ML20210P767

Insp Rept 70-7001/99-08 on 990529-0719.Violations Noted. Major Areas Inspected:Plant Operations,Engineering & Plant Support

ML20210P767
Person / Time
Site:	07007001
Issue date:	08/10/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
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Shared Package
ML20210P746	List: ML20210P742 ML20210P752 ML20210P767
References
70-7001-99-08, NUDOCS 9908130080
Download: ML20210P767 (12)

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4 U.S. NUCLEAR REGULATORY COMMISSION REGIONlli Docket No: 70-7001 Certificate No: GDP-1 Report No: 70-7001/99008(DNMS)

Facility Operator: United States Enrichment Corporation Facility Name: Paducah Gaseous Diffusion Plant Location: 5600 Hobbs Road P.O. Box 1410 Paducah, KY 42001 Dates: May 29 through July 19,1999 Inspectors: K. G. O'Brien, Senior Resident inspector J. M. Jacobson, Resident inspector Approved By: Patrick L. Hiland, Chief, Fuel Cycle Branch Division of Nuclear Materials Safety L

9908130080 990810 PDR ADOCK 07007001 C PDR

EXECUTIVE

SUMMARY

United States Enrichment Corporation Paducah Gaseous Diffusion Plant NRC Inspection Report 70-7001/99008(DNMS)

Plant Ooerations e A planned reduction in the enrichment cascade power load occurred without any significant issues. The safety and efficiency of the evolution appeared to be improved over a previous summer power load reduction because of a concerted effort by the plant staff to improve the material condition and availability of cascade purge and evacuation '

pumps in the various process buildings. (Section 01.1) i e The plant staff appropriately responded to an event in which five of ten cell motors failed I to shut down when the motor-stop button in the area control room was actuated. )

(Section 01.2)

Enaineerina e As part of the lessons-learned process, the plant nuclear criticality safety staff developed guidance for dealing with the potential safety issues which could result from breached cascade equipment as a result of an exothermic reaction similar to that which occurred at Portsmouth Gaseous Diffusion Plant in December 1998. (Section E1.1)

Plant Sucoort

• The inspectors initiated an unresolved item to track to breadth and depth of an issue involving classified matter, from the 1950's and later, that may not have been properly marked or stored and was located outside the controlled access area. Previously, the plant staff had identified an example of classified information, included in a 1950's document, that was not properly marked or stored. (Section S1.1) e The inspectors identified a violation, in that, the plant staff did not immediately notify the Plant Shift Superintendent of problems (sprinkler head corrosion) affecting some Technical Safety Requirement-governed fire protection systems. As a result, compensatory measures were not implemented, in some cases, for 3 weeks after the problems were initially identified. Once notified, the Plant Shift Superintendent appropriately responded to the problems. (Section F1.1) l 1

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I Report Details i

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1. Operations 01 Conduct of Operations 01.1 Reduction in Power for the Summer Months t i

a. Insoection Scope (88100)

The inspectors reviewed the plant staff's implementation of a planned significant reduction in the plant power load and operating equipment for the summer months.

b. Observations and Findinas l Beginning in late May and ending in early July, the plant staff performed a reduction in the plant power load from approximately 1900 megawatts (MW) to 300 MW. The power l reduction resulted from a desire to offset increased electricity costs during the summer l peak demand. Prior to initiating the power reduction, the plant staff prepared a  ;

schedule of cascade cells to be evacuated and shut down to support an orderly '

transition from high-power to low-power operations. The amount of power required for cascade operations was directly related to the amount of uranium hexafluoride 1 undergoing enrichment in the cascade cells.

The inspectors noted that the power load reduction occurred without any significant problems. The cascade cell shut-down schedule was generally adhered to with only minor deviations due to a few unforeseen equipment failures. The operations staff were '

aided in the evolution by the availability of the cascade purge and evacuation pumps.

The repair and replacement of inoperable purge and evacuation pumps had been a high priority for the plant staff over the previous year in recognition of the pumps'importance in providing a ready and efficient means to evacuate the uranium hexafluoride from cascade cells prior to shutting down the cells. The effective evacuation of cells significantly decreased the potential for a release or the solidification of material in the equipment. The emphasis on improving the material condition of the purge and evacuation pumps appeared to have a positive effect in performing the power reduction without incident.

c. Conclusions

- A planned reduction in the enrichment cascade power load occurred without any significant issues. The safety and efficiency of the evolution appeared to be improved over a previous summer power load reduction because of a concerted effort by the plant staff to improve the material condition and availability of cascade purge and evacuation pumps in the various process buildings.

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01.2 Inocerable Cascade Cell Trio Function

- a. Insoection Scope (88100) -

The inspectors reviewed the plant staff's response to an event in which half of the motors for a cascade cell did not stop when the cascade cell motor-stop button in the

- area control room (ACR) was depressed.

b. ' Observations and Findinas On June 3, a Building C-331 operator depressed the motor-stop button, located in the ACR, to shut down Unit 3-Cell 5 and noted that one set of the stage motors

'(Stages 6-10) for the cell continued to operate. The use of the motor-stop button for planned cell shutdowns was one means of satisfying Technical Safety Requirement {

(TSR) Surveillance 2.4.4.12-8 for the cell trip safety function. - The actuation of the i J

button was intended to cause twc, electrical breakers to open, one for Stages 1-5 and the other for Stages 6-10. However, only one of the electrical breakers opened. In response to the condition, the operator completed the cell shutdown by opening a secondary electrical breaker. The Plant Shift Superintendent (PSS) subsequently declared the cell trip function for the affected cell inoperable, pending troubleshooting and repair activities for the cell trip circuit, as appropriate.

The inspectors reviewed the Assessment and Tracking Report (ATR) initiated by plant staff to document the problem. The ATR indicated the event was not reportable based upon the availability of redundant equipment (the secondary breaker) to accomplish the safety function. The inspectors reviewed the Safety Analysis Report (SAR) and noted that the SAR discussed a number of alternate means of accomplishing a cell shutdown, within 1-2 minutes, if the motor-stop button did not function properly. Based upon the information included in the SAR, the inspectors determined that the plant staff's assessment of reportability was reasonable. The inspectors also noted that the ATR information indicated that the cell trip function was a quality system. However, the SAR and the Building C-331 Boundary Definition Manual identified the system as an augmented quality system. Although the actions taken to declare the system inoperable and remove the cell from service were appropriate, the inspectors noted that a number of plant staff had reviewed the ATR and did not notice the quality definition error. The certificatee initiated an ATR to document the deficiency.

c. Conclusions

. The plant staff appropriately responded to an event in which five of ten cell motors failed l

to shut down when the motor-stop button in the ACR was actuated.

08 Miscellaneous Operations issues 08.1 . Certificatee Event Reports (90712)  ;

The certificatee made the following operations-related event reports during the l inspection period. The inspectors reviewed any immediate safety concerns indicated at the time of the initial verbal notification. In the case of retracted notifications, the inspectors reviewed the basis for the certificatee's retraction of the notification at the .

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time of the retraction. The inspectors will evaluate the associated written report for each of the events followirig submittal.

Number Status Title 35790 Open Corrosion of High-Pressure Fire Water Sprinkler system Heads.

35816 Open Loss of Criticality Accident Alarm System Building Horn Power for Buildings C-409 and C-720-M.

08.02 Bulletin 91-01 Reports (97012)

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

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

Number Date Title l

35920 7/14/99 Failure to obtain independent verification of cylinder heel I weight before washing.

I 08.3 (Closed) Unresolved iteni 70-7001/98007-01: Lack of well-defined criteria to determine the complete training requirements for cascade first-line managers (FLM), in a response dated May 3,1998, the certificatee Identified the training requirements for FLMs. The FLMs having responsibility for cascade ACRs were required to complete a six-week course on cascade operations, To clarify the requirements, the certificatee revised KY/T-31, " Administrative Guide for the Cascade Operator Training Program (TDAG)." The inspectors reviewed the revised guidance and noted that the revision clarified the requirements for the training required for cascade FLMs as opposed to operators. The certificatee's policy required that any FLMs, who were utilized to perform as qualified operators, must complete additional training required for operators. The inspectors noted that the guidance appeared to meet the requirements in Section 6.6,

" Training," of the SAR and considered the item closed.

11. Enaineerina E1 Conduct of Engineering E1.1 Criticality Safety Ana!vses for Breached Eauipment

a. insoection Scope (88100. 88020)

The inspectors reviewed guidance documents developed by plant NCS staff as part of the plant staff's process of developing lessons-! earned from and corrective actions for issues resulting from the December 1998 fire at the Portsmouth Gaseous Diffusion Plant.

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b. Observations and Findinas During the inspection period, the inspectors reviewed an engineering notice and associated engineering evaluation developed by plant NCS staff. The guidance presented in tne documents was intended to clarify and amplify the appropriate methods for the plant cperations staff to respond to a breach in cascade equipment, i.e., a loss of moderation centrol, due to an exothermic reaction within the equipment. The recommendations provided were an attempt to ensure that prompt ac+ ion to restore the involved equiprnent to a known safe condition would be taken after the exothermic reaction or fire was over. The information indicated how to identify deposits, how to ensure appropriate spacing and moderation controls would be re-established, and the NCS bases for the recommendations provided. The guidance in the documents was to be included in the appropriate emergency procedures for future training and reference, as needed. The inspectors noted that the initiative by the plant NCS staff appeared to be pro-active in responding to some of the NCS issues identified as a result of the December 1998 event.

c. Conclusions As part of the lessons-learned process, the plant NCS staff developed guidance for dealing with the potential safety issues which could result from breached cascade equipment as a result of an exothermic reaction similar to that which occurred at Portsmouth Gaseous Diffusion Plant in December 1998.

IV. Plant Support S1 Conduct of Security Activities l S1.1 Classified Matter Outside the Controlled Access Area

a. Inspection Scope (88100)

The inspectors reviewed the circumstances surrounding the plant staff's identification of a letter containing classified information outside the controlled access area (CAA).

b. Observations and Find;nas On June 29, the inspectors were notified by the plant staff that a 1956 letter had been identified that contained classified information based upon examples included in the current classification guide. At the time of the discovery, the letter was not marked and did not have any other notations to indicate that it contained classified information. The classified nature of the letter was identified as part of a large classification review of historical documents which were being released by the United States Enrichment Corporation (USEC) to a third party. Prior to the discovery, the letter was stored in a notebook of various unclassified environmental documents. The notebook was located in an office in Building C-743, a building generally located outside the CAA. (The plant staff had the ability to bring the facility inside the CAA or leave it outside the CAA.) The plant staff had not had an occasion to reference the notebook for several years and did not suspect that it might contain classified information.

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Upon discovery, the p! ant staff properly marked the document and retained it under the control of plant security staff. The plant staff initiated an ATR and determined that there was no indication, within recent years, of any actual compromise of the classified information because the plant staff had not used or referenced the historical notebook.

In addition, the plant staff documented the event in the monthly security events log, provided to the NRC pursuant to 10 CFR 95.57(b), as an infraction of the Classified ,

Matter Security Plan involving a possible compromise. i The inspectors reviewed the document and the current classification guide, and discussed with some plant staff the possible causes for the document not being properly identified, marked, or controlled as classified matter. The inspectors noted a clear correlation between the information included in the document and examples of classified matter included in the classification guide. The inspectors also noted that the classification guide that was in effect at the time the documents were developed did not include as many or as detailed examples as the current guide for the subject matter.

The inspectors also noted the guides issued in the 1950's appeared to include an expectation that existing information would be evaluated to determine the appropriate classification status based upon the newly revised guides. However, the inspectors could not determine that such a reassessment of the letter had been performed.

As part of the immediate corrective actions for the event, the plant staff brought Building C-743 into the CAA on a permanent basis. This action reduced the likelihood that uncleared individuals would have unescorted access to any unknown classified information in the facility. In addition, the plant staff initiated an engineering service order (ESO) to bring the remaining USEC trailers in the area inside the CAA. At the end of the inspection period the ESO was beir.g reviewed under the plant change review process.

The inspectors concluded that the immediate and planned corrective actions for the event were appropriate. The circumstances appeared to indicate that the classified information was likely not compromised in recent years. The potential for compromise in the 1950's timeframe could not be assessed. In addition, the inspectors noted that the classified nature of the letter was not readily evident, and the letter itself was contained in a significantly larger notebook of unclassified materials which had not been referenced by the plant staff in recent history.

At of the end of the inspection period, the plant staff were continuing to review other documents maintained in the notebooks in which the involved classified document was stored. Pending a completion of the plant staff's efforts to review the remaining materials, the loss of control of the classified information outside the CAA will be tracked as an Unresolved item (URI 70-7001/99008-01).

c. Conclusion

The inspectors initiated an unresolved item to track to breadth and depth of classified matter, from the 1950's and later, that may not have been properly marked or stored and was previously located outside the CAA. Previously, the plant staff identified an example of classified information, included in a 1950's document, that was not properly marked or stored.

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. F2 Status of Fire Protection Facilities and Equipment F2.1 Sorinkler System Head Corrosion

a. 'Insoection' Scope (88100)

The inspectors reviewed the circumstances surrounding the discovery by plant staff that a number of sprinkler heads associated with the high-pressure fire water (HPFW) systems in the process buildings were corroded (Event Report 35790).

b. Observations and Findinas On June 2, plant fire protection staff notified the PSS that inspections of the HPFW systems had identified numerous sprinkler heads which were corroded and exhibited mineral deposits. The PSS reviewed the ATRs associated w'th the observations and declared the HPFW systems, with two or more adjacent heada corroded, inoperable.

The PSS's operability determinations were based on the system design which provided overlapping coverage for areas underneath adjacent heads. The initial report to the NRC identified 16 sprinkler systems in Building C-337 and or.e sprinkler system in Building C-333 as inoperable. Additional updates to the report were made when the plant staff identified additional systems with corroded sprinkler heads. These additional sprinkler heads and systems were identified as part of a re-inspection and re-review of previous inspection efforts after the plant staff understood the problem extent.

For each of the systems declared inoperable by the PSS, the plant staff appropriately entered the Limiting Condition for Operation Action Statements, began fire patrols, and confirmed altemate sources of water were available from building fire hydrants. The

' plant staff expeditiously replaced the corroded heads, prioritizing those systems with operability concems. As of the end of the inspection period, the plant staff had identified a total of 163 heads with corrosion or mineral deposits in the process buildings and replaced 78 of those heads. (Each HPFW sprinkler system contained some 400 heads and the large process buildings contained approximately 25,000 heads.) All of the systems declared inoperable because of adjacent corroded heads had been repaired and retumed to service after appropriate post-maintenance testing.

The inspectors noted that identification of the problem during the annual HPFW

~ inspections appeared to result from an increased rigor applied to maintenance and

surveillance activities associated with fire protection systems over the previous 2 years.

However, the inspectors also noted that the problem was not raised to the attention of the PSS and plant management in a timely manner. Specifically, the inspectors determined that the plant staff performing the walkdowns, which began on May 10,

< 1999, did not document the results and submit the information to the PSS until June 2. I During a preliminary review of the field data, the inspectors identified more than a dozen sprinkler systems with corroded heads, an unacceptable condition according the applicable fire l protection standards, for which an operability decision should have been made as early as May 10,1999. In all cases, the results of the inspections were not

- provided to the PSS until June 2, at which time, some 33 systems were conservatively declared inoperable.-

During discussions of the findings with the plant fire protection engineering staff, the j inspectors noted that the inspections were performed by fire protection personnel, a 8

group of individuals generally aware of conditions and inspcction findings which could affect the fire protection systems' performance. In addition, the inspectors determined that the governing Procedures CP4-SS-FS6106," Fire Protection Building Appraisals,"

and CP4-SS-FS6111. "TSR Surveillance, inspection, and Testing of Wet Pipe Sprinkler Systems," provided clear guidance on the need to document, in a non-conformance report (ATR), deficiencies affecting compliance with fire protection codes or standards.

The inspectors further noted that the plant procedures on reporting and corrective action also required the plant staff to promptly notify the PSS of conditions which could affect quality, including the operability of systems relied upon for safety.

Technical Safety Requirement 3.9.1 required, in part, that written procedures shall be implemented for activities described in the SAR, Section 6.11 Appendix A. The SAR, Section 6.11, Appendix A identified quality assurance, including corrective actions as an activity for which written procedures shall be implemented. Plant Procedures CP1-PO-SF1001, "PSS Communication," Revision 0, dated May 16,1996, and CP2-BM-Cl1031," Corrective Action Process at Paducah Gu 'ous Diffusion Plant,"

Revision 1, Change A, dated March 18,1999, required, in p that the plant staff shall notify the PSS immediately upon the identification of problems with TSR-related systems, including problems which could affect operability or reportability. The failure of the plant staff, conducting reviews of the fire protection systems, a TSR-related system, to immediately notify the PSS of problems identified with the systems is a Violation (70-7001/99008-02).

At the end of the inspection, the root cause for the corrosion problem had not been determined. A etatistical test plan to determine whether or not the phenomenon actually affected system anctionality and operability was under development. Initial testing indicated that the phenomenon did not affect the actuation temperature of the sprinkler

heads, but could raise the pressure required for adequate flow. In addition, water chemistry tests were underway to determine the cause of degradation. An initial cause

. was suspected to be microbe-induced corrosion. The final root cause determination and corrective actions were to be provided in an update to the initial 30-day written report for the discovery.

c. Conclusions The inspectors identified a violation, in that, plant staff did not immediately notify the PSS of problems (sprinkler head corrosion) affecting the TSR-governed fire protection systems. As a result, compensatory measures were not implemented in some cases for 3 weeks after the problems were initially identified. Once notified, the PSS appropriately responded to the problems.

l 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 July 19,1999. The plant staff acknowledged the findings presented. The inspectors asked the plant staff whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

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PARTIAL LIST OF PERSONS CONTACTED United States Deoartment of Enerav G. A. Bazzell, Site Safety Representative United States Enrichment Corooration J. L. Adkins, Vice President - Production

• M A. Buckner, Operations Manager

• L. L. Jackson, Nuclear Regulatory Affairs Manager J. A. Labarraque,' Safety, Safeguards and Quality Manager

• S. R. Penrod, Enrichment Plant Manager H. Pulley, General Manager U.S. Nuclear Reaulatory Commission J. M. Jacobson, Resident inspector

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

• Denotes those present at the exit meeting July 19,1999.

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

INSPECTION PROCEDURES USED l 4

IP 88020: Nuclear Criticality Safety IP 88100: Plant Operations IP 90712: In-office Review of Events 10

ITEMS OPENED, CLOSED, AND DISCUSSED Opened 70-7001/99008-01 URI Proper marking and control of classified matter.

70-7001/99008-02 VIO Failure to promptly notify the Plant Shift Superintendent of problems with Technical Safety Requirements-related fire protection systems.

35790 CER Corrosion of high pressure fire water sprinkler system heads.

35816 CER Loss of criticality accident alarm system building horn power for Buildings C-409 and C-720-M.

Closed 70-7001/98007-01 URI Training requirements for front-line managers.

Discussed None i

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..e LIST OF ACRONYMS USED ACR Area Control Room ATR Assessment and Tracking Report CAA Controlled Access Area CFR Code of Federal Regulations DNMS Division of Nuclear Materials Safety ESO Engineering Service Order FLM- First-Line Manager HPFW- High Pressure Fire Water IP inspection Procedure MW Megawatt NCS. Nuclear Criticality Safety NRC Nucler Regu!atory Commission PDR Public Document Room PSS Plant Shift Superintendent SAR Safety Analysis Report TSR Technical Safety Requirement URI Unresolved item USEC United States Enrichment Corporation i 1

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