ML20248L437
| ML20248L437 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 06/05/1998 |
| From: | Ting P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20248L431 | List: |
| References | |
| 70-7002-98-204, NUDOCS 9806110158 | |
| Download: ML20248L437 (21) | |
Text
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. S UNITED STATES g
.g NUCLEAR REGULATORY COMMISSION
't WASHINGTON, D.C. 20555-0001 49.....,o OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS NUCLEAR CRITICALITY SAFETY INSPECTION REPORT REPORT NO:
70-7002/98-204 DOCKET NO:
70-7002 LICENSE NO:
GDP-2 LICENSEE:
United States Enriclunent Corporation Two Democracy Center 6903 Rockledge Drive Bethesda, MD 20817 l
FACILITY NAME:
Portsmouth Gaseous Diffusion Plant INSPECTION DATES:
February 9 - 18,1998 INSPECTORS:
J. R. Davis Team Leader NCS Engineer Fuel Cycle Operations Branch Y.11. Faraz, PORTS Projeu Manager Enrichment Section, Special Projects Branch APPROVED BY:
Philip ring, Chief Fuel Cycle Operations Branch Division of Fuel Cycle Safety and Safeguards, NMSS I
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l ENCLOSURE 2 9906110158 090605 l
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70-7002/93-204 y
t TABLE OF CONTENTS t
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' B A C K G R O U N D.......................................................... 1 l _
EXECUTIVE
SUMMARY
...............................................1 Introd uction........................................................ 1 M aj or Resu l ts........................................................ 1 RE PO RT D ETA I L S........................................................... 2 01.
COMPLI ANCE PLAN CLOSURE................................... 2 Complir.nce Plan Item 08............................................ 2 l
Compliance Plan Item 09................
...... 4 Compliance Plan Item 10.......................................... 5 Compliance Plan Item 23........................................... 6 S umm ary...................................................... 8 L
02.
PL ANT ACTIVITI ES............................................. 9 02.1 Plant Compliance with NCS Administrative Controls.............. 9 02.2 X-705 Microfiltration Spill................................... I 1 02.3 X-705 Calciner Incident..................................... 12 03.
NUCLEAR CRITICALITY SAFETY INSPECTIONS, AUDITS, AND INVESTIG ATION S.............................................. 14 04.
OTH E R....................................................... 1 6
. 04.1 NCS Corrective Action Plan Implementation, Acitivity D.8....... 16 04.2. Safety Analysis Report Discrepancies.......................... 17 ITEMS OPENED, CLOSED, AND DISCUSSED.................................... 17 MANAG EM ENT M EETING S............................................... 18 AC RON YM S U S ED........................................................ 19 j
i NMSS FCIS
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BACKGROUND i
i The Portsmouth Gaseous Diffusion Plant (PORTS) operated by the United States Enrichment Corporation (USEC) preduces enriched nuclear fuel feed stock (UF.) for use in commercial nuclear fuel fabrication plants. The normal process involves the receipt of solidified, natural and slightly enriched uranium hexafluoride from various sources. The material is converted to a gaseous state and fed into the cascade where it is enriched in the U-235 isotope to commercial nuclear fuel requirements. Facility capabilities also exist for the maintenance and upkep of process equipment, uranium scrap recovery operations, and various laboratory testing functions.
EXECUTIVE
SUMMARY
Introduction The Nuclear Regulatory Commission (NRC) performed an announced nuclear criticality safety inspection of the PORTS facility located in Piketon,011, from February 9 - 18,1998. The 3
objective of the inspection was to review the adequacy of USEC actions to close NCS-specific items in DOE /ORO-2027/R4," Plan for Achieving Compliance with NRC Regulations at the Portsmouth Gaseous Diffusion Plant," October 11,1996 (Compliance Plan). In addition, the inspection also focused on the implementation of corrective actions for previously identified violations and inspector follow-up items (IFI) related to nuclear criticality safety (NCS).
As a result of the inspection, one unresolved item (URI),4 IFIs, and one violation (VIO) were j
identified. These specific findings and areas of review are fully developed in the Report Details; the major conclusions are summarized below.
Major Results 1)
An unresolved item was opened to determine whether USEC could adequately demonstrate closure of Compliance Plan (CP) issues 8,9, and 23, and whether these findings may relate to a more generic issue concerning other CP items. [Section 1]
l 2)
An inspector follow-up item was identified to ensure that appropriate measures are taken to ensure acceptable staff performance in operating and maintaining the plant to ensure nuclear safety with respect to implementing NCS administrative controls. [Section 2.1]
3)
An inspector follow-up item was identified to ensure that edequate NCS controls are established for the X-705 Microfiltration Operation following the unanticipated process upset that occurred in February 1998. [Section 2.2]
4)
An inspector follow-up item was identified to ensure that sufficient actions are taken and adequate safety is established for the X-705 Calciner Operation following the unanticipated process upset in January 1998. [Section 2.3]
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A violaticn was identified in that management failed to identify NCS control failures and j
report such events to the NRC as required. (Section 3.0]
6)
A concern was identified involving the use of non-NCS engineers to provide NCS J
oversight on the operating floor in support of commitments made in the coraprehensive corrective action plan submitted to the NRC December 22,1997. The effectiveness of this NCS corrective action plan activity will be reviewed as an inspector follow-up item
[Section 4.01]
7)
An inspector follow-up item was identified to ensure that Safety Analysis Report (SAR) accident analyses discrepancies with regard to currere fissile operations are acceptably resolved. [Section 4.02]
REPORT DETAIM
- 01. COMPLIANCE PLAN CLOSURE a.
Scope The inspectors conducted discussions with USEC management and reviewed plant documents that were provided to demonstrate the completion of Compliance Plan Item 08," Nuclear Criticality Safety Approval Documents," CP 09," Nuclear Criticality Safety Appr. Jal Implementation," CP 10," Nuclear Criticality Safety Training for Managers," and portions of CP 23, " Plant Changes and Configuration Management" as related to NCS.
b.
Observations and Findings Compliance Plan Issue 08 The inspectors reviewed CP Issue 08 and nated that at the time when the Compliance Plan was prepared, operations were identified at the PORTS Plant for which (1) the nuclear criticality safety evaluations (NCSEs) were incomplete or formal documentation was unavailable or (2) the doub'e-contingency analysis or other criteria forming the basis for safety had not been fully documented in an NCSE.
As of September 1995, USEC reported that approximately 65% of the existing NCSEs had been redrafted to meet current NRC requirements, but the remaining NCSEs still required substantial revision and re-work (both analysis and field verification) to ensure that an adequate safety basis had been developed for the processes associated with these documents. USEC management committed to the completion, documentation, and approval of formal NCSEs for all existing operations by November 30,1996.
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USEC also identified deficiencies in the administrative aspects of the nuclear criticality l
safety program r' lated to compliance with ANSI /ANS-8 standards that had not been l
e proceduralized or documented. USEC committed to resolve the administrative noncompliance by November 30,1996.
The inspectors reviewed the completion evidence provided by USEC for this item. The documentation consisted of a cross reference of Facility Change Agreements (FCA) and Development Memorandums (DM) with currently existing NCSEs to identify adequate analysis for all fissile material operations (FMOs). Since it could not be demonstrated that all FMOs were covered by either an FCA or DM, management indicated that field walkdown reviews were conducted to confirm that all ongoing FMOs were identified and analyzed for NCS concerns. Internal memorandum, POEF-832-97-020," Closure of Compliance Plan item 70-7002/08, Nuclear Criticality Safety Approval Documents,"
January 28,1997, indicated all tasks (including field walk downs for unanalyzed operations) were completed, but provided no substantiating evidence to support this conclusion. Therefore, the inspectors requested plant management provide the reference documentation that supported this memorandum to independently confirm that all plant areas were covered. Ilowever, the inspectors were not provided and could not locate any field copies of the FMO walkdowns from the engineers, line management, or project management who were assigned to the task.
Discussions with the former NCS Manager and project manager who were responsible for this task indicated that the walk down engineers typically e-mailed them with the results and completion of each assigned area and that a few unanalyzed FMOs were discovered during these walk downs, llowever, since these e-mails could not be located by plant staff, the inspectors requested that internal plant problem reports be provided as evidence of unanalyzed FMOs that were identified during this time; none could be located by plant staff. It is worth noting that during the inspection, a spill of fissile solution had occurred at the Microfiltration area of the X-705 facility due to an air line in the system which had not been adequately addressed by the NCSE/NCSA for the process. The inspectors also note thc several Bulletin 91-01 event notification reports have been submitted to the NRC since the time of Compliance Plan issue 8 completion which detail discovery of unanalyzed FMOs.
Fmther discussions indicated that the average time to walk down an NCSE or a Nuclear Criticality Safety Approval (NCSA) associated with an FMO and confirm that all operations were in accordance with the descriptions, assumptions, and requirements was about one-half to one full day. The inspectors question whether this was a sufficient amount of time to adequately verify all of the dimensions, controls, and conditions that were assumed or analyzed in the NCSE matched the as-exists field conditions. For example, USEC letter, GDP 98-0053," Notification of a Change in a Regulatory Commitment," dated March 20,1998, indicates that recent USEC i
experience shows a substantially greater time is needed to complete the process for each NCSA. Further indications ofless than adequate reviews and walk downs is evidenced w ss icis fg
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by USEC letter, GDP 97-0217,"Ponsmouth Nuclear Criticality Safety Program Corrective Action Plan," dated December 22,1997, which was issued in part to address deficient reviews and walk downs of NCSEs/NCSAs.
The inspectors also reviewed supporting evidence for compliance with ANSI /ANS-8 standards as committed to in the Safety Analysis Report (SAR). The inspectors reviewed Plant Problem Report PTS-98-00694, dated January 30,1998, which identified the lack of proper programmatic controls to ensure that all applicable industry standards (e.g., ANSI /ANS-8 Standards] requirements are incorporated into the PORTS NCS program. It also found that Task #7 of the Revised Corrective Action Plan for the PORTS NCS Program had identified several ANSI requirements which were not properly incorporated into PORTS procedures or training. The inspectors also note that NRC Inspection Report 97013, dated February 4,1993, identified the failure to implement a basic requirement specified in ANSI /ANS 8.19-1984 as related to NCS.
Finally, the inspectors noted that the Manager, Nuclear Regulatory Affairs (NRA), the Manager, Engineering Organization, and the Manager, Nuclear Regulatory Assurance and Policy, approved completion of this compliance plan issue without the benefit of any evidence to support a walk down verification to ensure all FMOs were covered by a
an NCSE or to ensure that the administrative aspects of the NCS program were in compliance with the SAR. The files provided to the inspectors identified no completion / closure criteria or other quality assurance / quality control actions by USEC management to ensure that CP issue 08 was adequately completed.
Compliance Plan Issue 09 The inspectors reviewed CP Issue 09 and noted that USEC committed to establish a program to identify and verify the full implementation of all NCS conditions, specifications, and controls designated in the NCSAs for all FMOs prior to NRC assuming regulatory oversight. The inspectors reviewed randomly selected completion packages provided for this issue and determined that USEC utilized a checklist-driven walk down verification, a cross-matrix of applicable procedures, and a cross reference of active NCSAs with FCAs and DMs similar to work completed for CP issue 08.
During this review, the inspectors determined that the plant had previously identified 31 significant inconsistencies specific to the X-705 facility which resulted in shutdown of the facility until appropriate modifications were made and new or revised NCSAs were developed. According to the closure evidence dated March 14,1997, CP Issue 09 was considered completed with the caveat that upon completion of the NCSAs, procedures updates, and walk down verifications for the X-705 facility, supporting evidence would be added to the compliance plan evidence package.
The inspectors questioned the Manager of NRA if any of the X-705 facility operations had been restarted. The manager indicated that certain X-705 operations had been NMSS rCIS j
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l restarted, but did not have the start-up specifics of such operations. The inspectors later determined that the Oil & Grease Removal Unit, Tunnel, Microfiltration, Narth l
Turnover Pit, and Uranium Recovery all were restarted between April 24,1997 and l
August 1,1997, but no supporting evidence was added to the CP Issue 091iles that demonstrated completion of the required NCSAs, procedure revisions, and walkdown l
verifications. Further discussions with the Manager of NRA indicated that while he l
believed these actions were adequately completed, he did not know why the required j
information was not maintained as part of the CP issue 09 completion file. However, it i
is worth noting that the operational procedures for the Microfiltration area of the X-705 facility did not identify the valving for the air line system which resulted in the spill of l
fissile solution as discussed previously. Similar events were also reporte:1 duting the i
months of December,1997 and January,1998 in the same area.
Compliance Plan issue 09 states that implementation of NCS As is through training, procedures, and postings, and that first-line management is responsible for ensuring that employees understand the procedures and understand the NCS requirements before work begins, but it does not appear that this was effectively accomplished. USEC letter, GDP 97-0217,"Portsmouth Nuclear Criticality Safety Program Corrective Action Plan," dated December 22,1997, which was issued in part to address deficient reviews and walk downs of NCSEs/NCSAs further demonstrates this point. Finally, the inspectors also note that, similar to CP issue 08, no completion criteria or other quality assurance actions by USEC management to ensure adequate completion of CP !ssue 09 was identified.
Compliance Plan issue 10 The inspectors reviewed USEC's completion of CP issue 10, which committed USEC to (1) develop a list of managers with oversight of nuclear criticality safety issues who require NCS training, and (2) complete the designated NCS manager training by July 9,1996.
The inspectors were provided five attendance sheets identifying a total of 32 upper-l level PORTS managers and technical staff who were trained in a 4-hour training j
module entitled " Supervisory NCS for Managers," between March 4,1996, and April 3, j
1996. The attendance sheets indicated that all attendees passed the requisite exam. A l
note on the CP issue 10 completion form, dated March 31,1996, indicated that two I
managers (i.e., an NRA manager and the Plant manager) had not completed the i
requisite training, but were not required to do so since they were not in positions of l
NCS oversight. However, the inspectors note that an attendance sheet dated April 3, i
1996 indicated that the plant manager had in fact completed the training anyway.
Discussions with the training instructor and the former NCS Manager who were I
l responsible for this issue indicated that a list did exist at the time of the training. The former NCS Manager also indicated that additional managers and technical personnel, such as members of the Plant Operations Review Committee (PORC), who had not received NCS manager training were also added to the list. Therefore, although no documentation providing the criteria and describing the process ofidentifying NM%
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70-70023 8-204 organization managers required to be trained in NCS was found and no listing of the identified managers with respect to the entire management group was provided, it was not apparent that any managers requiring training failed to receive such training.
The inspectors reviewed the NCS supervisory course objectives, content, and instructor i
lesson plans and noted that discussion of the PORTS NCS safety basis (i.e.,
f NCSAs/NCSEs, flowdown of requirements to operating procedures, etc.) was absent j
from the course material. The inspectors also reviewed the NCS supervisory course
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exam and determined that the questions were basic and the degree of difficulty of the I
exam was low. The inspectors noted that for almost all questions which had "all of the above" as one of the four possible answers, the correct answer appeared to be "all of the j
above." The inspectors were also informed that the PORTS Training Department instructor who actually conducted the supervisory NCS training at the time, organized the subject training course in conjunction with the NCS Manager, by condensing the 12-hour NCS training course, required for other PORTS managers and personnel, into a 4-hour course. According to the training instructor and the former NCS Manager, this action was necessary to accommodate the tight schedules of upper level managers.
The inspectors note lhat the absence of discussion on the PORTS safety basis in the NCS supervisory training could have been a contributing factor to the issues identified with the flow down and implementation of NCS controls committed to under CP Issues 8 and 9. Although not a commitment in CP lssue 10, it is worth noting that the organi7ation managers trained under CP Issue 10 had not been retrained to the updated NCS training course which now includes a discussion of the PORTS safety authorization basis. The PORTS procedural requirement for NCS refresher training is once every two years. Therefore, although it appears that all individuals requiring NCS supervisory training received instruction, the inspectors questioned the effectiveness of such training in ensuring that managcrs who have oversight responsibilities in this area actually understand this functional area well enough to effectively perform their duties.
Compliance Plan Issue 23 (AQ-NCS SSCs)
The inspectors reviewed USEC's completion of the portion of CP Issue 23 pertaining to AQ-MCS E'SCs. Thir issue committed USEC to (1) review all NCSAs and NCSEs to ideatify AQ-NCS itrms which support the double contingency principle; (2) identify and document AQUCS system boundaries, including support systems required for performance of the intended safety function; and (3) verify the implementation of the commitments in (1) and (2) by February 28,1997. The inspectors reviewed a sampling of NCSAs/NCSEs and associated documents including NCSA-0705-015.A08,"V'aste Water Treatment (Microfiltration System)," NCSA-0326-015.A02, " Extended Range Product (ERP) Withdrawal Station," and the associated System Boundary Manual sections to determine if AQ-NCS items were adequately identified per this requirement.
The inspectors determined that SSCs being relied upon for NCS control at the X-705 Microfiltration Operation were not adequately identified as AQ-NCS.
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70-7002/984 04 Specifically, a February 9,1998, event notification report described a fissile solution spill.which was the result of a previously unanalyzed air blowdown mechanism that allowed some of the solution to by-pass its intended path and spill onto the floor. The blank plate and the air line valves were not identified as AQ-NCS even though they were being relied upon for NCS control. The inspectors also determined that the lids for unfavorable geometry containers used in this area and the rigid cover for the 55-gallon sludge collection drum were not identified as AQ-NCS in the Boundary Definition Manual even though the NCSA identified them as NCS controls for this area.
The inspectors also reviewed NCSA-0326-015.A02 and noted that several SSCs which are relied upon by USEC as NCS controls were not identified as AQ-NCS SSCs.
Specifically, the gamma and/or mass spectrometers used to determine product assay, the isolation block valve between the manifolds of ERP-1 and ERP-2 withdrawal loops which prevents a higher assay from inadvertently entering an unauthorized cylinder, pressure instrumentation used to ensure no moderator intrusion into fissile material i
occurs, and the cylinder cold pressure check instruments and/or the in-process Nuclear Materials Control and Accountability (NMC&A) scales used to indicate the presence of water in an empty product cylinder were not classified as AQ-NCS and were not identified in the boundary definition manual as requiring a greater degree of control.
Discussions with the Manager, Configuration Management (CM), indicated that in responding to an IFI in NRC Inspection Report 97-206, the CM group had considered the gamma and mass spectrometers used for product assay, but determined them to be non AQ-NCS. A memorandum, dated September 29,1997, to this effect was provided to the inspectors. However, this conclusion is inconsistent with the PORTS Safety i
Analysis Report (SAR), Section 4.2.2.2, " Criticality in Tails, ERP, or Product Withdrawal Facilities," which states that withdrawal assays are closely monitored for NCS considerations and that assay monitoring and verification provide assurances that the probability of a criticality accident at ERP is low. Also, the inspectors learned that the NCS organization was reconsidering this issue as a probable AQ-NCS control.
The inspectors note that a previous NRC violation identified a related issue in Inspection Report 97-203 which was completed in June 1997. The violation involved the failure to identify and control SSCs associated with moderator control of Planned Expeditious Handling (PEH) equipment as AQ-NCS. In a response letter, dated July 28,1997, USEC acknowledged the violation and determined the reason to be a lack of knowledge and experience in applying the criteria for determining AQ-NCS SSCs. On July 23,1997, USEC reclassified SSCs used for PEH handling and storage as AQ-NCS. They also organized a management briefing on July 25,1997, to notify NCS and Configuration Management engineers of the new classification. Corrective actions to prevent recurrence included a lessons learned session with Quality Boundary Evaluators / Engineers and NCS engineers on August 29,1997, to review procedure XP3-EG-EG1037," Establishing & Controlling Quality Boundaries," to improve the i
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knowledge base and experience level of personnel establishing quality boundaries and classifying equipment; however, the corrective actions did not include a review of all NCSEs/NCSAs to ensure a correct AQ-NCS classification of SSCs having NCS significance. As a result, the corrective action was not effective in preventing future i
occurrences as identified in this report.
i Although inadequate corrective action was previously identified in NRC Inspection Report 97013, this inadequacy is identified here only as further evidence that USEC was aware ofincomplete actions in this area and this information should have raised concerns with the adequacy of CP Issue 23 completion. In addition, the inspectors note that an NRC letter," Certificate Amendment Request - Portsmouth Gaseous Diffusion Plant Commitment to Identify Structures, Systems, and Components (SSCs) Necessary to Meet the Nuclear Criticality Safety (NCS) Double Contingency Principle (TAC No.
L32035)," dated December 12,1997, confirmed USEC's commitment to include identification of AQ-NCS SSCs as a TSR requirement.
l l
I Summary l
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The inspectors determined that USEC failed to develop adequate completion criteria or I
other quality controls per Certificate requirements or maintain sufficient documentation to demonstrate that Compliance Plan issues 08,09, and 23 were adequately addressed.
Although USEC is committed by Certificate to independently validate, track, appropriately verify, and document all regulatory-related corrective actions and commitments, no evidence of adequate senior management validation and verification of completed actions for Compliance Plan Issue 08,09, and 23 was found.
In addition, the inspectors raised a concern over the adequacy and scope of the NCS I
supervisory training, in that, it did not include a discussion of the PORTS NCS safety basis. The inspectors note that the absence of discussion on the PORTS safety basis in the NCS supervisory training could have been a contributing factor to the issues identified with the inadequate flow down and implementation of NCS controls committed to under CP Issues 8 and 9. Finally, it is worth noting that the organization managers trained under CP issue 10 have not been retrained to the updated NCS training course which includes a discussion of the current PORTS safety basis.
Determination of whether USEC could adequately demonstrate closure of Compliance Plan issues 8,9, and 23, and whether these findings may relate to a more generic issue concerning other Compliance Plan items, will be tracked as URI 70-7002/98-204-01.
c.
Conclusions The inspectors determined that Compliance Plan Issues 08,09, and 23 w cre not adequately completed by USEC in that they did not provide substantive evidence that commitments made by USEC were completed with appropriate rigor, formality, and Nuss reis
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70-7902/98 204 In addition, the inspectors raised concern over the adequacy and scope of the NCS sup rvisory training,in that, it did not include a discussion of the PORTS NCS safety basis which could have been a contributing factor to the issues identified with the inadequate flow down and implementation of NCS controls committed to under CP issues 8 and 9. These findings may point to a more generic issue concerning other Compliance j
Plan Items.
02.
PLANT ACTIVITIES 1
02.1 Elant_Conmliance with NCS Administrative Controls
- a. &_og Tia inspectors reviewed the Bulletin 91-01 event notification reports detailing NCS administrative control f ailures that were made to the NRC Operations Center during the time period of the inspection to determine why
- such events continued to occur and what impact it has on actual safety of plant operations.
b.
Observations and Findmgs i
During this inspection period, the Portsmouth Plant issued ten Bulletin 91-01 l
event notification reports to the NRC Operations Center detailing the loss of l
NCS administrative controls. The inspectors determined that these reports involved the failure to maintain NCS control over spacing, volume, geometry moderation, and mass / enrichment. Specifically:
- 1. EN33694, EN33691, EN33707, EN33738, EN33716, and EN33686 detailed failure of plant personnel to maintain spacing control between fissile materials including Dry Active Waste (. DAW), sample buggies, waste buckets, and seals and seal cans;
- 2. EN33727 detailed failure of plant personnel to maintain volume control by using an unauthorized mop bucket in the X-333 process building;
- 3. EN33734 detailed failure of plant personnel to maintain geometry control by not locking shut a drain valve for a sump reservoir in the X-333 process building as required;
- 4. EN33371 detailed failure of plant personnel to maintain mass / enrichment control by maintaining uncharacterized sample containers of l
decontamination solution residuals in the X-710 facility, and; NMSS rCIS
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- 5. EN33697 detailed failure of plant personnel to maintain moderation control by not storing groups of seals in approved seal cans.
The inspectors noted that some of the event reports detailed multiple NCS administrative control failures and one in particular (EN33686) identified 17 spacing failures in one building on the same day. Although these spacing violations were corrected when identified, the following day a similar spacing violation was identified in the same location indicating that additional raanagement attention is required to determine the breath and depth of this issue and to address this recurring problem.
Similar findings have been documented in NRC Inspection Reports97-203 and i
97012. Specifically,in a letter dated July 28,1997, USEC responded to the
- Notice of Violation identified in Inspection Recort 97-203. They committed to:
a) have NCS evaluate these issues and recommend changes to the Management i
Analysis and Assessment Team by September 12,1997; b) conduct shift
]
briefings with plant personnel to discuss the violations and corrective actions by September 12,1997; and c) develop an NCS bulletin to communicate important NCS issues by August 29,1997. Ilowever, these management actions were not effective in preventing repeat administrative control failures.
Although inadequate corrective actions was previously identified in NRC Inspection Report 97013,it is noted that the Plant's Comprehensive Corrective Action Plan, dated December 22,1997 in response to this report included three different root cause analyses that determined failure to follow procedure as the major contributing cause for identified NCS control failures.
The plan committed to correcting the root causes by June 30,1998, but did not identify any interim compensatory measures to ensure plant personnel understand and have the ability to comply with NCS administrative controls.
The PORTS plant has reported more than 100 violations of NCS controls, mostly dealing with NCS administrative control failures, since regulatory transition.
I The effectiveness of management to take appropriate measures needed to ensure acceptable performance of the staffin operating and maintaining the plant to ensure nuclear safety is identified as IFI 70-7002/98-204-02.
c.
Conclusions The inspectors determined that management has not been elTective in measures needed to ensure acceptable performance of the staffin implementing the administrative controls specified in various NCSEs/NCSAs and procedures or in addressing repetitive violations of these controls.
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GDP-2 11 70-7002/98-204 02.2 X-705 Microfiltration Sniil 1
a.
Scope The inspectors reviewed the circumstances and safety / risk significant concerns associated with a process upset condition that occurred at the Microfiltration process in the X-705 facility during the course of the inspection, b.
. Observations and Findings On February 9,1998, the inspectors were notified by plant personnel that a spill of fissile solution had occurred in the X-705 facility at approximately 1530 hours0.0177 days <br />0.425 hours <br />0.00253 weeks <br />5.82165e-4 months <br /> that day. The inspectors toured the spill area and reviewed the circumstances j
surrounding this event. Apparently, about 80 gallons of solation that was to be transferred from the T-102B Filter Feed Tank to the T-103 A Filter Feed Tank was inadvertently transferred to the "A" Filter Press and subsequently overflowed onto the high bay floor. While reviewing the incident, plant personnel discovered that two blow-down air valves in an air vent line were incorrectly positioned, which allowed the solution to backflow into the filter press. Further investigation revealed that the air line system had not been adequately addressed by the NCSA or the operating procedure. Although an unsafe geometry container was directly beneath j
the "A" Filter Press at the time of the event, the container had a rigid sealing-lid in place per NCSA requirements and the solution was not able to enter the container.
Post-event sampling also determined that the solution contained insufficient fissile material to cause a criticality concern.
The inspectors discussed the failure to establish and maintam adequate NCS controls with the Floor Supervisor for this process area. In discussing this event, it was leamed that several related issues had occurred during the past few months.
Specifically, a spill of approximately fifty gallons of solution had occurred at the T-101 storage tank in Microfiltration on December 15,1997, due to the efiluent treatment discharge valve switch having been erroneously placed in the transfer position. Further investigation revealed that a second control, that of the Hi-Hi cut-off probe, failed to activate when the solution reached an excessive level to prevent the overflow of solution onto the high bay floor.
The inspectors determined that when the switch is placed in the transfer position, the computerized pH control automatically adjusts the solution to desired settings and then automatically transfers batch quantities to the tank. Since the Hi-Hi probe is not relied upon as a safety system and the automatic batching of material to the tank was not expected, further analysis of the adequacy of the NCS control is warranted. This itera is identified as IFI 70-7002/98-204-03.
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The inspectors also learned of an additional event that occurred in the X-705 facility j
during the month of January 1998. While performing the initial startup steps for the Efiluent Microfiltration System Operation, plant personnel discovered that the effluent valve switch was mispositioned. Plant post-event review determined that the components associated with all of the valve.' switching erroc discussed above (other than the spill involving the blow-down air valves) were required by the facility's i
procedures to be checked prior to performing the required task, but apparently were not verified.
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l These incidents are ofconcern to the NRC because they rep.esent raultiple failures regarding the implementation of NCS controls. Specifically; l) they involve unanalyzed, deficient, or tmanticipated failure modes ths. should have been
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identified and corrected under Compliance Plan issue 8,9, and 23; and 2) represent j
a failure ofoperations personnel to comply with operational requirements. These incidents may indicate that there is a potentially significant perfonnance weakness regarding the implementation of system lineup activities required to assure the
. availability and reliability of NCS controls.
The issue of failure to appropriately analyze plant operations is another example of URI 70-7002/98-204-01. The second issue of operations personnel failure to l
comply with operational requirements is a continuing deficiency and previous corrective actions have been ineffective in correcting this problem it is identified as another example of IFI 70-7002/98-204-02.
I c.
Conclusions The incidents described above collectively represent a safety concern in that:
- 1) operators are not consistently complying with the requirements mandated by operational procedures; 2) despite efforts ;o identify and characterize the site's safety basis, unanalyzed, deficient, or unanticipated failure moces were not 1
identified umil after an incident had occurred; and 3) management controls and oversight have not been effi etive in identifying and preventing such degradations of the safety basis. These issues relate to the inadequate completion of CP issues 8,9 L
and 23.
02.3 X-705 Calciar.I.Jacikat t
a.
Scope The inspectors reviewed the circumstances and safety / risk significant concerns associated with a process upset condition that occurred in the Uranium Recovery Operation at the X-705 facility on January 27,1998, to determine if USEC had identified the failure mode and taken appropriate actions to prevent recurrence.
IcIs w ss OM'
i GDP-2 13 70-7002N8 204 b.
D.bgogions and Findines On February 9,1998, while investigating the circumstances surrounding the spill that l
occurred at the Microfiltration Process in X-705, it was brought to the attention of l
the NRC inspectors tnat an event involving the Numbei 2 Calciner in the Uranium Recovery Operation had occurred on January 27,1998. Apparently, while operating in Mode III (i.e., material being processed). an actuation of the Calciner Discharge j
Collector Probe Detection System occurred. At that time, feed to the calciner was I
automatically stopped and the unit began a cool down cycle as designed.
1 The detection probes are installed on the calciner discharge funnel to detect excess uranium buildup and initiate a shut down of the feed supply. Such action is necessary since the discharge funnels are not a safe geometric configuration for handling high assay uranium oxide if filled to maximum capacity or if unreacted concentrated solution filled the funnel. Originally, only one probe was used, but
)
due to an incident in February 1983, in which the level probe failed to actuate upon C. discharge funnel becoming plugged, two independent and redundant probes were cdded to the calciners.
)
l The NRC inspectors were concerned about this event because the plant had not j
conclusively determined why this incident occurred. Initially, it was suspected that a vent valve in the system may have plugged with uranyl nitrate crystals which established a vacuum causing the solution feed rate to overwhelm the calciner resulting in probe actuation. However, the plant had not ruled-out the possibility j
that the operator failed to follow procedure by allowing the feed rate to exceed the established limit. It is notewo: thy that the operator initially did not believe the alarm was rea! since spurious false alaans had occurred previously due to condensation buildup on the probes.
The inspectors followed up by reviewing the NCS analysis supporting the calciner operation and raised questions as to whether all potential scenatios were evaluated and whether sufficient interlocks existed for all modes of operation. The inspectors also raised questions as to whether other scenarios existed which could overwhelm the calciner with an excessive feed rate such that unreacted, concentrated solution would reach the discharge funnel even when the calciner is at operating temperature. Powever, since the operation was suspended pending a root cause determination, no immediate safety concern existed. The adequacy of USEC actions to ensure safety is established for the operation prior to restart, is identified as IFI 70-7002/98-204-04.
c.
Conclusions The inspectors reviewed the circumstances surrounding a safety system actuation involving calciner operations in the X-705 facility that occurred in Januat 1998.
NMSS Fels D[M
GDP.2 14 70-7002'98-204 The adequacy of USEC actions to determine a root cause and implementation of adequate controls to prevent recurrence will be tracked as IFl 70-7002/98-204-04.
03.
NUCLEAR CRITICALITY SAFETY INSPECTIONS AUDITS, AND INVESTIGATIONS a.
Scope The inspectors reviewed internal plant problem reports related to NCS to ensure that each was appropriately evaluated and that adequate actions were taken to ensure safety.
b.
Ohgryations anMindings The inspectors reviewed several internal plant problem repons detailing NCS related events that had occurred during the months of December 1997, and January 1998.
Specifically, problem report PTS-98-0580 detailed that the safety basis of several NCS contingencies identified in NCSA Plant-028 were inadequate. However, the justification / analysis section of the problem report indicated that NCS was aware of the problem, but no further actions had been taken to address the reconstitution of the safety basis to ensure safety of plant operations. However, when the Manager of Nuclear Safety was questioned by the inspectors concerning this situation, the problem report was reviewed and determined to be a four-hour reportable event.
Plant management subsequently issued a stop work order to prevent the removal and transport of Planned Expeditious Handling (PEH) equipment and reported the incident to the NRC on February 11,1998.
The inspectors also reviewed problem report PTS 97-10680 detailing a common-mode failure in an NCS contingency associated with the operation of the small parts pit in the X-705 facility. Although USEC stopped processing small parts at this location, they initially deterrnined that the operation involved no loss of NCS control, and therefore, did not identify it as a reportable event. Ilowever, once brought to the attention of the Nuclear Safety Manager, the event was re-evaluated and correctly reported to the NRC on February 11,1998.
Problem Report PTS-97-10519 detailing the December 1997 spill at the Microfiltration Operation in the X-705 facility (described earlier) did not recognize the fact that the spill from the safe geometry tanks to the Door was a loss of geometry control. Although post-event review determined that the spill did not represent an immediate safety issue it still constituted a loss of control since the floor is not being controlled. In other words, the floor area would have to be analyzed to ensure it was sufficiently la ge to handle a prescribed volume of fissile solution, was not appreciably sloped in any one direction and would have to be controlled such that no modifications such as dikes, drains, or large geometry vessels would be allowed in the area without NCS approval.
w ss i cis O
GDP-2 15 70-7002N8-204 l
i
- Although NRC Inspection Report 97012 previously identified similar problems with failure to report safety events to the NRC, USEC's corrective actions submitted on February 9,1998, did not adequately address all of the near-term root causes to prevent future occurrences of this type. Specifically, USEC did not recognize that plant NCS engineers were not correctly detemlining the difference between the "as-l-
found" safety basis and the loss of NCS control barriers. Rather, the root cause was incompletely determined to be a lack of rigor and conservatism by the Plant Shift Superintendent (PSS). The inspectors also note that many of the event reports that were submitted to the NRC lacked timeliness, risk-significance, substance, and did not consistently identify or recognize the actual controls lost or what controls remained in place.
Certificate of Compliance, Condition 9, requires, in part, that "The United States Enrichment Corporation shall conduct its operations in accordance with the Technical Safety Requirements that are contained in Volume 4... of the Application..."
TSR 3.11, requires, in part, that "a Criticality Safety Program shall be established, implemented, and maintained as described in the Safety Analysis Report and shall address... nuclear criticality safety responsibilities." SAR Section 5.2.2.2 states, in part, that... NCS engineers are responsible for... advising appropriate management j
i
. of any NCS concems.. "
.(
Contrary to the above,'as of February 18,1998, NCS engineers did not advise l
appropriate management of NCS concerns, in that they did not recognize that j
abnormal conditions described in facility problem reports constituted the loss of approved NCS control baniers and, as such, did not advise appropriate management of the NCS problem. This is identified as Violation 70-7002/98-204-05.
c.
Conclusions l
i The inspectors determined that management has not been able to consistently identify NCS control failures and report such events to the NRC as required. Specifically, management did not recognize that plant NCS engineers were not correctly determining the difference between the "as-found" safety basis and the loss of NCS
[
control barriers. Fvents that have been reported to the NRC have lacked timeliness, risk-significance, substance, and have not consistently identified or recognized the actual controls lost or what controls remained in place, l
p p
L miss rcis
GDP 2 16 70 7002/93-204 04.
OTHER j
04.01 NCS Corrective Action Plan Implementation. Activity D.8 a.
Scope j
The inspectors reviewed the implementation of USEC's commitment to provide NCS oversight on the operating floor as a compensatory measure until adequate corrective actions can be taken with regard to NCS program development and implementation.
b.
Observations and Findines I
USEC committed to provide NCS oversight on the operating floor to ensure continued heightened awareness of the importance of NCS controls as an interim compensatory measure as part of their comprehensive NCS.
Corrective Action Plan submitted to the NRC on December 22,1997.
Discussions with the Manager, Nuclear Safety indicated that the NCS l
oversight is being provided by non-NCS engineers. Specifically, Health l
Protection (HP) and Operations personnel are being used to provide NCS oversight that have not received specific NCS training for the particular operational environment to which they are expected to provide advise. The inspectors note that even if these individuals receive specific NCS training for their operational area, such actions do not provide the same level of NCS oversight that would be provided by qualified NCS engineers since the operators and HP technicians lack the detailed experience, knowledge, and background that is afforded by extensive study, familiarity, and interactions in the NCS field. Therefore, the effectiveness of this NCS Corrective Action Plan activity will be followed as IFI 70-7002/98-204-06.
c.
Conclusions A concern was identified relating to the effective use of non-NCS engineers to provide NCS oversight on the operating floors to support commitments made to the NRC in the December 22,1997, Corrective Action Report.
04.02 Safety Analysis Report (SAR) Discrepancies a.
Scope
{
The inspectors reviewed the SAR to determine if accident analysis adequately represented the current operation.
~
suss reis
GDP.2 17 70-7002N>8-204 l
b.
Observations and Findings The inspectors identified a need for updating the SAR accident analysis to reflect current assay limits for cascade operations in building X-330 and I
X-333. Suspension of high enriched uranium (HEU) production at PORTS has resulted in increases in enrichment levels in portions of X-330 and X-333 process piping. However, the inspectors noted that some of the criticality scenario descriptions in the accident analysis section of the SAR (Chapter 4) are still based on the lower assay limitations from the time of IIEU production. For example, cases C-17," Criticality in X-333,8-inch Cold Traps," and C-19," Criticality in X-333,24-inch Aluminum Traps" consider uranium assay limitations that are below the levels currently authorized by Technical Safety Requirements (TSR). Such observations were brought to the attention of the Manager, Nuclear Safety for resolution.
l Adequate representation of SAR accident scenarios is identified as IFI 70-7002/98-204-07.
c.
Conclusions The inspectors identified discrepancies in the SAR accident analysis assumptions which do not adequately represent current fissile operations.
l The PORTS Nuclear Safety Manager was informed of the discrepancies for resciution.
1 ITEMS OPENED. CLOSED. AND DISCUSSED Opened URI 70-7002/98-204-01 An unresolved item was opened to determine whether USEC could adequately demonstrate closure of Compliance Plan (CP) Issues 8,9, and 23, and j
whether these findings relate to a more generic i
issue concerning other CP items.
1 IFI 70-7002/98-204-02 Review and follow up to determine the effectiveness of management to take appropriate measures to ensure acceptable staff performance in operating and maintaining the plant to ensure nuclear safety.
IFI 70-7002/98-204-03 Review and follow up to ensure that adequate NCS
(
controls are established for the X-705 Microfiltration Process.
l l
NMSS l' cts
a cor.2 is 70-7002/98-204 IFI 70-7002/98-204-04 Review and follow up to ensure that sufficient actions are taken and adequate safety is established for the X-705 Calciner Operation.
VIO 70-7002/98-204-05 Failure to identify NCS control failures and report such events to the NRC as required.
IFI 70-7002/98-204-06 Review and follow-up to ensure the effectiveness of using non-NCS engineers to provide NCS oversight on the operating floor in relation to the December 1997 NCS Corrective Action Plan.
IFI 70-7002/98-204-07 Review and follow up to ensure that SAR accident analyses discrepancies are adequately addressed.
1 Chuicd No NRC-identified issues were closed during this inspection.
MANAGEMENT MEETINGS j
j Exit Meeting Summary The NRC Inspection Team met with PORTS management throughout the inspection. An exit meeting was held on February 18,1998. No classified or proprietary information was identified.
The following is a partial list of exit meeting attendees:
Eensmouth Gaseous Diffusion Plant Jim Morgan, Acting Plant Manager Mark Hasty, Engineering Manager Dan Wilczynski, Nuclear Safety Manager Sandy Fout, Production Support Manager l
United States Enrichment Corporation James Miller, Vice Present Production, (by teleconference) l Ron Gaston, Nuclear Regulatory Affairs Sid Manin, Nuclear Regulatory Affairs Lee Fink, Safety, Safeguards & Quality NMSS FCIS 1
1
____-__---__--_a
GDP-2 19 70-7002/98-204 1e
.Qgpartment of Energy John Orrison Nuclear Regulatory Commission Jack Davis, Team Leader, Nuclear Criticality Safety, NRC Headquarters Yawar Faraz, PORTS Project Manager, NRC Headquarters David Hartland, PORTS Senior Resident Inspector ACRONYMS USED AQ-NCS................................. Augmented Quality-Nuclear Criticality Safety C F R.......................
..... Code of Federal Regulations CM.......................................
.. C mfiguration Management CP.........................
............. Compliance Plan DA W.............
..... Dry Activated Waste DM..................
.................. Development Memorandum
{
DOE............
... Department of Energy ERP........................................... Extended Range Product Withdrawal FCA................................................ Facility Change Agreement FMO..............................
... Fissile Material Operation H EU................................................... H i gh Enri ched U ran i u m H P........................................................... H ealth Protec tio n i
HQ........................................................ H eadq uarters (N RC)
IFI................................................... Inspector Follow up Item NCS.................................................
Nuclear Criticality Safety NCSA.......................................... Nuclear Criticality Safety Approval NCSE........................................... Nuclear Criticality Safety Evaluation NMC&A........
....................... Nuclear Materials Control and Accountability i
NRA.................................................. Nuclear Regulatory AfTairs NRC.....
.... Nuclear Regulatory Commission PEH.............................................. Planned Expeditious Handling PORC........................................... Plant Operations Review Committee 19RTS........................................ Portsmouth Gaseous Diff usion Plant PS S...................................................... Plant Shift Superintendent P C W................................................. Recirculating Cooling Water S AR...................................................... Safety Analysis Report TSR.................................................. Technical Safety Requirement UF6........................................................ Uranium Hexafluoride l
URI...........................................
............. Unresolved Item USEC.......
................. United States Enrichment Corporation i
I NMSS I Cth