ML20217N586

Ack Receipt of 990927 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7002/99-09 Issued on 990827

ML20217N586
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant
Issue date:	10/22/1999
From:	Phillips M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Adkins J UNITED STATES ENRICHMENT CORP. (USEC)
References
70-7002-99-09, NUDOCS 9910290077
Download: ML20217N586 (2)

Text

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1 o October 22, 1999 l

1 Mr. J. N. Adkins -

Vice President - Production r United States Enrichment Corporation Two Democracy Center 6903 Rockledge Drive Bethesda, MD 20817

SUBJECT:

RESPONSE TO INSPECTION REPORT 70-7002/99009(DNMS) i

Dear Mr. Adkins:

I This refers to your September 27,1999, response to the Notice of Violation transmitted to you

' by our letter dated August 27,1999, with Inspection Report 70-7002/99009(DNMS). We have reviewed your corrective actions for the violations and have no further questions at this time.

Your corrective actions will be examined during future inspections. 1 If you have any further questions, please' contact me at (630) 829-9806.

Sincerely,

/

Monte P. Phillips, Acting Chief Fuel Cycle Branch Docket No. 70-7002 Certificate No. GDP-2 cc: J. M. Brown, Portsmouth General Manager P. J. Miner, Manage r~ , Nuclear Regulatory Affairs, Portsmouth H. Pulley, Paducah General Manager

-S. A. Toelle, Manager, Nuclear Regulatory . {

' Assurance and Policy, USEC ' \(

- Portsmouth Resident inspector Office Paducah Resident inspector Office R. M. DeVault, Regulatory Oversight Manager, DOE E. W. Gillespie, Portsmouth Site Manager, DOE J. R. Williams, State Liaison Officer DOCUMENT NAME: G:\SEC\POR102_9.dnm To receive a copy of ti.ledoch Indicate in the box:"C" = Copy without enclosure *E"= Copy with enclosure"N"= No copy FFICE Rlli M l( PA , W l l NAME Wied4gihn/djp '

M DATE- 10$S/99' 10/28/99 OFFICIAL RECORD COPY

.9910290077 991022 5 PDR ADOCK 07007002 C- PDR j a

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l J. Adkins 2-bec w/ltr dtd 09/27/99: Docket File PUBLIC (E-07 R. Pierson, NMSS P. Ting, NMSS W. Troskoski, NMSS P. Harich, NMSS Y. H. Faraz, NMSS R. Bellamy, RI EJM, Ril (e-mail)

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l September 27,1999 GDP 99-2055 .

U. S. Nuclear Regulatory Commission Attention: Docum'ent Control Desk Washington, D.C. 20555-0001 ' l Portsmouth Gaseous Diffusion Plant (PORTS)

Doeket .No. 70-7002 Reply to Inspection Report (IR) 70-7002/99009 Notice of Violation (NOV) 99009-02 The subject IR contained a violation involving inadequate corrective actions taken to address issues

.with the material condition of the railroad track and associated equipment. The United States Enrichment Corporation's response to this violation is provided in Enclosure 1. Enclosure 2 lists the commitments contained in this submittal. Unless specifically noted, the corrective actions specified in each enclosure apply solely.to PORTS.

If you have any questions regarding this submittal, please contact Peter J. Miner at (740) 897-2710.

Sincerely, M h

. Morris Brown

' General Manager Portsmouth Gaseous Diffusion Plant

Enclosures:

As Stated cc: NRC Regional Administrator - Region Ill NRC Resident inspector - PORTS

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991001024379D92I 7Dr ADOCK 07007002 PDR C

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United States Enrichment Corporation Portsmouth Gaseous Diffusion Plant P.O. Box 628, Piketon, OH 45661 i

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Enclosure 1 GDP 99-2055

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Page1of3 l UNITED STATES ENRICIIMENT CORPORATION (USEC) i REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/99009-02

\ l Restatement of Violation I

Title 10 of the Code of Federal Regulations (CFR), 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 l conditions adverse to quality shall be corrected as soon as practical.

, Appendix A of Procedure XP4-BM-CIl002, " Problem Report Screening Process," defliu - a condition adverse to quality to include failures to perform activities described in the Safety Analysis

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Report and to execute processes or procedures.

Contrary to the above, between June 3,1998, and June 2,1999, the plant management did not correct a condition adverse to quality as soon as practical. Specifically, the plant management did not correct deficiencies identified with the inspection criteria, preventative maintenance program, and the condition of the rail cars, track, switches, and safety appliances, until two railcars carrying cylinders filled with liquid UF. , an activity described in the Safety Analysis Report, derailed on June

! 2,1999.

USEC Response

Background

On May 20,1998, the Nuclear Safety Assurance (NSA) engineer, who was a member of the NSA assessment team for railcar safety, issued four problem reports (prs) to document findings identified during the assessment. Subsequently, on June 3,1998, NSA issued report NSA-X98-04, Nuclear Safety Assurance Assessment of Rail Car Safety.

Responses to the prs were submitted by Engineering in mid-June 1998, to address the report findings. The NSA engineer reviewed the PR responses and determined that three of the four report p findings had not been properly addressed. Therefore, on June 26,1998, the NSA engineer issued three additional prs to ensure these findings identified in NSA-X98-04 would be re-addressed.

l On August 27,1998, PR-PTS-98-06158 was written to document an empty rail car derailed in the middle of a rail switch south of Building X-343 when the rail cars were being moved into building X-343 for loading. A Corrective Action Plan (CAP) was written and approved for this PR in mid-October 1998, to address issues with the rail cars and rail track.

Enclosure 1 GDP 99-2055 Page 2 of 3 On January 15,1999, Engineering closed the three additional prs issued for report NSA-X98-04 to the PR for the August 1998, derailment stating that the CAP for PR-PTS-98-06158 is addressing the findings in NSA-X98-04.

The present status of the CAP for PR-PTS-98-06158 was recently reviewed with a focus on how the three additional prs issued for the findings in report NSA-X98-04 have been addresse,d. The results of this review showed th'a t: 1) only two of three actions relating to the first additional PR would be adequately responded to by the CAP; 2) the one action relating to the second additional PR would be adequately responded to by the CAP; and 3) the third additional PR was not adequately responded to by the CAP.

On June 2,1999, PR-PTS-99-03092 was written to document the derailment of two railcars carrying six cylinders ofliquid UF 6. A review of the CAP for this PR showed that one of the three actions relating to the first additional PR issued and the action relating to the third additional PR issued for the findings in report NSA-X98-04 will be adequately addressed upon successful completion of the CAP.

I. Reason for Violation The reason for the violation was the PORTS management staff was not accountable for the quality of the corrective action pmcess to ensure the prs were properly completed.

Responses to the initial four prs issued for the findings in report NSA-X98-04 were submitted as completed during the revisions PORTS was making to enhance the Corrective Action Program in mid-June 1998. These responses lacked quality based on the revised program requirements. The responses to two of the three additional prs issued were closed to an approved CAP of a different PR as allowed by the Corrective Action Program.

However, closing pan of the first additional PR and the third additional PR to this different PR also lacked quality in that corrective actions to address the issue were not adequate. In closing the three additional prs to another PR, the PORTS staff did not question the timeliness of the scheduled corrective actions based on the risk significance of these issues in relation to the other safety significant issues the site was working to resolve.

II. - Corrective Actions Taken and Results Achieved

1. Engineering evaluated the site rail track inspection process for improvement. This evaluation was completed and approved by March 29,1999, and detemiined that the current procedure and inspection process provides for a safe railway system for the movement of railcars carrying UF.. Therefore, no revisions to the site rail track inspection process was needed. (This action completed part of one action associated with the first additional PR issued for report NSA-X98-04).

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. Enclosure 1 i GDP 99-2055 I Page 3 of 3

2. On June 5,1999, a compensatory action was put into place to limit the movement of liquid UF 6cylinders on railcars to only straight sections of reinforced concret . nack l beds. l III. Corrective Actions to be Taken

1. Engineering will evaluate the interplant rail car inspectian process for improvement.

This will include a review of the periodicity, attributes, and specifications for the inspections and the inspection repon review process. This action will be completed by October 29,1999.

2. PORTS will revise the interr 't rail car i .spection process using the recommendations issued by Engine ig. This actic i will be completed by October i 29,1999.  ;

Note: Completing actions No. I and No. 2 stated above will resolve two of three actions relating to the first additional PR issued and will resolve the action relating to the second additional PR issued for report NSA-X98-04. j

3. Develop and issue a procedure that establishes an oversight process for the PORTS i railroad system. This action will be completed by December 17,1999.

Note: Completing this action will resolve the third action relating to the first additional PR issued and will resolve the action relating to the third additional PR issued for report NSA-X98-04.

4. Issue lessons learned bulletin from PORTS General Manager to reemphasize the importance of properly completing all conditions adverse to quality issues. This action will be completed by October 22,1999.

5. Perform a representative surveillance of recommendations, assessments, and reviews in selected PORTS organizations to determine if conclusions from these reports were adequately evaluated. This action is scheduled to be completed by October 15.1999.

IV. Date of Full Compliance Full complian:e with the cited violation will be achieved by December 17,1999, when the last corrective action to correct the deficiencies identified as conditions adverse to quality is scheduled for completion thus resolving and completing the three additional prs issued for report NSA-X98-04.

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, Enclosure 2 GDP 99-2055 Page1 of 1

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List of Commitments *

1. Engineering will evaluate the interplant rail car inspection process for improvement. This ,

will include a review of the periodicity, attributes, and specifications for the inspections and I the inspection report review process. This action will be completed by October 29,1999. )

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2. PORTS will revise the interplant rail car inspec; ion process using the recommendatio.is I issued by Engineering. This action will be completed by October 29,1999.

3. Develop and issue a procedure that establishes an oversight process for the PORTS railroad system. This action will be completed by December 17,1999.

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4. Issue lessons learned bulletin from PORTS General Manager to reemphasize the importance i of properly completing all conditions adverse to quality issues. This action will be co.mpleted by October 22,1999.

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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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