ML20236G844
| ML20236G844 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 06/30/1998 |
| From: | Jonathan Brown UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-7002-98-206, GDP-98-2027, NUDOCS 9807060411 | |
| Download: ML20236G844 (9) | |
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L USEC A Clobal Energy Company June 30,1998 GDP 98-2027 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Portsmouth Gaseous Diffusion Plant (PORTS)
Docket No. 70-7002 Response to Inspection Report (IR) 70-7002/98206 Notice of Violation (NOV)
The subject Inspection Report (IR) contained three violations. USEC's response to these violations
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is provided in Enclosures 1 through 3 respectively. Enclosure 4 lists the commitments made in this i
report. Unless specifically noted, the corrective actions specified in each enclosure apply solely to PORTS.
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l If you have any questions regarding this submittal, please contact Dave Waters at (740) 397-2710.
l Sincerely, frnW L
J. Morris Brown General Manager g,
Portsmouth Gaseous DifTusion Plant
Enclosures:
As Stated cc:
NRC Region Ill Office
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NRC Resident Inspector - PORTS e
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9907060411 990630.
PDR ADOCK 07007002!
C YW u P.O. Box 800, Portsmouth, OH 45661
,l4 n 3b8 Telephone 614-897-2255 Fax 614-897-2644 http://www.usec.com
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Offices in Livermore, CA Paducah, KY Portsmouth,01i Washington, DC
1 GDP 98-2027 Page1of2 UNITED STATES ENRICIIMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/98206-02 Restatement of Violation 1
i Safety Analysis Report (SAR) Section 6.3.5.1.1 states, in part, that "The CM Program has been l
developed and documented in a site procedure and is implemented to ensure that changes from the plant baseline configuration are controlled to prevent degradation of safety or safeguards."
SAR Section 5.2.2.8 states, in part, that " Functional and physical characteristics of operations controlled for NCS are described in NCSAs and NCSEs. These components and features which are identified in the NCSAs and NCSEs are analyzed to determine the " boundary" of the system, encompassing those items that are essential to ensure operability....These components and features are documented in a manual for each facility....If an item is relied on for the criticality safety of an operation, it will be identified through the work control process as an NCS SSC....The systems which require configuration control are identified as Q orAQ-NCS."
I The Configuration Management Program Manual defines AQ-NCS items as "SSCs identified m i
NCSAs/NCSEs as required to meet the double contingency principle."
Contrary to the above, as of May 1,1998, systems, structures, and components (SSCs) relied on in NCSE-0326_013.E04, " Cascade Operations in the X-326 Building," and NCSE-0326_024.E04, "Fe' ding of 5-inch 8-inch, and 12-inch Cylinders in the X-326 Product Withdrawal Area," for double contingency were not identified as components relied on for criticality safety in the Boundary Definition Manual or classified as AQ-NCS items.
USEC Response I
I.
Reasons for Violation The reason for the viola. ion was Procedure XP3-EG-EG1037," Establishing and Controlling Quality Boundaries" does not provide adequate guidance for classifying systems, structures,
. and components (SSC) required to meet the double contingency prmeiple in approved NCSA/Es as AQ-NCS.
II.
Corrective Actions Taken and Results Achieved None
GDP 98-2027 Page 2 of 2 III.
. Corrective Steps to be Taken 1.
Revise : procedure XP3-EG-EG1037 to -incorporate the revised criteria for classification of AQ-NCS SSCs by August 27,1998.
2.
NCSA-0326_13 and NCSA-0326_024 will be reviewed and the SSCs reclassified by August 31,1998.
3.
Concurrent with Task 3, NCSA/E Upgrade Project, of the NCS Corrective Action Plan, (Reference USEC letter GDP 98-0104, dated May 7,1998) new or upgraded NCSAs/NCSEs will be reviewed and SSCs reclassified, as appropriate, in accordance with the revised XP3-EG-EG1037 procedure.
4.
The NCSA/Es that have already been upgraded will be reviewed and AQ-NCS SSC identified by September 30,1998.
IV..
Date of Full Compliance
- Full compliance will be achieved by August 31,1998, when the SSCs applicable to NCSA-0326_13 and NCSA-0326_024 have been properly classified as AQ-NCS.
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GDP 98-2027 Page 1 of 3 UNITED STATES ENRICIIMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/98206-03 Restatement of Violation 10 CFR 76.93 states, in part, that "The Corporation shall establish, maintain, and execute a quality assurance program satisfying each of the applicable requirements of ASME NQA-1-1989....or
' satisfying acceptable alternatives to the applicable requirements."
Quality Assurance Program (QAP), Section 2.16.3, states, in part, that " Procedures for the corrective action process are established to ensure the following....For significant conditions adverse to quality, the cause of the condition is determined and corrective action is taken to preclude recurrence."
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Contrary to the above, as of May 1,1998, adequate corrective actions had not been taken to preclude recurrence of VIO 70-7002/97-206-06 in the ERP withdrawal statian. NCSE-0326_015.E02,
" Extended Range Product (ERP) Withdrawal Station," did not demorutrate double contingency for this operation, and no TSR had been established in accordance wit'4 TSP 3.11.5.
USEC Response l
I.
Reasons for Violation The reasons for the violation were: 1) failure by plant personnel to recognize that the deficient NCSE constituted an " anomalous condition", and 2) the lack of procedural guidance, at the time this deficiency this discovered, as to the methodology for responding to anomalous conditions. Further discussion of the reason for the violation is provided below.
In response to a previous violation regarding the Low Assay Withdrawal (LAW) and Tails stations (i.e.,97206-06), USEC discovered in July 1997, that the Nuclear Criticality Safety Approval / Evaluation (NCSA/E) for the ERP withdrawal station was deficient in that it did not demonstrate double contingency. Subsequently, on September 19,1997, a corrective action to revise the ERP NCSE/A was added to the Problem Report associated with the LAW and Tails violation. An action was assigned in the plant's Business Prioritization System (BPS) to revise the NCSA/E for the ERP withdrawal station. However, because the tracking item in BPS was vague and de to a concurrent personnel change in the management of the NCS organization, the new NCS manager did not know that there were two changes to the L
ERP NCSA/E being processed. As a result, this action was closed in BPS on November 10, L
1997, based on a revision to the ERP NCSA/E. However, this revision did not address the lack of double contingency. Subsequently, during an inspection from April 27 to May 1, h
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GDP 98-2027 Page 2 of 3 1998, NRC identified that this deficiency still existed.
In hindsight, plant personnel did not recognize that the failure of an NCSA/E to demonstrate double contingency, in conjunction with the failure to establish a TSR, constituted an anomalous condition. Immediate action should have been taken to: 1) revise the NCSA/E for the ERP withdrawal station; and 2) suspend operation of the ERP withdrawal station until the 'NCSA/E was properly revised.
When the deficient ERP NCSA/E was initially discovered in July 1997, proceduralized guidance on how to address NCS anomalous conditions did not exist. As part of the NCS Corrective Action Plan (CAP), proceduralized guidance has been developed as discussed further in the following section.
II.
Corrective Actions Taken and Results Achieved I
1.
NCSA/E-0326_015.A03, was revised on April 29,1998. This revision demonstrated double contingency for the ERP withdrawal station.
i 2.
A review of all other NCSA/Es, to ensure double contingency was met, was j
completed by November 11,1997. With one other exception, this review showed that either the NCSA/Es met double contingency or appropriate TSRs were in place.
The exception was the use of unfavorable geometry vacuums ir or.ilding X-705.
Ilowever, this operation was shutdown and controls are in place to ensure the NCSA/E is revised before resuming operation.
3.
As documented in USEC letters GDP 98-0013 dated January 30,1998, and GDP 98-0094 dated April 30, 1998, concerning the NCS CAP, USEC has developed proceduralized actions for responding to NCS anomalous conditions. These actions include stopping activities in the immediate area, securing the area, notifying the Plant Shift Superintendent (PSS) and the NCS Manager or the Duty NCS Engineer.
4.
To ensure the Plant Shift Superintendents (PSS) understand that credit cannot be taken for controls that are not established in an approved and implemented NCSA/E, lessons learned training was provided by March 18,1998. (Also see response to violation 98-206-05.)
5.
A " lessons learned" emphasizing the importance of clearly and fully defining corrective actions which are placed in the BPS tracking system was completed by June 11,1998.
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GDP 98-2027 Page 3 of 3 III.
Corrective Steps to be Taken Revise the appropriate NCS procedure (s) to clearly convey that a process can only be credited as meeting double contingency ifit is documented in an approved NCSA/E and to require that the failure of an NCSA/E to demonstrate double contingency (without the
' establishment of a TSR) is to be treated as an anomalous condition. This action will be completed by September 25,1998.
IV.
Date of Full Compliance USEC achieved full compliance on April 29,1998, when NCSA/E-0326_015.A03, was revised to demonstrate double contingency for the ERP withdrawal station.
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GDP 98-2027 Page 1 of 2 UNITED STATES ENRICIIMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/98206-05 1
Restatement of Violation i
SAR Section 6.9.2 states. in part, that "The PSS assesses and categorizes abnormal events or conditions using the notification and reporting criteria set forth in 10 CFR 76 and the other applicable regulations referenced in 10 CFR 70.60. Table 6.9-1 provides a list of the initial event i
notification and reporting criteria."
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SAR Table 6.9.-1, paragraph 2.c(3), states that "Any case where it is determined that a criticality safety analysis was deficient and where the necessary controlled parameters were not established or maintained" is a 4-hour reportable event.
Contrary to the above, as of May 1,1998, no event notification was made following the discovery on August 29,1997, that double contingency had not been established for the Tails and LAW withdrawal stations.
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'USEC Response
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I.
Reasons for Violation The reason for this violation was the lack of adequate training for the PSS staff concerning the reporting criteria for a deficient NCSA/E. USEC procedure UE2-RA-IE1030," Nuclear Regulatory Event Reporting," states that NRC be notified within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of discovery for:
" Operations that do not comply with the double contingency principle, for which... any case where it is determined that a criticality safety analysis was deficient and where the 4
necessary controlled parameter is not established or maintained." Training and guidance i
given to the PSSs on this procedure did not clearly recognize that cases where an NCSA/E does not demonstrate double contingency is reportable per this criterion.
i II.
Corrective Actions Taken and Results Achieved i
1-An event notification for the discovery of the deficient NCSA/E for LAW and Tails was made on May 2,1998.
l 2.
Lessons learned training, identifying loss of double con'.ingency as either loss of a single control or the necessary controls not being established by an approved NCSA/E, was given to each PSS by March 18,1998.
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GDP 98-2027
.a Page 2 of 2 III.
Corrective Steps to be Taken The training module for UE2-RA-RA1030 will be revised to address the lessons learned from this event. This action will be completed by September 30,1998. This training module
- is required for any new PSS.
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' IV, Date of Full Compliance USEC achieved full compliance on May 2,1998, when the required event notification was
- made, i
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4 GDP 98-2027 Page1of1 List of Commitments
- NOV 70-7002/98-206-02 1.
Revise procedure XP3-EG-EG1037 to incorporate the revised criteria for classification of AQ-NCS SSCs by August 27,1998.
2.
NCSA-0326_13 and NCSA-0326_024 will be reviewed and the SSCs reclassified by August 31,1998.
- 3.
Concurrent with Task 3, NCSA/E Upgrade Project, of the NCS Corrective Action Plan, (Reference USEC letter GDP 98-0104, dated May _7,1998) new or upgraded NCSAs/NCSEs will be reviewed and SSCs reclassified, as appropriate, in accordance with the revised XP3-EG-EG1037 procedure.
J
'4.
The NCSA/Es that have already been upgraded will be reviewed and AQ-NCS SSC i
identified by September 30,1998.
1 NOV 70-7002/98-206-03 Revise the appropriate NCS procedure (s) to clearly convey that a process can only be credited as meeting double contingency ifit is documented in an approved NCSA/E and to require that the failure of an NCSA/E to demonstrate double contingency (without the establishment of a TSR) is to be treated as an anomalous condition.'. This action will be completed by September 25,1998.
NOV 70-7002/98-206-05 '
The training module for UE2-RA-RA1030 will be revised to address the lessons learned from this event. This action will be completed by September 30,1998. This training module is required for any new PSS.
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