ML20217A801
| ML20217A801 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 04/17/1998 |
| From: | John Miller UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Lieberman J NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| 70-7002-97-13, EA-98-012, EA-98-12, GDP-98-0076, GDP-98-76, NUDOCS 9804220335 | |
| Download: ML20217A801 (26) | |
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%/USEC A Global Energy Company JAMES H. MILLER Dir: (301) 564-3309 VICE PRESIDENT, PRODUCTION Fax: (301) 571-8279 Lir CA April 17,1998 GDP 98-0076 M'j, Po I
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Mr. James Liebermann Director, Office of Enforcement bbI United States Nuclear Regulatory Commission Washington, D.C. 20555-0001 p1 g
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t Portsmouth Gaseous Diffusion Plant (PORTS)
Docket No. 70-7002 Reply to Notice of Violation (NOV) 70-7002/97013 (EA 98-012)
Dear Mr. Lieberman:
The Nuclear Regulatory Commission (NRC) letter dated March 19,1998, transmitted the subject NOV which was categorized as Severity Level III and was the subject of a predecisional enforcement conference held on February 19,1998. This NOV concerned 16 examples (i.e., "A" through "P")
of deficiencies in the Nuclear Criticality Safety (NCS) program at PORTS. The United States Enrichment Corporation's (USEC's) reply to this NOV is provided in Enclosures 1 through 11, respectively (Note: USEC has combined the responses to examples "B" and "C" and "L" through "P" since they have similar root causes and corrective actions). The corrective actions specified in each enclosure apply solely to PORTS. Enclosure 12 lists the commitments contained in this submittal.
USEC does not contest the violations and examples thereof. Therefore, as directed by your March 19,1998 letter, Enclosure 13 is a check in the amount of $55,000 in payment of the civil penalty associated with this violation.
As noted at the predecisional enforcement conference, USEC takes seriously the events that have led up to this violation. We are clearly not satisfied with our perfomlance in the NCS area at PORTS. We have implemented an extensive Corrective Action Plan (CAP) intended to improve the effectiveness of the PORTS NCS program. This NCS CAP was initially submitted to NRC on November 10,1997, and subsequent updates were submitted to NRC on December 22,1997, and January 30,1998 (reference USEC letters GDP 97-2030, GDP 97-0217, and GDP 98-0013). \\ \\
Additionally, USEC has committed to provide NRC with quarterly status reports to this NCS CAP.
We are currently evaluating this CAP to determine if additional actions are required as a result of 6903 Rocidedge Drive, Bethesda, MD 20817-1818
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Telephone 30J-564-3200 Fax 301-564-3201 http://www.usec.com
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9804220335 980417 ucah. KY Portsmouth, OH Washington, DC PDR ADOCK 07007002 C
Director, Office of Enforcement April 17,1998 GDP 98-0076, Page 2 the deficiencies addressed in this violation. If additional actions are required, they will be reflected in the quarterly status report to the NCS CAP.
Ifyou have any questions regarding this submittal, please contact Ron Gaston at (614) 897-2710.
Sincerely, g
S. A.
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J. H. Miller Vice President - Production
Enclosures:
1-11) USEC's Reply to NOV 97013
- 12) List of Commitments
- 13) USEC Check No.15613 cc:
NRC Region III Administrator NRC Senior Resident inspector - PGDP Document Control Desk NRC Special Projects 13 ranch i
i GDP 98-0076 Page1of2 UNITED STATES ENRICIIMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/97013-A Restatement of Violation Technical Safety Requirement Section 3.11.2 requires, in part, that all operations involving uranium enriched to 1.0 wt% or higher of U-235 and 15 grams or more of U-235 shall be based upon a documented nuclear criticality safety evaluation and shall be performed in accordance with a documented nuclear criticality safety approval (NCSA).
NCSAs-0330-004.A00 and A01, Cascade Operation in the X-330 Building," dated October 21,1996 and October 24,1997, requires in part, that to ensure introduction of water into the uranium enrichment cascade does not occur, the following two controls shall be implemented and maintained:
Control A, Administrative Controls 7 (A00) and 8 (A01), require,in part, that protection from RCW (re-circulating cooling water) leakage into the Cascade shall be assured by maintaining the coolant pressure above both the UF [ uranium hexafluoride] and RCW pressures.
6 Control B, Administrative Controls 9 (A00) and 10 (A01), require, in part, that when a cell is shut down and the R-114 (Freon) removed from a cell, the RCW supply to the affected cell shall be valved off, the condenser drained and drain valve left open. The RCW shall remain valved off until the R-114 is returned to the system.
Contrary to the above, between March 3,1997, and November 4,1997, criticality controls A and B were not maintained for Cell 29-5-8 located in Building X-330. Specifically, the Freon coolant system pressure was not maintained greater than the UF system and RCW system pressures and the 6
condenser drain valve was not maintained open. (01013)
USEC Response I.
Reasons for Violation The reasons for this violation were:
1.
The NCSA Part C contingency matrix was flawed in that: 1) the Part C matrix did not accurately reflect the evaluation [i.e., the Nuclear Criticality Safety Evaluation (NCSE)]; and 2) it was not possible to achieve verbatim compliance with contingency controls for a shutdown cell (e.g., it was not clear from reviewing the NCSE as to which contingency analysis applied). Additionally, it was not possible to comply with the Part C contingency matrix in the NCSA, in that the coolant i
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GDP 98-0076 l
Page 2 of 2 pressure could not be maintained above the UF and RCW pressure for a shutdown cell.
2.
The NCSA implementation process was inadequate. When the NCSA was initially j
developed in October 1996, it did not assure that cells shutdown under previous controls would be in compliance with the new controls in the NCSA.
II.
Corrective Actions Taken and Results Achieved i
1.
The RCW drain valve for cell 29-5-8 was opened on November 4,1997 and the coolant system in cell 29-5-8 was pressurized with dry air to greater than the RCW j
pressure on November 17,1997.
2.
All other condensers in a shutdown condition were inspected and, if the condenser drain valve was found closed, the drain valve was opened.
4 3.
The NCS procedure was modified to include implementation requirement to review l
potential pre-existing conditions.
4.
This particular NCSA was revised under the new NCS process, outlined in the NCS Corrective Action Program (CAP) to assure that reasonable, understandable controls are in effect and properly flowed down and implemented.
j Ill.
Corrective Steps to be Taken All NCSAs are undergoing an upgrade in accordance with Task 3 of the NCS CAP l
(reference USEC letter GDP 98-0053 dated March 20,1998). This effort will, among other things, eliminate confusing or erroneous controls.
IV.
Date of Full Compliance USEC achieved full compliance on November 17,1997, when the coolant system was j
pressurized to greater than the RCW pressure.
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v GDP 98-0076 Page1of3 UNITED STATES ENRICHMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/97013-B AND C Restatement of Violation B.
Technical Safety Requirement 3.11.1 requires, in part, that the nuclear criticality safety program shall be established, implemented, and maintained as described in the Safety Analysis Report. Section 5.2.2.2 of the Safety Analysis Report entitled " Nuclear Criticality Safety Responsibilities," requires, in part, that Managers ensure all appropriate personnel receive nuclear criticality safety training as specified in the plant procedures.
Plant procedure XP4-EG-NSI102, " Nuclear Criticality Safety Personnel Qualification,"
Revision 1, dated May 1,1997, requires contractor personnel to complete training equivalent to qualified nuclear criticality safety walk-through team members, engineers and senior engineers.
Contrary to the above, as of December 11,1997, four nuclear criticality safety contractors
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did not receive criticality safety training as specified in plant Procedure XP4-EG-NS1102.
i Specifically, no documentation existed to determine if the minimum nuclear criticality safety qualifications specified in this procedure were met. (010023)
C.
Technical Safety Requirement 3.11.1 requires, in part, that the nuclear criticality safety program shall be established, implemented, and maintained as described in the Safety Analysis Report. Section 5.2.2.3 of the Safety Analysis Repo:t entitled " Nuclear Criticality Safety - Process Evaluation and Approval," requires, in part, that the minimum requirements for a qualified nuclear criticality safety engineer include the performance of at least four evaluations under the direction of a senior nuclear criticality safety engineer.
Contrary to the above, between March 3,1997, and December 11, 1997, three of the
" qualified," permanent nuclear criticality safety engineers did not perform at least four evaluations under the direction of a senior nuclear criticality safety engineer before being qualified as a nuclear criticality safety engineer. (01033)
USEC Response I.
Reasons for Violation The reason for violation "B" was failure to follow procedure XP4 EG-NSI 102. Specifically, the NCS manager did not ensure contractor personnel were properly qualified and qualification documentation was complete prior to assigning work. In addition, the NCS Manager did not understand that the entire procedure was intended to apply to contractors.
- 1.
GDP 98-0076 l
Page 2 of 3 The reason for violation "C" was an ineffective corrective action. Specifically, Problem i
Report (PR) 97-06093, dated August 2,1997, documented the failure to properly flowdown the requirement of SAR Section 5.2.2.3 into procedure XP4-EG-NSI102. However, the corrective action did not include a thorough evaluation of whether the NCS permanent Engineers met the SAR qualification requirements and updated qualification cards were not l
processed for those Engineers.
II.
Corrective Actions Taken and Results Achieved i
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As'of March 4,1998, all NCS contracted engineers have been trained and their qualification records corrected consistent with approved pmcedure XP4-EG-NS-1102. In addition, the NCS Manager and contractor rescentatives have been instructed that documentation of contractor qualifications must be reviewed and filed and the requirements of procedure XP4-EG-NS-1102 met prior to assigning contractor personnel to NCS activities.
j 2.
The review of NCS Engineer's qualifications in accordance with Task 2 of the NCS CAP identified NCS permanent Engineers who had not met all of the qualification i
requirements. On December 11, 1997, these Engineers were restricted from conducting further NCS evaluations until their qualifications were properly completed. Qualification cards were completed by April 15,1998, for the permanent Nuclear Criticality Safety Engineers in accordance with approved procedure XP4-(
EG-NS I102.
3.
The review ofNCS evaluations performed by unqualified NCS permanent Engineers l
determined that three NCSA/Es required corrective action. In all cases when a deficient evaluation was found, the fissile material operation was shutdown, if not
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already shutdown. Revision to these NCSAs is being performed in accordance with l
III.
Corrective Steps to be Taken 1.
The training and qualification program for the NCS organization is being reevaluated L
and upgraded. As part of this upgrade, by July 27,1998, the qualification program will be revised to more clearly describe additional details such as applicability, tasks covered, restrictions during training status, evaluation of candidate's qualifications, and documentation requirements.
2.
Task 14 of the NCS CAP contains actions to improve the overall corrective action process.
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GDP 98-0076 Page 3 of 3 IV.
Date of Full Compliance USEC achieved full compliance with example "B" of the violation on March 4,1998, when the last qualification record of NCS contracted personnel was completed. USEC achieved full compliance with example "C" of the violation on December 11,1997, when the three NCS Engineers were restricted from performing NCS evaluations. As noted above, these j
individuals were subsequently properly qualified.
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s GDP 98-0076 Page1of2 UNITED STATES ENRICHMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/97013-D Restatement of Violation Technical Safety Requirement 3.3, " Facility Staff Qualification," requires, in part, that facility positions be filled with persons whose experience and/or training qualify them for their respective positions. The minimum qualifications, functions, and responsibilities for key staff positions are
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described in the Safety Analysis Report. Section 5.2.2.2 of the Safety Analysis Report entitled
" Nuclear Criticality Safety Responsibilities," requires managers to be trained in nuclear criticality l
l safety. This training provides personnel with the knowledge necessary to fulfill their nuclear l
criticality safety responsibilities.
l Contrary to the above, as of December 1 ? 1997, the Certificatee did not ensure that training was l
provided for the nuclear criticality safety manager that was necessary to ensure that the manager could fulfill his nuclear criticality safety responsibilities. (01043) l USEC Response I.
Reasons for Violation l
The reason for the violation is that the manager making the placement did not use the position description. A contributing factor is the qualification requirements for the NCS l
Manager are not proceduralized. The qualifications for this position are specified in a position description. However, there was no procedural requirement to review this position l
description prior to hiring a temporary or full-time NCS manager.
l II.
Corrective Actions Taken and Results Achieved l
i 1.
On March 4,1998, an interim manager from the PGDP facility was assigned to the PORTS NCS organization. This individual satisfies the qualification requirements for this position.
2.
This event has been reviewed with the Nuclear Safety Manager (this is the position that the NCS Manager reports to) concerning the need to review the qualifications of the NCS Manager when this position is permanently filled.
III.
Corrective Steps to be Taken 1.
- USEC will document the training requirements for the NCS manager's position in the upgraded qualification program (see USEC's response to Violations 97013-B and
l GDP 98-0076 Page 2 of 2 C, in Enclosure 2) and provide additional training as necessary by June 30,1998.
2.
The requirement to use and comply with position descriptions for both permanent and temporary placements will be incorporated into an approved procedure by June l.
30,1998.
l IV.
Date of Full Compliance l
USEC achieved full compliance on March 4,1998, when an interim qualified manager from i
the PGDP facility was assigned to the PORTS NCS organization.
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i GDP 98-0076 Page 1 of 2 UNITED STATES ENRICIIMENT CORPORATION (USEC)
RESPONSE TO VIOLATION 97-013-E l
Restatement _ofViolation Technical Safety Requirement 3.11.1 requires, in part, that a criticality safety program shall be l
established, implemented, and maintained as described in the Safety Analysis Report. Section
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5.2.2.9 of the Safety Analysis Report entitled " Nuclear Criticality Safety - Operation Surveillance I
and Assessment," requires, in part, that in order to ensure that the nuclear criticality safety program is properly established and implemented: 1) USEC utilizes walk-throughs, assessments, and audits;
- 2) the results of these walk-throughs, assessments, and audits are documented and reported to appropriate managers, and; 3) nuclear criticality safety deficiencies are recorded and corrected according to the problem reporting system, and the data is trended to monitor and prevent future violations.
l Contrary to the above, between March 3,1997, and December 11,1997, walk-throughs, assessments, and audits conducted under the Management Self-Assessment Program, the Nuclear Criticality l
Safety Department Self-Assessment Program, and the Organizational Self-Assessment Program did l
not assure that the nuclear criticality safety program was properly established and implemented.
Specifically, the self-assessment programs did not: a) identify, record or correct numerous physical l
inconsistencies between plant operations in the cascade, laboratory, and withdrawal facilities and the applicable nuclear criticality safety evaluations and approvals; and b) incorporate the results of previous generic findings resulting in the recurrence of previously-identified nuclear criticality safety l
deficiencies as documented in the plant non-conformance reporting system. (01053)
USEC Response 1
I.
Reasons for the Violation i
As part of Task 16 of the NCS CAP, a multi-discipline team was assembled to determine why previous assessments were not effective. The team concluded that the various assessment programs are not effective because they are driven by quantity (driven by schedule) and not quality of the effort, which seriously impaired the plant's ability to critically evaluate the assessed processes for compliance, adequacy, and effectiveness. In addition, since there is little to no detailed guidance in the governing procedures on management's expectations for an effective assessment, the assessment programs cannot fulfill their purpose. Also, the " ownership" of some assessment programs was delegated to such a low level in some organizations that it had degraded to merely an administrative
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j GDP 98-0076 j
Page 2 of 2 II.
Corrective Actions Taken and Results Achieved In nccordance with Task 16 of the NCS CAP, a corrective action plan has been developed.
I Some completed elements include reviewing assessments against preestablished criteria, developing a list of problems and apparent causes, and preparing recommendations.
Ill.
Corrective Steps to be Taken The remaining elements of Task 16 of the NCS CAP include developing a corrective action plan for each assess ent program, training affected personnel, and implementing upgraded m
assessment programs. These remaining elements will be completed by October 30,1998.
IV.
Date of Full Compliance USEC will achieve full compliance by October 30,1998, upon completion of NCS CAP Task 16.
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GDP 98-0076 Page 1 of 2 UNITED STATES ENRICHMENT CORPORATION (USEC)
RESPONSE TO VIOLATION 97-013-F Restatementof_ Violation i
Technical Safety Requirement 3.5, " Reviews, Assessments, and Audits," requires, in part, that a system of reviews, assessments, and audits shall be implemented as defined in the Quality Assurance
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Program and in Section 6.8 of the Safety Analysis Report. Section 6.8.1 of the Safety Analysis i
Report entitled " Audits," requires, in part, that: 1) audits be conducted by the USEC Safety, Safeguards, and Quality organization, and; 2) audits verify the effectiveness of health, safety, and environmental programs and their implementation and determine the effectiveness of the assessment process.
Contrary to the above, between March 3,1997, and December 11,1997, audits conducted by the USEC Safety, Safeguards, and Quality Organization, did not correctly determine he effectiveness of the nuclear criticality safety intemal assessment programs. Specifically, the audits did not: a) identify that the nuclear criticality safety self-assessment program was not finding existing physical differences between plant operations and nuclear criticality safety evaluations and approvals; b) identify inconsistencies between management controls defined in the Safety Analysis Report and the management controls described in plant procedures, and; c) identify the recurrent nature of i
nuclear criticality safety requirement deficiencies documented in the plant non-conformance report system. (01063)
USEC Response I.
Background
In January 1997, the USEC Safety, Safeguards, and Quality (SS&Q) Organization conducted an audit of the PORTS NCS program. The timing of the audit (January,1997) was necessary to coincide with the annual appraisal of the NCS program as required by the Department of Energy's (DOE) Regulatory Oversight Agreement (ROA) which was in effect at the time.
Subsequently, on March 3,1997, regulatory oversight of the GDPs transferred from DOE to USEC. Section 5.2.2.9, " Nuclear Criticality Safety - Operation Surveillance and Assessment," of the NRC-approved PORTS SAR requires that internal audits of the NCS program be conducted at least every three years. However, USEC planned to continue to perform annual audits of the NCS program.
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GDP 98-0076 Page 2 of 2 11.
Reasons for the Violation At the time the January 1997 audit was performed, the PORTS NCS program was undergoing major changes, including implementation of "new" nuclear criticality safety approvals and evaluations (NCSA/E) and their implementing procedures in accordance with Compliance Plan Issues 8 and 9. Additionally, the plant's self-assessment programs hadjust undergone major change within the previous quarter. For those reasons, there was no performance history available with the "new" programs upon which the auditors could make an effectiveness determination.
Since both the NCS and self-assessment programs were in a state of flux when the January l
audit was performed, additional un-scheduled audits or surwillance should have been conducted in accordance with QAP Section 2.18.3.2.5. c and e. Had such assessments been l
performed, it is likely that the noted deficiencies would have been uncovered. As noted in NRC Inspection Report 70-7002/97-203, " The audit [of January 13-24,1997] evaluated procedural compliance and included performance based field observations. The inspectors noted that the audit identified a number ofissues that were addressed through either the plant problem reporting system or the NCS Implementation Action Plan. A review of the t
individual deficiencies and recommendations indicated that the audit findings were I
substantive." It is reasonable to expect that " substantive" findings would result from other audits.
III.
Corrective Actions Taken and Results Achieved Surveillance of the NCS CAP effectiveness began in January 1998 in accordance with Task 17 of the NCS CAP. As of March 31,1998, twelve (12) surveillances had been conducted.
These surveillances are intended to determine the effectiveness of the NCS CAP. The results of these surveillances are reported bi-monthly (the first report was issued at the end of January,1998)in accordance with the commitments of the NCS CAP. Additionally, other elements of the SS&Q Organization are conducting NCS field implementation assessments in accordance with NCS CAP Task 5. These assessments meet the intent of QAP 2.18.3.2.5.
IV.
Corrective Steps to be Taken i
No further corrective actions are required.
V.
Date of Full Compliance USEC achieved full compliance with the issuance of the first NCS CAP Subtask 17.2 report on January 27,1998.
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GDP 98-0076 Page1of1 UNITED STATES ENRICIIMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/97013-G RestatementofXiolation Technical Safety Requirement 3.11.1 requires, in part, that a nuclear criticality safety program shall be established, implemented, and maintained as described in the Safety Analysis Report. Section 5.2.2 of the Safety Analysis Report entitled " Program Elements," requires, in part, that the plant nuclear criticality safety procedures shall address responses to nuclear criticality safety approval violations.
Contrary to the above, between March 3,1997 and December 12,1997, the Certificatee did not develop plant nuclear criticality safety procedures to address responses to nuclear criticality safety approval violations. (01073) l USEC Response I.
Reasons for Violation The reason for the violation is failure to flow down SAR Section 5.2.2 concerning the need to proceduralize responses to nuclear criticality safety approval violations. A contributing l
cause was ineffective corrective action for Problem Report PR-PTS-97-05277 written in i
response to NRC Inspector Follow Item (IFI) 97-203-08 (same subject). Tb action taken in this PR was to place an article in The Open Line, a plant newsletter. That action was inadequate. The correct actions should have been to proceduralize responses to nuclear l
criticality safety approval violations as required by the SAR.
11.
Corrective Actions Taken and Results Achieved Procedure XP2-EG-NS1031, Nuclear Criticality Safety, effective February 12,1998, was revised to proceduralize responses to nuclear criticality safety approval violations.
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III.
Corrective Steps to be Taken No further corrective actions are necessary. Task 14 of the NCS CAP contains actions to improve the corrective action process.
IV.
Date of Full Compliance USEC achieved full compliance on February 12,1998, when revision 1 of XP2-EG-NS1031 became effective.
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GDP 98-0076 Page 1 of 2 UNITED STATES ENRICIIMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/97013-11
- Restatement.oGiolation Technical Safety Requirement 3.9.1 requires, in part, that written procedures shall be prepared, reviewed, approved, implemented, and maintained to cover activities described in Safety Analysis Report Section 6.11.4.1 and listed in Appendix A. Appendix A of the Safety Analysis Report states,
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in part, that activities involving internal audits and inspections, investigations, and nuclear criticality safety shall be covered by written procedures.
Contrary to the above, from November 10,1997 through December 12,1997, actis ities described h Safety Analysis Report Section 6.11.4.1 involving nuclear criticality safety were not covered by
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w ritten procedures. Specifically, the nuclear criticality safety approval and impleme nting procedure tabletop reviews and walkdowns were conducted utilizing a " Desktop Reference,' an unapproved plant procedure. (01083)
USEC Response i
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Reasons for Violation The reason for this violation is failure to comply with approved procedure UE2-PS-PS1031, j
" LIE Policy and Procedure Control Process", which requires approved p ocedures for tasks that implement procedures required by the SAR or commitments. The ttbletop reviews and walkdowns were initially considered enhancements. Ilowever, when these tabletop reviews and walkdowns became regulatory commitments, as part of the NCS CAP, the NCS organization should have developed, or revised, procedures to cover th :se activities.
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II.
Correttive Actions Taken and Results Achieved l
1.
hbletop reviews and walkdowns were incorporated into approv:d procedure, XP4-EG-NS1020, Completeness Review and Field Verification of NCSAs/NCSEs, Rev.
2, offective January 28,1998.
I 2.
This violation has been reviewed with affected NCS personnel to heighten their j
awareness as to the requirements of UE2-PS-PS1031.
I 3.
A review of NCS activities to determine if there were other NCS t.ctivities that need j
to be centrolled by an approved procedure identified the need for an approved procedue to cover the activities of the NCS Murder Board (see section D.1 of the NCS CAP). Procedure XP2-EG-NS1033, Nuclear Criticality Stfety Murder Board
4 GDP 98-0076 Page 2 of 2 Committee for this activity became effective on April 13,1998.
III.
Corrective Steps to be Taken No further corrective actions are required.
IV.
Date of Full Compliance USEC achieved full compliance by April 13,1998, when procedure XP2-EG-NS1033 for the Murder Board was implemented.
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GDP 98-0076 Page 1 of 2 UNITED STATES ENRICHMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/97013-1 RestatementoLViolation Technical Safety Requirement 3.11.1 requires, in part, that a nuclear criticality safety program shall j
be established, implemented, and maintained as described in the Safety Analysis Report. Section l
5.2.2.1 of the Safety Analysis Report, requires, in part, that the nuclear criticality safety program comply with American National Standards Institute /American Nuclear Society (ANSI /ANS) 8.19-l 1984.
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Section 9.2 of ANSI /ANS 8.19-1984 entitled " Administrative Practices for Nuclear Criticality Safety," requires, in part, that appropriate material labeling and area postings shall be maintained specifying material identification and all limits on parameters that are subject to procedural controls.
Contrary to the above, between March 3,1997, and December 12, 1997, appropriate material labeling and area postings were not maintained specifying material identification and limits on parameters subject to procedural controls. Specifically, area postings oflimits on parameters subject to the nuclear criticality safety controls specified in Procedure XP3-TS-TS1050, " Laboratory NCSA l
l Commitments," were not maintained for the following Building X-710 areas:
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IIallways between Rooms 120 and 135 where dry activated waste (DAW) was stored on a daily basis, j
Rooms 120,135,138,142, and 157 where fissile poly-bottle storage areas were maintained, Room 135 where fissile sample container waste solutions were stored throughout the room on laboratory benches, Room 142 where a mobile uranium hexafluoride sample can cart was located. (01093)
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USEC Response 1.
Reasons for Violation The ANSI /ANS 8.19 standard requirement for posting of administrative controls was not properly implemented in the PORTS NCS program procedures due to the lack of detailed guidance for determining when a posting is needed. Guidance for how to determine if a posting of administrative controls is required is being developed and will be issued as a lessons learned. The guidance will subsequently be put into the NCSA development procedure (XP4-EG-NS-1001). As the NCSA/Es are upgraded, as part of the NCS CAP Task 3, the specific posting requirements will be incorporated into the NCSA in accordance with the new guidance. USEC recognizes this means we will not be in compliance with Section 9.2 of ANSI /ANS 8.19 - 1984 until the upgrade effort is complete. USEC believes
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GDP 98-0076 Page 2 of 2 this position is acceptable because the administrative controls specified in the NCSA/Es are flowed down into the procedures and communicated through training. While we recognize there have been some problems with the effectiveness of these measures, we have corrected many of them. To stay focused on the compliance issues we have trended, and will continue to trend, the number of NCS violations against each NCSA. If trends increase, we will adjust the upgrade schedule for that specific NCSA (e.g., we have made some improvements to our dry active waste and contaminated metal NCSAs.) Addiianal actions will be taken if t
warranted. (e.g., increased attention to pre-job briefings in that area).
l The operations referenced in the subject NOV are in full compliance with the governing NCS approvals and operating procedures; therefore, there are no immediate safety concerns j
associated with these deficiencies. While the specific examples cited in the violation have not been corrected, NCS requirements for the X-710 Building are provided in approved procedure XP3-TS-TS 1050, Laboratory NCSA Commitments, affected personnel have been.
trained on these procedure requirements, and these controls are considered adequate while upgrades are being made in accordance with the NCS CAP.
II.
Corrective Actions Taken and Results Achieved As part of Task 7 of the NCS CAP, applicable industry standards were reviewed against the ANSI Standards, against SAR Section 5.2, and the NCS program procedures. This task was completed on January 31,1998.
III.
Corrective Steps to be Taken In accordance with Task 2 of the NCS CAP, Procedures XP2-EG-NS1031, " Nuclear Criticality Safety", and XP4-EG-NS1001, " Nuclear Criticality Safety Evaluation and Approval", will be revised to adequately address the ANSI standard requirements by July 27, 1998. Subsequent upgrade of the NCSA/Es, in accordance with the revised procedures will ensure the correct posting requirements are specified and implemented. Any NCSA/Es that have aheady been updated as part of the CAP that are affected by the revised procedures will i
be modified as necessary so that all NCSA/Es are in compliance with the new procedure.
j The NCSA/Es are being upgraded under Task 3 of the NCS CAP.
IV.
Date of Full Compliance Full compliance will be achieved upon completion of Task 3 of the NCS CAP. This task is being completed on a prioritized basis, with the last upgrades schedule for completion by May 31,2000.
GDP 98-0076 Page 1 of 2 UNITED STATES ENRICHMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/97013-J Restatement of Violation 10 CFR 76.93, Quality Assurance, requires, in part, that the Corporation shall establish, maintain, and execute a quality assurance program satisfying each of the applicable requirements of American Society of Mechanical Engineers (ASME) NQA-1-1989," Quality Assurance Program Requirements for Nuclear Faciliu : "
ASME NQA-1-1989 Basic Requirement 16, " Corrective Action," requires, in part, that conditions adverse to quality shall be identified promptly and corrected as soon-as-practical. In the case of significant conditions adverse to quality, the cause of the condition shall be determined and corrective actions taken to preclude recurrence,. USEC plant Procedure UE2-HR-CI1031,
" Corrective Action Process," Revision 0, dated August 31,1996, defined issues which are reportable or result in a notice (i.e., NOV, NCV) are significant conditions adverse to quality.
Contrary to the above, between March 3,1997, and D:cember 12,1997, the Certificatee failed to correct some nuclear criticality safety deficiencies, conditions adverse to quality, as soon-as-practical i
and failed to determine the cause of some significant conditions adverse to quality and take corrective actions to preclude recurrence. For example, Portsmouth staff did not correct nuclear criticality training, and procedural adherence deficiencies and did not determine the cause for and develop corrective actions to prelude recurrence of significant conditions adverse to quality as identified in problem reports PR PTS-97 08987,09722,10320,09495, and 09035. (01103)
USEC Response I.
Reasons for Violation In accordance with Task 14 of the NCS CAP, a team was assembled to thoroughly review the corrective action process. The team concluded that the reason for ineffective corrective actions was a lack of clear management expectations and a failure to hold personnel accountable for completing effective corrective actions within the committed time frame.
Contributing causes included:
Lack of an effective screening process; Overly restrictive requirements for responding to non-significant problems; Lack of a proceduralized process for dealing with multiple issues of the same problem;
GDP 98-0076 Page 2 of 2 i
No approved process for closing problems that warranted no actions to a track and trend process.
3 The Root Cause determination procedure was inadequate, and was not correctly utilizing the process in place.
II.
Corrective Actions Taken and Results Achieved The development, maintenance and implementation of the corrective action program was reassigned from the Administrative Support Manager to the Commitment Management Manager in order to place greater focus on the corrective action process. The Commitment Management Manager reports directly to the General Manager. The person filling this position is also the Chair of the Corrective Action Review Board (CARB). As such, actions have been taken to place increased emphasis on the root cause determinations and quality of the Corrective Action Plans (CAPS) by changing the CARB Charter. This has raised the awareness and level of attention to detail for root cause determinations and the quality of the CAPS and will provide added assurance that these actions are performed correctly.
III.
Corrective Steps to be Taken Corrective actions to improve the effectiveness of the corrective action process are being taken in accordance with Task 14 of the NCS CAP.
IV.
Date of Full Compliance USEC achieved full compliance through the development and implementation of the NCS CAP which addresses the root causes forNCS deficiencies and describes actions to prevent recurrence. The actions to improve the PORTS corrective action process are scheduled to be completed in accordance with Task 14.
o
. 0 GDP 98-0076 Page1of1 UNITED STATES ENRICHMENT CORPORATION (USEC)
RESPONSE TO VIOLATION 70-7002/97013-K Restatement of Violation 10 CFR 76.93, requires, in part, that the certificant shall establish, maintain, and execute a quality assurance program satisfying each of the applicable requirements ofAmerican Society ofmechanical Engineers (ASME) NQA-1-1989," Quality Assurance Program Requirements for Nuclear Facilities."
ASME NQA-1-1989 Basic Requirement 16," Corrective Action," requires in part that conditions adverse to quality shall be identified promptly and corrected as soon as practical. In the case of a significant condition adverse to quality, the cause of the condition shall be determined and corrective actions taken to preclude recurrence.
Contrary to the above, from September through December 1997, the Certificatee failed to promptly identify and correct conditions adverse to quality and implement corrective actions to preclude the recurrence of significant conditions adverse to quality, identified as violation 97203-05 in NRC Inspection Report 070-07002/97-203. (01113)
USEC Response USEC believes that the reason for the violation, corrective actions taken and results achieved, corrective steps to be taken, and date of full compliance are adequately addressed in the responses to examples E (Enclosure 4) and J (Enclosure 9) of this violation.
e
, 1 GDP 98-0076 Page1of3
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UNITED STATES ENRICHMENT CORPORATION (USEC)
RESPONSE TO VIOLATION 70-7002/97013-L, M, N, O, and P RestatementofSlolations L.
Nuclear Criticality Safety Approval-PLANT 045, Control A, required, in part, that the volume for a container used to collect waste is less than a nominal volume of I liter (1.25 liters). Control B, required, in part, that a second operator or supervisor verify that the l
correct volume container is utilized.
Contrary to the above, on December 9,1997, plant staff failed to implement either of the controls specified in Nuclear Criticality Safety Approval-PLANT 045 for a waste storage bottle attached to an Atomic Absorption Unit used to analyze samples, in Building X-710, Room 138. (01123)
M.
Nuclear Criticality Safety Approval-PLANT 011, Control B, item 6, required, in part, that all other uranium-bearing material, including other units, shall be kept at least two feet edge-to-edge from the unit [HEPA ventilation unit].
Contrary to the above, on December 10, two building X-330 HEPA ventilation units were stored next to each other, with less than two foot spacing as required by NCSA-PLANT 0ll. (01133)
N.
Nuclear Criticality Safety Approval-PLANT 018, Control A, item 5, required, in part, that a minimum spacing of two feet edge-to-edge must be maintained between dry active waste i
containers / bags and other types of uranium bearing equipment or materials prior to nondestructive assay surveys.
i Contrary to the above, on December 10,1997, several uncharacterized drums of dry activated waste were stored on the ground floor in Building X-330 with less than two foot spacing from several drums of contaminated scrap metal, another type of uranium bearing material as required by NCSA-PLANT 018. (01143)
O.
Nuclear Criticality Safety Approval-PLANT 064, Control A, item 11, required, in part, that a minimum spacing of four feet edge-to-edge must be maintained between groups of stored seals.
Contrary to the above, on December 10,1997, two groups of seals were stored in Building X-330 with less than four foot spacing between the two groups as required by NCSA-PLANT 064. (01153).
I
. 1 GDP 98-0076 Page 2 of 3 P.
Nuclear Criticality safety Approval-PLANT 048, Control A, item 10b, required, in part, that a minimum spacing of two feet edge-to-edge must be maintained between Blow-Out Prevention Actuators being stored.
Contrary to the above, on December 11,1997, several Blow-Out Prevention Actuators were stored on the cascade floor in Building X-330 with less than two foot spacing between the actuators as required by NCSA-PLANT 048. (01163)
USEC Response L
Reasons for Violation The reason for examples "M" through "P" of this violation is that when the governing NCSAs were prepared, confusing and/or conflicting NCS controls were created and i
inadequate training was provided. The reason for example "L" of the violation is that personnel were unaware of which NCSA applied to the collection container.
J II.
Corrective Actions Taken and Results Achieved 1.
For example 97203-L, the container was replaced with one of the proper volume on December 9,1997.
2.
For example 97203-M, the HEPA units were moved so they were two feet apart i
edge-to-edge on December 10,1997.
3.
For example 97203-N, the dry active waste barrel was properly spaced two feet edge-to-edge from the contaminated scrap barrel on December 10,1997.
4.
For example 97203-0, the groups of seals were moved to correctly meet the four feet i
edge-to-edge spacing requirement on December 10,1997.
5.
For example 97203-P, the blow-out prevention actuators were correctly spaced to meet the two feet edge-to-edge spacing requirement on December 11,1997.
6.
For example L, briefing with cognizant personnel to improve knowledge of applicable NCSAs and requirements were completed by December 19,1997.
,o L :.
1
- 1 J
GDP 98-0076 1
Page 3 of 3 7.
In addition to the corrective actions described in the NCS CAP, USEC has taken the following corrective actions to further improve PORTS personnel knowledge and training on NCS requirements:
Between March 11-13,1998, the Portsmouth Plant initiated a " Plant Wide NCS Stand-down". During this time period, each operation having NCS controls was suspended from performing NCS related activities (except for i
those required by the TSR) while facility Fissile Material Operations ( FMO) l personnel (i.e., currently,1217 plant personnel) participated in crew briefings on the NCS Corrective Action Plan, the " spacing" problems, the affected i
NCSAs, spacing controls, and expected responses to anomalous NCS J
conditions.
An error lab was also established to challenge and introduce personnel to NCS control problems and to emphasize correct solutions to various NCS non-conformances. Over 1400 plant personnel have completed this exercise.
In addition, FMO personnel were issued key chain type tape measures as an NCS awareness tool to be used in the field to ensure proper spacing.
8.
Training bulletins were developed and issued between March Il-13,1998, to plant personnel on NCS spacing requirements and anomalous condition responses. In addition, a special edition of The Open Line, a PORTS plant newsletter, was distributed to the general plant population which also contained NCS related informat.on to reemphasize compliance with NCS controls.
III.
Corrective Steps to be Taken Long term corrective actions to address inadequate and/or ccnfusing NCSAs are addressed by Task 3, "NCSA Upgrade Project"in the NCS CAP. This task is currently scheduled to be completed by May 31,2000.
j l
IV.
Date of Full Compliance USEC achieved full compliance on December 11,1997, when the specific conditions cited in the violation were corrected.
g,s
'. 3 GDP 98-0076 USEC Check No.15613 1
, 2 GDP 98-076 Page1ofI List of Commitments Cover. Letter USEC is evaluating the NCS CAP to determine if additional actions are required as a result of the deficiencies addressed in this violation. If additional actions are required, they will be reflected in the quarterly status report to the NCS CAP.
NOV 70-7002/97013 - n and c The training and qualification program for the NCS organization is being reevaluated and upgraded.
As part of this upgrade, by July 27,1998, the qualification program will be revised to more clearly describe additional details such as applicability, tasks covered, restrictions during training status, evaluation of candidate's qualifications, and documentation requirements.
NOV 70-7002/97013 - n 1.
USEC will documcnt the training requirements for the NCS manager's position in the i
upgraded qualification program (see Response to Violation 97013 - B and C, Enclosure 2)
]
and provide additional training as necessary by June 30,1998.
i 2.
The requirement to use and comply with position descriptions for both permanent and i
temporary placements will be incorporated into an approved procedure by June 30,1998.
NOY_20-2002/97013 _I in accordance with Task 2 of the NCS CAP, Procedures XP2-EG-NS1031, " Nuclear Criticality Safety", and XP4-EG-NS1001, " Nuclear Criticality Safety Evaluation and Approval", will be l
revised to adequately address the ANSI standard requirements by July 27,1998.
.