ML20248L929

Insp Rept 70-7001/98-02 on 980120-30.Violations Noted.Major Areas Inspected:Engineering,Maint & Surveillance,Plant Support,Training Program & QA Program

ML20248L929
Person / Time
Site:	07007001
Issue date:	02/26/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20248L922	List: ML20248L929
References
70-7001-98-02, 70-7001-98-2, NUDOCS 9803250037
Download: ML20248L929 (13)

Text

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U.S. NUCLEAR REGULATORY COMMISSION R E GIO N lil Docket No: 070-07001 Certificate No: GDP-1 Inspection Report No: 070-07001/98002(DNMS)

Facility Operator. l United States Enrichment Corporation i l

Facility Name: Paducah Gaseous Diffusion Plant Location: 5600 Hobbs Road P.O. Box 1410 Paducah, KY 42001 Dates: January 20 - 30, 1998 Inspector: R. G. Krsek l Fuel Cycle inspector Approved By: Patrick L. Hiland, Chief Fuel Cycle Branch Division of Nuclear Materials Safety i

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l 9003250037 900226

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ADOCK 07007001 l PDR

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EXECUTIVE

SUMMARY

United States Enrichment Corporation l Paducah Gaseous Diffusion Plant NRC Inspection Report 070-07001/98002(DNMS) j Enaineerina The certificant continued to address the issues conceming the design and surveillance of the levelator rail stop system in Building C-360, which was declared inoperable in October 1997. The certificant had taken prompt corrective actions in response to the Unresolved item identified in Inspection Report 070-07001/97012, and the inspector will continue to track the resolution of this issue. (Section E1.1) ,

I fAaintenance and Surveillance f The inspector observed post maintenance testing and a criticality accident alarm j system calibration during the inspection. The work activities observed were l completed in accordance with the maintenance work packages and applicable l procedures. Good communication practices were noted amongst plant staff during {

l observed maintenance and calibration activities. (Sections M1.1 and M1.2)

Plant Support 1 Trainina Proaram The inspector noted that the training program at the plant was undergoing changes both in organization and implementation. The inspector identified that training staff were unaware of certain procedures management requirements. As a result, training j procedures were placed on hold, and in certain cases tasks within the procedure were not stopped as required by the procedures management program. One violation was identified. (Section T1.1)

Quality Assurance Prooram

• The inspector reviewed the certificant's actions in response to an Unresolved item identified in inspection Report 070-07001/97009. The inspector concluded that a j final review of the 10 CFR 76.68 plant change for the current Quality Assurance Plan and the revised Quality Assurance Plan, will be conducted upon completion of these activities by plant staff. (Saction Q1.1)

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Report Details [ .

1. Enaineerina-E1.0 Conduct of Engineering ,

- E1.1 Buildina C-360 Levelator Rail Stoos y.

a. Inspection Scope (88020)

The inspector reviewed actions the certificant took in response to an Unresolved item (URI) identified in inspection Report 070-07001/97012, dated November 26, 1997. The URI addressed the adequacy of the current quarterly surveillance for the rail stops, and the review of the original design documentation for the levelator rail stop system.

b. Observations and Findinas inspection Report 070-07001/97012, documented the identification of an URI for the Building C-360 levelator rail stops. The URI add,ressed a potential inadequacy with the quarterly rail stop surveillance, and ' addressed the need to review the appropriate design documentation for the rail stop system. The certificant also acknowledged at the exit meeting that the design documentation for the rail stops was not readily available. During the inspection, the Building C-360 Manager declared the levelator inoperable.

The certificant conducted a records search and was unable to identify any design documentation regarding the design basis of the Building C-360 levelator stops.

Therefore, the Design Engineering Organization performed design and analysis calculations (DAC) for the as-found rail stops in Building C-360. The DACs were documented under Engineering Service Order Z99380, CALC No. DAC-815-19938-0001. The DAC investigation of the adequacy of the existing levelator rail stops determined that the rail stops would be inadequate for stopping a scale cart carrying a fullliquid cylinder traveling at the scale cart maximum velocity of 12-inches per second.

Subsequently, DAC-815-19938-0002 was initiated to modify the levelator rail stops to ensure the rail stops would prevent a scale cart, carrying a full liquid cylinder at maximum velocity, from accidentally rolling off the end of the levelator platform to the floor below, a distance of approximately four-feet. The DAC proposed two modifications to the existing system: 1) the attachment of commercial shock absorbing attachments to the scale cart; and,2) the attachment of structural members to the levelator platform as required to absorb the impact from the commercial shock absorbing attachments mounted on the scale cart. The modifications to the Building C-360 levelator were scheduled to be completed by the l end of February 1998.

The inspector discussed this URI and the developments since the last inspection I

with the Manager of Design Engineering, the design engineer, and a nuclear safety analysis engineer. Plant staff also presented and discussed the 10 CFR 76.68 plant change reviews and request for application change which were processed in conjunction with the scheduled system modifications. The plant staff noted that the system description contained in Safety Analysis Report (SAR), Section 3.6.9.1,

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"[ Building C-360] Scalas, Scab Carts, Hydraulic Lift and Elsvator," for tha rail stops st:tss, in pirt, thtt tha rail stops ara providad on tha outborrd sida of the platform to prevent rolling of the scale cart during rnovement of the [levelator] platform. In addition, SAR Section 3.15.1.4.13, "[ Building) C-360 Hydraulic Lifts," identifies the "Q" system boundary, with the same scenario of rolling of the scale cart during movement of the platform. However, the inspector noted that Technical Safety Requirement Design Feature (TSRDF) 2.1.5.8, states, in part, that the rail stops on the levelator prevent rolling the scale cart and the carried cylinder "off" the end of the lift. Facility staff concluded that the original rail stop design, as described in SAR Sections 3.6.9.1 and 3.15.1.4.13, did not include, nor account for the scenario of the actual scale cart movement onto the levelator platform. In other words, the TSRDF did not describe the function of the rail stops in preventing scale cart " roll-off" during the vertical movement of the levelator platform. The plant staff is presently evaluating the differences noted between the SAR descriptions and the TSRDF requirements.

The adequacy of the DAC for the levelator rail stops and the certificant efforts in resolving the technical differences between the SAR and the TSRDF is currently under review by the NRC.

During the inspection two Long Term Orders were in effect to prevent the use of the l Building C-360 levelator platform. Long Term Order 97-004 declared the levelator at Building C-360 inoperable and required flagging in front of the levelator, with no movement of scale carts beyond the flagging. The levelator could not be used for the movement of cylinders, liquid or solid, until the levelator rail stops were modified

- and Long Term Order 97-004 closed. Long Term Order 97-005 required that no liquid cylinders be placed on the Building C-360 scale carts. The inspector verified that the operators in Building C-360 were aware of the Long Term Orders, that appropriate flagging was in place around the levelator, and that the levelator was not used for the movement of any cylinders. In addition, the as-found rail stops were still in place and would not be removed nor inspected unti! modification work began on the Building C-360 levelator. Plant staff agreed to provide the NRC with inspection documentation, if the as-found rail stops were examined either visually or through non-destructive analysis, for system integrity upon removal.

c. Conclusions The certificant continued to actively address the issues raised in Inspection Report 070-07001/97012, conceming the design and surveillance of the levelator rail stop system in Building C-360. The levelator, decta:ed inoperable since NRC Inspection 070-07001/97012, was to remain inoperable until a newly designed and manufactured rail stop system was installed. The inspector will continue to track the resolution of this issue.

11. Maintenance and Surveillance M1.0 Conduct of Maintenance and Surveillance M1.1 Annual Testina of Buildina C-333A Autoclave Manual isolation System I

a. Inspection Scope (88025) iv

The inspector observed the annual testing of the autoclave manual isolation system for the eight autoclaves in Building C-333A. In addition, the corresponding maintenance work package and functional test procedure were reviewed for accuracy and completeness with regard to the operations which were performed.

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b. Observations and Findinas The inspector observed annual testing of the autoclave manual isolation system, which was performed as the final post maintenance test (PMT) of maintenance work package 9800364-05 for the autoclaves in Building C-333A. The autoclave manual isolation system actuation devices were tested for all eight autoclaves in Building C-(

333A. The actions for performing the PMT were specified in Procedure CP4-CO-CN6073, " Testing of C-333A/C-337A Autoclave Manual isolation System," and were performed by operations staff.

The inspector attended the pre-job briefing with the operations supervisor and staff and observed the specific actions taken by operations staff during the PMT. The inspector noted that all the appropriate " Prerequisites," were implemented and reviewed prior to the start of the PMT, as required by Procedure CP4-CO-CN6073.

Operations staff performed all the action steps of Procedure CP4-CO-CN6073, specified in the maintenance work package, and the inspector noted good communications between the operations staff, the operations supervisor, and other site staff involved in the completion of the PMT. Post-performance work activities were also conducted in accordance with Procedure CP4-CO-CN6073, and the autoclave manual isolation system test data sheet was current, and completed as required. The PMT was completed successfully, with no discrepancies in either the performance of equipment during the PMT, or the completion of the PMT by operations staff.

The inspector reviewed the completed maintenance work package and did not identify any concems or discrepancies in the work package.

c. Conclusions The test of the autoclave manual isolation system was performed successfully and in accordance with the appropriate procedures. The inspector noted good communication practices between all plant staff involved with the completion of the post maintenance test.

M1.2 Annual Calibration of Buildina C-331 Criticality Accident Alarm System "K" Cluster

a. Insoection Scope (88025)

The inspector observed the annual calibration of the "K" Cluster Criticality Accident Alarm System (CAAS) in Building C-331. The inspector observed job briefings, as well as the actual calibration and maintenance work. In acidition, the inspector reviewed and verified that the General Limiting Conditions for Operation were performed within the area control room and around the affected areas, when the "K" CAAS cluster was declared inoperable for the annual calibration.

b. Observations and Findinas v

On January 28, tha inspector obs rvrd tha annual calibration of the "K" CAAS clustsr in Building C-331. Technical S faty Rsquirsm:nt Surveillance 2.4.4.22-1, required that CAAS system equipment be calibrated annually. The work associated with this surveillance was prescribed in Maintenance Work Package R 9801024-01.

The calibration of CAAS clusters required that the CAAS cluster be declared inoperable. Subsequently, Building C-331 operations staff were required to initiate several actions to continue operations in order to fuifill the requirements of Section 2.4.4.2 of the Technical Safety Requirement Limiting Condition for Operation (LCO).

The inspector noted that operations staff in Building C-331 took actions in response to Condition A of LCO 2.4.4.2 well in advance of declaring the "K" CAAS cluster inoperable. Access to Building C-331 and the surrounding areas covered by the "K" cluster was restricted in advance of the calibration, and operations staff ensured all workers remaining in the affected area were provided with an attemate means of criticality accident alarm notification. The inspector noted good communication between the Plant Shift Superintendent's Office, Security staff, and staff working within Building C-331 during the entire evolution.

The work performed for the annual calibration required that the existing CAAS module be replaced by a newly calibrated CAAS module, as prescribed in Procedure CP4-GP-lM6210, " Criticality Accident Alarm System Module Replacement." Once installed the new CAAS module was tested in accordance with Procedure CP4-GP-IM6209, " Criticality Accident Alarm System Functional Tests." Prior to the start of work the inspector observed the pre-job briefing held with the instrumentation and control (l&C) maintenance foreman and the l&C maintenance workers. The l&C foreman went through a detailed review of the maintenance work package, the two in-hand procedures incorporated in the work package, the work permits for the job, and the responsibilities of each of the I&C maintenance workers for the evolution.

The inspector observed the work performed on the *K" CAAS cluster, and noted the l&C maintenance workers actions for the CAAS module replacement were in accordance with Procedure CP4-GP-lM6210. No operational difficulties were encountered during the CAAS module replacement, the work and CAAS module tests were successful, and the appropriate CAAS test report form required by Procedure CP4-GP-lM6210 was completed by the workers.

The inspector observed the CAAS functional tests performed with the actions prescribed in Procedure CP4-GP-lM6209. The l&C maintenance workers performed the work in accordance with the procedure, the functional test was successful, and the workers documented the functional tests on the CAAS functional test data sheet.

Throughout the entire work package evolution, the inspector noted good communication between plant staff, and the inspector also noted that when questions arose conceming prescribed procedural actions, work was properly halted until clarification was given by the I&C maintenance foreman. The post-job briefing held with the l&C foreman and maintenance workers was thorough.

The inspector reviewed the operations logs and forms in the Building C-331 area  ;

control room, and verified that operations staff performed the required actions  !

i specified in Technical Safety Requirement 2.4.4.2. A review of completed  ;

l Maintenance Work Package R 9801024-01, verified that the "K" CAAS cluster annual i L , calibration was performed in accordance with the work package and the work performed was properly documented.

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c. Conclusions I

instrumentation and control maintenance activities were conducted in accordance f with the specified procedures, and operations staff in Building C-331 took the proper actions for LCO 2.4.4.2, when the "K" CAAS cluster was declared inoperable. The inspector noted good communication practices between all plant staff during the maintenance evolution.  ;

l 111. Plant Support i T1.0 Operator Training and Qualification T1.1 Overall Trainino Proaram Implementation i

a. Inspection Scope (88010)

The inspector reviewed recent changes to and the overall implementation of the plant training program. The review consisted of interviews with the training organization manager and selected staff, and reviews of implementing procedures for the training organization.

b. Observations and Findinas The training and procedures program underwent an organization change on January 23, in that the program was divided into two independent organizations, the training organization and the procedures organization. In addition, the Training Manager reported directly to the General Manager, whereas previously, the Training and

, Procedure Manager reported to the Enrichment Plant Manager. The Training l Manager informed the inspector of the belief that the reorganization allowed for more efficient operation of the training function within the plant organization and communicated the importance and value of the plant training program.

l The inspector also noted that the implementation of activities within the Training Organization was also being reorganized. The training program was implemented through the use of several UE2, and CP2 level procedures which prescribed the actions necessary for tasks such as the conduct of training, instructor training, staff qualifications and test outs, on-the-job-training, and the completion of training program documentation. Training staff informed the inspector that a change was underway to retain the two " Conduct of Training," Procedures (UE2-TR-TR1030 and l CP2-TR-TR1032), and to incorporate the specific actions necessary to perform training tasks, into training guideline documents, referred to as, " Training Records Office Guides." The current CP2 level procedures prescribing the actions necessary for tasks such as instructor training, staff qualifications and test out, and on-the-job training would be deleted, and CP2-TR-TR1032, " Conduct of Training," would be i revised to reflect the new program (at the time of the inspection CP2-TR-TR1032 4 was under revision). The inspector noted that completion of the 10 CFR 76.68 plant change review process for the deletion and revision of the CP2 level procedures would assess whether or not these changes were allowed by the requirements ard commitments of the Certificate.

While reviewing the implementing procedures for the training program, the inspector noted that at the time of the inspection, seven training procedures were placed on a

" Procedure Hold." The procedures on hold, the effective hold date and the reason vii h

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for th] holds w;ra docum:nt:d es follows: Proc: dura UE2-TR-QP1002, "Or:I Ex min:tions," on hold since December 31,1997, due to an expired periodic review date; Procedure CP2-TR-TR-QP1035, "Needs, Job and Task Analysis," on hold since January 21 because, "[the) Procedure is pending deletion and a new procedure will replace this one due to inconsistencies with the actual analysis process"; Procedure CP2-TR-QP1038, " Design and implementation," on hold since November 11,1997, because the procedure was "Pending deletion"; Procedure CP2-TR-QP1039, "On-The-Job Training," on hold since January 21 because the procedure was "Pending deletion-being revised"; Procedure CP2-TR-QP1041,

" Training Records and Training Program Configuration Management," on hold since August 29,1997, because "[the) Procedure is inaccurate as written and a change to correct the problems is in progress"; Procedure CP2-TR-QP1042, " Instructor Training and Qualification," on hold since July 31,1997, because "[the] Procedure is in the deletion process - will adopt the UE2 Procedure and DOE [ Department of Energy) handbook"; and, Procedure CP2-TR-QP1033, Qualification, Test-Out, Exemption, and Remediation," on hold since June 30,1997, because of " inadequate flowdown from SAR 6.6.2, Trainee Selection; Defer to higher tier procedure UE2-TR-TR-1030 for guidance for the subjects referenced."

During interviews with the training manager and staff, the inspector noted that plant staff were not aware that Procedures UE2-PS-PS1031, and CP2-PS-PS1031,

" Procedure Control Process," required, in part, that when a " Procedure Hold" was issued, the tasks within the procedure were no longer performed. Several of the procedures which implemented the day-to-day operations of the current training program were on

• Procedure Hold." One example was Procedure CP2-TR-QP1041,

" Training Records and Training Program Configuration Management," referred to as a "Use Reference" Procedure in CP2-TR-TR1032, " Conduct of Training." The action steps of CP2-TR-TR1032 required staff to document completed training according to Procedure CP2-TR-OP1041, which was placed on hold August 29,1997, because

"[the) Procedure is inaccurate as written and a change to correct the problems is in progress." The inspector reviewed training records that documented tasks prescribed )

in Procedure CP2-TR-QP1039, "On-The-Job Training," and Procedure CP2-TR-QP1041, " Training Records and Training Program Configuration Management," were i performed during the time period when the procedures were placed on " Procedure l Hold."  :

In response to the inspector's findings, plant staff initiated Problem Report PR-NR-98-0482, to determine if certain training procedures could be taken off hold, and to initiate efforts to evaluate tasks performed while the procedures were placed on a

" Procedure Hold." In addition, plant staff stated that a review of other procedures on hold in other plant organizations would be initiated to ensure compliance with the requirements for a " Procedure Hold" in Procedure UE2-PS-PS1031 and a Significant Condition Adverse to Quality investigation would be initiated.

Technical Safety Requirement 3.9.1, requires, in part, that written procedures shall be prepared, reviewed, approved, implemented, and maintained for activities described in Safety Analysis Report, Section 6.11.4.1, and listed in Appendix A, to

( Safety Analysis Report, Section 6.11. Appendix A, to Safety Analysis Report, Section 6.11, requires, in part, that procedure management activities shall be covered by written procedures. Procedure UE2-PS-PS1031, "UE Policy and Procedure Control Process," Section 6.22.3, " Procedure Holds," requires, in part, that when a " Procedure Hold" is issued, the tasks within the procedure are no longer viii

perform:d. Contr:ry to th s3 r;quir;m:nts, o " Procedure Hold," w:s issu d for certain plant trrining progr:m procedur:s, end tha tasks within procedures continued to be performed. Specifically, from January 21, through January 27,1998, Procedure CP2-TR-QP-1039, "On-The-Job-Training," was placed on a Procedure Hold, and the tasks within the procedure continued to be performed. In addition, from August 29,1997 through January 30,1998, Procedure CP2-TR-QP1041,

" Training Records and Training Program Configuration Management," was placed on a Procedure Hold, and the tasks within the procedure continued to be performed.

The failure to ensure the tasks within a procedure were no longer performed, after a Procedure Hold was issued, is a Violation of the procedures management program (VIO 070-07001/98002-01).

c. Conclusions The inspector noted that the training program at the plant was undergoing changes both in organization and implementation. The inspector identified that training staff were unaware of certain procedures management requirements, as a result, training procedures were placed on hold, and in some cases tasks within the procedure were not stopped as required by the procedures management program. One violation was identified.

Q1.0 Quality Assurance Program Q1.1 Overall Proaram implementation

a. Inspection Scope (35701)

The inspector reviewed the certificant's actions in response to an URI identified in NRC Inspection Report 070-07001/97009 dated October 17,1997. In addition, the inspector reviewed the November 17,1997, United States Enrichment Corporation's (USEC) response (GDP 97-1043) to the URI with both the site and corporate Safety, Safeguards and Quality managers.

b. Observations and Findinas Inspection Report 070-07001/97009 identified a potential inconsistency between the supplementary requirements of ASME NQA-1-1989 (required by 10 CFR 76.93), the Quality Assurance Plan, and applicable implementing procedures. An URI identified that some supplementary requirements of ASME NOA-1-1989 for which the Quality Assurance Plan did not specifically identify exceptions or acceptable attematives, did not appear to be implemented at the plant. In addition, the inspector identified that plant staff was aware of this discrepancy, as early as August 1996. Consequently, the NRC requested a response from USEC to URI 070-07001/97009-01, specifically addressing which supplementary requirements of ASME NOA-1-1989 were not currently implemented at either of the USEC operated gaseous diffusion plants.

, The November 17,1997, response letter (GDP 97-1043), stated that unless an l alternative or exception was identified, then USEC had committed to all of the ASME NOA-1-1989 supplemental requirements, even if the supplemental requirements were not specified in the Quality Assurance Plan. Based on a review of the issue, USEC concluded, in the correspondence, that the omissions of some supplementary requirements did not impact the overall effectiveness of the Quality Assurance Program, because the omissions were: 1) generally minor in nature; 2) provided ix

d: tails of commitments already mid3 in tha Quality Assuranen Plan; 3) girstdy includ:d in plant procedures; or,4) did not apply to gaseous diffusion plant operations. Attachment A to the November 17,1997, correspondence provided a matrix of ASME NQA-1-1989 supplementary requirements'which were omitted from the Quality Assurance Plan. When an omission was identified, the implementing procedure which contained a supplementary requirement or a brief comment l conceming the supplementary requirement omission was provided in the matrix. In l

the correspondence, USEC committed to submit a revised Quality Assurance Plan to the NRC by January 30,1998, to clarify the current Quality Assurance Plan.

During interviews with the Corporate Quality Assurance manager, and the site Nuclear Regulatory Affs;rs and Safety, Safeguards and Quality managers, the

inspector'were informed that a notification of a change in the commitment date would

! be submitted to the NRC. On January 28, USEC submitted a notification of change l in regulatory commitment (GDP 98-0015) for the submittal of the revised Quality

Assurance Plan, changing the January 30 date to February 27,1998, to ensure that l the Quality Assurance Plan revision was complete, accurate, and had the necessary reviews and approvals.

c.- Conclusions The inspector reviewed the certificant's progress concerning the issues described in URI 070-07001/97009, and will continue to follow-up this issue in future inspection efforts. The inspector will review both the final 10 CFR 76.68 plant change for the current Quality Assurance Plan and the revised Quality Assurance Plan, upon completion by plant staff.

IV. Manaaement Meetinas X1 Exit Meeting Summary The inspector presented the inspection results to members of the plant staff and management at the conclusion of the inspections on January 30,1998. The plant staff acknowledged the findings presented. The inspector asked the plant staff whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

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

• S. Cowne, Nuclear Regulatory Affairs Lockheed Martin Utility Services (LMUS)

• D. Holt, Nuclear Regulatory Affairs l *J. Howe, Nuclear Regulatory Affairs

'D. Hallenbeck, Safety, Safeguards and Quality l *L. Jackson, Production Support Manager l *H. Pulley, Enrichment Plant Manager

• F. Kocsis, Procedures Manager

, *B. Chenier, Health Physics

• T. Graben, Health Physics

• S. Brawner, Training Manager

• W. Sykes, Nuclear Regulatory Affairs Manager

• R. Cothron, Maintenance

• S. Chappelle, Safety, Safeguards and Quality l *C. Hicks, Site and Facilities Support i

• Denotes those present at the January 30,1998 exit meeting l

Other members of the plant staff were also contacted during the inspection period.

! INSPECTION PROCEDURES USED IP 88020 Operations Review I l

IP 88025 Maintenance and Surveillance Activities IP 88010 Operator Training and Re-Training lP 35701 Quality Assurance Program Review i

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ITEMS OPENED, CLOSED, AND DISCUSSED Opened 070-07001/98002-01 VIO Failure to stop tasks prescribed in procedures which were "On Hold" Discussed 070-07001/97009-01 URI Potential failure to include ASME NOA-1 supplemental requirements in the implementation of the Quality Assurance Program.

070-07001/97012-03 URI Building C-360 levelator rail stops Closed None l

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LIST OF ACRONYMS USED CAAS Criticality Accident Alarm System CFR Code of Federal Regulations DAC Design Analysis and Calculation DNMS Division of Nuclear Material Safety DOE Department of Energy l&C Instrumentation and Control LCO Limiting Condition for Operation LMUS Lockheed Martin Utility Services NRC Nuclear Regulatory Commission PDR Public Document Room PMT Post Maintenance Test RWP Radiological Work Permit SAR~ Safety Analysis Report URI Unresolved item USEC United States Enrichment Corporation VIO Violation xiii l

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