ML20217K567

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7001/97-03

ML20217K567
Person / Time
Site:	Paducah Gaseous Diffusion Plant
Issue date:	08/12/1997
From:	Caniano R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	John Miller UNITED STATES ENRICHMENT CORP. (USEC)
References
70-7001-97-03, 70-7001-97-3, NUDOCS 9708150299
Download: ML20217K567 (1)

Text

_.

August 12,1997 Mr. J. H. Miller Vice President Production United States Enrichment Corporation Two Democracy Center 6903 Rockledge Drive Bethesda, MD 20817

SUBJECT:

RESPONSE TO INSPECTION REPORT 70 97003(DNMS)

Dear Mr. Miller:

This will acknowledge receipt of a response letter from Mr. Steve Polston, Daducah General Manager, dated August 1,1997,in response to our letter dated July 2,1997, transmitting a Notica of Violation. We have reviewed your corrective actions and have no further questions at this time. These corrective actions will be examined during further inspection, if you have any questions, please contact Patrick Hiland of my staff at (630) 829 9603.

Sincerely, Original Signed by Roy J. Canlano, Acting Director Division of Nuclear Materials Safety Docket No.

70 7001 cc:

S. A. Polston, Paducah General Manager W. E. Skyes, Paducah Regulatory Affairs Manager D.1. Allen, Portsmouth General Manager Paducah Resident inspector Office Portsmouth Resident inspector Office J. C. Hodges, Paducah Site Manager, DOE bec w/Itr dtd: 8/1/97: J. Lieberman, OE J. Goldberg, OGC -

i g

M. L. Horn, Project Manager, NMSS A

J. L. Caldwell, Ritt T. L. Simmons, Rlli PUBLIC (IE 07)-

DOCUMENT NAME: R:\\LT R S 2 LIC\\0T H E R\\F U E LFA C\\97 PA D.t.01

- 1.

w..,. w.

um.ni. ww.i. woh. 6. *c. copy wnhoui.it.ch/.nci t. coe, wnh.et.ch>.nci i,. e4..,

OFFICE Ritt h C.

Rlli Rlli Hilandh. h CanlanoM i

a Auf Kniceley:ib s

..q 0 g.

s DATE 08/lV97 08/\\\\/97 08/t/97 M81@g;Mghgg

. OFFICIAL RECORD COPY

o u,.na smc.

1 tadmca rapw.

o e

PaJtrah kle Offrc P O lbg1410 Pa.hkah. KV 42001 ict 302 4413M01 las.N12441 901 August I,1997 United States Nuclear Regulatory Commission SERIAL: GDP 971020 A1TN: Document Control Desk Washington, D.C. 20555 Paducah Gascous Diffusion Plant (PGDP)

Docket No.70 7001 Response to inspection Report (IR) 70-7001/97003 Notices of Vloistion (NOVs)

Nuclear Regulatory Commission (NRC) letter dated July 2,1997, transmitted the subject IR which contained six NOVs. Your letter requested a response to five of these NOVs. United States Enrichment Corporation's (USEC) response to these violations is provided in Enclosures

15. Enclosure 6 lists the commitments made in this report. Unless specifically noted, the corrective actions specified in each enclosure apply solely to PGDP.

In the cover letter to the IR, NRC expressed a concem that "many of the violations indicate slow or ineffective corrective actions to identified problems." We share your concern with the slowness of our corrective action program. We have discussed this issue at various PGDP management meetings. We recognize that improvement is warranted in improving the timeliness and responsiveness to significant issues (e.g., TSR violations) to ensure that such issues do not repeat themselves pending the development and implementation oflong term corrective actions.

Accordingly, the PGDP Corrective Action Program Manager has been assigned the task of evaluating and developing recommendations to improve our perfonnance in the area of corrective actions etrectiveness. The results of this assessment are scheduled to be presented to the Management Assessment and Analysis Team by September 5,1997. We will brief the PGDP NRC Resident inspectors on the results of this assessment.

We recognize that immediate action is needed to improve in the area of timely corrective action response. Therefore, in addition to the above initiative, we are currently evaluating actions that we can take quickly which will improve our responsiveness to important issues. Again, we will brief the PGDP Resident inspectors once a plan is determined.

M Tlg 3 3 $ttp

s-o=

United States Nuclear Regulalory Commission Page Two August 1,1997 1

If you have any questions regarding this submittal, please contact Bill Sykes at (502) 4414796.

Sincerely, hW l

Steve Polston General Manager l'aducah Gaseous Difrusion Plant SP:SRC:mel i

Enclosures i

cc:

NRC Region 111 NRC Senior Resident inspector, PODP l~

L g '.

f r

F A

?

I 1

'i

. 1 4

.a..

. = =....

-.. - a..

..a.,.--.

.. =

)

ENCLOSURE 1 UNITED STATES ENRICllMENT CORPORATION (USEC)

REPLY TO NOTICE OF VIOLATION (NOV) 70 7001/97003-01 Technical Safety Requirement (TSR) 2.4.4.2(b), Action Statement A.I.2 requires, in part, that in areas without an audible criticality accident alarm and where the maximum foreseeable absorbed dose in free air exceeds 12 rad, the certificatee shall irnmediately [begin to] monitor temperatures and pressures hourly in cascada cells containing uranium hexafluoride, enriched to 1.0 weight percent or greater.

Safety Analysis Report, Chapter 4, Appendix A, Table 2.51," Criticality Clusters and Building Alarmt," specifies, in part, that criticality accident alarm system (CAAS) local clusters "O" and "11" and building homs provide the criticality detection and accident alarms for Building C 310.

TSR I.2.8 defines "immediately" as: " required action shall be pursued without delay and in a controlled manner."

Violation Cited Contrary to the above, on May 8,1997, the certificatee did not immediately begin to monitor temperatures and pressures hourly for Building C 310 cascade cells containing uranium hexafluoride enriched to 1.0 weight percent or greater, when the area did not have an audible criticality accident alarm because clusters "O" and "11" had been removed fmm service.

Specifically, C 310 cluster "O" was declared inoperable at 0900, and cluster "11" was declared inoperable at 1020. The initial rounds to monitor temperatures and pressures in the cells were not initiated until 1200, a period of time exceeding TSR 2.4.4.2(b), Action Statement A.I.2 surveillance requirement.

I.

Rockground Infonq@n On May 8,1997, the Criticality Accident Alarm System (CAAS)in C 310 was removed from service na a planned evolution to complete required TSR quarterly surveillances.

CAAS cluster "O" was declared inoperable at 0900 for quarterly cluster module replacement. After completing this task, cluster "11" was declared inoperable at 1020 to complete the quarterly audibility testing.

When "H" cluster was declared inopera 'e, C-310 did not have operable CAAS 5

coverage. Operations had implemented TSR 2.3.4.7(a) and 2.3.4.7(b) Limiting Conditions for Operation (LCO) Action Statements. However, TSR 2.4.4.2(a) and 2.4.4.2(b) LCO Action Statements were not identified as required and these were not initially implemented. (Actions A.I.2 and A.I.4 of TSR 2.4.4.2 require monitoring temperatures / pressures in the cascade to maintain UF. in a gaseous state and not using the wet air pumps for cell evacuations. The required action A.I.2 was not implemented.)

El.1

^

}

When this deficiency was identified by an NRC inspector, Operations immediately initiated the required action at 1200. 'Ihe C 310 building manager had discussed the planned inoperability of the CAAS with the Assistant Plant Shia Superintendent (APSS) and confinned that the required LCO Action Statements were being implemented, however, the details of which specific actions were implemented were not discussed. The building manager completed an LCO Action Tracking Sheet and faxed a copy to the PSS.

The PSS/APSS did not review this sheet until after the deficiency was discovered at 1200.

During a review of past retivities involving C 310 CAAS, Operations discovered that TSR 2.4.4.2(a) and 2.4.4.2(b) LCO Action Statements were also not implemented when the C 310 CAAS was declared inoperable on April 28,1997. Cluster"II" was declared inoperable on April 28,1997, at 0920 for cluster module replacement. At 1320 cluster "O" was also declared inoperable to complete the building horn surveillance test. At this time, TSR required actions 2.3.4.7(a) and 2.3.4.7(b) were implemented, however, TSR required actions 2.4.4.2(a) and 2.4.4.2(b) were not implemented. The C 310 building Front Line Manager discussed this planned outage with the PSS and confirmed that the required 1.CO Action Statements were being implemented. Similar to the May 8,1997 event, the details of which LCO Action Statements were being implemented was not discussed. An LCO Action Tracking Sheet was submitted to the PSS ofTice and logged.

The deficiency was not identified by the PSS group at this time.

Similar events also occurred November 27,1996 and December 13,1996 under DOE regulation (DOE Inspection Report 97 01). The violations were failure to monitor cell temperatures and line recordem during periods when the C 310 CAAS was inoperable as required by plant Operational Safety Requirement (OSR) KY/D 3971. In these instances, two OSRs applied to C-310: OSR KY/D 3971 (Enrichment Cascade OSR) applied to C-310 up to the suction of the Nonnetex pumps; and KY/D 3974 (Product and Tails Withdmwal OSR) applied to C 310 from the Nonnetex pump suction up to the 200-foot purge vent stack.

11.

Reasons for the Violation The reason for the violation is a failure to adequately detennine the root and contributing causes from previous events, and a failure to consequently develop and implement effective corrective actions to address previous similar violations. For example, if TSR 2.4.4.2 requirements had been incorporated into TSR 2.3.4.7, the TSR violations on April 28,1997 and May 8,1997 may not have occurred.

The inefrectiveness of our corrective action program is addressed in the cover letter. 'Ihe discussion below addresses the specific violations cited in the report and provides those actions necessary to prevent recurrence.

The previous corrective actions were to: 1) provide training on OSR'KY/D 3971 to El 2

)

address the apparent training / knowledge deficiency by ensuring the lesson plan for the TSRs included the fact that two TSRs applied to C.310 CAAS and by requiring classroom training for affected personnel; and 2) provide crew briefings for all C 310 qualified personnel reiterating the use of the STAR principle (Stop, Think. Act Review) including the details of the specific deficiency of this event (failure to implement required OSR LCO actions of both KY/D 3974 and KY/D 3971).

An opportunity was missed that may have prevented the April 28,1997 and May 8,1997 violations.

A. The investigation should have included an analysis of the contribution of having two separate OSRs/fSRs specifying different required actions for an inoperable CAAS in C 310. Currently,in the TSRs for the Product and Tails Withdrawal Facilities, only CAAS has different TSR requirements specified in separate TSR sections (those for the cascade). This contributed significantly to the violations on April 28,1997 and May 8,1997. In these violations, the CAAS TSRs of 2.3.4.7 were implemented, while the requirements of 2.4.4.2 were not.

D. The remaining OSRsffSRs in efTect should have been evaluated to identify any other similar potential problem areas.

C. An additional contributing factor was that on April 28,1997, and again on May 8, 1997, when the C.310 building manager discussed the planned CAAS outage with the PSS, the details of specifically which TSR Action Statements were required was not discussed. When the LCO Action Tracking Sheet was processed by the APSS, the failure to implement TSR 2.4.4.2 was not identified.

In summary, there have now been four occurrences where personnel failed to implement the Enrichment TSR/OSR requirements for an inoperable CAAS in C 310. In every case, the Product Withdrawal TSR/OSR requirements were correctly implemented, while the Cascade TSR/OSR requirements applicable to C 310 were not.

111.

Conective Actions TakcLead Results Achieved

1. TSR 2.4 sections have been reviewed to detemline whether there are other examples of difTerent requirements specified in TSR 2.4 than the requirements in TSR 2.3. The other TSR sections in 2.4 do not present the same challenge to Operations personnel.

2. Technical Safety Requirement Clarification (TSRC) 97C004 has been established to add a reminder to trigger consideration of TSR 2.4.4.2(a) and/or 2.4.4.2(b) actions when taking actions required by TSRs 2.3.4.7(a) and/or 2.3.4.7(b). A note has been added befon TSR sections 2.3.4.7(a),2.3.4.7(b),2.4.4.2(a), and 2.4.4.2(b) instmeting personnel to refer to TSRC 97C004.

El 3

i 3.

- Crew briefings on TSRC97C004 for all C.310 qualified operators / managers and all PSS/APSS/ Cascade Coordinators have been completed.

111.

Conective Actions to be Taken

1. A review of other similar TSRs (2.1,2.2,2.3,2.5, and 2.6) will be perfomied to detennine if the format of these TSRs present a challenge for personnel to properly execute the requirements, similar to the problem presented ty 2.4.4.2 in C 310 (specifically, difTerent requirements located in separate TSR sections for a single system required to be operable by the TSR). This will be completed by August 8 I997.

2. We will submit TSR changes to TSR 2.4 and 2.3 to NRC for approval making the editorial change ofcross referencing the Required Actions of these two TSR sections as applicable to CAAS in C.310. This will be completed by October 7,1997.

3. We will change procedure CP2 CO CN1031," Tracking ofInoperable Stmetures, Systems, and Components," to require that the PSS discuss the specific required TSR actions with the afTected front line manager prior to declarirg a TSR required system inoperable for planned work or system inoperabilities due to emergent conditions.

This will be completed by September 30,1997.

IV.

Date of Full Comollance Full compliance with TSR 2.4.4.2 requirements have been maintained since the May 8, 1997 event. The actions to prevent recurrence will be completed when the proposed changes to the TSR have been approved by the NRC and training on these changes implemented (within 45 days of receiving NRC approval).

El4 h

ENCLOSURE 2 UNITED STATES ENRICllMENT CORPollATION (USEC)

REPLY TO NOTICE OF VIOLATION (NOV) 70 7001/97003 02 Technical Safety Requirement (TSR) 2.3.4.7 Action Statements A.2.1, A.2.2, and A.3, and TSR 2.4.4.2, Action Statements A.2.1, A.2.2, and A.3 seguire for areas not covered by criticality accident detection, that: 1) the area be evacuated inunediately; 2) access to the evacuated area be restricted; and 3) personnel, allowed into the restricted area, Le provided with an alternate means of criticality alann notification, such as a device that will alarm on sensing a 10 millirem per hour dose rate.

Procedure CP2 CO CA1030, Revision 0,"0PERATION OF Tile CRfTICALITY ACCIDFNT ALARM SYSTEM (CAAS)," dated March 3,1997, step 6.2.31) states that upon loss of CAAS coverage: " Access control consists of posting signs, traffic cones, or other type barriers around the perimeter of the afTected area which informs personnel of the LCO [ Limiting Condition of Operation) boundary and that access is not allowed unless authorized by the PSS/MIC [PSS or manager in charge) and proper dosimetry (for detection and audibility) or a radio (for audibility only) is worn."

Violation Cited Contrary to the above, on April 28, May 8, and May 14,1997, seven personnel, on six separate occasions, entered evacuated, restricted, and posted areas, around Buildings C-310 and C-337, which were not covered by criticality accident detection: 1) without authorization by the PSS or manager in charge; and 2) without proper dosimetry or a radio.

1.

Reason for violation The reason for the violation was ineffective controls to prevent personnel from entering unauthorized areas during a loss of CAAS coverage. Specifically, there were: (1) ineffective barriers (cones and flags) for the identification of evacuation zone boundaries; (2) ineffective communication of the procedure requirements for loss of CAAS coverage; and (3)less than adequate enforcement of the procedure requirement.

11.

Corrective Actions Taken and Results Achieved

1. The PSS issued a long tenn order to walk down placement ofcones and flags each time the CAAS LCO evacuation zone is established. In addition, physical placement of cones and flags was re-evaluated and the number of cones and flags used to establish boundaries was increased, E2-1

2. Communication of the TSR requirement was enhanced by the following actions:

a. The Enrichment Plant Manager received confinnation from all organization managers "that personnel in their organization understood their responsibilities relative to restricted areas during CAAS outage."

b. Nuclear Regulatory Affairs (NRA) fact sheets were issued afler each violation discussing the violation and irnmediate actions taken.

c. An employee bulletin, "AN IMPORTANT MESSAGE ABOUT TIIE CAAS "

was issued by the General Manager which details actions that occur when a CAAS is declared inoperable and employee responsibilitics.

d. A brochure has been prepared for visitors which desenbes their responsibility when a CAAS is declared inoperable and the evacuation zone is established.

Security issues the bulletin to all visitors.

Public address announcements are made and signs are posted at all open entry e.

portals when a CAAS evacuation zone is established. Signs at portals were originally posted only at shift change,

f. CAAS LCO information is included in General Employee Training, which is received by all new employees upon hiring and during requellfication every other

year,

3. Enforcement actions to be taken were discussed in employee bulletin, " Tile PLANT HAS DONE ALL IT CAN,IT'S NOW UP TO YOU," issued by the General Manager.

111.

Corrective Actions to be Taken

1. USEC will revise procedures and install hardware by October 31,1997, so that continuous flagging will be installed each time a CAAS evacuation zone is established.

IV.

Date of Full Comnliance Full compliance with this violation was achieved on May 14,1997, when personnel were removed from the restricted area. The actions to prevent recurrence will be completed by October 31,1997.

E2 2

.w.-

.,_.....r_

ENCLOSURE 3 UNITED STATES ENIUCilMENT CORPORATION (USEC)

REPLY TO NOTICE OF VIOLATION (NOV) 70 7001/97003-03 Technical Safety Requirements (TSR) 2.3,4.7(b) and 2.4.4.2(b) require that the criticality accident alarm shall be operable in areas where the maximum foreseeable absorbed dose in free air exceeds 12 rad.

Sali ty Analysis Report, Chapter 4, Appendix A, Table 2.51," Criticality Clusters and 13ullding Alarnu " specifies, in part, that criticality accident alann system (CAAS) local clusters "O" and "it" and building horns provide the criticality accident alarms for fluilding C-310.

Miglglion Cited Contrary to the above, on May 18,1997, between 1825 and 1950, the C 310 CA AS building homs were not operable in the areas where the maximum foreseeable dose in free air exceeds 12 rad.

I.

Background Infornation CAAS is used for warning plant personnel of a criticality incident. The systern is designed to detect gamma radiation and provide a distinctive, audible signal which will alert personnel to evacuate the areas that are potentially affected.13uilding horns are used, in addition to local CAAS cluster horns, to provide an aurlible alarm for evacuation.

Solenoid valves open to provide air :o the building homs, operating from either 120 VAC or 125 VDC power from a local distribution panel within the building they support.

On May 18,1997,125 VDC power was lost to all loads on distribution panel 310-AC-13 in lluilding C 310. The design of this 125 VDC power distribution system provides for automatic transfer of the load to a bank of batteries in the event of a loss of nonnal power, llowever, this also failed to occur. This power is required to operate the air solenoids on the C-310 building CAAS homs, and loss of this power rendered that system inoperable. Additionally, the inoperability of the building CAAS horns was not recognized at the time and thus no LCO actions were initiated for this system.

On May 23,1997, this occurrence was determined to be a reportable event and an investigation was initiated. The findings of this investigation have been reported pursuant to 10 CFR 76.120(c)(2) as event report ER 97-10.

Two similar events occurred on July I and July 13,1997, in C-310 when DC alarm power was lost for similar reasons. We are investigating the reasons for the subsequent E31

failures of the DC power system. Further corrective actions may be taken as a result of the investigations 1hc appropriate LCO actions were taken in these two cases.

11.

Reasons for Violation 1he reasons for this violation were:

1. The loss of 125 VDC power to the CAAS building horns is directly attributable to the degraded condition of a fuse in the rectifier supplying normal power and the oxidation of contacts on the power seeking transfer switch which prevented a throwover to backup power.1he loss was also caused by inadequate perfonnance of preventive maintenance associated with the testing of the automatic transfer switch. This test, had it been conducted as scheduled, may have revealed the degraded condition of the transfer switch contacts. These contacts transfer the load to the batteries. The investigation also found that this test was delinquent in the C-335 building.

Additionaliy, there was a lack of enforcement in controlling delinquent preventive maintenance tasks.

2. 1he failure to recognize the need to take LCO actions was due to inadequate guidance for the operators in the event of a DC power loss to the facility, t.nd inadequate awareness on the part of the operators regarding the effects of a loss of DC power.

111.

Corrective Actions Taken and Results Achieved

1. On May 23,1997, Maintenance replaced the control relay of the transfinwitch in C-310. (in combination with a fuse replacement, this allowed normal power to bc restored. CAAS had been operable under backup power.)

2. On June 10,1997, Operations completed the ACR Power Switch Test in C-335 building. (This action was taken to prevent a similar power loss in another building.)

3. Itequired Reading was initiated on July 30,1997, for C 300 and C-310 operators and UF, ilandling Managers to make them aware of this event and to heighten their awareness of the TSR requirements when DC power is lost <

4. On July 29,1997. Engineering completed an inspection, with assistance of Electrical Maintenance, of all DC power transfer systems in C-331, C-333, C-335 and C-337.

The inspection determined the current condition of the transfer relay and the associated fuses to the rectifier of the DC power transfer systems.

IV.

Corrective Steps to be Taken 132

_ _ = _.

The actions to be taken that are listed below are provided in Event Report ER 97-10 and are not new commitments.

1. Ily August 15,1997, Operations will ensure a system of communication of PM status / clear ownership and approvai ofi'M deferral exists.

2. Ily September 30,1997, Reliability Engineering will evaluate (taking into account the results of Corrective Action No.4) and determine the correct preventive maintenance requirements for the transfer relays in C 310, C-331, C-333, C 335, and C-337. This evaluation will also include determining the adequacy of the frequency of the DC power switch test.

3. Ily September 30,1997 Operations will issue an off normal procedure for loss of DC power in C 310.

4. Ily September 30,1997 Operations will issue off normal procedures for loss of DC power in C 331, C 333, C 335, and C 337.

Actions 3 and 4 above will ensure the operators recognize the appropriate actions to take for any future DC power losses.

V.

Date of Full Comollance Full compliance with the specifics described in the NOV was achieved on May 18,1997, at approximately 1950 when power was restored to the CAAS building horns thmugh the backup power source. The actions to prevent recurrence will be completed by September 30,1997.

E3 3

4 ENCLOSURE 4 UNITED STATES ENRICllMENT CORPOR ATION (USEC)

REPLY TO NOTICE OF VIOLATION (NOV) 70 7001/97003 11 10 CFR 76.93, " Quality Assurance," requires, in part, that the certificatee shall establish and execu*e a quality assurance program.

'lhe Quality Assurunce Program, Section 2.5, states, in part, that: 1) "Q" activities affecting safety or quality are prescribed and perfonned in accordance with documented instructions, procedures, or drawings of a type appropifate to the circumstances; and 2) these documents include or reference appropriate quantitative or qualitative acceptance criteria for determining that prescribed activities are satisfactorily perfonned.

Safety Analysis Report, Section 3.15,"Q and AQ Structures, Systems, and Components,"

specifies the criticality accident alarm system (CAAS) as a "Q" system, including building / slave lights and homs for Buildings C 333, C 333 A, C-337, and C-337 A.

Procedure CP4 OP lM6209," Criticality Accident Alarm System Functional Tests," Revisions I and 2, stated purpose was to: " provide instructions to functionally check the CAAS."

Violation Cited Contrary to the above, from March 3 through April 23,1997, the certificatec performed post maintenance functional tests of CAAS for Buildings C 333, C-333 A, C 337, and C-337 A using a procedure which did not include appropriate acceptance criteria for determining that the prescribed activities were satisfactorily performed. Specifically, Procedure CP4-OP lM6209 did not include acceptance criteria to ensure that all of the slave homs associated with Buildings C 333, C 333 A, C 337 and C-337 A CAAS clusters sounded upon an actuation signal.

1.

Backcround Infommtlan Procedure CP4 GP lM6209," Criticality Accident Alarrn System Functional Tests,"

Appendix A did not agree with the Safety Analysis Report (SAR), Chapter 4, Appendix A. The SAR stated C 337 CAAS clusters "V" and "X" are slaved to the homs that C 337 A's 'N" cluster actuates. The SAR also stated that C-333 A's "AA" and "AB" clusters are slaved to all of the C-333 building homs. CP4-GP lM6209 did not show these slaving features of CAAS in those buildings. Since CP4-GP lM6209 is the procedure used to satisfy the quarterly Technical Safety Requirements (TSR) surveillance requirement for testing oflocal cluster homs and building homs, USEC was unable to verify that the slaved horns, as noted above, were tested. This invalidated the past quarterly TSR surveillance requirements for C-333-A and C-337 "V" and "X" ch'sters, which is a violation of TSR Section 1.6.3, Surveillance Requirements.

E41

c 11.

Heason for Violation The primary reasons for the violation concemed deficiencies in drawings, procedures, and training. The following describes how each area contributed to this violation:

Drawings:

Several instrument drawings, used during development of the test procedure, contained no infonnation regarding the slaved relationship of the CAAS homs for the buildings cited. The drawings, both electrical and instmmentation, originally developed for the CAAS high assay upgrade program (llAUP), were developed for Paducah by Oak Iddge.

The drawings produced were treated by Paducah essentially as a turn key project, a cursory review was performed with no field verification, and the drawings placed in the configuration control program existing at that time. This inadequate review by Design IIngineering led to the slaved hom relationship being left otrof the instrument drawings, the electrical drawings, as noted below, were found to be correct. The information missing from the instrument drawings was not incorporated into CP4 OP lM6209. Thus, the surveillances were missed. This was a contributing cause of the inadequate procedure.

Procedures:

Procedure CP4-OP lM6209," Criticality Accident Alann System Functional Tests,"is used to perfonn TSR surveillances on the CAAS. CP4-GP-lM6209, Appendix A.

" Component identification ad 1.ocation," did not show proper slaving relationships for the CAAS building homs e fed. *lhe Action Steps of the procedure only referenced

" verify applicable hom...," making no reference to Appendix A. Since the procedure did not show the location of the slaved homs, they were never checked during the surveillance. The primary reason leading to this finding was that CP4 OP-lM5209 received an inadequate review and validation. Proper review and "in the field" validation would have discovered these slaving issues and they would have been incorporated into the procedure. Inadequacies in the procedure review and validation process also appear to have contributed to this violation.

Training:

Conduct of Maintenance training module,204.11.01, completed on April 15,1997,by approximately 400 Maintenance personnel, discusses the Maintenance Manager's expectations in the areas of accountability, use of the STAR concept (Stop, Think, Act, and Review), and the possession of a questioning attitude. The CAAS training modules discuss slaving features of the CAAS homs; so the Maintenance personnel who have attended these modules and subsequently used CP4-GP lM6209 should have noted the discrepancies between the procedurally expected results and the actual field CAAS hom response based on the infonnation disseminated in the CAAS trainin'g.

E4 2

Ill.

Corrective Actions Taken and Results Achieved I. The Plant Shill Superintendent (PSS) declared C 333, C 337, C 333 A.and C 337 A CAAS inoperable on April 23,1997.

2. TSit surveillances were performed on C-333 A's "AA" and "AB" clusters and C 337's "V" and "X" clusters. The surveillances were completed and C 333, C 337, C 333 A, and C 337 A CAAS was declared operable on April 24,1997.

3. A procedure change on CP4 OP lM6209 was perfonned to include correct slaved horn locations for C 337 and C 333 A. The procedure was effective on April 24, 1997.

4. CAAS safet) system drawings, both Instrument and Electrical, were reviewed to detennine the actual building slaving features and several discrepancies were found dealing with the slaving features. Due to the identified discrepancies, a verification of actual field conditions was performed. The field verification found C 337, C-337-A, C 333 and C 333 A clectrical drawings correct and instrument drawings inconect.

5. All other CAAS component locations listed in CP4 OP lM6209, Appendix A, were reviewed and verified to be co rect.

6. A review of CP4-OP lM4128," Maintenance of the Criticality Accident Alarm System," Appendix B, was performed to detennine if a similar condition existed.

This procedure also required a change, but, since it did not address surveillance requirements, the change will be implemented in conjunction with a revision already in progress on that procedure.

7. Electronics and Calibration personnel reviewed C-720 and C 710 CAAS procedures to detennine if a similar situation existed, and none did.

8. Engineering Notice, EN C-812 97 036, has been issued to address the revisions to the safety system drawings for C-337, C 337eA, and C-333/C-333 A This Engineering Notice was effective on May 21,1997,

9. Procedure CP3 EG E01074, became effective on December 31,1996. This procedure provides guidance for initiating, revising, and approving design and modification documents. Section 6.3 covers the actions necessary to change a drawing. llad this procedure been in place when the drawings were developed by Oak Ridge, Design Engineering would have been required to review the drawings and Oak IUdge to develop the drawings in conformance with a more comprehensive Configuration Management Program process now in existence.

E4 3

J

+

IV.

Corrective Actions to be Talga

1. Procedure CP4-OP lM6209 will be revised by August 18,1997, to ensure each individual CAAS horn, verified to be operating, is documented on a data sheet.

2. Procedure CP4 GP lM4128 will be revised by August 18,1997, to include proper slave horn locations in Appendix D.

3. The procedure change / revision process will be revised by August 29,1997, to require actual field validations ofintent changes to in hand procedures where physically possible.

4. CAAS training modules will be revised by September 8,1997, to casure actual field conditions are covered.

5. Training / Required Reading on proper procedure reviews and validations for plant personnel designated to perform these functions will be performed by September 15, 1997.

6. Using revised CAAS training modules, CAAS training for applicable Maintenance personnel will be conducted by October 13,1997.

7. Field walkdown of CA.AS drawings will be performed by September 26,1997, to ensure proper hom locations (column number).

8. Instrument CAAS safety system drawings will be revised by December 12,1997, as necessary, to incorporate discrepancies noted during field verification of drawings.

9. Electrical CAAS safcty system drawings will be revised by December 12,1997, as necessary, to incorporate discrepancies noted during field verification of drawings.

V.

Date of Full Complinnes Full compliance with this violation was achieved when procedure CP4-Op-lM6209 was changed to include correct slaved horn features, and when TSR surveillance testing on C 333 A's "AA" and "AD" clusters and C-337's "V" and "X" clusters were completed on April 24,1997. The corrective actions taken to prevent recurrence will be completed by December 12,1997.

E4 4

ENCLOSURE 5 UNITED STATES ENRICllhiENT CORPORATION (USEC)

IESPONSE TO NOTICE OF VIOLATION (NOV) 70 7001/97003 13 10 CFR 76.93. " Quality Assurance," requires in part, that the certificatee shall establish and execute a quality assurance program.

'lhe Quality Assurance Program, Section 2.16. " Corrective Action," requires,in part, that for significant conditions adverse to quality, the cause of the condition is determined and corrective action is taken to preclude recurrence.

Procedure UE2 llR Cl1031, Revision 0, dated August 31,1996,"CORIECTIVE ACTIONS,"

defined, in part, that a significant condition adverse to quahty included: 1) unauthorized changes to attributes of a procedure that implements nuclear criticality safety requirements; and 2) problem trends that have a strong potential to lead to issues of significance.

Violation cited Contrary to the above, from hiarch 3 through hiay 6,1997, the certificatee did not determine the cause for or take corrective action to preclude recurrence of a significant condition adverse to quality. Specifically, the certificatee did not: 1) identify that a hfarch 3,1997, intemal memorandum made an unauthorized change to a procedure which implemented nuclear criticality safety (NCS) approval, OEN 27; and 2) determine the root cause for and take corrective actions to preclude the recurrence of violations of the NCS approval GEN 27 in Building C-720.

1.

1]ackcround infomiation NCSA GEN 27, "llandling and Storage of Legacy Process Equipment," provides the requirements necessaiy to bring uncontrolled legacy process gas equipment into compliance with the double contingency principle, This NCSA is implemented through plant pmcedure CP2 TS TS2030, "llandling and Storage of Legacy Process Equipment."

An NCS memorandum indicating that NCSA GEN 27 did not apply to untagged process Equipment in C 720 was issued on hiarch 3,1997.

LL Reason for the Violation The reason for the violation is the lack of fonnal guidance for NCS to follow when providing interpretations to operations regarding the applicability of an NCSA. The potential for circumventing Plant Operations Review Committee (PORC) approval when providing interpretations of NCS A requirements was not recognized since a screening method was not available. The hiarch 3,1997, NCS memorandum was created to interpret ar.1 clarify the applicability of requirements in NCSA GEN 27 and procedure ES l

CP2 TS TS2030 to the equipment in C 720 based on other documents that controlled that equipment. The lack of a screening method subsequently caused the failure to identify the for the unauthorized change in the applicability of NCSA GEN 27 and implement conective actions to preclude the recurrence of violations of NCSA GEN 27 and procedure CP2 TS TS2030 in Building C 720 as required in the Quality Assurance Plan.

111.

Cortcetive Actions Taken and Results Achieved I. A site wide walkdown was completed on June 23,1997,in an effort to identify OEN.

27 equipment and to bring it into compliance with NCSA OEN 27 and CP2 TS.

TS2030. The identified equipment was then handled according to NCSAs GEN 27 or OEN 20 based on the equipments odgin.

2. An Engineering Notice (EN C 832 97 011) was issued on May 29,1997, which rescinded the March 3,1997, memorandum and reestablished the applicability of GEN 27 to C 720 and all plant facilities.

IV.

Corrective Actions to be Taken

1. Issue a procedure by October 27,1997, to govem the conduct of operations for the Engineering Function which specifically addresses the issuance of engineering guidanec/interpretatiens and establishes the appropriate level of approval for that

guidance,

2. Perfonn a crew briefing for all NCS staff members by August 8,1997, to ensure all members are following procedure CP3 EG E01080," Engineering Notices." This procedure is applicable to transmit data, justify a specific course of action or to provide the results of an engineering evaluation and is to be used only for the transfer ofinformation outside of other proceduralized activities.

3. By August 29,1997, review all retrievable memorandums by August 29,1997, sent by NCS staff since April 1,1996, to determine if other guidance that could have been an unauthorized change to the applicability requirements of an NCS A or procedure exists, it is not necessary to review memorandums sent prior to this date since all currently implemented NCSAs were issued subsequent to April 1,1996.

V.

Date of Full Comnlinqqs Full compliance was achieved on May 29,1997, when the Engineering Notice EN C-832 97-01I was issued which rescinded the March 3,1997,intemal memorandum. 'Ihe actions to prevent recurrence will be completed by October 27,1997.

ES 2

- - - - - ~

ENCLOSURE 6 LIST OF COMMITMENTS Ettelosure 1

- 1. A review of other similar TSRs (2.1,2.2. 2.3. 2.5 and 2.6) will be performed to detennine if the fonnat of these TSR requirements present a challenge to personnel to properly execute the requirements, similar to the problem presented by 2.4.4.2 in C.

310 (specifically, different requirements located in separate TSR sections for a single system required to be operable by the TSR). 'Ihis will be completed by August 8, 1997.

2. We will submit TSR changes to TSR 2.4 and 2.3 to NRC for approval making the editorial change ofcross referencing the Required Actions of these two TSR sections as applicable to CAAS in C 310. This will be completed by October 7,1997.

3. We will change procedure CP2 CO CN1031." Tracking ofinoperable Structures, Systems, and Components," to require that the plant shift superi'itendent (PSS) discuss the specific required TSR actions with the affected front line manager prior to declaring a TSR required system inoperable for planned work or systern inoperabilities due to emergent conditions. Thir. will be completed by September 30, 1997.

l. USEC will revise procedures and install haidware by October 31,1997, so that continuous flagging will be installed each time a CAAS evacuation zone is established.

The actions listed below are not new commitments, but come from Event Report ER 9710.

1. By August 15,1997 Operations will ensure a system ofcommunication of PM status / clear ownership and approval of PM deferral exists..

2. By September 30,1997 Reliability Engineering will evaluate (taking into account the results of Corrective Action No.1) and determine the correct preventive maintenance requirements for the transfer relais in C-310, C 331, C 333, C-335, and C 337. 'Ihis evaluation will also include detennining the adequacy of the frequency of the DC power switch test.

E61

3. lly September 30,1997, Operations will issue an o!T nonnal procedure for loss of DC power in C 310,

4. By September 30,1997, Operations will issue off nonnal procedures for loss of DC power in C 331 C 333,C 335, and C-337.

Enclosurta

1. Procedure CP4 OP.lM6209 will be revised by August !8,1997, to ensure cach individual CAAS hom, verified to be operating, is documented on data sheet.

2. Procedure CP4 GP !M4128 will be rev! sed by August 18,1997, to include proper slave hom locations in Appendix II,

3. Procedure change / revision process will be revised by August 29,1997, to require actual field validations ofintent changes to in hand procedures where physically possible.

4. CAAS training inodules will be revised by September 8,1997, to ensure actual field conditions are covered.

5. Training / Required Reading on proper procedure reviews and validations for plant personnel designated to perform these functions will be perfonned by September 15, 1997.

6. Using revised CAAS training modules, CAAS training for applicable Maintenance personnel will be conducted by October 13,1997.

7. Field walkdown of CAAS drawings will be performed by September 26,1997, to ensure proper hom locations (column number).

8. Instrument CAAS safety system drawings will be revised by December 12,1997, as necessary, to incorporate discrepancies noted during field verification of drawings.

9. Electrical CAAS safety system drawings will be revised by December 12,1997, as necessary, to incorporate discrepancies noted during field verification of drawings.

EDelosure 5

1. Issue a procedure by October 27,1997, to govern the conduct of operations for the Engineering Function which specifically addresses the issuance of engineering guidance / interpretations and establishes the appropriate level of approval for that guidance.

E6-2

_7._ _ _

2. Perfonn a crew briefing for all NCS stafimembers by August 8,1997, to ensure all members are following procedure CP3 EG E01080," Engineering Notices"."'This procedure is applicable to transmit data, justify a specifle course of action or to provide the results of an engineering evaluation and is to be used only for the transfer ofinfonnation outside ofother proceduralized activities, d

3. lleview all retrievable memorandums by August 29,1997, sent by NCS staffsince April 1.- 1996, to detenn!ne if other guidance that could have been an unauthorized change to the applicability requirements of an NCSA or procedure exists. It is not necessary to review memorandums sent prior to this date since all currently implernented NCSAs were issued subsequent to April 1,1996. Any problems discovered during this review will be documented in problern reports for conection.

1 1

E6 3

- -.