o ct 1 8 201o - nuclear regulatory commissiono ct 1 8 201o o_ _ _ _ les-10-00220-nrc attn: document...

O CT 1 8 201o o_ _ _ _

LES-10-00220-NRC

ATTN: Document Control DeskOffice of Nuclear Material Safety and SafeguardsU. S. Nuclear Regulatory CommissionWashington, D.C. 20555-0001

Louisiana Energy Services, LLC

NRC Docket Number: 70-3103

Subject: Reply to Notice of Violation 70-3103/2010-013 - Supplement

Reference: Letter from LES to NRC, LES-1 0-00208-NRC, Reply to Notice of Violation 70-3103/2010-013, dated September 20, 2010.

In the referenced URENCO USA (UUSA) letter the dates for achieving full compliancefor Examples 1, 2, and 3 (related to completion of the review for CR 2010-2530) wasSeptember 30, 2010. Examples 1, 2, and 3 included the prevention and completion of amatrix to verify critical characteristics. The original date was not met due to the need foradditional time to complete the action. The review, as documented in the CorrectiveAction Program (CAP), was completed on 10/3/10.

In the same letter, the date for achieving full compliance for Example 4 of the NOVresponse was August 12, 2010. For Example 4 an additional issue related to CriticalCharacteristic (CC) 7a was identified by UUSA and documented in CR 2010-3126 on9/29/10 as part of the aforementioned matrix action. This new issue involved a failure ofan ASL approved vendor to perform requested chemical testing for the bolt and nutsample size provided. The date stated for full compliance of Example 4, in the NOVresponse, was not met due to the new issue identified in CR 2010-3126. Thecompletion date for chemical test results for Example 4 was 10/1/10. (See Enclosure forNOV response submittal replacement pages. The highlighted sections identify therevised text).

As noted in recent discussions with the NRC, issues identified during completion of thematrix review have been entered into the CAP for further evaluation. Upon resolution ofthese issues (including cause and extent of condition as appropriate), UUSA will notifythe NRC of the achievement of compliance.

Condition Reports (CR-2010-3216 and CR-2010-3186) have been generateddocumenting the failure to notify the NRC that the commitment dates had not been metprior to the completion date. Should there be any questions concerning this submittal,please contact Gary Sanford, LES Director of Quality and Regulatory Affairs, at575.394.5407.

Sincerely,

David E. SextonChief Nuclear Officer and Vice President of Operations

Enclosure: Reply to Notice of Violation 70-3101/2010-013 Replacement Pages

LES,PO Box 1789, Eunice, New Mexico 88231,USA T: +1 575 394 4646 F: +1 575 394 4545 W: www.urenco.com/LES

Anthony D. Masters(Acting)Chief, Construction Projects Branch 1US NRC, Region II245 Peachtree Center Ave, NESuite 1200Atlanta, GA 30303-1257

Anthony T. GodyDeputy Director, Construction ProjectsUS NRC, Region II245 Peachtree Center Ave, NESuite 1200Atlanta, GA 30303-1257

Tyrone D. Naquin, Project ManagerTwo White FlintMail Stop EBB2-C40M11545 Rockville PikeRockville, MD 20852-2738

John Parker, ChiefRadiation Control BureauField Operations DivisionEnvironment DepartmentHarold S. Runnels Building1190 St. Francis Drive, Room S 2100P.O. Box 26110Santa Fe, NM 87502

Sarah Cottrell, Deputy SecretaryNew Mexico Department of EnvironmentOffice of the Secretary1190 St. Francis DriveP. O. Box 26110Santa Fe, NM 87502-0157

Patricia A. SilvaChief, Technical Support BranchDivision of Fuel Cycle Safety and SafeguardsOffice of Nuclear Materials and Safeguards6003 Executive Blvd.Rockville, MD 20852

Luis A. ReyesRegional AdministratorRegion II245 Peachtree Center Ave, NESuite 1200Atlanta, GA 303031-1257

Jay L. HensonChief, Fuel Facility Branch 2USNRC, Region II245 Peachtree Center Ave, NESuite 1200Atlanta, GA 30303-1257

Matt White, MayorCity of EuniceP.O. Box 147Eunice, NM 88231

Gary Don Reagan, MayorCity of Hobbs200 E. BroadwayHobbs, NM 88240

Cheryl Chance, Mayor of JalP.O. Box Drawer 340Jal, NM 88252

Greg Fulfer, ChairmanLea County Commissioners100 North MainLovington, NM 88260

Richard A. Ratliff, PE, LMPRadiation Program OfficerBureau of Radiation ControlDepartment of State Health ServicesDivision for Regulatory Services1100 West 49th StreetAustin, TX 78756-3189

Carlos Romero, ChiefRadiation Control BureauField Operations divisionEnvironment DepartmentHarold S. Runnels Building1190 St. Francis Drive, Room S 2100P.O. Box 26110Santa Fe, NM 87502

ENCLOSURE

Louisiana Energy Services/URENCO USA (LES/UUSA)

Reply to Notice of Violation 70-3101/2010-013 Replacement Pages

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* inspections and surveillances in Cascades 2 and 3 that had not been completedwhen the work plan was closed were unknown to those preparing the NRCsubmittal for Cascades 2 and 3;

* the installation and torquing of the bolts was already completed in the Cascades(there were no hold points) and additional Method 3 surveillances could not bedone;

* the turnover of CGD personnel between the time of NRC acceptance of the CGDof Cascade 1 and the submittal of documentation for the dedication of Cascades2 and 3;

* the lack of proper turnover between those who dedicated Cascade 1 and thoseremaining after May 1, 2010; and,

* the failure to perform adequate reviews to confirm that bolt torque surveillancesfor CCs la, 7b, and 8a were completed.

Corrective Steps Taken and Results Achieved for Violation - Examples 1, 2 and 3:

1. Surveillance 201 0-S-08-509 dated 6 August 2010, was performed to collectdocumentation of torque verifications as performed by vendor personnel andwitnessed by UUSA QC Inspectors. This surveillance was performed inconjunction with Surveillance 201 0-S-07-503 (covering torque verification of boltsfor Turnbuckles and Main Header Fixed Pipe Clamps in Cascade 3) for thesatisfaction of requirements in the CGD Plan for Upper Steelwork bolt torqueverification in Cascade 3 Method 3 critical characteristics 1 a, 7b, and 8a.Completed 8/6/10

2. Developed desktop guide EG-4-21 00-11, Critical Characteristic VerificationPackage, to provide detailed instruction for verification of Critical Characteristics(CC) being used for extent of condition reviews. The methodology contained inthis desktop is to be used in procedures for future Cascades CGD. Thismethodology provides specific actions for CC verification including QC reviews forcompletion of CC requirements. Completed 9/3/2010

3. Personnel associated with inspections for IROFS 41 have attended HumanPerformance Training. Completed 7/23/10

Corrective Steps That Will Be Taken To Prevent Further Violation - Examples 1. 2 and 3:

1 . Procedure EG-3-2100-05, Commercial Grade Dedication, shall be revised toinclude independent QA review of CGD documentation for complex commercialgrade dedication items such as IROFS 41. Due Date: 10/31/10

2. Conduct a detailed review of all data associated with Cascade 3 CGDrequirements. From this effort, a matrix will be developed that provides a detailedlisting of documentation to demonstrate that all requirements for each criticalcharacteristic for Cascade 3 have been met. The information in the matrix will beused as a template for future cascade dedication packages. In addition, CGD plansare to be revised for IROFS incorporating lessons learned. Completed 10/3/10

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CGD plans are to be revised for IROFS incorporating lessons learned. Completed10/3/10

3. The CGD team will appoint a Project Manager for IROFS 41 and develop a ProjectPlan that addresses the requirements of the process necessary to dedicate IROFS41. This project plan must include appropriate training such that the individualsimplementing the plan are aware of their roles and responsibility. Due Date:11/5/10.

4 As an enhancement, assign QC inspectors to the CGD team to perform requiredinspection in order to eliminate communication issues between QA, QC, and CGDteam. Due Date: 10/10/10.

5. As an enhancement, the annual audits of the criteria of the QAPD that the UUSAQuality organization implements shall include at least one member that has aSecurity Clearance at the UUSA facility. This will allow review of any CGD or otherinspection and audit activities that are conducted on classified programs orsystems, or in areas that cannot be accessed without a Security Clearance. Thisrequirement should be incorporated in the QA Audit Schedule proceduralized inQA-3-2000-01 Quality Assurance Audits. Due Date: 12/31/10

6. As an enhancement, perform supplemental reviews of the in-process activities toensure that the CGD activities associated with Cylinder Receipt and DispatchBuilding (CRDB) and Autoclave comply with the relevant corrective actionsabove. Due Date 11/1/10

7. As an enhancement, perform supplemental reviews of the in-process activities toensure that the CGD activities associated with UF6 Stations complies with therelevant corrective actions above. Due Date 11/1/10

8. As an enhancement, the QA Organization shall conduct quarterly surveillances ofthe CGD Process related to IROFS 41 beginning in January, 2011 for at least threequarters. This will cover the last quarter of 2010 and the first two quarters of 2011to ensure that QC activities in support of the CGD of IROFS 41 are beingconducted in accordance with UUSA procedures and processes. Areas to beaddressed include accuracy of data being recorded on a day to day basis, reviewof any work plans that have been closed since the prior assessment/surveillance,and review of any completed Receipt Inspection Reports and Form 3 packagessince the previous assessment/surveillance. Due Date: 7/15/11

The Date When Full Compliance Will Be Achieved for Violation - Examples 1, 2 and 3:

Full compliance will be achieved upon resolution of Turnbuckle Radiography Test issueand completion of required actions for Cascade 3 CGD. UUSA will notify NRC uponachievement of full compliance.

Actions impacting the quality of future cascade submittals (i.e., Cascade 4 and forward)will be complete prior to CGD package submittal.

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2. The four M24X85 bolts installed in the upper steel (battleship were removed andreplaced with bolts from a heat lot that had been tested. Completed 8/07/10

3. The M12x45 and M1Ox3O bolts were sent to an outside vendor for testing on8/7/10. The receipt inspection for the M12x45 and M10x30 bolts destructivetesting results was performed. Completed 8/12/10

Corrective Steps That Will Be Taken To Prevent Further Violation - Example 4:

1. CGD team is to appoint a Project Manager for IROFS 41 and develop a ProjectPlan that addresses the requirements of the process necessary to dedicate IROFS41. This project plan must include appropriate training such that the individualsimplementing the plan are aware of their roles and responsibility. Due 11/5/10.

2. As part of the extent of condition review, a matrix is being developed to documentthat testing for all bolt types used in Cascade 3 was completed, and the requiredtest data is acceptable. Completed 10/3/10

3. As an enhancement, develop new procedures or revise existing procedures toensure that all aspects of the control of procurement and installation of SSCscovered by cascade work are fully incorporated. Due Date: 12/31/10

The Date When Full Compliance Will Be Achieved for Violation - Examole 4:


The Reason for Violation - Example 5:

The issue identified by the NRC was that the number of weld inspections documentedon data sheets for Critical Characteristic 1Ob (CC1Ob) in Work Plan 1001-MECH-453-021, did not equal the number of welds identified on referenced drawings.

Work Plan (1001-MECH-453-021) requires a visual assessment of the fillet welds in theunits listed to confirm their size. The number of weld inspections documented on datasheets correlated directly to the number of weld symbols that were present on theassociated drawings instead of the actual number of welds inspected. It is notuncommon for one weld symbol to identify more than one weld. This is standardreference for weld symbols on drawings associated with IROFS 41. The data sheetsthat were assembled to document the visual weld inspections described abovecontained one signature block for each weld symbol as opposed to one for each weld.When interviewed, the QC inspectors stated that their interpretation of the work planstep and the critical characteristics based on the associated drawings illustration meantthat they were signing for multiple welds associated with a weld symbol with onesignature. QC inspectors stated that they always inspected all welds associated with aweld symbol prior to signing off the inspection on the data sheets.

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In addition to the above, programmatic reasons and actions stated in Examples 1, 2, and3 specific to the CGD process apply to this example.

Corrective Steps Taken and Results Achieved for Violation - Example 5:

A review of the design drawings was performed and verification of weld inspections toconfirm the subject welds had been inspected. These supplemental verifications werecompleted on 8/9/10.

Corrective Steos That Will Be Taken To Prevent Further Violation - Examples 5:

1. Conduct a detailed review of all data associated with Cascade 3 CGDrequirements. From this effort a matrix will be developed that provides a detailedlisting of documentation to demonstrate that all requirements for each criticalcharacteristic for Cascade 3 have been met. The information in the matrix will beused as a template for future cascade dedication packages. In addition, CGD plansare to be revised for I ROFS incorporating lessons learned. Completed 10/3/10

The Date When Full Compliance Will Be Achieved for Violation E - Examples 5:


The Reason for Violation - Example 6:

The issue identified by the NRC inspection was that the documentation of criticalcharacteristic 11 for the H frame vertical dimension was not documented in the correctmanner. The CGD Plan and the Work Plan, 1001 -MECH-453-01 1, both called for thecenter line of six mounting holes to be measured to the bottom of the base plate. Themeasurements were made from the center line of the bolt to the top of the base plate asopposed to the bottom as required by the Work Plan and CGD Plan. In some instancesthe measurements were from bolt center to bolt center which was contrary to the workplan instruction.

A review of the drawing revealed that there were basic dimensions annotated todelineate geometric tolerance requirements. In addition, there are linear measurementsshown with traditional plus or minus tolerances. The physical measurements are besttaken to the top of the plate with measurement of the plate thickness taken separatelybut added to the top measurement. The CGD Plan and the Work Plan did notspecifically call for this method of measurement thus leading to the discrepanciesbetween the values on the drawing and the measurements recorded in the work plan.

Neither the CGD Plan nor the Work Plan listed the acceptance criteria but rather gave ageneral tolerance of plus or minus 3 mm or plus, or minus 4 mm if the measurement wasto the center of the installed bolt, without specifying where the tolerance should beapplied.

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