ML20198F277
| ML20198F277 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 12/18/1998 |
| From: | Ting P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20198F268 | List: |
| References | |
| 70-7002-98-208, NUDOCS 9812280082 | |
| Download: ML20198F277 (23) | |
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t l U.S. NUCLEAR REGULATORY COMMISSION I
OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS !
= CRITICALITY SAFETY INSPECTION REPORT 1 l
l Docket No. 70-7002 Certificate No. GDP-2 Report No. 70-7002/98-208 ,
1 Applicant: United States Enrichment Corporation Location: Piketon, OH 45661 Inspection Dates: November 30 to December 4,1998 Inspectors: Dennis Morey Criticality Safety inspector liarry Felsher Criticality Safety Specialist Approved By: Philip Ting, Chief Operations Branch Division of Fuel Cycle Safety and Safeguards l
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r 9812290002 981218 M l PDR C ADOCK 07007002 pm }gl'i i
t UNITED STATES ENRICilMENT CORPORATION PORTSMOUTil GASEOUS DIFFUSION PLANT NRC INSPECTION REPORT 70-7002/98-208 l
EXECUTIVE SUMM ARY l Introduction The Nuclear Regulatory Commission (NRC) perfbrmed a routine, announced criticality safety inspection at the Portsmouth Gaseous Diffusion Plant located in Piketon, Ohio from ,
November 30 to December 4,1998. The inspection focused on the status and adequacy of the I Nuclear Criticality Safety (NCS) Corrective Action Plan (CAP), review of a recent change to Planned Expeditious llandling (PEll) deposit characterization, and open item review. The inspectors reviewed documents, interviewed plant staff, and conducted walkdowns of affected plant areas. The inspection effort was intended to help maintain a risk focus for future inspection efforts by identifying the primary risk area of the NCS CAP and c!osing open items that were complete.
During this inspection, the inspectors identified several weaknesses with the NCS program, opened two inspector Followup Items (IFis), and closed 22 open items from the previous criticality safety inspections.
Results
- The inspectors noted improvement in the implementation of administrative NCS controls.
- The inspectors determined that the NCS CAP is adequate to resolve programmatic NCS deficiencies.
- The inspectors identified a weal: ness in the reporting of CAP status by the certificatee.
- The inspectors determined that NCS Analyses / Evaluations (NCSA/Es) were generally of high quality.
- A weakness was observed regarding the establishment of the safety basis for water wagons in the cascade buildings.
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1 itEPORT DETAILS i.0 Plant Operations I i
- a. Scone The inspectors performed walkdowns of the X-326 and X-333 cascade buildings, X-344, X-705, and X-710 buildmgs. l l
- b. Observations and Findings The inspectors noted generel improvement in implementation of NCS controls in the facilities. For example, the inspectors observed that outdated postings had been removed, the certificatee was m the process of replacing steel dry active waste (DAW) drums with '
plastic drums at collection points, and ne violations of NCSA controls were observed.
The inspectors observed fissile material identification labels detached from containers stored in tissile material storage racks in Building X-326. The certMicatee took immediate action to locate the labels, identify which containers the labels belonged to, and reattach the labels to the containers.
The inspectors observed a large piece of equipment called a " water wagon" in the upstairs portion of Building X-333. The inspectors noted that the water wagons were different from other large containers in the cascade buildings in that the water wagcns A not have 1
drain holes to insure that they never become fliied with water. The certifict c.:ated that the wagon could hold about 1000 gallons of water and was used for drainha con ;ensers.
The equipment is mentioned in cascade NCSAs, but the certificatee stated tha: v equipment was not analyzed because it was not used for fissile material operations. The certificatee stated that there were no restrictions on where the wagon could go in the !
building. Wagons are not emptied immediately but are only emptied when they become full and so must be considered always full of water.
The inspectors asked if the wagon was ever moved under piping containing uranium hexafluoride (UF ) that was liquid or was at more than atmospheric pressure. The certificatee responded that liquid UF6 piping goes directly down to cylinders and is not located so that it would be possible for fissile material to enter a water wagon. The certificatee further stated that some cascade piping was positive pressure, but this piping ;
was all contained in cell housings where the water wagons could not be taken. The ;
inspectors asked the certificatee for a clear, written explanation of the safety basis of the water wagons. The certificatee responded that an engineering analysis would be perfbrmed.
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Subsequent to the on-site portion of the inspection, the certificatee performed an
. engineering evaluation, EVAL-CS-1998-0470, which specified the technical reasons why the water wagon is safe. The inspectors reviewed the certificatee evaluation and
- performed a series of confirmatory calculations. The inspectors performed the confirmatory analysis using the certificatee provided description of the equipment. The inspectors determined that with the water wagon filled to 25% capacity (1275 liters), the uranyl fluoride (UO 2F2) solution would become critical ( kefr+ 2a = 1.00 .006) at approximately 350 grams per liter of 5 wt% 235U, therefore requiring approximately 446 kilograms of UO 2F 2. These results are displayed in Figure 1 below which also demonstrates the behavior of the system near the critical value.
Concentration vs. k-eff 1275 Liter Container 1.2 - - - - --- - -- - -
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I.05 3 . .- _ _._ ._ - . _ --
,c o7,,,,.k. -103 -- .--*
25 0.8 - -- - - - - o7 ,,9L 0 q , -- -
0 %,. -
$ 0.6-0ja ,*0,54 a
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0.4 i- - ---
0.2 -- - - - - - - - -
0 - -- - - - - - - - ----- - - - ~ -
100 125 150 175 200 225 250 275 300 325 350 375 400 Concentration in grams UO2F2/ liter l
5 wt% U-235 )
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Figure 1 The inspectors reviewed the sensitivity of the calculation to a change in molarity and .
' determined that the calculation was not sensitive to this parameter. The inspectors also reviewed the minium critical mass of UO2F2 under optimal conditions (2.2 kilograms in a )
fully reflected cylinder according to Appendix F-1 of GAT-225 " Nuclear Criticality Safety Guide for the Portsmouth Gaseous Diffusion Plant") which occurs at a moderator to uranium ratio (H/U) of 530. Since only an unreflected slab is achievable in the water wagon, the inspectors determined that H/U will decrease substantially with slab thickness leading to a minimum critical mass substantially larger than under optimal conditions 1
such as more than 200 kilograms for a slab equivalent to a 5% full water wagon (approximately 67 gallons at 800 grams per liter and H/U of 27). Under normal circumstances, accidental accumulation of sufficient material for criticality is not 4
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expected due to plant configuration. Confirmatory calculations were perfonned with
. SCALE 4.3 using input similar to Figure 2 below.
KENO Input Example
- CSAS25 FATER WAGON 27GROUPNDF4 INFHOMMEDIUM FE 1 1.0 293 END SOLNUO2F2 2 350 0 1.0 293 92235 5 92238 9 5 A.3 END COMP 350 GRAMS PER LITER REAL PARM RUN=YES PLT =YES NUB =YES EIO PARM READ GEOM GLOBAL UNIT 1 COM=! WAGON WITH FE SHELL!
CUBOID 2 1 38 -38 45.6 -45.6 182.8 0 CUBOID 1 1 38.4 -38.4 46.1 -46.1 182.8 .4 END GEOM END DATA END Figure 2 The inspectors determined that the failure to recognize that the water wagons were different from other large containers in the cascade buildings, and therefore required NCS review, is a weakness.
- c. Conclusions The inspectors noted impiovement in the implementation of administrative NCS controls.
A weakness was observed the establishment of the safety basis for water wagons in the cascade. The certificatee performed an engineering evaluation subsequent to the inspection which adequately established the safety of this equipment.
2.0 NCS Corrective Action Plan (CAP)
- a. Scope The inspectors performed an extensive review of certificatee completion of the NCS CAP. Walkdowns of selected NCSA/Es were performed along with reviews of completion documentation packages. The CAP is a substantial effort to quantify and 5
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i resolve NCS issues at the facility. The inspectors elected to review the CAP because of
- . the safety significance of an effective NCS program at the facility and the existence of long term programmatic issues with the NCS program. l
- b. Observations and Findinus The inspectors reviewed the overall CAP to determine the extent of completion and the adequacy of the corrective actions taken. The inspectors determined that the CAP is adequate to resolve programmatic issues at the facility. l The inspectors noted that the current CAP is Revision 4 and is a compilation of activities that have taken place to resolve programmatic NCS issues for approximately the past year. The CAP outlines 28 tasks that must be completed of which the certificatee states that 22 are completed. Numerous activities are listed and discussed which do not have tasks listed. The inspectors general observations on the CAP Revision 4 are that many of the listed activities overlap and that there is an emphasis on review and correction of NCSA/Es.
The inspectors reviewed CAP Section B.l(a) which was titled "Walkdown of NCSA/Es Associated with Safety Analysis Report (SAR) Accident Scenario" because it appeared to overlap other NCSA/E reviews. Section B.l(a) stated that 13 walkdowns were performed. The inspectors requested a list of the NCSA/Es and the criteria for selection.
The certificatee provided a list from December of 1997, of 17 NCSAs that were reviewed and walked down with no specific criteria listed. The inspectors reviewed the list and associated documents and could not determine what the NCSAs have in common. The inspectors determined that CAP Section B.1(a) was an overlapping program which had been ill defined and eventually abandoned in favor of more robust tasks in the CAP.
CAP Section B.1(a) states that controls were adequately implemented but follows with the statement that 22 Problem Reports were generated as a result of the effort with one resulting in a reportable event. The inspectors determined that there was an underlying implementation weakness. The dominant programmatic NCS issue at the facility is implementation of NCS controls in the plant.
The inspectors selected Tasks 1,2,7, and 10 for review because these items were representative of completed tasks. The inspectors noted that completion of two of the tasks is tied to completion of other tasks and that this information is not adequately represented in status reports. Adequate reporting of CAP status will be tracked as IFI 70-7002/98-208-01.
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l Task 1 Task 1 consisted of building reviews of NCSA/Es. The certiticatee has reported that this task is complete. The inspectors noted that the final subtask listed, Subtask 1.8, is
" Implement Corrective Actions" which was not complete and will not be complete until Task 3 is completed. The inspectors determined that status reports should more precisely indicate the situation.
Task 2 Task 2 consisted of reviews of NCSA/Es completed by " unqualified" personnel. The certificatee has reported that this task is complete. The inspectors noted that Subtask 2.7 is " Correct NCSA/Es" which will also not be complete until Task 3 is completed. The inspectors determined that status reports should reflect when subtasks have been transferred to other related tasks for completion. For both Task 1 and Task 2, the bulk of the work for the overall task has not been completed.
Task 7 Task 7 consisted of comparing the NCS program to applicable industry standards. The certificatee has reported that this task is complete. The task focuses primarily on identification of requirements rather than compliance. The inspectors noted that no interim actions were identified. The inspectors reviewed the 45 compliance issues identified and determined that ANSI /ANS-8.19 steps 5.4 and 5.5 are crucial to the programmatic issue resolution. These steps concerned operations supervisors participating in procedure development and verification of compliance wP' NCS specifications. Because of the substantial upgrading of NCSA/Es that is underway, these steps should have had interira measures developed. Also, step 4.2.4 specifies a design requirement for storage structures and should have had an interim measure developed to support the NCSA/E upgrade. The inspectors determined that these three items were incorporated into procedure XP2-EG-NS1031.
Task 10 Task 10 consisted of personnel qualification verification. The certificatee has reported that this task is complete. For Subtask 10.1," Review Available Qualification Requirements in Applicable Industry Guidance," inspectors reviewed the January 29, 1998, niemorandum [POEF-832-98-013] and confimied that an adequate review of NCS qualifications was perfomied. For Subtask 10.2," Compare Guidance to Existing Administrative Control Procedures," and Subtask 10.3," Resolve Any Identified Discrepancies (Revise Procedures)," inspectors reviewed the March 6,1998, l
memorandum [POEF-832-98-026] and confirmed that while changes were made to the l procedure," Nuclear Criticality Safety Personnel Qualification," XP4-EG-NSI102 from 7
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.O Rev. O to Rev.1, the changes did not affect either the qualifications of then current l
. members of the NCS section or the NCS personnel qualification requirements. The inspectors determined that the tr.sk was complete.
- c. Conclusions o The inspectors determined that the NCS CAP is adequate to resolve programmatic NCS l deficiencies. The inspectors identified a weakness in the reporting of CAP status by the l certificatee. The int-elatedness of tasks conceals the real status of completion.
l 3.0 Revision of NCSA/Es l.
l' a. Score The inspectors selected specific NCS A/Es for review in order to determine the adequacy of certificatee upgrades. A variety of NCSA/Es were selected in order to capture the breadth of the NCS program.
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- l NCSA-0326_022.101 X-326. Use of Portable IlEPA Ventilation Units for .
Specific Activities.
'- NCSA-0333_015.A03, Cascade Operations in the X-333 Building NCSA-0705_015.A09, Waste Water Treatment (Microfiltration System)
NCSA-0710_009.A00, Storage Requirements for Fissile Material Transfer Room
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. NCSA-PLANT 043.A00, Fissile Material Transport
- NCSA-PLANT 006.A04, General Use of Small Diameter Containers for Storing High Enriched Material
- b. Observations and Findines The certificatee has undertaken a significant effort in conjunction with the CAP to rt ,iew all NCSA/Es and revise all NCSA/Es that are determined to have deficiencies. The
- inspectors reviewed seven specific overlapping efforts to upgrade NCSA/Es using ditTerent priorities.
- Section B.l(a), SAR Accident Scenario NCSA/E Walkdown L
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- Task 1, Building Review of NCSA/Es i
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Task 2, Review of NCSA/Es Completed by " Unqualified" Staff
- Section D.1, Enhanced Review Process l
Task 3, NCSA/Es Upgrade Project 1
- Task 26, NCSA/E Calculation Review l
- 15 NCSA/Es were identified as pre-Plant Operations Review Committee (PORC) ;
NCSA/Es and underwent a separate review (this procedure was not listed in the l CAP).
The inspectors reviewed previous Region III and lleadquarters reports concerning I criticality safety and noted only one specific finding in these reports was related to an inadequate NCSA/E. The inspectors also noted that the number of self-identified NCSA/E deficiencies was small, and the deficiencies identified were unrelated. The inspectors determined that certificatee NCSA/Es were actually of high quality with the system analyzed, the basis for safety, and controls all clearly spelled out. The certificatee stated that the decision to review and revise NCSA/Es was based upon the identification l of confusing controls, preparation by " unqualified" analysts, and previous modification of l NCSAs by Engineering Notices.
The inspectors reviewed approximately 105 NCS related Problem Reports (prs) from the previous seven months of operation and identified 4 that arose from a deficient NCSA/E.
One PR reported " unqualified" preparers or reviewers, two reported minor calculational errors, and one reported the failure to identify a double contingency event. The inspectors determined that only the failure to determine the double contingency event was safety significant but noted that the particular facility was not currently in operation.
NCSA-0326_022.101 X-326 The inspectors reviewed the NCSA/E and conducted a walkdown of the Portable fligh Elliciency Particulate Air (llEPA) Ventilation Units. The inspectors noted that NCSA-0326_022.101 is weak as written. Controls #4, #6, #12, and #14 listed in the NCSA Part B arc inadequate because they do not specifically tell the procedure writer what is required. For example, #14 states to shut the machine down upon loss of air %w but does not specify how to recognize when such a loss might be occurring. This NCSA and associated equipment is not in use because the certificatee has identified thu NCSA as having been prepared prior to the Plant Operations Review Committee (PORC) review process so that it was never reviewed by the PORC. The inspectors determined that certificatee processes currently in place are adequate to resolve this issue.
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NCSA-0333_015.A03 The inspectors conducted a walkdown of the X-333 Building to determine if off-line cells were in accordance with the NCSA requirements. The inspectors noted that controls were present in plant procedures as required. The inspectors checked condensers that were out of service and determined that they were in conformity with the NCSA.
NCSA-0705_015.A09 Inspectors interviewed certificatee personnel about the X-705 Microfiltration Spill which occurred during IR 98-204. Inspectors reviewed the updated NCSA/E -0705_015.A09 and perfomied a walkdown. The revised procedure explicitly spells out the procedures to be followed for normal operation, crossfeeding, transfer between filter feed tanks, and high 2"U concentrations. The NCSA/E was revised to explicitly note the NCS controls using passive design features, active engineered features, and administrative controls.
Based on the inspectors review of the documentation, interviews with certificatee personnel and walkdown, there are adequate NCS controls established for the X-705 Microfiltration Process.
NCSA-0710_009.A00 Inspectors reviewed and walked down NCSA/E-0710_009.A00," Storage Requirements for Fissile Material Transfer (Uranium Chain of Custody) Room." Inspectors interviewed certificatee personnel in NCS and operators who manage the storage rooms (Building X-710, Room 141 (excluding east end) and Room 114) and determined that the rooms were adequately analyzed for criticality safety, and the personnel were trained in the NCS requirements.
Inspectors determined that the postings in the field met the requirements of the NCSA/E.
During the review for the revision of the NCSA/E, NCS staff determined that an ambiguity existed in the current revision that could have allowed storage arrays on and below tables. Because NCS staff were unsure whether the storage method was allowed in the NCSA/E, a temporary restriction (along with temporary postings and training on the restriction) was developed and implemented. Inspectors determined that this action removed the ambiguity and placed the storage rooms in a safer condition. Ducing the walkdown, inspectors observed that the access to the storage rooms was adequately controlled and the storage of material followed thr: NCSA/E requirements.
NCSA-PLANT 043.A00 The inspectors reviewed the NCSA/E and condo;ted a walkdown of equipment used to transport fissile material between buildings. The inspectors determined that the NCSA/E is adequate for current operations. No fissile material transport operations were 10 o
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l underway during the walkdown. The inspectors reviewed approximately 105 NCS
. related prs from the previous 7 months of operation and did not identify any that arose from transport of fissile material.
NCSA PLANT 006.A04 Inspectors reviewed and walked down NCSA/E-PLANT 006.A04," General Use of Small Diameter Containers for Storing fligh Enriched Material" in Building X-226 and toured the cascade area. Inspectors determined that the postings in the field and the storage of containers met the requirements of the NCSA/E
- c. Conclusions The inspectors determined that NCSA/Es were generally of high quality and that planned efforts to upgrade NCSA/Es far exceeded the scope ofissues associated with these documents.
4.0 Flowdown of NCS Limits and Controls
- a. Scone The inspectors reviewed the NCS CAP to determine the adequacy of certificatee actions to improve the implementation of NCS limits and controls in the plant.
- b. Observations and Findines Although the certificatee had seven programs associated with upgrading NCSA/Es, the inspectors were only able to identify three tasks in the NCS CAP associated with flowdown of NCS controls. The three tasks were Task 5," Safety, Safeguards and Quality (SS&Q) Review ofImplementation," Task 20,"NCS Field Operational Assistants," and Task 23. "NCS Short-Term Corrective Actions." The inspectors noted that all ongoing operations are covered by an approved NCSA/E. NCSA/Es that w;ere walked down by the inspectors were in conformity with the as-built configuration of the facility or equipment that they covered and controls were in procedures and postings.
The inspectors also noted indications that redundant controls had been eliminated. The inspectors determined that the NCS CAP was adequate to improve implementation of NCSA/E controls in the plant.
The inspectors reviewed IFl 7002/97-203-02 and URI 7002/98-204-01 and determined that these items may be closed even though identification of Augmented Quality (AQ)-NCS items is not complete. The identification of AQ-'NCS items is an ongoing
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< l proc. ss which is significant from a risk perspective and should be evaluated upon
, completion or, at the earliest, after the completion of the NCS CAP. Identification of AQ-NCS items will be tracked as IFI 70-7002/98-208-02.
- c. Conclusions In the selected areas reviewed, flowdown of NCS controls was detemlined to be adequate.
5.0 Pelf Deposit Characterization
- a. Scope The inspectors reviewed a proposed certificatee NCS change that would allow an increase the mass limits required to trigger Technical Safety Requirements (TSR) controls on deposits for equipment that will remain installed in the cascade. The inspectors reviewed the following documents:
Memorandurn POEF-832-98-125,"TSR Compliance for Installed Equipment with Deposits."
- Calculation NCS-CALC-98-030, Revision 0," Minimum Critical Maximum Suberitical, and Safe Mass Values for a UO 2 2 F - 110 2
Mixture at an II/U Ratio of 4."
Document KY/L-1699," Investigation of Hygroscopic Properties of Uranyl Fluoride."
- b. Observations and Findinus The facility has two TSRs (used twice, once for X-326 and once for the remainder of the cascade) for moderator control in the cascade 2.2.3.15 and 2.2.3.16, one of which is applicable to installed equipment and one to removed equipment. The certificatee has used the same curves defining safe mass versus enrichment for both installed and removed equipment. Because TSR 2.2.3.16 defines safe mass in terms of optiraum conditions and TSR 2.2.3.15 defines safe mass in terms of system conditions, the cernficatee has decided to develop a new curve of safe mass versus enrichment for installed equipment based on evidence that (H/U) will never exceed 4 due to ambient conditions in the cascade (as noted ir? the TSR). This allows a significant increase in the mass limits for equipment that will remain installed.
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l The certificatee stated that cascade NCSAs require a buffer gas placed in equipment i . within eight hours following shutdown. The inspectors determined that the presence of the buffer gas means that the change in safe mass limits will only eliminate the TSR time requirements in certain cases.' Because the TSR requirements were based on wet air l
in-leakage causing criticality in deposits, the II/U change does nat cause a reduction in safety. The safe mass limits define deposits that can never become critical, due to wet air i in-leakage, and double contingency is assured, due to the buffer gas and unbreached condition of the equipment.
- c. Conclusions The inspectors determined that the change in safe masses due to changing the II/U !
L assumption does not alter the assoc;ated safety margin. The inspectors noted that the l
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analysis depends on NCSA requirements for :ascade operations to remain unchanged.
6.0 Open item Review IFI 70-7002/97-203-01 i' Tracked final management avaluation and long term corrective actions for two external l audits. Because the " Criticality Safety Pre-NRC Audit" memorandum dated April 24, 1997, concerned an internal audit (performed by certificatee contractor for certificatee NCS), there were ne documented management evaluation and long term corrective l actions. The author and NRA representative are confident that each recommendation has been completed, and the corrective actions were complete. Inspectors reviewed )
procedures that incorporated elements of the corrective actions, inspectors also reviewed the final managem - Tvaluati u and long term corrective actions for the external l
Assessment Report by George H. Bidinger," Programmatic Review of the Nuclear
- Criticality Safety Program at the Portsmouth Gaseous Diffusion Plant" dated April 29, 1997. Inspectors determined that recommended actions have been addressed. This item is considered closed.
s IFI 70-7002/97-203-02 l
Tracked evaluation of high enriched uranium (IIEU) feed related valves for Augmented Quality-Nuclear Criticality Safety (AQ-NCS) designation. Inspectors reviewed the evaluation of whether the llEU feed related valves should be designated AQ-NCS. In a memorandum dated March 25,1998, [POEF-832-98-032], certificatee determined that because (1) the boundary valves are defined by the SAR as AQ,(2) the NCSA/Es j adequately address the 97-203 inspector's concems. (3) the criticality controls are buffer l pressure and not valve alignment, and (4) the result of valve mis-alignment would be an a
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increase in gaseous UFs which cannot achieve criticality, there was no need to make the
, boundary valves AQ-NCS. Because the evaluation is clear and logical, the inspectors agree that the valves need not be designated AQ-NCS at this time. This item is considered closed.
VIO 70-7002/97-203-03 Concerned certificatee failure to assure that NCS calculation results for enrichments of up to 20% were bounded by validation report. Inspectors confirmed that United States Enrichment Corporation (USEC) has met the validation report action plan in the supplement to the revised response to the notice of violation (NOV) for IR 97-203. The report will require further review. This item remains open.
l VIO 70-7002/97-203-05 Concerned certificatee failure to comply with administrative controls in buildmgs X-330, X-344, and X-6619. Based on review of the Management Analysis and I
Assessment Team presentation viewgraphs and meeting minutes, inspectors confirmed that USEC has implemented the long term corrective actions in the response to the NOV.
This item is considered closed. l IFI 70-7002/97-203-06 Tracked effectiveness of corrective actions to provide adequate safety of plant changes.
Because this item is one of the recommendations from the Pre-NRC Audit reviewed as part ofIFl 97-203-01 and based on the interviews and documentation reviews for IFI 97-203-01, inspectors have confirmed that no plant changes or modifications which affect NCS will be implemented without the appropriate NCS approval. This item is considered closed.
IFl 70-7002/97-203-07 Tracked decontamination of PEli equipment currently in storage. Inspectors confirmed that certificatee has developed a Master PEli Remediation Action Plan to decontaminate the PEli equipment in storage in the X-330 Building. Because completion of the plan is not due until December 31,2000, and there are no deadlines that have passed between the beginning of the plan and the time of the inspection, this item remains open.
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l Concerns certificatee failure to assure correct and acceptable equipment as identified in NCSAs was installed on PEH equipment for moderator control. USEC has implemented immediate corrective actions but was unable to document that long term corrective actions were complete. This item will remain open.
IFl 70-7002/97-203-09 Tracked identification of how SAR commitment 6.3.5.6 is to be met. USEC has developed and implemented a plan to compile all relevant plant assessments and derive Configuration Management Performance Indicators (CMPIs). The Configuration l Management (CM) Program Manual [UEO-1058] has been completed, the CMPIs have l been chosen, and the last two years data has been collected / graphed. These graphs show that overall CM issues have declined over time. Inspectors reviewed CM documentation l (including an outside audit of the overall CM program) and interviewed CM personnel.
l Based on this review and interview, inspectors determined that the CM program is adequate. This item is considered closed.
l l 1F170-7002/97-203-11 l Tracked review of NCS annual training. Inspectors reviewed the December 1,1998, l
memorandum from training concerning NCS personnel and determined that certificatee :
program controls were adequate. This item is considered closed. )
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IFI 70 7002/97-203-12
- j. Tracked commitment to ensure that SAR 6.6 and ANS-8.20 requirements are met in a l
! consistent manner throughout the plant. Inspectors reviewed the procedure concerning appropriate recovery response for operations personnel following identification of an NCS noncompliant condition. Inspectors detennined that the procedure was appropriate, clear, and logical. This item is considered closed.
! IFI 70-7002/97-206-03 i
Tracks corrective actions concerning solid angle calculations, inspectors reviewed l certificatee documentation to change the single unit multiplication factor in Solid Angle
! calculations in cascade gas cooler interaction from 0.85 to the SAR requirement of 0.80 and determined that the calculations had been performed and were pending approval.
This item is considered closed.
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! IFl 70-7002/97-206-04 Tracks establishment of a fomial procedure for review of ESDS. Inspectors reviewed XP3-EG-EG1076, Rev.1," Preparation and Control of Engineering Specification Data Sheets," and determined that the procedure includes NCS review of ESDS when systems
- affected deal with NCS concerns. This item is considered closed. l i I VIO 70-7002/97-20605 Concerns certificatee failure to provide an adequate basis for ten-foot spacing rule on PEII equipment. The inspectors reviewed NCS-CALC-97-025," Interaction Calculations Between PEll Deposits." The inspectors determined that the basis fbr the ten-foot spacing requirement is established by the calculation. This item is considered closed. i VIO 70-7002/97-206-06 Concerns certificatee failure to develop a TSRs for rails and LAW Stations.
NCSE-0330_007.E01 was revised to reflect double contingency for the Tails Withdrawal i I
Station. In addition, Procedurc XP4-EG-NS1001, Rev. 2 was modified to include the requirements of TSR 3.11.5. This item is considered closed. j IFl 70-7002/97-206-07 l J
! Tracks correction of the ratio of preventive to corrective maintenance which was l approximately 20:80. The certificatee notes that a proper PM:CM ratio for a facility that is 40-50 years old and has never been rebuilt is about 50:50. The certificatee submitted evidence that the ratio of preventive to corrective maintenance has improved to approximately 30:70. The inspectors determined that there is limited safety significance associated with this issue, and certificatee efforts to resolve the concern are adequate.
This item is considered closed.
IFl 70-7002/97-206-09 l Tracks development of cascade equipment dry criticality justification. Inspectors reviewed the revised justification of cascade equipment dry criticality which used an interaction analysis using an array of discrete spheres containing in sum the corrected theoretical cell contents in memorandum POEF-832-97-104 and attachment NCS-CALC-96-012. Rev.1, and determined that certificatee had developed an appropriate, clear, and logical newjustification for cascade equipment dry criticality.
This item is considered closed.
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! IFI 70-7002/97-206-10
- Tracks coverage of orphan facilities by Criticality Accident Alarm System (CAAS) )
TSRs. Inspectors reviewed the certificatee documentation on the " orphan" CAAS for l
l Buildings 700,720,760, and XT847 and the CAAS exemption request for '
Building 74411. This item has not been addressed and remains open. j
! VIO 70-7002/97-206-11 Concerns certificatee failure to flowdown firelighting instructions into emergency packets. The inspectors reviewed two emergency packets at the X-300 complex and detennined that the certificatee has included extensive NCS instructions in Chapter 10 of the packets and has included a new Chapter 1 I containing pre-fire plans in the packets.
This item is considered closed.
URI 70-7002/98-204-01 Determine whether USEC can adequately demonstrate closure of CP Issues 8,9,23 and whether these findings relate to a more generic issue concerning other CP items. The inspectors determined thra the NCS CAP is adequate to resolve the performance issue associated with this item. An IFl will track completion of NCS CAP items regarding identification of AQ-NCS items. This item is considered closed.
l IFI 70-7002/98-204-02 Tracks effectiveness of management measures to ensure acceptable staff performance to maintain NCS. It is not clear what is to be tracked. Improvements in the NCS program indicate that further tracking of this item is not necessary. This item is considered closed.
IFI 70-7002/98-204-03 Tracks establishment of adequate NCS controls fbr X-705 microfiltration. It is not clear what is to be tracked. The inspectors determined that NCS controls for microfiltration are adequate. This item is considered closed.
IFl 70-7002/98-204-04 Tracks actions to establish adequate safety for X-705 calciner operation. Certificatee actions under the NCS CAP are sufficient resolve the item. This item is considered closed.
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< J VIO 70-7002/98-204-05 l
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Concerns certificatee failure to identify and report loss of NCS controls. The inspector I determined that the Problem Reports associated with this issue were reviewed for i reportability and were reported as required under NRC 13ulletin 91-01. The inspectors also determined that training on reportability requirements was given to Plant Shift Superintendents and NCS Engineers. This item is considered closed.
IFI 70-7002/98-204-06 Tracks effectiveness of using non-NCS engineers to provide NCS oversight in operations. l IFl does not state what is to be tracked. The inspectors noted that previously several )
operations staff were detailed to provide NCS oversight in the facilities. These operators ;
were not given any authority or responsibility which required qualification. The positions I were temporary and have been climinated. This item is considered closed. I VIO 70-7002/98-206-02 Concern certificatee failure to identify structures, systems, and components (SSCs) relied )
on for double contingency. The inspectors reviewed planned corrective actions for this )
item and detemiined that actions should be reviewed near the conclusion of the NCS CAP. This item remains open. l r
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1 MANAGEMENT MEETINGS l l The NRC Inspectors met with facility management periodically during the inspection. The i inspectors presented the inspection scope and findings to members of the certificatee staff at the l conclusion of the inspection on December 4,1998. No classified or proprietary infonnation was
' discussed At the exit meetings, Portsmouth management and staff acknowledged findings presented, and committed to take appropriate actions as discussed above.
PARTI AL LIST OF PERSONS CONTACTED ILogsmouth Morris Brown
- General Manager Marty Redden
- Emergency Management Charley Blackston* Nuclear Regulatory Affairs Doug Fagel' . Nuclear Regulatory Affairs l Pete Hopkins* Engineering Sid Martin
- Nuclear Safety
! Mike Hone
- Criticality Safety Manager Toni Brooks * - Nuclear Safety Manager .
Ralph Winarski - Criticality Safety - (
Ralph L.emming Criticality Safety )
Don Rockhold Nuclear Regulatory Affairs j Scott Scholl Nuclear Regulatory Affairs !
l l USEC Lee Fink
- SS&Q USNRC I l
l- Dave Hartland* NRC Resident Inspector l ii L
- Denotes exit meeting attendees.
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. ITEMS OPENEI). CLOSED, AND DISCllSSED l
l Opened IFI 70-7002/9d-208-01 Tracks adequate reporting of CAP status.
IFI 70-7002/98-208-02 Tracks identification of AQ-NCS items.
1 Closed IFI 70-7002/97-203-01 Tracked final management evaluation and long term corrective actions for two external audits.
IFI 70-7002/97-203-02 Tracked Evaluation ofIIEU feed related valves for AQ-NCS designation.
VIO 70-7002/97-203-05 Concerned certificatee failure to comply with administrative controls in buildings X-330, X-344, and X-6619.
IFI 70-7002/97-203-06 Tracked effectiveness of corrective actions to provide adequate safety of plant changes.
VIO 70-7002/97-203-08 Concerned certificatee failure to assure correct and accepted items identified in NCSAs were installed on PEll equipment for moderator control.
'FI 70-7002/97-203-09 Tracked identification of how SAR commitment 6.3.5.6 is to be met.
j IFI 70-7002/97-203-11 Tracked review of NCS annual training.
IFl 70-7002/97-203-12 Tracked commitment to ensure that SAR 6.6 and ANS-8.20 requirements are met in consistent manner throughout the plant.
IFI 70-7002/97-206-03 Tracked corrective actions concerning solid angle calculations.
IFI 70-7002/97-206-04 Tracked establishment of a formal procedure for review of ESDS.
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3 l VIO 70-7002/97-206-05 Concerned certilicatee failure to provide an ,
, - adequate basis for ten foot spacing rule on PEll equipment. l 1
VIO 70-7002/97-206-06 Concerned certificatee fitilure to develop a TSRs fbr Tails and LAW Stations.
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IFl 70-7002/97-206-07 Tracked correction of the ratio of preventive to !
! corrective maintenance which was approximately l 20:80. l i
IFl 70-7002/97-206-09 Tracked development of cascade equipment dry criticality justification.
a VIO 70-7002/97-206-11 Concerned certificatee failure to flowdown firefighting instructions into emergency packets.
} URI 70-7002/98-204-01 Determined whether USEC can adequately demonstrate closure of CP Issues 8,9, and 23 and !
s whether these findings relate to a more generic issue !
l concerning other CP items. l
- l IFl 70-7002/98-204-02 Tracked effectiveness of management measures to ;
ensure acceptable staff performance to maintain NCS.
- IFI 70-7002/98-204-03 Tracked establishment of adequate NCS controls for X-705 microfiltration.
IFl 70-7002/98-204-04 Tracked actions to establish adequate safety for X-705 calciner operation.
VIO 70-7002/98-204-05 Concerned certificatee failure to identify and report loss of NCS controls.
IFI 70-7002/98-204-06 Tracked effectiveness of using non-NCS engineers to provide NCS oversight in operations.
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4 Discussed VIO 70-7002/97-203-03 Concems certificatee failure to assure that NCS calculation results fbr enrichments of up to 20% ,
were bounded by validation report.
IFl 70-7002/97-203-07 Tracks decontamination of PEll equipment currently in storage.
IFl 70-7002/97-206-10 Tracks coverage of orphan facilities by CAAS TSRs.
i VIO 70-7002/98-206-02 Concerns certificatee failure to identify SSCs relied l on for double contingency.
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l 1ST OF ACRONYMS
'AQ-NCS Augmented Quality-Nuclear Criticality Safety l- CAAS- Criticality Accident Alarm System CAP Corrective Action Plan CM Configuration Management or Corrective Maintenance
' CMPI Configuration Management Performance Indicators
! CP _ Compliance Plan l DAW Dry Active Waste ESDS Engineering Specification Data Sheets p 11 EPA -Iligh Efliciency Particulate Air -
H IIEU ' High Enriched Uranium H/U Moderator to Uranium Ratio
'IFI-' Inspector Followup Item -
l LAW Low Assay Withdrawal
!- NCS Nuclear Criticality Safety '
~NCSA- NCS Analysis NCSE- NCS Evaluation i f NOV Notice of Violation l- NRC Nuclear Regulatory Commission
- . PEli Planned Expeditious llandling h .PM Preventive Maintenance L PORC- Plant Operations Review Committee r PR Problem Report !
!. SAR Safety Analysis Report 1
!- SSCs Structures, Systems and Components
!' SS&Q Safety, Safeguards, and Quality l TSR Technical Safety Requirement UF6 Uranium IIexafluoride j UO2F2 Uranyl Fluoride iUSEC United States Enrichment Corporation
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