ML20211C734

Insp Rept 70-7001/97-07 on 970715-0912.Violations Noted. Major Areas Inspected:Plant Operations,Maint & Surveillance, Engineering,Security & Environ Protection

ML20211C734
Person / Time
Site:	07007001
Issue date:	09/24/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20211C717	List: ML20211C714 ML20211C728 ML20211C734
References
70-7001-97-07, 70-7001-97-7, NUDOCS 9709260291
Download: ML20211C734 (32)

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U.S. NUCLEAR REGULATORY COMMISSION REGION lli 1

Docket No: 70 7001 3

Report No: 70 7001/97007(DNMS) i j Facility Operator: United States Enrichment Corporation i Facility Name: Paducah Gaseous Diffusion Plant i Location: 5600 Hobbs Road i P. O. Box 1410 Paducah, KY 42001

! Dates: July 15 through September 12,1997 Inspectors: K. G. O'Brien, Senior Resident inspector J. M. Jacobson, Resident inspector 4 R. G. Krsek, Fuel Cycle inspector, Region til i-i Approved By: P. L. Hiland, Chief Fuel Cycle Branch i-9709260291 970924 PDR ADOCK 07007001 C PDR

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EXECUTIVE

SUMMARY

United States Enrichment Corporation Paducah Gaseous Diffusion Plant NRC Inspection Report No. 70 7001/97007(DNMS)

] Plant Ooerations

• An abnormally high release of uranium from the main effluent stack occurred as the

result of the loss of control of the Building C 310 purge cascade. (Section 01.2)

• The inspectors determined that the operator's investigation and response to a decreasing tails withdrawal rate properly implemented lessons learned from a 1994 release event. (Section 01.3) 4

• The inspectors identified that the cylinder tare weight listings, used by Building C 310 operators to determine the maximum acceptable UF fill weight for cylinders, were not controlled as a quality document. (Section 01.4)

Maintenance and Surveillance i

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• The inspectors identified inconsistencies between the work control process, the Quality Assurance Plan, and the plant procedure policy. As a result of the inconsistencies, staff used work instructions, in one example, to work around a i procedure problem. (Section M1.1)

• On three occasions, the plant staff failed to prescribed in or accomplish in accordance with procedures, appropriate the circumstances, the control of maintenance activities affecting quality. As a result, a fire protection system was inoperable for an excessive period, the safety-related nitrogen supply for an area criticality accident alarm system horn was found isolated, and a negative air machine was operated contrary to assuciated nuclear criticality safety controls.

(Section M1.2)

Enaineerina

• The inspectors identified that engineering staff made changes to the autoclave instrument upgrade post modification testing requirements, as defined by an engineering specification, without performing a safety evaluation of the changes.

(Section E1.1)

• The inspectors identified that engineering-developed installation instructions were used to install changes to equipment in conflict with the Technical Safety

Requirements and the site procedure control program. (Section E1.2)

• The inspectors identified potential concerns with the response provided to Compliance issue 45 and with current engineering practices for the application of engineering specifications. (Section E1.3) 2

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l Plant Sucoort  :

1 Security I

• Plant staff identified several examples of classified matter and access thereto which were not properly controlled, an apparent violation. Some of these examples were identified in areas outside the plant controlled access area. Plant management began a building-by-building classified matter " purge" effort on August 26 to address the continued discoveries of classified matter which had not been properly controlled. (Section S1.1)

Environmental Protection

• Overall, the waterborne effluent monitoring program was implemented in accordance with Safety Analysis Report. However, the iiupectors identified that required calculational reviews of two environmental mon'toring notebooks were not conducted. (Section R1.1)

• Programs for continuous sampling of the C-310 purge vent and high-volume ambient air sampling were effective. Review of a dose assessment performed in response to a uranium release which occurred in July 1997 indicated a minimal impact on the annual offsite dose and no exceedance of regulatory requirements.

(Sections R1,2 and R1.3)

• The inspectors identified a lack of rigor in the documentation used to support an editcrial change to Section 5.1 of the Safety Analysis Report. in addition, a program deficiency was identified in that the periodic analysis of the low volume air sampling filters was stopped prior to final approval of the Safety Analysis Report change that removed the requirement. (Section R1.4) 3

DETAILS

1. Operations 01, Conduct of Operations' 01.1 Status of Plant (88100)

During the period, the plant operated in a steady state condition with the exception of the purge cascade upsets discussed in Section 01.2 01.2 Loss of Purae Cascade Ooerations

a. insoection Scone (88100)

The inspectors observed selected aspects of an event in which the purge cascade in the C-310 Withdrawal Building was temporarily lost.

$ b. Observations and Findinas On July 21, at approximately 9:20 a.m., a slug of light gasses (primarily nitrogen) was introduced to the Building C 310 portion of the cascade. The Building C-310 cascade was composed of 10 cells; 6 cells (numbers 1,3,5, 7,9, and 10) operated at a low speed and were the topmost portion of the enrichment cascade. The remaining 4 cells (numbers 2,4,6, and 8) operated at a higher speed and were the purge cascade for the processing of lower molecular weight (light) gasses prior to discharge of the light gasses out the effluent emission stack. Design of the Building C 310 cascade, to include both low and high speed cells, was intended to: 1) minimize uranium emissions, generally less than 1 gram per day; and,2) provide a mechanical means for control of the uranium hexafluoride (UFe) " front." The " front" was the location, within the cascade, where the UF, gas concentration decreased significantly relative to other " light" gasses. Normally, the " front" location was well below the top operating cell from which the stream of effluents was withdrawn. The effluent stream was routed through alumina traps, to remove minor residual uranium contamination, prior to exiting the cascade vent stack.

In response to the slug of light gasses, the area control roorn (ACR) operator attempted to increase the purge rate,i.e., increase the volumetric rate of flow of the light gasses through the high speed cells and thus increase the rate of emission from the stack. As an apparent consequence of the Topical headings such as 01, MS, etc., are used in accordance with the NRC standaroded inspection report outline contained in NRC Manual Chapter 0610. Individual reports are not expected to address all outhne topics, and the topical headin0s are therefore not always sequential.

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4 operator's action, some UF., from the low speed cells, was suctioned into the high speed cell compressors . High speed cell compressors were not designed to handle the heavy molecular weight material. As a result, high speed cells 8 and 6 successively tripped offline on motor overload.

Concurrent with the ACR operator's actions, a second operator was dispatched to the local control panel to trip Cell 4. The operator completed this action at approximately the same time the cell automatically tripped on motor overload.

Just prior to the high speed cells tripping, the ACR operator noted:

1) abnormal indications on instrumentation monitoring the concentration of gasses entering the high speed cells; and,2) a load increase on Cell 8. As a result, the operator closed the isolation valve on the line from the alumina traps to the vent stack. The operator took the action in order to limit any potential uranium emissions.

After shutdown of the three operating high speed cells (Cell 2 was down for maintenance), the operators consulted with ;ascade management and the system engineers. Based upon management and system engineering direction, the operator evacuated the involved process piping and cells in order to draw off as much residual UF, from the purge cascade as possible.

At the same time, additional nitrogen was added to help re-establish the i " front" which was pushed back into Building C-335 with the closure of the l stack isolation valve. The high speed cells were subsequently brought back L

on line, the isolation valve re-opened and the normal " front " location was established.

l Subsequent to the event, the environmental protection staff collected and analyzed samples from the Building C 310 effluent stack. The results indicated that 542.5 grams of uranium had been released from the stack due to the event. This amount was over 500 times the normal daily release rate.

However, a dose calculation indicated that the released material would theoretically add only approximately 4 microrem to the yearly public dose.

The additional dose was well below the 10 CFR 20 target of 10 millirem per year to a member of the public from airborne effluents. (See also Section R1.2.) ,

Plant staff initiated an investigation into the event to determine the root cause of the event and the release. Once completed, the inspectors will review the investigation results and the proposed corrective measures. The inspectors' review will be tracked as an inspector Follow-up Item (IFl 70-7001/97007-01).

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c. Conclusions An abnormally high release of uranium from the main effluent stack occurred as the result of the loss of control of the Building C 310 purge cascade.

Plant staff were conducting an investigation of the event which the inspectors will review.

01.3 Interruotion of Steam Heatina to a Tails Withdrawal Stati20

a. Insoection Scooe (IP 88100)

The inspectors reviewed the interruption of steam heating to a portion of the tails withdrawal area and the operator actions taken to identify and return the system to service,

b. Observations and Findinas During the inspection period, Building C-315 operators identified a decreasing trend in the tails withdrawal rate. In response to the findings, the operators reviewed possible causes for the decreasing trend and identified a plugged trap in the steam heating system. The plugged trap caused a loss of steam heating to a portion of the withdrawal piping. Given the findings, the operators concluded that a nearly solid plug of UF, had formed in the withdrawal piping and caused the decreasing withdrawal rate.

The chemical properties of UF, require constant heating and elevated temperatures to maintain the materialin either a gas or liquid state.

During the discovery process, the operators cleared the plugged trap, readmitting steam to the previcusly cooled heating system piping. Because this action could result in the direct heating of a nearly solid plug of UF, materialinside a closed process pipe, the operators immediately isolated the i involved piping. Further actions were then taken to reestablish the clarity of the involved piping. Piping clarity was required prior to resuming operations of the steam heating system for the cooled piping. Subsequently, piping clarity was established and normal withdrawal system steam heating and operations were re-initiated.

The inspectors noted that the operator's response was consistent with current procedures and was safety-focused. The operator's actions to shut off the steam heating system, following clearing of the steam trap, were taken to preclude the recurrence of a UF, piping system failure and an uncontrolled release of UF, to the area and environment. Previously, in December 1994, steam heating was lost and re initiated to a portion of UF, piping in Building C-337A. The involved piping contained a UF, plug which had developed during the time steam heating was lost. As a result of re-applying steam heating to the system, the UF, plug liquefied, expanded, and burst the piping. Once the pipe was burst, a significant quantity of UF, was released over approximately four hours.

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c. Conclusions The inspectors determined that the operator's investigation and response to a decreasing tails withdrawal rate properly implemented lessons learned from a 1994 release event.

01.4 . Control of Tare Weicht Books

a. Insoection Scoce (IP 88100.1 During tours of the Building C 310 withdrawal area, the inspectors reviewed documents and procedures used during normal withdrawal activities.

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b. Observations end Findinas During a tour of the Building C 310 withdrawal area, the inspectors reviewed a listing of cylinder tare (empty) weights. The tare weights, listed by cylinder number, were used to establish the cylinder fill limits (gross weight minus tare weight) for cylinders to be filled with liquid UF., The cylinder tare weight was a vital piece of data in ensuring product cylinders (10-ton, 48X cylinders) were not overfilled.

The inspectors noted that multiple versionc of the tare weight listings existed in the withdrawal room and wera available for operator use. The listings were st mped with different dates and contained some cylinder entries with different weights (weight differences usually on the order of pounds). The inspectors inquired how the plant staff controlled the listings to ensure only the most current and accurate weight was used. Operators and document control staff informed the inspectors that the listings were not controlled; however, operators generally used the listing with the latest date. The inspectors noted thai operations did not maintain a log of which document was the latest acceptable listing.

After continued discussions with the inspectors, operations management directed that past versions of the tare weight listings should be removed from the area and not be used.

' The regulations in 10 CFR 76.93 require, in part, that the Corporation shall establish, maintain, and execute a quality assurance program satisfying each of the applicable requirements of ASME NOA 1-1989.

Section 3.15 of the Safety Analysis Report (SAR), "O AND AQ STRUCTURES, SYSTEMS, AND COMPONENTS," defined the systems or components used in the plant that have a "Q" or "AQ" function, i.e., a significant safety function requiring the system or component to be covered 7

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I by the Quality Assurance Program (OAP). Section 3.15.1.3.13 of the SAR identified UF, cylinders, except 2S and 1-kilogram cylinders, as having a "O" i function for " safe containment of UF, during transport, sampling, feeding,-

filling, and storage and to prevent a release of liquid UF ."

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Section 2.6.1 of the QAP stated that: "A document control system is established for O items and related activities and services...This system ensures that documents defining the performance of quality related activities are controlled so only current and correct information is available at the location where the activity is performed prior to commencing work." The l failure to control the preparation, issue, and revision of the tare weight

!- listings used for filling "Q" cylinders in the withdrawal area is a Violation

[ (VIO 70 7001/97007-02).

i-j c. Conclusions

!. The inspectors identified that the cylinder tare weight listings, used by i Building C 310 operators to determine the maximum acceptable UF fill

) weight for cylinders, were not controlled as a quality document. This is a

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violation.

[ 08. Miscellaneous Matters 1

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~O8.1 (Closed) Certificatee Event Reoort 32713: Building C-333A Autoclave 4 North steam pressure control system discovered inoperable during heeling operations (Mode 5).

After the initial report, the certificatee performed an engineering evaluation which i- determined that the steam controller was not part of the steam pressure isolation safety system A subsequent functional test of the safety system, in the as found

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condition, demonstrated that the safety system would function as designed, even j with the controller inoperable. As a result, the certificatee retracted the event

report for an inoperable safety system. The inspectors reviewed the system design j and the post-event testing information. The certificatee's conclusion that the controller was outside the safety system boundary, and that the controller inoperability did not affect the safety system operability, appeared (easonable.

The inspectors had no further questions and this item is closed (CER 70 7001/97007 03).

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ll. Maintenance and Surveillance 1

4 M1, Conduct of Maintenance and Surveillance M 1.1 Work Instructions

a. insoection Sco6e (88103)

The inspectors reviewed the development, approval, and use of work instructions for maintenance and modification activities.

l b. Observations and Findinas The inspectors reviewed Procedure CP2-GP GP1032, " Work Control Process," which defined the management process and methods used to l direct the implementation of maintenance activities. The inspectors also discussed the procedure with plant staff and reviewed a number of work control documents in use by plant staff.

. The inspectors determined that the work control process for the development and use of " work instructions," was inconsistent with the plant procedure policy and the quality assurance program (OAP). Specifically, the work control process allowed staff to develop work instructions, using

portions of other plant procedures or other documents, to perform activities

outside the scope of either the original procedure or the other documents, j The work control process did not ensure that the work instructions were

! limited to skill of the-craft activities or that the instructions received management review and approval, as required by the OAP, l The inspectors reviewed some active and recently completed maintenance 4 work packages (MWPs). The inspectors also discussed implementation of l

the work control process with craft, system engineering, and management personnel. During the review of a sampling of active MWPs, the inspectors

} identified only one example of work instructions which were inconsistent i with the procedure policy or OAP (See Section E1.2). However, craft

_ personnel indicated that work instructions could be used to perform

activities that

1) were beyond skill-of the-craft; and,2) required detailed step-by step instructions in order to preclude negative safety impacts.

Coring a review of recently completed MWPs, the inspectors identified work 4

instructions which were a complicated weaving of steps from two different j procedures. The MWP stated purpose was to troubleshoot, calibrate, and test two autoclave safety-related instrument channels. The MWP work instructions used steps and sections of two procedures to direct completion of the work. The inspectors performed a walk-through of the instructions and determined that the directions were correct. However, the inspectors i

also determined that the instructions were merely a re ordering of the steps from one of the two referenced procedures. The inspectors discussed this 9

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L observation with the cognizant system engineer and were informed that the

! MWP instructions were used to work around a weakness in the procedure.

2 Specifically, the procedure directed craf t to lif t and land leads after the

circuit operation had been previously proven acceptable. This necessitated a i reverification of landed leads. The system engineer indicated that previous 3

requests to correct the procedure weakness had been made; however, the i requests were denied based upon an expected future change to the procedure. Other system engineers also informed the inspectors of some l procedure changes which were rejected by craft management. The system j engineers believed that the changes, if implemented, would have improved ,

the ease or technical correctness of the procedures. 1 i  !

! The inspectors discussed the findings with engineering and work control management. During the discussions, the inspectors highlighted the e

relationship of the current findings to vlotations cited in NRC Inspection Report 70 7001/97004. The work control manager also indicated that an internal review, conducted af ter the inspectors identified the issue,

documented additional examples of the problem. Each of the examples was resolved at the time identified, consistent with the procedure policy and QAP i

requirements.

.i l Based upon the inspectors' and the certificatee's internal findings, changes j to the work contral policy were initiated. The changes explicitly integrated l the work control and procedure policles and the OAP. Management also planned to conduct training for the MWF planners and others to ensure i immediate, effective implementation of the changes. The inspectors will l track implementation of the corrective actions to the issues as an Inspector j Follow up Item (IFl 70 7001/97007 04),

c. Conclusions l The inspectors identified inconsistencies between the work control process,

. the quality assurance plan, and the plant procodure policy. As a result of the ,

inconsistencies, staff used work instructions, in one example, to work around a procedure problem. Once the issue was identified, management took prompt action to resolve the inconsistencies.

+ M1.2 Control of Maintenance Activitleg f a. insoection Scone (88103)

] The inspectors reviewed the control of some maintenance activities. The activities involved the high pressure fire water system, a criticality accident alarm :ystem, and nuclear criticality efety controls.

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b. Observations and Findinas During the inspection period, the inspectors reviewed the cotiduct of three maintenance activities. The observations for each activity were as follows:

(1) Hioh Pressure Fire Water System Valve Recalt On August 5, plant staff initiated a maintenance work package (MWP) to replace the high pressore fire water Valve HP 016 S 3 under Work Order Task R 96000735 O'.. The valve was a part of the high pressure fire water (HM supply rystem external to Building C 333. As a part of the maintenance effort, .'irtain fire protection systems for Buildings C 333 and C 315 were to bo 'solated. Fire protection staff used the fire protection impairmont permit process to identify both the HPF system isolation points and the necessary compensatory actions. In addition, operations staff uced the Limiting Conditions for Operation (LCO) tracking system to approve, track, and controlimplementation of the Technical Safety Requiremont (TSR) compensatory measures.

On September 6, the assistant plant shift superintendent (APSS) toured the work area and identified that not all of the required compensatory measury) had boon implemented. Specifically, the APSS discovered that an altomate sourco of fire water was not connected to Building C 315. The normal fire water supply had been isolated approximately 21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> earlier at the start of the maintenance work, in response to the finding, the APSS took immediate action to connect the required fire water supply line.

Subsequent to the discovery, the inspectors reviewed the work package and permits that were in effect on the morning of September S. The inspectors also discussed the failure to provide an alternate water source with soveral of the involved staff. Based upon the work package materials, the I

inspectors identified that numerous maintenance-related procedural vlotations had contributed to the failure to implement the required compensatory measures, The inspectors determined that the work packago did not:

1) have an operations manager in charge authorization to start work:

2) include a &mplete or proper listing of the involved permits or controls for performing work; or,3) include an adequate description of necessary prerequisites, including compensatory measures, for the work.

The inspectors considered the absence of a work statt authorization as significant. Specifically, the work involved coordination among several service groups, buildings, and operations facets (cascade and sito wido).

The presence of a work start signaturo would normally indicate a management review of the plant status and systems to ensure that all 11

prer3quisites had been met. It also would have indicated that plant rnanagement had identified and pre designated a single individual or organization to control the work. Review of the work package by an operations manager could have identified that some necessary planning and control activities had not been accomplished.

in addition to the work package problems, the inspectors found that logging and tracking measures, used by the PSS and fire services to document activities, incorrectly indicated that the compensatory measures were Implemented. Specifically, the PSS and fire services' logs included entries indicating that the temporary supply lines were installed and that the lines had been flow tested. Those actions were not completed for Building C 315. The failure to adequately control maintenance of the C 315 fire protection system is an example of a work control Violation (VIO 70 7001/97997 05a).

(2) P,onerable Criticality Accident, Alarm System I

On August 5, the main control room received a tsouble alarm associated with the Ruilding C 335 *C" crirleality accident alarm system (CAAS). In responso to the alnm, the PSS declared the system inoperable and initiated both componsatory and corrective measures. The immediate corrective measures were implemented under MWP R 9705437 01. The MWP directed maintenance personnel to replace the CAAS nitrogen gas bottle. The nitrogon gas bottle functioned as the safety related pressure source to sound the CAAS air horns. The plant air system functioned to provide the routine nonsafety related pressure source for the CAAS air horns.

Maintenance staff,implomonting the MWP, verified that the trouble alarm was caused by a sensed low nitrogen gas bottle pressure. However, during attempts to replace the nitrogen gas bottle, the staff determined that the nitrogen gas bottle outlet valve was closed. Following this discovery, the maintenanco staff opened the nitrogen gas bottle valve and system pressure increased to the normal 1600 pounds por square inch (psi). Management subsequently declared the system operable.

During followup discussions with operations staff, the inspectors noted that maintenance was performed on the system approximately one week prior to the event. The inspectors reviewed the involved work package and noted that the work scopo did not include or direct closure of the nitrogen gas bottle outlet valve. Significantly, the package also did not ensure that the valve was open at the conclusion of the maintenance work.

I During discussions with maintenance staff and management, the inspectors were informed that some staff routinely closed the nitrogen gLs bottle valve ,

as a part of the post maintenance testing (PMT). Valvo closure was performed to preclude a loss of nitrogen pressure. The staff explained that the PMT sometimes caused the local plant air system pressure to drop low 12

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enough to blood pressure from the nitrogen gas bottle. Closing the valve prior to the testing trapped nitrogen gas prenure, initially about 1600 psi, between the bottle outlet and the remainder of the CAAS system A failure to open the valve following the PMT would result in a system whlen appeared operable until system leakage allowed the trapped pressure to decay to a level below the alarm setpoint.

In discussions with the inspectors, management indicated an awareness of the valve closing practice. As a result of the follow up to the trouble alarm, a procedure change was initiated. The change would authorize and formally control valve closure for the PMT and would ensure that the valve was re opened after testing. Although managomont appeared to be knowledgeable of the practice, the inspectors noted that the work package did not includo steps to either close the valve or ensuro it was open.

Thorofore, a conclusive statement of system operability, following the earlier maintenance, or the length of time the system was isolated could not be made. The inspectors noted that da procedure chango, developed to allow closure of the nitrogen gas bottle valve, was initiated in April 1997, some three months prior to the event.

The failure to adequately control maintenance of the Building C 335 *C" CAAS cluster is an examplo of a work control Violation (VIO 70 7001/97997 05b).

(3) Neaative Air Machino Oneration During a routine tour of the decontamination facility, Building C 400, the inspectors observed that a negative air machine (NAM) was staged for uso as a part of ongoing shop maintenance activities. Negative air machines were usad to vacuum up loose uranium deposits and to minimize the spread of coitamination during maintenance activities. The typical NAM design included an air movement system and several filters for capturing air contaminants and particulates. The ongoing shop maintenance activities in the area included disassembly of cascade components (valves) contaminated with enriched uranium deposits.

The inspectors reviewed the NAM performance data sheet attached the unit.

The data sheet was used to track the accumulation, on system filters, of uranium collected by the NAM. At the time of the inspectors' review, the data sheet included three entries, on two separate days, which were outside of the allowed acceptance criteria for continued NAM operation. The inspectors also noted that the system, although not in operation at the timo, was neither marked nor otherwise tagged to preclude future use.

The inspectors discussed the findings with building and criticality safety staff. The building staff concurred that the performance data were outside of the allowed operating parameters and took action to tag the NAM out of service. Criticality safety staf f informed the inspectors that the 13

performance data limits were controls required by the nuclear critict.lity safety evaluation and approval developed for the maintenance work. The controls were used to implement the nuclear criticality safety double contingency principle for operations involving enriched uranium.

Following identification of the issue, the inspector reviewed the plant problem reporting system to determino if similar problems had previously occurred. The inspectors noted that several problem reports had boon filed documenting problems with control of the NAM units. Correctivo measures for the identified problems woro recommended to include hands on training.

Building management indicated to the inspectors that no hands on training had been performed since the date of the referenced problem report, some four months ago.

The failure to adequately control maintenance of the Building C 400 NAM is an examplo of a work control Violation (VIO 70 7001/97997 05c).

(4) Summarv of Findinos The regulations in 10 CFR 76.93 require, in part, that the certificatoo shall establish, maintain, and execute a quality assurance program satisfying each of the applicablo requirements of ASME NOA 1 1989. Section 3.15 of the Sefety Analysis Report, "O AND AO STRUCTURES, SYSTEMS, AND COMPONENTS," defined, in part, the systems or components used in the plant that have a "O" or "AO" function, l.o., a significant safety function requiring the system or component to be covered by the OAP, Sections 3.15 and 5.2 of the Safety Analysis Report identified the high pr9ssure fire water system, the criticality accident alarm system, and nuclear criticality safety controls, as systems, components, or controls having a "O", "AO" or a significant safety function.

Section 2.5 of the OAP, "lNSTRUCTIONS, PROCEDURES, AND DRAWINGS," required, in part, that activities affecting quality are prescribed by and accomplished in accordance with documented procedures appropriato to the circumstancos. Activities affecting quality include rnaintenance work impacting the operability of the high pressure fire protection and criticality accident alarm systems or requiring the application of nuclear criticality safety controls for NAMs. The failure to perform maintenance work in accordance with documented procedures, appropriate to the circumstances, as identified in the examplos above is a Violation (VIO 70 7001/97007 05),

c. Conclusions For the three maintenance activities reviewed, the plant staff failed to control or perform the activities in accordance with procedures, appropriate to the circumstances. As a result, a fire protection system was inoperable 14

for an excessive period, the safety related nitrogen supply for an area criticality accident alarm system horn was isolated, and a negative air machine was operated contrary to associated nuclear criticality safety controls.

Ill. Enalneerina E1. Co,-Juct of Engineering E1.1 Autoclave Vacuum Testina

a. insoection Scone (88100)

I The inspectors evaluated the technical basis for a change to testing criterla included in a temporary procedure used to demonstrate the acceptability of a modification to the plant autoclaves,

b. Observations and Findinos During routine tours of the feed facilities, the inspectors observed activities ,

associated with an autoclave instrument modification. The inspectors reviewed some of the test procedures included in the modification package.

As a result of the review, the inspectors determined that some of the procedure test criteria were less stringent than the associated engineering specification acceptance criteria. The inspectors noted that the observation was a repeat of a similar finding (97004 09) documented in Inspection Report 70 7001/97004(DNMS). The previous finding related to the use of unapproved installation and testing procedures for the same modification.

The inspectors discussed the revised test criteria with the engineering staff and requested a copy of the safety evaluation performed for the change.

Engineering staff indicated that the procedure was developed based upon the overall project safety evaluation and that a 10 CFR 76.68 plant change review was conducted to support conversion of the prior " test plans" to procedures. The inspectors reviewed the project safety evaluation and noted that the evaluation did not discuss or assess the safety impact of changes made to the test criteria. The inspectors also reviewed the 10 CFR 76.68 plant change review documentation compiled as a part of the new procedure approval process. The plant change review documentation did not reference the base engineering specifications or discuss changes to the test criteria incorporated into the procedures, in response to the inspectors' findings, management placed a hold on use of the test procedures and performed a safety evaluation of the test criteria change. The evaluation identified an engineering basis for the vacuum test 15

and assessed the impact of changing the test criteria. The evaluation documented that the changes did not decrease the safety margin and were acceptable. Subsequently, the evaluation and procedures were approved by the Plant Operations Review Committee.

The regulations in 10 CFR 76.68 required, in part, that changes to the plant, as described in the SAR, could be rnade only if a written safety evaluation demonstrated that the changes would not result in undue risk to public health and safety. The Safety Analysis Report (SAR), Section 3.2.4, " Piping and Valves," stated that all autoclave piping, out to the outside contalnment valve, was installed according to national standards and engineering piping specifications. Engineering Specification 15137HP, "UF, Gas and Liquid Piping Systems," required the performance of a vacuum test at 0.5 pounds force per square inch absolute (psla), held for two hours with no noticeable rise in pressure. The failure to evaluate the safety impact of decreasing the requirements for vacuum testing of autoclave piping, as specified in the engineering specification, is a Violation (VIO 70 7001/97007 06).

c. Conclusions The inspectors identified that engineering staff made changes to the autoclave instrument upgrade post modification testing requirements, as defined by an engineering specification, without performing a safety evaluation of the changes. This is a Violation.

E1.2 Autoclave Modification Installatjon Instr 9ctions

a. insoection Scoos (88105)

The inspectors observed the installation of instrument upgrade modifications to autoclaves in Building C 337A.

b. Observations and Findinog During the observation of autoclave instrument upgrade project work, the inspectors noted that staff were using engineering developed installation instructions to perform the work. Specifically, the maintenance work package directed staff to install the modification in accordance with the fif th revision of engineering work instructions for engineering service order (ESO) 290830. The inspectors determined that the instructions had not been developed, reviewed, approved, or maintained in accordance with the site procedure program as described in Procedure CP2 PS PS1031, " Processing New Procedures and Deletions."

The inspectors had previously identified, in Inspection Report 70-7001/97004(DNMS), that maintenance staff were using installation instructions, in lieu of approved procedures, to perforra this modification. At the time of the original observation, the third revision of 16

( the installation inrtructions were in use, in response to the finding, management stopped the work and took steps to bring the conduct of the work into conformance with current regulatory requirements. The inspectors reviewed the corrective measures taken and noted that the corrective actions were directed primarily at the uncontrolled revision of the installation instructions. The corrective measures did not address the use of installation instructions vice approved procedures.

The inspectors discussed the findings with engineering management and were informed that the engineering developed inst! lation instructions .

were not intended for direct use by the maintenance staff. Instead, I engineering management expected that the maintenance planners would develop job specific procedures from the engineering instructions. The inspectors noted that this approach was inconsistent with information previously received from design and systern engineers. Specifically, some engineers indicated that it was acceptable to use work instructions to direct work, even work at a level beyond the skill of-the craft or involving complex safety related activities.

The inspectors also observed a management meeting at which the use of engineering developed instructions was discussed. The managers concluded that the practice was most likely inconsistent with the site procedures program and the Technical Safety Requirements. During the meeting, the managers discussed long term corrective measures to resolve the issue; however, the group concluded that no immediate corrective actions were necessary. The decision not to implement any immediate corrective actions appeared to be based upon a belief that most modification work was performed on systems that had been removed from service.

Following further internal discussions of the issue, management decided to stop all engineering modification work using installation instructions.

Management deemed this action the most appropriate to ensure that all work on safety related systems was conducted in accordance with the site procedures program and the Technical Safety Requirements. Following the work stoppage, formal procedures were developed, reviewed, and approved for each of the modifications, as appropriate. No significant procedural inadequacies were identified during the conversion of engineering instructions into procedures.

Technical Safety Requirement 3.9 requires, in part, that written procedures shall be developed, approved, and implemented for activities described in the Safety Analysis Report, Section 6.11, Appendix A. The Safety Analysis Report, Section 6,11, Appendix A, described changes to equipment as an activity requiring written procedures. Procedure CP2 PS PS1031,

" Processing New Procedures and Deletions," defined the methods and 17

l.

reviews required for the development of new procedures. The failure to develop and approve written procedures for the installation of modifications to the autoclaves, in accordance with Procedure CP2 PS PS1031, is a Violation (VIO 70 7001/97007 07).

c. Conclusio_ns The inspectors identified that engineering developed installation instructions were used to install changes to equipment in conflict with the Technical Safety Requirements and the site procedure control program. This is a violation.

E1.3 EDalneerino Soecifications

a. insoection Scone (88105)

(

The inspectors reviewed the identification and use of codes and s'iandards for operation and modification of the gaseous diffusion plant,

b. Observations and Findinas  !

During review of the autoclave instrument upgrade project, the inspectors discussed with engineering management the Safety Analysis Report (SAR) description of applicable codes and standards. In particular, the inspectors discussed SAR Set, tion 3.2.4, which stated, "All autoclave piping (out to the outside contair ment valve) is installed according to national standards and engineering pipmg specifications with a pressure rating of 200 psig minimum." Section E1.1, of this report, discusses specific applicction of the autoclave engineering specification.

As a part of the dialogue, engineering management indicated that a listing of which engineering specifications applied to each system did t'ot exist.

Instead, management directed, as described in an engineering standing order, design engineers to apply Department of Energy (DOE) Order 6430.1 A, " General Design Criteria," and engineering specifications, as contained in a site manual, to modification activities. The standing order also described a process by which exceptions to the standards and specifications should be documented. While the process appeared to define a reasonable manner by which to document the application of some standards to plant changes, the inspectors could not determine if the process maintained the current design basis, in addition, discussions with some engineers indicated that the site manual did not include all of the engineering specifications previously in effect under the DOE regulatory oversight.

As a followup to the discussions with engineering management, the inspectors reviewed the actions taken to address Compliance Plan issue 45,

" Codes and Standards." Comp!iance Plan issue 45, Requirements Section, 18

l referenced a Nuclear Regulatory Commission request that the United States Enrichment Corporation (USEC):" ... identify the applicable standards and I incorporate them into an existing or new SAR section for the following TSR i questions ..." The United States Enrichment Corporation's response to Compliance issue 45 was provided to the NRC January 31,1997. The inspectors noted that the response did not explicitly include the SAR Section 3.2.4 referenced engineering specifications, in addition, the

, inspectors noted that the response may not have fully addressed the Requirements Section referenced NRC questions, in March 1997, USEC committed to perform a second review of the codes

.! and standards issue. This commitment was made based upon NRC questions developed during the review of a Technical Safety Requirement 1 amendment request. The inspectors discussed the status of this second review with plant and corporate regulatory personnel. As of the end of j August 1997, no reviews had been performed and an action plan for the '

effort had not been approved. In addition, USEC had not defined or i communicated to the NRC a completion date for the review.

As of the end of the inspection period, the inspectors had not performed a complete review of the Compliance Plan issue 45 response. In addition, the i inspectors had not determined if omission of the previously applicable engineering specifications was appropriate or significant. The inspectors will track completion of these actions as an Unresolved item 4

(URl 70 7001/97007 08).

c. Conclusions The inspectors identified potential concerns with the response provided to Compliance issue 45 and with current engineering practices for the application of engineering specifications. Resolution of the issue will be

, tracked as an Unresolved item.

IV. Plant Suonorf S1 Conduct of Security and Safeauards Activities S 1.1 Control of Classified Materials

a. Insoection Scoce (88100 and 92702L The inspectors reviewed the circumstances surrounding several reports made to the NRC on the loss of control and the possible compromise of classified matter.

e d

19

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b. Observations and Findinas During the inspection period, the plant shift superintendent (PSS) made several 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> security event reports to the NRC pursuant to 10 CFR 95.57(b) for possible compromise of classified information. The reported events included:

• On August 12, plant engineering staff discovered an uncontrolled drawing which contained matter classified as Confidential Restricted Data. The material was found in a main administration building office within the controlled access area (CAA), that is, within the fenced area of the plant. However, the drawing was not maintained in a locked classified safe, as required, when unattended by an individual with a *0" or "L" clearance.

• On August 13. plant staff discovered two additional drawings containing CRD information. The two drawings were located in a trailer outside the CAA and had not been controlled as classified matter. One drawing was marked " Official Use Only" and one was marked " DECLASSIFIED." The " Official Use Only" marking was used during the period 1949 to 1952 to identify classified matter. The drawings also included other classification markings, apparently as a result of past declassification reviews, making the current classification status somewhat confusing. Although no known compromise of the classified matter occurred, a number of uncleared individuals routinely occupied desks in the trailer over the period (approximately 8 to 18 months) that the drawings were believed to have been in the trailer by plant engineering staff.

• On August 14, training staff discovered a videotape containing CRD in another trailer outside the CAA. The videotape was not properly marked or controlled as CRD and had apparently been in the trailer for years. The trailer was used to provide training to the general plant population. Therefore, the videotape was accessible to uncleared personnel for self study. However, no actual compromise of classified matter was confirmed.

• On September 3, security staff discovered 53 documents with old classification markings during a plant wide review of potentially classified documents. The documents were maintained in an unclassified repository in a cascade building inside the CAA.

Subsequent review by an authorized derivative classifier (ADC), a person trained and authorized to make classification determinations, concluded that the documents were no longer classified.

• On September 7, security staff discovered a document marked as CRD in an unclassified file cabinet in Building C-331. An ADC review identified that the document content was no longer classified; 20

however, the ADC could not declassify the document without the approval of the original classifying authority. As a result, the document was secured untilit could be properly dispositioned.

Again, no actual compromise of classified matter was confirmed for these events.

• On September 11, an improperly controlled classilbd drawing was identified in a cascade operations building as a result of the plant wide review of documents. After the discovery and while reviewing a contractor's request for ADC review of similar blueprints containing classified matter, security staff became concerned that such drawings may already have been improperly released. In following up the issue, security staff discovered three drawings containing CRD information in the control of an uncleared individual, i The individual was working for the contractor in Kevil, Kentucky, i.e.,

outside the CAA. This event represented an actual compromise of l ciessified matter. The drawings had been in the possession of the hd.viduel dince January 28,1997. The documents were recovered l from the individual and properly secured. Four similar drawings were discovered within the CAA in areas where the drawings were potentially accessible to uncleared personnel.

Following the identification of a similar violation, as documer ted in inspection Report 70 7001/97002, security management implemented a campaign to increase staff awareness of the problem of classified matter being uncontroiled. However, the written response to the earlier Notice of Violation (NOV), dated June 30, 1997, did not address the generic aspects of classified materials potentially being located throughout the plant without proper control.

As a result, most of the above items were not identified due to the implementation of a systematic response to the problem.-- By letter dated August 8, the NRC requested the certificates to submit a revised written response to the NOV. The NRC specifically requested the certificatee to identify when the generic problem would be resolved and compliance achieved.

On August 26, plant staff began a systematic effort to " purge" the plant of classified matter which was not being properly controlled.

The effort involved a review or screening of historical documents, drawings, formerly used procedures, computer disks, operator aids, etc. which had a potential, based on being declassified, marked with old classification markings, or the content of the material, to contain classified information.

The purge effort was being performed on a building-by building basis, with areas outside the fence receiving a priority review. Documents, which building management identified as being required for routine operations, would receive an ADC review. Other documents or 21

4 materials would be segregated and placed in a classified matter vault.

A subsequent ADC review would be made or the documents would be destroyed in accordance with the security plan. The team conducting the purge effort was required to log all discrepancies identified.

1 The regulations of 10 CFR 95.35(o) require, in part, that no person subject to the regulations in this part may receive or may rarmit any individual to have access to matter revealing Confidential Restricted Data unless the individual has a "O" or "L' access authorization. The failure to properly control, i.e., attend or secure in a classified safe, the CRD matter identified above permitted individuals without a "O" or *L" access authorization to have access to the matter is an apparent Violation (eel 70 7001/97007 09).

The apparent violation appeared to be similar to Violation 97002 31 issued with NRC Inspection Report 707001/97002, dated May 30,1997.

c. Conclusions Plant staff identified several examples where classified matter and access thereto was not properly controlled, an apparent violation. Some of these examples were identified in areas outside the plant controlled access area.

Plant management began a building by building classified matter " purge" effort on August 26 to address the continued discoveries of classified matter which had not boon properly controlled.

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

The certificatee made the following security related one-hour reports pursuant to 10 CFR 95.57(b) during the inspection period. The inspectors reviewed any immediate security concerns at the time of the initial verbal notification (see discussion in Section S1.1).

Number Status Data 31110 CER 70 7001/9700710 Closed 8/06/97 Possible Compromise of CRD Matter CER 70 7001/9700711 Closed 8/12/97 Possible Compromise of CRD Matter CER 70 7001/9700712 Closed 8/13/97 Possible Compromise of CRD Matter 22 i

- - - . - r .- --- --

\ .

CER 70 7001/9700713 Closed 8/13/97 Possible Compromise of CRD Matter CER 70 7001/9700714 Closed 8/14/97 Possible Compromise c! CRD Matter CER 70 7001/9700715 Closed 8/27/97 Possible Compromise of CRD Mattor CER 70 7001/9700716 Closeo 9/03/97 Possible Compromise of CRD Matter CER 70 7001/9700717 Closed 9/08/97 Possible Compromise of CRD Matter CER 70 7001/9700718 Closed 9/11/97 Possible Compromise of CRD Matter CER 70 7001/9700719 Closed 9/11/97 Possible Compromise of CRD Matter These security reports were aspects of the samo issue which is discussed in Section S1.1 and are thus being closed. The inspectors will review the certificatee's corrective actions as a part of the response to the apparent violation identified in that section.

R1 Environmental Protection R1.1 Waterborne Effluent Monitorina

a. Insoection Scone (88045)

The inspectors reviewed the waterbome effluent monitoring program through: 1) interviews with environmental monitoring and compliance staff;

2) a selective review of procedures for environmental monitoring; and,3) the observation of weekly waterborne effluent sampling conducted by environmental monitoring technicians,

b. Observations and Findinag The inspectors accompanied environmental mor.itoring technicians during weekly waterborno effluent sampling for several outfalls. Radiological waterborne sampling was observed at Outfalls K001 and K010, where weekly analysis of the effluent was required. The inspectors observed wookly calibrations and calibration checks of composite samplers and flow meters at other outfalls. The inspectors noted that sampling and calibration activities were in accordance with procedure CP4 EW-EM6203, " Sampling at KPDES Locations." Technicians were knowledgeable of the sources of the 23 l l

l j

1

\

4 various outfalls and noted proposed changes to the sampling procedure, j which would enhance the monitoring program. The inspectors verified that

the proposed procedural changes were being processed.

I 1 During a review of environmental monitoring notebooks used for waterborne i i effluent monitoring, the inspectors identified that calculations in notebooks l

used for the American Sigma refrigerated composite sampler and flow rneter 1 i were not reviewed and checked for accuracy. The sampler collected water  ;

1 samples over a specified frequency of time for radionuclide analysis and

! recorded the flow of effluent through an outfall. This flow rate was then

.i used in conjunction with radiological sample analyses to determine the quantity of material released from an outfall. Three other notebooks

! pertaining to waterborne effluent mont toring were reviewed, as required, by the group supervisor. Following the inspectors identification of the lasue, the environmental monitoring group supervisor indicated that post identification reviews of the calibration and calibration verification i calculations in both the American Sigma refrigerated composite sampler and the American Sigma flow meter notebooks were performed. No inaccuracles

. were identified as a result of the reviews.

j Technical Safety Requirement 3.9 requires, in part, that written

! procedures shall be prepared and implemented to cover the environmental I protection program specified in Technical Safety Requirement 3.16.

Procedure CP4 EW EV1110, " Environmental Monitoring Notebooks,"

I Section 6.2.5 required, in part, that if calculations were recorded in a l notebook, at least ten percent of the calculations were to be reviewed by

the supervisor or another technician, and the signature of the reviewer and review date were aiso to be logged in the notebook. The failure to review i notebook calibration calculations for the American Sigma refrigerated composite sampler and flowmeter from March 3 to August 12,1997,as

, required by Procedure CP4 EW EV1110, Rev. O,is a Violation i

(VIO 70 7001/97007 20).

The inspectors also observed the implementation of the chain of custody for environmental samples. The activity was performed in accordance with Procedure CP4 EW EV1130, " Environmental Chain of Custody." Also, quality control (OC) activities for outfalls K001 and K013, as specified in procedure CP4 EW EM6203, were verified and a review of OC data indicated no discrepancies in the data. Environmental monitoring records indicated that water outfalls were sampled in accordance with the frequencies specified in Safety Analysis Report Table 5.17.

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

I

c. Conclusloria Environmental monitoring technicians were knowledgeable and adhered to environmental monitoring procedures. The waterborne effluent monitoring program was implemented in accordance with the Safety Analysis Report, Section 5.1. The inspectors identified that calculational reviews of two environmental monitoring notebooks were not conducted as required. This is a violation.

R1.2 Airborne Effluent Monitorina

a. inanection Scone (88045)

The inspectors reviewed the airborne effluent monitoring program. Dose assessment calculations, performed by the environmental monitoring group in response to an unplanned uranium release from the Building C 310 purge vent stack, were also reviewed (Section 01.1).

b. Observations and FindlDER The Building C 310 purge vent stack was the lone onsite emission source which was continuously monitored for radioactive effluent. Emissions from other onsite sources were either calculated annually, using emission estimation methods established in 40 CFR 61, Subpart H (NESHAPS), or by periodic sampling of emission sources every five years. A review of air emission data for calendar year 1996, indicated that the estimated dose for the member of the public most likely to receive the hignest dose from the certificatee's operation, was below 0.1 millirem.

The inspectors accompanied an environmental monitoring technician during daily change out of the Building C 310 purge vent sampler. Procedure CP4 EW EV6250, "C 310 Vent Stack Sampling," which addressed sampler change outs, was thorough and extensive in describing actions needed in order to complete the task. The inspectors observed that the environmental monitoring technician's actions were in accordance with the written procedure, and good health physics practices were used in the collection of the purge vont samples. Equipment used in the purge vont sampler system was within the required calibration period. The inspectors observed no discrepancies in the chain of custody of the purge vent samples.

On July 22, a Building C 310 purge vent sample exceeded 10 times the baseline effluent quantity (BEO) limit, and an investigation was initiated by the certificates to determine the cause and effects of the release. The Building C 310 purge vent sample analysis determined that 542.5 grams of uranium were released from the stack in a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period. At the time of the inspection, facility staff were stillinvestigating the root cause of the release. However, environmental compliance personnel had completed an assessment of the effect of the BEO excoedance on the member of the 25

i public most likely to receive the highest dose from the certificatee's operation. Data from the past six months of operation as well as actual event data, were used to calculate a conservative estimato of the annual dose for the nearest member of the public for the 1997 calendar year. The assessment determined that there was no exceedance of the NRC annual dose limit and the estimated dose for the nearest member of the public would remain below 0.1 millirem for the 1997 calendar year. The inspectors reviewed the staff's calculations and noted that the calculations were conservative and accurate. The inspectors determined that the environmental compliance group's investigation was in accordance with Procedure CP4 EW EV6162,

• Data Investigation and Reporting."

c. Conclusions  :

The inspectors determined, based upon observations and personnel interviews, that'the program for continuous sampling of the Building C 310 purge vent stack was effective. A review of dose assessment data for a uranium release which occurred in July 1997 indicated no exceedance of dose limits for the nearest member of the public.

R1.3 Amblent Alr Emission Monitorina

a. insoection Scone (88045)

The inspectors reviewed the certificatee's amblent air monitoring program through accompaniments with environmental monitoring technicians, review of procedures and interviews with environmental monitoring and compilance personnel,

b. Observations and Findincs The inspectors accompanied an environmental monitoring technician on the weekly change out of sample filters at the six high volume ambient air sampling stations. The inspectors noted that sampling was performed in accordance with Procedure CP4 EW EV6201 and that the procedure content was detailed and reflected current practices. The inspectors noted that technician use of latex gloves, individual filter holders, and filter handling tools were an effective means of preventing cross contamination of the filters. Flow rate meters, at all the ambient elr sampling stations, were in calibration, and no discrepancies were noted in the chain of custody of the filters.

Sample quality control for the ambient air sampling stations consisted of a weekly " blind" duplicate at one of the ambient air sampling stations. A review of data for the duplicate samples did not indicate any discrepancies in 26

the ambient air sampling methods. A review of the environmental monitoring notebooks for the ambient air samplers verified that required entries were made, anomalous conditions were entered, and required cahulation reviews were performed.

J

c. Conclusions The inspectors concluded that tho high volume ambient air sampling program was offectively implemented by the environmental monitoring organization.

R 1.4 Environmental Proaram Changes

a. insoection Scooe (88045)

The inspectors reviewed a change to the environmental monitoring program described in Safety Analysis Report, Section 5.1. The change involved the removal of the low volume ambient air samplers from the ambient air monitoring program,

b. Observations and Findinas The inspectors reviewed two documents developed to support a revision to the Safety Analysis Report, Soction 5.1.2.1. The change involved discontinuation of the use of low volume ambient air samplers. The documents included a request for application change (RAC) No. 90 C 139, dated September 9,1996, and a plant change request (PCR)

No. PCR C 96150, dated January 1,1997. The RAC, which characterized the change as an editorial revision to the SAR, was approved on July 2, 1997. The SAR revision, deleted a reference which required the low volume air samplers to be part of the certificatoo's ambient alt monitoring program.

Based on a review of the documentation listed above and interviews with environmental complianco personnel, the inspectors determined that the original application was modified to remove references to the low volume ambient air sampling system. The deletions were implemented based upon discussions with the NRC. Cortificateo responses to NRC questions concerning the ambiont alt sampling program were revised to delete references to the low volume ambient air sampling system (responses 5.1019,28,29 and 37). The responses also highlighted the certificatee's intent to shutdown the low volume ambient air sampling system (response 5.1055). The certificatee determined that the provision, included in the second application requiring the use of the low volume air samplers, was inadvertent. Therefore, the revision to Safety Analysis Report, Section 5.1.2.1 was editorial. The inspectors noted that categorization of the change appeared correct; however, the conclusion was not justified by the limited information included in the change package.

27

4 Finally, the inspectors rioted an inconsistency between the Safety Analysis Report discussion of low volume ambient air sampling system filters analysis and actual plant practices. Specifically, the plant stopped performing analysis of the filters in October 1996; however, the change to the Safety Analysis Report, removing the use of the low volume ambient air samplers, was not approved until July 2,1997. The premature cessation of the analysis was a deficiency in program implementation.

c. Conclusions The inspectors identified a lack of rigor in the documentation used to support an editorial change to Section 5.1 of the Safety Analysis Report, in addition, a program deficiency was identified in that the periodic analysis of the low volume air sampling filters was stopped prior to final approval of the Safety Analysis Report change that removed the requirement.

T1 Transoortation of Radioactive Materials T1.1 Shloment of Uranium Hexafluoride Samotes Usina 1S Cylinders

a. Insoection Scone (90712)

The inspectors reviewed an NRC generic concern with the use of URENCO Weber 1S cylinders for shipping UF, samples. Specifically, some cylinders did not meet the dimensional requirements of American National Standards Institute (ANSI) Standard N14.1, " Uranium Hexafluoride -

Packaging for Transport."

b. Observations and Findinas On July 18, plant staff were informed by NRC Region til that certain IS cylinders, manufactured for URENCO Weber, did not meet the minimum dimensional requirements of ANSI N14.1. Department of Transportation regulations and NRC Certificates of Compliance require compliance with ANSI N14.1 for containers used to transport UF . Type 1S cylinders were typically used to transport UF, samples between fuel cycle f acilities in the United States and abroad, in response to the notification, the PSS initiated a search of the site to ascertain whether or not any 1S cylinders were -

available for use.

During the search, plant staff identified seven 1S cylinders in the Building C 710 laboratory. Discussions with laboratory staff indicated that Paducah had not routinely used 1S cylinders for shipments, and had never used 1S cylinders for shipments of UF , instead,1S cylinders were used to ship other chemicals. Based upon tags found on the 1S cylinders, laboratory staff estimated that the cylinders were last used in the 1980s. Based upon the generic communication from the NRC, the PSS tagged the cylinders to preclude future use for UF, shipments.

28

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c. Conclusions l

Plant staff responded quickly to a generic concern with 1S cylinders outside ANSI N14.1 dimensional requirements. Seven 1S cylinders were located onsite: however, indications were that the 1S cylinders had not boon used j by Paducah in recent years. In addition, none of the 1S cylinders had boon '

used for UF, shipments.

P8 Miscellaneous Plant Succort issues P8.1 (Closed) Cortificateo Event Rooort 32679: The cortificatee made a courtesy notification to the NRC of an oilleak in the Building C 537 No. 69 transformer because the event was reportable to the Stato of Kentucky. The notification was made in accordance with requirements outlined in the Safety Analysis Report.

(CER 70 7001/97007 21)

P8.2 (Closed) Certificatee Event Reoort 32769: The certificatee made a courtesy notification to the NRC of an inoperable warning beacon on the site meteorological tower because the event was reportable to the Federal Aviation Administration.

The notification was made in accordance with requirements outlined in the Safety Analysis Report. (CER 70 7001/97007 22)

P8.3 (Closed) Certificatee Event Rooort 32771: The certificatee made a courtesy notification to the NRC of an oil sheen at plant outfall 001 because the event was reportable to the State of Kentucky. The notification was mado in accordance with requirements outlined in the 9afety Analysis Report. (CER 70 7001/97007 23)

V. Management Meetinga X. Exit Meetina Summary The inspectors presented the inspection results to members of the plant staff and management at the conclusion of the inspections on August 15, August 25, and September 12,1997. 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.

1 i

29

PARTIAL LIST OF PERSONS CONTACTED United States Enrichment Corooration J. H. Miller, Vice President Production

'J. A. Labarraque, Safety, Safeguards and Quality Manager Lqc.kheed Mattin Utility Services (LMUS)

'S. A. Polston, General Manager

'H. Pulley, Enrichment Plant Manager

'W. E. Sykes, Nuclear Regulatory Affairs Manager

'S. R. Penrod, Operations Manager United States Denartment of Enerav (DOE)

'G, A. Barrell, Site Safety Representative Nuclear Reaulatorv Commission (NRCJ

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

'J. M. Jacobson, Resident inspector

'R. G. Krsek, Fuel Cycle Inspector

' Denotes those present at the August 15 and 25, and September 12,1997 exit meetings.

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

INSPECTION PROCEDURES USED IP 88100 Plant Operations IP 88102 Surveillance Observations IP 88103 Maintenance Observations IP 88105 Management Oversight and Controls IP 88045 Environmental Monitoring Program IP 90712 Inoffice Review of Events IP 92702 Followup of Evonts 30

lTEMS OPENED CLOSED, AND DISCUSSEQ Ooened 70 7001/97007 01 IFl root cause for loss of purge cascade 70 7001/97007 02 VIO failure to control tare weight books 70 7001/97007 04 IFl use of work instructions 70 7001/97007 05a,b,&c VIO inadequate control of work activities 70 7001/97007 06 VIO changed test acceptance criteria without evaluation 70 7001/97007 07 VIO use of engineering instructions for modification 70 7001/97007 08 URI codes, standards, and engineering specifications 70 7001/97007 09 eel apparent violation concerning control of CRD 70 7001/97007 20 VIO failure to check environmental calculations Clonad 70 7001/97007 03 CER autoclave 3A steam controller failure 70 7001/97007 10 CER possible compromisa -f crd matter 70 7001/97007 11 CER possible compromise of crd matter 70 7001/97007 12 CER possible compromise of crd matter 70 7001/97007 13 CER possible compromise of crd matter 70 7001/97007 14 CER possible compromise of crd matter 70 7001/97007 15 CER possible comptornise of crd matter 70 7001/97007 16 CER possible compromise of crd matter 70 7001/97007 17 CER possible compromise of crd mattsir 70 7001/97007 18 CER possible compromise of crd matter 70 7001/97007 19 CER possible compromise of crd matter 70 7001/97007 21 CER courtesy notification for oil spill 70 7001/97007 22 CER courtesy notification for inoperable tower light 70-7001/97007 23 CER courtesy notification for outf all oil sheen Discussed Nono 31 i

LIST OF ACRONYMS USED ACR Area Control Room ANSI American National Standards Institute APSS Assistant Plant Shif t Superintendent BEQ Base Effluent Guantity CAAS Criticality Accident Alarm System CER Certificates Event Report CFR Code of Federal Regulations CP Compliance Plan CRD Classified Restricted Data DOE Department of Energy HF Hydrogen Fluoride HFFW High Pretsure Fire Water IFl Inspector Followup Item LCO Limiting Condition for Operation MW Megawatt MWP Maintenance Work Package NAM Negative Air Machine NCS Nuclear Criticality Safety NCSA Nuclear Criticality Safety Approval NCSE Nuclear Criticality Safety Evaluation NOV Notice of Violation NOA National Quality Association NRC Nuclear Regulatory Commission PCR Plant Change Request PMT Post Maintenance Ten PORC Plarit Operation: R:4w committee PSIA Pounds Per Square Inch Absolute PSIG Pounds Per Square Inch Gago PSS Plant Shif t Supervisor QAP Ouality Assurance Program RAC Request for Authorization Change SAR Safety Analysis Report TSR Technical Safety Requirement U 235 Uranium 235 UF6 Uranium Hexafluoride URI Unresolved item USEC United States Enrichment Corporation VIO Violation 32 i

C