV) 70-7001/97014-01 Restatement of the Violation Technical Safety Requirement (TSR) 2.4.4.4 requires, in part, that moderation control be maintained when deposits of UO2 F,(uranyl oxyfluoride)in a pipe or component listed in TSR 2.4. Appendix A, are estimated to be greater than safe mass as determined by TSR 2.4 Appendix B, and the uranium assay is gnater than 1.0 weight percent. TSR 2.4, Appendix A, lists process gas coolers as applicable equipment. TSR 2.4, Appendix B, identifies 264 pounds as the safe mass limit for deposits of 2.0 weight percent material.

Surveillance Requirement 2.4.4.4-1 requires, in part, that the certificatee verify that coolant pressure is greater than the building RCW (re:irculating cooling water) pressure each shift when a UO2 F deposit greater than safe mass exists and the RCW is not drained.

Contrary to the above, on March 12,1997, the cettificatee had data indicating the presence of a UO 22F deposit in the Process Gas Cooler for the Number 1 Dual Speed (DS) Purge and Evacuation (P&E) Pump in Building C-335 (operating at up to 2.0 weight percent) which was over 600 pounds and exceeded the safe mass limit of 264 pounds, but did not verify that coolant pressure was greater than the building RCW pressure each shift while the RCW was not drained until January 15,1998.

On January 15,1998, the certificatee re-evaluated the mass of the deposit in the process gas cooler and determined that the deposit did exceed the safe mass for that location.

USEC Response I. Reason for the Violation The reason for the violation was a lack of procedural requirement for performing an independent review ofNDA deposit mass calculations.

Additionally, during the course of our investigation into the circumstances that led to this violation, USEC discovered a need to improve procedural guidance regarding actions to be taken when the potential for a deposit exists.Section III of this enclosure addresses the action to be taken to address this concern.

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Enclosure i GDP 98-0018 Page 2 of 2 j 1

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11. Corrective Actions Taken and Results Achieved l

1. 'The NDA group implemented independent reviews of NDA calculations on June 26, 1997 through a departmental memorandum.

2. A review was conducted of NDA calculations which occurred prior to the initiation ofindependent teviews. No other errors were discovered which would has y caused l

an erroneous report of deposit classifications. i

3. The requirements of TSR 2.4.4.4 were met on January 16.1998. by draining the freon condenser of water.

4. Following discovery of the calculation error, the correct assay was incorporated into the calculation and the NDA group detennined that a potentially greater than safe mass deposit existed in the C-335 #1 P&E cooler.

III. Corrective Actions to be Taken

1. 'The requirement for conducting independent reviews of calculations associated with quantification of deposit mass related to TSR 2.4.4.4 requirements will be incorporated into the appropriate procedure (s) by April 30,1998.

2. A procedure will be developed and implemented to provide guidelines for improving actions to be taken for potential deposits by July 31,1998.

IV. Date of Full Comoliance USEC achieved full compliance on January 16,1998, when the requirements of TSR 2.4.4.4 were satisfied.

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Enclosure 2  ;

i GDP 98-0018 Page I of 2 UNITED STATES ENRICHMENT CORPORATION (USEC)

REPLY TO NOTICE OF VIOLATION (NOV) 70-7001/97014-02 I

Restatement of Violation Technical Safety Requirement 3.11.2 requires, in part, that all operations imotving uranium enriched to 1.0 weight percent or higher and 15 grams or more of uranium-235 be performed in accordance with a documented nuclear criticality safety approval. )

Control 18 of Nuclear Criticality Safety Approval GEN-15, "On-Site Generation. Handling, Accumulation, Staging, Transportation, and Storage of Fissile or Potentially Fissile Waste up to a  ;

Maximum of 5.5 Weight Percent Enrichment," approved September 12,1996, requires that portable  !

containers used within an FCA [ Fissile Control Area) shall be limited a maximum size 5.5 gallon  !

capacity unless approved otherwise by NCS [ Nuclear Criticality Safety).

Comrary to the above, portable containers with capacities greater than 5.5 gallons were used within ,

Fissile Control Areas and not approved by Nuclear Criticality Safety in the following examples; l a) On November 25,1997, a portable laundry cart which had a capacity greater than 5.5 gallons was discovered in a Fissile Control Area in Building C-400; and  ;

B) On December 1,1997, a portable vacuum cleaner which had a capacity greater than 5.5 l gallons was discovered in a Fissile Control Area in Building C-720.

USEC Response

1. Pawi for Violation

'Ihe reason for the violation was that the training material (lesson plans) used to train fissile workers was inadequate. ' The training material did not address what could constitute a portable container which might be capable of having a capacity greater than 5.5 gallons. The material also did not alert the. workers that when these items are brought into an FCA they could violate the NCSA.

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Enclosure 2 ~

GDP 98-0018 Page 2 of 2 II. Corrective Actions Taken and Pa< nits Achieved

1. The laundry cart was removed from the FCA on November 25,1997.

2. The vacuum cleaner was removed from the FCA.

3. These incidents were discussed with the personnel that work in the affected areas of C-720 and C-400.

'III. Corrective Actions to be Taken

1. Crew briefings will be given to the appropriate Maintenance Operations, and Production Support personnel by April 8,1998.

2. The contents of the briefing material will be flowed down into the appropriate training medules by May 1,1998.

IV. Date of Full Camnlimace

- Full compliance with the TSR was achieved when the laundry cart and the vacuum cleaner were removed from the FCA.

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Enclosure 3 GDP 98-0018 Page1ofI LIST OF COMMITMENTS 97014-01

1. The requirement for conducting independer.t reviews of calculations associated with quantification of deposit mass related to TSR 2.4.4.4 requirements will be incorporated into the appropriate procedure (s) by April 30,1998.

2. A procedure will be developed and implemented to provide guidelines for improving actions to be taken for potential deposits by July 31,1998, 97014 '1. ~ Crew briefings will be given to the appropriate Maintenance, Operations, and Production Support personnel by April 8,1998,

2. The contents of the briefing material will be flowed down into the appropriate training modules by May 1,1998.

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