ML20249B068

Insp Rept 70-7001/98-10 on 980518-22.Violation Noted. Major Areas Inspected:Maint & Plant Support

ML20249B068
Person / Time
Site:	07007001
Issue date:	06/15/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20249B059	List: ML20249B058 ML20249B067 ML20249B068
References
70-7001-98-10, NUDOCS 9806220030
Download: ML20249B068 (8)

Text

. 1 U.S. NUCLEAR REGULATORY COMMISSION REGION lll l

Docket No: 70-7001 Certificate No: GDP-1 Report No: 70-7001/98010(DNMS)

Facility Operator: United States Enrichment Corporation Facility Name: Paducah Gaseous Diffusion Plant Location: 5600 Hobbs Road P.O. Box 1410 Paducah, KY 42001 Dates: May 18 - 22,1998 Inspector: R. G. Krsek, Fuel Cycle Safety inspector Approved By: Patrick L. Hiland, Chief Fuel Cycle Branch Division of Nuclear Materials Safety l

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i 9806220030 990615 i PDR ADOCK 07007001 C PDR ,

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EXECUTIVE

SUMMARY

United States Enrichment Corporation Paducah Gaseous Diffusion Plant i NRC Inspection Report 70-7001/98010(DNMS) l Maintenance

. The inspector observed routine pressure decay testing for autoclaves onsite and noted good communications skills among operations staff. In addition, the inspector noted that operations staff and management at the autoclave facilities were attentive and knowledgeable of ongoing issues in regards to the operation of the autoclaves.

(Section M1.1)

. A violation was identified regarding the levelator rail stops in Building C-360. An engineering analysis demonstrated that the rail stops would not have prevented rolling the scale cart and the carried cylinder off the end of the lift, as required by the Technical l Safety Requirement Design Feature statement. The inspectors noted that the certificate had taken comprehensive and immediate corrective actions to resolve the design and operationalissues. This issue was previously identified and discussed as an unresolved ,

item in NRC Inspection Reports 70-7001/97012(DNMS) and 70-7001/98002(DNMS).

(Section M8.1)

Plant Support

. A review of the certificate's liquid effluent sampling for 1997 revealed that effluent concentrations and the annual doses to members of the public were below the requirements of 10 CFR 20. (Section V1.1)

. A review of training records for managers requiring nuclear criticality safety training indicated that managers were either trained or properly restricted from work activities  ;

associated with nuclear criticality safety. An inspector follow-up item was identified to ]

track the development and implementation of a formalized work restriction process within the training and health physics organizations. (Section 11.1)  ;

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Report Details i

11. Maintenance M1 Conduct of Maintenance M1.1 Technical Safety Requirement (TSR) Surveillance for Autoclave Pressure Decay Testina

s. Inspection Scope (88025)

The inspector observed the TSR Surveillance for autoclave pressure decay testing. In addition the inspector observed ongoing autoclave operations at Buildings C-333A, C-337A, and C-360.

b. Observations and Findinas j i

Maintenance work had been performed on an outer-loop containment valve for Autoclave l No.1 West. The post-maintenance test for the maintenance work was to perform the i Technical Safety Requirement autoclave pressure decay test for the outer-loop containment valves. The inspector reviewed the corresponding maintenance work package, interviewed operations and maintenance staff, and observed the work performed.

The inspector noted that all the applicable prerequisites stated in Procedure CP4-CO-CN6054c, "TSR Surveillance - C-333A/337A Autoclave Pressure Decay Test," were performed. The inspector verified that the instrumentation used for the

- test was within the required calibration period, the appropriate valves were closed and caution tagged, and the applicable lock-out-tag-out permits were in place. The inspector noted that operations staff exhibited good communications through the utilization of a repeat-back technique for procedural steps, and that operations staff exhibited a l I

- questkming attitude throughout the performance of the pressure decay test. The inspector also observed portions of the autoclave restoration upon completion of the test and noted no discrepancies. The pressure decay testing evolution was successful, with no anomalies or testing failures throughout the test. The inspector reviewed the maintenance work package'and noted no discrepancies.

The inspector also observed ongoing operations at Buildings C-333A, C-337A, and C-360. The inspector noted that operations staff and management were attentive to the various activities being performed. Operations staff and management were also knowledgeable of ongoing issues not only with the autoclaves onsite at Paducah, but also with ongoing issues of autoclaves at Portsmouth.

c. Conclusions The inspector observed routine pressure decay testing for autoclaves onsite and noted good communication skills among operations staff. In addition, the inspector noted that operations staff and management at the autoclave facilities were attentive and knowledgeable of ongoing issues in regards to the operation of the autoclaves.

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M8 Miscellaneous Maintenance issues

- M8.1 (Closed) URI 70-7001/97012-03: Building C-360 Levelator Rail Stops.

Inspection Report 70-7001/97012, issued November 26,1997, raised issues regarding the adequacy of rail stop surveillance and an unresolved item was opened until a review of the design documentation was complete. Paducah plant staff subsequently issued a design analysis and calculation (DAC) report, because the original design documentation was not available. The DAC determined that the rail stops would be inadequate for stopping a scale cart carrying a full liquid cylinder traveling at full scale cart velocity (12 inches per second). Plant staff also noted that Safety Analysis Report (SAR),

Section 3.6.9.1, a system description of the Building C-360 levelator indicated that the rail stops were provided to prevent rolling of the scale cart during vertical movement of the levelator, after the cylinder scale cart was at rest. Howear, the TSR Design Feature, stated in part, that the rail stops on the levelator prevent ro,iing the scale cart and the carried cylinder off the end of the levelator. This issue along with the corrective actions taken for tus issue were documented in NRC Inspection Report 70-7001/98002(DNMS)

(Section E1.0).

The inspector reviewed the design and installation of the new levelator rail stops, in addition to the completed corrective actions. The certificate had completed the design and installation of the levelator rail stops, in addition to changes in the SAR, SAR update,  ;

and applicable procedures. The inspector did not identify any new concems after a i review of this documentation. The inspector confirmed, through inteniews with plant staff, that the original design of the levelator safety systems focused on the vertical movements of the levolator with a liquid cylinder on the scale cart A review of the current operations and safety systems associated with the use of the levelator confirmed that when moving the scale cart carrying a liquid cylinder, the rail stops were the only engineered control which would prevent rolling of the scale cart off the end c' .he levelator.

Technical Safety Requirement Design Feature 2.1.5.8, " Hydraulic Lifts - Rail Stops,"

requires, in part, that the rail stops on the levelator prevent rolling the scale cart and its carried cylinder off the end of the lift. The DAC-815-19938-0001, dated January 20, 1998, documented that the existing rail stops on the levelator were inadequate, in that the rail stops would not prevent rolling the scale cart and the carried cylinder off the end  ;

of the lift. Specifically, the DAC determined the rail stops would be inadequate for stopping a scale cart carrying a fullliquid cylinder traveling at full scale cart velocity (12 inches per second). The inadequacy of the levelator rail stops to prevent rolling the scale cart and the carried cylinder off the end of the lift is a Technical Safety Requirement Violation (VIO 70 7001/98010-01).

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IV. Plant Support

, V1 Conduct of Environmental Protection Activities V1.1 Environmental Monitorina Results for Calendar Year 1997

a. Inspection Scope (88045)

The inspector reviewed the certificate's environmental air and liquid sampling program

'through discussions with environmental, safety and health staff and reviews of sampling data for 1997.

b. Observations and Findinas Calculations which demonstrate compliance with 10 CFR 20.1301(d) demonstrated that ,

i the dose from airbome uranium to the nearest resident was below 0.1 millirem. The annual dose from airbome radioactive materials due to the licensed activities at the site was well below the 10 CFR 20 target of 10 millirem.

Liquid effluent sample results for the monitors located at the licensee's four main outfalls demonstrated an average concentration below the 10 CFR 20 limits for 1997,

c. Conclusions The certificate implemented the environmental monitoring program as required by the certificate for liquid effluent sampling. Liquids effluent concentrations and the annual doses to members of the public met the requirements of 10 CFR 20.

V8 Miscellaneous Environmental Protection issues V8.1 (Closed) VIO 70-7001/97007-20: Failure to review 10 percent of calculations recorded in Environmental Monitoring Notebooks. This violation was cited in NRC Inspection Report (

70 7001/97007(DNMS) for the failcre to perform the required 10 percent reviews of  ;

calculations in the American-Sigma refrigerated composite sampler and flowmeter environmental monitoring notebooks. The inspector reviewed the documentation used to complete the corrective action plan and noted no deficiencies. In ad@ ion, the inspector noted through a review of current data that the reviews were currently performed in accordance with the procedural requirements. Intemal surveillance conducted as a result of the corrective action plan also revealed minor deficiencies in the sampling program for which the certificate took appropriate corrective actions and policy changes.

The inspector concluded that corrective actions taken for the violation appeared appropriate and prevented recurrence of the violation.

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- 11.0 Conduct of Training Activities 11.1 Trainina Proaram lmolementation a .- Insoection Scor s (88010)

The inspector reviewed selected training records for the health physics organization, and plant staff required to have nuclear criticality safety (NCS) training for managers. -The L - inspector also reviewed the plant policy for the implementation of work restrictions for individuals who were past due on required training.

! b. ' Observations and Findinas

. Procedure CP2-iEG-NS1030 required, in part, that managers of personnel performing tasks associated with fissile material operations and managers of fissile material operations complete training Modules 501.02.06, "NCS for Supervisors," and Module 501.02.02SS/CR,"NCS Principles and Practices at PGDP." The inspector reviewed the records for managers required to receive this training and noted that all but one manager had the required training. The new'y appointed health physics manager, who did not have the required training, was appropriately placed on a work restriction.

The work restriction prohibited the manager from making any NCS decisions or signing any NCS documents. Based on this review, the inspector concluded that the certificate had met the NCS training requirements for managers as required by the SAR.

The inspector then reviewed the training program for the health physics organization, ,

which was partially independent of the onsite training organization. The inspector l reviewed the training record databases kept by both the health physics and training - i t

organizations and noted several discrepancies between the two databases. However, additional reviews by the inspector and investigations by the health physics training manager revealed that most of the discrepancies were administrative in nature. In addition, staff who were deficierit in safety-related courses had not compromised safety

~ by performing tasks, or entering areas for which the staff were not trained. Overall, the

. deficiencies included required training for a given training code not applicable to the employees' job, missing training records, and the failure to update the database. The inspector concluded that the discrepancies were minor and administrative in nature; however, the inspector noted that a well-defined process did not exist for the issuance and implementation of work restrictions within the health physics organization.

1 The inspector subsequently interviewed several individuals from the training organization knowledgeable of the implementation of work restrictions within the maintenance and l

' operations organizations. The inspector leamed that although the responsibility for the

-implementation of work restrictions was defined in policies and procedures, there was no j proceduralized precess for the implementation of work restrictions. The training staff had j defined and implemented a process for work restrictions within maintenance and j operations which was scheduled to be finalized and most likely proceduralized. Training  !

staff indicated that the implementation of this work restriction process had been successful. The inspector noted in discussions with the newly appointed health physics i

manager, that the training staff had recognized work restriction implementation as an area which needed improvement. The inspector noted that actions were taken, as evidenced through the. discussions with training staff, to enhance and formalize the work

. restriction process. Ongoing activities in both the training and health physics ,

s organizations to resolve and enhance issues associated with the work restriction process at Paducah will be tracked as an inspector Follow-Up item (IFl 70-7001/98010-02).

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c. Conclusions A review of training records for managers requiring training for NCS indicated that managers were either trained or restricted from work activities associated with NCS. An inspector follow-up item was identified to track the development and implementation of a formalized work restriction process within the training and health physics organizations.

V. 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 May 22,1998. Plant staff acknowledged the findings presented at the meeting. 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 Lockheed Martin Utility Services O. Cypret, Radiation Protection Manager L. Jackson, Nuclear Regulatory Affairs Manager P. Jenny, Health Physics Manager C. Jones, Design Engineering Manager S. Polston, Plant General Manager l V. Shanks, Production Support Manager j

S. Shell, Environmental Safety and Health Manager R. Starkey, Training Manager ,

I l United Statec Enrichment Corporation  !

J. Labarraque, Safety, Safeguards and Quality Manager INSPECTION PROCEDURES USED IP 88010: Operator Training and Re-Training i IP 88025: Maintenance and Surveillance Testing l lP 88045: Environmental Protection ITEMS OPENED, CLOSED AND DISCUSSED Opened I

70 7001/98010-01 VIO Technical Safety Requirement DF 2.1.5.8 and inadequacy of original design of Building C-360 levelator rail stops 70-7001/98010-02 IFl Resolution and enhancement of work restriction process within training and health physics organizations Closed 70-7001/97012-12 URI Building C-360 levelator rail stops l 70-7001/97007-20 VIO Failure to review 10 percent of calculations recorded in Environmental Monitoring Notebooks.

I Discussed l None l

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