ML20202G318

Insp Rept 70-7001/97-14 on 971125-980120.Violations Noted. Major Areas Inspected:Plant Operations,Maint & Surveillance, Engineering & Plant Support

ML20202G318
Person / Time
Site:	07007001
Issue date:	02/12/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
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Shared Package
ML20202G267	List: ML20202G263 ML20202G299 ML20202G318
References
70-7001-97-14, NUDOCS 9802200106
Download: ML20202G318 (19)

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U.S. NUCLCAR REGULATORY COMMISSION ,

. REGION lil' s

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< Docket No: 70 7001 Repost No:' - 70 7001/97014(DNMS) -

f Facility Operator: United States Enrichmen; Corporation Facility Name:_ Paducah Gaseous Diffusion Plant -

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Location: - 5600 Hobbs Road

- P.O. Box 1410 -

= Paducah, KY 42001 Dates: November 25,1997, through January 20,~ 1998 '

Inspectors: K. G. O'Brien,' Senior Resident inspector

. J. M. Jacobson, Resident inspector-Approved By: - Patrick L. Hiland, Chief Fuel Cycle Br6nch:

Division of Nuclear Materials Safety 9802200106 990212 '

PDR ADOCK 07007001 C PDR

'y.

. EXECUTNE

SUMMARY

United States Enrichment Corporation Paducah Gaseous Diffusion Plant 1NRC inspection Report 70-7001/97014(DNMS)

Plant Operations

+ -The failure to perform shiftly checks of the recirculating cooling water pressure for the

- No.1 Dual Speed Purge and Evacuation Pump in Building C-335_was a violation of Technical Safety Requirement 2.4.4.4. The violation rwsulted from an error in the non-destnactive essay calculations performed in March 1997.; Although the error was identified by plant staff, the violation is being cited because of the significance of -

identifying end maintaining the single-contingency control (moderation) for deposits of unsafe fiswee mass in accordance with the Technical Safety Requirement. (Section 01.2)

E _ After reviewing the response to a Bulletin 9101 event notification, the inspectors concluded that generation and handling of potentially fissile wastes at Paducah had been performed in accordance with nuclear criticality safety controls and that there had been no generic mis-characterization of fissile exempt wastes onsite. However, the nuclear 1 i

criticality safety staff had not adequately communicated to all staff how to implement the requirements of Nuclear Criticality Safety Approval GEN-07 relative to exempting wastes in accordance with the controls for characterizing potentially fissile wastes contained in Nuclear Criticality Safety Approval GEN-15. (Section 01.3)

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- A non-cited violation for failure to felly decontaminate small vacuum pump parts in

accordance with NCSA GEN-12 was identified by plant nuclear criticality safety staff. The _ '

lack of detailed guidance in the nuclear criticality safety approval on exempting cleaned -

parts from ruclear criticality safety controls contributed to inconsistent implementation of the nuclear criticality safety approval. (Section 01.4)-

• The inspectors and plant staff identified examples of a violation of the fissile control area 1 volume limit for portable containers, The violation appeared to result from inadequate

- training as to what constituted a portable container and required to be controlled in -

- accordance with Nuclear Criticality Safety Approval GEN-15 goveming fissile control areas onsite.- (Section 01.5)

Maintenance and Surveillance 1

. . Troubleshooting activities observed by the inspectors for the Building C-310 No.1 Alarm

' Annunciator Cabinet and its associated breaker were conducted in accordance with maintenance program and Technical Safety Requirements. The direct cause of the -

repeat breaker trips in October 1997 was not identiced, although the daily lamp test for the alarms was demonstrated to exceed the breaker rating of 10 amperes.

- (Section M1.1) -

Enoineerina A violation of Technical Safety Requirement 3.11.2 resulting from inadequate requests and evaluations for seal handling operations, as well as other deficiencies with nuclear 2

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criticality safety approvals identified during the inspection period, indicated's generic .

lasue existed with the amount of detail and rigor which had been used in the past by plant -

staff when developing nuclear criticality safety evaluations and approvals to ensure all activities involving potentially fissile materials and systems were addressed.

a (Section E1.1)

• - Plant staff undertook a probing self-assessment of the nuclear criticality safety program implementation at Paducah following a Special Inspection at Portsmouth which raised

l. significant issues with the implementation of nuclear criticality safety requirements. The self assessment resulted in the identification of generic findings for which plant staff - '

planned to develop root causes and corrective actions. (Section E1.2)

Plant Support

.- The inspectors identified a minor violation for a failure to post Form SF 702 for documenting classified storage area checks in Building C-400. Plant staff found and

, corrected similar deficiencies at other classified storage areas in response to the

inspectors' finding. (Section S1.1)

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A Raport Details L Operations Conduct of Operations'

= 01;1 General Comments (88100)

Nuclear criticality safety was the focus of many of the activities by plant staff and the inspectors during the inspection period. In response to events at Paducah and he Portsmouth Gaseous Diffusion Plant, plant staff undertook walkdowns and self-assessment activities to assess the status of the nuclear criticality safety programE

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and its implementation at Paducah. These activities included a stand-down of operations involving fissile materials on December 12 in order for management to convey its .

expectations for rigor and conduct of operations to all fissile material wt.4ers. As a result--

i of these efforts, plant staff identified 's number of discrepancies and implementation _

, problems with nuclear criticality safety approvals (NCSAs) which resulted in notifications .

l to the NRC pursuant to Bulletin 91-01.

01.21 Buildina C-335 Purne and Evacuation Pumos

- a. inspection Scope (88100)  ;

The inspectors reviewed the circurmtances surrounding a notification to the NRC that all L criticality safety controls had been lost for a uranyl oxyfluoride (UO22 F ) deposit exceeding safe mass in Building C-335.

b. Observations and Findinos

. On' January 15, plant non-destructive assay (NDA) staff discovered that an error had been made in the calculations of the uranium mass for deposits in the process gas -

coolers for the Number 1 and 2 Dual Speed Purge and Evacuation Pumps in Building.

C-335. Building C-335 was at the upper end of the enrichment cascade and had

historically processed uranium enriched to 2 0 weight percent (w/o) assay. The error in-

, .the NDA calculations resulted when the analyst assumed 1.4 w/o (the assay for Building .

C-337) instead of 2.0 w/o while calculating the mass of the deposits on March 12,1997.

l As a result, the masses of the UO2 F, deposits were not recognized as exceeding the safe mass threshold of 264 pounds for 2.0 w/o materials. Deposits which exceeded safe -

mass were required to be handled in accordance with the planned expeditious handling  ;

(PEH) requirements of Technical Safety Requirement (TSR) 2.4.4.4.

Upon discovery of the error, the NDA staff performed a quick re-calculation of the mass of the deposits using the correct assay and identified that deposits of over 600 lbs in the No.1 Gas Cooler and approximately.350 lbs in the No. 2 Gas Cooler could be present.

Both of these deposits would have been PEH deposits, although both were below the 1 Topic' al h' eadings such as 01, MS, etc., are used in accordance with the NRC standardized inspection report

. outline contained in NRC Manual Chapter 0610. Individual reports are not expected to address all outline topics,

and the topical headings are therefore not always sequential.

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! critical mass of 695 pounds for 2.0 w/o material. Since the No. 2 system had previously ,

been believed to contain a deposit below safe mass, and had been opened to the j L atmosphere for maintenance without the moderation control specified in the TSR Action i I Statements, plant staff made a four hour notification to the NRC for loss of all controls on  :

the No. 2 cooler PEH deposit.

Plant technicians later obtained more accurate NDA scans of the deposits by taking off  ;

i the housings for the pumps and using a crane to lower a neutron detector over the gas ,

coolers. Two independent NDA analyses were performed for each cooler which indicated .

that the deposit in the No.1 Gas Cooler was 348 lbs or less (still above the PEH limit) and u ~ the deposit in the No. 2 Gas Cooler was 254 lbs or less (below the PEH limit).- Because i E the deposit la the No. 2 Gas Cooler was below the safe mass of 264 lbs, plant staff were

not required to comply with TSR 2.4.4.4, and could handle the deposit in accordance with i

the controls for the nuclear criticality safety approval (NCSA) for equipment removal -

(GEN-10). These more accurate results led plant staff to retract the four-hour report. ,

made earlier. l h ,

l- The plant staff immediately entered the TSR 2.4.4.4 Limiting Condition of Operation

! . (LCO) Action Statements (Condition A) for a PEH deposit in a fluorinating environment for.

i the No.-1 Gas Cooler. These action statements included maintaining the deposit in a fluorinating environment (moderation control), initiating actions to determine the cause of

the deposit, and developing a plan of action within 30 days. - Surveillance Requirement (SR) 2.4.4.4-1 also required that a shiftly check of the recirculating cooling water (RCW)

- pressure be performed until the RCW system was drained to ensure that the RCW

! - pressure did not exceed the coolant (R-114) pressure and migrate into the gas cooler

i. (moderation control). The shiftly surveillance of the RCW pressure for the gas cooler was not performed at anytime during the March to January time frame.

L . During discussions after the discovery, the NDA staff stated that only qualitative gamma l- scans of this equipment were performed after March because SR 2.4,4.4-4 required

[ quarterly quantitative (neutron) scans for deposits in unit and cell bypass and drop piping U only. The staff recognized from the gamma scans that there was a potential deposit in

. the area, but did not feel there was a safety issue because there was no loss of thermal i efficiency for the cooler, a typical operational indication of a substantial deposit. Also, the

• i, geometry of the cooler mede it virtually impossible to assemble a spherical critical mass

upon which the calculation of 695 pounds was based. The_ qualitative gamma scans -

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performed after the initial error indicated that there were potential deposits in the gas i ' coolers or pumps, but the deposits did not appear to be growing. The inspectors noted, L however, that the TSR LCO required moderation control be maintained when deposits of UO2 F,in a pipe or component listed in TSR 2.4, Appendix A, were estimated to be greater than safe mass when the uranium assay was greater than 1.0 weight percent.

0 Technical Safety Requirement 2.4, Appendix A, listed process gas coolers as an

- applicable type of equipment.

L- -- After the identification of the calculetion error, the NDA staff reviewed all the iness I

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calculations which had been performed prior to June 26,1997, the date when independent verification of NDA calculations was instituted at the plant. No other mis-f classifications of PEH deposits were identified by the review.

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......g. 4 m 1 Technical Safety Requirement 2.4.4.4 required, in part, that moderation control be-

maintained when deposits of UO2 F, in a pipe or component listed in TSR 2.4, Appendix A, were estimated to be greater than safe mass as determined by TSR 2.4, Appendix B, and the uranium assay was greater than 1,0 weight percent. Technical Safety Requirement 2.4, Appendix A , listed process gas coolers as applicable equipment.

Technical Safety Requirement 2.4, Appendix B, identified 264 pounds as the safe mass

- limit for deposits of 2.0 weight percent material.- Surveillance Requirement 2.4.4.41 7 required, in part, that the certificatee verify that coolant pressure is greater than the

' building P.CW [ recirculating cooling water] pressure each shift when a UO,F, deposit .

greater than safe mass existed and the RCW was not drained. The failure to verify that

. the coolant pressure was greater than the RCW pressure each shift while the RCW was .

not drained and a PEH deposit was present in the process gas cooler for the Number 1 >

- Dual Speed Purge and Evacuation pump in Pullding C-335 (operating at assays up to 2.0 -

weight percent) from March 12, igg 7 until January 15,1998, is a Violation of TSR . >

-2.4.4.4 (VIO 70 700147014 01).

c. Conclusion ,

The failure to perform shiftly checks of the RCW pressure for the No.1 Dual Speed Purge and Evacuation Pump in Building C-335 was a violation of TSR 2.4.4.4. The violation-appeared to result from an error in the non-destructive assay calculations performed in March igg 7. Although the error was identified by plant staff, the violation is being cited because of the significance of identifying and maintaining the single-con'ingency control (moderation) for PEH deposits in accordance with the TSR Action Statements and Surveillance Requirements.

-01.3 Nuclear Cnticality Safety Anoroval for Waste Handlina

a. - Inspection Scoce (88100)

The inspectors reviewed the response to the plant staffs identification that the NCS .

policy for exempting potentially fissile wastes from NCS controls may not have been property implomanted (Certificatee Event Report 33453).

b. Observations and Findinos On December 23, plant staff identified that the independent verification and '

documentation of waste streams such as absorbent pads, oils, floor sweep, contaminated 1 metal,'etc., as fissile exempt, that is, exempt from NCS controls during handling and storage, may not have been accomplished in accordance with NCSA GEN-07, " Nuclear

= Criticality Safety (NCS) Exempt Material Policy." The NCSA required that for certain waste streams which could potentially be used with fissile operations, two independent .

checks of the origin of the materials be performed and documented to ensure that the a materials had not been used or contaminated with fissile material. Since documented evidence of the GEN-07 independent verification was not readily available, the Plant Shift Superintendent (PSS) made a 24-hour notificatk c the NRC, purst snt to Bulletin gi-01, that one of the controls for waste exemption had not been implemented.

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Fellowing the identification, plant staff began a thorough walkdown of the site and segregated all waste drums and containers which could have potentially been improperly 6

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- handled. This amounted to some 1700 drums and containers. At the same time, an investigation into the contents and disposition of each container was begun to identify the method used to characterize its exempt status The criticality safety staff (some of whom

' had been on vacation during the initial identification of the problem) and waste handling staff reviewed the waste handling program as part of the investigation.

The investigation revealed that the initial problem report had been predicated on the use of NCSA GEN-07 independently of other NCSAs goveming the genaration of potentially fissile waste., in actuality, NC8A GEN 15, "On-Site Generation, Handling, Accumulation,

. Staging, Transportation, and Storage of Fissile or Potentially Fissile Waste Up to a Maximum'of 5.5 Weight Percent Enrichment," govemed the generation of potentially fissile wastes since Septemtier igg 6 when the NCS program controls were upgraded to account for 5,5 weight percent materials (high-assay upgrade project). The independent verifications in NCSA GEN-07 were one method which could be used under GEN 15 to

- exempt waste from fissile material controls, The controls in NCSA GEN-15 identified which wastes were to be handled as potentially fissile based upon the point or generation _  ;

being potentially fissile or plant upsets which could generate potentially fissile wastes, in addition, NCSA GEN-15 specified the methods for characterizing wastes as exempt

- based upon sampling or process knowledge.

Plant staff reviewed the records for the 1700 containers segregated during the walkdown and identified that approximately 1500 had been characterized and handled in accordance with NCSA GEN-15 or a specific NCSA for the operation afler the high-assay

_ upgrade project implementation date. The remaining containers _had been generated and E characterized in accordance with the NCSAs goveming waste generation prior to the

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high-assay upgrade under the old plant operations up to 2.0 weight percent material,L A .

_  ; selected review by the inspectors confirmed this assessment. Discussions with plant L waste handling and operations staff indicated that they were familiar with how to treat L, potentially fissile wastes generated from fissile operations govemed by NCSAs, but were confused as to the use of NCSA GEN-07. The NCS staff indicated that GEN-07 was

developed, in part, to serve as a backup control should all else fail, i.e., a fissile operation -

had not been properly' identified, but was not written as or intended to be a stand-alone -

document. Plant management later issued a functional directive which reviewed and re- j

iterated the process and controls specified in NCSA GEN-15, which referenced NCSA '

GEN-07, for characterizing NCS-exempt wastes.

- On January 24, igg 7, after the end'of the inspection period, plant staff formally retracted ,

the 24-hour notification which had previous 9 been made for the problem report which

. Initiated the walkdown of the fissile exempt wastes onsite, lc? Conclusion

- After reviewing the response to a Bulletin gi 01 event notification, the inspectors

- concluded that generation and handling of potentially fissile wastes at Paducah had been performed in accordance with NCS controls and that there had been no generic

- mis-characterization of fissile exempt wastes onsite. However, the NCS staff had not adequately communicated to all staff how to implement the requirements of NCSA GEN-07 relative to exempting wastes in accordance with the controls for characterizing potentially fissile wastes contained in NCSA GEN 15, 1

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101.4 Decontam3rded Pumo Parts in Unanoroved Box

= af Inspection Scoce (88100) ,

The inspectors reviewed the response to a notification by plant staff that potentially fissile i

. vacuum pump parts, which had been decontaminated in Building C-400 m, treated as i fissile exempt, contained visible trace amounts of potentially fissile grease and oil  ;

contamination (Certificatee Event Repcrt 33476).

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' B. Observations ar.d Findinas On Decembe/ 30, plant NCS staff discovered that decontamination operators in BL,,lding

C-400 had been placing vacuum pump parts which had been cleaned in the building into a waste B 25 box after the cleaning. The NCSA goveming the operatiort. GEN-12,"Small'

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, LVacuum Pump and Datum pump Handling, Transport, Decontamination, Disassembly,"

' exempted cleaned parts from NCS controisi The NCSA did not specify requirements for surveys to determine acceptable levels of any trace contamination which might be -

present after cleaning as other NCSAs for decontamination activities did. As a result, >

chemical operations staff basically cleaned the parts by hand techniques, but were.

unable to clean or left small amounts of visible slugged oil or grease in crevices of certain

parts. As a result, NCS staff identified that the parts did not meet the cleanliness -

requirement specified in NCSA GEN-12.

_. Upon, discovery, plant staff immediately halted the operation and cordoned off the B-25 .

box containing the pump partsi The inspectors observed the status of the box and noted

that there was visible grease or sludge, which could have been slightly contaminated, on certain parts. However, because of the large amount of leakage associated with thi Earray of parts in the box, snd because of an NCS evaluation for the operation at 2.0

.weight percent (the maximum enrichment of any parts decontaminated) demonstrating an -

infinite cube of uranium tetrafluoride (UF ) in oil at a uranium mass loading of 40 weight _

p percent (s conservative assumption) was always safe, the safety significance of the event -

- appeared to be minor. As part of the long-term corrective actions, plant staff identiflad' L the need to develop an action plan to separate the parts in accordance with current NCS ;

controls and revise the NCSA to include specific criteria for cleanliness of parts when r' exempting them from NCS controls, This non-repetitive, certificatee-identified and corrected violation is being treated as a Non-Cited Violation,' consistent with P -

Section Vll B.1 of the NRC Enforcement Policy. (NCV 70 7001/97014 05) -

[ > c. Conclusions

? A non cited violation for failura to fully decontaminate small vacuum pump parts in.

4 accordance with NCSA GEN-12 was identified by plant NCS staff. The lack of detailed

. guidance in the NCSA on exemiting cleaned parts from NCS controls contributed to inconsistent implementation cide NCSA.

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101.3 = Unacoroved Container in Buildina C-400 Fissile Control Area -

- af Inspection Scope (88100)  ;

_ During routine tours of facilities, the inspectors observed the stctus of fissile control areas

- (FCA) and the potentially fissile materials stored within the FCAs for compliance.with .!

current NCS program controls.

b.' Observations and Findinas ,

During a routine tour of the Building C-400 Decontamination Facility on November 25, the -

inspectors identified a laundry cart which had a capacity greater than 5.5 gellons in an -

FCA.- The FCA posting identified that portable containers within the FCA were required to be limited to a maximum capacity o' 5.5 gallons. The laundry cart had been used to; transport sandbags which were being u. sd to contain a water line leak from equipmsnt1

- adjacent to t' a FCA.-- The cart was inadvertently left in the FCA by operations staff who -

. . thought that additional sandbags might be needed. At the time of the finding,' there were

, no indications of potentially fissile materialinside the laundry cart. A 24-hour notification ,

was later mwde to the NRC pursuant to Bulletin gi-01 (Certificatee Event Report 33318). -

-The inspectors noted that other instances of containers exceeding the FCA volume limit

' had been identified in the recent past. In addition, on December 1, plant staff identified a vacuum cleaner in an FCA in the Building C-720 motor shop which also exceeded the . .

5.5-gallon limit No fissile material was found inside the vacuum, A 24-hour event report was made to the NRC on this event as well (Certificatee Event Report 33333) Plant -

management indicated that chemical operations staff were uncertEn as to what

constituted a ? container" which would fall under the FCA requirements. The facility

. - manager indicated he believed there was a need for additional training for plant staff on

, L the FCA container volume control, Technical Safety Requirement 3.11.2, required, in part, that all operations involving -

uranium enriched to 1.0 weight percent or nigher and 15 grams or more of uranium-235 be performed in accordance with a documented NCSA. Control 18 of NCSA GEN-15, "On Site Generation, Handling, Accumulation, Staging, Transportation,' and Storage of Fissile or Potentially Fissile Waste Up to a Maximum of 5.5 Weight Percent Enrichment," '

approved September 12, igg 6, required that portable containers used within an' FCA shall be limited to a maximum size 5.5-gallon capacity unless approved otherwise by NCS.

The storage of a laundry cart and vacuum cleaner exceeding the 5.5-gallon capacity limit,

, without prior approval of the NCS staff, in FCAs at Paducah are considered examples of

'_ a Violation of TSR 3.11.2 (VIO 70-7001/97014-02).

. ci ' Conclusion

- The inspectors and plant staff identified examples of a violation of the FCA volume limit

for portable containers.- The violation appeared to result from inadequate training as to what constituted a portable container and should be controlled in accordance with NCSA GEN-15 which govemed FCAs onsite.

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,uu o 08.1 Qertificatee Event Reports (90712)

The certificatee made the following operations related event reports during the inspection period. The inspectors reviewed any immediate efety concems indicated at the time of the initial verbal notification. The inspectors will evaluate the associated written reports for each of these items following submittal.

Number Status E!g 33328 Open Loss of Building C 300 Alarm Computer for High Pressure Fire Water System (CER 70 7001/97014-03) 08.2 pulletin 9101 Heppris (97012)

The certificatee made the following reports pursuant to Bulletin 9101 during the inspection period. The inspectors reviewed any immediate nuclear criticality safety concems associated with the report at the time of the initial verbal notification. Any significant issues emerging from these reviews are discussed in separate sections of the report.

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33306 11/74/97 Inadequate Non Destructive Assay Scan of Building C-400 Spray Booth Ventilation Duct 33318 11/25/97 Portable Laundry Cart Exceeding Safe Volume found in Hssile Control Area of Building C-400 33333 12/1/97 Po the Vacuum Cleaner Exceeding Safe Volume found in Fissile Control Area of Building C 720 3331,2 12/11/97 Unauthorized Fissile Material Operation for Storage of Non-Reusable Sea! Parts in Bulidings C-400 and C 746-Q1 33402 12/13/97 Improper Spaclag of Negative Air Machine, Seal Parts, and Drums in Building C-400 Receiving Booth 33403 12/14/97 Improper Spacir.g of Potentially Fissile Vacuum Cleaner Components in Building C-400 Receiving Booth 33404 !2/14/97 Lack of Nuclear Criticality Safety Approval for Removal of ,

Equipment from Potentially Fissile Solution Processes in I Building C-400 l 33419 12/16/97 Discovery of Unanalyzed Condition for Storage Drums Containing Poteritlally Fissile Process Parts 33449 12/22/97 Potential Deficient Nuclear Criticality Safety Evaluation of Building C 360 Autoclave Pressure Decay Testing 10

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33453 12/24/97 Potential Violation of Independent Verifications of Exempt Wastes under Nuclear Criticality Safety Approval GEN-07 i 33457 12/26/97 Potentially Fissile Materials in B 25 Box in Building C 335 Not Handled in Accordance with Current Nuclear Criticality  !

Safety Approval GEN-09 spacing Requirements '

1 33478 12/30/97 Potentially Fissile Small Vacuum Pump Paris l Inappropriately Treated as Exempt from Nuclear Criticality Safety Controls 33509 1/8/98 ; Lack of Criticality Safety Evaluation for Abandoned Cold l Trapping Systems in Buildings C-331, C-333, C-336, and C 337 33614 _1/8/98 Loss of One Mass control (Independent Verification) for Sample Tube Gaskets Contaminated with Potentially Fissile Materials ,

33547- 1/15/98' Error in Non Destructive Assay calculations Led to improper Characterization of Uranium Mass in Gas Cooler for Building C 335 Dual Speed Purge and Evacuation Pump

11. Maintenance and Survell'anoe >

M1. Condud of Maintenance and Surveillance -

M1,1 Buildina C-310 Alarm Annunciator Breaker Reclacement .;

a. inspection Scope (88102. 88103) l

- The inspedors observed selected aspects of the breaker replacement and  ;

[ troubleshooting performed in response to two event reports for Building C 310 No.1 Alarm Annunciator Cabinet breaker trips during October 1997.

' - b. Observations and Findings  ?

The inspectors observed portions of maintenance and troubleshooting activities

- performed in response to repeat events in October 1997 during which the Building C-310 alarm for the high voltage process gas leak detection (POLD) system was made inoperable while required by TSR. The inoperability occurred when the breaker >

l associated with the No.1 Alarm Annunciator Cabinet tripped (Certificatee Event Reports -

. 33124 and 33125).1 This safety system provided detection for a release above the UF. .

product condensors, accumulators, and associated heated housings in Building C 310A.

The No.1 Alarm Annunciator Cabinet in the basement of Building C-310 provided alarm ,

relay power for over 100 alarms, including alarms in the building and slave alarms in ,

~ Building C 331. - However, the high-voltage PGLD system is the only safety system alarm .

I In response to which action would be required by operators (See Section 01.1 of NRC '

' Inspection Report 97011(DNMS)). .

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in response to the events, electrical maintenance staff removed the old breaker and replaced it with another 10 ampere breaker with a longer overcurrent time delay. The plant staff also performed troubleshooting activities which included measuring voltages

. and currents for various operating conditions and infrared thermography to search for overheated components. Troubleshooting activities observed by the inspectors conformed with the requirements of the applicable work package including logging lifted and landed leads and jumpers. In addition, the inspectors noted that plant staff ,

implemented smoke watches required by TSR 2.3,4.4 LCO Action Statements for the disabled PGLD system in a timely manner.

The direct cause of the breaker trips was not determined from the troubleshooting efforts.

However, plant staff did identify that during alarm lamp tests, performed on a daily basis, the current demand exceeded the breaker rating by over 3 amperes. In order to reduce the load during the daily test, the EM staff removed 43 4 watt bulbs from redundant alarms in Building C 331. In addition, lower wattage (3 ampere) bulbs were installed to reduce the load to below 9 amperes. The long term corrective actions planned included relocating the high voltage PGLD alarm from the No.1 cabinet to an attemating current alarm annunciator system in the building.

c. Conciusion Troubleshooting activities observed by the inspectors for the Building C 310 No.1 Alarm Annunciator Cabinet and its asociated breaker were conducted in accordance with maintenance program and TSR ,equirements. The direct cause of the repeat breaker trips in October 1997 was not identified as of the end of the inspection period, although the dally lamp test for the alarms was demonstrated to exceed the breaker rating of 10 amperes.

111. Ennineerina E1. Conduct of Engineering E1.1 Inadeousto Nuclear Criticality Safety Reauests and Evaluations

a. Inspectiqn Scope f88101)

The inspectors reviewed the circumstances surrounding Bulletin 9101 event reports for activities and equipment not adequately covered by current NCSEs (Certificatee Event Reports 33392,33402,33403,33404,33419, and 33509).

b. Observations and Findinas On December 11, chemical operations and NCS staff identified that contaminated seal paris had been placed in unapproved containers (both 30-gallon and 55 gallon

. containers)in the Building C-400 Seal Receiving Booth and a Building C-746-Q1 seal storage cage. The use of unsafe volume containers with potentially fissile materials was a loss of all double contingency controls for these parts and, as such, resulted in the plant staff making a four hour notification to the NRC under Bulletin 9101, in describing the es found condition, the event report identified the storage of seal parts as "an operation that deviated from the analysis process description and represented an unauthorized 4

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fissile material operation.' The process description, that is, the input to the NCSE and NCSA for the seal disassembly and decontamination operation (NCSA 3g73-27), did not identify a third stream of parts which had historically been present. These parts were items which would neither be stored in approved seal canisters or disposed of in 5.5-gallon drums as waste. The use of large volume drums for reusable parts was not noted at the time the NCSA was implemented on October 1,1996.

In walkdowns of Building C-400 and other seal storage areas onsite after the discovery, plant staff identified several other NCS problems. These included improper spacing of a negative air machine (NAM) from the seal parts in Building C 400 which were originally believed to be clean; potentially fissile vacuum cleaner components in the Building C 400 Seal Receiving Booth spaced improperly; the discovery that there was no NCSA goveming removal of equipment from solution processes in Building C-400 which, although there were rio known removals, could have impacted seven pumps of unknown origin found around the building; and, the discovery of 10 SS-gallon drums with surface contaminated parts in a Building C 337 seal cage which were not covered by an NCSA, resulting in a four hour notification to the NRC. The issues raised as a result of the walkdowns were insightful, but indicated there had been inconsistent identification of some sect handling and decontamination activities by plant staff during the development of the goveming NCSAs. None of the activities, however, involved significant quantitles of fissile material given the nature of the equipment involved.

A related problem identified by plant staff during the inspection period involved the lack of an NCSA for process cold traps in the cascade buildings. This problem was identified during a walkdown of the corrective action plan development for a violation discussed in inspection Report 97011 (VIO 70 7001/0701107) for failure to include the holding drums for the UFgR 114 separation system in an NCSA. The lack of a specific NCSA to ensure double contingency for the cold trap systems led to a four hour event notification pursuant to Bulletin 91-01 (CER 33509). At the time of the discovery, the cold traps were isolated from the cascade and had been abandoned for some 30 years, although the traps were still tied to the cascade. However, there were no indications of fissile materialin the cold traps. In addition, the last operator to use the equipment was contacted by plant staff.

The operator indicated the cold traps had been purged and evacuated prior to abandonment.

Technical Safety Requirement 3.11.2, required that all operations involving uranium enriched to 1.0 weight percent or higher and 15 grams or more of uranium 235 be based upon a documented NCSE and performed in accordance with a documented NCSA. The operation of seal decontamination and seal parts storage activities without an NCSE and NCSA upon which to base the use of unsafe volume drums containing seal parts contaminated with uranium enriched to greater than 1.0 weight percent in uranium 235, from March 3 through December 11,1997,is a Violation of Technical Safety Requirement 3.11.2 (70 7001/97014-04).

The inspectors noted that plant staff had identified the specific problems discussed above. However, the issues raised a generic concem with the rigor which had been used in identifying and describing all potentially fissile operations and equipment during the NCSA development process. Enforcement Guidance Memorandum 97 012 stated the expectation that

• violations involving potential programmatic issues not be dispositioned as NCVs (Non-Cited Violations)." For this reason, that is, the potential generic issues 13

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! with the past rigor of the NCSE and NCSA development process at Paducah, a violation of TSR 3.11.2 is being cited.

, . The NCS staff discussed with the inspectors the staffs revised process, which applied to NCSAs developed since August 1996, which involved a detailed walkdown of any new NC8A prior to its implementation to ensure all operations have been identified and analyzed in addition, in the response letter to NRC Inspection Report g7011, dated January 22,1998, the certificates committed to performing a review of all NCSE process -

, description sections and hazards ident:fication and analysis sections against actual field j- operations by March 31,19g8. The certificates also stated that the implementing procedure (Procedure CP4 EG.NS1101, ' Evaluation of Requests for Criticality Safety Approval") was revised in August igg 7 to provide more explicit expectations for scooptance of requests for process evaluation as well as dry runs before implementation of the NCSA. The oortificates committed to performing crew briefings with NCS

' engineers and contractors to review the violation of TSR 3.11.2 to ensure adequate identification of systems requiring an NCSA. Based on these corrective actions and commitments, a response to this violation will not be required.

c. Conclusion A violation of TSR 3.11.2 resulting from inadequate requests and evaluations for seal handling operations, as well as other deficiencies with NCSAs identified during the inspection period, indicated a generic issue existed with the amount of detail and rigor which had been used in the past by plant staff when developing NCSEs and NCSAs to ensure all activities involving potentially fissile materials and systems were addressed.

E1.2 Nuclear Criticality Safety Self Assessment

a. Inspection Scope (88100)

The inspectors discussed the results of an NCS self-assessment undertaken b'y plant staff to review the status of the Paducah NCS program after significant issues were raised during an NCS Special inspection at Portsmouth GDP on December 812,19g7.

- b. Observations and Findinos On December 15, the PGDP General Manager initiated a self assessment of the NCS .

program implementation at Paducah. The self assessment was based on over 100 field observations of work activities and interviews with several personnel who were involved in NCS work activities. The observation of field activities involved a comparison of actual conditions against the controls identified in the goveming NCSAs and implementing procedures, The interview questionnalra was developed by a cross discipline team of members and focused on both the inte/viewee's knowledge of applicable NCS requirements as well as the human factors aspects of the NCS program.

The self assessment resulted in thres generic findings as well as several strengths and '

weaknesses. The three generic fine.gs were: NCS products were not always written so as to be understood at the floor level; lack of clear management expectations from senior management had negatively affected the NCS program; and, lack of resources ,

(personnel, training, Knowledge, etc.) dedicated to the NCS program had negatively  ;

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impacted the understanding of NCS requirements and protocolin the field. As of the end of the inspection, plant staff were performing a root cause analysis for the findings of the NCS self assessment in preparation for developing corrective actions. The inspectors noted that the self assessment had been probing and had identified a number of areas in which the NCS program implementation could be enhanced at Paducah.

c. Conclusions Plant staff undertook a probing self assessment of the NCS program implementation at Paducah following a Special Team inspection at Portsmouth which raised significant issues with NCS program implementation. The self assessment resulted in the identification of generic findings for which plant staff planned to develop root causes and corrective actions.

IV. Plant Support S1.0 Conduct of Secunty Activitleg 81,1 Use of Security Form 702 to Document Security Chec.h3

a. Inspection Scope (88100)

During a tour of Building C-400, the inspectors followed up on an indication that Security Form 702 had nct been used for a classified storage area,

b. Observations and Findinas On December 15, the inspectors identified that there was no Form SF 702, " Security Container Check Sheet," posted at a classified storage area in Building C-400.

Procedure CP2-SS SE1036,"Ct.ASSIFIED MATTER PROTECTION AND CONTROL,"

required that a Form SF 702 be used to document opening, and checks of security containers and classified storage areas, in response to the finding, plant staff made a one hour security event notification to the NRC. Plant staff also performed a walkdown of all similar storage areas onsite and identified deficiencies with the use of SF 702 forms. For example, SF-702 forms were found to be missin,) for classified storage areas in Buildings C 720 and C-746-Q. A completed SF 702 form was eventually found for the classified storage area in Building C-400. Plant staff indicated an error was made when a new form was not posted when space had been used up on the previous form. New forms were immediately posted in the classified storage areas.

Although the SF 702 form was not posted, checks of the areas by the security police staff and responsible building personnel were performed in accordance with Procedure CP2-SS SE1036. The security police used data acquisition units for their checks. The failure to post and use Form SF 702 for security checks of the classified storage areas constitutes a violation of minor significance and is being treated as a Non Cited Violation, consistent with Section IV of the NRC Enforcement Polley (NCV 70-7001/97014-06).

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c, Conclusion The inspectors !dentified a minor violation for a failure to post Form SF 702 for  ;

documenting classified storage area checks in Building 0 400. Plant staff found and H corrected similar deficiencies at other classified storage areas in response to the i inspectors' finding.  !

S1.2 Control of Classified Matter The certificates continued to notify the inspectors of discoveries of classified matter which was not properly marked or controlled. The discoveries were made as a result of the certificatee's corrective actions for the deficiencies in the control of classified matter identified as an apparent violation discussed in Section 81.1 of NRC Inspection Report 70 7001/97007(DNMS). In accordance with a letter from the NRC dated October 28, 1997, these events were grouped and submitted in a weekly written report to the NRC. j S8 , Miscellaneous Security lasues S8.1 Certificates Security Reports (90712)

The certificates made the following security related one hour reports pursuant to 10 CFR 95 during the inspection period. The inspectors reviewed any immediate security concems associated with the report at the time of the initial s erbal notification. Any significant issues emerging from these reviews are discussed in separate sections of the report.

QAin TEt 11/29/97 Building C-100 Classified Print Vault Door Not Secured 12/15/97 Form SF 702 Not Posted at Building C-400 Classified Storage Area 12/15/97 Fom) SF-702 Not Posted for Classified Storage Areas in Buildings C-333 and C 337 12/16/97. Form SF 702 Not Posted for ClassiSed Storage Areas in Buildings C 720 i and C 746-Q

' T1.0 - . Conduct of Transoortation Activities T1.1 Qomaae to Undercarriaae of Railcars Used for CGinder Shlomonts On January 13, plant staff identified a shiny spot on the undercarriage of one of the cylinder transportation railcars while removing the Paducah Tiger Overpacks. Similar problems were later identified on five additional railcars. The problem appeared to be the result of the wheels of the railcar rubbing the bed during transportation. Because the bed of the car was being pushed into the overpacks, plant staff discontinued the use of all railcars for transporting cylinders until corrective actions were established and the railcars were inspected. The Portsmouth GDP was also notified of the problem. As of the end of 16

e om 1 the inspection period, rail shipments between Paducah and Portsmouth had been discontinued.

V. Mananoment Meetina ,

X. Exit Meetina Summary The inspectors presented the inspection results to members of the plant staff and management at the conclusion of the inspection on January 20,1998. The plant staff acknowledged the findings presented, but Indicated there was some concem with the initial characterization of the PEH deposit in Building C 335 as a potential TSR violation. The plant staff noted that the TSR LCO Action Statements had been entered expeditiously upon the discovery that, contrary to a previous calculation, the deposit was above safe mass. The inspectors asked the plant staff whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified. .

PARTIAL LIST OF PERSONS CONTACTED United States Enrichment Corporation

• J. H. Miller, Vice President Production

• J. A. Labarraque, Safety, safeguards and Quality Manager Lockheed Martin Utility Services (LMUS)

• S. A. Polston, General Manager

• H. Pulley, Enrichment Plant Manager

• W. E. Sykes, Nuclear Regulatory Affairs Manager

• S. R. Penrod, Operations Manager United States Department of Enerov (DOE)

G. A. Bazzell, Site Safety Representative

• Denotes those present at the January 20,1998 exit meeting.

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

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e INSPECTloN PROCEDURES USED lP 88100 Plant operations IP 88102 Surveillance Observations IP 88103 Maintenance observations IP 88105 Management Oversl9ht and Controls IP 90712 in-offlos Review of Events IP 92702 Follow-up of Events ITEMS OPENED, CLOSED, AND DISCUSSED QRtntd 70 7001/97014-01 - VIO failure to perform shiftly surveillance of recirculating cooling water pressure for planned expeditious handling deposit 70 7001/97014-02 VIO use of unapproved, unsafe volume containers in Fissile Control Areas 70 7001/97014 03 CER loss of alarm computer in Building C 300 for High Pressure Fire Water system 70 7001/97014-04 VIO - operations involving potentially fissile materials not covered by nuclear criticality safety evaluations or approvals Gl0&td 70 7001/97014-05 NCV spoolfic criteria for cleanliness of parts when exempting them from NCS controls 70 7001/97014 06 - NCV security Form 702 not used for a classified storage area Discussed 70 7001/97007-09 eel failure to property control classified matter 70 7001/97_011 02 - CER . loss of power to high voltage process gas leak detection system alarms 70 7001/97011 032 'CER loss of power to high voltage p.ocess gas leak detection system

- alarms 18

e LIST OF ACRONYMS USED ACR Area Control Room AQ Augmented Quality AQ NCS Augmented uuslity . Nuclear . Criticality Safety CAA Controlled Access Area CAAS Criticality Accident Alarm System CER Certificatee Event Report CFR Code of Federal Regulations DNMS Division of Nuclear Materials Safety

-FCA Fissile Control Area HPT Health Physics Technician IFl inspector Follow-up item LCO Limiting Condition for Operation NAM Negative Air Machine <

NCSA- Nuclear Criticality Safety Approval NCSE Nuclear Criticality Safety Evaluation NCV Non cited Violation NDA Non destructive Assay NOV Notice of Violation NRC Nuclear Regulatory Commission PDR Public Document Room PGLD Process Gas Leak Detection PGLD Process Gas Leak Detection PSIA Pounds Per Square Inch Absolute PSIG Pounds Per Square Inch Gage PSS Plant Shift Supervisor -

RCW Recirculating Cooling Water SAR Safety Analysis Report -

TSR Technical Safety Requirement URI Unresolved item USEC United States Enrichment Corporation VIO Violation ig