ML20045C608
ML20045C608 | |
Person / Time | |
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Site: | Framatome ANP Richland |
Issue date: | 06/07/1993 |
From: | Bocanegra R, Hooker C, Reese J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
To: | |
Shared Package | |
ML20045C598 | List: |
References | |
70-1257-93-03, 70-1257-93-3, NUDOCS 9306240067 | |
Download: ML20045C608 (14) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGION V Report No. 70-1257/93-03 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 12-16, 1993 6[7[T3 Inspectors:
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Dats Signed C. A. Hooker, Hjel Facilities inspector Tl %-
4,hs R. Bocanegra, Rabiation Specialist Date' Signed Wh Sh 3
Approved by:
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Date' Signed James H. Reese, Chief Facilities Radiological Protection Branch Summary:
Areas Inspected: This was a routine unannounced inspection of open items, management / organization, training / qualification, transportation of radioactive materials, and waste generator requirements.
Inspection procedures 30703, 88005, 88010, 84850, 86740, 92701, and 92702 were addressed.
Results: Within the scope of this inspection, three violations were identified that involved the failure to (1) provide certification exams to health physics technicians (Section 3.c), (2) implement a quality control program that included audits and management review of audits for waste shipments (Section 4.a), and (3) maintain records of surveys of exclusive use transport vehicles (Section 5.b).
Strengths were noted in (1) the addition of a new waste management department (Section 2.c), (2) root cause analysis and conduct of operations training (Section 2.d), and (3) the licensee's development of a new operator qualification and certification program (Section 3.a).
One unresolved item regarding surveys of each package of new fuel shipments (Section 5.a) was identified. One Inspection Followup Item (IFI) was identified regarding radwaste classification.
9306240067 930607 PDR ADOCK 07001257 C
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t DETAILS 1.
Persons Contacted 1.1 Siemens Power Corporation (SPC)
B. N. Femreite, Plant Manager
- R. E. Vaughan, Manager, Safety, Security and Licensing
- R. L. Feuerbacher, Manager, Plant Operations
- M. K. Valentine, Manager, Manufacturing. Engineering t
- L. J. Maas, Manager, Regulatory Compliance
- J. B. Edgar, Staff Engineer, Licensing
- D. J. Hill, Manager, Quality Control S. S. Koegler, Manager, Waste Management Engineering
- J. A, Shurts, Manager Materials and Scheduling
- J. W. Helton, Manager Plant Engineering
- L. D. Weaver, Supervisor, Traffic and Warehousing J. H. Phillips, General Supervisor, Chemical Operations
- T. C. Probasco, Safety Supervisor
- C. D. Manning, Criticality Safety Specialist
- E. L. Foster, Supervisor, Radiological Safety
- Denotes those attending the open exit interview on April 16, 1993.
In addition to the individuals noted above, the inspectors met and held discussions with other members of the licensee's staff.
In the following sections of this report, the siis lar use of the word a
" inspector" indicates that only one inspector was 1 volved in the specific area and the plural use indicates that both inspectors shared involvement in the specific area.
2.
Management and Organization (88005)
This area was reviewed to determine the licensee's compliance _with the requirements of the License Conditions, licensee procedures and the effectiveness of management controls of licensed activities.
a.
Changes During the past year several changes relative to the name of the facility, onsite organizational structure and staffing have occurred. On July 10, 1992, the licensee's name was changed from Siemens Nuclear Power Corporation to Siemens Power Corporation (SPC).
In October 1992, SPC and Siemens Power Generation Group in Germany integrated their worldwide nuclear fuel' and related services. Along with this integration, the Vice President of Richland Operations also assumed the overall coordination responsibility for fuel manuf acturing facilities located in Germany under the title of Vice President, Manufacturing. The previous Manger of Plant Engineering. assumed the direct responsibilities of SPC in Richland Washington under the title of
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2-Plant Manager-and reports directly to the Vice President, Manufacturing.
The inspector noted that the licensee had added a new Waste Management Engineering group to its Manufacturing Engineering department. This new group currently consisted of a manager and one assigned engineer, According to the manager, two additional engineers and a specialist are planned to be added to his staff.
This new group will review all onsite activities to minimize waste and improve handling methods for all liquid and solid wastes (hazardous, chemical and radioactive) generated onsite.
Long term plans include decommissioning of the liquid waste lagoons. The licensee's upcoming changes to convert from its current chemical conversion processes to a dry conversion process will eliminate the need for the lagoons. As described in previous NRC inspection reports, the licensee has not implemented an effective program to minimize waste. This new program should be an asset to licensed activities.
b.
Organization and Staffing Due to the planned retirement of the Manager Safety, Security, and Licensing (SS&L), in September 1992, an individual was hired from outside of the company to fill this position. Due to the retirement of the previous Manger, Regulatory Compliance in April 1992, this position was also filled by an individual from outside of the company.
Previously, the Safety Supervisor (SS) who reports to the Manager, SS&L provided direct oversight of the Criticality Safety Component (CSC), the Health Physics (HP)
Component, a Radiation Safety Specialist (RSP), a HP Records specialist, and the HP technicians. The SS also performs all the i
functicas for Industrial Safety.
In the fall of 1992, the 1
l previous HPS was promoted to a new position of Radiological Safety Supervisor to alleviate the SS's direct supervisory responsibility i
of the HP technicians. One of the senior HP technician was promoted to a Radiation Safety Specialist and reports to the Radiological Safety Supervisor.
Regarding staffing in the SS&L department, in September 1992, the licensee added an additional Criticality Safety Specialist (CSS).
This individual had previously held this position for several years and had taken an assignment in another portion of the organization. Although this individual has recently terminated employment with SPC, he continues to provide assistance via contracted services. The licensee also utilizes two additional contracted qualified CSSs who are assisting in the licensee's Criticality Safety Analysis Update Program. The licensee currently has two additional open positions in criticality safety 1
and is actively pursuing filling these positions. The licensee maintains one professional HP on their staff.
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During the past year, the licensee has increased its permanent HP technician staff from 11 to 18 individuals.
In addition to the 18 permanent staff, three college students provide services as helpers.
The additional staffing included a mix of trainees i
through senior and/or specialist positions.
Although their duties have not changed, the licensee has' changed the title of the RP technicians to Health and Safety. technicians (H&STs). This change-was to reflect the technicians involvement in other safety e
programs' not related to radioactive materials, Health and Safety Council (H&SC) c.
There had been no changes in the functions and responsibilities of the H&SC.
Minutes of the H&SC meetings for the past six months were reviewed. The inspector noted that H&CS meetings included the review of safety programs including; industrial safety, the status of bioassay and air sampling programs for the previous month. The H&SC continues to be an effective mechanism for informing management of safety issues. The council was not delineated the authority to review and approve procedures, operating plans or design changes. The H&SC minutes included copies of presentations made by the safety disciplines, the results of the monthly RP and criticality safety audits, the monthly housekeeping audit, results of Incident Review Boards (IRB), Incident Investigation Boards (IIB), and reports of EP exercises and drills. The H&SC also tracked the action items from NRC inspections, audits and IRBs. The tracking system also delineated the persons assigned the responsibility for closure of each item.
H&SC council met monthly and its membership was consistent with the management personnel described in Section 2.3.1, Part I of the license application.
d.
Managements Commitment to Program Improvement l
The inspector noted that approximately 50 key onsite personnel that included mangers, engineers, and supervisors were being provided training on root cause " TAP ROOT" incident investigation training.
This training consisted of a two day off-sitt workshop conducted by contracted experts in root cause analysis.
This training was scheduled to be completed on April 16, 1993.
In addition, about 200 personnel were being trained on Conduct of Operations (C00). The C00 training consisted of a two day off-site workshop conducted by contracted experts.
The C00 training was provided to each department from management through senior technician levels.
The C00 consisted of a philosophic approach to safety.
The inspector noted that in addition to the scheduled subjects, the workshops included a review of the General Electric, Wilmington, North Carolina, May 29, 1991, event (NUREG-1450) and selected significant events at SPC.
The above training programs were indicative of managements commitment to safety and improving operational performance.
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The licensee's performance in this area appeared adequate'and their programs appeared capable of accomplishing its safety objectives.
The root cause and C00 workshops were noted as program strengths.
No violations or deviations were identified.
3.
Operator Training / Retraining (88010)
This area was reviewed to determine the licensee's compliance with the requirements of the License Conditions, licensee procedures and 10 CFR Part 19. The inspector discussed the licensee's training programs with cognizant licensee representatives and reviewed selected licensee procedures, training lesson plans, and employee training records, a.
General Emplo_yee Training The inspector noted that new employees received new employee indoctrination training which included the basics of radiation safety, criticality safety, industrial safety, emergencies, and security and safeguards.
Personnel assigned to work with radioactive and fissile materials received specific additional formal training prior to working without an escort.
Contractor and/or temporary workers working onsite in non-radioactive materials areas without an escort were also provided training to the relative site hazards and emergency alarms.
Personnel were provided annual refresher training according to their assigned work areas.
Formal classroom training consisted of classroom lectures, slides and videos. Upon completion of the formal classroom training, each individual was tested as to their knowledge of the material presented.
b.
Operator Traininq Operator training and qualification, was discussed with cognizant supervisory staff members.
Previously, qualification of operators was accomplished by on-the-job training (0JT) for their assigned work station.
Subsequent to the initial new employee radiation safety and criticality safety training, each new operator typically spent their first two days in the office areas to become familiar with SPC's administrative procedures and plant staff before being assigned to a qualified operator.
New operators are under constant watch by a qualified person during the initial phases of their OJT. Qualification was based on a workers ability to perform an assigned task without errors, judgement of the qualified person who was assigned to observe their work and supervisor's observations.
Levels of qualification ranged from Technician levels 1 (trainee) through 4, and Specialist. Normally two hours per 3 weeks were devoted to some type of formal training that consisted of reading assignments, commercial videos-and training manuals, and home made videos.
The inspector noted that the licensee was in the process of implementing a newly-developed training and qualification program 1
5 for operators. Due to the complexity and the number of individual systems in the chemical operations group, one individual has been assigned solely to training and procedure updating.
The new training and qualification program consisted of defining all of the work stations and the procedures utilized at each work station. The procedures also include general facility procedures such as EMF-30, "SPC Safety Manual", general operating ~ safety procedures, applicable criticality safety specifications, and radiation work control procedures. Qualification included written tests on procedures, verification of demonstrated skills rel ated to current procedures and subsequent revisions.
Structured formal training will be provided on each procedure. The development of the new training and qualification program was noted as a major improvement from the licensee' previous program.
During facility tours, the inspector observed operators performing their duties and held discussions with several operators. The inspector did not identify any cause to suspect these individuals were not qualified to perform the task they were performing.
c.
H&ST Trainino and Qualification The licensee's H&STs are ranked in experience and qualification from trainee, Level I through Level III, Senior, and Specialist.
Although the licensee's training and qualification program for H&STs was noted as not being fully developed or placed in the licensee's controlled document program, a document, " Radiation Monitor Training & Certification Program," was being used as a guide for the licensee's current program and will be placed in the licensee's controlled document / procedure program after its final approval.
Based on the review of the licensee's records and discussions with the SS and the Radiological Protection Supervisor, the inspector made the following observations:
1)
License Condition No. 9 of License No. SNM-1227 authorizes the use of licensed materials in accordance with the statements, representations, and conditions contained in Part I of the licensee's application dated July 1987, and supplements dated November 12, 1987, through November 25, 1992.
Section 2.4.3, " Health Physics Technician Training," Part I of the license application states:
" Health Physics Technicians [H&STs] are given special training related to their radiation protection assignment.
Previous training is accepted if considered equivalent to the Advanced Nuclear Fuels
[SPC] training program.
Despite previous acceptable training, the Health Physics Technicians are required
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to become proficient in Advanced Nuclear Fuels radiation protection and criticality safety programs, specifications, procedures, and routines, as-demonstrated by successfully passing a Advanced Nuclear Fuels certification. examination within six months after employment as a Health Physics Technician.
In addition, refresher training is provided to all Health Physics Technicians annually."
The license does not define any technician grade level associated with the certification exam.
The inspector noted that Section 6.5, " Health Physics Technician Training," of the licensee's Safety Manual (EMF-30) states the same requirements as Section 2.4.3., Part I, of the license application, but delineates that the certification exam is taken within six months after attaining the " Radiation Monitor III l evel. "
The licensee's training program guide, " Radiation Monitor Training & Certification Program," delineates that persons hired in as a Level II or Level III technicians complete the certification program within three months.
2)
The inspector noted that as of April 16, 1993, that no qualification certification exams had been given to:
One individual hired as a Senior technician on July 25, 1990, one individual who was promoted to a Level III technician on July 29, 1992, one individual hired as a Level III technician on September 1, 1992, j
one individual hired as a Senior technician on September 8, 1992, and one individual hired as a Senior technician on September 22, 1992.
i The inspector also noted that the licensee's training guide specified the use of practical factors and qualification sign-off cards to demonstrate that the H&STs were qualified for tasks they were performing. However, no such records were maintained by the licensee.
Inconsistencies in the i
licensee's program relative to the time interval (three months - six months) for the certification exams were discussed with cognizant licensee representatives.
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7 The inspector recognized that several of the above individuals were only outside of the six month. certification requirements of Section 2.4.3 of the license application by one month.
However, based on the status of.the licensee's training program, there was no assurance that these individuals would have been given certification exams in the near future. Since all of the above individuals were performing tasks of qualified technicians, failure to provide them with certification examinations within six months of being hired and/or after achieving a qualified-position was identified as a violation of License Condition-No. 9 (70-1257/93-03-01).
4.
Radioac+ive Waste Management (84850)
The inspector reviewed portions of the plant's radioactive waste management program to determine whether the licensee had established and maintained adequate management-controlled procedures and quality assurance to reasonably assure compliance with 10 CFR 20.311,10 CFR 61, and license conditions. During the inspection, the inspector reviewed pertinent procedures, records, interviewed key personnel, and toured the facilities.
a.
Quality Control Program The requirements found in Part 20.311 were designed to control-transfers of radioactive waste intended for disposal at a land disposal facility. The inspector examined a sampling of radioactive waste disposal records for waste shipped from the site from December 22 to December 29, 1992. The waste shipment numbers included H-166 through H-170. Some minor discrepancies were noted on one of the records examined,_but appeared to be an isolated case.
The inspector noted to the licensee that regulations required that the licensee conduct a Quality Control (QC) program when shipping to a land disposal facility.
Specifically,10 CFR 20.311(d) states that any generating licensee who transfers radioactive waste to a land disposal facility shall comply with the requirements in paragraphs (d)(1) through (d)(8).
Paragraph (d)(3) states that a licensee shall conduct a quality control program to assure compliance with 10 CFR 61.55, " Waste Classification," and 10 CFR 61.56, " Waste Characteristics."
Additionally, the licensee's program must include management evaluation of audits.
Contrary to the above requirement, the licensee made five radioactive waste shipments to a land disposal facility on December 22 through December 29, 1992, and did not comply with 10 CFR 20.311(d)(3).
Specifically, as of April 16, 1993, the licensee did not have procedures in place to conduct the quality control program referenced in 10 CFR 20.311(d)(3), and
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consequently did not perform or document the required quality control audits. This was identified as a violation (70-1257/93-03-02).
b, Waste Classification Acceptable procedures for waste classification were communicated to Commission licensees in the form of a Branch Technical Position (BTP) on May 11, 1983. The document, titled " Low-Level Waste Licensing Branch Technical Position on Radioactive Waste Classification," stated that all licensees must carry ~out a compliance program to assure proper classification of radioactive waste.
The BTP presented a three-tier approach for implementing the waste classification system.
Elements of the three-tier method included:
Periodic analysis for all nuclides listed in Table 1 of 10 CFR Part 61.55.
Gamma spectroscopy of certain nuclides from which waste classification nuclides were correlated.
Gross radioactivity measurements which correlated activity e
levels of wastes from similar batches to the gamma spectroscopy measurements.
The licensee's method included using the 186 kev photo peak of U-235 to quantify radioactivity in the waste, and then correlating the U-235 activity to U-234, and U-238.
The measurements were performed using a sodium iodide detector.
This approach was similar to the third method cited in the BTP; however, the BTP also stated that confirmatory reanalysis of the correlation factors should be performed on at least a biennial basis. The licensee stated that a reanalysis was not performed and that due to the nature of their 10 CFR Part 70 license, ~ the facility only generated Class A waste. This issue will be further reviewed during a subsequent inspection (70-1257/93-03-03).
i Based on the results of the review, the inspector concluded that, except as noted above, the licensee's radioactive waste management program appeared to meet its safety objective.
One violation was identified.
5.
Transportation Activities (86740)
The inspector examined transportation activities to determine if the 1
licensee had established and maintained an effective management-controlled program to ensure radiological and nuclear safety in the receipt, packaging, and delivery for shipping of licensed radioactive materi al.
Transportation activities are regulated by the NRC and the i
9 Department of Transportation (DOT). The requirements are found in 10 CFR Parts 20 and 71 (NRC), and 49 CFR Parts 171-177 (DOT).
i a.
Package Surveys 10 CFR 71.5(a) requires that a licensee who transports licensed material outside of the confines of its plant or other place of use, or who delivers licensed material to a carrier for transport, comply with the applicable requirements of the regulations appropriate to the mode of transport of the Department of Transportation in 49 CFR Parts 170 through 189.
49 CFR 173.441 specifies radiation level limitations for each package of radioactive materials offered for transportation.
49 CFR 173.475 requires, in part, that before each shipment of any 4
radioactive materials package, the shipper ensure by examination or appropriate test that the external radiation and contamination levels are within the allowable limits specified in 49 CFR Parts 171 through 177.
The inspector reviewed selected records of low enriched fuel shipments and noted that the licensee performed direct radiation surveys on only one package per shipment consisting of identical packages. This practice was in accordance with plant procedures, and licensee representatives stated that the rest of the packages were not required to be surveyed because they contained the same level of U-235 enrichment and the packaging was of identical design in all respects.
Licensee representatives also stated that they believed they were in compliance with the requirements of both 49 CFR 173.441 and 49 CFR 173.475. The inspector discussed details of the licensee's survey procedure with Division of Safeguards and Transportation management of the NRC's Office of Nuclear Material Safety and Safeguards. The discussions also included the licensee's position that they believed they were in compliance with the regulations. This issue will be left as an unresolved item pending further NRC review. (70-1257/93-03-04).
b.
Transport Vehicle Surveys Several shipping records reviewed by the inspector clearly showed that the required transport vehicle surveys were performed.
For example, Shipment Nos. H-167 dated December 22, 1992, and H-170 dated April 13, 1993, document radiation readings at 2 meters from the vehicle and "in cab" surveys.
The inspector also noted that other shipping records did not show documentation that the transport vehicle was surveyed prior to leaving the site to assure compliance with radiation level limitations. A licensee representative stated that although the surveys had been performed by a Health and Safety Technician (H&ST), the documentation was inadequate. The inspector reviewed
10 the H&ST's logbook and noted entries that stated that trucks had been surveyed, but the results of these surveys were not documented as required by 10 CFR 71.91(a)(10). The shipments in question included the following:
Shipment No. PAL-0:93005 8 new fuel assemblies Shipping No. PAL-0:93002 e
12 new fuel assemblies Shipping No. PAL-0:93006 e
8 new fuel assemblies 10 CFR 71.87(j) requires that prior to each shipment of licensed material, the licensee shall ensure that external radiation levels around the package and around the vehicle, if applicable, will not exceed the limits specified in 10 CFR 71.47 at any time during transportation.
10 CFR 71.91(a)(10) requires each licensee maintain for a period of three years after shipment a record of each shipment of licensed material showing the results of the determinations required by 10 CFR 71.87 (i.e. vehicle surveys).
Failure to document and maintain records of transport vehicle direct radiation surveys is a violation of 10 CFR 71.91 (70-1257/93-03-05).
Based on review of the sampling of transportation activities, the inspector determined that except for the violation identified, the licensee's transportation activities appeared to be in compliance with NRC and DOT regulations.
One violation and one unresolved item were identified.
6.
Followup - Licensee Action on Previous Inspection Findings Section 4.0 of NRC Inspection Report No. 70-1257/92-09 described the NRC's request for the licensee to supplement its' response (letter dated November 20,1992) to the NRC's Notice of Violation and Proposed Imposition of Civil Penalty forwarded to SPC by letter dated October 22, 1992, with the details of their Criticality Safety Analysis Update Program (CSAUP).
By letter dated December 30, 1992, the licensee provided the Region V office with the details of its CSAUP. A copy of this CSAUP was also provided to the NRC Director, Office of Enforcement.
The adequacy and effectiveness of the licensee's implementation of this program will be reviewed in future inspections and is considered as an inspector followup item (70-1257/93-03-07).
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11 a.
Cited Violations (92702)
The inspector verified the corrective actions taken to correct the violation and those to prevent recurrence of the following violations as stated in the licensee's timely response to each matter:
70-1257/92-06-01 (Closed) - Failure to Incorporate the Double Contingency Policy in CSAs The inspector verified that the licensee had revised the l
applicable CSAs, CSSs and operating procedures to include process control parameters (feed flow rate and temperature control) to assure that the licensee's calciners produced UO, powder within the specified moisture limits. The inspector also verified that the operating personnel were effectively implementing the criticality controls specified in the operating procedures.
Long term corrective actions relative to assuring that controls i
necessary to implement the double contingency policy are adequately described in all CSAs, have been incorporated into the 1
licensee's CSA Update Program.
1 70-1257/92-06-02 (Closed) - Failure to Assure Safety Controls Described in CSAs were also Specified in CSSs The inspector verified that the licensee' had reestablished the -
supervisory key control for the discharge valves on slab hoppers in the applicable CSSs and operating procedure.
70-1257/92-06-03 (Closed) - Failure to Identify the Source CSAs in CSSs The inspector verified that the licensee had revised all of the CSSs to indicate the source CSAs.
70-1257/92-06-04 (Closed) - Failure of the Shift Supervisor to Maintain Control of Keys for Locks on Slab Hopper Discharge Valves The inspector verified that the Shift Supervisors had physical control of the keys for locks on slab hopper discharge valves as stated in the applicable CSAs, CSS, and operating procedure.
70-1257/92-06-05 (Closed) - Failure to Verify Moisture Sample Results The inspector verified that the licensee had effectively implemented human factor controls and made administrative changes relative to the operating procedures and revised moisture sample verification forms to prevent recurrence of this problem.
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m 12 70-1257/92-06-06 (Closed) - Failure to Follow Reporting Reauirements The inspector noted that the licensee was effectively implementing it new operating procedure," Abnormal Event Reporting," this new procedure is also described in NRC Inspection Report No. 70-1257/92-08.
70-1257/92-08-01 (Closed) - Failure to Analyze Credible Accidents The inspector verified that the licensee had revised the applicable CSAs to include additional accident scenarios and modified the effected systems to prevent recurrence of flooding the off-gas from overflows of fuel processing tanks.
Long term corrective actions relative to the assurance that credible accidents have been analyzed in all CSAs have been incorporated into the licensee's CSA Update Program.
b.
Inspector Followup Items (92701) 1 70-1257/91-04-03 (Closed) - Mechanism for Trackino IIB'and-IRB Actions The inspector verified that the licensee had developed and adequately implemented an effective corrective action / commitment i
tracking system. This system included corrective i
actions / commitments related to licensee identified items and those i
associated with regulatory agencies.
70-1257/91-04-16 (Closed) - Licensee's Closure of Findinq identified in their Internal Biennial Management Review of the Criticality Safety Program The Inspector verified that the licensee had adequately addressed i
and formally responded to all of findings delineated in their 1991 Criticality Safety Management System Appraisal report.
70-1257/91-04-34 (Closed) - Inadeauate Review of Precursor Events i
i The inspector verified that the licensee's enhancement of its root i
cause analysis and newly implementation of forming causal factors groups to evaluate generic implications of events adequately addresses this concern.
70-1257/92-02-01 (Closed) - Review of Licensee's Evaluation of Moderation Controls j
This item is being closed because it is generit to item 70-1257/93-02-01 described in the AIT report (70-1257/93-02).
The inspector considered the following items closed since they will be addressed in the licensee's CSA Update Program, which is V
1 13 under separate NRC review as item No. 70-1257/93-03-07 discussed-above.
70-1257/91-04 Surveillar.ce for Criticality Safety Engineering Controls 70-1257/91-04 Documentation of the technical. basis for assumptions and conditions in CSAs 70-1257/91-04 Identify Design Features and Process Systems Important to Safety in CSAs.
70-1257/91-04 Include Criticality Safety Limits in Operating Procedures 70-1257/91-04 Document Validation of Criticality Codes Used 70-1257/92-04 Evaluate the Potential Buildup of Low o
Enriched Uranium in Non-favorable Geometry Exhaust Systems 7.
Inspection Exit Meetina (30703)
The inspectors met with the licensee representatives, denoted in Section 1, at the conclusion of the onsite inspection on April 16, 1993. The scope and findings of the inspection were summarized.
The licensee was informed of the violations described in described in Sections 3, 4, and 5 of this report.
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