ML20236W006
| ML20236W006 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 07/30/1998 |
| From: | Pulley H UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-7001-98-09, 70-7001-98-9, GDP-98-1059, NUDOCS 9808050024 | |
| Download: ML20236W006 (9) | |
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1 IUSEC s A dlobal Endgy Company July 30,1998 GDP 98-1059 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Paducah Gaseous Diffusion Plant (PGDP)
Docket No. 70-7001 Response to Inspection Report (IR) 70-7001/98009 Notices of Violation (NOVs)
The Nuclear Regulatory Commission (NRC) letter dated June 30,1998, transmitted the subject IR which contained three NOVs. The United States Enrichment Corporation's (USEC) response to these violations is provided in Enclosures 1,2 and 3. Enclosure 4 lists the commitments made in this report. Unless specifically noted, the corrective actions specified in each enclosure apply solely to PGDP.
As indicated in Enclosure 2, USEC will submit a supplemental response to NOV 98009-02 by September 30,1998. This supplemental response will incorporate the recommendations from the evaluation described in the response in the Corrective Actions to be Taken for this violation and will address the root cause as described in the response.
Any questions regarding this matter should be directed to Larry Jackson at (502) 441-6796.
Sincerely, rd Pulle i
G.neral Manager Paducah Gaseous Diffusion Plant
Enclosures:
As Stated f
iI cc: NRC Region III Office h, g
/j ik NRC Resident Inspector - PGDP l
\\
9808050024 900730 F PDR ADOCK 07007001 C
PDRg P.O. Box 1410, Paducah, KY 42001 Telephone 502 441-5803 Fax 502-441-5801 http://www.usec.com Offices in Livermore, CA Paducah, KY Portsmouth, Oil Washington, DC
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l GDP 98-1059 l
Page1 of2 i
UNITED STATES ENRICHMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7001/98009-01 Restatement of Violation Title 10 of the Code of Federal Regulations, Part 76.93, " Quality Assurance," requires, in part, that the Corporation shall establish, implement, and maintain a Quality Assurance Program.
Section 2.16 of the Quality Assurance Program, " Corrective Action," requires, in part, that conditions adverse to quality shall be corrected as soon as practical.
Contrary to the above, between April 14 and May 13,1998, the Corporation failed to implement, as soon as practical, interim nuclear criticality safety spacing controls (corrective actions) for the Building C-333 wet air pump piping elbows, previously removed from a cascade support system and stored on the cell floor without an approved nuclear criticality safety evaluation, a condition adverse l
to quality.
USEC Response l
I.
Reason for the Violation The reason for this violation is that procedural controls were inadequate to prevent an error during the implementation of the administrative controls specified in the NCS Incident Repon. Procedural steps did not exist to defme the characteristics of a proper NCS boundary and ensure, through independent verification, that the specified boundary had been established. As a result, the administrative controls contained in the NCS Incident Report were not properly implemented.
II.
Corrective Actions Taken and Results Achieved l
1.
Access to the area was controlled and the area was properly flagged and posted on May 14,1998.
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The other areas referenced in NCS Incident Report Number NCS-INC-98-029 were visually verified to be properly flagged and posted.
3.
Plant areas currently roped off and posted due to NCS violations have been walked-down to ensure proper boundaries and postings have been established.
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I GDP 98-1059 Page 2 of 2 4.
A Crew Briefing was conducted with the NCS staff to address the need for more specific information on the NCS incident report related to corrective actions. This additional information will improve communications and help ensure compliance with NCS Program expectations.
5.
A functional directive has been issued to require use of the independent verification procedure when boundaries and posting are required by NCS Incident Reports until the action can be incorporated into a procedure.
III.
Corrective Action to be Taken Procedure CP2-EG-NS1031, " Nuclear Criticality Safety," will be revised by August 31,1998, to add specific requirements for the implementation of compensatory action boundaries, postings, and independent verification of proper posting.
IV.
Date of Full Compliance USEC achieved full compliance on May 14,1998, when the wet air pump elbows were re-
' posted and roped offin accordance with the directions as specified in the revised incident report.
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GDP 98-1059 Page1of2 l
UNITED STATES ENRICHMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7001/98009-02 Restatement of Violglion Title 10 of the Code of Federal Regulations, Part 76.93, " Quality Assurance," requires, in part, that the Corporation shall establish, implement, and maintain a Quality Assurance Program.
Section 2.5 of the Quality Assurance Program, " Procedures," required, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings appropriate to the circumstances, and shall be accomplished in accordance with these documents.
Contrary to the above, on May 14,1998, testing of the Switchyard C-537 fire sprinkler system for Transformer W. 72, an activity which affected quality, was conducted without documented instructions, procedures, or drawings appropriate to the circumstances. Specifically, the task test package did not include documented instructions or procedures, as appropriate, to ensure a minimum water flow rate, from the common water supply header to both the fire sprinkler and plant air systems, for continuous operation of the plant air compressors at a level suflicient to provide the minimum system air capacity required for operability of the criticality accident alarm system horns.
USEC Response L
Background
Dry compressed air is supplied from three buildings (C-600, C-620, and C-335) and an auxiliary air supply is located in Building C-607. Air compressor facilities may be operated separately or together to maintain air supply to the distribution headers. The minimum operability requirements for on-line air availability was 11,250 scfm.
Compressor trips have previously occurred during flow testing of the deluge systems in the switchyards. To minimize the risk of a compressor trip, prior to this event, testing was initiated with the transformer deluge system's supply valve (S2) closed. This method had been used previously with no resultant compressor trips. To preclude a surge of water that could reduce the water pressure to the C-335 XLE compressors, the S2 valve was slowly l
opened. However, the full flow of water through the transformer deluge system resulted in l
a reduced flow of cooling water available to the Centac compressor in C-335 and caused the i
compressor to trip.
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j GDP 98-1059 Page 2 of 2 II.
Reason for the Violation The reason for this violation was that the evaluation conducted by power operations, utility operations, and fire services prior to the testing at C-537 was inadequate in that the impact of the ambient water temperature, the closed sanitary water header, and a partially closed compressor cooling water valve were not accurately assessed.
III.
Corrective Actions Taken and Results Achieved 1.
All flow testing of switchyard fire suppression systems was suspended until corrective actions are taken to prevent recurrence.
2.
Routine testing and maintenance of fire hydrant and suppression systems that place flow demands on the sanitary and fire water system were stopped until the potential impacts on safety systems can be addressed.
3.
Current modifications being implemented and modifications in planning were reviewed to ensure that similar vulnerabilities did not exist for future work.
1 IV.
Corrective Actions to Be Taken 1.
The process for controlling activities will be evaluated by August 27,1998, to j
determine what actions are necessary to ensure that the impact of work directly and indirectly affecting safety related systems is accurately assessed.
j 2.
USEC will submit a supplemental response to this violation by September 30,1998.
This supplemental response will incorporate the recommendations from the evaluation l
described in Corrective Actions to be Taken No. I for this violation and will address the root cause as describe in the response.
V.
Date of Full Compliance USEC achieved full compliance with TSR 2.4.4.2 on May 14,1998, when the C-335 Centac compressor was restarted and the on-line plant air availability wrs restored to the minimum i
required for CAAS horn operable level.
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l GDP 98-1059 Page1of3 UNITED STATES ENRICHMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7001/98009-03 i
Restatement of the Violation Condition 8 of the Certificate of Compliance requires, in part, that the Corporation shall conduct operations in accordance with the Safety Analysis Report and the Compliance Plan.
Compliance Plan Issue 2, iequired, in part, that the Corporation shall evaluate as-found conditions, identified as a part of the Safety Analysis Report upgrade process, that represent risks more severe than described in the Safety Analysis Report in accordance with 10 CFR 76.68.
Title 10 of the Code of Federal Regulations, Part 76.68(b), requires, in part, that the Corporation shall evaluate any as-found conditions that do not agree with the plant's programs, plans, policies, and operations as described in the Safety Analysis Report in accordance with Part 76.68(a),
Contrary to the above, between October 31,1997, and June 8,1998, the Corporation did not evaluate as-found conditions, identified during the Safety Analysis Report upgrade process, to determine if the risks of the as-found conditions were more severe than previously addressed in the Safety Analysis Report. In addition, the Corporation did not evaluate the as-found conditions, that did not agree with the plant's operations, as described in Safety Analysis Report, in accordance with 10 CFR 76.68(b). Specifically, the Corporation failed to perform risk and safety evaluations for the following as-found conditions:
a.
The presence of uncontrolled keyed reset switches in the Building C-360 autoclave safety system actuation circuits which, if operated improperly, would cause the safety systems to be inoperable during normal and off-normal operations, without indication, and would result in significant increases in the Safety Analysis Report assumed accident releases.
b.
An unanalyzed reliance on the nonsafety-related plant air system by some safety-related autoclave containment valves in Buildings C-333A and C-337A in order to ensure valve closure within the Safety Analysis Report accident analysis time limits.
An unanalyzed, unmonitored, and non-failsafe reliance on the nonsafety-related plant air c.
system by the Buildings C-310 and C-315 withdrawal pump safety systems in order to ensure the Safety Analysis Report accident consequences were met.
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Snclosurc 3 GDP 98-1059 Page 2 of 3 USEC Response I.
Reason for the Violation The reason for this violation was due to an inadequate understanding of the Compliance Plan (CP) Issue No. 2 requirements. Specifically, USEC staff failed to evaluate, in a timely manner, the SARUP submittal, including the three cited examples, to determine if risks more
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severe than those submitted in the Safety Analysis Report (SAR) were involved.
1 USEC did perform a 10 CFR 76.68 evaluation of the general SARUP submittal. However, USEC did not follow the process as described in CP Issue No. 2 to evaluate the SARUP submittal for" risks more severe.. " until approximately six months after the submittal. USEC now recognizes the requirements of CP Issue No. 2.
Representatives from USEC met with NRC representatives on May 28,1998, to discuss the handling ofissues such as the three examples cited. At that meeting, USEC described to the NRC the process used to address SARUP issues. USEC agreed to follow that process for any future issues identified in the SARUP process. In addition, USEC agreed to submit in writing a process for handling SAR Chapter 3 rewrite issues that identify errors between the SAR and the field.
II.
Corrective Actions Taken and Results Achieved 1.
A comprehensive engineering evaluation of the SARUP submittal, including the j
known limitations, inaccuracies and deficiencies identified in Table 1 of the submittal, was completed on May 21,1998. This evaluation documented the assessment of S ARUP issues for risks more severe than those identified in the SAR.
2.
A specific engineering evaluation of the keyed reset switches in C-360 (Example a) was completed on Febmary 4,1998. As a result, a modification to rewire the control logic of the C-360 autoclaves has been initiated. (Both of the previous actions were documented in GDP 98-0025, dated February 23,1998.) Supplementary actions in the form of administrative controls were implemented via procedures on May 29, 1998.
3.
Operations management implemented additional operator training and actions to compensate for potential support system failures (e.g., instrument air in C-310 and 24 VDC in C-315) associated with the withdrawal pumps. Long Term Order 98-008 was issued for C-310 on March 25,1998, which imposed supplementary actions. For l
C-315, additional training on the potential support system failure, in the form of crew briefings, was completed on April 15,1998. (This addresses Example c.)
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GDP 98-1059 Page 3 of 3 i
III.
Corrective Actions to be Taken 1.
USEC will issue a Nuclear Safety Analysis Policy clarifying the requirements of Compliance Plan Issue No. 2 for identifying risks more severe than those previously addressed in the SAR. The policy will be issued and crew briefings given to Nuclear Safety Analysis personnel by August 17,1998.
2.
The actions associated with LTO 98-008 will be incorporated into an existing or new procedure by November 19,1998.
3.
' An assessment of the performance of the autoclave air-assisted containment valves in Buildings C-333A and C-337A, assuming degraded plant air system pressures, will be completed by September 4,1998. (USEC does not consider this action to be a regulatory commitment since it is not an action needed to either restore compliance or prevent recurrence with this violation.)
IV.
Date of Full Compliance Full compliance was achieved on May 21,1998, when 2 comprehensive engineering evaluation of the SARUP submittal, including the known limitations, inaccuracies and deficiencies identified in Table-1 of the submittal, was completed. This evaluation documented the assessment of SARUP issues for risks more severe than those identified in the SAR.
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LIST OF COMMITMENTS i
NOV 98009-01 i
1.
Procedure CP2-EG-NS1031, " Nuclear Criticality Safety," will be revised by August 31, 1998, to add specific requirements for the implementation of compensatory action l
boundaries, postings, and independent verification of proper posting.
NOV 98009-02 1.
The process for controlling work will be evaluated by August 27,1998, to determine what actions are necessary to ensure that the impact of work directly and indirectly affecting safety related systems is accurately assessed.
2.
USEC will submit a supplemental response to this violation by September 30,1998. This supplemental response will incorporate the recommendations from the evaluation described in Corrective Actions to be Taken No.1 for this violation and will address the root cause as described in the response.
NOV 98009-03 1.
USEC will issue a Nuclear Safety Analysis Policy clarifying the requirements of Compliance Plan Issue No. 2 for identifying risks more severe than those previously addressed in the SAR. The policy will be issued and crew briefings given to Nuclear Safety Analysis personnel by August 17,1998.
2.
The actions associated with LTO 98-008 will be incorporated into an existing or new procedure by November 19,1998.
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