ML20247A600
| ML20247A600 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 04/27/1998 |
| From: | Jonathan Brown UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-7002-98-03, 70-7002-98-3, GDP-98-2018, NUDOCS 9805060171 | |
| Download: ML20247A600 (11) | |
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l USEC
.. A Global Energy Company April 27,1998 GDP-98-2018 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Portsmouth Gaseous Diffusion Plant (PORTS)
Docket No. 70-7002 Response to Inspection Report (IR) 70-7002/98003 Notice of Violation (NOV)
The subject Inspection Report (IR) contained four violations involving: 1) failure to implement Nuclear Criticality Safety (NCS) controls,2) failure to control access to an area where a Criticality Accident Alarm System was inoperable,3) failure to declare a crane inoperable during preventive maintenance, and 4) failure to implement appropriate corrective actions to account for instrument drift. USEC's response to these violations is provided in Enclosures 1 through 4, respectively. lists the commitments made in this report. Unless specifically noted, the corrective actions specified in each enclosure apply solely to PORTS.
If you have any questions regarding this submittal, please contact Dave Waters at (614) 897-2710.
Sincerely, M
Mw J. Morris Brown General Manager Portsmouth Gaseous Diffusion Plant Enclosures (5) cc:
NRC Region III, Regional Administrator
'NRC Resident inspector, PORTS 1
9805060171 990427
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l P.O. Box 800, Portsmouth, OH 45661 l
Telephone 614-897-2255 Fax 611897-2644 http://www.usec.com OMces in Livermor., CA Paducah, KY Portsmouth. Oil W.ishington, DC
1 GDP 98-2018 Page1of3 UNITED STATES ENRICHMENT CORPORATION (USEC) j REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/98003-01 1
I Restatement of violation Technical Safety Requirement 3.11.2 requires, in part, that all operations involving uranium enriched to 1.0 weight percent or higher U-235 and 15 grams or more of U-235 shall be performed in accordance with a documented nuclear criticality safety approval (NCSA).
Nuclear Criticality Safety Approval (NCSA)-330-004.A02, " Cascade Operations in the X-330 i
Building," requires that any cascade equipment shutdown (motor turned off) and at a Uranium f
Hexafluoride (UF ) negative shall have a plant dry air or nitrogen buffer at greater than or equal to 6
14 pounds per square inch absolute (psia).
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Contrary to the above, on February 4,1998, the )AB3 compressor cooler was discovered to be at a Uranium Hexafluoride (UF6) negative without a dry air or nitrogen buffer at greater than or equal to 14 pounds per square inch absolute (psia).
USEC Response I.
Reasons for Violation j
The reason for the violation was due to the lack of a proceduralized program for verifying i
and maintaining a fluorinating environment in cells or other equipment which is shutdown i
and contains a PEH deposit. Because the 29AB3 compressor cooler had been shutdown without establishing a UF negative, it was assumed that a fluorinating environment existed.
6 However, there was no program in place to monitor shutdown.:quipment on a set frequency to determine if the fluorinating environment existed. As a result, on January 30,1998, when the inspector questioned what surveillance activity was used to ensure that shutdown equipment is maintained in a fluorinating environment, the plant recognized that a process had not been established. Subsequently, when temporary compensatory actions were implemented, the facility discovered on February 4,1998, that a fluorinating environment had not been maintained for 29AB3 compressor cooler.
A similar violation was identified on April 8,1998, when cell 29-3-2 was discovere? to be below the minimum acceptable UF concentration for ensuring that a fluorinating 6
environment is maintained. This additiona! example was due to poor communication between operations and laboratory personnel. Specifically, operations had requested samples of the cell be taken and analyzed by laboratory personnel. However, the results of the samples were not processed and communicated to operations personnel in a timely manner i
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GDP 98-2018 Page 2 0f 3 (i.e.,8 days vice hours). Further, operations personnel failed to follow-up with the laboratory as to the results of the sample. As a consequence, by the time the results were determined, the fluorinating environment in cell-29-5-2 had already decreased below the allowed limit.
II.
Corrective Actions Taken and Results Achieved i
1.
On February 4,1998, when 29AB3 cooler was discovered at a PG negative and was not in a fluorinating environment, TSR LCO condition 2.2.3.15B was entered and a dry air or nitrogen buffer at greater than or equal to 14 pounds per square inch absolute (psia) was established.
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On April 8,1998, when cell 29-5-2 was discovered at a PG negative and was not in a fluorinating environment, TSR LCO condition 2.2.3.15B was entered and a dry air or nitrogen buffer at greater than or equal to 14 pounds per square inch absolute (psia) was established.
3.
On January 30,1998, administrative controls were implemented via Daily Operating Instructions (DOI) establishing compensatory actions for ensuring a fluorinating environment is maintained on shutdown PEH equipment that is not at a UF negative.
6 These controls were strengthened on April 24,1998 when poor commtmications resulted in a similar violation. These additional controls include:
Requirements to submit written requests for lab samples weekly.
Requirements to notify the lab of specific reporting constraints.
Requiremems 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.
Requirements to record and trend the data and identify if an adverse condition is developing so prompt mitigating actions can be initiated prior to exceeding authorized safety limits.
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Positive discipline was conducted for those individuals responsible for not maintaining a fluorinating environment in cell 29-5-2
-III.
Corrective Steps to be Taken i
Develop and implement a formal program procedure for tracking PEH equipment. The procedure will include detailed administrative control requirements for maintaining this PEll equipment in a fluorinating environment. This action will be completed by May 11,1998.
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GDP 98-2018 Page 3 of 3 IV.
Date of Full Compliance -
USEC achieved full compliance on February 4,1998, and April 8,1998, respectively when -
TSR LCO condition 2.2.3.15B was entered and a dry air or nit ogen buffer at greater than or equal to 14 pounds per square inch absolute (psia) was established for identified non-compliant PEH equipment.
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GDP 98-2018 Page1of2 l
UNITED STATES ENRICHMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/98003-04 Restatement of Violalion Technical Safety Requirement 2.8.1.3 requires that the criticality accident alarm be operable 1
(audible) in areas where the maximum foreseeable absorbed dose in free air exceeds 12 rad.
For an area that does not have an audible alarm, the required action is to provide personnel allowed j
in the area with an altemate means of criticality alarm notification, such as a device that will alarm i
on sensing a 10 mr/hr dose rate, or a radio in constant communication with the Plant Control Facility.
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Contrary to the above, on March 6,1998, two plant employees entered the X-102 cafeteria while the audible alarm slaved to the X-710 laboratory detection was inoperable and without an alternate means of criticality alarm notification.
USEC Response I.
Reasons for Violation The reason for the violation was a failure by plant Protective Forces personnel, who are responsible for establishing appropriate barriers, to follow procedure XP4-SS-SP1108; Protective Force Pre and Post Maintenance Activities. This procedure requires the use of plastic chains with magnets and "Do Not Enter" signs which are unique to CAAS boundary postings. However, Protective Force personnel deviated from the procedure and used l
common " Caution" barrier tape to establish the limited exclusion CAAS boundary. As a result, when craft personnel arrived on the scene, they assumed the boundary was in effect j
for their scheduled repair activity and entered the exclusion area; unaware that the associated j
CAAS system was inoperable and that the entry was a violation of the TSR. Furthermore, Protective Force personnel failed to communicate their inability to follow the procedure requirements to their supervisor.
II.
Corrective Actions Taken and Results Achieved 1.
When craft personnel were confronted by building personnel and became aware of the LCO, they immediately evacuated the limited operations area. Afler discussions with the NRC resident inspector, who was on the scene, they reported the incident to their supervision. These actions were et mpleted the day the violation occurred.
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Following the incident, required reading was performed by protective forces j
personnel consisting of the problem report, corrective actions taken and the labeling criteria fu establishing Limited Operations Areas. This action was completed by March 25,1998.
3.
Positive discipline was administered to Protective Forces Personnel during a face-to-face communications session by the Organizational Manager. All supervisors were provided written expectations associated with following procedures, and educated on the consequences of not following procedures. The final session was held on April 24,1998.
4 III.
Corrective Steps to be Taken No further action is required.
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Date of Full Compliance USEC achieved full compliance on March 6,1998, when craft personnel evacuated the area.
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GDP 98-2018 Page 1 of 2 UNITED STATES ENRICI! MENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/98003-05 Restatement of Violation Technical Safety Requirement 2.8.1.32.5.3.10 requires the extended range product (ERP) crane to be tagged out of service within one hour of declaring the crane inoperable.
Contrary to the above, on February 20,1998, the certificate rendered the ERP crane inoperable without tagging the crane out of service during a preventive maintenance activity.
USEC Response I.
Reasons for Violation As indicated in USEC's response to NOV 97015-02, the reason for the violation was inadequate training, in that Cascade First Line Managers (FLMs) did not understand the significance of the work start approval process or the full. meaning of what their approval signature implied as related to safety and/or plant conditions. In addition, the corrective action plan associated with work start approval (i.e., USEC's response to NOV 97015-02) had not been fully implemented to prevent recurrence.
Specifically, the work control procedure (i.e., XP2-GP-GP1030; Work Control Process) establishes the FLM's responsibility related to work start approval. However, in the case of the cited violation, the FLM did not perform and adequate technical revi:w of the preventive maintenance work package, confirm that the ERP crane was in the proper configuration to support the maintenance activity, complete the operali!ity determination, or ensure appropriate TSR LCOs were implemented. This situation was discovered when the work package was presented to the next shifts Cascade Operations FLM for testing and close out after it was detemlined that cascade corrective maintenance was performed in addition to the preventive maintenance activity.
II.
Corrective Actions Taken and Results Achieved 1.
Upon discovery of the non-conformance, the PSS declared the ERP crane inoperable.
This action was completed on February 20,1998.
2.
Cascade FLMs were briefed by their respective Facility Managers on the lessons learned from two recent events where TSR violations occurred because work start approval was granted by a manager without understanding plant conditions or the l
GDP 98-2018 Page 2 of 2 scope of the work (i.e., the event cited in this violation and a similar event identified in NOV 97015-02. The briefings further communicated cascade management's expectations on work start authorization and the procedural requirements af XP2-GP-GP1030; IVork Control Process, relating to the FLM's responsibility for Work Start Approval. FLM briefings were conducted between February 24,1998 and March 13, 1998.
III.
Corrective Steps to be Taken Work Control Training module WCT 01.05; Work Controlfor Support Groups, will be reviewed b) Cascade Operations to ensure the teaming objectives are appropriate for FLM's and modified by Work Control as appropriate to incorporate the lessons learned from the events which resulted in this citation. In addition, this training module will be added to the required training list for new Cascade Operations FLM's by May 29,1998.'
IV.
Date of Full Compliance USEC achieved full compliance on February 20,1998, when the ERP crane was declared inoperable.
'This commitment was previously made in USEC's response to NOV 97015-02 (see GDP 98-2012 dated March 26,1998). Therefore, this action is not a new regulatory commitment with respect to this violation.
GDP 98-2018 Page1of2 UNITED STATES ENRICHMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/98003-06 Restatement of Violation 10 CFR 76.93, " Quality Assurance," requires that the Corporation shall establish, maintain, and execute a quality assurance program satisfying each of the applicable requirements of American Society of Mechanical Engineers (ASME) NQA-1-1989," Quality Assurance Program Requirements for Nuclear Facilities."
ASME NQA-1989 Basic Requirement 16," Corrective Action," states that conditions adverse to quality (CAQs) shall be identified promptly and corrected as soon as practical.
Appendix A, of Procedure UE2-HR-CI1031," Corrective Action Process," lists out of calibration instrumentation, including "as found" condition, as a specific example of a CAQ.
Contrary to the above, the certificate did not correct a problem with the autoclave low cylinder pressure shutoff system setpoint that did not account for instrument drin. As a result, the certificate operated Autoclave Numbers 4 and 6 at the X-343 Building between April 18, and November 11, 1997, during which time the setpoints drifted well below 20 psia, the minimum required by Technical Safety Requirement 2.1.3.9.
I.
Reasons for Violation The reasons for the violation were: 1) a non-conservative decision regarding the operability of autoclaves that were operating or had the potential to be operated below the revised i
setpoint; and 2) the failure to implement adequate controls to prevent the operation of autoclaves below the revised setpoint As indicated in the IR, following the discovery of two autoclaves that were outside the acceptance criteria for the low cylinder pressure shutoff system, the proceduralized setpoint for the autoclaves was increased from 20 psia to 23.1 psia to account for instrument drift.
However, plant personnel made a non-conservative decision that the remaining autoclaves could be operated at the old setpoint of 20.0 psia (i.e., the TSR limit) until the next scheduled calibration could be performed and the new setpoint implemented. Additionally, a formal Operability Evaluation (OE) was not perfonned to document this decision.
This calibration issue was revisited on October 28,1997, when engineering learned that the l
original calculated instrument drift was potentially greater than initially calculated due to a change in vendor supplied literature. An OE was prepared on October 29,1997, concluding that operations could continue to operate the autoclaves with a target setpoint of 23.1 psia, l
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but failed to confirm the autoclaves were recalibrates to the previous design calculated setpoint & tolerance value.-
II.
Corrective Actions Taken and Results Achieved 1.
'On January 23,1998, the inspector reviewed surveillance data and noted that as-found data taken on two autoclaves were below the TSR limit. Engineering reviewed this-same information.with the inspector and agreed that a TSR violation had occurred and appropriate notifications were made. At that time,it was determined that the Portsmouth facility was in full compliance with the TSR. This determination was based on the fact that, as of December 8,1997, the autoclaves were recalibrates to the calculated target setpoint except for the X-343 Autoclave #6 which was shutdown on September 1997, in support of the Nuclear Safety Upgrade Project.
2.
Between October 1,1997 and December 31,1997, Design and System Engineers received formal training on Operability Evaluations and the control mechanism imposed by the process. This action has improved engineering sensitivity through a heightened awareness of the overall process. It is believed that if the conditions surrounding this issues were to occur today, the controls would prevent recurrence.
III.
Corrective Steps to be Taken The engineering organization will communicate the lessons learned from this violation to enhance design engineers, systems engineers, and Plant Shill Superintendents understanding and sensitivity to operability evaluations. These briefings will be completed by May 30, j
1998.
'IV.
Date of Full Compliance USEC achieved full compliance on December 8,1997, when the autoclaves were determined to have been recalibrates to the calculated target setpoint.
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GDP 98-2018 Page1of1 List of Commitments
' NOV 70-7002/98003-01 Develop and implement a formal program procedure for tracking PEH equipment. Procedure will include detailed administrative control requirements for maintaining this PEH equipment in a l
fluorinating environment. This action will be completed by May 11,1998.
NOV 70-7002/98003-04 i
l No further action required NOV 70-7002/98003-05 Commitments previously submitted in USEC's response to NOV 70-7002/97015-02 NOV 70-7002/98003-06 The engineering organization wil.I communicate the lessons leamed from this violation to enhance design engineers, systems engineer, and Plant Shift Superintendents understanding and sensitivity to operability evaluations. These briefings will be completed by May 30,1998.
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