ML20211Q811

Insp Rept 70-7001/97-01 on 970908-12.Violations Noted.Major Areas Inspected:Qa Program

ML20211Q811
Person / Time
Site:	07007001
Issue date:	10/17/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20211Q794	List: ML20211Q789 ML20211Q797 ML20211Q811
References
70-7001-97-09, 70-7001-97-9, NUDOCS 9710230010
Download: ML20211Q811 (9)

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U.S. NUCLEAR REGULATORY COMMISSION REGION lli Docket No: 70-7001 Report No: 70-7001/97009(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: September 8 th ough September 12,1997 Inspectors: H. Walker, Reactor Engineer, DRS, Region 111 R. Krsek, Fuel Facilities inspector, Region til Approved By: P. L. Hiland, Chief 7 Fuel Cycla Branch 9710230010 971017 PDR ADOCK 07007001 C PDR a

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SUMMARY

United States Enrichment Corporation Ps ducah Gaseous Diffusion Plant NRC Inspe . tion Report No. 70-7001/97099(DNMS)

Quality Assurance Proaram e An unresolved item was identified regarding the failure to implement supplementary requirements of ASME NOA-1-1989. The regulations in 10 CFR 76.93 require the certificatee to establish, inaintain, and implement a Quality Assurance Program satisfying NQA-1-1989. The Quality Assurance Program did not identify exceptions or acceptable altematives to selected 1upplementary requirements of ASME C NOA-1-1989 which did not appear to be included in the implementing procedures.

(Gection Q1.1)

• The inspectors identified the failure to properly protect quality assuranco mcords in the quality assurance records storage vault as a violation. In addition, records management procedures did not include the requirement as described in Appendix C of the Quality

-._ Assurance Program. (Section Q1.2)

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4 DETAILS Q1. Quality Assurance Program' Q1.1 Overall Prooram implementation (35701)

a. Inspection Scope (35701)

- The inspectors reviewed the innplementation of the Quality Assurance Program (QAP), as required by 10 CFR 76.93. _ The review included: 1) interviews with personnel in the Safety, Safeguards, and Quality (SS&Q) organization; 2) selected implementing procedures for the QAP; 3) discussions with various plant personnel regarding the implementation of the QAP, and 4) selected problem reports relating to implementation cf the quality assurance function at ths plant.

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b. Observations and Findinos The Paducah Gaseous Diffusion Plant (PGDP) QAP is defined in Volume 3 of the PGOP Safety Analysis Report. The QAP was written to ensure that PGDP complies with 10 C.,'R 76.93,"Quali'y Assurance." Section 2.2.1 of the QAP commits PGDP to the Basic and Supplementary Requirements of ASME NQA-1-1989, unless specifically identified within the QAP.

During a review of the problem reporte generated by the SS&Q organization, the inspectors noted that Problem Report PR-QA-97-3501 identified that plant staff were concemed that several of the supplementary requirements of ASME NQA-1-1989 had not been implemented in procedures. During subsequent discussion 1 with SS&Q management, the inspectors were told that managerr ent wi.s aware of the issues in the problem report. The SS&Q manager indicated that some of the supplementary requirements of ASME NOA-1-1989 were not incorporated into implementing procedures used for quality assurance at the plant. The manager also stated that this overall issue had been addressed in three intemal United States Eniichment Corporation (USEC) memoranda which were provided to the inspectors.

The inspectors reviewed the following intemal memoranda:

1) Memorandum dated August 19,1996, entitled, "QAP identification of commitments and flow down of requirements;"

2) Memorandum dated July 11,1997, entitled, "Flowdown of NQA-1 Supplements -

Prob'am Report PR-QA-PI-3501;" and,

3) Memomndum dated nau?i 4,1997, entitled, "Flowdown of the QAP."

The latter memoraridum addressed the content of the two prior memoranda and concluded that USEC was in compliance with 10 CFR 76.93. The conclusion appeared to rest on the NRC approval of the QAP in the Certificatee Evaluation Report. USEC 1 Topical headings such as 01, MS, etc., are used in accordance with the NRC standardized inspection report outline contained in NRC Manual Chapter 0610. Individual reports are not expected to address all outline topics, and the topical headings are therefore not always sequential.

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believed that the approvalimplied an agreement with Section 1 of the OAP which indicated that the QAP for the Paducah and Portsmouth Gaseous Diffusion Plants satisfies the Basic and Supplementary require wents of ASME NQA-1-1989 as described within the document itself. This memorandum also stated that confusion existed with the originalintent of a sentence in Section 2.2.1 of the QAP which stated: "Unless spet,ifically identified within this document, USEC commits to the Basic and Supplementary requirements of ASM;i NQA-1-1989." The memorandum concluded that a Request for the Authorization of a Change (RAC), i.e., a change to the QAP, would be initiated to clarity the originalintent of this statement. The memoranda appeared to indicate that if a supplementary requirement of ASME NQA 1-1989, was not specified in the

" Requirements" section of the QAP, the supplementary requirement was not required to be implemented in order for the certificatee to be in compliance with 10 CFR 76.93.

During a review of the QAP, the inspectors noted that a number of ASME NQA-1-1989 supplementary requirements were not included in the " Requirements" section. The inspectors also noted that in at least two USEC responses to NRC questions conceming the QAP (QAQ30 and QAQ36 were provided as a par

• of the certification process for the Gaseous Diffusion Plants) USEC responded to NRC questions with the following response: "10 CFR 76.93 requires that USEC establish, maintain and execute a Cuality Assurance Program satisfying each of the applicable requirements of ASME NQA-1-1989, " Quality Assurance Program Requirements for Nuclear Facilities," or satisfying applicable altematives to the applicable requiremento. The QAP commits to the requirements of ASME NOA-1-1989, and its supplements."

Based on the documentatL n provided by responsible plant staff, the problem reporu identified above, and discussions with SS&Q management, the inspectors identified that some of the supplementary requirements of ASME NQA-1-1989, for which an exception or attemative was not approved, may not be included in the procedures implementing the QAP. However, a final determination could not be made during the inspection because of the inconsittencies in the QAP and the volume of procedures implementing the QAP.

The apparent failure to implement those supplementary requirements of ASME NOA-1-1989 for which the QAP did not specifically identify exceptions or acceptcble attematives is an Unresolved item (URI) requiring further review by the NRC (URI 70-7001/97009 01).

The inspectors noted that the failure to include NQA-1 supplementary requirements in procedures had been identified by plant personnel and that the issue had been documented in a number of problem reports, including PR-QA-97-3501. The inspectors noted that although the intemal memorandum dated July 11,1997, suggested that PR-QA-3501 be canceled entire'v, PR-QA-3501 was closed to Problem Report PR-QA-3499.

This problem report was stin open at the time of the inspection pending final resolution.

Thus, Problem Report PR-QA-97-3501, entered into the problem reporting system on July 2,1997, was still classified as open as of September 12,1997, indicating plant management had not aggressively pursued a timely response to a quality assurance deficiency.

c. Conclusions The insMctors identified an inconsistency between the supplementary requirements of ASME NOA 1-1989, the QAP, and applicable implementing procedures. The apparent 4

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failure to implement those supplementary requirements for which the QAP did not specifically identify exceptions or acceptable allematives is an Unresolved item. Plant management did not aggressively pursue a resolution to this problem once it was identified by plant quality assurance staff, Q1.2 Records Manaaement Proaram

a. Inspection Scope (35701)

The inspectors reviewed ins quality assurance records program through facility tours, procedure reviews, and interviews with records management staff In particular, the inspectors reviewed the following records management procedures:

a Procedure UE2-TO-RM1030, " Records Management Program;"

Procedure UE4-TO-RM1201, " Records Management Process;" and, Procedure UE4-TO-RM4203," Storage and Inspection of Stored Records."

b. Observations and Findinos The inspectors noted that specific exceptions were taken to Supplement 17S-1 of ASME NQA-1 in the QAP. Specifically, Appendix C of the QAP provided a technicaljustification for allowing a water-based fire protection system within the records storage vault, without floor drainage control, provided that records were stored with six inches of clearance from the floor. Appendix C also justified an exception for the penetration of roof drain lines through the vault.

During a tour of the records storage vault, the inspectors identified that some quality records in the vault were not stored six inches above the floor, in particular,20 of 25 file cabinets had quality records (drawings) stored in a bottom drawer which did not have six inches of clearance froc the floor. In addition, boxes of records were temporarily stored -

in the vault on the floor pending a determination of whether er not quality records were present. Records management staff were not aware of the six-inch clearance requirement in the vault, and records management procedures were not available in the work area for worker use. Furthermore, none of the records management procedures included the six-inch clearance requirement for records stored in the vau't.

The records management supervisor notified the inspectors that corrective actions were in place at the time of the exit meeting. The corrective actions included moving records stored in file cabinets with bottom drawers below six inches, properly storing temporary records on vault shelving, placing procedures within the work area for worker use, and filing a problem report to identify and correct proceduralinadequacies.

The regulations in 10 CFR 76.93 required the certificatee to establish, maintain, and e

execute a Quality Assurance Pror, ram. Section 2.2.3 nf the QAP, " Program implementation," required, in part, that the Quality Assurance Program be implemented through procedures which were consistent with the requirements of the QAP. The inspectors identified that from March 3 through September 10,1997, quality records in the vault were not being stored in accordance with Appendix C of the QAP and that the implementing procedures did not include a requirement for six inches of clearance from the floor. The failure to properly implement the requirement of the QAP in the records management program is a Violation of 10 CFR 76.93 (VIO 70-7001/97009-02).

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c. Conclusions The inspectors identified that recorda were not being stored within the records storage v,1uit as required by the technicaljustification in Appendix C of the QAP. Records management staff were not aware of the requirement and records management procedures did not incorporate the requirement.

V. Manaaement Meeting X. Exit Meetino Summary The inspectors presented the inspection results to members of the plant staff and management at the conclusion of the inspection en September 12,1997. The plant management acknowledged the findings presented.

The inspectors asked the plant staff whether any materials examined durir.g the inspection should be considered proprietary. No proprietary information was identified.

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PARTIAL LIST OF PERSONS CONTACTED United States Enrichment Cearporation

• J. Labarraque, Safety, Safeguards and Qualit/ Manager

• R.1.awton, Corporate Safety, Safeguards and Quality Manager

• S. Toelle, Corporate Nuclear Regulatory Affairs Manager Lockheed Martin Utility Services (LMUS)

• S. Chapelle

• D. Hallenbeck

• C. Nicks

• D. Holt

• P. Jenny

• S. Penrod

• S. Polston, General Manager

• H. Pulley, Enrichment Plant Manager

• W. Sykes, Nuclear Regulatory Affairs Manager

• J. Vorees, PORTS

• S. Wagner

• S. Williams Nuclear Reaulatory Commission (NRC)

• K. O'Unan, Senior Resident inspector

• H. Walker, Lead Engineer

• R. Krsek, Fuel Facilities inspector

• Denotes the ,e present or those who participated by telephone in the exit meeting on September .2,1997.

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

INSPECTION PROCEDURES USED IP 35701 Quality Assurance Program Review 7

ITEMS OPENED, CLOSED, AND DISCUSSED Opened 70-7001/97009-01 URI Potential failure to include ASME NQA-1 supplemental requirements in the implementation of the Quality Assurance Program.

70-7001/97009-02 VIO Failure to implement and include in procedures requirements specified in the QAP.

Closed None Discussed None 8

LIST OF ACRONYMS USED ANSI- American National Standards Institute ASME American Society of Mechanical Engineers CFR Code of Federal Regulations DNMS Division of Nuclear Material Safety DOE Department of Energy -

NOV Notice of Violation NRC- Nuclear Regulatory Commission PDR Public Document Room

.PGDP Paducah Gaseous Diffusion Plart QAP Quality Assurance Program SAR Safety Analysis Report SS&Q Safety, Safeguards, and Quality URI Unreso!ved item USEC United States Enrichment Corporation VIO Violation 3

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