ML20236X213
| ML20236X213 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 08/03/1998 |
| From: | Jonathan Brown UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-7002-98-07, 70-7002-98-7, GDP-98-2038, NUDOCS 9808070201 | |
| Download: ML20236X213 (4) | |
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USEC A Global Energy Company August 3,1998 GDP-98-2038 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) 70-7002/98007 Notice of Violation (NOV)
The subject Inspection Report (IR) contained two violations involving: 1) a failure to have adequate
. administrative controls in place during the conduct of a maintenance activity and 2) a failure to meet Technical Safety Requirements during an autoclave mode change. USEC's response to these violations is provided in Enclosures 1 and 2, respectively. There are no new commitments made in this report Unless specifically noted, the corrective actions specified in each enclosure apply solely to PORTS.
Ifyou have any questions regarding this submittal, please contact Dave Waters at (740) 897-2710.
d Sincerely, M
1#I4~
l J. Morris Brown General Manager 1
Portsmvith Gaseous Diffusion Plant j
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Enclosures:
As Stated cc:
NRC Region Ill Office
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q0 NRC Resident Inspector-PORTS
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9800070201 ?OO W PDR ADOCK 07007002-PDR C
P.O. IW 800, Portsmouth, OH 45661 Telephone 740-897-2255 Fax 740-897-2644 http://www.uwc.com Offices in Livermore CA Padacah, KY Portsmouth, OH Washington, DC
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GDP 98-2038 Page1of1 UNITED STATES ENRICIIMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/98007-01 Restatemeri of Violation t
Technical Specification Requirement 3.9.1 requires that written procedures be prepared, reviewed, approved, implemented, and maintained to cover operator actions to prevent or mitigate the J
consequences of accidents described in Safety Analysis Report, Chapter 4.
Safety Analysis Report, Table 4.2.8, lists hydraulic rupture of a frozen line during reheating of the line as a potential hazard requiring administrative controls for prevention.
Contrary to the above, on May 8,1998, Plant Procedure XP4-CO CA2380," Operation of the Tails Station,"did not provide adequate controls to prevent the hydraulic rupture of a frozen line during reheating.
USEC Response The reasons for the violation, the corrective actions taken, and the corrective actions taken to prevent recurrence are described in PORTS Event Report 98-08, Revision 1 (reference USEC letter GDP 98-
'2036 dated July 22,1998). The date of full compliance was achieved on May 19,1998, when a DOI was issued to specify the actions to be taken if heat is lost and/or housing temperatures associated with a liquid UF. drop below the desired temperature. This is an interim action pending the procedure revision described in the event report.
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GDP 98-2038 Page 1 of 2 UNITED STATES ENRICIIMENT CORPORATION (USEC)
REPLY 'l O NOTICE OF VIOLATION (NOV) 70-700158007-02 Restatement of Violation Technical Safety Requirement L6.2.2.d requires that entry into an Operational Mode that is applicable to a particular Limiting Condition for Operation (LCO) shall not be made unless the conditions for the LCO are met without reliance on provisions contained in the action statement.
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Technical Safety Requirement 2.1.3.3 requires that both channels of the uranium hexafluoride (UF )
cylinder high temperature system be operable in Modes II, IV, and VL Contrary to the above, on May 25,1998, the certificate transitioned from Mode III to Mode IV on Autoclave No. 5 at the X-343 Building with one of the UF cylinder high temperature channels inoperable.
USEC Response I.
Reasons for Violation The reason for the violation was inattention to detail on the part of the First Line Manager (FLM). Specifically, when the operators notified the FLM of the safety system actuation, the FLM incorrectly concluded that the autoclave was in MODE IV and directed sampling operations to continue rather than review' g the sampling procedure (i.e., XP4-TE-FD2705 m
"LiquidSampling in X-342 andX-343, ") to determine the actual MODE of aperation. When the PSS questioned the FLM as to the actual MODE of operation, the FLM recognized that the autoclave, by procedure, was actually in MODE III when the safety system actuation occurred, and that a MODE change had occurred prior to meeting all the Technical Safety Requirements for initiating sampling (MODE IV).
i IL Corrective Actions Taken and Results Achieved 1.
On May 25,1998, when the sample evolution was complete, the autoclave was declared inoperable which placed the plant in a mode of operation where the affected l
UF cylinder high temperature channel was no longer required to be operable.
2.
The failed thermocouple was repaired on May 25,1998, and the autoclave was restored to operable status.
3.
The First Line Manager was counseled to ensure the individual has a full understanding of management's expectations as related to procedure use.
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GDP 98-2038 Page 2 of 2 4.-
On June 5,1998, a lessons' learned training bulletin _was issued to applicable operations group personnel to communicate the details of the violation and to emphasize the importance of procedure adherence, j
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On June 21,1998, a "Use of Procedures" stand-down was conducted at Portsmouth to ensure all employees conducting safety related activities have a complete understanding of management's expectations as related to procedure use.
III.
Corrective Steps to be Taken No additional actions are required.
IV.
Date of Full Compliance
- USEC achieved full compliance on May 25, 1998, when the autoclave was declared inoperable which placed the plant in a mode of operation where the affected UF cylinder 6
. high temperature channel was no longer required to be operable.
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