ML20149H651

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7002/97-02

ML20149H651
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant
Issue date:	07/21/1997
From:	Caniano R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	John Miller UNITED STATES ENRICHMENT CORP. (USEC)
References
70-7002-97-02, 70-7002-97-2, NUDOCS 9707250099
Download: ML20149H651 (1)

Text

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July 21, 1997 EA 97-172 l

Mr. J. H. Miller Vice President - Production United States Enrichment Corporation Two Democracy Center 6903 Rockledge Drive Bethesda, MD 20817

SUBJECT:

RESPONSE TO INSPECTION REPORT 70-97002(DNMS)

Dear Mr. Miller:

This will acknowledge receipt of a response letter from Mr. Dale Allen, Portsmouth General Manager, dated June 6,1997, in response to our letter dated May 9,1997, transmitting a Notice of Violation regarding your failure to comply with Technical Safety Requirements.

We have reviewed your corrective actions and have no further questions at this time. These corrective actions will be examined during further inspection.

if you have any questions, please contact Patrick Hiland of my staff at (630) 829-9603.

Sincerely, Original Signed by T. Kozak Roy J. Caniano, Acting Director Division of Nuclear Materials Safety Docket No. 70-7002 cc: R. M. DeVault, DOE S. A. Polston, Paducah General Manager D. I. Allen, Portsmouth General Manager R. W. Gaston, Portsmouth Nuclear Regulatory {.

Affairs Manager 1 R. L. Woolley, Manager, Nuclear Regulatory ]

Assurance and Policy, USEC bec w/Itr dtd: 6/6/97: J. Caldwell, Rill T. Simmons, Rlli Office of Enforcement J. Goldberg, OGC E. Ten Eyck, FCSS

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. LOCKNEED M A R TIN Gregory II. Baker President June 6,1997 GDP-97-2006 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 I l

Portsmouth Gasecus Diffusion Plant (PORTS)

Docket No. 70-7002 l Response to Inspection Report (IR) 70-7002/97-002 Notice of Violation (NOV)

Nuclear Regulatory Commission (NRC) letter dated May 9,1997, transmitted the subject Inspection Report (IR) that contained two violations involving three examples of failure to comply with j Technical Safety Requirements. USEC's response to these violations is provided in Enclosures 1 i and 2 Enclosure 3 lists the commitments made in this report. Unless specifically noted, the corrective actions specified in each enclosure apply solely to PORTS.

In page 8 of the IR, NRC states that the events that led to the NOVs were indicative of a generic ,.

problem with the plant staffs implementation of the TSRs. We concur with this concern and have taken positive actions to raise the staff's awareness and expectation for TSR compliance, to improve the plant's understanding of operability, and improve identified incomplete TSR procedures.

Specifically, a senior manager of my staff was assigned to facilitate a management analysis into why TSR violations were occurring and determine the root causes of this negative trend. A TSR compliance enhancement plan was developed and is being implemented to address those awareness and expectation issues which led to our poor performance. The Plant Shift Superintendent (PSS) f roles and responsibilities have been expanded to strengthen the conunand and control function providing greater control over operability evaluations related to TSR Mode changes. Additionally, f as communicated in the attached responses, my staff is taking actions to improve weak TSR.

implementation procedures and we are committed to strengthen TSR implementation procedures as procedure weaknesses are identified.

y,er I have taken a personal interest in improving TSR compliance and have communicated my expectations through meetings, articles, and personal discussions with my staff. I believe ve are being responsive to this very important subject and I will continue my personal involvement to ensure plant personnel develop a questioning attitude which includes an improved awareness of TSR requirements, an increased level of knowledge related to regulatory compliance, and continued self-

, assessments to identify compliance weaknesses. Our goal is to achieve a high level of regulatory compliance through a position of self-reg cn ; id control.

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( 'U.S. uclear Regulatory Commission June 6,1997 Page Two If you have any questions regarding this submittal, please contact Charly Blackston at (614) 897-3120. ,

I l Sincerely, i Dale Allen General Manager DIA:CB .

' 1 Enclosures l

cc: Regional Administrator, Region Ill NRC Resident Inspector - PORTS L u

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U.S. uclear Regulatory Commissioner June 6,1997 Page Three Distribution:

Robert L.~ Woolley - 001 bec:

J. 'Adkins, HQ J. Dietrich,~ LMUS L. Fink,' PORTS R. Gaston, PORTS J. Labarraque, PGDP A. Rebuck-Ma i n, HQ S. Routh, HQ D. Scott, HQ D. Silvennan, ML&B

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i Enclosure 1 l UNITED STATES ENRICIIMENT CORPORATION (USEC)

REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/97002-01 Restatement of Violation  ;

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Technical Safety Requirement (TSR) 3.2.2.a states that minimum stafling requirements for 1 each facility are shown in Table 3.2.2-1.

TSR Table 3.2.2-1 requires that the minimal staffing level for the Tails Withdrawal Station have one assigned Operator during Modes II and III.

Contrary to the above, on March 21,1997 between 2:00 p.m. and 2:30 p.m., there was no assigned Operator present at the Tails Station during Mode II.

I. Reasons for Violation I

The reason for this violation was that a process / procedure was not in place to address manning requirements for the cascade facilities as outlined in the TSR Table 3.2.2-1 nor were these requirements flowed into the appropriate operating procedures. Contributing to the failure was the unavailability of TSRs at the floor level and a Eck of understanding of the new TSR manning requirements by the facility's operating staff.

II. Corrective Actions Taken and Results Achieved

1) The TSR minimum staffing requirements were documented in the cascade facilities 4

Daily Operating Instructions (DOI) and communicated to cognizant personnel in the three process buildings and Plant Control Facility (PCF).

2) Operators in the cascade buildings were briefed on the minimum staffing requirements specific to their facility to ensure operations personnel understood the manning requirements as stated in the TSR, the requirements of the DOI, and how these manning requirements are to be implemented.

3) Additional controlled TSR manuals were distributed to process areas in the X-333, X-330, X-326, and X-300 to make TSRs available at the floor level.

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' III. Corrective Steps to be Taken

1) USEC will develop a procedure that describes process facilities manning requirements, .

establishes ag methodology of how minimum stafling levels are maintained, and designates a more descriptive area of operation for assigned personnel. This action item will be completed by June 30,1997,

2) Once the procedure is complete and approved for use, appropriate operations l personnel will be trained to ensure personnel-adequately understand manning expectations. This action item will be completed by July 30,1997.

IV. Date of Full Compliance Full compliance was achieved when the TSR manning requirement at the Tails Withdrawal Station was restored at or about 2:30 p.m. on March 21,1997. The corrective actions to mitigate / prevent recurrence will be completed by July 30,1997.

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', c j Enclosure 2 i UNITED STATES ENRICHMENT CORPORATION (USEC)

REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/97002-02 Restatement of Violation Technical Safety Requirement (TSR) 1.6.2.2.d states that entry into an OPERATIONAL MODE that is applicable to the particular LIMITING CONDITION for OPERATION (LCO) shall not be made unless the conditions for the LCO are met without reliance on provisions contained in the ACTION statement.

TSR 2.7.3.13 and TSR 2.2.3.14 require DC control power for uranium hexafluoride stage motors to be operable for Mode II and Mode III.

TSR 2.2.3.1 requires the coolant high pressure relief system to be operable and their block i l

valves verified open prior to entry into Modes 11 or 111.

Contrary to the above, between March 3 and April 6,1997, the plant entered Mode II with DC control power for uranium hexafluoride (UF 6) stage motors inoperable for four cells and without verifying that the coolant high pressure relief system block valves were open.

I. Reasons for Violation The reason for the violation was a weakness in the process used to determine equipment operability at the time of transition to NRC oversight and inadequate administrative controls goveming TSR LCOs. Specifically, operators relied upon surveillance data performed under DOE Operational Safety Requirements (OSRs) to confirm equipment operability under the new TSR specifications. However, the OSR surveillance data was not properly evaluated to ensure it satisfied the applicable TSRs prior to transition to NRC regulatory oversight. A similar condition with the High Pressure Fire Water System was self-identified and reported to NRC [ Event Report 97-05] on April 9,1997. Further discussion on each of the above examples is provided below:

Examnle 1:

On March 3,1997, when USEC transitioned to NRC regulatory oversight, a condition existed in which the DC control power should have been declared inoperable because specific gravities in cells were documented as below the minimum acceptance specification of 1.180 specified in TSR surveillance requirements 2.7.3.13 and 2.2.3.14. This is because the surveillance procedure for battery cells, which existed prior to March 3,1997, did not specify that a TSR LCO had to be entered if the specific gravity was below 1.180. Additionally, plant personnel did not perform an adequate review of this, and other, surveillances, to ensure the E2- 1

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conditions of the applicable.TSR LCOs were satisfied prior to transition to NRC regulatory oversight.

Contributing to the error was the plant's lack of understanding of the difference between

" operable" and " functional." Personnel believed that if a system was functional and was able 1 to provide DC control power to the motor trip circuit, the system could be considered

- operable. This misinterpretation of the operability' concept is contrary to management expectations and contrary to the Operability Determination procedure, UE2-TO-NS1032,-  ;

currently in effect. J Example 2:

The second example describes a condition whem personnel failed to recognize that restart and i start-up of a cell from a " shut-down" state (Mode VI) are the same and have the same TSR

- limiting conditions for operation. Past practice allowed a cell to be quickly restarted when a cell tripped off-line if the cause of the trip was known and the brakes were verified disengaged. If a cell was shutdown (i.e., did not trip off-lir.e), the cell would be started-up following a detailed prestart-up check which included verifying the Freon block valve was scaled open. In this example, where the cell tripped off-line, the application of the TSR requirement for the mode change was not clearly understood by cascade personnel.

II. Corrective Actions Taken and Results Achieved

1) All DC power control batteries that were identified on March 19,1997 as being in an LCO have been restored to operable status in accordance with the new TSR procedures which were made effective as of March 3,1997.

2) Systems Engineering performed a review of TSR surveillance test data submitted in preparation for transition to ensure that other systems were not inoperable due to failed surveillances. Identified discrepancies were documented on problem reports, reported  :

to the PSS for a operability. determination, and appropriate corrective actions were taken.

3) A Daily Operating Instruction (DOI) has been written to address the implementation of TSR required actions when an LCO condition is entered or mode changes occur.

The DOI ' establishes a consistent approach to LCO monitoring ar.d tracking by instructing the PSS to verify TSR required actions and surveillances are completed each time an LCO condition is entered. To document the approval the PSS reviews the TSR requirements and logs the condition in the PSS logbook and instructs the field organizations to document the same information in their operating logs.

4) Status Boards are also used to make LCO conditions very visible to the PSS and others in the control room.

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. 5) A briefing was held with each PSS to communicate management's expectations related

- to surveillan'c e testing and operability, TSR Limiting Conditions of Operation, LCO tracking and documentation, and mode changes.

6) LCOs are tracked on the Daily Status Report issued each moming by the PSS. The report communicates to management across plant site the condition and status of the plant.

7) Operations First Line Managers have been briefed by their Group Managers on how

-surveillances relate to operability and how Limiting Conditions of Operations are .

entered. .I III. Corrective Steps to be Taken

1) A procedure is currently being developed which will establish a formal program to control LCOs. The procedure will provide guidance for the tracking of Limiting Conditions for Operations. The use of this tracking program will establish a process to ensure compliance with the TSR. The procedure is expected to be completed by August 30,1997.

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2) Once the procedure is complete and approved for use, appropriate operations )

- personnel will be trained to ensure personnel adequately understand the LCO trackmg i process. This action item is expected to be completed by September 30,1997.'

Additional corrective actions concerning a similar condition are documented in Event Report 97-05 and were forwarded to the United States Nuclear Regulatory Commission under cover letter dated May 9,1997 from Mr. Dale Allen, General Manager. 1 IV. Date of Full Compliance USEC is in full compliance with the TSRs as confirmed by the in-depth engineering review of TSR surveillance data completed May 30, 1997. The corrective actions to prevent recurrence will be completed by September 30,1997.

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I Enclosure 3 i

l UNITED STATES ENRICIIMENT CORPORATION (USEC) l LIST OF COMMITMENTS 70-7002/97002 NOV 97002-01 I

l 1) USEC will develop a procedure that describes process facilities manning requirements, establishes a methodology of how minimum staffing levels are maintained, and designates a more descriptive area of operation for assigned personnel. This action item will be completed by June 30,1997.

2) Once the procedure is complete and approved for use, appropriate operations personnel will be trained to ensure personnel adequately understand manning expectations. This action i'em will be completed by July 30,1997.

NOV 97002-02

1) A procedure is currently being developed which will establish a formal program to control LCOs. The procedure will provide guidance for the tracking of Limiting Conditions for Operations. The use of this tracking program will establish a process to ensure compliance with the TSR. The procedure is expected to be completed by August 30,1997.

2) Once the procedure is complete and approved for use, appropriate operations personnel will be trained to ensure personnel adequately understand the LCO tracking process. This action item is expected to be completed by September 30,1997, i