ML20202B551

Insp Rept 70-7002/97-13 on 971208-980109.Violations Noted. Major Areas Inspected:Nuclear Criticality Safety Operations & Engineering

ML20202B551
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant
Issue date:	02/01/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20202B540	List: ML20202B537 ML20202B551
References
70-7002-97-13, NUDOCS 9802120047
Download: ML20202B551 (34)

Text

-. ,

U.S. NUCLEAR REGULATORY COMMISSION -

REGION lil Docket No: 070-07002 Report No: 070-07002/97013 (DNMS)

Facility Operator: . United States Enrichment Corporation Facility Name: Portsmouth Gaseous Diffusion Plant ,

Location: 3930 U.S. Route 23 South P.O. Box 628 Piketon, OH 45661 Dates: December 8,1997, through January 9,1998 Inspectors: K. G. O'Brien, Senior Resioent inspector J. R, Davis, Criticality Safety inspector .

R. G. Krsek, Fuel Facility inspector S. Larcon, NRC Contractor

- Approved By: Patrick L. Hiland, Chief Fuel Cycle Branch Dwision of Nuclear Materisis safety -

9902120047 PDR 980204 ADOCK 07007002 PDR

_ _ _ - - - _ - _ a

Executive Summarv United States Enrichment Corporation

' Portsmouth Gaseous Diffusion Piant NRC Specialinspection Report 070 07002/97013 (DNMS)

Nuclear Criticality Safety Operations

• The inspectors determined that the certificant failed to ensure the proper implementation of b-)th nuclear criticality safety approval contingencies intended to preclude the introduction of recirculating cooling water into Cell 2g-5-8 in Building X-330, a cell containing a greater than critical mass, during the period March 3, to November 4, igg 7.

(Section 01.1)

+ - The inspectors identified that nuclear criticality safety procedures did not address the plant staff's response to the loss of a nuclear criticality safety approval control or the actions necessary to restore the control, as required by the Technical Safety Requirements. (Section 01.2)

T

+ The inspectors identified that the certificant failed to use material labels or area postings to specify procedural controls for nuclear criticality safety in Building X-710 As a result, nuclear criticality safety procedural controls were violated on several occasions, (Section 01,3)

+ The inspectors identified four separate incidents where the plant staff failed to properly implement one of two required nuclear criticality safety approval controls, in addition, the inspectors identified an instance when incorrect information was provided to plant staff by a nuclear criticality safety engineer which precluded, for one day, the staff's recognition that an activity was being conducted in violation of both the required nuclear criticality safety approval controls, (Section 01 A)

Nuclear Criticality Safety Enaineerina .

+- The inspectors determined that required training had not been defined or conducted to ensure that the nuclear criticality safety manager had the requisite knowledge to fulfill the assigned nucioar criticality safety responsibilities, (Section E5.1)

• The inspectors determined that Safety Analysis Report qualification requirements for nuclear criticality safety engineers were not property incorporated into nuclear crithality safety procedures and that vialvers to the requirements were given without documented justification. (Section E5.2)

• The inspectors determined that the nuclear criticality safety manager did not ensure that contractor staff had successfully completed and properly documented training as specified in plant procedures. (Section E5.3) t 2

_ _ _ . a

+ The inspectors determined that the intemal criticality safety self assessment programs lacked the specific guidance and technical criteria necessary to clearly define appropriate methods by which to determine the effectiveness of implementation of nuclear criticality safety controls. (Section E6.1)

+ The inspectors identified that the independent self assessment program did not correctly determine the effectiveness of the nuclear criticality safety intemal assessment programs as demonstrated by the existence of long standing differences between plant operations and nuclear criticality safety evaluations and approvals; long standing differences between plant procedures and the Safety Analysis Report requirements, and; the routine recurrence of nuclear criticality safety deficiencies, as documented by the plant problem reporting system. (Soction E6.2)

. The inspectors determined that the plant staff did not systematically evaluate recent nuclear criticality safety-related issues categorized as significant conditions adverse to quality. As a result, all causes for the issues were not identified and corrective actions were not proposed to preclude recurrence of the issues. (Section E7.1)

The inspe,ctors detemiined that tabletop reviews and operating procedure walkdowns were not conducted in accordance with an approved plant procedure, in addition, the instructions used for the walkdowns and tabletop reviews did not include a mechanism to document and assure that potentially generic root causes were incorporated into the nuclear criticality safety approva! m.1 operating procedure reviews. (Section E7.2)

. The inspectors determined that the N n.Guse evaluation and corrective actions to a previous violation were narrowly focused and not effective. (Section E8.1) 3 a

i.

t Report Details 01 Conduct of Operations 01.1 - Uranium Deposit in Buildina X 330. Cell 29-5-8

a. Insoection Scope (88020)

- The inspectors reviewed the circumstances which led to the discovery of a uranium

- deposit in Building X 330, Cell 29 5 8, which had not been maintained in accordance with the applicable nuclear criticality safety evaluation and approval requirements.

b. Observations and Findinas on November 3,1997, the certificant made a 4-hour NRC Bulletin 91-01 mport to the NRC Duty Officer following the discovery that both nuclear criticality safety contingencies for a cascade cell had been violated. Specifically, the operators identified: 1) that the recirculating cooling water (RCW) condenser drain valve for cascade Cell 33-8-9 was closed, aryd; 2) that the coolant system froon pressure was not greater than both the cell and RCW system pressures. Following identification of the problem, the plant staff took action to open the drain valve and verified that the cell did not contain a known urar,Ium deposit in excess of the safe mass. The 4-hour report indicated that completion of the two response ections retumed the operation to compliance with the nuclear criticality safety contingency requirements.

The inspectors reviewed the Bulittin 91-01 report and the associated nuclear criticality.

safety evaluation (NCSE) and nuclear criticality safety approval (NCSA). The inspectors determined that the NCSA required both the RCW drain valve to be open and the coolant-system to be pressurized to a pressure greater than either the cell or RCW system pressure to restore contingency compliance. The inspectors noted the Technical Safety Requirement (TSR) for moderation control of singularly contingent systems would require 1 the restoration of only one of these two contingencies to achieve contingency compliance.

The NCSA categorized the cell RCW system as a doubly contingent system.

On November 4i 1997, the certificant made a second NRC Bulletin 91-01 report following

. the discovery that 14 additional cascade cells had closed RCW condenser drain valves.

In addition, the report indicated that Cell 29 5-8 in Building X-330, also contained a uranium deposit larger than the always safe mass. The report further stated that corrective actions would include opening the drain valves and stopping all other cell treatment activities. The inspectors reviewed the NCSA associated with the cells and concluded that the immediate corrective actions did not restore both contingencies relied upon in the NCSA. The inspectors also determined that completion of the stated actions would only restore compliance of those aspects of cell moderation control that were singularly contingent and therefore covered by the TSR for moderation control. The cascade cell NCSA identified the RCW system as doubly contingent system.

As a followup to the Bulletin 91-01 report, the inspectors reviewed the circumstances that led to the situation reported on November 4,1997. The inspectors determined that Cell 29-5-8 was removed from service in May 1995 in order to perform maintenance on the RCW supply control valve. Through a review of the paperwork that directed the control 4

.. . . . . . J

V valve maintenance, the inspectors concluded that the cell was isolated and evacuated, the freon was removed from the condenser, and the RCW side of the condenser was isolated and drained. The inspectors noted that the system isolation process did not control the condenser drain valve position. The inspectors also concluded that all but two '

of the bolts for the RCW supply control valve had been removed. However, the RCW supply control valve was left in the system with a slight gap between the matt flanges.

The inspectors determined that the as left configuration would limit the pressure and amount of RCW water that could be trapped in the condenser without being noticed by operators during routine rounds. However, RCW could also enter the condenser through a leak in the RCW discharge valve; though the RCW system outlet pressure was only slightly greater than atmospheric pressure.

Shortly after the system was removed from servios, management decided to place the cellin a semi-permanent shutdown status. The inspectors reviewed maintenance and operator logs associated with the shutdown activities and concluded that the work instructions did not direct or require that the RCW drain valve be left in the open position, in October 1996, the plant staff developed and implemented an NCSA fer the Building X-330 cascade cells. The NCSA indicated that the RCW system was Loubly contingent with the two contingencies being, in part, that: 1) the cooldnt system pressure was maintained greater than both cell and RCW system pressures, and; 2) the RCW condenser drain valve was maintained open when the condenser was emptied. The laspectors noted that both operations and engineering procedures also required system walkdowns when new or revised NCSAs or NCSEs were implemented. However, the inspectors concluded that the walkdown requirement was either inadequate or was not performed, based upon the closed condenser drain valves identified in November 1997.

In March 19g7, the plant staff performed a non-destructive analysis (NDA) of Cell 29-5-8 and determined that the cell contained a uranium deposit larger in size than the always safe _ mass. The planned expeditious handling (PEH) deposit was estimated to be .

approximately 5 times larger than the minimum critical mass for the enrichment involved.

Based upon the NDA results, the plant staff took the actions required by TSR 2.7.3.14,

" Moderation Control," for a singularly contingent system with a " planned expeditious handling" deposit. - A

• planned expeditious handling" deposit was defined as a deposit

- with a mass greater then the always safe mass. The inspectors concluded that the staff's response was correct for those aspects of co'l moderation control that were singularly contingent; however, the response actions did not assure full compliance with the applicable NCSA which classified the RCW system as doubly contingent.

The inspectors reviewed the actions taken in March 1997 with some current plant shift supervisors (PSSs) and others. The interviewees informed the inspectors, almost without exception, that the TSRs described all of the response actions required following the discovery of a PEH deposit in the cascade. Also, most of the staff indicated that they would not consider it necessary to review or reference the applicable NCSA to ensure that other NCSA specified actions were completed. The inspectors concluded that the operations staff interviewed did not fully understand the TSR fc moderation control or the cascade NCSAs, 5

____ L

4 On September 5,1997, the plant staff took edion to remove the PEH deposit from Cell 29 5-8. During the removal activities, the plant staff determined that the deposit was located in both the compressor and the inlet piping. As a result, only a portion of the deposit was removed. The remainder of the deposit was reclassified as a new PEH deposit and the response clock was reset for the development of a removal plan.- The inspectors noted that throughout the removal process, none of the plant staff identified that the cell RCW system was considered doubly contingent or that the condenser drain valve was required to be open. Operations staff took no further actions relative to Cell 29 5-8 until the closed condenser drain valve was identified on November 4,1997.

In October 1997, a second change was made to the cascade NCSA and NCSE applicabie to the Building X-330 cells. The NCSA continued to identify the RCW system as doubly contingent. The two nuclear criticality safety contingencies were, in part, that:

1) the coolant (froon system] pressure shall be maintained above both the UF. [ uranium hexafluoride system) and RCW [ recirculating cooling water system) pressures, and; 2) the RCW supply to the affected cell shail be valved off, the condenser drained, and the drain valve left open. The inspectors again noted that other operations and engineering-procedures required a system walkdown of all new or revised NCSAs and NCSEs prior to implementation. The inspectors concluded that the as-found November 3,1997, configuration of some shutdown Building X-330 cells, including Cell 29 5-8, indicated that the walkdowns, if conducted, were ineffective.

Technical Safety Requirement 3.11.2, requires, in part, that all operations involving uranium enriched to 1,0 weight percent or higher U 235, and 15 grams or more of U-235 shall be based upon a documented nuclear criticality safety evaluation and shall be performed in accordance with a documented nuclear criticality safety approval. Nuclear Criticality Safety Approvals NCSA-0330404.A00, dated October 21,1996, and NCSA-0330-004.A001, dated October 24,1997, entitled, " Cascade Operations in the X-330 Building," required, in part, that the following two controls shall be implemented and maintained in order to preclude the introduction of recirculating cooling water into the cascade: 1) the coolant [ freon system) pressure shall be maintained above both the UF,

[ uranium hexafluoride system) and RCW [ recirculating cooling water system) pressures, and 2) the RCW supply to the affected cell shall be valved off, the condenser drained, and the drain valve left open for cells shut down and with the R-114 [ freon) removed from the cell. The failure to maintain: 1) the coolant system pressure greater then the cell and RCW system pressures, and; 2) the drain valve open for Cell 29-5-8 in Building X-330 from March 3 to November 4,1997, is an apparent Violation (eel 070 07002/97013 01).

c. Conclusions The inspectors determined that the certificant failed to ensure the proper implementation of both nuclear criticality safety approval contingencies intended to preclude the introduction recirculating cooling water into Cell 29 5-8 in Building X-330, a cell containing a greater than critical mass, during the period of March 3 through November 4,1997. In addition, the inspectors determined that some operations and management staff were not aware that the cascade recirculating cooling water system was considered a doubly contingent system.

6

_____m____.-__m.____ ._

01.2 The Response _ of Plant Staff to a loss of Nuclear Criticality Safety Aporoval Controls

a. Inspection Scope (88020)

The inspectors observed the Plant Shift Superintendent (PSS) and plant staffs response to the loss of one or both NCSA relied upon controls, in addition, the inspecters discussed management guidance provided to the staff relative to their response to the loss of one or both NCSA relied upon controls,

b. Observations and Findinas During facility walkdowns and tours, the inspectors observed the plant staffs identifcation and response to the loss of criticality controls in Buildings X-710 and X 330. The inspectors also discussed with plant staff, assigned to other process buildings, their response to the discovery that an NCSA control had been lost. The plant staff indicated that response actions were typically taken immediately upon the identifmation that an NCSA contro' had been lost. In addition, the response actions did not have to receive prior review by NCS staff or management. Some plant staff in Buildings X-710, X 330, and X-326, indicated that they were unaware of specific procedural guidance that defined the course of action to be taken following discovery that an NCSA control was not in effect. In addition, the plant staff interviewed were not sure if or when NCS staff would be involved in response actions.

A majority of the plant staff interviewed by the inspectors indicated that the PSS, once notified of an NCSA non-conformance, was responsible for contacting NCS staff.

However, the inspectors noted that the plant staff normally did not notify the PSS of NCSA nonconformances until after the response efforts, including restoration of the control, were complete. The inspectors also noted that some staff were unaware that, in certain scenarios, the uncontrolled restoration of an NCS control could be detrimental to worker safety.

Based upon the discussions with plant staff, the inspectors reviewed the NCS procedures to determine what guidance management had provided for the plant staffs response to the loss of NCSA controls. Procedure XP2 EG-NS1031, " Nuclear Criticality Safety,"

Revision 0, dated March 3,1997, Section 5.13 requimd, in part, that if an NCS problem report was submitted to the PSS, [the PSS] shall notify the NCS manager or an identified altemate. However, the procedure did not define the timeliness for the notification or specify who to contact in the event the manager was unavailable. In addition, the procedure did not delineate or preclude other response actions by either the PSS or plant staff. The inspectors noted that the procedure did address the plant staffs emergency response to a nuclear enticality safety accident.

During further discussions with some of the PSS staff, the inspectors were informed that the PSS staff maintained an NCS contact list that included both the NCS manager and attemates. However, the PSS staff also indicated that the advice received from NCS staff was sometimes inconsistent with guidance provided previously for a similar situation or provided by another NCS staff member.

7

_ _ __o

a Nuclear Regulatory Commission inspection Report 070 07002/97-203, dated June 27, 1997, included an inspection follow-up item (IF1) which previously documented that no plant wide policy exis%d which defined the appropriate response actions to the discovery of an NCSA non-compliant condition (IFl 070-07002/97 20312). The inspection report also included a commitment by the NCS manager to a review the issue to ensure that all Safety Analysis Report and American National Standards institute (ANSI) Standard 8.20,

" Nuclear Critica!ity Safety Training," requirements were met.

The inspectors reviewed the two corrective actions approved by plant management in response to the IFl. The corrective actions included: 1) NCS staff authored and printed an article in the July 23,1997, plant newspaper, "The Open Line," entitled, " Guidance for Employee Response to NCS Violt.tions," and; 2) the information and prescribed actions in the Open Line adicle were added to p; ant staff general NCS training and highlighted plant staff responses to NCSA violations. The article discussed three scenarios involving the loss of NCSA controls and provided guidance regarding the plant staff's response to the scenarios. The corrective actions were completed on October 31,1997.

During follow-up discussions with the inspectors, NCS management indicated that an NCS procedure, prescribing the essential actions or steps plant staff and the PSS should talte to safely and consistently respond to the loss of NCSA controls, did not exist. In addition, NCS management concurred with the inspectors assessment that some responses to the loss of an NCSA control required immediate guidance from qualified NCS staff to ensure the continued safety of plant staff.

Technical Safety Requirement 3.11.1 requires, in part, that an NCS program shall be established, implemenied, and maintained as described in the Safety Analysis Report.

Safety Analysis Report Section 5.2.2, " Nuclear Criticality Safety Program Elements,"

required, in part, that NCS procedures shall address the response to the loss of a nuclear criticality safety approval control.' Thc failure, from March 3 to December 12,1997, to develop and implement Nuclear criticality safety procedures to address the response to the loss of a nuclear criticality safety approval control and subsequent restoration of the controls is an Apparent Violation (eel 070-07002/97013-02),

c. Conclusions The inspectors identified that nuclear criticality safety procedures did not address the

- plant staff's response to the loss of a nuclear criticality safety approval control or the

- actions necessary to restote the control, as required by the Technical Safety Requirements The inspenrs also determined that some plant staff were unsure when and under which scenarion , :nvolving the loss of a nuclear criticality safety approval control, nuclear criticality safety ctaff should be contacted.

01,3 Implementation of Administrative Practices for Nuclear Criticality Safety

a. Inspection Scope (88020)

The inspectors reviewed several operations which relied upon administrative nuclear criticality safety controls as defined in nuclear criticality safety approvals and operating procedures.

8 J

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

I

b. Observations and Findinos During walkdowns of Building X 710 operations, the inspectors observed several areas where fissile or potentially fissile material was used and stored subject to the NCS controls specified in Procedure XP3-TS-TS1050, " Laboratory NCSA Commitments." The areas did not include postings or material labelings which specified the limits on parameters subject to the procedural NCS controls used to enhance the reliability of the - l administrative NCS controls. Some of the areas identified were:

. hallway between rooms 120 and 135 which were used fer the daily storage for dry activated waste (DAW); _

.- rooms 120,135,138,142, and 157 which were used for the storage of poly-bottles containing potentially fissile materials; _

• room 135 which had sample containers of Gssile waste solutions stored throughout the room on laboratory benches, and;  ;-

. room 142 which was used to store the mobile uranium hexafluoride monel sample can cart, i

The inspectors noted that several recent incidents were identified in Building X-710 that a involved the loss of nuclear criticality safety approval contrMs. The incidents were identified as the result of independent walkdewns of building fissile operations as directed ,

by the Production Support Manager. Many of the incidents documented during the period of December 4 through Dacomber 9,1997, involved the loss of controls included in administrative procedures, such as spacing limitations. During walkdowns of other buildings, the inspectors identified other areas used to store fissile materials subject to administrative or procedural NCS controls. The inspectors noted that the relied upon controls were not highlighted on a material label or posted in the areas.

Technical Safety Requirement 3.11.1 requires, in part, that a nuclear criticality' safety l program shall be established, implemented, and maintained as described in the Safety l Analysis Report. Safety Analysis Report Section 5.2.2.1, required, in part, that the )

nuclear criticality safety program shall comply with the American National Standards -1 Institute /American Nuclear Society (ANSI /ANS) Standard 8.191984, " Administrative Practices for Nuclear Criticality Safety." Section 9.1 of ANSl/ANS Standard 8.19-1984,

required, in part, that appropriate material labeling and area postings shall be maintained specifying material identification and all limits on parameters that are subject to procedural controls. The failure, from March 3 through December 12,1997, to ensure that appropriate material labeling and area postings, specifying material identification and all limits on parameters subject to procedural controls for activities in Building X 710 is an Apparent Violation (eel 070-07002/9701343).-- Specifically, area postings of limits on -

parameters subject to the nuclear criticality safety controls specified in Procedure XP3-TS-TS1050, " Laboratory NCSA Commitments," were not maintained for the various fissile and potentially fissile operations and storage areas highlighted above,

c. Conclusions The inspectors identified that the certificant failed to implement a basic requirement specified in ANSl/ANS 8.19-1984. Specifically, the certificant failed, on several 1-instances, to use material labels or area postings to specify procedural controls for i 9

i l

-- +

j_ nuclear criticality safety in Building X 710 as highlighted in Procedure XP3 TS TS1050,

" Laboratory NCSA Commitments."

01.4 Implementation of Nuclear Criticality Safety Approval . Reauirements

a. Inspection Scope (88020)

-The inspectors observed ongoing implementation of nuclear criticality safety approval requirements in Buildings X 710 and X 330,

b. Observations and Findinos On December 4,1997, the Production Support Manager instructed Building X 710 laboratory staff to review Parts A and B of all NCSAs applicable to laboratory fissile material operations, in addition, the laboratory staff performed a walkdown of each NCSA operation description and the associated NCSA controls. The reviews and walkdowns resulted in a number of NCS issues during the week of December 4,19g7, and tho' subsequent weekend. As a result, the PSS initiated an informal stop work ore,c for Building X,-710. The informal stop work direction was lifted on Monday, December 8, following laboratory staff briefings on the walkdown findings and the interim corrective actions. On December 8 and 9, NCS engineers were assigned to Building X.710 to resolve the staff questions on the NCSAs and ongoing operations.

The inspectors accompanied the NCS engineers during their activities in Building X-710 and observed the resolution of the staff's questions. The inspectors determined that the NCS engineers' responses were generally adequate. However, on one occasion the NCS engineer's response was determined to be inaccurate, Specifically, a laboratory staff member questioned the need to include a waste collection bottle, used for an atomic absorption unit in room 138, in Part A of the associated NCSA. The NCS engineer immediateh responded that the bottle in question was already addressed by NCSA-PMNT006, and ndicated that a need did not exist to include the bottle in Part A of another NCSA. The NCS engineer also highlighted that the waste collection bottle was

. required to be capped per NCSA-PLANT 006 and that the current condition of the waste collection bottle was inconsistent with the applicable NCSA controls.

The inspectors performed a verification of NCSA-PLANT 006 and determined that the NCSA was not applicable to room 138 operations. The inspectors communicated the review results to the cognizant NCS engineer, During a subsequent reevaluation of the question, the NCS engineer determined that the inspectors assessment was correct and

. further concluded that the activities conducted in room 138 were controlled under NCSA-PLANT 045. Specifically, NCSA-PLANT 045, Control A, required, in part, that the volume for a container used to collect waste shall be less than a nomina' volume of 1-Liter (1.25 Liters). Control B, required, in part, that a second operator or supervisor shall verify that the correct volume container was utilized.

The NCS engineer provided the revised information to the involved laboratory staff.

Shortly thereafter, the laboratory staff identified that the waste storage bottle was 2 liters in volume, a violation of NCSA-PLANT 045, Control A. In addition, the laboratory staff indicated that a second operator or supervisor had not verified that the correct volume container was used, a violation of NCSA-PLANT 045, Control B. Subsequent to the 10

laboratory staff's identification of the nonconformances, a timely NRC Bulletin g101 report was made to the NRC (NRC Event Notification No. 53374).

During walkdowns of Building X-330 NCSAs and reviews of operating procedures with '

plant staff on December 10 and 11, the inspedors identified four separate violations of NCSI. controls.' Each of the findings were communicated to plant staff and immediate actions were taken to verify the inspectors' observations and to restore the lost NCSA controls. The inspectors findings were as follows.

1. NCSA-PLANT 011, Control B, item 6, required, in part, that all other uranium bearing material, including other [high efficiency particulate absorption (HEPA) ventilation) units, shall be kept at least two feet edge-to-edge from the [HEPA ventilation) unit. During a walkdown, the inspectors identified that two HEPA ventilation units were stored on the cascade floor, next to each other, with less than a one-foot spacing between the two units.

Additionally, NCSA PLANT 011, Part B, Itom b, mquired, in part, that the HEPA ventilation units shall have a sign which displas 4 3e NCS controls for the HEPA ve.ntilation units. The inspectors identified that ole of the HEPA ventilation units did not have a sign as described in Part B, item 8. In addition, the second HEPA ventilation unit had a sign which was not in accordance with the requirements of item 8. The two-feet spacing requirement was property highlighted on the incorrect sign.

Following identification of the findings, the Inspectors communicated the information to building staff, Later that same day, the staff indicated to the inspectors that the NCSA controls had been property restored, However, the inspectors noted on a subsequent tour of the area that the spacing control had not been addressed. Instead, the staff had focused on and corrected only the sign inconsistencies. Through discussions with the involved building and NCS staff, the inspectors determined that the building staff did not inform or request the assistance of NCS staff during their resolution of the inspectors' findings.

Plant staff property reported the findings within the appropriate time requirements,

- (NRC Event Notification No. 33387)

2. - NCSA-PLANT 018, Control A, item 5, required, in part, that a minimum spacing of two-feet edge-to-edge must be maintained between dry active waste containers and other types of uranium bearing equipment or materials, prior to nondestructive assay surveys of the dry active waste containers. The inspectors identified that several uncharacterized 55-gallon drums of dry activated waste were stored less than one-foot from several uncharacterized 55-gallon drums of contaminated

- scrap metal. The drums were property located in a waste storage area on the ground floor of Building X-330.

The inspectors communicated the findings to plant staff who subsequently verified the findings, initiated corrective actions, and properly reported the findings within the appropriate tiine requirtments. ',NRC Event Notification No. 33383) 11

E 3.. NCSA PLANT 064, Control A, item 11, required, in part, that a minimum four feet edge to edge spacing must be maintained between groups of compressor seals.

The inspectors identified that two groups of compressor seals, stored in a seal cago on the Building X 330 cascade floor, were within the minimum four-feet spacing specified in the NCSA.

Plant staff verified the inspectors' findings, initiated corrective actions, and made a timely report of the findings. (NRC Event Notificat!on No. 33382)

4. NCSA PLANT 048, Control A, item 10b, required, in part, that a minimum spacing of two-feet edge-to-edge must be maintained between contaminated metalitems and all other contaminated items. On December 11, the insportors identified that at least ty;o sets of two contaminated metalitems were stored with less than two-feet of spacing between the contaminated metalitems. The inspectors also observed that no postings or labelings highlighting the NCSA controls for contaminated metal stored in the area were pror'at. The inspectors also noted that NCSA-PLANT 048, Part B, item 18 only required signs highlighting NCS controls for "long-term

• contaminated metal storage areas.

Plant ' staff vertfied the inspectors' findings, initiated corrective actions, and made a timely report of the findings, (NRC Event Notification No. 33395)

Technical Safety Requirement Section 3.11.2, requires, in part, that all operations involving uranium enriched to 1.0 weight percent or greater in U 235 and 15 grams or more of U-235 shall be based upon a documented nuclear criticality safety evaluation and shall be performed in accordance with a documented nuclear criticality . safety approval.

The failure to conduct the above described activities in Buildings X 330 and X-710 in -

accordance with the applicable nuclear criticality safety approvals is an Apparent Violation (eel 070-07002/9701344),

c. Conclusions The inspectors identified four separate incidents where the plant staff failed to property implement one of two required nuclear criticality safety approval controls, in addition, the inspectors identified an instance when incorrect information was provided to plant staff by a nuclear criticality safety engineer which precluded, for one day, the staff's recognition that an activity was being conducted in violation of both the required nuclear citicality safety approval controls. The plant staff took appropriate corrective actions and property reported each example of inadequate implementation of nuclear criticality safety approval controls in accordance with NRC Bulletin 91-01.

12

d I'

l E5 Nuclear Criticality Safety Trainina Deveicoment and implementation E5.1 - Nuclear Criticality Safetv Manaaer Qualifications

a. Inspection Scope f88015)

The inspectors reviewed the responsibilities of and training required for the position of nuclear criticality safety manager, in addition, the inspectors reviewed the experience, background, and training for the current nuclear criticality safety manager,

b. Observations and Findinas The inspectors reviewed the Safety Analysis Report and noted that the NCS manager responsibilities were described in Section 5.2 as administration of the NCS program which included:

• reviewing the overall effectiveness of the NCS program;

+ ortsuring that criticality safety staff members are placed, trained, and qualified in accordance with written procedures;

• NCS evaluations and NCS approvals are prepared and technically reviewed by qualified NCS personnel; and,

. waiving NCS staff qualification requirements for those individuals who are determined to have appropriate knowledge and skills in the NCS functional area.

The inspectors also noted that several procedures defined additional NCS manager responsibilities that were not contained in the SAR. Specifically, Procedure XP4-EG-NS1102, " Nuclear Criticality Safety Personnel Qualification," Revision 1, dated May 1, 1997; Procedure XP4 EG-NS1101, ' Nuclear Criticality Safety Walk-Throughs,"

Revision 0, dated March 3,1997, and; Procedure XP2-EG-NS1031, ' Nuclear Criticality Safety," Revision 0, March 3, igg 7, defined the following additional NCS manager responsibilities:

. modifying NCS qualification requalification requirements as new challenges in NCS are identified or new knowledge becomes available;

. reviewing, discussing, and correcting NCS-specific exercises related to qualifying personnel as senior NCS engineers;

• managing the NCS Walk-Through Program including determining NCS risk and assigning frequency reviews, trending of NCS-related problems and corrective actions, and ensuring the walk-throughs are completed by qualified personnel;

. providing iJCS guidance and direction involving emergency response, safety analysis, configuration control of equipment and processes, and;

. providing the PSS a list of qualified senior NCS engineers that are eligible to serve in the capacity of NCS manager during the manager's absence.

13 l

Based upon a review of the SAR and the procedures, the inspectors concluded that the SAR did not provide a complete summary of the NCS manager responsibilities. However, the inspectors determined that many of the NCS managers procedurally assigned responsibilities were components of duties assigned in Chapter 1 of the Safety Analysis Report to the Nuclear Safety manager, the NCS managers supervisor. The inspecto s noted that the SAR included educational, experience, and training requirements to ensure that the Nuclear Safety manager was able to perform the assigned responsibilities.

However, management had not oefined which of the educational, experience, or training requirements the NCS manager needed in order to effectively perform the delegated responsibilities. Management's failure to define the educational, experience, and training requirements necessary for the NCS manager to effectively assume significant responsibilities of the Nuclear Safety managerwas considered a weakness. 1 The inspectors also reviewed the background, experfsnce, and training of the current NCS manager. Through discussions with the NCS manager, the inspectors determined that the individual had an engineering degree; however, the manager previously had not been involved in nuclear criticality safety activities at either the NCS engineer, senior engineer, or manager levels, in addition, the inspectors noted that the individual had not received any specific training related to the position of NCS manager since appointment

~

to the job l In recognition of these seN-identified knowledge and training deficiencies, the NCS manager, upon appointment to the position, voluntarily re-assipied responsibility for management review of NCSEs and NCSAs to a sonict NCS engineer. The inspectors determined that the managers actions appeared appropriate and safety-focused; however, the actions were not procedurally authorized.

Technical Safety Requirement 3.3, Tacility Staff Qualification," requires, in part, that facility positions are filled with persons whose experience and/or training qualify them for their respective positions. Safety Analysis Report Section 5.2.2.2, required, in part, that 3 managers are trained in nucl6ar criticality safety and that the training provides personnel with the knowledge necessary to fulfil their nuclear criticality safety responsibilities. The failure, as of December 11, to establish and conduct training required to ensure that the nuclear criticality safety manager had the requisite knowledge to fulfill the assigned nuclear criticality safety responsibilities is an Apparent Violation (eel 070 07002/97013-05).

c. Conclusions The inspectors determined that required training had not been established or conducted to ensure that the nuclear criticality safety manager hac Se requisite site-specific knowledge to fulfill the assigned nuclear criticality safevj;esponsibilities, in addition, the inspectors concluded that some of the nuclear safety managers responsibilities had been delegated to the nuclear criticality safety manager without definition by management of the education, experience, and training necessary for the successful completion of the assigned responsibilities.

14

i E5.2 Nudear Criticality safetv Staff Qualifications

a. Insnection Socce (88015)

The inspectors rev' owed the experience, background, ar.d training for nuclear ortticality safety permanent staff members to ensure that only quellflod staff developed new or revised safety analyses, reviewed new or rr lised operating procedures, and provided plant staff advice and guidance on the implementation of nuclear criticality safety requirements.

= b. Chamatierij and Findinas The inspectors reviewed the SAR and noted that the NC8 staff qualifications were described in Section 5.2. NC8 management documented and tracked the completion of the qualmcations, in part, using plant Procedure XP4 EG N81102, " Nuclear Criticality Safety Personnel Quellfloation,* Revision 1, dated May 1,1997. The inspectors reviewed the procedure and determined that the procedure doveted from the SAR speomed training and qualification requirements. Spoo6fically, the procedure allcwed the NC8 manager to que'ify individuals as NC8 engineers without first performit.) four safety evaluations under the supervision of a qualmed senior NCS engineer. In addition, the procedure was unclear as to the documentation required to justify and authorize changes to the qualification cards. Sp6cifically, Section 6.3.4 of the procedure appeared to allow the NCS mar.ager to delete or add tasks to the qualmcation card depending on changes in nuc!ser criticality safety information and Individual job requirements without a documented justification. However, Section 5.1.4 of the procedure and the SAR required that any modification to the qualification requirements must be formalized and supported by a written statement giving th9 rationale or justification for making the modification.

.The inspectors reviewed training qualification cards for the six permanent NC8 staff against the SAR requirements and determined that three NCS staff members did not meet the SAR training requiremenis. Deficiencies noted in the qualification card recorded training included: 1) the failure to independently nerform four safety evaluations under the supervision of a quailflod senior NCS engineer,2) unapproved or ur justified waivers from some of the training requirements, including the minimum number of years of basic NCS experience, and; 3) undocumented general and specialized educational socomplishments. The inspectors determined that the qualification card doncienci6s were consistent with inaccuracies identified in the NC8 Procedure AP4 EG NS1102,

• Nuclear Criticality Safety Personne! Qualification."

Finally, the inspectors identified an apparent oeficiency in both the SAR and the plant procedures. Specifically, the SAR and plant procedures authorized the NCS manager to waive the minimum qualification requirements for plant specific operations familiarization -

and experience. Such an action by the NCS manager could allow an individual, unfamiliar with the plant processes and methodologies, to perform safety analyses and to provide generic NCS advice to plant staff in conflict with plant specific policies and procedures, resulting in a reduced safety margin or an increased potential for an NCS incident. The inspectors communicated this apparent deficiency to plant management for

- their review and resolution, as necessary.

15

Technical Safety Requirement 3.11.1, requires, in part, that a criticality safety program shall be established, implemented, and maintained as described in the Safety Analysis Report. Safety Analysis Report Section 5.2.2.3, required, in part, that a qualified nuclear criticality safety engineer shall have performed ut least four nuclear criticality safety evaluations under the direction of a sen;0r nuclear criticality safety engineer.

Section 5.2.2.3 also allowed the nuclear critict!!ty afety manager to modify the qualification requirements for nuclear criticality safety engineer qualification candidates that have worked for a minimum of three consecutive years or for senior nuclear criticality safety engineer qualification candidates who have v ted for a minimum of five consecutive years at other facilities as a nuclear crit.: slity safety engineer provided written justification is provided. The fal'ure, as of December 11,1997, to ensure that all nuclear criticality safety engineer qualification candidates had, prior to their certification :

1) performed the requ; red minimum number of nuclear criticality safety evaluations under the supervision of a senior nuclear criticality safety engineer, and; 2) the required minimum number of years or nuclear criticality safety experience is an Apparent Violation (eel 070-07002/97013 06),

c. Conclusions The inspectors determined that Safety Analysis Report qualification requirements for nuclear criticality safety engineers were not property incorporated into nuclear criticality safety procedures and that walvers to the requirements were given without documented justification. As a re;Jt, some engineers did not meet the Safety Analysis Report training requirements. In addition, the inspectors identified an apparent deficiency in both the Safety Analysis Report and plant procedures that would allow an individua! to become qualified as a nuclear criticality safety engineer without famillarity or training on site specific policies, practices, or procedares.

E5.3 Nuclear Criticalits uafety Contractor Staff Qualifications

a. Inspection Scope (8801Q)

The inspectors reviewed the experience, background, and training for nuclear criticality safety contractor staff to ensure thnt only qualified staff were authorized to perform nuclear criticality safety-related activities,

b. Observation and Findinas Nuclear Criticality Safety Procedure XP4 EG NS1102,' Nuclear Criticality Safety Personnel Qualification,' Revision 1, dated May 1,1997, specified the required minimum training for nuclear criticality safety contractor staff. The inspectors compared the procedural requirements with qualification cards and other documentation provided by the NCS manager to demonstrate that all current contractor staff were app.opriately tralned and qualified. Based upon a review of the materials, the inspectors t'etermined that only one of the five NCS contractor staff met the site specific qualification requirements.

Following completion of the inspectors' review, the NCS manager provided a supplemental correspondonce from the Paducah Gaseous Diffusion Plant conceming one additional contractor staff. The inspectors reviewed the supplemental correspondence and concluded that the document did not provide sufficient or specific formalinformation required to qualify the contractor based upon the procedural requirements.

16 1

During subsequent discussions with the NCS manager, the manager 'ndicated that the contractor staff did not p. ovide direct NCS guidance or advice to plc 'taff or perform the functions of qualified NCS cngineer, instead, the NCS manager' ur aed that the contrac' ors always work with a qualified NCS engineer or under t..; direct supervision of i a senior NCS engineer. However, the inspectors identified a contractor staff member providing NCS guidance to operations personnel on several occasions. In addition, the inspectors determined that an unqualified NCS summer intem was assigned primary responsibility for the conduct of the annual NCS self assessment surveillance of the Chemical Operations Group [POEF 77197 82,"1997 Annusi Self Assersment for the Chemical Operations Group," September 9,1997) without the direct guidance or oversight of a qualified NCS engineer.

Technical Safety Requirement 3.11.1 requires, in part, that the nuclear criticality safety program shall be established, implemented, and maintaint,d as described in the Safety Analysis Report. Safety Analysis Report, Section 6.2.2.2,

• Nuclear Criticality Safety Responsibilities," required, in part, that managers shall ensure that all appropriate personnel receive nuclear criticality safety training as specified in plant procedures. Plant Procedure XP4 EG NS1102,

• Nuclear Criticality Safety Personnel Qualification,"

Revision 1 dated May 1,1997, required contractor personnel to complete training equivalent w qualified nuclear criticality safety walk through team members, engineers, and senior engineers. The failure, es of December 11,1997, to ensure that four nuclear criticality safety contractors had successfully completed and property documented site-specific qualification training, as specified in Procedure XP4 EG NS1102, is an Apparent Violation (eel 070-07002/97013-07).

c. Conclusions The inspectors determined that the nuclear criticality safety manager did not ensure that contractor staff had sut.cessfully completed and property documented treining as specified in plant procedures, in addition, the inspectors identified severalinstances where unqualified contractor staff performed activities requiring cualification as a nuclear criticality safety walk ihrough team member, engineer, or senior engineer.

E6 Nuclear Criticality Safety Program Management and Administrative Practices E6.1 Nuclea Criticality Safety Manaaement Self Assessment Proarams

a. Inspretion Scone (88015)

The inspectors reviewed the structure, implementation, and effectiveness of the management self assessment programs including: 1) the Management By-Walking-Around program; 2) the Nu:: lear Criticality Safety Group Self Assessment Program, and;

3) the Organization Self Assessments Program.

17 j

b. Observations and Findinas Mananoment 8v Walkino-Around Proaram Plant Procedure XP2 0A-QAir 32,

• Management By Walking Around,' Revision 0, dated March 3,1997, (formeriy UE2 MC-QA1033) defined the Management By Walking Around (MBWA) program, Section 1.1 of the procedure stated, in part, ; hat the MBWA program provided managers with a focused and directed method of observing specific performance attributes, to ensure the effectiveness of management activities were monitored and reported. Section 6.6 further stated that each inspectio1, shallinclude a detailed walk through of the facility or area being inspected, including limited access and out-of the way areas. Although the procedure indicated that the program included a focused ar.d directed method for observing specific attributes, including nuclear criticality safety, the inspectors determined that the procedure did not provide specific NCS performanes attributes or evaluation cdteria.

The inspectors performed a review of MBWA reports for the second and third quarters of 1997. Information included in the reports and the guiding procedure indicated that the  !

facility rating factors were subjectively applied based upon non-specific guidelines and  !

applied only to proceduralimplementation adequacy. In addition, the inspectors l concluded that no definitive technical criteria was given or opplied by which to evaluate i the effectiveness of the application or implementation of nuclear criticality safety controls !

In each building. As a result, almost all buildings which processed or handled fissile  !

material were rated in the top 20th percentile for the periods reviewed. One building, Building X 330, was rated low for the third quarter; however, the reports did not include any information to document the rating basis or corrective actions planned to resolve the identified concems. The building was rated a 4 on a 10 point scale.

Nuclear Criticality Safety Group Self-Assessment Pronram The NCS staff performed walk thrcughs of facilities that may contain fissile material operations to assess the implementation of NCS requirements and to verify that conditions had not been altered so as to negatively impact NCS controls specified in the applicable NCSA and NCSEs, Plant Procedure XP4 EG NS1101,' Nuclear Criticality Safety Walk Throughs,' Revision 0, dated March 3,1997, defined the nuclear criticality safety walk through process. The inspectors reviewed the procedures and records of activities conducted in August, September, and October 1997 to determine if adequate assessments were being completed.

The inspectors determined that the procedure did not define specific technical criteria by which nuclear criticality safety adequacy should be evaluated. in addition, the NCS Survey Forms listed only the number of items reviewed versus number in compliance.

Therefore, no means existed by which to de'. ermine what aspects were looked at, how they were evaluated, and if the review was fully completed for that particular NCSA or review area. The inspectors discovered that at least two different forms were being used to conduct the walk-downs, with neither form proceduralized per the SAR requirements.

Procedure XP4 EG NS1101 also allowed the use of either of two types of walk-throughs to verify verbatim compliance with the N",SA coritrols, a general observation walk through and a detailed walk through. However, the procedure did not include criteria by which to determine which walk through was appropriate.

18

l The inspectors reviewed the logs of NCS assessments for August, September, and I October,1997 and concluded that no distinction was made between assessment forms  ;

used for the annual and monthly NCS assessments. The use of identical forms made it confusing and difficult to detemilne if NCS assessments were being completed consistently. In addition, no information was given conceming requirements or criteria for facility modification walk downs, the incorporation of NCS requirements into procedures walk downs, or documentation walk downs, in fact, POEF 12 710 97-055," Cascade Operations Nuclear Criticality Safety 1997 Annual Assessment,' dated July 31,1997, concluded that better guidance was needed to define how reviewers were to do the modifications assessments.

Finally, the inspectors determined thst only two NCSA implementation deficiencies were identified by the walk through process during the August to October time period. The results were in sharp contrast to the multiple deficiencies identified by the inspectors during the brief facility walk throughs conducted in October and December. The inspectors also noted that NCS staff had Identified significant numbers of NCSA implementation daficiencies during recent walk throughs of Building X 710.

Ornanization Self-Assessment Proaram The inspectors reviewed Procedure XP2-QA-QA1034,

• Organization Self Assessments,"

Revision 0, dated March 3,1997, to determine the methods and criteria used by plant staff to conduct the referenced self assessments. The stated purpose of the self assessment process was to evaluate an organization's objectives, goals, and program effectiveness, including effectiveness in preventing the recurrence of problems.

Section 5.1.2 of the procedure required organizational managers to develop a self assessment schedule which clearly defined the assessment's objectives, scope, frequency, and assigned assessor. Section 6.2 of the procedure required the assessor to review the performance measures of the activity to be assessed. The inspectors reviewed a schedule maintained for the self assessments and determined that the schedule was incomplete. Specifically, the schedule did not define the assessment objectives and scope, and did not contain performance measures.

The inspectors reviewed the organization self assessments for Buildings X 333 and X 710 covering the time period of July through September,1997. The Building X 710 July 1997 self assessment could not be located by plant staff and was not reviewed. The inspectors compared the self assessment results with recent NRC walkdowns and those conducted following the NRC's identification of several generic NCS implementation issues.

Self assessment of Building X 710 activities during the months of August and September, 1997, did not result in any findings. A total of 23 NCSAs were involved in the self assessments. No findings were reported for any of the walkdowns conducted in Building X 333 for the months of July, August, and September,1997. However, following the NRC identification of several NCSA issues in October 1997, plant staff identified numerous deficiencies with the technical content and implementation of NCSAs applicable to Building X-710. Many of the deficiencies resulted in reports to the NRC in accordance with NRC Bulletin 9101. Some of the recent findings, which represented long standing practices and appeared indicative of an ineffective seff assessment program, included:

19

l l

I

+ 10 instances of a loss of NCSA requirements for spacing, volume, geometry, and administrative controls;

+ one instance of the incorrect application of NCSAs controls to an operation when the NCSA was not applicable to the operation; )

+ one instance of a non-labeled, uranium bearing material found in a laboratory after the material was deleted from the mass logs, and;

+ one Instance of a laboratory not using controlled copy logs.  !

During another recent self assessment walkdown, the loss of an NCSA control occurred concurrerd LL M self assessment review. Specifically, an operator brought several containers M wmbearing material into a laboratory which resulted in the NCSA controllimh a &# ens being exceeded. The inspectors concluded that the occurrence, in cer, Junction with the examples above, Indicated that some personnel may not be knowledgeable of, fully understand, or fully appreciate the significance of NCSA contingency controls, in additiori, the inspectors noted that in severalinstances the wamdown team members could not determine if the operations were in compliance with NCSA requirements based on the current, available documentation. As a result, NCS staff had to clarify, update, or initiate new NCS requirements for certain fissile material operations. Examples included:

+ NCSA-0710-008 checklist required the ' hot water bath" to be limited to two cylinders; however, four cylinders were present during the walkdown. A subsequent checklist entry by the walkdown team member indicated that the as found condition was acceptable based upon revised NCSA requirements.

+ NCSA-0710 009 checklist required cylinders to be restricted to no less that 17 inches edge to edge spacing; however, the walkdown team member discovered the cylinders spaced less than 17 inches apart. A subsequent checklist entry by the walkdown team member indicated that the as found condition was acceptable based upon a revised NCSA requirement.

• NCSA 0710-023 specified fissile material mass values were not labeled on all containers; however, the walkdown inspector could not determine if the material was exempted from the NCSA requirement.

The inspectors noted that Compliance Plan issue 27, developed during the certification process, documented a certificant Identified need to develop specific criteria and guidance for conducting organizationailevel assessments in a unifonn manner. In correspondence to the NRC, the certificant has documented that the activities encompassed by the Compliance Plan Issue 27 were completed in September 1996. The inspectors concluded, based upon the above documented findings, that Compliance Plan issue 27 activities were not completed, in that the procedure did not include specific criteria to ensure that the assessments were conducted in a uniform manner.

20

l Summary Technical Safety Requirement 3.5, *Revi6ws, Assessraents, and Audits,' requires, in part, l that a system of reviews, assessments, and audits, shall be implemented as defined in the Quality Assurance Program and Section 6.8 of the Safety Analysis Peport. Safety Analysis Report Section 6.8, ' Audits and Assessments,' required, in part, that a system of

)

audits and assessments shall be implemented to ensure that the health, safety, and environmental programs, as described in the Safety Analysis Report, are adequate and effectively implemented. Safety Analysis Report Section 5.2.2.9,

• Operation Surveillance and Assessment," required, in part, that in order to ensure that the NCS program was property established and implemented, the certificant utilized walk throughs, assessments, and audits. In addition, results of the wa'k throughs, assessments, and audits were documented, and reported to appropriate managers. Nuclear criticality safety deficiencies were recorded and the data was trended to monitor and prevent future deficiencies.

The failure, as of December 11, of the walk throughs, assessments, and audits conducted under the Management Self Assessment Program, the Nuclear criticality Safety Self Assessment Program, and the Organization Self Assessment Program to identify historical and continuing nuclear criticality safety program and implementation deficiencies is an Aoparent Violation (eel 070-07002/97013 08). Specifically, the self-assessment programs: 1) did not identify existing safety issues in the NCS functional area; 2) did not preclude the recurrence of previously-Identified safety deficiencies; 3) did not adequately specify and consistently apply technical criteria by which to assess the effective implementation of nuclear criticality safety approvals, and;

4) did not assess the effectiveness of the individual self assessment programs to ensure adequate program establishment and implementation.

c. Conclusions The hspectors determined that the intemal criticality safety self assessment programs lacked the specific guidance and technical criteria necessasy to clearly define appropriate methods by which to determine the effectiveness of imp lementation of nuclear criticality safety controls. These deficiencies contributed, in part, to longstanding nuclear criticality safety problems which were not identified until after significant NRC involvement.

E6.2 Independent Self Assessment Proaram

a. Inspection Scope (88015)

The inspectors reviewed an independent self assessment of the nuclear criticality safety program and compared the self assessment findings and results to current NRC inspection and plant staff findings.

b. Observations and Findinas The inspectors reviewed audit report number OPNS97A001, ' Nuclear Criticality Safety,'

dated February 28,1997. The report was transmitted to the certificant on March 3,1997, as *lndependent Assessment Audit of Nuclear Criticality Safety.' The report documented a number of mejor conclusions including:

21

4

+ the operations organizat6on has a satisfadory program in place for conducting and documenting self assessments; e from an evaluation of the self assessment surveys conducted by section managers forwarded to the nuclear ortticality safety staff it was concluded that a schedule had been established and performance of self assessments had been satisfactorily accomplished to the requirements of the XP2 HR HR1031 procedure:

• based on discussions with nuoloar criticality safety staff and an evaluation of records, it was concluded that a satisfactory process exists for the nuclear criticality safety organlaation to perform monthly walkdowns throughout the plant;

( a review of the single contingency criticality specification nonoompliance event in Building X-705 found that the action plan implemented satisfactortly continues to preclude recurrence of the problem, and; e based on performance based field observations of old and upgraded nuclear crtlicality safety approvals, it was concluded that field verifications were being satisfactorily sooomplished.

The inspectors noted thet conclusions provided in the first two bullets disagreed with .e findings developed dering this inspection. Specifically, the inspectors identified, as documented in Section E6.1, that the intomal s+1f assessment process was ineffective at the identification and correction of long standing problems with implomontation of NCSA.

For example, the inspedors identified numerous physical differences between the description of operations documented in some NCSAs and NCSEs and the actual plant conditions. Several of the inspectors findings required the plant to stop the activities, recort the finoings to the NRC in a Bulletin 9101 report, and revise the NCS documents pror to ronnitiating the activities Many of the conditions identified by the inspedors have existed since 1996.

The inspectors observed that management issued a number of problem reports to track the proper completion of concems and recommendations documented in the assessment report. One roccmmendation, associated with the third bullet above, was to track the .

comp!stion of action items and recommendations from a previous assessment, the Nuclear Safety Assurance (NSA) NCSA/NCSE Assessment, completed on September 11, 1996. The September 11,- 1996, assessment found: 1) eight instances where the NCSA controls were not believed to be adequate or were not described adequately to prevent -

the contingent event; 2) ten instances where the evaluations or the supporting analysis were not considered thorough enough in either the analysis or the documentation; 3) four situations where the definition of controls was less than adequate, usually missing a significant factor that contributed to the prevention of a criticality, and; 4) nine instances where the NCSAs and NCSEs were not clear in describing the contingencies, the controls, or how the double contingency principal was met. Problem report, number PR-PTS 97 2117, was issued to document resolution of the concems from the 1996 assessment, consistent with the 1997 assessment report recommendation. The inspectors reviewed the history file for the problem report and determined that the problem report was closed without corrective actions. Specifically, the Safety, Scfoguards, and Quality group allowed closure of the problem report based upon a response provided by the nuclear criticality safety manager which indicated that *NCS i

4 will Sot be tracking these opinions." No additionalinformation was provided to either support the NCS position or to refute the previous assessment results.

The inspectors also noted that the action plan, referred to in the fourth bullet above, was not effective. Specifically, since March 3,1997, the plant has made 48 separste NRC Bulletin 9101 reports to the NRC for events involving the loss of one or both contingencies relied upon in NCSAs. The 48 events were analogous to the referenced event where an NCSA contingency control was lost for a singularly contingent operation.

The 48 reports appear to indicate that generic issues associated with the loss of contingenc!es have not been addressed.

The certificant's ersessment team made recommendations relative to the last bullet above. The certificant's recommendations dealt with mismatches between operations performed in the plant and the description of those operations included in and analyzed for the NCSEs and NCSAs. Problem report PR PTS-97 2117 was issued to ensure that the concems were resolved. The inspectors reviewed the problem report history file associated with the concems and concluded that the Safety, Safeguards, and Quality group had closed the report without resolution of the specific concems or the generic implications. Specifically, the problem report closure section included the following statement:

• NCS does not feel these [ items) need to be addressed in NCSA-0710-008,*

and; 'NCSA-0344A002.A01 has been reviewed and no revision is necessary. The NCSA was written and reviewed by qualified NCS personnel, reviewed by the PORC [ Plant Operations Review Committee) subcommittee and approved by the PORC.*

The inspectors compared the findings documented in the two self assessment reports with recent NRC findings and current plant problem reports. The inspectors concluded that the issues were similar from one assessment to the next and in some cases were exact recurrences of past issues. In addition, the inspectors determined that the Safety, Safeguards, and Quality group had, on several occasions, closed-out issues identified during the independent self assessment process without resolving either the specific issue or assessing the potential for generic concems. As a result, the process was not effective in the identification of the managernent system or management controls that led to the current NCS discrepancies. Further, the process was ineffective in assessing the adequacy of corrective actions implementation and tirreliness based upon he Safety, Safeguards, and Quality group's acceptance of resolutions to issues that were unsubstantiated and in conflict with the indepe,* dent assessment findings.

Technical Safety Requirement 3.5,

• Reviews, Assessments, ar.d Audits," requires, in part, that a system of reviews, assessments, and audits, shall be implemented as defined in the Quality Assurance Program and Section 6.8 of the Safety Analysis Report. Safety Analysis Report Section 6.8.1,

• Audits," required, in part, that audits verify the effectiveness of health, safety, and environmental programs and their implementation and determino the effectiveness of the assessment process. The failure of the audit program, as of December 11, to determine the effectiveness of the nuclear criticality safety intemal assessment programs, as demonstrated by the failure to identify: 1) the continued existeno: of physical Mferences between plant operations and nuclear criticality safety evaluatEns and appovals for the laboratory building and in the withdrawal facilities following repeated intemal assessments; 2) inconsistencies between management controls described in the Gafety Analysis Report and plant procedures, and; 3) the 23 1

1 i

i I

i recurrent nature of nuclear criticality safety requirement deficiencies documented in the 1 plant problem reporting system, is an Apparent Violation (eel 070 07002/97013 09).

l

c. Conclualons I The inspectors identified that the independent self assessment program did not correctly determine the effectiveness of the nuclear criticality safety intomal assessment programs i as demonstrated by the existence of long standing differences between plant operations and nuclear criticality safety evaluations and approvals; long standing differences between plant procedures and the Safety Analysis Report requirements, and; the routine recurrence of nuclear criticality safety deficiencies, as documented by the plant problem

, reporting system, E7 Quality Assurance in Nuclear Critloality safety Engineering Activities  !

i E7.1 Root Cause Evaluation of and Corrective Actions for Nuclear Criticality Safety lasues ,

s. Inspection Scope (88020) i The inspo'clors reviewed the plant staffs root cause evaluation of recent significant i nuclear criticality safety events and issues. In addition, the inspectors reviewed the corrective action plans provided to the NRC to address the root causes for the nuclear criticality safety events and issues,

b. Observations and Findinas Root Cause Evaluations During the period of October 15 to December 8,1997, the NRC inspectors and plant staff identified a number of significant problems with implementation of the NC8 program, Some of the issues identified included: 1) NCS staff used engineering notices to make unauthorized changes to approved nuclear criticality safety evaluations (NCSEs) and nuclear criticality safety approvals (NCSAs); 2) repeated failures by operations staff to implement NCSE and NCSA controls correctly due, in part, to a limited familiarity with the documents and inadequate incorporation of NCSE cnd NCSA requirements into <

operations procedures, and; 3) Inadequate initial walkdown of fissile material operations 1 by NCS staff as demonstrated by physical differences between the systems analyzed and ,

in use. Plant staff defined most of the above issues as significant conditions adverse to quality (SCAQs), in accordance with the quality assurance program.

Based upon the significant number of issues and categorization of the issues as SCAQs, the plant staff initiated efforts to determine the associated root causes and to identify apprcpriate corrective actions to preclude recurrence. . The inspectors reviewed the adequacy of these efforts through discussions with the staff involved and through a sampling review of the results.

Through discussions with the Corrective Actions (CA) and the Nuclear Safety (NS) managers, the inspectors determined that the NS manager performed the first informal root cause evaluation of the NCS issues during the first week of November 1997. The NS manager focused his evaluation on a number of recent NRC identified findings involving 24

, - . ,.,.---,,-,,4,-...-,-,-e,,w,,,,w., -v, os,,-,-,-,,,-m_+-,,- . - - . - - . , , -. ,, , - <-w,,~,.,m-+c..,,.-----,m..,m-.--,.ro w.--

unauthorized changes made to NCSAs and NCSEs using engineering notices. Root causes for the unauthorized changes included inadequate management systems and technical errors. The NS manager explained that the management systems root cause related to the denciencies in the process used to develop and review NCSAs and NCSEs, including direction given for work performed by the NCS engineers, management, and the Plant Operations Review Committee (PORC). The technical error root cause involved mistakes made by NCS staff during implementation of the NCSA and NCSE development process. The inspectors determlned that the root causes addressed some of the issues that led to the events; however, other signl0 cant root causes were not identified including management and staff training problems and procedures deficiencies, in addition, the inspectors noted that the NS manager, though trained in root cause evaluation procedures at other nuclear facilities, had not received site specific training or certification as a root cause evaluator.

The second root cause evaluation was conducted by the CA manager during the week of November 10,1997. The CA manager Informed the inspectors that the evaluation was performed using summary data, from the problem report tracking system, and the informal root causes previously determined by the NS manager. Approximately 300 of the 500 N,CS related problem reports submitted during 1997 were considered in the evaluation. The CA manager chose the problem reports that were included in the evaluation based upon his perception that the problem report subject matter was related to the inadequate implementation of NCSAs or NCSEs. The inspectors performed a brief review of the non included problem reports and noted several related to training and process proceduralinadequacies. The CA managerjustified the non inclusion in the evaluation of the inspector selected problem reports based upon personal assessment that the primary root causes were related to NCS implementation versus NCS development process problems. The inspectors noted that this approach was significantly different than the approach used by the NS manager.

The CA managers formal root cause evaluation included concluslan statements (root causes) that were consistent with conclusion statements developed by the NS manager.

However, the inspectors determined that the root cause focuses were different.

Specifically, the NS managers root causes focused on management and technical problems within the engineering process used to develop and approve the NCSEs and NCSAs. The CA managers root causes focused on management and technical problems associated with implementation of the NCSAs and NCSEs by the operations and other groups. These differences were highlighted when the CA manager presented the formal evaluation to the site Management Assessment and Analysis Team (MAAT).

During the presentation, the CA manager indicated that the primary root cause was inadequate audits and evaluations of employee activities. The MAAT disagreed and had the primary root cause changed to, ' employee communication needs improvement."

Neither of these conclusions concurred with the NS managers indicated root cause of inadequate management standards and policies.

Based upon discussions with the CA manager, ihe inspectors determined that the formal root cause process conducted by the CA manager was not supported by a review of the specific issues associated with any of the individual SCAQs and did not identify all the causes for the SCAQs. Specifically, the CA managers review relied exclusively upon the very lim!ted amount of information documented in the problem reporting system. Problem reporting system information normally included only data that was immediately available 25

4 when a problem was initiallyidentined. Almost none of the SCAQ problem reports reviewed by the inspectors includod any assessment of the policies, procedures, training, or other factors that could have contributed to the event. For example, problem reports, documenting the improper use of engineering notices to make changes to NCSAs and l NCSEs, did not include information on NCS management's inadequate understanding and acceptance of Safety Analysis Report and Technical Safety Requirements, two I

factors which the inspectors determined contributed to the events. The inspectors also noted that none of the SCAQ problem reports documented that some NCS engineers did not understand that the Technical Safety Requirements mandated PORC review of NCSAs, NCSEs, and changes thereto, another cause for some of the SCAQ events.

Finally, the inspectors noted that 39 of the 40 problem reports categorized as SCAQs did not have completed root cause evaluations or developed corrective actions as of the end of the inspection period. Many of the problem reports were signl0cantly overdue for review based upon the criteria defined in the plant corrective action procedures.

At the end of the onsite inspection period, plant management indicated concurrence with the inspectors findings and stated their plans to perform a revised root cause evaluation.

The evaluation process would include a team of individuals and incorporate detailed reviews of.each of the recent events to ensure that all causes were identified and addressed through appropriate corrective actions.

Initial Corrective Action Plan Following the inspectors identificailon of several NCS-related problems during the last two weeks of October 1997 management performed followup reviews of some NCS activities and identified numerous additional NCS related problems. Many of the findings resulted in telephonic reports to the NRC in accordance with Bulletin 9101 and associated supplements. As a result of the continuing NCS related problems, the NRC and certificant management held several teleconferences to discuss the findings, the apparent immediate antilong term safety significance of the findingt., und the planned near and long term corrective actions On November 10,1997, the certificant submitted to the NRC an outline of completed ana planned corrective actions to correct the problems.

The inspectors compared the proposed corrective actions to the root cause evaluations completed and approved by the MAAT on November 16,1M7, The inspectors noted that the coiTective actions were completed prior to the root cause evaluation being performed.

Through discussions with the NS and CA managers, the inspectors were informed that a cross reference between the root causes and the corrective actions had not been developed. During the MAAT meeting held on November 16,1997, to review and approve the root causes for the NCS related problems, the MAAT requested that the corrective actions should be cross referenced to the root causes to ensure that each of the causes were resolved by specific corrective actions. As of the date of the inspection, this cross reference had not been completed.

During discussions with the inspectors, neither management nor plant staff could conclusively state how and which of the corrective actions were intended to resolve the MAAT approved root causes, in addition, management could not definitively state that all of the root causes and necessary corrective actions had been identified. The inspectors also observed several NCS problems which appeared to occur, in part, due to inadequate 26

l root cause evaluations of recent similar problems and an absence of proposed corrective actions. One such example was the continued inclusion of NCS controls in the r,on-action step sections of procedures. A second example was the approval of revised NCS documents that did not require the posting of signs for all procedure administrative controls.

Title 10 of the Code of Federal Regulations, Part 76.93, requires, in part, that the certificant shall establish, maintain, and execute a quality assurance program satisfying each of the applicable requirements of American Society of Mechanical Engineers (ASME) NOA 1 1989, " Quality Assurance Program Requirements for Nuclear Facilities."

ASME NQA 1 1989 Basic Requirement 16,' Corrective Action," requires in part that conditions adverse to quality shall be identified promptly and corrected as soon as practical. In the case of a significant condition adverse to quality, the cause of the condition shall be determined and corrective actions taken to preclude recurrence. The failure to determine the root causes and take corrective actions to preclude recurrence for nuclear criticality safety-related significant conditions adverse to quality is an Apparent Violation (eel 070 07002/9701310).

Supplemental Corrective Action Plan Following the NRC's review of the certificant's corrective action plan (CAP) submitted on November 10,1997, the NRC held teleconfererw.es on November 12 and 18,1997, with the certificant to further define and clarify commitments made in the CAP. During the teleconferences, the certificant discussed their basis for continued safe operations and made additional commitments. On December 1,1997, the NRC requested that the certificant provide a written summary of all recent commitments relative to the NCS program. In addition, the NRC requested that the certificant address in their correspondence specific items raised in the NRC's December i letter, On December 22,1997, the certificant provided a supplemental CAP. The inspectors reviewed the supplemental CAP and determined that most of the issues discussed in the NRC's previous telephonic and written communications had been addressed. However, information provided to the inspectors during the course of the inspection ws. rot expressly included in the supplemental CAP.

During a telephonic exit meeting conducted on January 9,1998, the inspectors discussed the apparent missing information with plant management. The NS manager concurred with the inspectors findings and provided a verbal reconfirmation of commitments previously discussed during the inspection period. This information was also provided to the NRC in a letter dated January 13,1998. The inspectors reviewed the information and determined that the revised CAP appeared to provide adequate short and intermediate term actions to ensure safety and permit continued NCS operations.

c. Conclusions The inspectors determined that the plant staff did not systematically evaluate recent nuclear criticality safety-related issues categorized as significant conditions adverse to quality. As a result, all causes for the issues were not identified and corrective actions were not proposed to preclude recurrence of the issues. In addition, corrective action 27 w

plans, developed and provided to the NRC, were initially incomplete and required several revisions in order to provide adequate short and intermediate corrective actions.

E7.2 Implementation of the November 10.1997. Corrective Action Plan (GDP 97 2030)

a. Inspection Scope (88020)

The inspectors observed several

• tabletop" reviews conducted foi cascade building l operating procedures which implemented nuclear criticality safety approval controls. The

• tabletop" reviews were implemented as a part of the corrective action plan (CAP) submitted to the NRC on November 10,1997 (GDP 97 2030).

b. Observations and Findinas The CAP submitted to the NRC on November 10, .1997 (GDP 97 2030), stated, la part, that tabletop reviews would be performed for all Nuclear Criticality Safety Approvals (NCSA). In addition, the certificant performed tabletop reviews for operating procedures which implemented specific NCSA controls. Tabletop reviews for NCSAs were not conducted during the inspection; however, several tabletop reviews were conducted for the operafing procedures used in the cascade buildings.

The tabletop reviews observed by the inspectors were performed with an NCS engineer, an NCSA ' owner," at least one facility operator, and a system engineer as committed to in the CAP. The reviews observed addressed several aspects conceming the implementation of the NCSA controls in the operating procedures including overall procedural adequacy, placement of NCSA controls within the operating procedures, and the feasibility of the NCSA controls. The inspectors noted that team mere. hrs actively participated in the step-by-step review of the operating procedures. The inspectors also observed re enactments of operating procedure walkdowns, conducted in conjunction with the tabletop reviews, and noted no concerns. Nuclear criticality safety approval and operating procedure reviews, as well as the NCSA and operating procedure walkdowns, were conducted in accordance with a document entitled, ' Desktop Instruction for Operating Procedure and NCSA Thorough.1ess Review." The instruction was ussJ to t prescribe the specific a:tions team memben, needed to take in order to conduct the tabletop reviews and team walkdowns of the NCSAs and operating procedures.

During review of the instruction and interviews with tabletop review team members, the inspectors noted the cun o mview plan and instructions did not assure that the process incorporated root causet ird lessons leamed from recent self revealing NCS violations.

An example which highhgt.ied the deficiency was the evaluation of NCSA issues identified in October 1997, regarding a failure to use the Benedict equation for cascade operations as required by the NCSA (NRC Event Report Numbers 33123,33134, and 33146). NCS staff highlighted to the inspectors that a root cause for this incident was that the Benedict Equation NCSA control actions were in t' a ' Precautions and Limitations'section of an operating procedure vice in the

• Action Su W r.ection where required actions were prescribed. The current review plan and instructions did not provide a means to address potentially generic issuos, and did not assure that the review teams incorporated potentially generic root causes into ongoing CAP reviews. The current review plan and instructions also did not provide a mechanism to assure that NCS documents, previously approved as a part of the CAP, were re reviewed when potentially generic issues were 28

raised. The incorporation into the CAP reviews of generic root causes identified following the recent NCS events would preclude the recurrence of potentially generic issues. In addition, the inspectors identified that the instructions used to prescribe the actions needed to be taken by review team members during the tabletop reviews and walkdowns of the NCSAs and operating procedures were not an approved plant procedure.

Technical Safety Requirement 3.9.1 requires, in part, that written procedures shall be l prepared, reviewed, approved, imple nented, and maintained to cover activities described in both the Safety Analysis Report Section 0.11 and Appendix A. Safety Analysis Report Bection 6.11 requires, in part, that procedures shall prescribe those essential actions or steps needed to safely and consistently perform activities described in Appendix A. l Safety Analysis Repori Section 0.11, Appendix A, requires, in part, that activities involving intemal audits and Inspections, investigations, and nuclear criticality safety shall be covered by written procedures. The failure from November 10 through December 12, 1997, to develop and approve written procedures for the conduct of activities involving nuclear criticality safety is an Apparent Violation (eel 070 07002/9701311).

Specifically, the nuclear criticality safety approval and operating procedure tabletop r6 views and walkdowns were conducted utilizing the prescribed actions in a

• Desktop instruct!or) for Operating Procedure and NCSA Thoroughness Review," an unapproved plant procedure,

c. 9.g.nclusions The inspectors determined that tabletop reviews and operating procedure walkdowns were not conducted in accordance with an approved plant procedure, as required by Safety Analysis Report Section 6.11, Appendix A. In addition, the inspectors noted a weakness in the instructions used for the walkdowns and tabletop reviews, in that, the Instructions did not include a mechanism to document and assure that potentially generic root causes, from recent nuclear criticality safety events, were incorporated into the nuclear criticality safety approval and operating procedure reviews.

E6 Miscellaneous Nuclear Criticality Safety issues E8.1 f0 pen) VIO 070-07002/97-203-05: failure to maintain nuclear criticality safety approval double contingency controls for spacing and labeling.

The inspectors reviewed the management spproved root causes and corrective actions for the violatior'. Management determined that the root causes for the violation included:

1) the requirements were 'new," and: 2) Inadequate corrective actions for previous self-identified deficiencies. The related corrective actions included: 1) conduct shift briefings with personnel responsible for the spacing, labeling, and movement of uranium bearing material covered by the nuclear criticality safety approvals, and; 2) increase nuclear criticality safety walk throughs and trend data found with respect to the identified nonconformances. Each of the corrective actions were completed prior to September 1997 srid additional root causes and corrective actions were developed based upon the data trending.

The inspectors determined that the initial root cause evaluation was not comprehenslve, though tii. Items were categorized as significant conditions adverse to quality (SCAQs).

Specifically, the evaluation did not assess: 1) the potential for training weaknesses 29

associated with the 'new' requirements; 2) the need for or use of procedures as a part of the activities, and; 3) the use of signs or labels to more clearly focus staff attention on requirements for infrequently performed or unique activities. The inspectors also concluded that the corrective actions were not developed to preclude recurrence of the issues. Specifically, the corrective actions (shift briefings) were focused on the isolated incidents that were the subject of the violation and did not address the broader issue of effective implementation of 'new' requirements, in addition, the corrective actions i recommended to management following the increased NCS walkdowns and trending of identified nonconformances were not implemented and tracked. Therefore, the inspectors could not review the items and plant management could not determine that the actions were effective.

During NRC Inspections conducted in October and December 1997, numerous additional problems with the implementation of nuclear criticality safety spacing, lat sling, and other procedural controls were identified. Therefore, the inspectors determined that the root cause evaluation and corrective actions to the violation were not effective. The failure to perform a comprehensive root cause evaluation and to implement corrective actions to preclude the recurrences of nuclear criticality safety control violations is an Apparent Violation,(eel 070 07002/9701312).

30 l

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

1. • J. Morgan, Acting General Manager ,

1. • S. Polston, Paducah General Manager

1. • M. Hasty, Engineering Manager

1. • C. Sheward, Maintenance Manager

• R. McDermott, Operations Manager

• J. Vorees, Corrective Actions Program Manager

1. • H. Hopkins, Engineering Gloup Manager

'W. McLaughlin, Engineering Group Manager

1. • D. Wilcrynski, Nuclear Safrly Group Manager

1. • J. Bolling, Nuclear safety Section Manager

• S. Fout, Production Support Manager

• J. Anselmo, Special Programs Manager United States Enrichment Corporation

1. 0 Rifakes, Exe*cutive Vice President, Operations ,

1. J. Miller, Vice President, Production

1. S. Toolle, Nuclear Regulatory Assurance & Policy Manager

• L. Fink, Safety, Safeguards & Quality Manager

1. • R. Gaston, Nuclear Regulatory Affairs Manager

1. • S. Martin, Nuclear Regulatory Affairs U.S. Nuclear Reaulatory Commission (NRC)

1. C. Pederson, Director Division of Nuclear Materials Safety

1. • P. Hiland, Chief, Fuel Cycle Branch

1. W.Troskoski, Acting inspection Section Leader, NMSS

1. • K O'Brien, Senior Resident inspector, Team Leader

1. • R. Krsek, fuel Facilities inspector

1. J. Davis, Nuclear Criticality Safety Specialist, NMSS S. Larson, NRC Contractor

• Denotes those present at the initial exit meeting held on December 12,1997.

1. Denotes those present at the final exit meeting held on January g,1998.

INSPECTION PROCEDURES USED l

IP 88015 Headquarters Criticality Safety inspections IP 88020 Regional Criticality Safety inspections i

I 31 l

ITEMS OPENED, CLOSED, AND DISCUSSED Opened 070-07002/97013-01 eel Loss of 2 controls, with a greater than critical mass of UF, in the Unit 29, Cell 5, Stage 8 converter 070-07002/97013 02 eel inadequate procedures for responding to the loss of a nuclear criticality safety approval control 070-07002/97013-03 eel Failure to use materiallabeling and posting to communicate procedural criticality controls 070-07002/97013-04 eel Failure to implement nuclear criticality safety approval controls 070-07002/97013-05 eel Failure to define or conduct specific training for the nuclear criticality safety manager 070-07002/97013'-00 eel Failure to complete required training for nuclear criticality safety staff 070-07002/97013 07 eel Failure to complete required training for nuclear criticality safety contractors 070-07002/97013-08 eel lnadequata intemal nuclear criticality safety self-assessment program and implementation 070-07002/97013-09 eel inadequate independent nuclear criticality safety self-assessment program and implementation 070-07002/97013 10 eel Inadequate root cause evaluation and corrective actions for recent nuclear criticality safety issues 070 07002/97013-11 eel Inadequate and improper procedure used in corrective action process for recent nuclear criticality safety issues 070 07002/97013 12 eel Inadequate corrective actions to a previous nuclear criticality safety violation Closed None Discussed 070-07002/97 203 5 VIO Failure to maintain nuclear criticality safety approval double contingency controls for spacing and labeling 32

a 0704 7002/97 203 12 IFl No plant-wide policy existed which defined the appropdate response actions to the discovery of an NCSA non-compliant condition a

p i

f 7

(

r I

6 2

l

+

33 l

l ci!!r 't& W4-++-tr*een ee-.Mr, M- N WW4-" + w *4-.-wayy +qw e wy y--m ---tw te + e p- .

'p.=='y=- gy 4-emqyx e' +? _ g qip r7 !t-pT* wry *,p.y-- w-pp -gu -y w p i-+t M w's*erry 7 4*7M ,

LIST OF ACRONYMS USED ACR Area Control Room ALARA As Low As Reasonably Achievable CCC Central Control Center DAW Dry Activated Weste EWP Electrical Work Package FLM First Line Manager HEPA High Efficiency Paniculate Absorber IFl Inspection Followup item LOTO Lockout and Tagout LMUS Lockheed Martin Utility Services MAAT Management Assessment and Analysis Team MBWA Management By Walking Around NCS Nuclear Criticality Safety NCSA Nuclear criticality Safety Approval NCSE Nuclear Criticality Safety Evaluawn NDA Non-Destructive Analysis PDR Public Document Room ,

PEH Planned Expeditious Handling PORC Plant Operations Review Committee PPE Personal Protective Equipment ppm Parts per million PR Problem Report psla Per Square Inch Absolute PSS Plant Shift Superintendent RCW Recirculating Cooling Water RW Radiation Worker '

RWP Radiation Work Permit SCAQ Significant Condition Adverse to Quality UF. Uranium Hexatluoride VIO Violation WP Work Package I

34 y ,. .,,3 g y,i +.p. ar i.,.

p .-o