ML20212G940
| ML20212G940 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 09/23/1999 |
| From: | Phillips M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Adkins J UNITED STATES ENRICHMENT CORP. (USEC) |
| References | |
| 70-7002-99-04, NUDOCS 9909300159 | |
| Download: ML20212G940 (3) | |
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J p September 23, 1999 l
' Mr.1 N. Adkins ._ _
Vice President - Production - 1 United States Enrichment Corporation Two Democracy Center
, 6903 Rockledge Drive .
Bethesda, MD .20817 l
SUBJECT:
RESPONSE TO INSPECTION REPORT 70-7002/99004(DNMS)
Dear Mr. Adkins:
This refers to your August 6,1999, reply to the Notice of Violation (Notice) transmitted to you by .
our letter dated May 21,1999, with inspection Report 70-7002/99004. United States Enrichment Corporation (USEC) originally responded to our May 21,1999, letter on June 21, 1999.; However, NRC identified concerns with USEC's understanding of theissues and the effectiveness of corrective actions proposed. Subsequently, the NRC held a telephone conference with USEC Headquarters and Portsmouth plant staff on July 15,1999, to express
! ~ these concems and to request a revised response. We have reviewed your revised reply, and unfortunately, have determined that your responses to Violations 1.B and 1.C do not fully address the informational needs specified in the Notice and as clarified in the July 15,1999, teleconference. ,
.Your responses to the other violations meet the requirements of 10 CFR 2.201. Your corrective
-. actions for these violations will be examined during future inspections.
l . With regard to Violation 1.B our Notice detailed deficiencies in: (1) USEC's review of referenced and relied upon calculations for adequacy and applicability and (2) USEC's identification and documentation of assumptions related to the fissile material operations.
Section I, " Reasons for the Violation," example b, identified deficiencies in the plant's corrective
- actions specific to this violation which were not addressed or resolved in Section ll, " Actions i Taken and Results Achieved," or in Section ill, " Actions to be Taken." in addition, your !
l response did not address all of the deficient examples identified by the NRC, including those associated with POEF-340-98-113 and POEF-520-94-54 (although POEF-340-98-113 is l L
mentioned in Section 11 as subsequently being reviewed by plant staff, no explanation of the j reasons for the deficiency were discussed).
Specifically, the corresponding corrective actions specified in Section ll item (1) indicate that dol-832-99-03 was issued on June 17,1999, to instruct nuclear criticality safety (NCS) !
engineers in the appropriate peer review of referenced calculations. However, this action appears to restate an existing procedural requirement from XP4-EG-NS1001, " Nuclear ,
Criticality Safety Evaluations and Approvals" and an existing general requirement of your dafety i
'~ 9909300159 990923 PDR ADOCK 07007002 C PDR g
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- J. Adkins -
2-Analysis Report'(SAR) Section 5.2.2.2. " Nuclear Criticality Safety Responsibilities," which does
- not provide the NRC with any additional assurance that such action will prevent recurrence of
- the same or similar violations. Further, your contextual paragraphs addressing the violation 1
- indicate that the linkage between the nuclear criticality safety approval and the calculations was not initially identified because the referenced calculations were embedded within the evaluation . ,
- instead of being provided as a reference list at the end of the document. Your response indicates that your NCS Writer's Guide has been revised to require a full list of references at the back of the nuclear criticality safety evaluation (NCSE), but this action is not listed as a specific action under Section 11 and no commitment is made to ensure other currently active NCSEs ,
have adequately captured all referenced documents or why such assurance may not be ;
necessary.
You specifically elaborate on the reasons why NCSE-0705-015 was allowed to remain active for an extended period of time following discovery of inappropriately-reviewed supporting calculations by discussing the specifics of one supporting calculation, NCS-CALC-97-004. You explain in moderate detail the safety-specific reasoning of both the NCS manager and the NCS engineer for determining the impact that a potential error in NCS-CALC-97-004 would have on NCSE-0705-015 and why such potential impacts were considered non-credible. ,
However, the NRC would expect such safety-specific detail to have been documented as part l of the technical review and evaluation of the NCSE as required by SAR Section 5.2.2.3,
" Process Evaluation and Approval." You do not provide appropriate corrective actions for such a deficiency within your response. Finally, your explanation of reasons for the violation appears to identify repeated failures to adequately address this issue generically and raises questions conceming the adequacy, and particularly the effectiveness of the NCS corrective action plan effort to date which are not appropriately resolved within your response. ;
With regard to Violation 1.C, our Notice specifically detailed deficiencies in NCSE-0705-015 related to the lack of appropriate justifications for the use of unlikely events to support one or both legs of the double contingency principle. However, your response only considered incomplete documentation associated with NCSE-PLANT 079 (one example cited by the NRC). ,
By only addressing the specifics of NCSE-PLANT 079, your response lacks a comprehensive j understanding and reasons for the violation from a generic issues standpoint. Although Sections ll and lit list actions related to the use of unlikely events, they do not address the results achieved from USEC's review of this issue.
Because your reply did not fully address the informational needs specified in the Notice, you are required to resubmit a response to the Notice within 30 days of the date of this letter. We will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.
in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and
' your response will be placed in the NRC Public Document Room.
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l l J. Adkins l l
If you disagree with the conclusions reached, we will gladly discuss any concerns you have.
Sincerely, 1
Monte P. Phillips, Acting Chief Fuel Cycle Branch -
Docket No. 70-7002 Certificate No. GDP-2 cc: J. M. Rmwn. Portsmouth General Manager P a. Miner, Manager, 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 bec w/ltr dtd 08/06/99: Docket File PUBLIC IE-07 R. Pierson, NMSS P. Ting, NMSS W. Troskoski, NMSS P. Harich, NMSS Y. H. Faraz, NMSS j R. Bellamy, RI EJM, Ril (e-mail)
D. B. Spitzberg, RIV DOCUMENT NAME: G:\POR99004.RES To receive a copy of this document, Indicate in the box:"C" = Copy without enclosure "E"= Copy with enclosure"N"= No copy DFFICE R,1llj % l N h, /., l
! NAME GLGf:Itf' N.Galle-.y />, fe4 %
DATE 09/z3/99 9//M/91 OFFICIhL RECORD COPY C [119
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kUSEC' A Global Energy Company August 6,1999 GDP 99-2044 l
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U. S. Nuclear Regulatory Commission !
Attention: Document Control Desk i Wasmngtog, D.C. 20555-0001 . .
Portsmouth Gaseous Diffusion Plant (PORTS)
Docket No. 70-7002 Revised Reply to Inspection Report (IR) 70-7002/99004 Notice of Violations (NOVs) 1 In a letter dated June 21,1999, the United States Enrichment Corporation (USEC) replied to four i violations (see USEC letter GDP 99-2033) contained in NRC IR 70 7002/99004.
During a telephone conference that occurred on July 15,1999, the NRC expressed concerns with USEC's response to this IR. USEC agreed to revise our response to this IR by August 6,1999.
Accordingly, Enclosure I through 4 provides 'the requested information. Enclosure 5 lists the commitments contained within this submittal. The revisions to the enclosures are indicated by change bars in the right hand margin. Unless specifically noted, the corrective actions specified in the enclosures apply solely to PORTS.
Ifyou have any questions regarding this submittal, please contact Peter J. Miner at (740) 897-2710.
Sincerely, -
W 5^ 0 J. Morris Brown General Manager Portsmouth Gaseous Diffusion Plant
Enclosures:
As Stated cc. NRtTe* gen"aTMmTisfrator4 Region III#
NRC Resident inspector - PORTS NRC Chief, Enrichment Section, NRC Special Projects Branch United States Enrichment Corporation
' Portsmouth Gaseous Diffusion Plant AW1 1
- P.O. Box 628. Piketon. OH 45661 Y M'O [ /Of.
Enclosure 1 GDP 99-2044 Page 1 of 6 UNITED STATES ENRICIIMENT CORPORATION (USEC)
REVISED REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/99004-01 Rutatement of violation I
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Technical Safety Requirement 3.11.1 tequires, in part, that the Nuclear Criticality Safety Program shall be established, implemented, and maintained as described in the Safety Analysis Report and shall address process evaluations and approvals.
Safety Analysis Report Section 5.2.2.3," Process Evaluation and Approvals," required, in part, that Die nuclear criticality safety evaluation process shall include: 1) a determination of the credible process upsets which need to be considered; 2) the development of controls necessary to meet the double contingency principle; and 3) the identification of the assumptions and equipment needed to ensure nuclear criticality safety.
Contrary to the above, as of March 12,1999, the certificatee failed to determine all credible process upsets, develop controls necessary to meet double contingency principle, and identify all the assumptions and equipment.needed to ensure nuclear criticality safety for Nucler.r Criticality Safety Evaluation (NCSE) 0705-015 and Plant 079. Specifically, the certificatee did not:
- a. Identify the presence of and applicable controls for materials (e.g., Polyvinyl Chloride),
involved with the operations, which could affect nuclear criticality safety (NCSE 0705-015);
- b. Perform and document reviews, for adequacy and applicability, of referenced and relied upon calculations and did not identify and document assumptions related to the fissile material operations (NCSE 0705-015 and Plant 079);
- c. Identify or document controls and justifications, in terms of the availability and reliability, necessary to support the use of"unlikely events" as a part of the double contingency principle (NCSE 0705-015).
I. Reason for the Violation The reason for the violation is due to a combination ofinadequate procedure guidance and the fact that previous corrective ations had not yet been fully implemented. The specific reasons for each of the identified examples are detailed below.
Examnle a .
The reason for this example of the violation was due to an inadequate procedure. Procedure j XP4-EG-NS I 100, " Nuclear Criticality Safety Calculations," does not specifically include l
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Enclosure 1 GDP 99-2044 i Page 2 of 6 instructions to account for uncertainties in the neutron cross-sections in the materials of construction. This lack ofprocedural guidance resulted in a failure to account for chlorine in the calculations used to support NCSE-0705_015.A09. Contributing to the violation was an inadequate review of the NCSE since procedure XP4-EG-NS1001," Nuclear Criticality Safety Evaluations and Approvals," requires the Nuclear Criticality Safety (NCS) engineer to ensure calculations used in an NCSE contains sufficient detail to justify the basis and bounds the condition analyzed.
Example b The reason for the violation was because corrective actions had not been fully implemented. l As a result of a previous violation, on May 7,1998, PORTS committed to re-verify ;
calculations used in support of NCSE/As which were performed by unqualified engineers 1 (Ref: Task 26 of the NCS CAP Revision 4). This commitment was made after NCSE- l 0705_015.A09 was activated in the field (i.e., April 9,1998). The review and re-verification of all calculations 'were performed in conjunction with numerous other activities associated with the NCS Corrective Action Plan (CAPI %ulations were assessed / evaluated and a matrix was generated on June 30,1998, to clem.. tify those calculations which appeared inadequate and/or had not been peer reviewed by qualified personnel. In addition, I calculations which were identified at that time as questionable, were reviewed for safety significant concems. l l
Documentation indicates that Task 26 was officially listed as complete on June 30,1998. l The task was listed as complete before an official target completion date was ever established I with the NRC (see GDP 98-0147, Enclosure 1). However, the original documentation for l Task 26 completion did not include calculations NCS-CALC-97-004 and NCS-CALC l 012, which were utilized in NCS A-0705_015, and which had not yet received the appropriate l additional peer reviews. This occurred because the person originally responsible for l completing Task 26 did not identify that these calculations had been used to suppon NCSA- l 0705_015. The linkage between the NCSA and the calculations was not initially identified I because when the NCSA/Es were searched for calculational references, the references to the l calculations used in NCSE-0705_015 were embedded within the evaluation instead of l provided in a reference list at the end of the document. Subsequent revisions to NCSE- l 0705_015 have established a full reference list at the end of the document. In addition, the l PORTS NCS Writer's Guide for NCSA/Es has been revised to require a full list of references I at the back of the NCSE. I l
Subsequently in August 1998, all of the NCSEs were reviewed again to ensure that all I utilized calculations had been identified. At this time, calculations NCS-CALC-97-004 and l NCS-CALC-97-012 were identified as being used in NCSA/E-0705_015 and requiring I additional reviews. The additional review for NCS-CALC-97-012 was completed promptly l
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! , GDP 99-2044
! Page 3 of 6 in August 1998. -However, the additional reviews for NCS-CALC-97 004 were not l completed until March 1999.' The additional reviews for this calculation were not assigned l a high priority because the system being modeled in NCS-CALC-97-004 was a favorable l 1 L . geometry system with minimal interaction effects, which could have been shown to be 1 i suberitical without performing KENO calculations. While the calculation had been l referenced in the NSCE as demonstrating subcriticality of the pH controller it was not used I f l
to develop any specific NCS controls for the controller. Therefore, the possibility of a safety l ,
. significant error in NCS-CALC-97-004 which would affect the results of the evaluation or l the NCSA controls was considered non-credible by both the NCS Manager and the NCS l Engineer who authored NCSA-0705_015.A09. This is also the reason why NCSA- l 0705_015.A09 was not deactivated pending the completion of the additional reviews and l associated paperwork. The additional reviews eventually confirmed that there were no safety l significant errors in NCS-CALC-97-004. l l
Example c The reasons for this example of the violation were due to an inadequate procedure (XP4-EG-
- NS1001) and 'due to confusing or incomplete documentation in NCSE-PLANT 079.
Specifically, in the~first case, personnel were not required, by procedure, to specify the quantity and type ofinformation needed to support the use of unlikely events. In addition, NCS personnel did not routinely include the depth of information needed to adequately
- justify the use of unlikely events to show double contingency. In the second case, the NCSE did not document assumptions relating to the potential need to cover all containers (i.e., not just the equipment containing the deposit) with pre-staged moderation covers in the event of a fire sprinkler discharge. Our investigation concluded that additional controls for moderation covers were not needed for the containers, because the permitted containers were
, either safe under optimum moderation conditions, or else the moderation controls were l already specified in other NCSAs for the containers in question. The conflict in the controls relate to the NCSE stating that " interaction was not controlled," even though Section A.I.0
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of the NCSE required a 10-foot separation between the uranium deposits and other fissile material containers. Thus, personnel did not document interaction control in the proper section (A.7) of the NCSE or document why moderation controls were not necessary for 1' containers used to collect deposit material.
During the team review of NCSA-PLANT 079, the determination was made that the currently l
. active NCSA and NCSE were acceptable as is and did not require a Priority 1 NCSA l rpgrade. The team consisted of a qualified NCS Engineer, a System Engineer, an Operations l l Front Line Manager, and an operator from the Cascade. The team utilized a checklist which l l focused on identifying safety significant problems in the NCSA/E, problems in l l
implementation, and problems in the NCSA/E documentation that would jeopardize l I compliance with regulatory basis documents. As part of this review, the team focused on l j whether or not the controls in the NCSA were appropriate (i.e., all necessary controls were l i
Enclosure 1 GDP 99-2044 l ,
Page 4 of 6 y specified in the NCSA) and could be implemented in the field. Since the necessary l interaction controls were specified in the NCSA, the documentation of these interaction l controls in Section A.10 (Other) of the NCSE as opposed to Section A.7 (Interaction) was l notjudged by the team to be a safety significant flaw in the documentation. Similarly, the l
' failure to document why moderation controls (covers) were not required for the permitted l containers was notjudged to be a safety significant problem with the document, because in j the final analysis, the covers are not required for the criticality safety of the containers, as l documented in'other NCS evaluations. The commitment has been made to revise and j implement the documents by September 30,1999, consistent with the remainder of the l
- Priority 1 NCSAs. I II. Actions Taken and Results Achieved
- 1. On June 17,1999, NCS issued DOI-832-99-03 which requires NCS engineers to ensure calculations referenced in an NCSE/A are appropriately peer reviewed and 1 approved.
This DOI was revised and reissued on July 29,1999, to include any document (not l l just NCS calculations) utilized to support the safety basis in a NCSE. Documents l received from organizations other than NCS which become part of the safety basis l ;
for an NCSE are to be reviewed by both the NCS Engineer and peer reviewer to l ,
ensure that the conclusions of the document adequately support the NCSE and are l I utilized correctly (within its area of applicability) in the NCS document. I j
- 2. On May 10,1999, procedure XP4-EG-NS1001, was revised and implemented to j include a definition of"unlikely events" and provided instructions on using "unlikely i events"in an evaluation.
- 3. On March 5,1999, a preliminary review of NCSE/As was performed to identify where '.'unlikely events" were used as single, stand alone contingency controls and confirm that the controls were justifiable.
- 4. Required Reading was conducted with the NCS staff to re-emphasize the use of l
" materials of construction" credited in NCS evaluations. This action was completed l
- by July 12,1999. (Note: The original commitment due date of June 30,1999, for this l l action was not met. The PORTS NRC Resident Inspectors were informed on June l
- l. 30,'1999, that this action was not completed). i S. NCS generated final calculations investigating the effects of chlorine concentration I and distribution and revised NCSE-0705_015.A09 to include any changes which l were required as a result of the final calculations. This action was completed by July l 30,1999. l ;
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. 1 Enclosure 1
. GDP 99-2044 Page 5 of 6 I' ,.
l 6 :. PORTS revised NCSE-0705,_015.A09 to include sufficient justification as to the l availability and reliability of the control for "unlikely events" used as a single control l l for either leg of the double contingency matrix. During this effort, POEF-340-98-113 l was reviewed and confirmed to have been referenced correctly. This action was l completed by July 30,1999. l l
- 7. PORTS reviewed implemented NCSE/As to ensure "unlikely events" used as single l controls for either leg of the double contingency matrix had sufficient justification l as to the availability and reliability of the control. This action was completed by July l 16,1999. l l
8.' A lessons teamed was developed for NCS engineers, NCS sub-committee members, l and PORC members to emphasize the importance of documenting assumptions made l in NCSEs, and documenting controls in the correct section of the document. This l ,
action was completed by July 16,1999. -l 1 III. Actions to be Taken
- 1. By September 30,1999, NCS will revise procedure XP4-EG-NS1001, " Nuclear l Criticality Safety Evaluations and Approvals," to incorporate the requirements documented in DOI-832-99-03.
- 2. By November 30,1999, NCS will revise procedure XP4-EG-NSI100, " Nuclear l Criticality Safety Calculations," to include instructions to account for uncertainties in the neutron cross-sections in the materials of construction.
- 3. P6RTS will revise and implement NCSE-PLANT 079, by September 30,1999, to l !
document interaction controls in the proper section and to document why moderation ,
controls are not required for collection containers.
- 4. By September 30,1999, PORTS will review and revise any support calculations (and l
. associated NCS evaluations) associated with Priority 1 NCSAs which did not l properly account for variances in materials of construction. l
- 5. By May 18,2001, PORTS will review and revise any support calculations (and l )
associated NCS evaluations) associated with non-Priority 1 NCSAs which did not i i properly account for variances in materials of construction. l l Y
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l Enclosure 1 L GDP 99-2044 l Page 6 of 6 l.
! .IV. Date of Full Compance '
USEC will achieve compliance with the specific issues associated with the violation on September 30,1999, when both NCSE-0705_015 and NCSE-PLANT 079 are revised and !
implemented.
V. Additional Concerns Identified in the Inspection Report Examnie a An additional concem was noted in the inspection report with respect to the applicability of l results from calculation POEF-520-94-036," Criticality Safety Analysis of a Preliminary l Design for an F-can Secondary container" to the evaluation performed in NCSE-0705_015. l Specifically, the inspection report noted that followup discussions with the NCS Manager l revealed that the chlorine worth was not determined for the microfiltratimi evaluation l 4 because the above calculation had modeled criticality experiments involving the use of PVC, l and had concluded that a positive K-effective bias existed. The concem documented in the l inspection report is that the reasoning for and applicability of the calculation to NCSE- l 0705_015 was flawed. Specifically, there is no evidence in the calculation to support the l conclusion that the positive bias was due to the use of the chlorine cross sections and not due l to some other effect. In addition, the calculation is not referenced as part of NCSE- l 0705_015. (Note: A corrective action addressed this concem as discussed in Section II, item l 5 above). l Examole b The inspection report included an additional concern related to POEF-340-98-ll3 being referenced in NCSE-0705_015.A09 as an unreviewed calculation. This document is not an NCS calculation, rather it is an explanation of the chemical relationship between pH and uranium and was generated by a laboratory chemist. The NCS staff specifically requested the generation of this document because of the specialbed nature of the concem. POEF-340-98-113 was generated in accordance with approved procedures. The specific concem l identified was that the plant had not reviewed the document to determine whether the l conclusions adequately supported the NCSE-0705_015 assumed chemical behavior of I uranium concentration for various pH operational ranges. During the effort to revise and i peer review NCSE-0705_015.E10, POEF-340-98-il3 was reviewed and confirmed to have l been referenced correctly, l
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I Enclosure 2 GDP 99-2044 Page 1 of 2 UNITED STATES ENRICHMENT CORPORATION (USEC)
REVISED REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/99004-02 Restatement of Violation i
Technical Safety Requirement 3.11.2 requires, in part, that all operations involving uranium enriched to 1.0 weight percent or higher uranium-235 and 15 grams or more of uranium-235 shall be based upon a documented nuclear criticality safety evaluation and shall be performed in accordance with l
a documented nuclear criticality safety approval.
Contrary to the above, as of March 12,1999, the certificatee conducted laboratory activities, in support of NCSE 0705-015 which involved uranium enriched to greater than 1.0 weight percent uranium-235 and 15 grams or more or uranium-235, that were not based upon a documented nuclear criticality safety evaluation. Specifically, the laboratory staff:
- a. Conducted analyses of nuclear criticality safety-significant samples using a single laboratory -
technician to prepare samples for, and to perform, the wet chemistry process, with and I
wi.hout the,use of the spectrophotometer instrument and with the mass spectrometer instrument, without an evaluation of the operation and without an identification of the required controls necessary to avoid a loss of double contingency; and l
- b. Conducted analyses of nuclear criticality safety-significant samples using the mass ,
spectrometer and spectrophotometer instruments, without an evaluation of the operation and without an identification of the required controls to ensure that any out-of-control measurements on the low side would be detected and evaluated in a timely manner to avoid a potential loss of double contingency.
I. Reason for the Violation The reason for the violation was because corrective actions associated with the Nuclear Criticality Safety (NCS) Corrective Action Plan (CAP), Task 3, had not been fully l implemented. Specifically, NCSA upgrades have not been performed for laboratory activities l such as for NCSA-PLANT 053," Uranium Analysis and Sampling." The review of this NCSA is currently on the Priority 2 list of NCSE/As to be reviewed and upgraded.
II. Actions Taken and Results Achieved
- 1. On June 17,1999, PORTS issued a policy statement which requires out-of-control measurements for NCS significant samples be reported to NCS for evaluation.
. Additional requirements on out of control measurements on spectrometers and I l
spectophotometers were not warranted since the transfer of uranium material to an l L
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Enclosure 2 GDP 99-2044 Page 2 of 2 unsafe geometry is not performed without the results from the laboratory Quality l Control being checked. In the case of cascade mass spectrometers, the transfer of l material to unsafe geometry cylinders is analyzed as being double contingent without l reliance on the quality control checks being performed on laboratory mass i spectrometers.
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- 2. On April 28,1999, two Daily Operating Instructions (Dols) were issued to facility personnel. Specifically, DOI-705-99-12, was issued to X-705 to provide instruction and restricted operations personnel from processing solutions prior to receiving results of the independent samples. DOI-340-99-01, was issued to provide instmetion on the identification of NCS significant samples and the revised analysis approach.
In addition, DOI-340-99-01, provides guidance which now requires NCS significant samples to be independently analyzed'using two different laboratory technicians. l These DOIs will remain in effect and be incorporated into procedures, if necessary, l ,
after the completion of the upgrade of NCSA-PLANT 053. l )
- 3. On April 28,1999, an anomalous condition report was completed to evaluate the use l of a single technician for NSC significant samples and determined that "there were ;
l no credible scenarios that could result in a criticality due to the same person performing the analysis." It has been determined that there were no credible l scenarios involving a loss of double contingency. l ;
- 4. Existing NCSAs were reviewed to confirm Fissile Material Operation support l functions are properly identified and/or applicable to the evaluation. This action was l completed by July 30,1999. I l III. Actions to be Taken
- 1. NCSA-PLANT 053 will be modified or a new NCSA will be developed, as needed, to address independence of NCS significant samples and provide controls for out-of-control measurements on the low side to ensure the condition is detected and evaluated in a timely manner. This action will be completed as part of Task 3 of the l NCS CAP which is scheduled to be completed by July 30,2000. l l
I IV. Date of Full Compliance l USEC will achieved compliance with the specific issues cited in the violation when NCSA-l PLANT 053 is modified or a new NCSA is written to address independence of NCS significant samples and provide controls for out-of-control measurements. Daily Operating Instructions and a Policy Statement have been issued to ensure NCS significant sample s are independent, restrict operations personnel from processing solutions prior to receiving results of the independent samples, and to require out-of-control measurements for NCS significant samples be reported to NCS for evaluation.
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L t Enclosure 3 GDP 99-2044 l Page1of2 UNITED STATES ENRICHMENT CORPORATION (USEC)
REVISED REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/99004-03 Restatement of Violation l
Technical Safety Requirement 3.11.1 requires, in part, that the Nuclear Criticality Safety Program shall be established, implemented, and maintained as described in the Safety Analysis Report and shall address identification of safety system components and support systems necessary to meet the double contingency principle.
Safety Analysis Report Section 5.2.2.8, " Change Control," required, in part, that functional and physical characteristics of operations controlled for nuclear criticality safety were described in nuclear criticality safety evaluations and approvals. Components and features which were identified in the nuclear criticality safety evaluations and approvals were analyzed to determine the " boundary" of the system, encompassing those items that were essential to ensure operability. Structures, systems, and components which require configuration control were identified as quality (Q) or augmented quality (AQ)-NCS.
Contrary to the above, as o? March 12,1999, the certificatee did not identify the filter press blank plate, a component relied upon for double contingency in Nuclear Criticality Safety Approval NCSA-0705-015.A09 and essential to ensure operability, as an item relied on for criticality safety in the Boundary Definition Manual and did not classify the filter press blank plate as an AQ-NCS item.
I. Reason for the Violation The reason for the violation was due to an inadequate Structure, System, and Component (SSC) classification procedure, XP3-EG-EG1037, " Establishing and Controlling Quality Boundaries." Specifically, the procedure lacked sufficient detail to ensure AQ-NCS SSCs were correctly identified which resulted in the blank filter press plate being removed from the " passive design features" section of NCSA-0705_015.A09 during the NCSE/A review and approval process. Contributing to the cited violation was inadequate corrective actions.
Specifically, VIO-98-206-02 stated that SSCs in NCSA/Es 0326_013 and 0326_024 were not classified as AQ-NCS items. USEC responded to the violation and indicated the violation was due to inadequate guidance for classifying SSCs required to meet the double contingency principle. Procedure XP3-EG-EG1037 was revised as of August 27,1998, and the new criteria was used to review NCSA-0705_015.A09 which subsequently did not
, identify the filter press blank plate as AQ-NCS. Thus, the procedure used for classifying l
AQ-NSC SSCs continues to contain inadequate guidance to correctly identify SSCs important to NCS as AQ-NCS items.
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! Enclosure 3 GDP 99-2044 Page 2 of 2
- The commitment to revise procedure XP3-EG-EG1037 as a result of violation VIO-98-206- l l
02 was originally scheduled to be completed on September 30,1998 (per GDP 98 2027). l The commitment to review new or upgraded NCSA/Es and reclassify SSCs in accordance l I
with the revised XP3-EG-EG1037 procedure was not assigned a specific date, but war tied [
. to NCS CAP Task 3. l II. Actions Taken and Results Achieved
- 1. On April 28,1999, the filter plate was included in the Boundary Definition Manual I and appropriately classified as an AQ-NCS controlled item.
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- 2. USEC revised the AQ-NCS criteria to include passive design features relied upon for l NCS and revised procedure XP3-EG-EG1037 to clarify the guidance used for l classifying SSCs as AQ-NCS. This action was completed by July 30,1999. l
- 3. A lessons learned briefing was provided to the Plant Operation Review Committee - l 3
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(PORC) members and to the Configuration Management group related to NRC l Violations 98-206-02,98014-01c, and to the specific issues associated with this cited ' l violation. In addition, PORC was provided instructions on the criteria used to l j classify SSCs as AQ-NCS to include active and passive features. This action was l completed by August 6,1999. l III. Actions to be Taken
- 1. Configuration Management will review AQ-NCS flowdown of NCSAs completed as part of the NCS CA'P to identify other SSCs which may not have been correctly classified. This action will be completed by September 30,1999.
IV. Date of Full Compliance
. USEC achieved compliance with the specific issues associated with this violation on April 28, 1999, when the filter plate was included in the Boundary Definition Manual and appropriately classified as an AQ-NCS controlled item.
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Enclosure 4 GDP 99-2044 Page 1 of 2 I
UNITED STATES ENRICIIMENT CORPORATION (USEC)
REVISED REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/99004-05 Restatement of Violation l
I 10 CFR 76.93, Quality Assurance, requires, in part, that the Corporation shall establish, maintam, i and execute a quality assurance program satisfying each of the applicable requirements of American Society ofMechanical Engineers (ASME) NQA-1-1989," Quality Assurance Program Requirements for Nuclear Facilities."
Section 2.16, of the Quality Assurance Program, " Corrective Action," required, in part, that ,
conditions adverse to quality shall be identified promptly and corrected as soon as practical, in the case of significant conditions adverse to quality, the cause of the condition shall be determined and corrective actions taken to preclude recurrence. ,
Procedure XP2-BM-CIl031," Corrective Actions Process," Revision 0, Change A, dated June 15, 1998, Section 6.0, required, in part, that plant staff shall verify that changes to corrective action plans {
for significant conditions adverse to quality: 1) were warranted; 2) would fix the root or contributing l causes, as originally determined; and 3) were reviewed and approved by the Corrective Action j Review Board.
Contrary to the above, as of March 12,1999, the plant staff made changes to the corrective actions for a significant condition adverse to quality, as outlined in Problem Report PR-PTS-08987 and NCSA-PRI-01 and as communicated to the NRC in a letter dated November 13,1998, which reduced the scope of Priority 2 and 3 nuclear criticality safety evaluation and approval reviews and upgrades without: 1) determining that the changes were warranted; 2) determining that the revised corrective action plans would fix the root or contributing causes, as originally determined; and 3) having the changes reviewed and approved by the Corrective Action Review Board.
I. Reasen for the Violation The reason for the violation was due to a failure to follow procedure XP2-BM-CIl031,
" Corrective Action Process." The former engineering manager, with agreement from affected line organizations, implemented the reduction-in-scope without considering the procedural requirements necessary to implement the desired changes to the Nuclear Criticality Safety (NCS) Corrective Action Plan (CAP).
1 Management inappropriately focused on the fact that the CAP's actions were NRC l commitments and failed to process changes in accordance with the proceduralized I requirements of the corrective action process. As a result, review of the changes made to the l CAP which reduced the scope of the Priority 2 and 3 NCSA/Es did not formally include l u
- , . 4 L Enclosure 4 GDP 99-2044 j Page 2 of 2 confirmation that the changes were warranted, or confirmation that the changes would still l fix the root or contributing causes. Additionally, the changes were not reviewed nor I approved by the Corrective Action Review Board (CARB). l II. Actions Taken and Results Achieved
- 1. On April 20,1999, the Nuclear Safety Manager presented the revised NCS CAP (Revision 5) to the CARB for approval in accordance with procedure XP2-BM- l CIl031. In preparing Revision 5 of the CAP, it was confirmed that the changes were l
- warranted and that the revised CAP would still fix the root and contributing causes l of the deficiencies originally presented to the Management Analysis and Assessment l Team on November 16,1997. The CARB subsequently approved the revisei CAP for the associated problem report, PR-PTS-97-08987. l
- 2. On . July 13, 1999, a lessons learned was issued to Organizational Managers l l discussing the inappropriate manner in which the NCS CAP was handled. The l 1 lessons learned stated, in part, the following: "The Corrective Action Process is l )
governed by. procedure XP2-BM-CIl031. Section 6.9.3 provides guidance on what l !
steps are required to change a CAP action item. This provides for proper reviews and l oversight to ensure that the goals of the original CAP are kept in mind, or a new root l cause is determined that would necessitate further changes. Bypassing this l requirement allowed several changes to be made without this review. In this manner, I some changes that did not have an adequate basis were made and sent to the NRC." 1 Section 6.9.3, steps A.1 and A.6- of procedure XP2-BM-CIl031 specifically l addresses the responsibility of the issue owner regarding detennining that the change l is warranted, that the change will fix the root and contributing cause as originally l determined, and that the change receives CARB approval. l 6
III. Actions to be Taken No further corrective actions are necessary. l I
IV. Date of Full Compliance L USEC achieved full compliance on April 20,1999, when the CARB reviewed and approved the revised plan as required by procedure XP2-BM-C11031.
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i Enclosure 5 GDP 99-2044 Page 1 of 2 i
Revised List of Commitments
- 70-7002/99004-01
- l. By September 30,1999, NCS will revise procedure XP4-EG-NS1001, " Nuclear 1 Criticality Safety Evaluations and Approvals," to incorporate the requirements documented in DOI-832-99-03. (Example a)
. 2. By November 30,1999, NCS will revise procedure XP4-EG-NSI100, " Nuclear l Criticality Safety Calculations," to include instructions to account for uncertainties in the neutron cross-sections in the materials of construction.
- 3. . PORTS will revise and implement NCSE-PLANT 079, by September 30,1999, to l document interaction controls in the proper section and to document why moderation controls are not required for collection containers.
- 4. . By S'eptember 30,'1999, PORTS will review and revise any support calculations (and I associated NCS evaluations) associated with Priority 1 NCSAs which did not l properly account for variances in materials of construction. 4 l
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- 5. By May.18, 2001, PORTS will review and revise any support calculations (and l associated NCS evaluations) associated with non-Priority 1 NCSAs which did not l properly account for variances in materials of construction. l 70-7002/99004-02 ~ .
- 1. NCSA-PLANT 053 will be modified or a new NCSA will be developed, as needed, to address independence ofNCS significant samples and provide controls for out-of- <
control measurements on the low side to ensure the condition is detected and I evaluated in a timely manner. This action will be completed as part of Task 3 of the l NCS CAP which is scheduled to be completed by July 30,2000. l l i l 1 l I l
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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, 4 proce'dures, programs, or operations.
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Enclosure 5 GDP 99-2044 l Page 2 of 2 L
F: 70-7002/99004-03
- 1. Configuration Management will review AQ-NCS flowdown of NCSAs completed as part of the NSC Corrective Action Plan to identify other SSCs which may not have been correctly classified. This action will be completed by September 30,1999.
Note: The previous commitment relating to 70-7002/99004-05 has been completed. l O S*
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