ML20216C244
| ML20216C244 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 05/11/1998 |
| From: | Hiland P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | John Miller UNITED STATES ENRICHMENT CORP. (USEC) |
| References | |
| 70-7002-98-04, 70-7002-98-4, NUDOCS 9805190163 | |
| Download: ML20216C244 (1) | |
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May 11, 1998 Mr. J. H. Miller Vice President - Production United States Enrichment Corporation Two Democracy Center 6903 Rockledge Drive Bethesda, MD 20817
SUBJECT:
RESPONSE TO PORTSMOUTH INSPECTION REPORT 70-7002/98004
Dear Mr. Miller:
This refers to your April 27,1998, response to the Notice of Violation (NOV) transmitted to you by our letter dated March 27,1990, with inspection Report 70-7002/98004. 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. 70-7002 j
cc:
J. M. Brown, Portsmouth General Manager D. B. Waters, Acting Manager, Portsmouth Regulatory Affairs S. A. Polston, Paducah General Manager S. A. Toelle, Manager, Nuclear Regulatory Assurance and Policy, USEC Portsmouth Resident inspector Office Paducah Resident inspector Office R. M. DeVault, Regulatory Oversight Manager, DOE E. W. Gillespie, Portsmouth Site Manager, DOE bec w/itr did 04/27/98:
Docket File w/ encl PUBLIC IE-07 w/encI R. Pierson, MMSS w/ encl P. Ting, NMSS w/encI W. Schwink, NMSS w/enci P. Harich, NMSS w/ encl 1
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$NO~,nO F. Wenslawski, RIV/WCFO w/enci Greens w/o enci DOCUMENT NAME: G:\\SEC\\POR98004.RES Ta receive a copy of this document, Indicate in the box:"C" = Copy without enclosure *E" = Copy with enclosure"N" = No copy 0FFICE Rlli C,
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ESEC A Global Energy Company April 27,1998 GDP 98-2016 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington. D.C. 20555-0001 Portsmouth Gaseous Diffusion Plant (PORTS)
Docket No. 70-7002 Reply to Notice of Violation (NOV) 70-7002/98004-01 and 02 a,b,c,d The subject Inspection Report (IR) contained two violations: 1) Failure to stop work during an I&C Maintenance activity when procedural steps could not be adhered to, and 2) Failure to initiate problem re,mrts for safety, operating, and regulatory noncompliance issues to ensure corrective actions ere i. racked and implemented for the issues.
USEC's response to these violations is provided in Enclosures 1 & 2. Enclosure 3 lists the commitments made in this report. Unless specifically noted, the corrective actions specified in each enclosure apply solely to PORTS.
If you have any questions regarding this submittal, please contact Dave Waters at (740) 897-2710.
Sincerely, W
W
. Morris Brown General Manager Portsmouth Gaseous Diffusion Plant
Enclosures:
As Stated cc:
NRC Region III Office NRC Resident Inspector - PORTS P.O. Box 800, Portsmouth, OH 45661 Telephone 614-897-2255 Fax 614-897-2644 http://www.usec.com Offices in Livermore, CA Paducah, lW Portsmouth, OH Washington, DC MAY 012
i GDP 98-2016 Page 1 of 2 UNITED STATES ENRICHMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV),70-7002/98004-01 Restatement of Violation Technical Safety Requirement 3.9.1, requires, in part, that written procedures shall be implemented for activities described in Safety Analysis Report, Section 6.11.4.1, and listed in Appendix A, to Safety Analysis Report, Section 6.11 i
L Appendix A, to Safety Analysis Report, Section 6.11 requires, in part, that procedure management j
activities shall be covered by written procedures.
Procedun., UE2-PS-PS1034, "Use of Procedures," Revision 1, Change B, Section 6.2 requires, in t
part, ihat each procedure step in an In-Hand procedure is perfonned as written. If the activity cannot be performed as described, the following actions must be performed: stop the work activity; place the system in a safe condition; mark procedure step last performed; notify the appropriate manager l
for direction; and, if necessary, request or initiate procedure change or revision according to UE2-l PS-PS-1031.
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Contrary to the above, on March 5,1998, during the performance ofIn-Hand Procedure XP4-CU-l IM6100, "X-705 Test and Calibration of Calciners High-High Temperature Shutdown," the work l
group did not stop work when Section 8.3.12 of the Procedure XP4-CU-IM6100 could not be performed as written. Specifically, Section 8.3.12 of Procedure XP4-CU-IM6100 required the work group to verify the volt / ohm milliammeter indicated 80 to 120-volts AC. The volt / ohm-milliammeter indicated 124-volts AC during the completion of Section 8.3.12 of Procedure XP4-CU-IM6100, and the group did not stop work and continued to progress through the action steps of the procedure.
USEC Response I.
Reason for Violation l
The root cause for the violation is the First Line Manager (FLM) gave the Instrument &
Control (I&C) mechanics improper direction to continue the work. The same high voltage condition had been observed several times previous to this event. The reading obtained was assumed to be technically satisfactory because line voltage does vary widely throughout the plant. However, the assumption was not formally confimied by Engineering and procedure XP4-CU-IM6100 was not revised. A review of each of these individual's training records showed that each work group member received training in the use of procedures which should have prevented this situation.
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1 GDP 98-2016 Page 2 of 2 II.
Corrective Actions Taken and Results Achieved 1.
On March 5,1998, the FLM notified both the Maintenance Group Manager and System Engineer of the situation and both individuals instructed the FLM to stop work until procedure XP4-CU-IM6100 could be revised. The FLM stopped work. on the #1 calciner and the #1 calciner is currently out of service and will remain out of service until completion of the TSR required surveillance accomplished by XP4-CU-IM6100.
2.
A lessons learned was developed and presented to all maintenance personnel emphasizing management's expectations of the use ofin-hand procedures. These expectations were re-emphasized in our industry transition training classes which were presented to maintenance FLM's and craft personnel.
3.
The FLM was disciplined regarding the inappropriate direction given to continue proce.?are use with the out of spec reading.
III.
Corrective Steps to be Taken No further corrective actions are required.
IV.
Date of Full Compliance Full compliance was achieved on March 5,1998, when the work activity was stopped by the FLM.
GDP 98-2016 Page1of3 UNITED STATES ENRICIIMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/98004-02 a,b,c,d Restaterr ent of Violation Technical Safety Requirement 3.9.1, requires, in part, that written procedures shall be implemented for activities described in Safety Ana?ysis Report, Section 6.11.4.1.
bmion 6.11.4.1 of the Safety Analysis Report states, in part, that: "As a minimum, a procedure is required for any task that is described in, or implements a commitment that is described in, the
- Safety Analysis Report.."
Section 6.8.2.4 of the Safety Analysis Report," Problem Reporting," requires, in part, that: "All plant employees have the responsibility to write problem reports on safety, operating, and noncompliance items... Corrective actions are tracked through the plant's corrective action program."
Procedure UE2-HR-CIl030, " Problem Reporting," Revision 0, Change E, dated April 1,1996, Section 2.0, " Applicability," requires, in part, "That if there is any question as to whether or not to initiate a Problem Report (PR) for a given situation, a PR shall be initiated. Examples of problems include, but are not limited to violations of, or deviations from, programs, policies, and procedures or deficiencies which could cause safety, operability, or reportability concerns." Step 6.1.3.A requires that the problem report form be delivered to the Plant Shift Superintendent as soon as practical, but always prior to the end of the shift.
l Contrary to the above, from September 9,1997, through March 5,1998, the certificant did not initiate and deliver problem report forms to the plant shift superintendent by the end of the shift for the following examples of problems (Violations of, or deviations from, programs, policies, and procedures or deficiencies which could cause safety, operability, or reportability concerns):
a.
Plant staff did not initiate problem reports for deviations of the required quarterly face velocity measurement tests for laboratory fume hoods utilized for various operations in the Building X-710 Laboratory upon initial discovery. Problem reports were filed after questions were raised by the MRC inspections.
b.
A transportation violation was identified on September 9,1997, by a Paducah transportation specialist rei..rding a shipment of cylinders with residual uranium hexafluoride originating form the Portsmouth Gaseous Diffusion Plant. Portsmouth Packaging and Transportation staff were notified of the non-compliance and were faxed information regarding the transportation violation.
l GDP 98-2016 Page 2 of 3 A transportation violation was identified on December 16,1997, by a Paducah c.
Transportation specialist receiving an " excepted package-empty packaging" shipment from the Portsmouth Gaseous Diffusion Plant.
Portsmouth Packaging and Transportation and Plant Shift Superintendent staff were notified of the non-compliance and were faxed information regarding the transportation violation.
d.
A transportation violation was identified on January 23, 1998, by a Paducah Transportation Specialist regarding a shipment of cylinders with residual uranium hexafluoride originating form the Portsmouth Gaseous Diffusion Plant. Portsmouth j
Packaging and Transportation staff were notified on the non-compliance and were faxed information regarding the transportation violation.
I.
Reasons for Violation Example (a)
The reason for Example (a) of the violation was the X-710 Laboratory staff thought the fume hoods were within the allowed testing frequency and did not submit prs since a conflict in the testing frequency between the Chemical Hygiene Plan and the SAR was not recognized.
The Chemical Hygiene Plan makes reference to completing surveillance testing within three months (quarterly) and the SAR describes an extension period which is within 123 days of the last date tested. Therefore, the fume hoods inadvertently exceeded their allowed testing frequency.
Examples (b,c,d)
The reason for Exampies (b,c,d) of the violation was procedures UE2-HR-CIl030 " Problem Reporting," and XP4-SF-SF-1110 "PSS Actions on Problem Reports, "does not contain specific guidance for reporting and processing dual site PR issues.
II.
Corrective Actions Taken and Results Achieved Example (a) 1.
The X-710 Laboratory walked down each fume hood location to verify the last completed test date. The X-710 Laboratory staff submitted prs on March 6,1998, for all fume hoods identified to be out of compliance with their allowed testing period. Concurrently, fume hoods found out of compliance with their allowed testing l
period were satisfactorily tested on March 6,1998, by Maintenance personnel.
GDP 98-2016 l
Page 3 of 3 2.
Group briefs and/or required reading were given to the X-710 Laboratory staff on surveillance frequency definition. Also, management's expectations included new directions for identifying a problem and writing prs associated with laboratory fume hoods.
Examples (b,c,d) 3.
PR-PTS-98-01589 was written on March 6,1998, to document the Paducah transportation concerns identified in the cited violation. These concerns of cylinders being incorrectly marked, incomplete evidence packages, and labels mistakenly transposed were corrected by Portsmouth. However, corrective actions were originally initiated within days of the Paducah PR being written. Prompt open discussions between the Portsmouth and Paducah Operations and Packaging and Transportation staffs quickly resolved these issues.
4.
Procedure XP4-SF-SF1110 "PSS Action on Problem Reports," has been revised to include a requirement to screen Paducah prs for applicability at Portsmouth and write a PR ifissues are identified. This action was completed on March 31,1998.
1 5.
The Paducah prs are transmitted electronically to every Organization Manager dail; i
for them to review any concems reported at Paducah for applicability to Portsmouth.
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Corrective Steps to be Taken Example (a) 1.
The Chemical Hygiene Plan allowed testing peiiod will be revised by April 30,1998.
This will make this plan consistent with the surveillance frequency definition in the SAR.
Examples (b,c,d) 2.
A procedure is currently being created to replace UE2-HR-CI1030 to provide additional guidance for writing a PR for issues applicable to Portsmouth as well as issues originating at Portsmouth. The procedure is scheduled to be completed by June 30,1998.
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GDP 98 2016 Page1of1 L
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Reply to Notice of Violation (NOV) 70-7002/98004-01 and 02 a,b,c,d List of Commitments NOV 98004-02 a.b.c.d 1.
The Chemical Hygiene Plan allowed testing period will be revised by April 30,1998. This will mal:e this plan consistent with surveillance frequency definition irdhe SAR.
2.-
A procedure is currently being created to replace UE2-HR-CIl030 to provide additional guidance for writing a PR for issues applicable to Portsmouth as well as issues originating at Portsmouth. The procedure is scheduled to be completed by June 30,1998.
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