ML20212D865

Insp Rept 70-7002/97-08 on 970811-0921.Violations Noted. Major Areas Inspected:Plant Operations,Maint,Engineering & Plant Support

ML20212D865
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant
Issue date:	10/28/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20212D844	List: ML20212D838 ML20212D851 ML20212D865
References
70-7002-97-08, 70-7002-97-8, NUDOCS 9710310209
Download: ML20212D865 (17)

Text

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U.S. NUCLEAR REGULATORY COMMISSION.-

REGICN lli Docket No: 70 7002 Report No: 70-7002/97008(DNMS)

Certificate No: GDP-2

Applicant: United States Enrichment Corporation Facility Name: Portsmouth Gaseous Diffusion Plant Location: 3930 U.S. Route 23 South P.O. Box 628 Piketon, OH 45661 Dates: August 11 through September 21,1997

. Inspectors: C. R. Cox, Genior Resident inspector D. J. Hartland, Resident inspector Approved By: Patrick L. Hiland, Chief Fuel Cycle Branch 9710310209 971028 PDR ADOCK 07007002 C PDR

e EXECUTIVE

SUMMARY

United States Enrichment Corporation Portsmouth Gaseous Diffusion Plant NRC Inspection Report 70 7002/97008(DNMS) t This ;nspection report includes aspects of plant operations, maintenance, engu .aring, and plant 4

support. _The report covers a six-week pericd of routine resident inspections.

Plant Operations e The inspectors identified a failure to maintain miri! mum staffing levels for the Plant Shift Superintendent (PSS) position at the X-300 facility per the Technical Safety Requirement (TSR).' One violation was identified. (Section 01.1) e The inspectors identified a concem with the certificater' ' iteral compliance".with TSR requirements when a limiting condition for operation (Lm was entered and exited on multiple occasions in preparation for a planned expeditious handling (PEH) component removal. (Section 01.2)

Maintenance and Surveillance e The inspectors identified a concem with the lack of chemical safety controls while cutting out a piping x-joint that contained a uranium deposit. One violation was identified.

(Section M1.1) e Overall, PEH component removal and disassembly evolutions performed during the inspection period were well-planned and coordinated. However, the certificatee made a non-conservative decision to initiate a removal evolution during threatening we ather. In addition, the certificatee authorized maintenance personnel to work an excessive amount of overtime for a preplanned disassembly evolution. (Section M1.2)

Enoineerino e - The inspectors identified that the certificatee was using nonstandard 1S cylinders without a valid nuclear criticality safety approval (NCSA). One violation was identified. (Section E1.1) e The inspectors identified deficiencies witn both the initial and documented operability evaluations with regards to an issue with the autoclave low cylinder pressure shutoff system. (Section E1.2)

Plant Support e - The inspectors identified a concem with the certificatee's failure to take effective corrective acticns to prevent recurrence of repeated TSR violations of excessive unauthorized overtime. One violation was identified. (Section S8.3) 2 4

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i Report Details I. Operations 01 Conduct of Operations i 01.1 Violation of TSR Staffino Reauirements

a. Inspection Scope (88100)

The inspectors observed plant operations to verify compliance with TSR minimal staffing requirements,

b. Observations and Findinos On September 13,1997, during a routine visit at the X-300 plant control facility, the inspectors observed that the PSS exited the building to have a private conversation with a senior manager under the outside covered walkway. The inspectors were concemed that the PSS did not name an authorized designee who had been trained to execute plant emergency procedures before leaving the building as required by TSR 3.1.3. At the time of occurrence the qualified Assistant PSS was out on an emergency run to the X-333 building in response to a "see and flee" report. An Assistant PSS in training was present in the PSS office but was not qualified to execute emergency procedures. Upon identification of the concem, the inspectors informed the staff and the PSS retumed to the office.

Paragraph 3.1.H of plant procedure XP2-US-FO1204, " Shift Functional Staffing Requirements," defined the X-300 control room duty station as bounded by the building perimeter except the basement. A clarification of this requirement was included in the building's daily operating instructions, or night letters, stating that the covered walkway

< outside the building was not within the boundary. Failure to maintain the minimum staffing levels for the PSS position at the X-300 is a Violation of TSR 3.2.2 (VIO 70-7002/97006-01).

c Conclusion Although the office was not left unattended and the PSS was available, the inspectors were concemed with the certificatee's continued lack of attention to detail regarding compliance with TSR requirements. The inspectors had previously identified a similar concem in inspection Report No. 70-7002/97002 regarding staffing at the tails facility.

O1.2 Literal Compliance with TSR Reauirements

' Topical headings such as 01. M8, etc., are used in accordance with the NRC standardized inspection report outline contained in NRC Manual Chapter 0610. Individual reports are not expected to address all outline topics, and tne topical headings are therefore not always sequential.

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a. Inspection Scope (88100)

The inspectors observed plant activities to verify compliance with TSR requirements,

b. Observations and Findinos On August 12 during review of the cascade cocrdinator's logbook and shift tumover information, the inspectors noted that the certificatee was making multiple entries into an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> TSR LCO. TSR 2.2.3.15.B.1 required that a dry air blanket greater than 14 psia be maintained in cell 29-4-4 due to the presence of multiple PEH deposits in the cell.

The certificatee made the multiple LCO entries while reducing pressure below 14 psia to obtain negative hydrogen fluoride (HF) pressure in the cell in preparatbn for cutting out a compressor, in some cases, the certificatee entered the LCO for over 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, exited for 5 minutes, and then reentered the LCO. Although there were no apparent safety implications with the multiple LCO entries, the inspectors were concemed that the certificatee was abusing the intent of the TSR requirements.

c. Conclusion Although not a violation of TSR requirements, the inspectors concluded this example of

" literal compliance" to the regulations could set precedence and create a mind-set that results in decision making that is not conservative.

01.3 Steam Plar,1

a. Inspection Scope (88100)

The inspectors observed steam plant activities to verify safe operation,

b. Observations and Findinos The inspectors interviewed steam plant operators to leam their understanding of double redundancy. The operators explained that data displayed on the four computer screens can be interchanged between monitors; therefore, a failure of one or more monitors does not eliminate the operators from operating the steam plant.

, The inspectors consulted with steam plant operators, reviewed steam plant logs, and discussed with the steam plant engineer to find out if circuit breakers had tripped on motors. The steam plant operators stated that, since the January 1997 electrical upgrade to the steam plant, they were not aware of any circuit breakers tripping until the No.1 deaerator pump motor tripped on July 25,1997. The inspectors did not find any indications that motor circuit breakers had inadvertently tripped from a random reviewed of the steam logs since January 1,1997 or through a discussion with the steam plant engineer.

The inspectors reviewed the steam plant staffing from March 1,1997 to the present.

The inspectors noted that the certificatee augmented steam plant staff per the union realignments on March 1,1997. The prior staffing was composed of a stationary engineer, boiler operator, and an assistant boiler operator, in addition to the normal complement, either a boiler operator or stationary engineer was on the shift as a relief 4

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engineer to address maintenance activity items scheduled for repair, The relief engineer generally worked the day shift. The staff was also augmenied with an extra assistant boiler operator. In summary, the shift has been augmented since March 1997 with two relief operators.

c. Conclusion The inspectors determined that the operators can interchange the new control room monitors' functicas and displays between monitors. Since the electrical equipment upgrades were completed in January of 1997, there vias no indication that circuit breakers have tripped on motors. Steam plant staffing for operating the plant has remained consistent.

01.4 Problem Reportino (PR) System (88100)

a. Inspection Scope The inspectors reviewed the process used for prioritizing, assigning, and completing problem reports (PR).

b. Observations and Findinas The inspectors reviewed approximately 23 prs that employees had initiated the week of September 7,1997. The inspectors found that management had set priorities and logged all of the prs into the PR computer system within three days in accordance with the PR program. The inspectors teamed that management had recently changed the PR program to increase its efficiency and to ensure originators receive timely response to the action taken from the prs they submit. The inspectors found that in October 1996 the PR backlog peaked to 880 prs. The inspectors determined that shortly after the PR peak, engineering and operations had canceled several prs. The commitment manager stated that the prs canceled during this period were of low priority and determined to be insignificant. The inspectors reviewed five of these canceled prs and determined that the prs had been addressed through other means. In addition, the commitment manager added that the PR program had experienced some development problems during this period and that management did not als"ays communicate to PR originators when they had canceled their submitted prs.

The inspectors learned that the initiator's immediate supervisor reviewed prs before management set priorities and logged into the PR system. Through discussions with three engineers, the inspectors determined that these employees did not feel inhibited in raising management concems in prs.

c. Conclusion The inspectors determined that the PR program was being used, and employees continued to use the PR program as a means to resolve concems that they identify.

Concems with the certificatee's corrective actions to problems previously identified are discussed elsewhere in this report.

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08 Miscellaneous Operations issues 08.1 (Closed) Inspection Follow-up Item (IFI) 70-7002/9700]-01: The inspectors reviewed the training requirements for steam plant operators. The job and needs analysis had been updated ear 1y in 1996 and the operations training manager signed the training matrix on April 24,1996. Training records were available for review and indicated that operators had met required training except two steam plant operators. The two operators stated they had completed training but their training records were incomplete. Management removed them from shift work while the training staff evaluated their subject knowledge.

The training staff determined that their knowledge level was sufficient and their training records updated to show their qualification status. The lack of training records for the two operators is a failure to follow procedure UE2-TR TR1030, " Conduct of Training,'

dated August 8,1995. This failure is a violation of minor significance and is being treated as a Non-Cited Violation, consistent with Section IV of the NRC Enforcement Policy.

As fol'ow-up to another issue, the inspectors reviewed the qualificatons and training records of individuals in the Production Services area of the Poduction Support Division and did not identify any concems.

08.2 [ Closed) IFl 70-7002/97007-02: The inspectors reviewed the issuance of XP4-CO-CA3944, " Operations During a Steam Failure," Rev 0 before the effective date listed on the procedure. The memorandum issuing the procedure was sent one week before the effective date. The memorandum instructed controlled copy holders to insert the procedure on July 30,1997 (effective date). The controlled copy in the X-300 building was inserted on July 25. The on-duty cascade controller referred to the procedure during the loss of steam event on July 25. The procedure had been properly reviewed and signed by the plant manager. The required procedure reading had been completed by the cascade controller. The procedure was accurate and helped mitigate the consequences of the loss of steam. The use of the procedure before the effective date is a failure to follow procedure UE2-TO-RM1031, " Document Control Program," Rev. O.

This failure constitutes a violation of minor significance and is being treated as a Non-Cited Violation, consistent with Section IV of the NRC Enforcement Policy.

II. Maintenance M1 Conduct of Maintenance M1.1 Poor Controir Durina X-Joint Removal

a. inspection Scope (88103)

The inspectors reviewed an outgassing event that occurred during the removal of a cascade cell piping x-joint.

b. Observations and Findinas On August 30,1997, while maintenance personnel were cuttirig a piping x-joint from Cell 33-3-3, a building recall was initiated due to an apparent outgassing from a deposit in the adjacent piping. The recalllasted about five hours due to problems with isolating the 6

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release. Attempts to seal the open pipe wi*h a " shower cap" were unsuccessful and an expanded plug was eventually used. Individuals near the release were wearing full face ,

respirators. Air samples taken during the event and precautionary follow-up urinalysis for those potentially exposed to HF gas were negative. The deposits in the cell had

- been classified for uncomplicated handling (UH) because the assay of the material was determined to be less than one percent.

During follow-up, the inspectors reviewed the work package and noted that it did not contain any precautions to address the chemical safety concems. The cell had been removed from service a few weeks before the event when a seal failed, resulting in a

• ignificant amount of wet air leakage into the system and a cascade transient. Due to the severity of the seal failure, the operators had to shut the cell down before evacuating the process gas (PG) from the cell. As a result, a less effective method was used to remove the process gas from the cell, resulting in the formation of a UF6 deposit in the cell. Aware of the potential for the UF6 deposit, the operators took a HF sample from the cell a few days before cutting the x-joint and the results carne back positive. Some -

follow-up discussions resulted among operations, maintenance, and health and safety personnel but no precautions were added to the work package.

Due to the nature of the seal failure and the methsd used to evacuate the cell, the inspectors concluded that the certificatee should have provided some engineering controls in the work package. Due to the potential for a large uranyl fluoride deposit in the piping, caused by the uranyl fluoride reacting with the wet air leaking into the system, the certificatee should have performed an non-destructive assay (NDA) survey to ensure that the welders were not cutting into a deposit. In addition, a negative air machine should have been staged to address the smoke resulting from the reaction with the UF6 and wet air during the piping x-joint removal. The inspectors documented similar concems in inspection Reports 70 7002/96002 and 96003 regarding removal of equipment with PEH deposits. The certificatee apparently did not incorporate those lessons learned for removing equipment containing uncomplicated handling (UH) deposits, although the same chemical safety concems apply. Failure to provide adequate chemical safety controls as specified in procedure CMG 21, " Expansion Joint-Removal And Installation," during removal of the piping x-joint in cell 33-3-3 is a 4: Violation of TSR 3.9.1. (VIO 70-7002/97008-02).

c. Conclusion The inspectors were concemed that the certificatee did not incorporate lessons leamed

'for removal of PEH deposits to equipment containing UH deposits. The inspectors also

- noted that the certificatee had not begun the event investigation until prompted by the inspectors. The certificateo did not hold a critique until September 10, a week and a half after the event.

M1.2 Removal and Disassembly of Eauipment Containina PEH Deposits

a. Inspection Scope (88103)

The inspectors observed removal and disassembly of equipment containing PEH deposits and reviewed associated work packages.

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b. Observations and Findinas The certificatee removed and disassembled four pieces of equipment containing PEH deposits during the inspection period. The inspectors observed portions of the evolutions and determined that, overall, the activities were well-planned and coordinated. The certificatee prepared an approved procedure for the removal evolution; however, some weaknesses were noted:

During removal of Compressor 29-4-4, stage six, it began to rain. Fortunately, the roof of the X-330 cascade building did not leak near the work area; therefore, there were no immediate criticality concems. The certificatee was in compliance with the procedure, which required that the removal actior;s not be initiated during periods of precipitation. If removal actions had begun, the procedure allowed for work to continue since the roof was not leaking close to exposed deposits.

However, the inspqctors concluded that the certificatee's decision to initiate the evolution in threatening weather was not conservative. During subsequent evolutions, the certificatee was more ^autious in verifying that the chance of rain was minimal before initiating equipment removal.

The inspectors noted that three or four maintenance employees had worked approximately 24 straight hours on Geptember 34 disassembling a PEH compressor at the X-705 building. The inspectors noted that the authorized overtime was given without providing any limits. The inspectors concluded that the overtime was excessive and could have been avoided, as the maintenan2 evolution was preplanned. Further concems regarding management of overtime are discussed in paragraph S8.3.

c. Conclusions The inspectors concluded that, overall, the PEH equipment removal and disassembly evolutions were well-planned and coordinated. However, the inspectors were concemeo with the certificatee's overtime management.

Ill. Enaineerina E1 Conduct of Engineering E1.1 Enaineerina Evaluation of Non-Standard 1S Sample Cylinders

a. Inspection Scope (88105)

The inspectors reviewed the facility staff's response to a report from Paducah regarding nonstandard 1S sample cylinders.

b. Observations and Findinas On, July 18,1997, the Portsmouth plant shift supervisor (PSS) was notified by a Paducah PSS that 1S sample cylinders manufactured in the 1970s and currently identified as Urenco-Weber cylinders may not meet the ANSI N14.1, " Uranium Hexafluoride - Packaging for Transportation," standard. Specifically, the length and 8

diameter of those cylinders did meet the spe::itications ident;fied in Figure 1 of the standard. The Portsmouth staff verified that there were more than 103 of the cylinders in the current inventory, with most in Russia. Empty sampie cylinders (1S and 2S) were being shipped to Russia where samples would be taken of down blended Russian material. The samples would then be shipped back to Portsmou.h and analyzed before receiving the 2.5 ton cylinders of the sampled material. USEC notified Russia to suspend use of the 1S cylinders until the significance of the nonstandara dimensions was analyzed.

An engineering evaluation was completed on August 13, which concluded that the nonstandard cylinders did comply with the ANSI N14.1 standard at the time of manufacture. It was also verified with the Department of Transportation (DOT) that the cylinders met DOT regulations for the shipment of uranium hexafluoride. The evaluation also determined that the cylinders were safe to heat by verifying that the volume of tne cylinder met or exceeded the void volume requirements of the ANSI standard. On September 15,34 of the 1S cylinders were receivad.

The inspectors reviewed the evaluation and noted that the Russians met the DOT Type A regulations for the quantity of material shipped. However, the inspectors did note that the nuclear criticality safety analysis (NCSA), NCSA 0344A006.A03, for receiving and storing sample cylinders specified geometry control by use of cylinders that met the dimensions, referenced USEC-651, Revision 7," Uranium Hexafluoride: A Manual of Good Handling Practices." The nonstandard cylinders did not meet the dimension requirements of that NCSA for geometry control. Geometry control was not used for

, meeting the double contingenc/ of that NCSA but was an additional control. A new NCSA was developed for the nonstandard 1S cylinders. USEC then decided to destroy the nonstandard cylinders.

c. Conclusion The inspectors questioned whether the cylinders woulc still meet DOT regulations if greater than Type A material would be shipped. However, since the cylinders were being destroyed before refilling, the question was irrelevant. However, the use of the nonstandard cylinders without a valid NCSA is a Violation of TSR 3.11.2 (ViO 70-7002/97008-03).

E1.2 Poor Operability Determination for Autoclaves

a. Inspection Scope The inspectors reviewed operability determinations of as-found plant conditions,

b. Observations and Findinas On September 9,1997, the certificatee identified an operability issue regarding the autoclave's low cylinder pressure shutoff system. The system was designed to detect a closed or plugged cylinder valve and shut down the autoclave if the cylinder pressure did not reach 20 psia (pounds per square inch absolutel during the first hour of heating the cylinder. The certificatee discovered that the syste :s for the X-342 and X-343 building autoclaves had a programmable logic controller (PLC) which was set to shut the 9

autoclave down in 61.4 minutes, exceeding the hour set point required by TSR 2.1.3.9.

The inspectors reviewed the certificatee's operability determination and identified the following concems:

The certificatee ;nitially determined that autoclaves No. 5 and No. 7 at the X-343 building remained operable. This was based on a review of surveillance test records that documented shutdown times of less than 60 minutes using a wrist watch as the measuring device. The inspectors concluded that the certificatee's immediate operability determination was flawed because it was based on the use of a less accurate timing device than the PLC, which had minimal set point drift.

During follow-up discussions, certificatee management provided additional assurance of operability for all the autoclaves. The certificatee determined that the cylinder low pressure shutuff system worked with other safety systems and that some tolerance to the 60 minute set point was reasonable. However, the inspectors reviewed the certificatee's follow-up operability evaluation and noted that it did not adequately document this analysis. After further prompting from the inspectors, the certificatee revised the operability evaluation to include the technical analysis,

c. Conclusion The inspectors concluded that the certificatee's initial operability determination was flawed because it took credit for a less accurate timing device, in addition, the certificatee's technical analysis in the follow-up operability evaluation required some additionalinformation, E2 Engineering Support of Facilities and Equipment E2.1 Enaineerina Service Orders (ESO)

a. Inspection Scope (88100)

The inspectors reviewed the process for establishing ESO priorities,

b. Observations and Findinas The inspectors teamed that engineering management discussed the priority with the engineer being assigned the ESO before establishing a due date. Five working level engineers stated that the ESO due dates for answering ESOs can be changed based on the work load and other modifications being done to the system that the ESO addressed.

The engineers further explained that management sometimes canceled ESOs with high priorities due to new system upgrades that superseded fixing the existing equipment.

c. Conclusion The inspectors determined that the method used for setting priorities for ESOs was consistent with the ESO procedures, 10

4 E2.2 Enaineerina Drswinas

a. Inspection Scope (88100)

The inspectors reviewed the accuracy of system drawings in the UF6 sampling areas.

b. Observations and Findinas The inspectors compared several UF6 sampling system piping drawings with the existing system condition. The drawings were found to accurately represent the piping systems' configuration,

c. Conclusion No safety concems were identified during the review of the selected sampling UF6 piping drawings.

E8 Miscellaneous Engineering issues E8.1 (Closed) IFl 70-700/97003-09: The NRC reviewed the engineering calculations for determining the design safety margin for the H-frames u ed as lifting devices for moving liquid uranium hexafluoride filled cylinders. The calculat:ons were developed from industry recognized standards and appeared to demonstrate that the H-frames met the TSR general design features of a 5:1 safety factor. This item is closed.

E8.2 (Closed)10CFR21 Report dated July 24.1997: The NRC received a 10CFR21 report from USEC on July 24,1997, regarding an engineering computer code defect. The defect was identified in the computer code used to evaluate the crane supp=t structure at the extended range product withdrawal station. The evaluation was part of the project to replace the existing crane. Release 21.1 of STAAD-Ill structural analysis program was found to provide results that were not conservative. Releases 20 and 22 were found not to contain the defect. The defective code was used to evaluate the existing structure and not for the replacement. The existing structure was reevaluated with release 22 and found to be within the required specifications. The inspectors reviewed the project and determined that the existing and replacement cranes met the TSR design features and would meet OSHA and Crane Manufactures Association of America design features including fail-safe load brakes. This item is closed.

E8.3 (Open) IFl 70-7002/96006-01: The inspectors reviewed the engineering evaluations of autoclave "as found" pressure decay testing dated August 29, "97. The evaluation determined that the data was inconclusive and concluded t.% cher testing and reviews were necessary.

E8.4 (Closed) IFl 70-7002/96006-02: The inspectors reviewed the safety analysic report (SAR) amendment request for Freon pressure during cell treatment. The change was documented in the request for application change (RAC) 97X0076 and implemented in revision seven of the application. Yhe NRC reviewed and approved the amendment 1

request. This item is closed.

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E8.5 (Closed) IFl 70-7002/96003-01: The inspectors reviewed the operations of X-344 autoclaves No. 3 and No. 4 to determine if procedure changes were effective in reducing l high cylinder pressure alarms during sampling evolutions. The inspectors determined l that the procedure changes appeared to be effective in reducing the alarms. Since the changes in 1996, these autoclaves did not experience any further high cylinder pressure alarms during sample operations. This item is closed.

IV. Plant Support C1 Chemical Safety C1.1 Storace of Hazardous Chemicals (66062)

a. Inspection Scope The inspectors reviewed storage of chemicals in Building 710.

b. Observations and Findinas The inspectors found that the certificatee stored chemicals such as teflon, cement, epoxies, solvents, chemical etching solutions, resins, and other chemicals in Building 710, Room 185. Chemical Hygiene Plan, POEF-TO-710, approved these chemicals for storage in Building 710, Room 185.

The inspectors identified, during the review of the chemical storage area, a 20-foot section of flouring piping not painted yellow in the overhead outside Room 185 in Building 710. In addition, the inspectors noted that when maintenance removed certain ceiling tiles in Room 185, the fluorine piping had been painted approximately every 5 feet with the ye!!ow band signifying the fluorine system. The inspectors determined through visualinspection that the fire main piping had been painted a yellow color similar to the yellow fluorine color in the overhead ceiling area. The certificatee indicated that all the fire main water piping was paintea chromate yellow in the overhead ceiling areas and that all fire main piping that was below the ceiling had been paintea red. The inspectors observed that all the fire mains were painted red in all exposed areas in Building 710.

The certificatee stated that maintenance would paint the unpainted and partially painted fluorine piping,

c. Conclusion No safety concems were identified with the storage of chemicals in the buil6ng 710.

The lack of yellow paint of the fluorine pipe potentially compromises the correct identification of the pipe during a maintenance activity.

C1.2 Laboratory Fume Hoods

a. inspection Scope (88100)

The inspectors reviewed the status of the fume hoods at the X-710 building to ensure that the hoods were cperated following plant procedures.

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4 l b. Observations and Findinos i

The inspectors reviewed test data and walked down a sams-le of the fume hoods and verified that those in operation met the minimum requirements for flow velocity. The inspectors also reviewed applicable procedures, including those used to calibrate weight scales. No problems were identified.

c. Conclusions Tne inspectors did not identify any issues regarding the operation of the fume hoods.

C8 Miscellaneous Criticality issues C8.1 (Closed) IFl 70-7002/97002-05: The inspectors reviewed the reconstructed records for criticality training for supervisors. Based on the reconstructed recc-ds, the inspectors determined that 50 employees successfully completed the initial krJnhg course by passing a challenge exam and 45 personnel successfully completed refresher training.

Classroom training was given to 120 employees. More than 44% of those supervisors requiring training were allowed to successfully challenge the course and take the classroom training.

S8 Miscellaneous Plant Support Issues S8.1 Employee Concems Prooram

a. Inspection Scope The inspectors reviewed the effectiveness of the certifwatee's Employees Concem Program.

s b. Observations and Findinas The inspectors reviewed a December 1996 certificatee survey of the Employee Concems Program (ECP) and noted that most plant emoloyees responding to the survey believed that retaliation or retribution occurred at the plant. In addition, most respondents also indicated they would not report any suspected retaliation or retribution to the ECP manager. In response to the negative response, the certificatee had taken steps to improve management-employee communications. The ECP Manager committed to provide an informal presence in the plant to help address misconceptions about fear of reprisalin surfacing concerns through the ECP. The inspectors noted that certificatee had not appointed a full-time ECP Manager until August 1996, which may have contributed to the negative survey results. The certificatee intended to do another survey to assess the effectiveness of the corrective actions taken to date.

c. Conclusion The inspectors will continue to monitor the ECP to assess the effectiveness of certificatee's actions in improving the employee's perception of tne program.

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E.

S8.2 Emeraency Medical Staffino

a. inspection Scoce (88050)

The irtspectors reviewed the staffing requirements of the emergency medical services.

b. Observations and Findinos The inspectors consulted with the infirmary administrator on the ce.pability of the medical staff to respond to a significant medical event. The infirmary administrator stated that, at the time of the inspection, the infirmary was understaffed due to recent early retirements.

The director stated that the certificatee was actively hiring new medical personnel to replace those that had recently retired.

c. Conclusion Although the inspectors determined that the infirmary was not at normal staffing hvels, no regulatory concems were identified.

S8.3 (Closed) IFl 70-7002/97005-04: Review of effectiveness of corrective actions to concems regarding the management of overtime for the general work force. The inspectors continued to note examples where overtime limits were exceeded without prior approval. During the inspection period, the certificatee identified two more TSR violations as documented in Problem Reports (prs) PR-PTS-97-7987 (dated 9/10/97) and PR-PTS-97-8251 (dated 9/18/97). The inspectors found additional examples where the certificatee exceeded overtime limits without prior approval while performing nonsafety related work. However, those overtime excesses were determined not to be violations. Eight violations have occurred since the NRC assumed regulatory oversite on March 3,1997. In addition, as discussed in Section M1.2 of this repo.-t, the inspectors were concemed that maintenance employees worked about 24 straight hours to support a preplanned evolution. Although this overtime had prior approval, it was also symptomatic of a lack of controlin managing overtime of the workforce. Failure to provide effective corrective action to prevent recurrence of excessive unauthorized overtime is a Violation of 10CFR76.93, " Quality Assurance." (VIO 70-7002/97008-04).

V. Manaoement Meetinos X1 Exit Meetino Summary The inspectors presented the inspection results to menibers of the facility management on September 22,1997. The facility staff acknowledged the findings presented.

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

• D.1. Allen, General Manager

• J. B. Morgan, Enrichment Plant Manager

• M. Hasty, Engineering Manager

• R. W. Gaston, Nuclear Regulatory Affairs Manager -

• C. W. Sheward, Maintenance Manager

.* R. D. McDermott, Operations Manager United States Enrichment Corporation J. H. Miller, USEC Vice President, Production

• L Fink, Safety, safeguards & Quality Manager 1 United States Department of Enerav (DOE)

J. C. Orrison, Site Safety Representative Nuclear Reaulatory Commission (NRC)

• C. R. Cox, Senior Resident inspector D. J. Hartland, Resident inspector Y. H. Faraz, Project Manager, NMSS

• Denotes those present at the exit meeting on September 22,1997.

INSPECTION PROCEDURES USED IP 88050 Emergency Preparedness IP 88062 - Maintenance and Inspection IP 88100 Plant Operations IP 88101_ Configuration Control IP 88102 Surveillance Observations

IP 88103 Maintenance Observations IP 88105 Management Oversight and Controls IP 97012 Inoffice Reviews of Written Reports on Nonroutine Events

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l ITEMS OPENED, CLOSED, AND DISCUSSED .

Opened 70-7002/97008 VIO Failure to maintain minimum TSR 3.2.2 staffing levels for the PSS position at the X-300 building 70-7002/97008 VIO Inadequate chemical safety controls provided in procedure for x-joint removal 70-7002/97008-03 VIO Failure to receive and store is cylinders in accordance with an approved NCSA 70-7002/97008-04 VIO Failure to take effective actions to prevent recurrence of unauthorized TSR overtime exceedences Closed e

70-7002/97007-01 IFl Review of steam plant operator training requirements 70-7002/97007-02 IFl Review of issuance of controlled procedure before effective date 70-7002/96003-01 IFl Review effectiveness of procedure change for autociave sampling in the X-344 building 70-7002/97003-09 IFl Review of adeqtry of h-frame calculations 70-7002/96006-02 IFl Review of the SAR amendment request for freon pressure during cell treatment 70-7002/97002-0S IFl Review of reconstructed training records for criticality training for supervisors 70-7002/97005-04 IFl Review of effectiveness of corrective actions to concems regarding -

the management on workforce overtime Discussed

.70-7002/96006-01 IFl Review as-fourid leak-rate test data for autoclaves Certification issues - Closed None 16 1

l

LIST OF ACRONYMS L'3ED ANSI- American National Standards institute ASME American Society of Mechanical Engineers CFR -Code of Federal Regulations CofC Certificate of Compliance DOT Department Of Transportation ECP Employee Concems Program EPA Environmental Protection Agency g Gram HF Hydrogen Fluoride IFl Inspection Follow-up item IP inspection Procedure LCO Limiting Condition for Operation NCSA Nuclear Criticality Safety Approval NCV Non-cited Violation NDA Non-destructive Assay NOV Notice of Violation NRC Nuclear Regulatory Commission PDR Public Document Rcom

. PEH Planned Expeditious Handling PR Problem Report psia Pounds per square inch absolute PSS Plant Shift Superintendent QAP Quality Assurance Plan RAC Request For Application Change SAR Safety Analysis Report TSR Technical Safety Requirement UF. Uranium Hexafluoride UH Uncomplicated Handling USEC United States Enrichment Corporation VIO Violation wt% Weight-percent 17

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