ML20217P414
| ML20217P414 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 04/30/1998 |
| From: | Toelle S UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Pederson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| GDP-98-0094, GDP-98-94, NUDOCS 9805060277 | |
| Download: ML20217P414 (12) | |
Text
{{#Wiki_filter:._ c USEC A Global Energy Company April 30,1998 GDP 98-0094 Ms. Cynthia Pederson, Director Division ofNuclear Material Safety United States Nuclear Regulatory Commission 801 Warrenville Road Lisle, Illinois 60532-4351 Portsmouth Gaseous Diffusion Plant (PORTS) j Docket No. 70-7002 t Portsmouth Nuclear Criticality Safety Program Revised Corrective Action Plan - Quarterly Status Report i
Dear Ms. Pederson:
I USEC letter GDP 97-0217, dated December 22,1997, provided the Nuclear Regulatory Commission (NRC) with a revised Corrective Action Plan for the Portsruouth Nuclear Criticality Safety (NCS) Program. In this letter, USEC committed to provide NRC with a quarterly status report of this Corrective Action Plan. Accordingly, enclosed is the quarterly status report of the Portsmouth NCS Program Corrective Action Plan (CAP) for the period February 1,1998, through Apnl 27,1998 (i.e., the cut-off date for this report). j In response to NRC Notice of Violation 70-7002/97-013 (reference USEC letter GDP-98-0076, dated April 17,1998), USEC committed to evaluate the CAP to determine if additional actions are required. Accordingly, USEC is currently revising the NCS CAP to include six (6) new tasks as follows: Addition of NCS Field Operational Assistants; Fissile Material Operation Identification; Comparing the Safety Analysis Report Chapter 5.2 to Applicable Industry Standards and the NCS Program; NCS Short-Term Corrective Actions; i Planned Expeditious Handling (PEH) Deposit Surveillance Tracking; and, l Compliance Plan Review. n ,; e.v x a G 6903 Rockledge Drive, Bethesda, MD 20817 1818 g Telephone 301-564-3200 Fax 301564-3201 http://www.usec. corn QO \\ l 9805060277 98043'O ' - h. KY Portsrnouth, OH Washington. DC ^ PDR ADOCK 07007002 C PDR
MslCynthia Pederson April 30,1998 GDP 98-0094, Page 2 The revised NCS CAP, reflecting the new tasks listed above and the satusif the remaining tasks as described in this submittal, will be provided to NRC by May 7,1998 Additionally, USEC has scheduled a meeting with the NRC to discuss the status and implemenstion of the NCS CAP on May 15,1998. ~g, g If you have questions regarding this submittal, please contact Dave Waters at (740) 897-2710. Sincerely, s.o.6 A g Steven A.Toelle Nuclear Regulatory Assurance and Policy Manager Enclosure B cc: NRC Document Control Desk NRC Resident Inspector - PGDP NRC Resident Inspector-PORTS NRC Special Projects Branch DOE Regulatory Oversight M.: nager l
o Enclosure P GDP 98-0094-m age 1O N . p.4 April 1998 Quarterly Status Report of the PORTS Nuclear Criticality Safety Program Corrective Action Plan I. Purpose ~ .m To convey the status of the tasks in the Nuclear Criticality Safety'(NCS) Corrective Action Plan (CAP) II. Scope This report documents the results of a review of the NCS CAP. This review evaluated the adequacy and effectiveness of the Plan and the products of the Plan with respect to scope, implementation, prioritization, and scheduling. Also considered and incorporated are the findings from Safety, Safeguards, and Quality (SS&Q) assessments of the CAP (refer to Task 17 of the Plan). Section IV " Details," describes the subject, status, and the results of USEC's review. III. Executive Summary During this reporting period, USEC submitted to NRC two letters (i.e., GDP 98-0033 dated February 2:' 1998, and GDP 98-0053 dated March 20,1998) informing NRC of changes in the - due dates for several tasks of the NCS CAP. Specifically, the due dates for the following tasks were extended as follows: Task 2, " Review of NCSA/Es completed by Non-qualified Personnel was extended from February 28, 1998 to April 30, 1998. This task has been subsequently completed. Task 3, "NCSA/Es Upgrade Project" was extended to December 31,1998, for Priority 1 NCSAs; June 22,1999, for Priority 2 NCSAs; and May 31,2000, for Priority 3 NCSAs; Task 5,"SS&Q Review ofImplementation," was extended to February 15,1999, for Priority 1 NCSAs; August 15,1999, for Priority 2 NCSA's; and July 15,2000, for Priority 3 NCSAs; Task 8, " Vertical Slice Review," was extended to May 31,1998; and, Task 16, " Revise Assessment Programs," was extended to October 30,1998.
/ ~ 1 i Enclosure GDP 98-0094 Page 2 of10 Additionally, Task 10 " Personnel Qualification Verification" was scheduled for completion on March 31,1998. This task was completed as scheduled. However, in response to examples "B" and "C" of NRC NOV 70-7002/97013 (see USEC letter GDP 98-0076 da:ed April 17,1998), USEC identified some deficiencies in the documentation of training requirements fot NCS contractors and engineers. Therefore, USEC is keeping this task "open" and has extended the j completion date of this task to July 27,1998, to be consistent with the committed corrective action due dates for examples "B" and "C" of NOV 70-7002/97013. 1 Esch of the tasks of the CAP is proceeding according to schedule. Additional resources are being allocated for Task 3 to recover the schedule. Several new tasks (i.e.,20 through 25) are being added to the NCS CAP as a result of an internal review in accordance with Task 18, " Evaluation and Feedback." One of the new tasks (i.e., Task 23,"NCS Short-Term Corrective Actions') has been added to provide short-term compensatory actions to address recent NCS violations such as those described in NOVs 70-7002/97013 and 98003. IV. Details The following information is grouped according to the tasks listed on Table 2 of the NCS CAP, Revision 2. The cut-of1'date for this report is April 27,1998. Task 1 Facility Review of Nuclear Criticality Safety Target Date: 12/24/97 Assessments / Evaluations (NCSA/E) Complete. Task 2 Review of NCSA/Es Regarding Qualifications Target Date: 4/30/98 Complete. The review of NCS evaluations performed by "unqualitied" NCS Engineers determined that three NCSA/Es required immediate com:ctive action. These three NCSA/Es were revised and PORC approved by April 27,1998. An additional action has been identified in the effort to assemble the closure documentation for this task. There are some calculations that were done by the " unqualified" NCS Engineers. These calculations are currently being reviewed and a completion date is being determined. Task 3 NCSA/Es Upgrade Project Target Date: Priority 1,12/31/98 Priority 2, 6/22/99 Priority 3, 5/31/00 On-going. Additional NCS Engineers are being added to help recover the schedule.
E Enclosure GDP 98-0094 Page 3 of 10 1 Task 4 Enhance NCSA/E Training (Interim Process) Target Date: 2/28/98 l - Complete. This task isempneWecause the training module is given to individuals as they become involved with the NCS CAP. Task 5 SS&Q Review ofImplementation Target Date: Priority 1, 2/15/99 Priority 2, 8/15/99 Priority 3, 7/15/00 On-going. Two NCSA/Es have been completed and implemented to the point where SS&Q could monitor the implementation of the NCSA/E in the field. One NCSA/E has been walked down and found to be fully and correctly imnlemented. The second is in the process of being walked-down. Task 6 Complete Comprehensive Root Cause Analysis Target Date: 2/28/98 Complete. The root cause analysis was completed, the results were analyzed and a report was prepared (POEF-945-98-031, dated February 16, 1998). This analysis concluded the rush to meet schedules resulted in confusing, incomplete, unclear and ambiguous standards. Task 7 Compare Applicable Industry Standards Target Date: 1/31/98 Complete. The review of Industry Standards compared to the NCS Program identified 45 specific ANSI requirements for which there were not complete programmatic controls in the NCS procedures. A problem report was prepared and the results of the review are being included in the Task 12 activities for revising procedures. Task 8 Vertical Slice Review Target Date: 5/31/98 On schedule. The assessment team has nearly completed the venical slice review using five NCSA/Es as the means to review the program. Task 9 Continuous Improvement Program Target Date: 1/31/98 Complete. The lessons learned program is ongoing. A total of twenty lessons leamed have been processed. 1 1
sm ~ Enclosure GDP 98-0094 Page 4 of10 Task 10 Personnel Qualification Verification Target Date: 7/27/98 On schedule. The review of industry guidance on the qualifications of NCS Engineers was completed by March 31,1998, as originally committed. However, in the response to examples B and C of NOV 70-7002/97013, USEC committed to reevaluate and upgrade the training and qualification program for the NCS organization 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. Task 11 Outside/ Independent Assessments Target Date: 4/30/98 Complete: The review of previous assessment reports prepared by outside/ independent personnel is complete. Results were tabulated, a Problem Report was written and findings were forwarded for incorporation into Task 12 procedure upgrades. Among the potential programmatic enhancements identified were improvements to the documentation regarding Criticality Accident Alarm Systems locations; administrative changes to the quarterly validation of NCS sofnvare; and a change to the NCS evaluation procedure to require a safety basis in the NCSE before adding a control to the NCSA. Task 12 Policy / Procedure Revision and Training Target Date: 12/31/98 On schedule. The following procedures have been issued or revised to date: Procedure XP2-EG-NS1031, " Nuclear Criticality Safety," was revised to address responses to NCS anomalous conditions. Procedere XP4-EG-NS1102, " Nuclear Criticality Safety Personnel Qualifications," was revised to address issues raised through Task 10, Personnel Qualification Verification. A new procedure XP2-EG-NS1033, " Nuclear Criticality Safety Murder Board Committee," was issued. Procedure revisions currently in process are: Tasks 7 and 11 enhancenients are being written into four procedure revisions 1 -~
~ Enclosure GDP 98-0094 Page 5 of10 Developing additional NCS program procedure upgrades which include: Y-{ Upgrade of XP2-EG-NS1031 to enhance program ownership and,.gQ*J implementation; ~ 'l Upgrade of XP4-EG-NS1001, " Nuclear Criticality Safety Eva'uation and Approval," to incorporate hazard identification and evaluation { methods; Creating new procedures for tmking/ trending of NCS violations; j configuration control of NCS calculational software; guidance to NCS engineers for response to off-normal and emergency conditions; plant-level NCS training; and peer review; Upgrading XP4-EG-NS1102 to incorporate new NCS personnel training.and qualification requirements based on new process requirements and revised SAT evaluations. Task 13 Revise Training Program for Site Personnel Target Date: 4/30/98 l (Subksk 13.5) Complete. Fifteen training modules have been developed and 586 employees have been trained using these modules. The new process requires training development on specific NCSAs to commence following PORC approval of the NCSA and associated flowdown procedure (s). The SAT approach is used for training module development with at least one module developed for each new or upgraded NCSA. The goal of the training is to ensure personnel are made aware of the cognizant requirements and limitations established by the NCSA, their specific location in associated procedures, and any significant changes that were made. Plant NCSAs are evaluated on a case-by-case basis to ensure all affected w irk groups receive the needed training. Task 14 Corrective Action Program Enhancements Target Date: 6/30/98 On schedule. A cross-functional team was established to revamp the corrective action process. Changes have been made to the Corrective Action Review Board to increase the level of rigor in the root cause evaluation process and the development of corrective action plans. Task 15 Configuration Management Program Target Date: 2/28/98 Enhancements Complete. Procedure XP2-EG-CF1031," Implementing Action Worksheets," was originally implemented on February 28,1998. Subsequently, on March 6,1998, the
Enclosure GDP 98-0094 Page 6 of 10 procedure was placed on hold to correct the scope, designate the procedure " Regulatory, and provide additional training. The procedure was revised, resubmitted for plant-wide review, approved, and implemented as Revision 1 on April 22,1998. A group briefing was presented to 22 Engineering and plant personnel to familiarize them with the requirements of the procedure. Task 16 Revise Assessment Programs Target Date: 10/30/98 On schedule. A cross-functional team (including Quality Systems, Operations, Engineering, and Production Support) was established to revise the plant's several assessment processes. Activities in progress include: The overall expectations for all assessment programs is complete. Revisions to the Management-By-Walking-Around and Independent Assessments are in review. The team is providing support to the NCS group revising the NCS assessment and walk-through program as part of the overall revision of the NCS program procedure. The Organization self-assessment program procedure is being revised. Task 17 Oversight of Plan Implementation Target Date: 4/30/99 (Bi-monthly) On schedule. Thirteen surveillances of the NCS Corrective Action Plan have been done since January 27,1998. The focus of the surveillances has been on determining the completion of CAP tasks. The focus of the future surveillances will be shifted to determining the actual effectiveness of the plan in achieving compliance with NCS requirements in the field. Task 18 Evaluation and Feedback Target Date: Quarterly starting on 1/31/98 On schedule. The results of this evaluation are include.d, as applicable, into the specific various tasks of this CAP.
+ ... l Enclosure GDP 98-0094 Page 7 of10 Task 19 Evaluate Continued Use of Murder Board TagetDate:Notbefore 5/31/98 On schedule. The Murder Board is being used as described in the NCS CAP. This is an ongoing activity. Activity D.7 Response to Anomalous NCS Conditions Target Date: 2/11/98 2 Complete. The requirements of this task have been implemented via a standing order and training. Additionally, procedure XP2-EG-NS1031, " Nuclear Criticality ~ ", Safety," was revised to address responses to NCS anomalous conditions as described in the standing order. Activity D.8 NCS Oversight on the Operating Floors Target Date: 2/2/98 Complete. Five Field Operational Assistants (FOAs) were assigned to the Cascade Buildings to heighten awareness of the importance of NCS controls. Since this action was taken, USEC has determined that additional NCS oversight on the + Operating Floors is warranted. Due to the significance of this activity, a new task (i.e., Task 20, "NCS Field Operational Assistants") is being created and will be incorporated into Revision 3 of the NCS CAP. Further discussion of this task is provided below. Task 20 NCS Field Operational Assistants (FOA) Target Date: 6/15/98 This is a new task which will be reflected in Revision 3 to the NCS CAP. The FOAs, including the ones discussed in Activity D.8 above, report to the Assistant Plant Shift Superintendent, with technical guidance from NCS, and are currently assigned to each rotating shift. The FOAs have been tasked with providing additional field presence to identify nuclear criticality safety issues and support operations regarding nuclear criticality safety concerns. Their presence in the buildings has helped as a liaison between Operations and NCS and in general cleanup of the buildings. This helps eliminate the potential for NCS violations. Qualification cards have been developed for the FOAs. Task 21 Fissile Material Operation (FMO) Identification Target Date: 10/23/98 This is a new task which will be reflected in Revision 3 to the NCS CAP. A short- 'l term review of FMOs which are not covered by a NCSA was completed by reviewing a canceled NCSAs and verifying that those operations were indeed shut down. A
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- z Enclosure GDP 98-0094 Page 8 of10 methodology for documenting a more thoraugh review has been prepared and is in the process of being proceduralized. In addition, this procedure will establish the mechanism to communicate to the field which operations are fissile and non-fissile I
using a controlled document. Task 22 Compare SAR Chapter 5.2 to Applicable Target Date: 6/15/98 Industry Standards and the NCS program This is a new task which will be reflected in Revision 3 to the NCS CAP. The purpose of this task is to ensure that all documentation that describes the NCS program is consistent between SAR Chapter 5.2, industry standards, and NCS program documents. The subtasks of this task cre: l Compare requirements list generated under Task 7 to SAR Section 5.2 and ensure the SAR does not confr ' with standards. Compare SAR Section 5.2 to plant NCS procedures and if necessary develop a discrepancy list. Evaluate discrepancies for need for immediate action, a problem report, reperting, and then take appropriate action. Develop long term programmatic enhancements for input to Task 12. Task 23 NCS Short-Term Corrective Actions Target Date: N/A This is a new task which will be reflected in Revision 3 to the NCS CAP. Due to the continued number of NCS violations and subsequent NRC event reports, USEC has insthuted a series of short-term (quickly implem:nted) corrective actions that focus on the recent and current problem reports in an effort to stop the violations. These short-term compensatory actions are intended to allow time for the long-term NCS program upgrade actions to take hold. The following information describes these short-term actions: Require that all work packages include specific action steps / check sheets (consistent with approved procedures) for disposal of scrap or waste generated during the job. This action is intended to ensure jobs involvi4 potentially fissile material and/or waste have adequate guidance in the work packages with respect to how to handle and store potentially fissile wastes. Add some " operating margin" to items that are stored under administrative spacing requirements. (Areas where it is physically impossible to do this are exempt). This action is intended to look for areas where NCS controls (such
I w Enclosure i GDP 98-0094 Page 9 of 10 as spacing) could be enlarged to give personnel some operating margin prior to reaching a limit. For example, if the requirement for spacing is a minimum 2 feet edge-to-edge, the storage arrays should preferably be greater than 2 feet. Institute pre-job briefs for all NCS related activities to discuss the NCS requirements of the job. This action is intended to ensure that prior to starting ajob involving potentially fissile material the workers performing the job have aduquate guidance in where to put the waste, the workers are briefed on the associated NCS controls, and there are adequate storage locations ready to receive the waste. Revisit pre-job briefing activities to ensure adequate follow-on implementation guidance / procedure is in place, and pre-job briefings are consistent plant-wide. This action is intended to ensure that the improvements to pre job briefings were consistent across the plant, and that they continue. Review all storage areas to ensure NCS compliance (this was done in conjunction with the task described in the second bullet concerning addinr. " operating margin" to items that are stored under administrative spacing 1 requirements). Revise NCSA Plant 18, " Dry Active Waste," and NCSA Plant 48, " Contaminated Metals," to establish short term improvements. This action is intended to correct the most frequent sources of NCSA compliance issues. Conduct a building by building clean up to eliminate scrap. This action is intended to get rid of excess material in the process buildings and to minimize the material available that could potentially lead to violations of NCS requirements. Establish controls over all aspects of storage areas such as: boundaries, access permits, postings. This action is intended to address the apparent inconsistent and/or informal implementation of NCS waste s.torage areas across plant site. Guidance has been provided to the field for boundaries, access permits, and postings. Field personnel are currently evaluating and implementing changes to the storage areas. However, this is becoming less of an issue as the storage areas are being cleaned-up.
Enclosure GDP 98-0094 Page 10 of 10 Disseminate Problem Report infonnation to the floor level. This action is intended to ensure the details and lessons learned from NCS violations are being relayed to the craft verbally in a face-to-face setting. Implement Boundary Control Station (BCS) improvements. This action is intended to evaluate, and if possible reduce, the need for the number of BCSs. This effort is intended to limit the potential for NCS violations. ) Establish routine PA announcements on NCS violations / lessons leamed. This action is intended to provide a mechanism to inform all plant personnel of current NCS violation lessons learned, and to provide capsules of information of some NCSAs to stimulate discussion. Task 24 PEH Deposit Surveillance Tracking - Target Date: 5/11/98 This is new task which will be reflected in Revision 3 to the NCS CAP. PEH deposit surveillance tracking has been a source of recent event reports. In order to increase the effectiveness of these surveillances, a revised program is being established. As detailed in USEC's response to NOV 70-7002/98003-01(reference USEC letter GDP-98-2018, dated April 27,1998), regarding a loss of fluorinating environment associated with a PEH deposit, USEC committed to develop and implement a formal program procedure for tracking PEH equipment. The procedure will include detailed administrative control requirements for maintaining this PEH equipment in a fluorinating environment. 1 Task 25 Compliance Plan Review Target Date: TBD l This is new task which will be reflected in Revision 3 to the NCS CAP. This task i will review Compliance Plan actions that impact NCS. I i l i i sa-}}