ML20154R835

Insp Rept 70-7001/98-16 on 980902-1014.No Violations Noted. Major Areas Inspected:Operations,Maint,Engineering & Plant Support

ML20154R835
Person / Time
Site:	07007001
Issue date:	10/21/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20154R820	List: ML20154R818 ML20154R835
References
70-7001-98-16, NUDOCS 9810270204
Download: ML20154R835 (19)

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L l U.S. NUCLEAR REGULATORY COMMISSION REGIONlli l'

Docket No: 70-7001 Certificate No: - GDP-1 l.

Report No: 70-7001/98016(DNMS) .

l Facility Operator: United States Enrichment Corporation l

Facility Name:. Paducah Gaseous Diffusion Plant Location: 5600 Hobbs Road

- P.O. Box 1410 -

Paducah,KY 42001 Datesi September 2 through October 14,1998 -

! Inspectors: K. G O'Brien, Senior Resident inspector J. M. Jacobson, Resident Inspector Approved By: Timothy D. Reidinger, Acting Chief Fuel Cycle Branch Division of Nuclear Materials Safety l

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EXECUTIVE

SUMMARY

l United States Enrichment Corporation Paducah Gaseous Diffusion Plant NRC Inspection Report 70 7001/98016(DNMS) l Plant Operations A deficiency in the control of freezer /sublimers taken out of service due to inoperable l l high-high weight trip systems resulted in two freezer /sublimers inappropriately entering '

l Mode F/S 3. Prompt investigation and followup by the plant staff to ensure freezer /sublimers without operable safety systems could not be transitioned to an l- improper mode led to the issue being treated as a non-cited violation. (Section O1.1) l- .

Plant laboratory personnel incorrectly manipulated block valves required to be open by Technical Safety Requirement 2.4.3.4 and thereby isolated the relief path for the cell coolant system for two operating cells in Building C-310. The event appeared to occur as the result of a lack of understanding of the significance of the valves by laboratory personnel and a control-of-equipment policy that was not comprehensive. Prompt investigation and followup by the plant staff to address these issues led to the event being treated as a non-cited violation. (Section 01.2)

I Maintenance and Surveillance

. Deficiencies in the rigor of the program for controlling contractors performing work onsite were identified as a result of the inspectors' review of selected work packages and recent events in which contractor activities led to false actuations of safety systems.

(Section M1.1)

. The inspectors noted some problems with the completeness of the documentation of work performed in the work packages for the seismic modifications in Buildings C-310, C-310A, and C-315. Although none of the issues were characterized as having a significant impact on the capability of the modified systems to function as designed, the deficiencies made it difficult to independently verify the work performed by review of the work packages alone. (Section M1.2)

Enaineerina

. Plant engineering staff developed and proceduralized a rigorous methodology for testing the audibility of the Building C-720 criticality accident alarm system. As a result, the plant staff was able to significantly extend the range of coverage of the audibility function. (Section E1,1)

!~ . The inspectors concluded that the plant staff had implemented the interim compensatory actions and installed seismic design modifications in Buildings C-310, C-310A, and C-315 by September 30,1998, as identified in an NRC Confirmatory Order issued on April 22,1998. (Section E1.2) l~

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1 The plant staff responded promptly and effectively to the identification of two criticality accident alarm system modules exhibiting abnormal meter readings. The plant staff identified that the cause of the abnormal readings was a buildup of static electricity on the meters, not a problem with the internal comparator (fault) circuitry. As a result, one cluster which had been initially considered inoperable was determined to be operable and the associated event report was retracted. (Section E1.3) l Plant Supporf The plant staff identified and developed appropriate corrective actions for a security I incident in which an uncleared contractor drove a bus within the controlled access area of the site without a required security escort. As a result, the event is being treated as a non-cited violation. (Section S1.1)

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Report Details i t  !

l. Operations i p 01 Conduct of Operations t O1.1 Control of Freezer / Sublimer Ooerationg

a. Insoection Scooe (88100)

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The inspectors reviewed the circumstances surrounding two incidents of operators

placing a freezer / sublimer in an inappropriate mode.

. b. Observations and Findinas-y On September 21, the plant staff identified that the freezer / sublimer for Unit 4 Cell g in j- Building C-333 was in Mode F/S 3 (Cold Standby). At the time, the high-high weight trip

. system, designed to prevent uranium hexafluoride (UF.) bridging of the coolant tube fins and a possible rupture of the freezer / sublimer, had been declared inoperable because l- . the Technical Safety Requirement (TSR) requiring quarterly surveillance for the safety

system had not been completed due to cells being down for the summer outage.

- TSR 2.4.3.1 required that the freezer / sublimer high-high weight trip system be operable

when the freezer / sublimer was in Mode F/S 1 (Freeze) or. Mode F/S 3. The operations i staff had previously develope d a Limiting Condition of Operation (LCO) tracking sheet to I identify that the safety syster.) was considered inoperable. The operations staff had  !

believed that the unit was in Mode F/S 6 (Out of Service) with the R-114 drained. l However, the R-114 sight gtass was actually filled beyond the level indication and was  ;

thus misread by the operations staff. The operations staff did not check the weight i indications to ensure tN unit was actually in Mode F/S 6. As a result, the unit was i actually in Mode F/S 4 (Hot Standby) so that when additional R-114 was pumped into j the unit to perform a weight trip test, the freezer / sublimer controller tripped the unit into 1 Mode F/S 3.

On October 3, during operations to change the cascade gradient as the cascade power I level was increased, an operator attempted to reset an alarm on the digital process control system (DPCS) panel for the freezer / sublimer in Unit 5 Cell g of Building C-333.

Upon resetting the alarm, the freezer sublimer automatically transitioned from Mode F/S 4 to Mode F/S 3. - The high-high weight trip system for this sublimer was also inoperable due to a past-due quarterly surveillance in addition, the. cell associated with this freezer / sublimer was offstream, so the freezer / sublimer would have been unavailable for use in any case. For both incidents, upon discovery, the plant staff placed the affected freezer / sublimer in a mode for which the high-high weight trip system was not required. The plant staff also performed a walkdown of all freezer /sublimers that had been taken out of service due to Inoperable safety systems to ensure all units were in an appropriate mode. l In response to these incidents, the plant staff initiated investigations to determine the cause of the inadequate control of these freezer /sublimers and develop corrective actions. The investigations revealed that the first incident occurred as a result of operations staff not understanding that the R-114 sightglass had been overfilled. The second incident occurred as a result of a first-line manager not placing the freezer 4

sublimer in Mode F/S 4 at the local control panel and returning a caution tag to the appropriate contrei switch after the attempted quarterly surveillance was not successful; the lack of attention to detail on the part of the control room operator in attempting to manipulate the DPCS for a freezer sublimer which had been logged as inoperable; and the lack of understanding on the part of operations staff that even if the freezer / sublimer was placed in Mode F/S 4 at the local control panel, the DPCS automatically overrode this switch and placed the unit in Mode F/S 3 upon resetting certain alarms at the DPCS console in the control room.

As corrective action for the incidents, plant staff revised Long-Term Order (LTO)98-014 to require that any freezer /sublimers taken out of service due to inoperable weight trip systems be placed in Mode F/S 6, a mode in which the freon for the unit would be drained and for which the safety system was not required to be operable. Under this circumstance, the unit could not be inadvertently placed into Mode F/S 1 or Mode F/S 3 as both of these modes required the coolant system be filled with freon. In addition, plant staff were developing a procedure revision for the applicable operating procedure to specifically address and ciarify the requirements for controlling freezer /sublimers under various LCO Action Statements. Finally, the plant staff provided crew briefings to operators on the incidents and the revised LTO. As a result of the prompt followup by plant staff, this non-repetitive, certificatee-identified and corrected violation is being treated as a Non-Cited Violation (NCV 70-7001/98016-01), consistent with Section Vll.B.1 of the NRC Enforcement Policy.

c. Conclusions A deficiency in the control of freezer /sublimers taken out of service due to inoperable high-high weight trip systems resulted in two freezer /sublimers inappropriately entering Mode F/S 3. Prompt investigation and followup by the plant staff to ensure freezer /sublimers without operable safety systems could not be transitioned to an improper mode led to the issue being treated as a non-cited violation.

01.2 Ruoture Disk Block Valve Closure in Buildina C-310

a. Insoection Scooe (88100)

The inspectors reviewed the circumstances surrounding a report to the NRC of a I TSR-required safety system (R-114 coolant overpressure control system) being  !

disabled because block valves in-line with system rupture disks had been closed (Event .

Report 34811).

b. Observations and Findinas On September 19, an operator performing a pre-start inspection of Cell 4 in Building C-310 identified that the block valve in-line with the rupture disk for the coolant system was closed. This condition prevented the rupture disk from providing overpressure relief for the coolant system in the event of a coolant pressure transient.

After the initial discovery, the operator walked down the other cells in Building C-310 and identified that two cells which were onstream (Cells 2 and 6) also had the rupture disk block valves closed. TSR 2.4.3.4 required that the R-114 coolant overpressure control (relief) system be operable for Modes Cascade 1 and Cascade 2, i.e., whenever the cell process motors were energized and R-114 was in the coolant system.

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Building C-310 operations entered the LCO Action Statements and took immediate actions to return the valves to the open position and ensure the valves were sealed.

As a result of the initial findings, the plant staff made a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> event report to the NRC pursuant to 10 CFR 76.120(c)(2) because of a disabled safety system for which there 1 was no redundant equipment to perform the required safety function. Subsequent to the i event report, the plant staff performed an additional assessment which identified that the l coolant meletron (pressure switch) control system for Cells 2 and 6, an augmented quality-nuclear criticality safety system, was operable and performed a redundant safety function in that the system tripped the cell (i.e., placed the cell in Mode Cascade 3, a mode for which overpressure relief was not required) at a pressure below the setpoint of the relief rupture disks. As a result, the certificatee retracted the event report. The inspectors reviewed the reportability assessment and concluded that it appeared l

reasonable.

l l The bloc'K valves Were required to be sealed open to ensure the path for Coolant overpressure relief was available. A TSR-required quarterly surveillance of the block l valves was performed by a Building C-310 operator on August 18,1998, and did not

! identify any valves that were not properly sealed open. Immediately after the event, plant staff undertook an investigation to identify why the status of the valves had changed without Building C-310 operations staff knowledge. The investigation identified ,

that the coolant system for these three cells was slightly different than that for the other cells in Building C-310 and other cascade buildings. These cells had a sample tap for R-114 sampling by laboratory staff located in between the block valve and the rupture disk, whereas the other cells had a sample tap on a separate run of pipe. The small peanut valves which were used to aample sometimes leaked. As a result, laboratory staff sometimes manipulated the rupture disk block valves to control the amount of R 114 collected in the coolant samples or to prevent the system from leaking after sampling was complete. Laboratory staff generally, but not always notified operations staff upon entry into the buildings where samples were to be collected. However, the laboratory staff did not realize or communicate to operations staff that the sampling activities involved the manipulation of valves that were sealed open in order to maintain a TSR required operable overpressure relief path. Building operators, on the other hand, did not take a questioning attitude in understanding the scope and potential consequences of the sampling activities. As a result, the plant staff performing the investigation concluded that a generic issue with the control of equipment by operations staff existed.

i The plant staff developed a number of corrective actions in response to the event.

These actions included issuing Functional Directive 98-008 clarifying management's expectations that any manipulation of equipment falling under the purview of the Operations Department be performed in accordance with an approved procedure work package instructions or as minor maintenance and be approved by the Area Control Room; developing a revision to the general site procedure governing control of equipment to include a more detailed discussion of operations and non-operations staff responsibilities for manipulating equipment and communicating beforehand; and, reviewing departmental procedures to ensure that any evolutions which could involve non-operations personnel manipulating equipment have an appropriate level of detail to ensure that the status of plant equipment is known and controlled throughout and at the end of the job. As a result of the prompt followup by plant staff, this non-repetitive, certificatee-identified and corrected violation is being treated as a Non-Cited Violation 6

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t z(NCV 70-7001/98016-02), consistent with Section Vll.B.1 of the NRC Enforcement Policy. ,

c. Conclusions Plant laboratory personnel incorrectly manipulated block valves required to be open i by TSR 2.4.3.4 and thereby isolated the relief path for the cell coolant system for two operating cells in Building C-310. The event appeared to be a asult of a lack of

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understanding of the significance of the valves by laboratory personnel and a control-of-equipment policy that was not comprehensive. Prompt investigation and

- followup by the plant staff to address these issues led to the event being treated as a non-cited violation.

.08 ' Miscellaneous Operations issues 08.1 Certificatee Event Reports (90712) ,

[ 1 l- The certificatee made the following operations-related event reports during the inspection period. The inspectors reviewed any immediate safety concems indicated at the time of the initial verbal notification and also reviewed any subsequent retractions made. The inspectors will evaluate the associated written reports for each of the events

following submittal.

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! - &;-@gr Status lit lg None Closed Fourteen-ton cylinder received with radiation levels above transportation limits. (The finding was referred to NRC l l and State officials associated with the origination point of I l the shipment.)

34913 Open Discovery of an inoperable autoclave high pressure isolation system containment boundary due to failure of l autoclave head-to-shell seal.

L 08.2 Bulletin 91-01 Reports (97012) l The certificatee made the following reports pursuant to Bulletin 91-01 during the i inspection period. The inspectors reviewed any immediate NCS safety concerns associated with the report at the time of the initial verbal notification. Any significant issues emerging from these reviews are discussed in separate sections of the report. ,

Number Qtta Titig l

34895 10/9/98 Second pressure-monitoring device required by nuclear criticality safety evaluation not captured in L

u approval.

I 08.3 (Closed) Certificatee Event Report 34811: This event report is closed based on the

! discussion in Section O1.2.

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08.4 [QJmed) Certificatee Event Report 34851: This event report is closed based on the

[ disce sion in Section E1.3.

08.5 : LClosed) Certificatee Event Reoort 32215: Deficiencies identified in Building C-333 Sprinkler Systems A-4, B-4, and C-5. As documented in NRC inspection Report 70- l

. 7001/97002(DNMS), the certificatee initiated and completed an extensive project to l

' identify and correct deficiencies with the fire water systems onsite due to years of

~ inadequate control and maintenance. As a result, the NRC decided not to take enforcement action for this old design issue. Based on the corrective actions resulting from the fire water system walkdowns designed to ensure the current TSR-related system met applicable code and Safety Analysis Report (SAR) requirements, the 2

inspectors considered the event report closed.

08.6 - (Closed) Certificatee Event Report 32222: Deficiencies identified in Building C-337 Sprinkler Systems A-4, A-5, A-8, A-16, B-1, B-4, B-12, C-16, C-8, and D-5. See discussion in Section O8.5. This event report is considered closed.

08.7 (Closed) Certificatee Event Report 32228: Deficiencies identified in Buildings C-333 and C-335 sprinkler systems. See discussion in Section 08.5. This event report is

. considered closed.

08.8 (Closed) Certificatee Event Report 32231: Deficiencies identified in Building C-315 sprinkler system branch lines and Building C-337 Sprinkler Systems A-5. See discussion in Section O8.5. This event report is considered closed.

08.9 (Closed) Certificatee Event Report 32238 Deficiencies identified in Building C-335 Sprinkler Systems 9 and 28. See discussion in Section 08.5. This event report is considered closed.

, 1 08.10 (Closed) Certificatee Event Rooort 32252: Deficiencies identified in Building C-315 sprinkler systems. See discussion in Section 08.5. This event report is considered closed.

08.11 (Closed) Certificatee Event Reoort 32268: Deficiencies identified in Buildings C-331 and C-335 sprinkler systems. See discussion in Section 08.5. This event report is considered closed.

08.12 (Closed) Certificatee Event Report 32278: Deficiencies identified in Building C-315 sprinkler systems. See discussion in Section 08.5. This event report is considered closed.

08.13 (Closed) vertificatee Event Reoort 31972: Deficiencies identified in Building C-337 sprinkler systems (two sprinkler heads obstructed). See discussion in Section 08.5.

This event report is considered closed.

2 08.14 (Closed) Certificatee Event Report 32002: Deficiencies identified in Building C-331 f sprinkler systems (sprinkler heads obstructed and angled from vertical). See dMcussion in Section 08.5. This event report is considered closed.

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O8.15 (Closed) Certificatee Event Reoort 32012: Deficiencies identified in Building C-331 L sprinkler systems (sprinkler heads obstructed or not spaced per code). See discussion 1 in Section 08.5. This event report is considered closed.

- 08.16 (Closed) Certificatee Event Report 32026: Deficiencies identified in Building C-331  ;

sprinkler systems (branch line missing). See discussion in Section 08.5. This event 1 g report is considered closed.

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L L11. Maintenance and Surveillance r

. M1. - Conduct of Maintenance and Eurveillance 1

' M1.1 Control of Contractors Near Safety Systems i

a. Insoection Scope (8810.21 The inspectors reviewed the conduct of work performed by selected plant contractors to )

ensure the activities were conducted in accordance with the plant work control program. j

b. Observations and Fin'dinas The inspectors noted that recent events indicated that problems existed with the control of contractors performing work onsite! Examples of problems included a false safety. d system actuation of a process gas lee detection (PGLD) system in the Building C-310 i i~

. withdrawal area due to steam or smoke created during welding activities and a false actuation'of the seismic monitoring system in Building C-335 during construction work. 1

' As a result of these events, the inspectors reviewed current contractor work controls and discussed oversight activities with the responsible plant staff.

The inspectors' review identified some deficiencies in the control of contractor work j activities. Work packages required a pre-job walkdown by a construction ergineer and the contractor, but did not necessarily include input from the operations staff to identify potential operations impacts. The walkdowns were conducted only prior to the start of i activities at the work location and did not include periodic reviews to ensure that .

operational conditions had not changed, particularly if the work was interrupted for any l length of time. Selected work packages reviewed did not include potential concems  ;

associated with' performing work around permanently installed equipment or safety systems. Contractor work packages and acuvities also did not include the interim job L restart authorizations normally documented in work packages. Finally, the contractor  !

L+ ' work packages appeared to be generic and susceptible to perfunctory reviews since the i L  : instructions in the packages did not change (in terms of actual detailed content) from  ;

L, .one work location to another.

The inspectors did not identify any immediate safety or regulatory issues associated with

the contractor work reviewed. However, the inspectcrs noted that several of the issues g

were indicative of a negative trend in the control of cor& actors performing modification or maintenance activities onsite which could potentially result in more serious consequences if the trend was not arrested. The plant management and staff acknowledged the issues identified and, at the end of the inspection period, were in the l

process of developing and implementing corrective actions and work control l ' improvements in response to recent events involving contractors onsite.

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. c.. Conclusions

- Deficiencies in the rigor of the program for controlling contractors performing work I onsite were identified as a result of the inspectors' review of selected work packages and recent events in which contractor activities led to false actuations of safety systems.

M1.2 Seismic Modification Work Packaaes for Buildinas C-310 and C-315 (EA 98-156)

a. Inspection Scope (88102)

During the seismic modification walkdown discussed in Section E1.2 of the report, the inspectors reviewed numerous work packages associated with seismic modifications to the Building C-310, C-310A, and C-315 accumulators, condensers, withdrawal piping, and the Normetex pumps.

b. Qbservations and Findinas A number of problems with the work packages were noted by the inspectors during the review. Some of the work packages reviewed did not include all of the drawings necessary to complete the work, although the actual installation was completed in -

accordance with the approved drawings. Also, some of the work packages did not include any acceptance eteria or objective evidence to demonstrate that the work had been properly performed and could be validated at a future date (for example, detailed weld inspection sheets, welder qualifications, weld rods actually used, etc.). In one instance, an engineering notice was used as the method to modify drawings which were used to direct the installation work as opposed to using the normal process to l update and review the instructions in a work package. Although a safety evaluation was performed which indicated the change was within the design envelope, the change did not appear to be processed formally in conformance with the plant work control policy.

i The inspectors did not identify any work package problems which resulted in the identification of a noncorformance which had to be reworked (see Section E1.2 for a discussion of a nonconbrmance identified during the seismic modification walkdown). ,

However, the approach used in the preparation of the work packages and the l documentation of wou actually performed in the completed packages was not extensive enough to allow an i adependent verification of the installation activities by review'of the work packages ator e. The inspectors noted that this issue had been a problem with .

work control for ny,difications performed by plant staff in the past in that incomplete documentation made it difficult to understand the scope and completeness of work

- performed after t te modification was closed.

c. Conclusions The inspectors not id some problems with the completeness of the documentation of work performed in ? ie work packages for the seismic modifications in Buildings C-310, C-310A, and C-31f . Although none of the issues were characterized as having a significant impact ol the capability of the modified systems to function as designed, the deficiencies made it difficult to independently verify the work performed by review of the work packages alone.

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Ill. Enoineerina E1. ' Conduct of Engineering E1.1 Buildina C-720 Audibility Testina

a. insoection Scope (88100)

The inspectors observed selected portions of audibility testing performed by systems engineers to extend the range of coverage of the Building C-720 criticality accident ,

alarm' system (CAAS). In addition, the inspectors reviewed Procedure CP4-EG-EG9035.tmp, Revision 0, " Audibility Testing of the C-720 Criticality Accident Alarm System," dated August 18,'1998, and the results of the testing.

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b.- Qbservations and Findinas The inspectors notea that the audibility testing procedure contained acceptance criteria based upon the CAAS design audibility requirements in the SAR, supplemented with testing methodology provided in Intemational Safety' Organization Standard 7731 l (ISOS), " Danger Signals in the Workplace." The testing was performed using sound meters calibrated and controlled in accordance with the plant measuring and test equipment program or with a representative cohcrt of the plant population as identif;ed in ISOS 7731. The testing included verification that the ambient sound level measurements were based upon operating the noisiest equipment in the Building C-720 maintenance work shops. As a result of the testing, plant engineering staff were able to accurate!y map and significantly extend the range of coverage of the electronic CAAS horns in Building C-720.

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c. Qonclusions l

i Plant engineering staff developed and proceduralized a rigorous methodology for testing l the audibility of the Building C-720 CAAS. As a result, the plant staff were able to

j. significantly extend the range of coverage of the audibility function.

E1.2 Seismic Modifications in Buildinas C-310 and C-315 (EA 98-156)

I a. Inspection Scope (88100)

The inspectors reviewed the certificatee's interim compensatory measures and final corrective actions to address the issues identified in an NRC Confirmatory Order dated l April 22,1998. The Order (Enforcement Action 98-156) was issued to confirm l commitments made by the certificatee to limit the volume of liquid UF. stored in l accumulators on an interim basis and to install seismic modifications in Buildings C-310, l C-310A and C-315 to increase the seismic capacity of some equipment (Normetex withdrawal pumps, condensers, accumulators, and connective piping) in the facilities to withstand an earthquake producing a peak ground acceleration of 0.165 g. The review included observation of the operations staff's implementation of administrative controls for the site accumulators; review of the design analys:s calculations, plant change request, and work packages for the modification; and, a walkdown of the modifications using the approved drawings for the design to verify that the modifications had been completed.

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b. Observations and Findinas The Order confirmed the certificatee's commitment to limit access to Buildings C-310, C-310A, and C-315 to only those individuals essential to operations, inspections, or those personnel performing any modifications to fix the identified seismic failures.

During routine tours of the buildings from April through September 1998, the inspectors noted that occupancy of the buildings was limited to only these individuals identified

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above. In addition, the inspectors noted that long-term orders were issued to ensure that plant staff were aware of the restrictions on access to the buildings.

The Order confirmed the certificatee's commitment to take certain actions when the flow of liquid UF. was diverted to the online accumulator in Building C-310A or Building C-315 for greater than one hour. Specifically,' the plant staff were to: 1) notify the Plant Shift Superintendent (PSS) of accumulator usage; 2) begin tracking accumulated quantities by using calculated withdrawal rates; 3) require the PSS to )

initiate high priority actions for timely resolution of unscheduled outages; 4) require the  ;

Cascade Coordinator to take actions to reduce the tails downflow or product or tails I withdrawal rates to minimize accumulator use as appropriate; and,5) notify the NRC 1 resident inspectors. The plant staff issued LTO 98-004 which required the operatioris )

staff in Buildings C-310 and C-315 to notify the PSS any time the accumulators were i used (primarily during cylinder changes). The inspectors noted that the PSS recorded the usage times in the Building C-300 PSS log and that these times were typically less than 15-20 minutes. The inspectors noted that on the two occasions when an online accumulator was being filled for more than one hour due to inoperable safety systems in )

the product or tails withdrawal areas from April through September 1998, the plant staff

- implemented the actions described above. The shift engineer calculated the current withdrawal rate, maintenance activities were immediately initiated, and the NRC resident inspectors were notified. The inspectors did not identify any case in which liquid UF.

was diverted to an online accumulator for greater than two hours.

The Order confirmed the certificatee's commitment to stop the flow of liquid UF to the affected accumulator in the event the calculated accumulator inventory reached 4,000 pounds in Building C-310A or 10,000 pounds in Building C-315. The inspectors did not identify any events in which the affected accumulator inventories approached these levels.

TL' Order confirmed the certificatee's commitment to install seismic modifications to the equipment in Buildings C-310, C-310A, and C-315 by September 30,1998. The seismic modifications were to increase the seismic capacity of the equipment to withstand en earthquake producing a peak ground acceleration of 0.165 g [ acceleration due to gravity). The inspectors reviewed selected design analysis calculations to understand the scope of the modifications. The calculations appeared to address the seismic capacities of equipment involved with the production and withdrawal of liquid UF.,

including the Building C-310 and C-315 Normetex pumps, condensers and accumulators. The inspectors did not identify any issues with the design analysis. The results appeared to be appropriately transferred into drawings for the field installation.

The inspectors performed a walkdown of the seismic installations to compare the actual in-field work with the approved drawings. The drawings indicated the modifications were to be controlled as augmented quality items consistent with other components relied upon to provide seismic restraint identified in Section 3.15.3 of the SAR. In general, the 12

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~ inspectors noted that the locations and sizes of supports and tiedowns installed to -

increase the seismic capacity of the equipment were consistent with the design drawings. However, the inspectors noted that two of the bumpers installed on the West Normetex Pump in Building C-310 had the tiedown bolts secured through an I-beam running under the second floor and over a truck alleyway between Buildings C-310 and C-310A. The drawing indicated that the bolts were to be secured to a steel plate next to the I-beam on the underside of the concrete floor. In response to the inspectors' concern, plant engineering staff performed an engineering evaluation (EV-C-815 l 110, Revision 0) that concluded the as-built configuration was acceptable based on load calculations and initiated a drawing revision to capture the as-built configuration. The inspectors reviewed the evaluation and concluded the analysis appeared reasonable.

c. Conclusions I

The inspectors concluded that the plant staff had implemented the interim compensatory actions and installed seismic design modifications in Buildings C-310, C-310A, and C-315 by September 30,1998, as identified in an NRC Confirmatory Order issued on April 22,1998.

[ E1.3 Abnormal Meter Readinas for Criticality Accident Alarm System Modulea

a. Insoection Scope (88100)

The inspectors reviawed the circumstances surrounding the discovery of two CAAS modules with abnormal meter readings, one of which (Cluster "K" in Building C-331) led the PSS to declare the cluster of three modules inoperable because another module was in fault. The potential failure of two of three modules in the "K" CAAS cluster was reported to the NRC on September 29 (Event Report 34851).

b. Observations and Findinas On September 29, operations staff received a trouble alarm for the Building C-331 "K" CAAS cluster in the Building C-300 Central Control Facility. Instrument mechanics were dispatched to the cluster. The mechanics identified that the cluster, consisting of three independent monitoring modules, had the left module in fault and the center module reading 0 milliroentgen per hour (mR/h) on its meter, but was not in fault. The mechanics reset the left module and the Building C-300 trouble alann cleared. The center module reading was abnormal in that the modules had an internally generated electronic background signal set at 4.0 mR/h and a fault alarm set at 2.5 mR/h. Thus, if the module was truly sensing 0 mR/h, the fault light should have been lit. Because the CAAS clusters alarmed based on two-of-three voting logic, the PSS considered the cluster to be inoperable because of the anomalous meter reading and reported the event to the NRC pursuant to 10 CFR 76.120(c)(2).

During routine tours that same day, the inspectors identified another cluster, CAAS Cluster "S" in Building C-360 that had the right module with a meter reading 0 mR/h and no fault light. Because the other two modules had normal meter readings, the PSS considered the cluster to be operable, but initiated a plant walkdown to identify any other clusters with abnormal readings. No additional clusters were identified.

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l in response to the two events, the plant engineering staff initiated troubleshooting activities to determine the root cause of the abnormal meter readings. TI,e alant staff removed the "K" Cluster and brought it to the repair shop for testing. The L -found testing for the fault alarm set point and radiation alarm set point were found to be normal (2.5 mR/h and 10.0 mR/h, respectively. Also, the center meter reading returned to approximately 3.5 mR/h, but was noted to be very responsive to waving a hand in front of the meter. As a result, plant staff suspected that a static electricity buildup on the face of the meter was the cause of the abnormal reading. In addition, plant staff performed testing of the "S" Cluster with a weak radiation source which identified that the right module alarmed as required. After cleaning the meter with a static-removing toilette, the plant staff noted that the meter stylus retumed to the normal 4.0 mR/h reading. Based on the testing, the plant staff determined that the failure of the meter to accurately reflect the output of the module sensor circuitry did not impact the module intemal electronic comparator (fault) circuitry or the radiation alarm function of the i module. As a result, the PSS considered that CAAS Cluster "K" in Building C-331 had I been operable despite the abnormal meter reading and retracted the event report on i October 12. Based on the prompt and thorough followup by plant staff to the issue, the inspectors considered the assessment reasonable. The plant staff indicated that a voluntary report of the static problem for the module meters would be submitted to the NRC to alert other potential users of similar criticality alarms of the investigation I findings.

c. Conclusions The plant staff responded promptly and effectively to the identification of two CAAS modules exhibiting abnormal meter readings. The plant staff identified that the cause of the abnormal readings was a buildup of static electricity on the meters, not a problem with the internal comparator (fault) circuitry. As a result, one cluster which had been initially considered inoperable was determined to be operable and the associated event report was retracted.

IV. Plant Suonort S1 Conduct of Security and Safeguards Activities S1.1 Missina Security Escort for Contractor

a. Inspection Scope (88100)

, The inspectors reviewed the response by plant staff to an event in which a contractor, without a security clearance, was allowed unescorted access for a limited time within the controlled access area (CAA) of the plant.

b. Observations and Findinas On September 24, at approximately 9:00 a.m. (CT), the plant staff discovered that an uncleared contractor performing work within the CAA had driven a bus from one location of the site to another without a required security escort. The security escr,rt who had previously been responsible for the individual had been let off the bus with a group of other individuals requiring escort and had not realized that this left the bus driver

, unescorted. Upon reaching his final destination, a project escort coordinator realized 14

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that s Mcurity escort was not present and alerted the plant staff of the problem.

l Altho.g1 the contractor was allowed unescorted access while traveling with the bus, the l- contractor did not have access to any security sensitive areas of the plant during this

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l~ period of time. Nevertheless, the lack of a continuous escort while the contractor was within the CAA was a violation of the Paducah Security Plan and site security procedures.

The inspectors noted that the incident was correctly identified as a reportable event pursuant to 10 CFR 95 once the security staff and PSS were notified. However, the inspectors noted that the plant staff took some four to five hours to raise the issue j to the decision-making level which was a concem based on the nature of the report, a one hour notification. This appeared to be due to a new project coordinator who initiated an investigation immediately but did not understand the reportability aspects of p the issue.

The plant staff developed corrective actions for the event which included providing additional training to the contractor, escorts, and plant staff involved, ensuring that control of the bus keys would reside with the assigned escort and not the contractor, and assuring that each contractor bus driver would have an assigned escort who would sit in a specific seat behind the driver. As a result of the prompt followup by plant staff, ,

this non-repetitive, certificatee-identified and corrected violation is being treated as a 1 Non-Cited Violation (NCV 70-7001/98016-03), consistent with Section Vll.B.1 of the

,. NRC Enforcement Policy.

c. - Conclusions The plant staff identified and developed appropriate corrective actions for a security incident in which an uncleared contractor drove a bus within the controlled access area of the site without a required security escort. As a result, the event is being treated as a non-cited violation.

S8 Miscellaneous Security issues S8.1 Certificatee Security Reoorts (90712)

The certificatee made the following security-related one hour reports pursuant to 10 CFR 95 during the inspection period. The inspectors reviewed any immediate security concems associated with the report at the time of the initial verbal notification.

Date Title 9/24/98 Uncleared Subcontractor Drove Bus in Controlled Access Area without Security Escort.

10/6/98 Classified Repository Left Open and Unattended for Ten Minutns.

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V. Manaaemen:Meetina X.  : Exit Meeting Summary

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' The inspectors presented the inspection results to members of the plant staff and management p ' at the conclusion of the inspection on October 14. The plant staff acknowledged the findings l presented. The inspectors asked the plant staff whether any materials examined during the l . inspection should be considered proprietary. No proprietary information was identified.

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4 PARTIAL LIST OF PERSONS CONTACTED Lockheed Martin Utility Services

• M. 'A. Buckner, Operations Manager .

• L. L. Jackson, Nuclear Regulatory Affairs Manager

• S. R; Penrod, Enrichment Plant Manager '

• H. Pulley, General Manager ,

- United States Deoartment of Enerav G. A. Bazzell, Site Safety Representative United States Enrichment Corooration

'J. H. Miller, Vice President - Production J. A. Labarraque, Safety, Safeguards and Quality Manager U.S. Nuclear Reaulatory Commission l

• K. G. O'Prien, Senior Resident inspector

• J.~ M. Jacobson, Resident inspector

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• Denotes those present at the exit meeting held on October 14 1998.

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Other members of the plant staff were also contacted during the inspection period. l INSPECTION PROCEDURES USED IP 88100: Plant Operations IP 88102: Surveillance Observations IP 90712: In-office Review of Events _

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ITEMS OPENED, CLOSED, AND DISCUSSED Opened 34913 CER- Failure of autoclave containment function Closed 70-7001/98016-01 NCV Freezer /sublimers placed in improper mode with safety l system declared inoperable l

70-7001/98016-02 NCV Block valves required by TSR to be open found closed 70-7001/98016-03 NCV . Uncleared individual identified within the controlled access j l

area without required security escort E

34811. CER Safety system for cell coolant overpressure relief inoperable when required by TSR 34851 CER CAAS inoperable when required by TSR

! 32215 CER Fire sprinkler system deficiencies 32222- CER- Fire sprinkler system deficiencies 32228 CER Fire sprinkler system deficiencies 32231 CER Fire sprinkler system deficiencies 32238 CER Fire sprinkler system deficiencies l

32252 CER - Fire sprinkler system deficiencies 32268 CER Fire sprinkler system deficiencies ,

32278 CER Fire sprinkler system deficiencies 31972 CER Fire sprinkler system deficiencies 32002 CER Fire sprinkler system deficiencies 32012 CER Fire sprinkler system deficiencies 32026 CER Fire sprinkler system deficiencies ,

L Discussed

. None-i S-18

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l l LIST OF ACRONYMS USED i

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CAA  : Control Access Area ,

,CAAS- Criticality Accident Alarm System  :

CER lCertificatee Event Report '

l CFR iCode of Federal' Regulations 1 DNMS . Division of Nuclear Materials Safety i

DPCS'- ' Digital Process Control System I ISOS- Intemational Safety Organization Standard

.._. LLCO Limiting Condition for Operation l

'W LTO ._ Long Term Order '  !

NCV Non-Cited Violation i NRC. Nuclear Regulatory Commission PDR Public Document Room  :

PGLD Process Gas Leak Detection- )

1 PSS Plant Shift Supervisor i SAR- Safety Analysis Report i TSR Techhical Safety Requirement l

- U F. . Uranium Hexafluoride - -

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