ML18306A273
| ML18306A273 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 11/02/2018 |
| From: | Annacone M Westinghouse, Westinghouse |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards, NRC/RGN-II |
| References | |
| IR 2018004, LTR-RAC-18-78 | |
| Download: ML18306A273 (4) | |
Text
@ Westinghouse U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
Reply to a Notice of Violation Westinghouse Electric Company LLC Nuclear Fuel 5801 BluffRoad Hopkins, South Carolina 29061-9121 USA Direct tel: 803-647-1858 Direct fax: 803-647-2025 e-mail: annacom@westinghouse.com Your ref: 70-1151/2018-004 Our ref: LTR-RAC-18-78 November 2, 2018
Reference:
U.S. Nuclear Regulatory Commission Integrated Inspection Report Number 70-1151/2018-004 and Notice ofViolation Pursuant to the provisions of 10 CFR 2.201, Westinghouse Electric Company LLC (Westinghouse) herein provides a response to the NRC Integrated Inspection Report No. 70-1151/2018-004 and Notice of Violation (NOV), dated October 5, 2018. The inspection report addressed an inspection of the Columbia Fuel Fabrication Facility (CFFF) conducted in September 2018.
Attachment A provides the Westinghouse response to the NOV.
Should you have any questions or require additional information, please contact Nancy Parr ofmy Staff at (803) 647-3338.
Sincerely, Mik Annacone, Vice President Columbia Fuel Operations Westinghouse Electric Company LLC License SNM-1107 Docket 70-1151 cc:
U. S. Nuclear Regulatory Commission Regional Administrator, Region II 245 Peachtree Center Ave, NE Suite 1200 Atlanta, GA 30303-1257
© 2018 Westinghouse Electric Company LLC All Rights Reserved
ATTACHMENT A Page 2 of 4 Our ref: LTR-RAC-18-78 November 2, 2018 WESTINGHOUSE RESPONSE TO NOTICE OF VIOLATION 70-1151/2018-004-01 A. As stated, in part, by 10 Code of Federal Regulations (CFR) 70.61(e), the safety program established and maintained pursuant to 10 CFR 70.62 of this subpart, shall ensure that each item relied on for safety (IROFS) will be available and reliable to perform its intended function when needed and in the context of the performance requirements of this section.
As required by 10 CFR 70.62( d), each licensee shall establish management measures to ensure compliance with the performance requirements of 10 CFR 70.61. The management measures shall ensure that engineered and administrative controls and control systems that are identified as IROFS pursuant to 10 CFR 70.61(e) are designed, implemented, and maintained, as necessary, to ensure they are available and reliable to perform their function when needed, to comply with the performance requirements of 10 CFR 70.61.
Contrary to the above, the licensee failed to establish adequate management measures to ensure that two engineered controls identified as IROFS were designed and implemented such that they were available and reliable to perform their function. Specifically, for a minimum of three years prior to June 16, 2018, established management measures failed to ensure IROFS ADUHFS-502 and ADUHFS-902 were available and reliable to perform their intended function when needed in order to comply with the performance requirements of 10 CFR 70.61. As a result, on June 16, 2018, hydrofluoric acid (HF) solution was spilled from HF Spiking Station #2 and spilled from the diked area. This is a violation of 10 CFR 70.62(d).
A.1 ACKNOWLEDGEMENT OF THE VIOLATION The violation is correct as stated. The established management measures for the IROFS pertaining to structural integrity of the spiking station components and for the diked area did not provide adequate controls to ensure they remained available and reliable to perform their intended function.
A.2 REASON FOR THE VIOLATION The reason for the violation is that a gap existed in the CFFF standards related to design, configuration management, operations and maintenance when the spiking station dike and liner were modified in 2002.
A design modification was made in 2002 to line the diked area with polypropylene material to protect the concrete floor. The site did not recognize that this design change would allow process fluid to get trapped between the bottom of the liner and the epoxy-coated concrete surface. Thus, the modification introduced an unrecognized failure mode in which the concrete could become degraded and any resulting defect in the concrete underneath the liner would not be visible. The contributing factors are: (1) acceptance of system leaks into the diked area over time; (2) reliance on the integrity of the epoxy coating; (3) degradation of the polypropylene liner from operations and maintenance activities.
Page 3 of 4 Our ref: LTR-RAC-18-78 November 2, 2018 A.3 CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED The following corrective actions have been taken to assure the availability and reliability of the above noted IROFS:
Following the leak, on June 16, 2018, spiking station #2 was emptied of chemicals and removed from service. The system will remain out of service until an improved system is designed and implemented with adequate maintenance procedures.
Spiking station # 1 liner was leak tested and its integrity was verified. Compensatory measures were implemented to closely monitor operation of this system through hourly inspections of the spiking station when in use; barricading the area with instructions to place walking pads down if walking on the liner is needed; and changing the frequency of the containment barrier leak test from annual to quarterly and following any repair. These changes minimize the potential for degradation of the diked area and also provide for a timely response action should any indications of a system leak develop.
Westinghouse has executed a plan that involved temporary removal of spiking station #2, controlled removal of concrete and soil within the diked area, and implementation of a phased approach sampling protocol as approved by the South Carolina Department of Health and Environmental Control (SCDHEC) to characterize the extent of contamination present, determine the appropriate remedial actions and to generate required 10 CFR 20.1501 and decommissioning records. Removal of the contaminated soil is in process.
Quarterly. monitoring of the closest downgradient well for groundwater contamination has been instituted.
Significant changes regarding expectations for design and maintenance have occurred since the last major modification to the HF spiking station in 2002, to include:
The configuration management process requires an independent design verification for creating or changing IROFS.
The configuration management process requires addressing preventive maintenance (PM) and post repair/replacement functional testing for modifications which impact IROFS.
A procedure upgrade project is underway to assure that inspection procedures accurately and effectively validate the effectiveness of the IROFS.
A.4 ACTIONS TO PREVENT RECURRENCE The following additional actions are in progress or planned to prevent recurrence of this violation:
Develop and implement an improved design for both spiking station systems and diked areas to prevent spills of process solution from impacting the concrete and to guard against undetected deterioration of the concrete floor ( e.g., reducing potential leak locations, modifying piping, installing new equipment with improved preventative maintenance, and eliminating failure modes in the system and the dike).
Page 4 of 4 Our ref: LTR-RAC-18-78 November 2, 2018 Develop and implement an improved preventive maintenance procedure( s) for the spiking station system and diked area, including regular inspections to guard against undetected deterioration of the concrete floor.
Conduct a formal Design Review of the improved spiking station system, diked area and maintenance procedure(s). The Design Review shall use a Design Failure Mode and Effect Analysis (DFMEA) to identify and mitigate risks.
Assess similar design configurations where there is a liner/environmental barrier relied on for secondary containment to ensure proper preventive and post maintenance procedures are in place.
Conduct an extent of condition review throughout the facility for safety significant couplings similar to those used in the spiking station to verify maintenance procedures have been established.
Complete a thorough evaluation of the environmental protection program including a review of environmental protection design requirements. If issues are identified, ensure immediate compensatory measures are put in place and a long term improvement plan is developed and implemented through the Corrective Action Program.
A.5 DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved on June 16, 2018 when spiking station #2 was emptied of chemicals and removed from service. The system will remain out of service until an improved system is designed and implemented with appropriate maintenance procedures and management measures. Westinghouse management continues to monitor overall recovery and improvement commitments utilizing the Corrective Action Program.