ML20149H286

Insp Rept 70-7002/97-04 on 970519-0629.Violations Noted. Major Areas Inspected:Plant Operations,Engineering & Plant Support

ML20149H286
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant
Issue date:	07/18/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20149H271	List: ML20149H268 ML20149H282 ML20149H286
References
70-7002-97-04, 70-7002-97-4, NUDOCS 9707240308
Download: ML20149H286 (14)

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L . U.S. NUCLEAR REGULATORY COMMISSION l

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l REGION 111 -l l

Docket No: 70-7002 I

. Certificate No: GDP l l

Inspection Report No: .~70-7002/97004(DNMS)

Facility Operator: 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: May 19 through June 29,1997 Inspectors: C. R. Cox, Senior Resident inspector -

D. J. Hartland, Resident inspector Approved By: P. L. Hiland, Chief j Fuel Cycle Branch 1

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EXECUTIVE

SUMMARY

United States Enrichment Corporation- )

l Portsmouth Gaseous Diffusion Plant NRC Inspection Report 70-7002/97004(DNMS) l l

Plant Operatinas

• A safety screening was not performed for the use of an alternative valve line up for cell treatment. The use of a smaller diameter flow path may have hindered the operators' ability to evacuate the cellin an emergency as described in the Safety Analysis Report (SAR). A Technical Safety Requirement (TSR) violation was identified. (Section 01.1)

• Plant operators were not consistently documenting actions required by TSR limiting conditions for operation (LCOs). (Section 01.2)

• The operators continued drum bleeds to the cascade without recognizing that the ]

administrative limit for freon concentration within the cascade had been exceeded.

One non-cited violation (NCV) was identified. (Section 01.3)

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• The operators did not perform required post maintenance testing (PMT) on a tails station safety valve prior to placing it in service due in part to poor communications  ;

and shift turnovers. One NCV was identified. (Section 01.4) j I

Engineering l

• An operations procedure directed the use of a high pressure vent (HPV) system panel l for which post modification testing was not completed. A Technical Safety Requirement (TSR) violation was identified. (Section E2.1)

• The safety evaluation performed to analyze the as-found condition of the autoclave condensate drain screens did not adequately address the potential for partial blockage which could cause the water inventory to be exceeded in an autoclave. A L 10 CFR 76.93 quality assurance program violation was identified. (Section E8.1) l P_lant_ Support

• The inspectors identified an example of inadequate control of classified materials and l- ' cited a violation of 10 CFR 95. (Section S1.1) l l-

• The inspectors identified an unresolved item regarding the applicability of TSR overtime limits to the plant security force. (Section S8.1) 2

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Renort_Datails L_ Operations

- 01 Conduct of Operations' 01.1 Iemperatura_ Transient _Enllowing CelLTreatment i

a. . Inenar tinn Ecopa (RR100} i The inspeo ars reviewed the preliminary investigation into a temperature  ;

transient that occurred following the treatment of Cacade Cell 29-3-7. '

'b. Observations _anri Findings On June 15 while purging Cell 29-3-7 following treatment, plant operators l

observed a pressure rise in the cell. During followup to determine if a seal I was leaking, an operator discovered that a blowout preventer actuator was I glowing due to extreme temperatures and the Stage 1 compressor discharge temperature had reached the 280 degree fahrenheit limit. Per procedure, the i operators shut the cell down and the cell pressure stabilized. The operators 1 inspected the accessible portions of the celli had a sample of the contents )

analyzed, and did not find any evidence that an exothermic reaction had - I occurred. l The investigation determined that a potential cause for the temperature transient was a higher than normal uranium hexafluoride (UF ) concentration in the cell. This may have been because the 3-inch diameter line that was used to evacuate the cellinstead of the 12-inch line normally used did not

! remove all the UF liberated during the cell treatments in addition, only two of the three evacuation booster. station (EBS) stage compressors were operational at the time. As an immediate corrective action, operations management put a hold on tha use of the smaller diameter evacuation flow path until furthu analysis was performed.

l l The inspectors reviewed the plant procedure XP4-CO-CN2116(C), " Cell l Treatments in X-330," and noted that it referenced XP4-CO-CA2260A, "EBS i . Operations in X-330," for establishing the evacuation flow path. The EBS

! procedure specified a valve line up to be used but allowed for deviation if the p normal line up was not available using XP4-CO-CA2228, " Valve Orders."

Although the valve order procedure required review by the cascade Topical headings such as 01, M8, etc., are used in accordance with the NRC standardized 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, i

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t coordinator of the alternate line up established, the inspectors were j

> concerned that the plant was bypassing the procedure revision process which  !

L required that a safety screening be performed. In this particular case, the l inspectors determined that an unreviewed safety question (USO) .

! ' determination would have been required because the use of the smaller 1 lI diameter evacuation line may have hindered the operators' ability to evacuate the cellin an emergency as described Section 3.1.1.12.3 of the SAR. The

- failure of the EBS procedure to provide adequate guidance for the safety screening for alternate valve line-ups for cell treatments is a Violation of TSR l

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' 3.9.1. (VIO 70-7002/97004-01).

c. Conchinn ,

The inspectors were concerned that, although the valve order procedure may be acceptable for use with most evolutions in the plant, more rigorous reviews and restrictions were required for higher risk evolutions that involved criticality concerns or the potential for explosive mixtures. One violation was  ;

identified. '

i ll 01.2 Linulinn Ennditinn far Operation Lngging_Daficiencies '

a. Inspection _Scopa (RR1001 l

The inspectors reviewed the plant's documentation for completion of actions' ,

. required by TSR LCOs. -'

b. .Observatinns and Firidings ,

. In response to an inspector inquiry, the plant discovered inconsistencies in how completion of actions required by TSR LCOs were documented. For example, during criticality alarm actuation system (CAAS) cluster changes,

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several compensatory actions were required including monitoring temperature and pressure in surge drums, as applicable, to verify that the inventory was ,

maintained in the gas phase as required by TSR 2.2.3.2. No' evidence was discovered that indicated the surveillances were not being performed; however, in some cases, the results could not be verified because only a general statement was documented in the ACR log book instead of a record of the parameters monitored, in response to the inspectors' concern, plant operators prepared checklists to ensure that the LCO requirements were being implemented consistently in all

the cascade buildings. The plant' operators also intended to incorporate the  ;

checklists into.the applicable procedures.

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c. Conclumnns 1

The facility was cited in previous inspections for failure to properly implement I TSR requirements. As followup to those violations, the inspectors will verify l that the checklists were incorporated into plant procedures. I O1.3 Lack of Rigor _ Ear.Cascada_ Oxidant _Contral

a. InspectionScopa_18R100)

I The inspectors reviewed the plant operator's compliance to administrative controls for oxidant addition to the cascade to prevent explosive mixtures. '

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b. Observations _and Findings l On June 13 the cascade coordinator received and logged the results of the biweekly freon sample taken from the side purge cascade the previous day  ;

, withnut recognizing that the concentration exceeded the 2 percent l administrative limit. Procedure XP4-CO-CN2410. " Side Purge Cascade," j required that drum bleeds to the cascade be isolated when the limit was  !

exceeded. I i

The cascade coordinator continued to bleed drums to the cascade despite evidence from line recorders of elevated freon levels. Since the operators did  ;

not have the capability to determine real time freon concentration at the i purge cascade, it would have been prudent to stop the drum bleeds until the actual concentration could be determined. The drum bleeds continued until i June 18, when the concern was identified by operations management. l Failure to follow plant procedures is a violation of TSR 3.9.1. However, operations management identified the deficiency. In addition, during followup, operations determined that the intent of the procedure was to allow bleeding drums at a reduced flow rate with the elevated freon levels.

Subsequently, the procedure was changed to reflect how operations were currently being performed. Therefore, the significance of the noncompliance was minimal. As a result, the violation is being treated as a Non-Cited Violation (NCV) consistent with Section Vll.B.1 of the NBC_ Enforcement Enlicy.

c. Conclusion l The significance of the procedure noncompliance was minimal. However, the event was indicative of a lack of rigor in the control of oxidants in the cascade. One NCV was identified. i l

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1 01.4 Eaitura in Pa.rfntm Pnet Maintannnca Tastinn nn a Tnile Rnfety_ Valve

a. Inspection _ScoptL(RR100)

The inspectors reviewed the investigation into a missed post maintenance test I (PMT) for a safety valve at the tails station.

b. . Observations _and_Eindings On June 13 plant operators identified that a tails header was placed in service tne previous day prior to performing required PMT on a manifold safety valve. l The valve had previoush' failed to operate properly during a quarterly i pyrotronics smoke test. The valve was replaced and leak checked but the smoke test was not completed prior to placing the valve back in service.

Upon identification of the problem, the operators removed the loop frorn service and successfully completed the smoke test.  ;

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One of the causes of the event was apparent removal of an administrative  !

control tag without authorization. In addition, poor communications and shift turnovers among the operators was a contributing cause. Operations management was in the process of formalizing the operator turnover process  ;

in response to a violation discussed in a previous inspection report. The i violation involved failure to maintain minimal manning requirements at the tails station.

The failure to perform the PMT as required by plant procedures prior to placing the tails header in service is a violation of TSR 3.9.1. However, the plant operators identified the deficiency and testing was successfully I completed. Therefore, the violation is being treated as a NCV consistent witn  ;

Section Vll.B.1 of the NBC_ Enforcement _Rolicy.  !

c. Conclusion The inspectors continue to observe problems with operator communications and shift tur.7 overs. The plant is currently upgrading procedural requirements to formalize the turnover process. One NCV was identified.

IIL_ Engineering E2 Engineering Support of Facilities and Equipment E2.1 High_ Pressure _ Vent _ Operations _at_the_Iails_WithdrawaLStation i a. Inspection _Scopa_(8R1001 l

The inspectors walked-down the tails withdrawal system including the high pressure vent (HPV) system and discussed the system operation with operations personnel.

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b. Observations and Findings The inspectors toured the X-330 building and noted the HPV panel in the stairwellleading to the tails compressor area near unit X-29-1.

The HPV for the tails compressors is a manually operated system used to mitigate a minor out-gar 5g of UF, at a tails compressor as described in Table 4.2-5 of the Portsmou+ , Salaty Analysis Report (SAR). System operation was described in Po.:t. mouth Procedure XP4-CO-CA2380, " Operations of the Tails Station," Revision 1. A note in step 8.11.3 of the procedure identified controls for the HPV found in area control room (ACR) 2, at Surge and Waste Panel 3, and in Airlock 29-1 (stairwell near unit X-29-1). Section 3.2.2.4.1 of the Portsmouth SAR identified three locations (ACR 2, the stairwell, and the tails stations) for operating tails HPV.

The inspectors discussed with several tails station operators what actions to take during a minor outgassing of UF, from a tails compressor seal failure.

The tail station operators interviewed indicated they would go up the stairwell and verify the outgassing. Then they would call operators in ACR 2 to secure the tails compressors and depressurize the station to mitigate the release.

Those actions were in accordance with Portsmouth Procedure XP4-CO-CA2380 for situations where the HPV was inoperable. When the inspectors asked tails station operators abra the purpose of the HPV panelin the stairwell, one operator did not know s 'e others stated it was for operating the HPV system which had nevi .,een operable. The operators were not aware of the procedure step anr te identifying the HPV panels and their use.

The inspectors discussed the observations wm the facility manager for the X-330 building. The facility manager stated the panel in the stairwell had been a modification prior to March 3,1997, and it was not declared operable because no post-installation acceptance testing hdd been developed. The system engineer had walked-down the modification and had been developing acceptance testing but the system lacked a high priority. The modification process prior'to regulatory transition was acknowledged to have weaknesses which Portsmouth Compliance Plan Item 23 was developed to address. The current configuration control program would require acceptance testing to be completed prior to placing a system in service. Placing the system in service would include procedure changes and training to accurately reflect the status of the system.

Step 8.11.3 in Procedure XP4-CO-CA2380, " Operations of the Tails Station,"

Revision 1, directed use of a system which had not completed acceptance testing. Changes A and B, made after regulatory transition, provided l opportunities to maintain the procedure to accurately reflect the status of the HPV. Failure to maintain a procedure covering operator actions to prevent or mitigate the consequences of accidents described in SAR Chapter 4 is a Violation of TSR 3.9.1 (VIO 70-7002/97004-01).

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c. Conchininna l

Past' problems in configuration control of modifice4ns resulted in a procedure to reflect a modification prior to the modified syste..a being placed in service.

i One violation was identified.

!' E8 Mincallananum Enginaarina ISS"** i l

t E8.1 '(Placa<il Inenactinn Fnlinwun item flFn 70-700?/9700 1 01? The inspectors reviewed the USO determination for the as-found condition of autoclave condensate drain

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screens identified in Section 01.2 of Inspection Report No. 70-7002/97003. The I safety evaluation process used for the USQ determination was described in Portsmouth Procedure XP2-EG-NS1030, " Safety Evaluation of As-Found Discrepancies," Revision 0, and United States Enrichment Corporation (USEC)

Procedure UE2-EG-NS1030, "Unreviewed Safety Question Determination," l Revision O. Safety evaluation (SE) 97-0134, Revision 0, dated May 20, concluded there was no unreviewed safety question (USO). The SE was initially reviewed by  :

the plant operations review committee (PORC) on May 21 and rejected because the  ;

SE did not adequately address the condensate drain screen's effect on water inventory control. The SE was approved by the PORC on May 23 with a minor revision stating that partial blockage of the screen was unlikely; therefore, there would be no effect on water inventory. The conclusion that partial blockage was i r- unlikely was based on interviews with operators, reviews of problem reports, and

. procedure requirements for visual inspection for debris prior to initiating a heating cycle.

l The inspectors identifie'd debris in the autoclaves from routine evolutions. The inspectors also noted that there was no foreign material exclusion practices in place l to prevent material from fallir.g into the autoclaves. In addition, after the screens were removed on June 1, Autoclave No. 4 in the X-344 building had a high r condensate level system actuation that later was found to be due to debris in the l'

condensate line. The debris included gaskets and welding rods. This type of material in the condensate line indicated there was a problem with debris in autoclaves which the screens could have caught resulting in a potential partial l blockage above the condensate line.

i The inspectors discussed the SE with the safety analysis engineers. The engineers indicated there was not very good guidance on how to do an as-found safety 1 L . evaluation. The USQ determination guidance was developed to analyze proposed changes. The questions asked in the USO determination would be hypothetical questions. In the as-found condition, the engineers felt questions would be based on l actual history, that is, had there been partial blockage.

Portsmouth Procedure XP2-EG-NS1030, " Safety Evaluations of As-Found Discrepancies," Revision 0, was the procedure used to conduct the SE. The ourpose of the nracedure' was to evaluate an as-found condition's potential affect on the safety bds. The procedure did not provide adequate guidance to the safety analysis engineers to identify that the potential for partial blockage existed and that there 8

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e was the potential for the condition to increase the consequences of an accident l previously identified in the SAR. Partial blockage of the screen could cause the water inventory to be exceeded in an autoclave. If a UF, release occurred in an X-344 autoclave and the water inventory was exceeded, then the autoclave rupture disc would be challenged increasing the consequences of an accident identified in Section 4.2.3.2 of the SAR. American Society of Mechanical Engineers (ASME)

NOA-1-1989, " Quality Assurance Program Requirements for Nuclear Facilities," as ,

i required by 10 CFR 76.93 states, in part, that activities affecting quality shall be prescribed by procedures which shallinclude or reference appropriate quantitative or qualitative acceptance criteria for determining that prescribed activities have been satisfactorily accomplished. The procedure inadequacy is a Violation of 10 CFR 76.93 (VIO 70-7002/97004-02).

E8.2 IOpenLinspectinn Fnlinwup_ Item _(1FI)70-700?/97003-09: The facility engineering staff provided calculations demonstrating the design feature safety margin of 5:1 to the inspectors for review. The calculations indicated a 5:1 safety margin to ultimate failure and a 3:1 margin to yield. The inspectors questioned the reference to an ultimate failure safety margin and yield safety margin and noted the SAR and TSR l 'did not specify the safety margin as ultimate failure nor yield. Review of the old calculations before the SAR development indicated the calculations were for ultimate failure. The facility nuclear regulatory assurance staff was in the process of initiating a plant change request (PCR) to clarify which safety margin was referenced in the SAR and TSR. The IFl will remain open pending further review of the calculations.

IV._P_lant_ Support S1. Conduct _nLS ecurity_and_Sa feg uard_ Activities S 1.1 Access _to_ Classified _ Matter

a. Inspection.Scopaj9.0M l

l The inspectors walked-down several plant systems in the X-330 building.

b. . Observations _and_Eindings On June 13, the inspectors conducted a walk-down for a valving line up in I the X-330 building. The inspectors noted a valve actuator cover plate in ACR

2. The label on the cover plate appeared to identify a confidential restricted I data process. -The inspectors verified through the plant shift superintendent (PSS) that the labeling did present confidentialinformation. The PSS made the appropriate notifications for the possible compromise.

Security practices restrict access to ACRs such that classified material would be secured before uncleared personnel would be allowed in the ACR.

l However, since the labeling was not identified as classified material, ACR l personnel were not securing (covering) the labeling when uncleared personnel i entered the ACR.10 CFR 95.35(a) requires, in part, that no person subject to

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. the regulations in this part 'may receive or may permit any individual to have access to matter revealing Confidential Restricted Data unless the individual has a "O" or "L" access authorization. The failure to secure confidential material before allowing uncleared personnel access to the ACR is a Violation (VIO 70-7002/97004-03).

c. Conclusions The failure to recognize valve labeling in the ACR as confidential restricted -

data led to a violation of 10 CFR 95 being identified for a possible compromise of confidential data.

S8  : Miscellaneous _ Security and Rafeguard_ Issues S8.1 Bours_oLWntk

a. Inspection _Stope_(RR 1001 The inspectors reviewed the security practice of using overtime in excess of the TSR limits to meeting minimum manning requirements.

l b. . Observatinns and Findings The inspectors noted PSSs had approved overtime for security staff in excess L of the TSR .3.2.2.b limits on a weekly basis during June. Documentation for

the approvals indicated overtime was needed to meet minimum manning

! requirements. The overtime requirements for the security force included TSR Table 3.2.2-1 minimum staffing on occasion. The process for approving overtime per Portsmouth Procedure XP2-HR-LR1030, " Limitations on Hours of Work," Revision 0, was followed.

The weekly nature of the approvals is contrary to TSR 3.2.2.b which states

" routine deviations from the above guidelines is not authorized". The weekly approvals appeared to be a violation of TSR 3.2.2.b. However, in a l

letter to the NRC dated June 26, USEC has stated a position that l TSR 3.2.2.b limitations on the hours work does not apply to the security _

staffs at Portsmouth and Paducah.' The letter is being reviewed by the NRC.

! Until the review is complete and a response is sent to USEC, the weekly l- approval of overtime in excess of TSR 3.2.2.b limits will be tracked as an

! Unresolved item (URI 70-7002/97004-04).

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c. Conclusions i The inspectors determined that routine use of overtime in excess of TSR limits l was being used to meet manning requirements in security. One URI was identified.

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v. - uanasament_Maatings

! l X1 Frit Manting Rummary

, The inspectors presented the inspection results to members of the facility t

-management on June 30,1997. The facility staff acknowledged the findings presented.

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h PARTIAL LIST OF PERSONS CONTACTED -

Lockhead_ Martin litility Services (1-MUS)

• D.1. Alleri, General Manager *

• J. B. Morgan,' Enrichment Plant Manager

• M. Hasty, Engineering Manager

• R. W. Gaston, Nuclear Regulatory Affairs Manager

'C. W. Sheward, Maintenance Manager

• R. D. McDermott, Operations Manager -

United Riates Fnrichment Corporation l J. H. Miller, USEC Vice President, Production

• L Fink,' Safety, Safeguards & Quality Manager I 1

Unitad Riatas Departrnent of Energy _(DOEl J. C. Orrison, Site Safety Representative Nuclear _Begulatory_ Commission _(NRCl P. L. Hiland, Chief, Fuel Cycle Branch

• C. R. Cox, Senior Resident inspector i

• D. J. Hartland, Resident inspector Y. H. Faraz, Project Manager, NMSS

• Denotes those present at the exit meeting on June 30,1997.

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INSPECTION PROCEDURES USED i

IP 88100 Plant Operations IP 88101 Configuration Control

' IP 88102 Surveillance Observations l IP 88103 Maintenance Observations IP 88105 Management Oversight and Controls

IP 88020 Regional Criticality Safety IP 97012 Inoffice Reviews of Written Reports on Nonroutine Events ITEMS OPENED, CLOSED, AND DISCUSSED Opened

70-7002/97004-01 VIO Failure to maintain procedures covering operator actions to prevent or mitigate the consequences of accidents described in SAR Chapter 4. 1

! 1 70-7002/97004-02 VIO Inadequate procedure for performing SEs to evaluate as-found conditions.

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70-7002/97004-03 VIO Failure to secure confidential material before allowing unclear personnelin ACR.

70-7002/97004-04 URI Applicability of TSR overtime limits to plant security force.

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70-7002/97003-01 IFl Review of USQ determination for the X-344 building autoclave screens.

l Discussed 70-7002/97003-09 IFl Review of design calculations for H-Frames. I l

Certification _ Issues - Clnsed None i

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LIST OF ACRONYMS USED ACR- Area Control Room

• ASME- , American Society of Mechanical Engineers CAAS . Criticality Alarm Actuation System

-CFR ' Cnde'of Federal Regulations i DNMS Division of Nuclear Material Safety *

.EBS- Evacuation Booster Station

.HPV High Pressure Vent .;

~IFl~ inspection Followup item f

'IP inspection Procedure

.. . LCO ' ' Limiting Condition for Operation-l' NCV.- Non-cited Violation ,

NOV Notice of Violation NRC Nuclear Regulatory Commission PCR. Procedure Chan0e Request

• PDR Public Document Room I ' P M T'. Post Maintenance Test PORC. Plant Operations Review Committee PSS~ Plant Shift Superintendent '

QAP Quality Assurance Plan SAR Safety Analysis Report.

L SE Safety Evaluation -

.TSR Technical Safety Requirement  :

U F, . Uranium Hexafluoride URI Unresolved item USEC United States Enrichm' ent Corporation USO Unreviewed Safety Question VIO Violation 2:

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