ML20217P236
| ML20217P236 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 04/27/1998 |
| From: | Jonathan Brown UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-7002-98-04, 70-7002-98-4, GDP-98-2016, NUDOCS 9805060175 | |
| Download: ML20217P236 (7) | |
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'USEC A Global Energy Company April 27,1998 GDP 98-2016 United Sta'es Nuclear Regulatory Commissicn Attention: Document Control Desk Washington, D.C. 20555-0001 Portsmouth Gaseous Diffusion Plant (PORTS)
Docket No. 70-7002 Reply to Notice of Violation (NOV) 70-7002/98004-01 and 02 a,b,c,d The subject Inspection Report (IR) contained two violations: 1) Failure to stop work during an I&C Maintenance activity when procedural steps could not be adhered to, and '2) Failure to initiate problem reports for safety, operating, and regulatory noncompliance issues to ensure corrective actions are tracked and implemented for the issues.
USEC's response to these violations is provided in Enclosures 1 & 2. Enclosure 3 lists the commitments made in this report. Unless specifically noted, the corrective actions specified in each enclosure apply solely to PORTS.
If you have any questions regarding this submittal, please contact Dave Waters at (740) 897-2710.
Sincerely,
. Morris Brown General Manager Portsmouth Gaseous Diffusion Plant
Enclosures:
As Stated
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NRC Region III Office h
NRC Resident inspector-PORTS O
9905060175 990427 7
PDR ADOCK 07007002:
C PDR GlJ7 P.O.130x 800, Portsmouth, OH 45661 Telephone 614-897-2253 Fax 614-897-2644 http://www.usec.com Offices in Livermore, CA Paducah, KY Portsmouth, OH Washingon, DC
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GDP 98-2016 Page1of2 UNITED STATES ENRICllMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV),70-7002/98004-01 Restatement of Violation Technical Safety Requirement 3.9.1, requires, in part, that written procedures shall be implemented j
for nctivities described in Safety Analysis Report, Section 6.11.4.1, and listed in Appendix A, to Santy Analysis Report, Section 6.11 Apper. dix A, to Safety Analysis Report, Section 6.11 requires, in part, that procedure management activities shall be covered by written procedures.
Procedure UE2-PS-PS1034,"Use of Procedures," Revision 1, Change B, Section 6.2 requires, in part, that each procedure step in an In-Hand procedure is performed as written. If the activity cannot be performed as described, the following actions must be performed: stop the work activity; place the system in a safe condition; mark procedure step last perfonned; notify the appropriate manager for direction; and, if necessary, request or initiate procedure change or revision according to UE2-PS-PS-1031.
Contrary to the above, on March 5,1998, during the performance ofIn-Hand Procedure XP4-CU-IM6100, "X-705 Test and Calibration of Calciners High-High Temperature Shutdown " the work group did not stop work when Section 8.3.12 of the Procedure XP4-CU-IM6100 could not be
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performed as written. Specifically, Section 8.3.12 of Procedure XPLCU-lM6100 required the work group to verify the volt / ohm-milliammeter indicated 80 to 120-volts AC. The volt / ohm-milliammeter indicated 124-volts AC during the completion of Section 8.3.12 of Procedure XP4-CU-IM6100, and the group did not stop work and continued to progress through the action steps of the procedure.
USEC Response I.
Reason for Violation The root cause for the violation is the First Line Manager (FL.M) gave the Instrument &
Control (I&C) mechanics improper direction to continue the work. The same high voltage condition had been observed several times previous to this event. The reading obtained was assumed to be technically satisfactory because line voltage does vary widely throughout the plant. However, the assumption was not formally confirmed by Engineering and procedure XP4-CU-lM6100 was not revised. A review of each of these individual's training records showed that each work group member received training in the use of procedures which should have prevented this situation.
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Corrective Actions Taken and Results Achieved 1.
On March 5,1998, the FLM notified both the Maintenance Group Manager and System Engineer of the situation and both individuals instructed the FLM to stop work until procedure XP4-CU-IM6100 could be revised. The FLM stopped work on i
the #1 calciner and the #1 calciner is currently out of service and will remain out of service until completion of the TSR required surveillance accomplished by XP4-CU-IM6100.
2.
A lessons learned was develo,)ed and presented to all maintenance personnel l
emphasizir,g management's expectations of the use ofin-hand procedures. These expectations were re-emphasized in our industry transition training classes which l
were presented to maintenance FLM's and craft personnel.
3.
The FLM was disciplined regarding the inappropriate direction given to continue procedure use with the out of spec reading.
Ill.
Corrective Steps to be Taken L
No further corrective actions are required.
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IV.
Date of Full Compliance l
Full compliance was achieved on March 5,1998, when the work activity was stopped by the FLM.
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GDP 98-2016 Page1of3 UNITED STATES ENRICIIMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/98004-02 a,b,c,d Restatement of Violation Technical Safety Requirement 3.9.1, requires, in part, that written procedures shall be implemented i-for activities described in Safety Analysis Report, Section 6.11.4.1.
Section 6.11.4.1 of the Safety Analysis Report states, in part, that: "As a minimum, a procedure is required for any task that is described in, or implements a commitment that is described in, the Safety Analysis Report..."
Section 6.8.2.4 of the Safety Analysis Report," Problem Reporting," requires, in part, that: "All plant employees have the responsibility to write problem reports on safety, operating, and noncompliance items... Corrective actions are tracked through the plant's corrective action program."
Procedure UE2-IIR-C11030, " Problem Reporting," Revision 0, Change E, dated April 1,1996, Section 2.0, " Applicability," requires, in part, "That if there is any question as to whether or not to initiate a Problem Report (PR) for a given situation, a PR shall be initiated. Examples of problems include, but are not limited to violations of, or deviations from, programs, policies, and procedures or deficiencies which could cause safety, operability, or reportability concems." Step 6.1.3.A requires that the problem report form be delivered to the Plant Shift Superintendent as soon as l
practical, but always prior to the end of the shift.
Contrary to the above, from September 9,1997, through March 5,1998, the certificant did not initiate and deliver problem report forms to the plant shift superintendent by the end of the shift for the following examples of problems (Violations of, or deviations from, programs, policies, and l
procedures or deficiencies which could cause safety, operability, or reportability concerns):
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a.
Plant staff did not initiate problem reports for deviations of the required quaiterly face velocity measurement tests for laboratory fume hoods utilized for various operations in the Building X-710 Laboratory upon initial discovery. Problem reports were filed after questions were raised by the NRC inspections.
b.
A transportation violation was identified on September 9,1997, by a Paducah transportation specialist regarding a shipment of cylinders with residual uranium hexafluoride originating; form the Portsmouth Gaseous Diffusion Plant. Portsmouth Packaging and Transportation staff were notified of the non-compliance and were faxed information regarding the transportation violation.
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GDP 98-2016 Page 2 of 3 l
c.
A transportation violation was identified on December 16,1997, by a Paducah Transportation specializ receiving an " excepted package-empty packaging" shipment from the Portsmouth Gaseous Diffusion Plant.
Portsmouth Packaging and Transportation and Plant Shift Superintendent staff were notified of the non-compliance and were faxed information regarding the transportation violation.
d.
A transportation violation was identified on January 23, 1998, by a Paducah Sansportation Specialist regarding a shipment of cylinders with residual uranium hexafluoride originating form the Portsmouth Gaseous Diffusion Plant. Portsmouth Packaging and Transportation staff were notified on the non-compliance and were faxed information regarding the transportation violation.
I.
Reasons for Violation Exampic (a)
The reason for Example (a) of the violation was the X-710 Laboratory staff thought the fume hoods were within the allowed testing frequency and did not submit prs since a conflict in the testing frequency between the Chemical Hygiene Plan and the SAR was not recognized.
The Chemical Hygiene Plan makes reference to completing surveillance testing within three months (quarterly) and the SAR describes an extension period which is within 123 days of the last date tested. Therefore, the fume hoods inadvertently exceeded their allowed testing s
frequency.
Examples (b,c,d)
The reason for Examples (b,c,d) of the violation was procedures UE2-HR-CIl030 " Problem Reporting," and XP4-SF-SF-ll10 "PSS Actions on Problem Reports, "does not contain specific guidance for reporting and processing dual site PR issues.
H.
Corrective Actions Taken and Results Achieved Example (a) 1.
The X-710 Laboratory walked down each fume hood location to verify the last completed test date. The X-710 Laborat.y staff submitted prs on March 6,1998, for all fume hoods identified to be out of compliance with their allowed testing period. Concurrently, fume hoods found out ofcompliance with their allowed testing period were satisfactorily tested on March 6,1998, by Maintenance personnel.
GDP 98-2016 Page 3 of 3 2.
Group briefs and/or required reading were given to the X-710 Laboratory staff on surveillance frequency definition. Also, management's expectations included new directions for identifying a problem and writing prs associated with laboratory fume hoods.
i Examples (b,c,d) 3.
PR-PTS-98-01589 was written on March 6,1998, to document the Paducah transportation concems identified in the cited violation. These concems of cylinders being incorrectly marked, incomplete evidence packages, and labels mistakenly transposed were corrected by Portsmouth, llowever, corrective actions were originally initiated within days of the Paducah PR being written. Prompt open discussions between the Portsmouth and Paducah Operations and Packaging and Transportation staffs quickly resolved these issues.
4.
Procedure XP4-SF-SFl110 "PSS Action on Problem Reports," has been revised to include a requirement to screen Paducah prs for applicability at Portsmouth and write a PR ifissues are identified. This action was completed on March 31,1998.
5.
The Paducah prs are transmitted electronically to every Organization Manager daily for them to review any concerns reported at Paducah for applicability to Portsmouth.
III.
Corrective Steps to be Taken Example (a) 1.
The Chemical liygiene Plan allowed testing period will be revised by April 30,1998.
This will make this plan consistent with the surveillance frequency definition in the SAR.
Examples (b,c,d) 2.
A procedure is currently being created to replace UE2-HR-C11030 to provide additional guidance for writing a PR for issues applicable to Portsmouth as well as issues originating at Portsmouth. The procedure is scheduled to be completed by June 30,1998.
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GDP 98-2016 Page1of1 Reply to Notice of Violation (NOV) 70-7002/98004-01 and 02 a,b,c,d List of Commitments l
NOV 98004-02 a.b.e.d l
l 1.
The Chemical Hygiene Plan allowed testing period will be revised by April 30,1998. This will make this plan consistent with surveillance frequency definition in the SAR.
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2.
A procedure is currently being created to replace UE2-IIR-C11030 to provide additional l
guidance for writing a PR for issues applicable to Portsmouth as well as issues originating i.
at Portsmouth. The procedure is scheduled to be completed by June 30,1998.
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