ML20216G937
| ML20216G937 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 03/16/1998 |
| From: | Polston S UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-7001-97-14, GDP-98-0018, GDP-98-18, NUDOCS 9803200139 | |
| Download: ML20216G937 (6) | |
Text
i USEC A Globd Energy Company March 16,1998 GDP 98-0018 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Paducah Gaseous Diffusion Plant (PGDP)
Docket No. 70-7001 Response to Inspection Report (IR) 70-7001/97014 Notices of Violation (NOVs)
'Ihe 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 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.
l Any questUns regarding this matter should be directed to Larry Jackson at (502) 441-6796.
Sincerely, 1
ston General Manager Paducah Gaseous DifTusion Plant
Enclosures:
As Stated cc:
NRC Region III Office
'l NRC Resident Inspector-PGDP 9803200139 980316 lllllllllllllllllll PDR ADOCK 07007001
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P.O. Box 1410, Paducah, KY.2001 Telephone 502-441-5803 Fax 502-441-5801 http://www.usec.com Offices in Livermore, CA Paducah, KY Portsmouth, OH Washington, DC
GDP 98-0018 Page1of2 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 requims, in part, that moderation control be maintained when deposits of UO F (uranyl oxyfluoride) in a pipe or component listed in TSR 2.4, Appendix 22 A, are estimated to be greater than safe mass as determined by TSR 2.4, Appendix B, and the uranium assay is greater 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 pen:ent material.
Surveillance Requirement 2.4.4.4-1 requires, in part, that the certificatee verify that coolant pressure 4
is greater than the building RCW (recirculating cooling water) pressure each shift when a UO F 2 2 deposit greater than safe mass exists and the RCW is not drained.
Contrary to the above, on March 12,1997, the certificatee had data indicating the presence of a UO F deposit in the Process Gas Cooler for the Number 1 Dual Speed (DS) Purge and Evacuation 22 (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 1
1.
Reason for the Violation The reason for the violation was a lack of procedural requirement for performing an
- independent review of NDA 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 111 of this enclosure addresses the action to be taken to address this concern.
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GDP 98-0018 Page 2 of 2 II.
Corrective Actions Taken and Results Achieved 1.
The NDA group implemented independent reviews of NDA calculations on June 26, 1097.through a departmental memorandum.
2.
' A review was conducted of NDA calculations which occurred prior to the initiation
-3 ofindependent reviews. No other errors were discovered which would have caused j
an erroneous report of deposit classifications.
3.
The requirements of TSR 2.4.4.4 were met on January 16,1998, by draining the freon condenser of water.
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. 4.
Following discovery of the calculation error, the correct assay was incorporated into the calculation and the NDA group determined that a potentially greater than safe mass deposit existed in the C-335 #1 P&E cooler.
1 III.
Conective 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 Comoliggg USEC achieved full compliance on January 16,1998, when the requirements of TSR 2.4.4.4 were satisfied.
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GDP 98-0018 Page1of2 UNITED STATES ENRICHMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7001/97014-02 Restatement of Violation Technical Safety Requirement 3.11.2 requires, in part, that all operations involving uranium enriched to 1.0 weight percent or higher and 15 grams or mom 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 Pertent 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).
Contrary 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:
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 gallons was discovered in a Fissile Control Area in Building C-720.'
USEC Response 1.
Reason for Violation
'lhe 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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GDP 98-0018 l
Page 2 of 2 l
II.
' Corrective Actions Taken and Results Achieved j
1.
The laundry cart was removed from the FCA on November 25,1997.
2.
The vacuum cleaner was removed from the FCA.
l 3.
These incidents were discussed with the personnel that work in the afrected areas of C-720 and C-400.
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Corrective Actions to be Taken l
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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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Date of Full Comoliance 4
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Full compliance with the TSR was achieved when the laundry cart and the vacuum cleaner
. were removed from the FCA.
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GDP 98-0018 Page1ofI LIST OF COMMITMENTS 97014-01 1.
The requirement for conducting independent reviews of calculations associated with quantification ofdeposit mass related to TSR 2.4.4.4 requirements will be incorporated into the appropriate procedure (s) by April 30,1998.
2.
A procedtue will be developed and implemented to provide guidelines for improving actions to be taken for potential deposits by July 31,1998.
97014-02 f
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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