ML20204D861

Insp Rept 70-7002/99-01 on 990112-0222.Violations Noted. Major Areas Inspected:Plant Operations,Maint,Engineering & Plant Support

ML20204D861
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant
Issue date:	03/17/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20204D803	List: ML20204D799 ML20204D845 ML20204D861
References
70-7002-99-01, 70-7002-99-1, NUDOCS 9903240299
Download: ML20204D861 (19)

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U.S. NUCLEAR REGULATORY COMMISSION l

REGIONlli I I

Docket No: 70-7002 Certificate No: GDP-2 )

l Report No: 70-7002/99001(DNMS)

Facility Operator: United States Enrichment Corporation  !

Facility: Portsmouth Gaseous Diffusion Plant Location: 3930 U.S. Route 23 South P.O. Box 628 i Piketon, OH 45661 I Dates: January 12 through February 22,1999 Inspectors: D. J. Hartland, Senior Resident inspector -

C. A. Blanchard, Resident inspector 1

Approved By: Patrick L. Hiland, Chief Fuel Cycle Branch Division of Nuclear Materials Safety t

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l 9903240299 990317 l PDR ADOCK 07007002 l C PDR l

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EXECUTIVE

SUMMARY

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l United States Enrichment Corporation l Portsmouth Gaseous Diffusion Plant l NRC Inspection Report 70-7002/99001(DNMS) i l

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

Eant Ooerations

• The inspectors concluded that the certificatee failed to take action to prevent challenges l to safety systems prior to returning equipment to service. One violation was identified. l l

l (Section O1.1) e The inspectors concluded that the certificatee took appropriate action, upon l

l identification of errors in calculations involving the heavy metal precipitation process in Building X-705, to shut down all similar batching operations in the plant to determine the l extent of the problem, and to prevent recurrence. One non-cited violation was identified. l (Section O1.2) e Due to poor communications among operations staff, respirators for Area Control Room (ACR) No. 3 operators were staged in ACR No. 2. (Section 01.3)

! Maintenance and Surveillance e The certificatee did not enter the Technical Safety Requirement (TSR) action statement i for a cascade unit battery or monitor to verify that the minimum specific gravity  ;

requirement was not compromised. The safety significance was minimal as the charger maintained the required voltage and the TSR was not violated, as no cells were put in service in the affected unit while the battery was loaded. (Section M1.1)

, Enaineerina i e The inspectors identified examples of the failure to follow procedures regarding planned i expeditious handling deposit tracking, and response to nuclear criticality safety F anomalous conditions. (Section E2.1) l

• The inspectors concluded that the certificatee's calibration program did not ensure that instruments relied on to verify TSR compliance were calibrated. The certificatee could not readily determine the calibration status of instruments used to measure equipment l

and system operating parameters. In response, the certificatee initiated a sys,tematic and comprehensive plant initiative to ensure compliance with certificate requirements.

l One inspector followup item was identified. (Section E2.2) 2

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l Plant Suooort

• The shipment of an empty cylinder, with radiation levels in excess of NRC transportation limits, was due primarily to the shipment of the cylinder prior to the completion of a required 30 day " cooling" period. The safety significance was minimal as there was limited potential of radiation dose to the general population during shipment.

Pending further review by the NRC, these issues will be tracked as an unresolved item.

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Report Details

-L.Qantations 01 Conduct of Operations 01.1 Failure to Take Action to Prevent Safety Actuations

a. Insoection Scope (88100)

The inspectors reviewed the adequacy of actions taken by the certificatee to prevent recurrence of safety actuations prior to retuming systems to service.

b. Observations and Findinas ,

l During the inspection period, the inspectors noted two examples of systems returned to )

service following safety actuations without the certificatee determining the root cause  !

and taking action to prevent recurrence: I 1

e On January 12, operators received an instrument air low pressure alarrr and steam shutdown on Autoclave No.1 at Building X-344. In responue, the first line manager (FLM) checked the air pressure, as required by the annunciator response procedure, and observed that the pressure was normal. The FLM also noted that there were no apparent Technical Safety Requirement (TSR) implications and concluded that the instrument air low pressure switch was not safety-related without reviewing the boundary manual which indicated that the switch was a Quality component. The FLM believed that the alarm was spurious and placed the autoclave back in service without initiating a problem report or notifying the plant shift superintendent's (PSS) office.

After the transfer of the' remainder of the contents of the cylinder was completed, instrument maintenance performed as-found checks of the switch and found that '

l the switch was out-of-tolerance on the non-conservative side. Therefore, ,

I setpoint drift did not cause the actuation to occur. Engineering performed an investigation but could not determine the cause of actuation. The problem appeared to have been spurious actuation of the switen, as there have been no l recurrences.

The FLM's reasoning for retuming the autoclave to service without notifying the PSS or investigating the root cause was that the FLM believed that the l component was not safety-related. The inspectors concluded that whether the  !

component was satty-related or not, an effort was required to understand the L root cause and take action to prevent further challenges to the safety system

! prior to retuming the autoclave to service.

e On January 15, power was lost to the north crane at the Ta'Is Station early in the day and then later to the south crane. The latter resulted in a suspended solid cylinder and a challenge to the crane's safety system, as the brakes actuate on

- loss of power; The loss of power was due to icing of the feed rails. The

' certificatee later determined that the ice was coming from a leak in the roof and problem reports were initiated to document the events, but the PSS authorized

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the return to service of the cranes without taking action to prevent the problem 1 from recurring.

On January 18, the inspectors discussed the issue with several members of the plant staff, but no compensatory action was taken until involvement by the general manager. Upon further review, the certificatee took action, when temperatures fell below freezing, to run cranas operated outside unloaded over areas to be traversed prior to commencing cylinder moves. In addition, engineering committed to perform an evaluation to assess the potential impact of adverse weather on all plant cranes.

The inspectors noted that a similar event occurred in October 1997, as discussed in inspection Report 70-7002/97010 (DNMS). The event involved the return to service of an autoclave following a high steam p assure shutdown. The PSS authorized restart of that autoclave without verifying the root cause and preventing recurrence of the safety system actuation.

TSR 3.9.1 required, in part, that written procedures shall be implemented for activities described in Appendix A of Safety Analysis Report (SAR) Section 6.11, " Procedures."

Appendix A of Section 6.11 described investigations and reporting as an activity that shall be implemented in accordance with written procedures.

Paragraph 2.1.3 of Procedure XP2-BM-Cl1030, " Problem Reporting," requires that a problem report be initiated for false system actuations related to safety system items.

Paragraph 5.1.2a of Procedure XP4-SF-SF1110, " Plant Shift Superintendent Actions On Problem Reports," required, in part, that anytime a safety system actuated, the system was not returned to service until the actuation was investigated, corrective actions were taken to prever't recurrence, and actions documented and reported to appropriate level of management.

However, on January 12, the certificatee retumed Autoclave No.1 at Building X-344 to service following a steam shutdown without initiating a problem report and, as a result, did not investigate the cause or take action to prevent recurrence. In addition, on January 15, the certificatee returned both Tails Cranes to service following loss of power, which actuated the emergency braking systems, after documenting the events in problem reports but without taking action to prevent recurrence and documenting the ,

actioas. The failure to take action to prevent recurrence of safety system actuations is a Violation of TSR 3.9.1. (VIO 70-7002/9900141a,b)

c. Conclusion The inspectors concluded that the certificatee failed to take action to prevent challenges to safety system prior to returning equipment to service. One violation was identified.

01.2 Loss of Both Nuclear Criticality Safety (NCS) Controls Durina Batchina in Buildino X-705

a. Inspection Scope (88100)

The inspectors followed up on an event involving loss of both NCS controls in Building X-705.

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b. Observations and Findinos On February 9, during a record review, an operator identified errors in calculations used to determine uranium-235 (U-235) mass prior to transferring and processing waste solutions to an unfavorable geometry tank in Building X-705. The problem involved transcription errors of sample results to batch sheets used in the heavy metals precipitation process. The certificatee determined that the double contingency principle was violated because the second control, verification of the sample data and calculations by a second operator, did not identify the errors.

The transcription errors resulted in a non-conservative determination of the mass of U-235 processed to the unfavorable geometry. The certificatee corrected the errors and determined that 140 grams, instead of the 40 grams previously calculated, had been

- processed. The inspectors noted that the total amount of U-235 was still below the 200 gram limit specified in Nuclear Criticality Safety Approval (NCSA) 705-C27, " Heavy Metals Precipitation," and well below the minimum critical mass of 760 grams, assuming 100 percent enrichment. The inspectors also noted that additional safety margin was available, as the NCSA assumed that the enrichment of the uranium processed was 100 percent, when the certificate restricted possession limits to 10 percent enrichment.

The actual enrichment of the solution processed was determined to be 3.95 percent.

As immediate action, the certificatee shut down all batching evolutions in the plant that had the verification of calculations as a second NCSA control. The certificatee performed a 6 month review of previous batch sheets and found no additional errors.

The certificatee determined that the root cause was the failure of the verifier to independently check that the sample data was properly transcribed to the batch sheets.

As corrective action, the certificatee intended to enhance the applicable operating procedures to ensure that a fully independent verification of sample data and calcu!ations was performed.

The loss of both NCS controls was a violation of TSR 3.11.2. However, the certificatee identified the errors, the problem was determined to be isolated in nature, and corrective action was taken to prevent recurrence. In aJdition, the event was not safety significant as the mass limit specified in the NCSA was not exceeded. Therefore, this certificatee identified and corrected violation is being treated as a Non-Cited Violation (NCV),

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

c. Conclusions The inspectors concluded that the cetficatee took appropriate action, upon identification of the errors, to shut down all similar batching operations in the plant to determine the extent of the problem, and ?o prevent recurrence. One NCV was identified.

01.3 Eg-staaina of Respiratory Protection Eauipment

a. Insoection Scope (88100)

The inspectors reviewed the certificatee's interim corrective action to address the availability of respiratory protection equipment in the cascade buildings.

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! b. Observations and Findinas j

. The inspectors identified problems with the availability of respirators for

ascade operators during the December 9,1998, cell fire, inspection Report 070-7002/98019(DNMS) noted that the respirators for cascade operators were not pre-staged in a location that ensured the respirators would be immediately ,

, available to cascade operators in Building X-326 Area Control Room (ACR) No. 6. l 4

Specifically, the inspection report noted that the certificatee staged respirators for  !

l cascade operators outside the ACR. In respanse, the certificatee initiated action to 4

ensure that respirators were located in the ACR that the operators were assigned.

I i i On February 4, during a tour of Building X-330, the inspectors identified that the '

_ respirators for operators assigned to ACR No. 3 were staged inside ACR No. 2.

Subsequently, the inspectors discussed the issue with the PSS. The PSS immediately requested that operations staff take action to ensure respirators were staged in the ACR j that the operators were assigned. Approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> later, process building j management notified the PS ; that the respirators for ACR No. 3 operators were m aved

to the ACR. In addition, the Buildings X-326 and X-330 management notified the FSS that respirators were appropriately staged in the ACRs that the operators were assigned.

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! The inspectors discussed with operation management why respirators for ACR No. 3 j operators were not staged in the ACR. Operations management explained that the j building managers were instructed to move respirators into the ACRs as corrective j action to the December fire. Operations management stated that a verbal 4

misunderstanding resulted in respirators for ACR No. 3 operators staged in ACR No. 2.

The inspectors noted that operations management did not use a more formal mechanism, such as a daily operating instruction or operations organizational policy, to i communicate management's expectation regarding the location of respirators in the cascade buildings.

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c. Conclusions  ;

Due to poor communications among operations staff, respirators for ACR No. 3 operators were staged in ACR No. 2.

08 Miscellaneous Operation issues 08.1 Certificatee Event Reports (90712)

The certificatee made the following operations-related event reports during the inspection period. The inspectors reviewed any immediate safety concerns indicated at the time of the initial verbal notification. The inspectors will evaluate the associated written reports for each of the events following submittal, as applicable.

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Number Date Status Title l

N/A 02/15/99 Open 10 CFR 71.95 event - United States l Enrichment Corporation owned 308 l cylinders manufactured to American National Standards Institute (ANSI) N14.1 (1995 edition) had been shipped in overpacks whose Certificate of Compliance specifies manufacture to ANSI N14.1 (1990 edition) 35389 02/19/99 Open Safety System Failure - Criticality Accident Alarm System (CAAS) nitrogen operated

, hom, which was a slaved system, was discovered with the nitrogen bottle valved off.

08.2 Bulletin 91-01 Reports (97012)

The certificatee made the following reports pursuant to Bulletin 91-01 during the inspection period. The inspectors reviewed any immediate NCS concerns 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 this report or in future inspection reports.

Number Date Title 35246 01/12/99 4-Hour Report - Several Building X-705 NCSAs dealing with the disassembly of equipment previously classified as uncomplicated handling were determined to be deficient.

35275 01/15/99 4-Hour Report - Building X-326 NCSAs did not describe the operation / controls for certain abandoned in place equipment.

35302 01/22/99 4-Hour Report - No NCSA for three calibration buggies discovered in Building X-326.

35315 01/25/99 24-Hour Report - Violation of Building X-705 NCSA requirements for uranium bearing G-17 valves spaced less than 4 feet from seal cans.

35357 02/08/99 24-Hour Report - Plastic bag containing oily absorbent pads discovered in seal exhaust station with top open and without holes in bag.

35361 02/10/99 4-Hour Report - Sample results for raffinate solutions recorded incorrectly resulting in solution transfer to j geometrically unfavorable container without correct U-235 i concentration and mass recorded. (Section 8.2) 1 8

35394 2/22/99 24-Hour Report - Two off-stream cells in Building X-333 i discovered with condensers not vented.

08.3 (Closed) VIO 70-7002/97003-02: The certificatee's corrective actions were not

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adequate to prevent the recurrence of autoclave high condensate level safety system l actuations. To predade a reoccurrence, the certificatee issued work instructions for i autoclaves to ensure that any known or suspect foreign material entering the autoclave i

condensate drain system was removed. Subsequently, the certificatee revised the

appropriate autoclave procedures to incorporate the actions required by the interim foreign material verification work instruction. In addition, the certificatee increased the

condensate in-line strainer cleaning frequency to ensure the autoclave strainers were appropriately cleaned. The Building X-344 autoclave condensate strainers were i replaced with strainers that incorporated a larger surface area and mesh size. The l inspectors noted that the results of the certificatee's corrective actions to prevent recurrence of condensate level cutoff safety system actuations were effective and 3 considered the violation closed.

i 08.4 (Closed) VIO 70-7002/98003-01. VIO 70-7002/98005-02 (03014). and l VIO 70-7002/98005-01 (02034): Failure to ensure that equipment under a UF. negative j had a plant dry air or nitrogen buffer greater than or equal to 14 pounds per square inch j absolute. Also, a procedural violation associated with communication between process j services staff and the cascade controller was identified.

} The certificatee determined the lack of a proceduralized program for verifying and maintaining a fluorinating environment in cells or other equipment which was shutdown j and contained a planned expeditious handling (PEH) deposit was the cause of the j violation. Interim corrective actions included requirements to submit written requests for j lab samples weekly, to notify the lab of specific reporting constraints, and for lab j personnel to provide written sample results within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from obtaining samples.

j The inspectors noted that the certificatee's interim actions were flowed into

Procedure XP2-CO-CM1700, "PEH Tracking." The inspectors were not aware of any i further violations of this nature. As a result, the inspectors concluded the certificatee's

) corrective actions were reasonable and considered the violations closed.

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08.5 (Closed) URI 70-7002/98007-03

The certificatee's review and resolution of the issue j regarding guidance for autoclave operation during a building evacuation. The .

! certificatee revised applicable procedures to require that the local emergency director

[j report to the command post and brief the incident commander on the status of autoclaves. In addition, in response to a related issue (URI 70-7002/98005-03)

> regarding the "see and flee policy" in the cascade buildings, the incident commanders j have been instructed to permit operators to re-enter affected areas and monitor q operating equipment as conditions permit. The certificatee was also evaluating the use j- of alarming airbome radioactivity monitors in the facilities to allow for a more timely l assessment of the extent of a release. - The inspectors will use URI 70-7002/98005-03

to track this issue to completion. This item is closed.

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/ 08.6 (Closed) URI 70-7002/98007-04: Action plan to address the backlog of greater than safe mass deposits. The inspectors reviewed the latest plan and noted that the plan provided an overall schedule for removal of deposits, including identification of deficiencies which must be corrected prior to initiating chemical treatments. The inspectors noted that the plan provided the needed overall focus to address the backlog, 9

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and would continue to monitor progress as part of routine inspection. This item is closed.

II. Main % nance and Surveillance M1 Conduct of Maintenance and Surveillance M1.1 Failure to Enter TSR Action Statement After Loadina Battery

a. Inspection Scooe (88103)

The inspectors reviewed certificatee maintenance activities to ensure compliance with TSR action statements. 1 l

b. Observations and Findinas On January 19, the inspectors noted that on the previous day the certific, tee performed maintenance on the normallighting transformer for Unit 31-4. The activity required that the emergency egress lighting be energized which loaded the battery. The espectors noted that the operator did not identify the need to enter the 90 day action statement for TSR 2.2.3.14 prior to authorizing start wr,rk approval, nor was any monitoring of the battery performed even though the minimum specific gravity requirement may have been compromised.

The safety function of the battery was to provide cell remote power as well as emergency egress lighting. The emergency lighting was 125 volts, so half the 250 volt battery was drawn down when loaded. Therefore, not only were the TSR parameters potentially compromised, the life of the battery was also potentially reduced because the other half of the battery was overcharged with the 250 volt charger.

After discussion with the inspectors, the certifMatee immediately entered the 90 day l action statement. The surveillance performeo later that week indicated that the specific )

gravity of the cells was above the minimum required value of 1.180. In addition, an engineering evaluation was performed which recommended the need to enter the action statement when the battery was loaded, as well as develop a procedure to use a 125 voit charger to charge half a battery. The safety significance was minimal as the minimum required voltage was maintained by the charger. In addition, the TSR was not violated, as no applicable operational modes were entered in the affected unit while che ,

battery was loaded. l

c. Conclusions The certificatee did not enter the TSR action statement or monitor to verify that the rninimum specific gravity requirement was not compromised. The safety significance I was minimal as the charger maintained the required voltage. In addition, the TSR was l not violated, as no applicable operational modes were entered in the affecteci unit while the battery was loaded.  !

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M8 Miscellaneous Maintenance issues M8.1 (Closed) VIO 70-7002/98003-04: TSR violation during CAAS. The certificatee determined that the cause of the violation was that the protective forces personnel, who were responsible for establishing appropriate barriers, failed to follow Procedure XP4-SS-SP1108, " Protection Force Pre-and-Post Maintenance Activities."

The procedure required protective force personnel to use plastic chains with "Do Not Enter" signs which were unique to CAAS boundary postings. The certificatee identified that the protective force personnel deviated from the procedure requirement and used common " Caution" barrier tape for the limited exclusion CAAS boundary. As corrective actions, the protective forces personnel received refresher training in labeling criteria required to establish limited operations areas, including expectations associated with following procedures. The inspectors were not aware of any further violations of this nature. As a result, the inspectors concluded the certificatee's corrective actions were reasonable and consider the violation closed.

M8.2 (Closed) VIO 70-7002/97015-02 and VIO 70-7002/98003-05: Failure to comply with TSRs during maintenance and surveillance activities at the Extended Range Product Station. The certificatee identified the cause for the violations was due to inadequate training of the cascade FLMs. Specifically, the FLM did not perform an adequate i

technical review of the work packages to ensure appropriate TSR action statements were entered to support the activities. As corrective actions, the cascade FLMs received refresher training on lessons learned from the two events. In addition, crew briefings further communicated the certificatee's expectation on work start authorization and the requirements of Procedure XP2-GP-GP1030, " Work Control Process." The inspectors concluded the certificatee's corrective actions were reasonable and considered the violations closed.

Ill. Enaineer_iDE i

E2 Engineering Support of Facilities and Equipment E2.1 NCS Anomalous Procedure Non-Comoliances

a. Insoection Scooe (88101)

The inspectors observed the certificatee's response to NCS anomalous conditions.

b. Observations and Findinos The inspectors identified examples of failure to follow requirements in Procedure XP4-EG-NS1025, "NCS Response To Anomalous Conditions":

• NCS engineers did not complete the incident report required by the procedure

, after identifying several pieces of abandoned equipment in Buildings X-705 and

! X-700 that were not covered by an NCSA. However, an informal evaluation was

, conducted that indicated a safety concem did not exist, appropriate 3

compensatory actions were taken, and the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> notification to the NRC was

made in a timely manner, i

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• The certificatee identified that the evacuation booster station in Building X-326 ,

which has not been operated in years was not covered by an NCSA. The area  ;

was not immediately roped off as required by the procedure to prevent the intrcduction and interaction with other uranium-bearing material.

The inspectors also noted that the 50 percent uncertainty was not applied to deposits in equipment shutdown in Building X-326 during highly enriched uranium suspension activities. Applying the error resulted in an additional 444 deposits added to the PEH tracking list. The issue was of minimal safety significance as the equipment was buffered with dry air but additional controls would have been required if the equipment was removed as required by TSR 2.7.3.15.

Failure to follow procedures regarding PEH deposit tracking and response to anomalous conddions was a violation of minor safety significance and is not subject to formal ,

enforcement action.

l l c. Conclusion  ;

! l l The inspectors identified a violation of minor safety significance regarding failure to  ;

j follow procedures regarding PEH deposit tracking and response to NCS anomalous j conditions. l l E2.2 Instrumentatior1 Calibration Proaram I

a. Inspection Scope (88101)

The inspectors reviewed the certificatee's program to ensure instruments used for measuring process conditions were calibrated.

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b. Observations and Findinas l

On January 12, the inspectors discussed with the certificatee management an issue regarding instrument calibration as documented in Problem Report 99-0190, which identified that calibration stickers were missing or expired on several CAAS nitrogen cabinet instruments. The inspector noted that instruments were used to monitor the nitrogen bottle and line (down stream of regulator) pressures used for the CAAS strombos homs. In addition, the inspectors noted that the operator weekly round sheet required operators to record both pressures. Through a record review, the certificatee determined that the calibrations were current for nitrogen bottle and line pressure I instruments. However, the instruments were not included in the cet tificatee's Computer Maintenance Management System (CMMS), an instrument calibration scheduling system that automatically generated a maintenance service request when an instrument 1 calibration was due. The inspectors discussed with certificatee management the issue that the potential existed for operators to use uncalibrated instruments.  !

On January 27, during a tour of Building X-333, the inspectors identified instruments used to verify SAR, TSR, and NCS compliance with missing or expired calibration stickers. The certificatee took immediate action to address the calibration concerns and found that the cell freon, recycle cooling water, and seat exhaust header pressure i instruments were currently calibrated and included in the CMMS but were not j adequately labeled. The certificatee identified that the 16 battery voltmeters were not 12 l

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l calibrated or in the CMMS but had received a two-point voltage test. In addition, one air i pressure instrument used to verify adequate pressure was available to open cascade stage motor circuit breakers was not in the CMMS and the calibration due date was December 1997. The certificatee used the battery voltmeter instruments to ensure voltage was greater than 200 volts, and the air pressure instrument to verify cell breaker ,

air pressure was greater than 195 pounds per square inch gauge as required by TSR, Section 2.2.3.14, " Cascade DC Control Power." The certificatee determined ths'.the

- two-point check was an acceptable means to verify that the voltmeters were reading accurately, in addition, the air pressure gauge passed an as-found check.

On January 27, due to the potential generic implications of the issue, the certificatee formed a team to evaluate a sampling of instruments used to measure TSR, SAR, and NCS surveillances. The team identified the TSR surveillance, what process instrument was used to measure the surveillance requirement, the status of the instrument j calibration, and noted if the instrument was in the certificatee's CMMS system. The J certificatee found that instruments were calibrated for the select operable equipment but identified several administrative concems. The certificatee's identified instrument calibration concems included the following:

• Calibration stickers were missing or inaccurate.

e inconsistent quality classification (Non-safety versus Quality) for instruments used to measure TSR, SAR, and NCSA operating parameters. l 3

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• Several different systems were used to track the calibration of instru.1ents.  ;

e Operator round sheets did not specifically identify the instrument to measure

TSR, SAR, and NSA operating parameters.

l As a result, on January 28, the certificatee expanded the team charter to systematically .

! review the entire calibration program for compliance with TSR, SAR, and NCS j requirements. The inspectors noted that the calibration team review included the 1

following actions

i i e identify TSR, SAR, and NCS surveillance requirements.

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• Ensure the round sheet or procedure identify the appropriate instrument for required measurement.

! e Check the instrument for current calibration and appropriate quality classification, 3

and ensure the instrument was included in the CMMS. ,

j On February 2, to expedite the team's calibration program review, the certificatee issued

a directive to all production and utility facility managers. The directive required the i operators to verify that instruments read during routine round sheet log activities were i calibrated. As a result of this directive, severel problem reports have been initiated.

1 The inspectors noted that the certificatee took the appropriate interim actions to ensure

! operability of equipment or systems where calibration issues were identified. The i certificatee's completion of the review of the calibration program for compliance with  ;

TSR, SAR, and NCS requirements is an inspection Followup Item (IFI).

(70-7002/99001-02).

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c. Conclusion .

1 The inspectors concluded that the certificatee's calibration program did not ensure that j instruments relied on to verify TSR compliance were calibrated. The certificatee could I

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not readily determine the calibration status of instruments used to measure equipment and system operating parameters. In response, the certificatee initiated a systematic and comprehensive plant initiative to ensure compliance with TSR, SAR, and NCS requirements. One IFl was identified E8 Miscellaneous Engineering issues E8.1 (Closed VIO 70-7002/98003-06): The certificatee's corrective actions failed to ensure that the autoclave low cylinder pressure shutoff system setpoint did not drift below 20 psia. The certificatee determined the reason for the violation was a non-conservative decision which allowed the operation of autoclaves without first recalibrating the setpoint to a re-engineered higher setpoint. As corrective actions, the design and system engineers received fermal training on operability evaluations and the control mechanism imposed by the process. The training improved engineering sensitivity through a heightened awareness of the overall process. The inspectors were not aware of any further violations of this nature. As a result, the inspectors concluded the certificatee's corrective actions were reasonable and consider the violation closed.

IV. Plant SuDDort R1 Radiological Protection Controls R1.1 Emotv Cylinder Shioped in Excess of Transportation Limits

a. Insoection Scone (86740) '

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The inspectors followed up on an event regarding the shipment of an empty cylinder in excess of transportation limits for external radiation.

b. Observations and Findinas On February 11, during a survey of an incoming empty cylinder shipment from the  !

Portsmouth Site, Paducah Gaseous Diffusion Plant (PGDP) health physics technicians  !

discovered a 350 mrem / hour " hot spot," about the size of a dime, on the bottom of one 1 of the cylinders. Tae radiation levels exceeded the 200 mrem / hour NRC limit for the accessible surface of the shipping package as documented in 10 CFR Part 71.47. A one hour notification was made to the NRC as required by 10 CFR Part 20. The outgoing survey taken at Portsmouth the previous day indicated a maximum reading of 150 mrem / hour on contact with the cylinder.

The certificatee determined that the root cause was that the cylinder was shipped prior to the end of the 30 day " cooling" period required by Procedure XP4-TE-EA1807,

" Receipt of Natural and Paducah Product Feed and Shipment of Feed Containers," due 4 to a logging error. The cooling perbd allowed for the radioactive decay of short-lived radionuclide decay products of uranium which remained in the empty cylinder. The certificatee was also investigating possible causes for the difference in the readings between the two sites. The investigation included a review of calibration methodologies used to calibrate the instruments, a possible shift in contents during shipment, and an inadequate survey.

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The safety significance of this issue was minimal. The " hot spot" was located on the  ;

hottom of the cylinder and was not readily accessible during transportation. The '

maximum radiation reading from 1 meter was 6 mrem / hour, less than the 10 mrem / hour NRC limit. Radiation readings in the cab of the tractor trailer were less than 0.2 mrem / hour. As immediate compensatory action, pending completion of the investigation, the certificatee administratively limited cylinder shipments to PGDP to less i than 50 mrem / hour on contact. Cylinders shipped to other destinations with contact l radiation readings greater than 100 mrem / hour would require special approval from the ,

radiation protection manager. i 10 CFR Part 71.47 required, in part, that each package of radioactive material offered for transportation must be designed and prepared for shipment so that under conditions normally incident to transportation the radiation level did not exceed i 200 mrem / hour at any point on the extemal surface of the package. Paragraph 6.5 of Procedure XP4-TE-EA1807, " Receipt of Natural and Paducah Product Feed and Shipment of Feed Containers," also required that a cylinder must be stored for a period of not less than 30 days after emptying, (to allow for cooling) prior to return shipment to the supplier.

Pending further review by the NRC, these issues will be tracked as an Unresolved item (URI) 040-03392/99001-03.

c.' Conclusions The shipment of an empty cylinder, with radiation levels in excess of NRC transpmtion limits, was due primarily to the shipment of the cylinder prior to the completion of a required 30 day " cooling" period. The safety significance was minimal as there was limited potential of radiation dose to the general population during shipment. Pending further review by the NRC, these issues will be tracked as an Unresolved item.

i 88 Miscellaneous Security issues S8.1 Certificatee Security Reoorts (90712)

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

Dalt Tsla 01/15/99 Classified matter discovered in an unclassified database.

01/16/99 Classified repository in Building X-104 found unlocked and unattended.

01/20/99 Classified matter in Building X-710 logged into unclassified logbook.

02/01/99 Unmarked classified package containing videotapes sent to

{

Portsmouth from Paducah via United States Postal Service.

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02/02/99 Unmarked classified drawing discovered in Building X-333.

V. Manaaement Meetinas X1 Exit Meeting Summary The inspectors presented the inspection results to members of the facility management on February 22,1999. The plant staff acknowledged the findings presented. The inspectors asked the plant staff whether any materials examined during the inspection should be  ;

considered proprietary, No proprietary information was identified. '

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

iI i PARTIAL LIST OF PERSONS CONTACTED l

Lockheed Martin Utility Serviggg

• J. Brown, General Manager

• B. Carrick, Acting Engineering Manager l *S. Casto, Work Control Manager I- *S. Fout, Operations Manager  !

l *P. Miner, Regulatory Affairs Manager '

l - *P. Musser, Enrichment Plant Manager

• P. Miner, Regulatory Affairs Manager l *M. Wayland, Maintenance Manager Maited States Enrichment Corooration J. Adkins', United States Enrichment Corporation, Vice President, Production

• L. Fink, Safety, Safeguards & Quality Manager

• Denotes those present at the exit meeting on February 22,1999.

INSPECTION PROCEDURES USED IP 86740 Trarsportation IP 88100: Plant Operations IP 88101: Configuration Control l

IP f a103: Maintenance Observations IP 90712: In-office Reviews of Written Reports on Nonroutine Events j ITEMS OPENED, CLOSED, AND DISCUSSED Opened 070-7002/99001-01 VIO Failure to take action to prevent challenges to safety systems L prior to returning equipment to service.

i L 070-7002/99001-02 IFl Review of calibration program to ensure compliance with .

! certificate requirements.

I 070-7002/99001-03 URI Shipment of empty cylinder prior to completion of 30 day cooling

. period and in excess of transportation limits for radiation levels.

Closed l

l 070-7002/97003-02 VIO Failure to prevent the recurrence of the condensate level cutoff safety system actuations.

070-7002/98003-01 VIO Failure to ensure that the 29AB3 compressor under a uranium  !

hexafluoride negative had a plant dry air or nitrogen buffer greater i than or equal to 14 pounds per square inch absolute.

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1 l 070-7002/97015-02 VIO Failure to isolate the withdrawal manifold at Extended Range Product Station No.1 within 15 minutes after declaring the station inoperable.  ;

070-7002/98003-04 VIO Failure to control plant employees from entering an area that i required an audible CAAG.

l 070-7002/98003-05 VIO TSR Violation During Maintenance on ERP Crane.

070-7002/98003-06 VIO Failure to ensure that the autoclave low cylinder pressure shutoff system setpoint did not drift below 20 pounds per square inch absolute.

070-7002/98005-02 VIO Failure to ensure th'at equipment containing a deposit greater than safe mass was maintained in a fluorinating e?!ironment.

070-7002/98005-01 VIO Procedure violation associated with communication between process services staff and the cascade controller.

070-7002/98007-03 URI Guidance for autoclave operation during a building evacuation.

070-7002/98007-04 URI Action plan to address backlog of greater than safe mass deposits.

Discussed None 1 l

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l LIST OF ACRONYMS USED l ACR Area Control Room j ANSI American National Standards Institute i CAAS Criticality Accident Alarm System l

CFR Code of Federal Regulations

, _CMMS Computer Maintenance Management System DNMS Division of Nuclear Material Safety FLM First Line Manager

! IFl inspection Followup item ,

NCS Nuclear Criticality Safety l

. NCSA Nuclear Criticality Safety Approval )

NCV Non-cited Violation l NRC Nuclear Regulatory Commission l~ PDR Public Document Room l PEH Planned Expeditious Handling l- PGDP Paducah Gaseous Diffusion Plant .

l PSS Plant Shift Superintendent SAR Safety Analysis Report TSR Technical Safety Requirement U-235 Uranium 235 UF, Uranium Hexafluoride URI Unresolved item VIO Violation i

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