ML20248L787

Insp Rept 70-7001/98-05 on 980223-27.No Violations Noted. Major Areas Inspected:Plant Operations,Maint & Surveillance, Engineering & Plant Support

ML20248L787
Person / Time
Site:	07007001
Issue date:	03/17/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20248L782	List: ML20248L780 ML20248L787
References
70-7001-98-05, 70-7001-98-5, NUDOCS 9803240223
Download: ML20248L787 (11)

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U.S. NUCLEAR REGULATORY COMMISSION REGION lli Docket No: 70-7001 Certificate No: GDP-1 Inspection Report: 70-7001/98005(DNMS) l Facility Operator: United States Enrichment Corporation Facility Name: Paducah Gaseous Diffusion Plant Location: 5600 Hobbs Road P.O. Box 1410 Paducah,KY 42001 Dates: February 23-27,1998 inspector: C. A. Blanchard Fuel Cycle Ins.oector Approved By: Patrick L. Hiland, Chief Fuel Cycle Branch Division of Nuclear Materials safety I

9803240223 980317 PDR ADOCK 07007001 C PDR

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L EXECUTIVE

SUMMARY

United States Enrichment Corporation Paducah Gaseous Di#usion Plant NRC Inspection Report 70-7001/98005(DNMS)

Plant Operations

• The Process Building C-331, C-333, and C-337 operators interviewed did not appear to have a thorough understanding of the operating parameters for the freezer /sublimers (F/S). The inspector will monitor the certificate's corrective action to ensure that operators are knowledgeable of the F/S operation as an inspection followup item (IFl 70-7001/98005-01). (Section 04.1)

Maintenance and Surveillance e The addition of a pressure differential transmitter (PDT)-338 functional test, included in Procedure CP4-GP-lM6291, " Freezer / Sublimer recycle cooling water, Freon R-114, and Weight instrumentation Calibration and Functional Test," Revision 0, issued on February 13,1998, added an additional safety margin that the F/S alarm circuity will respond as designed. Selected PDT-338 calibration activities observed were conducted in accordance with specific procedures, and the instrument mechanics were knowledgeable of the F/S system. Pressure display colors and alarm settings on the operator control monitors (OCMs) were inconsistent between F/S and could be a human factors concem. (Section M1.0) e The monthly interim inspection for the 55-ton boom crane was conducted in accordance with procedural requirements. (Section M1.1) l Enaineerina e The plant operations review committee (PORC) members had a questioning attitude l conceming allissues discussed during the February 24, PORC meeting. The PORC l meeting observed was conducted in accordance with Technical Safety Requirements and Safety Analysis Report. (Section E7.1) e The nuclear criticality safety (NCS) training program was undergoing changes in implementation, and the method used to ensure that employees were current with required refresher NCS training relied heavily upon administrative controls.

(Section N4.1)

Plant Support e Cylinders in the Paducah tiger overpacks (PTOs) were loaded in accordance with approved procedures. The chemical operation first line manager (FLM) took appropriate action to stop the shipment of a PTO until a defective lock pin was replaced. The bill-of-laden and placarding for six randomly selected PTO shipments were completed in accordance with regulatory requirements. (Section A1.1) l 2

l-Report Details

1. Operations 04 Operator Knowledge and Performance 04.1' Ooerator Knowledae of Freezer /Sublimers System

a. Insoection Scope (88010)

The inspector discussed the operation of F/S with selected process building operators. In addition, the training manager explained operator F/S initial, continuing, and system l- approach training.

b. Observations and Findinas l The inspector discussed with operators from Process Buildings C-331, C-333, and C-337 the operation of the F/S. Operators explained that the F/S were controlled and operated from the area control room (ACR) in each process building, and the F/S main function was to contro'. uranium hexafluoride (UF.) inventory in the cascade to accommodate changes in the available electrical power. The inspector noted that six operators interviewed did not knew the normal operating range for the F/S Freon and recycle cooling water (RCW) systems, or the critical requirement to maintain F/S Freon system pressure greater than the RCW. The operators interviewed stated that initial F/S training covered operating temperatures and pressures for the F/S. Two Process Building C-331 operators stated that a F/S was rarely used in Process Building C-331, and subsequently the operators had forgotten the operating temperatures and pressures for the F/S systems. The operators interviewed explained that overall the operators would benefit from additional frequent F/S refresher training and more training on operating the F/S ACR control system.

The inspector discussed with the training manager the observation of the operators' limited knowledge concoming the F/S. In discussions with the inspector, the training manager explained that management expected operaters to know system operating pressures and temperatures and critical operating parameters of a cognizant system. In addition, a process building manager explained that ACR operators should know that they must maintain the Freon pressure above the RCW pressure, pressure and temperature alarm set-points for UF., Freon, and RCW, and the F/S UF capacity. The training manager stated that the operator training coordinator would reevaluate the frequency and content of F/S refresher training and ensure that ACR operators were current with required F/S training. The inspector will monitor the certificate's corrective action to ensure that operators are knowledgeable of the F/S operation as an inspection followup item (IFl 70-7001/98005-01),

c. Conclusions The Process Building C-331, C-333, and C-337 operators interviewed did not appear to have a thorough understanding of the operating parameters for the F/S.

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! 11. Maintenance and Surveillance M1.0 Conduct of Maintenance and Surveillance M1.1 - Annual Calibration of Buildina C-333 F/S Pressure Differential Transmitter 338

a. Inspection Scope (88025)

The inspector observed selected activities performed for the annual calibration of a j PDT-338 in Building C *,33. The inspector reviewed the required calibration i documentation, test equipment, rnd instrument mechanic actions required to perform a PDT-338 in-place calibration. In addition, the inspector performed a partial walkdown of a F/S system to observe the locations of the F/S RCW, R-114, and weight instrumentation. l l

b. Observations and Findinas j On February 26, the inspector observed the annual calibration of a PDT-338 in Building C-331. Technical Safety Requirement, Section 2.4.3, "i.imiting Control Settings, Limiting Conditions for Operation, Surveillance," and Section 3.11 " Nuclear Criticality Safety Program," address the surveillance requirements for the F/S high-high weight trip system and other "Q" components for the F/S system. The certificate developed and used Procedure CP4-GP-lM6291, " Freezer / Sublimer RCW, R-114, and Weight Instrumentation Calibration and Functional Test," Revision 0, to perform the annual calibration of the PDT-338. Procedure CP4-GP-lM6291, approved for use on February 13,1998, allowed instrument mechanics to perform the calibration of a PDT-338 either in the system or on a test stand but required calibration ambient conditions to be below 120-degrees Fahrenheit (F). In addition, the inspector noted that Procedure CP4-GP-lM6291, required a functional test for PDT-338 upon completion of the calibration as required for "Q" components. In discussions with the inspector, the i I

instrument mechanics explained that PDT-338 were calibrated in the test stand in Building C-333. The inspector observed that the PDT-338 test stand was located in an l air conditioned trailer adjacent to the ACR where the ambient temperature was  ;

approximately 75-degrees F during the PDT-338 calibration.

The inspector performed a walkdown of the RCW and Freon supply and retum piping to a F/S condenser-reboiler. The inspector noted the location of pressure transducer (PT)-308, which measures the F/S condenser-reboiler Freon pressure; PDT-339, which measures the RCW pressure drop across the F/S condenser-reboiler; and PDT-338, which measures the pressure differential between the RCW supply and Freon retum to F/S condenser-reboiler. The inspector observed that the instrument piping to the removed F/S instrumentation was adequately capped for foreign material exclusion and valves were appropriately tagged.

The inspector discussed the preparation and selected action steps for the calibration of the PDT-338 with two instrument mechanics. The inspector verified that the equipment used to perform the calibration of the PDT-338 was accurately recorded on Calibration D> cementation Sheet CP 21773," Calibration Data Sheet." The inspector verified that all equipment used during the PDT 338 calibration was within the calibration date. The inspector noted that the instrument mechanics knew what adjustments would bring the PDT-338 into the acceptable calibration range. The completed calibration results, 4

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[ recorded on Documentation Sheet CP-21773, " Calibration Data Sheet," documented that each required calibration pressure setting was on, or well within, the established acceptable pressure range.

The inspector reviewed selected functions of the F/S distribution process control system in the Building C-33? ACR with two instrument mechanics. The inspector observed that i the ACR's OCMs displayed schematics of the F/S systems. The maintenance mechanics demonstrated how an open PDT-338, PDT-339, or PT-308 circuit caused the OCM to display an off-scale negative pressure. The inspector noted that the OCMs displayed F/S pressures and temperatures in green when the systems were operating normally and red l

when the systems were operating outside the operating normal range. The inspector noted that the PDT-338 pressure display color was inconsistent between F/S for pressures greater than 30 psig. In a followup discussion with the inspector, the building manager explained that the two types of PDT-339 used had different operating pressure ranges. One of the PDT-339 used has a 0-100 psig range and the other PDT-339 has a 0-30 psig range. Therefore, the PDT-339 with a 0-30 psig range would display pressure reading in red above 30 psig while the other unit would display a pressure reading in green until the pressure difference exceeded 100 psig.

c. Conclusions j The addition of a PDT-338 functional test, included in Procedure CP4-GP-lM6291, added an additional safety margin that the F/S alarm circuity will respond as designed. Selected annual PDT-338 calibration activities observed were conducted in accordance with the specific procedures, and the instrument mechanics were knowledgeable of the F/S system. Pressure display colors and alarm settings on the OCMs were inconsistent between F/S and could be a human factors concem.

M1.1 Interim inspection of the SS-ton Boom Crane

a. Inspection Scope (88025)

The inspector reviewed selected aspects of an interim inspection for the 55-ton boom crane. The review consisted of interviews with the quality controii :Spectors and the comparison of observed activities with approved procedural requirements.

b. Observations and Findinas The inspector observed the monthly inspection on the 55-ton boom crane. Procedure CP4-TO-Ql1087, " Inspection and Testing of Mobile Cranes," requires the inspection of each item listed on the Form CP 19187," Mobile Crane Inspection Report, Appendix B."

The quality control inspectors identified chafed boom hydraulic lines and leaking seals on the front driver's side out-rigger hydraulic lifts. In discussions with the inspector, the quality control inspectors explained that the leaking seats were within the crane manufacture's acceptable leak rates and the chafed boom hydraulic line was only superficially damaged, therefore, the crane would not be taken out of service. In addition, the quality control inspectors visually inspected the super structure, boom, and carrier

structure for signs of welding fatigue and structural defects. The quality control i inspectors focused special attention on the condition of the crane hooks, hook block, and 5

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wire rope. The inspector verified that conditions observed by the quality control inspectors were accurately documented on the Form CP 19187.

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c. Conclusions l

The quality controlinspectors performed the monthly inspection of the 55-ton boom crane in accordance with procedural requirements.

Ill. Enoineerina E7 Quality Assurance in Engineering Activities E7.1 Plant Operations Review Committee l

a. Inspection Scope (88005)

The inspector attended a PORC meeting to compare selected activities observed with ,

SAR Section 6.2, " Safety Committee," and TSR Section 3.10 " Plant Operations Review

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Committee," requirements. I

b. Observation and Findinas On February 24, the inspector attended a PORC meeting to observe if activities conducted were in compliance with approved Procedure UE2-PO-OR1030, " Plant Operations Review Committee." The inspector n.oted that the PORC meeting consisted of the required chair person plus six chartered members from the areas of operations, engineering, NCS engineering, radiological safety, and quality assurance. The inspector j also noted that the meeting commenced at the preselected meeting time and followed the  !'

meeting agenda. Five procedural changes, throo new procedures, two SAR section changes, one justification to continue opfsrations, and two root cause investigations were addressed during the PORC meeting. Throughout the PORC meeting, the inspector observed that PORC members questioned changes and proposals in detail. The inspector observed that the PORC members did not approve the root cause investigation i for the incorrect installation of autoclaves electrical connectors because the investigation findings were not thorough enough nor conclusive. l

c. Conclusions The inspector observed that the PORC members had a questioning attitude conceming allissues discussed during the February 24, PORC meeting. The PORC meeting observed was conducted in accordance wi',h SAR and TSR requirements.

N4 Staff Training and Qualification on Nuclear Criticality Safety N4.1 Nuclear Criticality Refresher Trainina

a. Inspection Scope (88010)

The inspector reviewed the certificate's process for ensuring that NCS refresher training was current for employees.

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b. Observations and Findinas

On February 26, the inspector met with a training coordinator to discuss the certificate's l method for ensuring employees were current with required NCS refresher training. Safety Analysis Report, Section 6.6.1.2, " Continuing Training," stated, in part, that continuing training was provided for employees to improve job-related knowledge and skills and to promote safety, safeguards and security, and environmental protection awareness. The training coordinator explained that NCS training requires initial classroom training followed by refresher training every two years. The inspector noted that workers who use procedures containing nuclear criticality safety approval (NCSA) requirements receive additional NCS training. In addition, supervisors that direct work that contain NCSA requirements receive special supervisory NCS training.

The inspector reviewed the initial NCS training records for operators and maintenance l employees. Training records indicated that approximately 11 out of 323 operation employees had not received initial NCS training. In addition, the maintenance training records indicated that 3 out of 362 maintenance employees had not received initial NCS training. Further review of the operation and maintenance employees without initial NCS training indicated that seven of these employees were recently hired and scheduled for the initial NCS training. The other seven employees either were on extended sick leave of had transferred to another department that did not require NCS training.

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The inspector reviewed the refresher NCS training requirements and selected employee training records. Procedure CP2-EG-NS1030," Nuclear Criticality Safety Training,"

stated, in part, that the two-year cycle for NCS required refresher training begins after the e mployee completed initial NCS training. In addition, Procedure CP2-EG-NS1030, fillowed substitution of the dedicated NCS refresher training with another NCS training course, if the substitution NCS course included a review of general NCS procedural changes and past plant NCS issues.

The inspector questioned the training coordinator on how the certificate would ensure that employees were current with the NCS refresher training requirements. The training coordinator explained that the current method used to determine if employees were current with the required NCS refresher training was inefficient. The training coordinator explained that cognizant divisional training coordinators reviewed individual employee training records for employees who had received initial NCS training over two years ago, to verify that the employee had successfully completed another NCS training course within the past two years. In discussions with the inspector, the training manager stated that the certificate was developing dedicated divisional NCS refresher training courses which reviewed cognizant NCS issues and would aid in administratively controlling NCS refresher training. The inspector will monitor the certificate's progress in developing a dedicated NCS refresher training course and administratively ensuring that all employees receive the required refresher NCS training as an IFl (IFl 70-7001/98005-02).

c. Conclusions The inspector noted that the NCS training program was undergoing changes in  ;

implementation at the plant. The inspectors noted that the method used to ensure that l

employees were current with required refresher NCS training relied heavily upon i

administrative controls.

IV. Plant Support A1 Transportation Activities A1.1 Packmaina and Shioment of 10 ton Cylinders to Portsmouth l

a. Inspection Scope (86740)

The inspector observed the loading of 10-ton UF, cylinders into PTOs. The inspection l consisted of interviews with the chemical operations manager, FLM, and inspectors, and observing PTO 1rcspection activities.

! b. Observation and Findinas The inspector noted the type of equipment used to load 10-ton UF, cylinders into PTOs located on flat-bed trailers at the Building C-400 loading area. The chemical operation FLM explained that normally a 20-ton semi-gantry crane performed all loading and l unloading activities associated with packeging 10-ton cylinders on flat-bed trucks. The l chemical operation manager stated that the Building C-400 loading area's 20-ton l

semi-gantry crane was inoperable because of a defective hoist brake switch. The I

inspector observed that a 55-ton boom crane was used solely to remove and install the PTO lid, and a nuclear cylinder hauler (NCH)-35 was used to remove empty cylinders and full solid cylinders into the PTOs. The inspector verified that the 55-ton boom crane as l well as the NCH-35 mobile hauler inspection and testing records were current with the requirements of Procedure CP4-TO-Ql1087, " Inspection and Testing of Mobile Cranes."

The inspector observed selected activities associated with the inspection of six PTOs to ensure activities were conducted in accordance with Procedure CP4-CU-CH6433,

" Inspection of 10-Ton Cylinder type AF Protective Packages." The chemical operation inspectors donned the appropriate personal protective equipment (hard hats, leather j gloves, and wore thermoluminescent dosimeter) and never positioned themselves under the PTO lid or cylinder. The inspector observed that loading full solid cylinder into the -

PTO required several cylinder repositioning attempts before the cylinder was adequately positioned to allow the 1/4 to %-inch a required gap between the PTO lid and base at all four comers In addition, the chemical operation inspectors performed required PTO component inspections and removed interior PTO debris with a towel. The chemical operation inspectors identified a defective ball lock pin during one PTO inspection. ~ The site boundary manualidentified the PTO balllock pin as a "Q" item. The chemical  !

operation FLM appropriately notified the plant shift supervisor of the defective ball lock pin l who subsequently classified the PTO inoperable until the ball lock pin was replaced. The chemical operation FLM accurately identified the defective PTO ball lock pin on the required PTO Inspection Sheet CP-10633A. Approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after the PTO was declared inoperable, a mechanic replaced the PTO ball lock pin.

The inspector discussed the Building C-400 receiving pad condition with the chemical safety manager. The Building C-400 receiving pad was constructed of concrete, however, asphalt was used between the train rails. The condition of the concrete pad surface was smooth and in adequate condition. However, the inspector observed a small pile of broken concrete directly in the NCH-35 operating path. in addition, the inspector 8

identified several pot-holes and broken pieces of asphalt between the train rails. In discussions with the inspector, the chemical safety manager explained that personnel would remove the small pile of broken concrete and maintenance would repair the asphalt between the train rails. The inspector noted that the Building C-400 receiving pad '

l surface debris was removed the following moming and a problem report was issued to

! repair the asphalt during the inspection.

The inspector observed that the HP technician performed the required PTO and truck l radiation surveys. The HP technician monitored the six sides of the PTOs, the underside of the flat-bed trailers, and the truck cabs in accordance with Procedure

! CP4-HP-RP2105, " Surveys for Receipt and Shipment of Radioactive Material," and recorded the results on Form CP-20381, " incoming / Outgoing Tiger Pack Truck Cylinder Shipment Survey Results." In discussions with the inspector, the HP technician explained that the PTOs, flat-bed trailers, and the truck cabs radiation surveys, generally, were below the instrument detection limit of 0.25 mrem /hr which was significantly less than regulatory limits. The inspector noted that HP technician had recorded 0.25 mrem /hr radiation survey results as less than 0.25 mrem /hr on Form CP-20381.

The inspector determined that the certificate had completed required bill of lading transportation documentation and truck placarding in accordance with 49 CFR Part 173.

In discussions with the inspector, the package and transportation FLM demonstrated superior knowledde pertaining to the regulatory requirements of 10 CFR Part 71,

" Packaging and Transportation of Radioactive Material," and 49 CFR Part 173. The inspector noted that six trucks and trailers were appropriately placarded

c. Conclusions The inspector noted that the cylinders in the PTOs were loaded ir. accordance with

( approved procedures. The chemical operation first line manager (FLM) took appropriate action to stop the shipment of a PTO until a defective lock pin was replaced. The bill of lading and placarding for six randomly selected PTO shipments were completed in accordance with regulatory requirements.

IV. Management Meetings l

X1 Exit Meeting Summary The inspector presented the inspection results to members of the plant staff and management at the conclusion of the inspections on February 27,1998. The plant staff acknowledged the findings presented.

The certificate did not identify any of the information discussed at the meeting as proprietary.

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PARTIAL LIST OF PERSONS CONTACTED United States Enrichment Corporation (USEC) l

• S. Cowne, Nuclear Regulatory Affairs I

• J. Labarraque, Safety, Safeguards and Quality Manager Lockheed Martin Utility Services (LMUS) i l *D. Holt, Nuclear Regulatory Affairs l *R. Everett, Nuclear Regulatory Affairs

• H. Pulley, Enrichment Plant Manager

• S. Brawner, Training Manager

• D Couser, Portsmouth Training Manager 4

• K. Walker, Training

• D. Clayton, Training

• M. Sampson, Packaging and transportation

• W. Sykes, Corrective Actions Manager

• C. Shockley, Operations

• R. Green, Operations

• A. Canterbury, Nuclear Regulatory Affairs

• C. Hicks, Site and Facilities Support

• Denotes those present at the February 27,1998 exit meeting Other members of the plant staff were also contacted during the inspection perind.

INSPECTION PROCEDURES USED IP 88005 Management Organization and Controls IP 88025 Maintenance and Surveillance Activities IP 88010 Operator Training and Re-Training IP 86740 Transportation inspection Effort l

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ITEMS OPENED, CLOSED, AND DISCUSSED Opened 70-7001/98005-01 IFl Operators lack of knowledge conceming the operation of the freezer /sublimers.

'70-7001/98005-02 IFl Administrative control to ensure that employees receive nuclear criticality safety refresher training.

Discussed l

None l- Closed I None LIST OF ACRONYMS USED i

ACR- Area Control Room CFR Code of Federal Regulations DNMS Division of Nuclear Materials Safety F Fahrenheit i FLM First Line Manager SAR l&C Instrumentation and Control IFl Inspection Followup Item t LMUS Lockheed Martin Utility Services mrem milli-roentgens equivalent man NCH Nuclear Cylinder Hauler NCS Nuclear Criticality Safety NCSA Nuclear Criticality Safety Approval l .NRC Nuclear Regulatory Commission OCM Operation control monitor PDR Public Document Room PDT Pressure Differential Transducer PORC Plant Operation Review Committee psig gage pressure PT Pressu.e Transducer PTO Paducah Tiger Overpack RCW Recycle Cooling Water SAR Safety Analysis Report UF, Uranium Hexafluoride l

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