ML20206E659

Insp Rept 70-7001/99-04 on 990224-0412.No Violations Noted. Major Areas Inspected:Plant Staff Took Appropriate Actions to Trip Process Motors for Cell Involved with Motor Fire Due to Failed motor-to speed-increaser Coupling

ML20206E659
Person / Time
Site:	07007001
Issue date:	04/29/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20206E653	List: ML20206E648 ML20206E659
References
70-7001-99-04, 70-7001-99-4, NUDOCS 9905050193
Download: ML20206E659 (19)

Text

l U.S. NUCLEAR REGULATORY COMMISSION REGION lli Docket No: 70-7001 Certificate No: GDP-1 Report No: 70-7001/99004(DNMS)

Facility Operator United States Enrichment Corporation Facility Name: Paducah Gaseous Diffusion Plant Location: 5000 Hobbs Road P.O. Box 1410 Paducah, KY 42001 Dates: February 24 through April 12,1999 Inspectors: K. G. O'Brien, Senior Resident inspector J. M. Jacobson, Resident inspector R. G. Krsek, Fuel Facilities Inspector 1

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

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9905050193 990429 PDR ADOCK 07007001 C PDR ,,,

EXECUTIVE

SUMMARY

United States Enrichment Corporation Paducah Gaseous Diffusion Plant NRC Inspection Report 70-7001/99004(DNMS)

Plant Ooerations l

e The plant staff took appropriate actions to trip the process motors for a cell involved with j a motor fire due to a falle'dmotor-to-speed-increaser coupling. However, vibration data, which could have indicated a problem with the coupling, were not readily available to the operators involved. In addition, the alarm response procedures for motor load alarms did not provide quantitative guidance for making a decision on when to trip a cell based on motor load indications. (Section 01.1)

• The plant staff identified and promptly corrected a situation in which the process gas leak detection safety system for Building C-333, Unit 4, Cell 10 was incorrectly assumed to be operable. However, the plant staff made a non-conservative decision not to implement a smoke watch for the affected cell while the issue was under review. The event also identified a training deficiency in that the involved operations staff did not fully understand the interaction between the safety system and an associated cascade monitoring computer. (Section 01.2) e The shift tumover briefings conducted by the plant operations staff effectively .

communicated the status of the plant, current safety concems, and the planned l activities for the next shift to all the area control rooms onsite. (Section 01.3) e The inspectors identified a weakness in the communications among onsite organizations which resulted in the removal of controlled copies of some continuous operations procedures from Area 3 control rooms during the initial implementation of new computerized work stations for procedures. No safety issues were identified as the applicable emergency, off-normal, and alarm response procedures were still available in the control rooms as controlled copies. In addition, operations staff were knowledgeable on where to obtain procedures in the event the computer system failed. Plant management took prompt actions to resolve the issue. (Section 01.4)

Maintenance and Surveillance e The plant staff developed corrective actions for maintenance activities which resulted in an unplanned safety system actuation and inoperability, and an event response for a potential criticality. The corrective actions taken were limited in scope, however, and some of the potential programmatic issues associated with the events were not fully addressed until the inspectors asked questions. (Section M1.1)

Enaineerina e An unresolved item involving the plant change review process was identified in that the process did not overtly incorporate the requirements of 10 CFR 76.68(a)(3) for performing decreased effectiveness reviews for changes to the safety plans and programs described in the Safety Analysis Report. Although the inspectors did not identify any changes which decreased the effectiveness of the programs, the lack of a 2

specific procedural step to perform such reviews was a potential pitfall for plant change reviewers. The certificatee initially indicated that a change to the plant change review process was not necessary, but later determined that the goveming procedure would be revised to include an overt decreased effectiveness review for programs described in the Safety Analysis Report. (Section E1.1)

Plant Sucoort

• The inspectors concluded that the plant staff's actions, taken to resolve the noncompliances in the areas of radiation and environmental protection contained in Compliance Plan Issues 9,10,11,12,37 and 38, were sufficiently documented and reasonable. Based upon the reviews and inspection, the inspectors considered these Compliance Plan issues closed. (Sections R8.1, R8.2, R8.3, V8.1, and V8.2) i 3

Report Details I, Operations 01 Conduct of Operations 01.1 Buildina C-310 Cell 8 Motor Fire

a. Insoection Scope (88100)

The inspectors reviewed the circumstances surrounding an event which generated a significant amount of smoke in Building C-310. The event involved a potential motor fire which was the result of a failure of the coupling for the Cell Stage 3A motor and speed increaser associated with the high-speed centrifugal compressor,

b. Observations and Findinas During shift change on the evening of February 28, the operations staff reporting to Building C-310 noted a high vibration in the area control room (ACR) which continued to increase. Simultaneously, the Cell 8 motor load, indicated by a summing ammeter in the ACR, began to fluctuate as if a cell compressor were surging. Shortly thereafter, an operator, who had gone to the cell floor to investigate, noticed heavy smoke near Cell 8, but did not see any open flames. The operator called the ACR and requested that the ACR operator trip the cell motors. After the cell was tripped, the operators proceeded to isolate the lube oil to prevent the potential ignition or spread of any fire via the lube oil. The event lasted on the order of 7 to 10 minutes.

The plant staff identified that the event was the result of a failed coupling between the motor ar d speed increaser. A post-event review of the data stored in the cell vibration monitoring system indicated that there had been step changes in the vibration data which were opportunities to identify the problem before the actual event. The inspectus noted, however, that the current vibration monitoring system was of limited value to operators since there was no means to easily view real-time data for decision-making. In addition, the motor load alarms in the ACR were of limited value for such an event because the Building C-310 ammeters summed the current loads for all the stages in a cell as opposed to other process building ACRs with dedicated ammeters for each stage. As a result, assessing the performance of an individual compressor motor from the ACR was difficult.

The inspectors also reviewed the alarm response procedures (ARP) for motor load alarms in the cascade ACRs. The inspectors noted that the guidance provided to operators was limited insofar as the information for assessing the cause of the alarm or when to take specific actions to shut down equipment based on load indications was sparse. Action levels or acceptance criteria for load increases or decreases were not provided, only a generalized discussion of the possible causes of load alarms and the need to investigate and discuss the issue with the front-line manager. However, certain load changes could be indicative of conditions which would require immediate actions to prevent or mitigate a design-basis accident such as a uranium hexafluoride (UF.) and hot metal reaction.

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c. Conclusion The plant staff took appropriate actions to trip the process motors for a cellinvolved with a motor fire due to a failed motor-to-speed-increaser coupling. However, vibration data, which could have indicated a problem with the coupling, were not readily available to the operators. In addition, the ARPs for motor load alarms did not provide quantitative guidance for making a decision on when to trip a cell based on motor load indications.

01.2 Inocerable Buildina C-333 Process Gas Leak Detection System

a. Inspection Scooe (88100)

The inspectors reviewed the circumstances surrounding the report of an inoperable process gas leak detection (PGLD) system for Unit 4, Cell 10, in Building C-333 (Event Report No. 35409),

b. ' Observations and Findinas On February 26, at approximately 8:45 a.m., an operator performing a surveillance of the PGLD safety systems in Building C-333 identified that the PGLD heads for Unit 4 Cell 10 would not " test fire." The surveillance was performed by pushing a test button on the PGLD signal conditioner at the local cell panel which caused the voltage supplied to each PGLD head to be increased until each head went into the alarm state. This test verified the continued operability of the heads in the high-temperature environments of the cell housing and associated duct work.

At the time of performing Technical Safety Requirement (TSR) Surveillance 2.4.4.1-1, the operator also identified that the signal conditioner Indicated the PGLD system was locked in " computer test," a situation which prevented the system from actuating an alarm in the event of a release. In response, the operator placed thet PGLD system in

" override" which decoupled the PGLD system from the cascade motiitoring computer and allowed the test to be accomplished satisfactorily indicating the system was operable. The operator left the system in " override" and informed his supervisor. The supervisor, in consultation with a cascade manager, directed the operator to retum the system to the " normal" mode. This decision was made because of a mistaken understanding that the system would only be operable in the " normal" mode and because the surveillance procedure indicated that the system should be in " normal" mode for the next surveillance. These surveillances were required to be performed every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and were typically performed every 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The operator returned the system to " normal" while the managers sought the advice of the system engineer.

The followup analysis and discussion took approximately 90 minutes. While this analysis was being performed, the plant staff made a non-conservative decision not to implement a smoke watch, the required Limiting Condition for Operation (LCO) action for an inoperable PGLD system. The plant staff finally determined that the PGLD system was not operable in the " normal" mode with the " computer test" lamp lit. With I

the " computer test" locked in, the system would not respond to a release by providing an l alarm (its intended safety function). As a result, the cell operated at a pressure above )

atmospheric for a period of approximately 90 minutes without an operable PGLD i system. The LCO Action Statements for TSR 2.4.4.1 required a smoke watch to be established within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> upon identification of an inoperable PGLD system. Although l

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the PGLD system was inoperable, the plant staff did have other non-safety indicators of a situation which could result in a significant release from the cell including load alarms and seal alarms.

The plant staff's analysis identified that in the " override" mode, the computer was decoupled from the alarm circuit, thus enabling the system to properly respond to a release by alerting operations staff in the ACR. As a result, the plant staff immediately placed the system in the " override" mode (an operable condition). The plant staff also made an immediate procedure change to require that all PGLD systems covering cells operating above atmosphere (the condition for which an operable PGLD system was required) be placed in the " override mode." The procedure change was intended to assure operability of the PGLD systems should a similar event occur while the root cause and corrective actions for the event were determined. The plant staff also took other corrective actions including the replacement of the failed digital output card in the signal conditioner which was the original cause of the " computer test" lockup and the issuance of a " lessons leamed" package for operations staff on the event. As a result of the prompt followup by plant staff, this non-repetitive, certificatee-identified and corrected violation is being treated as a Non-Cited Violation (NCV 70-7001/99004-01),

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

c. Conclusion The plant staff identified and promptly corrected a situation in which the PGLD safety system for Building C-333, Unit 4, Cell 10 was incorrectly assumed to be operable.

However, the plant staff made a non-conservative decision not to implement a smoke watch for the affected cell while the issue was under review. The event also identified a training deficiency in that the involved operations staff did not fully understand the interaction between the safety system and an associated cascade monitoring computer.

01.3 Shift Tumover Briefinas

a. Insoection Scope (88100)

The inspectors attended and observed a number of shift tumover briefings held between the operations staff, including the Plant Shift Supervisor (PSS), in the Building C-300 Central Control Facility and the other area control rooms onsite.

b. Observations and Findinos The inspectors observed that the briefings were conducted in a professional manner and included a clear discussion of the activities and issues which occurred during the shift. In addition, the briefings addressed planned work, the current status of equipment, TSR impacts and current LCOs. The discussions included a very concise use of the repeat-back method for criticalinformation to ensure there was a shared understanding by the personnelinvolved. Overall, the communications in the tumover briefings appeared to be crisp, informative, and comprehensive.

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c. Conclusion l

The shift turnover briefings conducted by the plant operations staff effectively communicated the status of the plant, current safety concerns, and the planned l activities for the next shift to all the ACRs onsite.  !

01.4 Procedure Availability for Ooerations Staff

a. Insoection Scooe (88100)

The inspectors reviewed procedure availability in several control rooms throughout the plant during routine plant tours and inspections. The inspection consisted of observations in the field and interviews with plant operations and document control staff.

b. Observations and Findinas During interviews with various plant operators and observations of control room activities, the inspectors noted that operators accessed procedures through the onsite computer system. The inspectors noted that in most control rooms, controlled copies of the applicable procedures were also available, and the computer work stations supplemented the controlled copies. However, in Area 3 control rooms (toll transfer and l sampling, and vaporization areas) the inspectors identified that only emergency, off-normal, alatm response, and in-hand operating procedures were available as controlled copies. Other procedures used during the course of normal operations were only  ;

available through the computer work stations in these control rooms.

The operations staff indicated that in the beginning of March, the controlled copies of certain normal operations procedures had been removed from the control rooms. Some training had been provided to the operations staff by the front-line management; however, the inspectors noted that current operator knowledge of the computerized work stations was limited by the front-line management's computer system knowledge and involvement. The inspectors observed that some operations staff did not even have individual passwords to access the computer systems. However, when questioned by the inspectors as to how to obtain a procedure if the computer system was not operating, the operations staff identified that the Central Control Facility could fax controlled copies of operating procedures to the control room.

Discussions with plant staffin the Procedure and Document Control Departments indicated that at this stage of the transition to a computerized procedure program, the  ;

intent of the controlled copy removal process was not to remove procedures used in continuous operations. Further discussions with operations management and a review of intemal memoranda indicated that there were weak communications across plant organizations with regard to the intent and applicability of removing controlled copies of procedures. Plant management initiated prompt actions to correct this issue by ,

retuming applicable controlled copies of procedures used for continuous operations to the Area 3 control rooms, providing access to the computer system for individual users in these areas, and initiating additional training for the computer system to plant staff.

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c. Conclusions The inspectors identified a weakness in the communications among onsite organizations which resulted in the removal of controlled copies of some continuous operations procedures from Area 3 conW.! rooms during the initial implementation of new computerized work stations for procedures. No safety issues were identified as the applicable emergency, off-normal, and ARPs were still available in the control rooms as controlled copies. In addition, operations staff were knowledgeable on where to obtain procedures in the event the computer system failed. Plant management took prompt actions to resolve the issue.

08 Miscellaneous Operations issues l 08.1 Certificatee Event Reoorts (90712)

The certificatee made the following operations-related event reports during the inspection period. The inspectors reviewed any immediate safety concems indicated at the time of the initial verbal notification. In the case of retracted notifications, the j inspectors reviewed the basis for the certificatee's retraction of the notification at the l time of the retraction. The inspectors will evaluate the associated written report for each of the events following submittal.

Number Status Title 35409 Open Inoperability of the Building C-333, Unit 4, Cell 10 Process Gas Leak Detection System.

35483 Open Failure of the Building C-315 Normetex Pump Uranium Hexafluoride Release Detection System.

35505 Open Loss of Power to Criticality Accident Alarm System Beacons.

35543 Open inoperability of the Building C-710 Criticality Accident 4 Alarm Systems.

08.2 Bulletin 91-01 Reoorts (97012)

The certificatee made the following reports pursuant to Bulletin 91-01 during the inspection period. The inspectors reviewed any immediate nuclear criticality safety (NCS) concerns associated with the report at the time of the initial verbal nctification.

Any significant issues emerging from these reviews are discussed in separate sections of the report.

Number Q_a alt Title 35413 2/25/99 Potentially Fissile Trap Media was Discovered in an Unapproved 30-gallon Container.

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I 35534 3/30/99 Four drums Containing Seal Parts in Building C-746-Q1 l were Discovered to have been Improperly Characterized and Labeled.

lI. Maintenance and Surveillance l

l M1 Conduct of Maintenance M1.1 Criticality Accident Alarm System Maintenance Evolutions Inspection Scooe (88102. 88103) l a. )

The inspectors reviewed three criticality accident alarm system (CAAS) maintenance activities which led to an inadvertent safety system actuation, the evacuation of 1 two process facilities, and an inadvertent inoperability due to troubleshooting activities. !

The inspection included a review of pertinent work packages and discussions with plant staff,

b. Observations and Findinas Electronic Personal Dosimeter Alarm On March 3, Buildings C-337 and C-337A were evacuated in accordance with site procedures when an individual's electronic personal dosimeter (EPD) alarmed. The buildings were under an LCO due to testing of the CAAS clusters in Building C-337. In preparation for the testing, the CAAS clusters and homs were declared inoperable and the LCO Action Statements were entered. In accordance with the LCO Action Statements, personnel in the building were required to have an EPD on their person in case an inadvertent criticality occurred while the CAAS was inoperable. Site procedures required that under conditions in which the CAAS detection function was considered incperable, the actuation of any EPD in the affected area was to be treated similar to a CAAS alarm, i.e., personnel were to evacuate the area. After implementation of the emergency response procedure for an inadvertent criticality, the incident Commander determined that the EPD alarm had not been caused by an actual cnticality based upon personnel statements, surveys of the building and surveys of personnel criticality accident badge foils. As of the end of the inspection period, the cause of the alarm had not been determined.

The initial response actions appeared to be consistent with applicable operations and emergency procedures. The PSS required the building evacuation horns and subsequently the radiation horns and lights to be activated, in addition, a public address announcement to evacuate was made from the Central Control Facility in between the sounding of evacuation and radiation homs. However, the evacuation of personnel from Building C-337A was delayed. These personnel, who were outside the control room performing a valve alignment at the jet station, did not hear a public address announcement to evacuate the area and did not understand the significance of the evacuation and radiation homs. Entry into the LCO had been preceded with an announcement to disregard the radiation horns and lights which the PSS sounded once the report of the alarming EPD was received.

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n The inspectors noted that a " lessons leamed" developed for the operations staff after the event identified a number of opportunities to improve the response, but appeared to miss some significant issues. In particular, the inspectors noted that the emergency procedure did not specifically describe (in terms of how to promptly alert personnel) the response to a situation in which evidence of a potential criticality (such as one or more alarming EPDs) was obtained while the CAAS was undergoing testing. In addition, the inspectors noted that Procedure CP2-CO-CA2030," Operation of the Criticality Accident Alarm System," did not include guidance on entering the LCO for Buildings C-337A and C-333A, when Buildings C-337 and C-333 were under the LCO for CAAS testing. The CAAS homs in Building C-337A and C-333A wers tied into the CAAS detectors in Buildings C-337 and C-333, respectively. Under the circumstances, the actuation of the radiation homs and lights appeared to complicate and confuse the response. Following discussions with the inspectors, the plant staff determined that additional, more

. comprehensive corrective actions were required.

Buildina C-331 Criticality Accident Alarm System Actuation On March 13, a CAAS actuation in Building C-331 occurred while maintenance staff were completing and testing the connections for installing a portable CAAS cluster to be used to cover activities in a previously uncovered area on the ground floor. Although the CAAS LCO was entered for the work, the operations staff did not alert personnel to ignore the CAAS homs and lights as part of the modification activity because the work was not expected to impact the CAAS horns and lights for the building. The personnel in the building responded appropriately and evacuated the facility. Following the event, the plant staff identified that the actuation was caused by an electrician attempting to check for grounds on the terminal strip for the connections while power remain supplied to an adjacent terminal. In performing these checks, the electrician inadvertently contacted the wrong terminal, causing a short in the powered circuit and setting off the CAAS horns on that circuit.

The inspectors reviewed the associated work package for the activity. The work package reference Design installation and Verification Specification (DIVS)

DIVS-Z98181-E001," Portable CAAS Addition in Buildings C-331 and C-335." The DIVS indicated in Section 5.0 that the installation of the circuits and associated power cable should be performed in accordance with approved drawings. Upon completion of these activities, the modified circuits would have been energized. However, the following section for post-modification acceptance testing had a step which required that " prior to energizing the modified circuits perform a continuity check with a multimeter to verify the conductors have no shorts to ground." During the development of the work package, the continuity checks were moved from the post-maintenance testing section of the activity to the installation instructions, as appropriate. However, neither the work control staff nor the maintenance staff questioned the acceptability of performing checks for grounds with another safety-related circuit in the terminal box energized.

In reviewing the plant staff s initial event assessment, the inspectors noted that the assessment and corrective actions were narrowly focused on human error. The assessment did not identify or cddress the problems with the DIVS developed by the engineering staff. In addition, the inspectors noted a lack of rigor during the initial work package development and pre-job reviews by maintenance and operations staff who did not question the acceptability of performing checks for grounds with energized safety-related circuits in the immediate area. After additional discussions with the inspectors, 10

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the plant staff developed " lessons learned" packages for engineering, maintenance, operations, and work control staff. The packages addressed the need to thoroughly understand and identify precautions to protect against potential problems and risks l associated with work on or near energized systems.  !

Troubleshootina Causes inocerable Criticality Accident Alarm System On April 3, during troubleshooting activities after an electrical storm for a Building C-710 CAAS cluster trouble alarm, a maintenance front-line manager touched a I charred surge protection diode to determine the extent of damage and whether or not the circuit was open. This action inadvertently closed the circuit and caused a short to ground on the 48-volt system supplying power to the CAAS homs and lights in various facilities, resulting in two 48-volt breakers tripping. As a result, the power to the CAAS homs and lights for Buildings C-333, C-333A, C-337, C-360, C-710, C-720 and C-7460 was interrupted. The . Building C-300 CAAS panel trouble alarms for these facilities

! immediately illuminated. The plant staff quickly investigated and closed the breakers I

and retumed power to the affected homs and lights within approximately 2 minutes.

The plant staff subsequently reported the event to the NRC (Event Report 35543).

The inspectors reviewed the work package developed for the troubleshooting activities i and discussed the event with the maintenance staff involved. The inspectors did not I

identify issues with the work package or conduct of work. However, the maintenance staff identified that one of the steps in the procedure used to perform the post-maintenance testing was out of sequence. This procedure had recently been revised due to an improper removal of certain steps required to check the voting logic for a cluster (see Section M1.2 of Inspection Report 70-7001/99001(DNMS)). During ,

that revision, the step for tuming on the Building C-710 CAAS homs was moved and was now out of sequence so that the test could not be performed as written. The inspectors noted that this appeared to be a result of a poor procedure change review similar to the issue which had caused the need for the revision to be made. The maintenance staff developed an assessment and tracking report for the procedure problem and planned to change the steps back to the proper sequence before the next use of the procedure during the CAAS quarterly surveillances.

c. Conclusion The plant staff developed corrective actions for maintenance activities which resulted in an unplanned safety system actuation and inoperability, and an event response for a potential criticality. The corrective actions taken were limited in scope, however, and

. some of the potential programmatic issues associated with the events were not fully addressed until the inspectors asked questions.

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Ill. Enalneerina E1 Conduct of Engineering l E1.1 Decreased Effectiveness Reviews

a. inspection Scooe (88100)

The inspectors reviewed the certificatee's initla! resolution of an issue involving the performance and documentation of decreased effectiveness reviews for changes to the safety plans and programs contained in the SAR. The plant staff's issue was documented in Assessment and Tracking Report (ATR) 98-5791, dated September 16, 1998.

b. Observations and Findinas During previous inspections and licensing reviews, the NRC raised questions about the methodology and documentation used to justify that changes made to programs described in the SAR did not decrease the effectiveness of the programs. Such plans and programs included training, NCS, radiation protection, etc. In response to the questions, plant staff were able to identify why the changes did not decrease the effectiveness of the programs, although the rationale was not always immediately apparent. In addition to the NRC questions, the plant staff filed an ATR which identified that the plant change review (PCR) process (Procedure UE2-RA-RR1036, Revision 0, Change F, effective date October 15,1997) did not overtly require a decreased effectiveness review to be formally documented in the PCR package for these plans and programs (by a separate item to be addressed). A decreased effectiveness review was formally performed and documented for programs in Volume 3 of the application (quality assurance, emergency preparedness, physical security, etc.).

The inspectors reviewed the initial resolution and response to the ATR. In the response, the site management initially indicated that the Paducah staff would perform an additional decreased effectiveness review to supplement the required reviews in the PCR process. However, the management later indicated that these additional reviews were not required because, although the PCR procedure did not specifically address a decreased _ effectiveness review, the plant staff were expected to perform such a review during the development of a written safety analysis for changes to the SAR. The plant staff further indicated that a formal request for an Interpretation on whether decreased -

effectiveness reviews were required might be made to the NRC. The inspectors noted that while a decreased effectiveness review could be accomplished in a written safety analysis, the questions asked ac part of the written safety analysis had a significance level (undue risk to the public health and safety, common defense and security, and the environment) that was generally higher than a change affecting a program's effectiveness. Thus, there appeared to be a deficiency in the process in that a specific justification for no decrease in effectiveness was not required, and could be missed, during the PCR development to support a change to the plans and programs included in the SAR.

At the end of the inspection period, after questions by the inspectors, the plant staff Indicated that management had determined that a change to the PCR procedure was needed to specifically incorporate decreased effectiveness reviews for plans and 12 l l

1 programs described in the SAR. The procedure change was planned as part of a general revision to Procedure UE2-RA-RR1036. In addition, the plant staff indicated that a review would be performed of all PCRs approved since the last application renewal was approved to ensure none of the changes decreased the effectiveness of a program described in the SAR.

The regulations in 10 CFR 76.68(a)(3) allowed the certificatee to make changes to the .

plant or plant's operations as described in the SAR without prior Commission j approval provided that the changes not decrease the effectiveness of the plant's safety, j safeguards, and security programs. The lack of a procedural requirement for overtly performing a decreased effectiveness review for changes to the safety plans and programs described in the SAR will be tracked as an Unresolved item (URI 70-7001/99004-02) pending a final resolution of the issue,

c. Conclusion.,

An unresolved item involving the plant change review process was identified in that the process did not overtly incorporate the requirements of 10 CFR 76.68(a)(3) for performing decreased effectiveness reviews for changes to the safety plans and programs described in the SAR. Although the inspectors did not identify any changes which decreased the effectiveness of the programs, the lack of a specific procedural step to perform such reviews was a potential pitfall for PCR reviewers. The certificatee initially indicated that a change to the PCR process was not necessary, but later determined that the goveming procedure would be revised to include an overt ,

decreased effectiveness review for programs in the SAR. 1 IV, Plant Support R8 Miscellaneous Radiation Protection issues R8.1 - (Closed) Comoliance Plan Issue 9. " Radiation Protection Procedures": This issue was documented with two descriptions of noncompliance. The first item of noncompliance stated, in part, that the revision of the radiological protection procedures had not been ,

completed to fully implement the technical requirements of 10 CFR 20. The second item stated that the radiation protection program annual review for content and implementation, required by SAR Paragraph 5.3.1.3, had not been incorporated into plant implementing procedures. The Plan of Action and Schedule (PAS) required I procedure changes to address the 10 CFR 20 requirements and the radiation protection I program annual review.  !

The inspectors performed a review of selected parts of 10 CFR Part 20 and the l applicable UE2, CP2, and CP4 Level Health Physics Procedures. The inspectors l concluded that radiological protection procedures had been revised to reflect the 10 CFR 20 requirements for radiological protection. During routine tours and system walkdowns, the inspectors also noted health physics procedures were implemented and ,

no deficiencies were identified. Procedure CP4-HP-RP1105,"Intemal Assessment Program," required the annual review of the radiation protection program. The inspectors obtained and reviewed the 1997 and 1998 Radiological Protection Program Review and noted the review satisfied the requirements of 10 CFR 20.1101(c).

Business Prioritization System issue Number UC9612544 documented the certificatee's closure of Compliance Plan issue 9, and contained the necessary Information to  !

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demonstrate closure of this issue. The inspectors concluded the certificatee's actions l taken to resolve the noncompliances were sufficiently documented and reasonable, and I considered Compliance Plan issue 9 closed.

R8.2 (Closed) Comoliance Plan Issue 10. "Postina of Radioactive Materials": This issue was j documented with the following three descriptions of noncompliance: 1) building work l areas previously posted as " Regulated Areas" had not been re-posted to reflect the current " Restricted Area" and " Contamination Control Zone" designations; 2) not all restricted areas within United States Enrichment Corporation (USEC) leased space which contain unlabeled, but potentially radioactive, material containers had been j posted to state that each unlabeled container may contain radioactive material; and  ;

3) not all leased areas within the site boundary had been completely characterized l regarding the type, extent, and amount of radioactive material present, as a result some I areas have not been properly posted regarding the type, extent, and amount of radioactive material or hazards present. The PAS required completion of the following three commitments: 1) re-post areas previously posted as " Regulated Areas"; 2) post restricted areas within USEC leased space with signs stating that each unlabeled container may contain radioactive material; and 3) perform necessary radiological characterization and re-posting of USEC leased areas onsite.

The inspectors reviewed the closure documentation and noted the certificatee initiated a '

comprehensive program to re-post " Regulated Areas"in USEC leased space to Restricted Areas and Contamination Control Zones, consistent with the SAR. In addition, restricted areas were labeled with signs stating that each unlabeled container may contain radioactive material. During facility tours, the inspectors observed that leased areas onsite were properly posted and labeled, and no examples of inappropriate posting or labeling were Identified. Inspections conducted since March 3,1997, by the NRC also documented that leased areas onsite were properly posted and labeled. The site radiological characterization effort the certificatee initiated had also been completed.

The inspectors noted that the program was comprehensive and better characterized radiological contamination areas within the plant. Evidence files documented that as new contaminated areas were discovered, the areas were properly posted in accordance with SAR requirements. Business Prioritization System Issue Number UC9612545 documented the certificatee's closure of Compliance Plan issue 10, and contained the necessary information to demonstrate closure of this issue.

The inspectors concluded the certificatee's actions taken to resolve the noncompliances were sufficiently documented and reasonable, and considered Compliance Plan Issue 10 closed.

R8.3 (Closed) Comoliance Plan Issue 11. " Radioactive Calibration Source Accuracv": The description of noncompliance for this issue documented that contrary to the requirements of SAR Section 5.3.5, some calibration sources used for the calibration and checking of radiation detection instruments were not traceable to the National Institute of Standards and Technology, and were not within a positive and negative tolerance of 5 percent of the stated value. The PAS required the procurement of calibration sources which conformed with SAR Section 5.3.5, and the recalibration of all affected instruments within 12 months of receipt of the required calibration sources.

The inspectors reviewed procurement documents and certificates of calibration for the sources purchased and used for the calibration and checking of radiation instruments onsite. The current sources were all traceable to the National Institute of Standards and 14

I l

l Technology, and the uncertainty of the sources were 5 percent, as required. Preventive maintenance task summaries, which documented the calibration of instrumentation, were also reviewed and confirmed the recalibration of instruments with the required calibration sources. Business Prioritization System issue Number UC%I2546

- documented the certificatee's closure of Compliance Plan Issue 11, and contained the necessary information to demonstrate closure of this issue. The inspectors concluded the certificatee's actions taken to resolve the noncompliances were sufficiently

'de,cumented and reasonable, and considered Compliance Plan issue 11 closed.

R8.4 (Closed) Comoliance Plan issue 12.

• National Voluntary Laboratory Accreditation Proaram Certification": The description of noncompliance for this issue documented that the certificatee did not use a dosimetry processor accredited through the National Voluntary Laboratory Accreditation Program (NVLAP). The PAS required the certificatee to process dosimetry through an NVLAP accredited processor. The inspectors confirmed that the certificatee had resolved this issue and had used an l NVLAP accredited dosimetry processor. In 1998, the certificatee changed dosimetry I vendors and the inspectors verified that the current dosimetry processor was NVLAP accredited. Business Prioritization System issue Number UC96l2547 documented the certificatee's closure of Compliance Plan issue 12, and contained the necessary information to demonstrate closure of this issue. The inspectors concluded the certificatee's actions taken to resolve the noncompliances were sufficiently documented and reasonable, and considered Compliance Plan Issue 12 closed. l V8 Miscellaneous Environmental Protection issues V8.1 (Closed) Comoliance Plan Issue 37. " Environmental Trendino Procedures": The description of noncompliance for this issue documented that some environmental data was not currently trended to identify long-term changes in the environment that may result from plant operations. The PAS required the development and implementation of a procedure for long-term environmental trending.

The inspectors reviewed the closure documentation, and noted that the environmental data trending and background (ambient) level comparisons were incorporated into two certificatee procedures. Procedure CP4-EW-EV6162," Data Investigating and Reporting," was developed and implemented to establish a program for Investigating and trending environmental data. Procedure CP2-EW-EN1040," Establishment of 3 Baseline Effluent Quantities for Radiological Discharges and Action Levels for Environmental Monitoring," was developed and implemented to establish guidelines and methods for the determination of the baseline effluent quantities and action levels for gaseous emissions, wastewater discharges and the environmental monitoring program.

Business Prioritization System Issue Number UC96l2831 documented the certificatee's l closure of Compliance Plan Issue 37, and contained the necessary information to demonstrate closure of this issue. The inspectors concluded the certificatee's actions ,

taken to resolve the noncompliances were sufficiently documented and reasonable, and l L considered Compliance Plan issue 37 closed.

V8.2 (Closed) Comoliance Plan issue 38. "Hiah-Volume Ambient Air Samolers": The description of noncompliance for this issue documented the following issues:

1) sufficient data from the high-volume ambient air samplers had not been obtained to establish baseline action levels for individual air samplers; and 2) comparison of 15

t effective dose equivalents (EDE) from calculated data versus sampled data would not be able to be performed until 1997. The PAS required that action levels for the air  ;

samplers were established after sufficient data was collected. The PAS also required that the comparison of EDE from calculated versus sampled data was performed in the first half of calendar year 1997, l The certificatee obtained sufficient data and established baseline levels and action i levels for ambient air radionuclide monitoring by May 30,1996. A program was also j established to investigate and document the cause for exceeding an action level. On '

June 6,1997, the certificatee completed a comparison of emission modeling and  ;

ambient air sampling results for calendar year 1996. The report justified and concluded j that a direct comparison of EDEs from the calculated versus sampled data was not ,

feasible. However, the comparison did indicate that the certificatee was not significantly j underestimating the EDE to the most exposed member of the public and documented that the current method of demonstrating compliance with the applicable regulations was appropriate. Business Prioritization System issue Number UC96l2832 documented the certificatee's closure of Compliance Plan issue 38, and contained the necessary information to demonstrate closure of this issue. The inspectors concluded the certificatee's actions taken to resolve the noncompliances were sufficiently documented l and reasonable, and considered Compliance Plan issue 38 closed. i 1

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

The certificatee made the following security-related 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 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.

Date Title 3/4/99 Classified Matter was inappropriately Created and Distributed via an Unclassified Computer System.

V. Manaaement Meetinas X1 Exit Meeting Summary The inspectors presented the inspection results to members of the plant staff and management at the conclusion of the inspection on April 12,1999. 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.

16

PARTIAL LIST OF PERSONS CONTACTED Lockheed Martin Utility Services

'M. A. Buckner, Operations Manager L. L. Jackson, Nuclear Regulatory Affairs Manager S. R. Penrod, Enrichment Plant Manager

• H. Pulley, General Manager United States Deoartment of Enerav G. A. Bazzell, Site Safety Representative United States Enrichment Corooration

• J. L. Adkins, Vice President - Production 4 J. A. Labarraque, Safety, Safeguards and Quality Manager j U.S. Nuclear Reaulatorv Commission

• J. M. Jacobson, Resident inspector

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

• Denotes those present at the exit meeting April 12,1999.

Other members of the plant staff were also contacted during the inspection period, f 1

INSPECTION PROCEDURES USED l IP 88100: Plant Operations I IP 88102: Surveillance Observations IP 88103: Maintenance Observations I IP 90712: In-office Review of Events 1

17

r- ,

ITEMS OPENED, CLOSED, AND DISCUSSED Ooened i

70-7001/99004-02 URI Decreased effectiveness reviews for changes to safety plans and programs described in the Safety Analysis Report.

35409 CER Inoperability of the Building C-333, Unit 4, Cell 10 Process Gas l

Leak Detection System.

35483 CER Failure of the Building C-315 Normetex Pump Release Detection System.

35505 CER Loss of power to criticality accident alarm system beacons.

35543 CER Inoperability of the Building C-710 criticality accident alarm systems.

Closed._

l 70-7001/99004-01 NCV Inoperable Building C-333 process gas leak detection system not identified..

Compliance Plan issue 9 Radiation Protection Procedures.

Compliance Plan issue 10 Posting of Radioactive Materials.

Compliance Plan issue 11 Radioactive Calibration Source Accuracy.

Compliance Plan issue 12 National Voluntary Laboratory Accreditation Program Certification.

Compliance Plan issue 37 Environmental Trending Procedures.

Compliance Plan issue 38 High-Volume Ambient Air Samplers.

I Discussed l '

None 18 i

LIST OF ACRONYMS USED ACR Area Control Room  !

ARP Alarm Response Procedures ATR Assessment and Tracking Report CAAS Criticality Accident Alarm System ,

CER Certificatee Event Report l CFR Code of Federal Regulations .

DIVS Design Installation and Verification Specifications i DNMS Division of Nuclear Materials Safety l EDE Effective Dose Equivalent  !

EPD Electronic Personal Dosimeter IFl Inspector Followup Item l LCO Limiting Condition for Operation NCS Nuclear Criticality Safety NCV Non-Cited Violation 4

?

NRC Nuclear Regulatory Commission NVLAP National Voluntary Laboratory Accreditation Program PAS Plan of Action and Schedule PCR Plant Change Review j PDR Public Document Room j PGLD Process Gas Leak Detection i PSS Plant Shift Supervisor j SAR Safety Analysis Report i TSR Technical Safety Requirement j UF, Uranium Hexafluoride i URI Unresolved item USEC United States Enrichment Corporation 19