ML20199J509

Insp Rept 70-7002/97-10 on 970922-1102.Violations Noted. Major Areas Inspected:Plant Operations,Maint & Engineering

ML20199J509
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant
Issue date:	11/24/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20199J483	List: ML20199J478 ML20199J494 ML20199J509
References
70-7002-97-10, NUDOCS 9711280156
Download: ML20199J509 (19)

Text

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t U.S. NUCLEAR REGULATORY COMMISSION j

REGION lli

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Docket No:

70 7002 Certificate No:

GDP 2 1

Report No:

70 7002/97010(DNMS)

Applicant:

United States Enridiment Corporation Facility Name:

Portsmouth Gaseous Diffusion Plant i

Location:

3g10 U.S. Route 23 South P.O. Box 628 Piketon, OH 45661 Dates:

September 22 through November 2,1997 Inspectors:

D. J. Hartland, Senior Resident inspector T. D. Reidinger, Senior Fuel Cycle inspector, Ragion ill C. R. Cox, Senior Licensing Engineer, NMSS K. G. O'Brien, Senior Resident inspector, PGDP J. F. Schapker, Senior Mechanical Engh)eer Region lli Approved By:

Patrick L. Hiland, Chief Fuel Cycle Branch t

9_11290 971124 7

POR A

K 07007002

--C PDR

L EXECUTIVE

SUMMARY

United States Enrichment Corporation Portsmouth Gaseous Diffusion Plant NRC Inspection Report 70-7002/g7010(DNMS)

This inspection report includes aspects of plant operations, maintenance, engineering, and plant support. The report covers a six week period of routine resident and regionalinspecGons.

Plant Operations in the response to high condensate safety actuations at the X-343 Building, the e

certificates took appropriate action to immediately declare the autoclaves inoperable until a root cause could be determined and actions taken to prevent recurrence. However, in the case of a high autoclave pressure shutdown, the inspectors noted that the certificatee made a non-conservative decision to place the autoclave back in service, potentially challenging a safety system. One violation was identified. (Section 01.1)

Operators displayed a lack of attention to detail and questioning attitude in not maintaining Nuclear Criticality Safety Approval (NCSA) controls for storage of pigtail gaskets in F-cans at the Low Assay Withdrawal (l.AW) station. This example, as well the reportable events discussed, were indicative of continued problems with the implementation of NCSA requirements in the plant. One violation was identifHpd.

(Section 01.2)

Maintenance and Survelliance Inadequate work instructions, poor design control, and poor communications contributed e

to an inadcquate Post Maintenance Test (PMT) and operation of the Extended Range Product (ERP) crane in non-conformance with the approved design. (Section M1.1)

EnaineEng i

The inspectors concluoed that the certificatee's decision to shut down the autoclaves in response to a non-compliance with a Technical Safety Requirement (TSR) was appropriate and demonstrated conservative decision making. However, a discrenancy between the Safety Analysis Report (SAR) and the TSR demonstrated another example of an incomplete understanding of the facility design basis. One violation was identified.

(Section E1.1)

The inspectors determined that plant staff had used the engineering notice system to make changes to nuclear criticality safety evaluations and approvals. None of the changes reviewed by the inspectors was determined to create an immediate safety issue.

However, the practice bypassed the plant operations review committee (PORC) review and approval, a TSR requirement. One violation was identified. (Section E1.2) 2

Plant Supped Ememency Preparedness The cortscatoe's Emergency Plan and implementing Procedures provided sufflaient e

guidance for respondmg to plant emergencies, and the emergency resV noe organization training was adequate for responding to emergencies. Emergency response personnel were adequately tramed and were kr-r;tf-;;+able of emergency response procedures and equipment. (Section P1.1)

The certificatee maintained an effective tracking syr, tem for deficiencies identified during drills or exercises; proposed actions to correct a minor bacidog of corrective actions for Identified drill or exercise deficiencies were adequate. (Seew n P1.3) l i

Emergency drills were effective in exercising the certif6catee's emergency response

- e organization. (Section P1.3)

I The inspectors identified a violation in that the emergency management staff had not e

conducted Public Waming System (PWS) surveillances per procedure, in addition, the inspectors identified that preconditioning of the PWS was conducted prior to the performance of the monthly PWS surveillance tests. (Section P1.4)

The overall organization and management structure of the Emergency Plan function was e

consistent with the Emergency Plan and implementing Procedures. (Section P1.5)

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Report Details j

L Omarations.

01 Conduct of F-- "--4 01.1 Autoclave.RetumedIo Service.Without_corresdve Actions i

a. Inacection Scope (88100)

The inspectors reviewed the certificatee's response to avh.Jave safety actuations.

b. Observations and Findings On October is autoclave N at the X-343 Cuilding automatically wsnt into

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e oontainment due to a high steam safety actuation. The inspectors reviewed the i

certifketee's respense and idensifi'ed the following conoems:

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After vertfying that a UF6 release did r.ot occur, the operators be Aeved that the cause of the shutdown was a sticking steam regulating talve. The operators were feeding the cylinder to the emaeada at a maxim Ai rate, causing the vaporization rate of the UF6 in the cylinder to inenmee too rapidly. As a result, the temperature of the cylinder dropped below 200F, the point at which the steam regulator switched to a higher steam loading pren sure, but the valve apparently responded slowly to the loading signal.

The certificate ( failed to perform a test of the system to verify this theory or take action to prevent recurrence prior to retuming the autoclave back to service.

The Plant Shift Superintendent (PSS) did not document the justifm' ation for not declaring the autoclave inoperable on the problem report prior to placing the autoclave back in service.

The system engineer was not contacted prior to restarting the autoclave.

When contacted afterwards, the engineer recommended that testing be f

performed during the next shutdown.

During the verbal discussions with the inspectors of the safety actuation, the PSS stated that Technical Safety Requirement (TSR) 2.1.3.5 allowed for putting the autoclave back in service to food the remainder of the cylinder. This interpretation was apparently based on having an inoperable autoclave pressure channel. The inspectors determined that

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this interpretation was flawed because the TSR did not allow for entering

- Topical headings such as 01, M8, etc., are used in accordance with the NRC standardized inspection report outfit.e contained in NRC Manual Chapter 0610. Individual reports are not expected to address all outline topics, i

and the topical headings are thesefore not always sequential.

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i the operational mMe with the inoperable channel. Regardless, the cortincates never declared the pressure channel inoperable; therefore, that justincation did not apply j

in response to the inspec6ers' conoems with regards to retuming the autodeve to service without taking action to prevent recurrence, the operators declared the aukclave inoperable. Testing to determine the root cause of the safety actuation was stid pending

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at the end of the inspection period. Meanwhile, the certencates placed limits on cylinder l

feed rates to the cascade to minimize steam load fluctuations on the other autoclaves.

i Appendix A of Procedure UE2-HR-C11031," Corrective Action Process," listed a l

repoitable regulatory event as being an agamgle of a signincent condition adverse to i

quality. Failure to take action to prevent recurrence of the reportable autoclave safety actuation, a significant condition adverse to quality, is a Violetten of 10CPR76.93, j

" Quality Assurance." (VIO 70-7002/97010 01) 1 On October g autoclave Fs 2 and 4 at the X 343 Bulldog autcrt"; shut down e

within 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of each other due to actuation of the high condensate level safety j

system. In this case, the oestificates took appropriate action to immediately declare the autoclaves inoperable until the root cause could be determined.

Since both autoclaves were heating 14-ton cylir.ders for the Arzt time in several years, the certificatee Wils"ed there was a potential common cause for both actuations. Upon further investigation, the certl6 cates determined that the cause of the actuations was a drop in the infomal autoclave pressure whch caused water to back up into the drain line and activate the condensate level probes. In the smaller autoclaves, the energy from the steam supply was not enough to t

liquefy the 14 ton cylinder and maintam positive pressure in the autoclave. As corrective action, the certificates placed an administrative hold on heating 14-ton cylinders in the smaller autoclaves until modifications were made to correct the design deficierwy.

c. Conclusion

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in response to the two high condensate safety actuations, the certificates took appropriate action to immediately declare the two autoclaves inoperable until a root cause could be determined and actions taken to prevent recurrence. However, in the case of the high autoclave pressure shutdown, the inspectors identified a violation in that the certificatee made a non-conservative decision to place the autoclave back in service, without taking any corrective action.

5 01.2 Nuclear Criticality Safety Anoroved implementation Problems

a. Inspection Scope (88020)

The inspectors toured plant facilities to verify implementation of Nuclear Criticality safety Approval requirements.

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b. Observations and Findinas On October 16 during a routine inspection at the Low Assay Withdrawal (LAW) area, the inspectors noted that holders for F cons used to store pigtau gaskets at two of the stations were caution tagged to prevent their uso due to a spacing conoom. -Oudng follow up discussior's with the building management, it was determined that F-cans being i

used at the other two LAW stations were within two feet of uranium bearing material, in -

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violation of the requirements of NCSA-PLANT 025.A01," General Use of Small Diameter Containers for Storing up to 10% Enriched Material."

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The deficiency apparently resulted because the holders were attached to movable starxis located under the pigtsN connections. Since the stands were aquetable, there was no i

positive means of mairdaining the required spacing. The inspectors also observed that lids were not on the cans, as required by the NCSA when % cans were not attended. A E

second control, uranium assay, was maintained.

The certificates also identified several deficiencies with NC8A implementation during the' l

. Inspection period, two of which resulted in reportable events: -

failure to mairdain the required minimum coolard temperature for several cascade cells. The non-compliance constituted a loss of single control to prevent formation of deposit in the cascade. The second contiol, which was to maintain assay and prevent moderation, was not violated.

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failure to maintain required spacing in the steam bath used to dump UF6 cylinders in the X 710 Building. The second control, uranium assay, was not "iolated.

Failure to comply with NCSA requirements is a Violation of TSR 3.11.2.

(VIO 70 7002/97010 02) i

c. Conclusions Operators displayed a lack of attention to detailin not maintaining the lids on the F cans.

In addition, the operators failed to question why two of the holders were acceptable for use with the others tagged out. The examples discussed above are indicative of continued problems with the implementation of NCSA requirements in the plant, t

t 01.3 Review of the Problem Reportina System

a. Inspection Scope (88105) i The inspectors reviewed elements of the problem reporting system, including review of

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problem reports and observation of the problem report screening committee, to verify complicnce with the requirements of the quality assurance plan.

b. Observation and Findinos The problem reporting criteria included non-safety' as well as safety-related findings. The iscreening committee reviewed every problem report and classified each as r,ot quality-related, a condition adverse to quality, or a significant condition adverse to quality, i

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- Assignments were made by the screening committee to the appropriate organization for corrective act% or closure.

The inspectors reviewed a large sample of problem reports and conduded that the corrective actions taken appeared to be adequate and timely. The inspec6 ors also conduded that the reporting critorie was conservative, and that the screedg committee assigned the appropriate classification to problem reports based on importance to safety.

There was no evidence in the reviews or screenity process of management rejection of problem reports,

c. Gonclusions The hspectors concluded that the certificatee's problem reporting system was being implemeted in pocordance with quality estJrance plan requirements.

lL Maintenanos M1 Conduct of Maintenance M1.1 Poor Controls/ Communication Durina Crane Maintenance j

a. Inspection Scone (68103)

The inspectors reviewed a corrective maintenance activity for the Extended Range Product (ERP) crane.

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b. Observations and Findinas On October 20 the certificates declared the ERP crane inoperable due to a rubbing noise coming from tha bridge brakes or whools. During troubleshooting, maintenance personnel determined that cap screws that attached one of the wheels to the gear assembly had sheared. The shift engineer contacted the system engineer at home, who recommended that a functional test be performed as a Post Maintenance Test (PMT) upon replacument of the screws. The crane was declared operable after successful completion of the PMT and used to move a liquid cylinder, Upon further review the following day. the system engineer became aware of the failure mechanism of the screws. The system engineer was apparently not aware that the screws had sheared during the conversation that took place the previous evening, in addition, the system engineer loamed that the shift engineer approved replacement capscrews that wem 1/4" longer than those remuved. During further investigation, the system engineer discovered that the wheel assembly was not confqured in accordance with the approi ed drawing. As a result, the crane was declared inoperable again on -

October 22.

The system engineer determined that the original PMT was not sufficient because the -

whee! assembly had been removed from the crane for the maintenance activity. Since the assembly was load bearing and within the Q boundary, the system engineer requested that a 100 percent load test be performed to verify that the as found condition was acceptable for the liquid cylinder that was moved. On October 24, the crane passed

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the load lost. The orane remained inoperable at the end of the inspection period pending restoration to the wced design.

Failure to do requimd PMT testing pr6or to piecing the orano in servios is a violation of l

TSR 3.15. Huwever, plant personnel identified the c::Mg and M::;:r. testing 1

was successfully completed. Therefnre, the violation is being treated as a non cited violation (NCV) consistent with Section Vll.B.1 of the NBGJ.Ofe[9tstDLE9HGM.

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c. Conclusion

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inahquate work instructions and design ooritrol and poor communications contributed to

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en ir. adequate PMT and operation of the ERP crane in non-conformance with the approved design.

til. Enaineerina E1 Conduct of Engineering E1.1 Andegltyg.,BistLEttapure Steam Shutdown System

a. Inspection Scope (86101)

The inspectors walked down the high pressure steam shutdown system for the autoclaves in the X M2 Building and reviewed the system design with facility personnel.

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b. Observations and Find;nos On September 22 the inspectnes walked down the high pressure steam shutdown system for the autoclaves in the X 342 Sullding. The high pressure steam shutdown periormed a safety function of protecting the UF6-filled cylinder in the autoclave from overpressure, Overpressure protection was provided by removing the heat source to the cylinder by shutting off steam to the cutoclave when a high pressure was sensed in the autoclave.

The inspectors noted that the safety systera boundary drawings indicated that them were three pressure sensor channels for autoclave high pressure. Discussions with the system engineers and other facility staff indicated that two of the channels were for high -

autoclave pressure containment isolation actuation signals while one channel was for autoclave high pressure steam shutdown. The steam shutdown signal would shut the steam valves while the containment isolation signal would shut the steam valves and the

' other containment isolation valves, The high pressure steam shutdown signal (8 psig) was set lower than the high pressure containment isolation (15 psig).

The three pressure sensor channels and the functions indicated in the system drawing t

agreed with the system description in Section 3.2.1.1.1 of the Safety Analyses Report i'

(SAR) However, the inspectors noted the configuration did not agree with the limiting conditions for operation (LCO) for TSR 2.1.3.4. The TSR inferred that there were two

channels for the steam pressure shutdown. The discrepancy between the SAR and TSR -

was brought to the attentbn of the certificates, and all autoclaves were declared u

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An Operations Assessment Team (OAT) session was activated that aftemoon to determine a plan of action to bring the autoclaves back into service while complying with the TSR and SAR. The OAT determined that compier.co could be achieved by calibrating all three pro 6sure sensors to the lower set point of the steam shutdow n. That would provide at least two Jannels that would isolate steam to the autocieve when the high pressure steam shutdown set point v/as reesed. The Plant Operations Review l

Committee (PORC) concurred with the required calibration procedure sanges and the autoclaves were placed back in service af!st the cahbrations were completed,

c. Conclusions The inspectors concluded that the certificatee's dedslon to shut down the autoclaves was appropriate and Gomonstrated conservative decision making. The isoc=y plan developed by the OAT was also +;ti,,i":':. However, the discrepancy betwoon the

- SAR and TSR cdicated an incomplete understanding of the facility design basis on the part of plant staff. Operating the autoclaves with only one pressure channel available for the steam shutdown is a Violation of TSR 2.1.3.4. (VIO 70 7002/97010 03)

E1.2 - Enoineerina Notices Used To Chance,lqgAt

a. Inspection Scope Th; inspectors reviewed the plant staffs use of engineering notices to make changes to approved nuclear criticality safety evaluations and approvals.

b. Observations and Findinas During n routine review of planned maintenance activities, the inspectors noted that a manual used by maintenance planners to guide the preparation of maintenance work packages included nuclear criticality safety (NCS) related engineering notices (ens).

The manual directed the staff to incorporate the EN information into work activitiet, that were affected by some of the nuclear criticality safety evaluations (NCSEs) and Nuclear Criticality Safety Approvals (NCSAs).

The inspectors reviewed several of the ens included in the manual and noted that the ens appeared to change either the scope or applicability of the associated NCSAs.

. Some examples of the ens which changed the NCSAs included:

EN X NCS97-01g, Revision 0, changed the NCSA allowed travel path for

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uranium-bearing containers entering Building XT-847 from the poth specifically described an1 authorized route to any path that was kept free of other containers.

. No additional controls were initiated to ensure that the new paths were maintained free of other containers.

EN X NCS-97-026, Revision 0, eliminated an NCSA requirement that the

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insulation around sodium fluoride traps include a one inch hole to preclude the accumulation of the uranium materials in the insulation or void space. Instead of the required hole, the EN relied upon the presence of gaps at the bottom of the insulation.

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_ EN-X-NCS-97-030, Revision 0, extended the applicabitPy of an NCSA developed for the Building X 710 laboratories to the Building X-760 laboratories and den e a requirement for a sign to be posted in the Building X-710 laboratories.

EN-X-NCS97-049,- Revision 1, authorized the use and movement ofNCSA-controlled uranium-bearing equipment in an areas without criticality accident alarm

- coverage. The applicable NCSAs limited use of the equipment to areas with criticality accident alarm coverage.

EN-X NCS-97-062, Revision 1, authorized the removal of raschig sings from the oilinterceptor in Building X-342A in order to perform maintenance activities. The applicable NCSA required the ischig rings to be present at all times.

The inspectors reviewed the safety impact of some of the changes implemented using the engineering notice system. Although no immediate safety concems were developed, tl e potent'al existed for an activity to be authorized using the engineering notice system which conflicted with a fundarncital assumption of an existing nuclear criticality safety evaluation or approval.

The inspectors discussed the findings with the NCS manager and was informed that the practice of using ens to change the NCSAs and NCSEs was acceptable provided the

" intent" of the NCSA and NCSE was not changed. The manager Micated that the Procedure, XP4-EG-NS1001, Revision 1, " Nuclear Criticality Safety dvaluation And Approval," dated March 3,1997, allowed such changes. The inspectors noted that step 6.16 of the procedure allowed changes to the NCSAs which did not adversely affect the originally approved safety envelope described in the NCSE. The procedure directed that the changes should be documented in the original NCSA through the revision bars.

The inspectors compared the NCSA procodure with the TSR and the SAR. Technical Gafety Requirement 3.10 requires, in part, that the Plant Operations Review Committee (PORC) review and approve or disapprove all nuclear criticality safety evaluations and approvals. Section 5.2 of the SAR dessibed the process for developing, approving, and implementing NCSAs and NCSEs Section 5.2 required the PORC to review and approve the NCSAs.

Based upon the inspectors' and the certificatee's intemal review of requirements, plant management placed a hold on many of the activities conducted using the EN-authorized changes to the NCSAs and NCSEs. The inspectors conducted a review of the activities which were halted and the activities permitted to continue using the EN-authorized change. The inspectors noted that severa; of the activities which were authorized to continue appeared to still be in conflict with the requirements. Engineering management conducted a second review of the NCS ens and concluded that all should be canceled, in addition, tM engineering management initiated a review of the use of ens for other activities.

Technical Safety Requirement 3.10 requires, in part, that the PORC shall review and approve or disapprove all nuclear criticality safety evaluations and approvals. The failure to develop and have the PORC review and approve engineering notice implemented changes to nuclear criticality safety evaluations and approvals is a Violation of TSR 3.10.

(VIO 70-7002/97010-04) 10

- c. Conclusions The inspectors determined that plant staff had used the engineering notice system to make changes to nuclear criticality safety evaluations and approvals in conflict with the -

TSRs. None of the changes reviewed by the inspectors was determined to create an

".mmediate safety issue.

E1.3 Review of Trainina Rodgee,d

a. Inspection Scope

-l The inspectors performed e review of training record for the engineering departrnent.

b. Observations and Findinod The inspectors reviewed training documents and verified that engineering personnel who perform plant change request evabations were qualified to do so. The inspectors also verified that confined space training requirements were =160 current.

c. Conclusion

The inspectors concluded that confine spaces and procedure change request evaluation training were current for engineering personnel engaged in those activities.

IV. Plant Support P1.1 Emergency Plan and implementing Procedures a.

Inspection Scoop (88050)

The inspectors reviewed and discussed the plant's Emergency Plan (EP) and implementing Procedures, and organization and staffing with plant staff to determine if the emergency program was current with site conditions and being maintained in a state of operational readiness. The inspectors also reviewed training records and interviewed selected emergency response supervisory staff and technicians to evaluate their awareness of emergency procedures.

b. Observations and Findinos The Emergency Response Organization (ERO) and Emergency Response Personnel responsibilities were consistent with that described in the EP. The EP and Implementing Procedures provided adequate guidance on classification and mitigation of the consequences of emergencies, assessment for any potential releases of radioactive materials and hazardous chemicals, personnel accountability, sib evacuation, intemal and off-site notification of emergencies.

The inspectors noted that some implementing procedures contained trairing requirements that were not readily tracked or documented. Specifically, Procedure XP2-EP-EP1031, " Evacuation," Section 6.1.3, stated, in part, that the Local Emergency 11

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Diredor'(LED) was required to ensure that personnel working in the area rooolved -

training on evacuation and accountability. - The inspectors conducted an on-shift survey of.

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the PSS staff to determine whether the appropriate training was conducted or documented by the LED and the methodology used to ensure that training _was 4

conducted. The inspectors determined that although training was not formakzed or.

documented by the LED for personnel working in the PSS area, that either independent self study training was conduchd or the PSS staff had previous training in a different job assignment.-

- in addition, the inspectors could not determine the tracking mechanism used to ensure -

compliance with the training requirements. The emergency management staff informed the inspectors that this training requimment appeared to be a duplication of similar emergency management training given to plant staff. They cIso committed to conduct a detailed review of all the implementing procedures to eliminate similar duplicative.

requirements.

l The inspectors noted that selected training records were up to-date and tWiing lesson plans for the Plant Emergency Operations Director, Crisis Manager, incident Commander, and the Public Information Manager were of high quality and adequately covered subject matter relative to their respective assignments. The staffs training included emergency response in the areas of industrial hygiene, radiological response procedures, hazardous materials decontamination and spill control procedures, and first aid, including mass casualties procedures.

3 Interviews were conducted with several ERO members in different capacities. Personnel i

interviewed were knowledgeable of their responsibilities and procedures for their respective assignment in the emergency organization.

c. Conclusion

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The EP and implementing emergency procedures provided sufficient guidance for responding to plant emergencies. The emergency organization was adequate for

- responding to emergencies. Emergency response personnel were adequately trained and were knowledgoable of emergency response procedures and equipment.

P1.2 Offsite Support Aaencies 3

a. inspection Scope (88050)

The inspectors evaluated the plant staff's involvement with offsite support agencies as

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described in the Emergency Plan (EP).

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b. Observations and Findinas :

The Emergency Plan contained current agreement letters with offsite agencies for response or assistance during emergency events. -The certificatee had formally notified local, county, state, and federal support agencies regarding the biennial emergency management exercise that occurred on September 12, if)97. Atten<1ance was good from.

2 offsite support agencies during this exercise.. Plant staff contacted offsite support agencies on a quarterly basis to verify telephone numbers and points of contact.

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c. Conclusions Plard staff maintained adequate support from offsite agencies for respondog to or assisting during an emergency event.

P1.3 : Drills. Exercises. and Audits

a. Inspection Scope (88050)

>The inspectors reviewed records of drills, exercises, and audits and held discussions'with cognizant personnel.

b. Observations and Findmca in accordance with the EP, periodec drills or tabletop exercises were conducted by the plant's ERO sach year. Every two years a major field exercise, consisting of an accident scenario, activation of the ERO, and activation of emergency response facilities, had te3n conducted.

The inspectors noted that Procedure XP2-EP-EP5031. " Emergency Management Drill and Exercise Program," stated, in part, that the emergency management drills and exercises would be scheduled and conducted to ensure tha ERO's ability to mitigate the consequences of an emergency. Several emergency dri!'s scheduled and conducted

'since March 3,1997, included some of the followmg: plantwide accountability drills (day and night shifts), tomado drills (day and night shifts), evacuation drills, and communication vehicle rinlis.

l The inspect; rs reviewed the " Emergency Management Drill and Exercise Schedule" and identified that some drills were unrelated to the emergency management program; i.e.,

confined space drills, hazardous re.aterial spill drills, etc. These drills were developed to address special training requests from other facility organizations. It was noted that some -

of these quarterly drills were not conducted in a timely manner because of other staff resource commitments and it was not immediately communicated to the Emergency Management Director (EMD). The inspectors noted that although iniormal expectations existed for completing ccheduled drills in a timely manner, most drills were completed in the scheduled quarter. The p; ant staff agreed 'o revise the drill and exercise schedule into separate areas to better identify the regulatory " emergency management drills" and the non-regulatory drills associated with special requests.

In addition, the staff conducted a satisfactory emergency management exercise on

~ September 12,1997, with the NRC and offsite agencies.

Critiques conducted since March 3,1997, of selected drills and the tabletop exercise to the present were detailed and comprehensive to identify and correct deficiencies. The inspectors noted that although the staff ha'i established an effective system to track corrective actions for identified deficiencies from exercises and drills, some of the -

expected due dates for correcting the deficiencies were not mei.- However, the inspectors noted, during a review of several corrective action defisncies, that no items were identified as having significant safety rJar.ifi< ance or serious defn.;cncies in the EP h

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t content or implementation. The emergency management staff were resolving the corrective action backlog as additional resources became available.

1 The inspedors reviewed an annual emergency preparedness intomal audN that was.

issued Odober 18 - 1996. LThe audM was performed by members of the independent Assessments Group. None of the audWors had droct responsibility for implementing the emergency response program. The audN evaluated performance relative to the requirements of the EP and implementmg procedures, with an emphasis on ERO training and responsibilities, emergency equipment, and memorandums of understanding from offsite agencies.

There were several audit findmgs that were identified that required written problem

reports for corrective actions. One signi6 cant weakness was identified that addressed inadequate implementing procedures. Spedfically, implementing procedures did not

' define key positions of the ERO for the activation of the altemate Emergency Operation Center (EOC). The inspedors noted that the appropriate procedures were revised that addressed the five EOC key positions required for the EOC adivation. Other comments from the audit were being addressed by the emergency response staff.

c. Conclusions -

Emergency exercises and drills were generally consistent with the commitments in the EP

-and adequately exercised the ERO Although actions for recommendations and

' deficiencies identified in annual exercises were effectively tracked, a minor backlog for corrective actions was identified.

P1.4 - Surveillances of Emeroency Eauioment and Facilitieg

a. Inspection Scope (88050)

The inspectors reviewed the EOC, other facilities and equipment, and related surveillances to determine whether the emergency response equipment, instrumentation, and supplies located in emergency repositories were maintained in a state of operational readiness. The emergency response vehicles, mobile communications vehicles, incident 7

. commanders vehicles, and field team mon;toring kits were also inspected. The inspector also reviewed the testing of the public waming sirens and controls,

b. - Observations and Findinas The inspectors noted that emergency equipment repositories contained the quantities and equipment identified in the EP and implementing procedures. Cabinets containing emergency equipment and field kits were clearly identifiable, contents were ordedy, and well maintained. Radiation servey instruments located in the Emergency Response Vehicle (ERV) were calibrated and operational, and self-contained breathing apparatus air tanks stored on-board the ERV were full and ready for use. In addition, equipmentc

- and instrumentation stored at selected locations (Incident Commander's (IC) ERV, Communication Vehicle, Health Physics Emergency Response Equipment Room) were

- properly maintained.

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-t The inspectors reviewed documentation (in support of maintenance, penodic tests or

- surveillances) required by Procedure XP-2 EP EP5034," Maintenance of Emergency i

Faciisties and Equipment." The inspedors determined that surveillances were not :

conduded as required, surveillances records were either incomplete or missing, and the.

performance of some surveillances resulted in equipment preconditioning. -.

Specifically, the inspectors reviewed the monthly and semiannual surveillance testing documentation associated with the Public Waming System (PWS) from March 3,1997, to the present. The inspedors also interviewed the appropriate staff who conducted the

- surveillances. The inspectors were informed that the monthly surveillances conducted for.

the inaudible testing of the PWS included a " pre-test" surveillance and " post maintenance" surveillance test. The staff conducted a pre-test of the PWS to first

-determine whether the equ(pmerd was operable based on accepted values for voltages and other parameters. Any usatisfactory medings would then be repaired or corrected by the maintenance staff prior to the start of the " official" surveillance test of the PWS.

The inspectors reviewed Procedure XP2-EP-PU1031, "Public Waming System Activation," and determined that the current surveillance practice (pre-conditioning) was inconsistent with the procedure. The emergency management rtaff agreed with the inspectors that pre conditioning surveillances were unacceptabw. The emergency management staff indicated that a different procedure had been developed to address the routine electrical testing and maintenance of the PWS The emergency management staff immediately conducted a satisfactory surveillance of the PWS which was observed by the inspectors.

As a follow-up to the inspectors questions, the EMD initiated a review of other roatine preventive maintenance activities and surveillances associated with other emergency response equipment. The EMD informed the inspectors that the review results indicated that other examples of equipment preconditioning did not exist.

in addition, the inspectors identified that the semi-annual PWS audible testing of the PWS was not conducted in accordance with the " Drill and Exercise Schedule" for the first six months of the year. The emergency management staff indicated that in past practice, the PWS surveillance was not performed until a contractor was available to repair or correct any problems observed during the PWS surveillance. The inspectors determined that the current surveillance practice Pnaintenance staff on standby) was inconsistent with Procedure XP2-EP-PU1031,"Public Waming System Activation." The emergency reanagement staff immediately scheduled the semi-anmiel audible surveillance of the PWS for October 10,1997. Subsequently, the emergency management staff informed the NRC that the PWS surveillance test was satisfactory.

The inspectors observed a surveillance of the incident Correspondence (ERV) conducted by the assistant PSS using the appropriate inventory Checklist. The checklist included a requiremt nt that the vehicle contain a current and approved copy of the Portsmouth b

Gaseous ")iffusion Plant EP. During the surveillance, the assistant PSS stated that the EP was current. The inspector observed that the EP reierenced by the assistant PSS

was an obsolete Lockheed Martin EP dated 1994. The cmergency management staff in. mediate y supplied the correct EP to the assistant PSS.

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The Emergency Plan (EP) required, in part, that the Emergency Plan implementing Procedures (EPIP) be implemented to ensure that the emergency response equipment and facilities were maintained to enhance amorpency preparedness effective response actions taken to mitigate the consequences of emergency and to protect the health and safety of the public and workers at the plant.-

Procedure XP2-EP EP5034, " Maintenance of Emergency Facilities and Equipment,"

Section 6.1, stated, in part, that inaudible testing of the PWS be conducted at least monthly, and that audible testing be conducted semiannually.

The failure to conduct PWS surveillances in accordance with implementing Procedure XP2 EP-EP5034," Maintenance of Emergency Facilities and Equipment,"is a Violation of TSR 3.9.1. (VIO 70-7002/97010-45)

c. Conclusions The emergency preparedness staff maintained a good inventory of well-maintained emergency response equipment and supplies that were in a state of operational readiness. The inspectors identified that the issue of preconditioning prior to the performance of requiced surveillance testing of the PWS and the failure to conduct PWS surveillances per procedure was identified as a violation.

P1.5 Emergency Preparedness Organization and Administration

a. Inspection Scope (88050)

The inspectors conducted discussions with the EP staff regarding the current plant organization and reviewed the current organizational chart.

b. Observations and Find:nos The overall organization and management structure of the EP function was consistent with the EP and implementing procedures. The Emergency Management Diill and Exercise Coordinator and two Emergency Management Specialists reported directly to the Emergency Management Manager, who reported to the Plant Site and Facility Support Manager, who reported to the Plant General Manager Recently, an Emergency Management Consultant left due to budget constraints.

c Conclusions The structure of the emergency preparedness function was consistent with the requirements in the EP.

V. Manaaement Meetinas X1 Exit Meetino Summary The inspectors presented the inspection results to members of the facility management on November 3,1997. The facility staff acknowledged the findings presented.

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

• J. B. Morgan, Acting General Manager

• M. Hasty, Engineering Manager-

• R. W. Gaston, Nuclear Regulatory Affairs Manager

• C W. Sheward, Maintenance Manager

• R. D. McDermott, Operations Manager United States Enrichment Corporation J. H. Miller, USEC Vice President, Production

• L Fink, Safety, Safeguards & Quality Manager United States Department of Enerav (DOE)

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

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

• Denotes those present at the exit meeting on November 3,1997.

INSPECT'ON PROCEDURES USED IP 88100 Plant Operations IP 88101 Configuration Control IP 88102 Surveillance Observations IP 88103 Maintenance Observations IP 80105 Management Oversight and Controls IP 88020 Regional Criticality Safety IP 88050 Emergency Preparedness 17-1 I

4-ITEMS OPENED, CLOSED, AND DISCUSSED.

Opened 70 7002/97010-01l. VIO _ Failure To Take Action To Prevent Recurrence of An Autoclave Safety Actuation

?

.70-7002/97010-02 VIO Failure To Comph With NCSA Requirements For LAW Station F-Cans-70 7002/9701 403 VIO Operation Of Autoclaves With Only One Pressure Channel For Steam Shutdown 70-7002/97010-04 VIO Failure To Have PORC Approval For Changes To NCS Requirements implemented By Engineering Notices 70-7002/97010-05 VIO The Failure To Conduct PWS Surveillances Required By EP Closed None

. Discussed None Certification Issues - Closed None 18 e--nn-m

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6 LIST OF ACRONYMS USED -

ANSI

' American National Standards Institute

-'ASME American Society of Mechanical Engineers CFR Code of Federal Regulations DEC Drill and Exercise Coordinator -

EMM Emergency Management Manager-EMS Emergency Management Specialist

-EOC Emergency Operations Center EP Emergency Plan ERO

- Emergency Response Organization g

Gram IP inspection Procedure LCO Limiting Condition for Operation

- LMUS Lockheed Martin Utility Services

. NCS Nuclear Cnticality Safety NCSA Nuclear Criticality Safety Approval NCSE Nuclear Criticality Safety Evaluation NCV Non-cited Violation

-'NOV Notice of Violation NRC Nuclear Regulatory Commission PDR Public Document Room PGDP Paducah Gaseous Diffusion Plant PORC Plant Operations Review Committee psla pounds per square inch absolute PSS Plant Shift Superintendent QAP

- Quality Assurance Plan SAR Safety Analysia Report SCAQ Significant Condition Adverse to Quality TSR Technical Safety Requirement U-235 -

Uranium-235

.UF6 Uranium Hexafluoride USEC United States Enrichment Corporation VIO Violation

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weight-percent

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