ML20195H302

Insp Rept 70-7002/98-16 on 981019-23.Violations Noted.Major Areas Inspected:Operations,Maint & Plant Support

ML20195H302
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant
Issue date:	11/12/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20195H275	List: ML20195H270 ML20195H290 ML20195H302
References
70-7002-98-16, NUDOCS 9811230304
Download: ML20195H302 (12)

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U.S. NUCLEAR REGULATORY COMMISSION REGION lil Docket No: 70-7002 Certificate No: GDP-2 Report No: 70-7002/98016(DNMS) a Facility Operator: United States Enrichment Corporation Facility: Portsmouth Gaseous Diffusion Plant Location: 3930 U.S. Route 23 South P.O. Box 628 Piketon, OH 45661 Dates: October 19 through 23,1998 Inspector: R. G. Krsek, Fuel Cycle Safety inspector Approved By: Kenneth G. O'Brien, Acting Chief Fuel Cycle Branch Division of Nuclear Materials Safety I'

9811230304 981112 7' PDR ADOCK 07007002 C pm

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EXECUTIVE

SUMMARY

United States Enrichment Corporation Portsmouth Gaseous Diffusion Plant NRC Inspection Report 70-7002/98016(DNMS)

Plant Operations

. The inspector concluded that adequate corrective actions were being taken to address the root causes for a violation involving safety-related air-to-close valves. In addition, the certificatee initiated an action plan to verify that Safety Analysis Report design bases systems, that were credited for backup support, were properly tested. As a result of the action plan, the plant staff self-identified numerous issues associated with safety system components. (Section O8.1)

Maintenance

. The inspector concluded that maintenance staff were knowledgeable of the systems worked on and performed work in scwrdance with the applicable procedures and permits. Work packages reviewed by the inspector were adequately completed and closed; however, some weaknesses were noted regarding entries in the work-in-progress logs. (Section M1.1)

. The inspector identified a violation of 10 CFR 76.93 in that plant management failed to establish measures to ensure that instruments used to measure the closing time, an activity affecting quality, of the withdrawal station pigtailisolation and autoclave containment isolation valves (Q items) were of the proper type, range, and accuracy.

During subsequent testing, some valves were identified with closure times in excess of the performance limits specified in the Safety Analysis Report. The inspector also identified that certain surveillance test records did not appear to incorporate the minimum data required by the Quality Assurance Program. (Section M1.2)

Plant Supoort

. The inspector concluded that plant staff continued to effectively implement corrective )

actions in the Training Organization. The inspector noted improvements in the processes for ensuring plant staff were properly trained, and for administering work restrictions to plant staff delinquent in required training. (Section T1.1) 2

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$- ReDort Details 1

1. Operations

.r 08 Miscellaneous Operations issues 08.1 Review of Corrective Actions Taken for Air-to-Close Containment Valve issues

a. [nspection Scope (88020 and 92702)

The inspector reviewed the status of corrective actions taken for the Severity Level ill violation issued by the NRC on July 14,1998 (VIO 70-7002/98005-07). The violation involved a programmatic deficiency in the maintenance and surveillance program for

! air-operated, safety-releted valves at the Portsmouth plant.

j b. Observations and F;ndinas The plant staff Jetermined that the root cause of the violation was a failure to develop i a testing progtum to demonstrate that autociave air-to-close valves would perform

the intended design function, upon loss of the normal supply of air. Inspection i Report 70-7002/98005(DNMS) documented the immediate corrective actions taken i

by the plant staff. The certificatee's violation response dated August 10,1998, (GDP-98-0159) documented additional long-term corrective actions.

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. During the inspection, the inspector verified that the plant had established formal valve j testing criteria. Procedure XP4-TE-lM6715, " Autoclave Air Volume Tank Containment i Valve Test," Revision 0, prescribed instructions for testing the autoclave air volume tank

{. containment valves. In addition, the inspector observed the performance of the test j during the inspection (See Section M1.1). The inspector noted that Procedures XP4-

TE-UH6702, 'X-342 and X-343 Autoclave Quarterly Test," and XP4-TE-FD6717, j "X-344 Autoclave Quarteriy Test," were also revised to include quarterly testing criteria for the backup air reservoir tanks. The inspector verified that the plant staff developed g corrective actions addressed the air-to-close valves at the withdrawal stations and Building X-705. A quarterly preventive maintenance program was also established for the withdrawal station and Building X-705 valves. The quarter 1y preventive maintenance

program testing of the air-to-close valves was initiated on June 28,1998, as stated in

the violation response. The inspector noted that the corrective actions effectively addressed the root cause of the violation and the violation is considered closed.

In the violation response, the certificatee also committed to develop an action plan to verify that all Safety Analysis Report (SAR) design bases systems credited for backup were properly tested. On July 9,1998, the engineering staff documented an action plan to implement the corrective action. The action plan established two member teams to perform a review of all safety systems and the associated supporting systems. The plan required the teams to perform the following actions for each safety system: (1) become familiar with the safety system design and associated Technical Safety Requirement Surveillances; (2) determine the safety system design functions; (3) identify necessary support systems to the safety system; (4) identify the function of each component which satisfies the safety system design function; (5) review the current testing and surveillance programs associated with each safety system; and (6) determine if the safety system function of each component is properly tested by the current testing and 3

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surveillance program for the safety system. The final outcome of the review was a safety function verification team report. At the time of the inspection, the safety function verification teams were on schedule and had identified 26 significant issues which were documented in the plant problem reporting and corrective action system. The plant staff planned to complete the action plan in December 2002,

c. - Conclusion The inspector concluded that adequate corrective actions were being taken to address the root causes for Violation 70-7002/98005-07. An action plan to verify that SAR design bases systems credited for backup were properly tested was also initiated by the certificatee. The inspector noted that as a result of this action plan the plant staff have self-identified numerous issues associated with safety system components. The NRC

. will continue to monitor the certificatee's implementation of safety system surveillances as a part of the routine inspection program.

11. Maintenance M1 Conduct of Maintenance M1.1 Observation and Review of Onaoina Maintenance and Surveillance Activities

a. Inspection Scoos (88025)

The inspector reviewed maintenance work packages and procedures, interviewed maintenance and operations staff, and observed work activities and maintenance crew briefings,

b. Observations and Findinos The inspector observed ongoing maintenance activities conducted in Buildings X-333, X-343, and X-344. The inspector observed a seal replacement, an augmented quality (AQ) activity, for Unit 2, Cell 6 in Building X-333 and noted maintenance staff were knowledgeable of the work performed and the applicable safety permit requirements.

The inspector verified that the required hazardous energy lockouts and tagouts were in I place for the maintenance evolution. Maintenance staff were also observed using the appropriate personal protective equipment.

On October 22 the inspector observed the pneumatic, pilot-operated, air-to-close l containment valve test for Autoclave No. 6 in Building X-343. The requirements for performance of this quality (Q) system test were prescribed in Procedure XP4-TE-  !

IM6715 " Autoclave Air Volume Tank Containment Valve Test." The maintenance  !

evolution took place after the plant staff's identification of the issues described in Section M1.2 of this report. The inspector noted that the test was performed with the required measuring and test equipment (M&TE) for the measurement of time and pressure. Maintenance staff performing the test were knowledgeable of the overall system and the procedure-specified scope of work and performed the maintenance test in accordance with the procedure. All applicable work package documentation for the maintenance activity was properly completed.

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The inspector reviewed several completed maintenance work packages for Q system maintenance activities in the Building X-340 complex. The inspector noted that overall, the maintenance work packages reviewed were adequately completed and closed.

However, some weaknesses were identified in entries made in plant work-in-progress

logs for the reviewed maintenance work. Specifically, the plant staff did not make

, entries in the work-in-progress logs for special work and did not document some actions j taken for other maintenance evolutions,

c. Conclusions The inspector concluded that maintenance staff were knowledgeable of the systems worked on and performed work in accordance with the applicable procedures and permits. Work packages reviewed by the inspector were adequately completed and closed; however, some weaknesses were noted in the plant staff's use of the work-in-progress logs.

M1.2 Imolementation of the Measurina and Test Eauioment Proaram i

a. Inspection Scooe (88025)

I j The inspector reviewed maintenance work packages for surveillances and post-maintenance tests conducted on withdrawal station pigtail isolation and autoclave j containment isolation valves. The inspector also reviewed the requirements and j

procedures associated with the M&TE program.

b. Observations and Findinas On October 21 during a review of Q safety system component maintenance work packages, the inspector identified that the work package documentation did not specify the use of M&TE for the measurement time. Time measurement was required for some i surveillances and post-maintenance tests of Q isolation valves to ensure that the

, isolation valves closed within the period of time specified in the SAR accident analysis.

1 During discussions with maintenance and operations staff, the inspector was informed

that when work packages or post-maintenance tests required the measurement of time, the plant staff typically used either wall mounted clocks or wristwatches. The inspector

} noted that in the Building X-340 complex, the wall mounted clocks were located i approximately 20 to 30 feet away from the isolation valves.

4 Maintenance management, responsible for implementation of the M&TE program, also 1 informed the inspector that instruments and other measuring and test devices used to test time were not incorporated into the plant M&TE program. Based upon an j independent review of the inspector's findings, the plant staff initiated Problem Report

. (PR) PTS-98-07145 which documented that Q system surveillances and post-

maintenance tests requiring the measurement of time were not conducted in accordance with Quality Assurance Program requirements. In addition, plant

} management assembled a minl-Operational Assessment Team (OAT) to evaluate any immediate safety system operability, reportability, or compliance concerns associated with the issue. The inspector observed the mini-OAT and noted that discussions were i

focused on immediate safety issues. The mini-OAT reviewed operations which were 4 affected by the quality assurance issue and the engineering staff provided the Plant Shift Superintendent (PSS) with a reasonable assurance of operability for those safety i

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systems in service. The inspector noted that the engineering staff's documented basis for reasonable assurance of operability was generic in scope, addressed a wide range of safety system components, and did not provide specific bases for each system.

Based on the mini-OAT meeting, the PSS took action to: (1) ensure that no current inoperable and out-of-service safety-related equipment was returned to service without required testing using the appropriately calibrated and controlled time measurement s , devices; (2) request e Plant Operations Review Committee (PORC) operability evaluation (OE) for all SAR, Technical Safety Requirement, and boundary book safety system components; and (3) request calibrated and controlled timing devices be delivered to Portsmouth from the Paducah Gaseous Diffusion Plant M&TE program.

Upon receipt of the M&TE timing devices from the Paducah Gaseous Diffusion Plant, the plant staff performed functional tests of some safety system components, including the withdrawal station pigtail isolation an i autoclave containment isolation valves. The inspector noted that the SAR, Sections 4.2.3.2, " Pigtail Rupture Accident Analysis," and

, 4.2.3.4, " Pigtail Gasket Failure Accident Analysis," required the withdrawal station pigtail l isolation and autoclave containment isolation valves to close within 5 and 15 seconds, respectively, following a containment signal. The inspector also noted that the withdrawal station pigtail isolation valve 5 second closure time was the shortest response time requirement specified in the SAR accident analyses.

On October 23 the Building X-330 tails withdrawal station pigtail isolation valve closure l times were tested. Tests results for Position Nos.1 and 2 were determined to be I acceptable with closure times less than 5 seconds. However, test results for Position No. 3 documented that the valve took 6.6 seconds to close versus the acceptance criteria of 5 seconds. The inspector noted that Position No. 3 was last used October 20. During the week of November 5,1998, the inspector was informed that i some autoclave containment isolation valves failed the 15-second valve closure time i

test. The closure times for valves which failed the tests were in the range of 15.5 to 38.2 seconds. In allinstances where the closure time acceptance criteria was exceeded, the PSS declared the systems inoperable pending further evaluations and corrective actions, as appropriate.

1 Title 10 of the Code of Federal Regulations, Part 76.93, " Quality Assurance," requires, in part, that the Corporation shall establish, maintain, and execute a quality assurance

. program. Section 2.12 of the Quality Assurance Program," Control of Measuring and

, Test Equipment," requires, in part, that a system is established for the control of measuring and test equipment for Q items as specified in Section 2.2 of the Quality Assurance Program. Section 2.12 further requires that the system establish measures i to ensure that instruments and other measuring and testing devices used in activities l affecting quality are of the proper type, range, and accuracy. l Section 2.2.of the Quality Assurance Program and Section 3.8 of the Safety Analysis Report, *Q, and AQ Structures, Systems and Components," establish withdrawal station I pigtail isolation and autoclave containment isolation valves as Q items. Safety Analysis Report Sections 4.2.3.2, " Pigtail Rupture Accident Analysis," and 4.2.3.4, " Pigtail Gasket i Failure Accident Analysis," require the withdrawal station pigtail isolation and autoclave containment isolation valves to close within 5 and 15 seconds, respectively, in order to 4 ensure that accidental releases of uranium hexafluoride remain within the bounds of the accident analysis. The failure to establish measures to ensure that instruments used to i

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measure the closing time, an activity affecting quality, of the withdrawal station pigtail isolation and autoclave containment isolation valves (Q items) were of the proper type, range, and accuracy, as demonstrated, in part, by the failure to maintain the valves closing times with the performance limits specified in the SAR accident analyses is a Violation of 10 CFR 76.93 (VIO 70-7002/98016 01).

On October 22 the inspector observed a PORC meeting held to review an engineering staff-developed OE, SE-1998-0324, "The Use of Uncalibrated Timing Devices." The inspector noted that the PORC members exhibited a questioning attitude during their review of the OE. During the discussions, the inspectors observed that the engineering staff could not provide the PORC members with the results of previous tests of the withdrawal station pigtail isolation valves and could not fully characterize the potential impact of the previous lack of control of timing devices used to perform required surveillances and post-maintenance tests. As a result, the PORC rejected the OE. On November 10,1998, the PORC Chairman contacted the inspector and indicated that the PORC had rejected two additional versions of the OE proposed since the end of the -

inspection. The PORC Chairman indicated that engineering staff continued to work to develop an acceptable OE for the issue.

Subsequent to the PORC meeting, the inspector reviewed the procedures used to direct the routine Technical Safety Requirement testing of the withdrawal station pigtail isolation vralves. The inspectors noted that the procedures only required the plant staff to document the acceptability of the tests performed. The inspector also noted that Section 2.11.3, " Test Control," of the Quality Assurance Program required test records to contain as a minimum, both the test results and acceptability of the test. The inspector discussed the findings with plant management to determine if the acceptance criteria were maintained in other portions of applicable work documents. Pending the plant management's review of the inspector's findings and the inspector's assussment of any applicable documentation, the issue will be tracked as an Unresolved item (URI 70-7002/98016-02).

c. Conclusion The inspector identified a violation of 10 CFR 76.93 in that plant management failed to establish measures to ensure that instruments used to measure the closing time, an activity affecting quality, of the withdrawal station pigtailisolation and autoclave containment isolation valves (Q ltems) were of the proper type, range, and accuracy. As a result, during subsequent testing of isolation valves using controlled and calibrated measuring equipment, the plant staff identified some valves with closure times in excess l of the performance limits specified in the SAR. The inspector also identified that certain l

surveillance test records did not appear to incorporate the minimum data required by the 1 Quality Assurance Program. Further review of the latter issue will be tracked as an URI.

l M8 Miscellaneous Maintenance issues

' M8.1 (Closed) VIO 70-7002/98005-04: The violation was cited in the July 14,1998, Notice of Violation issued to the United States Enrichment Corporation (USEC) for the operation of an autoclave when the autoclave shell high pressure containment safety system component was incapable of performing a specified safety function. The violation was a direct result of Violations 70-7002/98005-05a,b and 70-7002/98005-06. The inspector l reviewed the root causes and corrective actions documented by the certificatee in the  ;

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1 August 10,1998, violation response and determined that the corrective actions appeared adequate. The inspector noted that full compliance with the applicable i Technical Safety Requirement was achieved on March 27,1998, when the affected

, autoclave was secured and declamd inoperable. Based uoon the inspector's review of corrective actions taken for the root and contributing causes for the violation, as discussed in Sections M8.2 and M8.3 of this report, this issue is considered closed.

I M8.2 (Closed) VIO 70-7002/98005-05a.b: The violation was cited in the July 14,1998, Notice of Violation issued to USEC for a failure to conduct maintenance activities in accordance with approved procedures. Specifically, during the performance of maintenanco activities on containment valve actuators, the maintenance staff failed to perform " bench 3 marking" of valve components and operational checks, as required by the maintenance procedure. The plant staff determined that the root and contributing causes for the i failure were as follows: (1) a lack of plant staff 'mderstanding of the procedural i requirements associated with implementatior, of ' General Intent" procedures; (2) inconsistencies in the training module or' pecadure use and Procedure UE2-PS-PS1034,"Use of Procedures"; (3) a i.Gre of the plant staff to perform a review of all " General Intent" procedures when the criteria for "In Hand" procedures was revised I in August 1997; and (4) a failure of the plant staff to provide specific guidance in Procedure XP4-TE-MM4104, " Valve Actuator Renewal, Replacement, and Installation,"

regarding operational checks. The inspector reviewed the root causes and corrective actions documented in the August 10,1998, violation response and noted that these actions, coupled with the plant's intemal corrective action plan, effectively addressed the scope of the violation. The inspector verified that all of the corrective actions described in the violation response had been taken through interviews with maintenance and operations staff, and through reviews of action plan documentation and updated procedures. The inspector concluded the certificatee's corrective actions were effective and considered the violation closed.

M8.3 LQIosed) VIO 70-7002/980054)6: The violation was cited in the July 14,1998, Notice of Violation issued to USEC for a failure to perform post-maintenance testing which demonstrated that safety system components would perform satisfactority in service after maintenance activities. The plant staff determined that the root and contributing causes for the failure included: (1) a lack of procedural guidance for developing and performing post-maintenance tests; and (2) poor communications among operations staff during the performance of the post-maintenance test. The inspector reviewed the root causes and corrective actions documented in the August 10,1998, violation response and noted that these actions, coupled with the plant's intemal corrective action plan effectively addressed the scope of this violation. The inspector reviewed Procedure XP3-EG-EG4010. " Post Maintenance Testing of Q, AQ and AQ-NCS Systems, Structures, or Components," dated July 16,1998, and noted that the engineering staff had proceduralized guidance for the development of post-maintenance tests. The procedure required the use of applicable Technical Safety Requirement surveillances as the post-maintenance test for safety system components and established a peer review of all post-maintenance tests. During tours and inspections, the inspector verified that post-maintenance tests were written in accordance with Procedure XP3-EG-EG4010.

The inspector concluded the certificatee's corrective actions were effective and considered the violation closed.

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l l IV. Plant Support l

'16 . Training Organization and Administration

.16.1 Review of Trainina Oraanization Corrective Action Plan

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a. Insoection Scope (88010 and 92702F l The inspector reviewed the training staff's actions to address deficiencies within the i training organization. The inspector reviewed revised plant procedures and corrective i action documentation, in addition to interviewing training staff.

I b.~ Observations and Findinas  ;

On July 24,1998, USEC transmitted a supplemental response (GDP-98-2037) to a .

Notice of Violation from inspection Report 70-7002/98008(DNMS). The response j addressed additional planned corrective actions to enhance the overall effectiveness of '

the training organization.

The plant staff established a Training Advisory Board (TAB) on August 3,1998, approximately two weeks prior to the commitment date indicated in the July 24,1998, supplemental response. The inspector discussed the results of the first TAB meeting  !

with training management and noted that the TAB had addressed several training issues i including: (1) the establishment of a TAB charter; (2) the initiation of reviews and  :

revisions to training review matrices for senior plant management; (3) the documentation of guidance for the newly established training review groups (TRG); and (4) the review of recent performance indicators. The inspector also noted that plant management had established TRGs for each plant organization, and that each TRG had held at least one meeting. The initial focus of the individual TRGs was to review and subsequently revise organizational and group training review matrices. At the time of the inspection, the TRGs were on schedule to review and revise the training review .

matrices by November 30,1998. The training organization had also augmented the maintenance training staff by assigning two additional technical trainers and identifying additional qualified on-the-job training instructors for maintenance training activities.

The inspector also reviewed Procedure XP2-TR-TR1030, " Conduct of Training,"

Revision 1, Sections 6.1.3 and 6.3. The inspector determined that significant changes had been made to the procedure, in that, the procedure now included a well-defined ,

process to ensure employees were properly trained, prior to the employee moving from l one job function to another, and to ensure the proper administration of training-related work restrictions.

c. Conclusion The inspector concluded that plant staff continued to effectively implement corrective actions in the training organization. The inspector noted improvements in the processes for ensuring plant staff were properly trained, and for administering work restrictions to plant staff delinquent in required training.

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18.0 Miscellaneous Training issues 18.1 (Closed) VIO 70-7002/98005-10: The violation was cited for the failure to revise on-the-job training modules when procedure changes required the training modules to be revised. The certificatee determined that the root cause of the violation was a lack of enforcement of procedure requirements for several implementing procedures, which resulted in a breakdown in communications within the training and proceduro l organization. The certificatee's review also identified that a total of 84 on-the-job l training modules required revisions. The inspector noted that the 84 on-the-job training guides were appropriately reviewed and updated by August 30,1998. The inspector also noted that changes were made to Procedures XP2-PS-PS1033, " Procedure  !

Change Process," and XP2-TR-TR1030, " Conduct of Training," to enhance the J

interfacing of training and procedure staff during procedure changes and the process for conducting training module reviews and revisions. The inspector verified that the corrective actions taken for this violation, as described in the June 17,1998, USEC ,

response to the Notice of Violation (GDP-98-2025), were implemented and completed. I The inspector concluded the certificatee's corrective actions were effective and considered tM violation closed.

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V. Manaaement Meeting 1 X1 Exit Meeting Summary The inspector presented the inspection results to members of the plant management and staff j

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at the conclusion of the inspection on October 23,1998. The plant management acknowledged 1 the findings presented at the meeting. The inspector asked the plant management whether any l materials examined during the inspection should be considered proprietary. No proprietary I information was identified.

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

• J. Anzelmo, PORC Chairman J. Brown, General Manager

• D. Couser, Acting Training and Procedures Organization Manager

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• P. Hopkins, Acting Engineering Manager P. Miner, Nuclear Regulatory Affairs Manager J

• T. Sensue, Nuclear Regulatory Affairs

• R. Smith, Production Support Manager

• D. Waters, Nuclear Regulatory Affairs

• M. Wayland, Maintenance Manager

• Denotes those present at the exit meeting on October 23,1998.

INSPECTION PROCEDURES USED IP 88010: Operator Training and Re-Training IP 88020: Operational Safety Review IP 88025: Maintenance and Surveillance Testing IP 92702: Follow-up on Violations / Deviations ITEMS OPENED, CLOSED, AND DISCUSSED Opened 70-7002/98016-01 VIO Failure to establish a system to control and calibrate instruments and other measuring and testing devices used to test time for quality components and to ensure that equipment performance is maintained within the limits specified in the Safety Analysis Report.

70-7002/98016-02 URI Documentation of test results and conformance with requirements specified in Quality Assurance Program Section 2.11.

Closed 7002/98005-04 VIO Operation of Autoclave No. 4 while containment valve FV-416X was operating incorrectly, Technical Safety Requirement 2.1.3.5 (EA-249).

70-7002/98005-05a,b VIO Failure to perform Sections 8.2.12 and 8.2.24 of maintenance Procedure XP4-TE-MM4104 during the replacement of the Valve FV-416X actuator (EA 249).  !

70-7002/98005-06 VIO Inadequate post-maintenance test instructions for j replacement of the Valve FV-416X actuator (EA-249). l l

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N ITEMS CPENED, CLOSED, AND DISCUSSED (cont'd) i Closed 70-7002/98005-07 VIO Air-to-Close autoclave safety system components in Autoclaves 1 through 5 of Building X-343 unable to perform the required safety function under certain conditions, Technical Safety Requirement 2.1.3.5 (EA-249).

70-7002/98005-10 VIO Failure to revise the training modules as required by the conduct of training procedure.

Discussed None LIST OF ACRONYMS USED AQ Augmented Quality DNMS Division of Nuclear Materials Safety LMUS Lockheed Martin Utility Services M&TE Measuring And Test Equipment OAT Operational Assessment Team OE Operability Evaluation PDR Public Document Room PORC Plant Operations Review Commktee PR Problem Report PSS Plant Shift Superintendent Q Quality SAR Safety Analysis Report  ;

TAB Training Advisory Board TRG Training Review Group

- URI Unresolved item USEC United States Enrichment Corporation VIO Violation

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