ML20247L075
| ML20247L075 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 05/18/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20247L066 | List: |
| References | |
| 70-7002-98-05, 70-7002-98-5, NUDOCS 9805220308 | |
| Download: ML20247L075 (27) | |
Text
l U.S. NUCLEAR REGULATORY COMMISSION REGION lli Docket No.:
70-7002 Certificate No.:
GDP-2 l
Report No.:
70-7002/98005(DNMS)
Facility Operator:
United States Enrichment Corporation Facility:
Portsmouth Gaseous Diffusion Plant Location:
3930 U.S. Route 23 South P.O. Box 628 Piketon, OH 45661 Dates:
March 9 through May 8,1998 Inspectors:
D. J. Hartland, Senior Resident inspector R. G. Krsek, Fuel Cycle Safety inspector Approved By:
P. L. Hiland, Chief i
Fuel Cycle Branch Division of Nuclear Materials Safety i
l i
9805220308 980518 PDR ADOCK 07007002 C
PDR L__________---______-.---------------
EXECUTIVE
SUMMARY
United States Enrichment Corporation Portsmouth Gaseous Diffusion Plant NRC Inspection Report 70-7002/98005(DNMS)
Operations During the inspection period the plant staff identified, on two separate occasions, that a fluorinating environment was not maintained for cascade equipment which contained a uranium deposit greater-than-safe-mass. The inspectors determined that on both occasions plant staff failed to comply with the action statement within the required time period for the applicable Technical Safety Requirement Limiting Condition for Operation.
One apparent violation regarding a failure to follow communications procedures, and one apparent violation with two examples regarding a failure to comply with Technical Safety Requiren%nts were identified. (Section 01.1)
The inspectors noted an apparent discrepancy between the certificate's current implementation of the See and Flee" policy and the Safety Analysis Report Accident j
Analysis. Actions taken by the plant staff to assess and provide the inspectors with additional information to determine compliance with the certificate will be tracked as an Unresolved item. (Section 01.2)
Maintenance and Surveillance The inspectors concluded that the incorrect installation of the autoclave containment Valve FV-416X actuator revealed deficiencies not only in the conduct of maintenance activities for safety system components, but also in the development and execution of post-maintenance testing for safety system components. The inspectors also noted negative trends regarding procedural adherence in the past performance of this particular maintenance activity, based upon the maintenance organization's review of previous actuator replacements. One apparent violation regarding the operation of an autoclave without an " operable" containment isolation valve, one apparent violation, with two examples, regarding failure to follow maintenance procedures, and one apparent violation regarding inadequate tests were identified. (Section M1.1)
The inspectors identified concems regarding the preventive maintenance program for alr-to-close safety valves. The plant staff initiated an operability evaluation, and as-found testhg of the air-to-close safety valves demonstrated that some air-to-close containment valves would not close during a loss of plant air or with a degraded plant air system. In addition, the inspectors identified a communication breakdown between the engineering and operations organizations in the implementation of interim compensatory actions. One apparent violation was identified. (Section M1.2)
Fngineenng The inspectors evaluated a condition regarding abandoned sections of recirculating cooling water piping and concluded that the plant staff's prioritization of the issue was appropriate, based on the minimal safety implications. (Section E2.1) j l
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E Plant Suoport The plant staff discovered, during " security sweeps" in Building X-326, several items containing highly enriched uranium, which caused the plant to exceed the material possession limits for a Category ill NRC facility. The inspectors noted that Building X-326 security was equivalent to a Category 11 NRC facility, and that plant staff responded to the nuclear criticality safety issues in accordance with plant policy and procedure. The exceedance of material possession limits was identified as an apparent violation. (Section S1.1)
The inspectors observed fire protection surveillance activities and noted a failure to l
enter a Technical Safety Requirement Limiting Condition for Operation. However, since the water supply capability was restored prior to the action statement completion time, the inspectors concluded this issue was of minor safety significance. One non-cited violation was identified. (Section F1.1)
The inspectors noted the on-the-job training module for actuator removal, replacement and installation had not been revised to reflect procedural changes. A review of on-the-job training modules onsite revealed that a total of 16 on-the-job training modules required revision due to procedural changes. One violation was identified. In addition, the inspectors concluded there was no correlation between the incorrect installation of the actuator (see Section M1.1) and this training program violation. (Section 15.1)
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Report. Details L on==+ians 01 Conduct of Operations 01.1 Lons of Moderation Control For Eautoment Containing a Greater-Than-Safe = Mass Uranium Deposit 1
a.
insoection Senna (88100)
The inspectors reviewed the circumstances surrounding the certificate's identification of a loss of nuclear criticality controls for cascade cells that contained greater-than-safe-mass uranium deposits. The inspectors also reviewed the certificate's compliance with the action statements of the applicable Technical Safety Requirements for shutdown cascade cells, b.
Observations and Findinas On April 7 the cascade controller reviewed laboratory analysis results of weekly samples taken to monitor the gases contained in shutdown equipment with greater-than-safe-mass uranium deposits. The sampling process was conducted to ensure the uranium deposits were maintained in a fluorinating environment. A fluorinating environment was defined to exist whenever the uranium hexafluoride (UF.) gas concentration was greater than 1 part per million (ppm). The April 7 laboratory analysis results indicated Cell 29-5-2 in Building X-330 had a low UF, gas concentration of approximately 6 ppm.
Based on the low gas concentration, the cascade controller requested a second sample on April 8. The April 8 laboratory analysis results indicated Cell 29-5-2 had a UF gas concentration ofless than 1 ppm. In response to the sample results, the cascade i
controller initiated actions to pressurize (buffer) the cell, using the plant dry air system, in accordance with Technical Safety Requirement 2.2.3.15.
During further review of the cell conditions, the cascade controller identified that the previous week's sample results had not been recorded. Subsequently, the cascade controller requested and received the March 31 laboratory analysis results which indicated that the Cell 29-5-2 UF, gas concentration was less than 1 ppm on March 31.
Based upon the laboratory analysis results for March 31 and April 8, the plant shift superintendent (PSS) determined that the applicable nuclear criticality safety control, moderation, had not been maintained, and an event report was made to the NRC in accordance with NRC Bulletin 91-01.
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At the time the fluorinating environment was lost, Cell 29-5-2 contained approximately l
6,238 grams (* 3,119 grams) of uranium-235 (U-235) with an enrichment of 5.5 percent.
Tha; safe mass for a spherical, optimally-moderated and reflected mass at the identified enrichment was 768 grams of U-235. Moderation, the only criticality control, was lost when the fluorinated environment was not maintained, and the cell was not buffered.
However, the plant staff estimated, based on normal wet air inleakage, that only after two years would the deposit absorb enough moisture to become moderated; therefore, an immediate nuclear criticality safety concem did not exist.
The inspectors discussed the findings with operations and laboratory staff and were informed that, on March 31, laboratory staff received and analyzed several samples 4
l related to shutdown equipment. However, the Cell 29-5-2 sample analysis results were not communicated to the cascade controller. The failure to communicate the March 31 c
results to the cascade controller appeared to be an oversight on the part of laboratory l
staff that was not recognized, at the time, by the cascade controller. Technical Safety Requirernent 3.9.1, required, in part, that written procedures shall be implemented for activities described in Safety Analysis Report, Section 6.11.4.1, and listed in Appendix A, to Safety Analysis Report, Section 6.11. Appendix A, to Safety Analysis Report, Section 6.11 required, in part, that Communication activities shall be covered by l
written procedures. Procedure XP2-TS-TS1032," Communications with Cascade Operations," Revision 0, dated September 11,1996, Section 6.4, " Action Steps,"
required, in part, that process services staff shall report sample results (requested by I
the Cascade Controller) to the Cascade Controller as the sample results became l
available. On March 31 process services staff failed to report sample results (requested by the Cascade Controller) to the Cascade Controller for Cell 29-5-2. The failure to communicate the Cell 29-5-2 sample results is an Apparent Violation (eel 70-i l
7002/98005-01).
l On May 6 a similar issue was identified when the certificate determined that the i
fluorinating environment for Cell 29-3-6 was lost. Cell 29-3-6 contained a uranium l
deposit at an enrichment of 3.55 percent, with approximately 2,786 grams of U-235.
The safe mass for a spherical, optimally-moderated and reflected mass at the identified enrichment was 988 grams of U-235. Samples taken at 12:00 p.m. on May 5 from adjacent stages within Cell 29-3-6 revealed inconsistent results. The sample results from Cell 29-3-6, Stage 2, where the uranium deposit was located, indicated that Cell 29-3-6 was in a fluorinating environment (428 ppm). However, sample results taken from Cell 29-3-6, Stage 1, indicated that the Cell 29-3-6 UF, gas concentration was less than 1 ppm. Both samples were taken from the local control center (LCC).
The sample results for Cell 29-3-6 were confirmed later in the day on May 5 and were l
properly communicated from process services staff to the cascade controller. However, due to poor communications amongst operations personnel, no actions were takea to resolve the sampling discrepancy until May 6. On May 6 samples were taken directly from Cell 29-3-6, Stages 1 and 3, through the stage blow-out preventers to ensure sampling accuracy. The results confirmed that the Cell 29-3-6 UF, gas concentration was less than 1 ppm. The inspectors noted that at approximately 6:00 p.m. on May 6, operations staff pressurized Cell 29-3-6 with dry air, in accordance with Technical Safety Requirement 2.2.3.15. The certificate made an event report to the NRC in accordance with NRC Bulletin 91-01, due to the loss of the single nuclear criticality safety control, moderation.
The inspectors reviewed the results of other samples taken over the past few months from Cells 29-5-2 and 29-3-6, in addition to other cells in the cascade with greater-than-safe-mass uranium deposits. The inspectors noted erratic trends in the sample analysis results. Specifically, the sample analysis results indicated that the concentration of UF, in a given cell increased and decreased erratically over time. The inspectors also noted that the rates ofincrease and decline were not consistent. Additional inconsistencies were noted in the results between the stages of a single cell. (A cell consisted of several stages which were not isolated from each other.) The inspectors determined that the sampling data was not indicative of a well-characterized and controlled sampling system. At the end of the inspection period, the certificate continued to evaluate the root causes for the inconsistent sample results.
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Previously, the inspeclors documented in NRC Inspection Report 70-7002/98003(DNMS) that up until January 30,1998, the certificate did not have a surveillance program in place to verify that a fluorinating environment was maintained in equipment that was shutdown and contained greater-than-safe-mass. In response to the finding, the certificate initiated an administrative control, via daily operating instructions, to take weekly samples to monitor the condition of shutdown cells containing a greater-than-safe-mass uranium deposit. At the time of this inspection, the l
process had not yet been proceduralized, instead, samples were requested verbally by the cascade controller, and the laboratory analysis results, once received, were documented in a log book. The inspectors noted that the informal process did not include a feedback mechanism that required operations staff to verify that the results were received. In addition, laboratory staff were not provided with criteria by which to assess the immediacy with which data should be provided back to operations staff.
Technical Safety Requirement 2.2.3.15, Moderation Control," Limiting Condition for Operation, required, in part, that moderation control shall be maintained when the UO F 22
[ uranyl fluoride] mass was greater-than-safe-mass. Action B.1, required, in part, that i
equipment which contains UO F deposits greater-than-safe-mass, not in a fluorinating 2 2 I
environment, and in Mode VI [ Shutdown] to be pressured with plant air or nitrogen to greater than or equal to 14 psia [ pounds per square inch absolute) within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after a UF, negative [less than 1 ppm UF, gas concentration) was obtained on the system.
The plant staff identified equipment, in Mode VI and containing a uranyl fluoride deposit greater-than-safe-mass, which did not r:nntain a fluorinating environment. The equipment was not pressurized with plant uir or nitrogen to greater than or equal to 14 psia, within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after the system was at a UF, negative as required by Technical Safety Requirement 2.2.3.15. Specifically, on March 31 Cell 29-5-2, which contained a uranyl fluoride deposit at an enrichment of 5.5 percent with approximately 6,238 grams
(* 3,119 grams) of U-235, was in Mode VI and not in a fluorinating environment, and was not pressurized in accordance with the Technical Safety Requirements. In addition, on May 5 Cell 29-3-6, which contained a uranyl fluoride deposit at an enrichment of 3.55 percent with approximately 2,786 grams of U-235, was in Mode VI and not in a fluorinating environment, and was not pressurized in accordance with the Technical Safety Requirements. Failure to perform the Technical Safety Requirement actions between the periods of March 31 through April 8,1998, for Cell 29-5-2 and May 5 l
through May 6,1998, for Cell 29-3-6 are two examples of an Apparent Violation (eel 070-07002/98005 02a,b),
c.
Conclusions The inspectors determined that the certificate failed to comply with the action statements for a Technical Safety Requirement to maintain shutdown equipment containing a greater-than-safe-mass uranium deposit in accordance with applicable Technical Safety Requirements. One apparent violation regarding a failure to follow communications procedures, and one apparent violation with two examples regarding a failure to comply with Technical Safety Requirements were identified.
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a 01.2 implementation of the Site-Wide "See and Flee" Poliev a.
Insoeinn Smne (88100)
The inspectors reviewed issues regarding the certificate's implementation of the site's "See and Flee" policy, b.
Observations and Findings l
On March 28 a small UF release occurred at the Tails station in Building X-330 during valve maintenance. Per plant procedure, the operators initiated a building recall and all staff reported to the area control room (ACR). Staff were required to remain in the ACR until negative air sample results were obtained in the field. As a result, a cell treatment in progress at the LCC for Cell 29-3-6, several feet away from the ACR, was left unmonitored for approximately 50 minutes.
Technical SCety Requirement 2.2.3.6 required that cell treatments be monitored every 30 minutes and the contents be evacuated within the next 30 minutes if monitoring was not performed. The basis for the requirement was to ensure that chemical reaction products were not formed in the cell, which could result in an exothermic chemical l
reaction. Since these actions were not accomplished within the specified time interval, the certificate entered Technical Safety Requirement 1.6.2.2.c, which required that the cell be placed in an operating mode for which the Limiting Condition for Operation (LCO) did not apply within one hour. As a result, the operators evacuated the cell contents and l
exited Mode IV as required.
The inspectors noted that implementation of the "See and Flee" policy for the March 28 event did not appear to fully evaluate the impact of on-going safety significant activities.
The certificate staff later determined that due to the size and location of the release, there was no apparent risk of exposure to an operator monitoring the cell treatment at the LCC for this event.
On February 11,1998, a small UF, release and smoke actuation occurred at Cell 31-2-6 in Building X-330. The operators initiated a building recall and all staff reported to the ACR as required. The operators tripped the cell from the ACR, per plant procedure, to reduce the cell pressure to below atmospheric. However, not all the block valves closed as designed to isolate the cell from the cascade. Due to the building recall, the operators were delayed in closing the valves from the LCC. In the meantime, the cell pressurized to above atmospheric pressure.
The inspectors noted that Safety Analysis Report, Chapter 4," Accident Analysis,"
Section 4.1.1.3.2, did not take credit for operator actions to isolate a cell from the LCC.
The inspectors questioned if a potential unreviewed safety question could exist, in the event of a large release, if a block valve did not close shut when the cell was tripped from the ACR. In such a scenario, some of the contents of the adjacent cells, if above atmospheric pressure, could be released as well resulting in a release in excess of that assumed in the accident analysis.
In response, the certificate performed a preliminary analysis that assumed 10 ininutes for the operators to respond to the LCC and close the block valves. However, under the current "See and Flee" policy, the operators would not be able to respond within that j
time frame. The inspectors' review of the certificate's review of the apparent I
discrepancy between the safety analysis and the "See and Flee" policy is an Unresolved item (URI 70-7002/98005-03).
c.
Conclusions The inspectors identified an apparent discrepancy between the certificate's current l
"See and Flee" policy and assumptions made for the timeliness of operator response to a transient plant condition.
08 Miscellaneous Operations issues i
08.1 Certificate Event Renorts (90712)
The certificate made the following operations-related event reports during the inspection period. The inspectors reviewed any immediate safety concerns indicated at the time of the initial verbal notification. The inspectors will evaluate the associated written reports for each of the events following submittal.
Number Status Iltle 33891 Closed Failure to Have Required " Smoke Detectors" Outside Two Compressors in Building X-330 - Retracted 1
33902 Closed Failure to Declare Fire Protection System inoperable in Building X-333 as Required - Retracted 33986 Closed Building X-343 Autoclave No. 4 Containment Valve Operating Incorrectly - Retracted 34050 Closed Failure of Autoclave Containment Valves During As-Found Testing for an Operability Evaluation The issues associated with Event Notification 34050 will be evaluated and assessed as a part of the resolution of the apparent violation discussed in Section M1.2 of this report.
08.2 Bulletin 91-01 Reoorts (97012)
The certificate made the following reports pursuant to Bulletin 91-01 during the inspection period. The inspectors reviewed any immediate nuclear criticality safety concerns associated with the report at the time of the initial verbal notification. Any significant issues emerging from these reviews are discussed in separate sections of this report.
Number Date Iille l
33907 03/16/98 24-Hour Report - Loss of One Criticality Control i
(Moderation)in Double Contingency Matrix 33911 03/17/98 4-Hour Report-Loss of One Criticality Control (Spacing) in Double Contingency Matrix and Failure to Reestablish this Spacing within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 8
Number Data Iltle 33912 03/17/98 24-Hour Repo 1-Loss of One Criticality Control (Spacing)
In Double Contingency Matrix 33923 03/19/98 24-Hour Report - Loss of One Criticality Control (Moderation)in Double Contingency Matrix 33925 03/19/98 24-Hour Report - Loss of One Criticality Contro!
)
(Moderation) in Double Contingency Matrix i
33927 03/19/98 24-Hour Report - Loss of Single Criticality Control 33937 03/20/98 24-Hour Report - Loss of One Criticality Control (Spacing) in Double Contingency Matrix 33942 03/22/98 24-Hour Report - Loss of One Criticality Control in Double Contingency Matrix, Dry Active Waste Bag Without Required Holes in Bottom 33949 03/23/98 24-Hour Report - Two Losses of One Criticality Control (Spacing or Moderation) in Double Contingency Matrix 33950 03/23/98 24-Hour Report - Loss of One Criticality Control (Moderation)in Double Contingency Matrix 33951 03/23/98 24-Hour Report - Loss of One Criticality Control (Spacing) in Double Contingency Matrix 33963 03/24/98 24-Hour Report - Loss of One Criticality Controlin Double Contingency Matrix 33972 03/20/98 24-Hour Report - Loss of One Criticality Control (Moderation) in Double Contingency Matrix 33973 03/22/98 24-Hour Report - Loss of One Criticality Control in Double Contingency Matrix 33974 03/26/98 24-Hour Report - Loss of One Criticality Control (Moderation)in Double Contingency Matrix 33984 03/30/98 24-Hour Report - Loss of One Criticality Control (Spacing) in Double Contingency Matrix 33985 03/30/98 24-Hour Report - Loss of One Criticality Control in Double Contingency Matrix 33999 04/01/98 24-Hour Report - Three Losses of One Criticality Control in Double Contingency Matrix 34006 04/02/98 24-Hour Report - Loss of One Criticality Control (Moderation)in Double Contingency Matrix l
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l Number Date lille 34009 04/02/98 24-Hour Report - Loss of One Criticality Control (Spacing) in Double Contingency Matrix 34010 04/02/98 24-Hour Report - Loss of One Criticality Control (Moderation)in Double Contingency Matrix 34012 04/03/98 4-Hour Report - No Nuclear Criticality Safety Approval for 12 Freezer /Sublimers in Building X-333 34019 04/04/98 24-Hour Report - Loss of One Criticality Control in Double Contingency Matrix 34026 04/05/98 24-Hour Report - Loss of One Criticality Control in Double Contingency Matrix 34027 04/05/98 24-Hour Report - Loss of One Criticality Control (Spacing) in Double Contingency Matrix 34029 04/06/98 24-Hour Report - Loss of One Criticality Control (Spacing) in Double Contingency Matrix - Six Items with Highly Enriched Uranium in Safe Geome'try Containers Discovered in Building X-326 34037 04/07/98 4-Hour Report - Loss of Single Criticality Control -
Cascade Cellin Building X-330 Not Maintained at Minimum Required Pressure
{
34042 04/08/98 24-Hour Report - Loss of One Criticality Control (Spacing) j in Double Contingency Matrix 34043 04/08/98 24-Hour Report - Loss of One Criticality Control in Double Contingency Matrix 34057 04/10/98 4-Hour Report - Loss of Single Criticality Control -
Cascade Cell 29-5-2 Not at Minimum Required Pressure 34114 04/21/98 24-Hour Report - Loss of One Criticality Control in Double Contingency Matrix 08.3 (Open) VIO 70-7002/97015-01: Dry active Waste (DAW) Bags Within Two Feet Of 1S Cylinders.
The violation was cited due to the ineffectiveness of the certificate's short-term corrective actions in preventing continued noncompliance with nuclear criticality safety l
approval (NCSA) requirements. In response to the violation, the certificate initiated a l
plant-wide stand-down from March 11 through March 13 to improve staff knowledge and i
training on nuclear criticality safety (NCS) requirements.
1 During the inspection period, the certificate took additional corrective actions which included:
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o adding specific action steps to work packages for disposal of waste generated during the activity; Instituting pre-job briefs for all NCS related activities; cleaning of affected buildings to eliminate scrap materials; adding an " operating margin" to items stored under administrative spacing e
requirements; designating staging areas for DAW and contaminated metal; removing infrequently used boundary control stations; and, applying more stringent access controls for the cascade buildings.
These additional actions appeared to have a short-term effect, as the frequency of the l
noncompliance was reduced by the end of the inspection period. The inspectors will i
continue to monitor performance in this area, and this item will remain open.
- 11. Maintenance and Surveillance M1 Conduct of Maintenance and Surveillance M1.1 Replacement of Autoclave.No. 4 FV-416X Containment Valve Actuator a.
Insoection Scone (88025)
The inspectors evaluated the circumstances and events surrounding the certificate's identification of the incorrect insta!Iation of the Autoclave No. 4 containment Valve FV-416X actuator, which occurred on March 24. The inspection consisted of the observation of event critiques, reviews of work package documentation and procedures, interviews with operations, maintenance and engineering staff, and reenactments of the maintenance and post-maintenance testing evolutions.
b.
Observations and Findinas Ooeration of Aufnclave No 4 in RuiMina X-343 On March 27 while preparing a feed cylinder for heating in Autoclave No. 4 in Building X-343, an operator noted that autoclave containment Valve FV-416X (shell vent line) operated incorrectly. Specifically, Valve FV-416X was closed when the autoclave was not in the containment mode and was opened when the autoclave was in the containment mode. The Valve FV-416X actuator was replaced by maintenance mechanics three days earlier on March 24. Following valve replacement, Autoclave No. 4 was declared operable by the Plant Shift Superintendent (PSS) on March 25. The inspectors noted that between March 25 and March 27 Autoclave No. 4 was operated for two heating and feeding cycles with te FV-416X autoclave shell high pressure containment valve, a safety system component, incapable of performing the specified safety function (valve closure upon a containment signal). A second manual autoclave shell high pressure containment valve (V-386-4) was operable and closed (as required 11
y-by operating procedures) for the two heating and feeding cycles which occurred l
between March 25 and March 27.
Technical Safety Requirement 2.1.3.5," Autoclave Shell High Pressure Containment Shutdown," Limiting Condition for Operation, required, in part, that the autoclave shell high pressure containment system shall be operable. Technical Safety Requirement Section 1.2.13, " Operable," stated, in part, that a safety system component shall be operable or have operability when the component is capable of performing the specified function (s), and when other auxiliary equipment that are required for the safety system l
component to perform its specified function (s) are also capable of performing their I
related support function (s). Operating Autoclave No. 4 between March 25 and March 27 while an autoclave shell high pressure containment safety system component was incapable of performing the specified safety function of containment valve closure upon a containment signal is an Apparent Violation (eel 70-7002/98005-04).
Maintenance Work Performed on Autoclave No. 4 in Buildino_ X-343 The inspectors reviewed maintenance Work Order R9811626-01, which was issued on March 24 to replace the Valve FV-416X actuator on Autoclave No. 4. Maintenance staff completed the actuator installation at approximately 10:00 p.m. on March 24. The initial event investigation conducted on March 30 identified that the symmetrical actuator was installed incorrectly. In addition, the investigators identified that the valve end of the actuator torque shaft, the valve side of the actuator housing, and the valve end of a coupling between the torque shaft and valve stem had no installation markings (bench mark).
Procedure XP4-TE-MM4104, " Valve Actuator Removal, Replacement and installation,"
Revision 0, Change C, Section 8.2, "Xomox Single Vane Valve Actuators," was the procedure prescribed by the work order to perform the actuator replacement.
Section 8.2.12,"Xomox Single Vane Actuators," of Procedure XP4-TE-MM4104, required, in part, that the maintenance staff performing the work activity ensure that each of the following pieces of equipment have a "V" stamped onto the component:
valve end of the actuator torque shaft; valve side of the actuator housing; and, valve end of the coupling between the torque shaft and the valve stem. The inspectors interviewed the maintenance mechanics and confirmed that Section 8.2.12 was not performed during the March 24 maintenance evolution. The mechanics incorrectly believed the "V" stamping step was not required because of the procedure classification (General Intent versus in-Hand), and because the mechanics believed the actuator was properly installed.
The inspectors performed a walkdown of other valve actuators and noted additional examples of installed actuators which did not have "V" stamps. Maintenance staff conducted a review of actuator replacements conducted since April 1997 and concluded that of 25 actuators which had been replaced, a total of seven actuators had no visible indication that the latest revision of XP4-TE-MM4104 was followed. Th6 maintenance I
organization also concluded that had the procedure and work order been followed as required for this maintenance evolution, the Valve FV-416X actuator could have been installed correctly.
During reenactments of the performance of an actuator replacement, the inspectors noted that Step 8.2.24 of maintenance Procedure XP4-TE-MM4104 required that the maintenance mechanics go to Section 8.5, " Operational Check." Section 8.5 required 12
the mechanics performing the actuator replacement to contact operations staff to perform an operational check of the valve actuator. If the valve actuator failed the operational check, the mechanics were to notify the supervisor. The inspectors determined through observations at the critique, interviews with maintenance staff, and reenactments that operational checks were not performed by maintenance staff.
Maintenance staff, both mechanics and front line managers, assumed that the operational check was the post-maintenance test required to be performed by l
operations staff after installation was complete. Therefore, upon completion of the installation portion of the procedure, maintenance staff turned over the work package to operations staff to perform a post-maintenance test, without an operational or functional test of the actuator as required by the procedure.
The inspectors conducted a review of the history of procedure Sections 8.2.12 to determine the basis for these action steps. The inspectors noted that Section 8.2.12 was added to the procedure in December 1996, as Change B. Section 8.2.12 was added to Procedure XP4-TE-MM4104 as corrective action for a Department of Energy (DOE) reportable event which occurred in November of 1995 (prior to NRC regulation) when a safety system containment valve on Autoclave No. 2 in Building X-344 was operating incorrect"/. The certificat( W investigatiori of the November 1995 incident concluded that the symmetrical acwator was installed incorrectly during a maintenance evolution. Step 8.2.12 was added to the maintenance procedure to provide additional assurance that actuators were installed correctly during maintenance evolutions.
Technical Safety Requirement 3.9.1, required, in part, that written procedures shall be implemented for stivities described in Safety Analysis Report, Section 6.11.4.1, and listed in Appendix A, to Safety Analysis Report, Section 6.11. Appendix A, to Safety Analysis Report, Section 6.11 required, in part, that Maintenance activities shall be covered by written procedures. Failure to perform Section 8.2.12 End Section 8.2.24 of Procedure XP4-TE-MM4104 during the replacement of the Valve FV-416X actuator on March 24 as required by both the procedure and the maintenance work order are two examples of an Apparent Violation (eel 70 7002/98005-05a,b).
Post-Maintenance Testing Performed on Autoclave No. 4 in Building X-343 After maintenance staff completed the installation of the actuator at approximately 10:00 p.m. on March 24, the work order was turned over to operations staff in Building X-343 for post-maintenance testing. Operations staff completed the post-maintenance tests at approximately 1:00 a.m. on March 25. The inspectors conducted interviews with the operators who performed the post-maintenance testing and also conducted a reenactment of the post-maintenance test. The inspectors noted that although the communications which had occurred between the operators during the post-maintenance testing may have been less than adequate, the operators completed the post-maintenance testing as written in the test instructions developed by systems engineering.
The test instructions contained in Work Order No. R9811626-01 contained the following three requirements: verify the actuator opens and closus valve as required without binding; verify actuator and valve position agrees with indicating lights or exoected position; and, safety system containment valves shall close in 10 seconds or less. The operators performed all the required steps of the test instructions, however the operators did not verify the expected position of the valve as suggested (not required)in the test instruction which stated "or expected position." The post-maintenance test 13
1 instructions failed to demonstrate that containment Valve FV-416X (a "Q" safety system component) was operable and would perform the intended safety function.
10 CFR 76.93, " Quality Assurance," required, in part, that the Corporation shall establish, maintain, and execute a quality assurance program satisfying each of the applicable requirements of ASME NQA-1-1989," Quality Assurance Program Requirements for Nuclear Facilities." Portsmouth Quality Assurance Program, Section 2.11.1, " Test Control-General," required, in part, that the test control system for l
"Q" items, was planned and executed to assure that testing was performed to l
demonstrate that safety system components will perform satisfactorily in service. The l
post-maintenance test planned and executed on March 24 for Work Order Number l
R9811626-01, failed to demonstrate that a *Q" safety system component, autoclave shell high pressure containment Valve FV-416X, would perform satisfactorily in service by closing upon a containment signal. The inadequate post-maintenance test for Work Order No. R9811626-01 is an Apparent Violation (eel 70-7002/98005-06).
Initini Certificate Corrective Ar4 inns l
As a result of the identification on March 27 that Valve FV-416X was operating backwards, the certificate initiated several immediate corrective actions, some of which l
are highlighted below. On March 27, upon discovery of the anomaly, the PSS initiated i
I instructions which required that prior to initiating a new heating cycle for an autoclave onsite, operations must perform the quarterly Technical Safety Requirement L
Surveillance for pressure decay testing, to ensure all autoclave containment valves operated property. On April 1 operations and engineering revised the post-I maintenance test for the replacemet of autoclave containment valves. The revised post-maintenance test incorporated not only the quarterly Technical Safety Requirement Surveillance for pressure decay testing, but t!so verification that the valve position was l
closed when an autoclave was in containment. In addition, the maintenance and operations organizations conducted crew briefings with staff regarding the incident. On April 9 the Engineering Manager issued a general policy statement to all engineering staff, which stated that post-maintenance tests shall ensure all Technical Safety Requirement surveillance are met prior to retuming a safety system component to service.
c.
Con += inns The inspectors concluded that the incorrect installation of the autoclave containment Valve FV-416X actuator revealed deficiencies in the conduct of maintenance activities for safety system components, and the development and execution of post-maintenance testing for safety system components. The inspectors also noted negative trends regarding procedural adherence in the past performance of this maintenance activity, as evidenced by the maintenance organization's review of previous actuator replacements.
One apparent violation regarding the operation of an autoclave without an " operable" containment isolation valve, one apparent violation, with two examples, regarding failure to follow maintenance procedures, and one apparent violation regarding inadequate tests were identified.
i i
14 1
M1.2 Maintenance and Surveillance of Air-to-C10Se_ Autoclave Containment Valves a.
insoection Scope (88025) l The inspectors reviewed the maintenance and surveillance program and as-found testing data (up to April 21) for the air-to-close autoclave containment valves in Building X-343. The inspection consisted of observations of as-found testing activities, interviews with operations, maintenance and engineering staff, and reviews of available documentation concerning the autoc! ave containment system for Building X-343.
b.
Observations and Findings System Description and Current Surveillance Program The inspectors reviewed the system configuration of the autoclave containment valves through walkdowns of system boundary drawings, reviews of operating and testing procedures, and interviews with operations and engineering staff responsible for the operation of the autoclaves. During the review, the inspectors noted that some of the autoclave high pressure containment system valves were air-to-open and air-to-close valves. The air-to-close containment valves normally operated with plant air (designated as a "Non-Safety" system) and were designed with air reservoirs (volume tanks). The air reservoirs (designated as "Q" safety systems) provided an alternative motive force to close the valves in the event of a loss of plant air or when the plant air pressure was below the minimum pressure required to close a containment valve (Iow plant air).
Each of the seven autoclaves in Building X-343 had five air-to-close containment valves, with each valve in a separate line. The valves were in the following lines: condensate "A" line (Valve FV411X1); condensate "B" line (Valve FV411X2); blowdown exhaust line (Valve FV410X); shell vent line (Valve FV416X); and, pigtail isolation or parent cylinder safety valve (Valve FV404). (The "#" symbol represents the designated number of each autoclave in Building X-343.) The condensate A, condensate B, blowdown exhaust and shell vent lines each had a redundant containment valve of a different type. The redundant valves were either spring-to-close valves which fait close in the event of a loss of plant air or 'iow plant air scenario, or were manually operated valves which were required to be closed during normal operations. In addition, the five air-to-close valves had two different types of air-to-close actuators. The FV411X1, FV411X2, and FV410X valves all had fail-safe Matryx actuators, which were designed to fail close instantaneously when a complete plant air failure occurred, or when the plant air supply fell below a predetermined setting. The FV416X, and FV404 valves had standard 90-degree double acting Matryx actuators which were not designed to fail close; however, during loss of plar,t air or low plant air scenarios, the valves were designed to close upon a containment signal using the air pressure in the air reservoirs as the motive force.
While reviewing the preventive maintenance and surveillance program for the air-to-close valves, the inspectors identiied that a quarterly procedural surveillance, which verified the air reservoirs would hnid a certain air pressure when isolated from normal plant air, was only performed on he pigtail isolation valve (Valve FV-#04). In addition, the inspectors noted that no surveillance or testing was routinely performed on the five air-to-close containment valves to ensure the valves would function properly in either a loss of plant air or low plant air scenario. At the time of the inspection, quarterly 15
Technical Safety Requirement and procedural surveillance only tested the air-to-close valves with normal plant air.
Since no current information was available to address these issues, the Systems Engineering Manager initiated an operability evaluation to perform as-found testing on the autoclave air-to-close containment valves. The as-found testing was prescribed by systems engineering and was designed to address whether or not the air-to-close safety
{
system components would perform the specified safety functions during both a loss of plant air and low plant air scenario. As-found testing requirements were developed for the two types of actuators present on the five air-to-close valves. On April 9, when initial as-found testing failures were reported back to the shift and system engineers, the PSS declared all 13 autoclaves inoperable, and all autoclaves which were heating and feeding at the time were immediately shut down. The certificate initiated as-found testing for all other air-to-close safety valves onsite; however, all as-found testing had not been completed at the time of the inspection, and the inspectors focused on the air-to-close safety valves for the Building X-343 autoclaves.
As-Found Testina of Air-to-Close Valves The testing requirements for the fail-safe Matryx actuators consisted of three as-found tests. The first test was conducted with normal plant air to verify the valve functioned properly. The test criteria included verification that upon a containment signal the containment valve closed within 15 seconds, as required by Safety Analysis Report Section 4.2.3.2. The second test simulated a loss of plant air scenario to determine if the fail-safe Matryx actuators functioned as designed and failed close upon loss of plant air as described in Safety Analysis Report Section 4.4.4. Safety Analysis Report Section 4.4.4, " Plant Air System Accident Analysis," stated that " Abnormal operation or failure of the air system will not result in a criticality or release of toxic or radioactive materials. Air-operated safety systems are designed to fail-safe in the event of an air failure. Air is essential for the continued operation of the plant. Cascade instrumentation and many of the control valves in the cascade, feed, and withdrawal l
systems are air-operated. These valves, like the safety systems, are designed to fail in l
a safe mode to prevent both equipment damage and material release." The third test simulated a containment signal while in a low plant air scenario. The test criteria conservatively defined low plant air as approximately 55 pounds per square inch gauge l
(psig), and tested the containment function of the valves at this pressure. The as-found l
testing failures for the fail-safe Matryx actuators in Building X-343 autoclaves (as of April 21) were as follows:
Autoclave No.1 Valve FV-110X failed the first test referenced above, and did not f
close within the required 15 seconds, subsequently the two other as-found tests were not performed.
Autoclave No. 2 Valve FV-210X and Autoclave No. 4 Valve FV-410X failed the l
second test, loss of plant air, by not closing upon loss of plant air.
For Atdoclave Nos.1 ihrough 5, the valves with fail-safe Matryx actuators passed all other as-found tests.
Tne testing requirements for the standard 90-degree double acting Matryx actuators, the second type of actuator used, consisted of two as-found tests. As previously noted only the fail-safe Matryx actuators were designed to fail close. The first test for Valves FV-16
l I
- 04, and FV-#16X (with a standard 90-degree double acting Matryx actuator) was performed as an operational verification of the air supply in the air reservoir. The test criteria was based on Procedure XP4-TE-TE6730, " Operational Verification of Safety Valve Air Supply," used to perform the previously mentioned quaderly procedural surveillance. The test required the air reservoir to hold a pressure of 85 psig for at least 30 seconds. The second test simulated a containment signal while in a low plant air scenario. The test criteria conservatively defined low plant air as approximately 55 psig, and tested the containment function of the valves at this pressure. The as-found testing failures for the valves with standard 90-degree double acting Matryx actuators in the Building X-343 autoclaves (as of April 21) were as follows:
Autoclave No.1 Valve FV-116X, Autoclave No. 2 Valve FV-216X, Autoclave No. 3 Valve FV-316X, and Autoclave No. 5 Valve FV-516X all failed the first as-found test, as the pressure for all four air reservoirs at 30 seconds was zero psig.
Maintenance staff who performed the tests stated that within seconds after the air j
supply was closed the pressure on all four reservoirs dropped to zero psig due to i
gross system leaks. Therefore, the second as-found test could not be performed on the four valves listed above.
For Autoclave Nos.1 through 5, the pigtail isolation valve (Valve FV-#04) passed the as-found tests. Valve FV-416X on Autoclave No. 4 passed both as-found tests.
r implementation of Corrective Actions i
I After the as-found testing was completed, the air-to-close valves were fixed, and as-left i
testing demonstrated that the problems identified in the as-found tests were corrected.
On April 17 Autoclave Nos. 3 and 4 were declared operable and began heating and l
feeding cycles. Systems engineering staff had stated that on April 17 operations staff were given additional administrative actions to place an autoclave in shutdown mode upon a low plant air alarm. The administrative actions were included in the recommendation section of Operability Evaluation POEF-823-98-006, and were additional conservative interim corrective actions to be taken until all as-found testing on the autoclaves had been completed. On April 21 the inspectors discovered that operations staff in Building X-343 had not received any information regarding additional actions to take upon a low plant air alarm. The inspectors leamed that a communication breakdown had occurred and that systems engineering had failed to forward the actual administrative instructions to operations staff. The administrative actions were implemented on the evening of April 21.
The inspectors reviewed the past history of the autoclave air-to-close safety valves and noted that in January of 1996 a self-revealing event identified that two autoclave pigtail isolation valves (parent cylinder safety valves) did not close as required, when a containment signal was inadvertently initiated by an operator in 1:luilding X-344. This i
event resulted in a DOE reportable event (the event occurred prior to NRC regulation),
and the NRC Resident inspection staff discussed the event in Observation Report 70-7002/96001(DNMS). The NRC Observation Report identified that the corrective actions taken for that incident were narrowly focused and did not address the overall generic issues associated with the air-to-close safety valves. In response to the 1996 event, plant staff initiated a problem report and developed a comprehensive corrective action
. plan addressing all the air-to-close valves onsite, to enhance the safety systems and develop a preventive maintenance program for the air-to-close valves. However, the corrective action plan was closed on November 9,1996, without implementation. The 17 i
--_-_o
l only corrective action initiated was the quarterly procedural surveillance for the pigtail isolatiori valve required by Procedure XP4-TE-TE6730.
l Technical Safety Requirement 2.1.3.5, " Autoclave Shell High Pressure Containment Shutdown," Limiting Condition for Operation, required, in part, that the autoclave shell high pressure containment system shall be operable. Technical Safety Requirement Section 1.2.13, " Operable," required, in part, that a safety system component shall be operable or have operability when it is capable of performing its specified function (s),
and when other auxiliary equipment that are required for the safety system component to perform its specified function (s) are also capable of performing their related support function (s). Prior to April 9,1998, Autoclave Numbers 1 through 5 in Building X-343 were operated with an autoclave shell high pressure containment safety system component not able to perform a specified safety function. Specifically, as-found testing of the seven air-to-close autoclave containment valves for Autoclaves 1,2,3,4, and 5 in Building X-343, demonstrated that the containment valves would not close on a containment signal, a specified safety function, during a loss of plant air or with a degraded plant air system. Failure to maintain autoclave safety system components operable to perform the specified safety function demonstrated a deficiency in the certificate's maintenance and surveillance program and is an Apparent Violation (eel 70-7002/98005- 07) c.
Conclusions The inspectors concluded that the as-found testing failures of the air-to-close autoclave containment valves demonstrated an inadequate maintenance and surveillance program for certain autoclave safety system components, in addition, the inspectors identified a communication breakdown in the implementation of interim compensatory actions between the engineering and operations organizations. One apparent violation was identified.
Ill. Engineering E2.0 Engineering Support of Facilities and Equipment E2.1 Mechanical Suonort of Abandoned Recirminting Cooling Water Pining a.
Insoection Smna (88100)
The inspectors evaluated an existing plant configuration issue regarding an abandoned section of recirculating cooling water (RCW) piping in Building X-333. In particular, the inspectors reviewed the certificate's bases for a low assigned work priority.
b.
Chservations and Findings An 8-inch diameter abandoned section of RCW piping in Building X-333 was located at the Cell 33-4-6 "even-side" coolant condenser and was supported only by the weld that attached the 8-inch diameter piping to the 32-inch diameter RCW building return header.
The 8-inch diameter piping was isolated from the header by two isolation valves.
A problem report was initiated in July 1996 to document a concern that since the piping was visibly shaking, a fatigue failure of the weld could occur. A catastrophic break of -
the RCW piping could result in the loss of cooling for up to 10 cells. In response to the 18
l problem report, engineering issued an engineering notice to remove the piping and one of the isolation valves, and to install a blind flange on the remaining valve.
Engineering determined that the potential for the welds to fail was minimal; therefore, a low priority was assigned for the pipe removal activity. The inspectors reviewed the Safety Analysis Report and procedural guidance and noted that loss of RCW was addressed in those documents, and if the pipe welds failed, no significant safety implications would result.
c.
Conclusions The inspectors concluded that the certificate's work prioritization for the unsupported RCW piping issue was appropriate, based on the minimal safety implications.
LP_lant Support S1 Conduct of Security and Safeguards Activities S1.1 Exceedance of Special Nuclear Material Possession Umits a.
Insoection Scope (88100)
The inspectors followed up on an event regarding an exceedance of special nuclear material (SNM) possession limits for the certificate.
b.
Observations and Findings On April 12 while performing " security sweep" activities in Building X-326, the certificate discovered six items containing highly enriched uranium (HEU), with U-235 enrichments of greater than 80 percent. The items included five tygon tubing pigtails and a section of pipe and valve. The certificate determined by nondestructive analysis that the items contained a total of about 775 grams of highly enrichment uranium. This resulted in the certificate possessing a total of approximately 1,339 grams of uranium greater than 20 percent assay in NRC regulated areas, exceeding the 1,000-grams possession limit for a Category lli NRC facility. Due to ongoing DOE activities in Building X-326, the security requirements for this facility were equivalent to a Category ll NRC facility.
The " sweeps" were performed by security staff for the Department of Energy, in support of a downgrade of security requirements in Building X-326 and in conjunction with the completion of HEU refeed activities. The items were found on a small cart, wrapped in plastic, and buried underneath scrap material in an NRC regulated storage area in the building. Since the as-found condition was a violation of NCS spacing requirements, the certificate responded in accordance with plant policies and procedures, to correct the as-found condition. In addition, the certificate made an event report to the NRC in accordance with NRC Bulletin 91-01.
The certificate determined, based on engineering evaluations, that the potential for a criticality (in the as-found condition) did not exist because the items, in the aggregate, contained less than the safe internal volume (0.32 gallons as-found versus a safe volume of 1.26 gallons), in addition, each individual item was configured in a favorable geometry (the diameters of the tubing, valve, and piping were less than 5.39 inches).
19
i The certificate was able to determine that the items had been used at the HEU product I
withdrawal area in the building, prior to shutdown of that process in 1991. The items were present in the storage location for an indefinite period of time. Upon discovery, the certificate transferred the items to a DOE regulated storage area, in accordance with plant policy.
During follow-up, the inspectors noted that the certificate did not attempt to locate or account for miscellaneous items potentially containing HEU materials, including non-installed process components, as part of the closure for Compliance Plan issue A.4.
The certificalee informed the NRC of this issue,in a correspondence dated October 31, 1996 (Serial: GDP 96-0189). That correspondence documented that the certifica!ee had completed the necessary inventories to provide assurance that certification of the Portsmouth plant would not cause the total quantities of SNM contained in leased and certified areas to exceed NRC Category lli limits. The enclosure to the correspondence documented that the SNM inventories did not address a number of materials, including miscellaneous items potentially containing HEU materials, such as non-installed process components.
Portsmouth Complicnce Plan Issue A.4," Possession of Uranium Enriched to Greater Than 10 percent U235," dated August 1,1993, required, in part, that the disposition of all discrete items of HEU materials (except for a de minimis total quantity across all leased areas not to exceed 999 grams of U235), not associated with suspension and refeed programs, shall be achieved by physically transferring them to DOE regulated storage areas by the completion date of February 28,1997.
Portsmouth Gaseous Diffusion Certificate of Compliance Condition 8 required,in part, that the Corporation shall conduct its operations in accordance with the statements and representations contained in the Certification Application dated September 15,1995, and the revisions dated May 31,1996; and in the Compliance Plan submitted July 12, 15, and 18,1996, and the revision submitted August 1,1996.
Safety Analysis Report Sectbn 1.5, " Possession Limits," dated May 31,1996, described that possession limits for NRC-regulated special material were shown in Table 1-3 of the Safety Analysis Report. Table 1-3, Section C of the Safety Analysis Report, dated May 31,1996, required, in part, that the Portsmouth Plant shall only possess 1,000 grams of uranium enriched in isotope U-235 to greater than 20 percent and up to 98 percent by we,lght.
On April 6 the certificate discovered discrMe items of special nuclear material stored in Building X-326, not associated with the suspension and refeed programs, which resulted in the Certificate possessing more than 1,000 grams of uranium enrbhed in isotope U-235 to greater than 20 percent and up to 98 percent by weight. The possession of SNM which resulted in the exceedance of possession limits for a Category lil NRC facility is an Apparent Violation (eel 070-07002/98005-08).
c.
Conclusions The inspectors concluded that the certificate's discovery on April 12, of items containing highly enriched uranium, resulted in the certificate exceeding the material possession limits for a Category lli NRC facility. One apparent violation was identified.
20
E, S8 Miscellaneous Security and Safeguards issues l
S8.1 (Onen) VIO 70-7002/97008-04: Failure to take effective corrective actions to prevent l
recurrence of unauthorized Technical Safety Requirement overtime exceedances.
The inspectors reviewed applicable records to verify that the security force was in l
compliance with hours of work limitations of Technical Safety Requirement 3.2.2.b. The inspectors concluded that overtime for the minimum staffing positions required in l
Technical Safety Requirement Table 3.2.2-1 did not exceed the guidelines in Technica!
l Safety Requirement 3.2.2.b on a routine basis. For the few exceptions, authorization was received in advance as required.
This item will remain open pending the inspectors' review of the effectiveness of the certificate's management of overtime for the general work force.
F1.0 Conduct of Fire Protection Activities F1.1 Fire water storage Tank surveillance a.
Inspection scone (88102)
The inspectors observed fire protection surveillance activities to ensure compliance with the appropriate Technical Safety Requirements.
b.
Observations and Findings On March 20 while observing high pressure water tank drop testing to verify the automatic start capability of the fire water pumps, the inspectors noted that the fire water tank volume fell below the 270,000-gallon minimum volume required to be verified monthly by Technical Safety Requirement Surveillance 2.2.3.4.2 and 2.7.3.3.2. In addition, the inspectors observed that the certificate did not enter an LCO action statement for the fire water system. When the issue was brought to the attention of the PSS, the decision was made to enter the LCO.
1 The certificate subsequently performed a more formal evaluation which concluded that the LCO entry was required. In addition to the fact that the tank volume was below the minimum volume requirement, the basis for the certificate's conclusion was that during the test, three fire water pumps were tumed to the "off" position. As a result, the remaining fire water pumps would not have provided the 16,000 gallons per minute (gpm), minimum required flow rate required by Condition C of Technical Safety Requirements 2.2.3.4 and 2.7.3.3.
Upon further review of the observations in the field and the Technical Safety Requirements, the inspectors noted that the Technical Safety Requirement action statement allowed a completion time of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to restore fire water supply capability to above 16,000 gpm. On March 20 the certificate had restored the fire water supply capability in approximately one hour. The inspectors determined that the failure to enter l
the LCO constituted a violation of minor significance and is a Non-Cited Violation, consistent with Section IV of the NRC Enforcement Policy (NCV 070-07002/98005-l 09).
f 21
c.
Conclusions The inspectors concluded that in this instance, the failure to enter the LCO was of minor significance and constituted a non-cited violation. However, continued problems Wth the implementation of Technical Safety Requirements during maintenance and surveillance activities continued to be noted.
11.0 ' Conduct of Training Activities 11.1 Revleinn of On-the-Job Training Modules a.
Inanardian Smna (88010)
The inspectors reviewed the implementation of the on-the-job training (OJT) program.
l The review consisted of interviews with the training organization manager and selected plant staff, and reviews of training modules for the OJT program.
b.
Ohmarvations and Findings A significant portion of the training program at Portsmouth utilized the systems approach l
to training method, which consisted of job performance measures and qualification standards. However, the program also utilized OJT to provide plant staff the skills and qualifications necessary to perform job tasks in a safe and consistent manner.
Approximately 104 "OJT Guide" modules were approved for use and utilized for training plant staff at the time of the inspection.
As follow-up to the incorrect installation of a valve actuator on March 24 (see Section M1.1), the inspectors reviewed the qualification training maintenance l
mechanics received. On-the-Job Training Guide Module 02.07.21, " Repair Plug Valves and Actuators," was the task qualification a maintenance mechanic needed to complete l
prior to becoming qualified to work on plug valve actuators. Based upon interviews with i
the qualified mechanic who performed the actuator replacement on March 24, and a review of training records, the inspectors noted the mechanic was qualified and had attended the crew briefings conducted when changes were made to the maintenance procedure for the removal and installation of plug valve actuators. The inspectors were unable to draw any correlation between the maintenance activity performed on March 24 and an inadequacy in the maintenance mechanic's training.
However, the inspectors did note that Module 02.07.21 was created on February 15, 1995, and had only one revision made since origination. The revision, dated February 11,1998, included only minor pen and ink changes to correct procedure numbers, chemical names and acronyms. Concurrently, the applicable procedure for valve actuator removal, replacement, and installation (XP4-TE-MM4104) had four major revisions since February 1995.
Section lli of the OJT module included the practical requirements section, which detailed the basic skills and knowledge a trainee must demonstrate to an instructor, in order to complete the OJT module and become task qualified. The inspectors reviewed and compared the OJT module and the procedure history for actuator removal, replacement and installation. The inspectors noted and the Training Manager concurred that the practical requirements section of OJT Module 02.07.21 had not been updated to reflect the revisions of the actuator removal, replacement and installation procedure. Training 22 l
module updates and revisions, due to procedural changes, were required by Procedure XP2-TR-TR1030," Conduct of Training." The current practical requirements section for OJT Module 02.07.21 were based on the previous maintenance procedure (CMG-53),
and the module did not incorporate any of the current procedural changes. Several of the procedural changes were the result of both engineering notices and corrective actions for self-revealing events.
On April 8 the Training Manager placed an administrative hold on all training modules which used the OJT format, in order to review the remaining OJT modules to assess the I
I magnitude of the issue. An April 14 memorandum documented that of the 104 other j
1 training modules which utilized the OJT format: 21 OJT modules were current: 52 OJT modules were technically correct, but required minor pen and ink changes to reflect the latest procedure revision number; and,31 OJT modules required revision prior to release for use. Of the 31 OJT modules which required revision prior to release for use, l
16 OJT modules were covered by the Compliance Plan milestone for "AQ" training implementation (to be completed by June 30,1998); and,15 OJT modules were utilized prior to April 8 and required revision to update the module, prior to being released for use.
Technical Safety Requirement 3.9.1, required, in part, that written procedures shall be implemented for activities described in Safety Analysis Report, Section 6.11.4.1, and listed in Appendix A, to Safety Analysis Report, Section 6.11. Appendix A, to Safety Analysis Report, Section 6.11 required, in part, that Training activities shall be covered by written procedures. Procedure XP2-TR-TR1030, " Conduct of Training," Revision 0, Change C, dated December 31,1997, Section 6.6.1.J, " Developing and Approving l
Lesson Plans and Training Guides," required, in part, that the training group revise training modules when necessitated by procedure changes. Prior to April 8, the training group did not revise 16 OJT training modules when procedure changes required the I
training modules to be revised. Specifically, the training modules which were available for use and not revised after procedural changes were made are as follows:
MTM00.07.21; MTM02.10.20; MTM02.07.10; MTM09.20.38; MTM09.20.42; MTM09.20.32; MTM09.20.34; MTM09.20.43; MTM09.20.31; MTM09.20.30; MTM09.20.29; MTE08.01.10; MTl16.19.30; MTl09.03.30; MT108.01.30; and, MTl01.01.44. The failure to revise the training modules as required by the conduct of training procedure is a Technical Safety Requirement Violation (VIO 70-7002/98005-10).
c.
Concineinns The inspectors noted the OJT training module for actuator removal, replacement and installation had not been revised to reflect procedural changes. A review of OJT training modules by the training organization revealed that a total of 16 OJT training modules were not updated after procedural changes, as required by the conduct of training procedure. One violation was identified. In addition, the inspectors concluded there was no correlation between the incorrect installation of the actuator (see Section M1.1) and this training program violation, as the qualified mechanic who performed the work was trained on all the procedure revisions which were made since February 1995.
I I
23
V. ma-a=aament Meetings X1 Exit Meeting Summary i
The inspectors presented the inspection results to members of the plant staff and management at the conclusion of the inspection on April 20,22, and May 8,1998. Plant staff acknowledged the findings presented at the meeting. The inspectors asked the plant staff whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
1 l
l l
t i
l 24
s <.
PARTIAL LIST OF PERSONS CONTACTED Lockheed Martin Utility Services (LMUS)
- J. Anzelmo, Corrective Actions Manager
- M. Brown, Portsmouth General Manager
- S. Casto, Work Control Manager
- S. Fout, Operations Organization Manager
- M. Hasty, Engineering Organization Manager
- R. Lipfert, Training and Procedures Organization Manager
- J. Morgan, Enrichment Plant Manager
- P. Musser, Acting Maintenance Manager
- R. Smith, Acting Production Support Manager United States Enrichment Corporation (USEC)
- L. Fink, Safety, Safeguards and Quality Manager
- R. W. Gaston, Nuclear Regulatory Affairs Manager
- S. Martin, Nuclear Regulatory Affairs Specialist
- Denotes those present at the April 20,22 and May 8,1998, exit meetings.
INSPECTION PROCEDURES USED IP 88005:
Management Organization and Controls IP 88025:
Maintenance and Surveillance Activities IP 88010:
Operator Training and Retraining IP 88100:
Plant Operations IP 88102:
Surveillance Observations 25
ITEMS OPENED, CLOSED, AND DISCUSSED Opened 70-7002/98005-01 eel Procedural violation associated with communication between process services and cascade controller (EA-250) 70-7002/98005-02a,b eel 2 Examples of the failure to perform the Technical Safety Requirement LCO actions for Technical Safety Requirement 2.2.3.15 (EA-250) 70-7002/98005-03 URI Discrepancy between the safety analysis and the *See and Flee" policy 70-7002/98005-04 eel Operation of Autoclave No. 4 while containment valve FV-4 416X was operating incorrectly, Technical Safety Requirement 2.1.3.5 (EA-249) 70-7002/98005-05a,b eel Failure to perform Sections 8.2.12 and 8.2.24 of maintenance Procedure XP4-TE-MM4104 during the replacement of Valve FV-416X actuator (EA-249) l 70-7002/98005-06 eel Inadequate post-maintenance test instructions for replacement of the Valve FV-416X actuator (EA-249) i 70-7002/98005-07 eel Air-to-Close autoclave safety system components in l
Autoclaves 1 through 5 of Building X-343 unable to l
perform safety function under certain conditions, Technical Safety Requirement 2.1.3.5 (EA-249) 70-7002/98005-08 eel Certificate possessed more than 1,000 grams of uranium enriched in isotope U-235 to greater than 20 percent by weight (EA-251) 70-7002/98005-09 NCV Minor violation involving the failure to enter the LCO during fire protection maintenance activities 70-7002/98005-10 VIO Failure to revise the training modules as required by the conduct of training procedure Discussed 70-7002/97008-04 VIO Failure to take effective corrective actions to prevent recurrence of unauthorized Technical Safety Requirement overtime exceedances 70-7002/97015-01 VIO Dry active Waste (DAW) Bags Within Two Feet Of 1S Cylinders Closed None 26
mi..
l l
^
LIST OF ACRONYMS USED ACR Area Control Room CFR Code of Federal Regulations DAW Dry Active Waste l
DNMS Division of Nuclear Material Safety DOE Department of Energy gpm gallons per minute HEU Highly Enriched Uranium LCC Local Control Center l
LCO Limiting Condition for Operation l
LMUS Lockheed Martin Utility Services NCS Nuclear Criticality Safety NCSA Nuclear Criticality Safety Approval NCV Non-Cited Violation l
NRC Nuclear Regulatory Commission l
OJT On-the-Job-Training l
PDR Public Document Room ppm parts per million psia pounds per square inch absolute psig '
pounds per square inch gauge l
PSS Plant Shift Superintendent RCW Recirculating Cooling Water l
SNM Special Nuclear Material l
U-235 Uranium-235 l
UF, Uranium Hexafluoride UO,F, Uranyl Fluoride URI Unresolved item l
USEC United States Enrichmsnt Corporation VIO Violation l
l 1
i l
t 27