ML20154J757

Insp Rept 70-7001/98-15 on 980908-11.No Violations Noted. Major Areas Inspected:Maint & Surveillance & Plant Support

ML20154J757
Person / Time
Site:	07007001
Issue date:	10/09/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20154J729	List: ML20154J724 ML20154J757
References
70-7001-98-15, NUDOCS 9810150327
Download: ML20154J757 (9)

Text

_ . . .

U.S. NUCLEAR REGULATORY COMMISSION REGION 111 Docket No.: 70-7001 Certificate No.: GDP-1 ,

Report No.: 70-7001/98015(DNMS)

Facility Operator. United States Enrichment Corporation i

Facility Name: Paducah Gaseous Diffusion Plant Location: 5600 Hobbs Road P.O. Box 1410 Paducah, KY 42001 Dates: September 8 - 11,1998 Inspector: R. G. Krsek, Fuel Cycle . Safety inspector f

Approved By: Timothy D. Reidinger, Acting Chief Fuel Cycle Branch Division of Nuclear Materials Safety I

~

9810150327 981009 PDR ADOCK 07007001 C PDR

\  !

EXECUTIVE

SUMMARY

United States Enrichment Corporation Paducah Gaseous Diffusion Plant NRC Inspection Report 70-7001/98015(DNMS)

Maintenance and Surveillance

. The inspector concluded that the maintenance activities and subsequent documentation for the replacement of a motor-operated valve subassembly and uranium hexafluoride detector head were adequate. Safety and health permits were appropriately implemented for both activities observed. The inspector noted that for the replacement of the motor-operated valve subassembly, the hold points for quality control inspections were all performed. (Section M1.1)

. The inspector observed quarterly Technical Safety Requirement surveillances for the criticality accident alarm system (CAAS). The work activities observed and associated documentation reviewed for the surveillances in Buildings C-33A and C-720 were generally adequate. However, weaknesses were identified by the inspector regarding the CAAS surveillance which occurred in Building C-333A, and a subsequent negative trend identified in the performance of previous CAAS system functional tests.

(Section M1.2)

Plant Suooort

. The inspector concluded that the waste management staff implemented an effective program for the management of various waste streams generated onsite, as evidenced by overall reductions in waste streams over the past five fiscal years. Shipments of low level radioactive waste offsite were handled and processed in accordance with the applicable NRC and Department of Transportation shipping requirements. The operation of the onsite waste assay system was conducted in accordance with the applicable procedure. (Section W1.1)

. The inspector reviewed the corrective action plan to enhance the overall effectiveness and quality of training onsite. The inspector determined that considerable progress had been made in the completion of action plan items, and that improvements in training were noted across various organizations onsite. (Section 11.1) 2

ReDort Details

1. Operations 08 Miscellaneous Operations issues (92702) 08.1 (Closed) VIO 070-07001/97012-02a. b. & c: Failures to implement operating procedures. The inspector reviewed the corrective actions taken for this violation, as documented in a December 23,1997, correspondence from the United States Enrichment Corporation. The inspector noted that all the corrective actions taken to prevent recurrence of this violation were complete, and that the corrective action items effectively addressed the root cause of the violation. During this inspection, the inspector also observed plant staff performing confined space entries and respirator fit checks. No problems were identified and these activities were conducted in accordance with plant procedures. The inspector also reviewed several post-maintenance tests (PMTs) for various maintenance work packages in the plant, and noted that the work instructions for the PMTs were adequate. Based upon the effectiveness of the corrective actions taken, as demonstrated by the completion of all corrective actions and the ir.apector's field observations, this issue is considered closed.

II. Maintenance M1 Conduct of Maintenance and Surveillance Activities M1.1 Qbservation of Maintenance and Surveillance Activities

a. Inspection Scooe (88025)

The inspector reviewed the implementation of various maintenance activities in pcogress during the facility tours and inspections. The int.pection consisted of observations af ongoing maintenance activities, interviews with maintenance staff and supervision and reviews of completed maintenance work packages.

b. Observations and Findinas The inspector observed ongoing maintenance activities in various buildings during the inspection. Specifically, the inspector observed and reviewed work associated with the replacement of a motor-operated valve (MOV) subassembly in Building C-337 performed in accordance with Work Order No. R 9803727-03, and the replacement of a high voltage uranium hexafluoride (UF.) detector in Building C-310 performed in accordance with Work Order R 9811343-01. During the observation of work for both activities, the inspector noted that plant staff conformed with the applicable radiation work permits and complied with the applicable requirements for the establishment of

" fire watches."

As part of the inspection for the replacement of the MOV in Buil ding C-337, the inspector walked down and verified that the appropriate lockouts and tagouts were in place, as required by Lockout /Tagout Work Permit No. 98-337-309. The appropriate requirements of the required ' Hot Work" permit for this evolution were also followed.

3

The completed work package for Work Order No. R 9803727-03 was reviewed and found to be in compliance with the goveming policies and procedures for work control.

In addition, the inspector noted that for this maintenance evolution all the " Hold Points" j for quality control inspections were performed.

The post-maintenance tests for both maintenance evolutions were successfully completed and adequately demonstrated that the equipment would perform as expected, following the maintenance activities. No concems were identified by the inspector during the course of inspection for these maintenance evolutions,

c. Conclusions The inspector concluded that the maintenance activities and documentation for the 3 replacement of a MOV subassembly and UF, detector head were adequate. The

]

appropriate safety and health permits were appropriately implemented for both activities I observed. The inspector noted that for the replacement of the MOV subassembly, the hold points for quality control inspections were all performed.

l M1.2 Observation of Quarterly Criticality Accident Alarm System Surveillances ,

1

a. Inspection Scooe (88025)

The inspector observed the implementation of Technical Safety Requirement surveillances for testing the criticality accident alarm system (CAAS) in Buildings C-720, and C-333A. The inspection consisted of observations of ongoing surveillance activities, interviews with instrument and maintenance staff and reviews of surveillance records.

b. Observations and Findinas On September 9 the inspector observed testing of the CAAS in Buildings C-333A and l

C-720. The testing was required by Technical Safety Requirement Surveillances 2.2.4.3  :

for Building C-333A and 2.6.4.1 for Building C-720. The surveillance required testing of l the CAAS, local cluster and building homs, in addition to the verification that the nitrogen supply pressure to the cluster horns was at least 900 pounds per square inch gauge. The action steps instrument maintenance staff were required to perform for the tests were prescribed in Procedure CP4-GP-lM6209, " Criticality Accident Alarm System Functional Tests."

l The inspector observed the ongoing testing activities at Building C-333A for Criticality l Accident Alarm Clusters AA and AB. While reviewing the required action steps of Procedure CP4-GP-lM6209 during the completion of testing activities, the inspector

! noted that instrument maintenance staff responsible for the verification of the red CAAS l waming light rotations did not have stopwatches. Procedure CP4-GP-lM6209, Sections 7.0 and 8.1 required the use of stopwatches which were entered into the material and testing equipment (M&TE) program. During interviews with instrument maintenance staff performing the work, the inspector noted that staff were confused as to whether or not M&TE stopwatches were required for this activity. The inspector then reviewed Procedure CP4-GP-lM6209 with the instrument maintenance supervisor, who acknowledged that Sections 7.1 and 8.1.13 required the use of M&TE stopwatches for verification of the actual revolutions per minute of the red CAAS warning lights. The inspector did not identify any other concerns with the maintenance activities observed.

4

The inspector then reviewed the associated work package documentation for CAAS testing in Building C-720, with the acting instrument maintenance supervisor overseeing this activity and the CAAS system engineer. The testing had just been completed and the work package documentation revealed that the M&TE stopwatches were utilized for this maintenance activity. The acting instrument maintenance supervisor and CAAS system engineer acknowledged that Procedure CP4-GP-lM6209 required the use of an M&TE stopwatch. No other issues were identified with regards to the work package documentation.

The insperior reviewed the completed work package for the CAAS testing in >

Building C-333A. The inspector informed the plant shift superintendent (PSS) that the completed work package documented that the maintenance activity was not performed .

in accordance with Procedure CP4-GP-lM6209, specifically, M&TE stopwatches were l not used to verify red CAAS waming light rotations. The PSS consulted the system engineer and instrument maintenance staff and concluded that although there was reasonable assurance of system operability, the tests for Clusters AA and AB needed to be re-performed in accordance with Procedure CP4-GP-lM6209. Later that evening, the quarterly Technical Safety Requirement surveillances for Clusters AA and AB in Building C-333A were performed in accordance with Procedure CP4-GP-lM6209. The PSS also initiated assessment and tracking report number 98-5655 to document the issue in accordance with plant policies and procedures.

Maintenance management and the PSS subsequently conducted a review of the last quarterly CAAS Technical Safety Requirement Surveillance for each CAAS cluster onsite. The review revealed that the latest CAAS cluster Technical Safety Requirement surveillance was performed in accordance with Procedure CP4-GP-lM6209. Additional ,

reviews did identify that inree previous surveillances were not performed with the M&TE stopwatches, as required by Procedure CP4-GP-lM6209. In addition, maintenance management conducting the reviews identified that some instrument maintenance staff did not conduct the surveillance in accordance with the procedure, but had previously performed the surveillance correctly under the guidance of different instrument j maintenance supervisors. The inspector noted ths.t in each of the five instances where j the maintenance activity had not been performed with the required M&TE stopwatch, the recorded values for the rotations of the red CAAS waming lights were approximately i three times greater than the required acceptance criteria of 20 revolutions per minute.

The inspector determined that although the M&TE stopwatches were not used, there was reasonable assurance of system operability.

On October 6,1998, the inspector contacted Nuclear Regulatory Affairs staff to determine what, if any, additional corrective actions were taken to address this issue.

Nuclear Regulatory Affairs staff highlighted the following corrective actions, in addition to the actions previously discussed: (1) Form CP-21243, contained in Procedure CP4-GP-IM6209, was revised to include specific nomenclature in the M&TE equipment block to  !

replace the previous "fillin" requirement. This change assured that during work j package closures, reviewers will be able to identify if the required M&TE was used for i the maintenance activity; (2) the maintenance supervisor was re-instructed on plant policies and requirements for the use of approved plant procedures; and i (3) maintenance management conducted crew briefings for the work groups involved in i the five deficient surveillances which emphasized management expectations for )

procedural compliance, and that each individual has "stop work" authority. The l l

5 j 4

-, s- - .. --. m- y.. _, , . - . , , -v.,- ._ w -. .

inspector acknowledged that the corrective actions taken by the certificatee were comprehensive and adequately addressed the issue.

The failure to follow work control practices during CAAS functional testing is a violation of minor significance which is not subject to formal enforcement action.

c. Conclusions L The inspector observed quarterly Technical Safety Requirement surveillances for the l CAAS. The work activities observed and associated documentation reviewed for the surveillances in Buildings C-33A and C-720 were generally adequate. However, a minor violation was identified by the inspector regarding the CAAS surveillance which occurred l

In Building C-333A, and a subsequent negative trend identified in the performance of previous CAAS functional tests, i

IV. Plant Suncort W1 Conduct of Radioactive Waste Management Activities W1.1 Review of Onsite Radioactive Waste Manaaemen_t

a. Inspection Scooe (88035)

The inspector reviewed the overallimplementation of the onsite radioactive waste management program with the waste management staff. The inspector also observed the shipment of low level radioactive waste offsite and demonstrations of the operation of the qualitative and quantitative waste assay system.

b. Observations and Findinas The inspector reviewed overall waste management data from fiscal year 1994 to present l with cognizant certificatee staff. Waste management data indicated that for the i hazardous and mixed waste streams onsite, an overall five-year average reduction of L 29 percent of the waste mass was observed. A comparison of the fiscal year with the largest mass of hazardous and mixed waste (1996) and the current fiscal year revealed a 47-percent reduction of the hazardous and mixed waste streams. The inspector also reviewed data for low level radioactive waste generated onsite. Data for the low level radioactive waste streams onsite indicated an overall five-year average reduction of 15 percent. A comparison of the fiscal year with the largest mass of low level i

radioactive waste (1997) and the current fiscal year revealed a 39-percent reduction of l low level radioactive waste mass. The inspector also reviewed the methods used to characterize onsite low level radioactive waste, as documented in KY/R-15, l

• Characterization of Low Level Radioactive Waste." Review of this document and j interviews with the waste management staff indicated that the program for the i characterization of low level radioactive waste was comprehensive and conservative.

The licensee made several shipments of low level radioactive wastes which included contaminated rubble and dry active waste. The inspector reviewed the final packaging of randomly selected shipments and noted that appropriate radiological surveys were performed and that levels of removable contamination ware below the limits specified in 6

49 CFR 173.443. In addition, records of shipping papers and waste manifests were reviewed and contained the information required by 49 CFR 172 and 10 CFR 20.

The inspector observed operation of the qualitative and quantitative (Q2) waste assay i

system. The Q8 waste assay system was used to determine the isotopic content and i activity present in certain waste streams onsite. The inspector noted that the plant staff implemented the appropriate material control and accounting and nuclear criticality safety controls specified for this particular operation in accordance with Procedure CP4-EW-WM4102, " Qualitative and Quantitative (Q2) Waste Assay System Operation."

c. Conclusions 4

The inspector concluded that the waste management staff implemented an effective program for the management of various waste streams generated onsite, as evidenced by overall reductions in waste streams over the past five fiscal years. Shipments of low level radioactive waste offsite were handled and processed in accordance with the applicable NRC and Department of Transportation shipping requirements. The l operation of the onsite waste assay system was conducted in accordance with the l applicable procedure.

11 Conduct of Training Activities 11.1 Review of Actions Taken to Enhance the Onsite Trainino Proaram

a. Insoection Scope (88010)

The inspector reviewed the status of an action plan, initiated to improve the overall effectiveness and quality of onsite tmining at the plant. The inspection consisted of  !

interviews with training and plant staff, and reviews of training documentation.  ;

b. Observations and Findinas in response to various NRC inspection findings, intemal self-assessments, surveillance program findings, and self-identified issues, the training organization initiated a comprehensive and extensive action plan to enhance the overall effectiveness and quality of the training program. The action plan detailed approximately 100 items, grouped into seven main categories for completion. At the time of the inspection, about 45 percent of the action items planned had been completed. During field observations and interviews with plant staff, the inspector noted improvement in the following areas on plant site: required reading process; increased control over establishing and  ;

maintaining training requirements; the implementation of a work restriction program throughout the plant; development of an efficient survey process for training program feedback; increased communications among various plant organizations and the training organization; and the establishment of discemable management expectations for the implementation of the training program, in addition to enhanced site-wide training expectations.

I The inspector also noted that organization managers all received monthly updates on

' the overall status of training for the plant. The monthly update emphasized the

requirement that workers had to complete training or be placed on work restriction, and appeared to be effective in identifying which organizations onsite required increased i

7

A i

l management attention with regards to training issues. The training organization also I j established performance indicators to measure the overall implementation of training and to track the effectiveness of training organization changes. The inspector reviewed trending data and noted improving trends in the training organization, specifically  ;

increased participation of plant staff in required training, and increased self identification I of training issues. The inspector noted several novel proposals to enhance the effectiveness of the training program, including an increase in the type of equipment i available for hands on training of plant staff, and the possible development of a .

simulator to assist plant staff in " hands on" training. l

c. Conclusions The inspector reviewed the corrective action plan to enhance the overall effectiveness and quality of training onsite. The inspector determined that considerable progress had  ;

been made in the completion of action plan items, and that improvements in training j were noted across various organizations onsite.

V. Management Meetinas Exit Meeting Summary X1' i

The inspector presented the inspection results to members of the plant staff and management at the conclusion of the inspection on September 11,1998. Plant staff acknowledged the l findings presented at the meeting. The inspector asked the plant staff whether any materials  !

l examined during the inspection should be considered proprietary. No proprietary information j was identified.

I i

8 l

l

PARTIAL LIST OF PERSONS CONTACTED l Lockheed Martin Utility Services L. Beach, Waste Management Manager M. Buckner, Operations Manager A. Canterbury, Maintenance Manager L. Jackson, Nuclear Regulatory Affairs Manager S. Penrod, Enrichment Plant Manager H. Pulley, F'iant General Manager V. ShankA Production Support Manager R. Starkey, Training Manager W. Sykes, Commitment Management Manager United States Enrichment Corooration J. Labarraque, Safety, Safeguards and Quality Manager INSPECTION PROCEDURES USED IP 88010: Operator Training and Re-training IP 88025: Maintenance and Surveillance Testing IP 92702: Follow-up of Previous inspection issues ITEMS OPENED, CLOSED AND DISCUSSED Opened None Closed 70-7001/97012-02a,b,&c VIO Failure to implement procedures Discussed None 9