ML20216H721

Forwards Revised Response to NRC Re Violations Noted in Insp Rept 70-7001/97-02.Corrective Actions: Compensated Shift Turnover Time Period Was Expanded from 12 to 24 Minutes for Personnel to Meet Tsr Requirements

ML20216H721
Person / Time
Site:	Paducah Gaseous Diffusion Plant
Issue date:	09/08/1997
From:	Polston S UNITED STATES ENRICHMENT CORP. (USEC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
70-7001-97-02, 70-7001-97-2, GDP-97-1031, NUDOCS 9709170045
Download: ML20216H721 (30)

Text

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Unded states F.michrnent Corporeton 3

Padwah Site (Hke P.O. Ibn 1410 Padwnh, KY 42001 Tel 502 4415803 I a n. 502 441-5801 September 8,1997 U.S. Nuclear Regulatory Commission GDP 97-1031 ATTN: Document Control Desk Washington, D.C. 20555 Paducah Gascous Diffusion Plant (PGDP)

Docket No. 70-7001 Revised Response to inspection Report (IR) 70-7001/97002 Notices of Violation (NOVs)

Nuclear Regulatory Commission (NRC) letter dated May 30,1997, transmitted the subject IR that contained eight NOVs. United States Enrichment Corporation (USEC) responded to these violations on June 30,1997. USEC also submitted a supplemental response to NOV 97002-31

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on August 1,1997.

In a letter to USEC dated August 8,1997, NRC expressed concern with USEC's responses to seven of the eight violations (i.e., Enclosures 1,2,4,5,6, 7 and 8 of our original response), and requested that USEC submit a revised response to these violations. The attached enclosures provide a complete revision to our original response. Bars in the right margins denote changes made to the original. As indicated in Enclosure 7 to this letter, USEC will provide a supplemental response to NOV 97002-31 by September 23,1997.

If you have any questions regarding this submittal, please contact Bill Sykes at (502) 441-6796.

Sincerely, 01

./.

(n O <,/v Steve Polston General Manager

/

Paducah Gaseous Diffusion Plant SP:SRC: mig Enclosures (9) cc:

NRC Region Ill NRC Senior Resident Inspector,PGDP lill!!Ililll!lllllllilEllll!Ill 9709170045 970908

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PDR ADOCK 07007001 C

PDR I

ENCLOSURE 1 i

UNITED STATES ENRICilMEN T CORPORATION (USEC)

REPLY TO NOTICE OF VIOLATION (NOV) 70 7001/97002-01 Restatement of Violation Technical Safety Requirement 3.2.2.a. requires,in part, that minimum staffing requirements for each facility are as shown in Technical Safety Requirement Table 3.2.2-1.

Technical Safety Requirement Table 3.2.2 1 defines the minimum stalling requirements for Building C-360 during Mode 7 (sampling) operations as "At least one person in the laboratory.

One person in the facility or immedbtely surrounding grounds to include the guard station and the cylinder yard."

Procedure, OPS 11, Rev. 2, Change D, dated March 3,1997, " Shin Tumover," step 6.2, requires, in part, that "The shin operating personnel shall not leave their work area until they are satisfied that their reliefis fully aware ofexisting conditions."

Procedure, OPS-8, Rev. O, Change 0, dated March 3,1997, " Shill Routines and Operating Practices," step 5.4.1, requires, in part, that operators " Exhibit professional conduct and good

'vatch standing practices to assure proper attention to plant conditions."

Procedure CP2-TR-TR1030, Rev.1, Change A, dated February 28,1997, " Required Reading,"

i steps 6.4 and 6.7, require, in part, that: personnel review, initial, and date the immediate Required Reading file prior to performing tasks and/or duties to which the material applies by reading the material within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of assignment.

j Contrary to the above, on April 14,1997, between 0630 and 0700, only one operator was in the l

Building C-360 Laboratory, facility, or immediately surrounding grounds while the facility operated in Mode 7. Specifically, one of the two required Building C-360 operators (1) left the assigned work area without being relieved; (2) retumed to the assigned work area attired in personal clothing which precluded normal access and proper attention to plant conditions controlled from or displayed in portions of the routine work area; and (3) assumed watch-standing responsibilities without reviewing, initialing, or dating immediate required reading files, which included materials issued since March 3,1997, that applied to the normal tasks and duties of the Building 360 operator, l.

Reason for the Violation The reason for examples 1 and 2 of this violation was that shin tumover administrative controls I

and policies were incorrect with regard to the requirements as identified in TSR section 3.2.2.

l The operative procedure (OPS-11, section 6.7.1) permitted operators to utilize a period of time prior to shin tumover to shower and be prepared to conduct shift turnover when their relief E1-1

arrived. Management considered the shower to be a pad of the facility referred to in TSR Table l

3.2.2 1 and had reasoned that an operator in the shower could respond to alarm conditions in I

roughly the same time as an operator that was remotely located in the facility work area as described in the TSR. Also, it was detennined that operators could respond to alarm conditions in personal clothes even if this required entrance into a Contamination Control Zone (CCZ).

These assumptions and the TSR training provided were not sufficiently conservative and failed to meet the intent of the requirements as described in the TSRs or upgraded Operations and llealth Physics procedures.

The reason for example 3 of the violation was that appropriate barriers were not established to ensure that operators completed the required reading assignments prior to being assigned to the affected facility. At the time of the incident, the operator qualified to work in C-360 was normally assigned to building C-335 and kept up to date on his required reading through the required reading book in C-335. No requirements or controls were in place to ensure that personnel not normally assigned to C-360 were provided the same information to review, 11.

Corrective Actions Taken and Results Achieved

1. The compensated shin tumover time period was expanded from 12 minutes to 24 minutes for personnel to meet the TSR stalling requirements and operation's personnel l

were notified that shin tumover does not include shower time. This allows adequate l

time for shin tumover and for oncoming shin personnel to assume facility operational responsioilities. OPS 11 was modified to support the changes in shift tumover l

requirements.

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2. C-360 backup operators have been placed on the C-360 required reading list in their respective nonnally assigned facilities.

3. Required reading manuals were reviewed and revised as required to ensure Cascade and UF. llandling personnel were listed in the appropriate required reading manuals according to their qualifications.

4. The Cascade Training Review Group (TRG) has developed a methodology for

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implementation of training requirements relative to system modifications to provide j

further assurance that backup operators are trained.

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5. A root cause analysis was conducted which determined the primary reason for l

workforce unfamiliarity with TSRs was inadequate procedural development and a l

corrective action plan has been developed and added to the Commitment Management l

System to address the results of this analysis.

]

I Ill. Corrective Actions to be Taken l

l None l

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IV. Date of Full Compliance USEC achieved full complianca with examples 1 and 2 of the violation when the shift turnover policy was revised on April 25,1997. Full compliance with example 3 of the violation was achieved on May 30,1997, when the qualified operators were verified to be on the appropriate list (s). Here are no further corrective actions needed to prevent recurrence, I

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ENCLOSURE 2 UNITED STATES ENRICilh1ENT CORPORATION (USEC)

REPLY TO NOTICE OF VIOLATION (NOV) 70-7001/97002-02 Restatement of the Violation Technical Safety Requirement 3.2.2.b. requires, in part, that administrative procedures be implemented to limit the working hours of facility staff who perform safety functions such that an individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period.

Procedure CP2 IIR-LR1030," Limitations on llours of Work," step 6.3.4, requires, in part, that "a person shall not be permitted to work more than 16 consecutive hours, excluding shift tumover time, without preauthorized approval from the general manager or designee "

Contrary to the above, on March 5,1997, two instrument mechanics performing safety functions (work on criticality accident alamt cluster "V"in Building C-337 and the associated required documentation) worked more than 16 consecutive hours, excluding shift tumover time, without preauthorized approval from the general manager or designee.

1.

Backcround Information On February 5,1997, the General hianager issued a policy directive to the Organizational hianagers to implement the flours of Work Limitations (32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> in a 48-hour period,80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> j

in a 7-day period, and 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in a 24-hour period,16 continuous hours and retuming to work l

less than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after last work period) effective March 3,1997 through March 31,1997. These limitations would be complied with over the March 3 through 31,1997, period by policy directive until the limits were revised in accordance with the Compliance Plan. (The plant was operating under the assumption that the hours of work limitations would change on March 31, 1997.)

On Febmary 15,1997, procedure CP2-IIR-LR1030 rev. O, " Limitations on llours of Work," was signed, effective date March 31,1997. This procedure stated the hours of work limitations were the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48-hour period,72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7-day period, etc. These limitations were the limits to be imposed once the NRC reviewed and approved the TSR change request required by the Compliance Plan. The March 31 date was the Compliance Plan commitment date to submit a proposed change to the TSR imposing the more stringent overtime limits. As noted above, we mistakenly identified this date as the date needed for compliance with the new limits.

II.

Reason for the Violation The violation was caused by a management decision not to implement a procedure on March 3,

[

1997, but instead, to implement a policy directive that was inadequate in detail and process l

directions. This decision caused the implementation of the TSR requirement to be less than l

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adequate and led to the violation. Also contributing to this violation was the fact that managers I

did not have a system to help them track work hours on a real time basis.

l III. Corrective Actions Taken and Results Achieved i

1. On March 7,1997, Change A of procedure CP2-IIR LR1030,"Ilours of Work Limitations," was issued. This change included the 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in a 24-hour period,32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> in a 48-hour period and 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> in any 7-day period, etc. (This action pmvided a procedure to replace the inefTective policy.)

2. Guidance in the form of electronic mail was provided to managers / employees clarifying the procedure and time entry methods during March and April of 1997.

(This guidance communicated more clearly and reinforced the procedure.)

3. An Overtime Canvassing System (OCS) computer program has been placed into service to assist in compliance with TSR llours of Work Limitations.

4. Awareness sessions were conducted with managers on Hours of Work Limitations and the monitoring system (OCS) on March 17,1997 and March 26,1997.

5. A performance indicator has been initiated to track the plant's progress for TSR Hours of Work Limitations compliance.

6. USEC infomied each individual covered by the Hours of Work Limitations by letter on June 16,1997, of the TSR requirements and the problems that have been encountered.

7. Procedure CP2-IIR-LR1030 was revised on August 1,1997, to better define working I

periods, shift tumover, and provide adequate explanation on how to calculate hours of l

work.

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8. The Functional Organization Managers were informed of the root cause of this I

violation. They were also reminded that TSR requirements must be implemented by l

formal procedures, not memos or policies. This communication was completed on l

September 4,1997.

l IV. Corrective Actions to be Taken

1. The revised procedure (CP2-HR-LR1030) will be communicated by September 30, i

1997, thrcugh the use of plant-wide required reading and the use of the site newsletter.

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V.

Date of Full Compliance USEC achieved compliance with this violation when the affected individuals were relieved off shift on the day of the violation. There are no further corrective actions needed to prevent recurrence, k

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ENCLOSURE 3 UNITED STATES ENRICIIMENT CORPORATION (USEC)

REPLY TO NOTICE OF VIOLATION (NOV) 70-7001/97002-03 Rutatement of Violation Technical Safety Requirement 3.9.1 requires, in part, that written procedures shall be implemented to cover the activities described in Safety Analysb Report, Section 6.11.4.1 and listed in Safety Analysis Report, Section 6.11, Appendix A.

Safety Analysis Report, Section 6.11, Appendix A lists Operations activities (including alarm response) as activities requirir.g written procedures.

Alarm Response Procedure CP4-CO-AR8360-7,"Iligh Level Drain D101," Rev. 0, dated July 31,1995, step 9 requires, in part, that following actuation of the water inventory control system (drain level probes), operators may retum the autoclave to service "When...cause of alarm has been determined and corrected."

Contrary to the above, on April 9,1997, Building C 360 operators returned autoclave No. I to service, following actuations of the water inventory control system, without determining or correcting the cause of the alarm.

I.

Backcround Information On April 9,1997, at 2030, the C-360 No, I autoclave experienced a high drain alarm. The autoclave was 30 minutes into a heating cycle. The alarm condition cleared immediately after being received. Only one of the two installed condensate probes actuated.

The alarm response procedure, CP4-CO-AR8360-7, requires the cause of the alarm to be

(

determined and corrected before retuming the autoclave to service. The evaluation of the condition by the PSS and C-360 management determined that the autoclave isolation was the result of a spurious actuation of the water inventoiy control system.

Although, the personnel responsible for compliance with supplemental Step 9 in CP4 CO-AR8360-7 believed they had adequately established the cause of the system actuation as spurious, the C-360 No. I autoclave was retumed to service without fully investigating the cause ofprimary system actuation. Their review did not include an analysis of the chart recorder data or instrumentation and control troubleshooting to establish continuity data regarding the conclusion that a spurious incident did occur.

On April 10,1997, after extensive review of chart recorder information, Engineering personnel determined that the system actuation was not spurious. The review included an evaluation and analysis of autoclave process parameters which provided inferential information about the E34

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4t presence of condensate. The actuation was the result of high condensate conditions caused by initiating heating cycles simultaneously for Autoclaves I and 2. The details of this event are the subject of Event Report PAD 1997 07, 11.

Reason for the Violation The reason for the violation was that clear and explicit guidance did net exist regarding the depth and nature ofinvestigations required prior to the retum of a system to operation aner safety system actuation in that there was not a requirement for an appropriate management review prior to retuming the afTected equipment to service.

Ill. Corrective Actions Taken and Results Achieved

1. On April 10,1997, the PSS group adopted the requirement to involve Systems / Shin Engineering in subsequent safety system actuations in C-360.

2. Upon completion of the current heat cycle for Autoclave No.1, Instrument Maintenance perfomied the Water Inventory Control System (WICS) functional test and operability was restored on April 11,1997.

3. On April 17,1997, Shin Operations Long-Term Order (LTO) 300-97-003 was issued to implement the practice described in Action 1 above. Per this LTO, any future safety system actuations (not limited to those in C-360) should be investigated with the aid of the assigned Systems Engineer.

4. On August 8,1997, procedural guidance was issued which establishes management l

expectations and investigation methodologies to be employed prior to retuming l

equipment to service aner a safety system actuation.

l IV. Corrective Actions to be Taken None l

V.

Date of Full Comoliance USEC is currently in full compliance with the requirements of the TSR in that a procedure is in place to provide guidance to activities as described in the SAR. LTO 300-97-003 which clarifies the requirements of this process was issued on April 17,1997. There are no further corrective l

actions needed to prevent recurrence.

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I ENCLOSURE 4 UNITED STATES ENRICllMENT : 3RPORATION (USEC) j REPLY TO NOTICE OF VIOLATION (NOV) 70-7001/97002-04 l

)

Restatement of the Violation Technical Safety Requirement 2.2.4.3.a and Technical Safety Requirement 2.2.4.2.a require that criticality accident detection shall be operable in areas, equipment, or processes which contain greater than 700 grams of urarium-235 at an enrichment greater than or equal to 1.0 weight percent uranium 235.

Contrary to the above, on March 4,1997, Building C-337 criticality accident detection cluster "V"and on March 18,1997, Building C-337 A criticality accident cluster "N" were inoperable for areas which contained greater than 700 grams of uranium-235 at an enrichment greater than or equal to 1,0 wdght percent uranium 235, i"

1.

Backcrounilnfom1ation The Criticality Accident Alarm System (CAAS) at the PGDP is designed to detect gamma radiation levels that would result from the minimum criticality accident of concem and to wam plant personnel by activating evacuation alarms. The CA AS consists of clusters of three detector modules and one logie module. According to the Safety Analysis Report (SAR), Section 3.12.6, "The clusters consist of three detector modules which alann when a gamma dose-rate of 10 milliroentgen per hour (mR/hr) above background is detected." Each detector module has an intemally generated signal to maintain a constant operational check of the detection circuits.

Currently the background reading of the detector is initially adjusted to display a nominal 10 mR/hr on the front panel of the detector module. The alarm setpoint of each detector module is currently set at a nominal 20 mR/hr so that the detector module will go into alarm status ifit receives radiation of 10 mR/hr or greater above background. The fault setpoint of each detector module is currently set at a norr.inal 5 mR/hr so that the detector module will go into fault status ifth ickground reading drops significantly. A fault status is indicative of equipment problems and causes the CAAS to transmit a trouble signal to the central control room. Each detector module will detect radiation independently of each other. The cluster is designed to minimize the number of false audible evacuation alanns that plant personnel experience by applying the following logic to interpret detector module alarm status. To receive an audible CAAS alann, one of two conditions must exist: (1) at least two of the three detector modules must be in alarm status simultaneously; or (2) only one detector module is in alarm status while the ot!" r two detector modules are in fault status.

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On November 6,1996, under regulation of the Department of Energy, two CAAS detector modules in cluster "X" in the C-337 building were observed with low background readings of 9 mIWr. (Event Report PAD 1996-0058). While the actual background radiation level would be essentially zero, the CAAS indicating meter is set to indicate a background of 10 mlWr i0.5 mIWr. This means at an actual radiation field of 10 mR/hr, the meter will indicate 20 mR/hr 10.5 mIWr ' Die alarm is set to initiate at 10 mlWr above background. (10 mIWr background setpoint plus 10 mIWr radiation field equals 20 mIWr alarm setpoint nominal values.) A low background reading on a module could prevent the module from going into alarm status even though it has detected a 10 mR/hr increase in radiation. As stated above, in order to generate an audible alarm, the cluster logic requires either (a) two detectors to be in alarm status; or (b) one detector to be in alann status while the other two detector modules are in fault status. Therefore, simultaneous low background readings on two detector modules could prevent an audible alarm from being generated even though one or more modules has detected 10 mIWr radiation. For that reason, clusters are currently declared inoperable if two of the three detector modules have background readings below 9.5 mIWr.

As a result of the above event, Long Term Orders (LTO) were issued to establish weekly field monitoring of CAAS clusters to determine if the low background readings constitute a system problem. The LTO instructs operators that " modules with readings found below 9.5 mR/hr are to be promptly reported to the plant shin superintendent and a work order initiated for change out." On February 4,1997, another incident of two CAAS modules with low background readings occurred (Problem Report PR-CO-97-0556). A preliminary event report was submitted April 2,1997, to NRC. CAAS clusters "U" and "AK" located in the C-337 building were l

observed with the two modules reading 9.0 mR/hr. The clusters were declared inoperable and the Limiting Condition for Operation (LCO) action steps as defined by Operational Safety Requirements (OSR), KY/D-3971, Section 3.1.2.3 were implemented. The modules were replaced by Instrument Maintenance and clusters "U" and "AK" were declared operable on February 4 and 7, respectively.

On March 4,1997, during the weekly field monitoring of the CAAS clusters, cluster "V" in C-337 process building was found with two of the three modules displaying background readings below 9.5 mIWr. Detector Module Serial No. 580054 and Detector Module Serial No. 580105 were both reading below 9.5 mlWr. The cluster detector units are Model GCM-650 gamma criticality monitors, manufactured by Nuclear Research Corporation. Cluster "V" was declared inoperable. Since TSR Section 2.4.4.2a defines the LCO as " criticality accident detection shall be operable" and since cluster "V" does not have complete overlapping coverage from adjacent clusters, the LCO action steps as defimed by TSR Section 2.4.4.2 were implemented. Due to this "as found" inoperable condition, an event notification (# 31892) was made on March 4,1997, pursuant to 10CFR76120(c)(2)(1).

During the course of the investigation, another was observed with two modules exhibiting backgmund readings below 9.5mR/hr. On March I8,1997, at 1305, cluster" N" in C-337A building was observed by the NRC inspector with two detector modules reading below 9.5 mR/hr (Detector Module Serial No. 580133 and 580142). Cluster" N" was declared inoperable E4-2

and the LCO action steps as defined by TSR Section 2.4.4.2 were implemented. Due to this as-found inoperable condition, an event notification (#31968) was made on March I8,1997, pursuant to 10CFR76120 (c)(2)(1). The modules were replaced by Instrument Maintenance and cluster" N" was declared operable at 1710 on March 18,1997. The modules were returned to the Instrument Maintenance Shop for testing.

11.

Reason for the Violation The initial setpoint of 20 mR/hr was based on the " Operation and Maintenance Manual for the l

Paducah Gascous Diffusion Plant Radiation / Criticality Alarm System," dated November,1990, 1

Setpoint drin in the pre-set background setpoint of 10 mR/hr was 12 mIUhr. This setpoint driR l

resulted in module readings below 9.5 mlvhr. It is now apparent that when the setpoints were l

initially established, the instrument drin of 2 mR/hr ( 20 percent) was not factored in. The l

root cause for this inadequacy was that standards, policies, or administrative controls were not in I

place at the time the original setpoints were established; and as a result, a technical error was i

made in the setpoint established.

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111. Corrective Actions Taken and Results Achieved l.

On January 2,1997, Operations issued LTOs to perform weekly checks of the CAAS clusters to check for low background readings. Modules with readings found below 9.5 mlUhr were to be promptly reported to the plant shin superintendent and a work order issued for change out.

2.

On March 4,1997, Instrument Maintenance replaced two modules in cluster "V" and the cluster was returned to an operable status at 2330.

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3.

On March 7,1997, Instrument Maintenance returned three detector modules to the I

vendor for further diagnostic tests and evaluation.

4.

On March 18,1997, Instrument Maintenance replaced two modules in cluster"N" and the cluster was retumed to an operable status at 1710.

5.

On April 7,1997, Engineering completed an Engineering Evaluation to support a change in the CAAS detector module setpoints. The new values will be 10 :mR/hr for the alarm setpoint and 4 mR/hr for the background setting. The trouble alarm will be lowered to 2.5 mR/hr. Engineering also generated required documentation to support the associated procedure changes.

6.

A procedure has been generated to accomplish the setpoint changes, CP4-GP-IM6272TMP, Rev. 0," Criticality Accident Alarm System Set Point Change,"

effective July 2,1997.

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IV. Corrective Actions to be Taken By September 23,1997, Instrument Maintenance will complete changes on setpoints of all CAAS detector modulas as defined in the Engineering Evaluation for the CAAS setpoint.

- I Affected Instrument Maintenance procedures (for instmment calibration and maintenance) will l

be modified, as required, to incorporate the new setpoints.

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Additionally, by February 16,1998, the CAAS setpoints will be included as part of the Setpoint l

Control Program.

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V.

Date of Full Comnliance Full compliance with the specifics described in the NOV was achieved on March 18,1997, when l

the CAAS detector modules were retumed to service. The corrective actions to prevent l

recurrence will be completed by February 16,1998.

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ENCLOSURE 5 UNITED STATES ENRICIIMENT CORPORATION (USEC)

REPLY'id NOTICE OF VIOLATION (NOV) 70-7001/97002-13 Restatement of Violation Technical Safety Requirement 3.11.1 requires, in part, that a Criticality Safety Program be implemented as described in the Safety Analysis Report.

Safety Analysis Report, Section 5.2.2.6 states, in part, that: " Operations to which NCS [ nuclear criticality safety] pertains shall be govemed by written procedures. These procedures contain the appropriate NCS controls for processing, storing, and handling of fissile material."

Procedure, CP2-TS TS2030, Rev. O, dated December 10,1996, "lIANDLING AND STORAGE OF LEGACY PROCESS EQUIPMENT,"is a procedure for handling fissile material which implements the controls fbr the Criticality Safety Program for handling legacy equipment with ur known amounts of potentially fissile material.

Procedure CP2-TS-TS2030, step 8.2.1, requires, in part, that personnel: " mark / rope off equipment and tag with a Legacy Process Equipment Tag."

Contrary to the above, from March 3 through April 15,1997, legacy process equipment on the cell floor in Building 335 (compressors and a G-17 valve), was tagged with a Legacy Process Equipment Tag, identifying the equipment as containing unknown amounts of potentially fissile material, but had not been marked or roped off.

I.

Reason for Violation The reasons for the violation were:

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NCSA GEN-27 and its intent were not efTectively communicated through training to all those l

a.

individuals who handled the associated process equipment. Training was originally l

performed through required reading.

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b. Training was not implemented for all personnel who performed activities related to l

implementation of NCSA GEN-27.

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c. The requirements of NCS A GEN-27 were not effectively flowed down into the implementing l

procedure, CP2-TS-TS2030.

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d. The NCSA did not clearly specify posting / labeling requirements for storage of process l

equipment.

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11. Corrective Actions Taken and Results Achieved 1,

Due to inconsistencies and errors which were discovered in CP2-TS TS2030, the procedure was placed on administrative hold. Engineering Notice EN-C-832-97-016 was written to document the basis for the procedural hold, and a Functional Directive was issued to ensure that all alTected personnel were made aware of the procedural hold. This required the immediate suspension oflegacy process equipment handling.

2.

NCFA GEN-27 was revised to clarify posting requirements and NCSA applicability.

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3.

CP2-TS-TS2030 was subsequently revised and implemented to correct errors and I

inconsistencies with NCSA GEN-27. This action included appropriate training (crew l

brielings) to support the implementation of CP2-TS-TS2030.

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4.

An extensive site-wide walkdown with the intent to identify all legacy process gas i

equipment and to place it in a safe configuration awaiting disposition according to l

GEN-20 and GEN-27 was completed. The equipment was also properly tagged l

and/or labeled. This included placing 10 foot buffer zones, posted accordingly, I

around uncharacterized legacy equipment until characterization could be completed.

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S.

The Plant Operations Review Committee (PORC) now requests submittal of the l

NCSE/A and all implementing procedures as a package for PORC review and l

General Manager approval. This helps ensure the procedures effectively implement I

the NCSA requirements.

l 111.

Corrective Actions to be Taken 1.

Organization Training Review Groups will identify any tasks performed by plant I

personnel which are governed by NCSA requirements and complete or revise j

appropriate training analysis. This action will better define both NCS-related tasks I

and the groups that perform them. This action will be completed January 23,1998.

l IV. Date of Full Comnliance Full compliance was attained on June 27,1997, when the existing GEN-27 equipment at PGDP was posted and demarmted with ropes that provided a 10 foot buffer zone and I

sufficient number of crew briefings for the revised procedure CP2-TS-TS2030 had been I

performed. Actions to prevent recurrence will be completed by January 23,1998.

l ES-2

ENCLOSURE 6 UNITED STATES ENRICllMENT CORPORATION (USEC)

REPLY TO NOTICE OF VIOLATION (NOV) 70 7001/97002-19 Restatement of Violation 10 CFR 76.120(c)(2) requires that the certificatee notify the NRC Operations Center within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> aller the discovery of an event in which equipment is disabled or fails to function as designed when (1) the equipment is required by a Technical Safety Requirement to mitigate the consequences of an accident; (2) the equipment is required by a Technical Safety Requirement to be available and operable and either should have been operating or should have operated on demand; and (3) no redundant equipment is available and operable to perform the required safety function.

Technical Safety Requirement 2.4.4.5 requires that the fire protection sprinkler systems in process Buildings C-331, C-333, C-335, and C-337 be operable in modes Cascade I through Cascade 3, except when the lube oil is valved off or removed from the cells covered by a specific sprinkler system.

Contrary to the above, as of 0930, on March 13,1997, the certificatee had not notified the NRC Operations center 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> aller the discovery, on March 12 at 0930, of a disabled sprinkler system required to be operable by Technical Safety Requirement 2.4.4.5. Specifically, numerous cells within Building C-331 were operating in modes Cascade 1 through Cascade 3, and no redundant equipment providing an equivalent fire-mitigating safety function was available, when sprinkler system 33, between columns V-33 and W-33 of Building C-331, was declared inoperable. The Certificatee notified the NRC Operations Center on March 27,1997.

1.

Backcround Information On March 12,1997, at 0930, Fire Services identified a disconnected sprinkler system branch pipe in C-331. This section of system 33 pipe supplies water to sprinkler heads located inside ventilation ductwork and near the ceiling above the ductwork between columns V-33 and W-33.

The Plant Shifl Superintendent (PSS) declared the C-331 system 33 inoperable in the area with the disconnected pipe at 1021 and a fire patrol was initiated in this area at 1030. The PSS reviewed the Technical Safety Requirement (TSR) 2.4.4.5," Fire Protection System - Building

. Sprinkler System" basis that stated "As discussed in the S AR accident analysis (Sections 4.3.2.5.1 and 4.3.2.5.2), an unmitigated lube oil fire in the process lube oil pits or on the cell floor could cause failure of the structural steel followed by localized collapse of the structure.

This collapse could damage process piping allowing a release of UF.." The PSS also reviewed SAR Sections 4.3.2.5.1," Lube Oil Fires" and 4.3.2.5.2," Ventilation Duct Fires."

Based on his review, he determined that the event did not meet the reporting criteria of 10 CFR 76.120(c)(2)(I) because the TSR basis and the referenced SAR sections did not indicate that E6-1

l t

section of sprinkler system was required nor did it specify the extent of systems adjacent to tube oil sources that might be required. "... by a Technical Safety Requirement to prevent releases, prevent exposures to radiation and radioactive materials exceeding specified limits, mitigate the consequences of an accident, or restore this facility to a preestablished safe condition afler an accident;..."

On March 13,1997, a review of this event was completed by PSS, Engineering, and Nuclear Regulatuiy Affairs (NRA) personnel and again the conclusion was reached that the event was not reportable. This review was conducted before the 24-hour reporting period had expired.

During subsequent discussions among Engineering, NRA, and PSS personnel on the potential reportability of this issue, Engineering was requested by the PSS group to develop a position on the reportability of this event, in the interim, the decision was made to report any newly identified items of this type under 10 CFR 76.120(c)(2).

On March 27,1997 Engineering completed an Engineering Position on Reportability on this subject and stated that the as-found condition appeared to constitute a reportable condition under 10CFR76.120(c)(2). During this evaluation, the appropriate engineering basis for the sprinkler system was identified. This basis is that the sprinkler systems provide protection to building structural components by cooling the area, thus, preventing damage potentially resulting in the collapse of building structures and a release.

I.

Reasons for the Violation The violation occurred when the PSS, with the concurrence of NRA and Engineering, classified I

this event as not reportable, based on an incorrect conclusion that the equipment was still capable of mitigating the consequences of an accident as described in the SAR. This conclusion was based on insufTicient knowledge of the requirement that heads not directly adjacent to or associated with potential lube oil fire areas be operable in order to adequately protect the building structural members in the event of the HPFW sprinkler system actuation.

I I

The reason for the violation was that the engineering basis for the fire protection sprinkler j

system did not describe the effect ofinoperable individual sprinkler heads on system operability.

1 As a result, the PSS classified this event as not reportable, based on his determination that the l

equipment was still capable of mitigating the consequences of an accident as described in the l

SAR. This conclusion was based on insufficient knowledge of the requirement that heads not I

directly adjacent to or associated with potential lube oil fire areas be operable in order to I

adequately protect the building structural members in the event of the HPFW sprinkler system I

actuation.

I i

11. Corrective Actions Taken and Results Achieved 1.

A 10 CFR 76.120(c)(2) report on the subject event was filed with NRC on March 27, 1997.

E6 2

2.

The PSSs and Assistant PS9s were infonnally briefed to report any similar newly identified Sprinxier System Discrepancies per 10 CFR 76.1.20(c)(2) until an Engineering position on reportability was established. Since the briefing, no similar reporting problems have occurred.

3.

A crew briefing on this event with all PSSs, Assistant PSSs, and Cascade l

Coordinat ns was completed by July 8,1997.

l IV. Corrective Actions to be Taken 1.

Engineering will issue an engineering basis for which sprinkler systems are required I

to be operable under TSR 2.4.4.5 and TSR 2.3.4.8 by November 21,1997.

2.

Incorporate the engineering basis provided by Engineering and TSR sections 2.3.4.8 l

and 2.4.4.5 as well as SAR sections 4.3.2.5.1 and 4.3.2.5.2 into the lesson plan for the liigh Pressure Firewater System by February 27,1998, i

3.

Complete training on the revised lesson plan for all PSSs, Assistant PSSs, and l

Cascade Coordinators by May 29,1998.

V. Date of Full Comoliance Full compliance was achieved on March 27,1997, when the event was reported in accordance with 10 CFR 76.120(c)(2). The corrective actions to prevent recurrence will be completed by May 29,1998, 1

E6-3 a

ENCLOSURE 7 UNITED STATES ENIUCllMENT CORPORATION (USEC)

REPLY TO NOTICE OF VIOLATION (NOV) 70 7001/97002-31 Restatement of Violation 10 CFR 95.35(a) requires, in part, that no person subject to the regulations in this part may receive or may permit any individual to have access to matter revealing Confidential Restricted Data unless the individual has a "Q" or "L" access t.uthorization.

Contrary to the above, from March 3 through April 15,1997, the certificatee, a person subject to the regulations in Part 95, permitted individuals who did not have "Q" or "L" access authorizations to have access to drawings revealing Confidential Restricted Data.

1.

Backcround Information The issue addressed by this Notice of Violation involves USEC not taking the actions necessary to prevent individuals not having a "Q" or "L" access authorization from having access to drawings revealing Confidential Restricted Data (CRD). This CRD information was not marked or protected as classified, in some instances was marked as declassified, and was found in areas l

for which uncleared persons were allowed access. This CRD information was generated during two different times but its unmarked availability had similar root causes. The matter in both instances had apparently not received a proper classification review. A contributing cause to l

this issue was that in one case the information on which the drawing was based was also not marked as being classified.

This issue is similar to other issues addressed in various PGDP Problem Reports where information that should heve been classified has been found not marked as classified. This issue was identified prior to transitice to NRC oversight and was included as a Noncompliance in the

" Plan for Achieving Compliance with NRC Regulations at the Paducah Gaseous Diffusion Plant,

" DOE /ORO-2026/R3 (Compliance Plan)." That Noncompliance was cited as follows, in part, "Some legacy documents have been identified which may not have received a proper classification review and may have been improperly marked with respect to classification." This issue is being treated as part ofIssue 26," Records Management and Document Control Program," in " Description ofNoncompliance" paragraph 1.(b)," Legacy Records." Due to an apparent oversight, a corrective action plan was not proposed for this legacy issue.

E7-1

II. Reasons for the ViolatioJ1 The reasons for this violation were:

1.

A document originated in the early 1950s was apparently generated prior to the cunent procedures for Authorized Derivative Classification and never received a classification review.

2.

He originator of a drawing failed to follow current procedures and obtain an Authorized Derivative Classification review of his drawing prior to distribution. His was due to a mistaken belief that the document would not be classified since the drawing on which it was based had not been classified.

Ill. Corrective Actions Taken and Results Achieved 1.

He subject events were reported to NRC and were documented as PAD-1997-018 and PAD 1997-023, dated April 14 and April 17,1997, respectively.

2.

An investigation was conducted to determine whether other copies of the drawings cited might exist in areas accessible by uncleared individuals. Some additional.

copies were located and sanitized of the classified information,i.e., the classifidd information was removed from the drawing, the drawings were destroyed, or were protected in a classified vault. This was completed on June 13,1997, 3.

Employees were notified on June 20,1997 through Functional Organizations and the l

l Site newspaper,Inside P, that all uncleared individuals were to be denied access of I

clectronically generated documents as well as hard copies of documents, until their work area could be reviewed by an Authorized Derivative Classifier and sanitized as required.

4.

A plant bulletin, Site and Facilities Support Memo No. 97-16, was issued that stated l

the policy / procedures associated with the requirements for Authorized Derivative l

Classification review of documents. This was completed on July 31,1997.

l 5.

Functional Organization Managers each reviewed the current procedural l

requirements for document classification to ensure they understood their i

responsibilities regarding document classification. The intent was to ensure that l

management was aware of their classified information responsibilities such that they l

may assure documents generated by their respective functional organizations are j

appropriately documented, classified, and protected. This was completed on July 31, l

1997.

I E7-2

6.

A procedure was developed for uncleared personnel access, CP2-SS SE1051, l

" Development of Security Plans for Uncleared Individuals," stating no uncleared l

personnel will be permitted access to the PGDP Controlled Access Area without i

receiving Security approval as described in the procedure. This is intended to prevent I

access to Classified Matter while uncleared. This procedure was implemented on l

July 31,1997.

l IV. Corrective Steps to be Taken 1.

As documented in USEC letter GDP 97-1024 dated August 1,1997, USEC will i

institute periodic surveillances of the various ftmetional organization's areas of l

responsibility to assess the adequacy of their implementation of the requirements /

l guidance of Classified Matter controls. These surveillances will be performed using l

the guidance / requirements of procedure CP2-QA-QS1031," Conduct ofInternal l

Surveillances." These surveillances will be performed by the Site and Facilities l

Support organization and may include members of the organization being assessed.

l These surveillances will be scheduled such that each functional area will be assessed I

at least once every two years.

l l

2.

The initial surveillance will be completed by October 31,1997, and assess inclusion I

of the procedural requirements of CP2-SS-SE1042 into each functional organization.

l l

l 3,

The organizational assessments will begin within one month of completion of the 1

initial surveillance. Site and Facilities Support / Security Management will review l

implementation of these surveillances semiannually.

l

)

4.

A comprehensive action plan has been developed to evaluate the scope of the legacy l

issue regarding classified matter control as noted in the above background

[

information. This action plan was discussed with the NRC Senior Resident Inspector l

on Friday, August 22,1997. A summary of this action plan is addressed in VI below.

l The pilot evaluation, being conducted in the C-331 cascade facility, which began on l

August 26,1997, must be completed before a final end date can be estimated. A final

[

action plan will be developed for the plant and remaining facilities upon completion i

of the pilot. This final action plan will be provided in a supplemental response to this l

NOV by September 23,1997.

l E7-3

V. Date of Full Compliancs Full compliance with the specifics described in the NOV was achieved on June 13,1997, u hen the noted classified matter was sanitized, destroyed, or protected.

A supplemental response to this NOV will be provided by September 23,1997.

l VI. Action Plan l

l GOAL:

Take the action necessmy to prevent disclosure of classilled inatter to uncleared I

individuals at pODp.

l l

Team (s) me being established using representatives from Records Management / Document l

Control, Subject Matter Experts, and " owners" of the facilities being evaluated, to review or l

screen documents pertaining to gaseous difTusion plant technology. 'lhese documents will I

include design drawings, procedures (not in controlled manuals), training documents, computer i

discs, operator aids, memos, and wall mounted flow diagrams involving potentially classified l

matter throughout the property protection area, as well as the cont.olled access area. Any l

documents found to be marked as listed below will be handled as classified documents and I

stored and protected in accordance with procedure or turned in to Records l

Management / Document Control.

I l

Secret I

Confidential l

+

Oflicial Use Only l

+

Restricted l

Declassified l

l The teams will be trained to recognize potentially classified material. Examples of this material l

include the following:

l l

(1) Ollicial Use Only documents that were created between the dates of June 1947 and October l

1951; I

(2) Documents marked " Restricted" prior to 1954; l

(3) Documents marked " Secret" or " Confidential," yet not protected as such; l

(4) Documents marked " Declassified," that may have been declassified improperly; I

(5) Documents that are potentially classilled, yet have not been reviewed for classification and I

marked and protected accordingly. These types of documents include:

l l

(a) scientific, technological, or economic matters relating to the national security, I

information at our facility that has the potential for being classified, such as seals, I

barriers and operational data, detailed design of cascade operations; I

(b)

United States Govemment programs for safeguarding nuclear materials or facilities j

such as information that has the potential of being classified, such as security phms l

E7-4

and the designe of safeguards facilities; I

(c) vulnerabilities or capabilities of systems, installations, projects or plans relating to the l

national security, such statements showing vulnerabilities, response times, number of I

guards responding to certain incidents.

I l

Exceptions to this review will include:

l l

l (a) Work Packages do not require screening; l

I (b) Verification of classilled safes will be perfonned by Records Management and is not within l

l the scope of this efTort;

[

l (c) His verification does not involve reading or ADC review of unmarked documents; I

(d) !Ilstorical log books, video tapes, computer disks of unknewn content shall be tumed in to l

Ilecords Management, l

(e) Personnel records, publications, textbooks, commercially produced documents, magazines.

l l

l cte, do not require screening.

l l

Facility " owners" should identify infonnation they want to keep and discuss with the team. This 1

infonnation will be given to Records Management / Document Control to properly handle.

l I

The team will be briefed before starting each facility efTort. He procedure for conducting I

walkdowns will be utilized. Communication with the plant will also be made to ensure they are l

aware of this efTort and goal. Any drawings which show redlined or as built data shall be turned I

in to Records Management for processing to Engineering. Any previously classified safe which l

has been declassified will receive a review for documents using previously stated criteria.

l Any discrepancies shall be noted on a verification log and annotated whether the document was I

declassified or properly protected and stored.

l E7 5

ENCLOSURE 8 UNITED STATES ENRICllMENT CORPORATION (USEC)

REPLY TO No ilCE OF VIOLATION (NOV) 70 7001/97002 32 Restatement of the Violation 10 CFR 76.60(g) requires that the certificatec comply with the applicable provisions of 10 CFR Part 71.

10 CFR 71.5(a) requires,in part, that the certificatee shall comply with Department of Transportation requirements in 49 CFR 170 through 189 for shipments oflicensed material outside of the plant boundaries.

10 CFR 71.12 states that a general license is issued to any licensee to transport, or deliver to a carrier for transport, licensed material in a package for which a license, certificate ofcompliance, or other approval is issued by the NRC.10 CFR 71.12 requires that the licensee comply with the terms and conditions of the certificate.

49 CFR 173.420(a)(2)(1) requires, in part, uranium hexafiuoride must be offered for transportation in packages (cylinders) marked in accordance with American National Standards Institute (ANSI) Standard N14.1.

Condition 6 of Certificate of Compliance No. 6553, Revision 10, for the Paducah tiger overpack, required that each 48X cylinder be inspected, tested, maintained, assembled, and used in accordance with American National Standards Institute Standard N14.1 1990.

American National Standards Institute Standard N14.1-1990, Sections 6 requires, in part, that cylinder valve and plug threads are tinned with a thin uniform coating of ASTM B32 alloy 50A solder. Section 6 also requires that cylinder name plates are stamped with the cylinder tare weight in pounds.

Contrary to the above, from March 3 through April 21,1997, the certificatee delivered cylinders to carriers for transport, outside the plant boundaries, that were not assembled and maintained in accordance with American National Standards Institute Standard N14.1. Specifically, cylinder valve and plug threads were not tinned with ASTM D32 alloy 50A solder and revised tare weights, detennined during 5 year hydrostatic tests, were not stamped on the cylinder name plates.

E81

Example 1 1.

Ilackcround Infonnation The cited violation states that USEC was in noncompliance with ANSI N14.1 from hiarch 3 through April 21,1997. Ilowever, it is noteworthy that USEC did not identify this deficiency (i.e., that the tin content of the cylinder valves and plugs) until April 9,1997. Upon discovery of 1

l this event, USEC took immediate and prompt corrective actions to (1) stop shipment of the alTected cylinders; (2) report this to NRC (both veibally and written); (3) submit an application for revision to the Certificate of Compliance (CoC)(USEC letter GDP 97 0065 dated April 14, 1997);( 4) submit an application for revision to the Radioactive Material Packaging and Transportation Quality Assurance Program (PTQAP)(USEC letter GDP 97 006 dated April 15, 1997);( 5) and a request for an exemption from the applicable DOT Regulations I

All of these actions were described in more detail in our 10CFR71.95 report sent to the NRC on hiay 8,1997. This issue was selfidentified, had no safety consequences, and was resolved l

expeditiously and explained to the NRC in a prompt manner,

11. Reason for the Violation The violation was caused by inadequate implementation of the regulatory requirement as a result l

ofinattention to detail with regards to ANSI N14.1, Section 6.

l ANSI N14.1 1990 specifies that the tinning be done with ASTM B32,50A solder, llowever, the l

procurement specification required that the tinning be done with ASTM B32, Sn50, and the l

maintent nce procedure required a mixture of two parts ASTM B32, SOA (50/50 solder) to one l

part ASTM B32,40A (40/60 solder). Therefore, many of our UF. cylinder valves and plugs I

were being lubricated with material that did not meet the literal ANSI N14.1 1990 requirements.

I l

A contributing factor was that the 50A dioy is not listed in the ASTM B321983 standard. The l

50A alloy was listed in B32 1976, the edition prior to 1983. 'lhls means that since ANSI N14.1-l 1994 specifies both ASTM D321983 and the 50A solder,it was not literally possible to comply 1

with ANSI N14.1-1990.

I 111. Corrective Actions Taken and Results Achieved 1.

USEC requested and received, from both the NRC and the Department of Transportation (DOT), an amendment to the NRC Certificate of Compliance (CoC),

PTQAP, and an exemption to the DOT regulations to allow resumption of shipping.

E8 2

2.

Internal maintenance procedures pertaining to cylinder valve and cylinder plug l

{

tinning were reviewed and modified, as necessary, to include steps to test and verify I

that the tinning solder mixture meets the limits imposed by the CoC. These actions l

were completed by August 27,1997.

l IV. Corrective Steos to be Taken Nonc l

l V. Date of Full Comnliance Full compliance with the specifics described in this extuuple of the NOV was achieved on l

April 16,1997 when the DOT regulation was appropriately exempted and the PTQAP was revised. There are no further corrective actions required to prevent recurrence.

l Example 2 1.

Benson for the Violation l

The reason for the violation is that the ANSI Standard does not contain a clear requirement to update the tare weight on the cylinder nameplate as it changes during the life of the cylinder.

Many sections of the Standard actually lead the cylinder user to believe that the Standard did not intend that this value be changed aller it was originally stamped. For example, the Standard section which recommends that the cylinder tare weight be re established during the five year recenification, continues in the same paragraph to direct that the month and year of the hydrostatic test be stamped on the cylinder nameplate and other records of inspection and test be retained by the cylinder owner for a period of five years or until the next recertification. Additionally, the figure in the ANSI Standard showing the cylinder nameplate contains one and only one blank for tare weight and multiple blanks for hydrostatic test month and year.

The second cause of this violation was an inadequate review of the ANSI Standard by plant personnel. Iteviewers of the standard should have questioned the lack of clear guidance on this subject in the standard, knowing that tare weight values do change and are a key input to the cylinder fill process. This resulted from the fact that plant personnel do not use the nameplate markings on the cylinder for operational purposes. Instead the paper documentation that accompanies the cylinder is relied upon to ensure that cylinder fill limits are not exceeded.

E8 3

11. Corrective Actions Taken nnd Results Achieved 1.

A fonnat assessment of attematives for stamping re established tare weights on cylinder nameplates was conducted and technically feasibl: alternatives were identified. A long term corrective action plan was Ibnnulated which will accomplish the objective of stan ping re established tare weights on cylinder nameplates within a reasonable period of time, i

2.

The assessment included a detennination of whether not stamping re established tare weight values on cylinder nameplates has any immediate impact on the safe operation of the plant. The results of this assessment concluded that, even if the operator mistakenly used the original cylinder tare weight value stamped on the cylinder nameplate, conservatism in the cylinder fill limits tabulated in the ANSI Standard would prevent any cylinder from being tilled without providing the required 5 percent ullage allowance. The conservatism credited in the assessment is the fact that cylinder fill limits in the ANSI Standard are based on the density ofliquid UF. at 250*F. The gaseous diffusion plant uses a controlled steam pressure of 8 psig, equivalent to 235'F, during the feed process. This conservatism results in the actual weight limits used during cylinder fill being at least 390 pounds less than the weight limits corresponding to a density ofliquid UF. at 235"F. A random sampling of cylinder documentation revealed that worst case tare weight loss over cylinder lifetime is much less than 390 pounds, Based on this detennination, PGDP has concluded that it is safe to continue plant operations while administrative controls are revised to fonnalize what is currently standard practice, i.e., not using tare weight infonnation stamped on the cylinder nameplate during the cylinder fill process.

3.

The Plant General Manager issued a policy memorandum on June 30,1997, stating l

that a long-term plan has been initiated to commence stamping of cylinder l

nameplates with re-established tar: weight values.

l l

4.

On June 30,1997, the Operations Manager issued a Long Tenn Order directing l

Operations to continue to use the value of tare weight contained in the Nuclear l

Materials Controls and Accountability (NMC&A) documentation for the cylinder fill I

process and r.ot use the tare weight value stamped on the nameplate.

l S.

On July 31,1997, the cylinder fill procedures were updated to specify that tare I

weights used during the cylinder fill process shall be obtained from NMC&A l

documentation and not from the cylinder nameplate.

l E8-4

111. Corrective Actions to be Taken l

1.

Ily September 30,1997, a request will be submitted to the ANSI N14.1 l

Subcommittee asking that the Standard be changed to clearly require that re-l established tare weight values be stamped on cylinder nameplates.

l 1

2.

13y September 30,1997, all plant engineers will complete required reading on this l

Issue in order to emphasize the need to closely scrutinize all specifications, even industry standards, for circumstances not foreseen by the original authors of the specification.

l 3.

Ily October 15,1997, procedures will be updated and a work control process will be l

in place to begin stamping of re established cylinder tare weights on the cylinder nameplates (either the existing nameplate or a supplemental nameplate to be welded onto the cylinder) as each cylinder comes due for its periodic cleaning, inspection and hydrostatic test.

l l

IV. Date of Full Comnllance l

l llecause the ANSI Standard does not contain a clear ti iuirement to stamp re established tare l

weights on cylinder nameplates, USEC believes that there was no deviation from full compliance l

with the ANSI Standard on this issue. As stated above, USEC believes that the nature of this l

violation was the failure of plant personnel to question an unclear point in the ANSI Standard I

and to adopt a conservative interpretation of the issue until this point is clarified. As a result of I

the actions listed above, USEC believes full compliance will be achieved by October 15,1997, l

At this point, USEC will have requested a clarification to the ANSI Standard and will have l

implemented the more conservative interpretation of the Standard by stamping tare weights on l

cylinder nameplates whenever these values are re-established during the periodic cylinder l

recertification.

l l

Full resolution of this industry wide issue will take several more years to complete. USEC's I

ultimate goal for this issue is twofold: (1) to have an ASNI N14.1 Standard which states a clear l

requirement for marking re-established tare weights; and (2) to be able to implement a policy of l

not filling any cylinders unless the cylinder nameplate is mmked with the most recent tare l

weight value. Based on the fact that some cylinders will not be due for periodic meenification I

for five years, and because the ANSI Standard N14.1 Subcommittee will require the participation l

of the entire community of UF cylinder owners to fully consider this issue, achievement of the l

ultimate resolution of this issue will not occur until late 2002.

l l

1 E8 5

I ENCLOSURE 9 l

LIST OF COMMITMENTS None l

1. The revised procedure will be communicated by September 30,1997, through the use of l

plant-wide required reading and the use of the site newsletter.

None l

1. September 23,1997, Instrument Maintenance will complete changes on setpoints of all l

CAAS detector modules as defined in the Engineering Evaluation for the CAAS setpoint.

l

- AfTected Instrument Maintenance procedures (for instrument calibration and maintemmce) l will be modified, as required, to incorporate the new setpoints.

l

2. Additionally, by February 16,1998, the CAAS setpoints will be included as part of the l

Setpoint Control Program.

j

1. Training Review Groups will identify any tasks performed by plant personnel which are l

governed by NCSA requirements and complete or revise appropriate training analysis. This l

action will better define both NCS-related tasks and the groups that perfonn them. This l

action will be completed January 23,1998.

l

1. Engineering will issue an engineering basis for which sprinkler systems are required to be j

operable under TSR 2.4.4.5 and TSR 2.3.4.8 by November 21,1997.

2. Incorporate the engineering basis provided by Engineering and TSR sections 2.3.4.8 and 2.4.4.5 as well as SAR sections 4.3.2.5.1 and 4.3.2.5.2 into the lesson plan for the liigh Pressure Firewater System by February 27,1998.

3. Complete training on the revised lesson plan for all PSSs, Assistant PSSs, and Cascade Coordinators by May 29,1998.

E91

1. As documented in USEC letter GDp 971024 dated August 1,1997, USEC will institute l

periodic surveillances of the various functional organliation's areas of responsibility to I

assess the adequacy of their implementation of the requirements / guidance of Classified l

Matter controls. These surveillances will be perfonned using the guidanec/ requirements of l

procedure Cp2-QA-QS1031," Conduct ofIntemal Surveillances." These surveillances will I

be perfonned by the Site and Facilities Support organization and may include members of I

the organization being assessed. These surveillances will be scheduled such that each i

functional area will be assessed at least once every two years.

l l

2. The initial surveillance will be completed by October 31,1997 and assess inclusion of the l

procedural requirements of CP2 SS SE1042 into each functional organization.

l I

3. The organizational assessments will begin within one month ofcompletion of the initial l

surveillance. Site and Facilities Support / Security Management will review implementation l

of these surveillances semiannually.

l

4. A comprehensive action plan has been developed to evaluate the scope of the legacy issue i

regarding classified matter contml as noted in the above background information. This l

action plan was discussed with the NRC Senior Resident inspector on Friday, August 22, l

1997. A summary of this action plan is addressed in VI below. The pilot evaluation, being I

conducted in the C 331 cascade facility, which began on August 26,1997, must be l

completed before a final end date can be estimated. A final action plan will be developed for l

the plant and remaining facilities upon completion of the pilot. This final action plan will be l

l provided in a supplemental response to this NOV by September 23,1997.

I Example 1 None 1

Example 2

1. By September 30,1997, a request will be submitted to the ANSI N14.1 Subcon mittee asking l

that the Standard be changed to clearly require that re-established tare weight values be l

stamped on cylinder nameplates.

I I

2. By September 30,1997, all plant en;;ineers will compkte required reading on this issue in l

order to emphasize the need to closely scrutinize all specifications, even industry standards, for circumstances not foreseen by the original authors of the specification.

l l

3. By October 15,1997, procedures will be updated and a work control process will be in l

place to begin stamping of re established cylinder tare weights on the cylinder nameplates (either the existing nameplate or a supplemental nameplate to be welded onto the cylinder) as each cylinder comes due for its periodic cleaning, inspection and hydrostatic test.

E9-2 l

l j