ML20248E784

Insp Rept 70-7002/98-08 on 980427-0508.Violations Noted. Major Areas Inspected:Operations,Maint & Surveillance, Engineering & Plant Support

ML20248E784
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant
Issue date:	05/29/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20248E772	List: ML20248E769 ML20248E775 ML20248E784
References
70-7002-98-08, 70-7002-98-8, NUDOCS 9806030447
Download: ML20248E784 (12)

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U.S. NUCLEAR REGULATORY COMMISSION REGION 111 Docket No.: 70-7002 Certificate No.: GDP-2 Report No.: 70-7002/98008(DNMS)

Facility Operator: United States Enrichment Corporation l

Facility Name: Portsmouth Gaseous Diffusion Plant Location: 3930 U.S. Route 23 South P.O. Box 628 Piketon, OH 45661 Dates: April 27 thru May 8,1998 Inspectors: C. A. Blanchard, Fuel Cycle Safety inspe .or K. G. O'Brien, Paducah Senior Resident i.1spector Approved by: Patrick L. Hiland, Chief i Fuel Cycle Branch Division of Nuclear Materials Safety 9006030447 980529 PDR ADOCK 07007002 ii C PDR 1

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EXECUTIVE

SUMMARY

United States Enrichment Corporation Portsmouth Gaseous Diffusion Plant NRC Inspection Report 70-7002/98008(DNMS) l Operations e The ir,spectors identified a violation that involved multiple examples of a failure to l propeny imp le mont some aspects of the plant training program. The examples were associated witn inadequate documentation of training requirements, inadequate initial training of individuals appointed to new positions, and inadequate control of individuals with deficient training qualifications. (Section 05.1)

Maintenance and Surveillance .

1 e The inspectors observed shift crane and lifting fixture inspections that were conducted an:i recorded in accordance with procedura! requirements. (Section M1.1) e Tiw 5spectors concluded that the certificate appears to have systematically engineered changes to correct the autoclave containment valve seat and stem leakage and the malfunction of the intemal autoclave and UF6 cylinder pressure transmitters.

(Section M2.1) e The inspectors concluded that the need for multiple revisions to Procedure XP4-TE-MM4722 and XP4-TE-MM4723 problems resulted from the certificate not physically verifying the assembly and disassembly steps with the actual valve during the development of these procedures. (Section M3.1)

Engineering

• The inspectors observed that the procedure review board (PRB) had a questioning attitude conceming all issues discussed during the April 29 meeting. However, the inspectors noted that the PRB efforts were diverted from ensuring that the breadth and depth of the actions imposed by the procedural change were adequately addressed to j correcting grammatical and minor technical errors. The April 29 PRB meeting was  :

conducted in accordance with Safety Analysis Report and Technical Safety Requirements. (Section E7.1)

Plant Support

e. The inspectors concluded that the certificate was retaining dosimetry records in accordance with Procedure XP4-HP-DS7102, " External Dosirnetry Records Management."

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{ Report Details L Operations 05 Operations Staff Training and Qualification 05.1 Training Raouirements and implementation j

a. Insonetinn Scone (88010) l l The inspectors reviewed the incorporation and implementation of operations-related training requirements, as specified in the Safety Analysis Repcrt, into plant procedures

and practices,

b. Observations and Findinas ,

The inspectors reviewed the system and records used by the plant training organization to document training requirements and completed training. The system included a matrix of training requirements, by position, and the current training status of individuals assigned to the respective positions. The system appeared well organized and comprehensive, however, many of the matrices had not been updated since 1996, j approximately a year prior to the NRC's assumption of regulatory oversight. Based upon  !

a sampling review of the matrices, the inspectors determined that some matrices did not I fully incorporate all Safety Analysis Report-required training. Specifically, the training matrices for the production support and nuclear safety managers did not include a requirement for nuclear criticality safety management training, a Safety Analysis Repcit-required training course. In addition, the general manager's training matrix did not include a requirement for basic radiation worker training, a training course necessary for unescorted access to radiologically controlled areas of the plant.

The inspectors also reviewed a monthly report, issued by the training organization to ,

plant managers, which documented the training status of all plant staff. Plant procedures l directed plant managers to use the report information to ensure that plant staff did not perform work following the expiration of required training. The report was distributed approximately one week prior to the end of the month and indicated training qualifications that expired at the end of the month, in 30 days, and in 60 days. During  ;

discussions with the training staff, the inspectors were informed that plant managers  !

were expected to review the training status of their staff and to issue work restriction memorandums for individuals with expired training requirements. This expectation was consistent with documented Safety Analysis Report and procedural requirements.

Based upon a cursory review of the most recent operations staff monthly training status i report, the inspectors determined the operations manager's training qualifications were less than the training matrix-specified minimum requirements for the position.

Specifically, the operations manager was either past due or had not received training in the areas of nuclear criticality safety for managers and technical safety requirements.

The inspectors noted that the current operations manager was appointed to the position on April 10,1998. Previously, the individual was the production support manager. The inspector compared the training requirements for the two positions and determined that the production support manager was not currently required to receive either the nuclear i criticality safety or technical safety requirements training.' However, the inspectors had previvusly determined that the production support manager's training matrix did not 3

ensure full compliance with the Safety Analysis Report and procedure-specified training requirements.

l The inspectors discussed the findings with plant management. Based upon an independent review of the findings, plant management concurred that the operations manager's training qualifications were less than the minimum training level specified in the training matrix. As a result, on May 6, the Enrichment Plant Manager issued a memorandum restricting the operations manager's activities in the areas of deficient training. The operations manager's responsibilities in the areas of nuclear criticality safety and technical safety requirements were subsequently delegated to other senior plant staff pending the operations manager's completion of the required training. The inspectors noted that the work restrictions memorandum should have been issued immediately following the April 23,1998, training organization transmittal of the most recent monthly training status report according to plant procedural requirements.

The inspectors performed a further sampling review of other newly transferred, hired, or

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temporarily assigned staff and identified additional deficiencies in the training qualifications for some individuals. The inspectors determined that plant management had not implemented work restrictions for the involved individuals prior to their appointment to the positions or following issuance of the most recent monthly training status reports. The inspectors communicated the additional findings to plant management for their review and action, as appropriate.

During followup discussions with the training manager, the inspectors were informed that work restrictions, placed on workers as a result of expired training qualifications, were not communicated back to the training organization following issuance of the monthly training status report. In addition, the training manager indicated that a previous spot check for the existence and use of work restriction memorandums by plant managers, conducted by the training organization, had identified that the system was not being fully implemented. The inspectors also noted that the last, most recent, internal quality assurance inspection of the training area did not evaluate the effectiveness of the current process. Finally, the inspectors concluded that the above findings were similar to training issues documented in NRC Inspection Report 70-7002/97013 and may indicate incompletely implemented or narrow corrective actions to the previous issues.

Technical Safety Requirement 3.9.1, requires, in part, that written procedures shall be implemented for activities described in the Safety Analysis Report. Safety Analysis Report, Section 6.6, " Training," describes training activities associated with the safe operation and management of the plant. Plant Procedure UE2-TR-TR1030," Conduct of Training," required, in part, that the organization managers: 1) develop and maintain training requirement matrices; 2) identify personnel requiring indoctrination and training who perform activities affecting quality; and,3) place work restrictions on or remove employees from duty where training is deficient. The managers' failure to: 1) as of May 5,1998, update (maintain) the training matrices for the production support and nuclear safety managers to include a requirement for nuclear criticality safety for managers training; 2) identify the newly appointed operations manager as an individual requiring indoctrination training in the areas of technical safety requirements and nuclear criticality safety for managers when appointed to the new position on April 10,1998; and,

3) the failure on April 23,1998, to place work restrictions on the newly appointed operations manager and the acting maintenance manager for the areas of deficient training is a Violation (70-7002/98006-01).

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c. Conclusions l l

The inspectors identified a violation that involved multiple examples of a failure to j properly implement some aspects of the plant training program. The examples were i associated with inadequate documentation of training requirements, inadequate initial l training of individuals appointed to new positions, and inadequate control of individuals with deficient training qualifications.

IL Maintenance and SurvellianCB I M1.0 Conduct of Maintenance and Surveillance M1.1 Building X-342 Crane and Lifting Fixture inspections 1

a. inspection Scope (88025) I i

The inspectors observed the inspection of lifting fixtures, interviewed UF6 handling j operators, and reviewed select crane and lifting fixture inspection records in {

Building X-342. j

b. Observations and Findings The inspectors observed Technical Safety Requirement 2.1.4.1, shift surveillance of UF6 slings and lihing fixtures. Technical Safety Requirement 2.1.4.1, required, in part, that operato;s inspect UF6 lifting fixtures prior to the first use during a shift. Procedure XP2-TE-TE6030," Inspection of UF6 Handling Cranes and Lifting Fixtures," Revision 2, dated i December 15,1997, provided instructions for inspection of UF6 handling cranes and lifting fixtures.

On April 22 the inspectors observed two Bui! ding X-344 operators who were inspecting crane and lifting fixture hooks, wire rope, and slings. The operators inspected the hooks for cracks, twisted, or abnormal throat openings. In addition, the inspectors noted that j the operators checked the alignment of the hook with the plane of the hook. The i operators checked the wire rope for broken wires, corrosion, kinks, and abnormal wear.

The operators inspecte,d the nylon slings for snags, punctures, tears, cuts, broken or .

worn stitches and the condition of the end fittings used for lifting UF6 cylinders. The i inspectors noted operators ensured that the lifting capacity and the next required load  !

test and visual test data was labeled and current on rigging equipment to be used during the shift period.

The inspectors discussed with operators precautions implemented before lifting UF6 cylinders in Building X-342. The operators explained that before a crane and associated ,

lifting fixture was used during a shift the operators performed an inspection using the l criteria established in " Overhead Crane Inspection Form," Appendix C, to Procedure  !

XP2-TE-TE6030. Additionally, the operators explained that operators would ensure that the lifting fixture capacity was sufficient for the load to be lifted and that the load and visual test were current prior to using a lifting fixture.

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1998. Procedure XP2-TE-TE6030, requires aperators to document the crane and lifting I fixture inspection on the " Overhead Crane inspection Form" each shift. The inspectors  ;

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observed that the " Overhead Crane inspection Form" was completed and appropriately approved by the First Line Manager (FLM) each shift during the month of March 1998.

c. Conclusions The inspectors observed that shift crane and lifting fixture inspections were conducted and recorded in accordance with procedural requirements.  ;

M2.0 Maintenance and Material Condition of Facilities and Equipment M2.1 Building X-342. X-343. and X-344 Autoclave Undata ,

a. Insoection Smne (8809M l

The inspectors reviewed select Building X-343, Autoclave No. 6 system upgrades with Compliance Plan DOE /ORO-2027/R3," Plan for Achieving Compliance with NRC i

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Regulations at the Portsmouth Gaseous Diffusion P! ant."

b. Observations and Findings The inspectors reviewed the system modifications to Building X-343, Autoclave No. 6. In discussion with the inspectors, the Autoclave No. 6 Project Engineer explained that the i autoclaves in Buildings X-342, X-343, and X-344 were Class I components under the NRC certification and that the certificate committed to imprnving the reliability and operation of the containment system. The certificate's commitment to upgrade the autoclaves was addressed in Compliance Plan DOE /ORO-2027/R3, issue No. 3.

The inspectors discussed with the Autoclave No. 6 Project Engineer the containment valves installed in Building X-343, Autoclave No. 6. The Autoclave No. 6 Project Engineer stated that existing safety system UF6 containment valves were quarter tum Teflon-sleeved plug velves that had a history of seat and stem leakage and were to be replaced with bellows seal globe valves, in addition, the inspectors leamed that the bellows seal globe valves have demonstrated reliable service in similar applications at the Portsmouth Gaseous Diffusion Plant (GDP) and in the autoclaves at the Paducah GDP. The inspectors confirmed that the containment bellows seal globe valves were installed in Building X-343, Autoclave No. 6 through review of the autoclave upgrade work packages and discussions with maintenance personnel.

Compliance Plan DOE /ORO-2027/R3, identified a certificate commitment to improve the accuracy of the intemal autoclave and UF6 cylinder pressure transmitters. In discussions with the inspectors, the Autoclave No. 6 Project Engineer, explained that the intemal autoclave and UF6 cylinder pressure transmitters were used to monitor the

- intemal autoclave and cylinder pressures. These transducers activated the safety system alarms. The Autoclave No. 6 Project Engineer, stated, that these transducer were malfunctioning causing a safety system alarm. The Autoclave No. 6 Project

! Engineer, stated, that the extreme temperature gradient experienced during the autoclave operation caused the transducers to fail. The inspectors noted that the instrument rnechanics had located the intemal autoclave and UF6 cylinder pressure transmitters outside the housing of Building X-343, Autoclave No. 6.

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c. Concinalnns t

l The inspectors concluded that the certificate appears to have systematically engineered changes to correct the autoclave containment valve seat and stem leakage and the malfuncika of the intemal autoclave and UF6 cylinder pressure transmitters.

M3 Maintenance Organization and Administration M3.1 Implementation of the Building X-343 Autoclave No. 6 Unarade Work Package

a. Insoection Senne (88025)

The inspectors reviewed the reasons for revising the new Building X-343, Autoclave No. 6 repair work procedures.

i b. Observations and Findings l

The inspectors reviewed the development evolution of Procedure XP4-TE-MM4722, "EG & G Valve Assembly and Disassembly" and Procedure XP-TE-MM4723," Rebuilding G.W. Dahl Valves." The Project Engineer explained that a contractor developed l Procedures XP4-TE-MM4722 and XP-TE-MM4723 using the vendor guidance supplied

! with the valve. In addition, the Project Engineer explained that the contractor did not l have either valve to physically verify disassembly and reassembly instruction. The inspectors noted that the certificate's initial procedural app oval included concurrence by the Nuclear Safety Manager, responsible functional manager, and Procedure Review l Group (PRC) Chairman. However, the Autoclave No. 6 Project Engineer explained that l during maintenance training a maintenance FLM identified that the approved and issued l Procedure XP4-TE-MM4722 did not specify the replacement of valve gaskets during i valve repair. In discussions with the inspectors, the Nuclear Maintenance Manager l l ' exp!ained that in general valve gaskets were replaced during valve repair. Additionally, Procedures XP4-TE-MM4722 and XP4-TE-MM4723 were revised after maintenance workers identified that the procedures did not specify a sequence for unbolting the valve bonnet to relieve the mechanical spring pressure prior to the bonnet removal. The  !

Autoclave No. 6 Project Engineer explained that both Procedures XP4-TE-MM4722 and i XP4-TE-MM4723 were revised again because maintenance workers found that limited access to the EG & G and G. W. Dahl valves did not allow the use of the specified measurement calipers during field training. The inspectors noted that the revision .

( evolution of Procedures XP4-TE-MM4722 and XP4-TE-MM4723 began approximately L one week prior to the certificate's May 1,1998, NRC commitment to upgrade Building X-343, Autoclave No. 6.

c. Concinnions The inspectors concluded that the need for multiple revisions to Procedure XP4-TE-MM4722 and XP4-TE-MM4723 resulted from the certificate not physically verifying the assembly and disassembly steps with the actual valve during the development of these procedures.

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liLEngineer]ng E7.0 Quality Assurance in Engineering Activitfes l E7.1 Plant Operations Review Committee

a. Insoection Scope (8800f)

The inspectors attended a procedure review board (PRB) rneeting to compare selected activities observed with Safety Analysis Report (SAR), Section 6.2," Safety Committee,"

and Technical Sasfety Requirement (TSR), Section 3.10, " Plant Operations Review Committee," requirements.

b. Observation and Findings On April 29 the inspectors attended a PRB meeting to observe if activities conducted were iri compliance with approved Procedure XP2-PS-PS1038, " Procedure Review Board." The inspectors noted that the PRB meeting consisted of the required chair person plus four chartered members from the areas of quality systems, nuclear regulatory affairs, nuclear criticality safety (NCS), and proouction support. The inspectors also noted that the meeting commenced at the preselected meeting time and followed the meeting agenda. Four procedural changes were addressed during the PRB meeting.

The inspectors observed that PRB members questioned changes and proposals in detail and identified several technical, grammatical, and spelling errors. The mgulatory affairs member identified that Procedure XP-2-GP-lM6031, "Model NCS-600 Neutron Criticality Alarm Cluster Insta!!ation and System Test," Revision 3, established the boundary from the cascade building at 500 feet instead of 200 feet during a criticality test. The inspectors observed that the PRB chairperson ensured that the secretary document each procedural issue discussed and designated who was responsible to address the issue. Additionally, the inspectors noted (nat the chairperson rephrased procedural changes to ensure that the discussed issue was accurately documented in the PRB meeting minutes. The inspectors verified that the published PRB meeting minutes accurately documented the issues discussed during the PRB.

c. Conclusions The inspectors observed that the PRB members had a questioning attitude conceming all issues discussed during the April 29 meeting. However, inspectors nnted that the PRB efforts were diverted from ensuring that the breadth and depth .oithe actions imposed by the procedural change were adequately addressed to correcting grammatical and minor technical errors. The PRB meeting observed was conducted in accordance with SAR and TSR requirements.

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l 1%.Elant Support l R3.0 Radiation Protection Procedures and Documentation R3.1 Review of Thermoluminascent DDSimater Record i i

a. Inspection Scope _@3B22)

The inspectnrs reviewed the process for analyzing Thermoluminescent Dosimeters  !

(TLDs) and maintaining dosimetry records, in addition, the inspectors reviewed select dosirnetryinvestigation records.

b. Observation and Findings i'

in discussions with the inspecters, the Health Physics Supervisor explained the method used to evaluate TLD results and maintain dosimetry records. The Health Physics Supervisor explained that on January 10,1998, the certificate began to use an independent contractor to analyze TLDs. Each TLD was bar coded with a unique employee number which was scanned into the TLD reader. The TLD reader analyzes the four elements in the TLD and electronically transfers glow curve data to a glow curve analyzer. The glow curve analyzer rejects erratic raw data which the independent contractor submits to the certificate. The Health Physics Supervisor explained that a dosimetry dose investigation was performed for each erratic TLD raw data reruit. The inspectors randomly selected four erratic TLD raw data results and verified that the certificate had performed the required dosimetry investigation. The raw data which met acceptable glow curve pa.'ameters was converted into deep, shallow, eye lens, photon, and neutron dose and electronically transferred to the certificate's health physics records system. The Health Physics Supervisor stated that if dose results exceed 100 mrem deep,300 mrem to the lens of the eye, or 1 rem shallow dose the certificate performed a dosimetry investigation.

The inspectors reviewed six dosimetry investigation records located in the certificate's Building X-1000 vault. The dosirnetry investigation records reviewed were assigned a

unique identification number, recorded in black ink, and signed by the Health Physics Supervisor and Health Physics Manager. The inspectors noted that lost dosimetry investigation records did not capture historical information concerning lost TLDs if subsequently the TLD was found in discussions with the inspectors, the Health Physics i manager stated that the as found condition and location of lost TLDs would be included in future dosimetry investigation reports.

c. Conclusions The inspectors concluded that tLe certificate was retaining dosimetry records in accordance with Procedure XP4-HP-DS7102, " External Dosiraetry Records Mar.agement."

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V. unnagement "cetings Xi Exit Meeting Summary The inspectors presented the inspection results to members of the plant staff and management on April 30 and May 8,1998. Plant staff acknowledged the findings presented at the two exit meetings. The inspectors asked the plant staff whether any materials exarnined during the

' inspection should be considered proprietary. No proprietary information was identified.

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PAP.TIAL LIST OF PERSONS CONTACTED Lockheed Madin Utilitv Services (LMUS)

• M. Brown, General Manager

• S. Casto, Work Control Manager {

• M. Conkel, Mechanical Cascade Maintenance Manager I

'D. Couser, Training Manager

• M. Hasty, Engineering Organization Manager

• R. Lipfert, Training and Procedures Organization Manager i

• R. McDermott, Operations Organization Manager f

• J. Oppy, Feed and Transfer Manager j

• D. Rogers, Work Control Manager

• R. Smith, Health Physics Manager

• T. Taulbee, Health Physics Operations Supentisor

• J. Thompson, Health Physics United States Enrichment Corporation (USEC)

• C. Blackston, Nuclear Regulatory Affairs Specialist ,

• L. Fink, Safety, Safeguards and Quality Manager j

• D. Waters, Nuclear Regulatory Affairs Manager

• Denotes those present at an exit meeting.

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1 INSPECTION PROCEDURES USED l

IP 88005: Management Organization and Controls IP 88025: Maintenance and Surveillance Activities IP 88010: Operator Training and Retraining IP 83822: Radiation Protection ITEMS OPENED, CLOSED, AND DISCUSSED Opened 70-7002/98008-01 VIO Inadequate documentation of trainir.g requirements, inadequate initial training of individuals appointai to new positions, and inadequate control of hdividuals with deficient training qualifications Closed None Discussed None 11

LIST OF ACRONYMS USED CFR Code of Federal Regulations DNMS Division of Nuclear Material Safety DOE Department of Energy FLM First Line Manager FME Foreign Material Exclusien GDP Gaseous Diffusion Plant LMUS Lockheed Martin Utility Services NCS Nuclear Criticality Safety NCV Non-Cited Violation NRC Nuclear Regulatory Commission PDR Public Document Room PGDP Paducah Gaseous Diffusion Plant PMT Post Maintenance Test PORC Plant Operations Review Group PORTS Portsmouth PR- Problem Report

'PRB Problem Review Board TLD Thermoluminescent Dosimeter UF6 Uranium Hexafluoride USEC United States Enrichment Corporation VIO Violation i

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