IR 07100103/2012014

Insp Rept 70-7002/97-12 on 971103-1214.Violations Noted. Major Areas Inspected:Plant Operations & Engineering

ML20198H250
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant, 07100103
Issue date:	01/09/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20198H217	List: IR 07100103/2012014 ML20198H213 ML20198H232
References
70-7002-97-12, NUDOCS 9801130238
Download: ML20198H250 (12)

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U.S. NUCLEAR REGULATORY COMMISSION REGIONlli Docket No: 70 7002 Certificate No: GDP 2 Report No: 70 7002/97012(DNMS)

Applicant: United States Enrichment Corpocation Facility Name: Portsmouth Gaseous Diffusion Plant Location: 3930 U.S. Route 23 South P.O. Box 628 Piketon, OH 45661 Dates: No, ember 3 through December 14,1997 Inspectors: D. J. Hartland, Senior Resident inspector J. M. Jacobson, Resident inspector, PGDP Approved By: Patrick L. Hiland, Chief Fuel Cycle Branch

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9001130238 9903o9 h0R ADOCK 07007002 PDR I

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EXuCUTIVE SUMMARY United States Enrichment Corporat'on, Portsmouth Gaseous Diffusion Plant NRC Inspection Report 70 7002/97012(DNMS)

This inspection report includes aspects of plant operations and engineering. The report covers a six week period of routine resident inspection Elant Operations e

e The inspectors noted that the certificatee's immediate corrective actions to an issue identified previously at the le s assay withdiawal (L/ W) station were narrowly-focuse The certificatee ver.fied compliance with nuclear criticality safety approval (NCSA)

requirements for F-cans at other withdrawal stations but did not ch6ck o?.her facilities in the plant where F-cans were used. As a result, the inspectors identified a non-compliance with NCS A requirements at the X-344 Building. In response to this and several other reportable events, the NRC performed a special inspection to review the certificatee's nucl9ar criticality safety (NCS) program implementation. One violation was identified. (Section O1.1)

• The certificatee failed to make the required notifications to the NRC in a timely manner due to poor turnovers and communication among operations shifts and lack of involvement from technical organizations. One violation was identified. (Section 01.2)

• During a review of a static cell treatment evolution, the inspectors were concerned that the certificatee decided to add another treatment to the cell with evidence of the presence of hydrocarbons. In addition, the operators did not evacuate the cell contents, as required by procedure, when additional hydrocarbons were detected. One violatian was identified. (Section O1.3)

Enaineerina e The inspectors identified several 00991 controlissues associated with cold recovery instrumentation. The inspectors were concerned that the certificatee did not identify these issues dur:ng the review of a problem report that was generated previously. One violation was identified. (Section E2.1)

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Report Details 1. Operations 01 Conduct of Operations'

0 NCS Implementation Problems a. Inspection Scope (88020)

The inspectors toured plant facilities to verify implementation of NCSA requirements, b. Observations and Findinas On November 7,1997, during a routine inspection at the X-344 facility, the inspectors observed that F cans used to store pigtail gaskets did not have lids. The inspectors had previously identified a similar concem with F-cans at the LAW station, as documented in Inspection Report 70-7002/97010, dated November 24,1997. The inspectors discussed the issue with the building manager, who then reviewed the applicable NCSx, 0344A007.A04, _" Waste Streams," for the facilit The cognizant manager noted that the controls for F-cans were discussed in the Part A description of the NCSA but requirements were not incorporated into Part B. In response, the building manager initiated Problem Report (PR) number PR-PTS-97 9598 to document the apparent inconsistency with the NCS requirements for F cans in other areas of the plant. The plant shift superintendent (PSS) reviewed the PR and concluded that a violation of NCS requirements had not occune On November 10 the inspectors discussed the issue with the site NCS organization. At h time of the initial discussion, the site NCS organization was not aware of the conce (3r ?n further review, the site NCS organization determined that uncovered F-cans were in n;t compliance with general plant NCSA PLANT 025.A01," General Use of Small

% meter Containers for Storing up to 10% Enriched Material," the same NCSA that applied to the LAW station. As a result, on November 12 the certificatee made a 24-hour notification to the NRC due to the loss of a control required by the NCSA. The basis for the control was to prevent spilling the contents of the cans into an unfavorable geometr The other control, contents less than 10 percent assay, was malataine Technical Safety Requirement (TSR) 3.11.2 requires, in part, that all operations involving uranium enriched to 1.0 weight-percent (wt.%) or higher U-235 and 15 grams (g) or more of U-235 shall be performed in accordance, with a documented nuclear criticality safety approval (NCSA). NCSA-PLANT 025.A01," General Use of Small Diameter Containers for Storing up to 10% Enriched Material," requires that non-empty F-cans be capped at all

' Topical headings such as 01, M8, etc., are used in accordance with the NRC standardized inspection report outline contained in NRC Manual Chapter 0610. Individual reports are not expected to address all outline topics, and the topical headings are therefore not always sequentia _

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timea except when filling, sampling, or emptying containers. Contrary to the above, on November 7,1997, the inspectors identified that one non-empty F-can, located in the X 344 Building was in storege and uncapped, a Violation (VIO 70-7002/97012-01).

In adGlion, the inspectors noted that this violation was similar to Velatbn 70-7002/97010-02, and that the corrective actions for Violative 70/1002/97010-02 were being addressed on Noven,ber 7,1997. A review of the corrsctive actions taken and planned to correct Violation 70 7002/97010-02, received from the United States Enrichment Corporation on December 23,1997 (GDP 97-2041), appeared to adequately address the issues highlighted in Violation 70-7002/97012 0 The certificatee identified several other violations of NCS requirements during the inspection periori that resulted in NRC notifications, in response, the NRC conducted a specialinspection to assess the certificatee's initial corrective actions. The results of that inspection will be documented in Inspection Report 70-7002/9701 c. Conclusions The inspectors noted that the certificatee's corrective actions to the F-can issue identified previously at the LAW station were narroMy-focused. The certificatee verified compliance with NCSA requirements for F-cans at other " withdrawal stations," but did not check other facilities in the plant where F-cans were use .2 Failure To Properly Characterize And Report Events Inspection Scope (88100)

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The inspectors reviewed certificatee performance with regards to the characterizing and reporting of events, b. Observations and Findinas The event discussed in paragraph 01.1 regarding the F-cans at the X-344 facility was an example of the certificatee's failure to identify and report a violation of NCS requirements in a timely manner. The inspectors also identified other examples during the inspection period:

- In conjunction with the identification of the NCSA non-compliance with the F-cans at the X-344 facility as discussed above, the inspectors raised a question regarding the reportability of Violation 70-7002/97010-02, identified previously at the LAW station. In response, the certificatee reported that event as well on November 13 (NRC Event Notification Number 33256).

- Similarly, on November 5 the certificatee made a late 4-hour notification to report a violation regarding the use of engineering notices (EN) to change NCSA requirements, which was also discussed in inspection Report 70-7002/9701 The basis for that report was that controls were not formally approved in accordance NCS program requirements (NRC Event Notification Number 33219).

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The inspectors also identified a mis-characterization of an event reported by the certificatee on December 4. The event involved an NCSA violation for spacing sample tubes in the X 710 Building. The certificatee initially identified the event as a loss of a single control. During further review at the request o' the inspectors, the certificatee determined that both controls had been lost and, as a result, revised the notification on December 8 (NRC Event Notification Number 33353).

- On October 27,1997, the certificatee identified that a failure of the cylinder intemal pressure loop on Autoclave #3 at the X 344 facility during operation two days before was reportable as a safety system component failure. A similar failure had occurred on Autoclave #7 at the X-343 Building on October 23,1997, and was reported to the NRC. The certificatee determined that it did not immediately identify the second failure as reportable due to poor tumovers and communication among the operations shifts (NRC Event Notification Number 33158). In addition, on November 3,1997, the certificatee identified that a loss of two nuclear criticality s Tfety controls in *.he enrichment cascade on November 2, 1997, was reportable as a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> notification (NRC Event Notification Number 33206).

Technical Safety Requirement 3.9.1 requires that written procedures be implemented to cover activities descnoed in Safety Analysis Report Section 6.11.4.1 and listed in Appendix A to Safety Analysis Report Section 6.11. Appendix A to Safety Analysis Report Section 6.11 states that " investigations and reporting" shall be covered by a written procedure. Paragraph 6.2.1 of plant Procedure UE2-RA-RE1030, Revision B,

" Nuclear Regulatory Event Reporting," requires verbal notification to the appropriate NRC office within the time requirements shown in Appendix D of the procedure, and that the information is completely and accurately described. Failure to make the rsquired NRC notifications in an accurate and timely manner, as required by the plant procedure UE2 RA-RE1030, " Nuclear Regulatory Event Reporting,"is a Violation of TSR 3. (VIO 70-7002/97012-02) Conclusion The certificatee failed to make the required notifications to the NRC in a timely manner, due to poor tumovers and communications among operations shifts and lack of involvement from technical organization .3 Procedural Adherence Violation Durino Static Cell Treatment a. Inspection Scope (88100)

The inspectors reviewed activities associated with the static treatment of Cell 29-4- b. Observations and Findinas Treatment was usually performed on cells with the compressors running. The certificate 3 ir"' "d a static cell treatment on Cell 29-4-4, which contained a deposit with greater than safe mass, because some of the equipment had previously been removed. The t

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certificatee prepared Procedure XP4-CO-CN2118-TMP, " Static Cell Treatment in X 330,"

to perform the cell treatmen About three minutes after the initial treatment was added on November 10, the operator observed a rapid temperature rise in Stage 6. The temperature instrument went off scale (> 400 degrees Fahrenheit (F)) for a few minutes and then returned to about 20-30 degrees F above other areas in the cell. As required by the procedure, in response to the abnormal reaction, the operators obtained gas samples te evaluate the concentration of the reactants in the cel After evaluating the sample results, the certificatee determined that the cause of the localized temperature excursion was the reaction of the conditioning agent with some residual wet air. Stage 6 of the cell had previously been opened to the atmosphere to remove the compressor and to weld plates over the flange Sample analysis from Stage 5 of Cell 29-4-4 indicated that hydrocarbon reaction products were present in that area. The hydrocarbons, under certain conditions, could react violently with the conditioning agent. Although Step 8,4.2 of the procedure required that the cell contents be evacuated to surge drums if hydrocarbons were detected, the certificatee decided to add another treatment to the cell. The basis for the decision, as documented in Evaluation EVAL-X330-SA-001, was that the concentration of the reaction products had not increased indicating that any residual hydrocarbons in the cell had been consume The certificatee also concluded in the evaluation that the procedure limited the maximum charge of the conditioning agent to less than levels that previous studies indicated could be used to remove hydrocarbons in cascade equipment without any adverse effect However, the inspectors noted that the certificatee did not initiate a change to the governing procedure to allow the addition of another treatment with evidence of the presence of hydrocarbon When the next treatment was added, the concentration of reaction products increased a0ain, indicating the presence of additional hydrocarbons in the cell. However, the cell contents were not evacuated as required by the procedure until the concern was raised by the inspectors. The cell treatment was then put on hold by the certificatee pending further evaluatio Technical Safe *y Requirement 3.9.1 requires that written procedures be implemented to cover activities described in Safety Analysis Report Section 6.11.4.1 and listed in Appendix A to Safety Analysis Report Section 6.11. Appendix A to Safety Analysis Report Section 6.11 states, in part, that cell treatments shall be covered by a written procedure. Paragraph 8.4.2 of plant Procedure XP4-CO-CN2118-TMP, Revision 0,

" Static Cell Treatment In X-330," states in part, that if the presence of fluorocarbons or hydrocarbons was detected and there were no indications of an abnormal reaction, to evacuate the cell contents to surge drums as needed. The failure to evacuate the cell with indication of the presence of hydrocarbons, as required by Procedure

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XP4-CO-CN2118 TMP, is a Violation of TSR 3.8.1, (VIO 70-7002/97012 03)

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. . Conclusion The inspectors identified that the certificatee added another treatment to Cell 29-4 4, with evidence of the presence of hydrocarbons, in addition, the operators did not evacuate the cell contents, as required by procedure, when additional hydrocarbons were detecte Miscellaneous Operatiens issues 0 (Closed) V)O 70 7002/97002 0.1: Failure to meet minimum staffing reouirement The cause of the event was that the TSR requirements were not flowed down into operating procedures. As correctiv6 action, the certificatee developed a procedure that described process facility manning requirements, established a methodology for how staffing levels would be maintained, and designated a more descriptive area of operation for assigned personnel. This item is close .2 (Closed) CER 70-7002/97-09: Disabling of the cascade automatic data p*ocessing (CADP) smoke detection system in the X 333 Buildin The ca.use of the event was an erroneous command entered in the system by an operator in the X-330 Building while attempting to deactivate smoke heads in that building. The operator immediately discovered the error and personnel established smoke watches as required by TSR 2.2.3.3. As corrective action to this and other events, plant management initiated STAR program training with the goal of preventing similar occurrences through self-checking. In addition, the certificatee changed applicable operating procedures to require deactivation of individual points rather than entire cell Further, entries in the system were required to be verified before entered. The inspectors had no further concems and this item is close .3 (Closed) JF,[ 70-7002/97003-10 (CER 97-05): Failure to enter TSR Limiting Condition for Operation (LCO) after multiple fire protection system supervisory alarm failure The cause of the event was that fire services personnel did not recognize that the supervisory alarms affected operability of the sprinkler systems. As corrective action, the certificatee revised applicable surveillance procedures to detail actions required when surveillance requirements were not met. Failure to comply with TSRs 2.2.3.4 and 2.7. is a violation. However, plant personnelidentified and took appropriate action to correct the deficiency. This licensee-identified and corrected violation is being treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Polic (NCV 70-7002/97012-04) Inspection Follow-up Item (IFl) 70-7002/97003-10 is close Ill. Enaineerina E2 Engineering Support of Facilities and Equipment E Poor Desian Control Of Cold Recovery Instrumentation l

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a. Ln3pretion Scor>e f88101) ,

- The inspectors reviewed operations and design at the cold recovery station to verify compliance with TSR and other certificate requirements, b. Observations and Findinas .

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During review of operations at the cold recovery station in the X 330 and X 333 cascade buildings, the inspectors noted that infrared analyzer carts were being used in lieu of !

installed instrumentation. The carts were being used to verify relief drum pressure less

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than 0.3 pounds per square inch absolute (psla), prior to flashing cold traps as required by TSR 2.4.3.2. The basis for the requirement was to ensure that the design differential

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across the cold trap rupture disk was not exceeded. The problem with the existing instrumentation was that the instrumentation was not scaled properly and could not effectively monitor pressure in that rang .

During further review, the inspectors identified several concerns with the use of the carts:

- Neither the existing instrument nor the carts were included in the safety system boundary. The inspectors also noted that carts were used elsewhere in the plant for safety-related applications, including during cell treatments to monitor gas concentrations as required by TSR 2.2.3.6 and 2.7, TSR 2.4.3.2 required that the instrument used to verify relief drum pressure less than 0.3 psia be calibrated on a semlannual basis. The carts were only calibrated annually. The certificatee performed a procedure change review (PCR), dated March 6,1997, to allow the use of the carts but the PCR did not identify the calibration frequency as a change to the TS The certificatee did not initiate a temporary modification package to approve the use of the carts for this application. Plant Procedure UE2-EG-GE1033,

" Temporary Modification Control," defined a temporary modification as a change in the function of a system or any of the system components which was not consistent with approved design as documented by official plant record file The certificatee had an opportunity to identify these issues previousl PR-PTS-97-8776, dated October 6,1997, raised a concern with the use of the carts for this application without a documented temporary modification packag The PSS concluded at that time that no action was required because the instrument was outside the safety bounoary and that TSR requirements were

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being me In response to the inspectors' concerns, the certificatee put a hold on flashing cold traps until a modification could be processed to install appropnate instrumentatio Surveillance Requirement 2.4.3.2.1 requires that the cold trap pressure relief system instrumentation be calibrated on a semiannual basis. Failure to calibrate the carts on a

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semiannual basis is a Violation of TSR Surveillance Requirement 2.4.3.2.1.

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l c. Conclusions j The inspectors were concemed that the certificatee did not identify these issues during review of the problem report that was generated previousl E8 -- Miscellaneous Engineering issues E (Closed) CERs 70-7002/97003-06 (97-04): 70-7002/97-07: 70 7002/97 08:

70 7002/97-11: and 70-7002/9713: High Condensate Level System (HCLS) autoclave actuations at the X-344 Building, The certificatee determined that the cause of the actuations was the accumulation of debris in the condensate strainers. The inspectors cited the certificatee, as discussed in inspection Report 70-7002/97005, for the failure to take action to prevent recurrence of the actuations. The inspectors will continue to track the effectiveness of the certificatee's corrective actions, including those given in response to Event Report 97-13, under Violation 70-7002/97003-0 E (Closed) IFl 70-7002/97002-03: Evaluation of crane fuse failure at the tails withdrawal statio The certificatee examined the failed fuse and could not determine the root cause. No evidence of a fault or overload condition was found in the circuit. Engineering determined that the incidence of fuse failure was very low and random and, therefore, did not recommend replacing fuses as part of the preventive maintenance program. The inspectors have no further concems regarding this issue, as the fuse failure appeared to be an isolated occurrence. This item is close V. Manaaement Meetinas X1 Exit Meetina Summary The inspectors presented the inspection results to members of the facility management on December 15,1097. The facility staff acknowledged the findings presented. The inspectors asked the plant staff whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie ._ ..

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PARTIAL LIST OF PERSONS CONTACTED Lockheed Martin Utility Services (LMUS)

• J. B. Morgan, Acting General Manager =

• M Hasty, Engineering Manager

• R. W. Gaston, Nuclear Regulatory Affairs Manager

• C. W. Sheward, Maintenance Manager R. D McDermott, Operations Manager

- United States Enrichment Corporation

- J. H. Miller, USEC Vice President, Production L Fink, Safety, Safeguards & Quality Manager United States Department of Enerav (DOE)

z J. C. Orrison, Site Safety Representative Nuclear Reautatory Commission (NRC)

• P. L Hiland, Chief, Fuel Cycle Branch

• D. J. Hartland, Senior Resident inspector Y. H. Faraz, Project Manager, NMSS

• Denotes those present at the exit meeting on December 15,199 INSPECTION PROCEDURES USED IP 88100 Plant Operations IP 88101 Configuration Control IP 88020 Regional Criticality Safety IP 97012 Inoffice Reviews of Written Reports on Nonroutine Events

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ITEMS OPENED. CLOSED. AND DISCUSSED Opened-70 7002/97012 01 VIO Failure to have covers on F-cans in Building X-344 70 7002/97012-02 VIO Failure To Make Required NRC Notifications On A Timely Basis 70-7002/97012-03, VIO Failure To Evacuate Coll With Indication Of The Presence Of Hydrocarbons As Required By Procedure 70 7002/97012 04 NCV Failure To Enter TSR LCO After Multiple Fire Protection System Supervisory Alarm Failures. (IFl 70-7002/97003-10)

70 7002/97012 05 VIO Failure To Calibrate Infrared Analyzer Carts On A Semiannual 1 Basis

. Closed 70-7002/97002-01 VIO Failure To Meet Minimum Staffing Requirement /97-09 CER Disabling Of The CADP Smoke Detection System In The X 333 Buildin /97003 10 IFl Failure To Enter TSR LCO After Multiple Fire Protection System Supervisory Alarm Failure /97003-06 CER HCLS autoclave actuation at the X 344 Building 70-7002/97-07 CER HCLS autoclave actuation at the X-344 Building 70 7002/97-08 CER HCLS autoclave actuation at the X-344 Building

, 70-7002/97-11 CER HCLS autoclave actuation at the X-344 Building 70-7002/97-13 CER HCLS autoclave actuation at the X-344 Building

70-7002/97002-03 IFl Evaluation Of Crane Fuse Failure At The Tails Withdrawal Station.

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Discussed 70 7002/97003-02 VIO HCLS autoclave actuation at the X-344 Building Certification issues - Closed None i

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LIST OF ACRONYMS USED CADP cascade automatic data orocessing CER Certificatee Event Report CFR- Code of Federal Regulations

DNMS Division of Nuclear Materials Safety DOE Department of Energy EN engineering notice F Farenheit g grams HCLS High Condensate Level System IFl Inspection Follow-up item IP inspection Procedure LAW low assay withdrawal LCO Limiting Condition for Operation LMUS Lockheed Martin Utility Services NCS Nuclear Criticality Safety NCSA Nuclear Criticality Safety Approval NCV Non-cited Violation NOV Notice of Violation NRC Nuclear Regulatory Commission PCR procedure change review PDR Public Document Room PR problem report psia Pounds Per Square Inch Absolute PSS Plant Shift Superintendent SAR Safety Analysis Report SR Surveillance Requirement TSR Technical Safety Requirement USEC United States Enrichment Corporation VIO Violation wt. % weight percent

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