ML20209E878

Insp Rept 70-7002/99-07 on 990517-0629.No Violations Noted. Major Areas Inspected:Operations,Maint & Surveillance, Engineering & Plant Support

ML20209E878
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant
Issue date:	07/09/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20209E859	List: ML20209E855 ML20209E867 ML20209E878
References
70-7002-99-07, 70-7002-99-7, NUDOCS 9907150170
Download: ML20209E878 (19)

Text

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l U.S. NUCLEAR REGULATORY COMMISSION

! REGIONlil l

l Docket No: 70-7002 l Certificate No: GDP-2 Report No: 70-7002/99007(DNMS)

! Facility Operator- United States Enrichment Corporation 1

Facility Name: Portsmouth Gaseous Oiffusion Plant Location: 3930 U.S. Route 23 Scuth P.O. Box 628 Piketon, OH 45661 Dates: May 17 through June 29,1999 Inspectors: ' D. J. Hartland, Senior Re sident inspector C. A. Blanchard, Resider t inspector Y. H. Faraz, Project Manager J. M. Jacobson, Resident inspector, Paducah Approved By: Patrick L. Hiland, Chief Fuel Cycle Branch Division of Nuclear Materials Safety

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9907150170 990709 PDR ADOCK 07007002 C ppg

i EXECUTIVE

SUMMARY

l United States Enrichment Corporation  !

Portsmouth Gaseous Diffusion Plant NRC Inspection Report 70-7002/99007(DNMS)

J Ooerations e ,

The insnectors concluded that although the operators properly characterized the cause of an autoclave steam shutdown as non-safety related, no troubleshooting was performed and the problem was not corrected as required by procedure prior to autoclave restart. In addition, the First Line Manager did not notify the Plant Shift Superintendent of the steam shutdown and request an operability determination.

(Section 01.1)

• The inspectors concluded that emergency personnel responded appropriately to cylinder handling events during the inspection period. The inspectors will followup on the results of the certificatee's integrated review of liquid cylinder handling site-wide.

(Section O2.1)

Maintenance and Surveillance _

• The inspectors concluded that the certificatee took the appropriate action to correct a deficiency in the procedure for de-energizing electrical equipment during an emergency.

(Section M2.1)

Enaineerina e The inspectors identified that Nuclear Criticality Safety staff displayed a lack of rigor in assessing an anomalous condition, resulting in violations of Nuclear Criticality Safety Approval requirements. (Section E2.1)

Plant Suooort l e The inspectors concluded that the plant staff's actions, taken to resolve noncompliances  ;

in the areas of radiation protection, training, and records management and document control contained in Compliance Plan issues 7,12,13,14,22,26,29, and 36, were sufficiently documented and reasonable. Based upon the reviews and inspection, the i inspectors considered these Compilance Plan issues closed. (Sections R8.1, R8.2, R8.3, R8.4, R8.5, R8.6,18.1, and P8.1) 2

1 Report Detalla

. 1. Operations 01 Conduct of Operations 01.1 Autoclave Retumed To Service Without Confirmina Cause

~ a. Inspector Scope (88100)

The inspectors reviewed the adequacy of actions taken by the plant staff in response to a steam shutdown of Autoclave No. 2 in Building X-344.

b. Observations and Findinas On May 17, while monitoring operation of Autoclave No. 2 in Building X-344, the First Line Manager (FLM) noted that the " steam on/ heat on" light was not illuminated, indicating that the steam isolation supply valves were closed. The FLM also noted that no visual or audible alarms had activated in response, the FLM instructed the operators to cycle the steam supply switch off and then back on; however, the valves did not open.

Upon further investigation, the FLM noted that the buffer air pressure was reading 9.5 pound per square inch gauge (psig), less than the normal operating pressure of between 11.5 to 12.5 psig. The FLM believed that the steam shutdown occurred due to the low buffer air pressure, a non-safety related design feature. The function of the air buffer was to prevent steam from entering the enclosure that contained the roll motor assembly during autoclave operation. Since the FLM believed that the shutdown was not a safety system actuation, the autoclave was then restarted. Approximately 10 minutes later, the autoclave went into containment due to an apparent high condensate actuation. The Plant Shift Superintendent (PSS) was then notified, the autoclave declared inoperable, and a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> notification made to the NRC to report the safety system actuation.

The certificatee's investigation revealed that the cause of the steam shutdown was indead due to a low air buffer pressure actuation. The certificatee determined that the actuation was due to a roll motor enclosure leak, as well as the low buffer air switch which had drifted 1 psig above the 6.5 psig setpoint. The certificatee repaired the leak tr d calibrated the switch prior to retuming the autoclave to service. The certificatee also determined that the cause of the high condensate safety actuation was that the rate of condensate formation resumed faster than the pressure rise in the autoclave following retum to service. In response to this event, the certificatee committed to change applicable procedures to require that any time an autoclave heating cycle was interrupted, actions were taken to ensure that the condensate was drained from the autoclave prior to retum to service.

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I During fo!'cwup, the certificatee determined that the operators did not receive l authorization from the PSS prior to retuming the autoclave to service following l

the low air buffer pressure shutdown. In addition, although the FLM properly characterized the cause of the shutdown, no action was taken to confirm the cause prior to autoc! ave restart. Also, the certificatee determined that Paragraph 8.7.25 of Pmeedure XP4-TE-UH2720 "X-344 Autoclave Startup," required troubleshooting and correcting tN problem when the " steam on/ heat on" was ]

discovered not illuminated before restoring steam to the autoclave.

As corrective action, the certificatee issued a section policy that required the PSS be notified and a problem report initiated anytime an autociave heating cycle was i interrupted. The certificatee also intended to change applicable operating procedures to l

incorporate the section policy. The failure to follow Procedure XP4-TE-UH2720 was a violation. However, the significance was minimal as the cause of the shutdown was correctly characterized by the FLM as non-safety related. The certificatee has also taken appropriate action to prevent recurrence. Therefore, the certificatee-identified i procedural violation is being treated by as a Non-Cited Violation i (NCV 70-7002/99007-01), consistent with Sectlan Vll.B.1 of the NRC Enforcement Policy.

c. Conclusions The inspectors concluded that although the operators properly characterized the cause of the autoclave steam shutdown as non-safety related, no troubleshooting was performed and the problem was not corrected as required by procedure prior to autoclave restart. In addition, the FLM did not notify the PSS of the steam shutdown and request an operability determination.

O2 Operational Status of Facilities and Equipment 02.1 Review of Cylinder Handlina Events

a. Ln_soection Scoce (88100)

The inspectors followed up on four cylinder handling events that occurred durinn the q inspection period. j

b. Observations and Findinas Susoended Uranium Hexafluoride Cylinder at Buildina X-330 On May 28, while plant staff was placing a full 14 ton liquid uranium hexafluoride UF.

cylinder on a rail car to begin the required 5 day cool down period, the hoist brakes on the Tails South Crane remained actuated. This caused the UF. cylinder to remain ,

suspended approximately 12 inches above the rail car cradle. As immediate corrective action, the certificatee shored up the 1 foot space between the cylinder and the rail car with wooden wedges and determined that the situation was safe in the short term. In addition, the certificatee removed all other liquid UF. handling cranes from service pending an investigation.

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At that time, the certificatee believed that the cause for the brakes not disengaging was a malfunction of the mechanism that kept the brake in an open position when a load was being raised or lowered. Upon further review, the certificatee determined that a pin that pivoted the armature which disengaged the brake may have either broken or loosened.

This brake design was unique to this crane; however, the certificatee inspected the brakes on the other cranes, identified no deficiencies, and returned the cranes to 3 service. l The inspectors observed the Plant Operations Review Committa (PORC) meeting which was convened on June 1 to review and approve the procedure developed to perform corrective maintenance on the brake and lower the cylinder onto the rail car cradle. The inspector observed that several valid questions were raised in the meeting by PORC members and were resolved prior to approval of the procedure. The certificatee allowed the suspended cylinder to cool the required 5 days before any corrective maintenance was initiated on the brake.

On June 2, the cedificatee replaced the affected pin after confirming that it had loosened. However, the certificatee also discovered severed wires in the crane control pendant cable which interrupted power to the hoist motor. The apparent cause of the severed wires was an improperly installed clamp used to suppod the weight of the pendant. After repair of the cable, the certificatee successfully lowered the cylinder on the rail car cradle without incident. The inspector observed the evolution and did not identify any issues. The inspector noted that the evolution was well-coordinated and a i thorough pre-brief was performed by maintenance supervision. During followup testing, ,

the certificatee determined that the loose pin would not have prevented the brake from I operating properly. Therefore, the certificatee concluded that the cause of the suspended cylinder was the severed wires. The certificatee inspected the pendants on the other liquid UF. handling cranes and no other problems were discovered.

Straddle Carrier Fire On May 27, a fire occurred on a straddle carrier used to transport solid and empty cylinders. The fire, which engulfed the cab, occurred outside of Building X-344 and was extinguished within about 5 minutes by the fire department after the 911 call was received. The cedificatee was not transporting a cylinder at the time and no injuries to personnel resulted. The certificatee immediately placed a hold on the use of other straddle carriers and formed a team to investigate the event.

The apparent cause was the rupture of a high pressure hydraulic line, and ignition of the fluid by the engine exhaust piping. The inspectors observed the damaged straddle carrier and noted the close proximity of the hydraulic lines to the engine exhaust manifold. As corrective action, the certificatee intended to process a plant modification to install insulation on the exhaust manifold and shielding between the high pressure hydraulic hoses and the hot engine parts.

The cedificatee also performed an engineering evaluation which concluded that a rupture of a cylinder from a straddle carrier fire was very unlikely. The basis for the conclusion was that pooling of the fuel was unlikely and that emergency responders would extinguish the fire in a timely mannar. The inspectors reviewed existing controls in place that would mitigate the impact of a fire and concluded that the controls were adequate.

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Railcar Derailment On June 2, two rail cars carrying deplete <! UF. cylinders onsite derailed while being moved several hundred yards from the Tails Withdmwal Station to a cool-down area.

The two cars were connected to a three-car train which was pulled by a diesel track mobile unit. The track mobile unit and the first car in the train did not derail.

Upon arrival at the scene, the incident Commander (IC) immediately evacuated the area around the derailed cars and activated the plant's Emergency Operations Center (EOC) for technical support. The IC visually inspected the derailed railcars and cylinders with binoculars from several different angles and observed that the cylinders were secure and had not shifted. The railroad system engineer performed a close-up inspection and confirmed that the railcars were stable. Plant staff assessed that the largest railcar tilt was a 6 degree angle from the horizontal. Plant staff previously performed a  ;

center-of-gravity analysis that indicated the cylinders could roll out of the railcar cradles I at approximately a 30 degree angle from the horizontal.

Before deactivating the EOC, the certificatee implemented some immediate corrective actions including:

• Suspension of movement of railcars on plant site and tagging them inoperable.

• Evaluation of the stability for railcars on plant site, e Securing the area around the derailed railcar and posting the area as a nonstandard liquid uranium cooling area.

Plant management established a recovery team to determine the method for removing the derailed railcar cylinders, to evaluate the railroad tracks plant wide (reinforced concrete track bed and wood ties with gravel ballast), and to perform a root cause investigation. Engineering developed a PORC-approved procedure for cylinder removal after the 5 day cooling period. On June 8, the certificatee removed the cylinders from the railcars using a 60 ton mobile crane approved for lifting solid cylinders. The inspectors observed the plant staff set up the crane and perform a trial lift that simulated the boom angle, boom length, and weight of cylinder to be lifted. In addition, the inspectors noted that the lift plan was within the range posted on the load chart of the crane. The inspectors observed that the cylinder removal from the derailed railcars was conducted without incident.

Based on preliminary information, defective rail ties caused the derailment of the two rail cars. The inspectors observed that the rails at the derailment site were twisted. On June 4, plant management approved Engineering Evaluation (EE) CE-1999-0348,

" Evaluate Railcar Usage on Tails Reinforced Concrete Track Bed," which authorized resumption of the movement of railcars and track mobiles on the Building X-330 Tails reinforced track bed. The evaluation identified that the reinforced concrete track alley and the areas just north and south of the track alley were acceptable for administratively controlled railroad traffic, including the movement of liquid UF cylinders on railcars.

Specifically, EE CE-1999-0348 noted that the rails were incased in a reinforced concrete bed which would not allow the rail to twist or tum. In addition, the concrete surface of the track bed was approximately 10 feet wide with the track bed level with the top of the rails, except for the railroad car wheel rim slots. Therefore, a derailment would be contained to the concrete bed because of the slow rate of travel of the rait cars.

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Susoended Llauld Cylinder At Buildina X-343 On June 29, while lifting a 10-ton liquid UF, cylinder from Autoclave No. 6 at ,

Building X-343, the South Crane hoist motor tripped when the amperage exceeded the I capacity of the motor thermal overloads. The emergency brake engaged as designed and the crane was declared inoperable with the cylinder suspended about 2 feet above l the autoclave. The PSS activated the EOC for technical support and shored up the space underneath the cylinder. The PSS also declared the other liquid UF, handling cranes inoperable pending an investigation of the root cause.

The certificatee preliminarily determined that the cause of the overload trip was the failure to properly tighten a connection following replacement of the overload device the previous day. The certificatee inspected and tested the overload devices on similar use cranes, did not identify any problems, and retumed those cranes to service. The certificatee prepared a PORC-approved procedure for restoring the South Crane and successfully completed the evolution on July 1.

In response to the multiple events during the inspection period, the cettificatee formed a team to evaluate the overall handling of liquid UF. cylinders onsite. The evaluation was to include development of a list of potential scenarios that could lead to off-normal cylinder handling events and mitigation plans and procedures to address those scenarios. The team also intended to evaluate the design basis and material conditbn of cylinder handling equipment. The inspectors' review of the results of the evaluation and the corrective actions taken is an Inspector Followup Item (IFl 70-7002/99005-02).

c. Conclusions The inspectors concluded that the emergency personnel responded appropriately to the

' cylinder handling events. The inspectors will followup on the results of the certificatee's integrated review of liquid cylinder handling site-wide.

08 Miscellaneous Operations issues 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. The inspectors will evaluate the associated written reports for each of the events following submittal, as applicable.

Number Data Status Titig 35732 05/17/99 Open Safety System Actuation, Building X-344 Autoclave No. 2 High Condensate Level.

35745 05/20/99

• Closed 4-Hour Report to other govemmental agency; Nuclear Criticality Safety Approval NCSA) violation identified in Department of Energy (DOE) regulated area.

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N/A 05/27/99 Open 10 CFR 71.95 event; cylinders received by customer with overpack ball lock pins disengaged.

35777 05/28/99 Open Safety System Actuation, Building X-330 Tails area, hoist brakes on south crane actuated while lowering a liquid UF, cylinder. 3 l

35837 06/16/99 Open Safety System Actuation, smokehead l actuation in the LAW condenser /

accumulator area.

35868 06/26/99

• Closed 4-Hour Report to other govemmental agency; NCSA violation identified in DOE regulated area.

35871 06/26/99 Open Safety System Failure, Building X-333, Cell 33-5-10 local cell trip circuit.

35875 06/28/99 Open Safety System Actuation, Building X-343 South Crane hoist brake actuation while a full liquid UF. cylinder was being removed from Autoclave No. 6.

• Reviewed by DOE.

08.2 Bulletin 91-01 Reports (97012)

The certificatee made the following reports pursuant to Bulletin 91-01 during the I inspection period. The inspectors reviewed any immediate NCSA concems associated with the report at the time of the initial verbal notification. Any significant issues emerging from these reviews are discussed in separate sections of this report or in future inspection reports.

Number Data I!!!n 35768 05/25/99 24-Hour Report - Building X-705,5 gallons of solution leaked onto the floor in violation of NCSA requirements.

35775 05/28/99 24-Hour Report - Building X-326, a 5 inch polybottle containing uranium bearing solution was discovered to be leaking from the top of the container and the lid was discovered to be loose in violation of NCSA requirements.

35776 05/28/99 24-Hour Report - Building X-705, six 250 mi sample bottles containing uranium bearing material were found spaced less than 2 feet edge-to-edge in violation of NCSA requirements.

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6 i 35799 06/04/99 24-Hour Report - Building X-330, surge drum pressure was monitored once each shift as required with a gauge that had been isolated from the drum, causing the actual drum pressure not to be read in violation of NCSA requirements.

I 35814 06/11/99 4-Hour Report - Building X-343, standing water was  !

discovered beneath Autoclave No. 6. NCSA for this operation was determined to be deficient in that it failed to identify controls necessary to maintain the analyzed condition.

35823 06/14/99 24-Hour Report - Building X-333, a recycle cooler stored on the cell floor, classified as uncomplicated handling, was discovered with a cover missing in violation of NCSA requirements. 1 35828 06/15/99 24-Hour Report - Building X-705, a small diameter container in a transport cart was spaced less than 2 feet edge-to-edge from a 1 inch line containing fissile solution.

35854 06/23/99 4-Hour Report - Building 744H, legacy valves and other cascade equipment were discovered in the building that did not meet the less than 15 grams uranium-235 (U-235) per piece of equipment that had been established as the acceptance criteria for receiving contaminated equipment 1 in violation of NCSA requirements. I 35870 06/25/99 24-Hour Report - Building X-744L, pallets of contaminated vacuum pumps on storage racks in contaminated storage area were discovered to be spaced less than 2 feet edge-to-edge in violation of NCSA requirements.

08.3 (Closed) URI 70-7002/98015-01: Apparent differences between plant operating procedures and the Safety Analysis Report (SAR) accident analysis assumptions.

Specifically, operating procedures ariowed inventory in the withdrawal station accumulator and condenser piping to exceed that assumed as the maximum release in j

- the accident analysis as described in SAR Section 4.2.3.3 (2000 lbs at Tails and 500 lbs at the Extended Range Product and Low Assay Withdrawal Stations). The certificatee identified the discrepancy but did not establish compensatory actions until prompted by the inspectors. The certificatee believed that the release of the total volume of the accumulators was bounded by another design basis accident, the rupture of a UF, liquid-filled cylinder.

After prompting from the inspectors, the certificatee initiated compensatory action that required venting the withdrawal station back to the cascade whenever flow to cylinders was interrupted for more than 15 minutes, which precluded exceeding the SAR assumptions. The certificatee later revised the applicable operating procedures to include the compensatory actions. In addition, the certificatee conducted refresher training with appropriate staff regarding the requirements for maintaining SAR compliance, including accident scenarios and their bounding conditions.

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Failure to take action to prevent plant operation in a potentially analyzed condition is a violation of ASME NQA-1-1989, Basic Requirement 16, " Corrective Action." However, the certificatee rarely operated the withdrawal stations with inventory exceeding the j limits assumed in the SAR. The certificatee also took immediate action after prompting j

' from the inspectors to correct the problem. Therefore, the issue is violation of minor '

significance end is not subject to formal enforcement action.

II. Maintenance and Surveillance M3 Maintenance Procedures and Documentation M3.1 Inadequate Procedure For De-energizing Equipment During Emergencies

a. Insoection Scone (88103)

The inspectors reviewed the certificatee's actions to address a weakness in the plant procedure for de-energizing equipment during emergencies.

b. Observations and Findinas' On December 9,1998, during the response to a fire in Building X-326, plant staff identified an issue regarding the de-energizing of electrical equipment in order to allow i fire 0ghters to extinguish the fire. Power operators de-energized the feeder to the equipment using the pistol grip at the switchyard to open the breaker. However, no y immediate action was taken to prevent an individual from inadvertently re-energizing the equipment and putting the firefighters at risk. The issue was documented in Problem Report 99-01440. l In response, the certificatee reviewed Procedure XP4-CU-PW5601, " Tripping of Switchyard Breaker and Bus," which directed the activities of power operations s . personnel when responding to cascade emergencies requiring electrical equipment to bc de-energized. The certificatee determined that the procedure did not require the breaker to be racked out or " lockout-tagout" protection applied which would be required i during a normal switching operation.

As immediate corrective action to the procedure deficiency, the certificatee issued a daily operating instruction that required the control switch be placed in the " trip lockout" position and a " danger unsafe" tag hung on the switch during an emergency. The certificatee also intended to revise the procedure to include the instruction. The inadequate proc 6 dure is a violation of Technical Safety Requirement (TSR) 3.9.1.

However, the deficiency was identified by plant staff and appropriate corrective action was taken to address it. Therefore, this certificatee-identified and corrected violation is being treated as a Non-Cited Violation (NCV 70-7002/99007-03), consistent with Sectiot VE 1.1 of the NRC Enforcement Policy.

c. Conclusion The inspectors concluded that the certificatee took the appropriate action to correct a deficiency in the procedure for de-energizing electrical equipment during an emergency.

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l M8 Miscellaneous Maintenance Issues M8.1 (Ooen) URI 70-7002/98016-02:. Documentation of test results as required by the Quality Assurance Plan, Section 2.11. The inspectors opened this item when it was noted that the certificatee was not documenting results in procedures for testing autoclave pigtail isolation valves, only acceptability (pass / fall) of the testing. In response, the certificatee committed to review and revise procedures, as necessary, to ensure that numeric test ,

results were recorded. The scheduled completion for the review was March 31,2000.

This item will remain open pending the inspectors' review of the certificatee's completed actions.

111. Enaineerina E2- Engineering Support of Facilities and Equipment E2.1 Nuclear Criticality Safety Anomalous Condition at Buildina X-744H

a. Inspection Scope (88100) l The inspectors followed up on an Nuclear Criticality Safety (NCS) anomalous condition at the X-744H Warehouse.

b. Observations and Findinas 1

On June 9, while performing radioactive contamination surveys on G-17 valves in the X-744H Warehouse, the certificatee discovered material in excess of 10 percent assay on the valves. In response, plant staff initiated a problem report which was screened by an NCS engineer as an anomalous condition. The engineer determined that no violations of NCS controls existed because it was assumed that the valves did not contain more than 15 grams of U-235 and the applicable NCSA, PLANT-048.A03,

" Contaminated Metal," analyzed material up to 100 percent assay. The certificatee then performed non-destructive analysis (NDA) surveys on the valves to quantify the assay and the mass of the U-235 in the hidden volumes of the valves. The purpose of the surveys was to determine where in Building X-705 the valves would be moved for decontamination.

Before the NDA results were received, the certificatee moved the valves to a staging area outside the warehouse. On June 22, the certificatee reviewed the NDA results which indicated that the combined content of all the valves contained in excess of 350 grams of U-235. An NCS engineer again reviewed the condition and determined that a violation of NCSA-PLANT-048.A03 did not occur, as no more than 350 grams of U-235 had been batched together.

During followup, the inspectors observed that the staging area was not posted in accordance with the NCSA. As a result, there were no controls in place to prevent plant personnel from batching the valves together which could have resulted in a potential violation of the NCSA. Upon further review, the inspectors also noted that another violation of the NCSA did occur, as the mass of the material was required to be quantified prior to movement. In response to the inspectors' issues, the certificatee properly posted the area and took action to space other potentially fissile material 11

remaining in the warehouses. In addition, the certificatee made a verbal notification to the NRC due to the NCSA non-compliance.

Technical Safety Requirement 3.11.2 required, in part, that all operations involving uranium enriched to 1.0 weight percent or higher U-235 and 15 grams or more of U-235 shall be performed in accordance with a documented NCSA. NCSA-PLANT-048.A03, " Contaminated Metal," required that individual items having hidden volumes greater than 1 gallon or visible uranium bearing materials beyond fixed stains / films shall be stored with a minimum 2 foot edge-to-edge spacing to other uranium-bearing items until NDA information (indicating less than or equal to 350 grams U-235) was obtained.

The NCSA also requ;ted that contaminated metal storage areas be posted, delineating the above requirements.

Contrary to the above, between June 9 and 22, the certificatee batched the G-17 valves .

In a staging area outside Building X-744H, with less than 2 foot edge-to-edge spacing to -

each other, before NDA information indicating less than or equal to 350 grams i U-235 was obtained. In addition, the certificatee failed to post the staging area as j required. This is a violation of TSR 3.11.2 (VIO 70-7002/09007-04).  !

c. Conclusion The inspectors identified that NCS staff displayed a lack of rigor in assessing the anomalous condition, resulting in violations of the NCSA.

IV. Plant Suonort R8 Miscellaneous Radiation Protection Issues R8.1 (Closed) Comoliance Plan issue 7. "Hioh Efficiency Particulate Air (HEPA) Filter System Testino" and Violation 70-2002/98014-Q14 This issue documented that in-place leak testing could not be performed for 6!! the fixed or portable HEPA filters onsite.

The planned actions to address the issue included retrofitting or replacing HEPA systems to allow leak testing in accordance with the applicable national standards, developing a database to track the portable HEPA units onsite, and establishing a basis for determining when HEPA filtration was required based on the Environmental Filter Criteria established by HEPA Filter System Team and the

- As-Low-As-Reasonably Achievable Committee.

The inspectors' review and the review documented in NRC Inspection Report 70-7002/98014(DNMS) indicated that the program to identify, modify, and test all required HEPA systems onsite was completed by the due date of June 30,1997.

However, Violation 70-7002/98014-01d documented that the evidence files for this issue did not include a justification for establishing which HEPA, systems were required based on the Environmental Filter Criteria. The inspectors' review of the evidence files during this inspection identified that the technical basis for classifying the HEPA filter systems onsite based on the established criteria was now documented. As a result, the inspectors concluded the certificatee's actions taken to resolve the noncompliances were sufficiently documented and reasonable, and considered Compliance Plan issue 7 and Violation 70-7002/98014-01d closed.

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R8.2 (Closed) Comoliance Plan issue 12. " 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

. procedure changes to address the 10 CFR 20 requirements and the radiation protectinn program annual review.

The inspectors performed a review of selected parts of 10 CFR Part 20 and the applicable UE2, XP2, and XP4 Level Health Physics Procedures. The inspectors concluded that radiological protection procedures had been revised to reflect the 10 CFR 20 requirements for radiological protection. The inspectors obtained and reviewed the 1998 Radiological Protection Program Review and noted the review was thorough, satisfied the requirements of 10 CFR 20.1101(c), and identified significant issues forimprovement which were being addressed in accordance with the certificatee's corrective action program. The inspectors concluded the certificatee's actions taken to resolve the noncompliances were sufficiently documented and reasonable, and considered Compliance Plan issue 12 closed.

R8.3 (Closed) Comoliance Plan issue 13. "Postina of Radioactive Materials": This issue was documented with the following three descriptions of noncompliance: 1) building work 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 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 )

regarding the type, extent, and amount of radioactive material present, as a result some l areas have not been property 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 progrem 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 radiolegical 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. The documentation in the evidence  ;

files appeared to be comprehensive and provided substantial evidence of the survey j techniques and areas involved in the site characterization process. The inspectors 13 b

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concludeo the certificatee's actions taken to resolve the noncompliances were sufficiently documented and reasonable, and considered Compliance Plan lasue 13 closed.

R8.4 (Closed) Comoliance Plan lasue 14. " National Voluntarv 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 process. The inspectors I confirmed that the certificatee had resolved this issue and had obtained NVLAP accreditation for the dosimetry processing unit onsite by March 3,1997.

J Subsequently, the certificatee decided to change dosimetry and obtained the services i of a NVLAP-accredited processor. The certificatee had documentation on file to l demonstrate that the dosimeters used were processed by a NVLAP-accredited  !

dosimetry processor. The inspectors concluded the certificatee's actions taken to I resolve the noncompliances were sufficiently documented and reasonable, and considered Compliance Plan issue 14 closed. 4 R8.5 (Closed) Comoliance Plan lasue 22. " Safety Committees": The description of noncompliance for this issue stated that the charter for the PORC had not been reviewed and revised to ensure consistency with SAR Section 6.2 and TSR 3.10. The inspectors reviewed Procedure UE2-PO-OR1030, " Plant Operations Review Committee," which provided the charter for the PORC quorum and approval process, and TSR 3.10. The inspectors confirmed that the applicable requirements were included in the implementing procedure for the PORC. In addition, inspections of PORC meetings conducted .since March 3,1997, indicated that the TSR and procedural requirements had been appropriately implemented. The inspectors concluded the certificatee's actions taken to resolve the noncompliance were sufficiently documented and reasonable, and considered Compliance Plan Issue 22 closed.

R8.6 (Closed) Comoliance Plan lasue 36. "Deoleted Uranium Manaaement Plan": This ist.ue identified two noncompliances associated with the handling and inspection of depleted uranium (Tails) cylinders at the site. The first noncompliance stated that the written ,

procedures for handling, moving, stacking and inspection activities did not conform with the current format and content requirements for the certificatee's procedures program.

The second noncompliance stated that the certificatee did not have a process in place for scheduling period visual inspections of USEC tails cylinders placed in long-term storage. The inspectors' review indicated that the XP4 proceduras associated with the handling, moving, stacking, and visual inspections of USEC tails cylinders onsite had been revised to conform to the current format and content requirements._ in particular, Procedure XP4-TE-UH6311, " Inspection of USEC Tails Cylinders in Long-Term Storage," incorporated the requirements for performing detailed visualinspections of the tails cylinders every 4 years to ensure any degradation was identified. The inspectors concluded the certificatee's actions taken to resolve the noncompliance were sufficiently documented and reasonable, and considered Compliance Plan lasue 36 closed.

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18 Miscellaneous Training issues 18.1 (Closed) Comoliance Plan issue 26. " Systems Acoroach to Trainina": The description of noncompliance for this issue documented that a systems approach to training had not been fully implemented for a number of the job classifications identified in SAR Section 6.6.3. ' The plan of action and schedute for the issue identifiad five actions to address the noncompliance: 1) Develop and implement a systems approach to training (SAT) for personnel relied upon to operate, maintain, or modify quality or augmented quality (AQ)-NCS or components; 2) Develop a detailed schedule for training the personnel in the job classifications identified; 3) Develop an SAT program (revise and validate task lists, design a curriculum for the tasks, develop leaming objectives and training materials) for systems engineers, cascade controllers, and NCS engineers or specialists; 4) Train these additional job classifications; and 5) Develop and implement an SAT program for activities affecting augmented quality systems and components.

The inspectors reviewed the closure documentation for selected job classifications, including systems engineers and cascade controllers. Based on the review, the inspectors concluded that each of the planned actions had been completed. The plant staff developed task-to-train-to-procedure matrices for the various job classifications.

The plant staff then developed training modules to cover each task with specific leaming objectives. The qualification requirements for each specific job classification were outlined in a trainirsg development and administrative guide. Documentation of completed qualification training for systems engineers and cascade controllers was available and appeared to be complete. The plant staff developed a listing of activities or tasks which involved AQ systems or components and provided training to affected workers. Based on the review, the inspectors concluded the certificatee's actions taken to resolve the noncompliance were sufficiently documented and reasonable, and considered Compliance Plan lasue 26 closed.

P8.0 Miscellaneous Quality Assurance Activities E8.1 (Closed) Compliance Plan lasue 29. " Records Manaaement and Document Control Procram": The description of noncompliance for this issue documented that records management and document control programs had not been fully implemented as identified in SAR Sections 6.10.1 and 6.10.2. The plan of action and schedule for the issues identified 6 major actions (and several sub-items) to address the noncompliance:

-1) identify and institute a records management program; 2) use the developed Configuration Management Program to address records needed to document source information; 3) tum over records to Administrative Support and provide for storage in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire-rated storage cabinets; 4) identify and tum over to Administrative Support computer codes and data used to support process systems; 5) institute a comprehensive, centralized document control program to meet Quality Assurance Program and certificate requirements; and 6) identify those legacy source documents which should be included in the document control program.

The inspectors reviewed the closure documentation and procedures developed to address these actions. The inspectors noted that a thorough investigation of the quality and regulatory records and documents generated by the various organizations onsite was performed. A tumover schedule and electronic indexing database to track records for storage and retrieval were developed and implemented. One-hour fire-rated safes for storage of quality and regulatory records were obtained. A centralized document control program was developed and implemented, including identification of documents 15 j

to be controlled, a tumover schedule, controlled distribution lists, cataloguing the documents in the program, and an electronic document controlinventory system. The review identified that all the planned actions had been completed by December 31, 1998, the date for full compliance in the Compliance Plan. Based on the review, the inspectors concluded the certificatee's actions taken to resolve the noncompliance were sufficiently documented and reasonable, and considered Compliance Plan issue 29 closed.

V, Manaaement Meetinas X1 Exit Meeting Summary The inspectors presented the inspection results to members of the facility management on June 29,1999. The facility staff acknowledged the findings presented and indicated concurrence with the facts, as stated. 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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PARTIAL LIST OF PERSONS CONTACTED United States Enrichment Corooration

• M. Brown, General Manager

• S. Casto, Work Control Manager

• D. Couser, Training Manager

• L. Fink, Safety, Safeguards & Quality Manager

• S. Fout, Operations Manager

• P. Miner, Regulatory Affairs Manager

• P. Musser, Enrichment Plant Manager

• M. 'Mayland, Maintenance Manager

• Denotes those present at the exit meeting on June 29,1999.

INSPECTION PROCEDURES USED IP 88100: Plant Operations )

IP 88103: Maintenance j IP 90712: In-office Reviews of Written Reports on Non-routine Events

~ ITEMS OPENED, CLOSED, AND DISCUSSED Ooened l

70-7002/99007-02 IFl Integrated review of cylinder handling.  !

l 70-7002/99007-04 VIO NCSA violation for valve storage at Building X-744H.

~35732 CER Safety System Actuation, Building X-344 Autoclave No. 2 High Condensate Level.

35777 CER Gafety System Actuation, Building X-330 Tails area, hoist brakes on south crane actuated while lowering a 14 ton liquid UF.

cylinder.

35837 CER Safety System Actuation, smokehead actuation in the LAW condenser / accumulator area.

35871 C,ER Safety System Failure, Building X-333, Cell 33-5-10 local cell trip circuit.

35875 CER Safety System Actuation, Building X-343, South Crane failed while a full liquid UF, was being removed from Autoclave No. 6.

Closed 70-7002/98015-01 URI Apparent differences between plant operating procedures and the SAR accident analysis assumptions.

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A 70-7002/99007-01 NCV Procedural violation of requirement to notify shift supervisor before retuming a shutdown autoclave to service.

70-7002/99007-03 NCV Inadequate administrative controls to ensure electrical equipment i remained out of service.

' 70-7002/98014-01d VIO Failure to document and place of file justifications for the downgrade of HEPA filter systems as required by Compliance Plan issue 7.

35745 CER 4-Hour Report to other govemmental agency; NCSA violation discovered in DOE regulated space.

35868- CER 4-Hour Report to other govemmental agency; NCSA violation discovered in DOE regulated space.

Compliance Plan issue 7, "HEPA Filter System Testing" Compliance Plan Issue 12, " Radiation Protection Procedures" Compliance Plan issue 13, " Posting of Radioactive Materials" Compliance Plan issue 14, "NVLAP Certification" Compliance Plan lasue 22, " Safety Committees" Compliance Plan issue 26 " Systems Approach to Training" Compliance Plan issue 29, " Records Management and Document Control" Compliance Plan Issue 36, " Depleted Uranium Management Plan" Qiscussed 70-7002/98016-02 URI Documentation of test results as required by Quality Assurance, Section 2.11.

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s LIST OF ACRONYMS USED AQ Augmented Quality CER Certificate Event Report CFR Code of Federal Regulations DNMS Division of Nuclear Material Safety DOE Department of Energy EE Engineering Evaluation EOC Emergency Operations Center FLM Front-Line Manager HEPA M'gh Efficiency Particulate Air IC incident Commander IFl Inspection Follow-up Item NCS Nuclear Criticality Safety .

NCSA Nuclear Criticality Safety Approval i NCV Non-Cited Violation i NDA Non-Destructivts Analysis NRC Nuclear Regulatory Commission NVLAP National Voluntary Laboratory Accreditation Program PAS Plan of Action and Schedule j PDR Public Document Room  ;

PORC Plant Operations Review Committee psig pounds per square inch gauge PSS Plant Shift Superintendent SAR Safety Analysis Report .

SAT System Approach to Training TSR Technical Safety Requirements l U-235 Uranium-235 UF, Uranium Hexafluoride URI Unresolved item USEC' United States Enrichment Corporation VIO Violation 19