ML20198H889

Insp Rept 70-7001/98-17 on 981015-1130.Violations Noted. Major Areas Inspected:Plant Operations,Maint & Surveillance, Engineering & Plant Support

ML20198H889
Person / Time
Site:	07007001
Issue date:	12/21/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20198H878	List: ML20198H873 ML20198H889
References
70-7001-98-17, NUDOCS 9812300049
Download: ML20198H889 (18)

Text

. _ . . . _ _ . . - . - - - - . _ .- . . - . . - _ - . .

l U.S. NUCLEAR REGULATORY COMMISSION REGION 111

)

Docket No: 70-7001 ,

I Certificate No: GDP-1 l

Report No: 70-7001/98017(DNMS) i Facility Operato.: United States Enrichment Corporation Facility: Paducah Gaseous Diffusion Plant Location: 5600 Hobbs Road P.O. Box 1410 Paducah, KY 42001 Dates: October 15 through November 30,1998 inspectors: K. G. O'Brien, Senior Resident inspector J. M. Jacobson, Resident inspector Approved By: Kenneth G. O'Brien, Acting Chief Fuel Cycle Branch

( Division of Nuclear Materials Safety l

l l

i 1

C

l 1

l 1

l EXECUTIVE

SUMMARY

United States Enrichment Corporation  ;

Paducah Gaseous Diffusion Plant '

NRC Inspection Report 70-1001/98017(DNMS)

Plant Operations

. The inspectors concluded that an apparent violation occurred on October 17,1998, when the Number 1 Normetex Pump in Building C-315 (Tails Withdrawal) tripped while running onstream following an inadvertent closure of the discharge block valve due to a failed solenoid valve on the air supply line. Following the event, the plant staff determined that the safety system design and the compensatory actions developed in response to a similar event on August 26,1998, were inadequate to ensure that the safety limit would not be exceeded for the design basis accident. As a result, the Normetex pump high discharge pressure safety systems were declared inoperable and the pumps placed in standby. Pursuant to a request from the certificatee, the NRC issued a Notice of Enforcement Discretion permitting continued Normetex pump operations while the NRC processed a Technical Safety Requirement change to remove the Safety Limit and associated Technical Safety Requirement. (Section 01.1)

- The implementation of planned corrective actions was not rigorous for two events in the spring of 1998 which indicated a potential problem with the robustness of the design of the cylinder valve closure system (part of the uranium hexafluoride release detection and isolation safety system for tails withdrawal). The failure of the closure mechanism when called upon cn November 1 resulted in a re-prioritization of the planned design modification as well as the development of additional preventive maintenance tasks for the valve closure systems onsite. (Section O1.2) .

. The response by plant staff to the identification of a loss of fluorinating environment for a piece of equipment containing a deposit of uranium greater than safe mass did not appear to be as prompt or coordinated as the condition warranted. As a result, the plant staff almost exceeded the 8-hour time clock for restoring the fluorinating environment.

However, plant staff subsequently remediated the deposit to below the safe mass quantity, thus removing the potential for the problem to recur. (Section 01.3)

. A non-cited violation of a nuclear criticality safety approval resulted when an in-hand procedure controlling the valving operations for freezer / sublimer R-114 system evacuation was improperly implemented. As a result of the self-assessment finding, and other valving errors resulting in significant plant transients made in the recent past, the plant staff were ir.1plementing independent verifications for those valving operations considered to be at high risk of error, while examining a general revision to the site-wide procedure controlling valve operations. (Section 01.4)

Maintenance and Surveillance

. An incident involving the initiation of work on a pressurized sprinkler system in Building C-331 whict', although it did not actually affect the functionality of the system, had a significant potential to make the system inoperable or injure the personnel involved. The incident appeared to result from an error on a sprinkler system drawing wh:ch led the plant staff involved to associate the inspector test valve to ba reloca!ed 2 .

9 l

with the wrong system during the work package development process. However, the incident also appeared to involve a lack of a questioning attitude by the individuals involved with placing the wrong system on permit and not ensuring positive identification of the affected sprinkler system before performing the work. (Section M1.1)

Enaineerina . l

=

The work performed since March 1997 (the date NRC assumed regulatory authority for certificatee operations) by a contractor that had not been placed on the approved suppliers list did not involve quality systems covered by the Quality Assurance Program.

(Section E1.1)

Plant Suooort The plant staff conducted an emergency management exercise which provided training for emergency responders and members of the crisis management team. The exercise was challenging and the response was conducted in accordance with the Emergency Plan and associated implementing procedures. (Section P1.1)

]

.- A non-cited violation resulted when plant staff identified classified documents in an  !

unmarked folder that were placed in the plant mail by a Department of Energy )

contractor and not controlled in accordance with 10 CFR 95 or the Classified Matter 1 Security Plan. The documents were immediately secured and an agreement  !

established that documents to be mailed as a result of a large-scale declassification review by the involved contractor would be reviewed by the certificatee security staff  ;

first. (Section S1.1)

. A non-cited violation of the Classified Matter Security Plan resulted when a security I guard tranrferred back into the Police Operations staff without possessing a "Q" clearance. I he plant security staff conducted a review of the qualifications for the entire i Police Operations staff and did not identify any other individuals with qualification deficiencies. (Section S1.2)

I t

.l l

l l

L i'

l 4

3 i

p i

l

_ _, ,_- 1

1 9

Report Detailt 1

1. Oowations 01 ~ Conduct of Operations O1.1 Normetex Pumo Pressure Transiefj i

a. Inspection Scope (88100) l The inspectors reviewed the circumstances surrounding a Normetex Pump trip on October 17,1998, that resulted in a pressure transient that exceeded the pump '

discharge bellows safety limit. )

. b. Qhgrvations and Findinas On October 17,1998, at 5:30 p.m. (CT), the Number 1 Normetex Pump in .

Building C-315 tripped while running in Mode 2 (Withdrawal). An operator, present in the area control room (ACR) at the time of the trip, noted that the resultant pressure transient, as displayed on an ACR computer display screen, reached approximately 50 pounds per square inch absolute (psia). The 50 psia peak pressure exceeded the ,

Technical Safety Requirement (TSR) 2.3.2.1 safety limit maximum pressure of 45 psia i for the discharge bellows. The transient lastad less than 10 seconds. At approximately 4 7:12 p.m., the Plant Shift Superintendent (PSS) instructed the Cascade Coordinator to  !

cease withdrawal operations (remove the pumps from Mode 2, and place the plant on recycle. At 9:05 p.m., the PSS declared the Number i Normetex Pump High Discharge Pressure System (HDPS) inoperable. The plant staff also made a voluntary notification of the event to the NRC on October 18 and submitted a written report on November 16 (Event No. 34926).

During an investigation of the incident, tha plant engineering staff determined that the oump discharge block valve inadvertently closed while the pump was operating onstream due to a failed solenoid valve in the air supply line for the block valve. The failed solenoid valve was one of three solenoid valves in series on the air supply line and was classified as non-safety. The block discharge valve was an air-to-open valve so the i j' closure of the solenoid valve upon failure caused the block discharge valve to close as designed. The mode of block discharge valve closure for this event was different from previous events in that the closure time was slower and the pressure transient in the pump was longer. As e result, the engineering analysis used to develop compensatory actions in response to a previous Normetex safety limit violation (see NRC Inspection Report 70-7001/98013(DNMS)) were not effective in maintaining the pump discharge pressure below 45 psia. The plant staff concluded that there were no compensatory actions available which would ensure that all pressure traasients resulting from an inadvertent discharge block valve closure would be maintained below the safety limit.

On October 18, the certificatee requested enforcement discretion to retum the Normetex withdrawal pumps to service even though the HDPS was inoperable (could not ensure the safety limit would not be exceeded) and TSR 2.3.2.1 could not be met in all cases.

The NRC verbally granted the enforcement discretion on October 18 and issued Notice

of Enforcement Discretion (NOED) Number GDP-2 on October 20. The enforcement i

discretion was granted until the NRC issued an amendment to remove the safety limit i

4

and associated TSR for the HDPS from the certificate as requested by the certificatee.

As documented in Inspection Report 70-7001/98013(DNMS), the amendment request was based nn an analysis demonstrating that the consequences from the accident scenario described in the Safety Analysis Report (SAR) for a Normetex discharge block valve closure and subsequent discharge line rupture did not meet the 10 CFR 76 threshold for accidents requiring a safety limit. Furthermore, as indicated in the certificatee's request for Enforcement Discretion and the NOED issued by the NRC, the release from a postulated rupture of the Normetex discharge bellows due to exceeding the TSR 2.3.2.1 safety limit was limited to the uranium hexafluoride (UF.) release detection system for the Normetex pumps, an additional TSR-required safety system.

The inspectors noted some problems with the immediate response to the event on the part of the plant staff. In particular, the decision to place the other Normetex pumps in i standby and to declare the HDPS inoperable was not timely (over 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from the initial pump trip) based on what appeared to be a clear indication that the safety limit had been exceeded, in addition, the compensatory actions to limit the suction and discharge pressures, implemented after the last event and NOED, were clearly not effective in maintaining the pressure transient below 45 psia. The inspectors also noted that the information recorded in the Building C-315 operators' log and gathered from the j involved operators prior to their leaving the site was sparse and hampered tho l development of a detailed event time line based on the operators' observations and I responses.

TSR 2.3.2.1 specified that the Normetex withdrawal pump discharge bellows pressure j shall not exceed the safety limit of 45 psia for all modes. The rise in discharge bellows pressure for the Number 1 Normetex Pump in Building C-315 to approximately 50 psia, as the pump transitioned from Mode 2 (Withdrawal) to Mode 3 (Standby) upon closure of the discharge block valve on October 17,1998, is an Apparent Violation (eel 70-7001/98017-01).

c. Conplusions The inspectors concluded that an apparent violation occurred on October 17,1998, when the Number 1 Normetex Pump in Building C-315 (Tails Withdrawal) tripped while l running onstream following an inadvertent closure of the discharge block valve due to a  !

failed solenoid valve on the air supply line. Following the event, the plant staff determined that the safety system design and the compensatory actions developed in response to a similar event en August 26,1998, were inader." ate to ensure that the safety limit would not be exceeded for the design basis accident. As a result, the Normetex pump high discharge pressure safety systems were declared inoperable and the pumps placed in standby. Pursuant to a request from the certificatee, the NRC issued an NOED permitting continued Normetex pump operations while the NRC processed a TSR change to remove the safety limit and associated TSR.

01.2 Buildba C-315 Valve Closure Linkaae Failure

a. Inspection Scope (88100)

The inspectors reviewed the circumstances surrounding a failure of the cylinder valve closure arm for Withdrawal Position 3 in Building C-315.

5

L -  ;

l l

l l

b. Observations and Findinas l'

On November 1, while using the cylinder valve closure system (part of the UF release detection and isolation safety system for tails withdrawal) to close a cylinder valve after the cylinder completed the fill cycle, Building C-315 operators observed that the closure arm became disconnected due to a loose setscrew. At the time of disconnect, the cylinder valve was approximately two turns from fully closed. Upon discovery, the l position was declared inoperable by the PSS and the event reported as a safety system l failure to the NRC in accordance with SAR reporting requirements (Event No. 34978).

l As a result of the event, plant staff performed a walkdown of the other valve closure i systems onsite. The walkdown identified some problems with a broken pin in a l universal joint on Position 4 in Building C-310 and some loose screw engagements in the feed facilities (where the valve closure systemc are non-safety systems). All systems were still functional, but the discrepancies noted were similar to problems identified previously. In particular, two events occurred in the spring of 1998, in which -

the valve closure shaft came apart during cylinder connection and fell off the air motor drive during cylinder valve closure. The failures occurred while the withdrawal positionc were in a mode for which the closer systems were not required. The events resulted in > ]

a recommendation to replace the setscrew and develop a long-term modi'ication to the closer assembly. However, there were no interim compensatory actions or preventive maintenance recommendations to ensure the closer setscrews remained tight to prevent  !

a recurrence while the modification went through the approval process. I 1

The Engineering Service Order (ESO) developed to modify tho system design did not i receive a high priority and had not been implemented at the time of the latest event. As a result, the corrective actions taken in response to the events'in the Spring of 1998 were not effective in preventing a similar event in November. After the latest event, l

plant staff increased the priority of the ESO (ESO No. 2A0340, dated April 24,1998) to Priority 1. Although the two previous events did not meet the certificatee's thn shold for a condition adverse to quality (three similar equipment failures in one calendar quarter),

the implementation of the planned corrective actions for these events did not appear rigorous based on the potential to adversely affect a safety system.

f

The 30-day written report to the NRC dated November 30,1998, identified a less than l adequate design of the valve closure linkage as the root cause and ineffective corrective l action for previous events as a contributing cause for the event. The report also identified corrective actions which included new quarterly preventive maintenance tasks to check mounting bolts, setscrews, the drive key on the motor output shaft, and universal joint position, movement, and lubrication. In addition, the plan's;aff committed to completing the new design and installation of the emergency cylinder wve closer system by March 1,1999. The report also committed the certificatee to cauing formal guidance on project prioritization criteria to ensure that nuclear safety projects receive i appropriate priority. The inspectors will continue to track the implementation of the  !

planned corrective actions as followup to the event report.  !

l

c. Conclusions The implementation of planned corrective actions was not rigorous for two events in the i j Spring of 1998 which indicated a potential problem with the robustness of the design of

the cylinder valve closure system (part of the UF release detection and isolation safety i

6 ,

i 1 -

system for tails withdrawal). The failure of the closure mechanism when called upon on November 1 resulted in a re-prioritization of the planned design modification as well as the development of additional preventive maintenance tasks for the valve closure systems onsite.

01.3 Loss of Fluorinatina Environment for Purae and Evacuation Pumo

a. Insoection Scope (88100) i i

The inspectors reviewed the circumstances surrounding the loss of the fluorinating environment for a deposit of greater than safe mass in the gas cooler for the Building C-335 Number 2 Dual Speed Purge and Evacuation Pump.

b. Observations and Findinas On November 6, a weekly sample pulled for the Number 2 Dual Speed Purge and Evacuation Pump in Building C-335 at 1:00 p.m. (CT), indicated that the concentration of UF. in the system had dropped below the level required to maintain a fluorinating environment. At the time, the gas cooler associated with the pump had been identified  ;

as containing a planned expeditious handling (PEH) deposit requiring that a fiuorinating  !

environment be maintained in accordance with TSR 2.4.4.4 Action Statements. The TSR required that the fluorinating environment be re-established or a dry gas blanket established within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of the identification of the loss of the fluorinating environment.

1 Building C-335 operators attempted to restore the fluorinating environment by adding a small amount of UF to the system. However, the attempt was not successful because ]

not enough material was added. A followup sample to check the condition of the system I was not taken until about 6:00 p.m. The results of the sample, which were not available until the day shift had left, indicated that the fluorinating environment had not been re-established. The night shift operators recognized that the 8-hour window to restore the fluorinating environment was running out and added a larger amount of UF to the system. This action re-established the fluorinating environment at about 8:55 p.m., well over 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> after the initial sampling.

Although the operators were successful in restoring the fluorinating environment within the 8-hour window, some problems were noted wit:1 the response to the condition. The day shift operators did not appear to be responsive to the initial identification of a i problem and the time clock established by the Limiting Condition for Operation (LCO) l Action Statement. In addition, the communications between the operators and sampling personnel did not appear to be efficient in communicating the priority for ensuring a re-sample and analysis were promptly performed to ensure the UF. added to the system i was sufficient to restore a fluorinating environment. The inspectors did note, however, that, subsequent to the incident, the plant operations staff were successful in reducing the deposit below the PEH (safe mass) level and exiting the LCC Action Statements by the end of the inspection period, thereby reducing the chance for further problems with loss of a fluonnating environment.

c. Conclusions i The response by plant staff to the identification of a loss of fluorinating environment for a piece of equipment containing a deposit of uranium greater than safe mass did not 7

appear to be as prompt or coordinated as the condition warranted. As a result, the plant staff almost exceeded the 8-hour time clock for restoring the fluorinating environment.

t However, plant staff subsequently remediated the deposit to below the safe mass

. quantity, thus removing the potential for the problem to recur.

01.4 Suildina C-337 Freezer / Sublimer Coolina Water not Drained a .' Insoection Scope (88100)

The inspectors reviewed the circumstances surrounding a report of the loss of a nuclear criticality safety (NCS) control for a freezer / sublimer (F/S) associated with Unit 5, Cell 9 in Building C-337.

b. Observations and Findinas ,

On November 19, plant staff performing a self-assessment surveillance identified that the F/S unit for Unit 5, Cell 9 in Building C-337 did not have the recirculating cooling water (RCW) drained from the F/S unit when the freon (R-114) system had been evacuated. Nuclear Criticality Safety Approval (NCSA) CAS.001.00 required that the R114-to-RCW pressure differential be maintained at least 2.0 psia or that the RCW system be iso!ated, drained, and tagged out-of-service from the associated I condenser /reboiler with the drain valve tagged open. The failure to open the condenser /reboiler drain valve when the R-114 system was evacuated in July 1998 led l to a condition in which the R-114 pressure was below the RCW pressure with RCW still in the system. The plaat staff immediately pressurized the R-114 system to greater than the RCW pressure (atmospheric) to restore the F/S system to the NCSA requirements and reported the loss of an NCS control in accordance with NRC Bulletin 91-01 (Event No. 35065).

1 The plant staff performed a surveillance of other F/Ss with enriched material onsite and l did not identify any others which were in noncompliance with the NCSA. The plant staff performed an investigation of the incident and identified that the event appeared to be the result of the improper impiementation of an in-hand procedure for performing the 1 R-114 system evacuation. The inspectors noted that there were other incidents during the reporting period which rair,ed a more generic concem with the positive control of  ;

valving and valve position knowledge in the plant. These incidents included an emergency response to a minor release from a feed header in Building C-333 which was potentially delayed because one of the header valves thought to be closed was open; a misvalving.of the dry air system which led to a significant slug of light gases to the cascade and necessitated a subsequent cascade split; a misvalving during a lineup of the Building C-331 wet air pumps which admitted a large amount of air from a cell to the cascade; and a valving error during troubleshooting activities in Building C-310 which caused an assay mixing loss in the building. While none of the incidents resulted o a significant safety issue, the incidents did involve significant plant transients and couk be precursors of a potentially more significant event. The plant staff acknowledged ue valving problems as a generic issue and indicated the associated events were being addressed in the corrective action process as a significant condition adverse to quality.

To address the NCSA violation, the plant staff developed a number of corrective actions.

These included checking all the F/S systems in cascade areas operating with enriched 8

.. . - - - - - - - - . - . . - . . _ - . - . - . - - . . . - - . . ~ . - . - . - . . . . . _ -

F

- uranium for compliance with the NCSA; draining the RCW systems fer fissile F/S systems out of service or tagging the R-114 system to ensure the system was not evacuated with the RCW not drained; and revising the in-hand procedure used to evacuate the R-114 system to include a requirement that the required valve manipulations be independently verified before the R-114 system could be evacuated.

l- addition, to address the generic issue of valve control, the plant staff were developing a lessons leamed module to provide training on the recent events to plant operations personnel. In addition, the plant staff were reviewing operations procedures to determine which specific valving operations should be independently verified while the general plant procedure controlling valve manipulations was evaluated for revision. As a result of the prompt followup by plant staff, this nonrepetitive, certificatee-identified and corrected violation is being treated as a Non-Cited Violation (NCV 70-7001/98017-02),

consistent with Section Vll.B.1 of the NRC Enforcement Policy.

c. Conclusions A non-cited NCSA violation resulted when an in-hand procedure controlling the valving -

operations for F/S R-114 system evacuation was improperly implemented. As a result i of the self-assessment finding, and other valving errors resulting in significant plant transients made in the recent past, the plant staff were implementing independent .

verifications for those valving operations considered to be at high risk of error, while examining a general revision to the site-wide procedure controlling valve operations.

08 Miscellaneous Operations issues 08.1 Certificatee Event Reoorts (90712)

The certificatee made the following operations-related event repcrts during the inspection period. The inspectors reviewed any immediate safety concerns indicated at the time of the initial verbal notification. In the case of retracted notifications, the inspectors reviewed the basis for the certificatee's retraction of the notification at the time of the retraction. The inspectors will evaluate the associated written report for each of the events following submittal.

Number Status Bla 34913 Open Steam leak from the head-to-shell locking ring on Autoclave 2 North in Building C-333A.

34926 Open Exceedance of the safety limit for the pump discharge pressure for the Number 1 Normetex Withdrawal Pump in Building C-315.

34953 Open Safety system actuation of the steam pressure control system for Autoclave 4 South in Building C-333A upon high steam pressure.

34978 Open Failure of the cylinder valve closure mechanism for Position Number 3 in the Building C-315 Withdrawal facility.

9

i. .

l

! Number Status Title f

35060 Open Loss of power to the Building C-310 criticality accident ,

alarm system beacons. I l 08.2 Bulletin 91-01 Reports (97012) l The certificatee made the following reports pursuant to Bulletin 91-01 during the l inspection period. The inspectors reviewed any immediate NCS concerns associN l 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 Date litle i

l 35065 11/20/98 Loss of single control for the Unit 5 Cell 9 F/S RCW l system. j 08.3 (Closed) Certificatee Event Report 34918: Incoming radiological survey of metal melt I box identified contamination levels on the external package surface slightly exceeding Department of Transportation limits. The certificatee promptly notified the shipper and carrier of the issue in accordance with 10 CFR 20. This event report is closed.

i 08.4 (Closed) Certificatee Event Report 35017: Notification of an asbestos spill due to siding l blown off the C-635 Cooling Tower during a severe thunderstorm. The certificatee immediately quarantined the area and completed clean-up of the debris in a timely j fashion. The certificatee notified the Environmental Protection Agency and provided a l courtesy notification to the NRC. This event report is closed.

l II. Maintenance and Surveillance M1 Conduct of Maintenance M1.1 Cut into Wrona Hiah Pressure Fire Water System l

i a. Insoection Scope (68103)

The inspectors reviewed the circumstances surrounding an incident in which work was initiated to relocate an inspector test valve (ITV) on a high pressure fire water system (HPPNS) which had not been removed from service or placed on permit for work.

l b. Observations and Findinas l On November 22, rnaintenance staff were attempting to relocate an ITV at Column A-21 in Building C-331 in order to remove an interference for seismic project workin the area.

The ITV, located at the end of the sprinkler system piping, was used during periodic flow tests of the high pressure sprinkler system to demonstrate the operability of the system per TSR 2.4.4.5. When the maintenance staff began to make a cut into the pipe as directed in the associated wd package, water began to leak out of the cut indicating the system was still unaer pressure. The maintenance staff immediately stopped work and notified Fire Services personnel and the PSS. The response identified that the ITV 4

10

at Column A-21 belonged to System 18 and not System 22 as indicated in the approved work package and on the lockout-tagout (LOTO) permit prepared to suppcrt the work.

Upon identification of the error, the PSS declared System 18 inoperable and Fire Services personnel drained the system to stop the leak. The size and location of the cut, because the problem was identified immediately, did not affect the sprinkler system pressure, and thus did not affect the actual functionality of the system. However, the event appeared to involve a significant potential to not only impact the system's capability to perform the design function, but could also result in injury to personnel since the line was pressurized. The maintenance staff repaired the cut and performed appropriate post-maintenance flow testing to return the system to service by the end of the next shift. ,

Following the event, the plant staff initiated an investigation to determine the cause of the identification of the wrong system by the work control and permitting systems. The initial results indicated that during the development of the design review for the ITV '

refocation, the drawing uscd to develop the package (C331 SP5-7644) identified the ITV at Column A-21 as part of System 22. A second drawing found after the event identified the ITV at Column A-21 as part of System 18. After the initialidentification of System 22 as the affected system, the plant staff followed the work control and LOTO processes without questioning the accuracy of the information on Drawing C331 SP5-7644 which ,

was an as-built drawing in 1959. The inspectors noted. however, that the ITV at the I work location had a tag on it indicating System 18. The work package development process did not include a walkdown of the entire sprinkler system, from the isolating j position-indicating valve exterior to the building to the ITV upstairs on the cell floor, to '

ensure the ITV identified on the System 22 drawing was positively the ITV at Column A-21. The work-planning walkdown of the sprinkler system focused on the immediate job area and relied upon the engineering design to identify the involved l sprinkler system for isolation. The lack of a questioning attitude by the personnel involved created a situation in which the work control process was followed, but indications available to identify the problem before it occurred were either not noticed or not understood.

As of the end of the inspection period, the plant staff had not completed the investigation or developed corrective actions for the incident. The inspectors will track the development of corrective actions for the incident as an Inspector Followup item (IFl 70-7001/98017-03).

c. Conclusions An incident involving the initiation of work on a pressurized sprinkler system in Building C-331 which, although it did not actually affect the functionality of the system, l had a significant potential to make the system inoperable or injure the personnel l involved. The incident appeared to result from an error on a sprinkler system drawing i whic,h led the plant staff involved to associate the inspector test valve to be relocated with the wrong system during the work package development process. However, the incident also appeared to involve a lack of a questioning attitude by the individuals i involved with placing the wrong system on permit and not ensuring positive identification of the affected sprinkler system before performing the work.

1 11

111. Enaineenma E1 Conduct of Engineering E1.1 Control and Oversicht of Construction Contractor )

i

a. Insoection Scope (88100)

The inspectors reviewed construction activities and projects worked by MURTCO for the period from March 1997 (the date NRC assumed regulatory authority for certificatee operations) to the present. The review included discussions with the cognizant project manager and security personnel.

b. Observations and Findinas The inspectors noted that MURTCO had bsen considered by plant quality assurance l staff for placement on the approved suppliers list (ASL), but had not been able to satisfy j all the Quality Assurance Program (QAP) requirements as of the end of the inspection i period. As a result, MURTCO would have been required to perform work on augmented quality (AQ), augmented quality - nuclear criticality safety (AQ-NCS), or quality (Q) systems onsite under the plant QAP or an approved supplier's QAP.

The review indicated that the projects that MURTCO had been contracted to complete as either a contractor or subcontractor had involved only balance-of-plant systems, such as RCW, or facility construction activities, such as the mechanical installation activities in the laboratory annex. None of the projects involved AQ, AQ-NCS, or Q systems. As such, MURTCO would not have been required to be on the ASL for the projets worked as either a contractor or subcontractor,

c. C_onciusions The work performed since March 1997 (the date NRC assumed regulatory authority for certificatee operations) by a contractor which had not been placed on the ASL did not involve quality systems covered by the QAP.

l IV. Plant SuDDolt P1 Conduct of Emergency Preparedness Activities P1.1 Emeraency Manaaement Exercise r

a. Inspection Scope (88100)

The inspectors observed selected aspects of an exercise conducted on November 18 to perform training of key responders in accordance with the site emergency preparedness j (EP) plan and the associated implementing procedures. The inspectors observed the response activitiec in the Emergency Operations Center (EOC) in Building C-300. The inspectors also attended a post-exercise critique held in the EOC.

[ 12

I

b. Observations and Findinos The exercise scenario involved an explosion of a boiler in Building C-600 with a subsequent loss of the control room and multiple injured personnel. The scenario resulted in the shutdown of the other boilers and a loss of steam production for the entire plant.

The inspectors noted that the response to the event was prompt and the EOC was quickly activated and staffed. In addition, a the site-wide accountability process was accomplished in a timely manner and the injured personnel were located and identified.

Communications between the EOC and technical support groups resolved a number of issues associated with the loss of steam. The EOC staff performed a good assessment of the short-term and longer-term impacts on plant operations from the loss of the Building C-600 steam plant and the cutoff of associated power supplies which affected some of the criticality accident alarm systems onsite. The EOC staff also ensured offsite assistance for the injured personnel was obtained. The critique held in the EOC after the exercise was thorough and identified a number of areas for improvement.

c. Conclusions The plant staff conducted an emergency management exercise which provided training for emergency responders and members of the crisis management team. The exercise was challenging and the response was conducted in accordance with the EP and associated implementing procedures.

S1 Conduct of Security and Safeguards Activities S1.1 Control of Classified InfQUDation l

a. Inspection Scope (88100) l The inspectors reviewed the circumstances surrounding the discovery of classified l documents in the plant mail. The event was reported in accordance with 10 CFR 95.57 to the NRC Region ill office.

l b. Observations and Findinas l

On October 29, plant staff discovered classified documents in a unmarked folder in Building C-720 after the documents were delivered from the mail room. At the time of the celivery, the mail room personnel were r.ot aware of the contents of the folder which l l originated from a Department.of Energy (DOE) contractor onsite. As a result, the folder l l and its contents were not protected as classified information. The documents were

carried outside the controlled access area for a brief period during the delivery to Building C-720. Upon discovery, the documents were properly controlled and secured  ;

in a classified repository in accordance with the 10 CFR 95 and the Classified Matter  ;

Security Plan. In addition to notifying the NRC Region lll office, the plant staff also l notified a site representative for DOE of the event.

In a followup investigation, the plant staff identified that the documents were placed in the mail by personnel involved with a large-scale declassification effort underway onsite for DOE. The documents were identified in Building C-720 by personnel possessing i

13

I l

appropriate clearances and there was no indication of a potential compromise resulting j from the event. As part of the corrective actions for the event, plant security staff and a responsible contractor representative developed a memorandum which required that any documents to be mailed as a result of the declassification review be provided to the certificatee security staff to ensure proper control of classified materials was maintained 1 onsite, in addition, the plant staff placed the issue of proper control of classified materials resulting from document reviews or facility decontamination activities on the agenda of the shared-site committee for action to reduce the likelihood of similar events occurring in the future. As a result of the prompt followup by plant staff, this nonrepetitive, certificatee-identified and corrected violation is being treated as a Non-Cited Violation (NCV 70-7001/98017-04), consistent with Section Vll.B.1 of thu NRC Enforcement Policy,

c. - Conclusions

< A non-cited violation resulted when plant staff identified classified documents in an unmarked folder that were placed in the plant mail by a DOE contractor and not ~

controlled in accordance with 10 CFR 95 or the Classified Matter Security Plan. The documents were immediately secured and an agreement established that documents to

' be mailed as a result of a large-scale declassification review by the involved contractor would be reviewed by the certificatee security staff first.

S1.2 Discovery of Security Guard without a Proper Clearance L a insoection Scope (88100) l The inspectors reviewed the circumstances surrounding a report of a member of the i

security forces performing active guard duties who did not possess a "Q" clearance.  !

l - The event was reported in accordance with 10 CFR 95.57 to the NRC Region lli office.

b. Observations and Findinas l L On November 2, the plant security staff identified that a member of the guard staff I~ assigned to Police Operations possessed an "L" instead of a "Q" clearance.

! Section 6.2.1 of the Classified Matter Security Plan required that members of Police Operations possess "O non-sensitive" secur ty clearances due to their potential access

- to information classified as Secret-Restricteo Data. At the time of the discovery, the I security staff indicated that there was no information classified at this level onsite.  !

In a followup investigation, the plant staff identified that the involved security guard had possessed an appropriate 'Q" clearance at some point in the past, but had undergone a

' cnange to an "L" clearance (Confidential-Restricted Data) when the individual L transferred out of Police Operations to another department. When the individual later L transferred back to Police Operations, the change in clearance level was not identified i by the plant staff as part of ensLring that all qualification requirements were met. The l l

l corrective actions taken by plant staff in response to the issue included removing the l guard from police duties until a proper clearance was obtained and checking the

. qualifications of the other members of Police Operations. No additional deficiencies I were identified. As a result of the prompt followup by plant staff, this nonrepetitive,

[ certificatee-identified and corrected violation is being treated as a Non-Cited Violation L

i l 14 r

! l

i

(NCV 70-7001/98017-05), consistent with Section Vll.B.1 of the NRC Enforcement 1 Policy.

c.' Conclusions A non-cited violation resulted when a security guard transferred back into the Police Operations staff without possessing a "Q" clearance. The plant security staff conducted 1 a review of the qualifications for the entire Police Operations staff and did not identify any other individuals w"h qualification deficiencies.  ;

'S8 . Miscellaneous Security issues

' S8.1 Certificatee Security Reports (90712)

The certificatee made the following security-related 1-hour reports pursuant to l 10 CFR 95 during the inspection period. The inspectors reviewed any immediate security concems associated with the reports at the time of the initial verbal notification.

Qain _ Title 10/29/98 Three classified documents unknowingly transported to Building C-720 by plant mail clerk and left uncontrolled in an unmarked folder.

11/2/98 Member of Police Operations discovered to have "L" instead of "Q" clearance.

11/4/98 Creation of classified document on unclassified computer and not reported to NRC in a timely manner. This event is still under review.

11/9/98 Legacy classified material was discovered in laboratory in a cabinet.  ;

Material was properly secured after identification. l 11/9/98 An escort in Building C-331 identified that the escort's security badge had been inadvertently left behind in the escorts' change room.

V. Manaaement Meetinga X1 Exit Meeting Summary The inspectors pasented the inspection results to members of the plant staff and management at the conclusion of the inspection on November 30. The plant staff acknowledged the findings presented. The inspectors asked the plant staff whether any materials examined dring the inspection should be considered proprietary. No proprietary information was identified.

15

,-y , , -

-+2, .. ,-,-i e .--., --- e..r-+ +

i PARTIAL LIST OF PERSONS CONTACTED  !

Lockheed Martin Utility Services

• M. A. Buckner, Operations Manager ,

• L. L. Jackson, Nuclear Regulatory Affairs Manager l

• S. R. Penrod, Enrichment Plant Manager I

• H. Pulley, General Manager United States Department of Enerav i

G. A. Bazzell, Site Safety Representative l l

United States Enrichment Corooration I i

• J. A. Labarraque, Safety, Safeguards and Quality Manager  !

J. H. Miller, Vice President - Production l

U.S. Nuclear Reaulatory Commission

• J. M. Jacobson, Resident inspector K. G. O'Brien, Senior Resident inspector

• Denotes those present at the November 30,1998 exit meeting.

1 Other members of the plant staff were also contacted during ti,e inspection period. I 1

INSPECTION PROCEDURES USED IP 88100: Plant Operations IP 88103: Maintenance Ot,servations IP 90712: In-office Review of Events 16

ITEMS OPENED, CLOSED, AND DISCUSSED Opened 70-7001/98017-01 eel Building C-315 Number 1 Normetex Pump safety limit exceeded following inadvertent closure of the discharge block valve.

70-7001/98017-03 IFl Identification of incorrect high pressure fire water sprinkler system to be remcVed from service for relocating inspector test valve during the work planning process.

34913 CER Steam leak from the head-to-shelllocking ring on Autoclave 2 North in Building C-333A.

34926 CER Building C-315 Number 1 Normetex Pump safety limit exceeded following inadvertent closure of the discharge block va!ve.

34953 CER Safety system actuation of autoclave steam pressure control system in Building C-339A.

34978 CER Failure of the cylinder valve closure mechanism for Position 3 in Building C-315.

35060 CER Loss of power to the criticality accident alarm system beacons for Building C-310.

Closed 70-7001/98017-02 NCV Failure to drain recirculating cooling water system for potentially fissile freezer / sublimer when R-114 system was evacuated.

70-7001/98017-04 NCV Failure to properly control classified documents placed in plant mail.

1 70-7001/98017-05 NCV Member of Police Operations discovered not to possess a "Q" l l

clearance as required by the Classified Matter Security Plan.

34918 CER Survey of incoming metal melt box idantified surface contamination above Department of Transportation limits.

i 35107 CER Courtesy notification of asbestos spill when siding was blown of l cooling tower during severe thunderstorm.

Discussed None i

17

o

..9.

LIST OF ACRONYMS USED ACR Area Control Room AQ Augmented Quality AQ-NCS Augmented Quality - Nuclear Criticality Safety ASL ' Approved Suppliers List CER. Certificatee Event Report CFR Code of Federal Regulations DNMS Division of Nuclear Materials Safety DOE Department of Energy EOC Emergency Operations Center EP Emergency Preparedness ESO Emergency Service Order F/S. Freezer / Sublimer HDPS- High Discharge Pressure System HPFWS High Pressure Fire Water System

'IFl Inspector Followup item ITV inspector Test Valve

). LCO Limiting Condition for Operation -

i

~LOTO Lockout-Tagout NCS Nuclear Criticality Safety NC.SA Nuclear Criticality Safety Approval NCV Non-Cited Violation i NOED Notice of Enforcement Discretion j NRC Nuclear Regulatory Commission PDR Public Document Room PEH Planned Expeditious Handling PSIA Pounds Per Square Inch Absolute PSS Plant Shift Supervisor Q: Quality QAP Quality Assurance Plan RCW Recirculating Cooling Water

'SAR- Safety Analysis Report 1 TSR .Tecnnical Safety Requirement UF, Uranium Hexafluoride URI Unresolved item USEC . United States Enrichment Corporation VIO. Violation t

18

_