ML20151K781
| ML20151K781 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 08/01/1997 |
| From: | Polston S UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-7001-97-03, 70-7001-97-3, GDP-97-1020, NUDOCS 9708060159 | |
| Download: ML20151K781 (20) | |
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United sttes Enrichment Corporation Paducah Sne Offke l
P.O Box 1410 l
Paducah. KY 42001 Tel. 502 44l-$803 Ias: 502 4415801 l
August 1,1997 i
1 United States Nuclear Regulatory Commission SERIAL: GDP 97-1020 ATTN: Document Control Desk l
Washington, D.C. 20555 Paducah Gaseous Diffusion Plant (PGDP)
Docket No. 70-7001 Response to Inspection Report (IR) 70-7001/97003 Notices of Violation (NOVs)
Nuclear Regulatory Commission (NRC) letter dated July 2,1997, transmitted the subject IR which contained six NOVs. Your letter requested a response to five of these NOVs. United States Enrichment Corporation's (USEC) response to these violations is provided in Enclosures 1-5. Enclosure 6 lists the commitments made in this report. Unless specifically noted, the corrective actions specified in each enclosure apply solely to PGDP.
In the cover letter to the IR, NRC expressed a concern that "many of the violations indicate slow or ineffective corrective actions to identified problems." We share your concern with the slowness of our corrective action program. We have discussed this issue at various PGDP management meetings. We recognize that improvement is warranted in improving the timeliness and responsiveness to significant issues (e.g., TSR violations) to ensure that such issues do not repeat themselves pending the development and implementation oflong-term corrective actions.
Accordingly, the PGDP Corrective Action Program Manager has been assigned the task of evaluating and developing recommendations to improve our performance in the area of corrective actions effectiveness. The results of this assessment are scheduled to be presented to the Management Assessment and Analysis Team by September 5,1997. We will brief the PGDP NRC Resident Inspectors on the results of this assessment.
We recognize that immediate action is needed to improve in the area of timely corrective action response. Therefore, in addition to the above initiative, we are currently evaluating actions that we can take quickly which will improve our responsiveness to important issues. Again, we will brief the PGDP Resident Inspectors once a plan is determined.
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I United States Nuclear Regulatory Commission Page Two l
l August 1,1997 l
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If you have any questions regarding this submittal, please contact Bill Sykes at (502) 441-6796.
I Sincerely, i
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l Steve Polston i
l General Manager l
Paducah Gaseous Diffusion Plant i
SP:SRC:mel j
I Enclosures cc:
NRC Region III j
NRC Senior Resident inspector, PGDP t
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ENCLOSURE 1 UNITED STATES ENRICHMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7001/97003-01 I
Technical Safety Requirement (TSR) 2.4.4.2(b), Action Statement A.I.2 requires,in part, that in areas without an audible criticality accident alarm and where the maximum foreseeable absorbed dose in free air exceeds 12 rad, the certificatee shall immediately [begin to] monitor temperatures and pressures hourly in cascade cells containing uranium hexafiuoride, enriched to 1.0 weight percent or greater.
Safety Analysis Report, Chapter 4, Appendix A, Table 2.5-1," Criticality Clusters and Building Alarms," specifies, in part, that criticality accident alann system (CAAS) local clusters "G" and "H" and building homs provide the criticality detection and accident alarms for Building C-310.
TSR 1.2.8 defines "immediately" as: " required action shall be pursued without delay and in a controlled manner."
Violation Cited Contrary to the above, on May 8,1997, the certificatee did not immediately begin to monitor temperatures and pressures hourly for Building C-310 cascade cells containing uranium hexafiuoride enriched to 1.0 weight percent or greater, when the area did not have an audible criticality acci6nt alarm because clusters "G" and "H" had been removed from service.
Specifically, C-310 cluster "G" was declared inoperable at 0900, and cluster "H" was declared inoperable at 1020. The initial rounds to monitor temperatures and pressures in the cells were not initiated until 1200, a period of time exceeding TSR 2.4.4.2(b), Action Statement A.I.2 surveillance requirement.
I.
Backcround Information On May 8,1997, the Criticality Accident Alarm System (CAAS)in C-310 was removed from service as a planned evolution to complete required TSR quarterly surveillances.
CAAS cluster "G" was declared inoperable at 0900 for quarterly cluster module replacement. After completing this task, cluster "H" was declared inoperable at 1020 to complete the quarterly audibility testing.
When "H" cluster was declared inoperable, C-310 did not have operable CAAS coverage. Operations had implemented TSR 2.3.4.7(a) and 2.3.4.7(b) Limiting Conditions for Operation (LCO) Action Statements. However, TSR 2.4.4.2(a) and 2.4.4.2(b) LCO Action Statements were not identified as required and these were not initially implemented. (Actions A.I.2 add A.l.4 of TSR 2.4.4.2 require monitoring temperatures / pressures in the cascade to maintain UF in a gaseous state and not using 6
the wet air pumps for cell evacuations. The required action A.1.2 was not implemented.)
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When this deficiency was identified by an NRC inspector, Operations immediately initiated the required action at 1200. The C-310 building managet had discussed the planned inoperability of the CAAS with th: Assistant Plant Shift Superintendent (APSS) t and confirmed that the required LCO Action Statements were being implemented, however, the details of which specific actions were implemented were not discussed. The building manager completed an LCO Action Tracking Sheet and faxed a copy to the PSS.
The PSS/APSS did not review this sheet until after the deficiency was discovered at 1200.
i During a review of past activities involving C-310 CAAS, Operations discovered that TSR 2.4.4.2(a) and 2.4.4.2(b) LCO Action Statements were also not implemented when i
the C-310 CAAS was declared inoperable on April 28,1997. Cluster"H" was declared inoperable on April 28,1997, at 0920 for cluster module replacement. At 1320 cluster "G" was also declared inoperable to complete the building horn surveillance test. At this time, TSR required actions 2.3.4.7(a) and 2.3.4.7(b) were implemented, however, TSR required actions 2.4.4.2(a) and 2.4.4.2(b) were not implemented. The C-310 building Front-Line Manager discussed this plarmed outage with the PSS and confirmed that the required LCO Action Statements were being implemented. Similar to the May 8,1997 event, the details of which LCO Action Statements were being implemented was not discussed. An LCO Action Tracking Sheet was submitted to the PSS office and logged.
i The deficiency was not identified by the PSS group at this time.
Similar events also occurred November 27,1996 and December 13,1996 under DOE regulation (DOE Inspection Report 97-01). The violations were failure to monitor cell 1
temperatures and line recorders during periods when the C-310 CAAS was inoperable as required by plant Operational Safety Requirement (OSR) KY/D-3971. In these instances, two OSRs applied to C-310: OSR KY/D-3971 (Enrichment Cascade OSR) applied to C-310 up to the suction of the Normetex pumps; and KY/D-3974 (Product and Tails Withdrawal OSR) applied to C-310 from the Normetex pump suction up to the 200-foot purge vent stack.
II.
Reasons for the Violation.
The reason for the violation is a failure to adequately determine the root and contributing causes from previous events, and a failure to consequently develop and implement effective corrective actions to address previous similar violations. For example, if TSR 2.4.4.2 requirements had been incorporated into TSR 2.3.4.7, the TSR violations on April 28,1997 and May 8,1997 may not have occurred.
The inelTectiveness of our corrective action program is addressed in the cover letter. The discussion below addresses the specific violations cited in the report and provides those actions necessary to prevent recurrence.
The previous corrective actions were to: 1) provide training on OSR KY/D-3971 to El-2
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address the apparent training / knowledge deficiency by ensuring the lesson plan for the l
TSRs included the fact that two TSRs applied to C-310 CAAS and by requiring j
classroom training for affected personnel; and 2) provide crew briefings for all C-310 l
qualified personnel reiterating the use of the STAR principle (Stop, Think, Act, Review) l inuuding the details of the specific deficiency of this event (failure to implement l
required OSR LCO actions of both KY/D-3974 and KY/D-3971).
1 An opportunity was missed that may have prevented the April 28,1997 and May 8,1997 violations.
A. The investigation should have included an analysis of the contribution of having two separate OSRs/TSRs specifying difTerent required actions for an inoperable CAAS in C-310. Currently, in the TSRs for the Product and Tails Withdrawal Facilities, only CAAS has different TSR requirements specified in separate TSR sections (those for the cascade). This contributed significantly to the violations on April 28,1997 and May 8,1997. In these violations, the CAAS TSRs of 2.3.4.7 were implemented, while the requirements of 2.4.4.2 were not.
B. The remaining OSRsffSRs in effect should have been evaluated to identify any other similar potential problem areas.
C. An additional contributing factor was that on April 28,1997, and again on May 8, 1997, when the C-310 building manager discussed the planned CAAS outage with the PSS, the details of specifically which TSR Action Statements were required was not discussed. When the LCO Action Tracking Sheet was processed by the APSS, the failure to implement TSR 2.4.4.2 was not identified.
In summary, there have now been four occurrences where personnel failed to implement the Enrichment TSR/OSR requirements for an inoperable CAAS in C-310. In every case, the Product Withdrawal TSR/OSR requirements were correctly implemented, while the Cascade TSR/OSR requirements applicable to C-310 were not.
III.
Corrective Actions Taken and Results Achieved
- 1. TSR 2.4 sections have been reviewed to determine whether there are other examples of different requirements specified in TSR 2.4 than the requirements in TSR 2.3. The other TSR sections in 2.4 do not present the same challenge to Operations personnel.
- 2. Technical Safety Requirement Clarification (TSRC) 97C004 has been established to add a reminder to trigger consideration of TSR 2.4.4.2(a) and/or 2.4.4.2(b) actions when taking actions required by TSRs 2.3.4.7(a) and/or 2.3.4.7(b). A note has been added before TSR sections 2.3.4.7(a),2.3.4.7(b),2.4.4.2(a), and 2.4.4.2(b) instructing l
personnel to refer to TSRC 97C004.
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Crew briefings on TSRC97C004 for all C-310 qualified operators / managers and all PSS/APSS/ Cascade Coordinators have been completed.
111.
Corrective Actions to be Taken i
- 1. A review of other similar TSRs (2.1,2.2,2.3,2.5, and 2.6) will be performed to determine if the format of these TSRs present a challenge for personnel to properly execute the requirements, similar to the problem presented by 2.4.4.2 in C-310 l
(specifically, different requirements located in separate TSR sections for a single system required to be operable by the TSR). This will be completed by August 8, 1997.
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- 2. We will submit TSR changes to TSR 2.4 and 2.3 to NRC for approval making the editorial change of cross referencing the Required Actions of these two TSR sections as applicable to CAAS in C-310. This will be completed by October 7,1997.
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- 3. We will change procedure CP2-CO-CN1031," Tracking ofInoperable Structures, l
Systems, and Components," to require that the PSS discuss the specific required TSR actions with the affected front-line manager prior to declaring a TSR required system inoperable for planned work or system inoperabilities due to emergent conditions.
j This will be completed by September 30,1997.
IV.
Date of Full Comoliance l
Full compliance with TSR 2.4.4.2 requirements have been maintained since the May 8, 1997 event. The actions to prevent recurrence will be completed when the proposed changes to the TSR have been approved by the NRC and training on these changes implemented (within 45 days of receiving NRC approval).
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ENCLOSURE 2 l
UNITED STATES ENRICHMENT CORPORATION (USEC) l REPLY TO NOTICE OF VIOLATION (NOV) 70-7001/97003-02 Technical Safety Requirement (TSR) 2.3.4.7, Action Statements A.2.1, A.2.2, and A.3, and TSR 2.4.4.2, Action Statements A.2.1, A.2.2, and A.3 require for areas not covered by criticality accident detection, that: 1) the area be evacuated immediately; 2) access to the evacuated area be restricted; and 3) personnel, allowed into the restricted area, be provided with an alternate means of criticality alarm notification, such as a device that will alarm on sensing a 10 millirem per i
hour dose rate.
Procedure CP2-CO-CA1030, Revision 0," OPERATION OF THE CRITICALITY ACCIDENT ALARM SYSTEM (CAAS)," dated March 3,1997, step 6.2.3B states that upon loss of CAAS coverage: " Access control consists of posting signs, traffic cones, or other type barriers around the perimeter of the affected area which informs personnel of the LCO [ Limiting Condition of Operation] boundary and that access is not allowed unless authorized by the PSS/MIC [PSS or manager in charge] and proper dosimetry (for detection and audibility) or a radio (for audibility only) is worn."
l Violation Cited Contrary to the above, on April 28, May 8, and May 14,1997, seven personnel, on six separate occasions, entered evacuated, restricted, and posted areas, around Buildings C-310 and C-337, l
which were not covered by criticality accident detection: 1) without authorization by the PSS or manager in charge; and 2) without proper dosimetry or a radio.
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11gason for Violation The reason for the violation was ineffective controls to prevent personnel from entering i
unauthorized areas during a loss of CAAS coverage. Specifically, there were: (1) ineffective barriers (cones and flags) for the identification of evacuation zone boundaries; (2) ineffective communication of the procedure requirements for loss of CAAS coverage; and (3) less than adequate enforcement of the procedure requirement.
11.
Corrective Actions Taken and Results Achieved
- 1. The PSS issued a long-term order to walk down placement of cones and flags each time the CAAS LCO evacuation zone is established. In addition, physical placement of cones and flags was re-evaluated and the number of cones and flags used to establish boundaries was increased.
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- 2. Communication of the TSR requirement was enhanced by the following actions:
The Enrichment Plant Manager received confirmation from all organization a.
managers "that persormel in their organization understood their responsibilities relative to restricted areas during CAAS outage."
- b. Nuclear Regulatory Affairs (NRA) fact sheets were issued after each violation discussing the violation and immediate actions taken.
- c. An employee bulletin, "AN IMPORTANT MESSAGE ABOUT THE CAAS,"
was issued by the General Manager which details actions that occur when a CAAS is declared inoperable and employee responsibilities,
- d. A brochure has been prepared for visitors which describes their responsibility when a CAAS is declared inoperable and the evacuation zone is established.
Security issues the bulletin to all visitors.
e.
Public address announcements are made and signs are posted at all open entry portals when a CAAS evacuation zone is established. Signs at portals were originally posted only at shift change.
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CAAS LCO information is included in General Employee Training, which is received by all new employees upon hiring and during requalification every other year.
- 3. Enforcement actions to be taken were discussed in employee bulletin, "THE PLANT HAS DONE ALL IT CAN, ITS NOW UP TO YOU," issued by the General Manager.
III.
Corrective Actions to be Taken
- 1. USEC will revise procedures and install hardware by October 31,1997, so that continuous flagging will be installed each time a CAAS evacuation zone is established.
IV.
Date of Full Comoliance Full compliance with this violation was achieved on May 14,1997, when personnel were removed from the restricted area. The actions to prevent recurrence will be completed by October 31,1997.
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l ENCLOSURE 3 l
UNITED STATES ENRICHMENT CORPORATION (USEC) i REPLY TO NOTICE OF VIOLATION (NOV) 70-7001/97003-03 Technical Safety Requirements (TSR) 2.3.4.7(b) and 2.4.4.2(b) require that the criticality
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accident alarm shall be operable in areas where the maximum foreseeable absorbed dose in free air exceeds 12 rad.
Gafety Analysis Report, Chapter 4, Appendix A, Table 2.5-1," Criticality Clusters and Building Alarms," specifies, in part, that criticality accident alarm system (CAAS) local clusters "G" and l
"11" and building horns provide the criticality accident alarms for Building C-310.
Violation Cited Contrary to the above, on May 18,1997, between 1825 and 1950, the C-310 CAAS building horns were not operable in the areas where the maximum foreseeable dose in free air exceeds 12 rad.
I.
Background Information CAAS is used for warning plant personnel of a criticality incident. The system is designed to detect gamma radiation and provide a distinctive, audible signal which will alert personnel to evacuate the areas that are potentially affected. Building horns are used, in addition to local CAAS cluster horns, to provide an audible alarm for evacuation.
Solenoid valves open to provide air to the building horns, operating from either 120 VAC or 125 VDC power from a local distribution panel within the building they support.
On May 18,1997,125 VDC power was lost to all loads on distribution panel 310-AC-B in Building C-310. The design of this 125 VDC power distribution system provides for automatic transfer of the load to a bank of batteries in the event of a loss of normal power. Ilowever, this also failed to occur. This power is required to operate the air solenoids on the C-310 building CAAS horns, and loss of this power rendered that system inoperable. Additionally, the inoperability of the building CAAS horns was not recognized at the time and thus no LCO actions were initiated for this system.
On May 23,1997, this occurrence was determined to be a reportable event and an investigation was initiated. The findings of this investigation have been reported pursuant to 10 CFR 76.120(c)(2) as event report ER-97-10.
Two similar events occurred on July 1 and July 13,1997, in C-310 when DC alarm power was lost for similar reasons. We are investigating the reasons for the subsequent l
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failures of the DC power system. Further corrective actions may be taken as a result of the investigations. The appropriate LCO actions were taken in these two cases.
II.
Reasons for Violation The reasons for this violation were:
- 1. The loss of 125 VDC power to the CAAS building horns is directly attributable to the degraded condition of a fuse in the rectifier supplying normal power and the oxidation of contacts on the power seeking transfer switch which prevented a throwover to backup power. The loss was also caused by inadequate perfonnance of preventive maintenance associated with the testing of the automatic transfer switch. This test, had it been conducted as scheduled, may have revealed the degraded condition of the transfer switch contacts. These contacts transfer the load to the batteries. The investigation also found that this test was delinquent in the C-335 building.
Additionally, there was a lack of enforcement in controlling delinquent preventive maintenance tasks.
- 2. The failure to recognize the need to take LCO actions was due to inadequate guidance for the operators in the event of a DC power loss to the facility, and inadequate awareness on the part of the operators regarding the effects of a loss of DC power.
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Corrective Actions Taken and Results Achieved
- 1. On May 23,1997, Maintenance replaced the control relay of the transfer switch in C-310. (In combination with a fuse replacement, this allowed normal power to be restored. CAAS had been operable under backup power.)
- 2. On June 10,1997, Operations completed the ACR Power Switch Test in C-335 building. (This action was taken to prevent a similar power loss in another building.)
- 3. Required Reading was initiated on July 30,1997, for C-300 and C-310 operators and UF Ilandling Managers to make them aware of this event and to heighten their 6
awareness of the TSR requirements when DC power is lost.
- 4. On July 29,1997, Engineering completed an inspection, with assistance of Electrical l
Maintenance, of all DC power transfer systems in C-331, C-333, C-335 and C-337.
The inspection determined the current condition of the transfer relay and the associated fuses to the rectifier of the DC power transfer systems.
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IV.
Corrective Stens to be Taken
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The actions to be taken that are listed below are provided in Event Report ER-97-10 and l
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- 1. By August 15,1997, Operations will ensure a system of communication of PM status / clear ownership and approva! of PM deferral exists.
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- 2. By September 30,1997, Reliability Engineering will evaluate (taking into account the results of Corrective Action No.4) and determine the correct preventive maintenance requirements for the transfer relays in C-310, C-331, C-333, C-335, and C-337. This evaluation will also include determining the adequacy of the frequency of the DC power switch test.
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- 3. By September 30,1997, Operations will issue an off-normal procedure for loss of DC power in C-310.
- 4. By September 30,1997, Operations will issue off-normal procedures for loss of DC power in C-331, C-333, C-335, and C-337.
Actions 3 and 4 above will ensure the operators recognize the appropriate actions to take for any future DC power losses.
V.
Date of Full comoliance Full compliance with the specifics described in the NOV was achieved on May 18,1997, at approxiraately 1950 when power was restored to the CAAS building horns through the backup power source. The actions to prevent recurrence will be completed by September 30,1997.
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l ENCLOSURE 4 UNITED STATES ENRICHMENT CORPORATION (USEC)
IEPLY TO NOTICE OF VIOLATION (NOV) 70-7001/97003-11 i
10 CFR 76.93, " Quality Assurance," require in part, that the certificatee shall establish and execute a quality assurance program.
The Quality Assurance Program, Section 2.5, states, in part, that: 1) "Q" activities affecting safety or quality are prescribed and performed in accordance with docu:nented instructions, procedures, or drawings of a type appropriate to the circumstances; and 2) these documents include or reference appropriate quantitative or qualitative acceptance criteria for determining that prescribed activities are satisfactorily performed.
Safety Analysis Report, Section 3.15, "Q and AQ Structures, Systems, and Components,"
specifies the criticality accident alarm system (CAAS) as a "Q" system, including building / slave lights and horns for Buildings C-333, C-333-A, C-337, and C-337-A.
Procedure CP4-GP-IM6209, " Criticality Accident Alarm System Functional Tests," Revisions 1 and 2, stated purpose was to: " provide instructions to functionally check the CAAS."
Violation Cited Contrary to the above, from March 3 through April 23,1997, the certificatee performed post maintenance functional tests of CAAS for Buildings C-333, C-333-A, C-337, and C-337-A using a procedure which did not include appropriate acceptance criteria for determining that the prescribed activities were satisfactorily performed. Specifically, Procedure CP4-GP-lM6209 did not include acceptance criteria to ensure that all of the slave homs associated with Buildings C-333, C-333-A, C-337 and C-337-A CAAS clusters sounded upon an actuation signal.
I.
Backcround Information Procedure CP4-GP-lM6209," Criticality Accident Alarm System Functional Tests,"
Appendix A did not agree with the Safety Analysis Report (SAR), Chapter 4, Appendix i
A. The SAR stated C-337 CAAS clusters "V" and "X" are slaved to the homs that
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l C-337-A's "N" cluster actuates. The SAR also stated that C-333-A's "AA" and "AB" i
clusters are slaved to all of the C-333 building homs. CP4-GP-IM6209 did not show these slaving features of CAAS in those buildings. Since CP4-GP-IM6209 is the i
procedure used to satisfy the quarterly Technical Safety Requirements (TSR) surveillance requirement for testing oflocal cluster homs and building homs, USEC was unable to l
verify that the slaved homs, as noted above, were tested. This invalidnted the past quarterly TSR surveillance requirements for C-333-A and C-337 "V" and "X" clusters, which is a violation of TSR Section 1.6.3, Surveillance Requirements.
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Reason for violation The primary reasons for the violation concerned deficiencies in drawings, procedures, and training. The following describes how each area contributed to this violation:
Drawings:
Several instrument drawings, used during development of the test procedure, contained no information regarding the slaved relationship of the CAAS homs for the buildings cited. The drawing ~s, both electrical and instrumentation, originally developed for the CAAS high assay upgrade program (HAUP), were developed for Paducah by Oak Ridge.
The drawings produced were treated by Paducah essentially as a tum key project, a l
cursory review was performed with no field verification, and the drawings placed in the configuration control program existing at that time. This inadequate review by Design Engineering led to the slaved horn relationship being left off of the instrument drawings, the electrical drawings, as noted below, were found to be correct. The information missing from the instrument drawings was not incorporated into CP4-GP-IM6209. Thus, the surveillances were missed. This was a contributing cause of the inadequate procedure.
Procedures:
Procedure CP4-GP-IM6209, " Criticality Accident Alarm System Functional Tests," is used to perform TSR surveillances on the CAAS CP4-GP-IM6209, Appendix A,
" Component Identification and Location," did not show proper slaving relationships for the CAAS building homs cited. The Action Steps of the procedure only referenced
" verify applicable homs...," making no reference to Appendix A. Since the procedure did not show the location of the slaved horns, they were never checked during the surveillance. The primary reason leading to this finding was that CP4-GP-lM6209 received an inadequate review and validation. Proper review and "in the field" validation would have discovered these slaving issues and they would have been incorporated into the procedure. Inadequacies in the procedure review and validation process also appear to have contributed to this violation.
Training:
Conduct of Maintenance training module,204.11.01, completed on April 15,1997,by approximately 400 Maintenance personnel, discusses the Maintenance Manager's expectations in the areas of accountability, use of the STAR concept (Stop, Think, Act, and Review), and the possession of a questioning attitude. The CAAS training modules discuss slaving features of the CAAS homs; so the Maintenance personnel who have attended these modules and subsequently used CP4-GP-lM6209 should have noted the discrepancies between the procedurally expected results and the actual field CAAS hom response based on the information disseminated in the CAAS training.
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III.
Corrective Actions Taken and Results Achieved
- 1. The Plant Shift Superintendent (PSS) declared C-333, C-337, C-333-A, and C-337-A l
CAAS inoperable on April 23,1997.
- 2. TSR surveillances were performed on C-333-A's "AA" and "AB" clusters and C-337's "V" and "X" clusters. The surveillances were completed and C-333, C-337, C-333-A, and C-337-A CAAS was declared operable on April 24,1997.
- 3. A procedure change on CP4-GP-IM6209 was performed to include correct slaved l
horn locations for C-337 and C-333-A. The procedure was effective on April 24, 1997.
- 4. CAAS safety system drawings, both Instrument and Electrical, were reviewed to determine the actual building slaving features and several discrepancies were found dealing with the slaving features. Due to the identified discrepancies, a verification of actual field conditions was performed. The field verification found C-337, C-337-A, C-333 and C-333-A electrical drawings correct and instrument drawings incorrect.
- 5. All other CAAS component locations listed in CP4-GP-IM6209, Appendix A, were reviewed and verified to be correct.
- 6. A review of CP4-GP-lM4128," Maintenance of the Criticality Accident Alarm System," Appendix B, was performed to determine if a similar condition existed.
This procedure also required a change, but, since it did not address surveillance requirements, the change will be implemented in conjunction with a revision already in progress on that procedure.
- 7. Electronics and Calibration personnel reviewed C-720 and C-710 CAAS procedures to determine if a similar situation existed, and none did.
- 8. Engineering Notice, EN-C-812-97-036, has been issued to address the revisions to the safety system drawings for C-337, C-337-A, and C-333/C-333-A. This Engineering Notice was efreetive on May 21,1997.
- 9. Procedure CP3-EG-EG1074, became effective on December 31,1996. This procedure provides guidance for initiating, revising, and approving design and modification documents. Section 6.3 covers the actions necessary to change a drawing. Had this procedure been in place when the drawings were developed by Oak Ridge, Design Engineering would have been required to review the drawings and Oak Ridge to develop the drawings in conformance with a more comprehensive Configuration Management Program process now in existence.
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l IV.
Corrective Actions to be Taken l
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- 1. Procedure CP4-GP-lM6209 will be revised by August 18,1997, to ensure each individual CAAS horn, verified to be operating, is documented on a data sheet.
- 2. Procedure CP4-GP-lM4128 will be revised by August 18,1997, to include proper slave horn locations in Appendix B.
- 3. The procedure change / revision process will be revised by August 29,1997, to require l
actual field validations ofintent changes to in-hand procedures where physically possible.
- 4. CAAS training modules will be revised by September 8,1997, to ensure actual field conditions are covered.
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- 5. Training / Required Reading on proper procedure reviews and validations for plant personnel designated to perfomi these functions will be performed by September 15, 1997.
- 6. Using revised CAAS training modules, CAAS training for applicable Maintenance personnel will be conducted by October 13,1997.
- 7. Field walkdown of CAAS drawings will be performed by September 26,1997, to ensure proper horn lo::ations (column number).
- 8. Instrument CAAS safety system drawings will be revised by December 12,1997, as necessary, to incorporate discrepancies noted during field verification of drawings.
- 9. Electrical CAAS safety system drawings will be revised by December 12,1997, as necessary, to incorporate discrepancies noted during field verification of drawings.
V.
Date of Full Comoliance Full compliance with this violation was achieved when procedure CP4-GP-lM6209 was changed to include correct slaved horn features, and when TSR surveillance testing on C-333-A's "AA" and "AB" clusters and C-337's "V" and "X" clusters were completed on April 24,1997. The corrective actions taken to prevent recurrence will be completed by December 12,1997, i
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i ENCLOSURE 5 UNITED STATES ENRICHMENT CORPORATION (USEC)
RESPONSE TO NOTICE OF VIOLATION (NOV) 70-7001/97003-13 10 CFR 76.93, " Quality Assurance," requires, in part, that the certificatee shall establish and execute a quality assurance program.
The Quality Assurance Program, Section 2.16," Corrective Action," requires, in part, that for significant conditions adverse to quality, the cause of the condition is determined and corrective actien is taken to preclude recurrence.
Procedure UE2-HR-C11031, Revision 0, dated August 31,1996," CORRECTIVE ACTIONS,"
defined, in part, that a significant condition adverse to quality included: 1) unauthorized changes to attributes of a procedure that implements nuclear criticality safety requirements; and 2) problem trends that have a strong potential to lead to issues of significance.
Violation Cited Contrary to the above, from March 3 through May 6,1997, the certificatee did not determine the cause for or take corrective action to preclude recurrence of a significant condition adverse to quality. Specifically, the certificatee did not: 1) identify that a March 3,1997, internal memorandum made an unauthorized change to a procedure which implemented nuclear criticality safety (NCS) approval, GEN-27; and 2) determine the root cause for and take corrective actions to preclude the recurrence of violations of the NCS approval GEN-27 in 13uilding C-720.
I.
13ackground Information NCSA GEN-27, " Handling and Storage of Legacy Process Equipment," provides the requirements necessary to bring uncontrolled legacy process gas equipment into compliance with the double contingency principle. This NCSA is implemented through plant procedure CP2-TS-TS2030, " Handling and Storage of Legacy Process Equipment."
An NCS memorandum indicating that NCSA GEN-27 did not apply to untagged process Equipment in C-720 was issued on March 3,1997.
IL Reason for the Violation The reason for the violation is the lack of formal guidance for NCS to follow when i
providing interpretations to operations regarding the applicability of an NCSA. The l
potential for circumventing Plant Operations Review Committee (PORC) approval when providing interpretations of NCSA requirements was not recognized since a screening l
method was not available. The March 3,1997, NCS memorandum was created to interpret and clarify the applicability of requirements in NCSA GEN-27 and procedure E5-1 4
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CP2-TS-TS2030 to the equipment in C-720 based on other documents that controlled that equipment. The lack of a screening method subsequently caused the failure to identify the for the unauthorized change in the applicability of NCSA GEN-27 and implement corrective actions to preclude the recurrence of violations of NCSA GEN-27 and procedure CP2-TS-TS2030 in Building C-720 as required in the Quality Assurance Plan.
IIL
. Corrective Actions Taken and Results Achieved
- 1. A site-wide walkdown was completed on June 23,1997, in an effort to identify GEN-27 equipment and to bring it into compliance with NCSA GEN-27 and CP2-TS-TS2030. The identified equipment was then handled according to NCSAs GEN-27 or GEN-20 based on the equipments origin.
- 2. An Engineering Notice (EN-C-832-97-011) was issued on May 29,1997, which rescinded the March 3,1997, memorandum and reestablished the applicability of GEN-27 to C-720 and all plant facilities.
IV.
Corrective Actions to be Taken
- 1. Issue a procedure by October 27,1997, to govern the conduct of operations for the Engineering Function which specifically addresses the issuance of engineering guidance / interpretations and establishes the appropriate level of approval for that guidance.
- 2. Perform a crew briefing for all NCS staff members by August 8,1997, to ensure all members are following procedure CP3-EG-EG1080, " Engineering Notices." This procedure is applicable to transmit data, justify a specific course of action or to provide the results of an engineering evaluation and is to be used only for the transfer ofinfonnation outside of other proceduralized activities.
- 3. By August 29,1997, review all retrievable memorandums by August 29,1997, sent by NCS staff since April 1,1996, to determine if other guidance that could have been an unauthorized change to the applicability requirements of an NCSA or procedure exists. It is not necessary to review memorandums sent prior to this date since all currently implemented NCSAs were issued subsequent to April 1,1996.
V.
Date of Full Compliance Full compliance was achieved on May 29,1997, when the Engineering Notice EN-C-832-97-01 I was issued which rescinded the March 3,1997, internal memorandum. The actions to prevent recurrence will be completed by October 27,1997.
ENCLOSURE 6 LIST OF COMMITMENTS
- 1. A review of other similar TSRs (2.1,2.2,2.3,2.5 and 2.6) will be performed to determine if the format of these TSR requirements present a challenge to personnel to properly execute the requirements, similar to the problem presented by 2.4.4.2 in C-310 (specifically, different requirements located in separate TSR sections for a single system required to be operable by the TSR). This will be completed by August 8, 1997.
- 2. We will submit TSR changes to TSR 2.4 and 2.3 to NRC for approval making the editorial change of cross referencing the Required Actions of these two TSR sections as applicable to CAAS in C-310. This will be completed by October 7,1997.
- 3. We will change procedure CP2-CO-CN1031," Tracking ofInoperable Structures, Systems, and Components," to require that the plant shift superintendent (PSS) discuss the specific required TSR actions with the afTected front-line manager prior to declaring a TSR required system inoperable for planned work or system inoperabilities due to emergent conditions. This will be completed by September 30, 1997.
- 1. USEC will revise procedures and install hardware by October 31,1997, so that continuous flagging will be installed each time a CAAS evacuation zone is established.
The actions listed below are not new commitments, but come from Event Report ER-97-10.
- 1. By August 15,1997, Operations will ensure a system of communication of PM status / clear ownership and approval of PM deferral exists.
- 2. By September 30,1997, Reliability Engineering will evaluate (taking into account the results of Corrective Action No.1) and determine the correct preventive maintenance requirements for the transfer relays in C-310, C-331, C-333, C-335, and C-337. This evaluation will also include determining the adequacy of the frequency of the DC power switch test.
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- 3. By September 30,1997, Operations will issue an off-normal procedure for loss of DC power in C-310.
- 4. By September 30,1997, Operations will issue oft-normal procedures for loss of DC power in C-331, C-333, C-335, and C-337.
l Fnclosure 4 l
- 1. Procedure CP4-GP-lM6209 will be revised by August 18,1997, to ensure each individual CAAS horn, verified to be operating, is documented on data sheet.
- 2. Procedure CP4-GP-IM4128 will be revised by August 18,1997, to include proper slave horn locations in Appendix B.
- 3. Procedure change / revision process will be revised by August 29,1997, to require actual field validations ofintent changes to in-hand procedures where physically possible.
- 4. CAAS training modules will be revised by September 8,1991, to ensure actual field conditions are covered.
- 5. Training / Required Reading on proper procedure reviews and validations for plant personnel designated to perform these functions will be performed by September 15, 1997.
- 6. Using revised CAAS training modules, CAAS training for applicable Maintenance personnel will be conducted by October 13,1997.,
7 Field walkdown of CAAS drawings will be performed by September 26,1997, to ensure proper hom locations (column number).
- 8. Instrument CAAS safety system drawings will be revised by December 12,1997, as necessary, to incorporate discrepancies noted during field verification of drawings.
- 9. Electrical CAAS safety system drawings will be revised by Dedmber 12,1997, as necessary, to incorporate discrepancies noted during field verification of drawings.
- 1. Issue a procedure by October 27,1997, to govern the conduct of operations for the l
Engineering Function which specifically addresses the issuance of engineering l
guidance / interpretations and establishes the appropriate level of approval for that guidance.
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- 2. Perform a crea bdefing for all NCS staff members by August 8,1997, to ensure all members are fohwing procedure CP3-EG-EG1080, " Engineering Notices"." This procedure is applicable to transmit data, justify a specific course of action or to provide the results of an engineering evaluation and i to be used only for the transfer f
ofinformation outside of other proceduralized activities.
- 3. Review all retrievable memorandums by August 29,1997, sent by NCS staff since April 1,1996, to determine if other guidance that could have been an unauthorized j
change to the applicability requirements of an NCSA or procedure exists. It is not l
necessary to review memorandums sent prior to this date since all currently implemented NCSAs were issued subsequent to April 1,1996. Any problems discovered during this review will be documented in problem reports for correction.
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