ML20196K105

Insp Rept 70-7001/99-07 on 990413-0528.Violations Noted. Major Areas Inspected:Plant Operations,Maint & Surveillance, Engineering & Plant Support

ML20196K105
Person / Time
Site:	07007001
Issue date:	07/01/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20196K103	List: ML20196K098 ML20196K105 ML20196K585
References
70-7001-99-07, 70-7001-99-7, NUDOCS 9907080146
Download: ML20196K105 (15)

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U.S. NUCLEAR REGULATORY COMMISSION REGION lil Docket No: 70-7001 Certificate No: GDP-1 Report No: 70-7001/99007(DNMS)

Facility Operator: United States Enrichment Corporation Facility Name: Paducah Gaseous Diffusion Plant Location: 5600 Hobbs Road P.O. Box 1410 Paducah, KY 42001 Dates: April 13, through May 28,1999 Inspectors: K. G. O'Brien, Senior Resident inspector J. M. Jacobson, Resident inspector Approved By: Patrick L. Hiland, Chief, l Fuel Cycle Branch Division of Nuclear Materials Safety 9907080146 990701 PDR ADOCK 07007001 C PDR

EXECUTIVE

SUMMARY

United States Enrichment Corporation Paducah Gaseous Diffusion Plant NRC Inspection Report 70-7001/99007(DNMS)

Plant Operations o The inspectors identified a reporting violation for which the plant staff took adequate corrective actions to prevent recurrence. The reporting violation was associated with the plant staff's discovery, during routine once-per-8-hour testing, of an inoperable safety system. (Section 01.1) e The inspectors determined that the high unavailability of nonsafety-related I equipment contributed to the extended time required for the plant staff to effectively respond to a large air inleakage to the process gas cascade, an expected operational difficulty. The increased response time also resulted in an unplanned increase in the j peak process gas enrichment level experienced following the unexpected large air  !

inleakage. (Section 01.2)

Maintenance and Surveillance j

e The inspectors identified that a violation occurred when the plant staff, on two occasions, did not implement in a timely manner compensatory measures required by the Technical Safety Requirements for an inoperable safety system. The initial corrective measures, implemented following the events, also did not appear to fully address underlying issues with the. plant staff and management's understanding of the system design, operational policies, and appropriate testing protocol. (Section M1.1) e The inspectors identified inadequacies in the plant staff's implementation and management's oversight of several safety-related maintenance and surveillance activities. (Section M1.2)

Enaineerina e The plant nuclear criticality safety staff's questioning attitude identified an inappropriate translation of a nuclear criticality safety control for exempting equipment from spacing from the goveming approvalinto the implementing procedure. As a result of the thorough followup and prompt corrective actions for the issue, the finding was characterized as a non-cited violation. (Section E1.1)

Plant Suocort e The NRC staff determined that a draft contingency plan, developed by the plant staff, contained classified information, in that, the included information was portrayed as a response plan to specific threat lovels and met the intent of the classification guide. An Unrasolved item was opened to track the inspectors' review of compliance issues associated with the plant staff's handling of the classified document between August and November 1998. (Sections S1.1) 2 5

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Report Details

1. Operations 01 Conduct of Operations 01.1 Untimelv Reoortina of an Inocerable Process Gas Leak Detection System

a. Insoection Scoce (88100)

The inspectors reviewed the plant staff's reporting of a safety system inoperability identified during foutine testing,

b. Observations and Findinos On April 11, during routine, once-per-8-hour testing of the process gas leak detection

- (PGLD) system for Building C-333, the plant staff identified an anomaly in the test results. Specifically, the plant staff identified that the PGLD system for Unit 5, Cell 4 did not respond as expected and was not functioning properly. The test results were observed at 9:45 p.m., documented, and placed in the area control room (ACR) for management review. However, upon completion of the testing, operations management I was not directly informed of the test results and compensatory measures were not impkmented. At the time of the testing, the PGLD system was required by the Technical Safety Requirements (TSR) to be operable as Unit 5, Cell 4 was operating at greater than atmospheric pressure.

At approximately 11:50 p.m., the Building C-333 front-line manager reviewed the PGLD test results for Unit 5, Cell 4. Based upon a review of the test results and discussions with the building staff, the front-line manager informed the Plant Shift Superintendent (PSS) of the Unit 5, Cell 4 PGLD system problems. Shortly after notifications to the PSS, the PSS declared the system inoperable, and the building staff implemented the TSR-specified compensatory measures for an inoperable PGLD system.

On the moming of April 12, the inspectors reviewed the activities and problems that occurred during the preceding weekend through a review of operations logs and completed Assessment and Tracking Reports (ATR). During the review, the inspectors

.noted the problems experienced with the Building C-333 PGLD system, the

- compensatory. measures implemented, and the PSS reportability assessment made of the events. The inspectors noted that the PSS's initial reportability assessment determined that the event was reportable within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

On the moming of April 13, the inspectors noted that the plant staff had not made a 24-hour notification for the PGLD inoperability that occurred on April 11. During discussions with the PSS, the inspectors were informed that on the aftemoon of April 12 the PSS, in consultation with other plant staff, concluded that the event was not reportable. The decision not to report the event was based upon the safety system failure having occurred during testing, when the system was properly removed from service. The inspectors noted, however, that the operations logs indicated that the plant staff did not properly remove the system from service. Specifically, the plant staff had not implemented the TSR-specified compensatory actions for an inoperable PGLD 3

system until after the Action Time had expired. Therefore, the system was not properly removed from service. (See Section M1.1).

Subsequent to the inspectors discussions with the PSS and other plant staff, the PSS determined that the PGLD system failed and that the required compensatory actions were not implemented within the TSR-specified time period. As a result, at 1:40 p.m.,

on April 13, the PSS made a formal notification to the NRC in accordance with 10 CFR 76.120(c)(2) for the failure of a safety system. The notification appropriately

> identified that the report should have been made within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the initial inoperability time of 9:45 p.m., on April 11.

Following the PSS's report to the NRC, plant management reviewed the conditions which contributed to the late report and implemented corrective actions to preclude a recurrence. The corrective actions included the development and issuance of a

" Lessons Leamed" summary to the PSS staff which reemphasized the PSS's responsibility and authority for making reportability decisions. In addition, the " Lessons Leamed" summary enumerated the specific criteria to be applied to the assessment of the reportability of a system failure identified during surveillance testing. The inspectors reviewed the corrective actions and discussed the " Lessons Leamed" summary with some of the PSS staff. The inspectors determined that the corrective actions appeared adequate to prevent recurrence.

Title 10 of the Code of Federal Regulations (CFR) 76.120(c)(2) requires, in part, that the cerificatee shall notify the NRC Operations Center within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the discovery of an event in which equipment is disabled or fails to function as designed when the equipment is required by a TSR: 1) to mitigate the consequences of an accident;

2) to be available and operable and should have operated on demand; and 3) no ,

redundant equipment is available and operable to perform the required safety function. l TSR 2.4.4.1, " Process Gas Leak Detection," requires, in part, that the process gas leak l detection system for a cell shall be operable whenever the cell is operated at greater than atmospheric pressure. On April 11,1999, Building C-333, Unit 5, Cell 4 was operating at greater than atmospheric pressure. The failure to report within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> that the Building C-333, Unit 5, Cell 4 Process Gas Leak Detection System, a system required to mitigate the consequences of an accidental release, was inoperable when ,

the system was required to be operable, and no other redundant equipment wm available, is a Violation (VIO 70-7001/99007 01).

c. Conclusi_qn_t The inspectors identified a reporting violation for which the plant staff took adequate corrective actions to prevent recurrence. The reporting violation was associated with the plant staff's discovery, during routine once-per-8-hour testing, of an inoperable safety system.

i 01.2 Laroe Air inleakaoe to the Process Gas Cascade

a. Inspection Scooe (88100)

The inspectors reviewed the plant staff's response to a large air inleakage to the process gas cascade.

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b. Observations and Findinos During the inspection period, the plant staff responded to a large air inleakage to the process gas cascade. The air inleakage resulted from the failure of a compressor shaft scal on equipment located within Building C-337. As a result of the air inleakage, a significant amount of light gases accumulated within the purge portion of the process gas cascade, forcing the " front" between the light (oxygen, nitrogen, etc.) and process (uranium hexafiouride) gases to be pushed out of the withdrawal building and into the cascade buildings. Once identified, the failed seal was isolated, the air inleakage was stopped, and the " front" was retumed to the normal location in the withdrawal building.

As a result of the air inleakage and the forced relocation of the " front," the inspectors noted that the plant staff lost the capability to control the process gas cascade enrichment through the routine withdrawal of enriched process gases from the cascade.

The loss of withdrawal capability, if allowed to persist long enough, could cause the plant staff to implement infrequently performed actions involving the mixing of process gas steams to limit the overall enrichment level of the process gas. This course of action was not required during the current event as the plant staff implemented measures to limit the maximum enrichment. During the event, the maximum enrichment of the process gas cascade rose to approximately 2.2 weight percent from 1.8 weight percent. The maximum certificate-allowed enrichment of the process gas was 2.75 weight percent.

The inspectors noted that a large air inleakage as a result of a seal failure was an expected operational difficulty. As a result, the plant design included nonsafety-related systems and alarms to identify, at the earliest possible time, the degradation or impending failure of a seal. However, during the current seal failure, the plant staff indicated that some of the relied upon nonsafety-related systems were not available for use and that some of the expected alarms were not received. Specifically, some inline analysis equipment, used to identify the concentration of gases within the process stream, was not functioning and some alarms associated with a seal failure did not actuate. As a result, the plant staff did not receive an early waming of the impending seal failure and the t!me necessary to locate the failed seal was increased.

The inspectors discussed the apparent potential safety impacts of the inoperable or unavailable nonsafety-related equipment with plant management. The plant

. management concurred with the inspectors assessment of the impacts and indicated that measures were being implemented to increase the maintenance attention provided to the inline systems and to increase management's awareness of the health of the systems. Plant management expected the measures to improve the systems' availability and reliability,

c. Conclusions The inspectors determined that the unavailability of nonsafety-related equipment contributed to the time required for the plant staff to effectively respond to a large air inleakage to the process gas cascade following a seal failure, an expected operational difficulty. The increased plant staff response time also resulted in an unplanned increase in the maximum process gas enrichment experienced following an unexpected large air inleakage.

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08 Miscellaneous Operations issues 08.1- Certificatee Event Reoorts (90712)

The certificatee made the following operations-related event reports during the inspection period. The inspectors reviewed any immediate safety concems indicated at

. the time of tae initial verbal notification. In the case of retracted notifications, the inspectors reviewed the basis for the certificatee's retraction of the notification at the time of the retraction. The inspectors will evaluate the associated written report for each of the events following submittal.

Number Status Title 35589 Open inoperability of the Building C-333, Unit 5, Cell 4 Process Gas Leak Detection System.

l 35639- Open Inoperability of the Building C-333, Unit 5, Cell 1 Process Gas Leak Detection System.

35642 Open High Autoclave Steam Pressure Alarm received in Building C-337 Autoclave Position 2 West.

08.02 Bulletin 91-01 Reoorts (97012)

The certificatee made the following reports pursuant to Bulletin 91-01durirg the inspection period. The inspectors reviewed any immediate nuclear criticality safety (NCS) concems associated with the report at the time of the initial verbal notification.

Any significant issues emerging from these reviews are discussed in separate sections of the report.

Number . Qgig Tilla 35606 4/18/99 A HEPA vacuum cleaner was discovered in a containment pan on top of the C-337 Surge Drum Room with the vacuum hose wrapped around the vacuum.

35608 4/19/99 During a walk through of the Disassembly area, two exempted parts were discovered which contained visible quantities of uranium.

35650 4/28/99 Discovery of inappropriately Grouped Fissile Equipment Categorized as Uncomplicated Handling.

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11. Maintenance and Surveillance

'M1 . Conduct of Maintenance and Surveillances M1.1 Pmcess Gas Leak Detection System inoperablisties

a. Inspection Scopei88102. 88103)

The inspectors reviewed the plant staff's response to and evaluation of several process gas leak detection system inoperabilities.

b. Observations and Findings On April 11,1999, at 9:45 p.m., the plant staff identified anomalies with the operation of a process gas leak detection system in Building C-333, Unit 5, Cell 4. The anomalies l were discovered during performance of the TSR-specified surveillance testing and were l documented on the appropriate forms.' Subsequent to completing the testing for all of the systems in Building C-333, the involved operator placed the testing records in the

, ACR for management review. However, the operator did not note or highlight the  !

identified anomalies to responsible operations supervision. j 4

~ At approximately 11:50 p.m., a front-line manager in Building C-333 reviewed the l' completed surveillance testing records and noted the documented anomalous conditions. Based upon the indicated results, the front-line manager informed the PSS j of the anomalous indications for the PGLD system for Unit 5, Cell 4. In response to the j identified anomalies, the PSS declared the system inoperable and instructed the l . front-line manager to initiate the TSR-directed actions for an inoperable system. The I directed actions included lowering the unit cascade pressure to below atmospheric .

I pressure or stationing a smoke watch in the immediate area of the inoperability within l l

one hour. The front-line manager and the PSS also assessed the event reportability as

= discussed in Section 1.1. j L Following the event, operations management reviewed the circumstances surrounding i I

the testing conducted on the evening of April 11,1999. The operations management l

' determined that the delayed implementation of the required compensatory measures occurred,in part, due to: 1) inadequate operations staff beginning of shift prioritization l t 2 of the required tasks; 2) an inadequate assignment of staff to perform the surveillance; l' 3) a non-questioning implementation of the surveillance by the operator located in the field; and_4) a non-evaluation of the surveillance results by the staff assigned to perform

, the work.

On' April 27, during the performance of a routine surveillance of the PGLD system for l _ Building C-333, the ACR operators received a PGLD alarm for Unit 5, Cell 1. In

response to the alarm, the ACR operator suspended the ongoing PGLD system surveillance and investigated the alarm. During the investigation, a building operator attempted to reset the alarm at a panel located outside the control room without success. Instead, each time the alarm was reset, the PGLD system re-actuated. As a g result, the operator viewed the area covered by the PGLD system. Within the area was i ~ a low speed purge and evacuation pump which did not demonstrate any obvious 7

out-gassing in progress. However, the operator did notice maintenance activities near the pump and the PGLD system which were producing sufficient airbome particles to actuate the system.

Given the building operator's observations, the ACR operator reviewed the TSRs and determined that the PGLD system in the area of the pump was not required to be

, operable. Therefore, the ACR operator directed that the alarm should be " locked" in until the maintenance activities were completed. The ACR operator's actions made that portion of the system associated with the alarm inoperable. The ACR operators .

communicated the implemented resolution to the PGLD alarm to a front-line manager and the PSS.

Approximately 90 minutes after the ACR operator locked in the alarm for that portion of the PGLD system associated with the pump, another front-line manager reviewed the status of the system. This front-line manager noted the ACR operator's actions, in addition to locking in the alarm for that portion of the PGLD system near the pump, also locked in the PGLD system alarms for Unit 5, Cell 1. At the time, Unit 5, Cell 1 was operating above atmospheric pressure, thus requiring the PGLD system to be operable.

With the alarm for Unit 5, Cell 1 locked ir me ACR operators could not receive any other alarms that might have been caue:u oy a release in the area of Unit 5, Cell 1.

Therefore, the PGLD system for Unit 5, Cell 1 was also inoperable.

l Subsequent to the second front-line manager's observations, the ACR operators took actions to initiate the requirt,d compensatory measures for an inoperable PGLD system and the PSS assessed the events for possible reportability. The required compensatory measures were implemented; however, not until after the maximum time period allowed  !

by the TSR was exceeded. During a followup review of the issue, the inspectors and some operations management noted that the sequence of events appeared to indicate 'l that the involved operations staff did not fully understand the design or operation of the  ;

PGLD system. The inspectors also noted that the operations and maintenance staff I had not properly planned and controlled the maintenance activity that caused the initial alarm in the area of the pump. Specifically, controls were not identified or implemented to preclude the maintenance work from negatively impacting the operability of safety-related equipment, the PGLD system.

On May 12, during another performance of routine PGLD system testing, the plant staff '

. Identified inoperable portions of the PGLD system associated with Building C-333, Unit 5, Cell 3. Immediately following the initial test efforts, a second testing of the PGLD system was performed. During the second test, different portions of the PGLD system for the same cell failed the test. Based upon the results observed during the two tests, the operations staff declared the system inoperable and entered the applicable actions for the associated TSR. The PSS also determined that the observed anomalies constituted a safety system failure and were reportable to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Later on May 12, the plant staff reviewed the circumstances which led to the safety system failure. The plant staff determined that the failure occurred due to an exposed wire in the system that was exclusively associated with the test circuit. As a result, the plant staff concluded that the system would not have failed during normal service had an actual release occurred. Therefore, the event was not reported to the NRC. In discussions with the regulatory affairs staff, the inspectors also noted that the current 8

testing process did not remove the system from service for the testing; therefore, future failures may still be reportable depending on the circumstances.

Based upon the repeat nature of the inadequate responses to the PGLD safety system failures during this inspection report, the inspectors questioned the breadth and depth of the plant staff's corrective actions. Specifically, the inspectors noted that the initial corrective actions for each event did not appear to address fundamental system and policy knowledge issues involving the operations staff. In addition, the initial corrective actions did not address inadequacies in the processes used to remove and return to service the PGLD system for testing or the inadequate communications which facilitated each of the events. As of the end of the inspection period, the plant staff were reevaluating each of the events individually and collectively to ensure that all pe'rformance issues were identified and corrected.

Technical Safety Requirement 2.4.4.1 required, in part, that the plant staff shall perform, within one hour, a continuous smoke watch on a cell or cells affected by PGLD system inoperability or shall place the cells in a Mode for which the Limiting Condition for Operations does not apply. The failures on April 11 and April 27 to place Building C-333 Unit 5, Cell 4, and Unit 5, Cell 1, respectively, in a Mode for which TSR 2.4.4.1 did not apply or to initiate a continuous smoke watch within one hour after the associated PGLD l systems were determined to be inoperable, is a Violation (VIO 70-7001/99007-02).

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c. Conclusion  !

The inspectors determined that a violation occurred when the plant staff, on two occasions, did not implement in a timely manner compensatory measures required by the TSRs for an inoperable safety system. The initial corrective measures, implemented following the events, also did not appear to fully address underlying issues with the plant staff and management's understanding of the system design, operational 1 policies, and appropriate testing protocol.

M1.2 Conduct of Maintenance Activities i

a. Insoection Scooe (88102. 88103)

The inspectors reviewed the conduct of routine maintenance activities. Activities and documentation reviewed included the calibration of safety systems for a freezer / sublimer, corrective maintenance involving a fire protection wet sprinkler system,

- and startup testing of a product withdrawal cell.

b. Observations and Findinos During a walkdown of ongoing operations and maintenance activities, the inspectors identified a number of anomalous conditions.

The first anomalous condition involved testing and repair work being performed for a freezer / sublimer in Building C-333. The inspectors reviewed the work and the work package controlling the efforts. While no specific deficiencies were identified with the actual repair efforts, the inspectors observed that the work scope and work approvals documented in the associated work package were not consistent with the actual activities being conducted in the field. The inspectors discussed the observations with 9

i work control and operations staff and were informed that both groups were aware of the current scope of the efforts. In fact, the work control staff indicated that the repair activities were expected based upon problems that previously had been identified with the freezer / sublimer. Both groups also concurred with the inspectors that the current work package scope-of-work and intent statements did not support the work efforts.

The inspectors were informed that the problems appeared to result from the plant staff's use of a generic outline for the work efforts without making any subsequent revisions to the package to reflect the actual scope of work. The inspectors did note that the work steps appeared to be consistent with the ongoing activities and that the operations staff were cognizant of the actual activities in progress. The inspectors noted that the work control process and procedures required changes to the work scope and intent, beyond the original approved efforts, to receive operations and other groups review and approval.' The second review was necessary to ensure that the work scope remained within the safety boundaries of the work package and to ensure that the post-maintenance testing was sufficient to ensure that the problems were corrected, that no new problems were introduced, and that the repaired systems were ready for a retum to senrice. Subsequent to the inspectors observations, the plant staff took action to modify the generic work package to ensure an adequate definition of the scope of work, to reenforce management's expectations regarding the proper method for implementing changes to the scope and intent of work packages, and entered the issue into the plant corrective action program for tracking and trending purposes.

The second anomalous condition involved the inappropriate handling of safety-related procedures used or referenced during the conduct of testing and start-up of a cell.

During a walk-through of Building C-310, the product withdrawal facility, the inspectors I noted uncontrolled and unverified procedures for the evacuation and start-up of a product withdrawal cell. At the time of the observation, neither of the activities directed by the procedures were in progress. However, both of the activities were conducted during the preceding 3 days. The inspectors determined that both of the procedures were the latest version. The inspectors also noted that the procedures most probably j

< had been left in the plant 1 to 3 days prior to discovery and that numerous operations staff had walked by the unattended procedures without questioning the acceptability of the observation.- Following the inspectors' observations, the operations staff performed a walkdown of the remainder of the facility to ensure that other uncontrolled and unverified procedures were not present. The operations staff also documented the issue in the plant corrective action program for tracking and trending purposes.

The final anomalous condition involved corrective maintenance performed on a fire protection system .in Building C-337. The inspectors observed a portion of the maintenance activities and noted an absence of foreign material exclusion controls for j the work efforts during a period of time when the work area was left unattended. The 1 inspectors reviewed the work package for the maintenance efforts and discussed the  ;

observations with the fire protection engineer. The work package was noted to require j the implementation of foreign material controls during the actual maintenance efforts; however, the package was silent as to the controls that should be implemented after the system was opened and the work area was left unattended. The fire protection engineer indicated that such controls were considered to be a " skill-of-the-craft" activity; however, the inspectors observed that several operations and maintenance personnel l walked past the work site without identifying the absence of any foreign material controls.

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L While reviewing the completed work package for the fire protection system corrective

' maintenance, the inspectors also noted numerous substantial inaccuracies with the l materials. Specifically, the inspectors noted that the operations staff had not properly documented the need for and entry into a TSR Action Statement for the work efforts. In addition, the post-maintenance testing documentation was not properly completed, signed by the involved staff, or reviewed by the responsible supervision prior to the system being retumed to service. The inspectors also noted that the plant staff's quality review of the documents had failed to identify any of the noted inadequacies. Following the inspectors' observations, the fire protection engineer documented each of the inadequacies in the corrective action program for resolution and discussed the findings with involved fire protection staff to ensure an immediate short-term performance improvement and compliance with applicable procedures. The operations management also reviewed the applicable out-of-service and control room logs to ensure that the involved equipment was properly controlled and compensated for during the system inoperability. No additional problems were identified. I Finally, the inspectors determined that the plant staff's failure, for each of the anomalous conditions,- to properly and correctly implement plant procedures for safety-related 4 activities constituted a violation of minor significance and is not subject to formal enforcement action,

c. Conclusion The inspectors identified inadequacies in the plant staff's implementation and management's oversight of several safety-related maintenance and surveillance activities.

l 111. Engineering E1 Conduct of Engineering E1.1 Imorooer Interoretation of Criticality Safety Soacino Exemption

a. Inspection Scope (88100. 88020)

The inspectors reviewed the plant staff's response to an issue involving the improper i

storage of equipment containing potentially fissile or fissile materials. The issues were l initially reported to the NRC pursuant to Bulletin 91-01 in Event Report 35650).

b. Observations and Findinos On April 28, plant NCS staff identified that one of the controls for " Uncomplicated i Handling (UH)" equipment covered by NCS Approval GEN-10 " Removal and Handling of Contaminated Equipment from the Cascade at Paducah Gaseous Diffusion Plant,"

j had not been properly interpreted when the implementing procedure was developed in

1997. Specifically, UH equipment or a UH grouping of equipment which contained less I than 5 pounds of uranium and could fit within an NCS-approved 5.5-gallon container i was exempt from spacing requirements. (All other UH equipment was required to be j spaced a minimum of 2 feet edge-to-edge.) This was based upon calculations l performed in the associated NCS evaluation which assumed a mass and specific .

geometry for the 5.5-gallon volume when developing the spacing exemption  !

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requirements. However, when the implementing procedure (Procedure CP2-CO-CN2030) was developed and reviewed, the restriction on the geometry of the volume was not included. The only limitation placed on grouping equipment was the 5-pound uranium limit.

Upon identification of the issue, the plant staff initiated an extensive walkdown of the plant to identify any equipment which had been inappropriately grouped or spaced as a result of the error. _ Improperly grouped and spaced equipment was identified in Buildings C-710, C-720 and C-409. Although one of the double-contingency controls for this equipment was violated, the mass in all the groupings was below the 5-pound mass limit and well below the safe-mass limit. The plant staff appropriately remediated the improper groupings of equipment, and revised the goveming procedure to assure the geometry constraints assumed in the calculations were maintained, i.e., only equipment in an NCS-approved 5.5-gallon container with less than 5 pounds of uranium could be exempted from spacing requirements. Based on the questioning attitude by plant staff in identifying the issue and the prompt and thorough response, this non-repetitive, certificatee-identified and corrected violation is being treated as a Non Cited Violation (NCV 70-7001/99007 03), consistent with Section Vll.B.1 of the NRC Enforcement Policy.

c. Conclusions I The plant NCS staff's questioning attitude identified an inappropriate translation of a NCS control for exempting equipment from spacing from the goveming approval into the implementing procedure. As a result of the thorough followup and prompt corrective

. actions for the issue, the finding was characterized as a NCV.

IV Plant Support S1- Security .  !

S1.1 ~Continoency Plan Develooment (88100)  !

a. Inspection Scooe (88102. 88103)

The NRC staff conducted a formal review of the classification status of a contingency  !

plan developed at the Paducah Plant.

b. - Observations and Findinos During the period of August 1998, the plant staff developed a draft document on a computer system that was authorized for handling non-classified documents. The plant staff developed the draft contingency plan in response to concems with terrorist activities at United States Embassies in Africa. Historically, the plant staff handled t contingency plans as classified documents.

On November 4,1998, the plant staff notified the NRC Duty Officer of an infraction of the Protection of Classified Matter Plan associated with the August 1998 development of the contingency plan. The report indicated that once the Classification Officer reviewed and recognized the material as classified in August 1998, the involved computer was 12

sanitized and paper and computer media copies of the document were marked and stored as classified material.

In NRC Inspection Report 70-7001/98018(DNMS), the Inspectors documented the results of an initial review of the issues surrounding the events of August 1998. As documented in inspection Report 70-7001/98018(DNMS), Section S1.2, the inspectors concluded that the contingency plan information did not appear to have met the threshold specified in the applicable classification guide. Therefore, the plant staff's development of the contingency plan on a computer not authorized for handling classified information would not have been an infraction of the Protection of Classified Matter Plan and would not have been reportable under the requirements of 10 CFR 95.57. The report further documented the existence of disagreements between the plant staff and managerr,ent regarding the appropriate classification level of the document and communications between the Classification Officer and United States Enrichment Corporation (USEC) staff prior to the classification decision.-

Subsequent to the issuance of Inspection Report 70-7001/98018(DNMS), the Region lli Fuel Cycle Branch requested the NRC Division of Facilities and Security to perform a formal classification review of the draft document. The Division's information Security Branch conducted the classification review using CP-PGD-5, " Joint NRC/ Department of Energy Classification Guide for Uranium !sotope Separation by t'ne Gaseous Diffusion Process." As a result of the formal review, the Information Security Branch determined that the document met the intent of the classification guide criteria and is therefore classified as Confidential-National Security Information. Specifically, the Branch staff concluded that the draft document contained information portrayed as a USEC protective force deployment plan for responding to specific threat levels as outlined in Sections 10.2.3 and 10.2.7 of the CP-PGD-5.

The inspectors also determined that the disagreements between plant staff, discussed in Inspection Report 70-7001/98018(DNMS), regarding the classification of the document, occurred around the time the plant staff reported the infraction to the NRC in November 1998, versus the August 1998 timeframe. In addition, the Classification Officers discussions, referenced in Inspection Report 70-7001/98018(DNMS), were held only with plant staff and did not involve USEC corporate personnel.

Based upon the NRC's formal assessment that the draft document met the intent of the classification guide and portrayed a deployment plan for responding to specific threat levels, the inspectors determined that a reevaluation of the circumstances that occurred in August and November 1998 was warranted. The completion of the reevaluation of the plant staff's handling of the classified document and the timeliness of the reportability of the event will be tracked as an Unresolved item (URl 70-7001/99007-04).

c. Conclusion

The NRC staff determined that a draft contingency plan, developed by the plant staff, contained classified information, in that, the included information was portrayed as a response plan to specific threat levels and met the intent of the classification guide. An URI was opened to track the inspectors' review of compliance issues associated with the plant staff's handling of the classified document between August and November 1998.

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V. Manaaement Meetinas X1 Exit Meeting Summary l The inspectors presented the inspection results to members of the plant staff and management at the conclusion of the inspection on May 28,1999. The plant staff acknowledged the findings presentod. The inspectors asked the plant staff whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

PARTIAL L!ST OF PERSONS CONTACTED United States Department of Enerav G. A. Bazzell, Slte Safety Representstive United States Enrichment Corporation

• J. L. Adkins, Vice President - Production

• M. A. Buckner, Operations Manager L. L . Jackson, Nuclear Regulatory A' fairs Manager J. A. Labarraque, Safety, Safeguards and Quality Manager S. R. Penrod, Enrichment Plant Manager

• H. Pulley, General Manager U.S. Nuclear Reaulatory Commission J. M. Jacobson, Resident inspector

• K. G. O'Brien, Senior Resident inspector

• Denotes those present at the exit meeting June XX,1999.

Other members of the plant staff were also contacted during the inspection period.

INSPECTION PROCEDURES USED IP 88100: Plant Operations IP 88102: Surveillance Observations IP 88103: Maintenance Observations IP 90712: In-office Review of Events 4

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ITEMS OPENED, CLOSED, AND DISCUSSED Opened 70-7001/99007-02 ~ VIO .. Failure to implement Limiting Condition for Operation actions within required timeframe for inoperable process gas leak

. detection systems.70-700, 19007-04 URI Timeliness of report made to NRC conceming classified document prepared on unclassifimi computer, Closed 70-7001/97007-01 VIO Failure to make timely report to NRC conceming an inoperable process gas leak detection system.

70-7001/97007-03 NCV Groupings of fissile " uncomplicated handling" equipment '

discovered by plant staff to be improperly exempted from spacing.

Discussed None LIST OF ACRONYMS USED ACR Area Control Room

-ATR Assessment and Tracking Report CFR Code of Federal Regulations '

DNMS.. DMsion of Nuclear Materials Safety NCS' Nuclear Criticality Safety

NCV Non-Cited Violation NRC? Nuclear Regulatory Commission PDR- Public Document Room PGLD Process Gas Leak Detection PSS Plant Shift Supervisor

.TSR Technical Safety Requirement UH Uncomplicated Handling URI Unresolved item USEC United States Enrichment Corporation VIO Violation l i

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