ML20237E603

Insp Rept 70-7001/98-14 on 980803-07.No Violations Noted. Major Areas Inspected:Plant Operations,Maint & Engineering

ML20237E603
Person / Time
Site:	07007001
Issue date:	08/27/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20237E600	List: ML20237E598 ML20237E603
References
70-7001-98-14, NUDOCS 9809010065
Download: ML20237E603 (7)

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U.S. NUCLEAR REGULATORY COMMISSION REGION ll1 l

1 Docket No: 70-7001 Certificate No: GDP-1 Report No: 70-7001/98014(DNMS) l l

Facility Operator: United States Enrichment Corporation i I

Facility Name: Paducah Gaseous Diffusion Plant Location: 5600 Hobbs Road i

P.O. Box 1410 I

Paducah, KY 42001 Dates: August 3 through 7,1998 l

Inspector: David J. Hartland, Portsmouth Senior Resident Inspector Approved By: Timothy D. Reidinger, Acting Chief Fuel Cycle Branch Division of Nuclear Materials Safety 9909010065 990927 PDR ADOCK 07007001 C PDR L _ _ _

EXECUTIVE

SUMMARY

United States Enrichment Corporation Paducah Gaseous Diffusion Plant NRC Inspection Report 70-7001/98014(DNMS)

Plant Operations

. The inspector determined that the plant staff properly implemented the Technical Safety Requirement-specified moderation controls for two cascade uranium deposits that were greater than sa'e mass.

. The inspector determined that cascade operators properly postponed the performance of a Technical Safety Requirement freezer / sublimer surveillance and maintained the equipment in an htperable status based upon an absence of proper test conditions.

However, the staff did not immediately document the off normal condition for further management review.

Maintenance

. The inspector determined that a post-maintenance test of the Building C-310 Criticality Accident Alarm System was well controlled with a proper level of first line management oversight. In addition other work packages reviewed were noted to include appropriate procedures and drawings for the beyond " skill-of-the-craft" work activities.

Enaineerina

. The inspector identified a minor violation.in that the plant staff connected a portable charger to a cascade battery bank without first performing required safety reviews and approvals.

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Report Details

1. Operations 01 Conduct of Operations 01.1 Observation of Onaoina Operations

a. Inspection Scope (88100)

The inspector conducted field reviews of ongoing operations to verify compliance with the Technical Safety Requirements (TSRs) and other requirements,

b. Observations and Findinos Greater-Than-Safe-Mass Uranium Deposits On August 3, the plant staff identified a greater-than-safe-mass uranium deposit in the Building C-335, Number 2 Purge and Evacuation (P&E) Cooler during the conduct of routine non-destructive analyses. Following identification of the deposit, the inspector confirmed that the plant staff established a dry gas blanket at greater than 14 pounds force per square inch absolute (psla) within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> in accordance with TSR 2.4.4.4,

" Moderation Control," Action Statement B. The inspector also determined that the plant staff drained the cooler recirculating cooling water (RCW) as required by TSR 2.4.4.4, Action Statement C.

During review of the staff's actions, the inspector noted that another greater-than-safe-mass uranium deposit was previously identified in the Building C-335, Number 1 P&E Cooler. The inspector determined that the deposit was currently being maintained in a fluorinating environment in accordance with Action Statement A of TSR 2.4.4.4. The inspector also verified that the surveillance requirements of TSR 2.4.4.4 were properly

. incorporated in a new Procedure CP4-CO-ON3045," Handling And Tracking Uranium

' Deposits."

Freezer / Sublimer Surveillance On August 4, the inspector observed the plant staff conduct a routine surveillance associated with a Building C-331 cascade freezer / sublimer (F/S). Thesurveillance was conducted in accordance with Procedure CP4-CO-6040K, "TSR Surveillance-Freezer / Sublimer Safety System Hi-Hi Weight Trip Test." The inspector observed that the operators were unable to place the F/S in Mode 3 (Cold Standby), a prerequisite for initiating the testing. The operators investigated the situation and determined that the F/S could not be placed in Mode 3 due to a conflict between a prerequisite for the mode and the current building RCW status. Specifically, the F/S control system required the RCW system low temperature to be greater than 85 degrees Fahrenheit. However, the building staff were maintaining the RCW temperature below the low temperature t-ip setpoint in order to provide additional cooling to plant air compressors co-located in the building.

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Based upon the results of the investigation, the plant staff postponed the surveillance and placed the F/S in Mode 6 (Out of Service) pending resolution of the conflict between the surveillance test prerequisite and the current plant conditions. Although the plant staff's actions appeared appropriate, the inspector noted that the plant staff did not initiate a plant nonconformance document, Action and Tracking Report, to document the issue for further management review and consideration of the potential generic impacts until several days after the event.

c. Conclusions The inspector determined that the plant staff properly implemented the Technical Safety Requirement-specified moderation controls for two cascade uranium deposits that were greater than safe mass. The inspector also determined that cascade operators properly postponed the performance of a Technical Safety Requirement-related freezer / sublimer surveillance and maintainea the equipment in an inoperable status based upon an absence of proper test conditions. However, the staff did not immediately document the off-normal condition for further management review.

II. Maintenance M1 Conduct of Maintenance M1.1 Review of Maintenance Activities

a. Inspection Scope (88025)

The inspector observed maintenance activities and reviewed s,everal work packages to verify compliance with procedural and other requirements,

b. Observations and Findinas On August 5, the inspector observed testing of the Building C-310 Criticality Accident Alarm System per Paragraph 8.1 of Procedure CP4-GP-lM6209, " Criticality Accident Alarm System Functional Tests," following a cluster replacement. The inspector determined that the evolution was performed in accordance with the procedure, was ws!!

coordinated, and was conducted with a good level of oversight by the maintenance first line manager.

The inspector also reviewed several safety-related, "Q" work packages associated with work in Buildings C-333A and C-360. The inspector noted that complex activities, requiring instructions beyond " skill-of-the-craft," appropriately referenced approved drawings and procedures. The inspector verified that signatures and other data were properly documented in the packages.

c. Conclusions The inspector determined that a post-maintenance test of the Building C-310 Criticality Accident Alarm System was well controlled with a proper level of first line management oversight. In addition, other work packages reviewed were noted to include appropriate procedures and drawings for the beyond " skill-of-the-craft" work activities.

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111. Enaineerina E2 Engineering Support of Facilities and Equipment E2.1 Installation of a Portable Charaer in Buildina C-333

a. Inspection Scope (88101)

The inspector reviewed the resolution of technicalissues to verify compliance with the design basis.

b. Observations and Findinas On August 4, the inspector observed that the plant staff had connected a portable charger to a Building C-333 Unit 3 Battery. The Unit 3 Battery had previously been cross-tied to the Unit 2 Battery following a failure of the Unit 2 Battery rectifier.

The plant staff installed the portable charger because 125 VDC loads, transferred from the rectifier to the battery following the rectifier failure, were supplied through the center tap of the 250 VDC battery. The load alignment resulted in an imbalance between the two sections of the battery bank. As a result, the battery discharged to a condition where one section had higher than normal voltage and the other half section had lower than normal voltage. The portable charger was used in parallel with the main charger to supply the load being drawn at the center tap and equalize the current required by the discharged cells. In addition to the normal building emergency lighting load, the battery supplied power for the area control room process gas leak detection system alarms a safety-related load.

' The inspector noted that the portable battery charger was installed using a maintenance work package. The package referenced Engineering Notice EN-C-822-97-095, Revision 0, to provide detailed instructions for charger operations. The inspector determined that the work instructions and engineering notice did not receive a 10 CFR 76.68 safety review. The inspector concluded that the installation of the portable charger to supply load for and maintain a charge on the battery constituted a temporary modification that required the safety reviews and approvals.

As immediate corrective action, operations management issued a long-term order that placed a hold the further installation of portable chargers until the required reviews and approvals were completed in addition, engineering management issued a memo to the work control organization to re-enforce a standing prohibition against the use of engineering notices as work instructions in lieu of procedures.

Title 10 of the Code of Federal Regulations, Part 76.68, requires, in part, that changes made to the plant shall be evaluated to ensure that the changes are consistent with the current safety basis and shall be reviewed by plant management. The failure to perform required safety reviews and approvals for the installation of the battery charger is a violation 10 CFR 76.68. However, since the violation did not result in a significant safety consequence, and because the plant staff took immediate action to resolve both the immediate and genedc aspects of the violation, the failure is being treated as a Violation of Minor Significance not subject to formal enforcement action, consistent with Section IV of the NRC Enforcement Policy (NUREG-1600, Revision 1). (NCV 70-l 7001/98014-01).

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c. Conclusion

The inspector identified a minor violation in that the plant staff made a temporary modification through the installation of a portable battery charger in Building C-333 without first performing required safety evaluations and management reviews.

V. Manaaement Meetinas X1 Exit Meeting Summary The inspector presented the inspection results to members of the plant staff and management at the conclusion of the inspections on August 7,1998. Plant staff acknowledged the findings presented at the meeting. The inspector asked the plant staff whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

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l PARTIAL LIST OF PERSONS CONTACTED United States Enrichment Corporation J. Labarraque, Safety, Safeguards and Quality Manager 1

Lockheed Martin Utility Services l

K. Ahem, Engineering Manager I M. Buckner, Operations Manager l L Jackson, Nuclear Regulatory Affairs Manager l S. Penrod, Enrichment Plant Manager l

H. Pulley, General Manager i 1

INSPECTION PROCEDURES USED IP 88025: Maintenance and Surveillance Testing l lP 88100:' Plant Operations IP 88101: Configuration Control ITEMS OPENED, CLOSED AND DISCUSSED Opened l 1

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Closed 70-7002/98014-01 NCV Failure To Perform 10 CFR 76.68 Review Prior To Installing Portable Battery Charger l

' Discussed .

=None l

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