ML20199K315

Insp Rept 70-7001/97-12 on 971006-10.Violations Noted. Major Areas Inspected:Engineering,Maintenance & Surveillance & Plant Support

ML20199K315
Person / Time
Site:	07007001
Issue date:	11/26/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20199K285	List: ML20199K281 ML20199K302 ML20199K315
References
70-7001-97-12, NUDOCS 9712010080
Download: ML20199K315 (12)

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U.S. HUCLEAR REGbdTORY COMMISSION REGIONlil Docket No: 70-7001 Inspection Report No: 70 7001/97012(DNMS)

Facility operator: United States Enrichment Corporation Facility Name: Paducah Gaseous Diffusion Plant i

Location: 5600 Hobbs Road

- P.O. Box 1410 Paducah,KY 42001 Dates: October 6 - 10,1997 Inspectors: T. D. Reidinger, Senior Fuel Cycle inspector R. G. Krsek, Fuel Cycle inspector Approved By- Patrick L Hiland, Chief Fuel Cycle Branch

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EXECUTIVE

SUMMARY

United States Enrichment Corporation Paducah Gaseous Diffusion Plant NRC Inspection Report No. 70-7001/97004(DNMS)

Enaineerina

. An inspector follow-up item was identified in Building C-335 regarding missing or loosely installed mounting bolts on the coolant condenser support plates. (Section E1.1)

. The inspectors identified that a violation occurred when employees failed to follow the requirements for a downgraded confined space entry while performing troubleshooting activities within a cell housing. (Section E1.2)

Maintenance and Surveillance

. Tne inspectors identified a violation regarding the release of an inadequate maintenance work package for autoclave upgrade maintenance activities. A maintenance *.vork package was released for work after management review, with an inappropriate procedure for use during the performance of a post maintenance test. (Section M1.1)

. The inspectors identified an unresolved item concerning the quarterly Technical Safety Requirement (TSR) surveillances performed on the hydraulic lift rail stops in Building C-360. During the course of the inspection, the certificatee was unable to provide the design analyses for the system, so that the inspectors could assess whether or not the quarterly surveillances assured that the rail stop system would perform the intended safety function. (Section M1.2)

Plant Suppp_rj Employee Trainina Proaram

. The inspectors identified a violation regarding a specific time requirement for the pressure fit check of respiratory protection equipment prior to use. Plant personnel were generally unaware and did not perform a procedural requirement for the 10 second positive and negative fit check, to test respiratory protection equipment prior to use.

(Section R1.1) 2

DETAILS

1. Enninee302 E1.0 conduct of Engineering E1.1 poolant Condenser Support Plates

a. Inspection Scope (88020)

The inspectors performed tours of the Building C-335 cascade to inspect the mounting bolts installed in the structural support plates of the coolant (R-114) condensers. In addition, the inspectors reviewed R 114 condenser installation drawings,

b. Observations and Findinas During tours of the Building C-335 cascade, the inspectors noted that the mounting bolts for the R 114 condensers were installed in the majority of R 114 condenser support plates. The R 114 condensers had four support plates which were anchored by mounting bolts to a horizontal steel support structure. Each support plate and supporting steel structure had four drilled holes, to secure the R 114 condensers to the building structure.

The inspectors observed that the majority of the R 114 condenser support plates in the Building C 335 cascade had missing or loosely installed mounting bolts. Subsequent tours of other similar cascade buildings revealed that the majority of R 114 condensers were secured to the building structures with mounting bolts. During walkdowns of the Building C-335 R 114 condenser systems, the inspectors also noted that the process piping for the recirculating cooling water and coolant systems connected to the R 114 condensers, restricted the lateral movement of the condensers. In addition, the condenser support plates appeared to be centered on the steel support structures, indicating that the R 114 condensers had not shifted due to the lack of mounting bolts, in response to the inspectors' findings, plant engineering staff reviewed the applicable R 114 condenserinstallation drawings. The drawings contained marginalinformation regarding the structuralinstallati n requirements for the R 114 condensers. The plant engineering staff also informed the inspectors that similar observations were documented in a problem report on October 5,1995 (PR CO-95-4107). An October 6,1995, memorandum written in response to the concems in PR-CO-95-4107, concluded that the as-found condition did not present an immediate concem to operations, but that measures snould be taken to secure the R 114 condenser in preparation for any future condenser work.

The plant engineering staff indicated that a problem report was written, based on the inspectors' current observations, to investigate any applicable seismic design calculation issues or accident analysis assumptions which would impact the as-found conditions of the R 114 condensers. The inspectors concluded there was no immediate safety concem. Engineering activities performed to resolve this issue will be tracked as an inspector Follow-Up item (IFl 70 7001/97012-01).

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c. Conclusions The inspectors concluded that the missing or loosely installed bolts in the R 114 support plates did not present an immediate safety concem. An inspector follow-up item will be used to track the plant engineering staff's resolution of this finding.

E1.2 Observation of Enaineerina Activities in Buildina C-331

a. inspection Scope f88020)

The inspectors observed engineering troubleshooting activities f or a compressor in Building C-335.

b. Observations and Findinag The inspectors observed engineering troubleshooting activities for the Unit 4, Cell 8, Stage 3 compressor in the Building C 335 cascade on October 7. The inspectors observed two employees prior to their entry into the cell housing. When both employees entered the cell housing and moved out of visual contact of the inspectors, the inspectors proceeded to the Building C-335 area control room (ACR) to review the associated work package (R9706474).

The inspectors noted that the work package included a confined space downgrade certificate (No. 97-33518). The downgrade certificate required the implementation of the buddy system, as well as the use of a plant radio if one of the entrants into the cell housing was out of visual contact with the ' baddy' stationed outside the cell housing. The inspectors then noted that the two employees who entered the cell housing at Unit 4, Cell 8 Stage 3 did not have a plant radio, and did not have a pe. son stationed outside )

the cell housing. The inspectors informed the ACR supervisor of the situation. The ACR supervisor sent operations personnel to the worksite, to ensure that an employee was stationed outside the cell housing as required by the downgraded confined space entry certi:icate. The ACR supervisor later confirmed with the inspectors that the employees in the cell housing were out of site and did not have a plant radio as required by the downgrade certificate.

As an immediate corrective action, plant management temporarily halted all onsite work in confined and downgraded confined space areas and initiated crew briefings regarding the issue for all plan' staff. The c,ew briefings covered the circumstances surrounding this incident, along with a review of the plant's confined space program.

Procedure CP2 SH-SH1031,

• Confined Space Program," requires, in part, that for work activities conducted in confined spaces, a confined or downgraded confined spre entry certificate must be issued. The certificate lists the requirements needed for work to be conducted in the confined space. Confined space downgrade Certificate Number 97-335-18, was issued on September 16,1997, for all work activities conducted in Unit 4 Cell 8 in Building C-335. On October 6, the ACR supervisor had signed Certificate Number 97 335-18 confirming that all the conditions for the certificate were fuifilled. The failure to perfomi work activities in a downgraded confined space, in accordance with Downgrade Certificate Number 97 335-18, on October 7, is a Violation (VIO 070-07001/97012-02a).

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I c Conclusions i

During the observation of engineering troubleshooting activities, the inspectors identified a violation, in that work activities were not performed in accordance with the confined space ent,y program and Ceitificate Number 97 335-18. .

11, Maintenance and Surveillance

, M1.0 conduct of Maintenance and Surveillance M1.1 Spildina C 360 Autoclave Conductivity Cells Time Delav Modifications. ,

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a. inspection Sc2P_9 (88025)

The inspectors reviewed the maintenance work package (MWP) associated wie, the -

Building C 360 autoclave conductivity cell time delay modifications. The in:;,ectors also reviewed the process for the development and management review:; of MWPs.

b. Observations and Findinas The inspectors reviewed MWP No. R9702287, provided as a source document for the Building C 360 autoclave conductivity cell time delay modification work. The inspectors

6dentified a weakness in the type and quality of information included in the MWP.

Specifically, the MWP did not include the appropriate procedure for the post maintenance test (PMT) of the autoclave conductivity cell 30 second time delay. The PMT section of the maintenance work package referenced Procedure CP4-CO-CN6055c, Rev.1, the previous procedure used for functional tests of a conductivity cell without a 30 second time delay, in addition, a copy of Procedure CP4 CO-CN6055c was not included in the MWP for this autoclave upgrade activity.

During follow up discussions with maintenance management, the inspectors were informed that, although the MWP should have referenced and included a correct PMT procedure which specified acceptance criteria for the testing of the 30 second time delays, the autoclaves were shutdown until all autoclave modification work was complete.

The engineering staff stated that the procedure for testing the Building C 360 conductivity cell time delays was in draft and would be incorporated into the MWP upon final review of the procedure. A stop work order was issued for the PMT section of the maintenance work package.

Procedare CP2 GP GP1032, " Work Control Process," specified the basic components necessary to ensure the development and management review of a quality work control package. The procedure defined the expected quality and detail of information in a MWP, in addition to the level of detail for the rigor of management reviews during the development and prior to the release of the MWP for work activities. CP2-GP-GP1032

- requires, in part, that MWPs are review,,d by a service manager, the manager-in-charge (customer), the planning manager, and a representative from systems engineering prior to release forinaintenance activities. The review process was in place to ensure that the MWP was accurate and adequate for the job being performed. The inspectors determined that Procedure CP2 GP-GP4032 provided adequate expectations to ensure that the required documentation for the MWP was provided; tha', the procedures used to S

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l develop the work package were available; and, that tho management reviews of the l developed package addressed both accuracy and adequacy.

The inspectors noted that the required management reviews for MWP No. R9702287  :

failed to identify that an inadequate procedure was prescribed for the post modification  !

testing of the conductivity cell 30 second time delays. The failure to adequately review >

and control MWP No. Rg702287, which was released for maintenance work associated I with the Building C 360 conductivity cell time delay modification, is a Violation of Procedure CP2-GP GP1032, " Work Control Process" (VIO 70 7001/9701242b).

c. Conclusions i

The inspectors identified a violation regarding the release of an inadequate MWP for maintenance activities. The inspectors identified that a managsment review of MWP No. R9702287 failed to identify that the procedure referenced for post maintenance testing activities was inadequate. The re'erenced procedure was used to functionally test the system prior to the upgrade activity, and did not specify any acceptance criteria for the functional testl~1 of the new system. The certificatee issued a stop work order for the PMT section of the MWP until the appropriate procedure for a PMT was developed.

M1.2 Quarteriv Surveillances of the Buildi.na_C-360 Levelator Rail Stops

a. Inspection Scope (88025)

The inspectors reviewed selected Technical Safety Requiremont surveillances for the Building C-360 toll transfer and sampling facility.

b. Observations and Findir)gg The inspectors reviewed Technical Safety Requirement (TSR) 2.1.5.8, " Hydraulic Lifts -

Rail Stops," ano the subsequent quarterly surveillances performed on the rail stops. The design feature, which was a part of TSR 2.1.5.8, stated, in part, that the rail stops on the levelator prevent rolling the sed.o cart and the carried cylinder off the end of the lift. The design basis for this TSR stated that this design feature minimized the expected frequency of the

• liquid cylinder rupture" accident scenario in Safety Analysis Report (SAR) Section 4.3.5.1.2.

Building C-360 personnel utilized the hydraulic lift, more commonly referred to as a "levelator," to lower all liquid UF cylinders from the autoclave work level to the ground level (a vertical distance of approximately 4 feet). The outside edge of the levelator had two rail stops (one for each rail of the scale cart wheels) to prevent the roll off of the scale cart during the movement of the liquid UF, cylinders onto the levelator and during the vertical movements of the it --%r. A rail stop consisted of a steel rectangular block fastened to the levelatui rwi by a mounting bolt. The mounting bolt traversed through the steel block and was considered to be a point of failure for the rail stop system.

Technical Safety Requirement surveillance 2,1.5.8-1 specified that a quarterly visual inspection of the rail stops be performed to ensure the rail stops were not bent or cracked. The inspectors verified the quarterly inspections were conducted, through a review of the

• Periodic Elevator inspection Reports," Form CP 20505. The inspectors 6

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then reviewed surveillance Procedure CP4-QA-QlB086,

• Elevator inspection," to ,

determine what actions were required as a part of the quarterfy surveillance.

Section 8.2.2 of CP4-QA-Qi6086, stated, " perform inspection of platform rail stops for structural damage." Interviews and a mock surveillance conducted with Quality Control staff indicated that as part of the surveillance, the niounting bolt for the steel rectangular block was not visually inspded for cracks or structural damage. The Quality Control staff agreed that a failure poi.it for the rail stop system was the integrity of the mounting bolt.

The inspectors also noted that the levelator rail stops were defined as a "Q' safety system in SAR Section 3.15.1 A.13, subject to the certificatee's Quality Assurance Program, required by 10 CFR 76.93, " Quality Assurance." In addition, the introduction to SAR Section 3.15, originally submitted to the NRC in August of 1996, stated, in part, that the rail stops would be evaluated for capacity and ability to perform their intended t,afety i function.

Follow up discussions with both the system and design engineering organizations revealed that the design calculations for the design bases of the rail stop system were currently not available.

At the exit meeting, the certificatee indicated that the only documentation available for the levelator rail stops, was the original purchase nrder for the hydraulic lift system, daied November 18,1977. The purchase order specifications required, " manual rail chocks

[ stops) on two sides of the platform." Although operations involving the handling of liquid cylinders were ceased at the time of the inspection due to autoclave upgrade activities, the Building C 360 Manager declared the levelators inoperable until questions regarding the ability of the rail stops to perform their intended safety function and the adequacy of the quarterly surveillances were addressed. The adequacy of surveillances for the rail stops cannot be addressed until the appropriate design documentation for the rail stops is reviewed by the inspectors. The adequacy of the quarterly rail stop surveillances will be addressed as an Unresolved item (URI) until the NRC reviews the appropriate design -

documentation for the rail stop system (URI 70-7001/97012 03).

c. Conclusions A URI was identified regarding the adequacy of the quarterly Technical Safety Requirement surveillances for the levelator rail stops. The adequacy of the surveillances cannot be assessed until the design documentation, which supports that the rail stops will perform the intended safety function, is reviewed by the NRC.

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111. Plant Support R1.0 Operator Training and Qualification R1.1 Respiratory Protection Trainina

a. Irispection Scoon (80010) ,

The inspectors observed the implernentation of the respiratory protection program  !

through direct observation of maintenance activities requiring respiratory protection, I interviews with staff who frequently use respiratory protection equipment, and a selective review of certain aspects of the respiratory training program.

b. Obsewations and Findinas  !

During plant tours. the inspectors noted numerous examples of the incorrect implementation of a site specific respiratory protection control. Specifically, en several occasions, plant staff were observed donning respirators without conducting the 10-second postive and negative pressure fit checks, required by Procedure CP2 SH lH1036," Respiratory Protection Program." During the observations of maintenance activities on October 7, and 8,1997, in Buildings C-335 and C 310, plant staff were observed performing both positive and negative pressure fit checks. The inspectors queried the plant staff involved prior to the start of work activities and determined that these individuals were not aware of the time requirements for the positive and negative pressure fit checks associated with the proper donning of respiratory protection equipment.

In addition, the inspectors interviewed plant staff conceming the 10-second positive and negative pressure fit check requirements and Jetermined that most staff were unaware of the specific preswre fit check requirements. The failure to implement Procedure CP2 SH-lH1036, "Kupiratory Protection Program" requirements associated with the 10-second positive and negative pressure fit checks was identified as a Violation (VIO 70-7001/97012-02c).

Discussions with the Environmental, Safety and Health Manager (ESHM) and training support personnelindicated that maintenance staff, operators and supervisors received training instructions on safe work practices, safety and health, and chemical hazards (including UFJ through the " Plant Access Training" and respiratory protection liaining.

Qualification and training requirements for health physic staff, operators and maintenance staff were outlined in the respective Training Development and Administrative Guides (TDAG) and the Division Training Requirements Matrix (DTRM). The Training Division ensured that the required training (NRC, OSHA, EPA, etc.) was conducted and documented at the proper frequency. The inspectors compared the TDAG qualification and training requirements with the current training records for selected supervisors, health physics staff and maintenance staff and determined that the training and documentation was consistent with the respective TDAG requirements.

The training staff highlighted that the training mcdules were subject specific teaching aids used by instructors for staff training. The modules were developed from procedures or regulatory guides by trainers, subject matter experts or contractor personnel. Respirator 8

l training module,503.09.08, Respirator Protection," was reviewed for content. The inspectors also reviewed the computer aided training module guidance associated with the proper donning of respirators that was given to plant staff. Both the module and computer aided 'taining contained sufficient detai! to evaluate the students' understanding on the subject material. Specifically, the respirator training modules provided clear directions in performing the required 10-second negative and positive pressure fit checks. The supplementary written lesson plans also provided the management's expectations that proper respirator use involved the 10-second positive and negative pressure fit check prior to use. The inspectors reviewed the test question

, bank associated with the respirator use and noted that although the test questions were well developed for various topical areas in the respiratory protection modules, no test questions were written to address the required negative and positive pressure fit checke prior to respirator use.

As a follow-up to the inspectors observations, the Environmental, Safety and Health Manager indicated that further reviews and spot evaluations would be conducted of other related training areas to improve training effectiveness in addition, test questions woulw be developed to emphasize the 10-second negative and positive pressure fit checks.

c. Conclusio_n_1 A vioiation was identified regarding two failures to implement specific time requirements for pressure fit checks for respirator operability prior to respirator use. Although annual respiratory protection training modules covered the time requirements for pressure fit checks of respiratory protection equipment, the inspectors identified that facility staff were generally unaware of the specific time requirements.

IV. Manaaement Meetinos X. Exit Meeting Summary The inspectors presented the inspection results to members of the plant staff and management at the conclusion of the inspections on October 10,1997. The plant staff acknowledged the findings presented. The inspectors asked the plant staff whether any materials examined during the inspection should be considered proprietary. No proprietary infomtation was identified.

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PARTIAL Lisi0F PERSONS CONTACTED ]

United States Endchment Corporation (USEC)

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• J. A. Labstraque, Safety, Safeguards and Quality Manager .

Lockheed Martin Utility Services (LMUS)

'M. A. Buckner, Work Control Manager

'H. Pulley, Enrichment Plant Manager

'W. E. Sykes, Nuclear Regulatory Affairs Manager ,

'S, R. Penrod. Operations Manager Nuclesr Reauletorv Commission

'T. D. Reidinger, Senior Fuel Facilities Inspector

'R. G. Krsek, Fuel Facilities inspector

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

• J. M.'Jacobson, Resident inspector

• Denotes those present at the October 10,1997 exit meetings.

Other members of the plant staff were also contacted during the inspection period.

INSPECT!ON PROCEDURES,.MgfQ IP 88020 Operations Review IP 68025 Maintenance and Surveit_lan',e Activities IP 88010 Operator Training and Re-T.nining f

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ITEMS OPENED. CLOSED AND DISCUSSED Opened l

70-7001/97012 4 1 IFl R 114 condenser support pletes .

70 7001/97012-02a,b.&c VIO Failure to implement procedures

-70 7001/97012-03 URI Building C 360 levelator rail stops ,

Discussed None ,

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UST OF ACRONYMS USED ACR- Area Control Room APSS' Assistant Plant Shift Superintendent DOE Department of Energy .

OTRM Division Training Requirements Matrix EPA Environmental Protection Agency ESHM Environmental, Safety, and Health Manager IFl inspector Follow-up item LMUS Lockheed Martin Utility Services i MWP Maintenance Work Package l NRC Nuclear Regulatory Commission -l' OSHA Occupational Safety and Health Administration PDR Public Document Room PMT Post Maintenance Test -

SAR Safety Analysis Report TDAG Training Development and Administrative Guidelines TSR Technical Safety Requirement t U 235 Uranium-235 ,

UF. Uranium Hexafluoride URI Unresolved item USEC United States Enrichment Corporation VIO Violation l

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