ML20216H082

Insp Rept 70-7002/97-05 on 970630-0810.Violations Noted. Major Areas Inspected:Licensee Plant Operations,Maint & Surveillance,Engineering & Plant Support

ML20216H082
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant
Issue date:	09/10/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20216H052	List: ML20216H046 ML20216H070 ML20216H082
References
70-7002-97-05, 70-7002-97-5, NUDOCS 9709160131
Download: ML20216H082 (18)

Text

4 U.S.' NUCLEAR REGULATORY COMMISSION REGION lli Docket No: 70 7002 Certificate No: GDP 2 Report No: -70 7002/97005(DNMS)

. Applicant: - United States Enrichment Corporation Facility Name: Portsmouth Gaseous Diffusion Plant Location: 3930 U.S. Route 23 South P.O. Box 628 -

Piketon, OH 45661 Dates: June 30 through August 10,1997 Inspectors: ' C. R. Cox, Senior Resident inspector D. J. Hartland, Resident inspector R. G. Krsek, Fuel Cycle inspector, Region ill Approved By: . P. L. Hiland, Chief Fuel Cycle Branch 1

9709140131 970910 PDR ADOCK 07007002 C PDR

EXECUTIVE

SUMMARY

United States Enrichment Corporation Portsmouth Gase ous Diffusion Plant NRC Inspection Report 70 7002/97005(DNMS)

Plant Ooerations e The inspectors identified a non-compliance with the nuclear criticality safety approval for storage of components containing uranium deposits with greater than safe mass in the X 333 building. A Technical Safety Requirement (TSR) violation was identified. (Section 01.1)

• The laspectors did not identify any concerns with the certificatee's initial response and recovery plan for the loss of steam event. (Section 01.2)

Maintenance and Surve . lance o The inspectors identified a concern regarding the use of work instructions in lieu of ,

approved procedures for the performance of complex safety related corrective maintenance. A TSR violation was identified. (Section M1.1)

Enaineerina e The inspectors continued to monitor the effectiveness of corrective actions to prevent autoclave high condansate level and high cylinder pressure safety actuations. One inspector followup item (IFI) was identified (Section E.8),

f Plant Sucoort Radiolonical Protection e The ;ertificatee's As Low As Reasonably Achievable (ALARA) program met requirements specified in the ALARA committee charter, adequately addressed facility radiological issues and established goals relevant to health physics issues at the gaseous diffusion plants. (Section R1.1) e Radiological survey frequencies for facilities reviewed during the inspection were being met, Health physics procedures adequately reflected current job practices, and health physics technicians demonstrated good survey practices.- (Section R1.2) e The respiratory protection program adequately addressed regulatory requirements concerning the use of respiratory protection equipment onsite. (Section R1.3) e The external dosimetry program was effectively implemented. Inspectors noted

- that for 1996 the maximum total effective dose equivalent for a radiation worker was below 10 percent of the NRC limits for radiation workers. The National Voluntary Laboratory Accreditation Program dosimetry laboratory was being 2

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operated in accordance with current laboratory procedurcs. The inspectors verified that a security system was in place to prevent corruption of personnel dosimetry data stored on electronic files. (Sections R1.4, R1.5)

• No discrepancies in posting and labeling were noted; however, the plant staff's knowledge of the content and purpose of the NRC Form 3 was poor.

(Section R1.6)

Security

• In response to an NRC concern, the certificatee initiated actions to ensure that security personnel performing safety related functions remained within the TSR hours of work limitations. However, the inspectors continued to hava concerns

- with the management of overtime for the overall work force. One non-cited violation and one IFl were identified. (Section S8.1) i 3

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Egoort Details I. Operationg 01 Conduct of Operations' 01.1 Non-Destructive Assav Surveillances for Leasev Eouioment

a. insoection Scoce (88102)

The inspectors reviewed the results of non destructive assay (NDA) j surveillances for cut out cascade equipment that had been stored on the cascade floor,

b. Observations and Findinag in response to a nuclear criticality safety issue identified at the Paducah Geseous Diffusion Plant, the facility staff walked-down legacy equipment in the cascade buildings to determine if the equipment was stored in accordance with an appropriate nuclear criticality safety approval (NCSA).

The walk-down was conducted from June 21 through June 27,1997. On June 27, the certificatee discovered a compressor with a uranium deposit greater than safe mass being stored in cell 33 8, stage 7. The certificatee classified the deposit as " planned expeditious handling" (PEH) and established a dry air buffer in accordance with TSR L.2.3.16 and

- NCSA Plant 028.1C2 dated August 20,1996.

On July 15, the inspectors noted the dry air purge line running from a panel from an operating cell to the stored compressor. In tracing down the purge line, the inspectors saw no steel plate covers on the compressor.

NCSA Plant 028.1C2 required steel plate covers with a pressure relieving device and a pressure gauge for storing PEH equipment. The inspectors notified the X-333 staff and the plant shift superintendent (PSS) about the NCSA requirements. The X-333 staff were not aware of the NCSA requirements. The inspectors highlighted that similar PEH storage problems had been identified in the X 330 building and documented in previous observation and inspection reports.

The facility staff determined that the compressor would have to be moved to attach the steel covers. Rather than move the PEH compressor, the nuclear criticality safety staff determined that the safest process was to develop a Topical headings such as 01 M8. etc., are used in accordance with the NRC standardaed inspection report outline contained in NRC Manual Chapter 0610. Individual reports are not expected to address all outline topics, and the topical headings are therefore not always sequential.

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- . - .. . - -. -_-_~_. - - - - _- . - - -- , -

-4 separate NCSA for the safe storage of the compressor. The < ompressor was then stored in accordance with the newly approved NCUA.

Technical Safety Requirement (TSR) 3.11.2 requires, in part, that all operations involving uranium enriched to 1.0 weight percent (wt%) or higher U 235 and 15 grams (g) or more of U 235 shall be performed in accordance with a documented nuclear criticality safety approval. The failure to have a documented NCSA available for the cornpressor is a Violation of TSR 3.11.2 (VIO 70 7002/97005 01).

c. Conclusion There was no immediate criticality safety concern because the existing covers provided some moderator control and a dry air purge was maintained.

While the NCSA walk down was conducted to identify storage problems, the failure to ensure all the NCSA requirements were met resulted in one violation. The event demonstrated that the lessons learned for PEH etorage in the X-330 buildmg were not communicated to the X 333 personnel

- 01.2 Lnss of Steam Event

a. Insoection Scone (88100)

The inspectors observed the certificatee's response to the loss of steam '

event that occurred on July 25,1997,

b. Observations and Findinas At approximately 6:30 a.m., on July 25,1997, the steam supply from the on site generating plant was lost. The event occurred when the two boilers that were in service at the time (#2 and #3) were damaged due to an interruption in feedwater supply. The plant was operated without a steam supply for approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> until boiler #1, which was out for maintenance at the time of the event, was retumed to service. The plant-was operated with a reduced steam supply until the #2 boiler was returned to service on August 7.

The inspectors observed the certificatee's initial response and the resulting recovery plan and did not identify any concerns. Plant operators took appropriate action to monitor the cascade for process gas freeze out. The low assay withdrawal (LAW) and tails stations were removed from service when evidence of freeze out was observed. Steam supply was restored to plant systems in a controlled fashion. Clarity checks were performed on

-those systems with potential freeze out prior to heating. An NRC special inspection team was dispatched to the site on July 29 to follow-up on the root causes of the event.

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c. C.onclusions The event did not result in any immediate criticality or chemical safety concerns. The inspectors did not identify any concerns with the certificatee's recovery efforts. The root causes of the event will be documented in the report submitted by the specialinspection team.

II. Mamteneugt M1 Conduct of Maintenance M1.1 lige Of Work Instructions For Safetv Related Work

a. insoection Scone (88103)

The inspectors observed various safety-related maintenance activities and reviewed the associated work packages, j b. Observations and Findinos l

The inspectors identified an issue regarding the use of work instructions in lieu of approved procedures for the performance of complex safety related work. The inspectors were concerned that the work instructions did not get the same level of review, most notably safety screenings and Plant Operations Review Committee (PORC) authorization. Changes to instructions were also not reviewed with the same rigor. Notable examples included:

• Work instructions used to cut out an x joint containing a PEH deposit from cell 29 2 2 in April 1997 did not reference the applicable TSR requirements. This deficiency could have been identified by the PORC had they reviewed the work instructions, as required by the procedure review process, hatead, a violation of TSRs resulted due to a poor interpretation of the requirements as discussed in Inspection Report 70 7002/97003.

• Work instructions were also used to replace trolley wheels and rails on the LAW crane in June 1997 (WO# 9704557). The inspectors reviewed the work package and did not identify any significant concerns. Some vendor information was provided but was extracted from controlled manuals, with the exception of a letter that was provided as guidance for use of an alignment tool, in addition, an engineering memo was used to document " verbal direction" given for resolution of deficiencies discovered during a hold point inspection.

The inspectors' reviewed the memo and discussed it with the engineer and did not identify any unintentional modifications to the crane.

However, the inspectors were concerned with the informality of those engineering reviews, 6

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However, the inspectors were concerned with the informality of those engineering reviews.  ;

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• The inspectors also identified that when problems with approved

-vork procedures were identified and documented on procedure l

development forms (oDFs), the work control process allowed for work instructions to be used until the procedure was changed. The inspectors reviewed a list of affected procedures and identified examples of safety-relatad applications including XP4-OM lM6512, "X 330/X 333 Cold Trap Relief Valve TSR Test / Calibration," and XP4 TE EM6550, " Preventative Maintenance of P&H Overhead Crane in X 344 Building." In response to the inspectors' concerns. the certificatee stopped the use of work instructions in place of existing procedures.

TSR 3.9.1 requires, in part, that written procedures be prepared, reviewed, approved, implemented, and maintained to cover activities described in Safety Analysis Report (SAR) Section 6.11.4.1. SAR Section 6.11.4.1 requires that maintenance activities be addressed by written procedures, documented work instructions, or drawings appropriate to the circumstances as described in Section 2.5 of the Quality Assurance Program (OAP).

Section 2.5.3 of the OAP delineates examples of activities (otherwise known as " skill-of tho craft") which do not require step-by step written procedures.

Failure to provide approved written procedures for complex safety-related work activities is a Violation of TSR 3.9.1 (VIO 70 7002/97005-02).

c. Conclusion Tha inspectors were concerned that work instructions did not receive the same level of review as approved procedures. One TSR violation was identified, Ill. Enaineerina E8 Miscellaneous Engineering issues E8.1 (Ocen) Violation (VIO) 70 7002/97003-02: Inadequate corrective action for autoclave high condensate level system (HCLS) safety actuations. As corrective action to the violation, the certificateo committed to perform weekly in-line strainer cleaning for X-344 building autoclaves until an appropriate frequency could be determined based on the rate of debris accumulatica. The certificatee also implemented foreign material exclusion controls for work performed inside the autoclave. In addition, the certificatee installed a new condensate strainer with a larger surface arer and mesh size on autoclave #1 in the X-344 building. The results of that action were being evaluated to confirm that desired results were being achieved.

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On July 21,1997, an HCLS actuation occurred on autoclave #3 at the X 344. In response to that actuation, the certificatee installed the larger strainers on the remaining autoclaves at the X 344 building _ No further actuations have occurred since the modifications were made. This item will temain oper., as the inspectors will continue to monitor the effectiveness of the certificatee's corrective actions.

E8.2 - (Ocen) _&nt Reoort 9710: On May 23,1997. a cylinder high pressure safety a :tuation occurred while heating a 21/2 ton Russian cylinder 'n autoclave #5 at the ,

X 343 building. Similar occurrences have occurred previously as discussed in

. Obrervation Report 70-7002/95005. The certificatee believed thet the root cause of tae events was unequal distribution of uranium hexafluoride (UF.) behind the.

cy inder valve or trapped gases t' sing released from within the cylinder. _ Corrective act.ons to the previous events included revising procedures to allow operators to "b.up" a cylinder if pressure was rising rapidly, in response to the latest actuation, the certificatee put on hold heating the Russian cylinders that had not previously been through a heating cycle at the plant until an engineering evaluation could be completed to determine additional actions to 4 prevent recurrence. On July 9, heating of Russian cylinders resumed following implementation of temporary procedural controls. Enhanced valve clarity checks were added to identify if unequal distribution of UF. existed behind thn valve. In addition, a modified heating process was implemented to reduce the heat rate.

Additional gas samples were also being taken to allow analysis of trapped gases.

The inspectors reviewed the temporary procedure and observed portions of the implementation and did not identify any concems. This item will remain open, as the inspectors will continue to monitor the effectiveness of the corrective actions.

(CER 70 7002/97005 03)

IV. Plant Suppg1 R1.0 Radiation Protection R1.1- As low As Reasonably Achievable Proaram

a. Insoection Scone (83822)

The inspectors reviewed the facility's As Low As Reasonably Achievable

. (ALARA) program through personnel interviews, ALARA committee documentation, and attendance at an ALARA subcommittee meeting.

b. Observations and Findinos The inspectors reviewed the ALARA Committee meeting minutes from April 29,1997 and discussed committee findings with appropriate personnel. Membership in the committee represented various disciplines from within the plant. Meeting minutes documented significant issues related to external and internal employee doses, external and internal dosimetry, personnel skin and clothing contaminations, environme .tal 8

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program reviews and subcommittee investigations of higher dose rates in specific plant areas. Attachments to the meeting minutes identified that the overall onsite Total Effective Dose Equivalent (TEDE) has decreased from a collective dose of 32.7 manrem in 1989 to 21.4 manrem in 1996.

Interviews with the radiation project manager (RPM) indicated that this reduction was due in part to a stricter badge issuance program coupled with a decrease in the lower level of detection (LLD) of dosimetry instrumentation.

The inspectors attended an ALARA subcommittee meeting which addressed the change of environmental baseline effluent quality (BEO) limits. Although the change was an increase in BEO limits, the RPM and environmental compliance manager highlighted that the BEOs were below regulatory requirements and that they anticipated this change, as the original BEO values were best estimates given data available at the time. The subcommittee also stated that this change would help to better reflect and evaluate environmental trends, as the current values at such a low threshold produced erratic data. The inspectors noted that the appropriato quorum was in pla n as specified by Procedure XP2-HP RP1032 "ALARA l Subcommittee."

l The inspectors reviewed the status of each of the seven Portsmouth ALARA l goals highlighted in the Memorandum POEF-X338300-96-256, "1997 l Portsmouth ALARA Goals Memo." ALARA goals proposed by the subcommittee were relevant and addressed radiological protection issues.

Goals included evaluations of uranium mateiial handler (UMH) work activities to ascertain if methods exist to reduce these workers' doses; track engineering service orders issued as a result of 1996 ALARA goals; develop training to provide guidelines for ALARA to emergency responders; and perform five radiological reviews to assess potential personal protective equipment (PPE) reduction for certain work activities. The completed goals were thnroughly documented and subsequent recornmendations would be addressed at an upcoming ALARA committee. Approximately 50 p.rcent of the year's ALARA goals were complete. Goals not completed wens due for completion before the end of the calendar year.

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Conclusions The inspectors concluded that the facility's ALARA program met requireme".ts specified in the ALARA committee charter, adequately addressed facility radiological issues and established goals relevant to radiological issues.

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e R1.2 Badiation Prote.g.t[gn Routine Ooerations

a. Inanection Scoos (83122}

The inspectors in%rviewed health physics technicians (HPT) and accompanied the HPTs on routine radiological surveys. Select radiological surveys for March to July 1997 and the radiation work permit (RWP) program were also reviewed,

b. Observations and Findinat The inspectors accompanied HPTs on routine radiological surveys in the X 333, X 330, X 343 and X 705 process buildings. All surveys observed were adequately conducted in accordance with Procedure XP2 HP H02032,

• Radiological Surveys," and the procedure reflected current HPT practices.

Surveys consir.ted of direct contamination frisks,100 square centimeter srnears and large area wipes. Daily surveys were observed in the X 333 and X 330 buildings and a review of records in local HPT offices indicated that the daily survey frequencies for these buildings were met. During a weekly survey in the X 705 decontamination building, one area wipo exceeded administrative contamination levels.

The inspectors observed that this area was decontaminated and resurveyed in a timely mariner, in accordance with Procedure XP2 HP HO2032. Survey techniques were good and technicians were f amiliar with the appropriate correction factore assigned to the readings of each instrument used for surveys. A revieve of HPT logbooks revealed that entries made highlighted routine and speciA occurrences on shif ts and contained sufficient information for futt re reference and shift tumovers. Health physics technicians interviewed were knowledgeable of specific facility process hazards, and were attentive during routine surveys to abnormal health physics conditions.

The inspectors observed the HPTs conducting empty cylinder survoys in the X 343 feed vaporization and sampling facility. Immediately af ter a product cylinder was emptied, the materiallef t over in the cylinder, of ten referred to as the heel, exhibits contact gamma radiction measurements as high as 400 mrem / hour. Empty cylinders in the X 343 facility and the adjacent empty cylinder storage yard accounted for the highest gamma radiation doso rates onsite. These elevated dose rat 6s were a result of uranium decay products lef t in the cylinder, and UMHs in this area exhibited the highect gamma radiation exposures onsite.

The inspectors observed UMHs perform contamination surveys and HPTs perform gamma radiation surveys on the empty cylindors. Although contact dose rates were high, the dose rate at 30 centimeters (cm) from the bottom of an empty cylinder was typically less than 100 mrom/ hour. When dose rates did exceed 100 mrem / hour at 30 cm, HPTs were required by procedure 10

to accompany tho empty cylinders, if the cylir, dors were moved or raised after being placed in the storage yard. All surveys observed at the facility woro performed in accordance with Procedure XP2 HP H02032. Health physics technicians and UMHs interviewed were knowlodgeable of the special considorations taken when empty cylind9ts wore handled.

Radiological work permits were required for work act#v. ties onsito which tako I

place in various radiologically contaminated areas at:d specified wh!:h radiological controls woro established within a ficility or work area. Health physics technicians were responsible for the completion and issuance of both gGnoral and job specific RWPs. The inspectors reviewed RWPs during tours of the aforementioned facilities throughout the inspection. RWPs for simi'ar areas onsite woro noted to be consistent from facility to facility, addicssed appropriate radiological concerns, contained current surveys of different areas and required appropriate PPE for specific areas. A review of l

job specific RWPs for completed work from March to July of 1997 l verified that RWPs were being completed in accordance with Proceduro l

UE2 HP RP1031. Although errors in administrative requirements wero '10ted i on RWP closcouts, the inspectors did not identify any radiological protection deficiency issues,

c. Conclusiong The inspectors noted that survey frequenclos in areas reviewed were being mot and that health physics procedures adequately reflected current job practices. Health physics technicians were knowledgeable of job tasks and conducted activities in accordance with written procedures.

R 1.3 Rosoiratory Protection Procram

a. inspection Scono (83822)

The inspectors reviewed the facility's respitatory protection program. This includod observation of respirator use onsito, interviews with sito industrial hyglone personnel responsible for respirator issuance and a review of licensoo proceduros regarding the use of respiratory protection,

b. Qhservations Primary control and issuance of respirators at the sito was the responaibility of the industrial hyglone group, with radiological protection staff addressing respirator use for radiological safety issues. Review of facility policies and procedures revealad the requirements in 10 CFR 20.1703 regarding the use of respiratory protection equipment woro addressed. The inspectors observed facility personnel donning, removing and utilizing respiratory protection equipment and noted no discrepancies from plant procedures.

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I The inspectors also toured the X 103 respirator c!aaning and maintenanco facility and interviewed industrial hygiene personnel. Respirator training and issuance procedures were reviewed with facility staff and the inspectors also observed respirator maintenance activities. The inspectors noted that after maintenance and prior to issuance all respiratory protection equipment was quantitatively tested for operability.

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c. Conclusions The facility was implomonting a respiratory protection program which adequatoly addressed both radiological and chemical harards requiring tho I need for respiratory protection. Written procedures and policios reflected current work practices regarding respirator uso.

R I .4 Extemalaasimetrv l

a. insocction Scone (E33221 The inspectors reviewed the facility's external dosimetry program and dosimetry data for onsite personnel,

b. ObEIYallona Thormoluminescent dosimeters (TLD) were used to deter.nino employoo caposures. The dostmotors were exchanged quarterly and first quarter 1997 data indicated no individual received greater than 50 percent of the administrative controllimit (ACL) for that calendar year quarter. The ACL has boon established as 500 mro.n TEDE for a calcadar year, and a dose 50 percent of this limit in a calendar quarter would result in a special evaluation of the wntker's job. A review of 1996 exposure data indicated that no employee recolved an exposure greater than 10 percent of the NRC limit of 5 rom por year. A selective review of dosimetry procedures in the Health Physics Proceduros Manual, Volume 2 indicated that procedures were up to date with the radiation protection program's current practicos.

The highest doop dose equivalents were found to be with uranium material handlers, whoso job entailed handling empty product cylinders which may exhibit high gamma dose rated for short periods of time due to uranium decay producta lef t in the empty cylinders (R1.2). Radiation protection personnel have initiated an evaluation of uranium material handler work activities to ascertain if a method exists to reduco UMH external dosos.

The inspectors reviewed special evaluations for personnel who received greater than 100 millirem in a calendar quarter and found the evaluations to be thorough and concise 5 addressing the root causes of the exposuroa.

Inspectors also reviewed documentation associated with declared pregnant workers and interviewed radiation protection staff responsible for implementing this prcgram. Declared pregnant worker (DPW) TLDs wero 12

analyzed monthly to better track current exposure history, and DPW evaluations contained sufficient background information concerning the DPWs work areas, as well as comprehensive data on the employoo'b prior exposure history. Completed as well as ongoing DPW ovaluations reviewod were below doso requiromonts specified in 10 CFR 20.1208. The facility does not currently employoo any minors as radiation workers.

c. Conclusions l The radiation protection staff woro implomonting an offectivo external dosimetry program. Areas where external camma doaos were elevated were i being evaluated to determino if methods exist to reducu worker exposures In l

those areas. Total Effective Dose Equivalents for personnel onsito were below 10 porcent of the NRC limits for radiation workers.

l R 1.5 Dosimouv Processina

a. Insoection Scoce (83822)

The inspectors reviewed processing of thermoluminescent detectors at the onsite dosimetry laboratory through interviews with dosimetry personnel and rov ews of dosimetry processing procedures,

b. Observation 1 The Portsmouth Gascous Diffusion Plant dosimetry laboratory currently holds personnel dosimetry accreditation from the National Voluntary Laboratory Accreditation Program (NVLAP) of the NationalInstitute of Standards and Technology (NIST). Dosimeters for both the Portsmcuth and Paducah Gaseous Diffusion Plants were processed at the Portsmouth NVLAP accredited laboratory, inspectors observed the processing of 30 TLD and 3 Quality Ccntrol TLD cards. The inspectors noted no discrepanclos during the observation in procedures and current work practices for utilizing the TLD reader. Dosimetry technicians highlighted that daily calibrations woro performed when the reader was being used, and that the quality control TLD placed af ter every tenth TLD card, ensured the reader propoily functioned. Allinformation concerning the TLD data was stored electronically on a dosimetry :omputer system and back up copies of all information were mado.

The inspectors reviewed the security of TLD data on dosimetry computers.

Discussions and demonstrations with the computer system analyst, showed that a limited number of radiation protection staff had access to changn sito personnel dosimetry data. The system analyst also highlighted that when personnel who have access to the database chango data, all pertinent information in the changed file is recorded, including the identity of the person making the change and the values of the old data which was changed, A printed copy of all the changes was also automatically made l

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and sent to the system administrator. On a weekly basis, the system administrator reviewed all the changos made to the database ensuring all changes made to dosimetry data were validated,

c. Conclusions l The inspectors determined that the NVLAP accredited dosimetry laboratory l was operated in accordance with current laboratory procedures and that a security system was in place to provent corruption of dosimetry data stored on electronic files.

RI.6 Postina and Labeling

a. insoection Sgsg (83822)

The inspectors observed posting and labeling in the X 330,333,343,103 and 705 buildings where radioactive motorial was used. The inspectors also reviewed postings of the NRC Form 3 and randomly interviewod facility personnel regarding the contents of the NRC Form 3.

b. Obervations During facility tours, the inspectors noted that radioactive material areas, airborne radioactivo areas, and radiation areas were properly maintained and posted as required by 10 CFR 20. The inspectors also interviewed health physics technicians about posting requirements. Technicians were knowledgeable of posting requirements and highlighted to inspectors during facility tours which areas were routinely posted areas. Labeling of radioactive materials and containers was consistent with 10 CFR Part 20, and the exemptions allowed by Section 5.3.1.7, " Posting and Labeling," of the Safety _ Analysis Report (SAR).

The inspectors also reviewed radiological posting issues in the empty cylinder storage yard adjacent to the X 343 food vaporization and sampling f acility. The bottom of freshly emptied cylinders could exhibit dose rates in excess of 100 mrom/ hour at 30 centimeters, until residual materials radioactively decay. The bottom of the cylinder where those high dose rates woro located, was verified to be inaccessible during storage, thus not requiring the area to be posted as a high radiation area. The inspectors also noted thet a RWP in place at the X 343 f acility incorporated a provision in the SAR which requires an HPT to be present when an empty cylinder exhibits gamma dose ratos higher than 100 mrom/ hour at 30 cm.

The inspectors verified that the NRC form 3, "Notico to Employoos," was conspicuously posted in numerous areas onsito. However, through interviews with f acility employoos, inspectors determined that employees were generally not aware of the NRC Form 3 and the contents contained within the document, Annual radiation worker training was verified to havo 14 l

addressed these postings. Radiation protection management agreed that increased attention would be given to address the content of the Form 3 during the next ennual radiation worker training,

c. Conclusions The inspectors noted no discrepancies in the posting and labeling of areas, but did identify that facility staff knowledge of the NRC Form 3 was poor.

Radiation protection management indicated that the next annual radiation training would reemphasize the content of the NRC Form 3.

S8 Miscellaneous Security and Sfgrgrds SB.1 (Closed) Unresolved item (URM/ffMf/97004 04: Applicability of TSR overtime limits to the plant security force. Ab documented in a letter dated July 18,1997, the NRC determined that all staff specifically mentioned in the TSR Table 3.2.2.1,

" Minimum Staffing Requirements," were covered by the hours of work limitation in TSR 3.2.2.b. In addition, any time a security force was utillred to perform a safety related function, TSR 3.2.2.b would also apply. Examples included the use of security force personnel to conduct fire watches or other TSR related activities, in a letter dated July 31, the certificates committed to realign Job duties and responsibilities to ensure that security personnel do not exceed TSR hours of work limitations. Failure to comply with TSR 3.2.2.b for the security force is a violation.

But the significance of the noncompliance was minimal and the certificatee has j taken action to prevent recurrence. As a result, the violation is being treated as a Non Cited Violation consistent with Section Vll.B of the NRC Enforcement Policy (NCV 70 7002/97005 04).

The inspectors have some additional concerns regarding the certificatee's management of overtime for the general work force. The inspectors have noted some examples, identified by the certificatee, of overtime exceedances without prior approval, including three during the inspection period. As corrective action, the certificatee has implemented a real time computerized overtime monitoring system for houtly workers. Training was completed for managers and a letter was issued to plant personnel to increase awareness and accountability. The inspectors review of the effectiveness of these corrective actions is an Inspector followup item (IFl 70 7002/97005 05).

V. Manaaement Meetings X1 Exit Meetina Summarv The inspectors presented the inspection results to members of the facility management on August 11,1997. The facility staff acknowledged the findings i

- presented.

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- PARTIAL LIST OF PERSONS CONTACTED i Lockheed Martin Utility Services (LMUS) f

'D 1. Allen, General Manager J. B. Morgan, Enrichment Plant Manager l

'M. Hasty, Engineering Manager  ;

'R. W. Gaston, Nuclear Regulatory Affairs Manager  ;

'C. W. Sheward, Maintenance Manager  !

'R. D. McDermott, Operations Manager i United States Enrichment Corooration f J. H. Miller, USEC Vice President, Production

'L. Fink, Safety, Safeguards & Quality Manager United States Deoartment of Enerov (DOE)

J. C. Orrison, Site Safety Representative  ;

Nuclear Raoulatorv Commission (NjiC1 C. R. Cox, Senior Resident inspector

'D. J. Hartland, Resident inspector Y. H. Faraz, Project Manager, NMSS R.G. Krsek, Fuel Cycle inspector ,

' Denotes those present at the exit meeting on August 11,1997.

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INSPECTION PROCEDURES USED l

l lP 88100 Plant Operations l

IP 88102 Surveillance Observations IP 88103 Maintenance Observations I IP 83822 Radiation Protection Program IP 97012 in office Reviews of Written Reports on Non routine Events ITEMS OPENED, CLOSED AND DISCUSSED Qoened 70 7002/97005 01 VIO Failure to have documented NCSA available for a PEH >

compressor stored in the X 333 building j

70 7002/97005 02 VIO Failure to provide approved procedures for complex safety-related work activities 70 7002/97005 03 CER Effectivenoss of corrective actions for cylinder high pressure safety actuations-70 7002/97005 04 NCV Weekly approval of overtime in excess of TSR limits for security staff during the month of June 70 7002/97005 05 IFl Effectiveness of corrective actions to TSR hours of work limitations violations Closed 70 7002/97004 04 URI Applicability of TSR overtime limits to plant security force Discussed 70 7002/97003 02 VIO Inadequate corrective action for autoclave HCLS safety actuations Certification issues Closed None 17 7

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LIST OF ACRONYMS USED l ACL Administrative Control Limit l ALARA As Low As Reasonably Achievable l BEO Baseline Effluent Quality l CER . Certificate Event Report l CFR Code of Federal Regulations CofC Certificate of Compliance DPW Declared Pregnant Worker g Gram HCLS High Condensate Level System HPT Health Physics Techniclan IFl Inspection Followup Item IP inspection Procedure LCO Limiting Condition for Operation LLD Lower Level of Detection LMUS Lockheed Martin Utility Services mrem milli roentgens equivalent man NCSA Nuclear Criticality Safety Approval-NCV Non cited Violation NDA Non destructive Assay NIST NationalInstitute of Standards and Technology NOV Notice of Violation NRC Nuclear Regulatory Commission NVLAP National Voluntary Laboretory Accreditatioi) Program PDR Public Document Room PEH Planned Expeditious Handling PORC Plant Operations Review Committee PPE Personal Protective Equipment PSS Plant Shift Superintendent OAP Ouality Assurance Plan RPM Radiation Protection Manager RWP Radiation Work Permit SAR Safety Analysis Report TEDE Total Effective Dose Equivalent TLD Thermoluminescent Detector TSR Technical Safety Requirement UF, Uranium Hexafluoride UMH Uranium Material Handler USO Unreviewed Safety Question VIO Violation wt% weight percent 18