ML20036A809

Insp Rept 70-1257/93-05 on 930419-22.Violations Identified & Being Considered for Escalated Enforcement Action.Major Areas Inspected:Insp of Findings Identified on 930209-12 & Review of Licensee Response on 930422

ML20036A809
Person / Time
Site:	Framatome ANP Richland
Issue date:	04/29/1993
From:	Hooker C, Reese J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20036A806	List: ML20036A805 ML20036A809
References
70-1257-93-05, 70-1257-93-5, NUDOCS 9305170033
Download: ML20036A809 (8)

Text

{{#Wiki_filter:. _ - _ _ _ 4 e-i U.S. NUCLEAR REGULATORY COMMISSION REGION V Report No. 70-1257/93-05 Docket No. 70-1257 License No. SNM-1227 Licensee: Siemens Power Corporation 2101 Horn Rapids Road Richland, Washington 99352-0130 Facility Name: Siemens Power Corporation Inspection at: Richland, Washington Inspection Conducted: April 19-22,1993 M M/AT r Inspector: C A. Hooker, acilities Inspector Date Signed hAi// 4 29 Approved by: / ipp'H~.Veese,C/ief 'Datd Signed FacMities Radiological Protection Branch Summary: Areas Inspected: This was a special in-office inspection of findings identified by the Augmented Inspection Team inspection (Report No. 70-1257/93-

02) conducted on February 9-12, 1993. This inspection also included the review of the licensee's response, dated April 22, 1993, to the NRC Region V Confirmatory Action Letter, dated February 12, 1993.

Inspection procedures 30703 and 92701 were addressed. Results: Within the scope of this inspection, four apparent violations were identified that involved the failure to: (1) follow procedures for modification of systems that involve fissile material, (2) follow operating procedures (taping of a safety interlock), (3) perform an adequate evaluation of the potential for moderator intrusion, and (4) failure to include safety codifications in tne criticality safety analyses. 9305170033 930430 7 PDR ADOCK 0700 C

-4: DETAILS l l } 1. Persons Contacted i 1.1 Siemens Power Corocration (SPC)

• R. E. Vaughan, Manager, Safety, Security and Licensing l
• L. J. Maas, Manager, Regulatory Compliance l

+

• Denotes persons contacted by telephone on April 22, 1993, to discuss the review of the findings from the Augmented Inspection Team (AIT) inspection (Report No. 70-1257/93-02) 2.

AIT Insoection (92701) On February 9-12, 1993, a special announced AIT inspection (Report No. 70-1257/93-02)-was performad to review the circumstances and determine the cause of a February 7,1993, event involving the' inadvertent accumulation of 124 kg of low enriched uranium dioxide (U0,) powder -inside of a lexan enclosure. Several of the findings identified by the AIT appeared to be violations of NRC requirements. As a result, this inspection (70-1257/93-03) includes the review of the enforcement actions related to the AIT's findings. 2.1 Procedures License Condition No. 9 of License No. SNM-1227 authorizes the use of j licensed materials in accordance trith the statements, representations, and conditions contained in Part.1 of the licensee's application dated July 1987, and supplements dated November 12, 1987, through~ November 25, l 1992. Section 2.5 " Operating Procedures, Standards and Guides," Part I of the-e license application, states in part that the licensee' conducts its business in accordance with a system of Standard Operating Procedures, Company Standards, and Policy Guides. Section. 7.3, " Work Urders," Chapter 3.0_, " Nuclear-Criticality Safety Standards," Chapter 3 of Siemens Safety Manual EMF-30, Revision 10, requires that Work Orders (W0s) shall be reviewed before' execution by the author, and approved by a supervisor or manager in Plant i Engineering, or his delegate, or the author's' manager to assure that the l ordered work meets one or more of the following criteria: "a) The work is a replacement in-kind of previously approved j equipment. i b) Fissile material equipment / operations are ~ not involved. t i; c). The work is authorized by.an Approved ECN." i t I

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2 Section 2.1, " Scope" of procedure EMF-858 No. 1.13, " Engineering Change-l Notice (ECN)," requires that ECNs be used for additions or deletions of, j or modification to, facilities, services and equipment when work meets one or more of the following criteria: l "Affects the basic principles of operation of the manufacturing process. Directly involves fissile material. i' Affects critically or radiological safety." j The AIT concluded tiat between September 11-14, 1992, a modification was i made involving the installation of limit switches on the discharge tube l of the U0, feed h'.,pper on each of four blenders to prevent unanticipated discharges of fissile material from the confines of its normal process. system. This modification was made using a WO and not under the control l l of an ECN and is identified as an apparent violation of License Condition No. 9 (70-1257/93-03-01). l Section 3.0, " Radiological, Industrial and Fire Safety," item 3.6, of Standard Operating Procedure, EMF-22, No. P66,813, " Preparation of-U0, l Powder as Press Feed," Revision No. 5, dated September 24, 1992, stated: j " interlocks are not to be bypassed during operation of the ' powder preparation process." On February 7,1993, following the inadvertent discharge of about 124 kg l of U0, powder from the Line 3-blender's feed hopper to its respective lexan enclosure, the licensee and an NRC -inspector observed that the. limit' switches (interlocks) on the discharge tube on the feed hopper of the Line 2 and Line'3 blenders had been taped.(bypassed) to prevent the automatic shutdown of the feed system if the discharge tube should dislodge during operation. The tape on the line 3 limit switch resulted in UD, powder being discharged from the confines of its analyzed process ~; system. There had been no approval from a shift supervisor or other licensee management authorizing the taping of the switches. Taping:of l these limit switches'is a1so identified as an apparent violation of l ~ License Condition No. 9 (70-1257/93-03-02), j 2.2 Criticality Safety Analysis l Section 4.1.1, " Process Analysis (Criticality Safety Determinations)," l Part I of the license application, states in part: i "Before any operation with special nuclear material is begun or changed, it is determined that the entire process will.be subtritical-under both normal and credibic abnormal conditions, -j and within the technical requirements specified in Section 4.2. Criticality safety analyses-{CSAs] are performed on all applicable processes..."

i 3 F Section 4.1, " Purpose and Scope," Chapter 3, " Nuclear Criticality Safety Standards," of licensee's Safety Manual (EMF-30), states- "The CSA is a study of equipment / operations involving fissile material at normal conditions and at credible accident conditions to determine if the criticality safety criteria are satisfied." + l Section 4.4, " Safety Evaluation," Chapter 3, " Nuclear Criticality Safety i Standards," states in paragraph 4.4.5.3, " Moderation Limits," L "The potential of accidental moderation due to water / oil leaks, sprays, overflows, condensation, siphoning, etc., l must be carefully evaluated and controls implemented as appropriate." i The AIT concluded that as of February 12, 1993, the licensee had not l carefully evaluated the potential for moderator intrusion into the chemical conversion Line 2 unfavorable geometry powder preparation systems from nearby systems containing moderating materials. Specifically, the licensee could not provide any technical basis for the assertion that the moderating liquid systems did not pose a criticality l safety concern in the event of a spill of U0, powder into the lexan enclosures such as occurred on February 7, 1993. In addition, the l i licensee could not provide any justification that nearby moderating systems did not pose a criticality safety concern relative to the design and operations associated with the VO, powder vacuum transfer systems. l i Failure' to perform such an evaluation is identified as an apparent violation of License Condition No. 9 (70-1257/93-03-03). l By letter dated April 22, 1993, the licensee fulfilled its commitment, l restated in HRC's Confirmatory Action Letter dated February 12, 1993, to i perform a technical evaluation of the potential for intrusion of moderating. liquids into the Conversion Line 2 00, blending and powder i preparation systems. Regarding this AIT concern, the licensee also - provided Region V a copy of their evaluation for review. l Section 2.1, Equipment Operation and Description," of the licensee's evaluation, " Conversion Line-2 Powder Preparation Systems Moderator Intrusion Analysis,

• EMF-93-068(P), issued April-8,1993, states that the feeder design allows the discharge tube to be pulled away from the i

feed hopper if the system becomes plugged with uranium powder. This section of the evaluation also states that a limit on the hopper will shut off the feeder to limit quantity of powder spilled inside of the hood (lexan enclosure). Section 2.2, " Moderator _ Intrusion Into the Vicinity of the Blending and j powder Preparation Equipment," states that during accident conditions, three methods exist for moderator intrusion into the vicinity of the blender and powder preparation equipment-from nearby liquid moderating systems: (1) liquid spray, (2) liquid floods, _and (3) liquid' carried in J the air. This section of the evaluation-also-states that should any M these tccidents occur, the blending tnd powder preparation sysic: e l 'l

c-n N i 4 y 4 a remains to keep moderators out of the U0,. Conversely, if an accident occurs that allows U0, powder to leak from the blending and powder - preparation system, one primary moderation control is lost, leaving the integrity of nearby liquid containing systems to keep the powder and l moderators separated. ~e Based on the review of the licensee's evaluation, the NRC staff concluded that the limit switches installed on the discharge tube of the feed hoppers in September 1992, were necessary controls to prevent j and/or mitigate the consequences of an accident (the discharge of UD, q As stated in the powder from the confines of its process system). 22, 1993, the licensee considers the licensee's letter dated April i subject powder feeder limit switches as part of the criticality' controls l and will incorporate the switches into the applicable CSAs. Appendix 2, " Guidelines for Requesting CSA for Plant Design Changes and l the Addition of New Equipment, " Chapter 3, Nuclear Criticality Safety l Standards," of the licensee's Safety Manual (EMF-30) states in part- ...As the manufacturing process is improved and refined, equipment in the plant is changed and/or new equipment is added. Each change or addition of equipment requires a new CSA...." The AIT disclosed that as of February 12, 1993, applicable CSAs.had not t been amended to incorporate the limit switches -(equipment) that~ were installed on the feed system of each of the four blenders in September 1992, to prevent discharges of low enriched UO, powder.from the. confines Failure to include-the limit switches in the of the process system. applicable CSAs and lower tier documents is identified as an apparent violation of License Condition No. 9 (70-1257/93-03-04). ) 3.0 Inspection Exit'Meetina (30703) f The inspector and discussed the scope and findings of the inspection j were summarized with the licensee representatives, denoted in Section I, i by telephone at the conclusion of the inspection on April 22, 1993. l i The iicensee was informed of the apparent violations described-in j described this report. t t i I I i

EliCLOSURE 2 I, f,. . r' 30762 Federal Register / Vol 57. No.133 / Triday, July 10, 1992 / Notices /j' AooRt s:E*: Send cornrnents to:ne Secetary of the Commission.U.S. Nuclear Regulatory Comm!ssion. Washig1on. DC 20555. ATIN: Docketing and Service Branch. Hand deliver comr ents to: One Wh] . Flint North.11555 Rockville Pike. - Rockville.MD between 7:45 a.m. to 4:1t i p.m Federal workdays. ! Copies of comments may be examine I at the NRC Public Document Room. 21: t L Street. NW. (Iower level). Washington. DC FoR FURTHER INFORalADON CONTACT: James ljebennan. Director. Office of ~ DJorcement.U.S. Nuclear Regulatory Commission. We shington. DC 20555 (355M-2741).

• SUPPciWENTARY 8HFORnLATION:

Baciground ne NRC's current policy on enforcement conferences is addressed : ~ Section V of the latest revision to the

• **Ceneral Staternent of Policy and Procedure for DJortement Actions."

(DJorcement Policy)10 CFR part 2

. appendix C that was published on February 18.1W2 (57 FR 5791). Ee D.forcement Policy states that. erJorcement conferraces will not normally be open to the public." . However, the Cormtission has decided . to implement a trial program to determine whether to maintain the i current policy with regard to enforcement conferences or to adopt a [Two-Year TrW Program for r.ew policy that would allow most i . Conducting Open Enforcement enforcement conferences to be open to Confscences; Pol;cy Statement ettendance by allmembers of the publi A ctacr. Nuclear Regul *vy POUCT St'temet Com=ir sion. pogig;cn ' Acnor pobcy stateme ne NRC is implementing a two-year EUMMARr: ne Nut! car Regulatory vial pmgram to aHow pubhc observation of selected enforcement Commission (NRC) is inuing this policy statement on the implementation of a pr gram er.d determ,C will ruon c ferntes. He M me whether to two year trial pregram to allcw selected enfo cement conferences to be o;>en to establish a permanent pohey for attendance by ell members of the ccnducting open crJorcement geners! public.nl: policy statement corJerences based on en essessment oi. describes the twci-yect t-ial prog:em the following c-itena: And informs the public of how to tet (1) Whether the fact that the irformation on upcoming open conference was open impacted the enforcement cerJerences. NRC's ability to conduct a meaningful

1. E f *"I Ih' i

D Art s:Ris trial program is effective on e rcement program: July 10.1W2. while comments on the . (2) Wheder the open conference

regram a t being received. Submit cracted the licenree,a pert

cipction m, commer:ts on or before the completion of the triel pt:psm scheculed for July ex conference:

% 11.1W2. Comments received after 0.is (3) Whether the NRC expended e date will be considered ifit Is prectict.1 tigmficant r. count of resourceo in to do so. but the Commitrion is able to mcking the corJerence public; r nd a nure cor.siderstion only for comment: 8)ne extent of public interes t in 4 ecened cn er befcre th:r de te. e ning the enforcement cer 'erence.

t ~ Tde s} Registez / Vol 57. No. 233 ey. Jdy 10.1962 / Notices 30?E3 s s i 'L CriteFia Tor Seleef.cg 0 pen three categories oflicensees will be sub}ect io personnsl aceening.that l Edcrcemect Codr*eus commerdal operaling teaclors.. signs, banners, posters,etc r oflarger Enforcement coderences will not be hospitals, and other hcensees, which than W be perm!!!cd. and that. f open to the pubhcif the'erforcernent will consist of the remainir.g types of dis uptive penons esy be removed. action beiq comtemplsted-Lcensees. Each regione' office win contmee to (1) Would be tsien spinst an D. An:mac!rg Open Enforcement enduct de edommmt confencs [ in6ddual, or if the acta thogh not Coderences pmceedings in aecordsnce with ngional taken against an inindval. tu ns on praetice. The erJorcement conference ^ * " " " " ' "*e that an wiH continue to be a meeting between whether an in6vidualhas comrdtted d erJ tcement conference wtD be open to the NRC and the licensee. While the () y es signibat penoanel pubbe observatim. the NRC wiD oraDY enforcement conference is open for failures where the NEChas re vested a ufy the licensee that the edorcemet public observation,it is not open for , ( e that thein6vidualls)i:dved e cederence mil be open to pubb.e public participation. present et the codererce; bservaUn as part of the esency,a trial Penons attending open erJorcercent 3 y (3)is based on the inicp of an NRC FmSNm

• 8' t CE"E 8 C PY conferences are reminded that (1) the 1

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• 8 i "UC' 8

28 Of0cc ofInvestigations (OI) report or apparut violeums ascuned at open r the pmgram. Licmsees mH crJorcement confertnces are subject to i .t mate the number d part,14 esled to (4) Invokes safeguards idormation. dpants it further review and may be sbbject to j privacy Actidormation.orother infor=ation which could be cor.sidered E change prior to sty resuldag so thet the NRC can schedule an edorcement aetion and (2) the appmpriately saed codernce m.m. Edottement corJettaces invoMng statements of views or expressions of He NRC will also noufy appmpriate opinion made by NRC employees at [ ,,g g,g g g g ",[co je pe en rcement conferences or the - overexposuns wiD be open assuming e e been the conference can be conducted c lack thereof, are not intended to without isc!csing the exposed 'dd".d and that H is open to publa. represent final determlnstions or beliefs. In6viduaTs name.In editior' C intends to announce open E" I ederccment coderences wClnot be open to the public if the coderence will erJortement conferencea to the public I' ' #8"'I ' "

• F""

i be conducted by telephone or the normally at leest 10 working ds)s in advance of the enforcement conference 9Y' conference will be conducted at a throgh the folicw',cg mechanisma: pmn e an opportunky to

I' relatively ses!!!icenstt's facihty.

(1) Notices posled in the public ' ' 'M I RneDy, with the approvalof the Document Roo~

1. #'E""

l_ Executive Di ector for Opentions, (2)ToU-free 12ephoce messages: and shequm% fomaM to b edorcement coderences whot be (3) ToU. free electronic bulletm board betor oW Mce pdocement for open to the pubbein spedalcases review and considentson. me:3egeg. where good caue las been shown after pending establishment of the toU. free Dated at Rocivius. M3, this nh day of JJy I balancing the beoefit of pvEc message systems, the public mey call W-observation against the poterialimpaet (41) 444732 to obtain a recording of For the Ecleat Reguhtwy Coce.Jsskc

. i e

on the agency's edorcemect action in a vpcoming open enforcement Sanme! J. OJti, ,!i puticular cue. corderences.The NRC willissue encther f.ecrescryof Ac Coeniula ,I The NRC wiD strive to conduct epen Federal Regis ter notice afler the foli. free p m,c c te.m rced u us a.m.) enforcement cedertnces durig the message systems are established. two yeat trialpmram m acoordance To easist the NRC in rnsking . em m. with the following three pals: appropriete anangements to support (1) Apprownstely5 percent of aD public observetion of edorcement i eligible edorcement codensees conferences, individuals intertsted in conducted by the NRC will be epen for attending a pardcular erJorcement pubbe ob$en at.on; coderence should notify the individual (2) At least one open edercer.er.t identified in the rnee tig notice corderente will be corducted in ea ch of unouncing the open enforcement the regional of? ices; and corJerence no la ter then five business (3) Open er.! : cement coderences days prior to the enforcement wiU be conducted with a ttriety cf the codrrnce. tpes c!bcensees. To avoid poterSalbies in the Menduct d O;>en Momemmt i e election process and to ! tempt to me et Cederaces the three goals stated abeve.every in eccordance with current practice, fourth eli ible enfonement coderence cdorcemmt corderences will continte. E involving one of three catepr:<s c! to normd!y be held at the NRC redonel. licensees will normtUy be open te the offices.Memben of the public wi:1 be i j public during the t selpnpar' s.Uned access to the NRC regiend However,in cues where then Is te of? ices to a ttend open enfomernent ongoing edjudicato y pmcee6q with coderences in occordence with the ene or more ir.tenenor Moreement standerc Operstir g procedu+e s Tor 4 conierences invcks issues nhied to previing Security Su; port Ter NTC tie a tb)ect matier d the e

tdjudtztion mey else be c;goir; !!wims And Meetings"puWhod md Tcr Nov:mber L 19M (M 17. WM). Ren t

the prpen: cf this t-itl;gttr, *.h: Twdurer pr:: vide thct s Lttu r ry lc j l}}