ML20035G905
| ML20035G905 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 04/09/1993 |
| From: | Kasnicki D, Mcalpine E, Troup G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20035G894 | List: |
| References | |
| 70-1113-93-03, 70-1113-93-3, NUDOCS 9304300165 | |
| Download: ML20035G905 (9) | |
Text
^
s
((QQto -
UNITED STATES WUCLEAR REGULATORY COlWMisslOM o
['g REGIO 9411 o
101 MARtETTA STREET.N.W.
~
- f ATLANTA GEORGI A 30323 g.....j Report No.
70-1113/93-03 Licensee:
General Electric Company
' Wilmington, NC 28401 Docket No.:
70-1113 License No.: SNM-1097 Facility Name:
Nuclear Fuel and Components Manufacturing Inspection Conducted: Macch 22-26 1993 Inspector:.
[Ap f
13 G. L. Trow, Tuel"Facilfy Project Inspector Date Signed BP' CUA 4/9/ cf 3 D. A. Kasnicki, Fuel Faci'lity Inspector Date Signed Approved by:
8['Ao 'We N9/93 o
E. J. McAlpine,. Chief i
Date Signed.
Radiation Safety Projects Section Nuclear Material-Safety and Safeguards Branch Division of Radiation Safety and Safeguards
SUMMARY
Scope:
This routine, unannounced inspection was conducted in the areas of management controls, facility operations, nuclear criticality safety and followup on previously identified items. The inspection included an evaluation of the adequacy of controls for the transfers from favorable geometry to nonfavorable geometry vessels in the Uranium Recovery from Lagoon Sludge facility.
Results:
Within the scope of the inspection, no violations or deviations were identified.
The licensee has completed the remaining items contained in the Performance Improvement Program. The controls for'the transfers in the URLS, facility were considered to be well designed and implemented.
9304300165 9304o9 DR ADOCK 07001113 PDR
i i
REPORT DETAILS i
1.
Persons Contacted
- S. Babb, Program Manager, Process Safety W. Becker, Principal Engineer, Reclaim and Support Technical Resources
- G. Bowman, Senior Program Manager, Compliance Improvement
- T. Brechtlein, Manager, Powder Production
- D. Brown, Manager, Reclaim and Support M. Chilton, Manager, Fuel Chemical Technical Resources T. Flaherty, Manufacturing Engineer, Reclaim and Support Technical Resources
- T. Hauser, Manager, Environmental Health and Safety and Nuclear Quality Assurance R. Keenan, Program Mar:2.ger, Compliance Auditing M. Lamb, Engineer, URLS Project A. Lehmann, Prir.cipal Engineer, Fuel Chemical Technical Resources
- D. McCaughey, Engineer, Criticality Safety Engineering
- T. McCawley, Manufacturing Engineer, Powder Production Technical RCsources S. O'Connor, Manufacturing Engineer, Fuel Chemical Technical Resources H. Shaver, Engineer, Radiation Safety Engineering L. Sheely, Senior Program Manager, Procedures / Training
- D. Silverthorne, Manager, Nuclear Fuel and Components Manufacturing j
- G. Smith, Senior Engineer, Fuel Chemical Technical Resources J. Taylor, Principal Engineer, Criticality Safety Engineering
- C. Vaughan, Manager, Regulatory Compliance
- F. Welfare, Acting Manager, Criticality Safety Engineering
- P. Winslow, Manager, Licensing and Nuclear Material Management i
Other licensee employees contacted during this inspection included area coordinators, operators auditors and technicians.
- Attended exit interview 2.
Organization (88005) i a.
On February 11, 1993, the Manager, Nuclear Fuel and Components Manufacturing announced an organization realignment involving Manufacturing Engineering and Manufacturing Technology and a realignment involving Materials. Neither of these realignments l
involved organizations described in the license application and thus did not require a license amendment.
b.
The Program Manager, Lagoon Elimination Project within Fuel Chemical Manufacturing has been reassigned as Program Manager, Process Safety. That individual had been designated as the Area Manager for the Uranium Recovery from Lagoon Sludge (URLS)
~
Facility Section 2.2.1.1 of the License Application requires f
i 2
that the Facility Manager delegate and assign responsibility to qualified Area Managers. On February 2, 1993, the Manager, Nuclear Fuel and Components Manufacturing issued a Area Manager i
Assignment memorandum, designating the Manager, Reclaim and Support as the Area Manager, URLS facility.
l No violations or deviations were identified.
3.
Performance Improvement Program Followup (88015, 88020) a.
In the licensee's letter of July 4,1991, regarding the URV
['
Restart Program, one item identified a the result of the June 25, t
1991, meeting in Region II was a " longer term plan." This plan subsequently became a Performance Improvement Program (PIP) and initially contained ten major areas.
The licensee submitted bi-weekly status reports on these items until the first of November, when the reporting period was changed to monthly.
Effective July 1, 1992, reporting was changed to quarterly.
The latest report, dated March 1, 1993 stated that the closure of the last items complete the tasks enumerated in the Performance i
Improvement Program.
b.
PIP Item 3.8.b dealt with enhancements of Active Engineered i
Controls which prevent the backflow of uranium-bearing solutions into other systems which could result in the accumulation of uranium in non-favorable geometry (NFG) vessels or transfer i
uranium or other chemicals to other parts of the plant site. A review of possible backflows in the Uranium Recovery Unit (URU) was conducted in June 1991 and reviewed by the NRC. This reviewed extended to the conversion area and other areas where uranium is i
handled and processed.
The backflow review addressed about fourteen system (chemical and utility) which had the potential for backflow.
Of these, the i
De-Ionized Water (DI) system was identified as needing upgrading to assure that backflow did not occur.
Four separate subparts of the system were provided with in-line instrumentation and isolation valves. On two subsystems,-two separate and independent i'
controls were installed and tested. Alarms for the controls were established in the Conversion Control Room.
+
c.
PIP Item 14.6.b dealt with the modification of a procedure to l
specify calibration and tolerance criteria as part of the maintenance upgrade.
{
Practice and Procedure (P/P) 70-23, " Calibration Program for Essential and Non-Essential Instrumentation and Controls", Rev. 10 t
was issued on January 15, 1993, to specify organizational responsibility for different types of_ instruments in the facilities on site and to require that organizations which specify requirements shall "specify frequency, tolerances and procedure
}
requirements in writing."
In the absence of a specification,_a j
t A
3
3 i
standard calibration tolerance was incorporated. A form was also 4
added to permit adding instrumentation to the maintenance computer base to schedule the periodic calibrations.
d.
PIP Item 14.7.a dealt with the rerouting of process waste streams.
The modification was in addition to the new tanks and monitor system done under PIP Item 6.
The modification involved splitting the laundry waste and radioactive waste streams and routing the radwaste through a new line to the lagoon.
License Amendment No. 28 (November 16,1992) authorized the monitoring scheme for the laundry waste system.
Facility Change Requests (FCR)92-953 and 92-1077 authorized the changes to the system. A Temporary Operating Instruction (TOI) was prepared for the operation of the system pending revision of the operating procedure.
+
The piping system modifications had been completed and the systems were operable.
I t
e.
PIP Items 12.5.a and 12.5.b dealt with the establishment of an audit procedure and specified frequency for Distributed Control Systems (DCS).
This item was previously completed but additional actions had been identified as necessary to conform to P/P 120-13,
" Development, Control and Maintenance of NF&CM Computer Software" and to include new DCSs which were installed following identification of the initial PIP Item.
j Two Fuel Chemical Manufacturing Section Administrative Routines (SARs) were issued to specify DCS configuration control.
SAR 350-27, "DCS Configuration Verification" specifies the methods and documentation requirements to support verification of j
configuration, which implements the requirements of Section 2.3.5
-l of P/P 120-13.
l Neither of the SARs specified a frequency for the configuration checks, nor did P/P 120-13 specifically. On March 19, 1993, the l
Manager, Regulatory Compliance by memo notified the Manager, Fuel Chemical Manufacturing that an annual verification of the URU DCS software configuration control would be required in accordance with SAR 350-27.
j In addition to URU, a DCS is installed on the hie production line 1
and additional DCS will be installed as part of the conversion i
line hazards upgrade. To define the requirements as DCS is being installed, license representatives stated that a modification to P/P 120-13 would be initiated so the configuration control i
requirements would be consistent and applicable to all DCS.
l f.
During the inspection, the inspector reviewed the actions indicated by the licensee for the PIP items. This included l
i
- - f
l l
4 observation of installed equipment, walkdown of systems, review of FCR packages and associated nuclear criticality safety analyses, review of procedures and discussions with cognizant personnel.
Based on these reviews, the inspector had no further questions concerning the completion of the PIP items.
The inspector noted that the Technical Report for the Radwaste System was revised and issued in October 1992 as part of the V-104 Project (PIP Item'6). However, the rerouting of the lines (PIP Item 14.7.a) changed the report. After discussions with cognizant personnel, they agreed that the Technical Report would be revised l
to reflect the system change so that the report was maintained l
current.
t l
4.
Followup on Previous items (88005, 88015, 88020) a.
(0 pen) Update of P&lDs in a Timely Manner, IFI 91-03-01.
A P/P defining responsibilities for revising and controlling Piping & Instrumentation Diagrams had been prepared, but at the end of the inspection, had not been approved and issued.
l b.
(0 pen) Improvement of Radiation Protection NCS Inspections, i
IFI 91-06-07 l
The licensee has not yet completed the actions to fully implement I
the use of Radiation Protection personnel to inspect for compliance with nuclear criticality safety requirements during their routine inspections and surveys.
]
c.
(Closed) NSE Review of Audit'and Inspection Results, IFI 91-06-11 This item dealt with the reporting of audit or inspection results for those activities conducted by the operations personnel such that Nuclear Safety Engineering-(NSE) was made aware _of the findings and could factor them into subsequent audits.
P/P 40-33, Rev. O, " Criticality Safety Self Audits" was issued on January 22, 1993. The P/P requires the establishment of reviews / audits of compliance to approved nuclear safety requirements and the establishment of a data base of requirements..
The Manager, Fuel Chemical Manufacturing is required to issue a summary report of the results quarterly to the Manager, NSE.
Additionally, Exhibit 1 of the P/P contains a list of specific inspections and reviews, the results of which are to sent to NSE.
The requirements of the P/P and the NSR/R data base were to be used by NSE beginning the first quarter of 1993.
t i
5 d.
(Closed) Implementation of Functional Test Centrols, IFI 91-06-13 l
This item dealt with the establishment of controls on Functional i
Test Instructions (FTIs) to assure that periodic tests are planned, conducted, and documented to meet the license requirement for the testing of Active Engineered Controls (AECs).
Fuel Chemical Manufacturing Section Administrative Routine (SAR) 350-28, Rev. O, " Functional Test Administration" was issued on March 1, 1993. This SAR establishes a new format for FTIs and i
sets two levels of FTIs - preoperational and functional.
The SAR specifies how tests will be administered, scheduled and documented using the MIPVAX computer system. NSR/R 02.01.18, AEC Control was also revised to identify the AEC, the FTI and the date the test was last performed.
Because over one hundred FTIs hava been identified just in URU, j
the licensee has initiated a program so a few tests are scheduled and conducted each week with only a few specific tests to be performed during shutdown. The SAR is currently identified as
" active" for URU and Waste Treatment but other areas, such as ADU i
Chemical and URLS are intended to be included in the program.
e.
(Closed) Followup on Corrective Actions from Reported Events, IFI 92-03-03 i
This item dealt with the review of three events which had challenged nuclear criticality safety limits, but which the action i
was incomplete at the time of the inspection.
J i
Two of the events related to powder spills in the slugger system.
A number of corrective actions had been proposed and implemented but problems were still encountered because of the-required
~
movement of the powder transfer system.
In August 1992 a i
Temporary Operating Instruction (TOI) was issued to require detailed weekly inspections of the handling systems. The original T01 was extended and subsequently replaced by a new TOI, which is 1
i currently effective. The weekly inspections continue to identify problems (mainly holes or tears in flexible connectors) but no i
j major failures were identified in the inspections reviewed for the period December 7, 1992 - March 1, 1993.
A change to the flexible connector and the method of attachment is being evaluated. The modification is being planned for one set of equipment.
Licensee representatives informed the inspector that a major modification to this portion of the process is being planned and will start later this year.
Inspection of system modifications will occur during routine inspections.
e e
6 The other event dealt with a high concentration in a dissolver in URU and the inability of the DCS to adjust the concentration due to a level measurement device malfunction.
As a result of this event, the material of the level probe was changed to be improve the resistance to the environment.
Several changes were made in the DCS control logic to change operating parameters and have the system do checks on the conditions.
Changes to the control logic were made using an FCR and functionally tested before release for operation. No further action is required for this event.
i 5.
Favorable Geometry (FG) to Unfavorable Geometry (UFG) Transfers of l
Uranium Solution Within the Uranium Recovery Lagoon Sludge (URLS)
Facility (88005, 88015, 88020, 88025) i Section 4.1.1 of the license application states that " Process designs shall incorporate sufficient factors of safety to require at least two unlikely, independent, and concurrent changes in process conditions before a criticality accident is possible." This statement is l
equivalent to American National Standard ANSI /ANS-8.1-1983, and is the Double Contingency Principle.
The scope of this inspection was taken from written guidance, provided by Region II management, on inspecting the implementation of NCS i
controls at the interface between FG and UFG containers or systems.
More specifically, the scope of this inspection consisted of the inspector requesting the following information from the licensee, discussing it with representatives, reviewing related procedures and other documentation, and touring related plant areas.
Relative to FG to UFG transfers within URLS, the inspector requested:
- 1) A list of such transfers where a sample is taken for lab analysis to check the concentration prior to transfer, 2) the corresponding procedures which address the taking of these samples, 3) the lab procedures which address the analysis of these samples.
For these transfers, the inspector i
requested information to address the following questions:
- 1) What assures the representativeness of the sample?, 2) What assures the prevention of changes to the concentration of the batch after the sample is taken and before the batch is released?, 3) What assures that the solution which is transferred is, indeed, the solution which was sampled and analyzed?, 4) What assures the accuracy of the lab analysis?, and 5)
+
What assures that the assay results are accurately reported and accurately received?
The inspector discussed the entire URLS process with a licensee representative.
In this discussion, the licensee representative stated that there are two such transfers of the type described above:
- 1) From T-6040 Filtrate Tank (an FG column) to either of T-2040 Waste Treatment i
Queue Tank or T-2080 Waste Holdup Tank (UFG tanks);-and 2) from T-8000 Sump Tank (an FG column).to T-3010 Second teach Tank (a UFG tank).
These transfers ~ occur at a frequency of about once per shift.
The Nuclear Criticality Safety (NCS) release limits are 100 ppm U and 33 grams U/ liter, respectively, for these two transfers; however, the release from T-6040 has an operations release limit of.5 ppm U.
i
)
7 The taking of the samples is addressed by the following procedures:
PROD NO. 150.10, URANIUM PRECIPITATION, REV. NO. 11, dated 3/17/93; PROD i
NO. 150.11, URLS SUMP CONTROL, REV NO. 5, dated 3/17/93; and PROD NO.
150.13, URLS CONTROL ROOM, REV. NO. 8, dated 2/12/93.
Thc analysis of the samples is addressed by the following procedures:
URLS PROCESS CONTROL PROCEDURES:
CENTRATE RECIRC TANK, T-6040, REV. NO. 2, dated 3/9/93; and SUMP HOLDING TANK, T-8000, REV. N0. O, dated 8/25/92.
r The representativeness of the samples is assured by a procedurally required, documented sampling and mixing study determined, 20 minute (minimum) mixing time.
This mixing time is measured with a timer.
Additionally, the operators are procedurally required to purge the short sampling line with at least 375 ml of solution before collecting the sample. Changes to the concentration after the sample is taken is assured by the batch processing characteristics of the operation. Once the batch is in T-6040 or T-8000, the pump which brought the batch to the tank is turned off, so there are then no up stream pressurized lines feeding into the tanks.
The input lines are also valved off. Assurance i
that the solution which is transferred is, indeed, the solution which was sampled and analyzed; and assurance that the assay results are accurately reported and accurately received is provided by a proceduralized communication and documentation " triangle" between the Floor Operator, Control Room Operator, and Laboratory Technician.
This triangle also employs the use of pad locks on the " double block and j
bleed" valves on the input lines to these tanks, where the Laboratory Technician is the custodian of the keys to the locks.
The T-8000 i
sample, only, is also analyzed for percent acidity; this distinction appears to make it further unlikely that there could be a mix up between tanks. The accuracy of the lab analyses is assured by the use of two methods of analysis to analyze aliquot amounts of the sample, i
j Discussion with the Lab Chemist indicated that Lab Technicians are watchful for the presence of solids in the sample and, in that event, a third method of analysis is used which measures the total amount of uranium in and out of solution. The inspector's examination of Control Room logs of these transfers revealed no over_ limit releases or other i
discrepancies.
I i
The inspector had one observation which licensee management agreed was worthy of addressing:
As a further enhancement to the control system discussed above, both T-6040 and T-8000 were physically posted with a sign indicating the release limits and other related-information, all of which appeared to be in agreement with the procedures; however, these signs were not controlled as were the corresponding procedures. These signs were a relatively recent addition and licensee management stated that they had considered the controlling of them, but had postponed-implementing that control because of awkwardness related to the methods that they had considered. They stated that they would revisit the issue and that they would probably make each sign an additional attachment, with its own revision number, to the corresponding procedure.
u J
8 i
The inspector stated to licensee representatives and management that the
.i administrative controls discussed above, in which the control actions are verified and documented,. appeared to have been designed and j
implemented well.
l l
No violations or deviations were identified.
i 6.
Exit Interview (30703) l The inspection scope and results were summarized on March 26, 1993, with those persons indicated in Paragraph 1.
The inspectors described those areas inspected and discussed in detail the' inspection findings and the inspectors' observations.
Although proprietary documents and processes were reviewed during the inspection, proprietary information is not contained in this report.
i l
+
t i
i i
i
'I 4
f
}
., -