ML20197A777

Insp Rept 70-7001/98-201 on 980209-13.Violations Noted.Major Areas Inspected:Compliance Plan Issue Closure,Plantwide Implementation of NCS Controls,Compliance W/Criticality Safety Commitments & Internal Self Assessment

ML20197A777
Person / Time
Site:	07007001
Issue date:	02/27/1998
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20197A767	List: ML20197A764 ML20197A772 ML20197A777
References
70-7001-98-201, NUDOCS 9803090383
Download: ML20197A777 (17)

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e U.S. NUCLEAR REGULATORY COhihilSSION OFFICE OF NUCLEAR h1ATERIAL SAFETY AND SAFEGUARDS Docket No: 70-7001 Certificate No: GDP-1 Report No: 70-7001/98-201 Certificate lloider: United States Enrichment Corporation Location: Paducah Gaseous Difrusion Plant Paducah, Kentucky Dates: February 9 - 13,1998 Inspectors: Dennis hiorey, Lead Inspector, NRC Headquarters Christopher ' ipp, Inspector, NRC Headquarters Approved By: Philip Ting, Chief, Operations Branch, Division of Fuel Cycle Safety and Safeguards, Nh1SS Enclosure 2 9803050383 900227 PDR ADOCK 07007001 C PDR i.-

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UNITED STATES ENRICHMENT CORPORATION i PADUCA11 GASEOUS DIFFUSION PLANT NRC INSPECTION REPORT 70-7001/98-201 EXECUTIVE

SUMMARY

& cal.liuntcled.

An NRC IIeadgearters team conducted an announced nuclear criticality safety inspecticn of the Paducah Gaseous Diffusion Plant (PGDP) in Paducah, Kentucky, on February 9 - 13,1998. The inspection was conducted using NRC licadquarters staff. The focus of this inspection was to determine the extent of completion of Nuclear Criticality Safety (NCS) related compliance plan

. items. In' addition to reviewing implementation of compliance plan criticality issues, the inspectors took a broad programmatic look at the Paducah NCS program to gain an understanding of the status of criticality safety program implementation and issue resolution.

. As issues were identified during the week, the inspection was expanded to include the following areas:

o Compliance Plan issue Closure i e Plantwide Implementation of NC5 Controls e Compliance with Criticality Safety Commit.nents e Internal Self Assessment e- Qualification of Staff ,

e DOE Material Storage Areas As a result of this inspection, a Level IV violation (VIO) of NRC requirements, a non-cited-violation (NCV), and two inspector followup iten:s (IFIs) were identified. Additionally, the inspectors were unable to determine the closure status of Compliance Plan issues 5 and 6.

- Results e A violation concerning two operating procedures in use with out of date criticality controls was identified. (Section 1.b(4))

e A non-cited violation concerning an unqualified staff member signing Incident Reports as an NCS Engineer was identified. (Section 5.b(1))

e Because of missing information in the evidence packages, the inspectors were unable to conclude that Compliance Plan Issues 5 and 6 were actually complete and closed. (Section f

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• The certificant had not developed a systematic method of assuring flowdown from the NCS Analyses (NCSAs)into procedures. As a result, the certificant could not demonstrate that they had implemented all of the NCSA controls. (Section 1.b(2))

• The inspectors noticed numerous incidents in which fissile material operators had not had the required trainir.g signed ofTor had the training deficiencies recorded. (Section 1.b(3))

• The certificant does not have a clear documented policy defming what tasks qualified, partially qualified or unqualified NCS staff may perform. (Section 5.b(1))

REPORT DETAILS 1.0 CnmplianctElanlssutClasnc

a. Scope ofIrlmestian The inspectors reviewed evidence packages and conducted walkdown inspections to determine whether Complianca "lan Issues 5,6, 7, and 8 were satisfactorily closed. The inspectors examined the c' e package for Compliance Plan Issues 5 and 6 to determine whether there was V accumentary evidence to conclude that all operations with at least 15g U-23( .nrichment of twt % U-235 were covered with applicable NCSAs, that the NC5 % ..ements had been flowed down into procedures and postings, that administrative aspects of the NCS program were incorporated into procedures, and that all aspects of Technical Safety Requirement (TSR) 3.9 had been implemented. The inspectors performed walkdowns of GEN-04 requirements and their associated procedures in Building C-710 to determine the extent ofimplementation of NCSA requirements.

The inspectors reviewed the closure package for Compliance Plan Issue 7 and performed walkdowns in Buildings C-720 and C-728 to determine the current status of this issue.

b. Observations and Findings (1) Compliance Plan Closure packages for NCS Issues l

Compliance Plan issues 7 and 8 concern the placement of criticality alarms and '

annunciators. The inspectors determined, after reviewing documentary evidence and the installed alarm and annunciators, that the Issue 7 had been adequately closed. Compliance Plan issue 8, which concerns criticality alarms in Building C-710, remains open. The compensatory actions for issue 8, which include the placement of portable altrms, were reviewed during the previous NCS inspection,97-208, and their implementation was found to be adequate.

4 Compliance Plan Issues 5 and 6 concern documenting and irnplementing NCSAs. The inspectors examined the closure package for Compliance Plan items 5 and 6 to ensure that all non-compliance. 'iad been corrected The closure package presented to the inspectors covered bol asues in one set of volumes, and consisted of a separate file for each NCSA.

Each file contained the applicable NCSA, the cover sheet of the corresponding NCS Evaluation (NCSE), a record of the Plant Operation Review Committee (PORC) review, a verification checklist of field implementation, the affected operating procedures, training records, and verification of postings. The inspectors also examined the administrative procedures for implementation f the criticality safety program. The inspectors found tFat the following administrative procedures provided the necessary implementation of the criticality safety program:

• CP4-EG-NSI 104 " Nuclear Criticality Safety Response to Emergency, Off-Normal, and Process Upset Ccnditions"

• CP4-EG-NSI 101 " Evaluation of Requests for Nuclear Criticality Safety Approval"

• CP2-EG-NS1030 " Nuclear Criticality Safety Training Requirements"

• CP2-EG-NS1031 " Nuclear Criticality Safety"

• CP4-EG-NSI 107 " Nuclear Criticality Safety Oversight Program"

• CP4-EG-NSI 113 " Nuclear Criticality Safety Incident Trending"

• CP2 EG-EG1031 " Criticality Accident Alarm System"

• CP2-EG-NS1033 " Assay and Exempt Waste Verification"

• CP2-EG-NS1042 "Transnortation of Fissile Material"

• CP2-EG-NS1034 " Sampling Labeling Program" In addition, the inspectors determined that the administrative recuirer.ie'ts of TSR 3.9, regarding the development and approval of operating procedures, was adequately completed.

The inspectors identified numerous apparent discrepancies in the evidence package training records such as incomplete sign-offs for crew briefings and required reading in the closure package for Compliance Plan issues 5 and 6 that had not been resolved. The inspectors also identified several discrepancies in the procedure flowdown portions of the closure packages for Compliance Plan Issues 5 and 6. There was no master list of those

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procedures that require NCSA controls and the certificant cannot confirm the accuracy of the procedure data in the Plant Issues Management System (PIMS) database. Due to these training and flowdown discrepancies, the inspectors could not confirm that Compliance Plan Issues 5 and 6 have been satisfactorily closed. They certificant stated that the evidence packages would be reviewed. The inspecton did not identify substantial evidence that the Compliance Plan issues are not actually closcd.

(2) Implementation of NCS A Limits and Controls The inspectors selected fourteen different NCSAs and traced through the procedures.

training, postings, and field verification to ensure that all criticality limits and controls had been adequately implemented. The inspectors requested a master list of procedures that contained criticality safety requirements from these NCSAs, and the certificant prosided them with a list of emrent procedures from the PIMS database. The inspectors compared this electronic list with the procedures that were grouped under these NCSAs in the evidence package, and determined that there were several cases in which the two sets of procedures did not correspond. Out of the fourteen NCSAs which were sampled, seven had procedures in the PIMS database which were missing from the evidence package.

When the inspectors raised this concern, the cenificant stated that some procedures had changed procedure numbers, and some new procedures had been issued since the evidence package was put together. The certificact investigved the seven discrepancies and found three cases in which NCSA commitment stamps were missing from the procedure or referred to the wrong NCSA, and had been entered into the PIMS database incorrectly.

These three procedures CP4-CU-CH2103, Rev.1, CP4-CU-CH2105, Rev. O, and CP4-CU-CH2106, Rev. O are discussed below, In all other cases, the PIMS requirements represented either new or renumbered procedures.

The certificant did not have any systematic method of assuring or demonstrating flowdown from NCSAs into procedures. The certificant indicated that it could not confirm that the information in the PIMS database was current or represented a complete list of operating procedures that required flowdown from each NCSA, given the observed discrepancies. The certificant stated that it had relied on o, erations managers to identify all affected operating procedures when the NCSAs were originated, and that all procedures thus identified had been placed into the evidence package. Although this method of review produced generally adequate results, the inspectors noted

• hat isolated failures to flowdown NCS requirements have continued to be identified.

(3) Implementation of NCS Training The inspectors examined training records in the evidence packages to confirm that all required training had been completed. The training records consisted of signoffs for required training modules, required readings, and crew briefings, with a training deficiency notice in the package for employees who did not complete the required training. The 6

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training deficiency puts a hold on the employee's involvement in fissile material operations until he has completed the required training. The inspectors noticed numerous incidents in which certain fissile material operators had not had the required training signed ofTor received the necessary training deficiencies. The certificant indicated that it would have to review the original trainirq, records to determine if this was a problem with the documentation of the closure package or ifemployees had not received required criticality safety training. As a result, the certificant identified an instance in which an employee had e not received the necessary training and had not been issued a training deficiency notice, on NCSA GEN-04,"Use ofIIEPA Vacuum Cleaners on Plant-Site " The inspectors could not determine whether the employee had performed vacuum cleaner operations for which he was not qualified, but procedures permitted the operation of vacuum cleaners by unqualified personnel if they were accompanied by a qualified operator. Standard procedure was to have two operators use the equipment, and so there does not appear to have been a safety issue. The certificant immediately issued a training deficiency notice for the affected employee until he could receive the necessary training. Management action to assure that the required operator training has been properly documented will be t.acked as IFI 70-7001/98-201-01.

l (4) Flowdown of NCSA Controls to Procedures As a result of reviewing the training records, the certificant identified three procedures which did not have the necessary NCS control flowdown. Procedures CP4-CU-CH2103,

" Field Decontamination," Rev.1, CP4-CU-CH2105, " Decontamination of Process Equipment Requiring Planned Expeditious Handling (PEH) or Uncomplicated Handling (UH)", Rev. O, and CP4-CU-CH2106, " Disassembly and Decontamination of Contaminated Seals," Rev. O did not contain all required nuclear criticality controls and limits from GEN-04, Request 1869. The certificant determined that the procedures instead contained the criticality controls and limits from the previous revision of GEN-04.

The inspectors examined the two revisions of GEN-04 and determined that there were meiy substantive differences between the two versions. In particular, GEN-04, Request 1869 contains new requirements to utilize physical restraints to enforce the two-foot spacing requirement during vacuum cleaner storage or the simultaneous transportation of more than one vacuum, on opening the vacuum cleaner in certain areas, and special requirements on storage of hoses. Clogged vacuum hoses must be stored in maximum 5.5 gallon waste drums, and hoses are not allowed to be wrapped around the vacuums. The vacuums cleaners are safe volume containers, and thus the main upset conditions are placement of two vacuums within the two-foot spacing limit and increased interaction between the vacuum and a clogged hose. The three procedures listed above (one of the procedures, CP4-CU-CH2106, was on hold) did not contain the requirements on passive restraints and storage of vacuum hoses. In addition, the previous revision of GEN-04 contained a table with two vacuum cleaner models which had been omitted from the current revision. The inspectors determined that the reason the two models were not included in the current revision was that they were no longer being used, rather than an

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underlying criticality reason . The two operating procedures in use without the correct

criticality controls is VIO 70-7001/98 201-02.

1 The inspectors examined the NCSE " Nuclear Criticality Safety Evaluation for the Use of HEPA Vacuum Cleaners at the Paducah Gaseous Diffusion Plant" and interviewed operations personnel to determine whether vacuum cleaner operations were being conducted safely in accordance with nuclear criticality controls. The certificant indicated that the required controls on vacuum cleaner spacing and vacuum hose storage were complied with, because the controls were included in a " reference use" or "in-hand" procedure that was used during all vacuum operations. The in-hand procedure is referenced in CP4-CU-CH2103 and is required to be used in hand during operations. In response to the above violation (VIO 70-7001/98-201-01), two of the affected procedures were put on hold (one procedure, CP4-CU-CH2106, was already on hold), and a problem report was issued. The certificant indicated that it intended to remove the conflicting requirements from the three procedures and instead use the reference procedure to comm neate administrative cor,trols. The safety significance was tuw because there is no evidence that work was performed to the three i Wes, even though the safety basis was degraded by having conflicting procedures. tspectors identified no evidence thst NCS controls had been violated as a result of the conflicting reauirements.

The certificant committed to perform a comprehensive review of all process descriptions against the actual field operations by March 31,1998, and to perform NCS dry runs on all active NCS As that were issued prior to the revision of procedure CP4-EG-NS 1101,

" Evaluation of Requests for Nuclear Criticality Safety Approval" that required a verification checklist. This is expected to provide additional assurance that flowdown has been completed.

(5) Field Verification of Procedures and Postings The inspectors examined the NCSAs covering the C-710 Laboratory Building and toured the various operations in the laboratory to determine whether there was adequate NCS A coverage of all operations and whether criticality controls were adequately implemented.

The inspectors noted that there were 17 different NCS As that applied directly or indirectly to operations within the lab. The various NCS As govern transfer, handling, and storage of various sample containers, waste materials, and standards. The various NCSAs have different requireraents for batch size and storage configuration. The main NCSAs examined during the review and subsequent walkdown were GEN-08, " Transfer, Handling, and Storage of Fissile /Potentially Fissile Samples" and GEN-19, " Handling, Transport, and Storage of UF Sample Tubes." The inspectors toured laboratory operations including sample analysis, sample cleaning, and the radiochemistry lab, and did not observe any spacing or batch size violations or operational problems. The postings in each room referenced the governing NCSA and there was normally only one NCSA covering a given process or area. The laboratory stafTindicated that there had been

8 numerous problem reports issued and t1 NCS had been called to walk down certain operations several times. The system of multiple NCSAs was confusing to laboratory personnel and to the inspectors.

The inspectors observed a sign labeled " Maximum Number of Samples for NCS Batch Limits"in the Sample Management and Radiochemistry Laboratory areas, which was signed by laboratory staff. The sign contained information regarding the number of containers of vadous sizes that could be grouped together and still keep within the cumulative volume limits of NCSAs GEN-08, GEN-19, and 1493-19. The inspectors examined the information on the sign and determined that it was technically correct and provided an additional 20% conservatism factor over the governing NCSA. Laboratory personnel indicated that this was because the containers ollen contained more than the nominal volume by up to 5%. Thus, if the nominal volume of the containers was used to calculate the cumulative volume of the batch, the batch would exceed the criticality limit by a few percent. The sign was designed to prevent the operators from having to compute the volume of a batch each time. Laboratory personnel also indicated that the sign was needed because the postings were too cumbersome and confusing to be used readily during operations.

The safety significance of this finding is low because the NCSA limits were not altered.

The inspectors noted that the practice of reinterpreting confusing or inconvenient criticality postings without the appropriate review could lead to inadvertent violation of criticality limits. The sign had not been reviewed or approved by NCS and thus could have contained inaccurate information or might not have been updated if the NCS A and underlying postings was revised. Immediate corrective action was to remove the sign and write a problem report. The certificant returned the sign to the lab under the control of the operator aid procedure pending placement of the information in a work procedure so the controls will be covered by the change control process. Placement of the additional batch sample information into a work procedure will be tracked as IFI 70-7001/ u 98-201-03.

c. Cnnclusions Because of the complexity of the NCSA structure, deficiencies in the Evidence Packages, and the lack of a master list of procedures that require NCSA, the inspectors were unable to conclude that Compliance Plan Issues 5 and 6 have been satisfactorily completed.

There is a weakness in operator training as evidenced by incomplete sign-offs for crew briefings and required readings in the closur, packages. The system for ensuring that operators receive required training is decentt lized and informal.

The inspectors determined that the complex system ofinterlocking NCSAs in the C-710 laboratory is su;ceptible to operator confusion and error. The inspectors identified

9 the poor work practice of reinterpreting and posting NCSA requirements when operators feel the postings are confusing.

2.0 Elan 1gide_impicmcDiatipp of NCS Controls

a. EcontoUnspsslion The inspectors reviewed the licensee listing of NCSAs and interviewed NCS staff to determine whether all plant areas containing fissile material were covered by appmpriate NCS controls. The inspectors also interviewed NCS staff to determine how the staff had gained assurance that all fissile material operations are entirely covered by NCS controls.

The inspectors reviewed the implementation of criticality safety controls from NCSAs GEN-010, GEN-020, and GEN-027 and performed a walkdown of Building C-331 to insure that the storage oflegacy equipment was in compliance with these NCSAs.

b. Observations _aD_(LEindings PGDP fissile material operations are covered by 118 NCSAs that are divided roughly into three groups: general, operation specific, and facility specific. For example, the general NCS A GEN-03 covers UF, cylinder handling operations, the general NCSA GEN-09 covers Negative Air Machine operations, and NCSA 3973-04 covers Building C-400 Cylinder Washing. For cylinder washing operations, requirements from all three NCSAs must be flowed down to numerous operating procedures. The even more complex example of building C-710 which has NCS controls from 17 different NCSA? was discussed above. The inspectors determined that the certificant did not maintain a consolidated listing of NCSA required controls which could be used to determine that all controls were actually implemented plant-wide for all fissile material operations. Instead, the certificant developed teams consisting of operations and engineering staff to review separate operations and facilities. These teams generally used their own process knowledge to determine that all necessary NCS analysis had been requested, that adequate ,

controls had been developed, and that the controls were in place.

NCSA coverage at PGDP results from a three stage process. The operator of a facility or process involving fissile material requests NCS analysis, and this request becomes Part A of the NCSA which normally includes a process description. The certificant NCS Organization then analyzes the process or facility and develops the controls which are listed and become Part B of the NCSA. Finally, the operator of the facility or process implements the NCS controls by developing procedures, training, postings or whatever may be required. Analysis and calculations are documented in an NCSE which is a separate document. NCSEs are not associated directly with NCSAs but are referenced as required. An NCSE, once written, may be referenced by one or many NCSAs and may eventually form the basis for a wide variety of NCS controls.

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c. Conclusions The NCSA program at PGDP has led to a complex system of overlapping requirements that cannot easily or formally demonstrate that all necessary analyses were performed and that the controls flowed down into the appropriate procedures.- Although the : .spectors observed several failures to flowdown NCS controls as noted above, no unanalyzed situations were identified during the inspection.

The boundary between neighboring NCSAs is not well-defined and may lead to inconsistent limits in neighboring processes due to the practice of having multiple operating procedures covering the same operations, which may involve conflicting NCS requirements.

3.0 Cpfnphange with Critig_ality Safety Commitmertts

a. Sgsng_0Dasacclin The inspectors reviewed certificant actions in response to Confirmatory Action Letter (CAL) CAL-003 to review all NCSAs which rely on administrative controls. The inspectors also reviewed certificant actions performed in support of a June 20,1997, certificant letter committing to perform comprehensive walkdowns of all buildings containing legacy equipment. The inspectors performed a walkdown in Building C-331 to observe compiance of stored iegacy equipment.

b. Ohservations and Findings CAL-003 was issued by Region Ill on February 28,1997, following review of an event at Building C-400 concerning the failure to properly implement a double contingency control b for the cylinder wash operation. The CAL required a complete review of all PGDP NCSAs which rely upon administrative controls and the identification of other scenarios which could have only one contingency or which rely upon controls which can be readily bypassed without management's knowledge. The cenificant stated that this review had been completed. The inspectors requested documentation ofcompletion of this CAL item. The documentation that was provided and reviewed indicated that corrective actions for the event had been completed and closed but did not indicate that a complete review of NCSAs with administrative controls had been completed. The inspectors noted that several cenificant employees stated that they remembered reviewing administrative NCS controls during the indicated timeframe.

By letter on June 20,1997, the certificant committed to perform comprehensive walkdowns of all buildings containing potentially fissile material to establish an accurate inventory oflegacy equipment. The inspectors requested evidence that the walkdowns had occurred as committed. T e package given to the inspectors contained no evidence

11 that the walkdowns had actually occurred other than a one-sentence remerk that the walkdowns were conducted between June 20 and 23,1997. '

The inspectors toured fluilding C-331 with a phnt operator who had participated in the walkdowns. The operator had a listing of all legacy equipment in all facilities. The lists contained hundreds ofitems and each piece oflegacy equipment had a unique identification number. The operator was able to proceed directly to particular pieces of equipment that the inspectors requested to see from the list. The inspectors concluded that the certificant had conducted facility walkdowns and had identified all legacy equipment,

c. Cnnelusions The inspectors determined that the certificant has completed the two commitments relating to programmatic NCS issues. The inspectors determined that, although documentation was lacking, adequate work was performed on these issues.

4.0 IntemnalSsifAssessment

a. S.cspe ofInsp1ction in order to assure that findings were adequately addressed by management and corrected in a manner that was timely and commensurate with risk, the inspectors reviewed the resuis of a certificant conducted internal self assessment of the criticality safety program which was conducted in response to recent events at Portsmouth. The inspectors interviewed management and staff personnel concerning the assessment and performed a walkdown with an NCS Field Operations Assistant (FOA).

b. Observationtand Findings Between December 15 and 31,1997, the certificant performed a management self-assessment of the PGDP NCS program. The assessment was chartered to determine if there were any programmatic NCS issues and to identify possible improvements. The assessment was performed internally by staff at PGDP. The assessment consisted of field obseivations and interviews. Three specific findings were identified:

1. NCS Products are not always written to be understood at the floor level.

2. Lack of clear management expectations, from the site senior management group, has negatively affected the NCS Program.

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3. Lack of resources (personnel, training, knowledge, etc.) dedicated to the NCS Program, in all functional areas, has negatively impacted the understanding in the field of NCS requirements and protocol.

In response to these findings, the certificant took immediate compensatory action consisting of the appointment of eight NCS FOAs. The FOAs have the responsibility to assist workers and front line managers with the understanding of the NCS implications of upcoming or ongoing production work. The eight FOAs were selected from senior operational staff who were determined to have an adequate understanding of NCS principles related to the subject areas and also possess the ability to coach other employees.

The inspectors conducted a walkdown of the cascade facilities with a newly appointed FOA. The FOA was observed to be knowledgeable of NCS requirements. During the walkdown, the FOA was observed to interact with production statTto correct minor deficiencies with NCS postings.

The certificant did not discuss the risk significance of the self-assessment findings except to note that no programmatic breakdown was apparent. The three findings generally correspond with the inspectors views based on this and two previous inspections concerning numerous minor NCS program issues that still require resolution. The inspectors determined that the immediate compensatory measures appeared appropriate and efTective The certificant had not yet developed complete corrective actions for the three findings.

c. Cmiciusions The certificant self-assessment provides a valid overview of the NCS program that coincides with previous inspection findings. The inspectors determined that the immediate corrective actions for the findings appeared adequate to assure safety until long-term corrective actions are developed and implemented.

5.0 Qualif.Eation of Staff

a. Scope ofInsp_cction The inspectors reviewed qualification requirements for NCS Engineers, Senior NCS Engineers, and the NCS Manager. The inspectors compared SAR requirements with their implementation in the licensee Training Development and Administrative Guide (TDAG).

The inspectors reviewed qualification records for all NCS staff at Paducah including contractors. The inspectors reviewed the position description for '.he NCS Manager.

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b. hervations and Findings (1) NCS Engineers and Senior NCS Engineers The certificant NCS Section has ten employees including the NCS Manager, three NCS Engineers, and two Senior NCS Engineers. The certificant also employs eight contractors to perform NCS analysis of whom seven are considered NCS Engineers and one is considered a Senior NCS Engineer.

An NCS Engineer has specific training and qualification requirements defined in SAR Section 5.2.2.3 which are: (1) a baccalaureate in engineering, mathematics or related science (2) familiarization with the facility by completing a minimum of 1 year in the PGDP NCS Section; (3) complete KENO V, a training course;(4) performing a minimum of four evaluations under the direction of a senior NCS engineer; (5) perfoiming walk-through inspections under the guidance of a qualified NCS engineer; (6) receive NCS surveillance team training; (7) attend a nationally recognized criticality safety course; and (8) 1 year of organized training in the physics of nuclear criticality and in associated nuclear safety practices, if the trainee does not have a nuclear engineering or physics background.

The inspectors determined that all employees listed as NCS Engineers or Senior NCS Engineers met the SAR requirements or, in the case of contractor employees, had the -

requirements waived in accordance with SAR Section 5.2.2.3 on the basis of their past NCS experience. Based on resumes and qualification documents, the inspectors did not identify any employee performing NCS work who appeared unqualified. The inspectors noted that some of the NCS staff have had specific requirements waived without documenting the criteria upon which the waiver was based. The certificant has not established a clear policy for waiving NCS qualification requirements.

The inspectors determined that although the process for becoming an NCS Engineer is well defined, the certificant utilizes partially qualified or unqualified NCS staff to perform many NCS tasks. The certificant has not established a clear policy regarding what tasks require qualification. The safety significance of unclear qualification requirements is the possibility that an unqualified employee may be allowed to perform NCS work which is also true of waiving requirements without a clear basis.

The inspectors determined that during January 1998, an NCS Engineer had signed four Incideat Reports without having completed qualification requirements for an NCS Engineer. PGDP procedure CP4-EG-NSI104 requires that Incident Reports be completed by an NCS Engineer. A member of the NCS staff who had not completed the (TDAG) requirements for an NCS Engineer had signed the four Incident Reports without 4 obtaining a co-signature from a qualified engineer. Compensatory action consisted of having a qualified NCS engineer immediately review and sign the reports. The certificant

14 also initiated a problem report. Based on his resume, the NCS Engineer who signed the incident Reports was well trained and experienced so that the safety significance is low.

Low safety significance and immediate and adequate corrective action meet the requirements for exercise of discretion, and therefore, this violation will not be cited.

Allowing an unqualified staff member to sign Incident Reports as an NCS Engineer is identified as NCV 70-7001/98-201-04.

(2) NCS Manager Certificant Position Description ENG.MJD.00ll requires the NCS Manager to have a B.S. degree in science, engineering or an appropriate field, nine years of engineering,  !

includinh our f years of NCS or reactivity controls experience, and six months experience in a uranium processing facility where NCS was practiced.' These requirements effectively mean that the NCS manager need have no specific NCS experience, which is currently the situation at PGDP. The inspectors determined that the new NCS manager did not have any specific NCS experience prior to his appointment the previous month. The certificant stated that the NCS manager is required to have a co-signature from a Senior NCS Engineer when approving NCS actions such as incident Reports. The requirement for a co-signature was informal and was not always followed. For example, in the violation noted above, two of the improperly signed Incident Reports were approved by the current NCS Manager without a co-signature.

c. Conclusions The certificant has not adequately documented the requirements for qualification of NCS Engineers so that determination of which work must be performed by qualified versus unqualified engineers is unclear. Failure to clarify requirements led to the signing ofIncident Reports by an unqualified employee.

The inspectors noted that the requirement for the NCS Manager, who has no previous NCS experience, to obtain a co-signature for certain actions was ir. formal and not always followed.

6.0 DOE Material Storagg Areas

a. Srape ofInspection The inspectors reviewed the DOE Material Storage Areas (DMSAs) and the certificant DMSA program to determine whether there was an adverse impact on NCS. The inspectors observed the DMSAs during a walkdown in Building C-331.

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b. OhsstYalionund Findings There are currently 148 DMSAs at PGDP which are identified with signs and barricades.

Seventeen of these DMSAs are not completely covered by the Criticality Accident Alarm System (CAAS) and have 10 foot buffer zones established. Access to DMSAs is controlled byjoint procedures. Through these joint procedures, equipment can be and is removed from these areas for use at PGDP.

The inspectors observed a DMSA in Building C-331 which contained approximately 15 small convertors from K-25 that were intended for the C-310 facility. The inspectors observed that these convertors were much smaller thad the convertors common to the C-331 facility. The inspectors were informed that this group of convertors was known to have contained material up of to 60% assay and NDA results indicatin3 approximate mass had been performed but the results of the assay were not readily retrievable. The certificant and the DOE Facility Representative stated that an NCSA had been developed for the equipment but the NCSA could not be easily located. The DOE Facility Representative also stated that he believed that the equipment had been cleaned before shipping and that he was not aware of the existence of any large deposits of high enriched ,

material in legacy equipment at PGDP. The inspectors determined that shipping documents concerning legacy equipment shipped to PGDP from K-25 or Portsmouth was not available. The cenificant and DOE have undertaken efforts to assay the equipment to establish the amount of fissile material involved. To date, all legacy equipment from K-25 and Portsmouth that has been assayed or examined internally has been found to be free of deposits. The cenificant states that they are not aware of any conditions in DOE space that threaten safety at PGDP. Equipment that could be observed by the inspectors did not have visible deposits. Although there were credible statements by employees, recorded assay information, and no visible deposits where inspectors were able to see into equipment, the inspectors could not conclude that all of the DMSA equipment had been properly cleaned due to the lack of affirmative documentation.

c. Conclusiom The inspectors determined that all identified NCS issues regarding DMSAs are currently being addressed. Notwithstanding the trend to find that equipment in the deleased areas ,

had been cleaned, the failure to completely characterize the DMSAs remains a concern.

7.0 Exit Meeting An exit meeting was held between NRC Headquarters and Resident Inspector staff and plant management on February 13,1998, and daily throughout the inspection. No classified or proprietary information was discussed.

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16 ITEMS OPENED. CLOSED. OR DISCUSSFR hemtDpened ~

IFI 70-7001/98-201-01 Document completion of required operator training.

VIO 70-7001/98-201-02 Operating procedures in use with out of date criticality controls.

IFI 70-7001/98 201-03 Placement of additional batch sample information into a procedure.

NCV 70-7001/98-201-04. Unqualified stafimember signing incident Reports as ai. NCS Engineer.

PARTIAL LIST OF PERSONS CONTACTFD lackhsed-Manin Utility Servic_es Steve Polston, General Manager Larry Jackson, Nuclear Regulatory Affairs D.C. Stadler, Nuclear Regulatory Affairs Carol Baltimore, Training- '

Ed Paine, NCS Manager Vince Risner, Senior NCS Engineer Tracey lienson, NCS Engineer Jeff Fletcher, Chemical Operations  :

Steve Penrod, Operations -

lioward Pulley, Enrichment -

IlSDDli Greg Bazzell, DOE Paducah Field Office MILC John Jacobson, Resident Inspector Priya Patel, NRC Headquarters Project Mans.ger u

17 ACRONYMS UEF,D CAL Confirmatory Action Letter DMSA DOE Material Storage Area FOA Field Operating Assistant ilEPA . liigh Efliciency Particulate Air IFl Inspector Followup Item KENO Name of a Computer Code (not an acronym)

NCS Nuclear Crit icality Safety NCSA Nuclear Criticality Safety Approval NCSE Nuclear Criticality Safety Evaluation NDA Non Destructive Analysis PEH Planned Expeditious Handling PGDP Paducah Gaseous Diffusion Plant PIMS - - Procedures Information Management System PORC Plant Operations Review Committee SAR Safety Analysis Report TDAG Training Development and Administrative Guide l VIO Violation i Ull Uncomplicated llandling

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