ML20217E346
| ML20217E346 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 03/26/1998 |
| From: | Morgan J UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-7002-97-15, GDP-98-2012, NUDOCS 9803310012 | |
| Download: ML20217E346 (7) | |
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USEC A Global Energy Company
- March 26,1998
- GDP-98-2012 United States Nuclear Regulatory Commission
- Attention: Document Control Desk Washington,' D.C. 20555 Portsmouth Gaseous Diffusion Plant (PORTS)
-- Docket No. 70-7002
- Response to Inspection Report (IR) 70-7002/97015 Notice of Violation (NOV)
The subject Inspection Report (IR) contained two violations involving: 1) failure to implement Nuclear Criticality Safety (NCS) controls, and 2) failure to comply with Technical Safety
> Requirements. USEC's response to these violations is provided in Enclosures 1 and 2, respectively. lists the commitments made in this report. Unless specifically noted, the corrective actions specified in each enclosure apply solely to PORTS.
' Regarding the latter violation (i.e., NOV 97015-02), NRC identified a similar potential violation in the exit meeting for IR 98003 conducted on March 8,1998 Specifically, during the routine monthly Extended Range Product (ERP) crdne preventive.naiar. nce testing, USEC failed to declare the system inoperable which resulted in a Technical Safety Requirement (TSR) violation.
USEC believes that the corrective actions being taken for NOV 97015-02 (see Enclosure 2) also address the circumstances that led to the potential violation being considered for IR 98003.
Accordingly, USEC requests NRC asses our corrective actions for NOV 97015-02 in evaluating the potential violation for IR 98003.
If you have any questions regarding this submittal, please contact Ron Gaston at (614) 897-2710.
Sincerely,
'Ja
. Morga
--@C r
Act ng General Yanager T Portsmouth Gaseous DitTusion Plant aavuau Enclosures (3).
- cc:
1.NRC Region III, Regional Administrator
~ NRC Resident Inspector, PORTS:
9803310012 980326.
PDR ADOCK 07007002
~
.C PDR P.O. Box 800, Portsmouth, OH 45661 Telfphone' 614 897-22S Fax 614-897-2644 http://www.us, c.com Oflices in Livermore, CA Paducah, KY Portsmouth, OH Washington, DC a2
i GDP 98-2012
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Page 1 of 3 j
UNITED STATES ENRICHMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/97015-01 I
.I Restatement of Violation Technical Safety Requirement 3.11.2 requires, in part, that all operations involving uranium enriched to 1.0 weight-percent (wt%) or higher U-235 and 15 grams (g) or more of U-235 shall be performed in accordance with a documented nuclear criticality safety approval (NCSA),
NCSA-PLANT 018.A01," Dry /.etive Waste (DAW) in Waste Generation Areas and a.
Interim Storage," requires that DAW containers with a capacity of 55 gallons or less be spaced at least two feet edge-to-edge from uranium bearing material.
On January 15,1998, the NRC inspectors identified that DAW bags located in X-344 building storage area were spaced less than two feet of IS sample cylinders i
containing uranium bearing material.
l b.
NCSA-PLANT 057.001,"Use of Gas Sampling Cart." requires that a minimum two f
foot edge-to-edge spacing be maintained between the sampling cart and other uranium bearing material.
1 On January 23,1998, plant staff discovered that two gas sampling carts contaimng uranium bearing material were spaced less than two feet from each other in the X-333 Building.
' NCSA-PLANT 48.A00, " Contaminated Metal," reonires a two foot edge-to-edge c.
spacing horizontal and vertical to other contaminated items (uranium bearing material).
1.
On December 31, 1997, plant staff discovered two buckets containing contaminated valve intemals were spaced less than two feet from each other, j
2.
On January 15,1998, plant staff discovered that bagged valve subassemblies
.were spaced less than two feet from AG-17 valve in the X-326 Building.
d.
NCSA-PLANT 66.A02, " Mop Buckets," requires passive design features, i.e., slots and holes, in the sides of the bucket for volume control.
On Januarp 15,1998', plant staffdiscovered an upright, empty mop bucket in a posted q
contamination area (uranium bearing material area) in the X-344 Building without J
the required passive design features.
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GDP 98-2012 Page 2 of 3
- Contrary to the above, between December 31,'1997, and January 15,1998, the certificatee failed to implement nuclear criticality safety controls as described by the '
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aforementioned examples.
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(USEC Response.
I.
Reasons for Violation The reasons for the violation were inadequate NCSA training and confusing or conflicting NCS controls. For example, in the case of examples "a" through "c". of the cited violation,
- plant personnel did not understand spacing requirements as they applied to dissimilar material or materials / components covered by different NCSAs. In the case of example "d" of the cited violation, plant personnel believed that the NCSA requirements only applied to
- mop buckets that were in use.
II.-
. Corrective Actions Taken and Results Achieved
. l..
USEC has corrected the conditions which resulted in the specific examples cited in the violation. The latest action to restore compliance was completed on January 23,
'1998.
2, On December 22,1997, USEC submitted a revised NCS Corrective Action Plan
. (CAP) to NRC (see USEC letter GDP 97-0217). An update to t_his report was subsequently submitted to NRC on January 30,1998 (see GDP 98-0013). This CAP addresses corrective actions that USEC is taking to achieve long term, sustained
' improvement in the. PORTS NCS program.
3.-
In addition to the corrective actions described in this CAP, USEC has taken additional corrective actions to further improve PORTS personnel knowledge and training on NCS requirements.
Between March Il-13,1998, the Portsmouth Plant initiated a Piant Wide NCS Stand-down. During this time period, each operation having NCS controls was suspended from performing NCS related activities (except for
' those required by the TSR) while facility Fissile Material Operations (FMO) personnel (i.e., currently,1217 plant personnel) participated in crew briefings
.on the NCS Corrective Action Plan, the " Spacing" problems, the affected K
- NCSAs, spacing controls, and expected responses to anomalous NCS conditions.
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i GDP 98-2012 Page 3 of 3 -
- An error lab was also established to chal'lenge and introduce to NCS control problems, and to emphasize correct solutions to various' NCS non-conformance. Currently,1461 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 ensum proper spacing.-
Training bulletins were developed and issued between March Il-13,1998, to plant personnel on NCSA describing spacing requirements by facility, and =
anomalous condition response. In addition, special edition of The Open Line, a PORTS plant news letter, was distributed to the general plant population which also contained NCS related information to reemphasize compliance with NSC controls.
III..
Corrective Steps to be Taken Long term corrective actions to address inadequate and/or confusing NCSA's are addressed by Task 3, "NCSA/E Upgrade Project, " in the NCS CAP. This task is currently scheduled to be completed by May 31,2000.
IV. -
Date of Full Compliance USEC achieved full compliance on January 23,1998, when the specific conditions cited in the violation were corrected.
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GDP 98-2012 Page1of2 UNITED STATES ENRICHMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/97015-02
)
' Restatement of Viointion
. Technical Safety Requirement;(TSR) 2.5.3.4 requires, in part, that the affected cylinder and withdrawal manifold be isolated within 15-minutes after declaring both smoke detectors for a withdrawal position inoperable.
- Contrary to the above, on December 15,1997, the certificate did not isolate the withdrawal manifold at Extended Range Product Station No.1 within 15 minutes after declaring the station inoperable for surveillance testing of the smoke detection system.
I.
Reasons for Violation The reason for the violation was inadequate training in that Cascade First Line Managers (FLMs) did not understand the significance of the work start approval process or the full meaning of what their approval signature implied as related to safety and/or plant conditions.
. Work control procedure XP2-GP-GP1030; Work Control Process establishes the FLM's responsibility related to work start approval. However, in the case of the cited violation, the FLM did not confirm that both ERP withdrawal stations were in the proper configuration to:
support the scheduled maintenance activity, to complete the operability determination for both' stations, or to ensure appropriate TSR LCOs were implemented. Consequently, when the Plant Shift Superintendent (PSS) and Cascade Controller questioned the status of the Extended Range Product (ERP) Station #1 during the testing evolution of ERP #2, personnel recognized that the station was not in a configuration required by TSR 2.5.3.4.
IL Corrective Actions Taken and Results Achieved 1.
Upon discovery of the non-conformance, the PSS ordered the station vented and the withdrawal manifold isolated. This action was completed on December 15,1997.
' 2.
Cascade FLMs were briefed by their respective Facility Managers on the lessons learned from two recent events (i.e., the event cited in this violation an' a similar d
event that occurred on February 20,1998, when the ERP crane was not declared inopersble1during the performance of 'a preventive maintenance) where TSR violations occurred because work start approval was granted by a manager without k
understanding plant conditions _or the scope of the. work. The briefings further
/ communicated cascade management's expectations on work start authorization and Lthe procedural requirements of XP2-GP-GP1030; Fork Control Process, relating to'.
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GDP 98-2012 Page 2 of 2 '
the First Line Manager's responsibility for work start approval. First Line Manager briefings were conducted between February 24,1998, and March 13,1998.
III.
Corrective Steps to be Taken Work Control Training module WCT 01.05; Work Controlfor Support Groups, will be reviewed by Cascade Operations to ensure the leaming objectives are appropriate for FLM's and modified as appropriate to incorporate the lessons learned from the events which resulted in this citation.. In addition, this training module will be added to the required training list for new Cascade Operations FLM's by May 29,1998.
IV.-
- Date of Full Compliance USEC achieved full compliance on December 15,1997, when the ERP station withdrawal manifold was properly isolated per TSR 2.5.3.4.
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GDP 98-2012 Page1of1 List of Commitments NOV 70-7002/97015-02 Work Control Training module WCT 01.05; Work Controlfor Support Groups, will be ~
reviewed by Cascade Operations to ensure the teaming objectives are appropriate for FLM's
'and modified as appropriate to incorporate the lessons leamed from the events which resulted in this citation. 'In addition, this training module will be added to the required training list for new Cascade Operations FLM's by May 29,1998.
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