ML20237A227
| ML20237A227 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 08/10/1998 |
| From: | John Miller UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Lieberman J NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| 70-7002-98-05, 70-7002-98-5, EA-98-249, EA-98-250, EA-98-251, NUDOCS 9808130189 | |
| Download: ML20237A227 (13) | |
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k d USEC
. A Global Energy Company JAMES H. MILLER Dir. (301) 564-3309 VICE PRESIDENT, PRODUCTION Fax: (301) 571-8279 August 10,1998 GDP 98-0159 Mr. James Liebermann.
Director, Office of Enforcement United States Nuclear Regulatory Commission Washington, D.C. 20555-0001 Portsmouth Gaseous Diffusion Plant (PORTS)
Docket No. 70-7002 Reply to Notice of Violations (NOVs) 70-7002/98005 (EAs98-249; 98-250;98-251)
Dear Mr. Lieberman:
Nuclear Regulatory Commission (NRC) letter dated July 14,1998, transmitted one (1) Severity Level III NOV and five (5) Severity Level IV NOVs (i.e., NOVs II.A through II.E). The events that led to these NOVs were the subject of a predecisional enforcement conference held on June 5,1998.
USEC's reply to the Severity Level Ill NOV is provided in Enclosure 1. USEC's reply to the Severity Level IV NOVs is provided in Enclosures 2 and 3 (Note: USEC has combined the responses j
to NOV II.A, II.D, and II.E, and the responses to NOVs II.B and II.C since they stemmed from issues that have similar root causes and corrective actions). Enclosure 4 lists the commitments contained in this submittal. The corrective actions specified in each enclosure apply solely to PORTS.
USEC does not contest these violations. Therefore, as directed by your July 14,1998, letter, is a check in the amount of $55,000 in payment of the civil penalty associated with the Severity Level III NOV.
If you have any questions regarding this submittal, please contact Dave Waters at (740) 897-2710.
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Sincerely, j
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4 ames H. Miller hde President, Production th 9908130189 990810 m
PDR ADOCK 07007002 PDN l
^ '{ }[7 6903 Rockledge Drive, Bethesda. MD 20817-1818
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Telephone 301-564-3200 Fax 301-564-3201 http://www.usec.com Offices in Livermore. CA Paducah, IW Portsmouth, OH Washington, DC i
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Director, Office of Enforcement August 10,1998-GDP 98-0159, Page 2
Enclosures:
- 4) List of Commitments
- 5) USEC Check No.16688 cc:
NRC RegionIII Administrator NRC Senior Resident Inspector - PORTS Document Control Desk
- NRC Special Projects Branch l
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GDP 98-0159 Page 1 of 2 UNITED STATES ENRICIIMENT CORPORATION (USEC)
REPLY TO SEVERITY LEVEL III NOTICE OF VIOLATION (NOV) 70-7002/98005 I (01013)
Restatement of Violation Technical Safety Requirement Section 2.1.3.5 titled," Autoclave Shell fligh Pressure Containment Shutdown," requires that the autoclav.e shell high pressure containment system shall be operable.
Technical Safety Requirement Section 1.2.13, requires, in part, that a safety system component shall be operable or have operability when it is capable of performing its specified function (s), and when other auxiliary equipment that are required for the safety system component to perfonn its specified function (s) are also capable of performing their related support function (s).
Contrary to the above, prior to April 9,1998, Autoclave Numbers 1,2,3,4 and 5 in Building X-343 were operated with an autoclave shell high pressure containment safety system component incapable ofperforming a specified safety function. Specifically, as-found testing conducted April 10 through April 21,1998, of the air-to-close autoclave containment valves for Autoclaves 1,2,3,4 and 5 in Building X-343, demonstrated that 7 of 25 of the air-to-close containment valves failed the test acceptance criteria and were not capable of performing the related support function.
USEC Response L
Reasons for Violation As discussed at the predecisional enforcement conference, the root cause of this violation was PORTS failure to develop a testing program to demonstrate that autoclave air-to-close valves will perform their design function on a loss of normal supply air.
A contributing cause to this violation was that the corrective actions for a similar issue identified in January 1996, regarding Parent Cylinder Safety Valves (PCSVs), were narrowly focused on the PCSVs and were not extended to include other air-to-close valves.
II.
Corrective Actions Taken and Results Achieved 1.
Affected autoclaves were declared inoperable. Also, all safety-related systems with air-to-close valves were either declared inoperable (i.e., X-705 calciner) or an operability evaluation was performed (i.e., ERP, LAW, and Tails).
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Valve testing criteria were established. The valves on the functional autoclaves were tested and repaired, as necessary, using this criteria. Once the valves were declared
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operable, the functional autoclaves were returned to service. The valves on the J
nonfunctional autoclaves will be tested and repaired, as necessary, before these autoclaves will be returned to service.
3.
Formal surveillance test criteria for testing the backup air reservoir tanks was issued on June 17,1998. Surveillance testing of these tanks is scheduled on a quarterly basis and commenced on June 28,1998. This testing will be conducted via work packages until the appropriate procedures are revised.
4.
An action plan was developed and issued on July 10,1998, to verify that S AR design bases systems credited for backup are being properly tested.
III.
Corrective Steps to be Taken AfTected procedures will be revised by September 30,1998, to include surveillance testing of the backup air reservoir tanks.
IV.
Date of Full Compliance Full compliance was achieved on April 9,1998, when the afTected autoclaves were declared inoperable which placed the autoclaves in a mode where the requirements of TSR 2.1.3.5 were no longer applicable.
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GDP 98-0159 Page 1 of 4 UNITED STATES ENRICHMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATIONS (NOVs) 70-7002/98005 II.A, ll.D, AND 11.E (02014,04014, and 05014)
Restatement of Violations A.'
Technical Safety Requirement Section 2.1.3.5 titled, " Autoclave Shell High Pressure Containment Shutdown," requires that the autoclave shell high pressure containment system shall be operable.
Technical Safety Requirement Section 1.2.13, requires, in part, that a safety system component shall be operable or have operability when it is capable of performing its specified function (s), and when other auxiliary equipment that are required for the safety system component to perform its specified function (s) are also capable of performing their related support function (s).
Contrary to the above, from March 25 through March 27,1998, Autoclave Number 4 in Building X-343 was operated with an autoclave shell high pressure containment safety system component incapable of performing a specified safety function. Specifically, on March 24,1998, a containment valve actuator was incorrectly installed, causing the FV-416X containment valve to work " backwards" while the autoclave was operated for two heating and feeding cycles.
D.
Technical Safety Requirement Section 3.9.1, requires, in part, that written procedures shall be implemented for activities described in Safety Analysis Report (SAR), Section 6.11.4.1, and listed in Appendix A to SAR Section 6.11. Appendix A to SAR Section 6.11 requires maintenance activities to be covered by written procedures.
Section 8.2.12 of written Procedure XP4-TE-MM4104, Revision 0, Change C, dated January 15,1997, titled, " Valve Actuator Removal, Replacement and Installation," requires, in part, that the maintenance staff performing the work activity ensure that each of the following has a "V" stamped on it: valve end of the torque shaft; valve side of the actuator housing; and, valve end of the coupling between the torque shaft and the valve stem. In addition, Section 8.2.24 directs the maintenance staff performing the work activity to request Operations personnel to perform an operational check.
i Contrary to the above, on March 24, 1998, maintenance staff performing an actuator i
replacement on autoclave containment valve FV-416X did not ensure that a "V" was stamped on the valve end of the torque shalt, the valve side of the actuator housing, and the valve end of the coupling between the torque shaft and the valve stem. Further, maintenance staff did not request that an operational check be performed on the repaired actuator.
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10 CFR 76.93, " Quality Assurance," requires, 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, " Quality Assurance Program Requirements for Nuclear Facilities."
Section 2.11 of the Quality Assurance Program titled, " Test Control," requires, in part, that the test control system for "Q" items, is planned and executed to assure that testing is performed to demonstrate that safety system components will perform satisfactorily in service.
Contrary to the above, on March 24,1998, the post-maintenance test planned and executed for Work Order Number R9811626-01, failed to demonstrate that the "Q" safety system component, autoclave containment valve FV-416X, would perform satisfactorily in service by closing upon a containment signal.
USEC Response 1
I.
Reasons for Violation As discussed at the predecisional enforcement conference, the root causes for these violations were:
1.
Failure to follow procedure due to a lack of understanding regarding compliance with
" General Intent" procedures; and 2.
The lack of procedure guidance for developing and performing Post Maintenance Tests (PMTs).
l Contributing causes to these violations were:
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When the criteria for an "In-Hand" procedure was revised in August 1997, a review l
was not performed to determine if existing " General Intent" procedures should be re-categorized; 2.
The training module concerning use of procedures was inconsistent with procedure UE2-PS-PS1034, "Use of Procedures", regarding compliance with " General Intent" procedures; f
3.
Procedure XP4-TE-MM4104, " Valve Actuator Renewal, Replacement, and i
Installation," does not provide specific guidance as to what an " operational check" involves; and,
GDP 98J59 Page 3 of 4 4.
Poor communications between operators during the performance of the PMT.
II.
Corrective Actions Taken and Results Achieved 1.
On March 27,1998, upon discovering that FV-416X was operating opposite its design function, the autoclave was secured and declared inoperable. Subsequently, the valve actuator was removed and reoriented to its correct position. On April 2, 1998, a satisfactory PMT, including a leak rate test, was performed.
2.
Valve actuators on the other functional autoclaves were verified to be in the proper orientation.
3.
The following corrective actions were taken to address the root causes of this violation:
Briefings were conducted with Operations and Maintenance personnel on the
" Lessons Leamed" from this event. Also, site meetings were conducted, by June 17,1998, to emphasize the importance of procedural adherence.
Maintenance personnel were instructed to treat " General Intent" procedures similar to "In-Hand" procedures as an interim measure pending a review to determine proper procedure categorization.
The procedure requirements for proper installation of valve actuators have been reviewed with maintenance personnel in the X-340 autoclave complex.
The PMT requirements for replacement of actuators have been revised to include leak rate testing per the Technical Safety Requirements (TSR).
Additionally, the PMT requirements for autoclave work packages have been reviewed and revised, as necessary, by June 17,1998.
Peer reviews of PMTs were instituted by Engineering to ensure that TSR surveillance and the requirements of the Quality Assurance Plan are met for TSR related SSCs. Also, proceduralized guidance (XP3-EG-EG4010, " Post i
Maintenance Testing of Q, AQ, and AQ-NCS System, Structures, or l
Components") on developing PMTs was issued and became efTective on July 16,1998.
4.
The following corrective actions were taken to address the contributing causes for this violation:
The training module on the use of" General Intent" procedures has been revised to clarify the requirements regarding compliance with " General Intent" procedures.
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e GDP 98-0159 Page 4 of 4 Procedure XP4-TE-MM4104 was revised and became effective on June 15, 1998, to enhance the criteria for ensuring correct actuator installation.
Management expectations on the " Conduct of Operations" have been reemphasized with Operations personnel. This action was completed by July 29,1998.
III.
Corrective Steps to be Taken 1.
Revise the affected autoclave startup procedures to include steps for checkmg applicable containment valve position by August 14,1998.
2.
Review and develop a schedule to revise those " General Intent" procedures which should be re-categorized as "In-liand" by September 30,1998.
IV.
Date of Full Compliance Full compliance with violation "A" was achieved on March 27, 1998, when, upon discovering that FV-416X was operating opposite its design function, the autoclave was secured and declared inoperable. Full compliance with violations "D and E" was achieved by April 2,1998, when the FV-416X valve actuator was removed, reoriented to its correct position, and a satisfactory PMT, including a leak rate test, was performed.
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GDP 98-0159 Page 1 of 3 UNITED STATES ENRICIIMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATIONS (NOVs) 70-7002/98005 II.B AND II.C (03014 and 02034)
Restatement of Violations B.
Technical Safety Requirement 2.2.3.15, " Moderation Control," limiting condition for operating requires, in part, for cascade operational modes I, II, Ill, IV, V and VI, that
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moderation control shall be maintained when the UO F (uranyl fluoride) mass is greater than i
2 2 safe mass.
Action B.1 of Technical Safety Requirement 2.2.3.15, requires, in part, that equipment containing UO F deposits greater than safe mass not in a fluorinating environment and in 22 Mode VI, to be pressurized with plant air or N (nitrogen) to greater than or equal to 14 psia 2
within eight hours after a UF,(uranium hexafluoride) negative was obtained in the system.
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Contrary to the above, from March 31,1998, through April 8,1998, Cell 29-5-2 contained a UO F deposit with an enrichment of 5.5 percent of approximately 6238 grams (+/-3119 2 2 grams) of uranium-235, a deposit greater than safe mass, was not in a fluorinating environment and in Mode VI, and was not pressurized with plant air or N to greater than or 2
equal to 14 psia within eight hours as required.
C.
Technical Safety Requirement 3.9.1, requires, in part, that written procedures shall be implemented for the activities described in Safety Analysis Report (SAR) Section 6.11.4.1 and listed in Appendix A to SAR Section 6.11. Appendix A to SAR Section 6.11 requires communication activities to be covered by written procedures.
Section 6.4 of written Procedure XP2-TS-TS1032 Revision 0, dated September 11,1996, titled " Communications with Cascade Operations," requires, in part, that process services staff shall report sample results (requested by the Cascade Controller) to the Cascade Controller as the sample results become available.
Contrary to the above, process services staff failed to report sample results (requested by the Cascade Controller) to the Cascade Controller as the sample results became available for Cell 29-5-2 on March 31,1998.
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s GDP 98-0159 Page 2 of 3 USEC Response I.
Reasons for Violation As discussed at the predecisional enforcement conference, the root causes for these violations were:
1.
Lack of a procedure for verifying fluorinating environments for PEH deposits and; 2.
On January 30, 1998, following the discovery that PORTS did not have a surveillance requirement to verify that a fluorinating environment exist;d for shutdown equipment, the compensatory actions that were implemented did not contain sufficient rigorin that:
There were no requirements to submit written requests for samples; a.
b.
There were no requirements to provide written sample results; The compensatory actions did not address timeliness of communicating c.
sample results; and d.
The compensatory actions did not address actions to take for anomalous sample results.
II.
Corrective Actions Taken and Results Achieved 1.
Cell 29-5-2 was pressurized in accordance with TSR 2.2.3.15.B.I.
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Daily Operating Instructions (Dols) were revised to include additional controls such as: a) requirements to submit written requests for lab samples weekly; b) requirements to notify the lab of specific reporting constraints; c) requirements for lab personnel to provide written sample results within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from obtaining samples; and d) requirements to record and trend the data and identify if an adverse I
I condition is developing so prompt mitigating actions can be initiated prior to exceeding authorized safety limits.
3.
Sl'ift briefings and required reading were conducted for laboratory and cascade sonnel on communication of sample results.
4.
A PEII tracking procedure (XP2-CO-CM1700, "PEH Tracking") was issued which superseded the above DOIs.
5.
Actions to address anomalous sampling conditions for shutdown cells with PEll deposits were added to procedure XP4-CO-CN2110, "X330 Cell Sampling."
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GDP 98-0159 Page 3 of 3 III.
Corrective Steps to be Taken An " Extent of Condition" review will be completed by October 2,1998, to determine if there are other TSR requirements that require additional procedural coverage.
IV.
Date of Full Compliance Full compliance.was achieved on April 8,1998, when Cell 29-5-2 was pressurized in accordance with TSR 2.2.3.15.B.l.
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i GDP 98-0159 Page1of1 List of Commitments
- Severity Level III NOV Affected procedures will be revised by September 30,1998, to include surveillance testing of the backup air reservoir tanks.
NOV II. A. II.D. and II.E Review and develop a schedule to revise those " General Intent" procedures which should be re-categorized as "In-Hand" by September 30,1998.
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' Regulatory commitments contained in this document are listed here. Other corrective actions listed in this submittal are not considered regulatory commitments in that they are either statements of actions completed, or they are considered enhancements to USEC's investigation, procedures, programs, or operations.
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GDP 98 -0159 USEC Check No.16688 l
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