ML20236L382
| ML20236L382 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 07/06/1998 |
| From: | Jonathan Brown UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-7002-98-204, GDP-98-2028, NUDOCS 9807100333 | |
| Download: ML20236L382 (4) | |
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USEC A Global Energy Company July 06,1998 GDP 98-2028 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) 70-7002/98204 Notice of Violation (NOV)
The subject Inspection Report (IR) contained one violation involving a failure to identify and report NCS control failures to the NRC.
USEC's response to this violation is provided in Enclosure 1. Enclosure 2 lists the commitments made in this letter.
Unless specifically noted, the corrective actions apply solely to PORTS. If you have any questions regarding this submittal, please contact Dave Waters at (740) 897-2710.
Sincerely, h
t denrIhanaer
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Portsmouth Gaseous Diffusion Plant
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Enclosures:
As Stated cc:
NRC Region III Office NRC Resident Inspector-PORTS W l g6/
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9807100333 980706 PDR ADOCK 07007002 C
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e P.O. Box 800, Portsmouth, OH 45661 Tclephone 614-897-2255 Fax 614-897-2644 http://www.uscc.com OfRces in Livermore, CA Paducah, KY Portsmouth, OH Washington, DC
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a GDP 98-2027 Page 1 of 2 UNITED STATES ENRICIIMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/98204-05 Restatement of Violation During an NRC inspection conducted February 9 - 18,1998, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedures for NRC
. Enforcement Actions," NUREG-1600, the violation is listed below:
Certificate of Compliance, Condition 9, requires, in part, that "The United States Enrichment Corporation shall conduct its operations in accordance with the Technical Safety Requirements that are contained in Volume 4... of the Application..."
Technical Safety Requirement (TSR) 3.11, requires, in part, that "a Criticality Safety Program shall be established, implemented, and maintained as described in the Safety Analysis Report and shall address.. nuclear criticality safety responsibilities."
Safety Analysis Report (SAR), Section 5.2.2.2 states, in part, that "... NCS engineers are responsible for... advising appropriate management of any NCS concerns..."
Contrary to the above, as of February 18, 1998, NCS engineers did not advise appropriate management of NCS concerns, in that they did not recognize that abnormal conditions described in facility problem reports constituted the loss of approved NCS control barriers and as such did not advise appropriate management of the NCS problem.
USEC Response I.
Reasons for the Violation The reason for the violation is that NCS Engineers were not properly trained in the requirements of NRC Bulletin 91-01, Supplement 1, " Reporting Loss of Criticality Safety Controls, and associated evaluations." Related information is provided in USEC's response to NOV 98206-05 (reference USEC letter GDP 98-2027).
With respect to PR PTS-97-10519, which concerned a spill at the microfiltration operation in the X-705 facility that occurred on December 15,1997, USEC has determined that this PR was properly determined to be not reportable by the PSS. This operation is a batch process and the "U concentration and quantity of the liquid were known to be lower than 2
the requirements of the governing NCSA. Nevertheless, USEC emphasizes that the appropriate management was notified of this issue via the Problem Reporting process.
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GDP 98-2027 Page 2 of 2 II.
Corrective Action Taken and Results Achieved 1.
Event notifications were made as follows:
NRC was notified about the inadequate analysis in NCSA/E Plant-028 (problem report PTS-98-0580) on February 11,1998.
NRC was notified about a possible common mode failure in the operation of the small parts pit in the X-705 facility (problem report PTS-97-10680) on February 11.,1998.
2.
Lessons learned training, identifying loss of double contingency 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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Corrective Steps to be Taken l
1.
" Lessons learned" training with NCS Engineers will be conducted to reemphasize the l
cvent reporting criteria of NRC Bulletin 91-01, Supplement 1, by August 28,1998.
This will include lessons learned training to ensure all NCS Engineers understand that deficient NCSA/Es are reportable events, and that incidents that lead to a complete loss of a controlled parameter, even though not identified in the NCSA/E, are reportable.
2.
Procedure XP4-EG-NS1025, "NCS Response to Anomalous Condition", will be revised to clarify notification response, as-found versus safety basis review, and NRC Bulletin 91-01 reporting by August 31,1998.
IV.
Date of Full Compliance USEC achieved full compliance on February 11,1998, when the notifications associated with problem reports PTS-97-10680 and PTS-98-0580 were made.
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GDP 98-2028 l
Page1ofI List of Commitments NOV 70-7002/98204-05 1
1.
" Lessons leamed" training with NCS Engineers will be conducted to reemphasize the event reporting criteria of NRC Bulletin 91-01, Supplement 1, by August 28,1998. This will include lessons learned training to ensure all NCS Engineers understand that deficient NCS A/Es are reportable events, and that incidents that lead to a complete loss of a controlled parameter, even though not identified in the NCSA/E, are reportable.
2.
Procedure XP4-EG-NS1025,"NCS Response to Anomalous Condition," will be revised to clarify notification response, as-found versus safety basis review, and NRC Bulletin 91-01 reporting by August 31,1998.
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